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                                                                                                              «»»


                               "f^ilffr
                                                                                                                  v 202-260-7151
                                                                                                               Fax: 202-260-7185
                                                                                                             ]ett.george@epa.gbv
                                                                                           George M. Jett
                                                                                            Chemical Engineer
                                                                                      U.S. Environmental Protection Agency
                                                                                     Engineering and Analysis Diyjsipn.(4303),
                                                                                     	-1-200 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 Schatzow
                 Director
Office of Water Regulations and Standards
                          Ill
                          (9
      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

-------

-------
SECTION

I

II

III
IV
VI
VII
VIII
        COLD FORMING SUBCATEGORY

              COLD ROLLING

           TABLE OF CONTENTS

                SUBJECT                         PAGE

PREFACE                                           1

CONCLUSIONS                                       3

INTRODUCTION                                     11

General Discussion                               11
Data Collection Activities                       11
Limitations for Cold Rolling Operations          12
Description of Cold Rolling Operations           13

SUBCATEGORIZATIQN                                33

Introduction                                     33
Factors Considered in Subcategorization          33

WATER USE AND WASTEWATER CHARACTERIZATION        49

Introduction                                     49
Description of the Cold Rolling Operation and    49
     Wastewater Sources

WASTEWATER POLLUTANTS                            61

Introduction                                     61
Conventional and Nonconventional Pollutants      61
Toxic Pollutants                                 62

CONTROL AND TREATMENT TECHNOLOGY                 65

Introduction                                     65
Summary of Treatment Practices Currently         65
     In Use
Control and Treatment Technologies Considered    68
     for Toxic Pollutant Removal
Summary of Sampling Visit Data                   70
Summary of Long-Term Analytical Data             75
Effect of Make-up Water Quality                  75

COST, ENERGY, AND NON-WATER QUALITY IMPACTS      131

Introduction                                     131

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                       COLD FORMING SUBCATEGORY

                             COLD ROLLING

                    TABLE OF CONTENTS (Continued)
 SECTION
IX
XI

XII
XIII
                 SUBJECT                       PAGE

Actual Costs Incurred by Plants Sampled or      131
     Solicited.for this Study
Recommended Control and Treatment Technologies  132
Cost, Energy, and Non-Water Quality Impacts     132
Estimated Costs for the Installation of         132
     Pollution Control Equipment
Energy Impacts                                  134
Non-Water Quality Impacts                       136
Summary of Impacts                              138

EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLI-  169
CATION OF THE BEST PRACTICABLE CONTROL TECH-
NOLOGY CURRENTLY AVAILABLE

Introduction                                    169
Identification of BPT                           169
Rationale for BPT                               169
Justification of BPT Limitations                174

EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLI-  187
CATION OF THE BEST AVAILABLE TECHNOLOGY
ECONOMICALLY ACHIEVABLE

Introduction                                    187
Identification of BAT                           187
Rationale for the Selection of the BAT          188
     Alternative
Selection of a BAT Alternative                  190
Site Specific BAT Limitations                   191
Demonstration of BAT Effluent Limitations       191

BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY  193

EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLI-  195
CATION OF NEW SOURCE PERFORMANCE STANDARDS

Introduction                                    195
Identification of NSPS                          195
Rationale for Selection of NSPS                 196
Selection of an NSPS Alternative                196

PRETREATMENT STANDARDS FOR THE DISCHARGES TO    205
PUBLICLY OWNED TREATMENT WORKS
                                n

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                      COLD FORMING SUBCATEGORY

                            COLD ROLLING

                   TABLE OF CONTENTS (Continued)
SECTION
                 SUBJECT                       PAGE

Introduction                                    205
General Pretreatment Standards                  205
Identification of Pretreatment Alternatives     205
Selection of PSES and PSNS                      206
                                m

-------

-------
NUMBER

II-l


11-2

II-3

III-l

III-2

III-3 to
III-5

II1-6 to
III-8

IV-1


IV-2


IV-3


V-l  to
V-5

VI-1

VI-2

VII-1
VII-2  to
VII-6

VI1-7  and
VII-8

VII-9  to
VII-11
        COLD FORMING SUBCATEGORY

              COLD ROLLING

                 TABLES

                 TITLE                          PAGE

BPT/BCT Treatment Model Flows, Effluent           7
     Quality, and Effluent Limitations

Treatment Model Flows and Effluent Quality        8

Effluent Limitations and Standards                9

Summary of Sampled Plants                        16

Description of Mills                             18

General Summary Tables                           20


Data Base Summary Tables                         27
Effect of Mill Configuration on the              40
     Discharge Flow Rate

Examples of Plants with Retrofitted Pollution    41
     Control Equipment

Relationship Between Flow and Operation          42
     Type

Summaries of Analytical Data from Sampled        52
     Plants: New Raw Concentrations

Toxic Pollutants Known to be Present             63

Selected Pollutants                              64

List of Control and Treatment Technology         77
     (C&TT) Components and Abbreviations

Summaries of Analytical Data from Sampled        82
     Plants: Raw Wastewaters and Effluents

Summaries of Long-Term Data                      98
 Net  Concentration and  Load Analysis Tables      100

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                       COLD FORMING SUBCATEGORY
                             COLD ROLLING
                          TABLES (Continued)
 NUMBER
VIII-1 to
VIII-3
VIII-4
VII1-5
VII1-6 to
VIII-10
VIII-11 to
VIII-15
VIII-16
VIII-17 to
VIII-20
VIII-21
VIII-22
VIII-23
IX-1
IX-2 to
IX-6
IX-7
IX-8 and
IX-9
X-l
XII-1 and
XII-2
XII-3
                  TITLE
Effluent Treatment Cost Tables

