FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
1
of
28
Coil
Coating
Point
Source
Category
(
40
CFR
465)
and
Canmaking
Subcategory
Detailed
Investigation
for
2004/
2005
Planning
Process
Executive
Summary
During
the
Screening
Level
Review
phase
of
the
2004/
2005
planning
process,
coil
coating,
including
the
can
making
subcategory
was
one
of
eight
industrial
categories
identified
solely
through
Factor
4
concerns.
Issues
driving
the
concerns
include
changes
to
industry
since
promulgation,
such
as:
1)
discharges
of
new
solvents
adopted
by
the
industry
and
not
regulated
by
existing
guidelines,
2)
costs
to
monitor
pollutants
no
longer
used
by
the
industry,
and
3)
applicability
issues
for
multi­
process
facilities.
Based
on
information
reported
to
the
Toxic
Release
Inventory
(
TRI)
and
the
Permit
Compliance
System
(
PCS),
toxic
discharges
from
coil
coating
and
canmaking
operations
are
low
relative
to
other
industrial
categories.
Discharges
from
a
single
facility
contribute
over
99%
of
the
total
toxic
weighted
pound
equivalent
(
TWPE)
loading
estimates
for
this
industry.

The
information
in
the
record
at
this
time
does
not
support
a
decision
to
revise
these
effluent
guidelines.
In
the
event
that
stakeholders
provide
additional
data
and
supporting
information
during
subsequent
review
cycles,
EPA
will
reevaluate
them
at
that
time.
In
the
absence
of
revisions
to
the
effluent
guidelines,
both
the
monitoring
concerns
and
the
applicability
issues
could
be
addressed
through
improved
information
dissemination
and
outreach
by
EPA.
The
Agency
could
prepare
a
fact
sheet
with
answers
to
these
and
other
frequently
asked
questions
(
FAQs),
including
the
names
of
current
contacts
within
EPA's
Office
of
Water.
The
Agency
could
announce
the
availability
of
this
fact
sheet
at
the
regular
meetings
for
permit
writers
and
pretreatment
coordinators
held
by
the
Office
of
Wastewater
Management
(
OWM),
and
through
internet
postings
and
email
alerts
to
the
Engineering
and
Analysis
Division
(
EAD)
stakeholders
mailing
list.
As
for
the
new
solvents
issue,
EPA
could
solicit
information
about
the
new
solvents
and
then
determine
whether
the
current
guidelines
would
in
fact
address
them
through
the
technology
basis.
The
results
of
this
research
could
be
considered
during
a
subsequent
planning
cycle.
Finally,
due
to
the
presence
of
a
single
facility
discharging
the
bulk
of
the
TWPE,
EPA
could
also
provide
assistance
to
permit
writers
in
preparing
BPJ­
based
permits.

Overview
This
report
presents
information
for
the
following
topics:
Background
Industry
and
Related
Subcategories
Wastewater
Characteristics
and
Pollutant
Sources
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
2
of
28
Pollutants
Discharged
Treatment
Technology
and
Pollution
Prevention
Concerns
Identified
Pre­
Proposal
Concerns
Identified
in
Comments
to
Proposal
Followup
Contacts
Possible
Solutions
Attachments
provide
the
following
supporting
information:
EPA
Databases
and
References
Used
in
this
Review
Point
Source
Categories
Identified
Solely
Through
Factor
4
Guidelines
Applicability
and
Regulatory
History
PCS
Discharges
TRI
Discharges
Reported
Pollutant
Loadings
Background
In
preparation
for
proposing
the
Preliminary
Effluent
Guidelines
Program
Plan
for
2004/
2005
("
Preliminary
Plan,"
published
in
February
2004),
EPA
analyzed
four
factors
identified
in
the
draft
"
National
Strategy
for
Industrial
Clean
Water"(
Edocket
OW­
2003­
0074­
0215).
See
Attachment
A
for
more
background
about
the
304(
m)
planning
Process.
The
four
factors
focus
on:
1
Potential
impacts
to
human
health
and
the
environment.
Preliminary
results
are
summarized
in
the
"
Factor
1
Analysis:
Human
Health
and
Environmental
Impacts
 
Status
of
Screening
Level
Review
Phase"
(
Edocket
OW­
2003­
0074­
0410).
2
Identification
of
an
applicable
and
demonstrated
technology,
process
change,
or
pollution
prevention
alternative
that
can
effectively
reduce
pollutants
discharged.
Preliminary
results
are
summarized
in
the
"
Factor
2
Analysis:
Technology
Advances
and
Process
Changes
 
Status
of
Screening
Level
Review
Phase."
(
Edocket
OW­
2003­
0074­
0287).
3
Evaluation
of
the
cost,
performance,
and
affordability
of
the
technology,
process
change,
or
pollution
prevention
measures
identified
using
the
second
factor.
4
Implementation
and
efficiency
concerns.
Preliminary
results
are
presented
in
the
"
Factor
4
Analysis:
Implementation
and
Efficiency
Considerations
 
Status
of
Screening
Level
Review
Phase"
(
Edocket
OW­
2003­
0074­
0329)

When
all
of
the
results
were
integrated
prior
to
proposing
the
Preliminary
Plan,
EPA
determined
that
8
point
source
categories
with
existing
effluent
guidelines
had
been
identified
solely
through
Factor
4
concerns.
(
See
list
in
the
Attachment
B.)
In
order
to
determine
the
best
course
of
action
to
address
these
concerns,
EPA
performed
an
analysis
of
issues
and
potential
solutions
for
each
of
the
8
categories.
The
results
of
that
analysis
for
the
Coil
Coating
category
and
the
Canmaking
subcategory
are
presented
in
this
report.
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
3
of
28
Industry
and
Related
Subcategories
The
Coil
Coating
point
source
category
is
regulated
at
40
CFR
Part
465.
See
Attachment
C
for
the
applicability
and
regulatory
background.
This
point
source
category
includes
facilities
reporting
under
Standard
Industrial
Classification
(
SIC)
industry
group341,
Metal
Cans
and
Shipping
Containers.
Specifically,
it
includes
SIC
3411,
Metal
Cans.
The
canmaking
subcategory
was
identified
during
the
Factor
4
analysis.

°
SIC
3411
­
Metal
Cans
Establishments
primarily
engaged
in
manufacturing
metal
cans
from
purchased
materials.

The
following
tables
present
the
facilities
in
this
category
that
report
to
the
Permit
Compliance
System
(
PCS)
and
to
the
Toxic
Release
Inventory
(
TRI).
Since
this
industry
ranked
low
during
the
screening
phase,
EPA
did
not
verify
any
of
the
information
reported
to
PCS
and
TRI,
and
has
used
it
as
reported.
Although
information
in
PCS
and
TRI
is
limited,
it
can
provide
insight
into
this
industry.
See
Attachment
A
for
more
details
about
PCS
and
TRI.

Table
1
shows
the
number
of
facilities
identified
in
this
industry.
Table
2
lists
the
facilities
reporting
to
PCS
under
these
SIC
codes.
Table
3
lists
the
facilities
reporting
to
TRI
under
these
SIC
codes.
Attachments
D
and
E
list
these
facilities
along
with
their
reported
discharges.

Table
1.
Number
of
Facilities
SIC
1997
Census
PCS
TRI
Total
Major
Minor
Total
No
reported
discharge
Direct
discharge
Indirect
discharge
Both
direct
&
indirect
3411
274
8
0
8
136
94
1
41
0
Source:
PCSLoads2000,
TRIReleases2000.

