United States '
 Environmental Protection
 .Agency .'•..•: '  ".. > ;
Effluent Guidelines Division
WH-552
Washington DC 20460
EPA 440/1-82/024

May 1982 '
 Water and Waste Management
tDevelopnhiiiit
 Document Jfbi4
 Effluent Limitations
                Final
 Ma nuf adtiiri hg

 Point  Soitfcl Category
 Volume II
 Coke  IVId
 Sintering
               il
                     jett.george@epa.gov
            George M. Jett
             Chemical Engineer
          U.S. Environmental Protection Agency
          Engineering and Analysis Division (4303)
           1200 Pennsylvania Avenue, NW '
            Washington, D.C. 20460

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           DEVELOPMENT DOCUMENT

                   for

     EFFLUENT LIMITATIONS GUIDELINES

     NEW SOURCE  PERFORMANCE  STANDARDS

                    and

          PRETREATMENT STANDARDS

                 for the

       IRON AND  STEEL  MANUFACTURING
          POINT SOURCE CATEGORY

             Anne M. Gorsuch
              Administrator

         •    Steven Sohatzow
                 Director
Office .of Water Regulations and Standards
                         \
                          UI
                          (3
      Jeffery Denit,  Acting  Director
       Effluent  Guidelines Division

           Ernst P. Hall, P.E.
     Chief, Metals  & Machinery Branch

         Edward L. Dulaney,  P.E.
         Senior Project  Officer
                May, 1982
       Effluent  Guidelines  Division
Office of Water Regulations and.Standards
   U.S.- Environmental  Protection Agency
         .Washington,  D.C.  20460

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SECTION

I

II

III
IV
VI
VII
VIII
         COKEMAKING SUBCATEGORY

           TABLE OF CONTENTS

                SUBJECT                .         PAGE

PREFACE                       .                     1

CONCLUSIONS                                        3

INTRODUCTION                                      15

General                                           15
Data Collection Activities                        15
Description of Cokemaking Operations              16

SUBCATEGORIZATION                                 29

introduction                                      29
Factors Considered in Subcategorization           29

WATER USE AND WASTE CHARACTERIZATION              39

Introduction                                      39
Description of Wastewater Sources                 39

WASTEWATER POLLUTANTS                             61

Introduction                                      61
Conventional Pollutants                           61
Toxic Pollutants                                  61
Other Pollutants                                  63

CONTROL AND TREATMENT TECHNOLOGY                  69

Introduction                                      69
Summary of Treatment Practices Currently          69
     Employed
Control and Treatment Technologies                75
Plant Visits                                      76
Summary of Monitoring Data                        79
Effect of Make-up Water Quality                   80

COST, ENERGY AND NON-WATER QUALITY IMPACTS       107

Introduction                                     107
Comparison of Industry Costs and EPA             107
     Model Costs
Control and Treatment Technologies Considered    108
     for Use in Cokemaking Operations
Treatment Costs                                  108
Summary of Pollutant Load Reductions             111
Energy Requirements Due to Installation          112
     of Recommended Technologies •

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                        COKEMAKING SUBCATEGORY

                    TABLE OF CONTENTS (Continued)
 SECTION
IX
X
XI


XII
XIII
                 SUBJECT                         PAGE

Non-water Quality Impacts                        112
Costs of Retrofit to Existing Systems            113
Water Consumption                                114
Summary of Impacts                               115

EFFLUENT QUALITY ATTAINABLE THROUGH THE          147
     APPLICATION OF THE BEST PRACTICABLE
     CONTROL TECHNOLOGY CURRENTLY AVAILABLE

Introduction                                     147
Identification of BPT                 .           147
Basis for BPT Limitations                        148
Justification for BPT Effluent Limitations       150

EFFLUENT QUALITY ATTAINABLE THROUGH THE          163
     APPLICATION OF THE BEST AVAILABLE
     TECHNOLOGY ECONOMICALLY ACHIEVABLE

Introduction                                     163
Model BAT Flow                                   164
Identification of BAT Alternatives               164
Selection of a BAT Alternative          .         165
Control and Treatment of Pollutants              166
     Us.ing BAT Technology
Justification for BAT Effluent Limitations       170

BEST CONVENTIONAL POLLUTION CONTROL              179
     TECHNOLOGY

EFFLUENT QUALITY ATTAINABLE THROUGH THE          181
     APPLICATION OF NEW SOURCE PERFORMANCE
     STANDARDS

Introduction                                     181
Identification of NSPS Technology                182
Flow Basis for All NSPS Alternatives             183
Response to Court Remand of NSPS Model           183
     Flow
New Source Performance Standards (NSPS)          184

PRETREATMENT STANDARDS FOR BY-PRODUCT            189
     COKE PLANTS DISCHARGING TO POTWS

Introduction                                     189
General Pretreatment Standards                   189
Pretreatment Considerations for            •      191
     Cokemakihg
Selection of PSES and  PSNS                       192

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NUMBER

II-l



II-2



II-3



II-4



II-5




II-6



II-7


III-l

111-2

III-3


III-4

IV-1


V-1  to
V-10

V-1 1

VI-1
         COKEMAKING SUBCATEGORY

                 TABLES               ,

                 TITLE                          PAGE

BPT/BCT Model Flow, Model Effluent                 7
     Quality and Effluent Limitations - Iron
     & Steel Plants

BPT/BCT Model Flow, Model Effluent Quality.        8
     and Effluent Limitations - Merchant
     Plants

BAT and NSPS Model Flow, Model Effluent            9
     Quality and Effluent Limitations and
     Standards — Iron & Steel Plants

BAT and NSPS Model Flow, Model Effluent           10
     Quality and Effluent Limitations and
     Standards - Merchant Plants

BAT Model Flow, Model Effluent Quality and        11
     Effluent Limitations Iron & Steel and
     Merchant Plants - Physical/Chemical
     Treatment

PSES/PSNS Model Flow, Model Effluent Quality      12
     and Effluent Standards - Iron & Steel
     Plants                                       .

PSES/PSNS Model Flow, Model Effluent Quality      13
     and Effluent Standards — Merchant Plants

By-Product Cokemaking Data Base                   19

Beehive Cokemaking Operations                     20

Coal Chemicals Produced at By-Product             21
     Recovery Plants

General Summary Table                             22

Examples of Plants with Retrofitted Pollution     36
     Control Equipment

Summaries of Analytical Data from Sampled         45
     Plants: Net Raw Concentrations

Summary of Process Wastewater Flow Rates          58

Toxic Pollutants Known to be Present              65

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                        COKEMAKING SUBCATEGORY

                          TABLES (Continued)
 NUMBER

VI-2


VI-3

VII-1


VI1-2 to
VII-4

VII-5

VII-6

VIII-1 and
VIII-2

VIII-3


VIII-4


VIII-5

VIII-6 to
VIII-8

VIII-9

VIII-  10

VIII-11

VIII-12

VIII-13


 IX-1

 IX-2

 IX-3
                  TITLE

Phthalates Found in By-Product Cokemaking
     Samples

Selected Wastewater Pollutants

List of Control and Treatment Technology
     (C&TT) Components and Abbreviations

Summaries of Analytical Data from Sampled
     Plants: Raw Wastewaters and Effluents

Summary of Long-Term Data

Effect of Make-up Water Quality

Effluent Treatment Cost Tables


Comparison of Model Costs vs. Actual
     Plant - Reported Costs

Model Control and Treatment Technology
     Summary

BPT Treatment Model Costs

BAT Treatment Model Costs


NSPS Treatment  Model Costs

PSES/PSNS  Treatment Model Costs

Industry-Wide Cost Summary

BAT Energy Requirement  Summary

BPT, BAT  and PSES  Solid Waste
     Generation Summary

BPT Effluent Limitations

BPT Model  Flow  Rates

Development of  BPT Model  Effluent
     Flow Rates
PAGE

 66


 67

 82


 87


 92

 93

 116


 1 18


 1 19


 126

 130


 134

138

 141

 142

 143


 152

 153

 154
                                 IV

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                        COKEMAKING  SUBCATEGORY
                          TABLES  (Continued)
 NUMBER
IX-4
X-1
X-2

X-3
X-4

X-5
XI I-1

XII-2
XII-3
XIII-1

XIII-2
                  TITLE
•Justification of BPT Limitations
BAT Model Flow Rates
Development of BAT Model Effluent
     Flow Rates
BAT Effluent Limitations
Impact of Selected BAT Technologies
     on Toxic Pollutants
Justification of BAT Limitations
Effluent Quality for NSPS Model
     Treatment Systems
New Source Performance Standards
Justification of NSPS
Effluent Quality for Pretreatment
     Alternatives
PSES/PSNS Effluent Limitations
PAGE
158
171
172

173
174

176
185

186
187
193

194

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                        COKEMAKING SUBCATEGORY
                               FIGURES
NUMBER


III-l to
.111-4

IV-1 and
IV-2

VII-1 to
VII-12

VIII-1

VIII-2


IX-1 to
IX-3

X-l  and
X-2

XII-1

XIII-1
                                TITLE
Process Flow Diagrams
          *
Discharge Flow Versus Size and
     Age Plots

Treatment System Diagrams of
     Sampled Plants

PSES and BPT Treatment Models

BAT and Advanced PSES/NSPS/PSNS
     Treatment Models

BPT Treatment Models
BAT Treatment Models


NSPS  Treatment  Model

PSES/PSNS  Treatment Model
PAGE


   25


   37


   94


  144

  145


  160


•  177


  188

  195
                                 vn

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SECTION

I

II

III
IV
V
VI
VII
VIII
         SINTERING SUBCATEGORY

           TABLE OF CONTENTS

                SUBJECT           .              PAGE

PREFACE                                          197

CONCLUSIONS                                      199

INTRODUCTION                                     205

Discussion                                       205
Description of the Sintering Process             205
Data Collection Activities                       206

SUBCATEGORIZATION          '                     217

Factors Considered in Subcategorization          217

WATER USE AND WASTEWATER CHARACTERIZATION        227

Introduction                                     227
Description of Sinter Plant Wastewater           227
     Sources

WASTEWATER POLLUTANTS                            231

Introduction                                     231
Rationale for Selection of Pollutants            23  1

CONTROL AND TREATMENT TECHNOLOGY                 235

Introduction                                     235
Control and Treatment Technology                 235
Control and Treatment Technologies               236
     Considered for Toxic Pollutant
     Removal
Plant Visit Analytical Data      '                240
Plant Visits                                     240
Effect of Make-up  Water Quality                  241

COST, ENERGY, AND  NON-WATER QUALITY  IMPACTS      259

Introduction                                     259
Actual Costs  Incurred by  the  Plants              259
     Sampled  or Solicited for this Study
Recommended Control and Treatment Technol-       260
     ogies
Cost, Energy  and Non-water  Quality Impacts       260
Estimated Costs for the Installation of          261
     Pollution Control Technologies
Energy Impacts                          .         262

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                        SINTERING SUBCATEGORY

                    TABLE OF CONTENTS (Continued)
 SECTION
IX
XI

XII
XIII
                 SUBJECT       '                  PAGE

Non-Water Quality Impacts                        264
Summary of Impacts                               265

EFFLUENT QUALITY ATTAINABLE THROUGH THE          275
APPLICATION OF THE BEST PRACTICABLE
CONTROL TECHNOLOGY CURRENTLY AVAILABLE

Identification of BPT                       f     275
Rationale .for BPT                                276
Justification of the BPT Effluent Limita-        277
     tions

EFFLUENT QUALITY ATTAINABLE THROUGH THE          281
APPLICATION OF THE BEST AVAILABLE TECHNOLOGY
ECONOMICALLY ACHIEVABLE

Introduction                                     281
Identification of BAT                            281
Rationale for the Selection of BAT               282
Effluent Limitations for the BAT Alterna-        283
     tives
Selection of a BAT Alternative                   284

BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY   291
EFFLUENT QUALITY ATTAINABLE THROUGH THE
APPLICATION OF NEW SOURCE PERFORMANCE
STANDARDS

Introduction
Identification and Basis for NSPS Treatment
     Scheme and Flow Rates
Rationale for Selection of NSPS
Selection of an NSPS Alternative
Justification of NSPS

PRETREATMENT STANDARDS FOR DISCHARGES TO
PUBLICLY OWNED TREATMENT WORKS

Introduction
General Pretreatment Standards
Identification of Pretreatment Alternatives
Selection of a Pretreatment Alternative
293
293
293

294
294
295

299
                                                                299
                                                                299
                                                                299
                                                                300

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 NUMBER

 II-l


 II-2



 III-l -

 III-2

 III-3

 IV-1

 IV-2


 V-l



 VI-1

 VI-2

.VII-1


 VII-2


 VII-3


 VI1-4


 VII-5


 VII-6

 VIII-1

 VIII-2
       .  SINTERING SUBCATEGORY

                . TABLES

                 TITLE        .                ' PAGE

BPT Model Flow, Model Effluent Quality,           203
     and Effluent Limitations

BAT/BCT/NSPS/PSES/PSNS Model Flow, Model          204
     Effluent Quality and Effluent
     Limitations and Standards

General Summary Table                             208

Data Base Summary                                 211

Rated Production Capacity Table                   212

Raw Materials Summary   "                          220

Examples of Plants with Retrofitted               221
     Pollution Control Equipment

Summary of Analytical Data from Sampled           229
     Plants:  Original Guidelines and
     Toxic Pollutant Surveys

Toxic Pollutants Known to be Present              233

Selected Pollutants                               234

Summary of Data for Operations Discharging        243
     to Central Treatment Facilities

List of Control and Treatment Technology          244
     (C&TT) Components and Abbreviations

Summary of Analytical Data from Sampled           249
     Plants:  Raw Wastewaters

Summary of Analytical Data from Sampled           250
     Plants:  Effluents

Summary of Long-Term Effluent Analytical          251
     Data

Net Concentration and Lo.ad Analysis               252

Effluent Treatment Costs                          267

Model Control and Treatment Technologies          268
                                 XI

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  NUMBER

VIII-3

VII1-4

VIII-5

IX-1

IX-2

X-l to
X-2

X-3

X-4

XII-1

XII-2

XIII-1
         SINTERING SUBCATEGORY

           TABLES (Continued)


                   TITLE

BPT Treatment Model Costs

BAT/PSES Treatment Model Costs   .,

PSNS/NSPS Treatment Model Costs

BPT Flow Summary and Justification

Justification of BPT Effluent Limitations

Pilot Treatability Study Data Analysis
     Tables

BAT Effluent limitations

Justification of BAT Effluent Limitations

New Source Performance Standards (NSPS)

Justification of NSPS

Pr'etreatment Standards (Existing and New
     Sources)
PAGE

270

271

272

278

279

285


287

288

296

297

301
                                XI 1

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NUMBER


III-l to
III-3

IV-1 to
IV-4

VII-1 to
VII-6

VIII-1

IX-1

X-l

XII-1

XIII-1
    SINTERING SUBCATEGORY


           FIGURES


            TITLE


Process Flow diagrams


Discharge Flow Versus Size and Age
     Plots

Treatment System Diagrams of Sampled
     Plants

BPT/PSES/PSNS/NSPS Treatment Models

BPT Treatment Model

BAT Treatment Model

NSPS Treatment Model

PSES/PSNS Treatment Model
PAGE


213


222


253


274

280

289

298

302
                                xm

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SECTION

I

II

III
IV
V
VI
VII
VIII
         IRONMAKING SUBCATEGORY

           TABLE OF CONTENTS

                SUBJECT                         PAGE

PREFACE                         •                 303

CONCLUSIONS                                      305

INTRODUCTION     .                                311

General Discussion        .                       311
Data Collection Activities                       311
Description of the Blast Furnace Process         312
Description of Wastewater Treatment              313

SUBCATEGORIZATION                                329

Introduction                      '               329
Factors Considered in Subdivision                329

WATER USE AND WASTEWATER CHARACTERIZATION        337

Introduction                                     337
Description 'of the Ironmaking Operation and      337
     Wastewater Sources

WASTEWATER POLLUTANTS              /             343

Introduction                                     343
Conventional Pollutants                          343
Nonconventional, Nontoxic Pollutants             343
Toxic Pollutants                                 343

CONTROL AND TREATMENT TECHNOLOGY                 347

Introduction                                     347
Control and Treatment Technologies       '        347
Control and Treatment Technologies for BAT,      349
     NSPS, PSES, and PSNS
Plant Visit Data                                 352
Plant Visits                                     353
Effect of Make-up Water Quality                  355

COST, ENERGY, AND NON-WATER QUALITY IMPACTS      383

Introduction                                     383
Comparison of Industry Costs and EPA Model       383
     Costs
Control and Treatment Technologies in Use or     385
     Available to Blast Furnace Operations
                                 xv

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                        IRONMAKING SUBCATEGORY

                    TABLE OF CONTENTS (Continued)
 SECTION
IX
XI

XII
XIII
                 SUBJECT

Estimated Costs for the Installation of
     Pollution Control Technologies
Energy Impacts
Non-water Quality Impacts
Summary of Impacts

EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLI-
CATION OF THE BEST PRACTICABLE CONTROL
TECHNOLOGY CURRENTLY AVAILABLE

Identification of BPT
Selection of BPT Limitations

EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLI-
CATION OF THE BEST AVAILABLE TECHNOLOGY
ECONOMICALLY ACHIEVABLE

Introduction
Identification of BAT
Rationale for the Selection of BAT
Effluent Limitations for the BAT Alternatives
Selection of a BAT Alternative
388
390
392

403
                                                                403
                                                                404

                                                                411
                                                                41 1
                                                                41 1
                                                                413
                                                                417
                                                                417
BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY   423

EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLI-   425
CATION OF NEW SOURCE PERFORMANCE STANDARDS

Introduction                                     425
Identification of NSPS                       •    425
Rationale for Selection of NSPS                  426
Selection of an NSPS Alternative                 426

PRETREATMENT STANDARDS FOR DISCHARGES TO         431
PUBLICLY OWNED TREATMENT WORKS

Introduction                                     431
General Pretreatment Standards                   431
Identification of Pretreatment Alternatives      431
Selection of Pretreatment Alternatives           432
                                xvi

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NUMBER
II-l

11-2

III-l and
111-2
111-3
III-4
IV-1

V-l  to
V-4
VI-1,
VI-2
VII-1

VII-2 to
VII-6
VII-7
VI1-8 and
VI1-9
VII-10
VII-11

VII-12
VIII-1 and
VI11-2
VIII-3
VI11-4
         IRONMAKING SUBCATEGORY
               '  TABLES
                 TITLE                          PAGE
BPT Model Flow, Model Effluent Quality           309
     and Effluent Limitations
Model Flow, Model Effluent Quality, and        .  310
     Effluent Limitations and Standards
General Summary Tables                           314

Data Base                                        321
Ironmaking Furnace Production                    322
Examples of Plants with Retrofitted              333
     Pollution Control Equipment
Summary of Analytical Data from Sampled          339
     Plants - Net Raw Concentrations
Toxic Pollutants Known to be Present         .    345
Selected Pollutants                              346
List of Control and Treatment Technology         356
     (C&TT) Components and Abbreviations
Summary of Analytical Data from Sampled          361
     Plants: Raw Wastewaters and Effluents
Summary of D-DCP Analytical Data                 366
Plant 0860B Pilot Plant Treatability Study       368

Plant 0860B Blast Furnace System Blowdown        370
Plant 0860B Chlorination Activated Carbon        371
     Treatment Facility Effluent
Net Concentration and Load Analysis              372
Effluent Treatment Costs                         394

Control and Treatment Technologies               397
BPT Treatment Model Costs                        399
                                xvn

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 NUMBER
VIII-5
IX-1
IX-2
IX-3
X-l
X-2
XII-1
XII-2
XIII-1
         IRONMAKING SUBCATEGORY
           TABLES (Continued)

                  TITLE
BAT/PSES/PSNS/NSPS Treatment Model Costs
Raw Wastewater Characteristics
BPT Effluent Flow Justifications
Justification of BPT Effluent Limitations
Alternative BAT Effluent Limitations
Justification of BAT Effluent Limitations
Alternative NSPS
Justification of NSPS
Alternative PSES and PSNS
PAGE
400
406
407
408
419
420
428
429
434
                                xvm

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NUMBER

III-l to
III-4

IV-1

IV-2

VII-1 to
VII-9

VIII-1

IX-1

X-l

XII-1

XIII-1
    IRONMAKING SUBCATEGORY


           FIGURES


            TITLE

Process.Flow Diagrams


Discharge Flow Versus Plant Age

Discharge Flow Versus Production

Treatment System Diagrams of Sampled
     Plants

Treatment Models

BPT Treatment Model

BAT Treatment Model

NSPS Treatment Model

PSES/PSNS Treatment Model
 PAGE

 324


 334

 335

 373


 402

 409

 421

' 430

 435
                                xix

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                        COKEMAKING  SUBCATEGORY

                               SECTION  I

                               PREFACE
The USEPA has promulgated effluent limitations and standards   for   the
steel  industry pursuant to Sections 301, 304, 306,  307 and 501 of  the
Clean Water Act.  The regulation  contains  effluent   limitations   for
best  practicable  control  technology currently available  (BPT)/ best-
conventional pollutant control technology (BCT),  and  best  available
technology  economically  achievable  (BAT)  as  well  as pretreatment
standards for neW and existing sources (PSNS and PSES) and new  source
performance standards (NSPS).

Th.is PaTfc of the!Development Document highlights the technical aspects
of  EPA s  study!  of  the Cokemaking Subcategory of the Iron and Steel
Industry.  Volume I of  the  Development  Document  .addresses  general
issues  pertaining  to  the  industry,   while  other  volumes  contain
specific subcategory reports.

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                         COKEMAKING SUBCATEGORY

                               SECTION II

                              CONCLUSIONS
Based upon  this study,  a  review   of   previous   studies   by   EPA,   and,
comments  received on the proposed regulation  (46  FR  1858),  the Agency
has reached the following conclusions:

1.   The Agency is retaining the  previous  subcategorization  of   the
     cokemaking  subcategory   into  by-product  and beehive  cokemaking
     operations  based  upon   the differences   in   the    respective
     manufacturing  processes.    The  Agency  has  also  retained   the
     segmentation  of   the  by-product  cokemaking  subdivision    into
     biological  and  physical/chemical  treatment  methods  at the  BAT
     level.  Based upon slightly  higher flow rates found  at  merchant
     coke   plants, a separate  subdivision for merchant coke  plants  has
     been developed.
               I                                    •
               i
2.   For the most part, the  originally  promulgated  BPT  limitations
     (1974)  are  practicable  and  achievable at all coke plants.  In
     fact,   data obtained  by the Agency since that time shows that   the
     previous  limitations for by-product coke plants are more lenient
     than could.be justified for  all pollutants except total suspended
     solids.  Nonetheless, except  for  total  suspended  solids,    the
     promulgated  BPT  limitations  are the same as those contained in
     the prior iregulation.  For   beehive  operations,   the  previously
     promulgated  BPT  limitation  of zero discharge of pollutants  has
     been retained.
               \         '
3.   Sampling  land  analysis  of  by-product  coke  plant  wastewaters
     revealed  [high   concentrations  of more than 40 toxic pollutants.
     Cokemaking; operations generate more  toxic  pollutants  than   any
     industrial;  category  examined  by  EPA.    The discharge of these
     toxic   pollutants  can,   however,  be  significantly  reduced  by
     industry  -compliance with  the BPT and BAT limitations and PSES as
     shown  below:

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Flow, MGD
TSS
Oil and Grease
Ammonia-N
Total Cyanide
Phenols (4AAP)
Toxic Organics
Toxic Metals
Other Pollutants
                              Direct Dischargers
                        Effluent Loadings (Tons/Yr)
                       Raw
                      Waste        BPT          BAT
              24
            1830
            2740
           21940
            1830
           10970
            4340
              95
           23040
               33
             3340
              405
             3800
              253
               25
              138
               35
              1,52
                 23
               2280
                173
                242
                 86
                  1
                 25
                 24
                 24
                            Indirect Dischargers
                        Effluent Loadings  (Tons/Yr)
Flow, MGD
TSS
Oil and Grease
Ammonia-N
Total Cyanide
Phenols (4AAP)
Toxic Organics
Toxic Metals
Other Pollutants
                      Raw
                     Waste

                       7.4
                     563.3
                     844.9
                    6759. 1
                     563.3
                    3379.5
                    1336.0
                      29.3
                    7097.1
                                             PSES
                             8
                             9
                             6
               4
             723
             108
             434'. 4
             115.8
             260.6
             208.1
              10.8
                        1664.9
The Agency's estimates of the   investment  and  annual  costs  to
achieve   the  . BPT   and  BAT  limitations  for  the  Cokemaking
subcategory are shown below.  The Agency has determined that  the
effluent  reduction  benefits associated with compliance with the
limitations and standards justify.the  costs.

          	Costs (millions  of July 1,  1978 dollars)
                 Investment Costs
         Total     In-Place    Required
BPT
BAT
PSES

TOTAL
168.6
 44. 1
 45.8

258.5
120.9
 11.1
 30.9

162.9
47.7
33.0
14.9

95.6
The Agency   has   also   determined   that
benefits  associated  with   compliance
(NSPS, PSNS)  justify those  costs.
    Annual Costs
     Total

      41 .6
      11.5
      10.2

      63.3

 the  effluent
with new source
                                              reduction
                                              standards

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"Confidential" plant  costs  are  not  included.   No  additional
capital  investment  for beehive operations is anticipated, since
the  remaining  active  plants  achieve  no  discharge.    Annual
operating '• costs  for  beehive cokemaking wastewater treatment  is
less than [$60,000 per year.

The Agency has promulgated BCT limitations for  suspended  solids
and  oil  ;and  grease  that  are  the  same as the respective BPT
limitations.  For  beehive  operations,  both  the  BPT  and  BCT
limitations are zero discharge.                     \
With regarid to the Third Circuit's "remand  issues",  the  Agency
concludes [that:

a.   The estimated  costs  for  the  model  wastewater  treatment
     systems  are  sufficient  to  cover  all  costs  required to
     install and operate the model technologies,  whether  as  an
     initial  fit  or  a retrofit.  The Agency has also concluded
     that [the ability to implement the model, wastewater treatment
     systems is not affected by plant age or size.  A  comparison
     between  the costs reported by the industry and the Agency.'s
     estimated costs for several  plants  demonstrates  that  the
     estimated model wastewater treatment costs are sufficient to
     account  for  all  site-specific  and other incidental costs
     which might be incurred.

b.   The Court ruled that the NSPS model flow of 100 gal/ton  was
     "not demonstrated" and therefore, remanded that issue to the
     Agency  for reconsideration*   In addition to the four plants
     surveyed in the original study by the Agency, . other  plants
     have i demonstrated  process  wastewater  flows of 100 GPT or
     less,; including two of the five participants  in  the  toxic
     pollutant  sampling  phase  of  this  study.   In  addition,
     process flows of less than 100 gal/ton were reported by  the
     industry in response to questionnaires for 24% of all plants
     surveyed.   However, the Agency increased the model flow used
     to  establish the BAT limitations and NSPS to 153 gal/ton to
     account for additional wastewater flows generated by wet air
     pollution control systems and to allow for up to 50  gal/ton
     of  dilution  water for optimization of biological treatment
     systems.

c.   The 175 gal/ton model discharge flow used to develop the BPT
     limitations is demonstrated and,  in fact, is less  stringent
     than | might otherwise be justified.  The increased data base
     now available shows that 47%  of the by-product  coke  plants
     discharge  less than 175 gpt  and the average flow for 80% of
     the plants is 173 gpt.
     The
     app
     which
appropr
previously promulgated BPT
   iate and the Agency has
   are identical.  The BPT
limitations
promulgated
limitations
for ammonia-N are
 BPT  limitations
for ammonia-N are

-------
e.
     achieved at the sampled plants using free and fixed  ammonia
     removal, stills  included in the BPT model treatment system,
     and  at  plants  with  biological  treatment.   The   Agency
     believes  the  ammonia-N  BPT limitations can be achieved at
     all   coke   plants   with   proper   operation   of    both
     physical-chemical and biological treatment systems.

     The components  of  the  BAT  model  treatment  systems  are
     'installed on a full scale basis at cokemaking operations and
     the  BAT  limitations  are  demonstrated at one plant in the
     industry.  Multi-step biological treatment is  practiced  at
     Plant  0868A,  and  other  treatment systems are designed to
     provide for such operation.  Recycle of barometric condenser
     water, with less than 4% blowdown  is  practiced  at  Plants
     0112D, 0448A and 0856F, and the blowdown flows at the latter
     two plants are 3 gallons per ton or less.

Although a significant  number  of  toxic  pollutants  have  been
identified  in  the  raw  wastewaters  from by-product cokemaking
operations, the Agency does not believe it is necessary to  limit
each  toxic  pollutant  detected.   Adequate  regulation of toxic
pollutants is attained by establishing limitations  for  cyanide,
phenols   '(4AAP),   benzene,   naphthalene,  and  benzo(a)pyrene.
Phenols   (4AAP)  accurately  represent  acid  extractable   toxic
organic  pollutants.   Benzene  has  been  selected  to  indicate
volatile organic pollutants, while naphthalene and benzo(a)pyrene
indicate base/neutral extractable  organic  pollutants  found  in
cokemaking  wastewaters.   By  limiting  the  discharge  of these
pollutants,  effective  control  is  provided   for   all   toxic
pollutants found in untreated cokemaking wastewaters.

The Agency has promulgated separate  BAT  limitations  for  those
existing  sources  which  have . full . scale physical/chemical BAT
treatment  systems  that  include  activated  carbon   adsorption
systems.

Tables II-l and 11-2 present the BPT and BCT effluent limitations
and the model flow rates and effluent quality for iron and  steel
and  merchant  cokemaking  operations, respectively.  Tables II-3
and I1-4, present the BAT and NSPS limitations and standards  for
the   iron   and   steel   and  merchant  cokemaking  operations,
respectively.  Table II-5 presents BAT limitations applicable  to
iron  and  steel  and  merchant  cokemaking  operations which use
physical/ chemical  treatment  systems.   Tables  II-6  and  II-7
present the respective PSES and PSNS.

-------


















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-------
                        COKEMAKING SUBCATEGORY

                             SECTION  III

                             INTRODUCTION
General       '

Cokemaking   operations   include   by-product  recovery  and   beehive
facilities.  Nearly all of the  metallurgical  coke  produced   in   the
United  States: is made in by-product recovery coke ovens which  operate
as part of  integrated  steel  mill  complexes.   By-product  recovery
facilities  are also used by merchant coke manufacturers, sometimes as
part of a chemacal or utility plant operation.  A very  small   portion
is  still  made  in  non-recovery  type  ovens  with arched roofs that
closely  resemble  beehives,  hence  the   name   beehive   cokemaking
operations.
              j
Both  types  of  cokemaking  facilities  are capable of producing high
quality metallurgical coke for use in blast  furnaces  or  in   foundry
cupolas.   Only  the  by-product  recovery  coke ovens are equipped to
produce a wide; variety of other products in addition to coke.   Further
details on  each  process  and  the  respective  pollutant  loads  are
presented in subsequent discussions.

Data Collection Activities
1^—          ~{~"      L-J".^.

In  addition to evaluating data from previous studies, EPA issued Data
Collection Portfolios (DCPs) to all by-product  cokemaking  facilities
known  to  be | active  at  the  time  questionnaires were distributed.
Responses were; received from all facilities.  Since that  time,  three
other  small independent plants have been reported producing coke, and
four of the original respondents have closed permanently.   There  are
currently  58 ! by-product cokemaking plants and one beehive cokemaking
plant in operation.  The DCPs  distributed  for  the  by-product  coke
plants  requested  information  about  production processes and rates,
process water usage and  discharge  rates,  wastewater  treatment  and
disposal  methods,  age of plants (first year of on-site production and
dates of rebui'lds), age of treatment systems, and location.

The  Agency  diid  not  seek  any  additional  data  regarding   beehive
operations.   The  previously  promulgated BPT limitations required no
discharge of  process  wastewater  pollutants.   The  Agency  did  not
receive any comments from industry during the rulemaking process which
questioned the! appropriateness of that limitation.

Based  upon  DCP  responses and other information, EPA issued Detailed
Data Collection Portfolios (D-DCPs) to nine  by-product  coke  plants.
These  D-DCPs [focused  upon  obtaining cost and operating performance
data for wastewater treatment facilities.
                                     15

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In addition to the questionnaire responses, the  Agency  reviewed  its
sampling data from prior studies of four coke plants, and sampled five
additional  plants for this study.  The Agency also performed sampling
and analyses as described in Volume I.

As shown in  Table  III-l,  the  expanded  data  base  for  by-product
cokemaking  includes  EPA  sampling  at  nine  plants  (15% of plants;
representing 20% of industry capacity), DCP responses from  59  plants
(95%  of  plants;  and  99% of capacity) and D-DCP responses from nine
plants (15% of the plants; representing 17% of capacity).  A  list  of
beehive operations is provided in Table III-2, but only one plant with
two batteries of ovens is known to be active.

Cokemaking by_ the By-Product Recovery Process

The production of metallurgical coke is an essential part of the steel
industry,  since  it provides one of the basic raw materials necessary
for  the  operation  of  ironmaking  blast  furnaces.   Of   the   two
traditional processes for the manufacture of coke, by-product recovery
ovens   have  virtually  eclipsed  the  beehive  ovens  in  commercial
applications.  Less than 1% of the metallurgical coke produced in 1978
was made in beehive ovens.  The remaining 99+% of coke production came
from coke plants practicing' varying degrees of by-product recovery (64
plants at 59 locations, some with 2 or 3 plants per  location,  in  17
different states).

The  by-product  recovery  process,  as  the  name   implies,  not only
produces high-quality coke for use as blast furnace  or  foundry  fuels
and  carbon  sources, but also provides a means of recovering valuable
by-products of the distillation reaction.  During this process, air is
excluded from the coking chambers, while heat  is  supplied  from  the
external  combustion  of  fuel  gases in flues located within dividing
walls separating adjacent ovens.

The volatile components are recovered from the coke  oven  gas  stream
and  processed   in a wide variety of ways to produce tars, light oils,
phenolates, ammonium compounds, naphthalene, and  other  materials  of
value,  including  .the  coke  oven gas itself.  Table II1-3 summarizes
by-product recovery processes in use at the 59  locations  where  sucn
cokemaking  operations exist in the United States.   Note that all coke
oven gas and crude coal tars are recovered at all  plants,  and  crude
light  oils,  ammonium compounds and naphthalene are recovered at most
plants.  Of the  remaining 23 products, five are produced at  only  one
by-product  recovery  plant.   With  one  exception,  no  single plant
recovers more than 12 of the 28 products listed.

Beehive cokemaking represents a distinctly different approach  to  the
production of metallurgical coke from the more widely used by-products
recovery process.  In the beehive process, air is admitted to the oven
during  the  coking  cycle so the volatile products  which distill from
the coal are immediately burned.  A small percentage of  these products
is transferred to the water used to cool the coke  (quench).  No  other.
water-borne   pollutants   are  generated  during  the   process.   For

-------
additional details on wastewater characterization  and
subcategorizati'on, refer  to Sections  IV  and  V.
its  impact  on
A  by-product  recovery   coke  plant  consists  of  batteries  of  ovens  in
which coking cdals are heated  to drive  off  volatile  components of  the
coal in the absence of air.  The coal used  is  usually  a  blend  of high,
medium and low [volatile bituminous grades selected because  of  specific
coking  characteristics.  The  volatiles are drawn off  and recovered  as
by-products during the process.  The  residue remaining in the  oven   is
the  coke  product.   Typical  coking   time is   18  hours.  The ovens
themselves are [narrow, rectangular,   silica brick   chambers   arranged
side  by  side ;in groups  of  20 to 90, most  often  in  batteries  of 50  to
70 individual ovens.  The smallest  plants   in the  industry   have   a
single  battery,  while   the largest  has up to 20 batteries with 60-70
ovens in each battery.  Most conventional ovens in use  today   are   of
similar  size, ; /typically 12  meters   long, 4.5  meters  high,  and 0.45
meters wide (approximately 13  x 5 x 0.5 yards).   However, new  ovens  in
service and under construction at several American coke  plants are   15
meters  long,  |6 meters high and 0.6 meters wide  (approximately 16.4 x
6.6 x 0.66 yards).  These larger ovens  can  accomodate  more  than twice
the  coal  charges  of the smaller ovens, thus producing more  coke per
charge, and reducing the  potential for  air   emissions  while   charging
and  pushing.  ' Additionally,  the" change  in  oven design provides the
opportunity  toj  install  certain  other technological   improvements
including  preheating  of incoming coal in  enclosed  chambers;  pipeline
charging systems using pulverized coal  (thus eliminating the need  for
opening  lids  atop the ovens while charging and  leveling the  charge);
and the installation of ductwork and shed-type enclosures   to   capture
and  clean  cha'rging  and pushing  emissions.    Such  emission control
practices have provided significant improvement in air quality around
by-products   coke   plants.    However,    these   and  other   similar
improvements increase the polluted  wastewater   load  and  volume   by
transferring thje air emissions into waters  used for  scrubbing.

In  addition to, increases in size of by-product coke ovens, the Agency
has noted several- trends  within this subcategory  since the  study which
formed  the  basis  of  the  originally promulgated'  limitations  was
completed.   Thje~  indirect  ammonia  recovery  process  is"'used  at fewer
plants (less than 7% of cokemaking capacity);  and,   the  recovery  and
refining  of light oils to benzene, toluene and xylene is less common.
On the other haind, desulfurization of coke  oven gas  is  practiced   at
more  plants,  thereby allowing for wider use  of  the by-product gas  as
fuel for  other!  steel  plant  operations.   New  techniques   for  gas
desulfurization-  and  subsequent  recovery   of sulfur  values have been
developed and installed at some coke batteries.   Hydrogen sulfides are
absorbed using ammonia from coke oven gas together with  catalysts in a
scrubbing solution.  The  sulfur-laden solution is then processed  into
a  liquid  ammonium  sulfate  slurry  which can  be  used in fertilizer
production or in chemical processes.
               j                              .
The application; of required air pollution controls in  areas where they
were  not  formerly  used  is  a  relatively   recent  development    in
cokemaking.     For  example,   the  problems associated  with   noxious
                                    17

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emissions from the charging of coal into hot ovens have been addressed
on new or rehabilitated  ovens  by  installing  pipeline  charging  of
preheated  coals,  or by equipping larry cars (charging machines) with
emission collection and scrubbing systems.  The  former  practice  may
include  exhaust  scrubbers on each of the preheaters, while the larry
car systems  generate  considerable  volumes  of  highly  contaminated
wastewaters  which  require  disposal.  Coke pushing emissions are now
being controlled by  emission  collectors  and  scrubbers,  either  on
enclosed  quench cars or in the form of shed enclosures.  These latter
structures are large collectors of dust-laden gas, some  as  large  as
114  meters  long,  18  meters- wide and 27 meters high (374 x 60 x 90
feet).  At some plants wastewaters blown down from either  system  are
currently  used  as  makeup  water  for  coke quenching.  Wet scrubber
systems  are  also  in  use  at  coke  screening  stations  and   coal
preparation,  handling  and  storage  areas.   All  of  these  systems
represent wastewater sources which are new  to  by-product  cokemaking
operations,  having  been  installed  only  within the  last few years.
More specific details relating to wastewater flows and  characteristics
are provided in Section  V.   Process  flow  diagrams   for  by-product
recovery and light oil refining are shown on Figures III-l and III-2.

An overall general summary of the by-product cokemaking operations and
practices  in  the United States is provided in Table III-4.  Data for
age, size, wastewater flow, by-product  recovery,  wastewater  control
and  treatment1 technology,  and  ultimate disposal of  wastewaters are
highlighted for each by-product coke plant.  Wastewaters from  several
coke  plants  are  discharged  to local publicly owned  treatment works
(POTWs) for final treatment 'following  limited  pretreatment  on-site.
Disposal  of  'contaminated  wastewaters  by  coke  quenching  is  also
practiced at several plants.  Additional discussion oniwastewater flow
and disposal follows in Sections V and IX.

Cokemaking By_ the Beehive Oven Process

This older cokemaking  process  accounts  for   less  than   1%  of  the
metallurgical  coke  produced  in  the United States.   Inherent  in the
beehive  process  are  the  significant   atmospheric   emissions   of
components  of  the  coal  charged  to  the ovens.  With the  increased
efforts  to  minimize  air  pollution  nationwide,  the use  of  this
operation  will continue to decline, since control of emissions places
severe constraints on oven operation,  making   it  more difficult  to
compete on an economical basis with the by-product recovery processes.
Refer to EPA-440/I-024a, Development Document for Effluent  Limitations
Guidelines  and  New  Source Performance  Standards for  the  Steelmaking
Segment of the Iron and Steel  Manufacturing  Point  Source   Category,
dated  June   1974, Page 36 et seq, for more  information on  the beehive
process.  Process flow diagrams for beehive plant operations  are  shown
on Figures III-3 and III-4.   Figure   III-3  shows  ;a   simpler   system
utilizing quenching within the oven, while Figure  III-4 illustrates an
external quenching arrangement at a more  modern plant.
                                     18

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                                        TABLE III-3

                   COAL CHEMICALS PRODUCED AT BY-PRODUCT RECOVERY PLANTS
Material           ;
Recovered

Coke Oven Gas
Crude Coal Tar  .
Crude Light Oils   :
Ammonium Sulfate   [
Naphthalene Solidifying at <74°C
Sodium Phenolate (or Carbolates)
Intermediate Light Oils
Toluene, all grades!
Benzene, specification grades
Xylene, all grades j.
Solvent Naphtha, all grades
Elemental Sulfur   '
Crude Chemical Oil !(Tar Acid Oils)
30% Ammonium Hydroxide
Naphthalene solidifying between
  74°C and 79°C
Soft Pitch of Tar  j
Enriched Ammonia Lijquor
Benzene, non-specification grades
Creosote Oils, straight distillate
Phenol, non-industrial grades
Hard Pitch of Tar  |
Creosote Oils in coal tar solution
Mono- and Diammonium Phosphates
Cresols            ,
Cresylic Acid      |
Picolines          :
Anhydrous Ammonia  |
Phenol, industrial 'grades
  No. of Plants
Practicing Recovery

      59
      59
      48
      43
      41
      25
      20
      10
      9
      9
      8
      8
      8
      6
      4

      4
      4
      3
      3
      3
      2
      2
      2
      1
      1
      1
      1
      1
Percent Practicing Recovery
% of No.
100.0
100.0
81.4
72.9
69.5
42.4
33.9
16.9
15.3
15.3
13.6
13.6
13.6
10.2
6.8
6.8
6.8
5.1
5.1
5.1
3.4
3.4
3.4
1.7
1.7
1.7
1.7
1.7
% of Coke Prod.
100.0
100.0
90.2
78.4
76.2
46.8
43.7
30.4
27.9
27.3
24.4
22.3
20.1
7.0
22.4
21.0
6.5
5.1
19.7
17.2
14.7
11.8
4.0
9.8
9.8
9.8
9.8
9.8
                                           21

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28

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                         COKEMAKING SUBCATEGORY

                               SECTION IV

                           SUBCATEGORIZATION
 Introduction    !

 The  Agency  subdivided  the  cokemaking  subcategory into by-products
 recovery and beehive processes because of  the  basic  differences  in
 process   equipment  and final products.   The by-product subdivision was
 further  divided  ! into  coke  plants  affiliated  directly  with  steel
 production  and merchant coke plants.   Each of  these subdivisions has a
 segment  for existing full  scale physical-chemical treatment systems at
 the BAT  level.   i

 The  Agency  concluded  that further  subdivisions within each of these
 processes are nojt appropriate.   The Agency believes  that  differences
 in   process  operations  and  air   cleaning systems  which contribute
 wastewaters  are| best  addressed   by  establishing  basic  conditions
 applicable   to  all   coke   plants,  and  then   providing  for specific
 incremental effluent limitations  for  qualifying  plants sbased  upon
 variations   fromj the  basic  conditions.   Accordingly,.the regulation
 contains allowances  for desulfurization using  wet absorption  methods,
 and  the practiqe   of  indirect  ammonia recovery,  only to the extent
 necessary to accommodate higher wastewater flows  associated with these
 operations.    The model  by-product   recovery  cokemaking  production
 facility includes   the coke ovens,  associated coke oven gas cleaning
 equipment,  and facilities  for recovery  of  crude   coal   tars,   ammonia
 compounds,  naphthalene,  and  crude  light oil.   Tar processing and crude
 light oil refining operations are  not included.                 '

 Factors   evaluated   with  respect  to  subcategorization  and subdivision
 are discussed  below  in greater  detail.
                 i
 Factors  Considered iri Subcategorization

 Manufacturing  Process and  Equipment

 Major differences between  the production  equipment  used  and  the  nature
 of  the cokemaking process  form  the basis   for   subdividing   cokemaking
 into  by-products and beehive operations.   In  the  by-products  recovery
 ovens, the  exclusion   of   air   and  the   use   of   flushing   liquor   to
 condition   coke  |oven  gas generates  significant  quantities  of  various
 types  of   wastewaters.    The   most   highly  contaminated    of    these
 wastewaters  originates  from  the  moisture  of the coal  itself,  and  takes
 the  form of excess  flushing  liquor which must  be  continuously removed
 from the flushing liquor system.  This  same moisture  is   vaporized   in
 the  beehive process,   along   with other volatile  constituents of the
 coal.  Air  is admitted  into  the  ovens  to  burn  these   volatiles   to
provide  additional    heat  for the coking process.   The Agency  found  no
                                    29

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significant differences  in  manufacturing  processes  and  production
equipment  between  by-product  coke  plants  associated directly with
steel production and merchant coke plants which are  used  to  produce
coke for a variety of uses.

Since there are basic differences in manufacturing process, it follows
logically  that the process equipment likewise differs between beehive
and by-products recovery operations.  The beehive operations are  much
simpler  than  the  by-product  operations.   Both processes have coke
quenching in common, but the  by-product  recovery  process  also  may
include   operations   such   as  ammonia  recovery,  dephenolization,
desulfurization, light oil refining and scrubbing  of  emissions  from
coal  and  coke  handling,  coal  charging,  and  coke pushing.  These
additional processing operations and  variations  in  equipment  cause
enough differences in wastewater quantity, quality and treatability to
warrant  separate  limitations  for  by-product and beehive cokemaking
processes even though both start with the  same  raw  material;  coal.
Within   the   by-product   cokemaking   operations,   variations   in
manufacturing process and equipment relate directly to the by-products
recovered.  However, wastewaters from all operations at a  given  site
are  usually combined and treated in a single treatment system.  Where
appropriate, incremental effluent limitations for by-product  recovery
are  provided  over  and  above the basic effluent ^imitations for all
plants.

Final Products

Although both processes have the production of coke as  their  primary
objective,  the  by-products recovery cokemaking operations (including
merchant coke production) yield a  wide  variety  of  final  products,
including  coke  oven gas, and crude coal tars (see Section I.I I, Table
III-3).  The basic products can differ from plant to plant.  The  coke
itself   can   be  either  furnace  coke  for  use  in  blast  furnace
iron-making, or foundry coke for cupola use.  Coke oven gas  can  vary
depending  on  the  chemical  composition  of  the coals coked and the
degree of cleaning and conditioning provided for the gas prior to  its
ultimate  use.   These  factors will also influence the quality of the
coal tars recovered.  Other recovered by-products will  determine  the
volume  and  quality of certain wastewater streams.  For example, most
by-products plants use semi-direct ammonia recovery methods  producing
ammonium  sulfate  or  ammonium  phosphate.   However,  six by-product
plants use indirect methods which produce ammonium hydroxide  instead.
This  latter  process  yields  larger  volumes  of  wastewater than do
semi-direct  recovery  methods.   There  are  other   differences   in
wastewater  generation • rate  and  quality  resulting from recovery of
crude  or   refined   light   oils,   from   sulfur   recovery,   from
dephenolization, and from  final cooler operations, whether recycled or
once-through.   Impacts  from  these  variations are discussed in more
detail in Sections  IX and  X.  The Agency believes that  it has properly
accounted for the plant to plant variations in wastewater quantity and
quality caused by the production, of different final products with  the
building  block  approach  used to develop the effluent  limitations and
standards.
                                     30

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There are no such variations for beehive  operations,  which  generate,
less  noxious  v?astewatefs.  As a result, the Agency believes that the
basic subdivision of cokemaking into beehive and by-products  recovery
processes is appropriate in part because of the diverse final products
produced by the jlatter operations.

Raw Materials   ;
                [                                          -
While  raw  materials  are  a  principal factor in subcategorizing the
steel industry, i'the coals used in the cokemaking subcategory  have  no
significance  on'  segmenting  the  cokemaking  subcategory.   Although
variations in coal chemistry affect wastewater quality  and  quantity,
other  factors such as the presence or absence of by-products recovery
components and air pollution emission controls  are  of  much  greater
significance  with  respect  to the generation of wastewater requiring
treatment.  Within the by-product cokemaking segment (iron  and  steel
and  merchant  cokemaking),  coals  are  blended  to  provide the most
desired combination of characteristics in the end product.  Thus,  the
generation   of!  wastewaters   requiring  control  and  treatment  is
influenced  by  'other  factors  "to" a  much  greater  extent  than  by
variations in raw .material charged to the ovens.  These influences are
adequately   cohered   by   incremental   effluent  limitations  where
appropriate.  Accordingly, the Agency has not subdivided or  segmented
by-product recovery operations on the basis of raw materials.

Wastewater Characteristics

As  indicated  above  in  the  discussion  of manufacturing processes,
beehive and by-product cokemaking  operations  generate  significantly
different  wastewaters.   Process  wastewaters fronf beehive operations
are related strictly to quenching operations, and as such are  readily
treated  by sedimentation for removal of suspended solids.  The excess
quench water is collected and evaporated on the hot coke product.  The
volume of wastewaters generated  by  the  beehive  process  vary  only
slightly from plant to plant.

The  by-product|recovery processes, on the other hand, generate excess
flushing liquors, benzol plant wastewaters, final cooler  wastewaters,
desulfurizer wastewaters, air pollution control scrubber effluents and
tar decanter wastewaters in addition to the wastewaters from quenching
operations.   Irji  contrast  to  beehive  operations, these wastewaters
contain pollutants•other than  suspended  solids  such  as  ammonia-N,
cyanides,  phenolic  compounds,,  sulfides,  oil and greases, acids and
alkalis, as well as many toxic organic pollutants.  While  the  Agency
found plant to plant variations in the quality of untreated cokemaking
wastewaters,  the  Agency  determined  that  these differences are not
significant in terms of further subdividing or  segmenting  by-product
cokemaking   operations.    The   Agency   did  not  find  significant
differences between wastewaters from iron -,and steel and merchant  coke
plants  and  has  not segmented the by-product recovery subdivision on
the  basis  of  Iwastewater  characteristics.   For  more  details   on
cokemaking wastewater characteristics refer to Section V.
                                    31

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'Wastewater  Treatability

 Wastewaters from beehive cokemaking operations'are effectively treated
 by   simple  sedimentation in settling ponds to remove coke fines picked
 up  during quenching.   Pond  overflows  are  readily  recycled  to  the
 quenching   operation,   with  minimal  impact on  air quality due to the
 general  absence of pollutants other than suspended solids.

 Based  upon  data .obtained   from   several  by-product   cokemaking
 operations,  the  Agency found plant to plant variations in wastewater
 quality  and  quantity.   However,  for   both   merchant   cokemaking
 operations   and  those  affiliated  with  steel  production, the Agency
 found  no variations in either the  quantity  or   the  quality  of  the
 wastewaters   which   would   affect   subcategor.ization   or  further
 subdivision of cokemaking  operations  beyond that  provided -by  the
 subdivision  into  merchant  and iron and steel  cokemaking operations.
 The distinction made between merchant and iron  and  steel  cokemaking
 operations  was made on the basis of flow as noted below.

 Size and Age

 Consideration was given to the impact of size and age when subdividing
 the cokemaking  subcategory  into  beehive and  by-product operations.
 Beehive  plants tend to be only about one-fifth as large  as  iron  and
 steel  affiliated by-products plants.  Although  the beehive process is
 an  older technology,  the only beehive plant  known  to  be  active  is
 "newer"  than  many  by-product  plants.   Thus,   these  size  and age
 differences  are  covered  by   the   basic   subdivision   into   two
 manufacturing  processes.   Within  the by-product cokemaking segment,
 differences in age betweeen merchant and iron and  steel  coke  plants
 are not  significant.   However, merchant coke plants tend to be smaller
 in  size  and, as a group, have slightly higher water use rates.

 With  respect  to  size expressed as rated capacity, the ratio between
 the largest  and  smallest  direct  discharge  by-product  cokemaking
 facilities   for  which  flow  data  are  available  is  32:1,  yet the
 corresponding ratio between total daily raw waste flows for those  two
 plants  is   less  than  8:1.  The Agency did not find any relationship
 between  flow rates per unit of production  and  size  except  for  the
 merchant segment, as noted above.  The total raw wastewater generation
 rates  reported for the six largest steel-owned direct discharge plants
 and the three  largest.  POTW  users  averaged   150  GPT,  while  the
 corresponding number of smallest plants averaged 159 GPT.   'Similarly,
 for merchant plants,  the three largest direct dischargers plus the two
 largest  POTW users averaged 162 GPT, while the  corresponding smallest
 merchant plants averaged 172 GPT.  The range of  flows for large plants
 is  narrower than for small, primarily because the larger ones practice
 similar  degrees of by-product  recovery  while  different  degrees  of
 by-product   recovery  is  practiced  at  the smaller plants.  As noted
 above, these differences are accounted  for  by   incremental  effluent
 limitations  within  the  by-product  segment  rather  than by further
 segmentation on the basis of size.
                                     32

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Scatter  diagrams  of  by-product   cokemaking  plants   plotting  rated
capacity  versus   flow,   and   identifying  those  which  discharge either
directly or  indirectly are  illustrated  in  Figures  IV-1  and  IV-2.   Note
that most plarits,  large and small,  are  generating  wastewater   at  less
than 250 gal/t'on,  indicating  that size  has little  impact  on flow.  •

The Agency did not find any impact  relating to the age of a coke plant
other  than  ;the   indirect  one  derived   from   the subdivision  into
by-product recovery and beehive segments.   To begin with,   age  itself
is a relative term, since most coke plants have  been in operation much
.longer than  their  current "oldest"  active  production units.   Data from
all  by-product  recovery  plants are also plotted in  Figures IV—1 and
IV-2, showing the year  of  rebuild for   the  oldest   active  battery
on-site  versuis  flow  for  each plant.  Many sites show  oldest active
batteries buillt between 1940  and 1962.  Flows  are  not  dependent  on
year  of  rebuild,  since  both  high and  low flows occur in  every age
group, indicating  that age  has no impact on flow.   Further  support can
be shown by  comparing wastewater generation, rates  for  old   and new
plants.   Defining  age   by  "oldest  active battery",  the  five oldest
plants average' 191 GPT, while the   five newest  average  205  GPT,   a
difference of pnly 7%.  If  age is defined  as "first date  of cokemaking
on-site",  these   flows are 175 GPT for old plants and 185  GPT for new
plants.   The | Agency  believes  that   these  differences    are  not
significant.  I
Plants  vary  [from 9
criterion for |age, or
is  considered!.   The
oldest active battery
available  data  for
cokemaking plant has
although  the j oldest
only a few years old.
which  are  purely by
to 15 years, and have
years.        i
to 81 years old if first year of operation is the
 from 1  to 66 years old if oldest active  battery
  oldest  site, 81 years, is only 14 years old if
 is selected as the  criterion  for  "age".   The
 age  demonstrates  that the "average" by-product
had cokemaking on-site for  at  least  50  years,
 active batteries are 26 years old and the newest
  Wastewater treatment systems (other than  those
-product recovery system components) date back 12
 usually been upgraded within the  last  6  to  8
The  Agency  also found that age does not have a significant  impact on
wastewater " characteristics  or  treatability.   Among   the   surveyed
plants,  the  newest and best treatment facilities were  found at  three
locations which have been making coke for more  than  70  years,  with
active  batterj.es  at least 25 years old.  Also, .to further complicate
the concept of; plant age, .there  can  be,  a  significant  distinction
between active! campaign years and calendar years.  The former involves
actual  use of j .a battery of ovens, which may be only  20  years during a
35 calender year period.  The need to rebuild  major  portions, of  an
operating  coke  plant at various intervals provides  an  opportunity to
install  or  upgrade,  wastewater  treatment  components  with  minimal
disruption  to;  the  remaining  process  operations.   A review of DCP
responses indicates that 68% of the. plants provided some upgrading  of
wastewater  treatment equipment to coincide with the  rebuild of active
batteries. ,,;•••                                              •   .
                                    33

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 In  response  to  the  Court's   remand,   the   Agency   compared   industry's
 actual   cost for pollution  control  facilities  with its  estimated  model
 plant costs.  The objective of  the  comparison   was  to   determine  the
 relative ease with  which  the model  wastewater  technology equipment  can
 be  retrofitted to  existing   systems  and production units.   Based on
 that comparison, the  Agency concludes that its model   cost   estimates
 are sufficiently   generous to  cover  the  associated retrofit  costs  for
 plants of all "ages." As  additional support, a review of the   list   of
 plant  ages   versus  installation dates for treatment systems confirms
 that most plants can  and  do retrofit  treatment  systems to   existing
 production facilities (Refer to Table IV-1).

 Based  upon   the  above,  the   Agency  finds   that  both old  and  newer
 by-product   cokemaking  production  facilities generate similar  raw
 wastewater   pollutant   loadings; that pollution control  facilities  can
 be  and   have been  retrofitted to   both  old and newer  cokemaking
 facilities   without  substantial  retrofit costs;  that  these  pollution
 control  facilities  can  and  are  achieving  the   same  effluent   quality;
 and,  that   further  subcategorization  or further segmentation within
 this subcategory on the basis of age  or size is not appropriate.

 Geographic Location

 The Agency has  concluded  that location  does  not   have   a significant
 effect   upon subcategorization or further-subdivision,  other than  the
 fact that beehive ovens tend to be   located   in   rural   areas within
 bituminous   coalfields  (Pennsylvania,  West   Virginia,   Virginia  and
 Kentucky), while by-products recovery plants are  situated at  locations
 where their  by-product  gas  can  be used  as fuel  (i.e.,   at  integrated
 steel  works,   or   urban  areas where  gas can be  distributed to  other
 users).   The  Agency accounts for this distinction  by  subdividing  the
 cokemaking subcategory  into  by-products and beehive processes.

 By-product   cokemaking  operations need  no further  segmentation because
 of  location.  By-product  recovery plants  are situated   in 17 states,
 but  half  of   the  total   number are found in  Pennsylvania,  Ohio,  and
 Alabama.   Only  six  are  located  west of  the Mississippi   River (2   in
 Texas,   1  each  in  California,  Colorado,  Missouri, and Utah).   The
 Agency did not  find any   significant  differences   due   to  geographic
 location.    The  effect   of  location in  terms  of  water  consumption  in
 arid or semi-arid regions is discussed  in Section.VIII.

 Process Water Usage
                                                  »

 For beehive operations,  flows are a function of  the  quenching   rate,
 and are uniform from plant to plant.  Excess quench water is  collected
 and  recycled   to   the  operation,  thus minimizing  the need for makeup.
water.   The Agency  did  not observe any  variations  in   process   water
 usage,   and,  accordingly,   believes  a single  model flow suffices  for
beehive operations.

The raw wastewater  flows-  reported to  EPA for  by-product  cokemaking
 installations   vary considerably from plant to  plant, with a  low  of  33
                                    34

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gallons per ton of coke to a high of  1395  gallons  per  ton.   These
flows  include ! process wastewaters only as non-contact cooling waters
were excluded by the Agency from total reported flows where  possible.
These   variations  in  flow  reflect  the  different  water  use  and
conservation practices at cokemaking operations.  Plants that have low
flows also have| minimum recovery of by-products, and rarely  have  any
auxiliary  equipment  such  as  charging  or  pushing emission control
scrubbers or desulfurizers.  As noted above, the Agency did find  that
merchant  coke i plants  tend  to  have slightly higher wastewater flow
rates than  coke  plants  affiliated  directly  with - iron  and  steel
production.    !
               i                   •                                .
The Agency believes these flow variations have been properly accounted
for  by  providing  incremental effluent limitations where appropriate
rather than by 'further subdivision based upon  wastewater  flow  rate.
These  limitations are provided for plants practicing indirect ammonia
recovery and wet gas desulfurization and are in addition to  the  base
limitations  applicable  to  all  plants.   Variations  in flow can be
reduced by implementing the wastewater recycle components included  in
the  model  BPT and BAT treatment systems.  These are recycle of final
cooler water, ammonium sulfate barometric condenser water, and recycle
of  air  pollution  control  system   scrubber   waters.    Additional
discussion  of ' these water usage-and wastewater generation flow rates
is provided in ;subsequent sections, particularly in Section V.