Model Control and Treatment Technology
     Summary
BPT Cost Summary:  In-Place and Required
BPT Treatment Model Cost Tables
BAT/PSES Treatment Model Cost Tables
BAT Cost Summary:  In-Place and Required
NSPS/PSNS Treatment Model Cost Tables
PSES Cost Summary:  In-Place and Required
BPT, BAT and PSES Energy Requirements
     Summary
BPT and PSES Sol id.Waste Generation
     Summary
BPT Effluent Limitations
BPT Discharge Flow Determination

Discharge Flow and Thickness Reduction
Justification of BPT Effluent Limitations
     Tables
BAT Effluent Limitations
New Source Performance Standards (NSPS)
Demonstration of NSPS Model Flow
     Rates
PAGE
 139

 142

 144
 145

 150

 155
 156

 164
 165

 166

 176
 177

 182
 183

 192
 198

 200

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 NUMBER

XI1-4 and
XII-5

XIII-1 and
XIII-2

XII1-3 and
XIII-4
        COLD FORMING SUBCATEGORY

              COLD ROLLING

           TABLES (Continued)


                  TITLE

Justification of NSPS


PSES Effluent Limitations


PSNS Effluent Limitations
PAGE

 201


 208


 210

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                       COLD FORMING SUBCATEGORY

                             COLD ROLLING

                               FIGURES
NUMBER

III-l to
III-3

IV-1 to
IV-5

VII-1 to
VII-28

VIII-1
IX-1

XII-1

XIII-1
                 TITLE

Process Flow Diagrams


Discharge Flow Versus Size and Age
     Plots

Treatment System Diagrams of Sampled
     Plants

BPT/BCT/BAT/NSPS/PSES/PSNS Treatment
     Models

BPT Treatment Model

NSPS Treatment Model

Pretreatment Model
PAGE

 30


 43


103


167


185

203

212
                                  IX

-------

-------
SECTION

I

II

III




IV
VI
 VII
 VIII
        COLD FORMING SUBCATEGORY

        COLD WORKED PIPE & TUBE

           TABLE OF CONTENTS

                SUBJECT

PREFACE

CONCLUSIONS

INTRODUCTION

General Discussion
Description of Pipe and Tube Mills

SUBCATEGORIZATION

Introduction
Manufacturing Process and Equipment

WATER USE AND WASTEWATER CHARACTERIZATION

Introduction
Water Use
Wastewater Characterization

WASTEWATER POLLUTANTS

Introduction
Conventional Pollutants
Toxic Pollutants

CONTROL AND  TREATMENT  TECHNOLOGY

Introduction
Summary of  Treatment Practices Currently
     Employed
Summary of  Sampling Visit Data
Effect  of  Make-up Water Quality
                Introduction
                Actual Costs Incurred by the Plant Surveyed
                     for this Study
                Control and Treatment Technology
                Cost, Energy, and Non-Water Quality Impacts
                Estimated Costs for the Installation of
                     Pollution Control Technologies
                Energy Impacts
                Non-Water Quality Impacts
PAGE

215

217

221

221
221

239

239
239

245

245
245
246

251

251
251
251

257

257
257

258
260
 COST,  ENERGY,  AND NON-WATER QUALITY IMPACTS     281
                                                 281
                                                 281

                                                 281
                                                 281
                                                 282

                                                 284
                                                 285

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                       COLD FORMING SUBCATEGORY

                       COLD WORKED PIPE & TUBE

                    TABLE OF CONTENTS (Continued)
 SECTION
IX
XI
XII
XIII
                 SUBJECT

Summary of Impacts

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

Introduction
Identification of BPT
Rationale for BPT Treatment Systems
Justification of the BPT Limitations

EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLI
CATION OF THE BEST AVAILABLE TECHNOLOGY
ECONOMICALLY ACHIEVABLE
                                                               299
                                                               299
                                                               300
                                                               300

                                                            -  305
BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY  307

Introduction                                    307
BCT Limitations                                 307

EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLI-  309
CATION OF NEW SOURCE PERFORMANCE STANDARDS

Introduction                                    309
Identification of NSPS                          309
Rationale for Selection of NSPS                 310
Selection of NSPS Alternative                   310
Demonstration of NSPS                           311

PRETREATMENT STANDARDS FOR COLD WORKED PIPE     313
AND TUBE OPERATIONS DISCHARGING TO PUBLICLY
OWNED TREATMENT WORKS

Introduction                                    313
General Pretreatment Standards                  313
Identification of Pretreatment Alternatives     313
                                xn

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NUMBER

II-l

III-l to
III-2

III-3 to
III-4

IV-1

V-1  to
V-2

VI-1 to
VI-2

VI-3 to
VI-4

VII-1
 VII-2 to
 VII-3

 VI1-4 to
 VII-5

 VIII-1

 VIII-2 to
 VIII-3

 VIII-4 to
 VIII-5

 IX-1 to
 IX-2
        COLD FORMING SUBCATEGORY

        COLD WORKED PIPE & TUBE

                 TABLES

                 TITLE

Effluent Limitations and Standards

General Summary Tables


Data Base Summary Tables


Flow Averages and Ranges

Summary of analytical Data from Sampled
     Plants: Toxic Pollutant Study

Toxic Pollutants Konwn  to be Present


Selected Pollutants
Operating Modes,  Control  and Treatment Tech-
      nology  (C&TT)  Components and Abbre-
      viations

