United States Offr
Envir ion Wa?
Agei
1981
Proposed Effluent
Guidelines
Rulemaking for the
Coil Coating
Point Source Category
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Background
The Clean Water Act
Under the Clean Water Act (the Federal
Water Pollution Control Act Amend-
ments of 1972, as amended by the Clean
Water Act of 1977), the Environmental
Protection Agency (EPA) is charged with
the responsibility to restore and main-
tain the chemical, physical, and
biological integrity of the Nation's
waters.
Direct Dischargers
The Act requires that all industries
discharging wastes into navigable
waters achieve by July 1, 1977, the "best
practicable control technology currently
available" (BPT). This control technology
represents the average of the best exist-
ing waste treatment performance within
each industry category or subcategory.
By July 1, 1984, the Act requires the
achievement of effluent limitations
based on the very best control and treat-
ment measures that have been
developed or that are capable of being
developed within the industry category
or subcategory. These effluent limita-
tions require the following controls:
• Toxic and Nonconventional
Pollutants—Application of the
"best available technology
economically achievable" (BAT)
• Conventional Pollutants—Applica-
tion of the "best conventional pollu-
tant control technology" (BCT)
New source performance standards
(NSPS) are also established for new in-
dustrial direct dischargers. NSPS, which
goes into effect at the commencement
of operation, is described as the "best
available demonstrated control
technology, processes, operating
methods, or other alternatives including,
where practicable, a standard permitting
no discharge of pollutants."
Indirect Dischargers
Indirect dischargers are industrial
facilities that discharge pollutants to
publicly owned treatment works (POTW).
The Clean Water Act directs EPA to
establish national pretreatment stand-
ards for pollutants that are incompatible
with municipal treatment plants. The Act
requires:
• Achievement, within 3 years of pro-
mulgation, of pretreatment stand-
ards for existing sources (PSES)
/
• Achievement, upon commencement
of operation, of pretreatment stand-
ards for new sources (PSNS)
Purpose of Proposed
Regulations
The primary purpose of these proposed
regulations is to provide effluent limita-
tions guidelines for BPT, BAT, and BCT
and to establish NSPS, PSES, and
PSNS under Sections 301, 304, 306, 307,
and 501 of the Clean Water Act. To pro-
mote these purposes, the regulations
may also establish monitoring require-
ments under Section 308 of the Act
and Best Management Practices (BMP)
under Section 304(e) of the Act.
While the requirements for direct
dischargers are to be incorporated into
National Pollutant Discharge Elimination
System (NPDES) permits issued under
Section 402 of the Act by EPA and par-
ticipating States, pretreatment stand-
ards are enforceable directly by the
Agency against indirect dischargers.
The proposed regulations do not re-
quire the installation of any particular
treatment technology. Rather, they re-
quire achievement of effluent limitations
representative of the proper operation of
demonstrated technologies or equivalent
technologies.
Industry
Coverage
The Coil Coating Industry is not
specifically included within any of the
U.S. Department of Commerce, Bureau
of the Census Standard Industrial
Classifications (SIC's); however, it may
be included as part of SIC 3479.
Coil coating is a rapidly expanding in-
dustry because it is an efficient and
economical way to apply a high-quality
coating to sheet metals. Coil coating in-
volves three basis materials—steel,
galvanized steel, and aluminum—plus
brass, galvalum, and coated steels. The
processing steps are cleaning, chemical
conversion coating, and application and
drying. More than 75 coil coating plants
operate in the United States, with 125
coil coating lines. Sixty-five percent of
the coil coating lines are concentrated
in Alabama, California, Illinois,
Michigan, Ohio, and Pennsylvania.
Water is used throughout the coil
coating processes. Characteristics of
the wastewater generated by coil
coating may vary depending on the
basis material and the processing op-
tions selected for cleaning and chemical
conversion coating.
