EPA
Office of Water
Regulations and Standards
United States
Environmental Protection
Agency
Technical Workshop
for Permit Writers
on Final Regulations
Porcelain Enameling Industry
and
Coil Coating Industry
March 2 and 3, 1983
-------
PORCELAIN ENAMEL MANUFACTURING PROCESS
Finishing tha part
by waldtag. cruiaV
tag. aupportfiig.
Farming Ina part
by onwins,
Cutting to sin by
OJIMChlllff
StMl
FABRICATION
r////////////////////////^^^^^
Cleaning tha part af
Pickling UM part
with acid and/M
rarrle ian ta ramava
nut aad M
oxida*.
•Uniag.
Rinsing.
Nickal Otpositten.
Rintlnf.
Nautfalizinf.
Dryinf.
PROPIRtV
SHAPIO,
CLEANED AND
ETCHED FART—
caady far paccalate
y///////////////////////^^^^
TWO-COAT METHOD
Ground caat batch
formulation from
Particla tin
raductlan by
PROPERLY FORMU-
LATED. SIZED AND
MIXED QROUNO
COAT-
ar.
firound caat
aoplkatlan
bydipptas.
Oryinx,
Firing.
ONE-COAT OR FINISH COAT METHOD
caat batch
fannMlatiM fraai
clay, vatar. frtt.
Partlclatiia
reduction by
PROPERLY FORMU-
LATED. SIZED AND
MIXED FINISH
COAT luipiadart
lavatar.
METAL
PREPARATION
PROCESSING
Ftatehcaat
appUcathMi
furn*catfiyta|
and fmtas.
FINISHED PART —
-------
COIL COATING
PROMULGATED REGULATION FOR THE
COIL COATING
INDUSTRIAL POINT SOURCE CATEGORY
-------
COIL COATING
THE COIL COATING CATEGORY
COIL COATING IS THE PROCESS OF CONVERTING BASIS
MATERIAL STRIP (OR COIL) INTO COATED STOCK.
USUALLY THREE PROCESS STEPS ARE INVOLVED —
CLEANING, COATING (CONVERSION COATING) AND PAINTING.
ANY TWO OF THESE THREE PROCESS STEPS QUALIFY AS COIL COATING
COIL COATING MAY BE CLASSIFIED IN SIC 3479,
COATING, ENGRAVING AND ALLIED SERVICES, NEC
-------
ACCUMULATOR
Q_
STITCHER
CLEANING
RINSING
lUHINu
DAIUTIUft
rAin i iNu
^
noviUR
SEALING
RINSE
CONVERSION
COATING
QUENCHING
SEPARATOR
-0
TAKEUP
SPOOLS
ACCUMULATOR
FIGURE 51! i. GENERAL PROCESS SEQUENCE FOR A SINGLE COAI COIL COATING LINE
-------
COIL COATING
THE COIL COATING CATEGORY (CONTINUED)
COIL COATING IS SUBCATEGORIZED INTO THREE SUBCATEGORIES
1. STEEL (INCLUDES CHROMIUM, NICKEL AND TIN - COATED STEELS)
2. GALVANIZED STEEL (INCLUDES GALVALUM, COPPER AND COPPER
ALLOYS SUCH AS BRASS)
3. ALUMINUM (INCLUDES ALUMINUM ALLOYS AND ALUMINUM COATED
STEEL)
-------
COIL COATING
THE COIL COATING CATEGORY - (CONTINUED)
WASTEWATER IS GENERATED IN ALL THREE PROCESS STEPS
PROCESS STEPS PRINCIPAL POLLUTANTS
CLEANING - Cr, Pb, Ni, Zn, Al, F, Fe-, Mn, P,
O&G, TSS, TTO
COATING - Cr, CN, Pb, Ni, Zn, Al, F, Fe, Mn,
O&G, TSS
QUENCH - Zn, Al, TTO
-------
COIL COATING
THE COIL COATING CATEGORY - (CONTINUED)
EPA OBTAINED DATA ABOUT 69 COIL COATING PLANTS
(ABOUT 125 LINES)
29 ARE DIRECT DISCHARGERS
39 ARE INDIRECT DISCHARGERS
1 DOES NOT DISCHARGE
-------
COIL COATING
THE COIL COATING CATEGORY - (CONTINUED)
DATA WAS COLLECTED FROM ALL KNOWN COIL COATERS
USING A DATA COLLECTION PORTFOLIO (DCP)
SAMPLING AND ANALYSIS VISITS WERE MADE TO 12 PLANTS:
ENGINEERING VISITS TO THREE ADDITIONAL PLANTS.