Summary of Analytical  Data frpm Sampled
      Plants: Raw Wastewaters and Effluents

Net Concentration and  Load Analysis
 Effluent Treatment Costs

 Model Control and Treatment Technologies
 BPT/BAT/PSES/PSNS/NSPS Treatment Model
      Costs

 Justification of BPT Effluent Limitations
      Tables
PAGE

220

225


235


243

248


253


255


262



267


270


288

289


 292


 301

-------

-------
                       COLD FORMING SUBCATEGORY
                       COLD WORKED PIPE & TUBE
                               FIGURES
NUMBER
                  TITLE
                                                               PAGE
III-l

IV-1
VII-1 to
VII-9

VIII-1
VIII-2
VIII-3
 IX-1 to
 IX-2
Process Flow Diagram                            237

Discharge Flow Versus Size and Age              244
     Plots

Treatment system Diagrams of Sampled            272
     Plants

BPT/BAT/BCT/PSES/PSNS/NSPS Treatment Model      295
     for Cold Worked Pipe and Tube Using
     Water

BPT/BAT/BCT/PSES Treatment Model for Cold       296
     Worked Pipe and tube Using Soluble Oil
     Solutions

PSNS/NSPS Treatment Model for Cold Worked Pipe  297
     and Tube Using Soluble Oil Solutions
BPT Treatment Models
                                                                303
                                 xv

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-------
SECTION

I

II

III
IV
VI

VII
 VIII
     ALKALINE CLEANING SUBCATEGORY

           TABLE OF CONTENTS

                SUBJECT
                                                               PAGE
PREFACE                                         315

CONCLUSIONS                                     317

INTRODUCTION                                    321

General Discussion                              321
Development of Limitations                      321
Description of Alkaline Cleaning Operations     322

SUBCATEGORIZATION                               337

Manufacturing Process and Equipment             337
Final Products                                  338
Raw Materials                                   339
Wastewater Characteristics                      339
Wastewater Treatability                         340
Size and Age                                    340
Geographic Location                             341
Process Water Usage                             341

WATER USE AND WASTEWATER CHARACTERIZATION       347

Introduction                                    347
Alkaline Cleaning Operations                    347

WASTEWATER POLLUTANTS                           351

CONTROL AND TREATMENT TECHNOLOGY                357

Introduction                                    357
Summary of Treatment Practices  Currently        357
     Employed
Advanced Treatment Systems  Considered for       359
     the Alkaline Cleaning  Subcategory
Summary of Sampling Visit Data                  361
Effect of Make-up Water Quality                362

COST, ENERGY AND NON-WATER  QUALITY IMPACTS     375

 Introduction                                    375
Actual Costs  Incurred  by  the Operations        375
     Sampled  for this  Study
Cost,  Energy,  and Non-Water Quality Impacts   ' 376
Estimated  Costs for  the  Installation of        376
     Pollution Control  Technologies
Energy  Impacts                                  378
                                 xvn

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                    ALKALINE CLEANING SUBCATEGORY

                    TABLE OF CONTENTS (Continued)
 SECTION
IX
XI

XII
XIII
                 SUBJECT                        PAGE

Non-Water Quality Impacts                       379
Summary of Impacts                              379

EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLI-  391
CATION OF THE BEST PRACTICABLE CONTROL TECH-
NOLOGY CURRENTLY AVAILABLE

Introduction                                    391
Identification of BPT                           391
Rationale for BPT                               392
Demonstration of BPT Limitations                393

EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLI-  399
CATION OF THE BEST AVAILABLE TECHNOLOGY
ECONOMICALLY ACHIEVABLE

Introduction                                    399
Selection of BAT Alternatives                   400

BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY  401

EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLI-  403
CATION OF NEW SOURCE PERFORMANCE STANDARDS

Introduction                                    403
Identification of NSPS Alternatives       "      403
Rationale for the Selection of NSPS             403
Selection of NSPS                               405

PRETREATMENT FOR DISCHARGES TO PUBLICLY OWNED   411
TREATMENT WORKS

Introduction                                    411
General Pretreatment Standards                  411
Rationale                                       411
                               xvm

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NUMBER
II-l

II-2
III-l to
III-2
III-3
III-4 to
III-5
IV-1
IV-2

IV-3

V-l

VI-1
VI-2
VII-1

VII-2

VII-3
VIII-1
VIII-2
VI11-3  to
VII1-4
     ALKALINE CLEANING SUBCATEGORY
                 TABLES
                  TITLE
BPT Model Flow, Effluent Quality and
     Effluent Limitations
BCT/BAT/NSPS/PSES/PSNS Treatment Model
     Flows, Effluent Quality and Effluent
     Limitations and Standards
General Summary Tables

Mills Sampled for this Study
Data Base Summary Tables
Discharge Flow and Subsequent Finishing
     Operations
Examples of Plants with Retrofitted
     Pollution Control Equipment
Geographic Location of Subcategory
     Operations
Summary of Analytical Data  of Sampled
     Plants:  Net Raw Concentrations
Toxic Pollutants known to be Present
Selected Pollutants
List of Control and Treatment
     Technology  (C&TT) Components
     and Abbreviations
Summary of Analytical Data  from
     Sampled  Plants:  Raw
     Wastewaters and  Effluents
Net Concentration  and Load  Analysis
Water  Pollution Control  Costs
Model  Control and  Treatment Technologies
BPT Treatment Model  Cost Tables
PAGE
319

