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MP&M P2 Compliance

Organization(s) Narragansett Bay Commission
Project Description The Metal Products and Machinery (MP&M) rule published in the January 3, 2001 Federal Register contains proposed wastewater discharge limits for the metal finishing industry that has the potential to close the doors on many small to medium-sized job shops. As part of the rule-making process, however, EPA did consider the benefits of pollution prevention and has developed a list of P2 alternatives that could be used in lieu of the proposed strict effluent limits. Section XXI (D) of the MP&M Rule states that metal finishing companies may continue to be regulated in accordance with existing categorical standards or local limits, whichever are more stringent, provided they have in place certain P2 and procedures. P2 practices specifically identified in the rule are as follows:

-Use Dragout Reduction/Recovery Techniques and Practices

-Implement Water Conservation Rinses Designs

-Practice Water Flow Control

-Segregate Process Wastewater from Non-Process Wastewater

-Use Water Conservation Practice with Respect to Air Pollution Control - in many cases "scrubber" water used to control chromium, nickel and other heavy metal air emissions can be utilized back in the plating process

-Use Good House Keeping Practices

-Minimize Discharge of Oily Waste to Process Rinse Tanks

-Sweep or Vacuum Dry Production Areas Prior to Washing/Rinsing

-Reuse Drum/Shipping Container Rinse Water Directly in Process

-Implement an Environmental Management System and Environmental Record Keeping/Reporting System

NBC saw this proposed rule as an opportunity to promote the use of these P2 activities within the local metal finishing shops. As part of this effort NBC's P2 Office will conduct "MP&M" P2 audits of metal finishing facilities and will follow-up with report in how a particular company can better comply with the MP&M P2 list. Companies that are in full compliance with list of P2 activities will receive a certificate of compliance. Should the MP&M rule be passed with the P2 option in place, those companies with compliance certificates will be in a good position to request an exception from the strict MP&M discharge limits. Should the rule not pass, NBC is confident companies implementing these P2 activities will see cost and environmental compliance benefits that will have made their efforts worthwhile. Activities conducted as part of this project are partially funded through an EPA PPIS grant award.

 
Project Contact
Name Jim McCaughey
Phone 401-461-8848
E-mail
 
Project Keywords
Industrial Sectors Metal Fabrication, Metal Finishing and Electroplating
 
Source
Newsletter Northeast States Pollution Prevention News - Vol. 12 No. 1, Spring 2002 [PDF]

 

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