-------
TABLE III-3
CONTINUOUS CASTING DATA BASE
Plants sampled for original
survey
Plants sampled for toxic
survey
Total plants sampled
Plants solicited via
D-DCP
Plants sampled and/or
solicited via D-DCP
Plants responding to
DCP
No. of
Plants
4 incl.
1 above
9 incl.
3 above
14
51
of Total
7.8
7.8 incl
2.0 above
13.7
17.6 incl.
5.9 above
27.4
100.0
Daily
Capacity
7214
% of
Daily Capacity
9.9
6923 incl.
4118 above
10,019
20,309 incl.
2,330 above
28,678
72,691
9.5 incl.
5.7 above
13.8
27.9 incl.
3.2 above
39.5
100.0
381
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CONTINUOUS CASTING SUBCATEGORY
SECTION IV
SUBCATEGORIZATION
Introduction
The Agency examined several factors to determine if the continuous
casting subcategory should be subdivided. Those factors include
manufacturing processes and equipment, final products, raw materials,
wastewater characteristics, wastewater treatability, size and age of
facilities, geographic location, and process water usage and discharge
rates. All were found to have no significant impact on
subcategorization. The following discussion addresses each of these
factors and confirms the continuous casting subcategorization.
Factors Considered ir\ Subdivision
Manufacturing Process and Equipment
The continuous casting operation is a process in which molten steel is
cast into a semi-finished product. Its particular process
characteristics distinguish it from other steelmaking operations.
However, the Agency concluded that further subdivision of the
continuous casting subcategory is not . warranted. The process and
equipment is basically the same for all continuously cast products.
Differences among casters are found in the casting control parameters
such as temperature, tundish nozzle pouring rates, withdrawal rates,
cooling rates, and type of caster design. These parameters, however,
do not significantly affect wastewater quantity or quality.
Final Products
Continuous casting operations produce a wide variety of semi-finished
products, varying in material composition and geometric form. The
basic process, though, of transforming molten steel to a semi-finished
product is the same. Sampling data do not indicate any significant
differences between carbon steel casters and specialty steel casters
nor among billet, bloom, or slab casters. Consequently, the Agency
concluded that further subdivision based upon final product is not
appropriate.
Raw Materials
The Agency found that raw materials do not distinguish continuous
casting facilities. The sampling data for specialty and carbon steel
casters exhibit no appreciable differences in the type and nature of
wastewaters produced. Sampling data are presented in Section VII.
387
-------
Wastewater Characteristics
Although continuous caster wastewaters are distinguishable from those
of the other steel industry subcategories, a review of sampling data
indicates no discernible pattern or apparent division among casters,
regardless of caster type or the type of steel cast. The Agency,
therefore, concludes that it is not appropriate to further subdivide
the subcategory on the basis of wastewater characteristics.
Wastewater Treatability
Continuous casting wastewater treatment does not vary appreciably from
plant to plant. While the Agency observed differences in the
concentrations of wastewater constituents, it also noted a common
approach to wastewater treatment. The major treatment components used
in these operations are gravity sedimentation, filters, and recycle
systems. The Agency concludes that further subdivision based upon
wastewater treatability considerations is not appropriate.
Size and Age of Facilities
The Agency considered the impact of size and age on subdivision of the
continuous casting subcategory. It analyzed possible correlations
relating the effects of age and size upon such elements as wastewater
flows, wastewater characteristics, and the ability to retrofit
treatment equipment to existing facilities. No relationships were
found, and size and age were determined to have no impact upon
subdivision.
There is no correlation between the size of a casting shop and any
pertinent factor such as process water usage or wastewater
characteristics. Figure IV-1 shows a plot of discharge flow rates (in
gallons/ton) versus production capacity (in tons/day) for continuous
casters. The size of the caster shop has no bearing upon the ability
to recycle and subsequently attain a low discharge flow rate. A
review of analytical data for sampled plants (presented in Section
VII) does not show any relationship between size and the
characteristics of the wastewater generated. Thus, the Agency
concludes that further subdivision based upon the size of casting
shops is not warranted.
"Age" was examined as a possible basis for subdivision as it relates
to feasibility and cost of retrofit. The concept of age for a casting
shop is not particularly important as the casting process is a
relatively new development. The DCP data indicate the "oldest" caster
now in operation was installed in 1955 with most being built in the
1960's. Accordingly, there is not much variation in the age of the
various casting shops. A comparison was made, however, of age and
process water usage in a similar manner as was performed for the size
of a caster shop. Figure IV-1 also illustrates this comparison. As
with the flow versus size plot, no relationship is evident. Thus, the
age of a shop has no effect upon the ability to recycle process water
and attain a low effluent discharge.
388
-------
Further analysis indicates that the age of a caster shop in no way
affects the quality or quantity of wastewaters generated. Older shops
generate the same kind and amount of wastewaters as newer shops. In
addition, the treatabillty of these wastewaters is the same.
The Agency also addressed the ability to retrofit water pollution
control equipment as part of the age analysi-s. The ability to
retrofit equipment has been demonstrated at several older plants as
shown in Table IV-1 . In ciddition, the Agency analyzed the cost of
retrofit to determine whether older plants require greater capital
expenditures than newer plants. The D-DCPs solicited this retrofit
cost information, and of the nine plants surveyed, none reported any
costs due to retrofit. While there were probably some retrofit costs
in all cases where wastewater treatment facilities were added to
existing casters, based upon the responses received to D-DCPs in this
and other subcategories, EPA concludes that such costs are not
significant.
Based upon the above, the Agency finds that both old and newer
production facilities genercite 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
The location of continuous casting facilities has no apparent impact
upon subdivision. The Agency analyzed the relationship between plant
location and pertinent factors such as process water use and
wastewater characteristics. No discernible pattern was revealed.
Most of the plants are located east of the Mississippi River. Six are
located in Texas, four in .California, and one each in Oklahoma,
Colorado, and Oregon. One caster is located in the arid west and
requires the use of only minimal quantities of water from a local
river. Consideration was given to the consumptive use of water, since
the model treatment systems involve the use of evaporative cooling
towers. However, the effects due to the consumptive use of water are
minimal. As a result, the Agency concludes that further subdivision
on the basis of geographic location is not appropriate.
Process Water Usage and Discharge Rates
The Agency examined process water usage and discharge rates as a
possible factor of subdivision. Table IV-2 presents flow averages and
ranges for those plants which supplied flow data. Data were compiled
according to the type of steel cast, the type of product cast, the
number of strands, and the type of caster. Although the data tend to
indicate that specialty casters use less water, the Agency concludes
that similar effluent flow rates for carbon and specialty casters can
be achieved by all casters if the recycle technology is used.
389
-------
Therefore, the Agency concludes that further subdivision based upon
process water usage or discharge rates is not appropriate.