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Pollutants
Pollutants discharged by the industry
include:
• Toxic Pollutants—Cadmium,
chromium, zinc, nickel, lead, copper,
and cyanide
• Conventional Pollutants—TSS, pH,
and oil and grease
• Unconventional Pollutants—Iron,
aluminum, phosphorous, and
fluoride
EPA's Development
Program
To implement the Clean Water Act, EPA
conducted a complex development pro-
gram. This program included:
• Development of analytical methods
for detecting and measuring toxic
pollutants
• Sampling of intake water and raw
and treated wastewater at a
representative number of plants
• Use of the best state-of-the-art
methods for detection of toxics, i.e.,
atomic adsorption spec-
trophotometry (AAS) and gas
chromatography/mass spectrometry
(GC/MS)
Technical Data Gathering
The technical analysis was based on:
• A data collection portfolio
developed by EPA to which 73
plants (representing about 125 coil
coating lines) contributed data
• Supplemental data were obtained
from:
—NPDES permit files
—Engineering studies (3 plants
were sampled and analyzed dur-
ing screening, and 13 plants dur-
ing verification)
Methodology
After developing analytical methods for
detecting and measuring toxic pollu-
tants, EPA studied the Coil Coating
Industry to determine whether separate
standards were needed for different
segments of the industry.
Next, EPA identified the wastewater
constituents to be considered for
effluent limitations guidelines and
standards of performance and identified
in-plant and end-of-process treatment
technologies that were being used, or
that could be used, by the industry. EPA
then identified the various treatment
technology options for BPT, BAT, BCT,
PSES, PSNS, and NSPS and analyzed
data on the performance of each
technology, including non-water-quality
environmental impacts.
The cost of each control and treat-
ment technology was estimated from
unit cost curves, and the economic im-
pacts of these costs were evaluated.
Finally, EPA selected the preferred op-
tion by industry subcategory for each
set of standards.
Subcategories
EPA has subcategorized the Coil
Coating Industry according to the three
basis materials coated.
• Steel (includes chromium, nickel,
and tin-coated steels)
• Galvanized steel (includes galvalum,
copper, and copper alloys such as
brass)
• Aluminum (includes aluminum-
coated steel)
Summary of Control
Technologies Considered
The following pollution control tech-
nologies were considered by EPA in
developing standards for the Coil
Coating Industry. The alternative treat-
ment technologies considered for exist-
ing direct and indirect discharge
sources include:
• In-Process Treatments
—Cascade rinsing
—Cooling and recycling of quench
water
—Conversion coating processes
that do not generate wastewater,
such as no-rinse conversion
coating
• End-of-Pipe Treatments
—Cyanide oxidation or precipitation
—Hexavalent chromium reduction
—Chemical precipitation of metals
using hydroxides, carbonates, or
sulfides
• Removal of precipitated metals and
other materials using settling,
sedimentation, filtration, and com-
binations of these technologies
The Proposed
Regulations
Proposed BPT
• Technology— Hexavalent chromium
reduction, cyanide removal, oil
skimming, pH adjustment, and
sedimentation to remove the resul-
tant precipitate and other suspend-
ed solids
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• Rationale—Represents average per-
formance of the best existing plants
(transfer technology used where
treatment is universally inadequate)
• Regulated Pollutants—Aluminum,
chromium, copper, cyanide, iron,
lead, nickel, zinc, TSS, oil and
grease, and pH
• Results—Removal of 352.7 metric
tons of toxic metals per year
Proposed BAT
• Technology—Based on the same in-
process wastewater flow control
and end-of-pipe treatment
technology required for BPT, except
with additional mixed-media filter,
plus recirculation and reuse of
quench water
• Rationale—High level of effluent
control achievable at reasonable
cost because of reduced size of
treatment equipment possible with
reduced wastewater flow
• Regulated Pollutants—Same as
those for BPT
• Results—Removal of 359.7 metric
tons of toxic metals per year
Proposed BCT
• Technology—Same as BAT for the
steel and galvanized steel sub-
categories; same as BPT for the
aluminum subcategory, except for
oil and grease, which is set
independently under BAT
• Rationale—Cost of removing TSS
and oil and grease is $0.54, $0.05,
and $1.43 per pound for the steel,
galvanized steel, and aluminum sub-
categories, respectively, as com-
pared with $1.27 for an average
POTW.