320

323

331
332

342

343

344

349

354
355
364

369

370
381
382
383
                                 xix

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                    ALKALINE CLEANING SUBCATEGORY

                          TABLES  (Conti nued)
 NUMBER

VII1-5 to
VIII-6

VII1-7 to
VIII-8

IX-1  to
IX-2

IX-3
XII-1


XII-2


XII-3
                   TITLE

BAT Treatment Model Cost Tables
NSPS Treatment Model Cost Tables
Flow Analysis and BPT Flow
     Justification Tables

Justification of BPT Effluent
     Limitations

New Source Performance Standards
     (NSPS)

Operations Demonstrating the NSPS
     Discharge Flow Rate

Justification of NSPS
PAGE

 385


 387


 394


 396


 406


 407


 408
                                xx

-------
NUMBER

III-l to
III-2

IV-1 to
IV-2

VI1-1 to
VI1-4

VIII-1

VIII-2

IX-1

XII-1
ALKALINE CLEANING SUBCATEGORY

           FIGURES


            TITLE

Process Flow Diagrams


Discharge Flow Versus Size and Age
     Plots

Treatment System Diagrams of
     Sampled Plants

BPT/BCT/BAT Treatment Model

NSPS Treatment Model

BPT Treatment Model

NSPS Treatment Model
PAGE

334


345


371


389

390

397

409
                                 xxi

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-------
SECTION

I

II

III




IV
VI
VII
VIII
        HOT COATING SUBCATEGORY

           TABLE OF CONTENTS

                SUBJECT                         PAGE

PREFACE                                         413

CONCLUSIONS                                     415

INTRODUCTION                                    423

Background                                      423
Description of Hot Coating Operations         .  424

SUBCATEGORIZATION                               445

Factors Considered in Subcategorization         445

WATER USE AND WASTEWATER CHARACTERIZATION       457

Introduction                                    457
Water Use in Hot Coating Operations             457
Applied Flow Rates                              458
Waste Characterization                          459

WASTEWATER POLLUTANTS                           465

Introduction                                    465
Conventional Pollutants                         465
Toxic Pollutants                                466

CONTROL AND TREATMENT TECHNOLOGY                473

Introduction                                    473
Summary of Treatment Practices Currently        473
     Employed
Plant Visits                                    476
Effect of Make-up Water Quality                 477

COST, ENERGY, AND NON-WATER QUALITY  IMPACTS     505

Introduction                                    505
Costs for Facilities In-Place                   505
Control and Treatment Technology  (C&TT)         507
Treatment Cost Estimates                        507
Energy Impacts                                  509
Non-Water Quality Impacts                       510
Water Consumption                               511
Summary of Impacts                              511
                                xxi n

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                       HOT COATING SUBCATEGORY

                    TABLE OF CONTENTS (Continued)
 SECTION

IX
XI


XII
XIII
                 SUBJECT

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

Introduction
Identification of BPT
Demonstration of BPT Limitations

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

Introduction
Identification of BAT
Effluent Limitations
Selection of BAT Alternative
Demonstration of the BAT Limitations

BEST CONVENTIONAL POLLUTION CONTROL
TECHNOLOGY
                                                               555
                                                               555
                                                               557

                                                            -  565
565
565
567
567
567

575
EFFLUENT QUALITY ATTAINABLE THROUGH THE         577
APPLICATION OF NEW SOURCE PERFORMANCE STANDARDS

Introduction                                    577
Identification of NSPS Technology               577
Selection of NSPS                               578
Demonstration of NSPS                           579

PRETREATMENT STANDARDS FOR HOT COATING PLANTS   585
DISCHARGING TO PUBLICLY OWNED TREATMENT WORKS

Introduction                                    585
General Pretreatment Standards                  585
Identification of Pretreatment Alternatives     585
Selection of Pretreatment Alternatives    .      587
                               XXIV

-------
NUMBER
II-l

II-2
II-3

II-4
III-l to
I.II-3
111-4
IV-1

V-l
V-2 to
V-4

VI-1 to
VI-3
VI-4
VII-1
VII-2 to
VII-4
V.I 1-5 to
VII-7
VII1-1
VIII-2
VIII-3

VIII-4
        HOT COATING SUBCATEGORY
                 TABLES
                 TITLE                          PAGE
BPT/BCT Treatment Model Flows and               419
     Effluent Quality
BPT/BCT Effluent Limitations                    420
Treatment Model Flows and Effluent              421
     Quality
Effluent Limitations and Standards              422
General Summary Tables                          429

Data Base                                       439
Examples of Plants with Retrofitted             452
     Pollution Control Equipment
Process Water Applied Rates                     460
Summary of Analytical Data from Sampled         461
     Plants:*Net Raw Concentration and
     Load Tables
Toxic Pollutants Known to be Present            468

Selected Pollutants                             471
List of Control and Treatment Technology        479
     (C&TT) Components and Abbreviations
Summaries of Analytical Data from Sampled       484
     Plants: Effluent Waste Loads
Net Concentration and Load Analysis Tables      488
Effluent Treatment Costs Reported  by  Sampled    513
     Plants
Energy Requirements  to  Achieve BPT Limits       514
Energy Requirements  to  Achieve Effluent         515
     Limitations  and Standards
Model Control  and Treatment  Technology          517
                                XXV

-------
 NUMBER
VIII-5 to
VIII-14
VIII-15 to
VIII-24
VIII-25 to
VI11-34
VIII-35
VIII-36
VIII-37
IX-1
IX-2 and
IX-3
X-l
X-2
X-3

XII-1

XIII-1
        HOT COATING SUBCATEGORY
           TABLES (Continued)