Table
2.
Coil
Coating
Facilities
Reporting
to
PCS
Under
SIC
3411
NPDES
ID
Facility
Name
City
State
No
facilities
reporting
to
PCS
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
4
of
28
Table
3.
Coil
Coating
Facilities
Reporting
to
TRI
Under
SIC
3411
Sorted
by
State
NPDES
ID
Facility
Name
City
State
85031MRCNN211NO
REXAM
BEVERAGE
CAN
CO.
PHOENIX
AZ
FACILITY
PHOENIX
AZ
91752MTLCN10980
METAL
CONTAINER
CORP.
MIRA
LOMA
MIRA
LOMA
CA
91311MRCNN20730
REXAM
BEVERAGE
CAN
CO.
CHATSWORTH
FACILITY
CHATSWORTH
CA
94533MRCNN2433C
REXAM
BEVERAGE
CAN
CO.
FAIRFIELD
PLANT
FAIRFIELD
CA
95824SLGNC6200F
SILGAN
CAN
CO.
SACRAMENTO
CA
80550MTLCN12011
METAL
CONTAINER
CORP.
WINDSOR
WINDSOR
CO
80403BLLPC4525I
BALL
METAL
BEVERAGE
CONTAINER
CORP.
GOLDEN
CO
80401VLLYM17755
VALLEY
METAL
CONTAINER
GOLDEN
CO
32205MTLCN1100N
METAL
CONTAINER
CORP.
JACKSONVILLE
JACKSONVILLE
FL
30161MTLCN110MC
METAL
CONTAINER
CORP.
ROME
ROME
GA
30050MRCNN48ROY
REXAM
BEVERAGE
CAN
CO.
FOREST
PARK
FACILITY
FOREST
PARK
GA
60609MRCNN1101W
REXAM
BEVERAGE
CAN
CO.
CHICAGO
PLANT
CHICAGO
IL
60915CRWNC1035E
CROWN
CORK
&
SEAL
CO.
INC.
BRADLEY
IL
46350MRCNN300NO
SILGAN
CONTAINERS
MFG.
CORP.
LA
PORTE
IN
01843CRWNC155SH
CROWN
CORK
&
SEAL
CO.
INC.
LAWRENCE
MA
55107MRCNN139EV
REXAM
BEVERAGE
CAN
CO.
EVA
STREET
ST.
PAUL
MN
SAINT
PAUL
MN
55044CRWNC84152
CROWN
CORK
&
SEAL
CO.
INC.
LAKEVILLE
MN
63010MTLCN42TEN
METAL
CONTAINER
CORP.
ARNOLD
ARNOLD
MO
38654MRCNN10800
REXAM
BEVERAGE
CAN
CO.
OLIVE
BRANCH
FACILITY
OLIVE
BRANCH
MS
38606CRWNCHWY35
CROWN
CORK
&
SEAL
CO.
INC.
BATESVILLE
MS
27107STRHC4000O
REXAM
BEVERAGE
CAN
CO.
WINSTON
SALEM
PLANT
WINSTON­
SALEM
NC
08852MRCNNGEORG
REXAM
BEVERAGE
CAN
CO.
BRUNSWICK
PLANT
MONMOUTH
JUNCTION
NJ
08854MRCNNSORAN
REXAM
BEVERAGE
CAN
CO.
PISCATAWAY
NJ
FACILIT
PISCATAWAY
NJ
08817MRCNN135NA
SILGAN
CONTAINERS
CORP.
EDISON
NJ
12550MTLCN1000B
METAL
CONTAINER
CORP.
(
NWB)
NEW
WINDSOR
NY
43213MTLCN350MC
METAL
CONTAINER
CORP.
COLUMBUS
COLUMBUS
OH
43420MRCNN2145C
REXAM
BEVERAGE
CAN
CO.
FREMONT
PLANT
FREMONT
OH
43571MRCNN10444
REXAM
BEVERAGE
CAN
CO.
WHITEHOUSE
PLANT
WHITEHOUSE
OH
73179MRCNN3400S
REXAM
BEVERAGE
CAN
CO.
OKLAHOMA
CITY
PLANT
OKLAHOMA
CITY
OK
00630CRWNCKM126
CROWN
CORK
DE
PUERTO
RICO
INC.
CAROLINA
PR
29010MRCNN609CO
REXAM
BEVERAGE
CAN
CO.
BISHOPVILLE
SC
FACILIT
BISHOPVILLE
SC
29520CRWNC100EV
CROWN
CORK
&
SEAL
CO.
INC.
CHERAW
SC
75604STRHC1001F
REXAM
BEVERAGE
CAN
CO.
LONGVIEW
FACILITY
LONGVIEW
TX
77029MRCNN8501E
REXAM
BEVERAGE
CAN
CO.
HOUSTON
FACILITY
HOUSTON
TX
77303CRWNC2501N
CROWN
CORK
&
SEAL
CO.
INC.
CONROE
TX
77478CNTNN12910
CROWN
BEVERAGE
PACKAGING
INC.
SUGAR
LAND
TX
79603CRWNC1900N
CROWN
CORK
&
SEAL
CO.
INC.
ABILENE
TX
98032MRCNN1220N
REXAM
BEVERAGE
CAN
CO.
KENT
WA
FACILITY
KENT
WA
98507CNTNN1202F
CROWN
BEVERAGE
PACKAGING
INC.
OLYMPIA
WA
53538MTLCN105EA
METAL
CONTAINER
CORP.
FORT
ATKINSON
FORT
ATKINSON
WI
54603CNTNN1501S
CROWN
BEVERAGE
PACKAGING
INC.
LA
CROSSE
WI
82401CRWNC4THST
CROWN
CORK
&
SEAL
CO.
INC.
WORLAND
WY
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
5
of
28
No
facilities
for
this
SIC
code
reported
to
PCS.
(
Eight
minor
dischargers
report
to
PCS
under
SIC
3411,
but
these
facilities
do
not
need
to
report
their
discharge
data.)
There
are
42
facilities
that
report
discharges
to
TRI,
all
but
one
of
these
report
only
indirect
discharges.
(
Note:
indirect
discharge
amounts
do
not
reflect
removals
by
the
receiving
treatment
facility.)
Facilities
are
located
in
21
states
and
Puerto
Rico.
Of
the
42
facilities,
10
are
located
in
Region
V.
A
single
facility
in
Indiana
contributes
over
95%
of
the
toxic
weighted
pound
equivalents
(
TWPE).
The
map
on
the
following
page
shows
the
locations
of
the
facilities
reporting
to
TRI.

U.
S.
Census
data
indicates
a
decrease
in
the
number
of
metal
canmaking
facilities
by
15%
between
1992
and
1997.
The
value
of
goods
shipped
has
also
declined
by
less
than
1%
during
the
same
time
period.
See
Table
4
below.

Advance
comparative
statistics
for
1997
to
2002
for
the
broader
category
represented
by
North
American
Industry
Classification
System
(
NAICS)
code
332
(
Fabricated
Metal
Product
Manufacturing)
show
a
continuing
decrease
in
the
number
of
establishments
of
almost
3%
but
just
over
1%
increase
in
the
value
of
shipments
(
not
adjusted
for
inflation).
See
Table
5.
Table
6
illustrates
the
increase
in
can
shipments
since
1982.

Table
4.
1992
and
1997
Census
Data
SIC
Industry
Segment
Number
of
Establishments
Value
of
Goods
Shipped
(
in
billions
of
dollars)

1997
1992
%
Change
1997
1992
%
Change
3411
Metal
Cans
274
324
­
15
12.0
12.1
­
0.6
Source:
1997
U.
S.
Economic
Census
Table
5.
1997
and
2002
Census
Data
NAICS
Industry
Segment
Number
of
Establishments
Value
of
Goods
Shipped
(
billions
of
dollars)

2002
1997
%
Change
2002
1997
%
Change
332
Fabricated
Metal
Product
Mfr.
60,602
62,384
­
2.8
245
242
1.2
Source:
2002
U.
S.
Economic
Census
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
7
of
28
Table
6.
Can
Shipments
by
Category
Year
Can
Shipments
in
Billions
of
Cans
Food
Beverage
General
Line
1982
27.6
57.9
3.8
1992
30.9
95.7
4.1
2002
31.3
100.5
4.4
Source:
CanCentral.
com..
<
http://
www.
cancentral.
com>
Accessed
on
July
6,
2004.

Wastewater
Characteristics
and
Pollutant
Sources
Wastewater
pollutant
loads
depend
on
the
basis
material
and
the
production
process
employed.
Table
7
illustrates
the
processes
and
the
associated
pollutants.