ENGINEERING STUDIES WERE MADE OF END-OF-PIPE
TREATMENT SYSTEMS.
-------
COIL COATING
THE COIL COATING CATEGORY - (CONTINUED)
DATA TO SUPPORT TREATMENT EFFECTIVENESS OF LIME & SETTLE (L*S)
TREATMENT COLLECTED DURING SAMPLING
DATA FROM COIL COATING, ALUMINUM FORMING, BATTERY MANUFACTURING
COPPER FORMING & PORCELAIN ENAMELING USED AS BASIS FOR L&S
DATA FROM ELECTROPLATING NOT USABLE AS BASIS FOR L&S
-------
COIL COATING
THE REGULATION
THERE IS NO PREVIOUS REGULATION OF COIL COATING
THIS REGULATION PROPOSED JANUARY 12, 1981;
PROMULGATED DECEMBER 1, 1982.
REGULATION INCLUDES BPT, BAT, NSPS, PSES AND
PSNS. BCT IS DEFFERED.
-------
CHEMICAL
ADDITION
CONVERSION
COATING
WASTEWATER
CLEANING
WASTEWATEfl
' CYANIDE 1
J TREATMENT I
"| (OPTIONAL)
D.5CHARGE
OTHER
(QUENCH WASTES)
REMOVAL OF
OIL AND GREASE
FIGURE 1X1. BPT WASTEWATER TREATMENT SYSTEM
-------
COIL COATING
THE REGULATION - (CONTINUED)
BPT
FLOW BASIS IS THE AVERAGE FLOW OF ALL PROCESS
STEPS IN THE SUBCATEGORY
FLOW
STEEL • 2.752 1/m2
GALVANIZED 2.610 1/m2
ALUMINUM 3.363 1/m2
END-OF-PIPE TREATMENT CHROMIUM REDUCTION, CYANIDE
PRECIPITATION, OIL SKIMMING AND L&S
-------
CONVERSION
COATINQ
WASTEWATER
CHEMICAL
ADDITION
-^^^. * ^ ^*»A-
CHROMIUM
REDUCTION
CHEMICAL
ADDITION
1 CYANIDE I
J TREATMENT I
*| (OPTIONAL)
CIEANIIIG
WASTEWATER
OTHER
(QUENCH WASTES)
RECYCLE TO QUENCH
REUSE TO PROCESS
REMOVAL OF
Oil AND OREA»E
FIGURE XI. BAT IEVEII WASTEWATER TREATMENT SYSTEM
-------
COIL COATING
THE REGULATION - (CONTINUED)
BAT-PSES
FLOW REDUCED BY REUSING QUENCH WATER FOR
CLEANING RINSE & COATING RINSE
FLOW
STEEL 1.173 1/mZ
GALVANIZED 0.896 1/m?
