EPA Self-Audit and Inspection Guide
Organic Finishing of Metals

Table of Contents

Definitions for Environmental Information

Air Pollution Control Equipment

Common air pollution control equipment includes two phases - particulate filtration and VOC control. Particulate filtration includes dry filters or waterwash curtains to capture large coating particles while allowing gases to pass freely. Proper filtration is required for VOC control equipment to work efficiently.

VOC control equipment includes recovery systems, solvent destruction systems, or concentrators. Recovery systems include carbon adsorption barrels that trap the VOC gases and release clean air. When the carbon is fully saturated, the contents are heated to vaporize the VOCs; the vapor is then condensed into a separate container for reuse or disposal. These methods are useful if the solvent is high-priced and if the airstream contains only a few solvent types that are compatible.

Solvent destruction systems are most popular. Destruction systems pull solvent-laden air into a chamber where it is heated. At the high temperature, the VOCs are converted to carbon dioxide and water. Systems can be regenerative, supplying heat back to the chamber to convert incoming air; or recuperative, recovering heat for other uses. These systems are most efficient when solvent concentrations are high.

Solvent concentration systems include rotary carbon adsorption or zeolite systems. Rotary carbon adsorption involves a slightly heated air stream passed through a rotating cylinder of carbon. The carbon strips the VOCs from the air stream. Zeolites are natural materials that can be formed to absorb selective molecules of VOCs. From either carbon or zeolite systems, the air with concentrated VOCs is then passed to a solvent destruction system.

Control technologies for NOx emissions from drying ovens include low NOx burners and air staging systems. NOx burners recirculate the emissions back to the combustion chamber. Air staging systems split the combustion air into two streams; the first stage air begins combustion and creates a reducing atmosphere, while the second stage completes combustion and creates an oxidizing atmosphere.

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was enacted in 1980 as a response to the public outcry over the problems at hazardous waste disposal sites. CERCLA provided EPA with a vehicle for responding to cleanup of hazardous waste contamination from accidental spills or from abandoned hazardous waste disposal sites.

Chlorofluorocarbons (CFCs)

Chlorofluorocarbons (CFCs) are compounds made from combinations of carbon, chlorine, and fluorine typically used as propellants, cleaners, or cooling agents. CFCs are non-toxic to workers, and are non-flammable. The compounds are very stable in the lower atmosphere and can persist for at least 100 years. When the molecules reach the upper atmosphere, they deplete the ozone layer. Manufacturing of CFCs has been banned in the US, and their use has been extremely restricted.

Conventional Pollutants

Conventional pollutants, as defined by the Clean Water Act, include biochemical oxygen demand (BOD), total suspended solids (TSS), fecal coliform, PH and oil and grease.

“Cradle-to-Grave”

“Cradle-to-grave” symbolizes the idea of analyzing the life cycle of a product from raw material extraction, manufacturing, use, and recycling or disposal. Cradle-to-grave analysis can provide a better assessment of a product's impact on the environment and indicate areas where pollution prevention opportunities should be investigated.

Criteria Pollutants

Under the National Ambient Air Quality Standards (NAAQS) regulations, the following compounds are considered to be criteria pollutants: particulate matter, nitrogen oxides, ozone, sulfur dioxides, carbon monoxide, and lead.

Effluent Guidelines and Standards

Effluent guidelines and standards are the basis for controlling the discharge of pollutants in wastewater, from industrial facilities to waters of the U.S., as well as from industrial facilities to POTWs. The EPA developed the industry-specific, technology-based standards to cover facilities performing similar operations that would use similar processes for treatment. Individual states may develop additional standards that would protect water quality in specific water bodies.

The technology-based and water quality based standards apply to facilities that discharge pollutants from point sources (i.e., direct discharges), such as pipes, tunnels, and other conduits, to waters of the U.S. Direct dischargers must obtain a National Pollutant Discharge Elimination System (NPDES) permit authorizing their discharges. The technology-based and water quality based standards form the basis of NPDES permit limitations of wastewater that a facility may discharge. Industrial facilities that discharge pollutants to publicly owned treatment works (POTWs), must meet certain pretreatment standards and are also known as indirect dischargers. These facilities may be required to obtain a permit from the POTW.