                  TITLE
BPT/NSPS/PSNS Treatment Model Cost Tables

BAT/PSES Treatment Model Cost Tables

NSPS/PSNS Treatment Model Cost Tables

BPT Cost Requirements
BAT Cost Requirements
PSES Cost Requirements
BPT and BCT Effluent Limitations
Justification of BPT Limitations

BAT Effluent Limitations
Justification of BAT Flow Basis
Justification of BAT-2 and NSPS
     Flow Basis
NSPS/PSNS Effluent Limitations
     Guidelines
PSES Effluent Limitations Guidelines
PAGE
 519

 529

 539

 549
 550
 551
 560
 561

 569
 570
 571

 580

 588
                                XXVI

-------
NUMBER

III-l to
III-5

IV-1 and
IV-2

IV-3 and
IV-4

VII-1 to
VII-13

VIII-1 and
VIII-2

IX-1 and
IX-2

X-l and
X-2

XI1-1 and
XII-2

XIII-1 and
XIII-2
        HOT COATING SUBCATEGORY

                FIGURES

                 TITLE
Process Flow Diagrams
Applied Rinse Flow Versus Production
     Capacity and Age Plots

Applied Scrubber Flow Versus Production
     Capacity and Age Plots

Treatment System Diagrams of Sampled
     Plants

Treatment System Diagrams
BPT Treatment Models
BAT Treatment Models
NSPS Treatment Models
PSES Treatment Models
PAGE

440


453


455


491


552


563


573


582


590
                               XXVI 1

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-------
                       COLD FORMING SUBCATEGORY

                             COLD ROLLING

                              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).

This part of the Development Document highlights the technical aspects
of EPA's study of the Cold Rolling Subdivision  of  the  Cold  Forming
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.

-------

-------
                       COLD FORMING SUBCATEGORY

                             COLD ROLLING

                              SECTION II

                             CONCLUSIONS
Based  upon  this  current  study,  a  review  of previous studies and
comments received on the regulation proposed on January 7, 1981 (46 FR
1858), the Agency has reached the following conclusions  with  respect
to the cold rolling subdivision of the cold forming subcategory.

1.   Cold rolling and cold worked pipe and tube operations  have  been
     combined  into one subcategory called "Cold Forming."  Because of
     differences in process operations and  wastewater  treatment  and
     disposal  practices,  the two operations are reviewed separately.
     This report addresses cold rolling operations.

2.   The Agency  is  retaining  the  previous  segmentation  for  cold
     rolling  operations,  but  has established subsegments for single
     stand recirculation and direct  application  mills.   Limitations
     and  standards  have  been  developed  separately  for single and
     multiple stand recirculation mills, combination mills, and single
     and  multiple  stand  direct   application   mills   because   of
     differences  in flow rates.  The segmentation of the cold rolling
     subdivision of the cold forming subcategory is as follows:

     Cold Rolling Operations
          Recirculation Mills                              •
               Single Stand
               Multi-stand
          Combination Mills
          Direct Application Mills
               Single Stand
               Multi-Stand

3.   The Agency has promulgated BPT limitations for the  cold  rolling
     subdivision which are different than those previously promulgated
     in 1976.  However, the promulgated limitations are based upon the
     same model treatment technology (dissolved gas flotation).  These
     changes  were  made to more accurately reflect data obtained from
     the industry and through sampling conducted by the  Agency  since
     the original .study.

4.   In addition to establishing separate subsegments for single stand
     mills, the Agency has changed  the  BPT  model  treatment  system
     flows for combination mills (from 400 gal/ton to 300 gal/ton) and
     direct application multiple stand mills (from 1000 gal/ton to 400
     gal/ton).   The  model  flows  for  single  stand mills  have been
     established at 5 gal/ton for recirculation mills, and 90  gal/ton

-------
8.


9.


10,
     for direct application mills.  The model flows for multiple stand
     recirculation mills remain the same at 25 gal/ton.

     Sampling of raw and waste  oil  solutions,  raw  wastewater,  and
     treated  and  partially  treated  wastewaters  from  cold rolling
     operations  demonstrated  that  the  presence  of  toxic  organic
     compounds  in  the  wastewaters is pervasive and highly variable.
     The presence of toxic organic pollutants is attributable  to  the
     oil  and cleaning solutions used at cold rolling operations.  The
     Agency concluded that it should establish limitations  for  toxic
     organic pollutants for all cold rolling operations.

     The  Agency  has  promulgated  BPT  limitations  for  toxic   and
     conventional   pollutants.    The   toxic  pollutants  for  which
     limitations   have   been   established   are   naphthalene   and
     tetrachloroethylene  (for  all  operations);  lead  and zinc (for
     carbon steel operations); and chromium and nickel (for  specialty
     steel  operations).   The  30-day  average  limitations for total
     suspended solids and oil and grease, and limitations for  pH  are
     based  upon  the  same  effluent  quality  as were the previously
     promulgated limitations.   Dissolved  iron  is  no  longer  being
     limited.