ALUMINUM 0.987 1/m2
END-OF-PIPE TREATMENT IS THE SAME AS BPT
-------
COIL COATING
THE REGULATION - (CONTINUED)
PRETREATMENT
COMPLIANCE DATE
FOR EXISTING SOURCES DECEMBER 1, 1985
FOR NEW SOURCES DECEMBER 1, 1982
-------
COIL COATING
THE REGULATION - (CONTINUED)
PRETREATMENT
PSES AND PSNS FOR THIS CATEGORY ARE EXPRESSED AS
MASS STANDARDS - MILLIGRAMS OF POLLUTANT PER SQUARE
METER OF PRODUCT
CONCENTRATION STANDARDS ARE NOT APPROPRIATE FOR THIS
CATEGORY BECAUSE SUBSTANTIAL POLLUTANT REDUCTION IS
ACHIEVED THROUGH FLOW REDUCTION
-------
COIL COATING
THE REGULATION - (CONTINUED)
PRETREATMENT
DATA NEEDED TO DETERMINE COMPLIANCE
- MEASURED WASTEWATER FLOW
- POLLUTANT CONCENTRATION
POSSIBLE ALTERNATES -
- WATER USE RATE OR WATER METER
- POLLUTANT CONCENTRATION
-------
COIL COATING
THE REGULATION - (CONTINUED)
PRETREATMENT
FOR MASS BASED PRETREATMENT STANDARDS
. 1. PRODUCTION RATE - BASED ON
A) PREVIOUS HISTORY - e.g. 5 YEAR AVERAGE
B) MAX MONTH PRODUCTION
C) NAME PLATE RATING
2. DISCHARGE STANDARD FROM REGULATIONS
3. DETERMINES DAILY MAX & MONTHLY AVERAGE DISCHARGE
-------
CONVERSION
CHEMICAL
ADDITION
J£
CHEMICAL
ADDITION
REDUCTION
J 1REATMENT I
"| IOPIIONAII
i___ _jl
WASTEWATER
OTHER
(QUENCH WASTES)
RECYCLE TO QUENCH
tt% REUSE TO COUMTERCURREHT HINJE
nisciiAncr
REMOVAL OF
OIL AND 6REASE
FIGURE XI I. BOT LEVEL IWASTEnATER TREATMENT SYSTEM
-------
COIL COATING
THE REGULATION - (CONTINUED)
NSPS - PSNS
FLOW FURTHER REDUCED BY REQUIRING COUNTERCURRENT
CASCADE RINSE IN BOTH CLEANING AND COATING
FLOW
STEEL 0.316 1/m2
GALVANIZED 0.343 1/m2
ALUMINUM 0.475 1/m2
END-OF-PIPE TREATMENT IS THE SAME AS BPT-BAT
PLUS POLISHING FILTRATION
-------
COIL COATING
THE REGULATION - (CONTINUED)
POLLUTANTS REGULATED
BPT
Cr
Cu
CN
Zn
Al
Fe
O&G
TSS
pH
BAT PSES
Cr Cr
Cu Cu
CN CN
Zn Zn
Al
Fe
NSPS
Cr
Cu
CN
Zn
Al
Fe
O&G
TSS
PH
PSNS
Cr
Cu
CN
Zn
-------
COIL COATING
THE REGULATION - (CONTINUED)
— ONE DAY MAXIMUM AND MONTHLY AVERAGE
VALUES ARE PUBLISHED FOR EACH POLLUTANT
« MONTHLY AVERAGE VALUE MUST BE USED FOR BOTH
DIRECT AND INDIRECT DISCHARGERS.
— COMPLIANCE WITH MONTHLY VALUES IS REQUIRED
REGARDLESS OF NUMBER OF SAMPLES ANALYZED AND
AVERAGED,
-------
COIL COATING
THE REGULATION - (CONTINUED)
PERIODIC ANALYSIS FOR CYANIDE MAY BE REDUCED TO
ONCE ANNUALLY PROVIDING TWO CONDITIONS ARE MET.
1. FIRST SAMPLE TAKEN IN CALENDAR YEAR IS ANALYZED
AND CN FOUND TO BE LESS THAN 0.07 mg/1.
2. THE OWNER OR OPERATOR CERTIFIES TO THE POTW OR
PERMIT ISSUING AUTHORITY THAT CYANIDE IS NOT USED
IN THE COATING PROCESS.
-------
COIL COATING
POST PROMULGATION ISSUES
REGULATION HAS NOT BEEN LITIGATED
INDUSTRY HAS PETITIONED ADMINISTRATOR TO:
1. USE CONCENTRATION RATHER THAN MASS LIMITATIONS
2. SPECIFY SPECIFIC CHEMICAL ANALYSIS OPTION TO BE
USED FOR ANALYZING FOR OIL & GREASE
-------
COIL COATING
DEVELOPMENT DOCUMENT ORGANIZATION
THERE ARE 17 SECTIONS IN THE DOCUMENT.