The national technology-based standards, or effluent limitations guidelines, establish a minimum level of treatment that is required for all dischargers in an industry category based upon the application of various control technologies. Over time, as technology to better treat wastewater is developed, the effluent guidelines may become stricter. Standards are different for both existing and new facilities, and for direct and indirect dischargers.

Existing facilities that are direct dischargers are required to comply with effluent limitations based on the best available technology economically achievable (BAT) for toxic and nonconventional pollutants. For conventional pollutants, the effluent limitations for existing facilities are based on best conventional pollutant control technology (BCT). New sources that are direct dischargers must comply with New Source Performance Standards (NSPS) which are based on the best available demonstrated control technology.

For indirect dischargers, categorical standards have been established. The Pretreatment Standards for Existing Sources (PSES) and Pretreatment Standards for New Sources (PSNS) are equivalent to BAT and NSPS, respectively, for direct dischargers.

Water quality based standards established by states are more stringent than the technology-based limitations. They are applicable to direct dischargers on a case-by-case basis when necessary to protect designated uses for a specified receiving water. Designated uses include drinking water supply, swimming, fishing, or navigation. In addition, the states must develop an anti-degradation policy so as to conserve, maintain, and protect existing uses and water quality of state waters, and to afford special protection to high quality or ecologically unique waters.

The states may designate allowable concentrations of 126 listed toxic pollutants in receiving water. States may also develop facility-specific Individual Control Strategies (ICSs) to reduce discharges of toxic pollutants to waterbodies impaired by point source discharges. Criteria for the water quality standards are to be developed from the latest scientific information on the concentrations and effects of specific pollutants on aquatic life and human health.

Emergency Response Plans

An emergency response plan is a guidance manual outlining the emergency response activities and notification processes that are to be followed in the event of an emergency at a facility. Facilities may be subject to Federal and State emergency response plan filing requirements. Facilities are encouraged to coordinate development of their emergency response plan with relevant State and local agencies to ensure compliance with any additional regulatory requirements at the State level.

Environmental Protection Agency (EPA)

The United States Environmental Protection Agency (EPA) was created to protect human health and to safeguard the natural environment. EPA is responsible for establishing guidelines and standards and enforcing environmental laws created by Congress.

Environmental Protection Agency (EPA) Authorized State Agency

An Authorized State Agency has been granted power by EPA to enforce Federal environmental regulations and oversee environmental activities within the State. States must demonstrate that their programs meet Federal requirements. Authorized State agencies oversee duties associated with non-hazardous solid waste management, permitting for air and water releases, and emergency planning.

Hazardous Air Pollutants (HAP)

Hazardous air pollutants (HAPs) are air toxics that pose a significant threat to human health and the environment. Common HAPs include benzene, toluene, formaldehyde, mercury, and polyaromatic hydrocarbons. The pollutants were first regulated by the 1970 Clean Air Act Amendments that instructed EPA to create a list of HAPs and then issue national emissions standards for those pollutants. Only eight substances were identified as HAPs, and only seven national emission standards for hazardous air pollutants (NESHAP) were promulgated by 1990.

Under the new Air Toxics program found in Title III of the Clean Air Act Amendments of 1990, Congress established an initial list of 189 substances to be regulated as HAPs. Rather than regulating individual pollutants by establishing health-based standards, the new Air Toxics program grants EPA the authority to regulate specific industrial major source categories with NESHAP based on maximum achievable control technology (MACT) for each source category. Sources not large enough to fall under the major source requirements may still be regulated under the “area” source requirements that will affect many small and mid-sized businesses and facilities. NESHAP and appropriate MACT standards are enforced through the Clean Air Act Title V Operating Permit Program.

Major sources subject to NESHAP are defined as those facilities emitting, or having the potential to emit, 10 tons per year or more of one HAP or 25 tons per year or more of multiple HAPs. Major sources are required to comply with MACT standards. Area sources are defined as non-major facilities that emit HAPs; categories that represent 90 percent of area sources that emit the 30 most hazardous HAPs are first to be targeted. Area sources must comply with either MACT or the less stringent, generally available control technology (GACT).