Table
7.
Sources
of
Process
Wastewater
in
Coil
Coating
and
Canmaking
Process
Wastewater
Pollutants
Cleaning
metals,
suspended
solids,
oil
Conversion
coating
metals,
suspended
solids
Finishing
suspended
solids
Canmaking
metals,
oil,
toxic
organics,
suspended
solids
Source:
1982
Coil
Coating
TDD
and
1983
Canmaking
Subcategory
TDD.

Pollutants
Discharged
Pollutant
discharges
to
surface
water
as
reported
to
PCS
and
TRI
were
evaluated
as
part
of
the
Factor
1
Analysis:
Human
Health
and
Environmental
Impacts.
Pounds
reported
as
discharged
were
converted,
wherever
possible,
to
their
toxic
weighted
pound
equivalents
to
provide
a
sense
of
relative
hazard
associated
with
those
discharges.
(
Note:
indirect
discharge
amounts
reflect
reductions
that
are
expected
to
occur
at
the
receiving
treatment
facility.)
Only
TRI
contains
information
about
pollutants
discharged
to
surface
water
by
coil
coating/
canmaking
facilities.
These
discharges
only
include
pollutants
characterized
as
nonconventional
pollutants.
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
8
of
28
Of
the
42
reporting
facilities,
only
one
facility
contributes
92%
of
the
total
pounds
and
99%
of
the
toxic
weighted
pounds.

Discharged
pollutants
that
can
be
characterized
as
nonconventional,
conventional,
or
priority
pollutants.
Table
8
below
shows
the
relative
contributions
of
each
pollutant
type,
including
both
pounds
discharged
and
toxic
weighted
pound
equivalents
(
TWPE)
discharged.
See
Attachment
E
for
the
discharges
in
toxic
weighted
pounds
as
reported
to
TRI
by
each
facility.
See
Attachment
F
for
a
breakout
of
these
discharges
by
pollutant.
A
discussion
of
each
pollutant
type
discharged
follows
the
table.

Table
8.
Pollutant
Discharges
Reported
to
PCS
and
TRI
Pollutant
Category
&
Primary
Pollutants
PCS
Pounds
PCS
TWPE
TRI
Pounds
TRI
TWPE
All
Pollutants
0
0
32,803
11,763
Nonconventional
0
0
32,803
11,763
Sodium
Nitrite
31,210
(
95%)
11,652
(
99%)
Manganese
1,592
(
5%)
112
(
1%)
Conventional
0
0
0
0
Priority
0
0
0
0
Nonconventional
Pollutants
TRI
included
only
nonconventional
discharges
from
this
point
source
category.
Of
these,
sodium
nitrite
discharges
(
from
a
single
facility
in
Indiana)
comprise
95%
or
more
of
the
discharges,
both
in
pounds
and
in
TWPE.
The
next
highest
discharge
was
of
manganese,
reported
discharged
by
38
of
the
42
reporting
facilities.

Conventional
Pollutants
No
information
on
conventional
pollutants
discharged
by
this
industry
is
available
through
PCS
or
TRI.

Priority
Pollutants
No
information
on
conventional
pollutants
discharged
by
this
industry
is
available
through
PCS
or
TRI.

For
purposes
of
comparison,
the
toxic
weighted
pound
equivalents
(
TWPE)
for
Coil
Coating
are
presented
in
the
following
tables
along
with
the
industries
reporting
the
highest
discharges
in
each
database.
Table
9
presents
the
information
reported
to
PCS
and
Table
10
presents
the
information
reported
to
TRI.
For
a
description
of
the
derivation
of
the
values
in
these
tables,
see
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
9
of
28
the
memo
in
the
public
record
titled
"
Description
and
Results
of
EPA
Methodology
to
Synthesize
Screening
Level
Results
for
the
Effluent
Guidelines
Program
Plan
for
2004/
2005,"
which
is
available
through
Edocket
at
document
number
OW­
2003­
0074­
0391.

Table
9.
Coil
Coating
TWPE
Reported
to
PCS
Compared
to
Top
Ranking
Results
40
CFR
Part
Point
Source
Category
PCS
Reported
TWPE
PCS
Rank
423
Steam
electric
power
generation
2,933,209
1
414
Organic
chemicals,
plastics
and
synthetic
fibers
1,805,928
2
422
Phosphate
manufacturing
1,095,321
3
415
Inorganic
chemicals
manufacturing
853,568
4
421
Nonferrous
metals
manufacturing
434,925
5
440
Ore
mining
and
dressing
383,560
6
410
Textile
mills
296,601
7
419
Petroleum
refining
198,251
8
455
Pesticide
chemicals
manufacturing,
formulating
178,977
9
418
Fertilizer
manufacturing
116,464
10
465
Coil
Coating
0
Table
10.
Coil
Coating
TWPE
Reported
to
TRI
Compared
to
Top
Ranking
Results
40
CFR
Part
Point
Source
Category
TRI
Reported
TWPE
TRI
Rank
414
Organic
chemicals,
plastics
and
synthetic
fibers
7,303,782
1
423
Steam
electric
power
generation
1,856,645
2
421
Nonferrous
metals
manufacturing
978,450
3
430
Pulp,
paper
and
paperboard
(
Phase
II)
628,785
4
415
Inorganic
chemicals
manufacturing
624,250
5
40
CFR
Part
Point
Source
Category
TRI
Reported
TWPE
TRI
Rank
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
10
of
28
429
Timber
products
processing
404,926
6
419
Petroleum
refining
385,347
7
455
Pesticide
chemicals
manufacturing,
formulating
324,393
8
428
Rubber
manufacturing
166,343
9
463
Plastic
molding
and
forming
106,189
10
434
Coil
Coating
11,763
25
Treatment
Technology
and
Pollution
Prevention
Coil
Coating:
Standard
treatment
for
coil
coating
may
include
chemical
precipitation
and
sedimentation,
oil
removal,
cyanide
removal,
chromium
reduction,
or
filtration.

Canmaking:
Standard
treatment
for
canmaking
may
include
chemical
precipitation
and
sedimentation,
oil
removal,
filtration,
neutralization,
chemical
emulsion
breaking,
or
dissolved
air
flotation.
Oil
skimming
was
used
as
the
technology
basis
for
total
toxic
organics
(
TTO)
removal
for
the
can
making
subcategory.
Since
toxic
organics
detected
in
can
making
wastewater
are
similar
to
those
in
aluminum
forming
and
coil
coating
wastewater,
the
removal
rate
from
aluminum
forming
plants
was
used
to
predict
the
organics
removal
for
can
making.
On
average,
aluminum
forming
plants
achieve
a
97
percent
removal
of
organics
by
oil
skimming.

Pollution
Prevention:
Recycle
and
reuse,
and
use
of
alternative
cleaning
or
conversion
coating
agents
are
the
focus
of
current
pollution
prevention
activities.
Some
facilities
have
achieved
zero
discharge
by
evaporating
wastewater
to
leave
a
dry
residue.
Separation
of
waste
streams
can
increase
the
efficiency
of
the
wastewater
treatment
system
and
reduce
the
pounds
of
chemicals
added
for
treatment.
See
Table
11
for
more
information
about
pollution
prevention
alternatives.

Table
11.
Water
Conservation
and
Pollution
Prevention
Alternatives
Process
Water
Conservation/
Pollution
Prevention
Alternatives
Aluminum
coil
coating
Install
ultrafiltration
units
to
remove
aluminum
etchings
from
cleaning
solutions.
This
extends
the
life
of
cleaning
solutions,
thus
reducing
use
of
cleaning
solvents,
and
reduces
discharges
of
aluminum
in
effluent.
Process
Water
Conservation/
Pollution
Prevention
Alternatives
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
11
of
28
Cleaning
Reduce
dragout
Reuse
of
alkaline
cleaning
rinse
water
as
make­
up
to
the
alkaline
cleaning
tank
Multi­
stage
countercurrent
rinses
Conversion
coating
Chromium
regeneration
system
Recycle
and
reuse
rinse
water
Recycle
quench
water
Use
cyanide­
free
chromating
solutions
Use
zinc­
free
sealing
rinses
Use
no­
rinse
conversion
coating
in
place
of
chromate
conversion
coating
Finish
coating
Use
of
solvent­
free
wax
reduces
organic
emissions,
reduces
gas
consumption
formerly
required
to
dry
the
wax/
solvent
mixture,
reduces
combustion
byproducts
from
drying
and
oxidation
process.

