June 10, 1996

Mr. Phil Bramlage

Pinellas County Utilities

14850, 118 Ave. North

Largo, FL 34644

Dear Mr. Bramlage:

As we discussed during our May 28, 1996 telephone conversation, the Metal Finishing (40 CFR 433) categorical standard uses a series of six "trigger" processes (i.e., electroplating, electroless plating, anodizing, coating, chemical etching and milling, and printed circuit board manufacture) as the basis for determining rule applicability. If any of these six "trigger" processes are present at a facility, then effluent from the six "trigger" processes and effluent from all of the forty other processes listed in the 40 CFR 433 regulation are covered. The term "present" in the regulatory applicability section means that one of the "trigger" operations is conducted at the site. Because the term "present" is not qualified with either discharge status or wastewater flow rate considerations, EPA has consistently interpreted the term "present" in terms of an operation being conducted at a site. Unfortunately, EPA does not have documents that define this policy in specific detail. However, it has been EPA policy since implementation of this rule to define an operation as "present" if it is performed at the industrial site, regardless of flow or other discharge considerations.

I hope you find the attached information useful. If you need any other information, please feel free to call me at (202) 260-7191.

Sincerely,

Mark Ingle

MP&M Phase II Project Officer

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