390
-------
TABLE IV-1
EXAMPLES OF PLANTS THAT HAVE DEMONSTRATED THE
ABILITY TO RETROFIT POLLUTION CONTROL EQUIPMENT
CONTINUOUS CASTING
Plant Code
0284A
0132
0136B
0188C
0316
0316A
• 0432A
0456A
04 76 A
0584F
0620C
0652
0672B •
0764
Mill Age Year
1974
1970
1967
1976
1965
1970
1969
1970
1969
1968
1975
1968
1975
1976
Treatment Age Year
1974, 1976
after 1977
after 1977
after 1977
after 1977
after 1977
1974
. after 1977
1977
1970, 1973
after 1977
1971, 1973
after 1977
after 1977
391
-------
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CONTINUOUS CASTING SUBCATEGORY
SECTION V
WATER USE AND WASTEWATER CHARACTERIZATION
Introduction
Process water use and characterization of the wastewaters generated by
the continuous casting process are the principal considerations in
determining pollutant loads, developing treatment alternatives, and
estimating costs. This section describes the water originating from
the process. The wastewater system description is limited to those
streams which come into contact with raw material, products, or
by-products associated with the process. This excludes the various
noncpntact cooling water systems that are used in the continuous
casting process. Wastewater characterization is based upon analytical
data obtained during field sampling surveys.
Water Use
The continuous casting process has three main plant water systems.
1. Copper mold noncontact cooling water system
2. Machinery noncontact cooling water system
3. Cast product spray contact cooling water system
Only the cast product spray contact cooling water is subject to this
regulation as the other two systems use noncontact cooling water only.
However, leaks of cooling water into the process water system would be
treated with the process water.
The cast product is only partially solidified when it emerges from the
molds. The interior core of the product is still molten steel at that
time. The cast product cooling water system sprays water directly
onto the product for further cooling. As the cast product surface
oxidizes, scale is washed away by the cooling water. The spray water
also becomes contaminated with oils and greases which are released by
the hydraulic and lubrication systems. As the cast product is
discharged on to the run-out tables for final cooling, additional
scale flakes off and drops beneath the tables. Sometimes this scale
is sluiced to the spray cooling water pit.
Approximately 5-10% of the water sprayed on the product is evaporated
with the balance discharged to a scale pit. Temperatures of
discharged spray waters range from 54° to 60°C (130° to 140°F). Other
minor wastewater systems include spray cooling of cast product,
acetylene torch cut-off, and miscellaneous cooling or sluicing.
A common industry practice is to recycle the process wastewater.
Table IX-2 is a list of the plants for which flow and recycle rate
395
-------
data were received. As shown, wastewaters are recycled at the vast
majority of plants at rates exceeding ninety percent. Several plants
report no discharge of process wastewater from continuous casting
operations.
Wastewater Characterization
The continuous casting process produces scale and oils and greases as
a result of the spray cooling process. Withdrawal and guide rolls
guide the cast product through the solidification stage. Since the
cast product is hot, the surface oxidizes and the resulting scale is
washed out with the spray cooling water. Additional scale flakes off
when the cast product is discharged onto the caster run-out tables.
Hydraulic and lubrication systems add oils and greases to the
wastewaters.
The raw wastewater discharges from the carbon and specialty steel
continuous casters are similar in waste characterization with regard
to the previously limited pollutants, suspended solids, oil and
grease, and pH. Tables V-l and V-2 present raw wastewater flow and
quality data for the plants sampled. The wastewater pollutant
concentration data represent the contribution of pollutants from the
casting process. Data for Plant AE, sampled during the original
guidelines survey, are not presented, since this operation was
resampled as Plant 075 during the toxic pollutant survey. The toxic
pollutant survey data are more complete and more representative of
current plant operations.
The analytical data presented in Table V-2 show the type and quantity
of toxic organic and toxic metal pollutants which have been found in
continuous casting wastewaters. Section VI deals more specifically
with the selection of pollutants, in terms of regulation, monitoring,
and the origin of these pollutants.
396.
-------
TABLE V-l
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
ORIGINAL GUIDELINES SURVEY
CONTINUOUS CASTING
Net Concentration of Pollutants in Raw Wastewate
Reference Code ,
Plant Code
Sample Point (s)
Flow, gal /ton
Suspended Solids
Oil and Grease
pH (Units)
Chromium
Copper
Lead
Zinc
0868B
AF
7-9
1475
mg/1
89
22
6.6
NA
0.12
-
1.0
0684E
Q
16
— •
mg/1
126
16.3
8.9
0.060
0.020
NA
0.040
Average
1475
mg/1
108
19
6.6-8.9
0.060
0.070
0.52
- : Calculation yielded a negative result.
NA: Not analyzed
NOTE: Plant B, a pressure slab caster, is not addressed here as it was scheduled
for shutdown in September of 1980.
Raw wastewater data for Plant D was unobtainable during sampling.
397
-------
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398
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CONTINUOUS CASTING SUBCATEGORY
SECTION VI
WASTEWATER POLLUTANTS
Introduction
This section describes the rationale for selecting those pollutants
for which effluent limitations and standards have been promulgated for
continuous casting operations.
Final selection of those pollutants was based upon an analysis of
wastewater samples collected during plant visits. This list of
pollutants was confirmed and augmented through extensive field
sampling that included analysis for toxic pollutants.
Conventional Pollutants .
The previously limited pollutants, suspended solids, oil and grease,
and pH, were chosen based upon the nature of the raw materials and
equipment used in the casting process. Suspended solids was chosen
because a large quantity of scale is generated by the casting process
and carried out by the spray cooling waters. When scale comes into
contact with cooling water, the particulates are transferred to the
wastewater. The suspended solids concentration indicates the degree
to which the process wastewater has been contaminated. Toxic metals
are often entrained with solids suspended in the wastewater. The
removal of suspended solids often results in removal of toxic metals.
The Agency selected oil and grease for limitation, because it is often
found in caster wastewaters. Lubrication is a necessary part of the
continuous casting process. Oil spills, line breaks, excessive
application of lubricants, and equipment washdown all contribute to
the presence of oil and grease in continuous casting wastewatets.
Finally, the Agency chose pH, a measure of the acidity or alkalinity
of a wastewater, because of the environmentally detrimental effects
which can result from extremes in pH. In addition, corrosion and
scaling conditions, which foul or damage process or treatment
equipment, can be caused by extreme pH levels. The pH of continuous
casting process wastewaters typically falls within the range of 6.0 to
9.0 standard units.
Toxic Pollutants
This study was also directed at evaluating toxic pollutant discharges.
The toxic pollutants analyzed during the verification sampling phase
of the project included those pollutants which were classified by the
Agency as "known to be present." This determination was made as a
result of industry responses to the DCPs and analyses performed during
399
-------
the screening phase. Table VI-1 lists those toxic pollutants for
which analyses were performed. A final toxic pollutant list was
compiled by including all pollutants which were detected in the raw
wastewater at an average concentration of 0.010 mg/1 or greater. This
list is presented in Table VI-2 for the continuous casting subcategory
and includes the previously discussed limited pollutants. The
pollutants listed in Table VI-2 are considered to be those which are
most representative and indicative of casting operations, and they are
addressed accordingly throughout this report.