Can
coating
Use
of
radiation­
cured
coatings
reduces
VOC
emissions,
eliminates/
reduces
need
for
carrier
solvents.

Source:
Technical
Development
Documents
and
industry
web
sites
Concerns
Identified
Pre­
Proposal
The
Coil
Coating
point
source
category
and
the
Canmaking
subcategory
were
identified
by
several
responders
surveyed
by
the
Agency
in
the
process
of
preparing
the
2004/
2005
Plan.
Their
suggestions
are
summarized
below.

Consultations
with
Permitting
Authorities
(
Section
2.5
of
the
"
Factor
4
Analysis:
Implementation
and
Efficiency
Considerations
 
Status
of
Screening
Level
Review
Phase"
(
Edocket
OW­
2003­
0074­
0329)
EPA
permit
writers
and
pretreatment
coordinators
note
that
the
industry
has
changed
since
the
effluent
guidelines
were
promulgated
in
1983.
The
industry
is
using
completely
different
solvents
than
those
assessed
during
the
development
of
the
existing
guidelines.
However,
no
supporting
data
has
been
provided
to
EPA
to
support
this
observation.
EPA
permit
writers
and
pretreatment
coordinators
are
also
concerned
about
the
costs
associated
with
monitoring
requirements
for
pollutants
that
are
no
longer
in
use
by
the
industry.
In
addition,
applicability
issues
have
been
identified
by
EPA
permit
writers
and
pretreatment
coordinators
in
two
Regions
(
2
and
5),
and
by
stakeholders
in
the
States
(
Alabama
and
Tennessee).
Questions
focused
on
facilities
with
multiple
processes
which
also
perform
coil
coating,
most
recently
aluminum
forming
facilities.

Concerns
Identified
in
Comments
to
Proposal
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
12
of
28
No
concerns
for
the
Coil
Coating
point
source
category
or
the
Canmaking
Subcategory
were
received
in
comments
to
the
Preliminary
Plan.

Followup
Contacts
Marv
Rubin,
EPA/
OST/
EAD
(
202)
566­
1050
Frank
Brock,
USEPA
Region
2,
(
212)
637­
3762
Matt
Gluckman,
USEPA
Region
5,
(
312)
886­
6089
Glenda
Dean,
Alabama,
(
334)
270­
5602
Possible
Solutions
EPA
appreciates
all
comments
and
suggestions
provided
by
the
stakeholders
and
EPA
Regional
staff.
Based
on
information
reported
to
TRI
and
PCS,
toxic
discharges
from
coil
coating
and
canmaking
operations
are
low
relative
to
other
industrial
categories.
Discharges
from
a
single
facility
contribute
over
99%
of
the
total
TWPE.
Stakeholders
and
EPA
staff
identified
various
issues
associated
with
discharges
from
coil
coating
and
canmaking
plants.
The
information
in
the
record
at
this
time
does
not
support
the
concerns
raised.
In
the
event
that
stakeholders
provide
additional
data
and
supporting
information
during
subsequent
review
cycles,
EPA
will
reevaluate
them
at
that
time.
However,
as
with
any
comments
received
by
the
Agency,
EPA
can
not
address
these
suggestions
without
adequate
supporting
data.
In
the
event
that
stakeholders
provide
additional
data
and
supporting
information,
on
these
or
any
of
the
issues
identified
above,
EPA
will
reevaluate
them
at
that
time.
In
the
absence
of
revisions
to
the
effluent
guidelines,
these
concerns
could
be
addressed
through
improved
information
dissemination
and
outreach
by
EPA.

New
Solvents
Being
Discharged:
There
is
a
possibility
that
the
new
solvents
are
controllable
by
the
technology
considered
in
the
development
of
the
guidelines
for
this
point
source
category.
The
permitting
of
control
authority
can
attempt
to
address
this
issue
by
answering
the
following
questions:
1)
What
are
the
solvents
in
use
when
the
guidelines
were
developed?
2)
What
is
the
technology
basis
for
controlling
those
solvents?
3)
What
are
the
new
solvents
being
used
by
the
industry?
4)
Are
these
new
solvents
controlled
by
the
technology?
At
this
time,
based
on
the
information
in
its
record,
EPA
has
no
basis
to
conclude
that
solvents
are
being
discharged
by
this
industry.
Solvents
were
not
identified
as
discharged
from
this
industry
in
either
PCS
or
TRI.
Consequently,
unless
EPA
receives
additional
information
that
demonstrates
solvent
discharges
are
a
concern
for
this
industry,
EPA
does
not
plan
to
address
this
issue
in
more
detail.

Costs
to
Monitor
Pollutants
No
Longer
in
Use:
For
direct
dischargers,
permit
writers
can
reduce
the
frequency
of
required
monitoring
through
the
provisions
described
at
40
CFR
122.44(
1)(
2)
"
Monitoring
waivers
for
certain
guideline­
listed
pollutants."
(
This
is
not
available
during
the
term
of
the
first
permit.)
For
indirect
discharges,
the
Office
of
Wastewater
Management
is
preparing
to
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
13
of
28
propose
a
waiver
provision
for
"
pollutants
not
present"
under
the
National
Pretreatment
Program's
streamlining
regulation.
That
regulation
is
projected
to
be
final
in
December,
2004.
EPA
can
alert
permit
writers
and
pretreatment
coordinators
to
both
provisions.

Applicability
Issues
for
Multi­
process
Facilities:
Applicability
issues
appear
to
be
extremely
case­
specific,
and
best
addressed
through
individual
discussions
with
Engineering
and
Analysis
(
EAD)
staff.
However,
a
table
addressing
the
potential
overlapping
guidelines
for
aluminum
forming,
coil
coating,
and
metal
finishing
would
also
be
helpful.
EAD
can
share
these
concerns
with
the
Office
of
Wastewater
Management
to
assist
them
in
increasing
the
consistency
of
application
of
effluent
guidelines.

Summary
of
Potential
Solutions:
Both
the
monitoring
concerns
and
the
applicability
issues
could
be
addressed
through
information
dissemination
and
outreach
by
EPA.
The
Agency
could
prepare
a
fact
sheet
with
answers
to
frequently
asked
questions
(
FAQs),
including
a
table
of
potentially
overlapping
guidelines
and
specifically
discussing
the
pollutant
monitoring
information.
This
fact
sheet
could
be
posted
on
EPA's
web
site.
In
addition,
the
Agency
could
announce
the
availability
of
this
fact
sheet,
and
the
name
of
the
current
EAD
staff
available
to
answer
questions
at
the
regular
meetings
for
permit
writers
and
pretreatment
coordinators
held
by
the
Office
of
Wastewater
Management
(
OWM)
and
also
through
email
alerts
to
the
EAD
mailing
list.
Finally,
due
to
the
presence
of
a
single
facility
discharging
the
bulk
of
the
TWPE,
EPA
could
also
provide
assistance
to
permit
writers
in
preparing
BPJ­
based
permits.

As
for
the
new
solvents
issue,
EPA
needs
data
about
any
solvents
being
discharged
before
it
could
determine
whether
the
current
guidelines
do
in
fact
address
them
through
the
technology
basis.
Information
on
the
new
solvents
may
be
available
from
permit
writers
and
others
in
the
field
experienced
with
this
industry.
Any
solvents
thus
identified
can
then
be
evaluated
relative
to
the
guidelines
technology
basis
to
determine
whether
they
would
in
fact
be
controlled
by
that
technology.
The
results
of
this
research
could
be
considered
during
a
subsequent
planning
cycle.
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
14
of
28
Attachment
A
EPA
Databases
and
References
Used
in
this
Review
Overview
of
the
304(
m)
Planning
Process
CWA
Section
304(
m)(
1)
requires
EPA
to
establish
a
schedule
for
the
annual
review
and
revision
of
all
existing
effluent
guidelines
and
to
identify
categories
of
point
sources
discharging
toxic
or
non­
conventional
pollutants
for
which
EPA
has
not
published
effluent
guidelines.
To
accomplish
this
review,
EPA
conducted
a
screening­
level
analysis
using
readily
available
information
from
EPA's
Permit
Compliance
System
(
PCS)
and
Toxics
Release
Inventory
(
TRI)
databases.
EPA
estimated
the
mass
of
pollutants
discharged
from
each
category,
weighted
the
pollutant
releases
based
on
chemical
toxicity,
and
ranked
the
categories
based
on
the
toxicweighted
pollutant
releases.