     Because of the  high  variability  in  the  occurrence  of  toxic
     organic  pollutants  in  cold rolling wastewaters, the Agency has
     promulgated limitations and standards only  for  naphthalene  and
     tetrachloroethylene which were found to be common to most rolling
     and cleaning solutions, respectively.  The Agency recommends that
     limitations  for other toxic organic pollutants be established on
     a case-by-case basis  for  the  particular  mix  of  rolling  and
     cleaning  solutions  in  use  at  a  given plant.  Because of the
     complex nature of  the  cold  rolling  process,  the  Agency  has
     concluded  that  it  is  not  possible  to  limit  toxic  organic
     pollutants at cold rolling operations by specifying  the  use  of
     "clean" rolling or cleaning solutions.
The Agency has promulgated BAT limitations for  toxic
which are the same as the respective BPT limitations.
pollutants
The Agency has promulgated'BCT limitations which are the same
the BPT limitations for conventional pollutants.
        as
EPA  estimates  that  compliance  with  the  BPT,  BCT  and   BAT
limitations and PSES will result in significant removals of toxic
and  conventional  pollutants.   A  summary of the discharges are
shown below.

-------
11
12,
13
                                    Direct Discharges
                            Effluent Loadings (Tons/Year)
     Flow,  MGD
     TSS
     Oil and Grease
     Toxic  Metals
     Toxic  Organics
                Raw Waste

                      29.6
                  22/502
                  86,942
                      94
                     337
            BPT/BCT/BAT

              28.1
             653
             286
              21
               4.1
                                  Indirect Discharges
                            Effluent Loadings (Tons/Year)
     Flow,  MGD
     TSS,
     Oil and Grease
     Toxic  Metals
     Toxic  Organics
                Raw Waste

                       0.2
                     275
                   3,986
                       5.4
                       2.1
               PSES

               0.2
               4.4
               1 .9
               0.3
               0.2
The Agency estimates that the industry will incur  the  following
costs  in  complying  with the limitations and standards for cold
rolling operations.  The Agency has determined that the  effluent
reduction   benefits   associated   with  compliance  with  these
limitations and standards justify the cos-ts presented below:

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

     PSES
         In-Place

           22.6
            0.0

            0'.004
Required

   5.1
   0.0

   0.058
In-Place

  2.8
  0.0

  0.0006
Required

  0.8
  0.0

  0.007
The Agency  has  also  determined  that  the  effluent  reduction
benefits  associated  with  compliance  with new source standards
(NSPS, PSNS) justify these costs.

Although the Agency believes that most new  source  cold  rolling
operations   will   be   recirculation   mills,  the  Agency  has
established NSPS for the recirculation,  combination  and  direct
application  segments  of the cold rolling subdivision.  The NSPS
model discharge flows are based upon best demonstrated  flows  in
each  segment  and  the same effluent quality used to develop the
BPT and BAT limitations.  The  Agency  believes  that  compliance
with  these  standards  will  not preclude production of any cold
rolled products at new source mills.

The Agency has promulgated pretreatment  standards  for  new  and
existing  sources  {PSNS  and  PSES)  discharging  to POTWs.  The
standards are the same as the respective BPT limitations.   These
standards  limit  the  discharge of toxic metal and toxic organic

-------
     pollutants and are intended to minimize the pass through of those
     pollutants at POTW operations.

14.  With regard to the "remand  issues,"  the  Agency  has  concluded
     that:

     a.   Less stringent effluent limitations are not appropriate  for
          older  cold  rolling  operations.  The age of a cold rolling
          mill has no significant effect upon  the  ease  or  cost  of
          retrofitting pollution control equipment.

     b.   The  alternative  treatment  systems  considered  for   cold
          rolling   operations  do  not  include  cooling  or  recycle
          systems.  Hence, there is no consumptive water usage.

15.  Table II-l presents the BPT effluent limitations, treatment model
     flows and effluent quality data  used  to  develop  the  effluent
     limitations  for  the  cold rolling subdivision.  The BAT and BCT
     effluent limitations are the same as the BPT limitations.    Table
     I1-2  presents  the NSPS, PSES, and PSNS treatment model flow and
     effluent quality data used to develop the standards.   Table  II-3
     presents the standards for NSPS,  PSES and PSNS.

-------



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                                    TABLE II-2

                    TREATMENT MODEL FLOWS AND EFFLUENT QUALITY
                     COLD FORMING SUBCATEGORY - COLD ROLLING
                                            Flowrates  (gal/ton)
1. Recirculation
   a. Single stand
   b. Multi stand

2. Combination

3. Direct Application
   a. Single stand
   b. Multi stand
                              BAT
5
25

300
90
400
          NSPS
5
10

130
25
290
            PSES
   5
   25

   300
   90
   400
                                                                  PSNS
         5
         10

         130
         25
         290
            .(1)
                  30-Day Average and Daily Maximum Concentrat ions
                   BAT
 NSPS
Pollutant

    TSS
    0 & G
119 Chromium
122 Lead
124 Nickel
128 Zinc
 55 Napthalene
 85 Tetrachloro-
    ethylene
     PSES
                AVG   MAX   AVG
                                                           PSNS
     MAX
  AVG
MAX
AVG
                      0.15  -
     0.15
         0.15
                                                               MAX
-
-
0.4
0.15
0.3
0.1
-
-
-
0.4
0.45
0.9
0.3
0.1
30
10
1.0
0.15
0.3
0.1
'-
60
25
0.4
0.45
0.9
0.3
0.1
-
-
1.0
0.15
0.3
0.1
- •
. -
-
0.4
0.45
0.9
0.3
0.1
—
-
1.0
0.15
0.3
0.1
-
-
-

0.45
0.9
0.3
0.1
              0.15
Note: Concentrations apply to all cold rolling operations and are expressed in
      mg/1 unless otherwise noted.  pH is also regulated at BCT and NSPS and is
      limited to 6.0 to 9.0 standard units for all cold rolling operations.

(1)  The limitations for chromium and nickel shall be applicable in lieu of those
     for lead and zinc when cold rolling wastewaters are treated with descaling or
     combination acid pickling wastewaters.