Consideration of Process Changes               ;

The BAT model treatment system does not include any in-process changes
although wastewater  quality  may  change  when  discharge  rates  are
reduced.   Many  plants  are employing recycle, reuse or treatment and
recycle to minimize water use and the volume of effluents  discharged.
The limitations! and standards are mass limitations and standards (unit
weight  of  poilutant  discharged  per unit weight of product) and not
volume  or  concentration  limitations  and  standards.    While   the
limitations  and  standards  can be achieved by extensive treatment of
large flows, the Agency believes that the  limitations  and  standards
can,  in  most | instances, be achieved more economically by minimizing
effluent volumes prior to final treatment.
                                    35

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                           TABLE IV-1

                  EXAMPLES OF PLANTS THAT HAVE
DEMONSTRATED THE ABILITY TO RETROFIT POLLUTION CONTROL EQUIPMENT
                      COKEMAKING SUBCATEGORY

Age of
Production Facilities
Age of
Treatment
System
Plant
Cokemaking Reference
Process Number
Beehive 0428A-1
0428A-2
0724G
By-Product 001 2A
Recovery 0012B
0024A
0024B
0060
0060A
0112
0112A
0112C
•0248A
0272
0280B
0396A
0402
0448A
0464C
0464E
0584F-M
0684D
0684F
06841
0684J
0732A
0810
0856A
0856N
0920B
0920F
First Year
On-Site
(Year)
^1930
^1930
^1920
1920
1919
1916
1901
1953
1928
1914
^1920
1921 	
1912
1919
1929
1906
1917
1942
1925
1914
1923
1927
1917
1918
1914
1929
1917
1918
1917
1942
1917
Active Batteries
Installed Upgraded
Oldest (Year) Newest (Year) (Year)
1963
1970
• -
1951
1966
1967
—
1953
1959
1951
1951
1948
1948
1948
1963
-
1955
1951
1952
1970
1947
-
1947
1947'
-
1950
-
1948
1953
1953
1945
1970
1970
1960
1979
1967
1979
1968
1977
1969
1976
1980
1965
1951
1968
1963
1955 ' -
1977
1959
1978
1979
1979
1955
1977
1965
1952
1958
1962
1980
1979
1956
1976
_
1970
1960
-
1974
1972
1969
1953
1947
1962
1976
-
-
1957
- •
-
1917
-
-.
1914
1976
-
1960
1970
'
1952
-
-
1917
1942
-
(Year)
1970


1977







1978
1971

1977
1972

1973
1971


1975


1976

1975
1975


1978
—
1973
1968
-
1979
1978
1977
1977
1978
1979
1980
-
-
1977
-
-
1971
-
-
1978
1979
-
1976
1974
-
1979
-.
-
1978
1977
-
                                   36

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                I         COKEMAKING SUBCATEGORY
                l                '                ?
                j               SECTION V

               WATER  USE  AND  WASTEWATER CHARACTERIZATION
 Introduction

 The sources and  characteristics  of process   wastewaters   generated  by
 cokemaking operations  are  reviewed herein,  with  particular  emphasis on
 by-product  cokemaking wastewaters.   Water  use   rates  were measured
 during field sampling  of selected plants, and  also  were   obtained   for
 active   by-prodjucty  plants   through  DCPs.    For .  the  two  beehive
 operations, field data ,alone  were   used.   Since  the   only  process
 wastewater source for  beehive cokemaking  is quenching runoff,  and  this
 source is readily recycled, the  Agency did  not solicit additional  data
 with DCPs from these sources.                         .  .

 Waste  characterization  for  both  cokemaking processes  is based  upon
 analytical  data; obtained  during  the   field   sampling   .programs.
 Long-term  data  were obtained from selected companies by  detailed  data
 collection-portfolio's  (D-DCPs),  which were   also  used to   supplement
 available  cost  ; information.    Additional   data  were acquired by EPA
 regional staff with the cooperation of individual companies,  and   from
 the activities of EPA's Office of Research  and Development.
                 !    .  .      .    . .  -  -                    .,..''..
 Water  use  rates discussed below pertain only to process wastewaters,
 and not to non-contact  or  non-process  cooling  water.    Non-contact
 cooling   water  and   non-process  waters   are not   limited   by   this
 regulation.      •.                          .
                 !       .''/.-          .      "         '
 Sources•          !
                 !             •           .           .          . •    •
 General process  and water flow diagrams of  a conventional by-   product
 coke  plant  and; associated light ;oil recovery plant  are presented  as
 Figures.111-1  and III-2.   Typical  beehive  operations  are  shown   on
 Figures  II1-3   and  II1-4.  in  actual practice,  75%  of the by-product
 coke plants have|some degree of  ammonia recovery as   shown  on  Figure
 III-l,  .and  even  more recover  crude light oils..  However,  only about
 25% refine lightjoils to the extent shown on Figure III-2.
                 l_        ,-          •              -              .      ^
The typical products generated during  the carbonization  of  a  metric
ton  (1..1  short tons)  of coal in the by-product cokemaking process are
as follows:
                                    39

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Coke Oven Gas
Tar
Ammonia as Nitrogen
Tar Acids
Hydrogen Sulfide
Light Oils
Coke - Sized
Coke - Undersized
Water
350 cu.  m
35 liters
2.4 Kg
2.4 Kg
3.0 Kg
12 liters
625 Kg
75 Kg
132 liters
(12,500 cu,
(9.2 gal)
(5.3 lb)
(5.3 lb)
(6.6 lb)
(3.2 gal)
(1380 lb)
(160 lb)
(35 gal)
ft.)
Although the above list summarizes the typical quantities  recoverable
from  grades of coal commonly used for cokemaking, the Agency observed
variations among different coals which are due to differences in  coal
chemistry,  moisture  and  volatility.  For example, the quantities of
coke oven gas generated per metric ton of coal coked reported,  for  58
coke  plants varied from 216 to 523 cubic meters per metric ton (7,000
to 16,970 cubic feet per short ton).

Raw  wastewater  loads  from  by-product  cokemaking  operations  vary
widely,  not  only  as a result of differences in coals used, but also
due to variations in recovery processes, water use systems,  operating
temperatures  of  the  ovens,  and  the  duration of the coking cycle.
However, all such variations, are subject to effective control  by  the
treatment  systems  considered herein. ' Raw wastewater flows generated
by the nine by-product coke plants  sampled  during  this  study  were
found  to  range from 90 to 580 1/kkg (21.6 to 139 gallons per ton) of
coke produced.  Maximum and minimum  effluent  flows  vary  even  more
widely  since  several  options  exist  for  treating  each coke plant
wastewater.  For example, at most  plants  with  biological  treatment
systems,  some  dilution water is added to optimize conditions for the
bioxidizing organisms.  Also, raw or treated wastewaters are  disposed
of by coke quenching at some plants.  Effluent flows from these plants
are lower than from plants where all wastewaters are discharged.

The   most   significant   wastewaters   generated  during  by-product
cokemaking and  by-product  recovery  operations  are  excess  ammonia
liquor;  final  cooler  wastewater;  light  oil  recovery wastewaters;
barometric condenser wastewaters from the  crystallizer;  desulfurizer
wastewaters; and, contaminated wastewaters from air pollution emission
scrubbers for charging, pushing, preheating, and screening operations.1'
In  addition,  miscellaneous  wastewaters  may  result from coke wharf
drainage, quench sump  overflows,  and  coal  or  coke  pile  runoffs.
Runoffs from storage piles and coke wharves should be contained within
a  diked  area  and  impounded  until  evaporated,  or  collected  and
transferred to the plant's wastewater treatment  system.   Condensates
from drip legs and gas lines, along with leakage from sample test taps
and  floor  washdowns  should  also  be  routed  to treatment prior to
release, since significant toxic pollutant  discharges  can  originate
from these diverse sources.  Among the possible means for control, the
following methods are most applicable:
1.   Collection and channeling of  miscellaneous
     wastewater treatment systems.
                         sources  to  process
                                     40

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2.   Impoundment with no discharge, provided that subsurface discharge
     through  ipercolation  is  prevented  by .the  use  of  impervious
     materials  to  line lagoons, storage ponds, and runoff collection
     stations.:

3.   For  situations  where  the  impact  on  air  pollution  can   be
     tolerated,  a  system  of  recycle  to extinction by coke or slag
     quenching operations may be acceptable.

The largest volumes of water  leaving  a  by-product  coke  plant  are
indirect  (noncontact)  cooling  waters  from a variety of cooling and
condensing  operations..  These  flows  are  not  considered   process
wastewaters,  ibut  leaks  in  coils or tubes can result in significant
contamination 'of these cooling waters.  Frequent inspection and proper
maintenance will  prevent  such  contamination  from  process  waters.
Inspection  and maintenance programs to minimize contamination of non-
contact cooling waters can  be  included  in  NPDES  permits  as  Best
Management Practices  (BMPs).

The  volume of; excess ammonia liquor produced from the distillation of
coal varies from 75 to 430 1/kkg (18 to 103 gal/ton) of coke at plants
using semi-dirject ammonia recovery, and from 260 to 442 1/kkg  (62  to
106  gal/ton) i.at  plants using indirect recovery.  Ammonia liquor was
sampled separately at six coke plants and as part of a mixed  flow  at
two  coke  plants.  Measurements showed excess ammonia liquor flows of
90 to 205 1/kkg (21.6 to 49.3 gal/ton).  The  pollutants  of  interest
are  shown  in  Table  V-l  for the original guidelines survey, and in
Table V-2 for ith'e toxic pollutant survey.  In order to determine which
pollutants  arse  contributed  by  cokemaking  operations,  the  Agency
subtracted  the intake concentrations of those pollutants found in the
raw wastewaters from the  raw  wastewater  concentrations.   Note  the
major  polluta'nts  found in excess ammonia liquor are directly related
to the  destructive  distillation  of . coal.   Since  excess  flushing
liquors  represent  the  first  step  in cooling the coke oven gas for
reuse,  the was'te ammonia liquor contains by far the greatest pollutant
load.  All by-products recovery plants generate excess ammonia liquor.
              i
Final cooler Wastewaters originate from direct contact cooling of coke
oven gas with jwater sprays which dissolve any  remaining  soluble  gas
components  an;d  physically  flush out condensed naphthalene crystals.
Final cooler wastewater volume ranges from 190 to 820 1/kkg (46 to 197
gal/ton), but |this volume can be and is reduced to between 8.3 and  42
1/kkg  (2  to ! 10 . gal/ton) by recycle. , Nearly 70% of the by-products
coke plants halve some wastewater from this source.

Available monitoring data (including toxic pollutant data)  for  final
cooler  wastewaters  are from one plant with a relatively high flow of
294 1/kkg (70.5 gallons per ton) of coke  produced.   These  data  are
shown  in  Tab|le  V-3  for  31   pollutants.  Somewhat higher pollutant
concentrations might be expected at plants with higher  recycle  rates
and  correspondingly  lower  blowdown  flows.   Although waste ammonia
liquor is the Imost contaminated cokemaking wastewater, the  levels  of
certain  volatile  pollutants (e.g., benzene, cyanide, isophorone, and
                                    41

-------
toluene) in final cooler wastewaters exceed those in  ammonia  liquor.
Additional- data  for  mixtures  of final cooler wastewater and benzol
plant wastwaters are shown in Table V-4.

Light oil recovery  (benzol plant) wastewater volumes also vary widely,
depending upon the degree of recovery (crude or refined), and  whether
recirculation  is  practiced.   Although once-through systems generate
from 835 to 6,260  1/kkg  (200  -  1,500  gal/ton),  recirculation  is
usually  practiced which reduces the discharge flows to between 46 and
534 1/kkg (11 to 128 gal/ton).  Toxic pollutant  concentrations  found
in  benzol  plant   (light oil recovery) wastewaters are shown in Table
V-5.   Certain  toxic  organics  (e.g.,  benzo(a)pyrene,   isophorone,
parachlorometacresol)  common in other coke plant wastewaters were not
detected in benzol plant wastewaters.  Also,  most  of  the  pollutant
concentrations  observed in benzol plant wastewaters are significantly
lower  than  those  in -the  other  cokemaking  wastewaters.   Notable
exceptions are benzene, toluene and xylene, which were found in benzol
plant  wastewaters ' at  levels  3  to  7  times  higher  than in other
wastewaters.  As in the case of final cooler wastewaters,  most  (over
60%)  of  the  by-product  recovery  plants have some flow from benzol
plant processes.

As noted.above, these three sources of wastewater are common  to  most
by-product  cokemaking  operations.   Additional sources include steam
condensates from ammonia and phenol recovery units,  drip  legs,  test
taps,  floor  drains  and  washdowns  and , runoffs from coke quenching
operations.  Steam condensates have been measured at 10 to 20% of  the
wastewater  volumes  delivered  to  the  recovery  units.   The  other
combined "miscellaneous wastewaters" were' found at flows  from  21  to
350  1/kkg (5 to 84 gallons/ton), depending to a large extent upon the
degree of housekeeping and maintenance  provided.   Some  plants  have
been  able to apply practices which minimize flows requiring treatment
prior to disposal, while others have chosen not  to,  and  allow  such
sources to be consumed in quenching operations.

Coke   quenching   operations  for  by-product  recovery  and  beehive
operations require an applied rate of 500 to 3,750 1/kkg (120  to  900
gal/ton),  with  an  average  application  rate  of  2,100  1/kkg (500
gal/ton).  Approximately one-third of the applied flow  (170  gal/ton)
is evaporated during each quench.  The runoffs are collected in a sump
and  reused for subsequent quenches with no discharge of wastewater to
treatment or receiving streams.   Thirty-one  by-product  coke  plants
dispose  of  much  of  their  process  wastewaters  by quenching.  The
process wastewaters which are most often disposed of in  this  fashion
are  final  cooler  blowdowns and benzol plant wastewaters.  In nearly
all cases, fresh water is mixed with the wastewaters, but in at  least
one   plant,   the   quench  stations  operate  using  more,  than  90%
contaminated water.

The  water  application  rates  required  for  quenching  result  from
attempts   to  strike  a  balance  between  the  need  to  quench  the
incandescent coke, and yet leave enough heat in the coke to  evaporate
water  trapped  within  it.   If  the water which remains entrapped is
                                    42

-------
 primarily  contaminated  wastewater,  many  of  the  contaminants  are
 transferred  to  the  blast furnace, thereby increasing the wastewater
 pollutant loads  at  the  blast  furnace  gas  washers.   Much  higher
 ammonia-N   concentrations  are  found  in  blast  furnace  wastewater
 recirculation systems at furnaces that are fed with coke quenched with
 dirty water.  To further compound the problem  of  using  contaminated
 wastewater  for  quenching,  studies  have  indicated  increased metal
 corrosion in arid  around  quench  stations  which  use  "dirty  water"
 quenching   compared  to  stations  using  fresh  water  makeup  only.
 Particulate emissions from quench towers tested with both contaminated
 and fresh makeup waters were found to be more than twice as high  with
 dirty   water  | quenching,   i.e.,   20.4  kilograms  (45  pounds)  of
 particulates per quench with dirty  water  versus  9.5  kilograms  (21
 pounds)  of  particulates per quench with clean water.  The difference
 was  related  to  the  higher  level  of  dissolved  solids   in   the
 contaminated  makeup  water.   The use of wastewater treatment systems
 prior to quenching may not be appropriate,  since  the  high  dissolved
 solids  concentrations  in  waste  ammonia  liquors are not reduced by
 conventional treatment means.   This dissolved matter is  converted  to
 particulates  in  the atmosphere as water vapor is flashed off.   Dirty
 water quenching is likely to become more limited in the future.  "

 There have not ;been  any  significant  steps" taken  toward  dry  coke
 quenching tin  rthis country, despite the use of this technology in the
 Soviet Union,  Japan,  England,  France,  Germany  and  Switzerland.   New
 cokemaking  operations  constructed  in  the  U.S.    will   most likely
• include water quenching with total recycle of quench water  and  fresh
 water  makeup.  ; Although all plants in this country practice quenching
 with water,  overflows from quenching operations were not reported  for
 many  plants.   > Quenching  wastewaters  from  by-product  and  beehive
 operations are usually recycled to extinction,  leaving no   wastewaters
 requiring further treatment.  The quality of wastewaters following its
 use  as  quench: water is shown in Table V-6 for fresh and  contaminated
 waters at by-pr;oduct  coke quenching operations  and in  Table  V-7   for
 fresh water  quenching at beehive operations.

 The  remaining wastewater sources identified during plant  surveys  were
 found at fewer than  half  of   the  cokemaking   operations.    Fourteen
 by-product  cokemaking  plants  have barometric condensers to create  a
 vacuum in ammonium  sulfate  crystallizer   systems.    This   operation
 generates   fairly    high   volumes   of    contaminated    wastewaters.
 Once-through  flpws  were reported between  83  and 1710  1/kkg (20 to   410
 gal/ton),  but [some   users  practice   tight recycle  of  crystallizer
 wastewaters',  reducing blowdown rates  to  4   to  42  1/kkg  (1   to  10
 gal/ton).  Thisjwastewater  is  often discharged  without  treatment,  even
 though  considerable  concentrations of  cyanides are present.   Refer to
 Table V-8  for  monitoring data  for•  barometric   condenser   wastewaters.
 Surface  condensers,   have   been  installed  at  some plants to minimize
 wastewater volume.

 Another wastewater  source requiring  treatment is   the  discharge  from
 wet   desulfurizers,   which are  used  at  eleven plants  to  recover  sulfur
 compounds  from  coke oven gas.   Again, once-through  flows are  high,  up
                                    43

-------
to  900  1/kkg  (216 gal/ton), but recycle is often practiced bringing
wastewater blowdown rates down to 33 to 125 1/kkg  (8 to 30 gal/ton)

In addition to the foregoing basic flows  .associated  with  cokemaking
and  by-product  recovery,  additional  process  waters originate from
scrubbers used to reduce  air  pollution  emissions.  Some  of  these,
notably  scrubbers  on  coal  handling, crushing ,or blending, and coke
handling* transfer or screening contribute  only   minor  volumes  with
easily  removable  suspended  matter  as  the  major pollutant.  Other
sources generate highly contaminated effluents  which  require  higher
levels   of   treatment;  notably,  blowdowns  from  coal  drying  and
preheating operations which are small in  volume but contain  thousands
of  mg/1  of  TSS  and  high  levels  of  volatile organic compounds.
Once-through flows average from 167 to 667 1/kkg  (40 to 160  gal/ton),
but  95% recycle of such wastewaters provides blowdown volumes of 8 to
33 1/kkg (2 to 8 gal/ton).  Scrubbers on  larry cars and other charging
equipment  generate  highly  contaminated wastewater  with  blowdowns
ranging  from  21  to   104  1/kkg   (5 to  25 gal/ton).  A recent survey
conducted by EPA Region  V  Eastern  District  Office  quantified  the
pollutant  concentrations  for  a   typical  larry  car scrubber system.
Monitoring data are presented in Table V-9.

The largest single volume of wastewater associated with air  pollution
controls  is that from  coke pushing operations.   Over.8340  1/kkg  (2000
gal/ton) can be applied to scrubbing emissions at  the pushing side  of
a  coke  battery.   Recycle of these wastewaters  can be used to reduce
the volume requiring treatment to  420 1/kkg   (100  gal/ton)  or   less.
Data   covering two pushing emission control systems are shown  in  Table
V-10.  Note that the concentrations of toxic  organic  pollutants  are
low  when  compared with  charging  emission scrubbers such  as the  larry
car data referred to above.

A -summary of average by-product cokemaking  process  wastewater   flows
observed   during   sampling  visits  and reported   in   responses  to
questionnaires  is presented  in Table V-T1 .  The  column headed  Average
of  Best"  represent   the average of  at   least  the  best   20-s  of
questionnaire   respondents.   The   Agency believes   these  plants are
representative  of  the  industry   and  that  other  plants   in   the
subcategory can achieve the BPT model treatment  system flow.

The    applied   flow  rates   for   beehive   cokemaking  operations   were
discussed above.  The  ability  to  recycle  all  wastewaters  to extinction
in the  coke   quenching  process   has   been   demonstrated  at  .beehive
cokemaking operations.

After   reviewing   the   net   and  gross  concentrations  Of  the pollutants
considered for  limitation in  the  cokemaking   subcategory,   the -Agency
concluded  the   effect  of   make-up water quality on  the  various  waste
streams  is minor  or  negligible.   Hence,  the  effluent   limitations  and
standards  were proposed on  a gross basis.   A detailed  review  of  these
data  is  presented  in  Section  VII.
                                     44

-------
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                                TABLE V-3
              SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
                         TOXIC POLLUTANT  SURVEY
                    BY-PRODUCT'COKEMAKING OPERATIONS
      NET CONCENTRATIONS OF POLLUTANTS IN FINAL COOLER SLOWDOWNS
(1)
Reference Code
Plant Code
Sample Point(s)
Flow, (Gal/Ton)

     Suspended Solids
     Oils & Grease
     Ammonia  (N)
     Sulfide
     Thiocyanate
     Phenolic Compounds
     pH, (Units)

3    Acrylonitrile
4    Benzene
35   2,4-Dinitrotoluene
36   2,6-Dinitrotoluene
39   Fluoranthene
54   Isophorone
55   Naphthalene
65   Phenol
(2)  Phthalates, Total
72   Benzo(a)anthracene
73   Benzo(a)pyrene
76   Chrysene
77   Acenaphthylene
80   Fluorene
84   Pyrene
86   Toluene

114  Antimony
115  Ars eni c
117  Beryllium
120  Copper  .
121  Cyanides
125  Selenium
126  Silver
128  Zinc
 0732A
 001
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 70.5

 29
 28
 30
 22   .
 52
 101
 7.3

 1.5
 37.3
 1.87
 0.236
 1.09
 4.00
 39.0
 59.7
 1.44
 0.107
 0.080
 0.053
 0.323
 0.156
 0.080
 17.0

 <0.003
 0.006
 <0.002
 <0.004
 188
 <0.005
 <0.025
 0.08
 (1) All values are  in mg/1 unless otherwise noted.
 (2) Value  shown  is  the sum of  all values for the following phthalates:
    66 Bis-(2-ethylhexyl); 67  Butylbenzyl; 68 Di-n-butyl; 64 Di-n-octyl;
    70 Diethyl and  71 Dimethyl phthalate.
                                     48

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-------
                                         TABLE V-5
                      SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
                                  TOXIC POLLUTANT SURVEY
                             BY-PRODUCT COKEMAKING OPERATIONS
              NET CONCENTRATIONS OF' POLLUTANTS 'IN BENZOL PLANT WASTEWATERS
         (1)
Reference Code
Plane Code
Sample Point(s)
Flow, (Gal/Ton)

     Suspended Solids
     Oils & Greases
     Armenia (N)
     Sulfide
     Thiocyanate
     Phenolic Compounds
     pH (Units)

1    Acenaphthene
3    Acrylonitrile
4    Benzene
34   2,4-Dimethylphenol
38   Ethylbenzene
39   Fluoranthene
55   Naphthalene
64   Pentachlorophenol
65   Phenol
(3)  Phthalates, Total
72   Benzo(a)anthracene
76   Chrysene
77   Acenaphthylene
78   Anthracene
80   Fluorene
81   Phenanthrene
84   Pyrene
86   Toluene
130  Xylene

114  Antimony
115  Arsenic
117  Beryllium
118  Cadmium
119  Chromium
120  Copper
121  Cyanides
122  Lead
126  Silver
                                            (2)
                                       0920F
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                                       23.4

                                       95
                                       38
                                       .366

                                       264
                                       127
                                       7.8

                                       0.150
                                       2.07
                                       74.5
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                                       0.654
                                       0.232
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                                       1.89
0684F
009
G-A
49.7

75
166
187
79
239
455
8.4-8.5

0.005
1.45
85.5
ND
<0.005
0.95
27.5
1..16
40.0
12.42
1.20
.1.49
1.19
ND
0.175
ND
1.05
11.5
145.0
0.055
MA
<0.01
NA
0.02
0.025
<0.05
<0.02
Average
  of 2

 36.6

  85
  102
  276
  40
  252
  291
  7.8-8.5

  0.0-78
  1.76
  80.0
  2.78
  0.33
  0.59
  16.4
  0.58
  57.9
  6.21
  0.60
  0.75
  0.60
  *
  0.185
  *
  0.53
  10.8
  72.5
                                                                                         .028
  0
  0.
  0
  0.003
  0.005
  0.01
  0.013
  0
  0.95
NA:  Not analyzed.
ND:  None detected.
- :  Calculation resulted in negative value for net concentration, and is equivalent Co ND.
* :  Compound could not be separated, but is present in sample.

(1)  All values are in mg/1 -unless otherwise noted.
(2)  Concentration is calculated by difference from other sampling points.
(3)  Value shown is the sum of all values for the following phthalates:  66 Bis-(2-ethylhexyl)
     67 Butylbenzyl; 68 Di-n-butyl; 69 Di-n-octyl, 70-Diethyl and 71-Dimethylphthalata.
                                                         50

-------
                                  TABLE  V-6
               SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
                         ORIGINAL  GUIDELINES  STUDY
                      BY-PRODUCT COKEMAKING OPERATIONS
                i         	'— ^>"-^-"*AciJ.xj.i.i\j w.r.EinA.1. J.L/JNO
     NET  CONCENTRATION OF POLLUTANTS IN WASTEWATKPS FPOM QUENCHING
                                                     Contaminated Water  ^
                                                           Make-up
Fresh Water
  Make-up
Reference  Code
Plant  Code
Sample Point(s)
Flow  (Gal/Ton)
     Suspended  Solids
     Oils  & Greases
     Ammonia  (N)
     Sulfide    |
     Thiocyanate
     pH (Units) !

117  Beryllium  \
121  Cyanides   ,
191  Phenolic Cpds.
  703
  9.6
  1.94
  <0.02
  <3
  7.6

  <0.04
  4.0
  1.46
                                                          448
                               (3)
 (11)
 84
 92
 135
 10
 8.5

<0.04
51
150
     (4)
         alues   e in
                                  otherwise noted.
                                   . 51

-------
                                        TABLE V-7

                      SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
                                ORIGINAL GUIDELINES STUDY
                              BEEHIVE COKEMAKING OPERATIONS                (1)
Plant Code
Sample Point (s)
Flow (Gal/Ton)
Suspended Solids
Oils & Greases
Ann on i a (N)
Sulfide
Thiocyanate
pH (Units)
117 Beryllium
121 Cyanide
123 Mercury
191 Phenolic Compounds
E
3-5
490
165
*^1
0.27
<0.02
<3
7.3
<0.02
0.002
O'.OOSl
0.011
F
490
29
•*•
<0.02
<3
7.3
<0.02
<0.002
G
l-( 2+3+4)
123
713
3.7

<0.02
7.0-7.3
<0.02
<0.002
0.0026
<0.002
Average of
3
368
302
1.2
0 . 09
0
Q
7.0-7.3
0
0.001
0.0019
0.004
- :  Calculation resulted in negative value for net concentrations, and is equivalent to ND,

(1)  All values are in mg/1 unless otherwise noted.
                                             52

-------
               !    -             TABLE V-8
               I          ,            •••'',
               i'
              SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
               i         ORIGINAL GUIDELIENS STUDY
               i      BY-PRODUCT COKEMAKING  OPERATIONS
             NET CONCENTRATIONS OF .POLLUTANTS  IN CRYSTALLIZER
               I     BAROMETRIC  CONDENSER WASTEWATERC  '
Reference Code i
Plant Code     >
Sample Point(s)
Flow, (Gal/Ton)
               i
     Suspended[Solids
     Oils & Greases
     Ammonia (N)
     pH (Units)

117  Beryllium;
121  Cyanide   ;••
191  Phenolic Compounds
0432B
  A
 4-3
 56.6

 35
 8.5
 0.27
 8.7

 <0.02
 138
 2.72
(1) All values lare in mg/1 unless otherwise noted,
                                   53

-------
                                TABLE V-9

              SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANT
                TOXIC POLLUTANT SURVEY - EPA REGION V EDO
                    BY-PRODUCT  COKEMAKING OPERATIONS
                   NET CONCENTRATIONS OF POLLUTANTSxIN
                     LARRY CAR SCRUBBER SLOWDOWNS
Reference Code
Flow (Gal/Ton)

     Suspended Solids
     Oils & Greases
     Ammonia (N)
     Sulfide
     Thiocyanate
     Phenolic Cpds.
     pH  (Units)

4    Benzene
34   2,4-Dimethylphenol
38   Ethylbenzene
39   Fluoranthene
55   Naphthalene
65   Phenol
68   Di-n-bvityl phthalate
72   Benzo(a)anthracene*
73   Benzo(a)pyrene
75   Benzo(k)fluoranthene
76   Chrysene*
77   Acenaphthylene
78   Anthracene*
81   Phenanthrene*
82   Dibenzo(a,h)anthracene
83   Indeno(l,2,3-dc)pyrene
84   Pyrene
0584B
24.2

9218
17.5
9.42
<0.25
<0.50
7.54
4.0

0.050
0.040
<0.010
0.68
0.27
1.72
<0.010
<0.64
0.31
0.40
<0.64
0.45
<1.04
<1.04
0.11
0.18
0.55
                                      54

-------
 TABLE  V-9 i
 SUMMARY OF; ANALYTICAL  DATA FROM SAMPLED PLANT
 TOXIC  POLLUTANT SURVEY -  EPA REGION V EDO
 BY-PRODUCT;COKEMAKING  OPERATIONS
 NET  CONCENTRATIONS  OF  POLLUTANTS IN
 LARRY  CAR SCRUBBER  SLOWDOWNS  7
 PAGE 2
 114  Antimony
 115  Arsenic
 117  Beryllium
 118  Cadmium
 119  Chromium
 120  Copper
 121  Cyanides
 122  Lead  1
 123  Mercury
 124  Nickel
 125  Selenium
 126  Silver
 127  Thallium
 128  Zinc  !
<0.001
0.244
<0.010
0.010
0.020
0.010
0.50
0.050
<0.001
0.036
<0.005
<0.006
<0.05
0.09
(1) All values are in mg/1 unless otherwise noted.
*   Compound could not be separated, but is present in sample.
                                    55

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                                                                                               1
                                        TABLE V-10
                       SUMMARY  OF ANALYTICAL DATA FROM SAMPLED PLANTS
                         TOXIC POLLUTANT SURVEY - EPA REGION V EDO
                             BY-PRODUCT  COKEMAKING OPERATIONS
                             NET CONCENTRATIONS OF POLLUTANTS
                      IN PUSHING EMISSION CONTROL SYSTEM SLOWDOWNS
                                                                  (1)
Reference Code
Flow (Gal/Ton)

     Suspended Solids
     Oils & Greases
     Ammonia (N)
     Sulfide
     Thiocyanate
     Phenolic Cpds.
     pH (Units)

4    Benzene
23   Chloroform
24   2-Chiorophenol
34   2,4-Dimethylphenol
37   1,2-Diphenylhydrazine
39   Fluoranthene
44   Methylene Chloride
55   Naphthalene
65   Phenol
66   Bis(2-ethylhexyl) phthalate
67   Butyl benzyl phthalate
68   Di-n-butyl phthalate
69   Di-n-octyl phthalate
70   Diethyl phthalate
71   Dimethyl phthalate
72   Benzo(a)anthracene*
73   Benz'o (a )pyrene
75   Benzo(k)fluoranthene
76   Chrysene*
77   Acenaphthylene
78   Anthracene*
79   Benzo(ghi)perylene
80   Fluorene
81   Phenanthrene*
82   Dibenzo(a,h)anthracene
83   Indeno(1,2,3-cd)pyrene
84   Pyrene
One-Spot Push
& Quench Car •-

    0684F
    70.0

    2260
    <1
    2.15
    <0.16
    0.10
    0.381
    6.5

    <0.010
    <0.010
    ND
    ND
    <0.010
    0.011
    0.017
    <0.010
    <0.010
    <0.010
    <0.010
    <0.010
    <0.010
    <0.010
    <0.010
    <0.010
    <0.010
    <0.010
    <0.010
    <0.010
    <0.010
    <0.010
    <0.010
    <0.010
    <0.010
    <0.010
    0.013
Stationary Emssion
   Control System

     0320
     43.5

     2032
     2
     0.51
     <0.25
     <0.50
     0.33
     4.6-7.1
     ND
     <0.010
     0.020
     ND
     <0.010

     <0.010
     0.070

     ND
     ND
     ND
     ND
     ND
     <0.010
     ND
     ND
     <0.010
     <0.010
     0.010
     ND
     <0.010
     0.010
     ND
     ND
     <0.010
                                           56

-------
TABLE V-10      |
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
TOXIC POLLUTANT SURVEY - EPA REGION V EDO
BY-PRODUCT COKEMAKING OPERATIONS
NET CONCENTRATIONS OF POLLUTANTS
IN PUSHING EMISSION CONTROL SYSTEM SLOWDOWNS
PAGE 2          ',           .    .      •   .  .
  (1)
114  Antimony
115  Arsenic
117  Beryllium
118  Cadmium
119  Chromium
120  Copper
•121  Cyanides
122  Lead
123  Mercury
124  Nickel
125  Selenium
126  Silver
127  Thallium
128  Zinc
One-Spot Push
& Quench Car

    NA
    NA
    0.002
    0.003
    0.147
    0.238
    0.235
    0.09

    0.178
    NA
    <0.003
    NA
    0.164
Stationary Emission
   Control System

     <0.001
     0.017
     <0.010
     <0.010
     0.010
     0.020
     0.015
     0.010
     <0.001
     ND
     0.010
     <0.006
     <0.050
     0.060
(1) All values are in mg/1 unless otherwise noted.
                f                                                       "
- : Calculation of net concentration yields negative number, due to higher level in
    make-up water.
* : Compound could not be separated, but is present in sample.
ND: None detected.
NA: Not analyzed;;
                                          57

-------


















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-------

-------
                         COKEMAKING SUBCATEGORY

                               SECTION VI

                         WASTEWATER POLLUTANTS
 Introduction    ;

 The  originally  promulgated   regulation   established  limitations  for
 by-product  cokemaking   operations   for   ammonia-n,   cyanide,   oil and
 grease, phenols  (4-AAP),  suspended  solids,  and pH.   The  Agency  found
 other  pollutants   in the wastewaters  in  significant quantities (e.g.,
 chlorides,  sulfates,   sulfides,  dissolved  solids),   but   did   not
 establish specific  limitations  for  those  pollutants.

 Conventional Pollutants
 In   the  originally  promulgated   regulation,   the   Agency established
 limitations for [three  conventional pollutants  (TSS,   oil   and  grease,
 and  pH).   Suspended  solids  originate,   in   part,   as   particles of
 condensed tars, ;naphthalene crystals and bits  of  fine coal   or   coke
 which  are  carried  out  with  coke  oven   gas,  and then  subsequently
 trapped  in flushjing  liquor.  Another source of suspended solids is the
 lime addition at fixed ammonia distillation columns.    Unreacted   lime
 is  the  major  [component  of  the suspended solids  in by-product  coke
 plant wastewater;s, while coke fines make  up  the bulk of   suspended
 solids   in  beehjive  wastewaters.   Biological treatment of cokemaking
 wastewaters also; generates suspended solids.

 Oils and greases! are among the numerous  products formed  during   the
 destructive  distillation  of  coal,  along with "the other  organic
 pollutants described below.   These  oils   and greases are   not   the
 typical  lubricating  oils  found  in the wastewaters  from other steel
 industry operations, but are organic compounds which are extracted  by
 the  solvents  used  in the analytical procedure for  measurement of oil
 and grease in wastewaters.

 The limitations regulate wastewater pH routinely  in  all subcategories,
 principally because of the environmentally  detrimental  impacts which
 occur   due  to j extremes  in  pH.   Untreated by-product  cokemaking
 wastewaters are typically alkaline due to high  levels   of  ammonia  in
 solution.  The pH is raised even further (to 10-12 standard units)  for
 ammonia  distillation,   thus  the  wastewaters  require neutralization
prior to discharge.    '
                i
Toxic Pollutants:

Total  cyanide  was   limited  in  the  prior   regulation.    For    this
regulation,  the Agency employed sophisticated  analytical techniques  to
evaluate  the  presence,   absence,  or magnitude  of  115 organic and  15
nonorganic toxic!pollutants in cokemaking process wastewaters.
                                    61

-------
Most  of  the  toxic  pollutants  found   in   by-product   cokemaking
wastewaters  are  products  of  the  destructive distillation of coal.
Additional sampling, specifically designed to  provide  data  for  the
toxic  pollutants,  confirmed  the presence of 40 toxic organic and
toxic metal pollutants.  Refer to Table VI-1  for  a  summary  of  all
toxic  pollutants found in cokemaking wastewaters.  Since the original
limitations required "no discharge of process  wastewater  pollutants
from  beehive  operations, the Agency did not include those operations
in the  toxic  pollutant  survey.   The  data  presented  for  beehive
cokemaking were gathered during the original guidelines study.

Sixteen  of  the toxic pollutants shown in Table VI-1 were observed at
relatively low concentrations (0.01 to 0.02 mg/1)  at  only  one  coke
plant    The  overall  list was shortened by deleting such pollutants,
primarily because pollutants found at such low  levels  are  generally
not treatable to lower levels.  The remaining 35 toxics appeared to be
more  characteristic of the raw wastewaters from by-product cokemaking
operations.

Based upon their presence in  untreated  wastewaters  from  cokemaking
operations,  the  Agency  considered  establishing limitations for the
following 29 organic and 6 nonorganic pollutants:
                       TOXIC ORGANIC  POLLUTANTS
Acrylonitrile
Benzene
2,4,6-Tri chlorophenol
Parachlorometacresol
Chloroform
2,4-Dimethylphenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Ethylbenzene
Fluoranthene
Isophorone
Naphthalene
4,6-Dinitro-o-cresol
Pentachlorophenol
                   Phenol
                   Bis(2-ethylhexyl)phthalate
                   Butyl benzyl phthalate
                   Di-n-butyl phthalate
                   Di-n-octyl phthalate
                   Diethyl phthalate
                   Dimethyl phthalate
                   Benzo(a)anthracene
                   Benzo(a)pyrene
                   .Chrysene
                   Acenaphthylene
                   Pyrene
                   Fluorene
                   Toluene
                   Xylene
 Antimony
 Arsenic
 Cyanide
TOXIC METAL POLLUTANTS AND CYANIDE

                   Selenium
                   Silver
                   Zinc
 The Agency found methylene chloride at  high  levels  in  all   of  the
 wastewater  samples  from  one  plant.   The  Agency  decided   not  to
 establish limitations for that  pollutant  since  its  detection  most
 likely  resulted  from  its  use  as  a  cleaning solvent for  cleaning
 sampling devices  and  laboratory  glassware  used  for  sampling  and
 analysis  of  certain  toxic  organic  pollutants.   While  the Agency
                                    62

-------
believes the presence of phthalate compounds in wastewaters from  many
steel  industry jwastewaters is due to leaching of these compounds from
the tubing use with automatic sampling equipment, the Agency  believes
that   certain  !phthalate  compounds  are  contributed  by  cokemaking
operations.     :

The Agency found six individual phthalates (refer to  Table  VI-2)  at
varying  levels  at the five coke plants, with no discernible pattern,
except that bis('2-ethylhexyl) and di-n-butyl phthalate were most often
found, and dieth'yl and dimethyl phthalate the  least  prevalent.   But
for  a given plant, (e.g., 009) diethyl or dimethyl phthalate could be
found  at  higher  concentrations  than  the  more  common  ones.   As
discussed  later,  in this report, removal of other toxic organics that
are limited should insure control of phthalates.

Other Pollutants

Ammonia-N,  is  iuniversally  found  at  extremely   high   levels   in
wastewaters  from  by-product  recovery  cokemaking  operations.   The
originally promulgated BPT regulation contained ammonia-N limitations,
as does this regulation.  Ammonia is found at high  concentrations  in
raw  by-product! recovery  cokemaking wastewaters, is acutely toxic to
aquatic life at[relatively low levels, and exerts a significant oxygen
demand in receiving streams.

The prior regulation also  contained  limitations  and  standards  for
phenols    (4AAP),  which  are  found  at  high   levels  in  cokemaking
wastewaters.
                i
The Agency considered  establishing  limitations  for  two  additional
nontoxic  pollutants:  thiocyanates  and  sulfides.   Thiocyanates are
present in cokemaking wastewaters, and have a potential  for  breaking
down   into  cyanides  and sulfides under certain conditions.  Sampling
data   obtained  'during  coke  plant  visits  provides  a   basis   for
establishing  limitations  for   thiocyanates.  However, long  term data
for  existing   biological  treatment  facilities  also  indicate  that
thiocyanate   isi adequately  controlled  by the model treatment  systems
considered by the Agency.  The same  is true of sulfides.  Accordingly,
the Agency has  not promulgated limitations for these pollutants.

Additional  wastewater  characteristics  and  pollutants  studied    in
by-product cokemaking operations include acidity/alkalinity,  aluminum,
barium,   boron,! calcium,  carbon,   chloride,  cobalt, hardness,  iron,
magnesium, manganese, molybdenum, nitrate, potassium, silica,   sodium,
solids  (dissolved and volatile), sulfate, tin, .titanium, vanadium and
ytterbium.  Data for  these pollutants are available  in a supplement  to
this  report.  Based upon  low   levels  of these  pollutants   found   in
cokemaking  wastewaters,  or  their nontoxic characteristics,  the Agency
has  not promulgated  limitations  and  standards for  them.
                                     63

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Selected Wastewater Pollutants

The  Agency  has  promulgated  limitations  and  standards  for  those
pollutants  which  it  considers  to  be  most  representative  of the
pollutants found in  cokemaking  wastewaters.   These  pollutants  are
shown in Table VI-3.  These include the pollutants which were included
in  the original BPT limitations, and for by-product cokemaking, three
additional toxic organic pollutants.

Because of the high costs of monitoring for toxic organic  pollutants,
the Agency reviewed analytical data to determine if certain pollutants
can  serve  as  "indicators"  for  groups of other pollutants found in
cokemaking wastewaters.  The Agency concludes that certain  pollutants
can  be  used as "indicators" for other pollutants.  Six volatile, six
acid extractable and 17 base/neutral  toxic  organic  pollutants  were
found  in  cokemaking  wastewaters.   To regulate these 29 pollutants,
benzene was selected  to  indicate  the  presence  of  volatile  toxic
organic  pollutants;  phenols  (4AAP) to indicate the presence of acid
extractable   toxic   organic   pollutants;   and   naphthalene    and
benzo(a)pyrene  to  indicate * the  presence of base/neutral compounds.
Available data from EPA surveys at plants  0868A  and  0684F  indicate
that  effective  treatment  for  these indicator pollutants results in
comparable reductions or the elimination of  the  remaining  25  toxic
organic  pollutants.  Additional information on the use of "indicator"
pollutants is found in Volume I.
                                    64

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                                         TABLE VI-1

                            TOXIC POLLUTANTS KNOWN TO BE PRESENT
                                   COKEMAKING SUBCATEGORY
Toxic Pollutant
	Number	

     1
     3
     4
     20
     21
     22
     23
     24
     34
     35
     36
     38
     39
     ,44
     54
     55
     57
     60
     64
     65
     66
     67
     68
     69
     70
     71
     121
Pollutant
By-product Cokemaking Operations

               Toxic  Pollutant
                    Number
Acenaphthene                ;     72
Acrylonitrile      .              73
Benzene                          75
2-Chloronaphthalene              76
2,4,6-Trichlorophenol            77
Parachlorometacresol             78
Chloroform                       79
2-Chlorophenol                   .80
2,4-Dimethylphenol               81
2,4-Dinitrotoluene               82
2,6-Dinitrotgluene               83
Ethylbenzene                     84
Fluoranthene                     86
Methylene Chloride               114
Isophorone                       115
Naphthalene                      118
2-Nitrophenol                    119
4,6-Dinitro-o-cresol             '120
Pentachlorpphenol                121
Phenol                           122
Bis-(2-ethylhexyl)phthalate      124
Butyl Benzyl Phthalate           125
Di-n-butyl Phthalate             126
Di-n-octyl Phthalate             128
Diethyl Phthalate                130
Dimethyl Phthalate
Pollutant

Benzo(a)anthracene
Benzo(a)pyrene
benzo(k)fluoranthene
Chrysene
Acenaphthylene
Anthracene
Benzo(ghi)perylene
Fluorene
Phenanthrene
Dibenzo(a,h)anthrancene
Indenot1,2,3-cd)pyrene
Pyrene
Toluene
Antimony
Arsenic
Cadmium
Chromium
Copper
Cyanide
Lead
Nickel
Selenium
Silver
Zinc
.Xylene
                               Beehive Cokemaking Operations
Cyanide
                                            65

-------
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66

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                                         TABLE VI-3

                               SELECTED WASTEWATER POLLUTANTS
                                    COKEMAKING SUBCATEGORY
A.  By-Product Recovery Processes;
    Pollutant      ;
                   i
         Suspended Solids
         Oil and Grease
         Ammonia—N '
         PH        :

    4    Benzene   !
    55   Naphthalene
    73   Benzo(a)pyrene
    121  Cyanides, Total
    191  Phenols (4r-AAP)
                   !
B.  Beehive Process;
   Regulated in the
Originally Promulgated
	BPT Level	

          X
          X
          X
          X
          X
          X

     No Discharge
Selected For
Regulation at
     BAT
     X
     X
     X
     X
     X
     X

No Discharge
                                             67

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1

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                        COKEMAKING SUBCATEGORY

                             SECTION VII

                   CONTROL AND TREATMENT TECHNOLOGY
Introduction

A brief summary' of the wastewater  treatment  practices  used  at  all
twelve  plants i visited  during  this study demonstrates the different
approaches to treatment of cokemaking wastewaters.  A summary  of  the
technology  used  within  the  entire  subcategory  is also presented.
Included are descriptions of  the  control  and  treatment  technology
applied  to  co'kemaking  wastewaters  and more detailed discussions of
technologies used to treat or control specific pollutants.

Summary of_ Treatment Practices Currently Employed
               i
Wastewater treatment at beehive  coke  plants  is  relatively  simple,
since  the  only  waste flow requiring control is excess water applied
during  coke  Quenching.   Treatment   consists   of   one   or   more
sedimentation  ibasins  to  recover  the  coke  fines,  which  are then
returned to the' coking process.  Water which overflows the  basins  is
recycled  to  Extinction  as  quench  water,  with  the result that no
wastewater is discharged.
               !
For by-product 'coke plants,  many  factors  influence  the  choice  of
wastewater  coritrol  and  treatment  alternatives.   The many recovery
practices reported in Section  III  are  indicative  of  the  possible
combinations  found  in  this  subcategory.  Similarly, the wastewater
control and treatment techniques practiced at  operating  coke  plants
demonstrate  variations  unique  to  this subcategory, yet the best of
these tend to a'chieve similar quality effluent loads.  These treatment
systems include physical/chemical controls, biological  treatment,  or
combinations  tjhereof.   Some  operators  provide  complete  treatment
facilities while  others  provide  only  limited  pretreatment  before
discharging  thjeir  wastewaters  to  POTWs.   These latter discharges,
although usually lower in flow, contain considerably higher levels  of
pollutants  tha|n do the direct effluent discharges.  Zero discharge is
achieved  at  Sixteen .by-product  coke  plants  through  disposal  of
wastewaters in quenching operations or through oxidative incineration.
Both   of  these  practices  have  limited  potential  for  widespread
application because of the impact on air quality.

A summary of trie control and treatment technology currently  practiced
at by-product cokemaking operations follows:

1 .    By-Product! Recovery
               \
     The by-prqduct recovery  system  itself  controls  the  level  of
     pollutants;  discharged  since  the  by-products  recovered  would
                                     69

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otherwise be part of the  untreated  wastewater   load   if   excess
ammonia  liquor  was  discharged  untreated.  Recoveries practiced
include:

a.   Crude coal tar - coal  tar   from   the  flushing   liquor   and
     primary   coolers    is   collected  for  resale   or   further
     processing on or off-site.   Crude  coal tar  is  recovered  at
     all by-product coke  plants in tar  decanters.

b.   Crude light oils - light oils are  scrubbed  from the coke
     oven  gas,  recovered  for   resale,  reuse   as a  solvent  for
     phenolics, or for further refining on or off-site.

c.   Ammonia and ammonium compounds  -  free  ammonia is  steam
     stripped  from  excess  ammonia  liquors at  most  plants.  Of
     those plants with ammonia stills,  about  half  also   recover
     fixed  ammonia  by   elevating the  pH of the  wastewaters with
     lime  slurry  or  caustic  soda  solutions.   The liberated
     ammonia   is directed into the coke oven gas  and removed with
     ammonia contained in the gas  with  sprays   of  sulfuric  or
     phosphoric   acid  in  an  absorber  (semi-direct recovery,
     practiced at 46 plants), or  by scrubbing  ammonia from   gas
     with   fresh   water,   which  is  recirculated   to  produce
     concentrated   ammonium   hydroxide   (indirect    recovery,
     practiced at 6 plants).

d.   Phenol, phenolates and carbolates  -  between  one-third   and
     one-half  of operating coke plants practice  dephenolization,
     either by vapor recirculation  or  liquid/liquid  extraction
     with  suitable  solvents.  In vapor  recirculation, the steam
     leaving the free leg of the ammonia  still is  scrubbed with
     dilute  caustic  soda  to form sodium phenolate.  This steam
     recirculates to the  ammonia stills for further-treatment  and
     recovery.  In solvent extraction,  the benzol, light oil,  or
     other  suitable solvent extracts phenolic compounds from  the
     wastewater.    The  phenolized  solvent  is   separated   and
     extracted  with  caustic.  Again,  sodium phenolates separate
     out, and the dephenolized solvent  is reused  in the  recovery
     system.

e.   Sulfur and sulfur compounds  -  eight  of  the  larger  coke
     plants,   representing 34% of the coke production  capacity in
     the United States,  have  desulfurization  systems  to  clean
     coke  oven gas for subsequent reuse  and to recover elemental
     sulfur  or  sulfur   compounds,   e.g.,    ammonium   sulfate.
     Techniques developed include iron  oxide boxes using Fe203 on
     wood  shavings;   absorption  and   desorption  with soda ash;
     Wilputte vacuum carbonate system;  Seaboard actified solution
     system;   Glaus  sulfur  recovery   systems;   and   a   Takahax
     absorption/Hirohax sulfur recovery system.

f.   Naphthalene - This compound is recovered at about 70 percent
     of the by-product  coke  plants.    Crystals  of    naphthalene
                                70.

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          condensed  in
          recirculating
          filtration  or
          crystals which
          However,   at
          between 74C°
          two I plants
           the   final  cooler   are   recovered   from   the
            final   cooler   wastewater    by    skimming,
            centrifugation.  At most plants, naphthalene
           solidify below 74°C  (165°F)   are   recovered.
           one   plant,  naphthalene  which crystallizes
         and 79C°  (165° to  174°F) is recovered; and,  at
         naphthalenes  solidifying   above or  below  74°C
          (165°F), are recovered separately.

     g.   Other by-products - recovery of  additional  by-products  is
          normally  related  to  the  further  refinement  of products
          recovered  above  in  cruder  mixtures,  or  in  alternative
          approaches  to  the  basic recovery techniques which lead to
          other forms.  For example, instead of recovering ammonia  as
          a su,lfate, phosphate, or hydroxide, one plant is designed to
          convert  ammonia  into  anhydrous ammonia, readily usable as
          fertilizer or for  other  chemical  processes.   Specialized
          recoveries  at  that  same  plant  include cresols, cresylic
          acid, and picolines.
              i
2.    Initial Treatment Practices
              i                                            -

     Once  the(se   various   levels   of   by-product   recovery   are
     accomplished,   contaminated  wastewaters  remain  which  require
     treatment! before discharge.  The general  practice  is  described
     below:    i                                               •

     a.   Recovery of free ammonia from excess  ammonia  liquor  only.
          This  step  is  considered to be by-product recovery, and is
          not [included in pollution control costs because of  its  use
          irrespective of water pollution control requirements.
              *                                              '
          Dephenolization of weak ammonia liquor, benzol plant wastes,
          and
final cooler blowdowns.   As in the case of free
                                                               ammonia
          stiLls,   this  step is considered to be by-product recovery,
          and Is not included in costing of pollution control systems.
          Wherie  dephenolizers  exist  at   plants   with   biological
          treatment  systems, they are usually not operated because of
          the | weak  market  for  recovered  products  and  the   high
          efficiency   of   phenol  removal  in  biological  treatment
          systems.

          Sedimentation   of   dephenolized   wastes,    miscellaneous
          wastjewaters  and  once-through  crystallizer wastewaters, if
          any,' in  a settling pond.

          Recycle  of coke quenching wastewaters to extinction with  no
          runoffs.    Makeup  to. the quench system is fresh water only,
          or  fresh  water  plus air pollution emission control  scrubber
          blowdowns,  if any.
                                   71

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Biological Treatment
a.
 d.
Assuming the above starting point, the first additional step
is the addition of a fixed leg to the  ammonia  still,  with
provision  for adding a lime slurry or caustic soda solution
and additional steam.  This  step  effectively  strips  more
ammonia from wastewaters.  The resulting high pH wastewaters
are  again  neutralized  with  acid.  At a few bio-oxidation
treatment plants, the stripping  of  fixed  ammonia   is  not
practiced  and  instead  a two or three to one dilution with
fresh water is used to bring the ammonia concentration  down
to  levels  which  will  not  inhibit  biological  activity.
However, this practice results in excessive flows and higher
pollutant loads in plant effluents.

A single stage  activated  sludge  bio-oxidation  system   is
provided  to  treat neutralized still wastes.  Dephenolizers
are  often  abandoned  at  this  point,   since   biological
treatment   can   control  phenolic  compounds  effectively.
Aeration is provided by mechanical agitation or through  the
use of large blowers.

Advanced bio-oxidation systems include  a  second  stage   of
biological  treatment,  or provide for extended oxidation  in
one stage.  The activated sludge  in  the two stage system may
be collected and  recycled   separately  at  each  stage,   or
collected  after  .the second stage and recycled to the  first
aeration basin as practiced  at  plant  003.    The  effluents
from   these  multi-stage  biological  reactors are   further
treated  by  sedimentation   in  a    clarifier   and,    where
necessary,  pH  adjustment   is  made.   A  possible  sequence
involves phenol  removal   in the   first  of   three   stages,
cyanide  and ammonia oxidation to  nitrites and nitrates in a
second stage, then  denitrification  in a final  stage  prior  to
aeration and discharge.   Systems  observed during   the  field
surveys  include  single   stage   and two stage bio-oxidation
reactors.  All   have  varying  degrees  of  dilution  water,
although   several   operate   without  dilution  for  months at a
time.  Also, a noncontact cooling  system has  been  installed
at one  plant   to  control  temperature, a  critical  factor  in
treatment  plant  operations.   As  a result,  dilution water  has
been  essentially  eliminated at  this  plant.

As an  alternate  to  the  above   systems,   a  single  stage
activated  sludge  system  can be  operated with  high sludge age
to produce   comparable   effluent quality.   This  alternative
would not  require any  major capital  modifications to several
of  the  biological  systems  currently   installed   in   the
 industry.    However,   changes in operating practice would be
required.

A system which  adds powdered activated carbon  to  a  single
stage  bio-oxidation  system  is  currently   being tested to
                                 72

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          determine  the  degree  of  effluent  reduction  attainable.
          Benefits are anticipated in improved toxic organic pollutant
          andj  suspended  solids  removal;  elimination  of color from
          plant effluents; enhanced oxidation and nitrification-  and
          increased stability under shock loads.                '     '

     e.   A  final   polish   by   filtration   provides   significant
          improvement  in  total  suspended solids removal.  Deep bed
          mixed media pressure filter systems are demonstrated  in this
          application.
             f                                 .
4.    Physical/Chemical  Treatment

     a    Assuming the  level  of treatment  described  in  Paragraph  2
          witj    a   dephenolizer,    the  first  level   of  additional
          technology includes a fixed leg on the  ammonia  still  with
          provisions for  adding a lime slurry or caustic soda solution
          and  additional  steam  to   strip  fixed  ammonia  from  the
          was^ewater.   Since  a high pH results  from  this  treatment,
          neutralization  with acid must  be provided  before the treated
          wastes   are  discharged.    Miscellaneous  process wastes are
          sometimes  rerouted  to  pass  through  both stills   and  the
          dephenolizer.
             i            '                 •  -  '

          The• j  addition of  a  fixed ammonia still  to  the  operation of  a
          well!  designed  and  operated  '  dephenolizer    can    produce
          effluents   of    sufficient    quality   to  achieve   the BPT
          limitations.
             i                        .

    b-.    At  t;his  point,  several  options  are  available  for  those
          plants   which do  not  have biological treatment  systems.  One
          potential route for plants discharging as  point  sources  is
          toward   adsorption  of organics  on activated carbon.   Before
          this,  can be  accomplished  at  a  reasonable  cost,   certain
          preliminary steps must be carried  out as follows:
         (1)
         (2)
• Flows, must be minimized wherever possible.   Barometric
i condensers  on  crystallizers  should be recycled, with
; 4-6-s blowdown to treatment.   Final cooler recycle loops
, should  be  tightened,   and   miscellaneous  wastewaters
; should be reduced to minimum flow through prevention of
|leaks and spills.
i                     .    •  .          •    .. .

iThe wastewaters from the settling pond or sedimentation
;unit are filtered to remove  the  suspended  solids  and
iany tars or floating material which may remain,  and are
:then  passed  through  activated  carbon  columns.  The
iresulting  effluent   is  discharged.     Filtration   is
:accomplished -most effectively by deep bed,  mixed media
ipressure units,  although other filtration  alternatives
[are available.
                                 73

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c.
d.
          An  alternative  preliminary  treatment  sequence  prior  to
          adsorption  on  carbon  would  provide  aggressive oxidation
          using chemicals such as .chlorine,  chlorine  dioxide,   sodium
          hypochlorite,   ozone,   or  peroxides  to  destroy  organic
          pollutants,  ammonia and cyanides.   The acid addition in step
          4(a) above would be relocated.'   A  typical  sequence  using
          chlorine  would  include  aeration;  aggressive oxidation at
          high pH (alkaline chlorination); neutralization,  using  the
          relocated  acid  addition  equipment  from above; breakpoint
          chlorination; suspended solids removal by  sedimentation  or
          filtration;   and  a  final  polish by passing the wastewater
          through activated carbon columns.

          Plants  which  discharge   wastewaters   to   publicly-owned
          treatment  works currently practice an intermediate level of
          treatment.  For  example,  one  plant  visited  during  this
          survey  has  aggressive  oxidation  with chlorine to provide
          batch treatment of excess ammonia liquor prior to discharge.
          Treatment is  carried  out  only  to  the  degree  that  the
          wastewater is acceptable to the regional sanitary authority.
          Most   plants   discharging  to  POTWs,  including  the  one
          mentioned above, do not provide sufficient  pretreatment  to
          prevent  discharge  of pollutants which interfere with, pass
          through, or are otherwise incompatible with POTW operations.

5.    Incineration/Evaporation

     a.   Another  alternative  approach  to  coke  plant   wastewater
          treatment  and  disposal  has been practiced at at least two
          plants, and was planned for  a  third  plant.   All  of  the
          wastewaters   from   the   coke   plant  are  distilled  and
          incinerated  in controlled combustion systems.  Coke oven gas
          and crude coal tar are the only by-products  recovered,  and
          no  wastewaters  are  discharged  to receiving streams or to
          sanitary authorities.  The system is viable only  where  the
          impact  on air pollution can be tolerated, and therefore has
          limited potential for widespread application.

     b.   Zero discharge  of  pollutants  from  by-product  cokemaking
          operations   is  achieved  at some plants by disposing of the
          process wastewaters in coke quenching.  An adverse impact on
          air pollution occurs as a  result  so  this  alternative  is
          expected  to  gradually decline as a solution to the problem
          of  wastewater  disposal.   The  nature  and  magnitude   of
          pollutant  emissions from quenching operations have been the
          subject of extensive study both here and abroad.  Tests were
                                                       100!
                                                                 fresh
conducted comparing emissions from plants using
water  make-up  with  those  from plants with treated and/or
untreated process wastewaters for  make-up.   At  least  one
researcher conducted tests on the same quench stations using
fresh  and  contaminated  make-ups  while  maintaining other
conditions  as  constant  as  possible.   Researchers   have
concluded  that  a  typical  "dirty  water"  quench  station
                                74

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c.
            releases  more  than  twice  as  much  participates;  four  times as
            much  benzene-soluble   organises;   more   than-  twice  as   much
            benzo(a)pyrene;   and,   nearly  nine  times  as  much'benzene to
            thejsurrounding  atmosphere than do the  same operation   usinq
            clean water"  for make-up.

            SinCe by-product  coke  plants must continuously  dispose  of or
            otherwise eliminate water originally locked up   as  moisture
            in  |coals,  the   only  likely approach to zero discharge from
            coke  plants   would  be  to  require  treatment of  process
            wastewaters  to   an  extent where, their use for coke or slag
            quenching would not  affect  air  quality.    This  level   of'
            treatment  would  approximate  the  more   advanced stages of
            biological or  physical/chemical systems described  above   as
            applicable   to  point  source  dischargers.    The  critical
           pollutant  mitigating  against  the  use    of    well-treated
           wastewaters  for  quenching  is dissolved  solids,  since such
           solids become  airborne particulate as the  water  evaporates
           Since  the  capital  and  energy  requirements   for  removing
           dissolved solids from coke plant wastewaters  are  high    it
          fdoes  not  appear likely that dissolved solids  controls will
  .         be implemented at any plants.

 Control and Treatment Technologies for  BPT

 Two treatment alternatives were  identified   as  model  BPT  treatment
 technologies   : for    the   prior   regulation.     One  is  based  upon
 physical/chemical and biological treatment,  while the  other  included
 ?nX*o£ ?£1C31/CheSi(?1    controls.     The   physical/chemical   system
 includes the  by-product  recovery operations  noted in  item 1 above   and
 the following Wastewater  treatment operations:   fixed ammonia removal;
.dephenolization;  pH  control;   and,  \sedimentation.    The  biological
 alternative  dpes   not   include   dephenolization,   but  does    include
 aeration   equipment,    biological   oxidation   basins  and  associated
 clarifiers  for: suspended  solids  control.

Although the  BPT limitations can  be  achieved with   either   alternative
™°5e? ™°re/  P16 Aaency  has used onlV  the biological alternative  as a
model BPT treatment  system  for this  regulation  to  be   consistent   with
the  selected  BAT model treatment  system.

Control  and Treatment Technologies for BAT,  PSES,  PSNS and NSPS

Of   the   various  control and treatment options available  for advanced
treatment of  by-product cokemaking wastewaters, the Agency considered
?.  . i.fo.lowing! model  treatment  system  to achieve the promulgated
limitations   and  standards.   The  model  system   incorporates    the
following treatment steps.

The   first   step   involves  minimizing  process  wastewater  flows
Barometric  condenser or crystallizer wastewaters are  recycled   with   a
=in°KK blowdov™  (4%)  to  treatment.   Air pollution  emission  control
scrubber loops ;are recycled at high rates.  Slowdowns  from  preheating
                             75

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and  charging  are  treated  in  the  BPT system, while blowdowns from
Ske-Side^Subbers are settled "and  then  used .to  ^lace  ^tion
uiat-^r  at  the  biological  treatment  system.  For PSES and Pbwt,, tne
b?o?ogical treatment Itep is not included since  biological  treatment
is provided at POTWs.    .             -    -'

For  the  BAT  model  treatment  system, a second or extended stage of
bioloaical  treatment  is  added.   For  costing   purposes   separate
                                                                    ,  ;


 adverse impacts  on air quality.