SECTIONS I & II ARE A SUMMARY OF THE DOCUMENT
SECTIONS III & IV EXPLAIN THE TECHNOLOGY AND SUBCATEGORIZATION
SECTION V PRESENTS DATA COLLECTED
SECTION VI DISCUSSES POLLUTANTS
SECTION VII PRESENTS TECHNOLOGY AND PERFORMANCE
SECTION VIII PRESENTS COSTING METHODOLOGY
SECTION IX - XIII REGULATORY DEVELOPMENT
SECTION XIV - XVII - REFERENCE INFORMATION
-------
PROMULGATED REGULATION FOR THE
PORCELAIN ENAMELING
INDUSTRIAL POINT SOURCE CATEGORY
-------
PORCELAIN ENAMELING
THE PORCELAIN ENAMELING CATEGORY
PORCELAIN ENAMELING IS THE PROCESS OF APPLYING A FUSED
VITRIOUS ENAMEL COATING TO A BASIS METAL.
USUALLY TWO PROCESS STEPS ARE INVOLVED ~ METAL
PREPARATION AND COATING
PORCELAIN ENAMELING MAY BE INCLUDED AS SOME PART OF
SIC CODES 3431 3631 3632 3633 3639 3911
-------
THE PORCELAIN ENAMELING CATEGORY - (CONTINUED)
EPA OBTAINED DATA ABOUT 119 PORCELAIN ENAMELING PLANTS
28 ARE DIRECT DISCHARGERS
88 ARE INDIRECT DISCHARGERS
3 DO NOT DISCHARGE
-------
THE PORCELAIN ENAMELING CATEGORY - (CONTINUED)
PORCELAIN ENAMELING IS SUBCATEGORIZED INTO FOUR SUBCATECORIES
1. STEEL (SOMETIMES CALLED ENAMELING IRON)
2. CAST IRON
3. ALUMINUM
4. COPPER
5. PRECIOUS METALS - A POSSIBLE SUBCATEGORY IS NOT REGULATED
-------
THE PORCELAIN ENAMELING CATEGORY - (CONTINUED)
DATA WAS COLLECTED FROM ALL KNOWN PORCELAIN ENAMELERS
USING A DATA COLLECTION PORTFOLIO (DCP)
SAMPLING AND ANALYSIS VISITS WERE MADE TO 17 PLANTS:
ENGINEERING VISITS TO MANY ADDITIONAL PLANTS.
ENGINEERING STUDIES WERE MADE OF END-OF-PIPE
TREATMENT SYSTEMS.
-------
THE PORCELAIN ENAMELING CATEGORY - (CONTINUED)
DATA TO SUPPORT TREATMENT EFFECTIVENESS OF LIME & SETTLE (L&S)
TREATMENT COLLECTED DURING SAMPLING
DATA FROM COIL COATING, ALUMINUM FORMING, BATTERY MANUFACTURING
COPPER FORMING & PORCELAIN ENAMELING USED AS BASIS FOR L&S
DATA FROM ELECTROPLATING NOT USABLE AS BASIS FOR L&S
-------
PORCELAIN ENAMELING
THE REGULATION
THERE IS NO PREVIOUS REGULATION OF PORCELAIN ENAMELING
THIS REGULATION PROPOSED JANUARY 12, 1981;
PROMULGATED NOVEMBER 2H, 1982.
REGULATION INCLUDES BPT, BAT, NSPS, PSES AND
PSNS. BCT IS DEFERRED.