Toxic metal pollutants originate in the molten steels which are cast.
These metals find their way into the wastewaters through the scale
particulates which are washed from the cast product. Three organic
pollutants/ parachlorometacresol, di-n-butyl phthalate, and di-n-octyl
phthalate, were also detected in caster wastewaters at significant
levels. The phthalate compounds, however, are not believed to be
characteristic of the casting process. Evidence developed during the
sampling inspections indicates that their presence is probably related
to plasticizers in the tubing used for the automatic collection of
wastewater samples. With respect to parachlorometacresol, it appears
in concentrations that, aside from recycle, are below treatable
levels. For these reasons, the Agency has not promulgated effluent
limitations and standards for this pollutant. The Agency believes
that this pollutant does not tend to concentrate in recycle systems.
Although the concentrations of these pollutants in recycle system
blowdowns will be approximately the same as in the discharge from
once-through systems, the mass loadings of these pollutants will be
reduced proportionately to the degree of recycle. Accordingly, with
the high degree of recycle incorporated in the BAT, NSPS, PSES, and
PSNS technologies, the Agency believes that compliance with the
effluent limitations and standards for conventional and toxic metal
pollutants will indicate a comparable reduction in the discharge of
those toxic organic pollutants that may be present in continuous
casting wastewaters.
400
-------
TABLE VI-1
TOXIC POLLUTANTS KNOWN TO BE PRESENT
CONTINUOUS CASTING
Toxic Pollutant
Numeric Designation
22
23
34
39
Pollutant
68
69
86
(1)
(1)
119
120
122
125
128
Parachlorometacresol
Chloroform
2,4-Dimethylphenol
Fluoranthene
Di-n-butyl phthalate
Di-n-octyl phthalate
Toluene
Chromium
Copper
Lead
Selenium
Zinc
(1) Appearance of this pollutant in continuous casting wastewater
is believed to be due to plasticizers found in sampling equipment.
401
-------
TABLE VI-2
SELECTED POLLUTANTS
CONTINUOUS CASTING
Total Suspended Solids
Oil and Grease
PH
119 Chromium
120 Copper
122 Lead
125 Selenium
128 Zinc
402
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CONTINUOUS CASTING SUBCATEGORY
SECTION VII
CONTROL AND TREATMENT TECHNOLOGY
Introduction
The Agency established the BPT, BAT, PSES, PSNS, and NSPS alternative
treatment systems after determining the current level of treatment in
the industry. The various treatment technologies were then formulated
as "add-ons" to this primary level of treatment. Control and
treatment technologies available for the various levels of treatment
are discussed in this section. The Agency has promulgated effluent
limitations and standards for these levels of treatment based upon an
evaluation of the effluent monitoring data obtained during plant
visits and .treatment capabilities demonstrated in this and other
subcategories. Treatment system summaries, schematics, and wastewater
monitoring data for the visited plants are also presented in this
section.
Summary of Treatment Practices Currently Employed
As noted earlier, the wastewater produced by the continuous casting
process primarily results from the spray water system which brings
cooling water into contact with the hot semi-finished product.
The basic treatment systems used at continuous casting plants include
primary settling devices, which are often scale pits equipped with
drag link conveyors and oil removal facilities. The scale pit
overflow is often treated in settling lagoons, filters, or clarifiers.
The treated water is then recycled through cooling towers with a small
blowdown discharged. (About 35 percent of the industry reports no
discharge and recycle of 100% of the wastewater.) Cooling towers are
used to reduce the process water temperature prior to recycle.
Chemical flocculation systems are provided with clarifiers to aid in
the settling of solids. Clarifier underflows are then dewatered by
vacuum filters or centrifuges.
Several different types of filters are used. Flat bed filters, with
disposable filter belts, or deep bed filters are often used. The deep
bed filters require backwashing to clean the filter media. Flat bed
filters use a media which is disposed of along with the solids
filtered. The deep bed filters discharge backwash waters to sludge
tanks. Filtered solids are then disposed of in landfills. The
capital cost of flat bed filters is approximately 1/3 that of deep bed
filters. In addition, flat bed filters do not require the backwashing
and other equipment necessary to operate deep bed filters effectively.
Four casting plants presently use flat bed filters. Thirteen plants
have deep bed filters. Nine of these plants use central treatment
systems. In these cases, the deep bed filters treat other wastewaters
403
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in addition to continuous casting wastewaters. Filtration of the
continuous casting discharge will remove toxic metals entrained in the
suspended solids, as those metals are in particulate form rather than
in a dissolved state.
Table III-2 presents the treatment technologies and modes of operation
for al-1 caster plants.
Control and Treatment
Technologies Considered for Toxic Pollutant Removal
The detection of toxic metals in continuous casting wastewaters
required the consideration of additional treatment for BAT, NSPS,
PSES, and PSNS. The blowdown treatment technologies selected for
review are deep bed filtration, lime precipitation and sedimentation,
and vapor compression distillation. Consideration was also given to
the use of sulfide precipitation as an alternate technology. This was
ultimately deleted because of the limited benefits that it might
achieve over lime precipitation. A brief discussion of these
technologies follows.
A. 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.
Particulate pollutant removal is accomplished by passing the
wastewater stream, either under pressure or by gravity, through a
filter media. The filter media, generally sand, anthracite 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. As indicated above,
filtration is used at continuous casting operations. Flat bed filters
which are commonly used are, however, much less effective than the
multimedia filters described here.
B. Lime Precipitation and Sedimentation
Lime addition, followed by sedimentation, is used to further reduce
the levels of particulate and dissolved toxic 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 technology is well demonstrated in this
industry.
c- Vapor Compression Distillation
Vapor compression distillation is a process by which zero discharge
can be achieved. In this process the wastewater is evaporated
404
-------
concentrating the constituents in the wastewater to slurry
consistency. The steam distillate is recondensed and recycled back to
the production process for reuse. 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 of the system requires a high calcium to sodium
ratio (hard water).
Summary of. Sampling Visit Data
The Agency visited seven continuous casting facilities during the
overall study* Four of these plants were visted for the original
study, and four were surveyed during the latter toxic pollutant study.
Four of the seven plants are carbon steel casters, and three are
specialty steel casters. One plant was sampled twice; as Plant AE for
the original study and as Plant 075 for the toxic pollutant study.
This plant is addressed as Plant 075, since the data obtained during'
the second study,are considered to be more representative of present
operations.
Table VII-1 provides a legend for the various control and treatment
technology abbreviations used throughout this report. Tables VII-2
and VI1-3 present the raw and effluent wastewater loads for the above
mentioned continuous casting plants. Figures VII-1 through VII-7 are
wastewater treatment schematics of the plants sampled. A brief
description of the treatment practices and facilities at each of the
sampled plants follows.