In
addition
to
reported
discharges
in
PCS
and
TRI,
EPA
used
other
readily
available
data,
as
well
as
information
from
public
outreach,
including
industry
categories
recommended
by
stakeholders
for
regulatory
development
or
regulatory
revision,
to
evaluate
implementation
and
efficiency
considerations.

For
additional
details
on
EPA's
screening­
level
analysis
refer
the
following
documents
in
EPA
Docket
Number
OW­
2003­
0074:


Memorandum:
Description
and
Results
of
EPA
Methodology
to
Synthesize
Screening
Level
Results
for
the
Effluent
Guidelines
Program
Plan
for
2004/
2005,
DCN
548,
Section
3.0;


Development
of
PCSLoads
2000,
DCN
620,
Section
2.1.2
(
this
document
explains
how
pollutant
loads
were
calculated
from
PCS
data);
and

Evaluation
of
RSEI
Model
Runs,
DCN
618,
Section
2.1.1.
Information
from
EPA's
Permit
Compliance
System
(
PCS)
and
Toxics
Release
Inventory
(
TRI)
databases
were
used
to
create
the
PCSLoads2000
and
TRIReleases2000
databases.
These
databases
were
the
primary
source
of
information
used
to
conduct
this
review.
Since
this
industry
ranked
low
during
the
screening
phase,
however,
EPA
did
not
verify
any
of
the
information
reported
to
PCS
and
TRI,
and
has
used
it
as
reported.

TRIReleases2000
The
Toxic
Release
Inventory
(
TRI)
is
the
major
source
of
data
for
the
TRIReleases2000
database.
TRI
is
the
common
name
for
Section
313
of
the
Emergency
Planning
and
Community
Right­
to­
Know
Act
(
EPCRA).
Each
year,
facilities
that
meet
certain
thresholds
must
report
their
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
15
of
28
releases
and
other
waste
management
activities
for
listed
toxic
chemicals.
That
is,
facilities
must
report
the
quantities
of
toxic
chemicals
recycled,
collected
and
combusted
for
energy
recovery,
treated
for
destruction,
or
disposed
of.
A
separate
report
must
be
filed
for
each
chemical
that
exceeds
the
reporting
threshold.
The
TRI
list
of
chemicals
for
reporting
year
2000
includes
more
than
600
chemicals
and
chemical
categories.
For
this
review,
EPA
used
data
for
reporting
year
2000,
because
they
were
the
most
recent
available
at
the
time
the
review
began.

There
are
three
criteria
that
a
facility
must
meet
to
be
required
to
submit
a
TRI
report
for
that
reporting
year.
The
criteria
are:

(
1)
SIC
Code
Determination:
Facilities
in
SIC
Codes
20
through
39,
seven
additional
SIC
codes
outside
this
range,
and
federal
facilities
must
concern
themselves
with
TRI
reporting.
EPA
rarely
checks
or
refutes
facility
claims
regarding
the
SIC
code
identification.
The
primary
SIC
code
determines
TRI
reporting.

(
2)
Number
of
Employees:
Facilities
must
have
10
or
more
full­
time
employees
or
their
equivalent.
EPA
defines
a
"
full­
time
equivalent"
as
a
person
that
works
2,000
hours
in
the
reporting
year
(
there
are
several
exceptions
and
special
circumstances
that
are
well­
defined
in
the
TRI
reporting
instructions).

(
3)
Activity
Thresholds:
If
the
facility
is
in
a
covered
SIC
code
and
has
10
or
more
full­
time
employee
equivalents
it
must
conduct
an
activity
threshold
analysis
for
every
chemical
and
chemical
category
on
the
current
TRI
list.
The
facility
must
determine
whether
it
manufactures,
processes,
OR
otherwise
uses
each
chemical
at
or
above
the
appropriate
activity
threshold.
Reporting
thresholds
are
not
based
on
the
amount
of
release.
All
TRI
thresholds
are
based
on
mass,
not
concentration.
Different
thresholds
apply
for
persistent
bioaccumulative
toxic
(
PBT)
chemicals
than
for
non­
PBT
chemicals.

In
TRI,
facilities
report
annual
loads
released
to
the
environment
of
each
toxic
chemical
or
chemical
category
that
meets
reporting
requirements.
They
must
report
onsite
releases
to
air,
receiving
streams,
disposal
to
land,
underground
wells,
and
several
other
categories.
They
must
also
report
the
amount
of
toxic
chemicals
in
wastes
transferred
to
off­
site
locations,
including
discharges
to
POTWs
and
other
off­
site
locations,
such
as
commercial
waste
disposal
facilities.

For
this
review,
EPA
focused
on
the
amount
of
chemicals
facilities
reported
either
discharging
directly
to
a
receiving
stream
or
transferring
to
a
POTW.
For
facilities
discharging
directly
to
a
stream,
the
loads
were
taken
directly
from
the
reported
TRI
data
for
calendar
year
2000.
For
facilities
that
transfer
toxic
chemicals
to
POTWs,
EPA
first
adjusted
the
TRI
pollutant
loads
reported
to
be
transferred
to
POTWs
to
account
for
pollutant
removal
that
occurs
at
the
POTW
prior
to
discharge
to
the
receiving
stream.
This
adjustment
was
made
using
POTW
removal
efficiencies
from
EPA's
Risk
Screening
Environmental
Indicators
(
RSEI)
model
(
see
Section
2.1.1
of
the
docket
for
more
information
on
TRI
and
the
RSEI
model).
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
16
of
28
Reporting
facilities
are
not
required
to
sample
and
analyze
wastestreams
to
determine
the
quantities
of
toxic
chemicals
released.
They
may
estimate
releases
based
on
mass
balance
calculations,
published
emission
factors,
site­
specific
emission
factors,
or
other
approaches.
Facilities
are
required
to
indicate,
by
a
reporting
code,
the
basis
of
their
release
estimate.
TRI's
reporting
guidance
is
that
for
chemicals
reasonably
expected
to
be
present
but
measured
below
the
detection
limit,
facilities
should
use
one
half
the
detection
limit
to
estimate
the
mass
released.
The
guidance
is
slightly
different
for
dioxins
and
dioxin­
like
compounds
in
that
it
allows
nondetects
to
be
treated
as
zero.

TRI
provides
the
option
for
facilities
to
report
releases
as
specific
numbers
or
as
ranges,
if
appropriate.
Specific
estimates
are
encouraged
if
data
are
available
to
ensure
the
accuracy;
however,
EPA
allows
facilities
to
report
releases
in
the
following
ranges:
1
to
10
pounds,
11
to
499
pounds,
and
500
to
999
pounds.
For
this
analysis,
EPA
used
the
mid­
point
of
each
reported
range
to
represent
a
facility's
releases.

EPA
weighted
the
direct
and
indirect
pollutant
releases
to
surface
waters
using
toxic
weighting
factors
(
TWFs)
developed
by
Office
of
Water/
Engineering
and
Analysis
Division
(
EAD),
to
calculate
toxic
weighted
pound
equivalents
(
TWPE)
for
each
reported
release.
See
4.2.3
and
4.2.4
for
more
discussion
of
TWFs
and
calculation
of
TWPE.
EPA
compiled
data
taken
from
TRI,
the
adjusted
releases
from
POTWs
to
surface
waters,
the
calculated
TWPE,
and
the
relationship
between
SIC
codes
and
point
source
category
into
a
Microsoft
Access
 
database
named
TRIReleases2000.
Some
corrections
were
made
to
this
database
as
further
study
was
conducted
on
the
TRI
data.
Limitations
of
TRI
are
discussed
in
Section
IV
of
the
Technical
Support
Document
for
this
planning
process.