-------
PORCELAIN ENAMELING
THE REGULATION - (CONTINUED)
ALL LIMITATIONS AND STANDARDS ARE MASS BASED
(FLOW * CONCENTRATION = MASS)
CONCENTRATIONS DERIVED FROM "COMBINED METALS
DATA BASE" FOR L8S
FLOW FOR EACH REGULATORY LEVEL DEVELOPED FOR
EACH SUBCATEGORY
FLOW IS NORMALIZED AGAINST AREA OF METAL PROCESSED
-------
PORCELAIN ENAMELING
THE REGULATION - (CONTINUED)
BPT
FLOW BASIS IS THE AVERAGE FLOW OF ALL PROCESS
STEPS IN THE SUBCATECORY
FLOW METAL PREP COATING
STEEL 40.042 I/m2 8.102 I/m2
CAST IRON 0.693 l/m2
ALUMINUM 38.896 l/m2 15.041 l/m2
END-OF-PIPE TREATMENT CHROMIUM REDUCTION,
OIL SKIMMING AND L&S
-------
COATING
WASTEWATER
ALL OTHER
PORCELAIN
ENAMELING
WASTEWATER
CHEMICAL
ADDITION
CHROMIUM
BEARING
WASTEWATER
CHEMICAL
ADDITION
DISCHARGE
SLUDGE TO
DISPOSAL
SLUDGE
DEWATERING
(IF APPLICABLE)
FIGURE IX-1. BPT TREATMENT SYSTEM FOR STEEL AND ALUMINUM SUBCATEGORIES
-------
PORCELAIN ENAMELING
THE REGULATION - (CONTINUED)
BAT-PSES
FLOW REDUCED BY REUSING TREATED WATER FOR
MOST COATING OPERATIONS
FLOW METAL PREP COATING
STEEL 40.042 I/m2 0.6361/m2
CAST IRON 0.636 l/m2
ALUMINUM 38.896 l/m2 0.636 l/m2
END-OF-PIPE TREATMENT IS THE SAME AS BPT
-------
RETURN TO PROCESS
COATING
WASTEWATER
METAL PREPARATION
WASTEWATER
CHEMICAL
ADDITION/^S
CHROMIUM
BEARING
WASTEWATER
CHROMIUM
REDUCTION
CHEMICAL
ADDITION
SEDIMENTATION
A G REMOVAL
CHEMICAL
PRECIPITATION
SLUDGE
DEWATERING
SLUDGE TO
DISPOSAL
(IF APPLICABLE)
NOTE: CAST IRON 8UBCATEGORY GENERATES NO METAL PREPARATION WASTEWATER
FIGURE X-l. EXISTING SOURCES BAT OPTION A
-------
PORCELAIN ENAMELING
THE REGULATION - (CONTINUED)
PRETREATMENT
COMPLIANCE DATE
FOR EXISTING SOURCES NOVEMBER 25, 1985
FOR NEW SOURCES NOVEMBER 25, 1982
-------
PORCELAIN ENAMELING
THE REGULATION - (CONTINUED)
PRETREATMENT
PSES FOR THIS CATEGORY IS EXPRESSED AS A CONCENTRATION
STANDARD - WITH AN ALTERNATE MASS STANDARD
CONCENTRATION STANDARDS ARE USED BECAUSE THE BAT-PSES
FLOW IS ONLY SLIGHTLY REDUCED FROM BPT. (ABOUT 12%)
NSPS IS A MASS STANDARDS
CONCENTRATION STANDARDS ARE NOT APPROPRIATE FOR NEW
SOURCES BECAUSE SUBSTANTIAL POLLUTANT REDUCTION IS
ACHIEVED THROUGH FLOW REDUCTION
-------
PORCELAIN ENAMELING
THE REGULATION - (CONTINUED)
PRETREATMENT
DATA NEEDED TO DETERMINE COMPLIANCE WITH MASS STANDARDS
- MEASURED WASTEWATER FLOW
- POLLUTANT CONCENTRATION
POSSIBLE ALTERNATES -
- WATER USE RATE OR WATER METER
- POLLUTANT CONCENTRATION
-------
PORCELAIN ENAMELING
THE REGULATION - (CONTINUED)
PRETREATMENT
FOR MASS BASED PRETREATMENT STANDARDS
1. PRODUCTION RATE - BASED ON
A) PREVIOUS HISTORY - e.g. 5 YEAR AVERAGE
B) MAX MONTH PRODUCTION
C) NAME PLATE RATING
2. DISCHARGE STANDARD FROM REGULATION