Plant AF (0868B) - Figure VII-1
Wastewater from the continuous caster at this plant is treated
together with vacuum degassing wastewater. Treatment consists of a
scale pit with oil skimming, high flow rate pressure filters, a
cooling tower, and a recycle pump system. Slowdown is less then 2
percent of the applied flow. Deep bed filters are used with the
backwash waters being discharged to the caster scale pit.
Plant D (0248B) - Figure VII-2
Caster wastewater is first settled in a clarifier. The clarifier
underflow is batch discharged to the river, while the overflow is
pumped through a filter and then recycled to the process.
Plant Q (0684E) - Figure VII-3
Caster sprays are discharged to a collection sump for settling and
then pumped to a cooling tower. Water is recycled from the cooling
tower to the process. There is no discharge from this system.
405
-------
Plant 071 (0284A) - Figure VII-4
This plant has a scale pit and pressure sand filters to remove
suspended solids from the caster machine spray waters. Filter
backwash is discharged to a sludge concentrator. Sludge is hauled
away by a contractor, and the concentrator overflow is returned to the
scale pit. Filtered water is recycled to the caster sprays after
passing through a cooling tower. There is no discharge from this
system.
Plant 072 (0496) - Figure VII-5
This plant has a central treatment system for vacuum degassing and
continuous casting wastewaters. Caster wastewater is discharged to a
scale pit which receives degasser wastewater as well. The wastewater
is then recirculated through a cooling tower to pressure sand filters
Backwash waters are discharged to the scale pit, which overflows to a
large lagoon or reservoir. Filter effluent is passed through another
cooling tower and finally recycled to the process. Aside from filter
backwash, this system achieves zero discharge, since all of the
wastewaters are recirculated.
Plant 075 (0584F) - Figure VII-6
Plant 075 was originally sampled in 1974 as Plant AE. Modifications
to the treatment system caused the revisit. Caster wastewater is
first pumped to primary scale pits. Some water is recycled to the
process from there, but most of it is passed through flat bed filters.
A °lowdown om the filte.rs is discharged to lagoons. The filter
effluent is recirculated through a cooling tower and then pumped to
walnut shell deep bed filters. The backwash is discharged to the
lagoons, as the filter effluent is recycled to the caster sprays
Recycle is approximately 97 percent of the process flow.
Plant 079 (0060K) - Figure VII-7
This plant uses flat bed filters and recycle with 0.8% blowdown to a
scale pit, which serves as a final settling pond. Filtered water is
recycled to the caster after passing through a cooling tower.
Effect of_ Make-up Water Quality
Where the mass loading of a limited pollutant in the make-up wal-er 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.
As shown in Table VII-4, the effect of make-up water quality for
continuous casting operations is not significant when compared to the
raw waste loadings for the limited pollutants. The pollutants in the
406
-------
intake water supply do not exceed 5 percent of the pollutants in the
raw wastewaters. Thus, the Agency has determined the effluent
limitations and standards should be applied on a gross basis, except
to the extent allowed by 40 CFR 122.63(h).
407
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TABLE VII-1
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
t: U
T
n
Untreated
Treated
P Process Wastewater % of raw waste flow
F Flume Only % of raw waste flow
S Flume and Sprays % of raw waste flow
FC Final Cooler % of FC flow
BC Barometric Cond. % of BC flow
VS Abs. Vent Scrub. % of VS flow
FH Fume Hood Scrub. % of FH flow
3. REt,n Reuse, where t • type
n = % of raw waste flow
t: U = before treatment
T a after treatment
4. BDn
Control Technology
10. DI
11. SR
12. CC
13. DR
Disposal Methods
20. H
21. DW
Slowdown, where n s discharge as % of
raw waste flow
Deionization
Spray/Fog Rinse
Countercurrent Rinse
Drag-out Recovery
Haul Off-Site
Deep Well Injection
408
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TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 2 ' -
C.
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 Evaporation, Multiple Effect
24. ES Evaporation on Slag
25. EVC Evaporation, Vapor Compression Distillation
"D. Treatment Technology
30. SC Segregated Collection
31. E Equalization/Blending
32. Scr Screening
33. OB Oil Collecting Baffle
34. SS Surface Skimming (oil, etc.)
35. PSP Primary Scale Pit
36. SSP Secondary Scale Pit
37. EB Emulsion Breaking
38. A Acidification
39. AO Air Oxidation
40. GF Gas Flotation
41. M Mixing
42. Nt Neutralization, where t = type
t: L = Lime
C = Caustic
A = Acid
W = Wastes
0 s Other, footnote
409
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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. T
47. TP
48. SLn
49. BL
50. VF
51. Ft,m,h
Flocculation, where t = type
t: L = Lime
A s 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
53. CO
S » Sand G = Gravity
0 = Other, P = Pressure
footnote
Chlorination, where t = type
ts A - Alkaline
B = Breakpoint
Chemical Oxidation (other than CLA or CLB)
410
-------
TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 4 '
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 » 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 s 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
411
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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
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
412
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CONTINUOUS CASTING SUBCATEGORY
SECTION VIII
COST, ENERGY, AND NON-WATER QUALITY IMPACTS
Introduction
This section addresses the cost, energy, and non-water quality impacts
of applying the different levels of pollution control to continuous
casting operations. It includes - a discussion of actual treatment
costs incurred at sampled plants, alternative treatment technologies,
and the cost, energy, and other non-water quality impacts associated
with the application of the BPT, BAT, NSPS, PSES, and PSNS alternative
treatment systems. In addition, the consumptive use of water is
addressed.
Actual Costs Incurred a_t Plants Sampled For This Study
The water pollution control costs for the continuous casting
operations visited during this study are presented in Table VIII-I.
The costs were derived from data supplied by the industry at the time
of sampling or from data submitted in response to the D-DCPs. The
costs haverbeen adjusted to July 1978 dollars. In some 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, those costs were provided by
the plants.
The capital cost data from the plants noted above were compared with
the Agency's estimated expenditures and factored on the basis of
production for these plants. Many component costs may vary due to the
fact that different plant personnel use different methods to determine
costs. Despite these limitations, the comparison indicates that model
cost estimates of seven continuous casting operations are
representative of the actual costs of these operations.
425
-------
Plant
0584 F
0868 B
0384 A(2)
0384 A(3)
0528 A
0620 A
0684 E
Total Cost
CONTINUOUS CASTING
EFFLUENT TREATMENT COST COMPARISON
Actual
Cost
2,413,632
3,559,140
2,028,858
10,025,762
5,926,290
1,030,000
4,397,468
29,381,150
Estimated(l)
Cost
4,401,000
2,338,000
2,274,000
4,397,000
5,828,000
1,084,000
2,682,000
23,004,000
(l) Estimates are made on a tonnage (TPD) basis.
(2) Billet casting operation.
(3) Slab casting operation.