-------
                                       TABLE  II-3

                           EFFLUENT  LIMITATIONS  AND STANDARDS
                        COLD FORMING SUBCATEGORY - COLD ROLLING
Pollutants

1.  Recirculation
    a. Single stand
            (2)
          (2)
    TSS  •
    0 & G
119 Chromiumv
122 Lead
124 Nickel'
128 Zinc
 55 Napthalene
 85 Tetrachloro-
    ethylene

    b. Multi Stand
            ,(2)

           (2)
    TSS
    0 & G
119 Chromium1"
122 Lead
124 Nickel'
128 Zinc
 55 Napthalene
 85 Tetrachloro-
    ethylene

2.  Comb inat ion
            .(2)
           (2)
    TSS
    0 & G
119 Chromium''
122 Lead
124 Nickel'
128 Zinc
 55 Napthalene
 85 Tetrachloro-
    ethylene
                      Effluent Limitations and Standards (kg/kkg of Product)

                         BAT         NSPS          PSES          PSNS
                                                                                (1)
AVG

_
0.83
0.31
0.63
0.21
-
-

_
4.17
1.56
3.13
1.04
-
-

_
50.1
18.8
37.5
12.5
_
MAX

-
2.09
0.94
1.88
0.63
0.21
0.31

—
10.4
4.69
9.39
3.13
1.04
1.56

—
125
56.3
113
37.5
12.5
AVG
62.6
20.9
0.83
0.31
0.63
0.21
-
-
125
41.7
1.67
0.63
1.25
0.42
-
-
1630
542
21.7
8.14
16.3
5.42
—
MAX
125
52.2
2.09
0.94
1.88
0.63
0.21
0.31
250
104
4.17
1.88
3.75
1.25
0.42
0.63
3250
1360
54.2
24.4
48.8
16.3
5.42
AVG

-
0.83
0.31
0.63
0.21
-

.
—
4.17
1.56
3.13
1.04
-
-

-
50.1
18.8
37.6
12.5
- -
MAX

-
2.09
0.94
1.88
0.63
0.21
0.31
~ ;
-
10.4
4.69
9.39
3.13
1.04
1.56

-
125
56.3
113
37.5
12.5
AVG

-
0.83
0.31
0.63
0.21
—
-
_ ,,
—
1.67
0.63
1.25
0.42
—
-
. ....
•-
21.7
8.14
16.3
5.42
-
MAX

-
2.09
0.94
1.88
0.63
0.21
0.31
_
—
4.17
1.88
3.75
1.25
0.42
0.63
— _
-
54.2
24.4
48.8
16.3
5.42
                             18.8  -
8.14
18.8
                                                                      8.14

-------
 TABLE II-3
 EFFLUENT LIMITATIONS AND STANDARDS
 COLD FORMING SUBCATEGORY - COLD ROLLING
 PAGE 2
 Pollutants

 3.  Direct Application
    a.  Single  Stand
            .(2)
          ,(2)
    TSS
    0 & G
119 Chromium*1
122 Lead
124 Nickelx
128 Zinc
 55 Napthalene
 85 Tetrachloro-
    ethylene

    b. Multi Stand
            .(2)
    TSS
    0 & G
119 Chromiumv
122 Lead
124 Nickelv
128 Zinc
 55 Napthalene
 85 Tetrachloro-
    ethylene
          ,(2)
                           Effluent Limitations  arid  Standards  (kg/kkg of Product^1^

                             BAT         NSPS        PSES         PSNS
                           AVG   MAX   AVG   MAX  AVG   MAX    AVG   MAX
15.0
5.63
11.3
3.75
37.5
16.9
33.8
11.3
3.75
313
104
4.17
1.56
3.13
1.04
626
261
10.4
4.69
9.39
3.13
1.04
15.0
5.63
11.3
3.75
37.5
16.9
33.8
11.3
3.75
                   4.17
                   1.56
                   3.13
                   1.04
                                5.63  -
1.56  -
                                                        5.63
                                      3630  7260  -
                                      1210  3020  -
                                25.0  -
18.2  -
10.4
4.69
9.39
3.13
1.04

1.56
66.8
25.0
50.1
16.7
—
167
75.1
150
50.1
16.7
48.4
18.2
36.3
12.1
-
121
54.4
109
36.3
12.1
66.8
25.0
50.1
16.7
-
167
75.1
150
50.1
16.7
48.4
18.2
36.3
12.1
-
121
54.4
109
36.3
12.1
                                                        25.0
                                                                     18.2
(1)  The limitations and standards have been multiplied by 105 to obtain the
     values presented in this table.
(2)  The limitations for chromium and nickel shall be applicable in lieu of those for
     lead and zinc when cold rolling wastewaters are treated with descaling or combination
     acid pickling wastewaters.
                                        10

-------
                       COLD FORMING SUBCATEGORY

                             COLD ROLLING

                             SECTION III

                             INTRODUCTION
General Discussion

Cold  rolling is the process in which flat unheated steel products are
reduced in thickness by rolling  operations.   The  rolling  operation
compresses  the  steel  between  rolls  to reduce the thickness of the
product while  imparting  desired  physical,  mechanical  and  surface
properties.   Oil  solutions  are  applied  directly  to  the rolls or
product to dissipate the heat produced during rolling and  to  provide
lubrication.   Various  oils  and .oil  application  systems  are used
depending on the product being rolled and the  properties  desired  in
the  steel.   There  are  three  types of oil application systems: (1)
recirculation; (2) combination; and (3) direfct application.  The  cold
rolling  subdivision  has  been  segmented to recognize differences in
these systems.