          Flow minimization occurs earlier,  since it can be
         plant designs without regard for existing treatment components

                                                                 '
         2-
                                                            o
SastSwater b  quenching is not considered to be  appropriate  for
sources for the reasons cited above.
                                                                    new

   ehie   sgmnt   of  the  cokemaking  subcategory.
 cokemlking operations are located in areas remote from POTWs   and   it
 is  highly  Snlikely  that  new  beehive operations will be built .the
 Agency  has  not  promulgated  pretreatment  standards   for   beehive
 cokemaking.

 Plant Visits

 Nine by-product 'coke plants and  three beehive  coke plants were visited
 diring  this  study; four by-product and all beehive plants during  the
 spring of  1973? and the remaining five by-product plants  during   1977
 SS  ?978    Table  VII-1 provides  a key to  the  symbols used  in Tables
 VII-2  3 and 4  and other tables  to. describe  control  and   treatment
                                    . 76

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 technology.   |Tables  VII-2   through  VII-4  present  raw  wastewater  and
 effluent concentrations and  discharge loadings  for each  plant   studied
 ?""?g  ^he   two  surveys.    A   brief  description   of each  wastewater
 treatment  system  follows.   More  details   are  available   on    the
 wastewater  flow  diagrams   as   indicated  by  a  figure  for  each plant
 visited.

 Plant A (0432B) - Figure VII-1
               j
 Excess  ammonia  liquor,  final  cooler  blowdown,   and  benzol  plant
 wastewaters   .are   subjected  to  free  ammonia  -stripping,  then  to
 dephenolization by the  solvent  extraction   technique.   Dephenolized
 liquors are conveyed to a settling sump, then to  the receiving stream.
 .Barometric  condenser  water discharges direct  to the receiving stream
 without treatment.   Quench runoffs are recycled to  extinction.    Onlv
 fresh water is used for quench makeup.

^Plant B (0112); - Figure VII-2

 Excess ammonicj liquor is collected and equalized  (five day retention)-
 diluted  3:1   iwith   noncontact  cooling  water from light oil coolers'
 blended with   [phosphoric  acid,   antifoam  and  steam;   treated   in  a
 single-stage   grated  activated  sludge  lagoon  (8   hour retention);
 clarified;  and discharged to the receiving stream.  The  bulk  of  the
 sludge -is  ^circulated,   with   minor   blowdown of  sludge to a  sewage
 treatment plant.  Final  cooler blowdown  and benzol  plant  wastewaters
 are  diluted  1:2  and  are disposed of  by  coke quenching.   Quench  waters
 are recycled  to  extinction.   Coke  wharf   drainage  is   collected  and
 impounded  in  at lagoon with  no outlet.
               i       -  .      -
 Plant C (0384AJ) - Figure VII-3

 Excess  ammonia   liquor   is   dephenolized  by  light  oil  extraction-
 stripped of free  and fixed   ammonia,-  settled   (two  to  three  hour
 retention);   and  discharged   to   a POTW  for  further  treatment.   Final
 cooler blowdown and benzol plant  wastewaters  are used  as  makeup   for
 coke  quenching'.  Quench  runoff and  coke wharf drainage  are  recycled  to
 extinction at  quench  stations.  At  least  one  quench station uses  fresh
 water makeup only.

 Plant D  (0272)'- Figure VII-4

Excess  ammonia  liquor  is conveyed to a desulfurizer  tower- filtered
 (ceramic media); dephenolized  by  solvent  extraction;  stripped of  free
and   fixed  ammonia;  diluted  (88:1)  by a cooling water stream; and,
discharged to  the receiving stream.  Quench stations  use  fresh  water
makeup only, with no discharge.

Plant  001 (0732A) - Figure VII-5

Excess   ammonia  liquor  is  equalized;   stripped  of  free  ammonia-
dephenolized by vapor recirculation; diluted  (85:1) with cooling water
and other wastewater flows;  and  discharged   to  a  receiving  stream
                                     77

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of the survey.

Plant 002 (0464C) - Figure VI I -6

Excess  ammonia  liquor  and  final cooler "owdown is de Pgenollzed by



makeup for coke quenching, which is recycled to extinction,

Plant 003 (0868A) - Figure VI 1-7

        ammonia  liquor  and  miscellaneous wastewaters are equalized^

                                                            -    ation
Excess
                                                                wit   no



water  is  recycled  to  extinction.

plant  008 (0920F)  - Figure VII-8






makeup and have no discharge.

Plant  009 (0684F)  - Figure VI I -9  (Physical/chemical system)




 carbon-  and,  free  and  fixed  ammonia  stripping.    Benzol   Plant
 wastSwaters  from  two plants are mixed; passed through gas flotation;
 ™Sd Sedil fiUration;Pand, adsorption by activated carbon  prior  to
 disposal in coke quenching.

 Plant E  (0428A) -  Figure VII-10

 Coke  quench  runoffs  are  treated  "once-through" in simple  settling
 ponds, with no provision  for recycle.
                                      78

-------
 Plant F (0428A) - Figure VII-11
 Coke quench runoffs are collected in a settling basin.  The  overflows
 are recirculated to quench stations with no aqueous discharge from the
 plant.

 Plant G (0724G) - Figure VII-12
             . [                                 .
 Coke  quench , runoffs are collected in primary settling ponds, further
 clarfied in secondary settling  ponds,  and  are  recycled  to  quench
 stations.   There is no wastewater discharge from this plant.

 Summary of Monitoring Data
              I
              I
 A  review   of:  data presented in Tables VII-2 through VII-4 shows that
 certain bio-ojxidation and carbon adsorption systems are  effective  in
 reducing  toxlic  organic  pollutants  to  low  levels  from by-product
 cokemaking opjerations,  and that the total  recycle  of  wastewater  in
 beehive cokemaking  operations  effectively  controls discharges from
 these plants.^
              E '                 ""**
 Biological systems  have been  used/for  treating cokemaking  wastewaters
 for  a  number  of   years,  with the removal of phenolic compounds as  a
 primary goal.;  Although a great deal of information  is  available on
 the  performance of  activated  sludge  units in  controlling phenolic
 compounds,  the development  of data  regarding  toxic  pollutants   other
 than    phenolic  compounds   and  cyanides  has   only  recently  been
 undertaken.   Less operating data fo'r   toxic  organic  pollutants  are
 available  from full  scale activated  carbon  adsorption treatment  plants
 since,   thus•;far,  only two companies  have  installed  and operated such
 technology.   ,EPA   sampling  survey  data  demonstrate   that   either
 technique   can eliminate more than  90%  of all  toxic organic pollutants
 present in coke plant wastewaters,   although  the   biological  systems
 have  certain  operating  cost advantages.

              i
 Originally, advanced levels of  treatment  using biological  systems were
 expected -to  ;involve   multiple   stages   for  accomplishing  selective
 degradation  of  pollutants  in   series,  e.g.,  ammonia  and  cyanide
 removal,    nitrification  and  denitrification.    The   two  bio-plants
 surveyed for toxic pollutant  removals  (Plants  003  and  008)  control
 toxic pollutants using  a single  stage  (008)  or two  identical  stages in
 series   (003).   The  second  stage  at   Plant  008  has been put  into
 operation since  it was  originally surveyed.  Overall removal of   toxic
 organic  pollutants  averaged better than 90% with  phenolic compounds,
 naphthalene,.benzo(a)pyrene,  acenaphthylene  and   xylene   reduced  at
 rat.es   greater  than  99%.   Chloroform appeared to be  the  major  toxic
organic  pollutant  which  persists  in   the   final    effluents,   at
concentrations; of 0.2 mg/1.  Measurable amounts of  benzene  and toluene
alsOQ  remain,  ; even  though  the  systems have removal  efficiencies of
96.7^5 or better.  High  concentrations of  these  two  pollutants  were
originally  present in raw wastewater, thus even very effective removal
efficiencies  :Still   leave  behind  measurable  residues.   Despite the
                                    79

-------
continued presence of fractions of a milligram per liter for a limited
number of organic pollutants, activated sludge systems  proved  to  be
very  effective  in  controlling  toxic  organic  effluents  from coke
plants.  The model BAT biological treatment system has been  shown  to
remove  virtually  all  toxic  organic  pollutants  to near detectable
levels.

Data for one of the full-scale carbon adsorption systems is  presented
wherever  Plant  009  is  Discussed. : These data demonstrate uniformly
good removal efficiencies for most of the  toxic  organic  pollutant?.
Exceptions  include chloroform and acrylonitrile, which was reduced by
74.3% but still appeared at  a  concentration  of  0.19  mg/1   in  the
effluent.     Poor   removal   efficiencies
for   ethylbenzene
                                                                   and
parachlorometacresol 'are""primarily  due  to  their   extremely   low
concentrations   in   untreated  wastewater,  <0.002.  and   0.007  mg/1
respectively.  In general, field sampling at  Plant   009
   ^  _ _.  .  ,         j   _ 	J_J	_1_A.J)  fm ~* *«• In *^ »* *^ *•! r* *
the  effectiveness  of
organic pollutants.
                                                           demonstrates
                        * A /  o.J.^ia.v-1  b_»»-*iii^ .1. ^ « *>9  «» w   — —	   — -              ^
                        activated carbon adsorption  for  treating toxic
Comparison  of  Data

As mentioned above,  the availability of long-term data for many of the
toxic pollutants  is  limited.   However,  considerable data are available
for pollutants such  as phenols (4-AAP), cyanides, ammonia-N,  oil  and
grease,  and suspended solids.   Table,711-5 compares the long-term data
for  those  pollutants reported for two plants,  with short-term results
observed during EPA  sampling  surveys at the same sampling point.  Witn
few exceptions, these data are in good agreement.

Effect  of Make-up Water Quality

Where  the mass loading of a limited pollutant in the make-up water  to
a process   is small  in  relation  to  the raw waste loading of that
pollutant,  the impact of make-up water quality on wastewater treatment
system performance  -is  not  significant,  and,  in  many  cases,  not
measurable.   In   these  instances, the Agency has determined that the
respective  effluent  limitations and standards should be applied  on  a
gross  basis.

Table   VII-6   presents  an  analysis  of  the  effect of make-up water
aualitv on  the raw waste loading of each of the pollutants  limited  in
the   regulation  for  the  cokemaking  subcategory.  The make-up water
aualitv data and  raw waste load data were  obtained  from   coke  plant
sampling  surveys completed for this study.  The analysis demonstrates
that  make-up water quality for all  limited pollutants except suspended
solids is insignificant compared to the raw waste  loading.  Note  that
 for    suspended   solids  in  the  make-up  water,  the  next   highest
 concentration  to the maximum  concentration of  287  mg/1   is   11  mg/1.
 Notwithstanding  the  potential for high  levels  of suspended solids in
make-up waters, the model biological treatment   systems   contain  bio-
 oxidation units that operate  with mixed-liquor suspended solids  levels
 of  up  to  5000  to   10,000  mg/1.  These solids  are removed  prior to
 discharge.   Thus, the  impact  of high make-up   water  suspended   solids
                                                                            1

                                      30

-------
concentrations  is  not  significant  for  cokemaking operations.  The

Agency has determined that the limitations  and  standards  should  be

??? *?7^°n  *  g^oss  basis,  except to the extent provided by 40 CFR
I // . o J vn ; .     '
                                  81

-------
                               TABLE VII-1

                 OPERATING MODES, CONTROL AND TREATMENT
                    TECHNOLOGIES AND DISPOSAL METHODS

                                 Symbols
A.      Operat-ing Modes

        1.   OT

        2.   Rt,s,n
                   Once-Through

                   Recycle, where t =
                                  s =
                                  n =

                                  t:
                                      type waste
                                      stream recycled
                                      % recycled

                                      U = Untreated
                                      T = Treated
 B.
 C.
             P
             F
             S
             FC
             BC
             VS
             FH

             REt,n
              BDn
            Process Wastewater %
            Flume Only         %
            Flume and Sprays   %
            Final Cooler       %
            Barometric Cond.   %
            Abs. Vent Scrub.   %
            Fume Hood Scrub.   %
                                 of raw waste flow
                                 of raw waste flow
                                 of raw waste flow
                                 of FC flow
                                 of BC flow
                                 of VS flow
                                 of FH flow
                    Reuse,  where  t  =  type
                                 n  =  % of  raw waste  flow

                                 t:   U = before  treatment
                                     T = after treatment

                    Slowdown, where n = discharge as % of
                                        raw waste flow
Control Technology

10.  DI             Deionization

                    Spray/Fog Rinse

                    Countercurrent Rinse

                    Drag-out Recovery
11.  SR

12.  CC

13.  DR

Disposal Methods

20.  H

21.  DW
                             Haul Off-Site

                             Deep Well Injection

-------
TABLE VII-1r
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 2      !
        Disposal Methods (cont..)
        22.  ! Qt,d
                    Coke Quenching, where t =  type
                                          d =  discharge as %
                                               of makeup

                                          t:  DW = Dirty Water
                                              CW = Clean Water
        23.  , EME

        24.  ! ES

        25.  ! EVC
                    Evaporation, Multiple Effect

                    Evaporation on Slag

                    Evaporation, Vapor Compression Distillation
    i
Treatment Technology           ,
    r          "     '

30• Isc             Segregated Collection

                    Equalization/Blending

                    Screening

                    Oil Collecting Baffle

                    Surface  Skimming (oil,  etc.)

                    Primary  Scale Pit

                    Secondary Scale Pit

                   Emulsion Breaking

                   Acidification

                   Air Oxidation

                   Gas Flotation

                   Mixing                                (

                   Neutralization, where t = type

                                         t:  L •= Lime
                                             C = Caustic
                                             A = Acid
                                             W = Wastes
                                             0 = Other, footnote
       31.  ,E

       32.  |Scr
            I
       33.  | OB

       34.  ;SS
            !

      ' 35.  |PSP
            i
       36.  ;SSP

       37.  ;EB

       38.  ;A

       39.  :AO
            i
       40.   JGF

       41.   JM

       42.   !Nt
                                   S3

-------
TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 3		
        Treatment Technology (cont.)

        43.  FLt            Flocculation, where t
         44.   CY

        44a.   DT

         45.   CL

         46.   T

         47.   TP

         48.   SLn


         49.   BL

         50.   VF


         51 i  Ft,m,h
                        type
                    t:   L  = Lime
                        A  = Alum
                        P  = Polymer
                        M  = Magnetic
                        0  = Other, footnote

Cyclone/Centrifuge/Classifier

Drag Tank

Clarifier

Thickener

Tube/Plate Settler

Settling Lagoon, where n = days of retention
                           time

Bottom Liner

Vacuum Filtration  (of e.g., CL, T, or TP
                   .underflows)

Filtration, where  t  = type
                   m = media
                   h  = head

      m               h
              D = Deep Bed
              F = Flat Bed
          52.   CLt
    S = Sand      G = Gravity
    0 = Other,     P = Pressure
        footnote

 Chlorination, where t = type
                                                  t:  A = Alkaline
                                                     B — Breakpoint
          53.   CO
                              Chemical  Oxidation  (other than CLA or CLB)

-------
TABLE VII-1    ;
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 4         '
D.
Treatment Technology (cont.)
        54.  BOt
        55.   CR

        56.   DP:

        57.   ASt
       58.  APt
       59.  DSt!
               i

               [

               i

       60.  CT !
               I
       61.  AR :

       62.  AU j

       63.  ACti





       64.  IX :.
               I
               F
       6,5.  RO '
               [
       66.  D   ;
                    Biological Oxidation, where t = type
                                                t:   An = Activated  Sludge
                                                    n  = No.  of Stages
                                                    T  = Trickling  Filter
                                                    B  = Biodisc
                                                    0  = Other,  footnote

                    Chemical  Reduction  (e.g.,  chromium)

                    Dephenolizer

                    Ammonia Stripping, where t =  type

                                            t:   F =  Free
                                                L =  Lime
                                                 C =  Caustic

                    Ammonia Product, where t = type

                                          t:  S = Sulfate
                                              N = Nitric Acid
                                              A = Anhydrous
                                              P = Phosphate
                                              H = Hydroxide
                                              0 = Other, footnote

                   Desulfurization, where t = type

                                          t:   Q = Qualifying
                                              N = Nonqualifying

                   Cooling Tower

                   Acid Regeneration

                   Acid Recovery and Reuse

                   Activated  Carbon, where t = type
                                           t:  P = Powdered
                                              G = Granular
                   Ion Exchange

                   Reverse Osmosis

                   Distillation

                            85

-------
TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 5              	__
D.
Treatment Technology (cont.)
        67.  AA1

        68.  OZ

        69.  UV

        70.  CNTt,n
        71.  On

        72.  SB

        73.  AE

        74.  PS
                    Activated Alumina

                    Ozonation

                    Ultraviolet Radiation

                    Central Treatment, where t = type
                                             n = process flow as
                                                 % of total flow

                                             t:  1 = Same Subcats.
                                                 2 = Similar Subcats.
                                                 3 = Synergistic Subcats.
                                                 4 = Cooling Water
                                                 5 = Incompatible Subcats,

                    Other, where n = Footnote number

                    Settling Basin

                    Aeration

                    Precipitation with Sulfide
                                     06

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                                               II
104

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II

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               ;          COKEMAKING SUBCATEGORY

               |           :.   SECTION VIII
               I                     ''  •           .
              CJOST,  ENERGY, AND NON-WATER QUALITY IMPACTS
 Introduction  |

 This section presents the estimated  costs  of  applying 'the  various
 alternative wastewater treatment systems.   The analysis, also considers
 the  energy  requirements  and  non-water  quality  impacts (including
 sludge disposal  and by-product recovery)   associated  with"  compliance
 with  the  promulgated BPT,  BAT, BCT,  NSPS, PSES,  and PSNS limitations
 and standards.

 All of the basjic components  of the various model treatment systems are
 presently  in [ use.    In  addition,   as  there   are   many   possible
 combinations  'and  variations of the treatment systems available which
 may be used to[ achieve the limitations and standards,  not  all  plants
 will   be   required   to  add  all  of the treatment system 'components (or
 incur  all of'the incremental costs indicated) ..to bring facilities into
 compliance with  the  limitations  and   standards.    Estimates  of  the
 capital   investment  required to bring all by-product  and beehive coke
 plants into compliance with  the  BPT  and BAT limitations are  presented
 in  this section.                  .          ,         '

 Comparison of. Industry Costs and EPA Model Costs

 The water  pollution control  costs  reported  for plants visited during
 this study are|presented in  Tables VIII-1  and   VIII-2   for  by-product
 and   beehive  :operations,   respectively.   The  individual   treatment
 systems,  gross'; effluent  loads, and reductions  achieved  are   described
 in  Section VIII   The  Agency  determined actual  industry costs from data
 supplied   for  ,the  plants (all  costs  converted to  July 1978 dollars).
 Standard  cost of  capital  and depreciation   percentages were  used  so
 that these basic  costs would be  comparable from plant  to  plant.

 In  general, tljie  costs varied  primarily with  increasing sophistication
 of  treatment systems,  and  less-with  the size of the treatment   system.
 Annual  costs  ; f or  three biological  oxidation .plants  (B,  003,  and 008).
 are lower  thanithose  for  physical/chemical  systems,   especially  for
 energy and  chemicals.                                      .
Table  VIII-3  jprovides  a  comparison of
estimated cost^ for facilities in-place at
physical/chemical   plants.    Footnotes
information  relating  to  factors  which
             observed.   For  some plants,
              by  coke  quenching,  thus
             requiring  treatment.  Overal
             the industry's capital  costs
differences
disposed  of
wastewaters
within 4% of
actual industry costs vs EPA
 seven biological  and  five
 to   Table  VIII-3  provide
 contribute • to   the   cost
 some of the wastewaters are
minimizing  the  volume   of
1,  model-based estimates are
  and  13%  lower, than  the
                                  107

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industry's  annual  costs.   The Agency concludes that its model-based
estimates accurately reflect actual costs incurred  by  the  industry.
As a whole, cost estimates based upon models are sufficiently generous
to  cover  initial  investment  costs  including  land acquisition and
clearing, retrofitting new systems to old production  facilities,  and
other site specific costs as well as the cost of capital equipment.

For  beehive  operations,  capital and annual costs reported for three
plants proved  to  be  a  small  fraction  of  model-based  estimates,
primarily   because  the  model  includes  a  standard  allowance  for
roadways, fencing and buildings associated with wastewater  treatment,
while the actual  beehive plants either do not have such components or
such  costs were not reported.  For, beehive operations, the wastewater
treatment components could usually  be  provided  at  low  cost.   For
example,  at  plant  E  a  settling  basin was installed for less  than
$7,000 by using the natural contours of their site and a small earthen
dike.  The model estimate for the basin,  including  site  preparation
and  excavation,,  would  be about $36,000.  In every case, model costs
are at least four times greater than actual  plant  cost  for  beehive
cokemaking operations.

Control and Treatment Technology (C&TT)
Considered for Use in Cokemaking Operations

The  control  and  treatment technology (C&TT) in Use or avail-able for
use for cokemaking operations is presented in Table VII1-4.  It  should
be recognized that this regulation does not require  the  installation
of  these  C&TT  steps.   Any other, alternative treatment system which
achieves the limitations are acceptable.  In addition to  listing  the
treatment  methods .available, Table VI11-4 also presents the following
information:                 •     • ,

1.   Description                                       ,
2.   Implementation time                               '
3.   Land requirements             ;
                                   i
The levels  of  treatment,  their  'respective  costs,  the  'pollutants
removed,  and  the  energy  requirements and non-water quality  impacts
associated with those levels of treatment are discussed below.

A.   Treatment Costs

     1.   BPT Effluent Limitations :

          a.   By-Product Cokemaking Operations

               Reference  is made to Section  IX for   identification of
               the  model: BPT  treatment system.  Certain  steps which
               result in  the reduction of pollutants  in the wastewater
               are commonly practiced for the  purpose  of  by-product
               recovery,   and  thus  are  not  considered  wastewater
               treatment  technologies.  Accordingly,  these  steps  are
               not  costed  as  wastewater   treatment  systems.    Free
                                    100 .

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2.
     ammonia  stripping   and  dephenolization   of   the    raw
     wastewaters  fit  ;this description,  since  their  primary
     aim  is   the  recovery  of  ammonium   salts and  sodium
     phenolates.   Refer  to  Table  VII1-5  for   BPT  model
     treatment component  costs.

     The  Agency has calculated costs for  facilities in-place
     at each  by-product cokemaking plant,  and has   estimated
     the  costs  of  the  model  system components which  are
     required to achieve  the BPT  limitations.   The  Agency
     identified  the  wastewater treatment facilities at  two
     plants (0684F and 0732A) as advanced physical/chemical
     systems  because of the presence of key components  (full
     scale  activated carbon systems) while all other plants
     have been costed  with  biological   treatment systems.
     The   Agency  believes  the  estimated  BPT   costs   are
     accurate on the basis of the favorable cost comparisons
     shown in Table  VIII-3.   Table  VIII-11   presents   the
     Agency's  estimates  of industry-wide capital  and annual
     costs required  to   achieve  the  BPT limitations   for
     cokemaking operations.

b.   Beehive  Cokemaking Operations

     The model BPT treatment system consists  of   collecting
     all  quenchwater  runoffs  in a settling pond, and then
     recycling all pond overflows to the  quenching  station.
     A;   "no   discharge"  condition  results.   The  Agency
     estimates that no additional expenditures  are  required
     for beehive cokemaking operations to  achieve  compliance
     with the BPT limitation.
       E
BAT limitations.
       i
a.   By|-Product Cokemaking Operations

     Reference is made to Section X  for   identification  of
     trie  model  BAT  treatment system.   The initial  capital
     investment and annual operating  costs  for  a   typical
     4700 TPD iron and steel by-product coke plant are shown
     in  Table  VIII-6  and  for a typical 1690 TPD merchant
     coke plant in Table VII1-7.   Model plant costs for each
     BAT alternative  considered  by  the  Agency  are  also
     presented  in  Tables  VIII-6 and VIII-7.   Table VIII-8
     presents  similar data for physical-chemical  cokemaking
     operations.    Table VIII-11  presents  industry-wide cost
     data for  iron and steel coke 'plants and  merchant  coke
     pljants,   respectively,   for  the  model  BAT  treatment
     system selected as the basis for the BAT limitations.
                             109

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b.   Beehive Cokemaking Operations

     Since the BPT limitation of  no  discharge  of  process
     wastewater pollutants has been achieved at beehive coke
     plants,  additional  technologies  and  investment  and
     operating costs are not required.

BCT Limitations

a.   By-Product Cokemaking Operations

     Section 304(b)(4) of  the  Act  requires  that  certain
     "conventional"   pollutants   be   controlled   by  BCT
     limitations.  The "conventional" pollutants limited  by
     the  BPT  limitations '• for  by-product  cokemaking  are
     suspended solids, oil and grease, and  pH.   Since  the
     BPT  and BCT limitations are the same, there are no BCT
     costs for cokemaking operations.

b.   Beehive Cokemaking Operations

     Since zero discharge is the BPT limitation for  beehive
     cokemaking  operations;, the BCT limitation is also zero
     discharge and there are no BCT costs.
NSPS
     By-Product Cokemaking Operations

     Model treatment system costs have  been  developed   for
     three  NSPS  alternatives  which  are  similar  to those
     considered for BAT.  Advanced biological treatment   the
     same  as  that  considered  for  BAT   is the model NSPS
     technology.  Refer to Table VII1-9 for NSPS model costs
     covering by-product  cokemaking.  Since this study  does
     not include projections of industry capacity additions,
     industry-wide new source costs are not presented here.

     Beehive Cokemaking Operations
     No NSPS  costs were
     operations.

Pretreatment  Standards
developed  for  beehive  cokemaking
a.   By-Product  Cokemaking .Operations

     Six  alternative  treatment  systems  were   considered  for
     pretreatment.  standards  for   existing  and  new sources.
     Costs  for these  alternatives   are   presented  in  Table
     VIII-10.    Industry  wi;de costs, for the  promulgated'PSES
     are  presented  in Table VIII-11.
                          no

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          b.   [Beehive Cokemaking Operations
               i
               JAs  noted  earlier,   since   the   remaining   beehive
               jcokemaking  operation is located in an area remote from
               iPOTWs, and it is very unlikely  that  any  new  beehive
               [operations   will   be   built,   the  Agency  has  not
               promulgated  PSES  or  PSNS  for   beehive   cokemaking
               operations  and  has not developed the respective model
               treatment system costs.
               I
B.   Summary of Pollutant Load Reductions

     Refer to Volume I, Appendix C of this  Development  Document  for
     summaries j of costs and effluent quality data for iron and steel,
     merchant, ;and beehive cokemaking operations,  respectively.   The
     annual  to|ns  of  the  various pollutants removed from cokemaking
     wastewaterp by complying with the BPT  and  BAT  limitations  and
     with PSES are also shown in Appendix C of Volume I.
               i
C.   Energy Requirements

     The various levels of treatment for  cokemaking  wastewaters  all
     consume  relatively  .low  amounts  of  energy,  mostly at the BPT
     level.    ;                      • .  •

     1.    Energ^ Impact at BPT/BCT

          The Agency estimates that installing and operating  the  BPT
          model!  treatment  systems  at all cokemaking operations will
          consume 58.2 million kwh  of  electricity  per  year.   This
          total; includes 49.6 million kwh for treatment at 31 iron and
          steeli  plants,  8.3 million kwh for treatment at 11 merchant
          plant's, and 0.3 million kwh for treating wastewaters at  the
          single operating beehive cokemaking plant.  This consumption
          represents:0. 1 % of the 57 billion kwh consumed by the entire
          steel| industry in 1978, a relatively insignficant impact.

     2.    Energy Impact at all BAT Levels

          Additional treatment components must be added to upgrade the
          BPT model treatment  systems  to .the  BAT  model  treatment
          systems.    The  additional  energy requirements for each BAT
          alternative are shown  in  Table  VII1-12.   The  additional
          energy   requirements   for   the   most   energy  intensive
          alternative would be less than 0.1% of total industry  power
          consumption.

          No  additional  energy  is  required  to comply with the BAT
          limitations for beehive cokemaking operations.
                                    ill

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D.
 3.   Energy  Impacts  at NSPS,  PSNS,  and  PSES

     Since   NSPS  model   treatment    systems    are    based    upon
     technologies  essentially  [identical  to  a  combination  of the
     proposed BPT  and  BAT/BCT, model   treatment   systems   their
     requirements  are  equivalent  to the  sum of the  proposed BPT
     and BAT model requirements.  Some  minor  amounts  of   energy
     can be  saved by  incorporating  flow reduction at  the earliest
     possible level,  thus reducing  some equipment size  and  cost.

     The  estimated energy requirements for NSPS alternatives are
     based upon a 4700 ton per  day  iron and  steel   plant   model
     size  or  a  1690  ton   per  day  merchant  plant  model  size
     operating 365 days  per. year.   NSPS  Alternative 1   would
     require 2.8  million  kwh for  iron and  steel plants,  or 1.2
     million kwh for  merchant plants.   Alternatives 2, and 3  would
     consume varying  additional' amounts.   For  PSES   and   PSNS,
     model   plant  sizes of 4,700 tons  per day for  iron and  steel
     plants  and 920 tons per  day for  merchant plants  formed  . the
     basis   for  all  estimates.; PSES Alternative 1 consumes  4.96
     million kwh at 8 iron and steel  plants,  and 1.33 million kwh
     per year for 8 merchant plants.  PSNS  Alternative 1  would
     consume 0.62 million kilowatt-hours/year for iron and steel
     model-sized  plants,   and  |0.30  million  kwh  for merchant
     plants.

     The  Agency  believes  that  the   pollution control benefits
     described  outweigh  adverse  impacts  associated  with   the
     increased energy consumption described.

Non-water Quality Impacts

1.    Air Pollution

     Certain treatment steps in I the BPT  model  treatment  system
     are  designed  to  return  ; additional  amounts  of  ammonia,
     hydrogen sulfide and hydrogen cyanide to the coke  oven   gas.
     If careful  control of collectors, ductwork and piping is  not
     practiced,    some   of  these  gases  could  escape  to   the
     atmosphere.   In the biological treatment steps, a  potential
     for  odor  exists if  the biomass is not properly maintained.
     Systems which depend  on incineration  either  by   controlled
     combustion  or recycle to extinction over quench towers (such
     as  BAT  Alternative   4)   generate  significant  particulate
     carryover from high concentrations of  dissolved   solids  in
     the wastewaters.   These solids precipitate and disperse over
     wide areas,  even if the wastewaters are pretreated to remove
     regulated  pollutants  prior   to  evaporation.    The  Agency
     concludes that  the effluent  reduction  benefits  associated
     with  compliance  with the jlimitations and standards justify
     any minor adverse air impacts that  may result.
                                   ir;

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     2.    Solids Waste Disposal

          The Use of lime to raise pH levels prior  to  fixed  ammonia
          stripping  can  produce  10 to 12 tons of sludge per day per
          plant in the form of unreacted calcium hydroxide, along with
          precipitated calcium carbonates and sulfates.  The  disposal
          of  these  sludges will impose costs, and care must be taken
          to prevent sludges from redissolving and entering streams as
          runoff from landfill  sites.   Sludges  should  be  recycled
          where!  practical  to  consume as much as possible in process
          reactions.   Lesser  amounts  of  sludges  are  formed  when
          caustic soda is used as the alkali, but caustic soda is more
          expensive  than  lime  and  the  resultant  dissolved solids
          discharge will be  higher.   Other  sludges  resulting  from
          water' treatment include coal or coke fines which are readily
          recycled  to  coke  ovens.   Also,  the biological treatment
          systems generate some bacteriological sludges which  require
          periodic  disposal.   Some  plants,  e.g., Plant B, transfer
          such isludges to a local POTW at  very  low  flows  (1  gpm),
          while others landfill these sludges along with sediment from
          settling ponds.                           '      \

          Relatively  little  additional  impact  in the form of solid
          waste.s results  from  application  of  the  BAT  alternative
          treatment systems.  Small amounts of additional sludges will
          form,;  but  will  be'  only a fraction of those generated for
          disposal by the BPT model treatment  system.   These  solids
          must ;be properly disposed of, and are subject to regulations
          under    other    applicable   statutes.    However,   their
          environmental impacts are lessened by separating  them  from
          wastewater  and  controlling  their  disposal  on  land.   A
         .summary  of  the  solid  wastes  generated   by   cokemaking
          operations  is  presented in Table VIII-13.  The Agency does
          not consider recovered ammonium sulfate as solid  waste  due
          to wastewater treatment even though, at times, this material
          cannot be readily sold due,to unfavorable market 'conditions.

E.   Costs of Retrofit for Existing Plants

     In addition to the cost comparison reported above  and  in  Table
    ''VII1-3, trie Agency attempted to isolate the actual costs expended
     to  retrofit  process  wastewater  treatment  systems to existing
     production facilities.  Nine coke plants were selected to provide
     detailed installation costs.  Respondents were asked  to  itemize
     costs  which  would  not  have been incurred if treatment systems
     were installed simultaneously with construction,  replacement  or
     expansion j  of   production   facilities.   Of  the  nine  plants
     solicited,1 two provided no cost data, three  replied  that  there
     were  no  iretrof it  costs  applicable to their treatment systems,
     three  reported retrofit costs of 2.7% to  6.9%  of  their  total
     treatment! plant  costs,  and  one  cited costs at 13.4% of total
     cost.   These  latter,  higher  percentage  costs  reflected  the
     dismantling, relocation, and reassembly of a benzol plant.  While
                                   113

-------
     this  may  have been necessary in this particular case to provide
     space for building a wastewater  treatment  plant,  the  cost  of
     benzol  plant  reassembly  is  more  Correctly characterized as a
     process cost.  If reassembly were backed out of retrofit cost for
     this site, the remaining retrofit items  are  7.7%  of  treatment
     plant installation costs.  The estimated on-site costs based upon
     treatment  plant  model costs compare favorably with total actual
     costs reported by those plants solicited, including three of  the
     four  which  provided  retrofit cost data.  After comparing these
     data, the Agency concludes its  cost  estimates  based  upon  the
     model  plants  are  sufficiently  generous  to  cover  all normal
     retrofit costs.   For  most  plants,  the  Agency  believes  that
     retrofit costs will be a small;fraction of total investment cost.
                                   i
F.   Water Consumption             •

     The need to minimize flows by recycle of final cooler  water  and
     crystallizer  barometric  condenser  water  will  have only minor
     impact on water consumption at'by-product cokemaking  operations.
     Water   consumption   attributable  to  wastewater  treatment  is
     estimated to increase to a total of 0.85 million gallons per  day
     when  all  plants achieve the BPT limitations and to 1.09 million
     gallons per day when the BAT  limitations  are  .achieved.  " These
     losses are minor compared with !the 22.6 million gallons currently
     evaporated  at  coke, quench stations on a typical production day.
     Based upon these factors, the Agency  concludes  that  the  water
     consumption  losses,   on  a  nationwide basis,  are justified when
     compared with the effluent  reduction  benefits  attributable  to
     compliance with the BPT and BAT  limitations and PSES.

     The   Agency  also  evaluated 'whether  the  establishment  of  a
     subdivision for plants located in arid or semi-arid  regions  was
     warranted.    It found that the water loss for those plants is the
     same as for plants in other areas of the country.   Moreover,   the
     plants  in .water-short  regions (0196A,  0448A,  0492A,  and 0864A)
     continue to use wet quenching stations?  even though dry quenching
     technology is available  and  is  currently  practiced  in  other
     countries.    The wet  cooling tqwers at plants located in arid and
     semi-arid regions consume about,  1  million gallons per day,   which
     is  35  times the amount which will be consumed by complying with
     the BPT and BAT limitations.   In complying with the BPT  and  BAT
     limitations,   however,  thousands of pounds of pollutants will not
     be discharged.   Based on these factors  and  those  discussed  in
     Volume  I of this Development Document,  the Agency concludes that
     the amount  of water which will be consumed by plants  located  in
     arid  and  semi-arid   regions Is  justified when compared to the
     effluent reduction benefits,  and that establishing a  subdivision
     with  alternative,   less stringent effluent limitations for those
     plants is not warranted.      . >   •
                                   114

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Summary of Impacts

The Agency concludes that the effluent  reduction  benefits  described
below  for  the ' cokemaklng  subcategory  outweigh the adverse  impacts
associated  with  energy  consumption,  air  pollution,  solid   waste
disposal, and water consumption.

                     Effluent Loadings  (Tons/Year)
                       Raw
                        Waste
Flow, MGD       *
TSS        ,     j
Oil and Grease  I
Ammonia (N)     t
Total Cyanide   i
Phenols (4AAP)  ;
Toxic Organics
Toxic Metals    !
Other Pollutants
    32,
 2,480
 3,713
29,710
 2,480
14,853
 5,812
   129
31,190
   BPT

   33.;
3,340
  405
3,800
  253
   25
  138
   35
  152
   BAT

   22.7
2,280
  173
  242
   86
    0.6
   25
   24
   24
    PSES

    4.8
  724
  109
  434
  116
  261
  208
   1 1
1 ,665
The  Agency  also  concludes,  that  the  effluent  reduction  benefits
associated with 'compliance with  new  source  standards  (NSPS,  PSNS)
outweigh  the.  Adverse  energy  and  non-water  quality  environmental
impacts.        ;
                                   115

-------
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                 j                  TABLE VIII-2
                 i

                 EFFLUENT TREATMENT  COSTS  REPORTED BY THE  INDUSTRY
                 '  	BEEHIVE COKEMAKING	

                 '     (All  Costs  Converted  to  7/1/78  Dollars)
Plant Code       [
Reference Code   ;
                 i
Initial Investment
Annual Costs     i
  Capital
  Oper. & Maint.'
  Energy & Power|

TOTAL            [

$/Ton
$/1000 Gal treated
   E
 0428A

$ 6,720

    600
 40,500
      0

$41,100

  0.113
  0.230
   F
 0428A

$12,600

  1,130
 20,160
      0

$21,290

  0.0584
  0.119
   G
 0724G

$32,800

  2,950
  2,020
  1,140

$ 6,110

  0.0272
  0.221
                                     117

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                                       TABLE VIII-3

               COMPARISON OF COSTS FOR SURVEYED PLANTS (VISITS AND D-DCP'S)
              ESTIMATES  BASED ON  TREATMENT  MODELS  VERSUS ACTUAL PLANT  COSTS'
                          (ALL COSTS CONVERTED TO 7/1/78 DOLLARS)	
Plant Codes
A-0432B
B-0112
C-0384A
D-0272
003-0868A
008-09 20F
009-0684F
0012A
0426
0584F(B)
0584FCM)
TOTALS
Cost
Reported
By Industry
Capital
4,069,000
1,209,400
6,919,600
3,450,800
9,775,500
6,192,000
10,600,000
2,755,500
3,550,600
5,100,700
2,427,900
56,051,000
Annual(1)
2,279,700
237,200
2,327,600
619,000
3,027,100
1,041,700
5,097,600
NR
746,700
656,200
537,900
16,570,700
                                                 Cost
                                               Estimated
                                              From Models
                                          Capital

                                         4,241,300
                                         1,546,800
                                         5,235,000
                                         3,288,700

                                         8,114,500
                                         5,876,300
                                         7,976,700

                                         3,646,700
                                         3,834,400
                                         4,848,000
                                         5,631,600
 Annual

1,348,000
  460,200
1,645,800
  812,900

2,289,300
1,561,700
2,609,000

  880,100
  959,700
1,246,600
1,504,800
 % Difference
   In Costs

Capital  Annual

  +4.2   -40.9
 +27.9   +94.0
 -24.3   -29.3
  -4.7   +31.3
 +32.3
  +8.0
  -4.9
  +132
+28.5
+90.0
+180
                                        54,240,000   14,438,000
                                                               (8)
                                                                    -3.2   -12.9
                                Notes
        (2),(5)
        (2),(3),(5)
        (2),(4),(5)
 -17.0   -24.4
  -5.1   +49.9
 -24.7   -48.8   (5),(6)
        (2),(5)
(2),(5),(8)
(1) Standard depreciation and capital recovery factors were used to develop standard annualized
    cost of capital estimates.  Actual plant operating and maintenance costs are included.
(2) Part of raw waste flow is treated.  The remainder is discharged untreated, or
    disposed of via quenching.
(3) Dilution flow  is excess of model dilution flow rates and added, resulting in some
    oversized equipment at plant.
(4) Indirect discharger.  Costs are for pretreatment only.
(5) Partial ammonia stripping.
(6) Cokemaking wastewaters from an off-site cokemaking operation  are treated at this plant.
(7) Wastewaters from plant M are partly treated in plant B, providing certain cost savings.
(8) Annual costs extimates for plant 0012A are not included.  Actual annual costs were not
    reported for this plant.                       .

NR: No annual cost data reported.
                                              118

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            TABLE  VIII-4,

 CONTROL AND TREATMENT  TECHNOLOGIES
      COKEMAKING SUBCATEGORY
Description
                                               Implementation
                                               Time  (Months)
     Land
  Usage (ft )
 I&S    Merchant
I.   BY-PRODUCT COKEMAKING - ALL SYSTEMS;

 A       GAS FLOTATION (Final Cooler Slowdown and
         Benzol Plant Wastewaters Only) - Waste
         pickle liquor is used to break emulsions,
         and an inert gas mixture is introduced
         to enh'ance the separation of oils and
         greases by flotation.

 B       LIME ADDITION - Wastewaters from Step A
         are mixed with waste ammonia liquor
         and miscellaneous process wastes,
         dephenolized (if plant has an operating
         dephenolizer on—site), stripped of free
         ammonia and treated with lime (or caustic soda)
         to raise the pH to 11-12 units.  Dephenolizer,
         free ammonia still, and any associated equili-
         zation steps are considered to be by-
         product recovery process components, and
         are not included among wastewater
         treatment costs.
                                  8 to 10
                                                                  1,200
          400
                                  2 to 4
                                                                 5,000
          2,400
FIXED IAMMONIA STRIPPING - Steam stripping
stills are used to remove as much ammonia
as possible prior to further treatment.
Most operations use lime in Step B, but
an increasing trend toward caustic soda
usage has been observed, particularly
since 'lime still sludges are considered
to be hazardous wastes under RCRA
requirements .

EQUALIZATION - Blend the discharge from
Step !C with wastewaters from crystallizer
barometric condenser and provide for sedi-
mentation in a settling basin or tank with
one day's retention time.  Unreacted lime
partic;les and other suspended matter
separates out, and is periodically removed
by clatashell bucket or transferred to vacuum
filters (see subsequent step).
                                  8 to 10
10,000    4,200
                                  4 to 6
50,000    20,000
                119

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TABLE VIII-4
CONTROL AND TREATMENT TECHNOLOGIES
COKEMAKING SUBCATEGORY
PAGE 2
                         Description
         BIOLOGICAL TREATMENT SYSTEM;

         NEUTRALIZATION WITH ACID - The overflow
         from Step D is monitored and adjusted as
         necessary.
                                               i
         AERATION - The total wastewater flow  !
         from Step E 'is aerated by vigorous mechani-
         cal agitation or by the use of air blowers
         and subsurface diffusers.  This step
         provides oxygen necessary to support
         bio-organisms in Step G.              :

         BIOLOGICAL OXIDATION - Wastewaters are1
         treated in a single-stage activated sludge
         basin provided with its own clarifier and
         sludge recycle system.  At least 24 hour
         retention time is provided.  If necessary,
         up- to 50 gallons/ton of fresh water is added
         to the basin to optimize conditions for
         bio-oxidation.

         VACUUM FILTRATION - Excess sludges from
         clarifier underflows and equalization
         basin are dewatered by vacuum filters.;
         Filtrate is returned to the activated
         sludge basin.  (Last step in BPT system.)

         RECYCLE, - Convert barometric condenser
         on crystallizer from once-through to
         96 percent recycle system, with four
         percent blowdown to treatment.  Replace
         up to 50 GPT of optimization water with
         blowdowns from air pollution emission j
         scrubbers; dispose of excess scrubber '
         blowdown from pushing by quenching    [
         operation.                            |
Implementation
 Time (Months)
    2 to 4
    4 to 6
     Land
  Usage (ft )
 I&S    Merchant
3,200
1,200
   12 to 18
80,000    32,000
    6 to 8
3,200
1,600
    6 to 8
                                         120

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TABLE VIII-4       ;
CONTROL AND TREATMENT TECHNOLOGIES
COKEMAKING SUBCATEGORY
PAGE 3
                         Description
                                              Implementation
                                               Time  (Months)
     Land  .
  Usage (ft).
 I&S    Merchan
 M
AERATION -; An additional aeration step is         4 to 6
provided in a second-stage bio-oxidation
system.  As in Step F, the aeration
system may; be either mechanical-agitation
or air injection via blowers, and diffusers.

BIOLOGICAL! OXIDATION - A second stage of         12 to is
activated sludge treatment is installed
to provide;further control of ammonia-N,
cyanide, phenols (4AAP) and other toxic
organic pollutants.  This stage also includes
a clarifier and sludge recycle system.

NEUTRALIZATION WITH CAUSTIC SODA - As'            2 to 4
treatment proceeds in the second-stage
activated sludge system, there is a
tendency to produce acidic end-products
which could inhibit bio-oxidation.  To
prevent this, caustic soda solutions
are added to the system to control such
acidity.  ;

SODIUM CARBONATE ADDITION - Since bio-            2 to 4
organisms in the first stage of activated
sludge treatment will utilize most of the
carbon available in wastewaters, a sup-
plemental carbon source is added to the
second stage basin.  Sodium carbonate
is added for this purpose and to aid in
buffering the system.

COOLING TOWER - In order to adequately   .         9 to 12
control temperatures without using ex-
cessive dilution water, side-stream
cooling ofia portion (up to 75 percent)
of the total wastewater flow is achieved
using a cooling tower.  Uncontrolled
temperature changes outside a narrow
range adversely affect biota.  (Last
step in selected BAT system - BAT 1.)
                                                                          3,200
          1,200
                                                                          80,000    32,00'
625
625
                                                                          4,800
          2,40^)
                                      121

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TABLE VIII-4
CONTROL AND TREATMENT TECHNOLOGIES
COKEMAKING SUBCATEGORY
PAGE 4                           '
C&TT
                         Description
         PRESSURE FILTRATION - The effluent from
         Step N is passed through pressure filters
         to provide additional suspended
         matter removal.  Filter backwash is re-
         turned to the activated sludge system  ,
         clarifier.  (Last step in BAT-2).

         POWDERED ACTIVATED CARBON ADDITION - To,
         further enhance control of ammonia and ;
         organics, powdered activated carbon is
         added to both activated sludge stages..
         The filtration provided in Step 0 prevents
         carryover of powdered carbon as a con-   .
         tributor to TSS loads.  (Last step in
         BAT-3.)

         RECYCLE TREATED WATER TO QUENCHING
         OPERATIONS - All of the effluent from  :
         Step N (or any subsequent step) is col-
         lected and consumed in coke quenching
         operations as a replacement for water  ;
         consumed there.  This option can cause '
         serious air pollution impacts due to
         the effluent's high dissolved solids
         content, which then flashes off as air-
         borne particulate matter.  (Last step
         in BAT-4.)

         PHYSICAL/CHEMICAL TREATMENT SYSTEM!

         GAS FLOTATION (Final Cooler Blqwdown and
         Benzol Plant Wastewaters Only) - Waste
         pickle liquor is used to break emulsions,
         and an inert gas mixture is introduced
         to enhance the separation of oils and  ,
         greases by flotation.

         LIME ADDITION - Wastewaters from Step A
         are mixed with waste ammonia liquor
         and miscellaneous process wastes,
         dephenolized (if plant has an operating
         dephenolizer on-site), stripped of free
Implementation
 Time (Months)

   12 to 18
     Land  _
  Usage (ft )
 I&S    Merchant
1,200
                                                                                    800
   10 to 12
400
200
    4 to 6
    8 to 10
1,200
400
    2 to 4
5,000
2,400
                                           122

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TABLE VIII-4      |
CONTROL AND TREATMENT TECHNOLOGIES
COKEMAKING SUBCATEGORY
PAGE 5            •
                         Description
Implementation
 Time (Months)
    Land
 Usage (ft^)
I&S    Merchan
                  I                ,                          •
         ammonia arid treated with lime (or caustic soda)
         to .raise the pH to 11-12 units.   Dephenolizer,
         free ammonia still, and any associated equili-
         zation steps'are considered to be by-
         product recovery process components,  and
         are not included as wastewater
         treatment.'

         FIXED AMMOJNIA STRIPPING - Steam stripping         8 to 10
         stills are  used to remove as much ammonia
         as possible prior to further treatment.
         Most operations use lime in Step B, but
         an increasing trend toward caustic soda
         usage  has been observed.

         EQUALIZATION - Blend the discharge from            4 to 6
         Step C with wastewaters  from crystallizer
       -  barometric!  condenser and provide for  sedi-
        mentation in a settling^ basin or tank with
         one  day's retention time.   Unreacted  lime
         particles and  other suspended matter
         separates put,  and  are periodically removed
        by clamshell bucket  or transferred to vacuum
         filters  for  dewatering  (see  subsequent step).

        NEUTRALIZATION WITH ACID  - The overflow            2  to 4
        from Step D  is monitored  and  adjusted as
        necessary to assure  that  the  treated
        effluent lies within the  6.0  to  9.0 pH range.

        RECYCLE - Convert barometric  condenser         '    6  to 8
        on crystaliizer from once-through  to
        96 percent recycle system, with  four
        percent blowdown to treatment.  This re-
        duces flows  to treatment, and increases
        treatment plant efficiency.

        PRESSURE FILTRATION - The total plant  ef-        12 to 18
        fluent is passed through pressure filters
        in order to  remove additional suspended
        matter and jprotect the carbon adsorption
        system whic'h follows.
                   10,000    4,200
                   50,000     20,00'
                  1,200     800
                                     123

-------
TABLE VIII-4
CONTROL AND TREATMENT TECHNOLOGIES
COKEMAKING SUBCATEGORY
PAGE 6
C&TT
 H
                         Description
Imp1ement at ion
 Time (Months)
    Land
 Usage (ft )
I&S    Merchant
         GRANULAR ACTIVATED CARBON ADSORPTION - Fol-      18 to 24
         lowing Step G, a full scale system using
         towers packed with activated carbon granules
         is installed to provide effective control of
         toxic organic pollutants and other adsorbable
         pollutants.  Spent carbon may be regenerated
         by means of on—site furnaces, or may be returned
         to its supplier for reactivation off-site.

         EQUALIZATION - Treated effluents from Step H      4 to 6
         are collected and retained for four to six
         hours in a settling basin prior to discharge.
         This step provides time for settling of any
         carbon granules or other suspended matter
         which may have left the carbon towers.  (Last
         step in selected BAT P/C system.)

         BREAKPOINT CHLORINATION - Further treatment      12 to 18
         for control of non-adsorbed organics,
         cyanide and ammonia is provided via two-step
         (alkaline and breakpoint) chlorine addition to
         complete oxidize such pollutants.  Careful
         monitoring and control must be provided to
         minimize formation of chlorinated intermediates,
         and Step J must be followed by a dechlorination
         step.

         DECHLORINATION VIA S02 ADDITION - Any  resi-       2 to 4
         dual chlorine from Step J is eliminated by ad-
         ding a suitable reducing agent such as SO. or
         sodium metabisulfite  prior to discharge.   (Last
         step in BAT-2 P/C system.)    "

         RECYCLE TREATED WATER TO QUENCHING OPERATIONS -    4 to 6
         All of the effluent from Step I (or K) is  col-
         lected and consumed in coke quenching  operations
         as  a replacement for  fresh water  consumed  there.
         This option can cause serious air pollution im-
         pacts  due  to the effluent's high  dissolved solids
         content, which  then flashes off as  airborne  par-
         ticulate matter.   (Last  step in BAT-3  P/C  system.)
                   3,200
         1,200
                   8,000
         3,200
                   3,200
         1.200
                  625
        400
                                       124

-------
TABLE VIII-4      |
CONTROL AND TREATMENT TECHNOLOGIES
COKEMAKING SUBCATEGORY
PAGE 7            '
                         Description
Implementation
 Time (Months)
    Land
 Usage
I&S    Merchant
II.  BEEHIVE COKEMAKING:
         SETTLING jBASIN - A sedimentation pond is pro-     2 to 4
         vided  to collect all wastewaters, which are
         retained juntil coke fines and other participates
         settle out.  Pond must be periodically cleaned
         out to insure sufficient -retention times.
                  i
         RECYCLE -j All of the effluent from Step A is       2 to 4
         pumped back for use in the coke quenching pro-
         cess.  The additional impact on air quality is
         minimal when contrasted with the beehive coke-
         making process itself.  There is no aqueous dis-
         charge from the wastewater treatment system
         (Last step in Selected BPT system.)
                             3,200
                                          125

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                !       , COKEMAKING SUBCATEGORY
               • f

                i              SECTION IX

               EFFLUENT QUALITY ATTAINABLE THROUGH THE
             APPLICATION OF THE BEST PRACTICABLE CONTROL
                    TECHNOLOGY CURRENTLY AVAILABLE
The Best Practicable  Control  Technology  Currently  Available   (BPT)
limitations  are;  for  the  most  part,  the  same as those originally
promulgated in June 1974., The June 1974  development  document   (EPA-
440/I-74-024-a; !  Development   Document   for   Effluent  Limitations
Guidelines and New.Source Performance Standards for the  Steel  Making
Segment  of  the;  Iron  and Steel Manufacturing Point Source Category)
describes the methods  used  to  develop  the  originally  promulgated
limitations.    ;

Identification ojf BPT
                i
Based  upon  the|  information contained in Section III through VIII of
this report, thej Agency  has  determined  that  the  Best  Practicable
Control  Technology  Currently  Available  (BPT)  model technology for
cokemaking operations  includes  the  following  wastewater  treatment
systems:        j

A.   For By-Product Cokemaking Operations
                i           •                   ,           _

     Blending of I wastewater streams from benzol plants,  final  cooler
     blowdowns, ! and  .miscellaneous  process  wastewaters  with excess
     ammonia liquor prior to  ammonia-N  removal  in  a  free  ammonia_
     still.   Dephenolization  of  the  waste ammonia liquor and  other
     streams is \ not  included.   The  free  still  effluent  is  made
     alkaline (pH 9-11) with lime and stripped of fixed ammonia in the
     fixed  leg pf an ammonia still.  Barometric condenser wastewaters
     from the crystallizer are combined with ammonia  still  effluents
     and  detained  in  a  storage tank, sedimentation basin or lagoon
     with a one 
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B.   For Beehive tokemaking Operations

     The BPT model  treatment  system  consists  of  equalization  and
     settling  of  coke  fines  in  >a basin, with total recycle of the
     basin overflow to quenching operations.  A periodic  cleanout  of
     the  basin is necessary, and recovered solids are recycled to the
     ovens.  Refer to Figure IX-3.  ;

The BPT effluent limitations are summarized in Table  IX-1.   The  BPT
limitations  are by no means the lowest values attainable by the model
technology, but instead represent  performance  values  which  can  be
reasonably  attained  on  a day by day basis.  It should be noted that
the Agency is not requiring that dischargers use the model technology.
Other systems, including the physical-chemical treatment system  noted
above,  can  be used as long as the BPT limitations are achieved.  The
limitations presented in Table IX-1 are  30-day  average  limitations.
The  maximum  daily  effluent  limitations  are three times the 30-day
average  limitations  except  for  total  suspended  solids  where   a
multiplication  factor  of  1.93 is used.  Total investment and annual
costs associated with the installation  of  the  BPT  model  treatment
systems are provided in Table VIII-11.

Model Treatment Systems

Both  the  biological  and  physical-chemical  coke  plant  wastewater
treatment systems illustrated in Figures IX-1 and IX-2,  respectively,
are  widely  used  in  the industry.  Hence, the Agency believes these
treatment  systems  are  appropriate   for   establishing   the   best
practicable technology limitations.  Aside from disposal of cokemaking
wastewaters  in coke quenching operations, discharge to POTWs, and,'in
a few cases, incineration of cokemaking wastewaters,  the  Agency  did
not find other treatment technologies in use by the industry.

Model Flow Rate

Because of plant-by-plant variations in by-product, recovery operations
and  air  pollution  control systems/ the Agency used a building block
approach in developing the limitations.  The by-product cokemaking BPT
effluent limitations promulgated in 1974 were based upon a basic  flow
rate  of  730  1/kkg  (175  gal/ton), with supplemental allowances for
indirect ammonia recovery  and  qualified  desulfurizers.   Additional
data  gathered  since  promulgation  of  the  original BPT limitations
indicate that this flow accurately reflects the average  of  the  best
process  wastewater  flow  rates  for by-product cokemaking operations
affiliated with iron and steel plants at the BPT level  of  treatment.
Slightly  higher  flows  are  reported for merchant cokemaking plants.
Additionally, 50 gal/ton of dilution water  is included to optimize the
operation of biological treatment systems for both iron and steel  and
merchant plants.  Refer to Table IX-2 for the model BPT flow rates for
the sources of wastewaters regulated by the BPT limitations.

The  DCP  responses  for  all  active by-product cokemaking facilities
indicate that 57% of the plants generate  less  than   175  gallons  of
                                    148

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 process    wastewaters  per  ton  of  coke  produced,   including  those
 wastewater flows  disposed of in coke quenching operations.   Thus,   the
 basic  model   flow of 175 gallons per ton used in establishing the BPT
 limitations is readily demonstrated  at  a  large  number  of  plants.
 Table  IX-3  presents the development of the model flow rates for  each
 wastewater source for cokemaking operations affiliated with iron  both
 and  steel plants  and merchant cokemaking operations.   Note that for
 most   sources  of  wastewater,   the  model  flow .rates  for  merchant
 operations are,  slightly  higher  than  those for iron and steel  coke
 plants.         i

 The Agency determined that the  six by-product coke plants that operate
 indirect   ammonia  recovery  systems  should  have  an  allowance   for
 additional floW   because  of the dilute weak ammonia  liquor generated
 compared  to semi-direct recovery systems.   Accordingly,   an  allowance
 based  upon an additional model wastewater flow of up  to 251  1/kkg (60
 gal/ton)   is   provided  in. the  BPT  limitations  for  these  plants.
 Likewise,  for tftose plants which include wet desulfurizers,  the Agency
 has    included ;  an  allowance   for  additional  flow   resulting  from
 contaminated  coijidensates.   However,  not all desulfurizers qualify   for
 these  additional   flows.    Dry  adsorption  systems with ferric oxide
 boxes, or  extraction methods using  solvents  which do   not  increase
 wastewater volumes are not eligible for the additional allowance.   The
 most   common   types  of  desulfurizer  contains  a potash  or soda ash
 scrubbing  system  for adsorbing  EZS and a  vacuum  distillation  system
 (the   vacuum   carbonate  process).    These systems are eligible for an
 additional  flowjallowance of up  to  104  1/kkg  (25   gal/ton).    This
 allowance   includes  the  extra steam condensate and slurry associated
 with treatment  of  desulfurizer  wastes in a fixed ammonia still.

 The Agency  also Iprovided an allowance of 209 1/kkg  (50   gal/ton)   for
 dilution   water [  to  optimize  the 'biological  treatment process.   The
 Agency found  that  some operators believe dilution water  is  required to
 provide additional  microorganisms   to  the  treatment  system;   others
 relate  dilution   water  to  control  of ammonia-N,  cyanide,  or phenols
 (4AAP); others  believe dilution water is needed to minimize   dissolved
 solids  levels; ; and,   others add  dilution water to control  wastewater
 and treatment  system temperature.   Information  available to  the Agency
 suggests that, temperature  control  is  the most  important  factor.  While
 other means of  temperature  control  can be  implmented   to minimize   or
 eliminate   the  ineed  for   dilution   water,   the Agency  believes it is
 appropriate to  provide an  allowance  of   50  gal/ton.   Data   for well
 operated  biological   treatment  systems indicate that  50  gal/ton is an
 appropriate amount  (see Table IX-3).   The  Agency has determined that,
with  proper  prjetreatment   and  operating  control,  the BPT  limitations
 can be achieved 'in  biological treatment systems  with a   dilution flow
of  50  gal/ton.I    At  some  plants  that  are not  currently  achieving  the
ammonia-N  limitations,  operating practices  might have  to  be   modified
to   provide  for   partial   nitrification   to   achieve   the   ammonia-N
 limitations.    ;

Thus,  considering  50 gal/ton  for dilution  flow,   the  BPT   limitations
are  based  upon a  basic flow rate of  938  1/kkg  (225 gal/ton)  for iron
                                   149

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 and  steel  plants and 1000 1/kkg (240 gal/ton)  for merchant  plants  to
 allow  for  fresh water addition to; optimize treatment where necessary
 (see  Table  IX-3).    The  allowances  noted  above   for   qualifying
 desulfurizers   and    indirect   ammonia  recovery  systems  are  also
 applicable, as appropriate.         :

 Effluent Quality                   j

 The   Agency  determined  that  the i prior  effluent  limitations   for
 ammonia-N,  total cyanide,  and phenols (4AAP)  are demonstrated at both
 biological and physical-chemical treatment  systems.   However,  based
 upon  comments  received  on the proposed regulation,  the Agency found
 that the prior suspended solids limitations based upon 50 mg/1 and the
 proposed limitations based upon TOO mg/1 are  not  readily  achievable
 with  biological  treatment systems.  The 30-day average BPT suspended
 solids limitation contained in this regulation is based upon 140  mg/1
 and  the daily maximum value is based upon a concentration of 270 mg/1.
 The  Agency considered effluent data from suspended solids from several
 biological  treatment,  systems  in 'developing these concentrations but
 relied primarily upon data  from  Plant  0868A,  where  a  substantial
 amount  of  long  term  data are available.  This plant which includes
 nitrification of ammonia-N, demonstrates that suspended solids removal
 from this  type of treatment is difficult even in  this  well  operated
 plant.   The  Agency  recognizes  that occasional upsets will occur in
 biological treatment systems used to treat cokemaking wastewaters  and
 that  under  such  conditions  the  activated  sludge  may  not settle
 properly,  causing high levels of suspended solids  to  be  discharged.
1 The   limitations  were developed by excluding concentrations above 300
 mg/1 from the data base at Plant  0868A.   The  Agency  believes  that
 levels  above  300  mg/1  do  not represent normal operations.  Of the
 relatively few data excluded in this fashion, most were  significantly
 higher   than   300  mg/1  and  would  have  inordinately  biased  the
 limitations to higher levels that are  not  representative  of  normal
 operations.   Reference  is  made   to  Appendix  A  of  Volume  I  for
 additional information.