• Regulated Pollutants—TSS, pH, and
oil and grease
Proposed NSPS
• Technology—Same as BAT plus
counter-current rinsing and no-rinse
conversion coating
• Rationale—Cost for required
modification and downtime
generated by additional technology,
which impacts existing plants, is
not a consideration for new sources
^
• Regulated Pollutants—Same as
those for BPT
Proposed PSES
• Technology—Same as BAT
• Rationale—Same as that for BAT
• Regulated Pollutants—Cadmium,
chromium, zinc, nickel, lead, and
copper
Proposed PSNS
• Technology—Same as that for
NSPS
• Rationale—Same as that for NSPS,
since the hydraulic loading on
POTW would be reduced
Non-Water-Quality
Aspects of Pollution
Control
Air Pollution
• Imposition of BPT, BAT, BCT, NSPS,
PSES, and PSNS will not create any
substantial air pollution problems
Solid Waste
• Coil coating facilities generate
43,900 metric tons of solid waste
(wet basis) per year (1976)
• Proposed BPT limitations will add
45,700 metric tons of solid waste
per year
• Proposed BAT limitations and PSES
will add approximately 8,100 metric
tons per year beyond BPT
• With the proposed pretreatment
standards, POTW sludges will have
commensurately lower quantities
and concentrations of toxic
pollutants and will therefore be
eligible for a wider range of
disposal alternatives
• POTW sludges with high concentra-
tions of toxic pollutants are listed
as "hazardous" and are subject to
costly handling, transportation,
storage, and disposal requirements;
whereas POTW sludges with low
concentrations can be disposed of
according to open dumping stand-
ards of the Act
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Consumptive Water Loss
• None of the requirements will cause
significant consumptive water loss
Energy Requirements
• To achieve BPT, BAT, BCT, and
PSES, direct and indirect
dischargers will increase total
energy consumed for production by
less than 1 percent
Best Management
Practices
Although EPA is not proposing them at
this time, the Agency is considering
development of BMP specific to the Coil
Coating Industry. These will be appli-
cable to all industrial sites and will
offer guidance to permit authorities in
establishing the BMP required by unique
circumstances at a given plant.
Economic Impact
Analysis
The economic impact analysis is based
on:
• A screening analysis to identify
plants that could incur significant
costs and suffer adverse economic
impacts from compliance with the
proposed regulations
• Plant-specific production data and
compliance costs estimated by EPA
for 58 sample plants, of which 15
(26 percent) were determined to be
facing possible adverse economic
impact
• A financial analysis of potentially
vulnerable plants to quantify the
level of anticipated impact and to
assess the likelihood of plant
closure
• Resulting financial profiles used in
calculating financial ratios to
analyze plant profitability and the
size of the capital investment
• Comparision of plant-specific ratios
with threshold values established at
levels at which closure among toll
coaters, captive operations, and ad-
junct operations became likely
• Generalization and extension of
results of sample plant analysis to
entire industry
Impact Summary
• Total additional capital investment
of $14.9 million to bring 70 existing
sources into compliance with pro-
posed limitations
—BPT: $3.5 million
—BAT: $2.4 million beyond BPT
—PSES: $9.0 million
• Total annual compliance costs of
$4.9 million
—BPT: $1.6 million
—BAT: $0.8 million beyond BPT
(based on original version
as analyzed; modified ver-
sion as proposed is
expected to cost 20 to 25
percent less)
—PSES: $2.5 million
Capital investment of $400 to $600
million for new sources to satisfy
the expected production increase
from 1980 through 1985 (excluding
construction costs)
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Glossary
AAS Atomic adsorption
spectrophotometry
BAT "Best available technology
economically achievable,"
to be achieved by July 1,
1984
BCT "Best conventional pollu-
tant control technology,"
to be achieved by July 1,
1984
BMP Best managment practices
BPT "Best practicable control
technology currently
available," to be achieved
by July 1, 1977
EPA U.S. Environmental Protec-
tion Agency
GC/MS Gas chromatography/mass
spectrometry
NPDES National Pollutant
Discharge Elimination
System
NSPS New source performance
standards, to be achieved
upon commencement of
operation of a new plant
POTW Publicly owned treatment
works
PSES Pretreatment standards for
existing sources, to be
achieved within 3 years of
promulgation
PSNS Pretreatment standards for
new sources, to be achiev-
ed upon commencement of
operation of a new plant
SIC Standard Industrial
Classification (Department
of Commerce, Bureau of
the Census)
TSS Total suspended solids
For further information, contact:
Technical information may be obtained
from:
Mr. Ernst P. Hall
Effluent Guidelines Division (WH-552)
U.S. Environmental Protection Agency
Washington, D.C. 20460
(202) 426-2726
Copies of the technical documents may
be obtained from:
Distribution Officer
Effluent Guidelines Division (WH-552)
U.S. Environmental Protection Agency
Washington, D.C. 20460
(202) 426-2724
The economic analysis may be obtained
from:
Ms. Renee M. Rico
Economic Analysis Staff (WH-586)
U.S. Environmental Protection Agency
Washington, D.C. 20460
(202) 755-2484
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