Ask the Expert Question-and-Answer Archive (Wastewater Treatment)
by Mike McGinness, EcoShield Environmental Systems, Inc.
40 CFR Part 413, 433 and 465
Q. My company is looking at an aquisition of a company that conducts electrogalvanzing (zinc only) over a steel substrate in-line with a conventional coil coating operation. How do you determine whether Part 413 or Part 433 applies to your wastewater discharge? I have read the regulations and it is confusing.
A. Luckily, there is a simple answer. You must meet the definition of an electroplater (Part 413) first. If you meet the definition of an electroplater then appropriate parts of Part 413 apply. If you are covered by Part 413 and if you have any one of the listed Metal Finishing processes listed in Part 433, then you are also regulated as a Metal Finisher. If you do not do one of the listed plating processes, then you are not a Metal Finisher. However, if you are not an electroplater and therefore not a Metal Finisher, and if you clean metal parts (having one of the listed Metal Finishing processes listed in Part 433) you may be covered by Part 438, the new METAL PRODUCTS AND MACHINERY POINT SOURCE CATEGORY!
If you are doing electrogalvanizing you are at least an electroplater, and probably a Metal Finisher, making you exempt from Part 438.