Each facility in a given source category must achieve a designated minimum level of emissions reduction. This level is called the MACT Floor and is a technology-based standard, rather than health-based. The overall objective of the MACT standard is to achieve the maximum degree of emissions reduction without unreasonable economic or other impacts. MACT Floors are different for new and existing facilities. New facilities must achieve at least the emissions limitation of the best-controlled similar source. Existing sources must meet the average emissions limitation achieved by a percentage of the best performing sources in their category. After the MACT standards have been applied to a source category, EPA will evaluate the remaining risk and may promulgate additional health-based standards to further reduce HAP emissions.

Hydrochlorofluorocarbons (HCFC)

Hydrochlorofluorocarbons (HCFC) are compounds made from carbon, chlorine, fluorine, and hydrogen commonly used as replacements for chlorofluorocarbons (CFC). While the compounds provide similar propellant, cleaning, and cooling capabilities as CFCs, they are slightly less damaging to the ozone layer.

Heavy Metals

Heavy metals include mercury, lead, cadmium, and zinc. These materials may be found in some coating material formulations, surface preparation solutions, or as part of substrates. Concentrations of these materials are limited in wastewater by the National Pollutant Discharge Emissions Standards. The metals may enter wastewater discharges as a result of phosphatizing rinses or from wet blasting of coatings materials.

Listed and Characteristic Hazardous Wastes

Characteristic hazardous wastes are materials that exhibit toxicity, reactivity, ignitability, and/or corrosivity. Materials with these characteristics have been found to cause or contribute to an increase in mortality or serious illness, or pose a hazard to human health or the environment when improperly treated, stored, transported, disposed or otherwise managed.

Listed hazardous wastes are materials specifically identified as hazardous because they have exhibited characteristics of hazardous wastes, have been found to be fatal to humans or to test animals, or contain toxic, carcinogenic, mutagenic, or teratogenic constituents. Both individual materials and categories of materials are listed as hazardous.

Local Emergency Planning Committees (LEPCs)

Local Emergency Planning Committees (LEPC) are appointed by State Emergency Response Commissions (SERC) to prepare for and respond to local emergencies regarding environmental issues, such as a hazardous spill or release. Each State can have numerous LEPCs to help better serve the areas of the State.

Major Source

Different regulatory programs under the Clean Air Act have different definitions for a major source and should be referred to when determining applicability: the New Source Review Program (40CFR51.165), the Prevention of Significant Deterioration Program (40CFR52.21), the National Emission Standards for Hazardous Air Pollutatnts (40CFR63.2), and the State Operating Permit Program (40CFR70.2). Major sources for purposes of the Air Toxics program are defined as those facilities emitting, or having the potential to emit, 10 tons per year or more of one hazardous air pollutants (HAPs) or 25 tons per year or more of multiple HAPs.

Material Safety Data Sheets (MSDS)

Material Safety Data Sheets (MSDS) are informational fact sheets developed for each commercially available chemical, compound, or substance. MSDSs provide general product information, physical components and characteristics of the product, health risk information, fire and explosion warnings, product reactivity data, spill and disposal procedures, storage and handling issues, and personal protective equipment suggested when working with the material. MSDSs are to be made easily accessible to employees working with chemical substances and to surrounding communities.

Maximum Achievable Control Technologies (MACT)

Maximum Achievable Control Technologies (MACT) are technologies used for hazardous air pollutant abatement. These technologies thus establish the minimum level of emissions reduction that facilities within a specific category must achieve.

Maximum Concentration Limit (MCL)

The maximum concentration limit (MCL) determines the maximum amount of a specific pollutant permitted to be released in wastewater streams. MCLs have been established for daily (eight-hour) and monthly average releases of such pollutants as heavy metals, total toxic organics, and conventional pollutants.

National Ambient Air Quality Standards (NAAQS)

National Ambient Air Quality Standards (NAAQS) establish maximum concentrations for criteria air pollutants in specified geographical areas. These pollutants include carbon monoxide (CO), lead (Pb), nitrogen dioxide (NO2), particulate matter (PM-10), ozone (O3), and sulfur dioxide (SO2). To prevent established concentrations from being exceeded, State and local governments may require air pollution controls on existing, new, and modified industrial facilities; tighter standards on emissions from motor vehicles; and the use of alternative fuels.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

National Emission Standards for Hazardous Air Pollutants (NESHAP) establish limits on emissions of hazardous air pollutants. NESHAPs are being developed based on industry categories and target the HAPs mostly likely present in these industry processes.