Reference is made to the discussion presented in Volume 1 for further,
verification of the applicability of the treatment model costs.
The data show that industry costs are about 28% higher than the
Agency's estimate for the seven continuous casting treatment systems.
However, most of the difference is attributed to the continuous slab
caster at Plant 0384 A, which has an applied flow which is twice that
of the model flow. EPA estimates are based upon production and not
upon applied flow. Thus, the treatment components in place at this
facility are larger than the corresponding model size treatment
components, which are more typical of the subcategory. Industry costs
are about 4 percent higher than the Agency's estimates without
considering costs for this facility. In any event, the above data
demonstrate reasonably good agreement between actual industry costs
and EPA estimates. The Agency concludes that its cost estimates for
the continuous casting subcategory reasonably reflect actual costs.
Control and Treatment Technologies (C&TT)
Recommended For Use in Continuous Casting
The BPT and BAT model treatment system components are presented in
Table VII1-2. The model treatment systems for BPT, BAT, NSPS, PSES,
and PSNS are depicted in Figure VIII-1. It should be noted that these
specific C&TT components are not required. Any treatment system which
achieves compliance with the proposed effluent limitations is
adequate.
On this summary table, the following items are described for each
step:
1. Description of the treatment and/or control step
2. Implementation time
3. Land usage
426
-------
Cost, Energy, and Non-water Quality Impacts
Estimated Costs for the Installation of.Pollution Control Technologies
A. Costs Required to Achieve the BPT Limitations
In order to develop BPT compliance costs, it was necessary to
develop a BPT model sized to represent the average continuous
casting plant found in the United States. The model size
(ton/day) was developed on the basis of the average production
capacity of all continuous casters. The treatment model
components and flow rates are also representative of actual
continuous casting operations. The unit cost for each treatment
model component was developed. These costs are presented in
Table VIII-3 along with BPT model annual costs and raw and
effluent flows and pollutant concentrations.
The capital requirements needed to achieve the BPT limitations
for the continuous casting operations were determined by applying
the treatment model component costs, adjusted for size, to each
casting operation. The estimates of the expenditures required to
bring these plants from current treatment levels to compliance
with the BPT limitations, were necessary to assess the economic
impact of the effluent limitations and standards upon the
industry. The estimated capital cost to comply with BPT for this
subcategory is $64.4 million (July 1978 dollars). Of this total,
equipment valued at $59.6 million is currently in-place at
various casting facilities as of July 1981. Hence, $4.8 million
remains to be spent for additional treatment equipment. The
incremental annual operating costs for the BPT treatment systems
remaining to be installed is $0.8 million.
B. Cost Required to Achieve the BAT Limitations
The Agency considered three alternative treatment systems for the
BAT model treatment system as described in Section X. The
investment and annual expenditures for each of the BAT
alternative treatment systems, in excess of BPT expenditures, are
presented in Table VII1-4. The subcategory investment and annual
expenditures for each BAT alternative are shown below.
BAT Alternative Investment Cost Annual Cost
1
2
3
$ 846,000 $ 115,000
$ 3,054,000 $ 425,000
$39,755,000
$5,500,000
C. Costs Required to Achieve NSPS and .PSNS
The Agency considered three treatment alternatives for continuous
casting facilities which are constructed after the proposal of
these standards. The NSPS and PSNS treatment alternatives are
similar to the BPT/BAT model treatment systems except that a
427
-------
greater degree of recycle is achieved at NSPS/PSNS-1 than at BPT.
Also the in-line BPT flat bed filter is replaced by a pressure
filter at NSPS/PSNS. The acid neutralization step, the final
step in alternative 2, is not necessary in the PSNS-2
alternative. The NSPS and PSNS treatment alternatives are
discussed in Sections XII and XIII, while the treatment model
costs are presented in Table VII1-5. Only model costs are
presented, since projections of capacity addition were not made
as part of this study.
E. Costs Required to Achieve PSES Compliance for the Industry
The Agency considered four pretreatment alternatives for existing
continuous casting facilities which discharge to POTW systems.
These PSES alternatives are identical to the BPT/BAT model
treatment systems, with the exception of the acid neutralization
step which is not a part of the PSES-3 alternative. The PSES
treatment alternatives are discussed in Section XIII, while the
treatment model costs are presented in Table VII1-4. The
subcategory costs for these alternatives follow:
PSES Alternative
1
2
3
4
Investment Cost-$ Annual Cost-$
8,901,000
141,000
443,000
8,540,000
The costs for PSES Alternatives 2 through 4
the costs for PSES-1.
1,330,000
19,000
62,000
1,182,000
are incremental to
Energy Impacts
Moderate amounts of energy are required to operate the various
treatment systems considered for the continuous casting subcategory.
The major energy expenditures occur at the BPT treatment level, while
BAT-l/PSES-2 and BAT-2/PSES-3 require minor incremental energy
expenditures. The incremental energy requirement for BAT-3/PSES-4 is
133 kw which is more than twenty times that of BAT Alternative 1.
A. Energy Impacts at BPT
The estimated energy requirements are based upon the assumptions
that treatment systems similar to the model treatment system will
be installed at all continuous casting shops, and, that these
systems will have flows similar to those of the model. On this
basis, the estimated annual energy usage for BPT treatment
components for all continuous casting operations is 108.7 million
kilowatt-hours of electricity. This estimate represents about
0.19 percent of the 57 billion kilowatt-hours used by the steel
industry in 1978.
428
-------
B.
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 needed to upgrade
facilities from BPT to the three BAT alternatives follow.
BAT
Alternative
1
2
3
kwh per
year '
300,000
•1,200,000
21,200,000
% of 1978 Industry
Usage
0.00055
0.0021
0.037
Energy Impacts at NSPS and PSNS
The energy requirements for the NSPS and PSNS models follow. The
Agency did not evaluate the total energy requirements for NSPS
and PSNS, since estimates of future additions were not made as
part of this study.
Model
NSPS-1,PSNS-1
NSPS-2
PSNS-2
NSPS-3
PSNS-3
Energy Impacts at PSES
kwh per year
2,612,000
2,660,000
2,652,000
3,460,000
3,452,000
The estimated energy requirements for the four PSES alternative
treatment systems are based upon the same assumptions noted for
BPT. The estimates for the four systems are:
PSES
Alternative
1
2
3
4
kwh per
year
18,116,000
84,000
280,000
5,936,000
% of 1978
Industry Usage
0.032
0.00015
0.00049
0.010
The energy requirements for PSES Alternatives 2 through 4 are
incremental to the PSES-1 energy requirements. As stated below,
the Agency believes these energy requirements are justified by
the effluent reduction benefits. •
429
-------
Non-water Quality Impacts
In general, the non-water quality impacts associated with the
alternative treatment technologies are minimal. The three impacts
evaluated are air pollution, solid waste disposal, and water
consumption.
A. Air Pollution
The Agency expects no adverse air pollution
with any of the model treatment systems.
