Metal Finishing Guide Book

2011-2012 Surface Finishing Guidebook

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Page 526 of 707

operations and processes, and improving waste minimization and resource recovery techniques have become prerequisite to achieving compliance. Implementation of the basic BPT and BAT technologies is often inadequate to meet frequently unreasonable, and usually unnecessary, local limits set far below the technology-based standards. Increasingly, local limitations are being based on mathematical models using faulty software programs and arbitrary POTW effluent standards, rather than good science and environmental ncessity. Although federal regulations have remained unchanged since their 1984 effective date, the U.S. EPA proposes to get back into the act of tightening pre- treatment standards for metal finishers. In late 1994, the U.S. EPA proposed draft- ing Metal Products and Machinery (MP&M) Effluent Guidelines, which would impose specific concentration limitations on many metal fabricating and machine shops presently not covered under any federal industrial pretreatment category. U.S. EPA estimates the regulation would bring another 20,000 companies nationwide under the pretreatment requirement umbrella. The proposal, how- ever, includes the prospect of shifting all metal finishers and electroplaters to the MP&M Guidelines, thus eliminating the current regulations. The MP&M limits are expected to be developed from reassessing technology-based pollutant con- centrations. This could effectively reduce federal pretreatment limitations by 50- 90%, depending on the pollutant, as current effluent quality among metal fin- ishers is much lower, for many reasons, than in the 1970s when the original BPTs/BATs were established. Although metal finishing and POTW effluent quality have continued to improve annually, the incidence of enforcement actions and amounts of the resul- tant penalties have increased. Many municipalities have adopted "automatic" penalties for any discharge violation, and have modified pretreatment ordi- nances to make it easier to collect penalties. The U.S. EPA was required to draft the MP&M Guidelines in March, 1995. As of the date of this writing, the regulation has not been published. If the regula- tion is drafted per the original proposal, future regulatory enforcement will be more likely to increase. Improved treatment system operation and performance will become an even greater economic necessity of the metal finisher. Furthermore, the treatment focus will further shift from conventional phys- ical-chemical treatment to the more advanced, more expensive treatment meth- Filter Presses, Clarifiers, Sludge Dryers, Waste Treatment Systems, Evaporators, Bags, Cloth and Media We also buy and sell used equipment Ph: 216-881-7900 • Fax: 216-881-8950 Email: 525

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