NPDES inspectors conducted an inspection at Eagle Bronze on August 11, 2014. A previous inspection had been conducted on June 28, 2010. Eagle Bronze makes bronze and steel sculptures, although the majority of them are bronze. Many bronze sculptures go through a patina process. The patina process applies heat and a chemical called sulfurated potash to produce a dark color on the bronze surface that oxidizes the bronze producing the dark color. Wastewater from this process is discharged to the Lander POTW. Both EPA inspections determined that the wastewater discharged from rinsing sulfurated potash from bronze sculptures is regulated under the Metal Finishing Point Source Category (40 C.F.R. Part 433). This is because the process of applying sulfurated potash to bronze meets the definition of coating, which is a regulated process.
IUs that discharge wastewater regulated by a categorical process, such as metal finishing, are signification industrial users (SIUs). Categorical SIU (or CIU) regulations are self-implementing. CIUs are required to submit a baseline monitoring report before they begin discharging, a 90-day compliance report within 90 days of commencing discharge, and semiannual compliance reports. These reports include sample data for samples collected by the CIU. Eagle Bronze has not sampled or reported.
The Administrative Order on Consent was issued to require Eagle Bronze to comply with required sampling, reporting, and notification.