PCSLoads2000
The
Permit
Compliance
System
(
PCS)
is
the
major
source
of
data
for
the
PCSLoads2000
database.
PCS
is
a
computerized
management
information
system
maintained
by
EPA's
Office
of
Enforcement
and
Compliance
Assurance
(
OECA).
It
was
created
to
track
permit,
compliance,
and
enforcement
status
of
facilities
regulated
by
the
National
Pollutant
Discharge
Elimination
System
(
NPDES)
program
under
the
Clean
Water
Act
(
CWA).

More
than
65,000
industrial
facilities
and
water
treatment
plants
have
obtained
permits
for
water
discharges
of
regulated
pollutants.
To
provide
an
initial
framework
for
setting
permit
issuance
priorities,
EPA
developed
a
major/
minor
classification
system
for
industrial
and
municipal
wastewater
discharges.
Major
discharges
almost
always
have
the
capability
to
impact
receiving
waters
if
not
controlled
and,
therefore,
have
been
accorded
more
regulatory
attention
than
minor
discharges.
There
are
approximately
6,400
facilities
(
including
sewerage
systems)
with
major
discharges
for
which
PCS
has
extensive
records.
Permitting
authorities
classify
discharges
as
major
based
on
an
assessment
of
six
characteristics:
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
17
of
28
(
1)
toxic
pollutant
potential;
(
2)
ratio
of
discharge
flow
to
stream
flow;
(
3)
conventional
pollutant
loading;
(
4)
public
health
impact;
(
5)
water
quality
factors;
and
(
6)
proximity
to
coastal
waters.

Facilities
with
major
discharges
must
report
compliance
with
NPDES
permit
limits
via
monthly
Discharge
Monitoring
Reports
(
DMRs)
submitted
to
the
permitting
authority.
The
permitting
authority
enters
the
reported
DMR
data
into
PCS,
including
the
type
of
violation
(
if
any),
concentration
and
quantity
values,
and
the
Quarterly
Non­
Compliance
Report
(
QNCR)
indicators.
Minor
discharges
may,
or
may
not,
adversely
impact
receiving
water
if
not
controlled.
Therefore,
EPA
does
not
require
DMRs
for
facilities
with
minor
discharges.
For
this
reason,
the
PCS
database
includes
data
only
for
a
limited
set
of
minor
dischargers
when
the
states
choose
to
include
these
data.
As
a
consequence,
extensive
data
are
not
available
for
minor
discharges
in
PCS.

Parameters
in
PCS
include
water
quality
parameters
(
such
as
pH
and
temperature),
specific
chemicals,
bulk
parameters
(
such
as
BOD
5
and
TSS),
and
flow
rates.
Although
other
pollutants
may
be
discharged,
PCS
only
contains
data
for
the
parameters
identified
in
the
facility's
NPDES
permit.
Facilities
typically
report
monthly
average
pounds
per
day
discharged,
but
also
report
daily
maxima,
and
pollutant
concentrations.

For
this
review,
EPA
used
data
for
reporting
year
2000,
to
correspond
to
the
data
obtained
from
TRI.
EPA
used
its
Effluent
Data
Statistics
(
EDS)
system
program
to
calculate
annual
pollutant
discharges
using
the
monthly
reports
in
PCS.
Because
units
of
measure
vary
widely
in
PCS,
EPA
developed
the
EDS
system
to
estimate
mass
loadings
based
on
data
stored
in
PCS.
The
EDS
system
uses
existing
PCS
reported
mass
loading
values
or
multiplies
reported
discharge
flows
and
effluent
concentrations
to
estimate
loadings
for
each
outfall
(
discharge
pipe),
taking
into
account
the
various
units
of
concentration
and
flow
rates.

Where
concentrations
were
reported
as
below
detection
limit
(
BDL)
EPA
assumed
the
parameter
concentration
was
equal
to
zero
for
parameters
never
detected
by
the
facility
in
2000.
For
parameters
sometimes
detected
and
sometimes
not,
the
"
BDL"
concentration
was
set
equal
to
half
of
the
detection
limit.
.
The
EDS
system
program
sums
the
monthly
loads
to
calculate
annual
discharges,
interpolating
(
using
average
reported
loads)
for
months
with
missing
reports.

EPA
weighted
the
calculated
annual
pollutant
discharges
using
EAD's
TWFs
to
calculate
TWPE
for
each
reported
discharge,
as
it
did
for
the
reported
TRI
releases.
See
sections
4.2.3
and
4.2.4
for
more
discussion
of
TWFs
and
calculation
of
TWPE.
EPA
compiled
data
taken
from
PCS,
the
calculated
TWPE,
and
the
relationship
between
SIC
codes
and
point
source
category
into
a
Microsoft
Access
 
database
named
PCSLoads2000.
As
further
study
was
conducted
on
the
PCS
data,
some
corrections
were
made.
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
18
of
28
Other
Information
Sources
In
addition
to
TRI
and
PCS,
EPA
used
the
following
sources
of
information
in
its
review
of
this
industry:


1997
Economic
Census
data;
and
2002
Economic
Census
data.


Contacts
with
reporting
facilities
to
verify
reported
releases
and
facility
categorization.


US
EPA,
October
1982.
Development
Document
for
Final
Effluent
Limitations
Guidelines
and
Standards
for
the
Coil
Coating
Point
Source
Category.
EPA440/
1­
82/
071.


US.
2001.
Code
of
Federal
Regulations.
40
CFR
Part
465:
Coil
Coating
Point
Source
Category.


US
EPA,
November
1983.
Development
Document
for
Final
Effluent
Limitations
Guidelines
and
Standards
for
the
Coil
Coating
Point
Source
Category
(
Canmaking
Subcategory.
EPA440/
1­
83/
071.


Jupiter
Aluminum
Corp.,
1999.
Pollution
Prevention
Project
Report.
Accessed
at
<
http://
www.
ecn.
purdue.
edu/
CMTI/
Technology_
Transfer/
Jupitp2­
web.
htm>
on
July
6,
2004.


US
EPA
Coatings
Alternative
Guide
(
CAGE).
Accessed
at
<
http://
cage.
rti.
org>
on
July
6,
2004.


CanCentral.
com.
Information
about
the
can
industry.
Accessed
at
<
http://
www.
cancentral.
com>
on
July
6,
2004.


National
Coil
Coating
Association
web
page.
Accessed
at
<
http://
www.
coilcoating.
org/>
on
July
6,
2004.
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
19
of
28
Attachment
B
Point
Source
Categories
Identified
Solely
Through
Factor
4
Industry
Formal
Comment
Process
Previous
Suggestions
(
Sec.
2.4)
Draft
Strategy
Outreach
Comments
on
Draft
Strategy
(
Sec.
2.2)
Comments
on
2002/
2003
Plan
(
Sec.
2.3)
Permitting
Authoritie
s
(
Sec.
2.5)
AMSA
&
ASIWPC
A
(
Sec.
2.6)

Coal
Mining



Coil
Coating

Dairy
Products
Processing

Electrical
and
Electronic
Components

Fruits
and
Vegetable
Processing


Metal
Molding
and
Casting




Mineral
Mining
and
Processing

Seafood
Processing



FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
20
of
28
Attachment
C
Applicability
and
Regulatory
History
Applicability
of
40
CFR
Part
465
Subpart
A
­
Steel
Basis
Material
Subcategory.
This
subpart
applies
to
discharges
to
waters
of
the
United
States,
and
introductions
of
pollutants
into
publicly
owned
treatment
works
from
coil
coating
of
steel
basis
material
coils.

Subpart
B
­
Galvanized
Basis
Material
Subcategory.
This
subpart
applies
to
discharges
to
waters
of
the
United
States
and
introductions
of
pollutants
into
publicly
owned
treatment
works
from
coil
coating
of
galvanized
basis
material
coils.