 For  beehive operations, no change in the .proposed BPT  limitations  is
 necessary.   The recommended technology and the no discharge condition
 have been demonstrated on a long-term basis.

 Justification for BPT Limitations

 A summary of effluent data from sampled plants  is presented  in   Table
 IX-4.   Data  are  reported, for the total wastewater  flows  leaving the
 coke plant.  For Plant 009, the load shown  includes a  treated  effluent
 which is disposed of by quenching,. in addition  to the  direct discharge
 flow.

 Most plants achieve  the  BPT   limitations.   Where   noncompliance  is
 noted,  a  simple  explanation  usually  accounts   for  the failure of
 certain plants  to meet the limitations.  For example,  failure  to  meet
 the  ammonia-N   limitation  results from  the absence  of  fixed  ammonia
 removal steps at Plants A, B,  002,:0584F-M  and   0684F   (quench).   For
                                      150

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cyanides,  untreated  barometric  condenser  flow containing excessive
amounts of cyanides is discharged untreated at Plant A.  For  phenolic
compounds,  Plants  C  and 002 provide only minimal control, since the
wastewaters  are  discharged  to  POTWs.   Consequently,  most  plants
demonstrate  tWe  ability  to achieve the limitations for each limited
pollutant.  The; Agency believes that the  model  BPT  flow  rates  and
effluent  quality can be achieved at all coke plants provided properly
designed treatment facilities are installed and those systems are well
operated.  The data shown in Table IX-4 justify the BPT limitations.
                                   151

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§!
                     B O
ra S
               152

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                                         TABLE IX-2

                                    BPT MODEL FLOW RATE
                             BY-PRODUCT COKEMAKING SUBCATEGORY

                             (All Flows in Gallons/Ton of Coke)
Wastewater Source
               i

Waste Ammonia Liquor
Final Cooler Blpwdown
Barometric Condenser Discharge
Benzol Plant Wa'stewater
Steam & Lime Slfirry
Miscellaneous Sources (leaks, seals, test taps,
  drains)      |
Subtotal - Process Wastewaters

Dilution to optimize bio-oxidation

TOTAL FLOW FOR BIOLOGICAL TREATMENT SYSTEMS
  Flow Basis
 BPT Effluent
I&S   Merchant
 32
 10
 75
 25
 13
 20

175

 50

225
 36
 12
 75
 28
 15
 24

190

 50

240
Additional Flowj Allowances Provided in the Regulation:
               i                            -
For Qualified Desulfurizers (Wet), up to:                   25      25
For Indirect Ammonia Recovery, up to:                       60      60
               i                  ~                       -
No Additional Allowances For:
               i

Air Pollution Control Scrubbers:        •     _/
  Coal Drying or Preheating - up to 15 GPT Slowdown*         0       0
  Charging/Larry Car - up to 5 GPT Slowdown*                 0       0
  Pushing Side Scrubber - up to 100 GPT Slowdown*            0       0
               i
MAXIMUM TOTAL FLOW             -                            310     325
    Up to 50 GPT of dilution .water is replaced by blowdowns from air pollution control
    scrubbers. !Any excess blowdpwn (from pushing only) is disposed of via quenching
    operations,'or treated and reused in the scrubber system.
                                         153

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                 TABLE IX-3

DEVELOPMENT OF BPT MODEL EFFLUENT FLOW RATES
             BY-PRODUCT COKEMAKING
Was tewater Source Flow in GPT
Waste Ammonia Liquor 32 for I&S








Waste Ammonia Liquor 36 for Merc.



Final Cooler Slowdown 10 for I&S

r






Final Cooler Slowdown 12 for Merc.


Barometric Condenser at 75 for I&S
Crystallizer and Merc.
(once-through)
Benzol Plant Wastewaters 25 for I&S







Code No.
0948A
0684H
06841
0112C
' 0112
0684J
0920B
0060
0112D

724F
0212
0464C
0280B
0174
0448A
0856F
0684A
0920B
0112C
0584C
06841
0320

0464C •
0272

0584F-M
0432B
0684A
0112A
0448A
0920B
04J32B
0060A
0056N
0948A
GPT
19
26
26
27.8
30
30
31
32
32
Average of
21
26
30
33
36
Average of
0.4
1.2
2.6
4.2
5.4
5.6
6.0
6.2
Average of
5.8
7.0
Average of
20
56
Average of
11
13
15.9
21
23.4
24
24.3
25
Code No.
0060A
0584C
0112A
0584F-M
0112B,
0448A
0684D
0856F
Conf.
18 = 32 GPT
0272
0024B
0732A
0012A

9 = 36 GPT
0060
0432B ,
0684B
0112D
0112B
0584F-M
0860B
0384A
16 = 10.0 GPT
0724F

3 = 11.9 GPT
0248A
0396C
4 •= 75 GPT
0112B
0060
0112C
0112
0864A
0584C
0432A
0024A
                                                                 GPT
                                                               33
                                                               34
                                                               35
                                                               35
                                                               36
                                                               37
                                                               38
                                                               38
                                                              <38

                                                               36
                                                               43
                                                               47
                                                               48
                                                               7.2
                                                               8.5
                                                               11.3
                                                               12
                                                               13
                                                               17.7
                                                               26
                                                               32

                                                               23
                                                                79
                                                                144
                                                                27
                                                                28
                                                                28
                                                                32
                                                                32
                                                                33
                                                                33.3
                                                                34
                               Average of 16  = 25.2 GPT
                    154

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 TABLE IX-3        '  !'
 DEVELOPMENT OF BPT M0DEL EFFLUENT FLOW RATES
 BY-PRODUCT COKEMAKING
 PAGE 2              i
  Wastewater Source
 Flow  in  GPT
 Benzol  Plant  Wastewater    28 for Merc.
 Steam and Lime  Slurry
 (plants with  free  and
 fixed stills  in operation)
 13  for I&S
Steam and Lime Slurry^
(plants with free and,
fixed stills in operation)
15 for Merc.
Miscellaneous Sources;      20 for I&S
(leaks, seals, test taps,
drains, etc.)        ;
Miscellaneous Sources;      24 for Merc.
(leaks, seals, test taps,
drains, etc.)        ,    • •
Additional Flow for
Wet Desulfurization
25 for I&S
and Merc.
                                               Code No.
                                                              GPT
                                                                          Code No.
0012A
0464E
0012B

0060
0112C
0112B
0384A
0948C
0864A
0684Jr
0920FU
0584C
0856F
17
20
25
Average of 6 =
7.0
7.2
7.3
8
8
8.2
n 10
' 10.8
11
12
, -Average of 19 =
0012AV ; 7.2
0732A
0272
0426

0112B
0112A
09 2 OB
0432A
0384A
0948A
0112D

0732A
0272

0112B
0272
0112A
0732A
0280B
0112D
7.2
8
16
Average of 8 =
5
8
10
•12 •
17
19
21
Average of 13 =
21
22
Average of 3 =
8
13
20
20
21
22
0272
0426
0732A
28 GPT
0920B
0112
0112A
0684H
0584F-B
1 f
0684F
0868A
0320

' 12.6 GPT
0464E
0724F.
0012BU'
0174
14.7 GPT
0948C
0684A
0684B
0860B
0584C
0868A

20 GPT
0280B

24 GPT
0060A
0856A
0584F-M
0584C
0584B

                                                                                          GPT
 26
 32
 50

 14
 15
 15
 16
 16
 16
 18
 18
 22
                                                             16
                                                             16
                                                             16.8
                                                             30.6

                                                             21
                                                             22
                                                             23
                                                             25
                                                             32
                                                             49
                                                            28
25
25
28
42
53
                                                      Average of 11 = 25 GPT
                                           155

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TABLE IX-3
DEVELOPMENT OF BPT MODEL EFFLUENT FLOW RATES
BY-PRODUCT COKEMAKING
PAGE 3
  Wastewater Source

Additional Flow for
Indirect Ammonia
Recovery

Additional Flow for
Optimization of..
Bio-Oxidation

Total Plant Effluent
(Bio-Oxidation Systems
In-Place)
Total Plant Effluent
(Bio-Oxidation Systems
In-Place)

Total Plant Effluent
(No Bio-Oxidation Systems
In-Place; includes all
flows leaving plant,
even if disposal is via
quenching or other
means)
Flow in GPT

60 for I&S
and Merc.
50 for I&S
and Merc.
                                              Code No.
GPT
Code No.
                                                                                         GPT
           (3)
225 for I&S
240 for Merc.
                                        (3)
175 for I&S
           (3)
Total Plant Effluent
(No Bio-Oxidation Systems
In-Place; includes all
flows leaving plant,
even if disposal is via
quenching or other
means)
190 for Merc.
                                        (3)
0464E 43
0464B 54
Conf . <60
; Average of
0584F-M 35
0464E 36
0426 48
Average of
0920F 14-3
086 8A 146
0112A* 169
0584C* 199
Average of
0426 196
0464E 236
; Average of
0060F 44
0448A 60
0492A . 64
0920B 80
0684A 89 ,
OU2D* 102
0856F 102
0856N 104
0112B* 117
0948C** 123
0060A* 131
0860B 134
09:48A 135
0248A 136
0432B 149
0112C 152
Average of
0464C 33
0174 67
0464B** 96
Conf.** <100
Conf.
0948C
0024A
6 = 59 GPT
0584F-B
0112A

5 = 49 GPT
0012
0584F-B
0584F-M*
0856A*
8 = 205 GPT
0012A

3 = 232 GPT
0684F
0432A
0060*
0024A**
0384A
0946A
0864A
06841
Conf.
0256E
0684D
0684B
0860A
0684J
0320

31 = 161 GPT
0280B*
0732A*
0464E**
Conf.**
<60
62
74

48
78


224
237
242
281

265


153
158
160
173
175
182
208
218
<220
233
239
259
269
309
314


197
227
236
<250
                                            156

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 TABLE  IX-3            i
 DEVELOPMENT  OF  BPT MODEL  EFFLUENT FLOW RATES
 BY-PRODUCT COKEMAKING'
 PAGE 4
  Wastewater  Source
Flow in GPT
                                               Code No.
Total Plant Effluent  j      190  for Merc.
(No Bio-Oxidation Systems
In-Place; includes all
flows leaving plant,  i
even if disposal is via
quenching or other    <
means)                <
                                         (3)
                                                              GPT
                                                                          Code  No.
                                                                                          GPT
                   0272*          112         0656A
                   0024B          122         0212
                   0012B          153         0012A
                   0426           196
                           Average of 15 - 171 GPT
255
256
265
                      I
Conf.: Plant identity jis to remain confidential.
*    : Indicates that total plant effluent flow includes flow from wet desulfurization.
**   :, Indicates that [total plant effluent flow includes flow from indirect ammonia recovery.

(1) Plant uses causti^ soda instead of lime slurry in fixed ammonia still.
(2) Additional flow of 8-30 GPT is added at Plant 0868A.  Data from this plant were used to
    extablish BAT Limitations.
(3) Total plant effluent flows reported by the plants.  Not all plants have flow from all
    wastewater sources' listed above or in Table IX-2.
                                           157

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              :           COKEMAKING  SUBCATEGORY

              ,                 SECTION  X

              ;   EFFLUENT QUALITY ATTAINABLE  THROUGH
           THE APPLICATION OF  THE BEST AVAILABLE  TECHNOLOGY
                       ECONOMICALLY ACHIEVABLE
Introduction

The effluent iimitations  to be achieved  by  July  1,  1984  are  to  specify
the degree of |effluent reduction attainable through  the  application of
the Best Available Technology Economically  Achievable  (BAT).    BAT  is
to  be  determined  by identifying the very best  control  and treatment
technology employed within the industrial subcategory, or where it  is
readily transferable from one industry to another, such  technology may
be identified |as BAT.  Four BAT treatment alternatives were  considered
for  by-produdt  cokemaking.  For beehive operations, BAT is identical
to the BPT limitations described in Section IX.

As indicated  |in  Section V,  significant   changes  in   air emission
controls and wastewater control and treatment  technology  have produced
several   treatment  options  for  by-product  cokemaking operations.
Because of th^ number of  choices available,  the Agency decided  to  use
a  building block approach in developing the BAT  limitations as it did
with the BPT limitations.  Flow rates from  certain wastewater  sources
can  be  minimized  by  recycling  or  reuse  where  appropriate, or by
process changes which eliminate  or  substantially   reduce   wastewater
volumes,   such   as  replacing  barometric condensers   with  surface
condensers.   JThe  approach  contained   in   the   original  development
document EPA-4'40/l-74-024a (recycling barometric  condenser wastewaters
to  achieve  a  72  gal/ton  flow reduction from  that source alone) is
applicable to ;15 of the 59 plants responding to EPA  questionnaires and
is  currently : practiced  by  seven  plants,   which  have an  average
condenser  bldwdown  flow of 5.2 gal/ton.   The other 44 plants  have no
wastewaters fr|om-this source.

Although waste.water disposal by coke quenching is   widely   practiced,
more  stringertt; . air  pollution  control requirements mitigate  against
continued widespread use  of this practice.   Consequently,  the  Agency
believes  it'. iwould  be   inappropriate to establish  BAT  limits  at zero
discharge on that basis.   For costing  purposes,  the  Agency  assumed
that   on-site  biological  treatment  to   achieve   the   BPT  and  BAT
limitations would be installed at those plants.   Also, the water  used
in  scrubbers j associated  with  control of"atmospheric emissions from
oven charging and pushing require control and  treatment.   Recycle  of
the  scrubber  waters  can  be  used  to minimize the volume  requiring
treatment.   However,  the  blowdowns from these  systems must be  treated
prior to discharge.
                                    163

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Model BAT Flow

The  flows  of  the  model  treatment system for by-product cokemaking
operations are based upon values shown in  Table  X-1.   Plants  which
demonstrate  the  BAT  model  flow | for each wastewater source and the
total BAT model flow are listed in ^able X-2.

The limitations include an allowance for additional process wastewater
flow for those plants practicing indirect ammonia recovery.  These six
plants produce about 6% of the annual coke tonnage.  They qualify  for
supplemental  load  allowances  based  on  251 1/kkg (60 gal/ton) flow
rates.  The desulfurizer allowances listed  in  Section  IX  are  also
included in the BAT limitations.   ,    '    '

Based upon the performance at several well operated plants, "the Agency
provided  an allowance of up to 50 gal/ton for fresh water dilution to
optimize biological treatment at the BPT level (see Table  IX-3).   At
the  BAT  level,  'this  dilution  water is replaced by settled pushing
emission control system blowdowns or other wastewaters  that  are  not
highly  contaminated.   The adverse impacts of temperature changes can
be controlled by installing indirect cooling systems  or  by  allowing
sufficient   retention  and  equalization  time  prior  to  biological
treatment.  Providing suitable pretreatment and  equalization  of  the
ammonia liquor prior to biological ,treatment also minimizes the amount
of  "dilution"  which  may be necessary to protect the microorganisms.
Where sufficient wastewater volumes from other less aggressive sources
exist, they should replace all or part of the 209 1/kkg  (50  gal/ton)
dilution  which  was  included  in  the  BAT  limitations.  The Agency
provided 50 gal/ton in the model treatment system flow rate  for  this
purpose.

Identification of. BAT Alternatives

The  model wastewater flows used as a basis for BAT cost estimates are
summarized  in  Table  X-1.   The  ;pollutant  levels  which  the   BAT
alternative  treatment  system  can  achieve  are discussed below on a
pollutant-by-pollutant basis.  The alternative systems  are  described
in  Table  VIII-4 and schematics of the four BAT alternative treatment
models are shown in Figure VI11-2. : The BAT limitations are set out i
-------
 B.
component costs are shown in Table  VII1-6  for
plants and in Table VII1-7 for merchant plants.

BAT Alternative 2
                                                       iron  and  steel
      Filtration of the effluent  from  the  BAT  Alternative  1   model
      treatment  system  is included to minimize carryover of suspended
      solids and any toxic pollutants that  may  be  entrained  in  the
      solids.  !This system appears as Alternative 2 in Figure VIII-2.

 C.    BAT Alternative 3
              I
      Alternative 2 may be upgraded to provide better control of   toxic
      organic  >pollutants  and  ammonia  removal  by  the  addition  of
      powdered activated carbon to the biological reactors.    Refer  to
      Figure  yiII-2,   Alternative  3  for  a  diagram  of  the system.
      Limited  data indicate that single stage systems,  with or without
      powdered!   activated   carbon  can  produce  comparable  effluent
      quality.|  However,  the Agency does not have  sufficient,  data  to
      establis^ limitations based upon that technology.

 D.    BAT Alternative  4
              i                              -        -      .

      The  treated  effluent  from  the  above  biological  alternative
      systems  may be disposed of by coke quenching where impacts  on air
      pollution  can  be   tolerated.    Although  this  approach  is not
      recommended it provides a  means  of  achieving  zero  discharge.
      Refer  to  Figure  VIII-2,  Alternative 4 for the  treatment  system
      diagram, jand to  Tables VII1-6 and VII1-7 for component costs.

 Selection of_  a BAT Alternative

 The Agency  selected BAT  Alternative  No.  1,  depicted in  Figure X-l,  as
 the   model  treatment  system upon which the BAT'limitations are  based.
 This  technology is practiced  in   this  subcategory on  a   full-scale
 basis.   The  ;two-step  or   extended  biological   oxidation  system is
 currently installed at four by-product coke plants.  However,  all  of
 these  systems   are  not  operated to.achieve the  BAT limitations.   The
 Agency has  determined  that  the biological  treatment system  installed
 at  Plant   0868A  is   the   best  treatment  system.    In  making   this
 determination,;  the Agency  considered the  coke production   facility  at
 Plant 0868A;  the by-product  recovery facilities;  air pollution control
 systems;    untreated   wastewater  characteristics;  the  geographical
 location of the  plant; and  the design  and  operation of  the  treatment
 facilities.   !The   Agency  found no factors .which  it believes  make  this
 plant unique Or  not suitable  for  designation  as the best  plant.
              i            ,
 While  filtration   of  biological  treatment   system   discharges   is
 practiced   at I  Plant   0856A,  the  overall performance of the filtration
 system at this plant has not  been satisfactory because  of   design   and
 mechanical problems.   Hence,  the Agency has  not included  filtration in
 the selected BAT model treatment system.   BAT Alternative No.  3,  which
provides  for j the  addition   of  powdered   activated carbon,  has been
                                    165

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limited to short-term testing on a pilot scale, and shows  promise  of
marginal reductions in total pollutant loads.  Alternative 4 cannot be
applied in most cases because of its impact on air pollution.

Currently,   two   plants  are  operating  advanced  physical/chemical
wastewater treatment systems  that  -include  technologies  other  than
bioxidation.   Mixed  media pressure filtration and granular activated
carbon adsorption using fixed bed columns  are  provided  at  both  of
these  plants  (0684F  and  0732A). , The latter plant also is equipped
with alkaline chlorinatidn.  The Agency has promulgated  separate  BAT
limitations  for  those cokemaking operations with full scale granular
activated carbon columns installed prior  to  the  proposal  of  these
limitations.  These limitations are similar to the BAT limitations for
other  by-product cokemaking plants, except for ammonia-N, phenols (4-
AAP) and total cyanide.  Refer to Table X-3 for the  physical/chemical
BAT  effluent  limitations  and  to Figure X-2 for the model treatment
system.   The  limitations  can  be; achieved  by  treatment   systems
consisting  of  flow minimization (as in BAT Alternative No. 1 above),
fixed  ammonia  stripping,  followed  by   pressure   filtration   and
adsorption on fixed beds of granular activated carbon.  Refer to Table
VIII-8 for cost information.   '     :

Control and Treatment of. Pollutants Using BAT Technology

Appendix  C  of  Volume  I presentsjeffluent quality data for each BAT
alternative technology.  The Agency evaluated the impact of BAT  model
treatment  system  components  on toxic pollutants using data obtained
during sampling  surveys  at  Plants  003,  008,  009,  together  with
long-term  and special verification pilot scale study data from Plants
0868A and 0732A, respectively.  The'treatment system  at  Plant  0732A
has  only  been  recently  installed,  thus  long-term  data  are  not
available.  Plant 0868A represents BAT  Alternative   1,  while  Plants
0732A  and  0684F  are  the  two  physical/chemical treatment systems.
Sufficient monitoring data are available to determine treatment system
impacts on toxic pollutants  (Table X-4).

As discussed in Section VII and summarized  in Table  VI1-3,  the  many
toxic  organic  pollutants   identified  in wastewaters from  by-product
cokemaking can be controlled by treating those  pollutants   listed   in
the  BPT  limitations  and,  in  addition,  benzene,  naphthalene, and
benzo(a)pyrene.  The Agency selected these  toxic  organic   pollutants
and  phenols   (4-AAP)  to  serve as indicators for volatile, acid, and
base/neutral toxic organic pollutants.

A discussion of the reductions achieved by  the  BAT  model  treatment
system  on a pollutant by pollutant basis follows.  Table X-5 compares
actual plant performance with the BAT effluent limitations.

Ammonia-N

The BAT limitations for ammonia-N are achieved  at  Plant   0868A  with
biological   treatment.    During   the  toxic  pollutant  survey,  the
discharge  (0.77 mg/1,  201 gal/ton)  amounted to less than  5  percent   of
                                    166

-------
the  BAT  1 imitation.   Long  term  data  provided  for the plant show
consistent compliance  with  the  30-day  average  and  daily  maximum
limitations.   jFrom  April, 1979 through May, 1981 all monthly average
values with one exception  (4.4% over .the limit) were within the 30-day
average BAT limitation.  Daily maximum  concentrations  were  exceeded
for   only  one  day  during  that  twenty-six  month  period.   These
observations we're confirmed during seven  weeks  of  EPA  verification
sampling  on-sijte  between  October,  1979  and February, 1980.  Daily
maximum discharges never exceeded  45%  of  the  BAT  limitation,  and
monthly  averages for October, January, and February were at <1%, 55%,
and 92% of the BAT 30-day  average  limitation,  respectively.   Daily
analyses reported by the company covering the same period indicate the
same  high  degree  of  compliance  with the daily maximum limitation.
This successful! ammonia-N  load reduction is achieved  by  passing  all
wastewaters  through  free  and fixed stills, an aerated sludge lagoon
with two separate compartments, and a clarifier.  The  ammonia  stills
reduce  ammonia levels from 2,400 mg/1 in the raw liquor to 60 mg/1  in
the combined feed to biological treatment.   The  ammonia  content   is
further reduced by the later treatment.
               i
With one exception, the ammonia-N limitations were not achieved at the
remaining  plants.   These  plants  do  not  conform  to the BAT model
treatment facility, or are not operated to achieve  a  high  level   of
ammonia-N removal.  Cokemaking wastewaters from Plant C are discharged
to  a  POTW, and no other  treatment for ammonia is provided except the
free and fixed stills.  Plant 0920F has a treatment  sequence  similar
to  Plant  0868A,  however,  the  benzol  plant  wastewaters  are  not
pretreated for iammonia-N.  Although the ammonia  liquor  has  only   33
mg/1  of  ammonla-N  after stripping, the addition of raw benzol plant
wastewaters rai|ses the ammonia-N concentration  in  the  feed  to  the
biological  treatment  system  to  202 mg/1.  Biotreatment reduced the
ammonia-N conteht to 127 mg/1 in the effluent.   At  the  time  during
which  Plant  Oi920F was sampled (Sept. 6-9, 1977), only one of the two
aeration basinsi was in use.  The  Agency  believes  that  with  proper
pretreatment  and full operation of the biological treatment system  at
this plant, the, ammonia-N  limitations could be achieved.

Monitoring  data  for  Plant   0684F   (physical/chemical   treatment)
indicates  an  iammonia-N   discharge of 2.7 times -the applicable 30-day
average BAT limitation, at 0.0859 kg/kkg.  This includes a portion   of
the treated wastewater which is currently evaporated by coke quenching
and not passed through the ammonia-N still.  The actual ammonia-N load
discharged  directly  is   0.0568  kg/kkg, which exceeds the BAT 30-day
average limitations for physical/chemical treatment  systems  by  76%.
Although  the  treatment   system  is  designed  to strip fixed ammonia
following caustic addition,  both  toxic  survey  and  long-term  data
indicate  this ; reaction   is  not carried to completion.  During EPA's
sampling visit,' the ammonia-N concentration was reduced from 7750 mg/1
to 290 mg/1 in the still,  but pH values  never  exceeded  9.0  in  the
still  effluent,  indicating that the 290 mg/1 could have been further
reduced.  Long-> term data  reported for the plant covering  the  period
from  May,  197J9 through May, 1981 are in the form of weekly averages.
Ammonia-N concentrations in the still effluent averaged 130  mg/1  but
                                    167

-------
 the   range   was   11.8  mg/1   to  860  mg/1.   Twenty out  of  twenty-five
 monthly  averages  exceed the  75  mg/1   used  as  the  basis   for   30-day
 average   limitations  for physical/chemical   treatment  systems.   When
 ammonia-N discharges based upon the  low discharge flows  reported   for
 Plant 0684F  are  calculated,  the limitations are exceeded for  six of
 the  twenty-five months.    Moreover,   31% of   the  individual  results
 exceeded the  daily  maximum  concentration,  even though results  were
 reported weekly,  not daily.   This plant can attain the BAT   limitation
 for   ammonia-N for  physical/chemical plants by improving fixed ammonia
 removal  efficiency.
                                   i
 In summary,  the Agency believes that the BAT  limitations for ammonia-N
 can  be achieved at  all plants equipped with the  model   BAT treatment
 systems  or equivalent.           .
                                   !
 Total Cyanide

 The  BAT  limitations  for  cyanide are  achieved  at plants with biological
 treatment systems.    For Plant  0868A,  daily analyses  for the  period
 November 1977  through May 1981  demonstrate compliance, averaging  2.75
 mg/1  on a  year-round   basis.    For  the  43 months for  which daily
 analyses are  available,   one  monthly  average  exceeded   the   30-day
 average   limitation.    Daily  maximum  limitations  were exceeded  only
 twice in 43  months.   This high  level  of  compliance  continued  through
 the   seven week EPA  verification survey  (October  1979 through February
 198Q).   Overall average  total cyanide loads for this  survey were  at
 48%   of   the  30-day  average  limitations and none  of 21 daily  values
 exceeded the daily maximum limitation.

 Both  long term data  (six  months)  and   data  obtained  during the   EPA
 toxic    pollutant    survey   for  Plant   0920N also  demonstrate   the
 achievability  of  the 30-day average  and  daily  maximum limitations   for
 cyanide.    The Agency   believes  that  the cyanide  limitations  can  be
 achieved at  all coke plants equipped   with  the  model   BAT treatment
 system or equivalent.

 Phenols  (4AAP)

 Data   obtained   during   the   sampling   surveys   demonstrate   the
 achievability  of  the maximum  daily BAT limitation  for phenols (4 AAP).
 Three biological  treatment plants were discharging less  than  50%   of
 the  BAT daily maximum limitations.   Moreover,  long-term data covering
 43  months   of  operation  at   Plant   0868A    demonstrate    consistent
 attainment   of the 30-day  average  limitation.    During that  period,  the
overall  average of all monthly  averages was 42% of the 30-day  average
 limitation.     The  limitations   were   exceeded  during one  month in  43
months,   the  first month of operation.  The  daily  maximum   limitation
has  been  exceeded   only  ten times out of 1,237 observations.   During
the  seven-week   verification   study   at    this   plant,    effluent
concentrations  of   phenols   (4AAP) averaged 62% of the  30-day average
limitation,  and  no   individual  result  exceeded  the  daily  maximum
limitation.

-------
The  primary  treatment  system  component   in  the  physical/chemical
systems  is  activated  carbon  adsorption.   Phenols   (4AAP)   in   the
wastewaters  flowing into the two separate activated carbon systems at
Plant 0684F wepe effectively reduced.   During  the  EPA  survey,   the
concentration j in the waste ammonia  liquor was reduced  from 90  mg/1 to
0.058 mg/1; an<3,  the  concentration  in  all  other  wastewaters   was
reduced  from ; 1,550 mg/1 to 0.168 mg/1.  Long-term data from the  same
plant show  avjerage  effluent  loads  of  0.000077  kg/kkg  discharged
directly  and ' <0.000002  kg/kkg  disposed   of  by  quenching.  Direct
discharge data are based upon 102 analyses.  Five  of   the  individual
values  exceed  the  concentration   used  to develop the daily  maximum
limitations; however, the limitation was exceeded only  twice.
The Agency bel-ieves that the phenols  (4AAP)
achieved at all coke plants.
BAT  limitations  can  be
Benzene
The toxic pollutant plant sampling visits and the verification program
at  Plant 0868JA are the primary sources of data for benzene,  (refer to
Table VII-3 for data for toxic organic pollutants).   Short-term  data
indicated  that  the BAT limitations for benzene are acheived at Plant
0684A  by  carbon  adsorption,  and  at  Plant  0868A  by   biological
treatment.   Mbnitoring  data  from  the seven week (21 sampling days)
verification sampling at Plant 0868A indicate that the BAT  limitations
for  benzene  were  consistently  achieved.   Daily  discharges  never
exceeded  42% ; of the daily maximum limitation, and averaged  less than
18%.  Also, pilot plant  data  from  Plant  0732A  indicate   that  the
physical/chemical  treatment  system removes benzene effectively.  The
effluent concentrations from the carbon columns  averaged  <0.03  mg/1
consistently, j  This  approaches  the  performance  of  the full-scale
system installed at Plant 0684F where the benzene concentration in the
discharge was found to be less than 0.01 mg/1.

Naphthalene   ;
              [                    ." '        ' •            •     -
The BAT naphthalene limitation was  achieved  at  three  of   the  four
plants  surveyed  for  toxic pollutants.  Biological systems  at Plants
0868A  and  09j20F  attain  "none  detected"   and   <0.000002   kg/kkg
respectively". ''A similar value is achieved at Plant 0684F.

Pilot  scale  data  for  Plant  0732A . (physical/chemical) show carbon
column  effluents  at  <0.01   mg/1, .  often   at   "none   detected".
Verification  J3ata for Plant 0868A show that the 21 daily observations
were all less than the daily maximum BAT limitation.  Based upon these
data, the Agency concludes that the BAT limitation for naphthalene  is
being  achieve
-------
Benzo(a)pyrene

The  daily  maximum  limitation for benzo(a)pyrene was achieved at all
four of the  coke  plants  surveyed  by  the  Agency.   Discharges  of
0.000011  kg/kkg  and  "none  detected"  were  recorded for biological
treatment at Plants 0868A and 0920N, respectively;  and,  a  level  of
less   than   0.00001   kg/kkg   was  recorded  at  Plant  0684F  with
physical/chemical treatment.   Pilot  plant  data  for  the  activated
carbon system at Plant 0732A showed <0.01 mg/1 or "none detected."

Verification  data  for  Plant 0868A were consistently below the daily
maximum concentration value except for a  two-day  outage  in  January
1980.   The  daily  maximum  limitation  was exceeded on only one day.
Pilot filtration data indicate this outage was due . to  benzo(a)pyrene
which had been adsorbed on activated sludges, and was carried out with
abnormally   high   concentrations   of  TSS  (500-1400  mg/1).   Post
filtration of the BAT Alternative No. 1  'effluent  could  be  used  to
minimize  the  discharge of toxic organic pollutants during periods of
treatment system upsets.

The Agency believes that BAT limitations for benzo(a)  pyrene  can  be
achieved at all coke plants'.       :

Justification for BAT Effluent Limitations

Table X-5 presents a summary of actual plant performance data with the
BAT  effluent limitations.  These data indicate that well designed and-
well operated treatment  systems  can  be  used  to  achieve  all "BAT
effluent limitations.
                                    170

-------
                                         TABLE X-l

                                      BAT FLOW SUMMARY
                             BY-PRODUCT  COKEMAKING SUBGATEGORY
                             (All Flows in Gallons/Ton of Coke)
Wastewater Source


Waste Ammonia Liquor
Final Cooler Slowdown
Barometric Condenser Slowdown
Benzol Plant Wastewater
Steaia & Lime Slurry
Miscellaneous Sources (leaks, seals, test taps,
  drains)         1
Subtotal - Process Wastewaters

Dilution to optimize bio-oxidation
                  i      -       '
BASIC TOTAL FLOW                ,
  Flow Basis
 BAT Effluent
I&S   Merchant
 32
 10
 3
 25
 13
 20

103

 50*

153
 36 .
 12
  5
 28
 15
 24

120

 50*

170
Additional Flow Allowances Provided in the Regulation:

For Qualified Desulfurizers (Wet), up to:                   25      25
For Indirect Ammonia Recovery, up to:                       60      60

No Additional Allowances For:
                  I       -
Air Pollution Control Scrubbers:
  Coal Drying or Preheating - up to 15 GPT Slowdown*         0       0
  Charging/Larry Car - up to 5 GPT Slowdown*                 0       0
  Pushing Side Scrubber - up to 100 GPT Slowdown*            0       0

MAXIMUM TOTAL FLOW                  •      '                 238     255
    Up to 50 GPT of dilution water is replaced by blowdowns from air pollution control
    scrubbers.  Any excess blowdown (from pushing only) is disposed of via quenching
    operations, or treated and reused in the scrubber system.
                                        171

-------
                                                                 TABLE  X-2
                                               DEVELOPMENT OF BAT MODEL EFFLUENT FLOW RATES
                                                           BY-PRODUCT COKEMAKING
Flow Basis in GPT
Uastewater Source
Waste Ammonia Liquor
Final Cooler Slowdown
Barometric. Condenser
Slowdown11'
Benzol Plant Wastewaters
Steam and Lime Slurry
Miscellaneous Sources
Additional Flow for
I&S
32
10
3(4%)
25
13
20
50
• Merc.
36
12
5(7%.)
28
15
24
50
Plants Which Demonstrate BAT Flow
Code No. GPT
Same as BPT. Refer
Same as BPT. Refer
0448A 
-------














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                I         COKEMAKING SUBCATEGORY .

                :               SECTION  XI

         BEST CONVENTIONAL  POLLUTANT CONTROL TECHNOLOGY  (BCT)
The  1977 Amendments added  Section  301(b)(2)(E)  to  the  Act  establishing
"best  conventional pollutant  control  technology"  (BCT)  for  discharges
of conventional pollutants from  existing   industrial  point  sources.
Conventional   pollutants   are  those   defined   in  Section   304(a)(4)
[biochemical  oxygen  demanding  pollutants   (BOD5),   total   suspended
solids   (TSS),  ifecal coliform,  and pH], and  any additional  pollutants
defined by the Administrator as  "conventional"  (oil  and  grease,  44   FR
44501, July 30,: 1979) .
                f                   .                              •
BCT  is  not an [additional  limitation  but replaces BAT for the control
of conventional pollutants.  In  addition to other  factors  specified  in
Section  304(b)(j4) (B),  the  Act   requires  that  BCT  limitations   be
assessed  in light of a two part "cost-reasonableness" test.   American
Paper Institute iv. EPA, 660 F.2d 954  (4th Cir.   1981).   The  first test
compares the cost for private  industry  to   reduce  its   conventional
pollutants  with;  the  costs   to   publicly  owned  treatment works for
similar levels of reduction in their discharge   of   these  pollutants.
The   second   tfest  examines  the cost-effectiveness   of  additional
industrial treatment beyond BPT.   EPA  must find  that   limitations  are
"reasonable"  under both tests before  establishing them  as BCT.  In  no
case may BCT be less stringent than BPT.
                i                                               ...
EPA published its methodology  for  carrying out   the  BCT   analysis   on
August 29, 1979! |(44 FR 50732).    In the case-mentioned  above,  the Court
of  Appeals  ordered  EPA  to  correct  data  errors   underlying EPA's
calculation of the.first test,  and to  apply  the  second  cost  test.
(EPA had argued that a second  cost test was not  required.)

The  Agency  has'  decided  to set  the BCT limitations  equal  to the BPT
limitations for cokemakirig operations.
                                    179

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                 ;        COKEMAKING  SUBCATEGORY

                 j             SECTION  XII

          EFFLUENT  QUALITY ATTAINABLE  THROUGH  THE  APPLICATION
              OF, NEW  SOURCE  PERFORMANCE STANDARDS (NSPS)
 Introduction     i

 The new source performance  standards  (NSPS)  are  to  specify  the   degree
 of  effluent  reduction achievable  through  the application  of the  best
 available  demonstrated   control    technology    processes,   operating
 methods,  or  other  alternatives,  including,   where   practicable,   a
 standard permitting no discharge of  pollutants.    While  this   latter
 goal   is  achievable for  beehive cokemaking  operations, the Agency has
 decided not to propose NSPS for beehive operations  because  it is  very
 unlikely  that -hew  beehive  processes  will  be built in  the  future.
 However, even if:some new source were to be  built   the  BPT and   BAT
 limitations   (no  discharge  of  wastewater pollutant  to. navigable
 streams) would apply to such sources.

 For by-product cokemaking,  a "no discharge of pollutants" standard  is
 difficult   to   :attain.    The  coking  operation   liberates moisture
 contained in thejcoal and,  in effect, generates  water as  a  by-product.
 Other  sources oficoke plant wastewaters are  final cooler  wastewaters,
 benzol  plant  wastewaters, coke quenching tower overflows,  coke wharf
 drains, steam condensed in  the  ammonia  stills,   cooling   tower   and
 boiler  blowdowns, cooling  system leaks, general washwater  used  in the
 coke plant  areaj  and  dilution  water,  if any,   used  to optimize
 conditions  for  jbiological treatment.  In addition, the  latest  in air
 pollution emission controls are required at  new  sources,   which   may
 increase the volumes of water requiring control  and  treatment.

 If  no  liquid discharge  is to be achieved from modern  by-product  coke
 plants, a means of total  disposal must be found  for  the 135  liters/kkg
 (32. gal/ton) of excess flushing liquor which is produced.   All of   the
 pollutants  in  1-;his  water,  with  the possible exception of suspended
 solids, are amenable to pyrolytic   decomposition.    A   rough  estimate
 shows  that  about  126,000  kilogram  calories per  metric  ton of  coke
 produced would be required  to  dispose  of   this  waste.    This  is   a
 negligible  percentage  of  the fuel value of the tar and  gas generated
 in the production of a ton  of  coke.   However,  there  is   reason  to
 believe that unless very  sophisticated means are used to  pyrolytically
 dispose  of  this  water,  serious air pollution problems  would result.
 The gases released from less than optimum incineration of   this  water
 could  be  expected  to   contain  high concentrations of  the oxides  of
 nitrogen  and  sulfur  and  some  particulate  matter.    If  a   simple
 incinerator  with a wet scrubber were used,   the basic pollutants would
merely be transferred back  to another water  stream,   thus producing   an
 even larger volume than the original.
                                   101

-------
Since many of  the toxic pollutants in the liquid stream are volatile,
evaporation  of the liquid to dryness would result in many of the same
problems as incineration.  In  fact,  examination  of  numerous  other
points  of disposal of this stream within an integrated steel mill all
yield the same answer.  While total pyrolytic  decomposition  of  this
small wastewater stream to innocuous gases would be the most desirable
method   of  complete  disposal,  air  pollution  impacts  and  energy
constraints render this option impractical.

For the above  reasons,  the  Agency  decided  not  to  propose  "zero
discharge" NSPS for by-product cokemaking.

Identification of_ NSPS Alternative Treatment Systems

Three  NSPS  alternative  treatment  systems  were  considered for new
sources.  Each has biological treatment as  the  principal  component,
while  one  includes  powdered  activated carbon addition for improved
treatment.  The biological sequence! is demonstrated at Plant  0868A  -
the Agency's selection as the best treatment plant.  Enhancement using
powdered  activated  carbon  (PAC)  is currently undergoing testing at
several operations.  The operators of two coke plants with  biological
treatment  systems  are  investigating  the  addition  of  PAC  to the
aeration  basin  to  enhance  removal  of  carbonaceous  material  and
ammonia-N.   Figure  VII1-2  presents the model NSPS treatment systems
and Table 'XII-1 present the model plant effluent quality data for  the
NSPS alternatives described below.

NSPS Alternative 1

At  new  cokemaking  operations,  the  opportunity to minimize process
wastewater flow is available.  Hence, the  first  step  in  each  NSPS
alternative is the elimination of extraneous water.  Dry desulfurizers
are  generally  available  and  are recommended for use at new plants;
however, the Agency has included  allowances  for  wet  desulfurizers.
Operation  of  certain by-products recovery units may not be part of a
new source plant.  For example, companies may  choose  not  to  refine
light  oils  (less benzol plant wastewater), or not to recover ammonia
as an ammonium salt (replaces crystallizer wastewaters  with  a  small
volume   waste).    Even  if  ammonium  sulfate  is  produced,  vacuum
crystallizers with steam ejectors  should  be  equipped  with  surface
condensers,   rather  than  barometric  condensers,  or  an  alternate
crystallization system can be used.,  For those plants where barometric
condensers are to be installed, the wastewaters can be  recycled  with
only  very limited blowdowns requiring treatment.  This latter step is
considered to be a pollution control cost, while  most  of  the  other
means to eliminate water are process related.

Modern  and  more  efficient  free • and  fixed  ammonia stills are now
available from several sources to provide effective  ammonia  recovery
and cyanide stripping.             ;

All  wastewaters  are  transferred to a holding and equalization basin
for detention; pH i^ adjusted; the twastewaters are then transferred to
                                    182

-------
a two-step or extended biological oxidation system  with  a  clarifier
and  vacuum  filtration  of  underflows.  Either dilution water or the
addition of wastewaters from air pollution emission controls, up to 50
gal/ton, is included.  Refer to  Figure  VII1-2  for  a  process  flow
diagram and Table VII1-9 for model plant costs.

NSPS Alternative 2

The  alternative  described above is supplemented with post filtration
of the clarifier effluent to prevent pass  through  of  toxic  organic
pollutants during treatment plant upsets.

NSPS Alternative 3.

All  parts  of NSPS Alternative No. 2 are included with provisions for
adding  powdered  carbon  to  both  activated  sludge   basins.    The
filtration  system  prevents  carryout  of excessive suspended solids.
Refer to Figure VIII-2 for a diagram of  this  alternative  and  Table
VII1-9 for model plant costs.

NSPS Model Treatment System Flow Rates

Since   charging,   pushing  and  preheating  emissions  controls  are
generally required at new s6urces, all- NSPS flows  include  up  to  50
gal/ton  from  ithese  sources  in  place  of  dilution  water  for the
biological tera^tment systems.  The  recycle  of  barometric  condenser
wastewaters  with  a  3  gallon  per  ton  blowdown is included in all
alternatives,  \as  are  recycle  of  final  cooler   wastewaters   and
minimization  o!f  flows  from benzol plants and miscellaneous sources.
The model treated wastewater flow rates for each alternative are based
upon 153 galloris/ton of coke for iron and steel coke  plants  and  170
gal/ton  for merchant coke plants, which are the same model flows used
as the bases for the BAT limitations.   Refer  to  the  discussion  in
Section  X,  arid in particular to Table X-l for further details on the
NSPS model flow.  The NSPS model treatment system flow rates are  well
demonstrated.  \

Response to Cou'rt .Remand of NSPS model Flow

The  previous  INSPS  were remanded by Third Circuit Court on the basis
that the model iflow was "not demonstrated."  The  only  plant  in  the
original  survey  with  a  treated effluent flow less than 100 GPT was
plant C, and ari undetermined portion of its  process  wastewaters  was
then disposed qf by coke quenching.

The toxic pollutant survey turned Reference is made to Table II1-3 for
industry-wide data.  Data submitted by 59 coke plants indicate that 12
have  total  process  wastewater  flow  rates  lower than 100 gal/ton.
Thus, from plant data,  it is evident that  the  100  gal/ton  flow  is
demonstrated  by many plants using various disposal means.  Two of the
sampled plants '(002 and 0684F) also had measured flows  of  less  than
100 gal/ton.   I
                                    183

-------
Although  the TOO gal/ton flow has been effectively demonstrated, cost
estimates for NSPS and the standards are based upon  153  gal/ton  for
iron  and  steel  plants  and  170  gal/ton for merchant plants as the
Agency believes these flows are more  appropriate.   The.  increase  in
flow  compensates for the growing trend toward air pollution emissions
control with wet scrubbers.

NSPS

The effluent standards for new sources are summari-zed in Table  XI1-2.
Alternative No. 1 has been selected as the NSPS model treatment system
(depicted  in  Figure  XII-1).   Refer,  to  sections  IX  and  X for a
discussion of individual pollutants and the ability of existing plants
to demonstrate compliance with NSPS.  Table XI1-3 compares  NSPS  with
existing plant.performance.
                                    184

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                               TABLE XII-1
                         :  EFFLUENT QUALITY FOR
                       NSPS MODEL TREATMENT SYSTEMS
                          COKEMAKING SUBCATEGORY
Flow, gal/ton


TSS, mg/1  ;

Oil & Grease*, mg/1
           t  '
Ammonia-N, mg/1

Cyanides, mg/1

Phenols (4AAP), mg/1

Benzene*, mg/1

Naphthalene*, mg/1

Benzo(a)pyrene*, mg/1

pH (Units)
Alternative:
Iron & Steel
Merchant









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170
140
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25
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0.05
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153
170

20

5

20

5.0

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0.03

0.03

0.03

6-9
*Values shown are maximum daily concentrations only.
                                   185

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-------
                         COKEMAKING SUBCATEGORY

                              SECTION XIII

                 PRETREATMENT STANDARDS FOR BY-PRODUCT
                    COKE PLANTS DISCHARGING TO POTWS
 Introduction   ;

 This  section  presents  available  pretreatment alternatives for coke
 plants with discharges to publicly owned treatment works (POTWs).  The
 Agency  has  not  promulgated  pretreatment  standards   for   beehive
 cokemaking  operations.   None  of  the  existing  beehive  -operations
 discharge to POTWs and it is unlikely that this would occur because of
 their  location and the fact that existing beehive  operations  achieve
 zero  discharge;.    Even  if  it  could  be determined that an existing
 beehive operator was proposing to discharge indirectly by a  POTW,   it
 would   be  extremely  costly  to pay sewerage charges for a wastewater
 which  can effectively be eliminated  using  the  BPT  model  treatment
 system.   .Moreover,   the General Pretreatment Regulations,  40 CFR Part
 403,   applicable .to  all  sources,    including   beehive   cokemaking
 operations,   would  apply.  ' Accordingly,  the Agency has decided not to
 proposed pretreatment standards for beehive cokemaking plants.
                r             i.              •
 The  Agency  has   considerated  pretreatment  standards  for  new  and
 existing  by-product  cokemaking operations.   The general pretreatment
 and  categorical   pretreatment  standards   applying   to   cokemaking
 operations  are discussed below.           •

 General  Pretreatment Standards

 For  detailed  information on Pretreatment  Standards refer  to 46  FR 9404
 et seq,  "General  Pretreatment  Regulations for Existing and  New  Sources
 of   Pollution,";  (January 28,  1981).   See also 47 FR 4518 (February 1,
 1982).   In  particular,  40 CFR  Part  403  describes  national   standards
 (prohibited    discharges   and  categorical   standards),   revision   of
 categorical standards,  and  POTW pretreatment  programs.

 In   establishing   pretreatment  standards  for  by-product   cokemaking
 operations,   the   Agency considered  the objectives and requirements of
 the General Pretreatment Regulations.    The   Agency  determined  that
 untreated  discharges   of  cokemaking wastewaters  to  POTWs would result
 in pass  through of toxic and nonconventional  pollutants.    The  Agency
 also  considered   other   factors specifically applicable  to  by-product
 cokemaking operations which are  discussed  below.
                I

 Pretreatment Alternatives for  Cokemakinq  Operations

Because direct discharge  limitations  for  cokemaking   operations   are
based upon bioldgical treatment, the Agency considered  six alternative
treatment  systems  for  PSES  ranging  from   a system  similar to that
                                   109-

-------
provided by the industry prior to on-site biological treatment to full
BAT treatment   These alternatives are illustrated .1*1  Figures  VIII-1
and  vm-I with accompanying effluent quality data presented in Table
XIII-1.  Model plant costs are presented in Table Vlli-iu.

PSES/PSNS Alternative 1_              .     ,

This alternative is similar to the level of pretreatment  provided  by
the  industry  for  cokemaking wastewaters prior to on-site  biological
treatment   Final cooler  and  barometric  condenser  wastewaters  are
recycled    Benzol  plant  wastewaters  and final cooler  blowdowns are
routed through a dissolved gas   flotation  system  for  oil  and  &cum
removal    Waste ammonia liquors are dephenolized, and all wastewaters
are  stripped  of  ammonia-N  with  free  and  fixed  ammonia  stills.
Equalization and PH control complete the. pretreatment system.

PSES/PSNS Alternative 2

This   alternative  is   the  same as   the  model  BPT treatment  system
described   in  Section   IX  and   includes  single    stage   biological
treatment    The  first  step  is  the minimization of  process  wastewater
flows  by recy™ of final cooler and barometric  condenser wastewaters
Following Recovery  of   by-products: by   free   ammonia   stripping   and
deDhenolization, treatment  continues with  lime addition,_fixed_ammonia
st?ipSinS>   equalization and  detention in  a  settling basin,  and  single
Stage  biological oxidation  prior to  release  to sanitary  sewers.

PSES/PSNS Alternative's

This  alternative  is  the same   as  BAT-1,   and   includes   all  of  PSES
Alternative 2  plus  a  second stage biological oxidation  unit to further
reduce   ammonia-N    cyanide,    phenols    (4AAP)   and,   toxic  organic
pollutants.                         |

PSES/PSNS Alternative £

This   alternative   includes  post 'filtration  of  the  discharge   of
Alternative 3  described above.

 PSES/PSNS Alternative 5.            ;

 Alternative  5  includes  the addition of powdered carbon to the above
 system"    This  alternative  may  produce  slightly  lower  levels  of
 KSpSnded  solids,   oil  and  grease,   toxic metals, and toxic organic
 pollutants.                   .

 PSES/PSNS Alternative 6.

 The treated effluent  from  Alternative  2  through  5   above  may   be
 disposed  of  by coke quenching where the impacts on air pollution can
 be tolSrated.  'This alternative^ is  not  recommended  even ' though   it
 provides a means of achieving zero discharge.
                                     190

-------
Pretreatment Considerations for Cokemaking Operations

Ammonia-N      ;
     . -         i               •                    •  -
Most  POTWs  in  the United States are not designed for nitrification.
Hence,  aside from incidental removal, most if not all of the ammonia-N
introduced into POTWs from cokemaking  operations  will  pass  through
into receiving^waters without treatment.  Depending on the size of the
POTW  and  the: volume  of  and  pretreatment  provided for cokemaking
wastewaters, operating problems may not be  experienced  at  the  POTW
because  of  dilution.   nonetheless,  the ammonia-N discharged to the
POTW will passithrough untreated.

The discharge from Plant 0584B to the Detroit sewerage system provides
an excellent example of the above.  Waste  ammonia  liquors  from  the
coke plants at;Plant 0584B are pretreated with free ammonia stills and
dephenolizers  Iprior to discharge to the Detroit sewerage system along
with sanitary wastewaters and minor miscellaneous coke plant  sources.
Final  cooler  Iwastewaters,  benzol  plant  wastewaters,  and  pushing
emission control wastewaters are disposed of by coke quenching at this
plant.   The ammonia-N discharge from Plant 0584B to the Detroit sewage
treatment plant ranges between 12,000 and 15,000 Ibs/day.   Since  the
Detroit  sewage  treatment  plant  is  designed  to  provide secondary
treatment  (no! ammonia-N  removal)  for  800  MGD,  the  coke   plant
wastewater  isi diluted  and  does not interfere with POTW operations.
Hence,  virtually the total coke plant ammonia-n discharge continues to
reach the Detroit River.

Another example of lack of POTW treatment for ammonia-N resulting from
cokemaking operations is provided by the East Chicago, Indiana  sewage
treatment  plant.  This facility receives partially treated coke plant
wastewaters from Plants 0384A and  0948C.   Recent  investigations  of
this  facility: by  Region  V  of  EPA  show the plant is experiencing
significant  operating  problems,  notably  with  respect  to   sludge
handling  and  ;overall  efficiency.  The Region attributes many of the
problems at this facility to coke plant  wastewaters.   Data  for  the
East Chicago sewage treatment plant demonstrate this facility does not
remove  or otherwise treat ammonia-N.  Hence, the ammonia-N discharges
from Plants 0384A and 0948C pass through untreated.
              11                     '                      »
Data for the Middletown, Ohio sewage treatment plant, which is a well-
run secondary treatment facility, show that partial  nitrification  is
occurring at the plant.  It is likely that this plant will be upgraded
to  full  nitrification  in  the  future.   In this case the ammonia-n
discharged from Plant 0060 into the Middletown sewage treatment  plant
would not pass;through the municipal facility.

Total Cyanide  :

As  noted in Volume I, Section V, cyanide compounds can  interfere with
the operation of and pass  through  POTWs,  as  well  as  enhance  the
toxicity  of  metals  commonly  found in POTW effluents.  The Agency's
data indicate  i that  pass  through  of  cyanide  at  municipal  sewage
                                    191

-------
                                                                         1
treatment  plants   is  about  50%.  Available data for the Middletown,
Ohio sewage treatment plant demonstrate pass through of  cyanide  from
Plant 0060.

Phenolic Compounds                 :

Phenol and phenolic compounds can be effectively treated in POTWs with
properly  acclimated  systems.   Data  for the Middletown, Ohio sewage
treatment plant show consistent effluent  concentrations  in  the  low
parts per billion range.

Toxic Organic Pollutants

Raw  and  partially  treated  cokemaking wastewaters from several coke
plants containing high concentrations of toxic organic pollutants  are
currently  discharged  to  POTWs.  ;Based upon the information and data
presented in Volume I, data from the Middletown, Ohio sewage treatment
plant, and data for coke plant biological treatment plants, the Agency
concludes that  the  toxic  organic  pollutants  found  in  cokemaking
wastewaters  can  be  significantly reduced with properly designed and
operated  biological  treatment  systems.   However,  many  of   these
pollutants  are  degraded  to  only a limited extent in POTWs and most
tend to concentrate in POTW sludges.


Selection of Pretreatment Alternatives

The promulgated pretreatment standards for existing sources (PSES) and
new sources (PSNS) are based upon RSES/PSNS Alternative 1, (see  Table
XIII-2   and   Figure   XIII-1)..  ' As  noted  above,  this  level  of
pretreatment is similar to that provided by the industry prior to  on-
site  biological treatment of cokemaking wastewaters.  As shown by the
data presented below, the Agency believes this level  of  pretreatment
will  prevent  pass  through  of  coke  plant pollutants at POTWs to a
greater extent than would occur if  untreated  cokemaking  wastewaters
were discharged to POTWs:
Ammonia-N
Total Cyanide
Phenols (4AAP)
Benzene
Benzo(a)pyrene
Naphthalene
PSES/PSNS
Alternative 1
   94%
   80%       i
   92%
   82%
   73%       :
   89%       :
                                           POTW
52%
                                    192

-------
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-------

-------
                        SINTERING SUBCATEGORY

                              SECTION I

                               PREFACE
The USEPA has promulgated effluent limitations and standards  for  the
steel  industry  pursuant to Section 301, 304, 306, 307 and 501 of the
Clean Water Act.  The regulation  contains  effluent  limitations  for
best  practicable  control  technology currently available (BPT); best
available  technology  economically  achievable  (BAT);   pretreatment
standards for ;new and existing sources (PSNS and PSES); and new source
performance   [standards   (NSPS).    Effluent   limitations  for  best
conventional pollutant control technology (BCT) have been reserved for
future consideration.

This part of the Development Document highlights the technical aspects
of EPA's study of the Sintering Subcategory  of  the  Iron  and  Steel
Industry.   Volume  I  of  the  Development Document addresses general
issues pertaining to the industry while other volumes contain specific-
subcategory reports.
                                   197

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1

-------
                        SINTERING SUBCATEGORY

                              SECTION II

                             CONCLUSIONS
Based upon this study, a  review  of  previous  studies  by  EPA,  and
comments  received on the proposed regulation (46 FR 1858), the Agency
has reached the following conclusions concerning sintering operations:
1 .
The  Agency  has  retained  one  subcategory  for  all  sintering
operations.    The  expanded  data  base  confirms  that  further
subdivision  is  not  necessary  to  effectively   regulate   all
sintering operations.

The data indicate that the BPT  effluent  limitations  originally
promulgated  (1974) for sintering operations did not sufficiently
account for wastewater discharges from all  sintering  wastewater
sources.  ; Accordingly, the Agency has promulgated less stringent
BPT effluent limitations for suspended solids and oil and  grease
based   upon   a  model  plant  effluent  flow  of  120  gal/ton.
Compliance with the BPT limitations is  demonstrated  by  systems
treating both machine (windbox) and discharge end wastewaters.

The Agency's monitoring of sintering process wastewaters revealed
significant concentrations of four toxic organic  and  six  toxic
metal  pollutants,  in addition to cyanide.  The Agency concluded
that the discharge of  these  pollutants  can  be  controlled  by
available,; economically achievable technologies.  The Agency has,
therefore,  promulgated  BAT limi tat ions •.   A summary of raw waste
loadings and the discharges resulting from attainment of the  BPT
and BAT limitations is presented below.

                     DIRECT DISCHARGERS
            Pollutant Loadings (tons/year)
     Flow (MGD)
     Ammonia (N)'
     Cyanide(T)
     Fluoride
     Oil and Grrease
     Phenols(4AAP)
     TSS       !
     Total Toxic Metals
     Total Toxic Organics*
                         Raw Waste

                           93.4
                          853.8
                           28.5
                          853.8
                       34,153.3
                           28.5
                      868,064.2
                          298.8
                           17.1
                                           BPT
  7.2
 65.8
  2.2
274. 1
 76.8
  2.2
427.6
 14.0
  1 .3
 BAT

  7.2
 65.8
  2.2
219.3
 38.4
  2.2
109.7
  4.8
  1 .3
     * Toxic organics does not include the individual
       phenolic compounds.
                                   199

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A summary of raw waste loadings and the discharges resulting from
attainment of the PSES is presented below.
                INDIRECT (POTW) DISCHARGERS
               Pollutant Loadings (tons/year)
Flow(MGD)
Ammonia(N)
Cyanide(T)
Fluoride
Oil and Grease
Phenols(4AAP)
TSS
Total Toxic Metals
Total Toxic Organics*
                     Raw Waste

                      i   5.8
                      :  53.4
                         1.8
                      :  53.4
                     2,134.6
                         1 .8
                    54,254.0
                        18.7
                         1 .1
                        PSES

                         0.5
                         4.4
                         0. 1
                        14.6
                         2.6
                         0. 1
                         7.3
                         0.3
                         0. 1
* Toxic organics does not include the individual
  phenolic compounds.         '•

The Agency's estimates of the costs of compliance with  BPT,  BAT
and  PSES  for  the sintering subcategory are presented below for
facilities  in  place  as  of  July  1,  1981.   The  Agency  has
determined   the  effluent  reduction  benefits  associated  with
compliance with the effluent limitations  and  standards  justify
these costs.

            Costs (Millions of July 1, 1978 Dollars)
           Investment Costs             Annual Costs
BPT
BAT
PSES

TOTAL
In-Place

  58.8
   0.5
   3.2

  62.5
Required

   5.1
   5.5   !
   0:4   '•

  11.0
In-place

19.8
 0.05
 1 .3

21 .1
Required

  2.2
  0.8
  0.05

  3.0
The  Agency  has  also  determined  that  the
benefits associated with compliance  with
(NSPS, PSNS) justify these costs.
                                       effluent reduction
                                   new  source  standards
The BPT, BAT, and PSES model treatment systems for the  sintering
subcategory  include  wastewater  recycle.   Responses  from  the
industry regarding several sintering operations indicate that the
recycle systems in use at these plants do not present significant
problems with respect  to  scaling,  fouling  or  plugging.   The
Agency  has  concluded  that  the  use  of  recycle  systems is a
reasonable and demonstrated method of achieving  the  limitations
and standards for this subcategory.
                               200

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10;
1 1
The Agency has not promulgated BCT limitations  for  conventional
pollutants  (TSS  and  oil  and grease) in sintering wastewaters.
This  sectiion  of  the  regulation   is   reserved   for   future
consideration.

NSPS for sintering operations using wet methods of air  pollution
control  are  the  same  as  the BAT effluent limitations and are
based upon the BPT and BAT wastewater treatment technologies.  It
is recognized that dry air cleaning systems which do not generate
process wa'stewaters may be  installed  on  new  source  sintering
operations.                  •

EPA has promulgated pretreatment standards for new  and  existing
sources  (iPSNS  and  PSES),  discharging  to POTWs which limit the
amount of Itoxic pollutants which can be introduced into  a  POTW.
These standards are intended to minimize the impact of pollutants
which pass through POTW operations.

Although four toxic organic and six toxic  metal  pollutants,  in
addition  ;to  cyanide,  were  found  in  the raw wastewaters from
sintering [operations, the Agency believes it is not necessary  to
directly  jlimit  each  toxic pollutant.  The Agency believes that
adequate qontrol of toxic metal pollutants can be achieved by the
control of lead and  zinc.   Toxic  organic  pollutants  are  not
limited for sintering operations.

To facilitate less costly  central  treatment  and  to  make  the
sintering limitations compatible with the ironmaking limitations,
the  Agency  has  promulgated  BAT limitations and NSPS, PSES and
PSNS  for i ammonia-N,  total  cyanide,  and   phenols(4AAP)   for
sintering |  wastewaters  which  are  co-treated  with  ironmaking
wastewaters.

With regard to "remand issues," the Agency concludes that:

a.   Regarding the use of tight  recycle  systems  for  sintering
     operations, the discharge flow of 75 gal/ton for new sources
     has  not  been  adequately  demonstrated.  Consequently, the
     Agency-based NSPS, as well as the other effluent limitations
     and standards-on a demonstrated flow of 120 gal/ton.

b.   The estimated cost to install a wastewater treatment  system
     is  not  significantly affected by whether it is an "initial
     fit" ior a "retrofit".  In addition, the ability to implement
     various wastewater treatment practices is  not  affected  by
     plant  age.   A comparison of actual costs (reported for the
     plants  visited  or  represented  by  the   industry   D-DCP
     responses)   with   EPA's   cost  estimates  developed  from
     treatment models indicates that  the  estimated  subcategory
     treatment   costs   are   sufficiently   generous  to  cover
     site-specific and other incidental costs.
                                    201

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     c.    The treatment technologies included  in  the  various  model
          treatment  systems will not cause any significant impacts on
          the consumptive use of water.