3. DETERMINES DAILY MAX & MONTHLY AVERAGE DISCHARGE
-------
PORCELAIN ENAMELING
THE REGULATION - (CONTINUED)
NSPS - PSNS
FLOW FURTHER REDUCED BY REQUIRING COUNTERCURRENT
CASCADE RINSE IN CLEANING
FLOW METAL PREP COATING
STEEL 3.564 l/m2 0.6361/m2
CAST IRON 0.636 l/m2
ALUMINUM 3.473 l/m2 0.636 l/m2
END-OF-PIPE TREATMENT IS THE SAME AS BPT-BAT
PLUS POLISHING FILTRATION
-------
1 L _J L -I l_ J
..**... • w f L*^-x\^^w**fc^^-J
L*, J^.A^J! i^^^^^^n
PREPARATION -*~^^^-"^^-| |
r-niiMTirn r~itonr-MY niMitnt
OPERATIONS COUNTER CURRENT RINSES
! PROCESS
.BATCH
I DUMPS
1
1 METAL PREPARATION
WASTEWATER
CHEMICAL
ADDITION/^
CHROMIUM 1 >V
BEARING f /
WASTEWATER -*~A^*s^-*w»-
*"" CHROMIUM
REDUCTION
FR
Wl
E
*T
1
8»
El
' COATING WA8TEWATER RETURN TO PROCESS
1^
BACKWASH
CHEMICAL
ADDITION
l/>
\^J
^- / ^- SEDIMENTATION -^ i-BfcBy>tl"""«"'*K
CHEMICAL oeta REMOVAL HOLDING TANK Rj POLISHIN<» 5
PRECIPITATION AS NECESSARY | K£!£ZZ£,l°!&
*__ ~_* ^***ll^tj tJtW*p 1 • " "'
SLUDGE
1 ^ ( /J\ |/rfO 1 SLUDGE TO
RECYCLE \\ 1 Yl 1 DISPOSAL
\^-^/ 1 I
SLUDGE MBftMMra
(IF NECESSARY)
DISCHARGE
MOrt: CAST IRON SUBCATEOOftY GENERATES NO METAL PREPARATION WASTBWATER.
FIGURE XI-1. NEW SOURCES SELECTED OPTION
-------
PORCELAIN ENAMELING
THE REGULATION - (CONTINUED)
POLLUTANTS REGULATED
BPT BAT
Cr Cr
Pb Pb
Ni Ni
Zn Zn
Al Al
Fe Fe
O&G
TSS
pH
PSES
Cr
Pb
Ni
Zn
NSPS
Cr
Pb
Ni
Zn
Al
Fe
O&G
TSS
pH
PSNS
Cr
Pb
Ni
Zn
-------
PORCELAIN ENAMELING
THE REGULATION - (CONTINUED)
ONE DAY MAXIMUM AND MONTHLY AVERAGE
VALUES ARE PUBLISHED FOR EACH POLLUTANT
MONTHLY AVERAGE VALUE MUST BE USED FOR BOTH
DIRECT AND INDIRECT DISCHARGERS.
COMPLIANCE WITH MONTHLY VALUES IS REQUIRED
REGARDLESS OF NUMBER OF SAMPLES ANALYZED
AND AVERAGED.
-------
PORCELAIN ENAMELING
THE REGULATION - (CONTINUED)
PERIODIC ANALYSIS FOR CHROMIUM MAY BE REDUCED TO
ONCE ANNUALLY PROVIDING TWO CONDITIONS ARE MET.
1. FIRST SAMPLE TAKEN IN CALENDAR YEAR IS ANALYZED
AND CHROMIUM FOUND TO BE LESS THAN 0.08 mg/l.
2. THE OWNER OR OPERATOR CERTIFIES TO THE POTW OR
PERMIT ISSUING AUTHORITY THAT CHROMIUM IS NOT
USED IN THE PROCESS.
-------
PORCELAIN ENAMELING
POST PROMULGATION ISSUES
THE REGULATION IS BEING LITIGATED
INDUSTRY'S SPECIFIC COMPLAINTS ARE
NOT YET AVAILABLE
BRIEF DUE
-------
PORCELAIN ENAMELING
DEVELOPMENT DOCUMENT ORGANIZATION
THERE ARE 17 SECTIONS IN THE DOCUMENT.
SECTIONS I & II ARE A SUMMARY OF THE DOCUMENT
SECTIONS III & IV EXPLAIN THE TECHNOLOGY AND SUBCATEGORIZATION
SECTION V PRESENTS DATA COLLECTED
SECTION VI DISCUSSES POLLUTANTS
SECTION VII PRESENTS TECHNOLOGY AND PERFORMANCE
SECTION VIII PRESENTS COSTING METHODOLOGY
SECTION IX - XIII REGULATORY DEVELOPMENT
SECTION XIV - XVII - REFERENCE INFORMATION
------- |