National Pollutant Discharge Elimination System (NPDES) Permits

National Pollutant Discharge Elimination System (NPDES) Permits limit discharges of pollutants into water from point sources. Industrial dischargers must obtain permits prior to releasing wastewater into receiving waters.

New Source Performance Standards (NSPS)

New Source Performance Standards (NSPS) under the Clean Water Act are limitations on water pollutants discharged from recently constructed facilities. The standards are based on the Best Available Demonstrated Control Technology. Facilities may choose the type of wastewater treatment system that best suit their needs as long as it meets the same cleaning ability of the best available control technology.

New Source Performance Standards under the Clean Air Act are nationally uniform emission standards for new stationary sources falling within particular industrial categories. NSPSs are based on the pollution control technology available to that category of industrial source but allow the affected industries the flexibility to devise a cost-effective means of reducing emissions. NSPSs are currently in place for the following industries that perform organic surface coating: (1) metal furniture manufacturing; (2) automobiles and light-duty trucks; (3) large appliances; (4) sheet metal rolls and coils; and, (5) beverage cans.

Non-Conventional Pollutants

Non-conventional pollutants under the Clean Water Act are defined as any pollutants not classified as either toxic or conventional pollutants. EPA included this classification to account for developments in industry and the changing characterization of possible water pollutants.

NOx

NOx are emissions of nitrogen oxides typically created during the combustion of fuels during dry-off and curing stages of organic finishing.

Ozone-Depleting Substances

Ozone-depleting substances (ODSs) are chemical compounds that harmfully react with ozone to transform ozone into oxygen. The most common ODSs are chlorofluorocarbons (CFCs). These compounds transform ozone into oxygen while continuously recycling chlorine within the atmosphere. The constant supply of chlorine in the atmosphere supports additional ozone depleting reactions.

Occupational Safety and Health Administration (OSHA)

The Occupational Safety and Health Administration (OSHA) is charged with promoting and protecting employee health, safety, and awareness. The mission of the OSHA is to save lives, prevent injuries and protect the health of America's workers. OSHA inspects facilities for violations of health and safety, and investigates employee complaints of violations.

Point Source Pollutants

Point source pollutants are direct wastewater discharges into national water sources, such as rivers, lakes, and streams. Common discharge sources of point source pollutants are pipes, ditches, channels, and sewer deposits.

Publicly Owned Treatment Works (POTWs)

Publicly Owned Treatment Works (POTWs) are treatment works owned by a State, unit of local government, or Indian tribe, usually designed to treat domestic wastewaters. POTWs are required to demonstrate that industrial sources of toxic pollutants are in compliance with all of their pretreatment requirements, including local limits.

Priority Pollutants

Priority pollutants are hazardous or radioactive organic and inorganic chemicals present in an environmental setting, such as air, water, or vegetation. These pollutants were identified by EPA as indicators of environmental contamination.

Pretreatment

Pretreatment refers to reducing the amount of a pollutant, eliminating a pollutant, or altering the nature of a pollutant in wastewater before it is introduced into publicly owned treatment works (POTW). Under Title III of the federal Clean Water Act (CWA), the EPA is required to establish pretreatment standards that must be met by industrial facilities before they discharge wastewater to publicly owned treatment works. Pretreatment standards target those pollutants that would interfere with a POTW's operation, would not be susceptible to treatment by a POTW, or would adversely impact POTW equipment and personnel.