12.   Table  II-l   presents  the  BPT  effluent  limitations  and   the
     supporting treatment model flow and effluent quality data for the
     sintering  subcategory.   Table I1-2 presents the treatment model
     flow and effluent quality data, as well as  the  limitations  and
     standards  used  to  develop the BAT effluent limitations and the
     NSPS, PSES,  and PSNS for the sintering subcategory.

13.   The annual costs presented above are different than those used by
     the Agency in the Economic Impact  Analysis  completed  for  this
     regulation.    After  the  Economic Impact Analysis was completed,
     the Agency discovered an error in the estimated  sludge  disposal
     costs  for  sintering operation.  The correct costs are presented
     in this document.  The incorrect annual cost used in the Economic
     Impact Analysis are about 8.2 million dollars less for  treatment
     facilities  in  place,  and 0.9 million dollars less for required
     treatment  facilities.   The  Agency  does  not  consider   these
     differences   significant  in  terms  of  whether  the  costs  of
     achieving  the  resulting   effluent   reduction   benefits   are
     justified.   In  addition,  with  respect  to  possible  economic
     impacts, differences of this magnitude were accounted for by  the
     sensitivity analysis included  in the Economic Impact Analysis.
                                    202

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                         SINTERING SUBCATEGORY

                              SECTION III

                              INTRODUCTION
 Discussion     '

 During   iron   and   steel   production  operations,   large quantities of
 particulate matter  (fines,  mill  scale,  flue  dust)   are  generated  by
 blast   furnaces; open  hearth,  electric arc,  and basic oxygen furnaces-
 and, hot  forming  mills.    The  particulate  matter  is  removed  from
 process  gases, by   dry or wet air  pollution control  devices to reduce
 air emissions  or to clean  the  gases for reuse as fuel.   Mill scale  is
 recovered from wastewaters discharged from hot forming operations.   A
 large percentage of this iron  rich  material  is recovered  through   the
 sintering operation.   The fused   material  (sinter)  produced by the
 sintering operation is reused  as raw material in blast  furnaces.

 Description of!the  Sintering Process
               t                      •

 Sintering is an agglomeration  process in which iron bearing   materials
 (generally  fines)   are  mixed  with  iron   ore,  limestone,  and finely
 divided fuel such as coke  breeze.   The  fines consist  primarily  of  mill
 scale and dustifrom basic   oxygen   furnaces,   open  hearth   furnaces
 electric  arc  furnaces, and blast furnaces.   Mixers (e.g., ball drums)
 are used  to mix the raw  materials   before   they are  placed  on   the
 traveling grate  of   the   sinter   machine.    Near  the  head  end of the
 grate,  the surface  of  the  raw  materials is   ignited  by  a   gas fired
 ignition  furnace located  over the  bed.   As  the mixture moves along  on
 the traveling  grate, air is drawn down  through the  mixture at the  wind
 boxes to  enhance combustion and  to  sinter (fuse)  the  fine   particles
 As   the  bed  ;burns,  carbon  dioxide,   cyanides,  sulfur   compounds!
 chlorides and  fluorides are driven  off  with  the gases.   Oil  and grease
 on the  mill scale is vaporized and  driven off.

 The sinter drops off the grate at the discharge end of  the machine and
 is cooled (either by air or a  water   spray),   crushed,   and   screened.
 Screening is•;necessary   to   maintain   uniformity  in  the size of the
 sinter  fed to blast furnaces.  Improperly sized sinter  and   the fines
 from  the  screening   operation  are  returned  to  the  operation for
 reprocessing.   |Wastewaters  are generated  in  this process  primarily  as
 a  result  of  [scrubbing  the  gases  and. dusts  associated  with the
 sintering process.   Wastewaters  are  also  discharged if  excess water  is
 used to cool the sinter.   The  sintering operation   wastewater  sources
 are  depicted  ;in   the process flow  diagrams  (Figures III-l,  111-2 and
 •*• •*• •*•"~ -J / •         f
                                                  »

Eleven of the thirty-three  (the  confidential plant  is not included  in
 this  total)   sinter  plants   in the  United States  do not generate any
process wastewaters since dry  air pollution control equipment is   used
                                   205

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at  these  plants  (refer  to  Table  III-l).    One  plant  has no air
pollution control equipment and does not  generate  sintering,  process
wastewaters.   Dry  air  pollution control equipment includes cyclonic
dust collectors or, with newer operations, fabric type  dust  filters.
The  "dry"  plants  are  listed  in  Table III-l but are excluded from
further review since they do not generate process wastewaters.

Sinter production capacity ranges from  500  to  12,200  tons/day  for
"wet" plants and from 1,132 to 16,600 tons/day for "dry" plants (Table
III-3).   The  total  rated  capacity  of  all  plants  (excluding the
capacity of one plant which was claimed to be confidential) is 148,212
tons/day.   "Wet" plants comprise about 57% of the total capacity.

The pollutants generated in  sintering  operations  include  suspended
solids  and  oil  and  grease,  as well as toxic inorganic and organic
pollutants.   The  originally  promulgated    (1974)   regulation   for
sintering operations included effluent limitations for  total suspended
solids, oil and grease, and pH.    j
Data Collection Activities

For  this study,  the Agency  conducted  additional  sampling  and  gathered
detailed information from the  industry to   provide   an   expanded   data
base    to   develop  limitations.    The  primary   sources  of   industry
information  are  DCP   (basic   questionnaire)  responses.    The    DCP
requested   information   pertaining   to  production   processes,  process
water.usage,  process wastewater discharges,  and   wastewater  treatment
systems.    The  Agency   received DCP   responses   from  every sintering
operation.   These data  are presented in Table  III-l .

Detailed questionnaires (D-DCPs)  were  sent to  five  plants.  The D-DCPs
sought long-term  treatment facility effluent quality,  operating  cost,
and sintering process operating data.   The D-DCP  responses assisted in
verifying   cost   estimates,  and establishing retrofit costs.   Only two
plants provided  long-term analytical data  relating  to  the  previously
limited BPT pollutants.    No  data were  provided  by the industry for
toxic  metal and  toxic organic  pollutants.

The Agency  identified   34  steel  plants  with  sintering  operations.
Confidentiality   was   claimed   for   one  plant with regard to  all data
submitted.   These data  are not included in Table  III-l.   The  Agency
visited four plants during  the original guidelines survey.  The Agency
determined   that  data  for  three of these plants were not suitable for
use:  one did not supply requested cost  or  production  data;   another
operation    treated   sintering   wastewaters    in   combination  with
wastewaters from another process, thereby making treatment predictions
difficult;  and,  the third plant had problems with equipment during the
sampling survey and the sintering wastewater  could  not  be  sampled.
During  the  toxic • pollutant  survey,  the  Agency  conducted another
 sampling visit at one of these plants and also visited  two  additional
plants  to  increase  the data base and to monitor for  the presence of
 toxic pollutants.  The results of these sampling visits (Plants 0060F,
                                     206

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0112D, and 0432A) demonstrate that  significant  quantities  of  toxic
metal  pollutants are found in sintering wastewaters.  The Agency also
conducted  pilot  scale  wastewater  treatment  system   demonstration
studies  at  plant  0060.   Table  III-2  summarizes the data base for
sintering operations.

As with the originally promulgated effluent limitations and NSPS,  the
limitations  and  standards  are  established on a unit process basis.
Supporting this: approach is the observation that  all  plants  combine
their  various , sintering  process  wastewaters  for  treatment.  This
system provides; for the increased efficiencies of operation associated
with the common treatment of various unit process wastewaters.
                                   207

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                               TABLE III-3

                                SINTERING
                   RATED PRODUCTION CAPACITY (TONS/DAY)
Plants generating
wastewaters
 Dry Plants
PLANT CODE

   0060
   0060B
   0060F
   0112A
   0112B
   01120
   0112D
   0396A
   043 2A
   0448A
   049 2A
   0584C
   0584E
   0856F
   0856Q
   0864A
   0868A
   0920B
   0920F
   0946A
   0948C
    0112
    0384A
    0432C
    0584B
    0684B
    06841
    0856JI
    0856N
    0856T
    0860B*
    0860H
    0948A
PRODUCTION CAPACITY

    2,640
    2,400
    1,360
    12,200
    4,000
    2,683
    6,070
    3,312
    6,500
    3,850
    1,900
    3,800
    8,187
    7,200
    500
    2,910
    7,783
    1,000
    1,500
    540
    4,000

    84,335 SUBTOTAL

    6,145
    4,000
    2,500
    4,600
    Unk
    1,500
    15,000
    1,132
    5,000
    16,600
    5,000
    2,400

    63,877    SUBTOTAL

    148,212   TOTAL
 *:  Plant has been retrofitted with wet air pollution control systems.
                                      2-12

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213

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214

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215

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                         SINTERING SUBCATEGORY

                               SECTION IV

                           SUBCATEGORIZATION
 The basic steelmaking segment of the basic steel industry is comprised
 of  several separate and distinct processes.    The  Agency  found  that
 individual  processes,   products and wastewater characteristics affect
 industry subcategorization.    Based  upon  a  review  of  the  factors
 mentioned above,  the Agency  has established sintering as an individual
 subcategory.    Several   factors  were  evaluated  to  determine if the
 sintering  subcategory   requires  further  subdivision.    The   Agency
 concludes,  however,   that  further subdivision is not warranted.   The
 factors  reviewed  in reaching these conclusions are discussed below.

 Manufacturing  Process and Equipment

 Sintering is unique in  that  it is  the  only  process  in  which  iron
 bearing   fines ^such  as mill  scale  and flue dust from other steel
 operations)  are :mixed with other materials and combusted  to  form  an
 agglomerate.    The agglomerate, in turn,  is used as a raw .material for
 the ironmaking process.   Because no other  ironmaking  or  steelmaking
 process   is  similar,  the Agency determined that the establishment of a
 sintering subcategory is appropriate.

 Despite  the  various combinations of raw materials which are fed to the
 sintering operation,  the process operation does not vary significantly
 from plant to  plant.   The basic process includes raw material  mixing,
 ignition  and   combustion,   agglomeration  of  the sinter, cooling and
 screening.  The .Agency  determined that no further subdivision of  this
 subcategory  is  warranted  on  the  basis  of  manufacturing
 differences.

-Final Product
process
 Sintering  produces  only one final  product.    This  final   product  may
 vary    in   physical  and  chemical  makeup   among  plants,   but  these
 differences are |slight  and of  little importance to  subdivision.    The
 Agency   determined   that  differences  in final product do not warrant
 further subdivision of  the sintering subcategory.

 Raw Materials   ;
                i             .         '
 The raw materials used  in  the  sintering process consist of ores,   mill
 scale,   coke,  limestone,   slag   fines   and sludges (Table IV-1).   The
 availability of ithese materials  at each location  determines  the  raw
 materials   used jat  that, facility.   Although the composition of the raw
 materials  may  vary  from plant  to plant,  the Agency  found  that  these
 variations do  not significantly  affect  process wastewaters.   The  model
 treatment   systems   evaluated  by   the   Agency  provide  for effective
                                   217

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control  of  the  various  sintering  process  wastewater  pollutants.
Accordingly,  the  Agency  concluded  that  these  differences  do not
warrant further subdivision of this .subcategory.

Wastewater Characteristics

The wastewaters generated at  sintering  operations  result  primarily
from  the  scrubbing  of  the  process  gases and dusts.  Although the
nature of the wastewaters may vary as a result of their origin in  the
sintering  process,  similar  pollutants  are  found  in all sintering
wastewaters.  For example, oil and grease  and  suspended  solids  are
common  in  all  sintering  wastewaters,  as  are  cyanide,  fluoride,
sulfide, phenols, and various toxic ;metals.  Although these pollutants
may be found in  varying  levels,  the  range  of  concentrations  and
loadings are not so-large as to warrant further subdivision.  Multiple
sintering operation wastewater sources are combined at many plants for
treatment   (e.g.,  windbox,  discharge  end).   Based upon the factors
presented above, the Agency determined that further subdivision  based
upon wastewater characteristics is not warranted.

Wastewater Treatability

As  noted  for  BPT, a concern in the treatment of sintering operation
wastewaters is the removal of suspended solids, which in turn  results
in  a  reduction  in the levels of those pollutants which comprise the
suspended solids.  This reduction in suspended solids is  accomplished
by  using  sedimentation technology.  Except for one plant  (which dis-
charged to a blast furnace gas scrubbing recycle system),  all  plants
have  similar  wastewater  treatment  systems.  For treatment of toxic
pollutants at the BAT level, the Agency considered several  wastewater
treatment   technologies   including  filtration,  precipitation,  and
alkaline chlorination.  The Agency does not  believe  plant  to  plant
variations    in    wastewater   characteristics   affect   wastewater
treat: ability.   Accordingly,  the  Agency  determined   that   further
subdivision based upon wastewater treatability is not warranted.

Size and Age

The Agency considered the effect of size and age on the subdivision of
sintering  operations.   Its analysis of the impact of size and age on
such  elements  as  wastewater   generation,   discharge   flow   rate
(associated with the ability to recycle), and the ability and costs to
install treatment did not demonstrate a need for further subdivision.

The  question of further subdivision on the basis of age was addressed
by comparing plant age and discharge flow data.   Discharge  flow  was
used  as  an  indication of wastewater treatment capability, since the
wastewater  characteristics  and  treatability  are  similar  for  all
sintering  operations.   Figure  IV-1  is a plot of discharge flow vs.
plant age for all  plants,  while  Figure  IV-2  presents  a  plot  of
discharge  flow vs. plant age for only those plants with treatment and
recycle facilities.  The low discharge flows exhibited at some of  the,
oldest  plants   (representing  the  ability  to provide adequate basic
                                    21E

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treatment) indicates that further subdivision of this  subcategory  on
the  basis  of age is not appropriate.  In addition, pollution control
equipment can be; retrofitted to existing plants as demonstrated by the
plants noted on Table IV-2.  The industry did not  report  significant
retrofit  costs : for  either older or newer sintering operations.  For
the eleven plants (55% of the "wet"  sinter  -plants)  listed  on  this
table,  the. tim'e between the first year of production and the year of
major water pollution control equipment installation varies  from  six
years to thirty-three years.
                i
The  question  o'f  size  was evaluated by comparing the rated capacity
(size) of each plant with its discharge flow.  Figure IV-3 presents  a
plot  of  discharge, flow  vs. plant rated production capacity for all
plants, while Figure IV-4 presents a plot of discharge flow vs.  plant
rated production capacity for only those  plants  with  treatment  and
recycle facilities.  The distribution of the data meeting or exceeding
the  BPT  model -!' flow  indicates  that  plant size does not affect the
ability to  provide  wastewater , treatment.   The  points  are  widely
distributed from small to large plants.                         J
                i                •
Based  upon  the  above,  the  Agency  finds  that  both old and newer
production  facilities  generate  similar  raw  wastewater   pollutant
loadings;  that ! pollution  control  facilities  can  be and have been
retrofitted to  feoth  old  and  newer  production  facilities  without
substantial  retrofit  costs;  .that these pollution control facilities
can and are achieving the same effluent  quality;  and,  that  further
subcategorizatidn  or  further segmentation within this subcategory on
the basis of age or size is not appropriate.

Geographic Location

Most of the sinter plants are located in the East and  Midwest.   Only
one  plant  (which  has  recycle  facilities  installed) is located in
either an arid qr  semi-arid  region.   Most  plants  have  wastewater
recirculation  a!s an integral part of treatment.  These plants are not
restricted on the basis  of  geographic  location.   Accordingly,  the
Agency  concluded  that further subdivision on the basis of geographic
location is not warranted.         »

Process Water Usage

Process water usage varies from plant  to  plant  depending  primarily
upon  the  type ; and  number  of  "wet"  scrubbers  in  use.  However,
wastewater quality for all .operations is similar and  all  wastewaters
from  each  plant  are  combined  for  treatment.   In  addition,  low
discharge flows ifrom the sintering operations are achieved  by  plants
having  .both  high  and  low  applied  flow  rates.  Hence, the Agency
concluded that further subdivision  based  upon  process  water  usage
rates is not warranted.
                                   219

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                               TABLE IV-1

             RAW MATERIALS SUMMARY FOR SINTERING OPERATIONS
                         GENERATING WASTEWATERS	
                   (Percent of  total raw1 material feed)
                                                IRON SOURCES
PLANT
 NO.

0060
0060B
0060F
0112A
0112B
0112C
0112D
0396A
0432A
0448A
0492A
0584G
0584F
0856F
0856Q
0864A
0868A
0920B
0920F
0946A
0948C
FUEL
    (1)
  3.9
  2.2
  2.0
  4.9
  5.0
  4.6
  2.6
  4.3
  4.1
  5.0
  4.1
  7.0
  9.0
  6.0
  5.6
  6.2
  5.7
  13.2

  3.0
  3.9
FLUXES
      (2)
  22.0
  20.7
  15.5
  18.0
  20.0
  17.5
  15.6
  22.6
  28.7
  18.6
  16.9
  19.0
  32.5
  17.0

  11.8
  15.8
  24.9
  26.4

  35.7
                          ORES
   (3)
33.5
25.1
24.4
70.2
45.0
63.0
39,5
67.5
53,8
72.9
60.4
46,0
50,7
58*0
76,0
75.9
75,1
29.6
37^0
50*6
43,0
IRON BEARING
  MATERIALS

    40.6
    52.1
    58.0
    6.9
    30.0
    14.9
    42.3
    5.6
    13.4
    3.4
    18.6
    28.0
    7.8
    19,0
    18.5
    6.0
    3.4
    32.4
    36.7
    46.4
    17.5
                                                            (4)
ALL IRON
SOURCE: s
   .5
   .1
74.0
77.1
82.
77.
75.0
77.9
81.8
73.1
67.2
76.4
79.0
74.0
58.5"
77.0
94.4
82.0
78.5
61.9
73.6
97.0
60.4
 (1). Includes  coke  and  coke breeze.
 (2)  Includes  limestones, dolomite, sand, stone  fines, calcined fines, etc.
 (3)  Includes  iron  ore,  ore fines, pellet fines, taconite fines, etc.
 (4)  Includes  mill  scale, flue dust, metallic  fines, sludges, filter cakes,
     slags,  sinter,  etc.
                                     22(D

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               !                 TABLE  IV-2

              EXAMPLES OF PLANTS THAT HAVE DEMONSTRATED THE
          ABILITY TO RETROFIT WATER POLLUTION CONTROL EQUIPMENT
                           SINTERING SUBCATEGORY
  Plant
Reference
  Code

0060B
0060F
0112B
0112C
0448A
0548C
0584C
0864A
0868A
0920F
0946A
 Plant Age -
First Year of
  Production

   1958
   1957
   1950
   1948
   1943
   1959
   1959
   1944
   1941
   1944 ,
   1939
  Treatment Age -
Year of Installation
  Major Components

       1968
       1975
       1970
       1960
       1971
       1965
       1965
       1962
       1954
       1973
       1972
                                     221

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                       FIGUREIZ-I

               DISCHARGE FLOW vs. PLANT AGE

                        SINTERING

                        ALL  PLANTS
  8-
  8.
  5
  8.

  IO




  8.
is
—t o.
It ®
  to
UJ
o


<8

gg-
CO
  8.
  00
  8-

   1939
1944
1949
1954
1999
1964
1969
                                                 1974   1979
                        PLANT AGE
                           222

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  8
  00
  o
  o
  in
-
<
o
UJ
o
IT
O
CO
                           FIGURE  12-2
                  DISCHARGE FLOW vs. PLANT AGE
                             SINTERING


                      PLANTS THAT RECYCLE

                          — — X ...i —
                              X '"'
                                    	„ BPT Level
    1941
1946
1951
1956
1961
1966    1971
                                                      1976     1981
                             PLANT AGE
                               223

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                            FIGURE TJZ1-3

         DISCHARGE FLOW vs.  PLANT  RATED  PRODUCTION  CAPACITY

                             SINTERING

                           ALL PLANTS
   CO
   h-
   o
   o
   10
   CO
p

LJ
CD
o:
   0-
   o.
o
  o
  o.
  00
  o
  8
                                                 BPT Level
          —i—*-*	r~-	r5-2	1	

          2500    5000    7500    IOOOO    12500   15000    17500   200OO
T
                  PLANT RATED CAPACITY (TONS/DAY)
                                224

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                        FIGURE nr-4
   DISCHARGE  FLOW vs. PLANT  RATED  PRODUCTION  CAPACITY
                          SINTERING
            :       PLANTS THAT RECYCLE
  o
  o_
   ^
  o
  o
  in
< 2!
CD
u. o>

UJ
O
(T
< O
X O
O <°
CO
  o
  o
  to
                                                BPT Level
         X
        X
          2500
5OOO
7500
10000   12500   15000    17500   20000
                PLANT RATED CAPACITY (TONS/DAY)
                              225

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                        SINTERING SUBCATEGORY

                              SECTION V

              WATER USE AND WASTEWATER CHARACTERIZATION
Introduction                  .     .     ,

Process  water | usage  .is  a  significant  factor  in  determining the
pollutant  loads  and  in  estimating  the  cost  of  removing   those
pollutants  generated  by  sintering  operations.   The  importance of
carefully controlling process water usage  cannot  be  overemphasized.
The  Agency  used  data  from the sampling visits and DCPs to evaluate
process water use, pollutant discharges, total wastewater volumes, and
to identify existing control and treatment technologies.

Wastewater characterization is based upon  data  obtained  during  the
field  sampling  programs.  During the original guidelines survey, the
A'gency  investigated  the  levels  of  limited  pollutants   (suspended
solids, oil and grease and pH) in the process wastewaters.   During the
second  field  ;sampling  program,  the  Agency  again investigated the
levels of the previously limited pollutants and  performed   additional
monitoring for toxic inorganic and organic pollutants.

The   water   use  rates  discussed  below  pertain  only  to  process
wastewaters.   Noncontact  cooling  or  nonprocess  waters   are   not
included.  Process wastewaters are those waters which come into direct
contact  with  the  process,  product,  by-products, or  raw  materials.
Noncontact cooling waters are cooling waters  which  do  not directly
contact  the  processes,  products,  by-products,  or  raw   materials.
Nonprocess waters are those  waters  which  are  used  for ,  nonprocess
operations, e.g., utility and maintenance department requirements.

Description of Sinter Plant Wastewater Sources

As  noted  earlier, sintering process wastewaters result from dust and
gas. scrubbing equipment and from sinter cooling  and  quenching.   Some
newer  plants  are  equipped  with "dry" air pollution equipment while
many older plants are equipped with  "wet" systems.  Sinter   plant  gas
and  dust scrubbing equipment is generally separated  into two systems.
One of the sysjtems scrubs the fumes  and dusts from the hot sinter bed,
ignition furnace, and sinter bed wind boxes, while  the  other  system
controls  emissions  from the sinter crushers, sinter fines  conveyors,
raw material storage bins, and feeders.  As  can  be  noted   in  Table
II1-1,  however,  common  industry   practice is  to combine the various
wastewater.streams for  treatment.

Industry responses to the DCPs provided process  wastewater and treated
effluent flow  data.  In many  instances  the flow  rates were reported  as
measured values,  but in other instances the  flows  were reported   as
design  rates  or  rates  based  upon best engineering  judgment.  Where
                                    227

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available, plant visit or D-DCP  flpw data were  included  in  Table  Ill-l
in lieu of DCP data.

Raw process wastewater flows ranged from 417  1/kkg   (100  gallons/ton)
of  sintered  product  to 27,543  1/kkg  (6605  gallons/ton).   The lowest
flow, for sinter cooling water,  was observed  at  a plant with dry  air
pollution   equipment.    Other   plants   exhibited   similar  process
wastewater flows (e-.g., 106, 133  and   134  gal/ton).   Two of   these
plants have as many as four scrubbers.

Plant  effluent  flows  also varied oven a wide  range, i.e., 108  1/kkg
(26 gallons/ton) to  27,543  l/kkg;  (6605  gallons/ton).    The  lowest
effluent  flow  was  observed  at 1 a  plant   which  discharges  only a
thickener underflow.   In  this  system,  the thickener  overflow  is
completely  recycled.   The  wide  range in flows' can  be attributed to
several factors, but the number  of:scrubbers  and the   scrubber  design
and efficiency influence water usage rates.

One  method  of  conserving  water  and  reducing  the quantities  of
discharged  pollutants  is  the  recirculation   of  partially  treated
wastewaters.   Wastewater recirculation is currently practiced at more
than 12 sinter plants and is  a  major  component  of  the   BPT  model
treatment  system.    Although  wastewater  recirculation can result in
increased levels of certain pollutants  in  recycled  wastewaters,  the
significant  reduction  in  total discharge flow results in an overall
reduction in discharged pollutant loads.

Sintering  wastewaters   contain   large   quantities   of   suspended
parti-culate  matter  and oil and grease. , In  addition, toxic inorganic
and  organic  pollutants  and  fluoride  were   found   in   sintering
wastewaters  at  significant levels.  The concentration data presented
in Table V-l provide a measure of the pollutant  loads  contributed  by
the  process, thereby indicating which pollutants are  significant with
respect to sintering operations.  After reviewing the  raw   waste  and
treated effluent levels of pollutants and the degree of recycling, the
Agency  determined  that  the  effect  of  makeup water quality on the
discharge is negligible.    Accordingly,  the  Agency   has   decided  to
promulgate  effluent  limitations and standards  which  are based solely
on gross values.  Additional information  on  the  effect   of  make-up
water quality is presented at the end of Section VII.
                                   228

-------
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-------

-------
                        SINTERING SUBCATEGORY

                              SECTION VI

                        WASTEWATER POLLUTANTS
Introduction

A  review  of  pollutants  found in steel industry wastewaters and the
general strategy for selecting pollutants for which  limitations  have
been  promulgated are presented in Volume I.  The selection of limited
pollutants for the sintering subcategory was based upon  this  process
and on other factors pertaining to the sintering process and sintering
wastewaters.

Rationale, for Selection of_ Pollutants

The pollutants which the Agency found in sintering process wastewaters
reflect the variety of sintering process raw materials (e.g., iron and
steelmaking  flue dust, ores, mill scale, coke, limestone, slag fines,
and blast furnace thickener sludges).  Fines and dust from all sources
contribute to the  suspended  solids  loadings.   Oil  and  grease  is
present primarily as a result of the oils and greases carried into the
process  by  the scrap and mill scales.  Compounds detected in the oil
and grease analysis can also result from the incomplete combustion  of
coke   in   the;  sintering  process.   The  presence  of  fluoride  is
attributable to;the use of lime  fluxing  agents  and  slag  fines  in
sintering operations.

Particulates generated during the sintering process are transported in
the  process  gases,  and  are  removed  by scrubbing with water.  The
solids found in the  process  wastewaters  are  comprised  of  several
chemical constituents including various toxic pollutants.  The removal
of  the  suspended solids therefore results in the removal, to varying
degrees, of a  number  of  other  pollutants   (e.g.,  metals).   Other
pollutants  (i.e., chloride, sulfate) are present at substantial levels
in  the  process  wastewater-s,  but  are  not  included in the list of
selected pollutants since they are not toxic and difficult to  remove.
Treatment  for 'these  pollutants  is  not  commonly  practiced in any
industry.                                                       .

The presence of; toxic organic and inorganic pollutants is attributable
to the raw materials used in  the  sintering  process.   Although  the
Agency  detected  phthalate  compounds   (e.g., butyl benzyl phthalate,
di-n-butyl phthalate and di-n-octyl phthalate), it believes that their
presence is due to sampling and analytical procedures.  An  evaluation
of  process  conditions  and  operations  provided  no indication that
phthalates are generated directly as a result  of  sinter  production.
The  toxic  metkl pollutants found in the wastewaters originate in the
iron  bearing  materials  charged  to  the  sinter   machine.    These
                                    231

-------
pollutants  contaminate  the process wastewaters mainly as a result of
scrubbing the particulates from the process gases.

This study also considered the levels of the other  toxic  pollutants.
Initially,  all  pollutants  classified  as "known to be present" were
included in the list of pollutants'for  the  sintering  process.   The
above  classification  was  developed on the basis of responses to the
DCPs, and  analyses  completed  during  the  screening  phase  of  the
project.  Table VI-1 lists these pollutants.

The  Agency  calculated a net concentration (reflecting the level of a
pollutant contributed by the process) for each pollutant  detected  in
the  raw wastewaters at 0.010 mg/1 or greater.  Those pollutants found
at an average net concentration of ,less than 0.010 mg/1 were  excluded
from  further  consideration  in  the  selection process.  The list of
selected  pollutants  is  presented  in  Table  VI-2.   Although   net
concentrations  were  used  for  this analysis, the Agency established
effluent limitations on a gross basis only (see Section V and  Section
V JL j. / •                              •
                                   232

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              TABLE  VI-1

 TOXIC POLLUTANTS  KNOWN TO BE  PRESENT
	SINTERING OPERATIONS
       4    Benzene
       23   Chloroform
       39   Fluoranthene
       59   2,4-Dinitrophenol
       65   Phenol
       72   Benzo(a)ahthracene
       73   Benzo(a)pyrene
       76   Chrysene
       84   Pyrene
       85   Tetrachloroethylene
       115  Arsenic
       118  Cadmium
       119  Chromium
       120  Copper
       121  Cyanide
       122  Lead
       124  Nickel
       125  Selenium
       126  Silver
       127  Thallium
       128  Zinc
                  233

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                                                       1
     TABLE VI-2

 SELECTED POLLUTANTS
      SINTERING
     PH
     Ammonia (N)
     Fluoride
     Oil and Grease
     Phenols (4AAP)
   -  Total Suspended Solids
39   Fluoranthene
65   Phenoli
76   Chrysehe
84   Pyrene
118  Cadmium
119  Chromium
120  Copper
121  Cyanide (T)
122  Lead  i
124  Nickel'
128  Zinc  •
           234

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                         SINTERING *SUBCATEGORY

                              SECTION VII         %

                    CONTROL AND TREATMENT. TECHNOLOGY
 Introduction

 The  model   treatment  systems for BPT,  BAT,  BCT,  NSPS,  PSES,  and PSNS
 were   established  after  determining  current  wastewater   treatment
 practices   in  ;the  industry.   The various, treatment technologies were
 formulated  to  supplement  a  primary  level  of  treatment.    Effluent
 limitations, were established on the basis of effluent analytical data
 obtained during  plant visits,  D-DCP long-term analytical data,  and the
 demonstrated capabilities  of  certain technologies.    Treatment  system
 summaries,   schematics  and wastewater analytical  data for the visited
 plants are  presented in this  section.

'Control and Treatment Technology - Sintering  Operations

 Most   sintering   wastewater  treatment  facilities  .currently   provide
 treatment   for  suspended  solids,  although removal  of other  pollutants
 occurs incidentally.   A summary of treatment   practices   noted  during
 plant visits arid reported  in  the DCPs follo'ws.

 a.    Wastewaters from sixteen  of the 21   "wet"   sintering plants  are
      treated   in  central   treatment  facilities.    Five  plants  have
      separate  treatment  facilities  which  discharge   directly   to
      navigable^waters.   In almost  all  instances, the central treatment
      systems   ;receive  only   ironmaking  and  sintering  wastewaters.
      Treatment facilities  at  the five sintering plants  with  separate
      treatment <  systems are similar in design to the central treatment
      facilities.   An evaluation of  data  from   separate  and   central
      treatment ,  systems indicates  that  similar   flow  rates,  recycle
      rates,  and  effluent levels are achieved  with either system.    The
      treatment .  models  presented   herein   are   for separate treatment
      facilities', ' thus  overstating  treatment   plant   costs    where
      co-treatment   is  practiced.   Central  treatment tends to  decrease
      overall treatment costs.    Table   VII-1  presents  a summary  of
      pertinent  data  for   plants   discharging   to   central  treatment
      facilities.

 b.    Sedimentation is  the primary  wastewater treatment  technology
      applied   to  sintering operation  wastewaters.   Of the  21  "wet"
      sinter plants,  sixteen are equipped with thickeners or  clarifiers
    .and five  have settling lagoons.   At eighteen plants,  the   sludge
      removed   from  thickeners   is  pumped  to vacuum filters which are
      used to dewater  the sludge.   At  several  plants,   the  dewatered
      solids  are  returned to  the sintering  operation to recover iron
      values.   The  filtrate is returned to  the thickener   influent  and
      the  thickener   effluent   is  either discharged or recycled.   Five
                                   235

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     plants  discharge  treated  wastewaters  to  other  steel   plant
     operations for reuse.                        -..      •

c.   In order  to  enhance  solids  removal,  various  coagulant  aids
     (principally  polymeric flocqulants) are added to the wastewaters
     prior to settling.  These flo|cculants  (used at seventeen  plants)
     help  to  form  larger, more readily settleable particles.  Toxic
     inorganic  and  organic  pollutant  removal  is   incidental   to
     suspended solids removal.    1

d.   As mentioned above, five plants discharge treated wastewaters for
     reuse in other steel plant operations.  Wastewater  treatment  at;
     four  of  the  five  plants  ;is  provided  at  central  treatment
     facilities.  Also, treated effluent from four of the five  plants'
     is  reused  as  make-up  for blast furnace coolers and scrubbers.
     The effluent from one central treatment  facility  is  reused  at
     many  other operations.  In some of these systems, sinter process
     wastewater  pollutants  are  diluted,  rather  than   effectively
     treated.                                                          ;

e.   Recycle of treated process wastewaters  is  practiced  at  twelve
     plants.   Eight  of  these  plants  (five  of which have separate!
     treatment facilities) recycle treated  effluents at rates  varying
     from  30%  to  100%.   Three  plants  (one of which has a separate
     treatment  facility) -  recycle   both   untreated   and   treated!
     wastewaters  at  rates  varying  from  77% to 94%.  The remaining
     plant recycles only untreated wastewaters at a rate of 88%.   The
     basic   recycle   system   includes    sedimentation  with  vacuum
     filtration for sludge dewaterjing.  Flocculating agents  are  used!
     to enhance solids removal capabilities in some systems.

f.   Alkaline chlorination is used at two plants to  control  cyanide.
     In  both  instances,  sinter  plant  wastewaters are treated with
     blast furnace wastewaters in -central treatment systems.           '

g.   Filters are used at three plants for additional suspended  solids
     removal.   The sintering wastewaters are treated with ironmaking,
     steelmaking, or steel finishing wastewaters in .thse systems.

h.   One plant discharges the blowdown from a  treatment  and  recyclk
     system  to  a  publicly  owned  treatment  works  (POTW).  In this
     instance,  sintering  wastewaters  make  up  76%  of  the  volume
     discharged to the POTW.                               .            ;

Control and Treatment Technologies
Considered for Toxic Pollutant Removal

The  treatment  technologies  which  the  Agency  has  considered  for;
sintering wastewaters are described below.  BAT, NSPS, PSES, and  PSNS
levels of treatment are reviewed in detail  in subsequent sections.
                                   236

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 Filtration                        ,

 Filtration is generally used to further reduce the  discharge  of
 suspended^ solids.    However,  filtration  can  also  be  used to
 control those toxic  pollutants  which  are  entrained  with  the
 suspended;  solids.    Filtration  can  be  used  as the last major
 component;in a treatment system or to  provide  a  polished  feed
 stream  to  another  treatment  operation,  e.g.,  adsorption  on
 activated carbon.   Participate pollutant removal is  accomplished
 by  passing  the  wastewater  stream, either under pressure or bv
 gravity,  through a filter media.    The  filter  media,  generally
 S  '   a^173011^  coal  and/or  garnet,  permits  water  to pass
 through but prevents the  passage  of  much  of  the  particulate
 matter  suspended in the wastewater.   The filter media itself may
 be comprised of a single type and size of media,  various sizes of
 the same type of media,  or a mixed media which  contains  several
 types  and;sizes of  media.

 Lime Precipitation  and  Sedimentation

 Lime addition,  followed by  sedimentation,  is  used  to  further
 r^H??c f e  JSVeiS  °f.  t0xic metals-    This additional removal
 results from the formation of metal hydroxide precipitates  which
 are subsequently  removed  in inclined plate separators.   Inclined
 plate  separators are gravity sedimentation devices in   which  the
 effective,  settling  area   is  much larger than the area actually
 occupied  by this equipment.   This component has been demonstrated
 sub at   :industry/   in  Particular   at   Plant  0060F    in   this


 Alkaline  Ghlorination

 The Agency  considered alkaline chlorination for the treatment  of
 sintering   wastewaters   based  upon the  use of this technology at
 several sinter  plants  which   have  combined  and  blast   furnace
 wastewater   treatment  systems.   The primary  purpose  of  alkaline
 chlorination   is  to  reduce   the  levels   of   cyanide   in    the
 wastewaters.   It is  also effective for oxidizing  phenolics,  other
 toxic  organic pollutants,  and ammonia-N.

 Cyanide oxidation involves  two  basic  reactions:   the oxidation of
 cyanide   to  cyanate at a PH greater than  10,  immediately  followed
 by  the further  oxidation of the cyanate  to  carbon dioxide   and
 ?i^S!SS- +     S   .PH. °u  8'°-8-5-   Cyanogen   chloride  is   an
 intermediate product of the   oxidation of   cyanide to   cyanate.
 care  must-  be  taken to maintain wastewater  pH  greater than  10  in
 order to prevent the evolution of the  toxic  cyanogen chloride  gas
 and to insure rapid and complete cyanide oxidation.  It  must   be
 noted  that  chlorine  consumption  will   be   in  excess   of  that
predicted strictly on the basis of cyanide oxidation requirements
due to the; presence of other  oxidizable pollutants.  Chlorine  can
be added e;ither in the gaseous state,   through a   chlorinator,   or
as a liquid  (sodium hypochlorite).
                               237

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     Electrodes   which  measure  the  wastewater  oxidation-reduction
     potential (ORP)  can be used  to,  control  the  chlorine  feed  to
     insure  complete  cyanide destruction.   ORP is an electrochemical
     measurement,  expressed as positive or negative millivolts,   which
     can  be  used  to  determine  the  direction  and rate of various
     oxidation or  reduction reactions.  In this application,  the  ORP
     would   be   maintained  at  a  point  indicative  of  rapid  and
     essentially complete cyanide oxidation.

     The effectiveness of this technology is reviewed in  more  detail
     in   the   ironmaking  subcategory  report  with  sampled  plant,
     long-term,  and  pilot  plant  analytical  data.   Sinter   plant
     wastewaters   are   similar   in  composition  to  blast  furnace
     wastewaters in that both  contain  cyanide,  phenols,  and  toxic
     metals.  As a result, the application of alkaline chlorination to
     either  waste stream should produce similar effluent quality.  As
     noted  previously,  alkaline  chlorination  is  applied  to   the
     combined sinter and blast furnace wastewaters.

d.   Dechlorination

     To minimize the potential toxicity of wastewaters which have been
     chlorinated,  the Agency considered dechlorination as a  treatment
     method  to  reduce  total residual chlorine levels in  the treated
     discharge.  Dechlorination of  a  chlorinated  central  treatment
     plant  effluent,  which   includes sintering,  ironmaking and other
     process wastewaters, has  been  practiced  since  1977  at  Plant
     0584E.   This technology  is also widely practiced in the electric
     power  generation and electroplating  industries.  As  one  of  the
     final  treatment  steps,  dechlorination  is generally effective on
     wastewaters generated by  various sources.   The  Agency  believes
     that   it   is   equally  effective  when  applied   to sintering
     wastewaters.   Reducing   agents,  such   as  sulfites   or    sulfur
     dioxide,  are  added  to  the   chlorinated effluent  in sufficient
     quantities to react with  the ekcess  residual   chlorine,  thereby
     forming  nontoxic chlorides.   This technology  is added at the end
     of two-stage chlorination systems  to   minimize  excess  chlorine
     discharges.

e.   Sulfide  Precipitation

     The  addition of   sulfide   compounds   in  a  wastewater  treatment
     process  may  result   in   a  higher degree of  toxic metals removal
     than  can    be    achieved   with  typical    lime    flocculation,
     precipitation   or   sedimentation procedures..  Some  of the  metals
     which can  be effectively   precipitated  with   sulfide  are   zinc,
     copper,   nickel,   and  lead,   all of which  are found in  sintering
     wastewaters.  The increased  removal  efficiencies  are attributable
     to the  relative  solubilities:  of   metal  hydroxides  and   metal
     sulfides.    In   general,  the metal  sulfides  are less soluble than
     the  respective  metal  hydroxides.   It must be  noted,  however,  that
     an excess of   sulfide   in  a \ treated  effluent   may  result  in
     objectionable odor problems,  especially if the pH  is less  than  7.
                                    1230

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     One  method of controlling the excess feeding of sulfide involves
     the addition of a ferrous sulfide  slurry.   As  ferrous  sulfide
     will not readily dissociate in the waste stream, the free sulfide
     level  is- kept  well below objectionable limits.  However, since
     the affinities of the other metals for sulfide are  greater  than
     that  of  ;iron,  the  other metal sulfide precipitates are formed
     preferentially to iron sulfide.  Once  the  sulfide  requirements
     for  the  other  metal  precipitates  is satisfied, the remaining
     sulfide remains in the ferrous sulfide form and the  excess  iron
     from  the  ferrous  sulfide is precipitated as a hydroxide.  When
     used in conjunction with alkaline chlorination, sulfide  addition
     will also Consume excess chlorine following oxidation.

f.    Removal of Toxic Organic Pollutants with Activated Carbon

     Activatedjcarbon has been  used  in  many  applications  for  the
     removal of toxic organic pollutants from wastewater streams.  One
     of  the  more  frequent  uses  is  the  reduction  of COD and BOD
     concentrations in the effluent from sanitary  treatment  systems.
     Activated  carbon is also used to remove toxic organic pollutants
     from  wastewaters  of  various  industrial  operations  including
     petroleum | refining,  organic chemicals, and cokemaking.   Several
     toxic organic pollutants found in sintering wastewaters are  also
     found  in  cokemaking wastewaters.   This can be attributed to the
     use of coke in the sintering operation.

     Operational guidelines for the use of  activated  carbon   specify
     that  where  treatment  of  combined waste streams is involved or
     where the , water  to  be  processed  has  significant  turbidity,
     preliminary  treatment by clarification followed by filtration is
     required to achieve optimum performance.   The  use  of  chemical
     precipitation  and  diatomaceous .earth  filtration  is sometimes
     required to achieve the  clarity  required  for  the  removal  of
     pollutants,  present  at  low levels.   Particulates in wastewaters
     can adsorb organics and then release these organics after passage
     through the carbon bed.

     Laboratory tests performed on single  compound  systems  indicate
     that  processing  with  activated  carbon  will  achieve  residual
     levels on ^the order of 1  microgram per  liter  for  many   of  the
     organic  compounds  on the toxic pollutant list.   Compounds which
     respond well  to adsorption include chlorinated phenols,   phenols,
     nitrophenols,  and polynuclear aromatics.

     Control  of  pH  in  the  neutral  range is necessary to  minimize
     dissociation  of both acidic and basic organic  compounds.    As  a
     general  rule,  normal pH variations within the neutral  range will
     not  signijf icantly  affect  the  operation  of  activated  carbon
     columns.
     well  as
     systems
     high  pH.
  It  may  also  be noted that it may be impractical (as
extremely  expensive)  to  have  two  carbon  adsorption
in  series, one operating at a low pH and the other at a
                                   239

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     Data for existing industrial  wastewater  treatment  applications
     indicate   that   activated   carbon   adsorption  technology  is
     transferrable to the treatment of sintering  wastewaters.   Refer
     to Sections VII and X of the irpnmaking subcategory report and to
     Volume   I   for  details  regarding  the  capabilities  of  this
     technology.  For specific details pertaining, to sintering process
     wastewaters,  refer  to  the  pilot  study  and  full-scale  data
     presented   in   the  ironmaking  report.   Since  sintering  and
     ironmaking  wastewaters  are  similar  and  are   often   treated
     together, data for the treatment of ironmaking wastewaters can be
     applied  in the development of effluent limitations for sintering
     operations as well as for ironmaking operations.

g.   Vapor Compression Distillation

     Vapor compression distillation  is  the  process  by  which  zero
     discharge  can  be  achieved.  ; In this process the wastewater is
     evaporated, concentrating the constituents in the  wastewater  to
     slurry  consistency.   The  steam  distillate   is reeondensed and
     recycled back to the process.  jThe slurry discharge can be  dried
     in  a mechanical drier or allowed to crystallize in a small solar
     or steam-heated pond prior  to  final  disposal.   One  desirable
     feature  of  the  process   is  its relative freedom from scaling.
     Because of the unique design of the system, calcium  sulfate  and
     silicate   crystals  grow  in solution as opposed to depositing on
     heat  transfer  surfaces.   Economic  operation  of  the  systems
     requires a high calcium to  sodium ratio  (hard water).

Plant Visit Analytical Data

Table  VII-2  presents  the  definitions  for  the various control and
treatment technology and operating mode  abbreviations.   Table  VI1-3
presents  a  summary  of raw wastewater data  from sintering operations
visited during  both  the  original : guidelines  and  toxic  pollutant
surveys.   Table  VI1-4  presents  a1  summary  of  effluent  data from
sintering operations visited during both the  original  guidelines  and
toxic,  pollutant surveys.  Table VII-5 presents a summary of  long-term
effluent data provided in the D-DCP responses.

Plant Visits

The Agency sampled  the wastewaters from seven sintering plants.  Since
complete data could not be obtained from three of the  plants  visited
during the original guidelines survey, the  limited data were  of  little
value    in  determining  wastewater  treatment  performance   in  these
instances.  A brief description  of  each  of  the  visited  plants   is
presented  below.   Schematic  diagrams  of   the  respective  treatment
facilities are  presented at  the  end of this  section.

Plant H  (0432A)  ^ Figure VII-1      ;

Wastewaters  from the  sinter  plant  are mixed  with wastewaters  from  the
blast furnace and other  sources, and then treated for suspended  solids
                                   2!40

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removal  with  polymer  addition and sedimentation  in thickeners.  The
thickener overflow is discharged to  a  receiving   stream,  while  the
underflow is dewatered with vacuum filters.

Plant l_ (0291C) - Figure VII-2

Wastewaters  frdm  the  sinter  plant  are  mixed . .with  blast furnace
wastewaters and /treated in a thickener  to  remove  suspended  solids.
The  thickener  underflow  is dewatered with a vacuum filter, with the
filtrate .being returned to  the  thickener.   The   thickener  overflow
undergoes   further  treatment  including  alkaline  chlorination  and
filtration.  This effluent is discharged to  the  main  plant  pumping
station, mixed with make-up water and reused.

Plant J (0396A) - Figure VII-3                             ;  •  •

Sinter plant scrubber wastewaters are combined with the underflow from
the  blast  furnace treatment system thickener and  treated in a second
thickener.  Most of the overflow is recycled to the sinter  plant  gas
scrubber  system.   A  cooling  tower  in the recycle line reduces the
recycled  wastewater  temperature.   A  portion  of  the  overflow   is
discharged to a POTW.

Plant 016 (0112D) - Figure VII-4                    „

Wastewaters  from  the sinter mixing drum and sinter machine scrubbers
are combined in a moisture eliminator cone, which acts as  a  settling
chamber.   The supernatant of the .eliminator is recycled to the sinter
machine scrubbers, while the underflow  is  discharged  to  a  central
treatment system where further treatment is provided.

Plant 017 (0432A) - Figure VII-5

Wastewaters  from  six  sinter  process scrubbers are mixed with blast
furnace wastewaters and  treated  to  remove  suspended  solids  in  a
thickener.   The  thickener  overflow  is  further  treated by means  of
chlorination  and  sedimentation  in  a  second  thickener  and   then
discharged.

Plant 019 (0060F) - Figure VII-6
                        . ".         .     .       *
Sinter plant wastewaters are treated by adding lime to aid precipitate
formation.   The;  floe  is  settled  in  a  "Lamella"  thickener.  The
overflow is mixed  with  make-up  water  and  recycled  to  the  steam
hydro-scrubbers.   The  underflow  is  discharged   to  a blast furnace
clarifier for further treatment.-
               : !                     •

Effect of_ Make-up Water Quality         .

The Agency believes that where the mass loading of a limited pollutant
in the make-up water to a process is small  in  relation  to  the  raw
waste  loading  of that pollutant, the impact of make-up water quality
on wastewater treatment system performance is not significant, and,  in
                                   241

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many cases, is not measureable.  In !these instances,  the  Agency  has
determined  that 'the  respective  effluent  limitations and standards
should be developed and applied on a gross basis.

As shown in Table VII-6, the  effect  of  make-up  water  quality  for
sintering  "operations  is  not  significant when compared to raw waste
loadings for the limited pollutants.  Thus, the Agency  has  determined
the applicable effluent limitations'and standards  should be aPPlied on
a gross basis, except to the extent provided by 40 CFR  122.63  (h).
                                     24:

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                                        CO
                                        a

                                        
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                               TABLE VII-2

                  OPERATING MODES,  CONTROL AND TREATMENT
                   TECHNOLOGIES AND DISPOSAL METHODS

                                 Symbols
A.
 B.
Operating Modes

1.   OT

2.   Rt,s,n
                            Once-Through

                            Recycle, where t
                                        .   s
                                        •   n
type waste
stream recycled
% recycled


p
F
S
FC
BC
VS
FH

s
Process Wastewater
Flume Only
Flume and Sprays
Final Cooler
Barometric Cond.
Abs. Vent Scrub.
Fume Hood Scrub.
t:

% of
% of
% of
% of
% of
% of
% of
U
T
n
raw
raw
raw
FC
BC
VS
FH
= Unti
= Tre£

waste
waste
waste
flow
flow
flow
flow
•eated
ited

flow
flow
flow




         3.    REt,n
              BDn
                    Reuse, where  t =  type
                                  n =  % of raw waste flow

                               ,   t:   U = before  treatment
                                      T = after treatment
                                                     •
                    Slowdown, where n = discharge as % of
                                        raw waste flow
 Control Technology

 10.   DI             Deionization

 11.   SR

 12.   CC

 13.   DR

 Disposal Methods

 20.   H

 21.   DW
                             Spray/Fog Rinse

                             Countercurrent Rinse

                             Drag-out Recovery



                             Haul Off-Site

                             Deep Well injection
                                     244

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TABLE VII-2
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 2
        Disposal Methods (cont.)

        22.  Qt,d
        23.   EME

        24.   ES
              i
        25.   EVC

        Treatment Techno1ogy
 Coke Quenching,  where t = type
                       d = discharge as %
                           of makeup

                       t:   DW = Dirty Water
                           CW = Clean Water

 Evaporation,  Multiple Effect

 Evaporation on Slag

 Evaporation,  Vapor Compression Distillation
        30.   SC

        31.   E

        32.   Scr

        33.   OB

        34.   SjS

        35.   PSP
             1 r

        36.   SSP

        37.   EB

        38.   A;

        39.   AQ

        40.   GF

        41.   M

        42.   Nt
 Segregated Collection

 Equalization/Blending   ~~

 Screening

 Oil Collecting Baffle

 Surface Skimming  (oil, etc.)

 Primary Scale Pit

 Secondary Scale Pit

 Emulsion Breaking

 Acidification

 Air Oxidation

 Gas Flotation

Mixing

Neutralization, where t = type
                                                 t:  L = Lime
                                                     C = Caustic
                                                     A = Acid
                                                     W = Wastes
                                                     0 = Other, footnote
                                     245

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TABLE VII-2
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS     ;
PAGE 3        	       :
D.
Treatment Technology (cont.)
        43.  FLt
        44.  CY

        44a. DT

        45.  CL

        46.  T

        47.  TP

        48.  SLn


        49.  BL

        50.  VF


        51.  Ft,m,h
                              I
                    Flocculatibn, where t = type
                              p
                                        t:  L = Lime
                              :              A = Alum
                              I              P - Polymer
                                            M = Magnetic
                              i              0 = Other, footnote
                              !                  •         '    '
                    Cyclone/Centrifuge/Classifier

                    Drag Tank
                              r
                    Clarifier

                    Thickener

                    Tube/Plate Settler

                    Settling Lagoon, where n = days of retention
                                               time

                    Bottom Liner

                    Vacuum Filtration  (of e.g., CL, T, or TP
                                       underflows)

                    Filtration, where  t = type
                              :         m = media
                                       h = head

                          m   i             h
              D = Deep  Bed
              F = Flat  Bed
                       S
                       0
Sand
Otner,
footnote
G = Gravity
P = Pressure
         52.   CLt
         53.   CO
                    Chlorination, where  t =  type
                              i
                              [
                                         t:   A = Alkaline
                              I               B = Breakpoint

                    Chemical Oxidation  (other than CLA or CLB)
                                     246

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TABLE VII-2
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 4
D.
Treatment Technology (cont.)
        54.  BOt
        55.  CR

        56.  DP

        57.  ASt
        58.   APt
        59.   DSt
        60.

        61.

        62.

        63.
     CT

     AR

     AU

     ACt
        64.   IX

        65.   RO
                    Biological Oxidation, where t 7= type
                                                        t:  An = Activated Sludge
                                                            n  = No. of Stages
                                                            T  = Trickling Filter
                                                            B  = Biodisc
                                                            0  = Other, footnote
                    Chemical Reduction (e.g., chromium)

                    Dephenolizer

                    Ammonia Stripping, where t = type

                                             t:  F = Free
                                                 L = Lime
                                                 C = Caustic
                    Ammonia Product,  where t

                                           t
                    Desulfurization,  where t

                                           t:
                            type

                            S = Sulfate
                            N = nitric Acid
                            A = Anhydrous
                            P = Phosphate
                            H = Hydroxide
                            0 = Other, footnote

                            type

                            Q = Qualification
                            N = Nonqualifying
Cooling Tower

Acid Regeneration

Acid Recovery and Reuse

Activated Carbon, where t = type
                                                    t:   P = Powdered
                                                        G = Granular
                    Ion Exchange

                    Reverse Osmosis
                                    247

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TABLE VII-2
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 5                     	
D.
Treatment Technology (cont.)
        66.
        67.  AA1

        68.  OZ

        69.  UV
        70.  CNTt.n
                    Distillation

                    Activated Alumina

                    Ozonation

                    Ultraviolet Radiation

                    Central Treatment, where t = type
                                                     n = process flow as
                                                         % of total flow

                                                         1 =» Same Subcats.
                                                         2 = Similar Subcats.
                                                         3 = Synergistic Subcats.
                                                         4 = Cooling Water
                                                         5 = Incompatible Subcats,
        71.  On
                    Other, where n = Footnote number
        72.  SB
                    Settling Basin
        73.  AE
                    Aeration
        74.  PS
                    Precipitation With Sulfide
                                      248 •-

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                        SINTERING SUBCATEGORY

                             SECTION VIII

             COST, ENERGY, AND NON-WATER QUALITY IMPACTS
introduction

This  section  presents  the model treatment systems and industry-wide
costs for th.eiinodel treatment systems described in Sections IX through
XIII.  The analysis presented  in  this  section  includes  the  costs
associated  with  the  application  of the various technologies, and a
consideration of energy requirements  and  non-water  quality  impacts
(i.e.,  solid  waste  generation rates, air pollution impacts, and the
consumptive use of water).

Actual Costs Incurred by the Plants
Sampled or Solicited for This Study

Water pollution control costs supplied by the industry  for  sintering
operations  surveyed  during this study or included in D-DCP responses
are presented;in Table VIII-1.  These costs have been equated to  July
1978  dollars:  from the actual cost and year(s) of expenditure(s) data
supplied by each of these plants.

The Agency compared the capital cost data reported for several  plants
to  its capital cost estimates.  This comparison was made to determine
whether the Agency's estimated treatment model costs are sufficient to
cover the industry's-actual costs, including site-specific  and  other
incidental  costs.   Following  is  a tabulation of the actual capital
costs reported by  the  industry  (refer  to  Table  VIII-1)  and  EPA
estimated costs factored from the model cost:
Plant No,

0060
0396A
0856F
0864A
0920F

TOTAL

01 12A
Actual Cost ($)

    733,550
    832,000
    511,020
  1 ,731,048
  2,626,000
  6,433,818

  1,206,430
Estimated Cost ($)

 1,808,700
 3,134,300
 2,248,800
 1 ,334,300
 1 ,987,900
10,533,100

 6,991,100
The above cost data are for facilities  in-place  as of  January  1,  1978.
The  large difference between the actual and  estimated costs for  plant
0112A  is due to substantial differences  in   production  capacity  and
flow   between!  this plant and the treatment model.  On this basis,  the
costs  for Plant 0112A were not  included  in the totals.    While actual
                                   259

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costs  were  also  reported  for  Plant  0432A,  which  has  a central
treatment system  for  blast  furnajce  and  sintering  wastewaters,  a
determination  of  those  costs  attributable  to sintering wastewater
treatment could not be made because the sinter plant flow  is small  in
relation to the total central treatment system flow.

Referring to the costs for the remaining five plants, actual costs for
two  of  the  plants are greater than the estimated costs  and three of
the estimated costs are  higher.   The  most  noteworthy   observation,
however,  is  the  comparison of the total costs, as this  more closely
reflects on the appropriateness  of  using  model  costs   to  estimate
subcategory-wide costs.  As the reported costs are about 34% less than
the Agency's estimated costs, the estimated costs compare  favorably in
two  ways.   First,  the  Agency's total cost estimate is  sufficiently
generous to account for the various site-specific and other- incidental
costs associated with  industry's  compliance  with  the   limitations.
Second,  the  Agency's total cost estimate is not excessively generous
and thus provides a fair indication of the cost of  treatment  to  the
industry.                          >

Control and Treatment Technologies ;(C&TT)
Recommended for Use in the Sintering Subcate'qory

The  components  of  the  BPT  and  BAT  model  treatment  systems are
presented in Table VIII-2.  It should be  noted  that  the  regulation
does  not  require  the installation of the model treatment system, as
any treatment arrangement which achieves the effluent limitations  and
standards  is  adequate.  Table VIII-2 presents information pertaining
to the following items.

1.   Description
2.   Implementation time           |      .
3.   Land requirements

Cost, Energy, and Non-Water Quality Impacts

Introduction                       '

Compliance with the BPT and BAT limitations and the. NSPS,  PSES,  and
PSNS   will  require  additional  expenditures  (both  investment  and
operating) and additional energy consumption.  This section  addresses
these  requirements and the air pollution, water consumption and solid
waste  disposal  impacts  associated  with   each   treatment   system
considered.  Costs and energy requirements were estimated  on the basis
of  the  alternative treatment models developed in Sections IX through
XIII of this report.  Figure VIII-V illustrates the BPT and BAT, NSPS,
PSES, and PSNS alternative treatment models.
                                   .260

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Estimated Costs1for the Installation
of Pollution Control Technologies

A.   Costs Required to Achieve the BPT Limitations

     As a first step in estimating the costs of each treatment  model,
     the  Agency  developed  a  model system upon which cost estimates
     were to be;based.  The model size  (tons/day)  and  applied  flow
     rates  were  developed  on  the  basis  of the average production
     capacity and average applied flow rate for.  all  "wet"  sintering
     operations,   respectively.   Reference  is made to Section IX for
     identification of the BPT model treatment system.   Table  VIII-3
     presents  the model treatment component capital and annual costs.
     The Agency has calculated costs for facilities in-place  at  each
     "wet"  sintering  operation,  and  has estimated the costs of the
     model system components required to achieve the BPT  limitations.
     On  the  basis of the cost comparison provided previously in this
     section,  the  Agency  believes  that  its  cost  estimates   are
     sufficient to cover site-specific and other retrofit costs.

     The  capital  requirements for achieving the BPT limitations were
     determined;by  applying  the  model  treatment  component  costs,
     adjusted for size, to each "wet" sintering operation.  Based upon
     these  data,  the  Agency  estimates  that  as  of  July  1, 1981
     approximately 5.1 million dollars remains to  be  spent  for  BPT
     facilities1.    The  associated annual cost of operation of BPT for
     sintering operations is estimated to be 2.2 million dollars.

B.   Costs Required to Achieve the BAT Limitations.

     Reference is made to Section X for  a  description  of  the  five
     alternative  treatment models considered and for the selection of
     the treatment model upon which the  BAT  limitations  are  based.
     The additional investment and annual expenditures for each of the
     BAT  alternative  treatment models are presented in Table VIII-4.
     The BAT costs for each "wet" sintering operation were  determined
     by  adjusting  the model costs for each required component by the
     actual size of the plants.  The subcategory-wide  costs  are  the
     sums  of  the  costs  for  each of the sintering of plants in the
     industry. [ The subcategory costs (July 1, 1978 dollars) for  each
     of the BAT( alternatives are as follows:
   BAT
Alternative

    1
    2
    3
    4
    5
    Investment Costs ($)
In-Place

  509,400
1,196,200
1,370,000
1 ,879,400
        0
                     Annual Costs ($)
Required

 5,512,600
 3,784,200
 8,963,300
45,977,600
74,799,800
In-Place

 52,400
138,500
170,400
222,800
      0
 Required

   742,300
   503,700
 2,120,800
 6,924,200
15,395,000
                                   261

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C.   Costs Required to Achieve the BCT Limitations
                                     t
     BCT  has  been  reserved  at  this  time,  since  the  BCT   cost
     methodology  was  remanded  by  the  Fourth Circuit Court.  A new
     methodology is currently under development in the Agency.

D.   Costs Required to Achieve NSPS  ;

     The Agency considered five treatment alternatives as  model  NSPS
     treatment systems.  The NSPS treatment systems are similar to the
     BPT/BAT  treatment  systems,  however,  the  model  size has been
     increased in recognition of theitrend toward  larger  new  source
     sintering  operations.   The  NSPS model treatment system size is
     based upon the average production capacity  of  those  facilities
     which:began operation in the last decade.  The capital and annual
     costs for the NSPS alternative treatment systems are presented in
     Table  VIII-5.   Refer  to  Section  XII  for  discussions of the
     treatment models and the selection of the model  upon  which  the
     NSPS  are based.  Since this study did not include projections of
     industry capacity additions, industry-wide new source  costs  are
     not presented here.