Subpart
C
­
Aluminum
Basis
Material
Subcategory.
This
subpart
applies
to
discharges
to
waters
of
the
United
States
and
introductions
of
pollutants
into
publicly
owned
treatment
works
from
coil
coating
of
aluminum
basis
material
coils.

Subpart
D
­
Canmaking
Subcategory.
This
subpart
applies
to
discharges
to
waters
of
the
United
States,
and
introductions
of
pollutants
into
publicly
owned
treatment
works
from
the
manufacturing
of
seamless
can
bodies,
which
are
washed.

Definition:
Coil
coating
means
the
process
of
converting
basis
material
strip
into
coated
stock.
Usually
cleaning,
conversion
coating,
and
painting
are
performed
on
the
basis
material.
Part
465
applies
to
processes
that
perform
any
two
of
the
three
operations
REGULATORY
BACKGROUND
Regulatory
History
Final
versions
of
the
effluent
limitations
for
Subparts
A
­
C
were
promulgated
October
30,
1982.
Effluent
limitations
for
Subpart
D
(
Canmaking)
were
promulgated
November
1983.

The
technology
basis
of
existing
regulations
for
subparts
A
­
C
is:


cyanide
treatment,
chromium
reduction,
oil
removal,
lime
precipitation
and
sedimentation
for
BAT
and
PSES;


recycle,
cyanide
treatment,
chromium
reduction,
oil
removal,
lime
precipitation
and
sedimentation,
and
sludge
dewatering
for
BPT;
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
21
of
28

recycle,
cyanide
treatment,
chromium
reduction,
oil
removal,
chemical
precipitation
and
sedimentation,
and
sludge
dewatering
for
NSPS;
and

recycle,
cyanide
treatment,
chromium
reduction,
chemical
precipitation
and
sedimentation,
and
sludge
dewatering
for
PSNS.

The
technology
basis
for
existing
regulations
for
subpart
D
is:


wastewater
flow
normalization,
chromium
reduction,
oil
removal,
and
lime
precipitation
and
sedimentation
for
BPT;


in­
process
flow
reduction,
chromium
reduction,
oil
removal,
and
lime
precipitation
and
sedimentation
for
BAT
and
PSES;
and

BPT
end­
of­
pipe
treatment
and
in­
process
flow
reduction
for
NSPS
and
PSNS.

Existing
Limitations
Effluent
limitations
guidelines
are
mass­
based
on
the
basis
of
milligram
(
mg)
per
surface
area
processed
in
square
meters
(
m2)
and
grams
(
g)
per
one
million
cans
produced.

BCT
was
deferred
for
all
Subparts
(
A­
D).

Limitations
were
established
based
on
subcategorization
by
basis
material
used
or
product
(
metal
cans).

Pretreatment
standards
for
total
toxic
organics
(
TTO)
were
established
for
new
and
existing
sources
in
the
canmaking
subcategory.
EPA
detected
14
organic
compounds
at
quantifiable
levels
during
wastewater
sampling,
and
selected
these
compounds
to
be
included
in
the
regulation.
According
to
Part
465,
TTO
is
the
sum
of
the
mass
of
each
of
the
following
toxic
organic
compounds
which
are
found
at
a
concentration
greater
than
0.010
mg/
1:

1,1,1­
Trichloroethane;
1,1­
Dichloroethane;
1,1,2,2­
Tetrachloroethane;
Bis
(
2­
chloroethyl)
ether;
Chloroform;
1,1­
Dichloroethylene;
Methylene
chloride
(
dichloromethane);
Pentachlorophenol;
Bis
(
2­
ethylhexyl)
phthalate;
Butyl
benzyl­
phthalate;
Di­
N­
butyl
phthalate;
Phenanthrene;
Tetrachloroethylene;
and
Toluene.
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
22
of
28
EPA
received
comments
after
proposal
that
changes
in
can
making
technology
had
eliminated
toxic
organic
pollutants.
Sampling
data
collected
between
1978
and
1983
did
not
support
this
comment.

Other
Effluent
Guidelines
40
CFR
Part
467
(
Aluminum
Forming)
is
applicable
to
rolling,
drawing,
extruding,
forging,
and
related
operations
such
as
heat
treatment,
casting,
and
surface
treatments.
For
the
purposes
of
this
regulation,
surface
treatment
of
aluminum
is
considered
to
be
an
integral
part
of
aluminum
forming
whenever
it
is
performed
at
the
same
plant
site
at
which
the
aluminum
is
formed.
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
23
of
28
Table
C­
1.
Effluent
Guidelines
for
Coil
Coating
and
Canmaking
Pollutant
BPT
30­
day
averages
BAT
30­
day
averages
NSPS
30­
day
averages
PSES
30­
day
averages
PSNS
30­
day
averages
Subparts
A­
C
(
mg/
m2)
Subpart
D
(
g/
1
million
cans)
Subparts
A­
C
(
mg/
m2)
Subpart
D
(
g/
1
million
cans)
Subparts
A­
C
(
mg/
m2)
Subpart
D
(
g/
1
million
cans)
Subparts
A­
C
(
mg/
m2)
Subpart
D
(
g/
1
million
cans)
Subparts
A­
C
(
mg/
m2)
Subpart
D
(
g/
1
million
cans)

Chromium
0.45­
0.58
38.70
0.16­
2.0
15.10
0.052­
0.47
11.45
0.16­
0.20
15.10
0.052­
0.047
11.45
Copper
2.61a
NR
0.90b
NR
0.21
a
NR
0.90a
83.90
0.21a
63.60
Cyanide
0.32­
0.41
NR
0.11­
0.14
NR
0.028­
0.25
NR
0.11­
0.14
NR
0.025­
0.38
NR
Zinc
1.46­
1.89
131.15
0.51­
0.66
51.18
0.14­
0.20
38.80
0.51­
0.66
51.18
0.14­
0.20
38.80
Aluminum
6.26b
688.00
1.84b
268.48
0.59b
203.52
NR
NR
NR
NR
Iron
1.65­
1.74
5676.00
0.57­
0.74
2214.96
0.20­
0.22
1679.04
NR
2214.96
NR
1679.04
Phosphorous
NR
1468.45
NR
573.04
NR
434.39
NR
573.04
NR
434.39
Manganese
NR
NR
NR
NR
NR
NR
NR
24.33
NR
18.44
Oil
and
grease
31.31­
40.4
2580
NR
NR
3.16­
4.75
763.20
NR
1006.80
NR
763.20
TSS
52.2­
67.3
4192.5
NR
NR
3.79­
5.70
1240.20
NR
NR
NR
NR
TTO*
NR
NR
NR
NR
NR
NR
NR
12.59
NR
9.54
pH
7.5­
10.0
7.0­
10.0
NR
NR
7.5­
10.0
7.0­
10.0
NR
NR
NR
NR
*
Total
toxic
organic
pollutants
include
1,1,1­
Trichloroethane,
1,1­
Dichloroethane,
1,1,2,2­
Tetrachloroethane,
Bis
(
2­
chloroethyl)
ether,
Chloroform,
1,1­
Dichloroethylene,
Methylene
chloride
(
dichloromethane),
Pentachlorophenol,
Bis
(
2­
ethylhexyl)
phthalate,
Butyl
benzyl­
phthalate,
Di­
N­
butyl
phthalate,
Phenanthrene,
Tetrachloroethylene,
and
Toluene.

a
Subpart
B
only.