POTWs are commonly referred to as municipal sewer systems. POTWs store, treat, recycle, and reclaim municipal sewage and industrial wastes of a liquid nature, and are required to have an National Pollutant Discharge Elimination System (NPDES) permit to discharge water from their systems directly to creeks, rivers, or other waters. A NPDES permit regulates the quality and quantity of water the POTW may discharge from its system. Facilities that discharge wastewater to POTWs are known as “indirect” dischargers; these facilities are not generally required to obtain an NPDES permit for such discharges but are usually required to obtain a permit from the local POTW. This permit will outline effluent limitations in terms of volume and concentration of pollutants thus defining the pretreatment necessary for the facility to perform. Facilities that discharge wastewater directly to streams, creeks, or other bodies of water are called “direct” dischargers; these facilities are required to obtain an NPDES permit for such discharges

Pretreatment programs are established on both the national and local level. Restrictions have been placed substances in three categories: prohibited discharges, national categorical pretreatment standards and local pollutant limits. An individual industrial facility may be subject to some or all of these restrictions.

Certain wastewater discharges are prohibited for all industrial facilities that discharge to POTWs because of the potential hazards these discharges create. Specific prohibited discharges include:

• pollutants that would create a fire or explosion
• pollutants that would cause corrosive structural damage to a POTW
• solid or viscous pollutants that would obstruct flow in a POTW
• pollutants that result in toxic gases, vapors, and fumes
• ignitable wastes
• oil and grease

Local pollutant limits protect against improper treatment at a POTW. These limits prevent industrial pollutants from flowing through a POTW without receiving adequate treatment that would cause the POTW to violate its NPDES permit. Pollutants that would inhibit or disrupt the POTW operation and result in a violation of a POTW's NPDES permit are also restricted. Local limits are decided based on the equipment and treatment facilities available at the POTW. Local limits are often reflected in agreements between the POTW and individual industrial users. Such agreements are effectively POTW use permits.

Some facilities may qualify for removal credits from authorized POTWs. The credits allow industrial users to increase the amounts of pollutants they discharge to the POTW when the POTW is capable of treating and removing the pollutant. The POTW treatment system must consistently and effectively remove the pollutant through normal operations. Removal credits are only available for facilities covered by national categorical pretreatment standards.

Particulate Matter

Particulate matter (PM) is the term used for a mixture of solid particles and liquid droplets found in the air. While individual particles can not be seen with the naked eye, collectively they can appear as black soot, dust clouds, or gray hazes. Particles originate from a variety of sources in organic coating facilities, most often exhaust from drying ovens.

The characteristics, sources, and potential health effects of larger or “coarse” particles and smaller or “fine” particles are very different. Fine particles are those particles that are less than 2.5 microns in diameter. Fine particles result from fuel combustion. Fine particles can also be formed in the atmosphere from gases such as sulfur dioxide, nitrogen oxides, and volatile organic compounds. Coarse particles are those particles larger than 2.5 microns. Coarse particles are generally emitted as dust from sources such as the desert, fields, vehicles traveling on unpaved roads, and crushing and grinding operations.

Reasonably Available Control Technology (RACT)

Reasonably available control technology (RACT) are air emission control technologies that meet requirements for emission standards and are also technically and economically feasible. RACT requirements apply to stationary sources in ozone nonattainment areas and throughout an ozone transport region.

Receiving Water

Rivers, lakes, oceans or other water courses that receive treated or untreated waste waters.

Superfund Amendments and Reauthorization Act (SARA)

The Superfund Amendments and Reauthorization Act (SARA) amended the Resource Conservation and Recovery Act and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Under SARA, remedial actions of facilities were strengthened to include reporting of on-site spills and releases.

SARA also includes the regulation more commonly referred to as the Emergency Planning and Community Right-to-Know Act (EPCRA). This Act requires planning and reporting on listed toxic chemicals to provide the public, as well as EPA, with information on the storage and release of these chemicals in their communities. EPCRA is generally recognized as a separate statute independent of other issues contained in SARA.

State Emergency Response Commissions (SERCs)

State Emergency Response Commissions (SERCs) are responsible for coordinating emergency response activities within the State. By appointing local emergency planning committees (LEPCs), the SERCs have the ability to serve numerous areas within their State.

Standard Industry Classification (SIC) Codes

Standard Industry Classification (SIC) Codes designate industry categories for commercial, government, and independently owned businesses. The number groupings reflect the type of business, or the type of process or service provided by the classified businesses. SIC codes range from 0110 to 9999. Fabricated metal products, which includes surface coating operations, are listed under SIC code 3400, while metal coating and allied services are listed more specifically as SIC code 3479.