E.   Costs Required to Achieve PSES and PSNS

     Pretreatment standards apply to those existing  and  new  sources
     which  currently  or may discharge wastewaters to POTWs.  The six
     alternative pretreatment systems  are  similar -to  the  BPT  and
    falternative  BAT  model  treatment  systems.   The model size for
    'pretreatment standards for existing sources  (PSES) is  the  same
     as that of the BPT and BAT.treatment models, while the model size
     for  pretreatment standards for!new sources (PSNS) is the same as
     that of the NSPS treatment models.  Reference is made to  Section
     XIII :for identification of the model PSES/PSNS treatment systems
     and for selection of the model system upon  which  the  PSES  and
     PSNS  are  based.   PSES model costs are identical to the BPT and
     the BPT  plus  respective  BAT  alternative  model  costs  (Table
     VIII-4).   The PSNS model treatment component costs are identical
     to the NSPS model treatment costs presented in Table VIII-5.  The
     Agency estimates that 0.36 million dollars remains  to  be  spent
     for  PSES  facilities and that PSES annual costs of operation are
     1.33 million dollars.

Energy Impacts

Moderate amounts of energy will be required for the BPT model and BAT,
NSPS,  PSES,  and PSNS alternative treatment systems for  the  sintering
subcategory.   The  major  energy expenditures occur at BPT, while the
selected  BAT  model  treatment  system  requires   relatively   minor
additional  energy  expenditures.  This relationship reflects the high
recycle rate in the BPT model treatment system.   Energy  requirements
for PSES will approximate the corresponding BPT and BAT systems, while
the requirements for NSPS and PSNS wjlll be slightly greater than those
for the corresponding BPT and BAT system.
                                   262

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B,
Energy Impacts at BPT

The Agency estimated the energy requirements for this subcategory
based upon the assumption that  all  "wet"  sintering  operations
will  install  treatment  systems  similar  to  that of the model
treatment system with flows similar to that  of  the  model.   On
this  basis,  the energy requirement for BPT for all active "wet"
sintering  operations  is  40.2   million   kilowatt   hours   of
electricity  per  year.   This estimate represents about 0.07% of
the 57 billion kilowatt hours of electricity used  by  the  steel
industry iri 1978.

Energy Impacts at BAT

The  estimated  energy  requirements  for  the  BAT   alternative
treatment systems are based upon the same assumptions noted above
for  BPT.   The estimated energy requirements at each alternative
treatment level for all active "wet"  sintering  operations,  and
the relationship to 1978 industry power consumption, follows:
                :  BAT
               Alternative

                  1
                ;  2
                  3
                ;  4
                  5
kwh per
Year
2.28
1 .20
4.26
11.46
239. 6
million
million
million
million
million
                                            % of Industry
                                                Usage

                                                 0.004
                                                 0.002
                                                 0.007
                                                 0.020
                                                 0.42
     The Agency considers the requirements of the selected alternative
     (No.l)  to ;' be justified in light of the total industry usage and
     the effluent reduction benefits obtained.
     Energy Impacts at NSPS and Pretreatment

     The  estimated  PSES  energy  requirement
     treatment  '• level,  and  the  relationship
     power consumption, are as follows:
                                           at  each   alternative
                                           to the  industry's  1978
          Model

          PSES-1
          PSES-2
          PSES-3
          PSES-4
          PSES-5
          PSES-6
                      kwh/Year
2
2
2
2
3
18
.48
.64
.56
.72
.20
.46
mill
mill
mill
mill
mill
mill
ion
ion
ion
ion
ion
ion
% of Industry Usage

  0.0044
  0.0046
  0.0045
  0.0048
  0.00.56
  0.032
     Following are the estimated model energy  requirements   for   each
     NSPS  and  rPSNS  alternative  treatment system.  Estimates of the
     total energy impact of NSPS and  PSNS  are   not  included,   since
     projections  of  capacity  additions were not  included  as part of
     this study.
                                    263

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               Model

               PSNS-1
               PSNS-2
               PSNS-3
               PSNS-4
               PSNS-5
               PSNS-6
               NSPS-1
               NSPS-2
               NSPS-3
               NSPS-4
               NSPS-5
   kwh/Year
 4.77
 5.00
 4.8.8
 5. 10
 5.65
30.90
 5.06
 4.95
 5. 16
 5.72
30.90
million
million
million
million
million
million
million
million
million
million
million
     The estimated energy requirements for the  model  NSPS  and  PSNS
     alternative  treatment systems are greater than the corresponding
     BPT and BAT alternative totals because of model size differences.
                                    i
Non-Water Quality Impacts           |

In general, the Agency has concluded that  non-water  quality  impacts
associated with the model treatment technologies will be minimal.  The
impacts  of these technologies on air pollution, solid waste disposal,
and water consumption are presented ;below.

A.   Air Pollution

     The use of alkaline chlorination in conjunction with BAT and NSPS
     Alternatives 3 and 4, (PSES/PSNS alternatives 4 and 5) may result
     in the localized atmospheric  discharge  of  chlorine.   However,
     since the chlorine is added directly to the wastewater and reacts
     rapidly  with the constituents Jin the wastewater, only negligible
     amounts would be  emitted  to  !the  atmosphere.   In  these  same
     alternatives,  proper  operating  practices  and procedures would
     greatly reduce or  eliminate  potential  air  pollution  problems
     associated  with  the  use of dechlorination agents (e.g., sulfur
     dioxide).

     In addition to the above atmospheric discharges, regeneration  of
     spent activated carbon from BAT and NSPS Alternative 4 (PSES/PSNS
     Alternative  5)  may  also result in the atmospheric discharge of
     various pollutants.  However, the regeneration  temperatures  are
     sufficiently high to oxidize most organic pollutants.

     In  view  of these observations;, the Agency does not consider the
     impacts of air pollution to be isignificant.

B.   Solid Waste Disposal

     The  BPT  model  treatment  system  will   generate   significant
     quantities   of   solid   wastes  which  require  disposal.   BAT
     alternatives are minimal and are included  with  those  for  BPT.
     The  Agency  estimates  that  compliance  with  the  BPT  and BAT
                                    264

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     limitations will  result in the generation of 2,655,000  tons/year
     of  solid  wastes.    BAT accounts for less than 1% of this total.
     The solid wastes  generated at PSES amount to 165,940 tons/year.

     As with BPT and BAT,  the incremental solid waste generation rates
     for PSES/PSNS alternatives 2-6  and  NSPS  alternatives  2-5  are
     minimal  over  those  of  the respective first alternatives.  The
     solid waste generation rate is 290,400 tons/year for the PSNS and
     NSPS treatment models.

C.   Water Consumption

     Evaporative cooling is not included .as a treatment step  in  this
     subcategory,  and  those  treatment  steps which are included are
     essentially not water consumptive.  As a  result,  there  are  no
     impacts  due to water consumption af the BPT, BAT, NSPS, PSES and
     PSNS levels of treatment.

Summary of  Impacts

In summary, the Agency concludes that  the  pollutant   load  reduction
benefits  described  below  for the sintering subcategory outweigh the
adverse energy and non-water  quality  environmental  impacts:

                          DIRECT DISCHARGERS
               '  Pollutant  Loadings  (tons/year)
      Flow  (MGD)
      Ammonia(N)
      Cyanide(T)
      Fluoride
      Oil and Grease
      Phenols(4AAP)
      TSS
      Total Toxic Metals
      Total Toxic Organics*
   Raw Waste

     93.4
    853.8
     28.5
    853.8
 34,153.3
     28.5
868,064.2
    298.8
     17.1
                                           BPT
  7.2
 65.8
  2.2
274.1
 76.8
  2.2
427.6
 14.0
 1.3
 BAT

  7.2
 65.8
  2.2
219.3
 38.4
  2.2
109.7
  4.8
 1 .3
      * Toxic organics does not include the individual
        phenolic compounds.
                                     265

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                     INDIRECT (POTW) DISCHARGERS
                    Pollutant Loadings (tons/year)
                                  Raw Waste
     Flow(MGD)
     'Ammonia(N)
     Cyanide(T)
     Fluoride
     Oil and Grease
     Phenols(4AAP)
     TSS
     Total Toxic Metals
     Total Toxic Organics*




2,

54,

5
53
1
53
134
1
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.8
.4
.8
.4
.6
.8
.0
.7
1 . 1
PSES

 0.5
 4.4
 0. 1
14.6
 2.6
 0. 1
 7.3
 0.3
 0. 1
     * Toxic organics does not include the individual
       phenolic compounds.

The  Agency  also  concludes  that  the  effluent  reduction  benefits
associated  with  compliance  with  new  source standards (NSPS, PSNS)
outweigh  the  adverse  energy  and  non-water  quality  environmental
impacts.
                                   266

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                                       TABLE  VIII-2

                             CONTROL AND TREATMENT  TECHNOLOGIES
                                   SINTERING SUBCATEGORY
C&TT
 B
 H
                          Description
 THICKENER - Provides  suspended  solids
 removal as a result of  sedimentation.
 Free oils and greases are removed by skim-
 ming.  This step  also achieves  significant
 reductions in the levels and  loads  of  those
 metals which'are  in the particulate form.

 FLOCCULATION WITH POLYMER - This step  enhan-
 hances suspended  solids and particulate  pollu-
 tant removal performance in Step A.

 VACUUM FILTER - Vacuum  filters  are  used  to
 dewater the sludges removed from the
 sedimentation steps."  The filtrate  is  re-
 turned to the treatment system  influent.

 RECYCLE - Ninety-two  percent  of the thick-
 ener effluent is  returned to  the process.
 This serves  to reduce the pollutant load
» discharged from the process.

 NEUTRALIZATION WITH ACID - The  pH of  the BPT
 treatment system  effluent is  monitored and
 adjusted as necessary to assure that  the
 treated effluent  pH is  within the neutral
 range.                            :.

 PRESSURE FILTRATION - Filters provide  addi-
 tional  suspended  solids and particulate
 pollutant removal.

 NEUTRALIZATION WITH ACID - This is  a  BPT
 treatment  system  model  C&TT  step which is
 relocated  for use in  BAT Alternative  Nos.
 1 and  2..                         \

 FLOCCULATION WITH LIME  - Lime is  added in
 order  to provide  additional  toxic ^metals
 removal.                          '
Implementation
 Time (months)

   15 to 18
                                                              15 to 18
                                                               12 to  14
                                                              8  to  10
    Land
Usage (ft )
           I
20,000
                                                                             625
                  20,000
                  625
                  625
                                                               15  to  18
                  625
                                                                  12
                  625
                                       268.'

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TABLE VII1-2
CONTROL AND TREATMENT TECHNOLOGIES
SINTERING SUBCATEGORY
PAGE 2
C&TT
Step
 K
 M
 N
                Description
INCLINED PLATE SEPARATOR - This component pro-
vides additional suspended solids and particu-
late pollutant removal.

TWO-STAGE CHLORINATION - This C&TT is pro-
vided cyanide destruction and to oxidize
phenols and ammonia.  The basic pro-cesses
include:  lime addition; first stage chlorine
addition; first stage reaction period; acid
addition; second stage chlorine addition; and
second stage reaction period.

SULFUR DIOXIDE ADDITION - The reducing agent
sulfur dioxide is added to the Step J efflu-
ent in order to reduce essentially all resid-'
ual chlorine resulting from Step J.

ACTIVATED CARBON ADSORPTION - Prior to dis-
charge, the treated wastewaters (the filter-
effluent) in BAT Alternative No. 4 are
passed through a column of granular activated
carbon in order to remove residual levels of
toxic organic pollutants.  This removal is
achieved by adsorption on the activated car-
bon.      ;

EVAPORATION - The effluent from the BPT
treatment system model is delivered to a
vapor decompression evaporation system.
This system produces a distillate quality
effluent and crystalline solids.

RECYCLE - The effluent of Step M is returned
to the propess as a makeup water supply.
Imp 1 ement a t i on
 Time (months)

   10 to 12
                                                              12 to 15
    Land
Usage (ft2)

245



2500
   8 to 10
                                                              15 to 18
625
                  625
   18 to 20
1000
   12 to 14
625
                                         269

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                        SINTERING SUBCATEGORY

                              SECTION IX

        EFFLUENT [QUALITY ATTAINABLE THROUGH THE APPLICATION OF  '
     THE BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE
The  Agency  has promulgated effluent limitations for Best Practicable
Control Technology Currently  Available  (BPT)  different  than  those
originally  promulgated in June 19741 for sintering operations.  Based
upon the changes in  the  model  treatment  system  flow  rate,  these
limitations  are also less stringent than those proposed on January 7,
1981 (46 FR 1858).  The limitations have been adjusted to  accommodate
all sintering wastewater sources.   The limitations promulgated in 1974
did  not  take into account wastewaters from raw material handling air
pollution control systems.  As the  June  1974  development  document2
described  the  basic methods used in developing the previous effluent
limitations, the intent of this section is to  provide  substantiation
of  the BPT effluent limitations.   A review of the treatment processes
and effluent limitations associated  with  the  sintering  subcategory
follows.

Identification of BPT

The  Agency  used  the original 1974 BPT model treatment system as the
model treatment system ,for the BPT  limitations,  (See  Figure  IX-1).
Suspended  solids  are  removed  from  process  wastewaters by gravity
sedimentation in a thickener.  A polymeric flocculant is added to  the
thickener  influent  to optimize the removal of suspended solids.  The
thickener underflow is dewatered in a vacuum filter, and the  filtrate
returned  to the thickener inlet.   About 92% of the thickener overflow
is returned to the sintering  operation.   The  pH  of  the  treatment
system  blowdown,  which  is  typically  alkaline,  is adjusted to the
neutral pH range with acid.  Oils and greases are removed  by  surface
skimming  in  the  thickener and also by entrainment within the solids
which settle in the thickener.

As  noted  previously,  the  BPT  limitations  do  not   require   the
installation  of  the  model  treatment  system.  Any treatment system
which achieves compliance with the BPT limitations is appropriate.
JFederal Register; Friday,  June  28,  1974;  Part  II,  Environmental
Protection Agency; Iron and Steel Manufacturing Point Source Category;
Effluent Guidelines and Standards; Pages 24114-24133.
2EPA 440/1-74-024-a, Development  Document  for  Effluent  Limitations
Guidelines  and  'New Source Performance Standards for the Steel Making
Segment of the Iron and Steel Manufacturing Point Source Category.
                                    275

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The BPT limitations are based upon ;the  same  effluent  concentrations
used  in  developing  the  originally  promulgated limitations and the
limitations proposed on January 7,  1981.   These  concentrations  are
well  demonstrated  as  shown  by the data in Table A-6,of Appendix A,
Volume I.  However, information received  during  the  comment  period
indicates  the  model effluent flow should be increased from 417 1/kkg
(TOO gal/ton) to 499 1/kkg (120 gal/ton).  As the model effluent  flow
has  been  increased,  the  effluent  limitations  were also increased
proportionately.  The BPT effluent limitations are presented below:

                                   •   kg/kkg of Product
                                   '(lb/1000 lb of Product)	
                              Daily Maximum
                               Limitations
              30-Day Average
                 Limitations
Total Suspended Solids
Oil and Grease
pH (Units)
0.0751
0.0150
0.0250
0.00501
           6.0 to 9.0
Rationale for BPT                  1

Treatment System
                                   r
As noted in Section VII, the components of   the  BPT  model   treatment
system are presently  in use at most sintering operations.
                                   i
Model Discharge Flow               !
                                   i              •
Table IX-1 presents a summary of  trie  flow,  recycle  rate,  and  operating
data for this subcategory.  The original model effluent  flow  was  based
upon data from one sintering operation which generates wastewater from
only  the  discharge  end  (sinter cooling,  crushing,  and screening)  of
the  process.   However,   since   wastewater discharges   originate  at
several  points in the sintering  operation  (refer to  Section  III),  the
Agency increased the  model effluent flow to accomodate all  wastewater
sources.  The model flow rate of  120  gal/ton represents  the average of
those  plants  (identified  by asterisks in Table  IX-1) which practice a
high degree of wastewater  recycle from the  machine  end  (wind  box,  raw
mater-ial  transfer,   etc.).   Plants'  with   recycle  rates equal  to or
greater than 88% were used in this analysis.    The  Agency   considers
plants  with   these recycle rates representative of the  best  plants in
this subcategory.  The plants used to develop the model  flow  rates are
representative of other sintering operations and  include wastewaters
from   the  wind  box and other sources.  Plant  0060F,   at  which
wastewaters are recycled and the  lowest discharge   rate   is   achieved,
was  not  included  in  the  development  of the model flow rate.  The
scrubber system at  this   plant   uses steam and   is different   than
scrubbers  commonly   used  at sintering operations.  The data in  Table
IX-1 demonstrate that the  model   effluent   flow  of   120 gal/ton  is
achieved  at   several plants including those that  recycle wastewaters
from only the  discharge end or  from both ends of the   operation.    The
                                   ; 276

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Agency  believes   that   the model  flow  rate  can  be  achieved  at  all  wet
sintering plants by providing or  increasing  the  rate  of  recycle.

It should be noted that  those flows   averaged  to   develop   the  model
effluent  flow  are  for  plants   in  which  process   wastewaters  are
generated  at  the machine  end   of  the  sintering   operation.    The
pollutant  loads   in  machine  end process  wastewaters  were typically
found to be greater than the loads in   discharge end,   both end   or
cooling  wastewaters (refer to process  descriptions in Section  III  and
to the analytical  data in Section  VII).  Recycle rates  and   discharge
flows  achieved;  in systems with more highly contaminated wastewaters
demonstrate the ability of those   operations with  less  contaminated
wastewaters  to  achieve  similar  discharge flows and  recycle rates
Referring to Table IX-1, applied flows  in several instances  (discharge
end, both end, or  contact cooling) approach  or are  less  than the  model
effluent flow.  The Agency concludes that the treatment model effluent
flow, and resultant  recycle -rate,  are  well   demonstrated in  this
subcategory.

Justification of the BPT Effluent  Limitations

Table  IX-2  presents  plant  effluent  data which   support  the BPT
limitations.  These data show two  stand-alone   plants   in   compliance
with  the  BPT  effluent  limitations for suspended solids and  oil and
grease.   The  PH   at  Plant  0396A  is  higher   than   the  maximum  pH
limitation  of  9.0  standard units.   The pH alone will not  affect the
levels of the other BPT limited  pollutants  and,  therefore,   has  no
bearing   on   this  particular  analysis.    Several   other  sintering
operations are in  compliance with  the BPT effluent limitations.    Many
of these (Plants 0060,  0112D,  0448A,  0584C,   0860B,  and 0864A) are part
of central treatment systems.
                                   277

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                                         TABLE IX-1
                             BPT FLOW SUMMARY AND JUSTIFICATION
                                    SINTERING SUBCATEGORY
Plant
Code
0448A
0060F
0868A
0920F*
0396A
0584F
0856Q*
0112B
0920B
0948C*
0112D*
0060
0856F
0432A
0112A
0112C
0584C
0864A
0060B
0492A
0946A
Applied
Flow (gal/ton)
UNK
301
100
: 2124
341
106
2805
133
134
1124
1432
1667
220
245
1604
1292
1368
2819
2186
2582
6605
                              Discharge
                            Flow (gal/ton)

                              . 0
                               26
                               70
                               74
                               80
                               106
                               H7
                               133
                               134
                               135
                               142
                               219
                               220
                               245
                               288
                               793
                               1368
                               1733
                               2186
                               2582
                               6605
Operating
  Mode

RTP-100
RTP-91
RTP-30
RTP and RUP-94
RTP-75
OT
.RTP-96
OT
OT
RUP-88
RTP-90
RTP and RUP-80
OT
OT
RTP and RUP-77
RTP-39
OT
RTP-38
OT
OT
OT
Origin of Process
   Wastewaters       Basis

    B                DCP
    A                VISIT,:
    D                DCP   ;
    A                D-DCP
    B                VISIT'
    B '               DCP
    A                DCP
    C                DCP
    C                DCP   !
    A                DCP
    A                VISIT
    C                D-DCP
    C                D-DCP
    C                VISIT;
    B                D-DCP
    B                DCP
    A                DCP
    C                D-DCP
    C                DCP
    C                DCP
    A                DCP
A:  Front end of operation   (e.g., wind box, machine-other than wind box,  storage and  f
    handling area dusts)
B:  Discharge end of operation.
C:  Both ends of operation.
D:  Contact cooling of the product only.
    Denotes those plants used to determine the BPT treatment model effluent  flow.
    average recycle rate of these plants is 92% and the average discharge  flow  is
    117 gal/ton.                        ,   I
                                     The
                                         278

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                                                    279

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280

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                        SINTERING SUBCATEGORY

                ;              SECTION X

                 EFFLUENT QUALITY ATTAINABLE THROUGH
           THE APPLICATION OF THE BEST AVAILABLE TECHNOLOGY
                       ECONOMICALLY ACHIEVABLE
Introduction

The  Best  Available Technology Economically Achievable (BAT) effluent
limitations are'to be achieved by July 1, 1984.  BAT is determined  by
reviewing  subcategory practices and identifying the best economically
achievable  control  and  treatment  technology  employed  within  the
subcategory.   In  addition,  where  a treatment technology is readily
transferable from another subcategory or industry, such technology may
be identified as BAT.

This section identifies five  BAT  treatment  alternatives  which  the
Agency  considered  for  the  sintering subcategory.  In addition, the
rationale for selecting the BAT model treatment system flow rates  and
effluent   pollutant   concentrations   are  reviewed.   Finally,  the
rationale for selecting the BAT model treatment system is discussed,

Identification of BAT                      	

Based upon the information contained in Sections III through VIII, the
following alternative treatment systems were developed  to  supplement
the   BPT   model  treatment  system.   These  treatment  systems  are
illustrated schematically in Figure VI.II-1 .
1 .
2.
*
3.
BAT Alternative 1                                      *

In the first BAT  Alternative,  the  BPT  blowdown  flow  of  120
gal/ton  is  filtered  to  reduce  the levels of toxic metals and
suspended solids.  The pH of the effluent is adjusted using acid.
The pH  adjustment  step  is  a  BPT  component  which  has  been
relocated in the sequence of treatment steps.

BAT Alternative 2

BAT Alternative 2 includes lime precipitation  and  sedimentation
of the BPT treatment system blowdown for toxic metals control and
subsequent pH control.                                      '
          "!       '           '  -                                •
BAT Alternative 3

This alternative includes the treatment system components of  BAT
Alternative   2,   and  adds  two-stage  (alkaline)  chlorination
following clarification for the  purpose  of  oxidizing  cyanide,
phenols,  and  other  toxic  organic pollutants.  The chlorinated
                                   281

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     effluent is dechlorinated
     prior to discharge.

4.   BAT Alternative 4
with  an  appropriate  reducing  agent
     The  fourth  BAT  alternative
     treatment system components of
     and  adsorption on granular
     organic pollutants added as the
     discharge.

5.   BAT Alternative 5
    treatment  system   includes   the
     BAT Alternative 3 with filtration
 activated carbon for removal of toxic
     final treatment  steps  prior  to
     In this alternative zero discharge is achieved by evaporating the
     BPT treatment system- blowdown and returning all of the condensate
     to the process.

Investment and annual costs for the BAT alternative treatment  systems
are presented in Section VIII.

Rationale for the Selection of BAT

Treatment Technologies

The  model  BAT  applied  and  discharge flows are based upon the same
recycle rate (92%) and discharge flciw used to develop the BPT effluent
limitations.  Referring to Table  IX-1,  the  average  and  individual
recycle  rates  of  the  plants used to develop the model BAT effluent
flow support a 92% recycle rate.  The Agency has  included  filtration
in  some  of the model BAT treatment systems to reduce the toxic metal
effluent loads.  Removal of toxic metals is'accomplished by removal of
suspended solids, in which the metals are entrained.  Three of the  21
"wet" sintering plants are equipped with filtration as part of central
wastewater  treatment systems.  Filtration is also used extensively in
other steel industry subcategories  (e.g.,  ironmaking,  basic  oxygen
furnace,  continuous casting, and hot forming) and in other industries
for  the  removal  of  suspended  particulate  matter   from   similar
wastewater streams.           •      |
                                                    •
Lime  addition  for  the  purpose  of  pH  adjustment  and precipitate
formation is a common  wastewater  treatment  practice.   The  use  of
clarifiers  for wastewater sedimentation is common in this subcategory
and in a wide variety of other subcategories and industries.

Two-stage  (alkaline)  chlorination  is  included  as   a   means   of
controlling  cyanide,  ammonia-N,  and phenols and other toxic organic
pollutants.  Alkaline chlorination is practiced at two plants in  this*
subcategory  as  part  of co-treatment with blast furnace wastewaters.
Dechlorination using reducing agents is  included  to  control  excess
residual   chlorine.   Dechlorination  is  practiced  at  one  central
treatment plant which receives sintering process wastewaters.
                                  • 282

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Activated carbon adsorption is included to remove  any  toxic  organic
pollutants  which may remain after treatment by alkaline chlorination.
Activated carbon is  used  in  one  sinter  plant  application,  where
ironmaking and sintering process wastewaters are co-treated.

Flows

Refer  to  Table  IX-1  for  the  data  used  to develop the model BAT
treatment system effluent flow.  The plants which have  recycle  rates
of  90%  or more approach or exceed the model BPT recycle rate of 92%.
As noted in Section IX, the Agency believes that a recycle rate of 92%
and a model effluent flow of 120 gal/ton are appropriate for  the  BAT
model  treatment  Systems.   Aside  from  the use of vapor compression
distillation, the Agency is not aware  of  other  methods  to  further
reduce the discharge volume.

Wastewater Quality

Reference  is made to-the ironmaking subcategory-report for a complete
discussion of the development of effluent limitations  for  ammonia-N,
total  cyanide, phenols (4AAP), and total residual chlorine applicable
when sintering wastewaters are co-treated with ironmaking wastewaters..

Toxic Metal Pollutants

To  determine  the  effluent  concentrations  for  the   toxic   metal
pollutants, the Agency evaluated monitoring data from several sources.
The  Agency  reviewed  long-term  filtration system effluent data from
similar wastewater treatment applications and pilot treatability study
data to determine the toxic metals removal capabilities of  filtration
systems.   A review of these data and the monitoring data presented in
Section VII indicate that the toxic metal,s are present in  particulate
form.   The  toxic  metals effluent concentrations used to develop the
BAT effluent limitations are the same as those used to  establish  the
toxic   metal   limitations   for1  ironmaking   wastewaters.   t These
concentrations are achievable by sintering operations and were used to
facilitate co-treatment with ironmaking wastewaters, a common practice
in the industry.  These toxic metals concentrations are support by the
pilot filtration data for plant 0060 presented  in  Table  X-l.   Lime
precipitation   and  sedimentation  data  from  the  same  source  are
presented in Table X-2.

Sulfide  addition  was  considered  for  treatment  of  toxic  metals.
However,  because of the marginal incremental toxic metal removal over
other  technologies,  and  because  this  technology  has   not   been
demonstrated  ,in this subcategory, the Agency did not consider sulfide
precipitation as an alternate BAT technology.

Effluent Limitations for the BAT Alternatives

The  effluent  limitations   associated   with   the   BAT   treatment
alternatives  were developed on a mass basis (kg/kkg or lb/1000 Ib) by
applying  the  model  plant  effluent  flow  of  120  gal/ton  to  the
                                   283

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respective BAT treated effluent concentrations of each pollutant.  The
effluent  limitations  for each alternative were established using the
procedures outlined in Volume I.  The effluent flow and concentrations
have been previously documented in tjhis section.  Table  X-3  presents
the  effluent  limitations  developed  for each treatment alternative.
The  flow  and  concentration  basis  for  the  limitations  are  also
presented.                          ;'

Selection of_ a BAT Alternative

The  Agency selected BAT Alternative 1 (depicted in Figure X-l) as the
BAT  model  treatment  system.   The  Agency   determined   that   BAT
Alternative  1 provides significant benefits with regard to reductions
in toxic  pollutant  effluent  loads  and  should  be  the  BAT  model
treatment system.  While Alternative 1 is the selected BAT. option, the
Agency  believes  that  Alternative 2 (lime precipitation) can also be
used to achieve the BAT  limitations-   Except  as  noted  below,  the
Agency  does  not believe that the relatively low levels of ammonia-N,
total cyanide, phenols  (4AAP)  and  other  toxic  organic  pollutants
warrant  the  application  of  more  advanced  technologies  including
two-stage alkaline chlorination and'activated carbon to all  sintering
plants.    Evaporation   technology   to   eliminate   the   discharge
(Alternative 5), while technically feasible, is extremely  costly  and
was not selected on that basis.

The  Agency  recognizes  that co-treatment of compatible sintering and
ironmaking wastewaters is practiced at several  plants.   Accordingly,
the  Agency  has promulgated effluent limitations for ammonia-N, total
cyanide,  phenols  (4AAP),  and  total  residual  chlorine  which  are
applicable  to  sintering  wastewaters  when these wastewaters are co-
treated with ironmaking  wastewaters.   The  achieveability  of  these
limitations  are demonstrated by the performance at Plant 0860 B which
is discussed in detail in the ironmaking  subcategory  report.   These
sintering BAT limitations are based^upon the model plant effluent data
for  sintering and ironmaking operations and the sintering model plant
flow  of  120  gal/ton.   The  promultation  of  BAT  limitations  for
ammonia-N,  total cyanide, and phenols (4AAP) for sintering operations
is  consistent  with  the  Agency's  co-treatment  .policy.    Greater
discharges  of toxic  and non-conventional pollutants will not  result
when these wastewaters are co-treated rather than treated  separately.
The  levels  of  these pollutants in BPT treatment system effluents is
close to that found  in  ironmaking  wastewaters  after  treatment  by
alkaline chlorination.              :                             t

The  BAT effluent limitations are presented on Table X-3 under the BAT
Alternative 1 heading.  The  achievability  of  these  limitations  is
demonstrated  by  the  performance data developed from the pilot study
and the fact that the model flow rate is well demonstrated.  The model
flow rate is the same as the BPT model  treatment  system  flow  rate.
Table  X-4  justifies  the  sintering  BAT  limitations for a sintering
operation co-treated with an  ironmaking operation.
                                    284

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BAT Limitations

Sintering sl\
Ironmaking

Total

Current Discharge
of Plant 0860B
                                         TABLE X-4

                         JUSTIFICATION OF BAT EFFLUENT LIMITATIONS
                                   SINTERING SUBCATEGORY
30-Day ^
Ammonia-N Cyanide
(Ib/day) (Ib/day)
166.3 16.6
120.4 12.0
Average Limitations

Phenols-4AAP Lead
(Ib/day) (Ib/day)
1.7 4.
1.2 3.
2
0

Zinc
(Ib/day)
5.0
3.6
286.7

 47.4
28.6

 0.7
[2.9
 0.1
    (2)
7.2

NA
8.6

1.4
(1)  Sintering Production - 16,600 TPD (from DCP)
     Ironmaking Production - 20,611 TPD (from DCP)
(2)  Represents activated carbon treatment.

NA:  No analyses performed.
                                              288

-------
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                                     289

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                        SINTERING SUBCATEGORY

                              SECTION XI

            BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
Introduction

The  1977 Amendments ad'ded Section 301 (b) (2) (E) to*the Act establishing
"best conventional pollutant control  technology"  (BCT)  for  discharges
of   conventional  pollutants  from  existing  industrial point  sources.
Conventional  pollutants  are  those  defined  in  Section   304(a)(4)
[biochemical oxygen Demanding pollutants  (BOD5),  total  supended  solids
(TSS),  fecal coliform, and pH], and  any  additional pollutants defined
by the Administrator as "conventional"  (oil and grease, 44  FR  445Q1,
July 30, 1979).                     •                     .

BCT  is  not an additional limitation but replaces BAT  for  the control
of conventional pollutants.  In addition  to other factors specified  in
Section  304(b)(4)(B),  the  Act  requires  that  BCT   limitations   be
assessed  in light of a two part "cost-reasonableness"  test.   American
Paper Institute v. EPA, 660 F.2d 954  (4th Cir. 1981).   The  first test
compares  the   cost  for  -private   industry to reduce its conventional
pollutants with the  costs  to  publicly  owned   treatment  works  for
similar  levels  of  reduction in their discharge of these  pollutants.
The  second  test  examines  the  cost-effectiveness    of   additional
industrial  treatment  beyond BPT.  EPA must  find that  limitations are
"reasonable" under both tests before  establishing them  as BCT.   In   no
case may BCT bfe less stringent than BPT.

.EPA  published  its  methodology  for carrying out the  BCT  analysis  on
August 29, 1979 (44 F.R. 50732).  In  the  case  mentioned   above,  the
Court  of  Appeals ordered EPA to correct data errors underlying EPA's
calculation of  the first test, and  to apply  the  second   cost  test.
(EPA had argued that a second cost  test was not required.)

EPA  has  determined  that  the  BAT  technology is capable  of  removing
significant amounts of conventional pollutants.   However, EPA  has  not
yet  proposed   or promulgated a revised BCT methodology in  response  to
the  American Paper Institute v. EPA decision  mentioned  earlier.  Thus,
it is not now possible to apply the BCT cost  test to  this  technology
option.   Accordingly,  EPA is deferring  a decision on  the  appropriate
BCT  limitations until EPA proposes  the revised BCT methodology.
                                    291'

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                        6INTERING SUBCATEGORY

                             SECTION XII

         EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICATION
                 OF NEW SOURCE PERFORMANCE STANDARDS
Introduction

NSPS are to be established based upon a consideration of the degree of
effluent reduction achievable through . the  application  of  the  Best
Available   Demonstrated   Control   Technology   (BADCT),  processes,
operating methods, or other alternatives including, where practicable,
a standard permitting no discharge of process wastewater pollutants to
navigable waters.  The Agency concluded that zero discharge,  however,
is   not   a   feasible  treatment  alternative  for  "wet"  sintering
operations.  As  discussed  in  Sections  VII  and  X,  there  are  no
technologies  applicable to all sintering operations that would result
in attainment o'f zero discharge in  a  cost  effective  manner.   Zero
discharge  may  be  achieved at new sintering operations by installing
dry air cleaning systems.  However, the Agency did not establish  NSPS
on this basis since, in some instances, "wet" air cleaning systems may
be  more  effective and more appropriate for given applications.  NSPS
alternative  treatment  systems  and  effluent  standards  have   been
developed to accommodate the use of "wet" air cleaning systems.

Identification and Basis for NSPS
Treatment Scheme and Flow Rates

NSPS Alternative 1

This  alternative  is identical to BPT and BAT Alternative 1 (refer to
Sections IX and X).  This system includes sedimentation of raw process
wastewaters in a thickener in  conjunction  with  the  addition  of  a
flocculant  to  enhance solids removal.  Treatment process sludges are
dewatered by vacuum filtration.  Most of the thickener effluent  (92%)
is  recycled to' the process, while the remaining thickener effluent is
discharged as a blowdown.  The recycle blowdown  undergoes  filtration
to  remove toxic metals and suspended solids.  Prior to discharge, the
pH of the treated effluent is adjusted, as necessary, to  the  neutral
range with acid.

NSPS Alternative 2_

This  alternative  is  identical  to  BPT and BAT Alternative 2.  Lime
precipitation and clarification, instead of filtration, of the recycle
system blowdown noted above is included for toxic metals removal.
                                   293

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NSPS Alternative 3_                 \

This alternative is identical to BPT and BAT Alternative 3.  Two-stage
alkaline chlorination is  included  in this alternative for  the  purpose
of  cyanide, ammonia and  phenol oxidation.  Dechlorination is provided
prior to discharge.

NSPS Alternative 4.

This alternative is identical to BPT  and  BAT  Alternative  4,   This
alternative  provides for the removal, by activated carbon adsorption,
of the remaining toxic organic pollutants that may be present.

NSPS Alternative 5

This alternative is the same as BPT and BAT Alternative 5  and provides
for zero discharge by the use of evaporation technologies.

In order to accommodate process developments which would   be  included
in  the  construction  of  a new source "wet" sintering operation, the
Agency examined various   industry  trends.   In  all  likelihood,  new
sintering  operations will have greater production capacities than the
4000 tons/day used for BPT  and  BAT  model  treatment  systems.   The
Agency  averaged  the  production  .capacities  of sintering operations
constructed  in  the  last  decade; and,  based  upon  that   average,
established  a new source model size of 7,000 tons/day, which was used
for NSPS  costing.   Although  the  effluent  limitations   (kg/kkg  of
product) developed for the BAT model treatment systems are the same as
those  for  the  new  source systems, the increased model  size for new
source operations results in increased  treatment  model   capital  and
annual costs due to the increase iiii the volume of wastewater requiring
treatment.   A  review  of the subcategory summary data indicates that
the model BPT and BAT applied and discharge flows  are  applicable  to
new  "wet"  sintering operations.  Trends which might affect flow were
not detected.
                                   F
The NSPS treatment systems described  above  are  depicted in  Figure
VIII-1.    The corresponding effluent levels and loads are  presented in
Table XII-1.  Cost data for NSPS are presented in Section  VIII.

Rationale for Selection of NSPS    ;

The NSPS alternative treatment systems  include  the  same components
described  for  the  BPT  and BAT model treatment systems  discussed in
Sections IX and X.  Reference is made to those sections for  a  review
of the treatment technologies.     |

Selection of -an NSPS Alternative   ;

The  Agency  selected NSPS Alternative 1, depicted in Figure XII-1, as
the NSPS model treatment system.  This alternative  was  selected  for
the same reasons noted in Section X regarding the selection of the BAT
                                    294

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model  treatment  system (i.e., the benefits derived from reduction in
the effluent loads of various pollutants).

The NSPS are presented in  Table  XII-1  under  the  heading  of  NSPS
Alternative  1.    As  noted  in Section X for BAT, NSPS for ammonia-N/
total cyanide, phenols (4AAP), and total residual chlorine  have  been
promulgated  to  accommodate co-treatment of new source ironmaking and
sintering wastewaters.

Justification of_ NSPS

Recycle of sintering  wastewaters  is  practiced  at  several  plants.
Reference  is made to Table IX-1 which lists these plants.  Filtration
of sintering wastewaters is practiced at plants 0584C,  0860B,  0920B,
and  0946A.   Lime  or caustic precipitation and alkaline chlorination
are practiced at plant 0860B.  Alkaline chlorination is also practiced
at plants 0432A and 0946A.  Reference is made to Tables X-1, X-4,  and
XII-2 for demonstration of NSPS for sintering operations.
                                    295

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                        SINTERING SUBCATEGORY

                             SECTION XIII

               PRETREATMENT STANDARDS- FOR DISCHARGES TO
               ; '    .PUBLICLY OWNED TREATMENT WORKS
Introduction                                  ,

This   section   presents   pretreatment  alternatives  for  sintering
operations with discharges to publicly owned treatment works  (POTWs).
One  sintering  plant  currently  discharges  process wastewaters to a
POTW.  The general pretreatment and categorical pretreatment standards
applicable, to sintering operations are discussed below.

General Pretreatment Standards

For detailed information on Pretreatment Standards refer to 46 FR 9404
et seq.,  "General  Pretreatment  Regulations  for  Existing  and  New
Sources  of  Pollution,"  (January  28,  1981).   See  also 47 FR 1518
(February 1, 1982).  In particular, 40 CFR Part 403 describes national
standards  (prohibited  and  categorical   standards),  .revision   of
categorical   standards   through   removal   allowances,    and   POTW
pretreatment programs.

In establishing pretreatment standards for sintering  operations,  the
Agency  considered  the  objectives  and  requirements  of the General
Pretreatment Regulations.  The  Agency  determined  that  uncontrolled
discharges  of  wastewaters  from  sintering operations to POTWs would
result in pass-through of toxic .pollutants.            '

Identification of Pretreatment Alternatives

PSES and PSNS alternative treatment systems are .identical to  the  BPT
model  treatment  and  the BAT alternative treatment systems (refer to
Sections IX and X for a discussion of these treatment systems).  These
alternatives are set out below and illustrated in Figure XIII-1.

PSES/PSNS Alternative 1 - Flocculant addition,  gravity  sedimentation
in a thickener, vacuum filtration of sludges, and recycle (92%) of the
system  effluent.   This  alternative  is  the  same  as the model BPT
treatment system.

PSES/PSNS Alternative 2 - Filtration of the blowdown  from  the  first
alternative.  This system is the same as BAT Alternative 1.

PSES/PSNS  Alternative  3  -  Lime  addition  and  clarification,  are
included to treat the blowdown from the first alternative.

PSES/PSNS  Alternative  4  -  Two-stage  (alkaline)  chlorination   is
included after lime addition and clarification.
                                    299

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PSES/PSNS  Alternative  5  -  Filtration  and  adsorption on activated
carbon are added to PSES and PSNS Alternative No.  4  for  removal  of
toxic organic pollutants which may;be present.

PSES/PSNS  Alternative  6  -  Th'e recycle system (PSES and PSNS No. 1) |
blowdown is processed by vapor  compression  distillation  to  achieve
zero discharge.

Selection of. a Pretreatment Alternative
                       >           ;
The  pretreatment alternatives described above are designed to control
toxic metals, and thus are designed to minimize pass through of  these
pollutants  at  POTWs  which  receive  sintering wastewaters.  The six
pretreatment  alternatives  accomplish  between  93  percent  and  100
percent removal of the toxic metal pollutants limited at PSES/PSNS.

PSES/PSNS  Alternative 2 was selected as the basis for the promulgated
PSES and PSNS.  This alternative is  the  same  as  the  selected  BAT
alternative   for   sintering  operations.   PSES/PSNS  Alternative   2
provides for substantial removal of  toxic  metals  without  the  high
costs associated with evaporate technologies.  More advanced treatment
is  not  appropriate,  as  most of the toxic metals found in sintering
wastewaters are in a particulate form.  The  removal  rates  of  toxic
metals  from untreated sintering wastewaters for PSES/PSNS Alternative
2 are compared to the POTW removal fates for these metals:       *
                                                    a
                    PSES/PSNS
                    Alternative 2 r      POTW
     Lead
     Zinc
98.9%
98.5%
48%
65%
As shown above, the selected PSES/PSNS alternative will  prevent  pass
through  of  toxic  metals  at POTWs to a significantly  greater degree
than would occur if sintering wastbwaters were discharged  untreated  to
POTWs.  The achievability of these standards  is reviewed  in   Sections
IX  and  X.   The model treatment system is depicted  in  Figure XIII-1,
and the PSES and PSNS are presented in  Table XIII-1.   Reference   is
made to Sections IX and X for demonstration of PSES and  PSNS.
                                  I  3.00

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                        IRONMAKING SUBCATEGORY

                              SECTION I

                               PREFACE
The USEPA has promulgated effluent limitations and standards  for  the
steel  industry pursuant to Sections 301, 304, 306, 307 and 501 of the
Clean Water Act.  The regulation  contains  effluent  limitations  for
best  practicable  control  technology currently available (BPT); best
available  technology  economically  achievable  (BAT);   pretreatment
standards for neti and existing sources (PSNS and PSES); and new source
performance   standards   (NSPS).    Effluent   limitations  for  best
conventional pollutant control technology (BCT) have been reserved for
future consideration.

This part of the Development Document highlights the technical aspects
of EPA's study of the Ironmaking Subcategory of  the  Iron  and  Steel
Industry.   Volume  I  of  the  Development Document addresses general
isssues pertaining to the industry while other volumes contain specific
subcategory reports.
                                    303

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                        IRONMAKING SUBCATEGORY

                              SECTION II

                             CONCLUSIONS
Based upon this ^current study,  a  review  of  previous  studies,  and
comments  received on the proposed regulation (46 FR 1858), the Agency
has reached the following conclusions:

1.    In  the  proposed  regulation,  the  ironmaking  subcategory  was
     subdivided  into  iron  blast  furnaces  and ferromanganese blast
     furnaces.   That  subdivision  has  been   maintained   in   this
     regulation.   However,  since  there were no ferromanganese blast
     furnaces in operation during the data gathering period  for  this
     regulation  (there  are  none presently in operation), the Agency
     has  promulgated  only   the   previous   BPT   limitations   for
     ferromanganese  blast furnaces and reserved all other limitations
     and standards (BAT, BCT, NSPS, PSES,*PSNS).  The Agency  believes
     that  BAT  ,and  BCT  limitations  and  NSPS,  PSES  and  PSNS for
     ferromanganese furnaces should be established on  a  case-by-case
     basis  using  the  model wastewater treatment technology outlined
     for ironmaking blast furnaces.  The Agency  found  no  basis  for
     further  subdividing  ironmaking  into  pig  iron  producers  and
     ironmaking furnaces associated with steel production.

2.    On the basis of the  data  collected  for  this  study,  the  BPT
     effluent   limitations originally promulgated in 1974 for iron and
     ferromanganese blast  furnaces  based  upon  recycle  of  process
     wastewaters,  are  practicable  and  achievable.   The Agency has
     promulgated  BPT  limitations  which  are  identical   to   those
     previously-: promulgated.

3.    The Agency's  monitoring  of  ironmaking  blast  furnace  process
     wastewaters   revealed   significant  discharges  of  nine  toxic
     inorganic  and eight toxic organic' pollutants in addition  to  the
     currently  limited pollutants.  The Agency has concluded that the
     discharge  of these pollutants can be controlled by the available,
     economically achievable  technologies  which  include  additional
     recycle  and  blowdown treatment  consisting of lime precipitation
     and  two-stage  alkaline  chlorination  at  the  BAT   level    of
     treatment.   A  summary of raw waste loadings, and the discharges
     resulting  from attainment of  the  BPT, BAT  and  PSES  limitations
     and standards' for ironmaking  blast  furnaces, is presented below:
                                   305  .

-------
                        Pollutant Discharges  (Tons/year)
Flow (MGD)
Ammonia (as N)
Cyanide, Total
Fluoride
Phenols (4AAP)
TSS
Toxic Metals
Toxic Organics1
                     Direct Discharges
              Raw Waste

                  825.6
                25,147.2
                15,088.3
                18,860.4
                3,772.1
            2,388,979.8
                33,382.8
                  201 .2
  BPT

   29.2
2,672.8
  178.2
2,004.6
 ' 102,
1,87).
   77. 1
    7. 1
5
0
  BAT

 16.4
149.7
  0.7
498.9
  0.4
548.-8
 11.4
  4.0
                                                 Indirect
                                                 Discharges
                                                   Raw Waste
     38.4
  1 ,169.6
    701 ,
    877,
    175.
111,115:
  1,552.7
      9.4
8
2
4
3
PSES

 0.8
 7.7
 0.04
25.6
 0.02
28. 1
 0.6
 0.2
4.
1 Does not include total cyanide or any of the
individual phenolic compounds.

The Agency's estimates of the costs of compliance  with  -the  BPT
and  BAT  limitations and PSES for the ironmaking subcategory are
presented below for facilities in place as of July 1, 1981.   The
Agency  has determined the effluent reduction benefits associated
with compliance  with  the  effluent  limitations  and  standards
justify these costs.
Costs (Millions of Julv


Total
434.
30.
13.
7
8
9
Investment
In-
4


Place
12.3
7.6
13.2
Costs


1, 1978 Dol.
Annual
Lars)
Costs


Required In— Place Required



22.
23.
0.
4
2
7
52.
2.
2.
5
3
3
2.
6.
0.
7
R
2
     BPT
     BAT
     PSES

     The Agency  has  also determined that  the effluent  reduction benefits
     associated  with compliance  with new  source standards  (NSPS,  PSNS)
     justify  those costs.

     The  estimated   costs   of   compliance   for BAT  are  based  upon  the
     Agency s  assumption   that   the  BAT model  two-stage    alkaline
     chlorination  treatment system  will be installed  at each plant
     However,  the   Agency   expects   that    alternate   less    costly
     technologies    will    be    installed   at   many  plants.    These
     technologies include minimization of blast furnace  blowdowhs with
     slag  quenching;  co-treatment of blast   furnace  wastewaters  with"
     cokemaking  wastewaters in  biological  treatment  systems,   and
     certain  innovative  technologies that  can  achieve   the    BAT
     limitations at  less or  equal costs.  The Agency estimates  that 60
     percent  of  the  plants  are  currently  able  to evaporate  process
     wastewaters on  slag.  The Agency  has  also determined  that   the
     effluent  reduction  benefits  associated with compliance with  new
     source standards  (NSPS, PSNS)  justify these costs.
                                  306

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5.
6.
7.
8.
9.
10,
1 1
The BPT and  BAT  model  treatment  systems  for  the  ironmaking
subcategory  include  wastewater  recycle.   Responses  from  the
industry for several plants indicate that they do not  experience
scaling,   fouling,   or   plugging  problems  with  the  recycle
components used at those plants.  The Agency has concluded that a
70 gal/ton blowdown is achievable and practicable as a  component
of  the  BAT  model  wastewater  treatment system.  A major steel
company has recommended that the Agency base BAT limitations on a
model flow of 35 gal/ton.                     -

The Agency has not promulgated BCT limitations since the BCT cost
methodology was remanded to the Agency for reconsideration.

The Agency has promulgated NSPS for ironmaking  operations  which
are  equivalent  to  the BAT limi-tations for toxic pollutants and
provide for additional suspended solids control'by filtration.

EPA has promulgated pretreatment standards  for  new  (PSNS)  and
existing  (PSES)  sources which limit the quantities of toxic and
nonconventipnal pollutants which can be introduced to POTWs.  The
PSES and PSNS are the same as the BAT limitations.

Although several toxic organic and toxic  metal  pollutants  were
found*in untreated ironmaking wastewaters, the Agency believes it
is   not * necessary  to  establish  limitations  for  each  toxic
pollutant.  The Agency believes that adequate  control  of  toxic
organic  pollutants  can  be  achieved  by  the  control of total
cyanide "and phenols (4AAP).  Likewise, control of lead  and  zinc  '
will   result   in   comparable  control  of  other  toxic  metal
pollutants.

To facilitate less costly  central  treatment  and  to  make  the
ironmaking   limitations  compatible  with  those  for  sintering
operations, the Agency has established an oil and grease effluent
limitation for the ironmaking subcategory.
With  regard  to
concludes that: .
Third  Circuit  "remand  issues,"  the   Agency
          Its estimated  costs  for  the  model  wastewater  treatment
          systems  are  sufficient  to  cover  all  costs  required to
          install and operate the model technologies,  whether  as  an
          initial  fit  or  a retrofit.  The Agency has also concluded
          that the ability to implement the model wastewater treatment
          systems is not affected by plant.age.  A comparison  between
          the   costs  reported  by  the  industry  and  the  Agency's
          estimated costs for several  plants  demonstrates  that  the-
          estimated model wastewater treatment costs are sufficient to
          account  for  all  site-specific  and other incidental costs
          which might be incurred.

          The use of recycle through cooling towers at the BPT and BAT
          levels of treatment and the use of  evaporation  of  process
                                   307

-------
12,
     wastewaters  on  slag  as' a  means  of  achieving   the  BAT
     limitations  will  result  in  minor   increases   in  water
     consumption.   It  is  estimated  that implementation of the
     technologies included  in  the BPT model treatment system will
     result in a net  increase  in water consumption  of   3.0  MGD.
     This increase represents  0.35 percent of the total  volume of
     water  applied   in  this  subcategory.  Implementation of the
     treatment technologies included in the BAT  model   treatment
     system  will  result   in  a  net  increase of  3.1 MGD.  This
     increase represents 0.36 percent  of  the  total  volume  of
     water  applied   in  this  subcategory.  However, recycle also
     significantly  reduces  or  eliminates  the    discharge   of
     pollutants.   Since  the  total  water  consumption is small
     compared to total  industry  water  usage,  the  Agency  has
     concluded   that  the  impact  of  the  limitations on  the
     consumptive use of water  in this subcategory is minimal  and
     is  justified  by  the effluent reduction benefits  resulting
     from their use.  These technologies are presently in use  at
     plants in "arid" and "semi-arid" regions.

Table  II-l   presents  the  BPT  effluent  limitations   for   the
ironmaking  subcategory and the treatment model flow and effluent
quality data used  to  develop, these  limitations.   Table  II-2
presents  the  BAT  effluent limitations, and the NSPS,*PSES, and
PSNS for the ironmaking subcategory  as  well  as   the   treatment
model  flow  and  effluent  quality  data  used  to develop these
limitations and standards.
                                   308

-------
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-------
                        IRONMAKING SUBCATEGORY

                             SECTION III

                             INTRODUCTION
General Discussion

The production of molten iron from coke,  iron  ores  and  beneficiated
iron ores, sintered products, and limestone  is an  integral part of  the
basic  steelmaking, process.  In  1980, blast  furnace iron production in
the United States supported about 61% (on a  net tonnage basis) of U.S.
raw steel production.  The balance is  produced  directly  from  steel
scrap  in electric steelmaking remelting furnaces.
                                   ™;
Process wastewaters are generated in ironmaking operations as a result
of  gas  cleaning  and cooling which permits the reuse of the gas as a
fuel.  Both  iron and ferromanganese blast  furnaces  are  included   in
'this study.

The Agency previously promulgated a regulation governing blast furnace
operations   in  1974  and  established  limitations  for the following
pollutants:

          Total Suspended Solids
          Ammonia-N
          Cyanide  (Total)
          Phenols  (4AAP)
          Fluoride
          Sulfide
          pH

Data Collection Activities

Industry responses to the basic  questionnaires   (DCPs)  comprise   the
major  source  of  data  for  blast  furnace  operations.    The Agency
requested  information pertaining to  production,  processes,  process
water  usage,  process  wastewater discharge,  and  wastewater  treatment
systems.  The DCP  responses  for  iron blast furnaces are  summarized  and
tabulated  in Table III-l.  The DCP information for the   ferromanganese
blast, furnace is summarized  and  tabulated in Table III-2.

The Agency sent detailed questionnaires  (D-DCPs)  to selected plants to
gather  cost and furnace operating data and  long-term monitoring  data.
The responses to   these  questionnaires   provided  useful   data   which
verified   cost  estimates,   established   retrofit   costs (if  any),  and
provided  additional  effluent quality data.   The  Agency   identified   56
plants  with blast  furnace  operations  including  two merchant  pig-iron
producers.   One firm claimed confidentiality with  regard to  all   data
submitted  and  collected  by the Agency during surveys.   These data do
not   appear  .in  Table   III-l.   The  Agency   also    identified    one
                                    311

-------
 ferromanganese   blast   furnace  and   164  iron blast  furnaces  at  the  56
 plants  with  blast  furnace  operations.   Four of the iron blast furnaces
 are associated  with  merchant  pig iron  producers..  The operation   of   4
 to  6   furnaces per plant is not uncommon and one plant had  11  active
 furnaces.    Table   II1-3   summarizes   the  data  base  for   ironmaking
 operations.

 Description  of  the Blast Furnace Process

 Blast   furnaces are large cylindrical  structures in which  molten iron
 is produced  by  the reduction   of  iron  bearing  ores  with  coke and
 limestone.   Reduction  is promoted by blowing heated  air into  the lower
 part  of   the   furnace.    As   the raw  materials melt and  decrease  in
 volume, the  entire mass of the furnace  charge  descends.   Additional
 raw  materials   are  added (charged) at the top of the furnace to keep
 the raw material mass  within  the furnace  at a constant level.
                                   ., j,
 Iron oxides  react  with the hot carbon monoxide from  the burning   coke,
 and  the limestone reacts  with impurities in the iron bearing material
 and the coke to form molten slag.  These  reactions start at the  top  of
 the furnace  and proceed to completio;n as   the  charge  passes to the
 bottom  of   the furnace.   The molten slag,  which floats on top  of the
 molten  iron, is drawn  off  (tapped) by way  of  a  tapping  hole.   The
 molten  iron  is  also  tapped through a hole below the  slag tapping hole.
The  production  of   iron  from  a  blast   furnace   is
following approximate charge and yield relationships:
                     based upon the
          Raw Materials

          1.8 kkg iron ore
          0.6 kkg coke
          0.45 kkg limestone
          3.2 kkg air
Products
0.9 kkg iron
0.5 kkg slag
4.5 kkg process gas
Blast furnace operations within  the  U.S.  primarily  produce   (>99%)
basic  iron.  Several plants have occasionally produced ferromanganese
iron, although during this study only one ferromanganese  furnace  was
found  (Figure 111-4).  Production oif iron  (rated capacity) on a plant
basis ranges from 800 to 22,200 TPD (Table  III-4).   The  total  rated
capacity  of  all  active  operations  is   294,260  TPD (excluding the
confidential plant).  Twenty-five percent of the plants account for 50
percent of the rated capacity.

The gases which are produced in the furnace are exhausted through  the
top  of the furnace.  These gases arfe cleaned, cooled, and then burned
to preheat the incoming air to the furnace.  Generally,  gas  cleaning
involves  the  removal  of  the  larger  particulates  by  a  dry dust
collector, followed by a variety of ^wet" or  "wet/dry"  gas  cleaning
systems  for  fine  particulate  removal.   The  three most common gas
cleaning systems are illustrated in Figures  III-l,  2,  and  3.   The
first  system  (Type  I)  uses  one wet scrubber (primary); the second
(Type II) uses two wet scrubbers  (primary  and  secondary);  and  the
                                   312

-------
third  (Type  III)  uses  one  wet  scrubber and one dry air pollution
control device.  Gases are cooled with direct contact sprays jn  large
gas  cooling  vessels.   At  many  plants, all or a portion of the gas
cooling wastewaters are cascaded to the gas cleaning systems described
above.

Description of_ Wastewater Treatment

Prior to the mid  1970's,  the  treatment  of  ironmaking  wastewaters
consisted  of  the  removal  of  suspended  solids by sedimentation  in
conjunction with  the  addition  of  flocculating  agents  to  improve
removal   efficiencies.   The  clarified  wastewaters  were  typically
discharged directly on a once-through basis without further treatment.
Today, however, about ninety percent of the blast  furnace  wastewater
treatment systems include recycle  (after  the thickener , and discharge
Inly  a relatively small percentage  (generally 5  to.10%) of the process
flow    Nearly  all   recycle  systems  employ cooling towers^to  reduce
recycle  wastewater   temperatures.   The  thickener   underflows  are
typically  dewatered  by  vacuum filters  with the  filtrate returned  to
the thickener  influent.  The ,dewatered   solids  are  either  sent   to
sintering  operations or to off-site disposal.   The specific treatment
practice!  in use  at each plant are  detailed  in Table  III-1  for  iron
blSst furnace  plants   and  in  Table   III-2  for the  ferromanganese
furnace.
                                     313

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                               TABLE  III-3           »

                   IRON MAKING BLAST  FURNACE  DATA BASE
Percent of Rated Percent of
No. of Total No.
: Plants of Plants
Plants sampled, for 4 7.4
original study
Plants sampled for 7 .13.0
toxic pollutant study
Total plants sampled 11 20.4
Plants responding via 7 13.0
D-DCP
Plants sampled and/or.v 15 27.8
responding via D-DCP
Plants which responded 54 100
to DCP
Capacity Rated
(Tons/Day) Capacity
15,200 4.7

54,080* 16.8

69,280* 21.5
62,050 19.3

116,640* .36.2
321,511* 100.0

(1) Three plants which responded via D-DCP were also sampled during the
    toxic pollutant survey.

* : Does not include the tonnage of the confidential plant.
                                     321

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                   *           TABLE III-4

                      IRON MAKING FURNACE PRODUCTION
             PLANTS RANKED FROM HIGHEST TO LOWEST PRODUCTION
             	(TONS PER DAY - RATED CAPACITY)
Reference Number

   0384A
   0860B
   0112A
   0112B
   0432A
   0584B
   0984C
   0112
   0112D
   0860H
   0684F
   0856B
   0856F
   0868A
   0584F
   085 6N
   0448A
   0856R
   08561
   0320
   0864A
   0060B
   0948A*
   0432C
   0432B*
   0112C
   0584C
   0528A
   0060
   0856T*
   0920B
   092 ON
   0396A
   0396C*
   0684G
   0920A
   0684H
   0684B
Rated Capacity
	TPD	

   22,200
   20,611
   19,140
   12,550
   11,000
   10,900
   10,700
   10,600
   10,500
   9,912
   9,200
   8,600
   8,206
   8,054
   8,020
   8,000
   7,200
   6,750
   6,400
   6,270
   5,700
   5,600
   5,400
   5,367
   5,275
   5,200
   5,200
   5,000
   4,730
   4,707
   4,400
   4,200
   3,400
   3,180
   3,150
   3,100
   2,870
   2,800
                                     322

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TABLE III-4
IRON MAKING FURNACE PRODUCTION
PLANTS RANKED FROM HIGHEST TO LOWEST PRODUCTION
(TONS PER DAY - RATED CAPACITY)
PAGE 2                       	
Reference Number

   0724A
   0060A
   0684A
   0946A*
   06841
   00*60F
   0584D
   0248A*
   0256E*
   08560*
   0492A
   0426
   085 6Q
   0948B*
   0732A

   TOTAL
Rated Capacity
	TPD

   2,800
   2,560
   2,520
   2,400
   2,300
   2,200
   2,150
   2,000
   2,000
   1,234
   1,200
   1,100
   1,100
   1,055
   800

   321,511  (294,260*)
*  : Plant is now shutdown.  The capacities of these plants
    are not included in the indicated total.

NOTE: The capacity of the confidential plant is not presented
      or included in the total.
                                     323

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324

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325

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326

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327

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                        IRONMAKING SUBCATEGORY

                              SECTION IV

                          SUBCATEGORIZATION
Introduction

The steel industry is comprised of separate  and  distinct  processes.
Industry  subcategorization  was  primarily affected by the individual
processes, products,  and wastewater  characteristics.   Other  factors
considered   for   subdivision   were:    raw   materials,  wastewater
treatability, size, age, geographic location, and process water usage.
With regard to ironmaking operations,  differences  between  iron  and
ferromanganese  blast  furnaces  were  identified and found to justify
subdividing the ironmaking subcategory.  However, the Agency found  no
significant  differences between blast furnaces producing pig iron and
those associated with steel production.  A discussion of each of these
factors and the subdivision of the ironmaking subcategory follows.