B. Solid Waste Disposal
impacts associated
The treatment steps incorporated in the BPT and BAT treatment
systems will generate significant quantities of solids eind oils
and greases. A summary of the solid waste generation, on a dry
basis, for the continuous casting subcategory, at the BPT, BAT,
and PSES levels of treatment, follows.
Treatment
Level
Solid Waste Generation
Continuous Casting Subcategory
(Tons/Year)
BPT
BAT-l,BAT-2,BAT-3
PSES-1
PSES-2,PSES-3,PSES-4
19,740
3,290
The BPT and PSES-1 treatment levels remove virtually all of the
solid wastes which the model treatment systems are capable of
removing. Most of the solid waste is comprised of suspended
solids (principally iron oxides) which require proper disposal,
if they are not reused in the iron and steel making operations.
The oils, which can not be reused or reclaimed, also require
proper disposal, generally off-site.
The estimated amounts of solid wastes and
generated by the NSPS/PSNS models follow.
oils and greases
Treatment
Level
NSPS-1, PSNS-1
NSPS-2, PSNS-2
NSPS-3, PSNS-3
C. Water Consumption
Solid Waste Generation
Treatment Model
(Tons/Year)
470
470
470
The Agency analyzed the consumption of water for the alternative
treatment systems. The total process water usage and the
consumptive use of water in the continuous casting subcategory
430
-------
are estimated to be 233 and 3.44 million gallons of water per day
(.MGD), respectively, as of July 1978. Upon installation of the
BPT model or BAT alternative treatment systems, this total will
increase slightly to 3.84 or 3.88 MGD respectively. Therefore,
the fraction of water actually consumed is very small, about
1.7%. This slight increase in the amount of water consumed is
insignificant compared to the remaining water that will be
recycled. The volume of fresh water required for use as make-up
will be greatly reduced due to recycle, and very little
additional fresh water will become contaminated.
The Agency concluded that the pollution control benefits
associated with recycle in this subcategory justify the above
minor water losses on both a nation-wide and an arid or semi-arid
region basis. Three of the four plants the Agency considers to
be in arid or semi-arid regions have recycle systems installed
for continuous casting operations. Hence, the effect of the
limitations on additional water losses for these plants will be
negligible. The fourth plant does not have a continuous casting
operation. If one were installed at this facility, only about
0.3 MGD would be lost. The Agency concludes that losses of this
magnitude at this site are not significant.
Summary of Impacts
In summary, the Agency concludes that the pollutant reduction benefits
described below for the continuous casting subcategory outweigh the
adverse energy and non-water quality environmental impacts.
Direct Discharges
Effluent Loads (Tons/Year)
Flow, MGD
TSS
Oil and Grease
Toxic Metals
Raw Waste
200
18,268
7,612
493
BPT
4.4
266.5
66.6
10.8
BAT
0.9
29.3
5.9
1 .7
Indirect Dischargers
Effluent Loads (Tons/Year)
PSES
Raw Waste 2
Fow, MGD
TSS
Oil and Grease
Toxic Metals
33.3
3,045
1,269
82.2
0.2
3.7
0.7
0.6
The Agency also concludes that the effluent reduction benefits
associated with compliance with new source standards (NSPS, PSNS)
outweigh the adverse energy and now-water quality environmental
impacts.
431
-------
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433
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TABLE VIII-2
CONTROL AND TREATMENT TECHNOLOGIES
CONTINUOUS CASTING SUBGATEGORY
E
H
Description
Scale Pit with Drag Tank and
Surface Skimming - Initial solid
•waste reduction is accomplished
via gravity sedimentation. The
skimmer provides initial surface
oil reduction.
Flat Bed Filter - This step
provides additional solid
waste reduction.
Cooling Tower - The heat load
of the process recycle is re-
duced in this step.
Recycle - Ninety-six percent of
the filter effluent is returned
to the process. This step re-
duces the pollutant load dis-~
charged from the process.
Pressure Filter - Additional
solid waste and oil and grease
reduction is accomplished.
Neutralization with Lime - The
addition of lime results in the
formation of metallic hydroxide
precipitates which can be removed
by sedimentation.
Inclined Plate Separator - Through
sedimentation, additional suspended
solids and particulate metallic
pollutants are removed.
Neutralization with Acid - The
pH of the treatment system
effluent is monitored and adjusted
with acid.
Imp1ement at i on
Time (months)
6-8
Land
Usage (ft2)
700
15-18
18-20
12-14
2400
900
625
15-18
12
625
625
10-12
8-10
50
434
-------
TABLE VII1-2
CONTROL AND TREATMENT TECHNOLOGIES
CONTINUOUS CASTING SUBCATEGORY
PAGE 2
C&TT
Step
Description
Implementation
Time (months)
Land
Usage (ft )
Vapor Compression Distillation -
This step produces v?ater of dis-
tillate quality for recycle to
the process.
Recycle - The water produced in
step I is completely recycled to
the process.
1000
625
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CONTINUOUS CASTING SUBCATEGORY
SECTION IX
EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICATION
OF THE BEST PRACTICABLE CONTROL TECHNOLOGY
CURRENTLY AVAILABLE
Introduction
The Agency has promulgated BPT limitations which are the same as those
orginally promulgated in 19741 and reproposed on January 7, 1981 (46
FR 1858).2 A review of the treatment processes and effluent
limitations associated with the continuous casting subcategory
follows.
Identification of BPT
The BPT model treatment system is the same as the system used to
develop the original BPT limitations promulgated in June 1974. This
system includes a primary scale pit equipped with a drag link conveyor
and oil removal facilities, a flat bed filter, a cooling tower, and
recycle. Suspended solids collected by the scale pit are disposed
internally or landfilled. Accumulated oils are hauled away or
incinerated. The overflow from the scale pit is pumped to a flat bed
filter." The filter effluent is recycled through a cooling tower to
the process, except for a small blowdown, which is discharged to a
receiving stream. Make-up water is added to the recycle system to
compensate for evaporative and blowdown losses.
Figure IX-1 depicts the BPT model treatment system for continuous
casters. The BPT effluent limitations, which represent 30-day average
and daily maximum values are presented below:
JSee EPA 440/1-74 024a; Development Document for Effluent Limitation
Guidelines and New Source Performance Standards for the Steelmaking
Segment of the Iron and Steel Manufacturing Point Source Category,
June 1974.
2See EPA 440/1-80/024b; Proposed Development Document for Effluent
Limitations Guidelines and Standards for the Iron and Steel
Manufacturing Point Source Category, December 1980, Volume III.
441
-------
Pollutant
Suspended Solids
Oil and Grease
pH (Units)
kg/kkg of Product
(lb/1000 Ib of Product)
Daily
Maximum
0.0780
'0.0234
30-Day
Average
0.0260
0.00780
6.0-9.0
Rationale for BPT Treatment System
As noted in Section VII, each . of the BPT model treatment system
components is in use at a number of continuous casting operations.
