United States Offr Envir ion Wa? Agei 1981 Proposed Effluent Guidelines Rulemaking for the Coil Coating Point Source Category ------- 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. ------- 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 ------- • 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 ------- 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) ------- 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 ------- |