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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