State Implementation Plan (SIP)

State Implementation Plans (SIP) are vehicles for implementing regulations to comply with the Clean Air Act. SIPs identify sources of air pollution and determine required reductions to meet and maintain the national ambient air quality standards (NAAQS). In developing a SIP, each State is first divided into air quality control regions, typically consisting of several counties or a metro area and surrounding counties. Then the State determines, through statistical data, whether or not, and by how much, air pollution in each region exceeds the limits for each air quality standard. Control requirements are imposed to reduce emissions from the various sources in each area to achieve compliance. Each State is responsible for creating its own SIP that must be approved by EPA before becoming federally enforceable.

Suspended Solids

Suspended solids are small particles of solid pollutants that float on the surface of, or are suspended in, sewage or other liquids.

Title V Permitting

Title V permitting is the mechanism by which EPA integrates all of the federally applicable requirements of the Clean Air Act designed to reduce emissions of air toxics, improve and maintain air quality, meet new source requirements, and control the precursors of acid rain. The operating permit program is administered by states under federally approved programs. A facility's operating permit will indicate the emissions standards and operation limitations that it must follow in order to stay in compliance.

Toxic Pollutants

Toxic pollutants are those priority pollutants identified by EPA that display toxic, hazardous characteristics.

Toxic Organics

Toxic organic chemicals include a variety of chemicals, such as polychlorinated biphenyls (PCB) and dioxin, which are considered to be severely damaging to human health, wildlife, and aquatic species. The toxic organics are persistent in the environment, remaining chemically reactive for long periods. The materials can accumulate in animal and fish tissue, be absorbed in sediments, or find their way into drinking water supplies, posing long-term health risks to humans. Toxic organics originate from industrial discharges, including wastewater from organic finishing facilities. The total toxic organics in wastestreams are regulated by facility NPDES permits.

Toxic Release Inventory

The Toxic Release Inventory (TRI) is a compilation of chemical procurement and release data from manufacturing facilities in the US. TRI reports are required for facilities with more than 10 full-time equivalent employees and that use more than 1,000 pounds of a listed substance annually. Facilities are required to report hazardous, toxic, and ozone-depleting chemicals used, and the amount of each released to the air, publicly owned treatment works, receiving waters, landfills, and other disposal facilities. EPA maintains a database of records for public record.

Volatile Organic Compounds (VOC)

Volatile organic compounds (VOCs) include a variety of chemicals, such as formaldehyde, benzene, and perchloroethylene, that have relatively low vapor pressures. VOCs are emitted as gases from liquid coating materials containing organic solvents. VOC exposures can cause serious health problems, and contribute to smog by promoting the creation of ground level ozone. The VOC content of a coating material is typically represented as the proportion of the coating that is VOCs, expressed as kilograms VOC per liter of solids.

Pursuant to Title I of the Clean Air Act, national ambient air quality standards (NAAQS) have been established for ozone. Thus, VOC emission sources located in ozone nonattainment areas are subject to reduction. In addition, VOC emission sources located in ozone attainment areas must maintain the established standards.

Major sources in ozone nonattainment areas are required to meet thresholds for VOC emissions. In areas where ozone nonattainment is severe, major sources may not emit more than 25 tons per year, those in areas where ozone nonattainment is moderate to marginal may not emit more than 100 tons per year. Existing sources in the various areas are required to control any increase in emissions, and in most cases are required to achieve a continual decrease in VOC emissions. In areas where ozone is a moderate to severe problem, all major sources must implement reasonably available control technology (RACT) standards, which are the technology and pollution controls that are most reasonably available and economically feasible to achieve the lowest emission limit. In some cases, areas with severe or extreme problems with ozone may require facilities to install best available control technology (BACT) for control of VOC emissions. BACT must be used regardless of the economic feasibility.

New major sources or proposed expansion of existing major sources are required to comply with new source review (NSR) provisions so that ozone conditions do not grow worse. In nonattainment areas, facilities must offset the new emission source by removing or reducing a greater amount of emissions from another source or elsewhere on the same source and must achieve the lowest achievable emission rate (LAER). In attainment areas, facilities must install best available control technology (BACT).

189 HAPs