Justification of_ BPT
Table IX-1 presents sampled plant effluent data which support the BPT
effluent limitations. The ability to achieve the BPT effluent
limitations with flat bed and other types of filtration systems is
well demonstrated by those data. The Agency believes those plants are
representative of the industry. One sampled plant was not achieving
the BPT limitations, 'because filter backwash water was discharged
directly. Recycling the backwash for further treatment and increasing
the total system recycle rate would allow that plant to meet the
limitations. Hence, based upon the data from these plants and those
achieving zero discharge, the Agency concludes the BPT limitations are
achievable. Table IX-2 shows the basis for the applied and discharge
flows for the continuous casting subcategory.
442
-------
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TABLE IX-2
SUMMARY OF FLOWS AND RECYCLE RATES
CONTINUOUS CASTING SUBCATEGORY
Plane Code
0060
0076
0084A
0132
0136B
0188C
0248B
0284A
0316
0316A
0456A
0496
0596
0620A
0672A
0780
0740A
0180
0608A
0384A-1
0620B
0060K
0468F
0684E
0432A
0696A
OS48D
0476A
0060H
0384A-2
0584F
0112D
0468B
0528A
0444
0868B
0060D
0864C
0068B
0856F
0652
0460A
0204
0860H
0860B
Average Applied Flow m 3381 gal/ton.
Average Discharge Flow s 466 gal/ton.
"Average of Che Best" Discharge Flow
Applied Flow
(gal/ton)
_
1656
-
-
-
-
2000
564
-
-
-
1542
5161
22
547
1934
1415
4012
2764
3281
2000
2985
2187
1375
2496
1341
3755
16210
923
7062
3489
6408
927
4814
4294
8258
1678
-
6111
1278
1375
4509
2543
5318
5489
Discharge Flow
(gal/ton) 0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1.2*
4.0*
11*
16*
24*
25*
28*
49*
56
66
79
81
92
98
117
128
128
144
245
310
554
571
611
1278
1375
1527
2543
5318
5489
Operating Mode
RTF 100
RTF 100
RUP 100
RTF 100
RTF 100 .
RTF 100
RTF 100
RTF 100
RTF 100
RTF 100
RTF 100
RTF 100
RTF 100
RTF 100
RTF 100
RTF 100
RTF 99.9
RTF 99.9
RTF 99.6
RTF 97.1
RTF 98.9
RTF 99.2
RTF 98.7
RTF 96.5
RTF 97.8
RTF 95.1
RTF 97.9
RTF 99.5
RTF 90
RTF 98.6
RTF 97
RTF 98
RTF 86
RTF 97
RTF 94.3
RTF 96.2
RTF 67
RUP 90
OT
OT
RTF 66.2
REU 100
RET 100
OT
Basis
DCP
DCP
DCP
DCP Update
DCP Update
DCP Update
DCP
Survey
DCP Update
DCP Update
DCP Update
Survey
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
Survey
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
Survey
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
20 gal/ton.
* Flow values marked with an asterisk were used in the "average of the best" calculation.
- Inadequate questionnaire response.
444
-------
M
LU
tr
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in
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§
I
445
-------
-------
CONTINUOUS CASTING 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, ]984. BAT is determined by
reviewing subcategory practices and identifying the best economically
achievable control and treatment technologies employed within a
subcategory. In addition, a technology that is readily transferable
from another subcategory or industry may be identified as BAT.
This section identifies the model BAT flow rate, the three BAT
alternative treatment systems, and the resulting effluent levels
considered for continuous casting operations. The rationale for
selecting the treatment technologies is also presented. Finally, this
section addresses the Agency's selection of a BAT model treatment
system to serve as the basis for the BAT limitations.
BAT Model Flow Rate
Reanalysis of the available data has shown that the BPT discharge flow
of 125 gal/ton is much higher than the actual discharge flow
demonstrated by the plants having technology similar to the model
treatment technologies (i.e., primary scale pit with drag link
conveyor and surface skimming, flat bed filter, recycle, and cooling
towers). While the Agency is retaining a model BPT flow (which is
less stringent than might be justified), it has set the model BAT flow
at 25 gal/ton. Reference is made to Table IX-2 for the development of
the model flow rate. The Agency considered data for those plants With
blowdown flows up to 50 gal/ton. The Agency believes these plants are
representative of plants with good water management practices in the
subcategory. The Agency did not select zero discharge as the model
flow for continuous casting operations because it does not believe
zero discharge can be achieved at all plants. The Agency believes 25
gal/ton can be achieved at plants with existing recycle systems at
little or no additional cost. The Agency believes that 25 gal/ton is
a flow rate which can be achieved by well operated high rate recycle
systems for continuous casting wastewaters. Plant responses indicated
that fouling and scaling are not significant problems in continuous
casting recycle systems.
Identification of_ BAT
Based upon information contained in Sections III through VIII, the
Agency developed the following BAT alternative treatment systems (as
447
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add-ons to the BPT model treatment system) for the continuous casting
subcategory. These alternatives are illustrated in Figure VIII-1.
A. BAT Alternative 1
In the first BAT Alternative, the blowdown from the BPT system is
filtered. Filtration is effective in removing those metals
entrained in suspended solids. However, available data for
continuous casting operations indicate that not all metals are in
particulate form and pass through of dissolved metals occurs.
B. BAT Alternative 2
Lime precipitation and sedimentation of the BPT treatment system
blowdown is used to remove both particulate and dissolved toxic
metals.
C. BAT Alternative 3
In this alternative, vapor compression distillation is used to
achieve zero discharge. The distillate quality condensate is
returned to the process.
These treatment systems include technologies in use at one or more
plants, or demonstrated in other wastewater treatment applications.
The BAT limitations are presented in Table X-1, along with the model
flow and concentration basis. The pollutants listed in this table
represent a condensation of the list of selected pollutants presented
in Section VI. The Agency selected pollutants for limitation based
upon the following factors: treatability using the technologies
presented in the alternatives; quantity and toxicity in relation to
the other process wastewater pollutants; the ability to serve as
indicators of both the presence and the removal of other pollutants•
and the applicability as a pollutant in a central treatment system
with other compatible wastewaters.
Monitoring data indicate that zinc is present at higher levels than
any of the other toxic pollutants found in continuous casting
wastewaters. As noted in Volume I, treatment of those toxic
pollutants found at high levels in the process wastewaters will result
in treatment of the toxic pollutants found at lower levels. Based
upon the observations noted above, the Agency selected zinc as the
toxic pollutant to be limited at BAT. While other toxic metals are
found in continuous casting wastewaters, the control of zinc will also
result in comparable controls of the other toxic metals. In order to
make the continuous casting limitations compatible with those for
steelmaking and vacuum degassing, the Agency has also promulgated BAT
limitations for lead and zinc.
Investment and annual costs for the BAT alternative treatment systems
are presented in Table VII1-4.