NR
=
Not
regulated
b
Subpart
C
only.
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
24
of
28
Attachment
D
PCS
Discharges
SIC
NPDES
ID
NAME
CITY
Flow
(
MGD)
Pounds/
Year
TWPE
Percent
of
Total
SIC
TWPE
Cumulative
Percent
of
Total
SIC
TWPE
No
Reported
Results
for
this
point
source
category.
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
25
of
28
Attachment
E
TRI
Discharges
­
Only
Indirect
Discharges
Reported
for
All
But
One
Facility
SIC
Code
Facility
TRI
ID
Facility
Name
Facility
City
Facilit
y
State
Total
lbs
Total
TWPE
Percent
Total
of
SIC
TWPE
Cumulative
Percent
Total
of
SIC
TWPE
3411
46350MRCNN300NO
SILGAN
CONTAINERS
MFG.
CORP.
LA
PORTE
IN
31,210
11,652
99%
99%

3411
12550MTLCN1000B
METAL
CONTAINER
CORP.
(
NWB)
NEW
WINDSOR
NY
156
11
0%

3411
30161MTLCN110MC
METAL
CONTAINER
CORP.
ROME
ROME
GA
156
11
0%

3411
32205MTLCN1100N
METAL
CONTAINER
CORP.
JACKSONVILLE
JACKSONVILLE
FL
156
11
0%

3411
43213MTLCN350MC
METAL
CONTAINER
CORP.
COLUMBUS
COLUMBUS
OH
156
11
0%

3411
53538MTLCN105EA
METAL
CONTAINER
CORP.
FORT
ATKINSON
FORT
ATKINSON
WI
156
11
0%

3411
63010MTLCN42TEN
METAL
CONTAINER
CORP.
ARNOLD
ARNOLD
MO
156
11
0%

3411
80550MTLCN12011
METAL
CONTAINER
CORP.
WINDSOR
WINDSOR
CO
156
11
0%

3411
91752MTLCN10980
METAL
CONTAINER
CORP.
MIRA
LOMA
MIRA
LOMA
CA
156
11
0%

3411
08852MRCNNGEOR
G
REXAM
BEVERAGE
CAN
CO.
BRUNSWICK
PLANT
MONMOUTH
JUNCTION
NJ
17
1
0%

3411
08854MRCNNSORA
N
REXAM
BEVERAGE
CAN
CO.
PISCATAWAY
NJ
FACILITY
PISCATAWAY
NJ
17
1
0%

3411
27107STRHC4000O
REXAM
BEVERAGE
CAN
CO.
WINSTON
SALEM
PLANT
WINSTONSALEM
NC
17
1
0%

3411
29010MRCNN609CO
REXAM
BEVERAGE
CAN
CO.
BISHOPVILLE
SC
FACILITY
BISHOPVILLE
SC
17
1
0%

3411
30050MRCNN48ROY
REXAM
BEVERAGE
CAN
CO.
FOREST
PARK
FACILITY
FOREST
PARK
GA
17
1
0%

3411
38654MRCNN10800
REXAM
BEVERAGE
CAN
CO.
OLIVE
BRANCH
FACILITY
OLIVE
BRANCH
MS
17
1
0%

3411
43420MRCNN2145C
REXAM
BEVERAGE
CAN
CO.
FREMONT
PLANT
FREMONT
OH
17
1
0%

3411
43571MRCNN10444
REXAM
BEVERAGE
CAN
CO.
WHITEHOUSE
PLANT
WHITEHOUSE
OH
17
1
0%
SIC
Code
Facility
TRI
ID
Facility
Name
Facility
City
Facilit
y
State
Total
lbs
Total
TWPE
Percent
Total
of
SIC
TWPE
Cumulative
Percent
Total
of
SIC
TWPE
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
26
of
28
3411
55107MRCNN139EV
REXAM
BEVERAGE
CAN
CO.
EVA
STREET
ST.
PAUL
MN
SAINT
PAUL
MN
17
1
0%

3411
60609MRCNN1101W
REXAM
BEVERAGE
CAN
CO.
CHICAGO
PLANT
CHICAGO
IL
17
1
0%

3411
73179MRCNN3400S
REXAM
BEVERAGE
CAN
CO.
OKLAHOMA
CITY
PLANT
OKLAHOMA
CITY
OK
17
1
0%

3411
75604STRHC1001F
REXAM
BEVERAGE
CAN
CO.
LONGVIEW
FACILITY
LONGVIEW
TX
17
1
0%

3411
77029MRCNN8501E
REXAM
BEVERAGE
CAN
CO.
HOUSTON
FACILITY
HOUSTON
TX
17
1
0%

3411
85031MRCNN211NO
REXAM
BEVERAGE
CAN
CO.
PHOENIX
AZ
FACILITY
PHOENIX
AZ
17
1
0%

3411
91311MRCNN20730
REXAM
BEVERAGE
CAN
CO.

CHATSWORTH
FACILITY
CHATSWORTH
CA
17
1
0%

3411
94533MRCNN2433C
REXAM
BEVERAGE
CAN
CO.
FAIRFIELD
PLANT
FAIRFIELD
CA
17
1
0%

3411
98032MRCNN1220N
REXAM
BEVERAGE
CAN
CO.
KENT
WA
FACILITY
KENT
WA
17
1
0%

3411
80403BLLPC4525I
BALL
METAL
BEVERAGE
CONTAINER
CORP.
GOLDEN
CO
12
1
0%

3411
80401VLLYM17755*
VALLEY
METAL
CONTAINER*
GOLDEN
CO
4
0
0%

3411
00630CRWNCKM126
CROWN
CORK
DE
PUERTO
RICO
INC.
CAROLINA
PR
3
0
0%

3411
01843CRWNC155SH
CROWN
CORK
&
SEAL
CO.
INC.
LAWRENCE
MA
3
0
0%

3411
29520CRWNC100EV
CROWN
CORK
&
SEAL
CO.
INC.
CHERAW
SC
3
0
0%

3411
38606CRWNCHWY3
5
CROWN
CORK
&
SEAL
CO.
INC.
BATESVILLE
MS
3
0
0%

3411
54603CNTNN1501S
CROWN
BEVERAGE
PACKAGING
INC.
LA
CROSSE
WI
3
0
0%

3411
55044CRWNC84152
CROWN
CORK
&
SEAL
CO.
INC.
LAKEVILLE
MN
3
0
0%

3411
60915CRWNC1035E
CROWN
CORK
&
SEAL
CO.
INC.
BRADLEY
IL
3
0
0%

3411
77303CRWNC2501N
CROWN
CORK
&
SEAL
CO.
INC.
CONROE
TX
3
0
0%

3411
77478CNTNN12910
CROWN
BEVERAGE
PACKAGING
INC.
SUGAR
LAND
TX
3
0
0%
SIC
Code
Facility
TRI
ID
Facility
Name
Facility
City
Facilit
y
State
Total
lbs
Total
TWPE
Percent
Total
of
SIC
TWPE
Cumulative
Percent
Total
of
SIC
TWPE
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
27
of
28
3411
79603CRWNC1900N
CROWN
CORK
&
SEAL
CO.
INC.
ABILENE
TX
3
0
0%

3411
82401CRWNC4THST
CROWN
CORK
&
SEAL
CO.
INC.
WORLAND
WY
3
0
0%

3411
98507CNTNN1202F
CROWN
BEVERAGE
PACKAGING
INC.
OLYMPIA
WA
3
0
0%

3411
08817MRCNN135NA
SILGAN
CONTAINERS
CORP.
EDISON
NJ
1
0
0%

3411
95824SLGNC6200F
SILGAN
CAN
CO.
SACRAMENTO
CA
1
0
0%

3411
TOTAL
32,803
11,764
*
Only
direct
discharging
facility,
no
indirect
pounds
reported.
FINAL
DRAFT
Coil
Coating
August
12,
2004
Page
28
of
28
Attachment
F
Reported
Pollutant
Loadings
SIC
Nonconventional
Pollutants
CAS
PCS
Discharges
TRI
Indirect
Discharges
TRI
Direct
Discharges
Facilities
Reporting
Pollutant
Pounds
TWPE
Facilities
Reporting
Pollutant
Pounds
TWPE
Facilities
Reporting
Pollutant
Pounds
TWPE
3411
SODIUM
NITRITE
7632000
0
 
 
1
31,210
11,652
3411
MANGANESE
7439965
0
 
 
38
1,587
112
1
4
0.28
3411
GLYCOL
ETHERS
N230
0
 
 
3
1
0.00013
3411
N­
BUTYL
ALCOHOL
71363
0
 
 
3
1
0.000093
3411
SUM
OF
NONCONVENTIONAL
POLLUTANTS
0
0
32,799
11,763
4
0.28