Factors Considered in Subdivision

Manufacturing Process and Equipment

The production of iron and ferromanganese is unique within  the  steel
industry  because  it  is  the  only  process  in  which  iron bearing
material, limestone  and  coke  are  converted  into  molten  iron  or
ferromanganese.   While  many  refinements  have  been  made  to blast
furnaces to improve operating  efficiencies,  the  basic  process  has
remained unchanged.  The refinements include more stringent control of
the  quality  of  raw  materials,  reaction rates and times within the
furnace, the use of high top pressures, and oxygen and oil  injection.
However,  these  refinements  have  not  had  a major influence on the
quality or quantity of the wastewaters generated during the ironmaking
process  and,,  thus,   do  not  warrant  further  subdivision  of  this
subcategory.                                                        f

Final Product

Various grades of iron may be produced in a blast furnace (e.g., basic
iron,  ferromanganese, alloy iron), however, over the past decade more
than 99% of the iron produced in this country was  basic  iron.   Less
than  1  percent  of  total blast furnace production was attributed to
ferromanganese production.  A review of the DCP data reveals that only
five U.S.'blast furnaces have historically produced  iron  other  than
pig  iron  and  these  furnaces  produced only ferromanganese.   Two of
these five furnaces produced over 95% of the  ferromanganese  made  in
this  country.   At this writing, there are no ferromanganese furnaces
in  operation.   The  subdivisions   already   noted   recognize   the
differences between iron and.ferromanganese blast furnaces.
                                   329

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Raw Materials

The  major  raw  materials   used   for   ironmaking   are  coke,  iron  ore,
limestone, pellets,  and  sinter.    Secondary   raw   mate-rials  include
scrap,  gravel,  tars   and  oils of various  types, mill  scale,  flux and
.dolomite.  Following is a summary  of the  major  raw  materials   used  in
the iron furnaces:
          Feed
          Material

          Coke
          Iron Ore
          Pellets
          Sinter
  Mean
of Burden

  26.1
  14.0
.  38.8
  23.7
Mean Ib/ton
of Hot -Metal

   1 ,259
     744
   1,811
   1 ,096
For  the  one   ferromanganese   furnace,   the   raw material  composition
consisted of coke  (36%),  ferromanganese  ore   (47%),   stone   (12%)   and
other  materials   (5%).   The use  of  large quantities  of  ferromanganese
ore  in the production   of  ferromanganese  iron   was   a   factor   which
distinguishes   this  process   from  the  basic iron process.   Other  raw
material differences are  minor and;,  as such,  do   not   warrant further
subdivision of  the ironmaking  subcategory.

Wastewater Characteristics

Ironmaking  process wastewaters result from cleaning  (i.e.,  scrubbing)
and  cooling the dirty  furnace  exhaust gases.   These gases are cleaned
to   a  high  degree  and  cooled  so  that they may be  reused as fuel to
preheat the air charged to  the furnace and, in a number  of   instances,
for  steam production.

The  gas streams contain  dust, quantities of  raw materials  and process
reaction products  including many   pf the  same   pollutants  found   in
cokemaking  wastewaters.    The phenolic  pollutants found in ironmaking
wastewaters are attributable   to   the  coke   used  in  the   ironmaking
process.   Cyanide and  ammonia   (reaction products  formed within  the
furnace or transferred from the coke charge to the furnace  gases)   are
carried  over   with  the  gas   stream  and transferred to the scrubber
waters.  Several types of wet  gas cleaning systems are   used  in  the
ironmaking  subcategory  (e.g.,  venturi scrubbers, adjustable orifice
scrubbers, separators,  'spray   chambers).  The   subdivisions already
noted  recognize the differences  between iron and ferromanganese blast
furnace wastewaters.   Subdivision pn the basis  of the   type of  gas
cleaning system is not -warranted.

Wastewater Treatability

The  basic ' treatment   in place in. ironmaking wastewaters includes  the
removal of suspended solids by gravity sedimentation  and the  recycle,
to   the  scrubbers,  of  90 to 95% of. the wastewaters after cooling in
evaporative  cooling   towers.     Other    pollutants   (e.g.,  metals)
associated  with the suspended solids are also removed by the settling
                                     330

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process.  The quality and'treatment of blast  furnace  wastewaters   is
similar  throughout  the  subcategory and, as a result, subdivision  on
the basis of wastewater treatability is not warranted.  The same  type
of  treatment  was  provided  for  the previously noted ferromanganese
furnace.

Size and Age

The Agency considered the impact of the size  and  age  of  ironmaking
operations  on  the  subdivision  of  the ironmaking subcategory.  The
Agency determined that age  is  of  little  importance  because  blast
furnaces  require  periodic  major rebuilding, typically every five  to
ten  years.   These   major   rebuilds   often   include   substantial
modifications  to  the furnace which, in  many cases, is comparable  to
the construction of a new furnace. . Most existing blast furnaces  have
been  rebuilt  many  times,  and some furnaces originally built in the
early 1900's are still operating today.  As ;the furnaces are  rebuilt,
various  technological  and production advancements are implemented  to
improve furnace operation and gas cleaning.

Figure IV-1 is a plot of effluent flow vs. plant age for  plants  with
treatment  and  .recycle  facilities.   This  diagram demonstrates that
there is no correlation between effluent flow and plant  age,  notably
at  flows  less  than 125 gal/ton (the BPT model flow).  Effluent flow
provides a measure of treatment capability, as recycle is one  of  the
major treatment components used in developing the BPT, BAT, NSPS, PSES
and  PSNS  alternative  treatment  systems and the respective effluent
limitations and standards.

Although the age of a blast furnace is difficult to define, the Agency
investigated the  effect  of  age  on  the  feasibility  and  cost   of
retrofitting  pollution  control equipment.  The comparison of the age
of a blast furnace with the year in which pollution control facilities
were installed (see Table IV-1), demonstrates that  pollution  control
equipment ?has  been  retrofitted  at  the  oldest furnaces.  As noted
above,  similar rates of pollutant discharge are  achievable  at  blast
furnaces  of  all  ages.   As  a result,  the Agency has concluded that
retrofitting pollution control facilities to both old  and  new  blast
furnaces is feasible.

The  cost  of  retrofitting  the  BPT  systems  to blast furnaces were
provided by industry in DCP responses.   The data  show  that  retrofit
costs  amount  to  about  5  percent  of the total capital cost of the
pollution control equipment.  In addition, as shown in Section VIII  of
this report, comparison of actual costs incurred by industry with  the
Agency's  estimated  costs  for the same pollution control facilities,
demonstrates that the Agency's estimates are sufficient to account for
retrofit and other site-specific costs.   The  Agency  thus  concludes
that  the  cost  of  retrofitting pollution control equipment at blast
furnaces is not  significant.    Since  more  than  90%  of  the  blast
furnaces  have  been  retrofitted  with  BPT  water  pollution control
systems, the feasibility of retrofitting the BPT wastewater  treatment
system  is well demonstrated.   Compliance with-BAT, on the other hand,
                                    331

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will require the installation of add-on treatment  systems  which,  in
most instances, will not involve any significant retrofit costs.

The  Agency  evaluated  the question of size by plotting effluent flow
vs. production (Figure IV-2).  This diagram demonstrates that there is
no relationship between effluent flow and plant size as  indicated  by
treatment and recycle facilities.  It also demonstrates that the lower
flows  (representative  of  BPT and BAT model systems) are achieved at
blast  furnace  operations  with  high  production  as  well  as   low
production.  The Agency found that many plant sites have several blast
furnaces.   These  furnaces  range  from old to new, and from small to
large capacity.                    .              ...     .  ,

Based upon the above,  the  Agency  finds  that  both  old  and  newer
production   facilities  generate  similar  raw  wastewater  pollutant
loadings; that pollution control  facilities  can  be  and  have  been
retrofitted  to  both  old  and  newer  production  facilities without
substantial retrofit costs; that these  pollution  control  facilities
can  and  are  achieving  the same effluent quality; and, that further
subcategorization or further segmentation within this  subcategory  on
the basis of age or size is not appropriate.

Geographic Location

Location  has  no  effect  upon  subdivision.  Most blast furnaces are
located in the  predominant  steel  producing  areas   (e.g.,  Chicago,
Pittsburgh,  Cleveland).   A  few  plants  are located in water scarce
areas and, as a result, these plants use  operational  methods  (e.g.,
wastewater  recirculation)  which  conserve water.  As .of July  1, 1978
about 54 percent of the plants  (distributed  throughout  the  country)
had been retrofitted with recycle systems.  Currently, recycle systems
are  installed  at  about  90  percent  of  the  blast furnaces in the
country.  Of the 4 plants located in "arid" and "semi-arid"  areas,  3
plants  have  installed and one operating recycle systems.  The fourth
plant is currently installing  a  recycle  system.  ' Also,, wastewater
quality  among  the  plants  surveyed   is similar and, of the surveyed
plants, one is located in an arid or  semi-arid  region,  one   in  the
southwest, and the others in the midwest and east.

Process Water Usage

The  Agency  examined  process  water   usage  as  a possible basis for
further subdivision.  The data  indicated that process  wastewater  flow
had no significant impact on the ability to treat process wastewaters.
In  fact, many of the plants with the highest applied  flows have  lower
discharge flows than plants with  lower applied  flows.   Based  upon
these  factors,  the  Agency concluded  that further subdivision of the
ironmaking  subcategory  based  upon  process  water   usage   is   not
warranted.
                                    332

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                                TABLE IV-1

                           EXAMPLES OF RETROFIT
                          IRONMAKING SUBCATEGORY
Blast Furnace
0060B
0112
0112A
0320
0384A
0396A
0396C
0426
043 2A
0432B
0528A
0584C
0584D
0684F
0684G
0684H
0724A
08561
0860B
0860H
0920B
Plant Age

1942
1943
1941
1920-1947
1907
1907-
1903-
1958
1910-
1900-
1954
1956-
1904-
1908
1906
1943
1902
1901
1908
1928
1913
                                                    -1909
                                                    -1905

                                                    -1919
                                                    -1966

                                                    -1961
                                                    -1911
Treatment
   Age

1958
1962
1948
1976
1976
1929
1929
1979
1951
1930
1977
1965
1953
1970, 1977
1971
1971
1974
1956,1970
1980
1968,1972
1976
                                   333

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                         FIGUREIZ-I
             BLAST FURNACE-RECYCLING PLANTS
   o
   ID.
   <0
   o>

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   ea
   (O
                       BPT Level
   1880    1892     1905    1917    1930    1942    1955     1967    1980


   AGE (FIRST YEAR OF PRODUCTION  OF OLDEST FURNACE AT PLANT)
                               334

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                             FIGURE rZ-2
                 BLAST FURNACE-RECYCLING PLANTS
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                        IRONMAKING SUBCATEGORY

                              SECTION V

              WATER USE AND WASTEWATER CHARACTERIZATION
Introduction        .  . •

This  section  presents  data  which  characterize  wastewater streams
originating in blast furnace operations.   These  data  were  obtained
during the field sampling programs conducted at one ferromanganese and
eleven  iron  blast  furnace operations.  During the original sampling
program the Agency measured the levels of the pollutants limited under
the originally promulgated effluent  guidelines.   During  the  second
field  sampling  program  the  levels  of  those pollutants were again
measured,  while  additional  monitoring  was  performed   for   toxic
pollutants.   To  confirm  and  expand upon the-toxic pollutant survey
data, the Agency conducted sampling visits at three  additional  blast
furnace  sites  (plants  0112, 0684F, and 0860H).  The Agency included
data from these visits in the existing data base.  The.Agency did  not
observe  any  significant  differences  in  the basic character of the
process wastewaters during these visits.

Description of_ the- Ironmaking Operation and Wastewater Sources

The  water " use  rates  discussed . below  pertain  only   to   process
wastewaters,  and  do  not  include  noncontact  cooling or nonprocess
waters.  Process wastewater is defined as water which  has  come  into
direct  contact:  with  the  process,  products,  exit  gases,  and raw
materials associated with blast furnace operations.  The  wastewaters,
thereby, become contaminated with the pollutants characteristic of the
process.   Noncontact  cooling water, is defined as that water used for
cooling which does not come into direct contact  with  the  processes,
products,  by-products, or raw materials.  Nonprocess water is defined
as that water which is used in  nonprocess  operations,  such  as  for
utility and maintenance requirements.

Water is used within the blast furnace operation for two purposes: (1)
to  cool  the  furnace,  stoves,  and ancillary facilities, and (2) to
clean  and  cool  the  furnace  top  gases.   Although  blast  furnace
wastewaters  are  primarily the result of the gas cleaning and cooling
processes, there are other  wastewaters  sources.   During  the  plant
visits,  the  Agency  found  additional  wastewaters  from a dekishing
operation  (plant  0432A),  which  treated  these   wastewaters   with
sintering  wastewaters,  and  from  a slag quench wastewater treatment
operation  (plant 0112D).  Other miscellaneous waters,  such  as  floor
drains  and  drip  legs,,  are  also  included   as  part of the process
wastewaters, but, as mentioned above,  the  gas  scrubber  and  cooler
wastewater is the primary and most important wastewater.
                                   337

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The  industry  provided  process  wastewater and treated effluent flow
data in the DCP responses.  In many instances these data were reported
as measured  values,  but  some  were  reported  as  best  engineering
judgment  or  design  values.    In  most  instances  DCP flow data are
presented in the summary table; however, where available, plant  visit
or  D-DCP information was used in lieu of the DCP data.  Plant process
wastewater flows varied over a wide range (1034 to 6708 gal/ton)  and,
likewise,  plant  effluent  flows also spanned a wide range (0 to 3902
gal/ton).  This wide range in  flows  can  be  attributed  to  several
factors,  but  scrubber design and efficiency, the number of scrubbers
used, and gas cooling requirements generally are the principal factors
influencing water  usage.   The  effluent  flow  rates  are  primarily
determined  by the amount of recycle employed.  There is no indication
that the industry adjusts process  water  usage  to  meet  reduced  or
increased   production   demands,  except  to  the  extent  that  such
production changes affect the number of furnaces  in  operation  at  a
given plant.

One  method  of  conserving  water  and  reducing  the  quantities  of
pollutants  discharged  is  recycle.   Recirculation   of   ironmaking
wastewaters is currently practiced at about 90% of the plants and is a
major   component   in  the  BPT  model  treatment  system.   Although
recirculation may result  in  an  increase  in  the  concentration  of
certain dissolved inorganic pollutants in the recycled wastewater, the
significant  reduction  in  discharge  flow which results from recycle
reduces the total pollutant load discharged.

Blast  furnace  wastewaters  contain  suspended  particulate   matter,
cyanide,  phenols  and  ammonia;  all  of which are limited by current
NPDES permits.  Other wastewater pollutants include toxic  metals  and
certain  toxic organic pollutants which originate in the raw materials
or are formed during the reduction process.   The  concentration  data
presented  in  Tables-  V-l  through  V-4  provide  a  measure  of  the
significant  pollutants  contributed  during  each  pass  through  the
process.   After  reviewing  the  data, the Agency determined that the
effect of makeup water quality on  these  wastewaters  is  negligible.
Accordingly,  the  effluent limitations and standards are based solely
on gross values.  Refer  to  Section  VII  for  a  further  discussion
regarding this issue.
                                    338

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                                         TABLE V-l

                       SUMMARY  OF  ANALYTICAL  DATA FROM SAMPLED PLANTS
                                ORIGINAL  GUIDELINES  SURVEY
                       	IRON  MAKING BLAST  FURNACES	

             Pick-up per pass concentrations (mg/1) in raw process wastewaters
Reference Code           0946A       0396A         0448A
Plant Code               L           M             N
Sample Point(s)          l-(6+8)     l-(2+4)       l-(2+5)
Flow, gal/ton            5,400       .2,057         3,350

    pH (Units            6.6         7.1-8.3       6.6
    Ammortia (as N)       1.19        2.70          7.98
    Fluoride             0.15        1.3           2.24
    Phenols (4AAP)       0.120       -             0.529
    Suspended Solids     72          611           306
121 Cyanide (Total)      1.4.2        0.806         1.68
0060F
0
l-(4+5)
3,123

7.4-7.5
10.1

0.085
1,167
Average

6.6-8.3
5.49
0.92
0.184
539
0.976
-:  Calculation results in a negative value.  Negative values were
    considered zero in the determination of the averages.
                                            339

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                                           TABLE V-2

                      SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
                                  TOXIC POLLUTANT SURVEY
                               IRON MAKING BLAST FURNACES
Pick-up per pass concentrations (mg/1) in raw process wastewaters
Reference Code 0196A
Plant Code 021
Sample Point (s) (B-D)
Flow, j?al/ton 1280

pH 8.4-8.9
Ammonia (N) 20.4
Fluoride 2.6
Phenols (4AAP)
Suspended Solids 3502
9 Hexachlorobenzene 0.155
23 Chloroform
31 2,4-Dichlorophenol ND
34 2,4-Dimethylphenol ND
39 Fluoranthene 15.955
55 Naphthalene 0.014
65 Phenol 2.135
73 Benzo(alpyrene 14.198
7 6 Chr y s ene 0.420
80 Fluorene
84 Pyrene 15.104
114 Antimony NA
115 Arsenic NA
118 Cadmium 0.036
119 Chromium 0.040
120 Copper 0.099
121 Cyanide (Total) 15.8
122 Lead 53.5
124 Nickel 0.100
125 Selenium NA
128 Zinc 59.9
0112D
026
(G+K)-(I+M+N
1567
i.
6.4-7.1
16.3
-
0.052
386
ND
-
ND
0.0
0.0
0.012
ND
-
0.015
0.021
0.003
NA
NA
0.010
0.046
-
0.008
0.096
0.013
NA
4.55
- : Calculation results in a negative value.
zero in the determination of
NA: No analysis performed
ND: Not detected
the averages


0432A
027
) (C-A)
3091

9.2-9.7
17
6.5
2.91
1610
ND
0.018
ND
0.053
0.082
ND
0.595
0.0
0.0
0.006
0.053
0.033
0.044
0.067
0..067
0.112
12.0
4.67
0.0
0.061
19.9
Negative
•


0684H
028
B-(A+C)
2277

6.9-12.1
10.4
1.8
0.68
1599
ND
-
0.200
0.0
-
—
-
ND
ND
ND
—
NA
NA
0.146
0.628
1.14
0.080
23.2
1.15
NA
29.7
values were






Average

6.4-12.1
16.0
2.7
0.910
1774
0.039
0.004
0.050
0.013
4.009
0.006
0.682
3.550 -
0.109
0.007
3.790
0.033
0.044
0.065
0.195
0.338
6.97
20.4
0.316
0.061
28.5
considered





Overall/.. *
Average

6.V-12.1
10.8
1.8
0.547
1157
0.039
0.004
0.050
0.013
4.009
0.006
0.682
3.550
0.109
0.007
3.790
0.033
0.044
0.065
0.195
0.338
3.97
20.4
0.316
0.061
28.5




(1) Average of all values on Tables V-l and V-2.
                                             340

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                                TABLE V-3

              SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
                        ORIGINAL GUIDELINES SURVEY
              	FERROMANGANESE  BLAST FURNACE	

    Pick-up per pass concentrations  (mg/1) in raw process wastewaters
Reference Code
Plant Code
Sample Point(s)
Flow, gal/ton

    pH (Units)
    Ammonia (as N)
    Manganese
    Phenols (4AAP)
    Suspended Solids
121 Cyanide (Total)
Gas Scrubber

0112C
Q
2-(4+1)
2.233

12.1-12.2

2,946

17,193
Gas Cooler

0112C
Q
5-4
5,705

8.6—8.7
136
5.41
0.461
50
105
    Calculation results  in a negative value.
                                    341

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                                TABLE V-4

              SUMMARY OF ANALYTICAL :DATA FROM SAMPLED PLANTS
                          TOXIC  POLLUTANT  SURVEY
             	FERROMANGANESE BLAST FURNACE	

    Pick-up per pass concentrations (mg/1) in raw process wastewaters
Reference Code
Plant Code
Sample Points
Flow, gal/ ton

    Ammonia (as N)
    Manganese
    Phenols (4AAP)
    Suspended Solids
4   Benzene
23  Chloroform
55  Naphthalene
85  Tetrachloroethylene
86  Toluene

115 Arsenic
117 Beryllium
119 Chromium
121 Cyanide (Total)
122 Lead
127 Thallium
128 Zinc
0112C
025
(B+D) - (C+E)
11.540

25
79
0.142
3750
8.8-11.3

0.013
0.018
0.015
0.055
0.010

1.74
0.003
0.047

0.737
0.045
4.41
-:  Calculation results in a negatiye value.
                                     342

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                        IRONMAKING SUBCATEGORY

                              SECTION VI

                        WASTEWATER POLLUTANTS
Introduction                                                   •

This section presents the pollutants which the Agency determined to be
characteristic  of  ironmaking  process wastewaters, the rationale for
their selection and the sources of these pollutants.  First, a list of
pollutants considered to be characteristic  of  ironmaking  operations
was  developed based upon data gathered during the original guidelines
survey and from the DCP responses.   The  Agency  confirmed  that  the
initial,  list of pollutants was appropriate and added other pollutants
by reviewing monitoring  data  gathered  during  the  toxic  pollutant
survey.

Conventional Pollutants

The   originally   promulgated   BPT   effluent  limitations  included
limitations for total suspended solids and pH.   The  Agency  selected
total  suspended  solids  because  of  the  substantial  quantities of
particulates found in the ironmaking process wastewaters.

The Agency limited pH because it  is  a  measure  of  the  acidity  or
alkalinity  of  wastewater  discharges.   In  addition  to  its direct
adverse environmental  impacts,  extremes  in  pH  can  aggravate  the
adverse  effects  of  other  pollutants such as ammonia-N and cyanide,
influence corrpsion rates and affect process and wastewater  treatment
system  operations.   The  pH  of  ironmaking  process  wastewaters is
typically in the neutral to slightly alkaline range.

Nonconventional, Nontoxic Pollutants

In both iron and ferromanganese blast furnace operations,  ammonia  is
present  in the furnace exit gases and in furnace process wastewaters.
Ammonia is present as a result of the various nitrogen  compounds which
are driven out of the coke charge  during  blast  furnace  operations.
Fluoride  is  present in ironmaking process wastewaters as a result of
the fluoride compounds, primarily calcium  fluoride,  present   in  the
limestone  charged  to  the  furnace.   The  presence   of manganese in
ferromanganese blast furnace wastewaters  is related  to  the type of ore
used  in ferromanganese furnace operations.  Limitations for  ammonia-N
were  included in the previous regulation.

Toxic  Pollutants

Cyanide  is  generated  in the reducing atmosphere  of the furnace  as  a
.result of the reaction of nitrogen in the blast air  with  carbon   from
the   coke  charge.   Larger quantities of cyanide are generated at the
                                    343

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higher temperatures  associated with  ferromanganese  furnaces.   Phenolic
compounds are driven out of   the   coke   charge  during   blast   furnace
operation,   Toxic   phenolic  pollutants  were  limited  indirectly in  the
originally promulgated regulation  by the limitations  established   for
phenols  (4AAP).

The  Agency  also  considered othet toxic   pollutants  found  in blast
furnace  wastewaters.  The Agency determined the pollutants  existing  in
these process wastewaters on  the basis of  responses to the  DCPs,   and
analyses  performed  during the screening  phase of  the project.  Table
VI-1 presents these  pollutants.

The Agency evaluated relevant data   regarding  these  pollutants   and
calculated  net  concentration values (reflecting the pollutant pickup
through  the process  as described in   Section  V)  for  each  pollutant
detected in the raw  process wastewaters.   Those pollutants  found at  an
average  net  concentration of less  than 0.010 mg/1 were excluded from
further  consideration.   A   list    of   pollutants,   including    the
conventional  and  nonconventional   pollutants,  detected   in   the  raw
process wastewaters  at net concentrations  of  0.010  mg/1  or  greater  are
presented in Table VI-2.

The  toxic  metal  pollutants detected   in   the  process  wastewaters
originate in the raw materials (primarily  the ores  and sinter)  charged
to  the  furnaces.   These pollutants are  present in the blast  furnace
exit gases and contaminate the process   wastewaters  during  scrubbing
and  cooling  operations.   The  predominant  toxic  metal pollutants  in
ironmaking  process  wastewaters   are lead   and  zinc.   For   details
pertaining  to  the  selection of pollutants considered for  limitation,
refer to Sections X  through XIII.

Although several toxic organic pollutants  are included in the  list   of
pollutants presented in Table VI-1,  Table  VI-2 does not  include all  of
these   pollutants.    The    Agency   excluded certain   toxic   organic
pollutants from Table VI-2 (i.e., phthalates) because it believes that
those pollutants are artifacts  (i.e.,   resulting   from  sampling  and
laboratory   procedures),   which    are  unrelated  to   blast   furnace
operations.   The presence of  the remaining toxic organic pollutants  is
attributable  to  the  raw  materials  charged  (primarily,  the  coke
charge).    These  pollutants  can  be  controlled   by  limiting other
pollutants.

Other pollutants (e.g., calcium,  chloride) are present at  substantial
levels in the process wastewaters,  but are not included  in the  list  of
selected pollutants  since they are nontoxic in nature and difficult  to
remove.   Treatment of these pollutants in  wastewater discharges is not
commonly practiced in any .industry.
                                    344

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                               TABLE  VI-1

                 TOXIC  POLLUTANTS  KNOWN TO BE  PRESENT
   Iron Blast Furnaces

    Phenols(4AAP)
4   Benzene
9   Hexachlorobenzene
23  Chloroform
31  2,4-dichlbrophenol
34  2,4-dimethylphenol
39  Fluoranthene
65  Phenol
73  Benzb(a)pyrene
76  Chrysene
84  Pyrene
85  Tetrachloroethylene
86  Toluene
114 Antimony
115 Arsenic
118 Cadmium
119 Chromium
120 Copper
121 Cyanide (Total)
122-Lead
124 Nickel
125 Selenium
128 Zinc
Ferromanganese Blast Furnaces

         Phenols(4AAP)
     4   Benzene
     23  Chloroform
     55  Naphthalene
     65  Phenol
     85  Tetrachloroethylene
     86  Toluene
     115 Arsenic
     117 Beryllium
     119 Chromium
     121 Cyanide (Total)
     122 Lead
     127 Thallium
     128 Zinc
                                  345

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                               TABLE  VI-2

                          SELECTED POLLUTANTS
   Iron Blast Furnaces

    pH
    Ammonia (as N)
    Fluoride
    Phenols (4AAP)
    Suspended Solids
9   Hexachlorobenzene
31  2,4-Dichlorophenol
34  2,4-Dimethylphenol
39  Fluoranthene
65  Phenol
73  Benzo(a)pyrene
76  Chrysene
84  Pyrene
114 Antimony
115 Arsenic
118 Cadmium
119 Chromium
120 Copper
121 Cyanide (Total)
122 Lead
124_Nickel
125 "Selenium
128 Zinc
Ferromanganese Blast Furnaces


    PH   .
    Ammonia (as N)
    Manganese
    Phenols (4AAP)
    Suspended Solids
4   Benzene
23  Chloroform
55  Naphthalene
85  Tetrachloroethylene
86  Toluene   "
115 Arsenic
117 Beryllium
119 Chromium
121 Cyanide (Total)
122 Lead,
127 Thallium
128 Zinc
                                   346

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                        IRONMAKING SUBCATEGORY

                             SECTION VII       '

                   CONTROL AND TREATMENT TECHNOLOGY
Introduction

A review of the control and treatment technologies currently in use or
available for use for ironmaking operations provided the basis for the
selection  and  development  of  the  BPT,  BAT,  NSPS,  PSES and PSNS
alternative treatment systems.  DCP, D-DCP, and plant visit data  were
reviewed  to identify those treatment components and systems currently
in use.  Treatment capabilities, either demonstrated  in  this  or  in
other  subcategories  (refer  to Volume I), were used by the Agency in
evaluating  the  various  model  wastewater  treatment   technologies.
However,  only  well  demonstrated  technologies  were used to develop
effluent limitations and standards for ironmaking operations.

This section also presents the raw  wastewater  and  treated  effluent
monitoring  data  from  sampled  plants,  pilot plant studies, and the
monitoring data provided by the industry through D-DCP  responses  and
responses  to  supplemental questionaires issued in response to public
comments on the  proposed  regulation.   Thj.s  section  also  presents
descriptions  of  treatment  systems at each of the sampled plants and
examines, in detail, the effect of make-up water quality on raw  waste
loadings.                                            •

Control and Treatment Technologies           ,

As noted earlier, ironmaking wastewaters result primarily from furnace
top  gas  cleaning  and  cooling.    Other  wastewater  sources  may be
included; however, these.sources comprise only a minor portion of  the
total  pollutant  load.    Although  the  typical ironmaking wastewater
treatment  systems  were  initially  designed  for  the   removal   of
particulate matter only, other pollutants, (i.e., ammonia, cyanide and
phenols)  are  pr.esent  in  these  wastewaters  and require treatment.
Following is a summary of actual treatment practices as determined  by
the  Agency  through  plant  visits and DCP responses (refer to Tables
III-l and III-2).

a.   The initial step in the treatment of  ironmaking  wastewaters  is
     the  removal  of  suspended  solids.   All  of  the  plants use a
     thickener (or similar gravity sedimentation component) to  remove
     suspended  solids  from process wastewaters.  The technology also
     partially removes other pollutants which  are  entrained  in  the
     suspended solids (e.g., the toxic metals).

b.   The slurry from the bottom  of  the  thickener  is  dewatered  by
     various devices.  Vacuum filters are used at most plants f,or this
     purpose.
                                   347

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g
h,
In order to improve solids removal performance in the thickeners,
coagulant aids such as polymers and ferric chloride are added  to
the  wastewater  stream  at the thickener inlet.  These coagulant
aids enhance solids removal by aiding in the formation of larger,
more readily settleable particles.  This technology also  results
in  a  certain  degree  of  toxic pollutant removal as pollutants
entrained in the solids are removed.  Coagulant aids are used  at
over three-fourths of the plants.

At  five  plants,  the  thickener/clarifier  overflow  is  reused
elsewhere.   One  method  of  reuse  involves  the  mixing of the
thickener effluent with incoming fresh water for use  in  various
process  or cooling applications throughout the plant, as well as
for*makeup to the blast furnace gas cleaning and cc-cling systems.
In these operations, the reused water is  discharged  at  various
points  throughout the plant.  Reuse of the effluent in the plant
water system results in the dilution of the wastewater  and  does
not  result  in  the  removal  of the pollutants contained in the
wastewater.

In order to conserve water and to reduce  effluent  waste  loads,
most  plants  employ  systems  in  which  a  large portion of the
process wastewater is,recycled.  Recycle is now practiced or will
shortly be practiced at about 90% of the plants.   In  the  basic
recycle  system, the thickener effluent is recirculated through  a
cooling tower to the gas cleaning and  cooling  operations.   The
wastewater  discharge  in  these  instances consists of a blowdown
from the thickener effluent or from the cooling  tower  eftluent.
As  noted  above,  the  sludge  which settles  in the thickener is
dewatered by a vacuum filter and  the filtrate  is returned to  the
thickener   influent.    In  treatment  and  recycle  operations,
flocculation,  sedimentation  and  recycle   provide   the   most
significant  means  of  pollutant  load  reduction, although some
oxidation and air stripping may occur in the cooling tower.

Chlorination is used at several   plants  to  reduce  cyanide  and
phenol   levels.    At  one  plant,  the  thickener  influent  is
chlorinated and discharged without recycle.    At   another  plant,
the  thickener  effluent   is  recycled  after  passage  through  a
cyanide destruction  system   (alkaline  chlorination).   Both  bf
these plants were sampled  during  this study, and the latter plant
exhibited  the  capability   to significantly reduce the levels of
ammonia, cyanide, and phenol. : Alkaline chlorination systems have
been  installed  at  several  plants  to  treat  recycle   system
blowdowns.

The blowdowns from two recycle systems are discharged  to PQTWs.

The blowdowns from recirculation  systems at  five plants are  used
to  quench  slag  or  coke,  or are evaporated  in EOF hoods.  This
treatment arrangement,, under  careful control,  can   eliminate   the
discharge of pollutants  into  receiving waters.
                                    48

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Control and Treatment Technologies for BAT, NSPS, PSES and PSNS

Several  toxic  pollutants  were found in the treated effluents of the
sampled plants at concentrations greater than 0.5  mg/1.    Because  of
high  discharge  levels  and  pass through of pollutants-at POTWs, the
Agency has promulgated BAT limitations and NSPS, PSES,  and  PSNS  for
these  toxic  pollutants.   The effluent limitations and standards are
based upon the application levels of treatment beyond that 'for BPT.  A
description of the treatment technologies considered by the Agency for
BAT, NSPS, PSES and PSNS is set out below.

Filtration

Filtration is a common and  effective  method  of  removing  suspended
solids  and those pollutants (particularly the toxic metals) which are
entrained in these solids.  Filtration can be used as the  last  major
component in a treatment system or may be used to provide pretreatment
prior  to  another  component  (such  as  an activated carbon system).
Generally, the filter bed is comprised of one  or  more  filter  media
(e.g.,  sand,  anthracite, garnet) and a variety of filtration systems
are available (flat bed, deep bed, pressure  or  gravity).   As  noted
above,  filtration  can  be  used  to  reduce the discharge of certain
insoluble toxic pollutants, (the non-dissolved toxic metals).  However,
other toxic pollutants, such as ammonia-n, cyanide and  phenols,  will
not  be  removed  from  the  process  wastewaters  by this technology.
Filtration is used in a wide variety of steel  industry  applications,
including  three  central treatment facilities (one was sampled) which
treat- ironmaking wastewaters.

Toxic Metals Removal Using Sulfide Precipitation

Sulfide precipitation  has  been  shown  to  be  capable  of  reducing
effluent  toxic  metals  concentrations substantially below the levels
achieved in lime flocculation and precipitation systems.  Some of  the
toxic  metals  which  can effectively be precipitated with sulfide are
zinc, copper, nickel and lead.  The increased removal efficiencies can
be attributed to:the comparative solubilities of  metal  sulfides  and
metal  hydroxides.   In  general,  the metal sulfides are less soluble
than the respective metal hydroxides.  However, an excess  of  sulfide
in  a  treated  effluent can result in objectionable odor problems.  A
decrease  in  wastewater  pH  will  aggravate  this  problem,  and  if
wastewater  treatment  pH  control  problems result in even a slightly
acidic pH,  operating  personnel  can  be  affected.   One  method  of
controlling  the  presence  of  excess sulfide in the treated effluent
involves feeding an iron sulfide slurry.   Ferrous  sulfide  will  not
readily dissociate in the waste stream, ensuring that the free sulfide
level  is kept below objectionable levels.  However, the affinities of
the other metals in the waste stream for sulfide are greater than that
of iron,  which  causes  other  metal  sulfide  precipitates  to  form
preferentially  to iron sulfide.  Once the sulfide requirements of the
other metal precipitates are satisfied, sulfide remains as  a  ferrous
precipitate  and the excess iron from the sulfide is precipitated as a
hydroxide.  With the use of  filtration  following  sulfide  addition,
                                   349

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significant  toxic  metals  load  reductions can be achieved.  Sulfide
precipitation is not used for the treatment of BPT  effluents  in  the
ironmaking subcategory.

Alkaline Chlorination

Certain nonconventional and toxic pollutants are amenable to treatment
by  oxidation  reactions.   Because  it is well demonstrated on a full
scale basis within the ironmaking subcategory, the  Agency  considered
two-stage alkaline chlorination as an alternative treatment technology
at  the  BAT,  NSPS,  PSES  and  PSNS  levels  of treatment.  Alkaline
chlorination involves the addition of  chlorine  (a  strong  oxidizing
agent)  to  process  wastewaters which already are, or which have been
adjusted,  to  an  alkaline  pH.   Chlorine  addition   is   typically
accomplished  by  the  eduction  of  the  gas into a pumped wastewater
sidestream which is returned to  the  treatment  process,  or  by  the
addition  of  a liquid such as sodium hypochlorite to the wastewaters..
The oxidation reduction  potential  (ORP)  of  the  wastewaters  being
treated  is  measured  during  treatment  to  monitor  and control the
alkaline chlorination treatment process.

Two-stage alkaline chlorination is used primarily to destroy, ammonia,
cyanide,  phenols,  and   other   toxic   organic   pollutants.    The
end-products of the cyanide destruction reactions are CO2 and N2.  The
end-products  of  the oxidation of ammonia are principally N2 and H2O,
while the end-product of phenols oxidation is CO2.

While alkaline chlorination is an effective means of removing ammonia,
cyanide, and phenols,  it  can  produce  toxic  organic  compounds  at
undesirable  levels.   These  compounds,  primarily  halomethanes, are
by-products of the reaction between chlorine and certain  constituents
(precursors) in the ironmaking wastewaters.  Studies conducted by both
the  Agency  and  industry  on  blast  furnace  wastewaters treated by
alkaline chlorination show varying levels  of  halomethane  formation.
The  data indicate that formation of halomethanes is largely dependent
upon the  treatment  configuration  and  the  presence  of  precursors
(measured  as  suspended  solids).   Where  adequate  suspended solids
removal is achieved  prior  to  chlorination,  the  total  halomethane
concentration  found  in the chlorinated effluent is held to levels of
about 0.1 mg/1 (the  drinking  water  standard  for  trihalomethanes).
Studies  performed  at  potable  water  treatment  plants  resulted in
similar findings.

Monitoring conducted at Plant 0432A, where alkaline  chlorination  was
practiced on blast furnace wastewaters after suspended solids removal,
showed  that  only  low  levels (0.05 mg/1) of chloroform were formed.
No other halomethanes were detected.  Data from a  pilot  plant  study
conducted by U.S. Steel at Plant 0860B, indicate less than 0.1 mg/1 of
total  halomethanes  in  the  chlorinated effluent (Table VI1-8).  The
pilot facility included  pH  adjustment  and  clarification  prior  to
chlorination.  Data for full scale operation of the treatment facility
are  similar  to  the  pilot  scale  data.   Pilot  studies  were also
conducted by Metcalf & Eddy,  Inc,  for  EPA  using  single-stage  and
                                    350

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two-stage   alkaline   chlorination  systems,  with  and  without  air
stripping.  These studies again  demonstrated  that  the  system  with
suspended  solids  removal preceding chlorination had the lowest level
of  halomethane  formation  (total  halomethane  of   0.2   mg/1   and
trihalomethane of 0.06 mg/1).   This system also included air stripping
of  the  wastewater prior to the addition of chlorine.  Air stripping,
however, is not expected to have a significant effect on the  presence
of  precursors,  since studies conducted at water treatment facilities
indicate  that  aeration  prior  to  chlorination  has  no  effect  on
halomethane  formation.   Considering  the  available data, the Agency
believes  that  alkaline  chlorination  of  ironmaking  and  sintering
wastewater  preceded by removal of suspended solids will result in the
formation  of  only  low  levels  of  halomethanes  while  substantial
quantities of ammonia, cyanide, and phenols (4AAP) will be removed.

Dechlorination

To  minimize  the  potential  toxicity  of wastewaters which have been
chlorinated, the Agency  considered  dechlorination  to  reduce  total
residual  chlorine levels in the treated discharge.  Dechlorination is
practiced on a full scale basis at plant 0584C for a central treatment
facility which includes sintering and  ironmaking  wastewaters.   This
technology  is  also widely practiced in the electric power generation
and electroplating industries.  Reducing agents, such as  sulfites  or
sulfur  dioxide,  are  added to the chlorinated effluent in sufficient
quantities to react with the excess residual chlorine, thereby forming
nontoxic chlorides.

Removal of. Organlcs With Activated Carbon

Adsorption with activated carbon is widely used  for  the  removal  of
organic  pollutants  from  wastewaters.   This  technology  is used to
reduce the concentrations  of  oxygen  demanding  substances  in  POTW
effluents.   This technology is also used to remove organic pollutants
in industrial wastewaters including  those  from  petroleum  refining,
organic  chemical  manufacturing  and  cokemaking.  It should be noted
that several toxac organic pollutants found in ironmaking  wastewaters
are  also  found in cokemaking wastewaters.  This can be attributed to
the use of coke  in  the  ironmaking  process.   Activated  carbon  is
installed  on  a  full scale basis for the treatment of ironmaking and
sintering wastewaters at Plant 0860B.

Operating guidelines for the use of activated carbon specify that when
combined wastewater streams are being treated or where the  wastewater
to  be  treated has significant turbidity, clarification or filtration
is necessary to Achieve optimum  treatment  efficiency.   The  use  of
chemical  precipitation  and  diatomaceous  earth  filtration  may  be
necessary to achieve the clarity required for the removal of the toxic
organic pollutants which may be  present  at  low  levels.   Suspended
solids  control  is  also  necessary because particulates in water can
adsorb organic pollutants, and then release the organics after passing
through the carbon bed.
                                   351

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 Laboratory tests performed on single compound  systems  indicate  that
 processing  with  activated  carbon may achieve residual levels on the
 order of  1   microgram  per  liter  for  many  of  the  toxic  organic
 pollutants.    The  Agency believes that the following compounds (among
 others) respond well to adsorption: carbon tetrachloride,   chlorinated
 benzenes,    chlorinated   ethanes,  chlorinated  phenols,   haloethers,
 phenols, nitrophenols, DDT and  metabolites,   pesticides,   polynuclear
 aromatics and PCBs.

 The  pH  of  the wastewater to be treated must be controlled within the
 range 6-8  to minimize dissociation of both acid and  basic  compounds.
 Generally,   normal  pH  variations  within  the neutral range will not
 significantly affect the operation of activated carbon systems.

 Vapor Compression Distillation


 Vapor compression distillation is a  process   which  can  be  used  to
 achieve   zero  discharge.    In  this  process,   the  wastewaters   are
 evaporated resulting in the concentration of   non-volatile  pollutants
 and  .other  constituents in the wastewater to slurry consistency.   The
 steam distillate leaving the system is condensed and recycled back  to
 the  production  process for resue.   The slurry discharge  can be dried
 in  a  mechanical drier or allowed to crystallize in  a  small   solar  or
 steam-heated  pond  prior to final disposal.   One desirable  feature of
 the process  is its relative freedom  from  scaling.    Because  of   the
 unique  design  of  the  system,  calcium sulfate and silicate crystals
 grow  in solution as  opposed to depositing on  heat  transfer   surfaces.
 Economic  operation   requires  a  high  calcium  to sodium ratio (hard
 waters).

 Plant Visit  Data

 Table VII-1  provides  a legend for  the various   control   and   treatment
 technology   abbreviations  used   in   various   tables   throughout  this
 report.  Table VI1-2  presents a  summary  of  raw wastewater  and effluent
 data  for the iron  blast   furnaces   visited  in  conjunction   with   the
 original  guidelines   survey.    Table VII-3 presents  a  summary  of  all
 iron  blast furnace raw wastewater   data   collected   during   the  toxic
 pollutant survey,  and Table  VI1-4  presents  a summary of  the  respective
 effluent  data.    Table  VI1-5  presents a  summary  of  raw  wastewater  and
 effluent data  from a  ferromanganese blast furnace visited  during   the
 original  guidelines   survey.    Table  VII-6   presents : a  summary  of
 ferromanganese  raw wastewater  and  effluent  data   obtained  during   the
 toxic pollutant  survey.

 Table  VII-7  presents   a summary  of  the  effluent data provided  in  the
 D-DCPs.  Tables  VI1-8  and VI1-9 present summaries of pilot plant  data
 from  plant  0860B.    Table  VII-10  presents  a  summary of  long-term
 effluent data for  the  recycle  system  blowdown  at  plant  0860B.   This
 recycle  system  is the  same as the BPT treatment,model  system.  Table
VII-11 presents  a  summary  of  effluent   data  from  the  full-scale
                                   352

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alkaline  chlorination/activated  carbon  treatment  system  in use at
plant 0860B.    ."•-.-

Plant Visits

Iron Blast Furnaces

Following are summaries of the treatment in place at eight iron  blast
furnaces  visited  during  the original guidelines and toxic pollutant
surveys.  Plant schematics are found at the end of this section.

Plant L  (0946A) - Figure VII-1

Blast furnace gas cleaning system wastewaters are combined with sinter
plant  wastewaters  and  treated  by  sedimentation  in   a • thickener,
followed  by  alkaline  chlorination,  filtration and recycle with  the
blowdown being discharged to  a receiving stream.

Plant M  (0396A) z Figure VII-2

Blast  furnace  gas   cleaning system  wastewaters   are   treated    by
sedimentation  in  a  thickener,  evaporative   coolinland recycle.   A
portion  of  the thickener overflow is discharged to  a POTW while  most
of  the overflow is passed through a cooling  tower and recycled.

Plant N  (0448A) - Figure VII-3

Blast furnace gas cleaning  wastewaters  are  treated  by sedimentation in
a   thickener,  evaporative  cooling  and  recycle.   The  blowdown   is
completely  evaporated by slag and  in   coke   quenching,  and   EOF  hood
sprays.  There  is no  wastewater  discharge to receiving  waters.

Plant 0  (0060F) - Figure VII-4

Blast    furnace   gas  cleaning  .system  wastewaters  are  treated   by
sedimentation  in  a  thickener, evaporative cooling,   and  recycle.    An
electrostatic  precipitator  is used  following the  venturi  scrubbers  and
gas  cooler.    The   blowdown  is  completely  evaporated  by  slag and coke
quenching,  and: in EOF hood  sprays.   There is no  wastewater   discharge
to a receiving  stream.

Plant  021  (Confidential)

Wastewaters  from  individual  blast  furnace'  scrubbing   systems  are
 combined and treated by sedimentation in a   thickener,   acid  addition
 for  pH adjustment,  evaporative cooling and recycle.  A portion of the
 recycle water is  blown down.  , The  blowdown  is  'combined  with  other
 plant wastewaters and treated further at a central treatment facility.

 Plant 026 (01 1;2D) - Figure VII-5

 Blast  furnace?  gas cleaning system wastewaters are combined with slag
 pit quench  wastewaters  and  treated  by  pH  adjustment  with  acid,
                                     353

-------
 coagulation   with   polymer,   sedimentation  in  a  thickener,  evaporative
 cooling  and  recycle.   A portion  of  the  recycle water  is  blown  down   to
 a   central   treatment  facility which  receives  wastewaters  from several
 steelmaking  and  forming and  finishing operations.

 Plant  027  (0432A)  - Figure VIJ-6

 Blast  furnace gas  cleaning,  sintering,  and  dekishing   wastewaters  are
 combined  in a central treatment facility which  includes sedimentation
 in  a thickener,  and alkaline chlorination.    The   effluent from  the
 once-through treatment system is discharged to a receiving  stream.

 Plant  028  (0684H)  z Figure VII-7

 Blast  furnace gas  cleaning system wastewaters  are  treated  by aeration,
 pH  adjustment  with   lime,   chlorination,   coagulation  with  polymer,
 sedimentation in a thickener,  evaporative   cooling  and  recycle.   A
 portion  of the recycle water is  blowndown to a POTW.

 Ferromanqanese Blast Furnace             -

 Ferromanganese  blast   furnace   operations   are  similar to iron blast
 furnace  operations as  top gases  are cleaned using  the same types   of
 wet    scrubbers.    However,   major    differences  between iron  and
 ferromanganese furnaces with respect' to  raw  materials and   furnace
 operating  temperatures result   in   differences in process wastewater
 quality.  Ferromanganese furnaces produce higher levels  of  cyanide and
 manganese.

 Information    on   ferromanganese  furnaces  is   limited   because,
 historically  only   a  few furnaces in the U.S.   have   produced
 ferromanganese.  In fact, at the time of this  study only one   furnace
 was operational.   Recently this  remaining furnace was shut  down and  is
 not expected to  renew  operations i;n the forseeable  future.

 During   the   course of the original  guidelines  and toxic pollutant
 surveys, this  particular ferromanganese operation was surveyed twice.
 The  operation   was sampled a   second time  because  its wastewater
 treatment system had been upgraded since the first  visit.   The result
 of this  upgrading  was  that the operation ceased  discharging po.llutants
 to  the  receiving  stream.  Approximately 90  gal/ton of wastewater 1/ft
 the system-with  the filter cake  which was transported to   a   landfill
 for disposal.

A  brief  description   of this plant  under  the two  different treatment
 approaches is provided  below:

 Plant Q  (01120  -  Figure VII-8

Venturi  scrubber wastewater   treatment  included  sedimentation  in  a
 thickener    and    complete   recycle   to 'the   scrubbers.    Gas  cooler
wastewaters  were discharged  to a  receiving  stream without treatment.
                                    354

-------
Plant 025 (0112C) z Figure VI1-9

Venturi scrubber wastewater  treatment  included  sedimentation  in  a
thickener   and   complete  recycle  to  the  scrubbers.   Gas  cooler
wastewater treatment included sedimentation in a  thickener  with  the
thickener  effluent  being  completly  recycled  to the coolers.  This
plant had no wastewater discharge to a receiving stream.

Effect of Make-up Water Quality

Where the mass loading of a limited pollutant in the make-up water  to
a  process  is  small  in  relation  to  the raw waste  loading of that
pollutant, the impact of make-up water quality on wastewater treatment
System performance  is  not  significant,  and,  in  many  cases,  not
measurable.   In  these  instances, the Agency has determined that the
respective effluent limitations and standards should be developed  and
applied on a gross basis.

Table  VII-12  presents  an  analysis  of  the effect of make-up water
quality on the raw waste loadings  of each pollutant  limited   in  the
regulation  for  the ironmaking subcategory.  These data were obtained
from blast furnace sampling surveys completed  for  this  study.   The
analysis   clearly   demonstrates  that  the  levels  of  the   limited
pollutants in-;the intake waters are not significant  compared   to  raw
waste  loadings.  The  intake waters added  less than one percent to the
raw waste  loadings of  each limited pollutant.   Thus  the  Agency  has
determined  that  the  limitations and standards should  be applied on  a
gross  basis, except to the extent provided by 40 CFR 122.63th).
                                    355

-------
                       TABLE VII-1

         OPERATING MODES, CONTROL AND TREATMENT
            TECHNOLOGIES AND DISPOSAL METHODS

                         Symbols
A.      Operating Modes

        1.   OT

        2.   Rt,s,n
                    Once-Through

                    Recycle, where t
                       • \           3
                                   n
                                               type waste
                                               stream recycled
                                               % recycled
                                       U
                                       T
                                                   Untreated
                                                   Treated
     P
     F
     S
     FC
     BC
     VS
     FH

3.   REt,n
4.   BDn
                     Process Wastewater
                     Flume Only
                     Flume and Sprays
                     Final Cooler '
                     Barometric Cond.
                     Abs. Vent Scrub.
                     Fume Hood Scrub.
                                          of raw waste flow
                                          of raw waste flow
                                          of raw waste flow
                                          of FC flow
                                          of BC flow
                                          of VS flow
                                          of FH flow
                            Reuse, where t 3 type
                                         n » % of raw waste flow

                                         t:  U m before treatment
                                             T =• after treatment

                            Slowdown, where n'» discharge as % of
                                !                raw waste flow
B.      Control Technology

        10.  DI             Deibnization

        11.  SR

        12.  CC

        13.  DR

C.      Disposal Methods

        20.  H

        21.  DW
                    Spray/Fog Rinse

                    Coutitercurrent Rinse

                    Drag-out Recovery
                    Haul Off-Site
                        j1

                    Deep Well Injection
                            356

-------
TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 2	
        Disposal Methods (cont.)

        22.  Qt,d
                    Coke Quenching, where t = type
                                          d = discharge as %
                                              of makeup

                                          t:  DW a Dirty Water
                                              CW = Clean Water
        23.  EME

        24.  ES

        25.  EVC
                    Evaporation, Multiple Effect

                    Evaporation on Slag

                    Evaporation, Vapor Compression Distillation

Treatment Technology

30.  SC             Segregated Collection

                    Equalization/Blending

                    Screening

                    Oil Collecting Baffle

                    Surface Skimming (oil, etc.)

                    Primary Scale Pit

                    Secondary Scale Pit

                    Emulsion Breaking

                    Acidification

                    Air Oxidation

                    Gas Flotation

                    Mixing

                    Neutralization, where t 3 type
        31.  E

        32.  Scr

        33.  OB

        34.  SS

        35.  PSP

        36.  SSP

        37.  EB

        38.  A

        39.  AO

        40.  GF

        41.  M

        42.  Nt
                                                  t:  L = Lime
                                                      C = Causiic
                                                      A = Acid
                                                      W = Wastes
                                                      0 3 Other, footnote
                                    357

-------
TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 3
D.
Treatment Technology (cont.)
        43.  FLt
        44.  CY
       44a.  DT
        45.  CL
        46,
        47.  TP
        48.  SLn
        49.  BL
        50.  VF
        51.   Ft.m.h
                    Flocculation, where t = type
                                                    L = Lime
                                                    A = Alum
                                                    P 3 Polymer
                                                    M = Magnetic
                                                    0 = Other, footnote
                    Cyclone/Centrifuge/Classifier

                    Drag Tank
                    Clarifier
                    Thickener
                    Tube/Plate Settler

                    Settling Lagoon, where n ™ days of retention
                                                       time
                    Bottom Liner
                    Vacuum Filtration (of e.g.,  CL, T> or TP
                                       underflows)

                    Filtration,  where t = type
                                      m = media
                                      h = head
                                  m
             D 3 Deep Bed
             F a Flat Bed
                       0
Sand
Other,
footnote
3 = Gravity
 P = Pressure
        52.   CLt
        53.   CO
                    Chlorinatioh,  where t = type

                                        t:  A - Alkaline
                                            B = Breakpoint

                    Chemical Oxidation (other than CLA or CLB)
                                   358

-------
TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 4       '      	
D.
Treatment Technology (cont.)
        54.  BOt
        55.  CR

        56.  DP

        57.  ASt
         58.  APt
         59.   DSt




         60.   CT

         61.   AR

         62.   AU

         63.   ACt




         64.   IX

         65.   RO

         66.   D
                    Biological Oxidation, where t 3 type
                                                        t:  An = Activated Sludge
                                                            n  » No. of Stages
                                                            T  =» Trickling Filter
                                                            B  ™. Biodisc
                                                            0  = Other, footnote
                    Chemical Reduction (e.g., chromium)

                    Dephenolizer

                    Ammonia Stripping, where t s type
                                             t:  F '
                                                 L '
                                                 C '•

                    Ammonia Product, where  t a  type

                                            t
                                                             Free
                                                             Lime
                                                             Caustic
                                                        S  =» Sulfate
                                                        N  = Nitric  Acid
                                                        A  = Anhydrous
                                                        P  » Phosphate
                                                        H  = Hydroxide
                                                        0  = Other,  footnote
                     Desulfurization,  where  t =

                                            t:


                     Cooling Tower

                     Acid Regeneration

                     Acid Recovery and Reuse

                     Activated Carbon, where t
type

Q
N
Qualifying
Nonqualifying
 type
                                             ts  P
                                                 G
     Powdered
     Granular
                     Ion Exchange

                     Reverse Osmosis

                     Distillation

                             359

-------
TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 5
D.
Treatment Technology (cont.)
        67.  AA1
        68.  OZ
        69.  DV
        70.  CNTt,n
        71.  On
        72.  SB
        73.  AE
        74.  PS
                    Activated Alumina
                    Ozonation
                    Ultraviolet Radiation

                    Central Treatment, where t = type
                                                         process flow as
                                                         % of total flow

                                                         1 ™ Same Subcats.
                                                         2 '=• Similar Subcats.
                                                         3 * Synergistic Subcats.
                                                                        si
                                                                          Subcats.
                                                 4 » Cooling Water
                                                     Incompatible
                    Other, where n ™ Footnote number

                    Settling Basin
                    Aeration
                    Precipitation with Sulfide
                                   360

-------
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                                           363

-------
                                        TABLE VII-5

                       SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
                                 ORIGINAL GUIDELINES SURVEY
                      	   FERROMANGANESE BLAST FURNACE
Raw Wastewaters
Plant Codes
Sample PointCsK
Flow, gal/tonU;
   Scrubber

     0112C

       Q
       2
     2,233
   Gas Cooler

      0112C.

        Q
        5
      5,705
                      mg/1
           lbs/1000 Ibs
    pH, Units
    Ammonia (as N)  .
    Manganese
    Phenols (4AAP).
    Suspended Solids
121 Cyanide (T)

Effluent

Sample Point(s)
Flow, gal/ton
C&TT
  12.2-12.2
156
2,960
19.1
17,260
3,886
1.45
27.6
0.178
161
36.2
T, VF, RTP-100
                        No discharge of
                          wastewater
                          pollutants
mg/1
lbs/1000 Ibs
     8.6-8.7
136         3.24
6.05        0.144
0.471       0.0112
57          1.36
104         2.47
                             No  treatment
                               provided
                                            364

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                                   TABLE VII-6

                  SUMMARY  OF ANALYTICAL  DATA FROM SAMPLED PLANTS
                              TOXIC  POLLUTANT  SURVEY
                           FERROMANGANESE  BLAST  FURNACE
Reference Code
Plant Code
Sample Point (s)
Flow, gal/ton
C&TT
Raw Wastewaters

0112C
025
B+D
11,540
                 Effluent

                 0112C
                 025

                 0
                 CL, T, CT, RTF
    Ammonia (as N)
    Manganese
    Phenols (4AAP)
    Suspended Solids
    pH

  4 Benzene
 23 Chloroform
 55 Naphthalene
 85 Tetrachloroethylene
 86 Toluene

115 Arsenic
117 Beryllium
119 Chromium
121 Cyanide (Total)
122 Lead
127 Thallium
128 Zinc
0.017
0.158
0.038
0.064
0.013

7.67
0.011
0.176
692
1.89
0.328
30.5
        8.8-11.3
                     lbs/1000 Ibs

                     34.2
                     12.2
                     0.312
                     200
0.000818
0.00760
0.00183
0.00308
0.000626

0.369
0.000529
0.00847
33.3
0.0910
0.0158
1.47
                                      365

-------
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                        IRONMAKING SUBCATEGORY

                             SECTION VIII

              COST, ENERGY AND NON-WATER QUALITY ASPECTS
Introduction

This section presents the incremental costs which the Agency estimates
the industry will incur in  meeting  the  limitations  and  standards.
These  costs  were  determined  on  the basis of the appropriate model
wastewater treatment systems.  The analysis includes  a  consideration
of   energy   requirements;   non-water   quality  impacts;  and,  the
techniques, magnitude and costs associated with the application of the
BPT,  BAT,  BCT,  NSPS,  PSES  and  PSNS  model  wastewater  treatment
technologies.  . This section also reviews the consumptive use of water
as it relates to the ironmaking subcategory.

Comparison of_ Industry Costs and EPA Model Costs

Tables VIII-1 and VIII-2 present the  water  pollution  control  costs
reported  by  dischargers  which  were  sampled during the original or
toxic pollutant  surveys  or  which  responded  to  the  D-DCPs.   The
reported  costs  have  been  updated  to  July  1978 dollars.  In most
instances, standard cost of  capital  and  depreciation  factors  were
applied  to  the . reported  costs  to  determine those portions of the
annual costs of operation.  In the remaining  instances,  these  costs
were provided by the industry.  The amortization costs reported by the
industry  (cost  of  capital  and  depreciation)  are  similar  to the
amortization costs which would have been determined  by  applying  the
factors noted on the tables.

As  shown  below,  the  capital cost data provided by the industry are
compared with the Agency's  estimates  of  required  expenditures  for
eleven  plants.   The  Agency's  estimates  are  based  upon the model
treatment system factored to the size of each of the eleven plants.

-------
      Plant No.
Actual Costs
Estimated Costs
       0060
      *0060F
      *01 12
      *0112D
       0320
       0384A
      *0396A
       0432A
       0684F
      *0868A
      *0920B
       0946A
      TOTAL
  2,963,000
  6,020,000
  7,384,000
  8,217,000
 14,806,000
 20,896,000
  1,664,000
  9,290,000
 22,507,000
  4,707,000
  5,172,000
  6,492,000
110,118,000
   5,158,700
   5,226,300
  13,425,400
  14,327,300
  10,808,100
  22,284,500
   6,786,400
   9,572,600
  16,238,400
   7,637,800
   7,921,800
   4,004,700
 123,392,000
 *Plants  with  effluent  flows  equal  to  or  less  than
 model  effluent  flow  of 125 gal/ton.
                            the  BPT  treatment
NOTE:      The  data   reported   for   Plant   0684F   include   costs    for
           screening,   settling   tanks,  and  other  items  not  included in
           the Agency's estimated costs.  There  are .two   blast   furnace
           wastewater  treatment  facilities at  this  plant.

Estimated  costs for  two-thirds of  the  plants listed above  are  greater
than the actual costs reported   for  these  plants.   More   important,
however,   is  the comparison of the actual  and  estimated costs  totals,
as this comparison reflects upon the overall  accuracy of the  Agency's
estimate   of  the  costs  of  compliance  for  the entire   ironmaking
subcategory.  Since actual costs are  89   percent of   the estimated
costs,  the  Agency   concluded   that its estimates fairly  reflect  the
actual cost of compliance with  the  limitations  and standards, and that
these estimates are sufficient-to account for site-specific and  other
incidental  costs  (such  as retrofit).  A  more detailed discussion of
this issue is presented in Section  VII  of Volume I.  It should also be
noted that the reported cost total   for  those  plants  with  effluent
flows  equal  to or less than the BPT treatment model effluent flow is
only 60 percent of the estimated cost total for  these  plants.   This
demonstrates  that  the  -limitations  and standards may be  achieved at
less cost than estimated by the  Agency.

In addition, the Agency compared its  estimated  costs  for  its  model
treatment  system with a cost estimate prepared by an engineering firm
for the same model treatment system.  This  firm  estimated  the  costs
for  the  second  BAT  treatment alternative  in the October 1979 draft
development document and supplied its estimate as  a comment  regarding
the  draft  development  document.  A comparison of the flow basis and
estimated costs for the treatment model and company model follows:
                                   304

-------
     Flow
     Capital
EPA Estimate

50 gal/ton
$2.49 million
Engineering Firm
     Estimate

100 gal/ton
$3.94 million
Reviewing the cost figures alone, the Agency's estimate  would  appear
to  be  significantly less than the engineering firm's estimate.  Upon
further analysis, however, it is clear that the difference between the
estimated costs is attributable to the different flow  basis  used  to
size  the  treatment components.  The Agency's .estimated cost is $3.78
million, when the Agency's flow basis is adjusted to  conform  to  the
engineering firm's model  (100 gal/ton).  This is within 4.1 percent of
this .engineering  firm's  unsolicited  estimate  thereby  providing a
further check  :on  the  Agency's  costing  methodology.   The 'general
discussion   regarding    this  issue  in  Volume  I  provides  further
verification of the accuracy of the Agency's  estimates  of  treatment
model costs.
                                                                      »

Control and Treatment Technology in Use
or Available to Blast Furnace Operations

The  technologies  in  use or available for use to treat blast furnace
wastewaters are presented ,in Table VIII-3.  It should be noted that  a
discharger  is  not  required  to  use  any  of  the  model technology
components, as any method of treatment  which  achieves  the  effluent
limitations  or  standards  is  adequate.   In addition to listing the
treatment methods available, these tables provide  the  following  for
each component:

1.   Description
2.   Implementation time
3.   Land requirements

Later in this section, the Agency sets out the estimated costs for the
individual components of  these treatment systems.