448
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Rationale for the Selection o£ the BAT Alternatives
The following discussion presents the rationale for selecting the BAT
alternative treatment systems and for determining the effluent flow
rates and concentration levels of the limited pollutants.
Treatment Scheme
The alternative treatment systems applied and discharge flow rates, of
3400 and 25 gal/ton/respectively, are based upon a system recycle
rate of 99.3 percent. Table IX-2 summarizes current applied and
discharge flow rates of continuous casting operations for which flow
data were provided. The average of the applied flows was 3381
gal/ton. The model discharge flow was set at 25 gal/ton. The Agency
believes this discharge flow is achievable at all continuous casting
operations and represents good operation of properly designed high
rate recycle systems for continuous casting wastewaters. This flow is
well demonstrated in this subcategory. In fact, zero discharge has
been reported for several plants. The Agency has not selected zero
.discharge as the BAT flow because it believes that zero discharge
cannot be universally achieved without the use of costly evaporative
technologies.
Filtration is included in the first BAT alternative treatment system
in order to reduce the discharge of particulate metals entrained in
suspended solids in the BPT system blowdown. Twelve of the
thirty-nine plants for which treatment system information was provided
have filters. Many of these, however, are installed to filter the
entire process flow at higher filtration rates and with different
media than would be used to filter a small blowdown. Filtration is
also used in other steel industry subcategories and in other'
industries for the removal of suspended particulates from wastewater
streams.
Since the, data presented in Section VII indicate that filtration is
not particularly effective in removing dissolved toxic metals, the
Agency has also investigated the use of lime precipitation and
sedimentation to control both particulate and dissolved toxic metals.
The Agency did not consider this technology in developing the proposed
BAT limitations. Upon close review of available data in response to
public comments, the Agency believes this technology is an appropriate
option for the control of toxic metals found in continuous casting
wastewaters. Lime precipitation and sedimentation technology is well
demonstrated in the steel industry and in the continuous casting
subcategory.
Although vapor compression distillation is not used in this
subcategory, the effectiveness of this treatment technology has been
demonstrated in pilot studies and in wastewater treatment applications
in other industries.
449
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Wastewater Quality
The average effluent concentrations (in mg/1) incorporated in each!BAT
alternative treatment system follow (the maximum values are enclosed
in parentheses).
Pollutant
Lead
Zinc
BAT
Alt. 1
0.1
0.7
(0.3)
(2.1)
BAT
Alt. 2
0.3 (0.9)
0.45 (1.35)
BAT
Alt. 3 .
Zero Discharge
Zero Discharge
Toxic Metal Pollutants
A. BAT Alternative 1
To determine the effluent concentrations for the toxic metal
pollutants, the Agency evaluated analytical data from a variety
of sources. Long-term filtration system effluent data for hot
forming operations were reviewed to determine the toxic metal
removal capabilities of filtration systems. Reference is made to
Volume If Appendix A, for the derivation of 30 day average and
daily maximum performance standards. However, sampled plant
filtration data available for continuous casting operations
indicate that toxic metals are not removed to the same degree,
principally because some of the toxic metals found in continuous
casting wastewaters are dissolved. Thus, the effluent
concentrations presented above are higher than those shown in
Appendix A for hot forming operations.
B. BAT Alternative 2
Performance data for lime precipitation systems for steelmaking
wastewaters are presented in Table A-48 of Appendix A. These
performance data were obtained for wastewaters that are more
highly contaminated with particulate and dissolved toxic metals
than are continuous casting wastewaters. Thus, the performance
data for steelmaking wastewaters are applicable to continuous
casting wastewaters. Also shown below are performance data for a
full scale recycle and sedimentation system for continuous
casting, vacuum degassing, and hot forming wastewaters (Plant
0684E). The untreated continuous casting and vacuum degassing
wastewaters at this plant comprise about one half of the
wastewaters treated in the central treatment facility at this
plant.
450
-------
Pollutant ;
Suspended Solids
Lead
Zinc
Number
of
Observations
159
26
26
Average
20 mg/1
0.061
0.323
Based upon the steelmaking data and the data presented above, the
Agency established the 30 day average model plant effluent
concentrations at 0.30 mg/1 and 0.45 mg/1 for lead and zinc,
respectively.
B. BAT Alternative 3
As noted previously in this section, BAT Alternative 3 includes a
vapor compression distillation system to achieve zero discharge.
Effluent Limitations for BAT Alternatives
The effluent limitations for the BAT alternative treatment systems
were calculated by multiplying the model effluent flow and the
corresponding concentrations of metals with appropriate conversion
factors. Table X-l presents the effluent limitations developed for
each treatment alternative.
Selection of a BAT Alternative
The Agency selected BAT Alternative " 2 as -the BAT model treatment
system upon which the proposed BAT limitations are based. Filtration
was found not to be effective for removing toxic metals from
continuous casting wastewaters, while lime precipitation can remove
both particulate and dissolved toxic metals. The second alternative
was also selected to facilitate central treatment of continuous
casting, vacuum degassing and steelmaking wastewaters. The model BAT
treatment technologies and model plant effluent quality are the same
for all of these operations. Table X-2 presents the BAT limitations
for continuous casting operations. Vapor compression distillation was
not selected on the basis of high costs and limited incremental toxic
pollutant removal over lime precipitation.
Demonstration of BAT Limitations
Table X-2 presents a list of those plants achieving the BAT
limitations for continuous casting operations with the model treatment
technology. The Agency believes these plants are representative of
the wastewater treatment performance achievable by the industry.
Moreover, about 40 percent of the industry is achieving the BAT
limitations by operating with no discharge from the BPT treatment
system and without plugging, fouling and scaling problems.
451
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TABLE X-2
JUSTIFICATION OF BAT EFFLUENT LIMITATIONS^
CONTINUOUS CASTING SUBCATEGORY
BAT
Plants
AF (0868B)
D (0248B)
Q (Unk)
071 (0284A)
072 (0496)
079 (0060K)
Discharge Flow
(gal/ton)
25
17
Zero Discharge
Zero Discharge
Zero Discharge
Zero Discharge
25
Lead
0.0000313
0.000030
0
0
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0.0000073
Zinc -
0.0000469
C&TT Components
0
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PSP, SS, FF, CT, RTP 99.3,
NL, TP, NA
PSP, SS, FDSP, CT, RTP 98.9
CL, FP, RTP 100
PSP, CT, RTP 100
PSP, FSP, T, CT, RTP 100
PSP, FDSP, CT, RTP 100
PSP, FF, CT, RTP 99.2
(1) Kg/kkg of product
- : The limitation is not supported with data from this plant.
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CONTINUOUS CASTING SUBCATEGORY
SECTION XI
BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
Introduction
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), fecal coliform, and pH and any additional
pollutants defined by the Administrator as "conventional" oil and
grease, (44 FR 44501, 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.
case may BCT be less stringent than BPT.
In no
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 has 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.
455
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