With the exception of the vapor  compression  distillation  component,
all   of  the  ^treatment  technologies  listed  on  Table  VIII-3  are
demonstrated within the ironmaking subcategory.  As noted  in  Section
VII,  these technologies  have been proven to be reliable and effective
for  treatment   of   ironmaking   wastewaters.    Vapor   compression
distillation  is  a  technology  which  'has been demonstrated, in other
industries.  Refer to Section VII  for  additional  details  regarding
this technology.

Estimated Cost for the Installation of. Pollution Control Technologies

A.   Costs Required to Achieve  the BPT Limitations

     The first step in determining the estimated costs  of  compliance
     involved the development of a treatment model upon which the  cost
     estimates   could  be  based.    The. model  size   (tons/day)  was
                                    385

-------
      developed on the basis of the average production capacity for all
      blast furnace sites.   This method was used so that the concept of
      joint treatment of wastewaters from several blast furnaces at one
      site  could be more accurately represented.   The Agency  developed
      the   applied  flow  for  the  model  treatment system on the same
      basis.

      The components and effluent flows discussed in Sections IX and  X
      were   then  included  to complete the development of the treatment
      model.    Subsequently,   unit  costs  for  each  treatment   model
      component  were  developed.   , Table VII1-4  presents the estimated
      investment  and   annual    expenditures    associated   with   the
      application  of  BPT   model   treatment  technologies to the model
      plant.   The.capital and annual costs needed to  achieve  the  BPT
      level  of treatment were determined for each blast furnace site by
      adjusting  the model  treatment component costs for plant capacity
      using  the 0.6 power factor.   These estimates pertain to only iron
      blast  furnaces as no  ferromanganese blast furnaces are  currently
      in  operation.   As noted  previously,  ferromanganese blast furnace
      production has been   only  a  minor  segment  of.  all   ironmaking
      operations.    In  order  to  assess the economic impact of the BPT
      effluent limitations  upon the industry,  the Agency estimated  the
      expenditures   required   to  bring  each   blast  furnace site from
      current  (July 1,  1981 ) 'treatment  levels  to  the  BPT  level.    The
      initial   status  of   each plant  was determined from DCP responses
      which described the treatment facilities in-place as  of  January
      1978.    The Agency has  updated the status to July 1,  1981,  taking
      into account  the blast  furnaces  that  have since been  retrofitted
      with  BPT treatment systems,  and  the  permanent retirement of  some
      older, uncontrolled furnaces.  The estimated capital   requirement
      of BPT for  this subcategory  is $22.4  million,  while the estimated
      annual   cost   is  $2.7  million.   The capital  and annual  costs  of
      treatment facilities  in-place, as  of  July 1,   1981,  at  existing
      iron  blast   furnaces amount  to $412.3 million and $52.5  million,
      respectively.

B.    Costs Required  to  Achieve  the  BAT  Limitations

      The Agency considered six  BAT  alternative treatment  systems   for
      the  ironmaking  subcategory.  Each of the  systems  is  depicted  in
     Figure  VIII-1.    The   descriptions,   rationale,   and   additional
     details   for   these  alternatives  are  provided  in  Section  X.  The
     Agency's  estimates of the  investment  and  annual  costs  for  the BAT
     treatment  alternatives  are   presented   in  Table  VII1-5.   The
     treatment  costs   for   each site were  determined  by adjusting the
     model treatment  costs for  size.    Total  estimated  capital  and
     annual  costs   for  the  subcategory   represent   the   sum  of the
     treatment costs  for each active iron   blast  furnace   site.   The
     estimated  investment   and  annual  costs   for  each   alternative
     treatment system for the ironmaking subcategory are as  follows:
                                  33,6

-------
    BAT
    Alternative

    1
    2
    3
    4
    5
    6
Investment
In-place
                Costs ( * ) ( $ )
                 Required
                                                    Annual Costs  ($)
   578,600
 1,318,600
 3,530,800
 7,630,500
10,756,900
     0
           6,997,800
           9,963,900
          11,268,300
          23,204,500
         112,334,400
         171,635,900
   In-place

   89,400
  154,400
  550,400
2,266,400
2,662,100
    0
  Required

   934,400
 1,333,300
 1,714,400
 6,771,700
18,365,000
35,055,000
     (i) Four plants which already discharge  to  quenching  operations
     are not considered  in alternatives  two through six, as the Agency
     expects  that  wastewaters   from  these plants will  continue  to  be
     disposed of  in this manner.

     As noted in  Section X,  the BAT  effluent  limitations  are   based
     upon  BAT  Alternative   4.   The  Agency  recognizes, however,  that
     wastewaters  from  some plants will be  disposed of   by  evaporation
    'on  slag (Treatment Alternative 1).   Although less expensive than
     BAT-4  BAT  T  can  be used to  achieve the  BAT limitations   at   many
     plants.  The Agency did not  promulgate BAT limitations based upon
     BAT  Alternative   1 because not all blast furnaces  are equipped
     with adjacent slag  processing operations.    For   the  purpose  of.
     determining   industry   cost  requirements,  the Agency  assumed that
     BAT-4 would  be installed at"  all blast  furnace   sites,   with  the
     exception   of  the  four plants  currently achieving, zero  discharge
     through  slag quenching.  This  is  a  conservative  assumption   since
     a survey conducted  by  the Agency  indicates that  60« of  the  plants
     may  be  able  to  achieve  compliance  through BAT-1.   The  actual
     costs  incurred by the  industry  may, therefore,   be substantially
     less   than   estimated  by the Agency.   The Agency is also aware of
     certain  technologies   that   may   be' innovative   for    treating
     ironmaking   wastewaters  to   achieve   the BAT  limitations at less
     cost.   These technologies may also   see  widespread  use  in  the
     industry.      •

C.   BCT  Cost Comparison

     The  BCT analysis  was   not  performed  since  the  governing  BCT
     regulation  was  remanded by the Fourth Circuit  Court (See Volume
     I);    BCT   effluent  limitations  have  been  reserved  for   the
     ironmaking subcategory.

D.   Costs  Required to Achieve NSPS

     Seven alternative  treatment systems,  depicted in  'Figurer VIIIT1,
     were  developed  for   new  blast  furnaces.  The NSPS alternative
     treatment systems  include the treatment components of   the  model
     BPT  and  BAT  alternative  treatment   sytems.    The  NSPS  model
     treatment costs are presented in Table  VII1-5.
                                   387

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E.   Costs Required to Achieve the Pretreatment Standards

     Pretreatment standards apply to those plants which  discharge  to
     POTW  systems.   The seven pretreatment alternatives are the same
     as the NSPS model treatment systems.   These  systems,  shown  in
     Figure   VIII-1,   provide  for  reductions  in  toxic  pollutant
     discharge levels and in effluent flows.  Refer  to  Section  XIII
     for  additional information pertaining to pretreatment standards.
     The model costs for the pretreatment alternatives are included in
     Table VIII-5.  The capital annual  costs  for  the  two  existing
     indirect  dischargers  were  determined  by  adjusting  the model
     treatment costs for size.  The total costs for  each  PSES  model
     'treatment system are as follows:
     PSES
 Alternative

     1
     2
     3
     4
     5
     6
     7
     Investment Costs ($)
                    Annual Costs ($)
In-place

12,916,700
    0
    0
    60,400
   297,500
   297,500
    0
 Required

     0
  232,800
  386,400
  386,300
  648,700
3,84.9,400
5,966,200
In-place

2,133,900
    0
    0
   10,200
  120,900
  120,900
  Required

    '0
   32,700
   51,700
   53,800
  176,400
  591,000
1,218,500
     The  costs  for alternatives 2 through 7 are incremental over the
     costs for alternative 1 .

Energy Impacts Due to the
Installation of the Alternative Technologies

Comparatively modest amounts of energy are  required  by  the  various
levels  of treatment for the ironmaking subcategory.  The major energy
expenditures are being  incurred  at  the  BPT  level  while  the  BAT
alternative  treatment  systems  require  relatively  minor additional
energy expenditures.  This relationship reflects  the  use  of  vacuum
filters,  cooling  towers, and primary recycle technologies (the major
energy consumers) in BPT.  Energy requirements at the NSPS,  PSES  and
PSNS  levels  of . treatment  will  be  similar  to  the  total  of the
corresponding BPT and BAT treatment systems.

A.   Energy Impacts at BPT

     The Agency estimates that the BPT treatment  components  for  all
     ironmaking  operations consume about 420.0 million kilowatt hours
     of electricity per year.  This figure represents 0.74% of the  57
     billion  kilowatt hours of electricity used by the steel industry,
     in 1978.

-------
B.   Energy Impacts at BAT
     The  estimated  subcategory  BAT  energy  requirements,  and  the
     respective percent of industry power use in 1978, are as follows:
     BAT
     Alternative

         1
         2
         3
         4
         5
         6
 Million
  kwh/yr

   4.30
   3.74
   5.15
  13.26
  29.08
 545.22
              of  Industry
               Usage

               0.008
               0.007
               0.009
               0.023
               0.052
               0.96
     The  Agency considers the energy requirements set out above to be
     reasonable and justified, especially when compared to  the  total
     industry   energy   use  and  the  pollutant  reduction  benefits
     described below.
     Energy  Impacts at NSPS, PSES and PSNS.

     The Agency estimates of the energy requirements  for  the NSPS
     Pretreatment models are. as "follows:
                                           and
        PSES
     Alternative

          1
          2
          3
          4
          5
          6
          7
Million
kwh/yr
 19,
  0.
  0,
  0,
  0.
  1,
54
20
19
18
59
44
 27.96
 %  of  Industry
	Usage

    0.034
    0.00035
    0.00033
    0.00032
    0.0010
    0.0025
    0.049
      Model

      NSPS/PSNS  -1
      NSPS/PSNS  -2
      NSPS/PSNS  -3
      NSPS -4
      PSNS -4
      NSPS -5
      PSNS -5
      NSPS -6
      PSNS -6
      NSPS/PSNS  -7-
    Million
    kwh/yr

      9.77
      9.87
      9.86
      9.90
      9.86
     10.11
     10.06
     10.53
     10.49
     23.75
                                    389

-------
      The  energy  requirements  for  PSES-2  through  7  are  incremental  over
      the  requirements  for  PSES-1.

Non-water Quality  Impacts

There are minimal non-water  quality  impacts  associated  with  the model
technologies.  Three impacts  were  analyzed:    air  pollution,  solid
waste disposal,  and water  consumption.   The analysis conducted  for the
ironmaking  subcategory  found  that  no significant non-water  quality
impacts will result from the  installation  of  the treatment  systems
under consideration.
A.   Air Pollution

     The use of wet cooling towers  in the BPT model  treatment   system
     may result in the atmospheric  discharge of volatile compounds and
     ammonia-N.   Cooling  tower drift may contain toxic pollutants at
     levels  similar  to  those  present  in   recycled   wastewaters.
     However-,  the  Agency  believes  that  any  adverse environmental
     impact associated with these emissions is minimal and   localized.
     As  no  other  air  pollution  impacts are expected as a result of
     industry's  compliance  with   the  BPT  limitations,  the   Agency
     concluded  that  there  are  no significant air pollution  impacts
     associated with the limitations.

     With respect  to  the  BAT  alternative  treatment  systems,  the
     evaporation  of  process  wastewaters on slag (BAT Alternative 1)
     may result  in  the  emission  of  pollutants  contained   in  the
     wastewater into the atmosphere, however, this impact will  also be
     minimal  and  localized.   Activated carbon regeneration (required
     in association with BAT  5), may also result in the  emission  of
     some  pollutants  found in the wastewater.  However, under  proper
     operating conditions these pollutants would be incinerated.

B.   Solid Waste Disposal

     The model BPT and BAT alternative treatment systems will generate
     quantities of  solid  wastes.    A  summary  of  the  solid  waste
     generation  rates  (on  a  dry  solids  basis) at the BPT  and BAT
     levels of treatment for the ironmaking subcategory is as follows:
     Treatment
       Level

     BPT
     BAT-1
     BAT-2
     BAT-3
     BAT-4
     BAT-5
     BAT-6
Solid Waste Generation for the
	Subcategory (Tons/Year)

     5.14 million
     Minimal
     Minimal
      7,800
     21,450
     21,450
     Minimal
                                   390

-------
    Although  the  quantities  of  solids  generated  at  the  BPT  level   are
    substantial,   these   solids are  often  sintered  and  thus reused in
    the   blast  furnace.   Moreover,   the   incremental   solid   wastes
    generated  at the  BAT level are  not  significant compared to those
    generated at  BPT.


    The  Agency  estimates  that the NSPS and  Pretreatment  alternative
    treatment  systems will  generate the following amounts of solid
    wastes  on a model  plant  basis:
     Treatment
     Level

     NSPS/PSES/PSNS - 1
     NSPS/PSES/PSNS - 2
     NSPS/PSES/PSNS - 3
     NSPS/PSES/PSNS - 4
     NSPS/PSES/PSNS - 5
     NSPS/PSES/PSNS - 6
     NSPS/PSES/PSNS - 7
Solid Waste Generation for the
  Treatment Model (Tons/Year)

         119,465
         119,465
         119,465
         119,665
         120,015
         120,015
         119,465
     As  noted  previously,   the  NSPS,   PSES,  and  PSNS  alternative
     treatment  systems  are  similar  to  the  BPT  and BAT treatment
     systems.   The solid wastes generated at the NSPS, PSES  and  PSNS
     levels  of  treatment  are of the same nature as the solid wastes
     generated by the model  BPT and BAT alternative treatment  systems
     and thus present the same disposal requirements and possibilities
     for reprocessing.

C.   Water Consumption          t

     In the  ironmaking  subcategory,  the  Agency  has  included  wet
     cooling  towers  in the BPT, BAT, NSPS, PSES and PSNS alternative
     treatment systems.  Wet cooling  towers  are  presently  used  at
     nearly 90% of the blast furnace sites to reduce system heat loads
     and  thus  permit higher recycle rates.  The use of those devices
     results in some degree of  water  consumption  (in  the  form  ot
     evaporation and drift).  In response to the Third Circuit Court s
     remand of this issue, the Agency carefully analyzed the amount of
     water consumed by evaporation and drift.  In addition, the Agency
     analyzed  the  amount of water which will be evaporated for those
     discharges employing BAT Alternative 1   (evaporation  of  process
     wastewater on slag).

     The  total water usage in the subcategory is 864 MGD.  The Agency
     estimates that the net  amount   (i.e.,   in  addition  to  current
     consumption)  of  water which would be consumed  in the ironmaking
     subcategory at the  BPT  and  BAT  levels  of  treatment  are  as
     follows:
                                    391

-------
     Treatment
       Level

     BPT
     BAT-1
     BAT-2
     BAT-3
     BAT-4
     BAT-5
     BAT-6
 Net Water
Consumption

 3.0 MGD
18.1 MGD
 0.1 MGD
 0.1 MGD
 0.1 MGD
 0.1 MGD
 0.1 MGD
  % of Total
Volume Applied

    0.36
    2.1
    0.01
    0.01
    0.01
    0.01
    0.01
     The  estimates  set  out above are  in addition  to  the  11.2 MGD of
     water presently consumed in existing  cooling   devices   (1.3%  of
     total applied volume).

     Based  upon  the  relevant  factors  discussed   in Section III of
     Volume I, as well  as  those  discussed  above,  the  Agency  has
     concluded  that  the  impact of the limitations  and standards for
     the ironmaking subcategory on the consumption   of  water  in  the
     steel  industry  on . both  a nationwide and an  arid and semi-arid
     regional basis is minimal and justified, especially in  light  of
     the effluent reduction benefits associated with  these limitations
     and  standards.   Recycle systems have been installed at three of
     the four blast furnace operations in arid or  semi-arid  regions,
     and  a  recycle  system  is  currently  being   installed  at  the
     remaining operation.  Thus, these effluent limitations will cause
     no significant incremental water consumption at  plants located in
     "arid" and "semi-arid" regions.

Summary of Impacts
        1 " l                            4

The Agency concludes that the effluent reduction benefits shown  below
justify  the  adverse  environmental  impacts  associated  with energy
consumption,   air  pollution,   solid  waste,   and  water   consumption
discussed above:
                                   392

-------
                         Raw Waste and Effluent Loads  (Tons/Year)
                               Direct Discharges
                       Raw Waste
                   BPT
                        BAT-4
Flow (MGD)
Ammonia   (N)
Cyanide, Total
Fluoride
Phenols (4AAP)
TSS
Toxic Metals
Toxic Organicsd)
     825
  25,147
     088
15,
18
     860
   3,772
1,388,979
  33,382
     201

2,

2;

1,


29.
672.
178.
004.
102.
871 .-
77.
7.
2
8
2
6
5
0
1
1
16.
149.
0.
498.
0.
548.
11 .
4.
4
7
7
9
4
8
4
0
38
1,169
701
877
175
111,115
1,552
9
.4
.6
.8
.2
.4
.3
.7
.4
Indirect Discharges
 Raw Waste   PSES
              0.8
              7.7
              0.0
             25.6
              0.0
             28.1
              0.6
              0.2
ci>Does  not  include  cyanide  or  any  of  the  individual  phenolic
compounds.

The  Agency  also  concludes  that  the  effluent  reduction  benefits
associated  with  compliance  with  new  source standards (NSPS, PSNS)
outweigh  the  adverse  energy , and : non-water  quality  environmental
impacts.                       ;
                                   393

-------
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TOTAL
                                                                        394

-------
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-------
                                   TABLE VII1-2

                             EFFLUENT TREATMENT COSTS
                           FERROMANGANESE BLAST FURNACES
                  (ALL COSTS  ARE EXPRESSED IN JULY,  1978 DOLLARS)
'Plant  Code
 Reference  No.

 Initial Investment Cost

 Annual Costs

     Capital^1'

     Operation  and Maintenance

     Energy, Power, Chemicals, etc.

     Other  (sludge)

 TOTAL

 $/Ton
    Q
  0112C
     025
    0112C
$3,809,500



$  342,474

   382,780

   151,260

   283,118

$1,159,632

$     5.47
$9,296,200



$  835,728

   491,760

    68,844

   317,004

$1,713,336

$     7.27
                                (2)
 (1)   The capital charge is based upon the formula, 0.0899 x initial investment.
 (2)   Inasmuch as a portion of the investment cost covers the period 1964-68,
      the cost for this period was broken down to 65 percent in 1964 and
      35 percent in 1967 based on 308 information.
                                      396

-------
                                       TABLE VIII-3

                             CONTROL AND TREATMENT  TECHNOLOGIES
                                   IRONMAKING  SUBGATEGORY
C&TT
Step
 B
 E
 H
                Description
THICKENER - This step provides suspended
solids removal as a result of sedimentation.
Significant reductions in the levels and loads
of those pollutants (principally toxic metals)
in the particulate form are also provided.

FLOCCULATION WITH POLYMER - This step enhan-
ces suspended solids and particulate pollu-
tant removal performance in Step A.

VACUUM FILTER - Vacuum filters are used to
dewater and reduce the volume and mass,
of the sludges removed from the sediment-
ation steps.  The filtrate is re-turned
to the treatment system influent.

COOLING.TOWER - This C&TT step reduces the
recycled wastewater heat load.

RECYCLE - At BPT ninety-six percent of the
cooling tower effluent is returned to the
process.  At BAT levels of treatment, ninety-
eight percent of the cooling tower effluent is
returned to the process.

DISPOSAL ON SLAG - Slowdown from the cool-
ing tower, Step E, is disposed of on slag.
The recycle system blowdown must be restricted
to that volume which can be evaporated on slag.

PRESSURE FILTRATION - Filters provide addi-
tional suspended solids and particulate
pollutant removal.

NEUTRALIZATION WITH LIME - Lime is added for
toxic metals removal and pH control.  This
enhanced capability results from the removal,
by sedimentation, of metallic hydroxide
precipitates.
Implementation
Time (months)

  15 to 18
Land
Usage
                                                                               69,000
                                                              15 to 18
                                                                               1000
                   20,000
                                                              18 to 20


                                                              12 to 14
                   2500


                   3000
                                                              6 to 8
                                                              15 to 18
                                                                 12
                   No addi-
                   tional re-
                   quirements .
                   625
                   625
                                             397

-------
TABLE VIII-3
CONTROL AND TREATMENT TECHNOLOGIES
IRONMAKING SUBCATEGORY
PAGE 2                 	
                           Description
 K
 M
 N
INCLINED PLATE SEPARATOR - This component pro-
vides additional suspended solids and particu-
late pollutant removal capability as a
result of enhanced sedimentation performance.

NEUTRALIZATION WITH ACID - Prior to discharge,
acid is added (as needed) to the treated
effluent, in order to assure that the treated
effluent pH is within the neutral range.

TWO-STAGE CHLORINATION - This C&TT step pro-
vides the ability to destroy cyanide and to
oxidize phenols and ammonia.  The basic pro-
cesses involved:  lime addition; first stage
chlorine addition; first step reaction period;
acid addition; second stage chlorine addition;
and, second stage reaction period.

SULFUR DIOXIDE ADDITION - The reducing agent
sulfur dioxide is added to the Step K
effluent in order to remove essentially all
residual chlorine resulting from Step K.

ACTIVATED CARBON ABSORPTION - Prior to dis-
charge, the treated wastewaters (the filter
effluent) from BAT Alternative No. 5 are
passed through a column of granular activated
carbon in order to remove residual levels of
toxic organic pollutants.  This removal is
achieved by adsorption on the activated car-
bon.

EVAPORATION - The effluent from the BPT
treatment system model is delivered to a
vapor decompression evaporation system.
This system produces a distillate quality
effluent and crystalline solids.

RECYCLE - The effluent of Step N is returned
to  the process as a makeup water supply.
Implementation
Time (months)

  10 to 12
                                                              8 to 10
                                                              12 to 15
                                                                     Land
                                                                     Usage
                                                                               225
                   625
                   2500
                                                              8 to 10
                                                              15 to  18
                 — 625
                   625
                                                               18  to  20
                   1000
                                                               12  to  14
                   625
                                              390

-------



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-------
402

-------
                        IRONMAKING SUBCATEGORY

                              SECTION IX

   EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICATION OF THE BEST
          PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE
The  Agency  promulgated  the  same  limitations  that were originally
promulgated in June 1974 *as the Best Practicable  Control  Technology
Currently  Available  (BPT)  for ironmaking operations.  The June 1974
development  document2  provides   background   information   on   the
development of the originally promulgated limitations.

Identification of BPT

A.   Ironmaking Blast Furnaces

     The BPT  model  treatment  system  includes  sedimentation  in  a
     thickener;  coagulant  addition  for  enhanced  suspended 'solids
    . removal performance; sludge dewatering by vacuum filtration; and,
     recycle through a cooling tower of about  96%  of  the  thickener
     effluent.   The  remaining  thickener  effluent  is discharged as
     blowdown.  Figure IX-1, depicts  the  treatment  system  described
     above.

B.   Ferromanganese Blast Furnaces                               ,

     The iron blast furnace BPT model treatment system also applies to
     ferromanganese blast furnace operations.  However, different  BPT
     effluent  limitations  were promulgated to account for the higher
     blowdown  concentrations  of  pollutants  limited  at   BPT   for
     ferromanganese furnaces.


Table   IX-1   summarizes   the   characteristics  of  ironmaking  and
ferromanganese blast furnace  raw  process  wastewaters.   "The  30-day
average BPT effluent limitations are as follows:
iFederal Register; Friday,  June  28,  1974;  Part  II,  Environmental
Protection   Agency:    Iron  and  Steel  Manufacturing  Point  Source
Category; Effluent Guidelines and Standards; Pages 24114-24133.
2EPA-440/I-74-a,  Development  Document   for   Effluent   Limitations
Guidelines  and  New  Source Performance Standards for the Steelmaking
Segment of the Iron and Steel Manufacturing Point Source Category.
                                    403

-------
                                  kg/kkg of Product
                               (lb/1000 Ib of Product)
     Pollutants

Total Suspended Solids
Ammonia (N)
Cyanide (Total)
Phenols (4AAP)
pH (Units)
                                 Ironmaking
                                 Blast Furnaces

                                  0.0260 .
                                  0.0535
                                  0.0078
                                  0.0021
           Ferromanganese
          Blast Furnace

           0.1043
           0.4287
           0.1563
           0.0208
                                  Within the range 6.0-9.0
                                            are  three  times the
     The  maximum  daily  effluent  limitations
     average values presented above.

Selection of_ BPT Limitations

A.   Treatment System

     As noted in Section VII,  the  Agency  found  that  each  of  the
     components   included  in  the  BPT  model  treatment  system  is
     presently  in  use  at  most  blast  furnace  sites.   Given  the
     widespread  use of these components, the Agency believes that the
     BPT model treatment system is appropriate.

B.   Model Treatment Flow Rates

     The Agency retained the BPT model treatment system effluent  flow
     rate  of  125  gal/ton used-to develop the previously promulgated
     BPT  limitations.   As  shown  in  Table  IX-2,  this   flow   is
     demonstrated at several plants.

C.   Effluent Quality

     The Agency also retained the BPT model treatment system  effluent
     quality  from  the prior regulation.  These concentrations are as
     follows:
                                30-Day
                                Average
                                                      Daily
                                                     Maximum
Total Suspended Solids
Ammonia-N
Total Cyanide
Phenols(4AAP)
                                      50
                                     120
                                      15
                                       4
mg/1
150
375
 45
 12
mg/1
As  shown  in  Section  VII,  these  concentrations  are  readily
demonstrated at plants with recycle systems in place.
                               404

-------
D.   Justification of BPT Effluent Limitations       •

     Table IX-3  presents  effluent  data  for  ironmaking  operations
     sampled  by  the  Agency  and  data  from D-DCP respondents which
     support the BPT limitations.  The only sampled  plants  or  D-DCP
     respondents  which  did  not  comply with the BPT limitations are
     those which had once-through treatment systems.  The Agency could
     not fully evaluate the compliance status of a few plants  because
     of  insufficient data supplied by the industry.  These plants are
     not listed in the table.  Although, alkaline chlorination is used
     at a few of the plants that  comply  with  the  BPT  limitations,
     nearly  all  plants achieve the BPT limitations with no treatment
     of the recycle system blowdown.  The sampled plants not  included
     in  Table  IX-3  could comply with the BPT limitations if recycle
     systems were installed.  Recycle systems have been  installed  at
     many of these plants since these data were collected.  The Agency
     estimates  that  about  ninety percent of the currently operating
     ironmaking operations are in compliance with the BPT limitations.
                                   405

-------
                       TABLE
        RAW  WASTEWATER   CHARACTERISTICS

               IRONMAKING   SUBCATEGORY

         (All values expressed in mg/l unless otherwise noted)
                      IRON MAKING
                    BLAST  FURNACES
                  FERROMANGANE:SE
                  BLAST FURNACE
  FLOW (gal/ton)
3200
 II.54O
  AMMONIA (as N)
   10
   71
  CYANIDE(Total)
   10
   692
  PHENOLS (4AAP)
  2.5
     6.5
  SUSPENDED
  SOLIDS
 900
 4160
  pH (Units)
6-10
8.8- 11.3
(I) Raw wastewater quality reflects the discharge from a once-through system.

(2) Data are based upon one plant which was operating at the time of
   sampling. These values reflect the increases due to recycle.
                               406

-------
                              TABLE  IX-2

                    BPT EFFLUENT FLOW JUSTIFICATION
                         IRONMAKING SUBCATEGORY
Plant Reference
Code
0112
0112D
0448A
0528A
0684F
0732A
08561
0856N
0860B
0860H-
0868A-02
0920B
0948A-02
0948C
Discharge
Flow (gal/ton)
71
73
101
66
61
<10(3)
60.7
76.5
45.5
120
122
83
96
85
Operating
Mode
RTP-96
RTP-97
RTP-97
RTP-97
RTP (>90)
RTP-(<100)
RTP-(>98)
RTP-(>90)
RTP-(>90)
RTP and RUP-96
RTP and RUP-96
RTP and RUP-96
RTP-90
RTP and RUP-96
Source of
Data
D-DCP
VISIT
VISIT
Request
Request^2'
VISIT
Request
Request;(1)
(1)
Request,
DCP
D-DCP
D-DCP
DCP
DCP
(1) These data represent averages of all long-term data
    submitted by these plants.
(2) This value is an average of long-term data submitted by this plant,
    These data reflect the effects of discharge flow reduction efforts,
(3) Estimated value.
                                     407

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                                         TABLE IX-3

                     JUSTIFICATION OF BPT EFFLUENT LIMITATIONS (kg/kkg)
                     	        IRONMAKING SUBCATEGORY
                Ammonia
                (as  N)      Cyanide (T)
Iron Making  Blast  Furnaces

BPT             0.0535     0.00780
Plants
L  (0946A)
N  (0448A)
0.0186     0.000173
NJ
0684H
     (1)
0.00724
0 (0060F)  /    0.0356     0.00468
026 (0112D)    0.0122     0.000014
028 (0684H)    0.0125     0.000178
030 (0112)     0.0437     0.00666
0.0117     0.000750
Ferromanganese Blast Furnace

BPT            0.429      0.156
                           Phenols
                            (4AAP)
                NA
                           0.0208
025 (0112C)    No discharge of process wastewater
               pollutants.
                             TSS
                           0.00210     0.0260
                0.000363    NJ
0.000015    0.0163
                           0.000008    0.0198
                           0.00157     NJ
                           0.000066    0.0174
                         pH
                           0.000004    0.0199     8.0
          C&TT Components
                                       6.0-9.0   T,FLP,VF,CT,
                                                 RTP-96
7.6       T,CLA,SS,
          Filters,RTP-37

6.7-8.1   T,CT,SL,RTP-97
          ES
                                                 T,FLP,CT,VF,
                                                 RTP-97,ES
                                       7.3-7.5   T,FLP,VF,NA
                                                 CT,RTP-95

                                       8.2-8.8   A,CLA,FLP,CL,
                                                 CT,FLFC,NA,
                                                 RTP-92

                                       7.2-7.5   T,FLP.,NA,VF,
                                                 CT,RTP(Unk)
            0.0161     8.6
          A,NL,FLP,CLA
          CL,VFVCT
                            0.104      6.0-9.0   See comments
                                                 in Section IX.

                                                 CL,T,VF,
                                                 CT,RT1>-100
(1)  Based on D-DCP analytical data
NA:  No analysis performed
NJ:  Not justified

Note:  For definitions of C&TT Codes, see Table VII-1.
                                             408

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409

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                        IRONMAKING SUBCATEGORY

                              SECTION X

        EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICATION OF
          BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
Introduction

This  section  identifies  six  BAT  alternative   treatm'ent   systems
considered  by  the Agency in developing the BAT effluent limitations.
Since there are no  ferromanganese  blast  furnaces  in  operation  or
scheduled  for  operation  the Agency has not promulgated BAT effluent
limitations   for   ferromanganese   blast   furnaces.    Should   any
ferromanganese   blast  furnaces  operate,  appropriate  BAT  effluent
limitations should be established on a case by case basis using  "best
professional  judgment".   In  those  instances, the model BPT and BAT
treatment systems for iron blast furnaces should be  considered.   The
only  ferromanganese  blast  furnace  In  operation at the time of the
Agency's monitoring programs was operating  with  no  discharge.   The
technologies  included  in  the  BAT alternative treatment systems are
capable of attaining similar pollutant effluent levels for  both  iron
and  ferromanganese  blast  furnace  operations.  However, for the BAT
model treatment system, operating costs for  ferromanganese  treatment
systems  are likely to be higher due to the higher levels of ammonia-n
and total cyanide in wastewaters from ferromanganese operations.

Identification of BAT

Based upon the information presented in Sections III through VIII, the
Agency  developed  the  following  treatment   technologies   as   BAT
alternative  treatment  systems for the ironmaking subcategory.  These
treatment systems are .designed to be compatible  with  the  BPT  model
treatment   system.    Schematic  diagrams  of  the  alternatives- are
presented in Figure VIII-1.

BAT Alternative 1                  -

The blowdown flow is reduced by increasing the recycle rate of the BPT
model treatment system to the point where it can be  consumed  in  the
quenching  (cooling)  of  blast  furnace  slag.   The treatment system
includes a slag pit  collection and recycle sump and associated pumps.
As all of the blowdown is evaporated,  process  wastewater  pollutants
are not discharged into receiving waters.                          "

BAT Alternative 2_

The  blowdown  flow is reduced to 70 gal/ton by increasing the recycle
rate of the BPT model  treatment  system.   The  reduced  blowdown  is
treated  by  filtration.   Pressure  filters are used to  reduce toxic
metals in the blowdown hy  removing  those  toxic  metals  present  in
                                   411

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particulate  form.  The filters also remove other pollutants which may
be entrained in suspended solids.

BAT Alternative 3^

The  reduced  blowdown  flow  (70  gal/ton)  is  treated   with   lime
precipitation  and  sedimentation.   Lime  is  added  to  remove  both
dissolved  and  particulate  toxic  metals   present   in   ironmaking
wastewaters.   The  toxic  metal  hydroxides are gravity settled in an
inclined plate separator prior to discharge.  Toxic metals as.well  as
other  pollutants'  present in particulate form will also be removed by
sedimentation.                     ;

BAT Alternative 4_                               .

The reduced blowdown (70 gal/ton) is treated with  two-stage  alkaline
chlorination.   Lime  is added to the blowdown to raise the pH to 10.5
or greater.  The toxic metal precipitates and other  suspended  solids
formed by lime addition are removed in inclined plate separators prior
to  alkaline  chlorination*  Chlorine is added to the first reactor to
convert the cyanides to cyanates and to oxidize ammonia-N and phenolic
compounds.  As the wastewaters leave the first reactor, acid  is  added
to  reduce  the pH to 8.5.  Additional chlorine is added in the second
reactor to complete the oxidation of cyanides,  as  well  as  residual
ammonia-N  and phenolic compounds.  The effluent is then dechlorinated
with appropriate reducing agents prior to discharge.

BAT Alternative 5_

Additional treatment  of  the  effluent  from  BAT  Alternative  4  is
provided  by  adsorption  on  activated carbon.  Activated carbon will
remove residual levels  of  toxic  organic  pollutants  which  may  be
present in the wastewater.

BAT Alternative 6.                                 .

The  blowdown  from  the  recycle  system  (70 gal/ton) is processed by
vapor  compression  distillation.   The  high  purity   water   (steam
condensate)   is  returned  to  the  recycle  system  resulting in zero
discharge of wastewater.
Except for vapor compression distillation, the treatment  technologies
described  above  are   in  full scale use at one or more blast  furnace
wastewater treatment systems, or demonstrated on the  basis  of  pilot
plant   studies  in  this  subcategory.   The  applicability  of  each
treatment system is reviewed .below.

The pollutants selected for limitation and  the  effluent  limitations
for  each  alternative  are  presented   in  Table  X-l.   The Agency's
selection  of  pollutants  for  which  BAT   limitations   have   been
promulgated  is based upon the following considerations:  the relative
                                    412

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level, discharge load, and environmental impact of each pollutant; the
need  to  establish  practical  monitoring   requirements;   and,   to
facilitate  co-treatment  of  ironmaking  and sintering wastewaters, a
common practice in the industry.

Treatment for the selected  pollutants  will  generally  result  in  a
similar  or  greater  degree  of  treatment  for pollutants chemically
related to the selected pollutants and found  at  lower  levels.   For
example,  nine toxic metals were identified in the process wastewaters
from blast furnace operations at  concentrations  greater  than  0.010
mg/1.    However,  the  Agency has promulgated BAT limitations for only
lead and zinc. Significant removal of the other metals will  occur  in
conjunction with the treatment and control of these metals.

Rationale for the Selection of BAT

Treatment Technologies

Recirculation  of treated wastewater is one of the major components of
the BAT model treatment system.  The recirculation  rate  of  the  BPT
model treatment system is increased  from 96% (125 gal/ton) to 98% (70
gal/ton  blowdown).   Recycle  of  blast'furnace wastewaters is widely
demonstrated in the industry.  The 70 gal/ton blowdown  rate  is  also
demonstrated   and  is  discussed  in  detail  below.   In  the  first
alternative, the blowdown is reduced to the  point  where  it  can  be
consumed  to  quench  (cool)  slag.   Approximately  60%  of the blast
furnaces have adjacent slag operations.  This practice is demonstrated
in the industry (Plants 0060F, 044-8A, 0860H)  and  provides  a  fairly
inexpensive  approach  to  achieve the BAT limitations.  Filtration is
used to treat wastewaters from three blast furnace operations  (Plants
0584C,  0860B  and 0946A.  Precipitation and alkaline chlorination are
used in several blast  furnace  wastewater  treatment  systems  (0320,
0504C,  0860B).   The  primary purpose of alkaline chlorination is the
oxidation of ammonia-N,  cyanide, phenolics, and  other  toxic  organic
pollutants.   The  fifth BAT alternative includes activated carbon for
the removal of residual levels of toxic organic  pollutants  from  the
effluent  of  BAT Alternative 4.  this is demonstrated on a full-scale
basis at Plant 0860B in this subcategory.

Model Flow Rate

The Agency has retained the BPT applied flow  of  13,344  1/kkg  (3200
gal/ton)  for  use  in  the  BAT  alternative  treatment systems.  The
discharge flow of 292 1/kkg (70 gal/ton) used to develop the  proposed
BAT  limitations has been retained.  In the draft development document
the Agency cited data for Plant 0112 that indicate 70  gal/ton  is  an
achievable  blowdown  rate  for  blast  furnace  recycle systems.  The
industry noted that longer term  data  for. that  plant  indicate  the
blowdown rate for this operation is about 78 gal/ton, and that monthly
average  flows  during  the  period of record exceed 130 gal/ton.  The
industry contends that flows less than 70 gal/ton cannot be maintained
for long periods of time because of. the build-up of  dissolved  solids
which  can  lead  to  an  increased potential for stress corrosion and

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mineral  scaling.   The  Agency  disagrees  that  70  gal/ton  is  not
sustainable  on  a  long term basis.  Data for Plant 0112 show that 70
gal/ton has been maintained for long periods of time without  fouling,
scaling,  or  plugging  problems.   The Agency notes that the blowdown
rate at this plant is controlled to maintain cyanide discharges  below
certain  levels and that dissolved solids or other indices relating to
fouling or scaling are not used to control the blowdown  rate.   Thus,
the  Agency  believes  a  blowdown rate of 70 gal/ton is achievable at
this plant.  The Agency solicited data for other  well-operated  blast
furnace recycle systems. .These data are shown below:
     Plant
     0528A
     08561
     0860B
Period Covered
   by Date

January 1978-
July 1980
November
May 1981
1979-
October 1980-
December 1980
             Average Daily
           Blowdown (gal/ton)
                                           68.5
                                           60.7
                                           45.5
Based  upon  these  data;  the  performance  data for Plant 0112 noted
above; the performance of one of the two blast furnace recycle systems
at Plant 0684F; and, the performance at Plants 0060F, 0448A, and 0860H
where blast furnace blowdowns are consumed on slag and other  sources,
the Agency believes that 70 gal/ton is an achievable blowdown rate for,
all  blast  furnaces.   These  plants  are  typical  of  those  in the
industry, are located in different geographic areas, use different raw
materials, and are operated by different companies.   Aside  from  the
demonstration  of  the 70 gal/ton blowdown rate noted above, one major
steel company suggested the Agency use a blowdown rate of  35  gal/ton
to establish BAT effluent limitations.

Wastewater Quality

The  average  and maximum effluent concentrations included in each BAT
treatment alternative  are  presented  in  Table  X-l.   No  data  are
presented  for Alternatives 1 and 6 since these alternatives result  in
zero discharge.  The effluent levels for Alternatives 2 through 5  are
discussed below.

Ammonia-N

Alternatives 2'and 3 do not provide for treatment of ammonia-N.  Thus,
the discharge of ammonia-N from these systems  is the same as that from
the BPT recycle system.

To  some  extent, ammonia-N will concentrate  in recycle systems as the
blowdown  rate  is  brought  under  hydraulic  control  and  ' reduced.
However,  the discharge loading will decrease  with decreasing blowdown
rate rather than remain the same.  Thus,  there  is  an  advantage   to
                                   414

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minimizing  blowdown  rate.   The  investment  costs  of the treatment
facilities will be reduced as well as the costs of chemicals  required
for blowdown treatment.

Alternatives  4  and  5 include alkaline chlorination for treatment of
ammonia-N, total cyanide, phenols  (4AAP),  and  other  toxic  organic
pollutants.   The  proposed  BAT  ammonia-N limitation is based upon a
concentration of 1.0 mg/1 obtained  from  pilot  plant  studies.   The
industry  submitted  data  for  a full scale system (Plant 0860B) that
suggests  a  BAT  limitation  based  upon  10  mg/1  might   be   more
appropriate.   The  Agency  sollcated  long  term data for this plant.
Based on its analysis of these data (Table A-38,  Appendix  A,  Volume
I),  the  Agency  concluded  that a model effluent concentration of 10
mg/1 is appropriate for this technology as these data demonstrate that
a well operated system can achieve that value.  The data presented  in
Table  X-l  reflect  that  value.   Ammonia-N  is  not  removed by the
activated carbon system installed at  this  plant.   Activated  carbon
system   are   not  capable  of  ammonia-N  removal.   Available  data
demonstrate that the  alkaline  chlorination  process  used  prior  to
activated carbon consistently removes ammonia-N to less than 10 mg/1.

Total Cyanide

Alternatives  2  and  3  do  not  include treatment for total cyanide.
Thus, the level of discharge was set at the level determined from  BPT
recycle system blowdowns, or about 5 mg/1.  This value is supported by
the data presented in Section VII.

For  Alternative  4, the Agency proposed a total cyanide limitation of
1.0 mg/1 based upon alkaline chlorination pilot  plant  data  obtained
for  Plant  0860B.  This concentration is demonstrated to be achievable
by full scale operation at Plant 0860B and several pilot plant  studies
conducted at other plants  (0112D, 0684F, and 0860H).

Data for Plant 0860B demonstrate that the alkaline chlorination system
at this plant consistently removes cyanide to  less than 1.0  mg/1  and
that  activated  carbon  has  virtually  no effect on cyanide removal.
This is also demonstrated  at Plant 0684F where  activated  carbon  has
virtually no effect on cyanide removal from cokemaking wastewaters.

Phenols (4AAP)                                 .

Again,  Alternatives   2 and  3 provide no treatment for phenols  (4AAP).
The effluent levels presented in Table X-1 do   not  reflect  treatment
for phenols (4AAP).

For Alternative  4, the Agency proposed a BAT phenols  (4AAP)  limitation
based  upon a   concentration  of  0.1 mg/1.   Data obtained  from pilot
plant studies  conducted  by the industry at Plant  0860H  were  used   to
develop   the  proposed   limitation.   The  achievability  of  the  BAT
limitation  is  based upon pilot plant and  full   scale  data   for Plant
0860B   (prior   to  adsorption  on  activated  carbon)  and pilot  studies
conducted  by the' industry  and the Agency  at Plants  0112D,   0684F,  and
                                   415

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 0860H.    The  alkaline  chlorination  system  installed at Plant.0860B
 reduces  phenols (4AAP) to the low ?g/l range prior to activated carbon
 treatment.   The phenols (4AAP)  limitation for Alternative 5 are  based
 upon  data from Plant 0860B after activated carbon treatment.

 Toxic Metal  Pollutants

 The   Agency  reviewed long-term  effluent data for filtration systems  to
 determine the  toxic  metals  removal  capabilities  of  these  systems
 (BAT-2)   used  in similar wastewater  treatment applications.   Available
 data  indicate  a significant portion  of the toxic metals in  ironmaking
 wastewaters  are  in  particulate form  and  can  be removed with the
 suspended solids.   In those instances   in  which  the  long-term data
 (noted   above   and  discussed  in Volume I)  are for ironmaking process
 wastewater   filtration  applications,   toxic   metals   removals  are
 generally   based   upon   the   degree  of  suspended  solids  removal
 accomplished.   The sampled plant monitoring data presented in  Section
 VII   demonstrates  this  general  pattern,   although  the toxic metals
 effluent concentrations are generally  slightly higher than the  levels
 expected strictly on the basis  of the  metal/TSS ratio.

 Sedimentation   and  filtration   are  not  effective for removing toxic
 metals dissolved in process wastewaters.   In order to remove  both  the
 dissolved and   particulate  fractions  of the toxic metals  the Agency
 considered lime precipitation and sedimentation (BAT Alternatives 3, 4
 and   5).   The   presence  of dissolved  toxic  metals   in  ironmaking
 wastewaters  is  related to the nature of the process itself.   Some  of
 the volatilized metals,  -e.g., zinc,  are not   entirely  transformed   to
 oxides   and  some   of  the  metals may be present as fine particulates
 measured as  dissolved metals by the  analytical methodology.   The toxic
 metals effluent levels which can be  achieved  by  lime   precipitation,
 sedimentation,  and filtration were determined on the basis of  a review
 of  sampled  plant monitoring data and data  for Plant 0860B.   Lead and
 zinc  are the toxic metal  pollutants  selected for  limitation   at BAT.
 The   Agency- based the lead limitation for Alternatives 3, 4,  and 5  on
 typical  BPT  blowdown levels and the  zinc  limitations are based upon
 data  from Plant  0860B.

 Sulfide   addition   was  also considered as a means  of further  reducing
 the loadings of  toxic metals.   Because this  technology   has   not bean
 demonstrated  in   this subcategory and only  marginal  incremental toxic
 metals removal  can be realized,  the  Agency   did  not   include   sulfide
 precipitation as a BAT model  treatment technology.

 Toxic Organic Pollutants

 The   removal  of   most toxic  organic pollutants is  accomplished  in BAT
 Alternative  4 (alkaline  chlorination).   Activated  carbon  treatment   in
BAT  Alternative   5  is designed  specifically  to remove  residual  levels
 of those  toxic organic pollutants which may  be  present  after treatment
 in BAT 4.  Ironmaking  wastewaters treated to  the BPT  level can  contain
 toxic organic pollutants  (phenolic compounds,  fluoranthene), that  may
remain  detectable  after  alkaline chlorination  at  concentrations at or
                                   416

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near treatability levels.  Also,  application  of  BAT  Alternative  4
could  result  in  the  formation of low levels of total halomethanes.
However, as noted in Section VII, the Agency believes that the  proper
application  of  alkaline  chlorination  can minimize the formation of
trihalomethanes to levels of 0.1 mg/1 or less.  These low  levels  are
generally  not  toxic  to  aquatic life and would not violate proposed
drinking water standards if found directly in  water  supply  intakes.
Nonetheless,   activated   carbon  treatment  was  considered  as  BAT
Alternative 5 for toxic organic pollutant removal.

The treatment capabilities of activated carbon are  based  upon  pilot
plant studies and effluent data from Plant 0860B.  The monitoring data
for  Plant  0860B and a blast furnace, wastewater treatment pilot plant
study are presented in Tables VII-8, 9 and VII-.ll.   Plant  0860B  and
the   pilot   treatment  system  included  alkaline  chlorination  and
activated carbon treatment components.  The data  for  both  of  these
sources  support  the  attainability of the effluent concentration for
phenols  (4AAP) included  in BAT  Alternative  5.   An  avlrage  phenols
(4AAP) effluent concentration of less than 0.05 mg/1 was achieved with
activated carbon during a pilot scale study at plant 0860H.

Total Residual Chlorine

A  total  residual  chlorine  limitation  of 0.5 mg/1 daily maximum  is
included in BAT 4 and 5  to  control  excess  chlorine  resulting  from
alkaline chlorination.   Several reducing agents can be used to destroy
excess   chlorine.   The  chemistry of this reaction is well documented
throughout the literature and the technology  is well  demonstrated   in
other   industries  as  well  as  in  this  subcategory at Plant 0584C.
Discharge levels  of  total  residual  chlorine  at  plant  0584C  are
consistently well below  0.5 mg/1.

Effluent Limitations for BAT Alternatives

The  effluent  limitations  for  the BAT alternative treatment systems
were developed on a mass basis  (kg/kkg or lbs/1000  Ibs)  by considering
the model plant effluent flow  (70  gal/ton)   and  the  respective  BAT
effluent  concentrations.  The  effluent limitations presented  in Table
X-1 for  each treatment alternative are on a mass basis,  therefore, any
combination of effluent  flows and concentrations may be  used to attain
the specified -mass  limitations.                                -

Selection of. a BAT  Alternative

The Agency  selected BAT  Alternative  4, depicted  in  Figure X-1, as  the
basis   for  the  BAT  limitations.   The  selection process  included a
review  of the  treatability of   the   toxic  pollutants   considered  for
limitation,  the effluent  levels of  these pollutants  in  each treatment
alternative, and the  costs of  each alternative.  With   the   exceptions
of  BAT Alternatives   1,   5,   and   6,  the Agency  determined  that BAT
Alternative 4  provides  the most significant benefits with  respect   to
the   control   of   toxic  pollutants.   The  Agency  did  not  select BAT
Alternative  1  because slag  evaporation cannot be  used  at  all  plants;
                                    417

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Alternatives   5   and   6   were   not   selected   on   the   basis   of   high
incremental costs and  minimal  additional  pollutant removal  over   that
provided  by   Alternative  4.    The   pollutants   of major  concern are
ammonia-N, total  cyanide, phenols  (4AAP),  and  toxic metals.   As   shown
in  Table  X-l,   the   effluent  levels  of most of these pollutants are
reduced only at BAT  Alternative 4.    The formation   of   chlorinated
organics can be minimized to low levels with properly  applied alkaline
chlorination systems.  Thus, the costly activated carbon step included
in   BAT  Alternative  5  does  not   achieve   significant   incremental
pollutant removals.  The  Agency concludes that the effluent   reduction
benefits  associated   with  alkaline chlorination of   blast furnace
wastewaters outweigh the  negative aspects of   the  generation of  low
levels of brominated and  chlorinated compounds.

The  achievability  of the  BAT limitations is  well demonstrated by the
performance of Plant 0860B  and by the pilot studies noted above.   This
comparision  is   presented  in  Table  X-2.    Based upon   data    and
information ,~ available to  the Agency,   it is important that lime or
caustic addition  and  subsequent  suspended   solids  removal  precede
chlorination,  both  to   insure proper  control of pH and toxic metals,
and,  to  minimize  the   formation    of   trihalomethanes   from    the
chlorination  reaction.   The   Agency  believes   that the reduction of
ammonia-N, cyanide, and phenols (4AAP)   outweighs the formation of
halomethanes.


While  BAT  Alternative   1  is   the   least expensive   alternative and
achieves the highest   degree   of  treatment  (i.e.,  no discharge of
process  wastewater  pollutants  to   navigable  wasters),  the  Agency
concluded that this alternative  cannot  serve   as   the   basis,  for  BAT
effluent  limitations  for  the  entire subcategory.  Due to the methods
of slag handling  (i.e., remote  from  the blast  furnace)  this technology
cannot be used at some plants.    However,  as noted in Section  VIII,  the
Agency believes that BAT Alternative  1  may be  selected  for many plants
as the  least  expensive  means  of   achieving  the  BAT limitations.
Approximately  60%  of the  plants have  slag operations  adjacent to the
blast  furnaces.    The  Agency   is   also   aware   of  other    treatment
technologies   that   may   be   innovative  for   treating  ironmaking
wastewaters to achieve  the  BAT  limitations  at   less  cost.    These
technologies  involve  reducing  recycle   system   blowdowns to minimum
levels with subsequent blowdown  treatment.
                                    413

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                        JRONMAKING SUBCATEGORY




                              SECTION XI



         BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY (BCT)
Introduction


















44501, July 30, 1979) .
co,-t-i«n  Vru(b) (4) (B) ,  the  Act  requires   that   BCT
 case  may  BCT  be  less  stringent than BPT.
      had argued that a second cost test was not required.)
 BCT limitations until EPA proposes the revised BCT methodology.
                                      423

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                        IRONMAKING SUBCATEGORY

                             SECTION XII

               EFFLUENT, QUALITY ATTAINABLE THROUGH THE
           APPLICATION OF NEW SOURCE PERFORMANCE STANDARDS
Introduction

NSPS  are  based  upon  effluent  quality   achievable   through   the
application  of  Best Available Demonstrated Control Technology (BDT),
processes, operating methods, or other alternatives, including,  where
practicable, a standard permitting no discharge of pollutants.

Identification of NSPS

The  seven  alternative  treatment systems developed for NSPS shown in
Figure XI1-1 are the same as the BPT  and  BAT  alternative  treatment
systems  except  filtration  is  included in the alkaline chlorination
alternative.  The corresponding effluent standards for these treatment
alternatives are presented in Table"XII-T..  Following is a summary  of
the   treatment   technologies   included   in   each  NSPS  treatment
alternative:                     '  . *
     NSPS - 1
     NSPS


     NSPS


     NSPS
_ o
- 4
     NSPS - 5
     NSPS
          Gravity sedimentation in  a  thickener,  coagulant
          aid  addition,   vacuum  filtration of sludges,  and
          recycle through  a  cooling  tower.   The  recycle
          system  blowdown  is  discharged  without  further
          treatment.
                                                                    is
The blowdown from the recycle system of NSPS 1
minimized and evaporated on slag.

The recycle system blowdown  undergoes  filtration
prior to discharge.

The recycle system blowdown  is  treated  by  lime
precipitation  and  sedimentation  in  an inclined
plate separator prior to discharge.

The recycle system blowdown  is  treated  by  lime
precipitation  and two-stage alkaline chlorination
followed by filtration and dechlorination.
          The      effluent      from      the
          chlorination/dechlorination  system  of
          treated by activated carbon.
                                          alkaline
                                         NSPS 5 is
                                    425

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     NSPS  -  7
The recycle system blowdown is processed by  vapor
compression    distillation    to   achieve   zero
discharge.
Rationale  for  Selection  of  NSPS  3                  .

Since, except  as  noted above,  the  NSPS  treatment  alternatives  are   the
same  as the BPT  and BAT treatment systems,  the rationale  presented in
Sections IX and X for these systems is  applicable to  NSPS.

All of the NSPS treatment schemes  are addressed collectively below.

Treatment  Technologies

As noted in previous sections, the treatment  technologies  included   in
the  NSPS  alternative   treatment   systems are demonstrated within  the
ironmaking subcategory or  transferred   from  other   subcategories   or
related  industries  (as discussed in Section X).  The model treatment
technologies are  applicable for NSPS for ironmaking wastewaters.

The resulting  effluent quality for the  NSPS  treatment alternatives  are
presented  in Table  XII-1.   'As  noted   in   Section   X,  the   critical
pollutants and   their effluent levels  are based  upon the  demonstrated
capabilities of the wastewa'ter treatment technologies.   The   effluent
levels  for  suspended   solids  are based on the performance  of Plant
0860B and  long term effluent data"   for   clarification  and  filtration
systems applied to ironmaking and  other similar wastewaters.   The data
for  Plant 0860B are presented in Table VII-11 while the  supplemental
long term  data-analysis  is  set out in Appendix A  of Volume  I.   These
data  clearly  demonstrate the achievability and appropriateness of  the
NSPS effluent  levels.

Another  available  technology  is nonevaporative  cooling  of  blast
furnace  wastewaters.  This system has  the potential  for extremely  low
blowdown rates, or, possibly,  zero discharge.    This  technology  .is
installed  at two  plants  and is currently being installed at others.

Flows

The  applied  and discharge  flows developed  for  BPT   and  BAT  ar%
applicable and are included in all  NSPS  treatment  alternatives.    As
noted in Section  X, the  treatment  model  effluent  (blowdown) flow of  70
gal/ton  has  been  demonstrated   on  the  basis ' of  long-term data  at
several plants.

Selection  of an NSPS Alternative

The Agency selected NSPS  5, depicted in   Figure   XII-1,  as  the  NSPS
model  treatment  system.   This alternative  was  selected for  the same
reasons presented in Section X regarding  the  selection  of   the  BAT
model  treatment  system.   However,  the  NSPS model treatment, system
includes filtration for  additional  suspended  solids removal.  As noted
for BAT,  evaporation of  the recycle system blowdown to  extinction   on
                                    426

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slag  is  a  means of attaining NSPS.  The NSPS are presented in Table
XII-1 under the heading of NSPS 5.

The NSPS standards are clearly  demonstrated  by  the - performance  of
Plant 0860B.  This comparision is presented in Table XII-2.
                                    427

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                        IRONMAKING SUBCATEGORY

                             SECTION XIII

               PRETREATMENT STANDARDS FOR DISCHARGES TO
                    PUBLICLY OWNED TREATMENT WORKS
Introduction

This  section  presents  alternative  pretreatment  systems  for blast
furnace operations with discharge to publicly  owned  treatment  works
(POTWs).   The blowdowns from two ironmaking operations are discharged
to POTWs.   The  general  pretreatment  and  categorical  pretreatment
standards applying to ironmaking operations are discussed below.

General Pretreatment Standards

For detailed information on Pretreatment Standards refer to 46 FR 9404
et seq  "General Pretreatment Regulations for Existing and New Sources
of  Pollution,"  (January 28, 1981).  See also 47 FR 4518 (February 1,
1982).  In particular, 40 CFR Part 403  describes  national  standards
(prohibited   and  categorical  standards),  revision  of  categorical
standards through removal allowances, and POTW pretreatment programs.

In establishing pretreatment standards for ironmaking operations,  the
Agency  considered  the  objectives . and  requirements  of the General
Pretreatment  Regulations.   The  Agency  determined  that   untreated
discharges  of  ironmaking  wastewaters  to POTWs would result  in pass
through of toxic pollutants.

Identification of_ -Pretreatment Alternatives

The PSES and PSNS alternative treatment systems are identical   to  the
BPT and the BAT alternative treatment systems presented in Sections IX
and  X.   These alternatives are shown in Figure VIII-1.  Reference is
made to Sections X  and  XII  for  a  discussion  of  these  treatment
systems.

Following is a summary of the treatment system components included in
each pretreatment alternative:
PSES/PSNS Alternative  1 -
                              Coagulant    aid    addition,     gravity
                         sedimentation    in   a   thickener,    vacuum
                         filtration of sludges, recycle (98%)   through
                         a  cooling  tower.    The  blowdown  from  the
                         recycle system is discharged without  further
                         treatment.

PSES/PSNS Alternative 2 -     The   recycle   system   blowdown   from
                         Alternative  1  is  completely  evaporated on
                         slag.              .
                                    431

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 PSES/PSNS Alternative 3 -     This  alternative    is   the   same   as
                          Alternative  2  except  that  the blowdown is
                          treated by filtration and discharged,  rather
                          than evaporated on slag.

 PSES/PSNS Alternative 4 -     The recycle system blowdown  is  treated
                          by lime precipitation and sedimentation in an
                          inclined plate separator prior to discharge.

 PSES/PSNS Alternative 5 -     The recycle system blowdown  is  treated
                          by  two-stage  alkaline chlorination prior to
                          discharge.

 PSES/PSNS Alternative 6 -     The   effluent   from    the    alkaline
                          chlorination   system  of  Alternative  5  is
                          further treated by filtration  and-  activated
                          carbon.

 PSES/PSNS Alternative 7 - "    The recycle system blowdown is processed
                          by vapor compression distillation to  achieve
                          zero discharge.

 The  intent  of the pretreatment  standard is to provide for reductions
 in the effluent levels of .ammonia,  cyanide,  toxic  metals,   and  toxic
 organic  pollutants.    Recycle  of   the  wastewaters will  substantially
 reduce  the  pollutant   loads   discharged   from   blast    furnaces.
 Evaporation  on  slag,  although  not universally applicable,  eliminates
 the discharge of the blowdown.   Filtration  and lime precipitation   are
 included for  the purpose of  reducing toxic  metals effluent  levels.   As
 noted   in  Section X,  the major portion  of  the toxic metals  waste  load
 is entrained  in  the  particulate  matter  suspended  in   the  process
 wastewaters.    Consequently,  suspended solids  control  by  sedimentation
 and filtration will result  in  the removal of  a substantial portion   of
 the toxic  metals  load.    Lime  precipitation will  provide  additional
 toxic  metals  removal  and load  reductions   through   precipitation   of
 those   toxic   metals  dissolved in the  wastewaters.   Two-stage alkaline
 chlorination  technology.is  included  to remove  ammonia-N,  cyanide,   and
 phenols  (4AAP).   Activated carbon provides additional  removal of toxic
 organics    that   may    remain    in    the  wastewater   after   alkaline
 chlorination.
Table XIII-1 presents the effluent standards  for each alternative
those pollutants considered for regulation.

Selection of Pretreatment Alternatives
for
 ™       Alternative 5 was selected as the basis for the promulgated
PSES  and  PSNS.   As  noted  earlier,  PSES/PSNS  Alternative  5   is
equivalent  to the selected BAT alternative for ironmak'ing operations
This alternative provides  for  the  greatest  removal  of  toxic  and
nonconventional pollutants found in ironmaking wastewaters without the
high  costs  of  activated  carbon  and  zero  discharge  technologies
included in Alternatives 6 and 7, respectively.
                                  432

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Aside from recycle (PSES/PSNS Alternative 2),  there  is  no  specific
treatment  in  the  BPT  system  for  toxic  and  rionconventional  and
pollutants; nor is there any in PSES/PSNS Alternatives 3 and 4.  Thus,
the Agency believes PSES/PSNS Alternative 5  is the  appropriate  model
technology   for   PSES/PSNS.    The   removal   rates  of  toxic  and
nonconventional pollutants from untreated ironmaking  wastewaters  for
PSES/PSNS  Alternative  5  are  compared to  the POTW removal rates for
these pollutants:

                        . Pollutant Removal Rate.Comparison	
     Ammonia-N
     Cyanide
     Lead
     Zinc
PSES/PSNS
  Model  '

 99.3%
 99>9%
 99.9%
 99.9%
Actual
 POTW

  0%
 52%
 47%
 65%  .
As shown above, the selected PSES/PSNS alternative will  prevent  pass
through' of  toxic  and nonconventional pollutants found in  ironmaking
wastewaters to a significantly greater  degree   than  would   occur   if
ironmaking  wastewaters  were  discharged   untreated  to   POTWs.    The
achievability of these standards  is demonstrated in   Table  X-2.   .The
model   treatment system is depicted in .Figure XIII-1  and PSES and PSNS
are shown in Table XIII-1.   •;
                                   433

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*U.S. GOVERNMENT PRINTING  OFFICE:  1982-O-36l-OS5/kb52
                                                                435

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