Due mainly to the use of the oil  solutions,  various  pollutants  are
discharged  at  high  levels  from  cold  rolling mills.  The two most
common are oil and grease and total suspended solids.  However, due to
the nature of some of the oils used in the process, toxic  metals  and
toxic  organic pollutants are also present in cold rolling wastewaters
at significant levels.

The  Agency  promulgated  BPT  limitations  for  cold   rolling   (CR)
operations  in  1976  for  four  pollutants:  oil  and  grease,  total
suspended solids, dissolved iron, and pH.  For this study, the  Agency
conducted  additional  sampling and gathered detailed information from
the  industry.  ' This  additional  information  indicates  that  these
wastewaters  are  contaminated  with  varying  levels of diverse toxic
organic pollutants.  The potential for high levels  of  toxic  organic
pollutants  in  the  discharges from cold rolling operations is great.
The Agency has, therefore, promulgated effluent  limitations  for  two
toxic  organic  pollutants common to most cold rolling wastewaters and
recommends that limitations for  other  toxic  organic  pollutants  be
established on a case-by-case basis.

Data Collection Activities

Process  information and wastewater quality data were obtained through
sampling visits at 72 cold  rolling  operations  at  24  plants.   The
Agency conducted eleven sampling visits during the original guidelines
study  and  visited  64  operations  during the recent toxic pollutant
survey (3 plants were  resampled).   The  plants  which  were  sampled
during  the  course  of  this  study  are  listed  in Table III-l.  An
                                    11

-------
 intensive sampling program was  conducted  at  one  plant  (0684F)   to
 characterize   the  performance  of  the  model  wastewater  treatment
 technology with respect to toxic organic pollutants.

 One of the Agency's primary sources of  information  for  the  current
 study  are industry responses to the DCP's that were sent to about  85%
 of  the active cold rolling operations in the United  States.    Through
 these  questionnaires,  the Agency requested information on process  and
 discharge flow rates,  treatment systems in use,  mill  capacities  and
 modes  of  operation.   DCP responses were received for two hundred  and
 twenty nine cold rolling mills.   The data for these  mills  have been
 tabulated  and  are  summarized in Tables II1-2 to II1-5.   Table II1-2
 lists all the plants that have cold rolling mills  and  describes  the
 number  and type of the cold rolling mills at each site.   Tables II1-3
 to  III-5 provide  more   detailed  information  for  individual   mills.
 These  tables  have  been  separated  by  the  type of oil application
 system.

 Detailed Data Collection Portfolios (D-DCP's)  were sent to  thirty-one
 selected  mills  to  gather long-term effluent quality data,  cost data
 for  treatment systems  installed,  and information on  mill   operations.
 The   D-DCP  responses   provided   data to verify Agency cost estimates,
 establish retrofit costs,  and to provide additional  effluent  quality
 data.    Tables  III-6   through  III-8 summarize the data  base for cold
 rolling  operations.

 Limitations for Cold Rolling Operations

 The  original  limitations for cold rolling operations  were   established
 separately  by mill  type (oil  application system),  and applied  to each
 mill  as  a whole regardless  of  the number of  rolling stands present   at
 the   mill.   In response  to  industry comments the Agency reexamined  and
 refined  this  segmentation.

 The Agency first  examined whether segmentation   of  the cold  rolling
 subdivision   by  the type of  oil  application system was appropriate or
 whether  all  cold  rolling mills could  operate with  recirculating  oil
 systems  (which  would reduce  the  amount  of  pollutants  discharged).   The
 Agency   analyzed   all  available  data and  contacted mill operators  and
 designers.  From  this study,  the  Agency  determined  that not   all  cold
 rolling   mills   can  make   the modifications  necessary  to  convert from
 either direct  application  or  combination   systems  to recirculation
 systems.   Some   direct  application  and  combination  type  mills  can
 recirculate all oil solutions.  Other mills  with   oil  sumps   located
 beneath    the  mills  would  require  major   capital   investments  and
production disruptions to convert  to  recirculation  systems.   For  this
 reason,   the  Agency  has  retained   the original segmentation  by mill
 type.

The Agency also considered  establishing   limitations   for  each  mill
stand  to  account for possible flow  variations  that  can occur  between
cold rolling mills with  different  numbers  of  stands.   The  Agency
tabulated all available data and  compared both methods  (limitations on
                                    12

-------
a  per  mill  basis  vs.  limitations  on  a  per  stand  basis).  The
limitations developed by aggregating the single stand allowances  were
more  stringent  in some instances, and less stringent in others, than
those limitations established on a mill basis.  Therefore, the  Agency
has  promulgated  limitations  on  the  same  basis  as  the  original
regulation.

The Agency also investigated  whether  separate  effluent  limitations
should  be  established for single and multiple stand mills within the
recirculation and direct application segments.  (There are  no  single
stand  operations at combination mills).  The Agency found substantial
differences in flow rates between single and multiple stand mills.  As
a result, the Agency has promulgated separate effluent limitations for
these categories.

The Agency reevaluated the limitations for the four pollutants   (i.e.,
total  suspended solids, oil and grease, pH and dissolved iron)  listed
in the original regulation.  The sampling conducted by the Agency  has
indicated  widespread  contamination  of cold rolling wastewaters with
toxic organic  and  metal  pollutants.   The  Agency  has,  therefore,
promulgated  limitations for toxic pollutants at the BPT level and has
eliminated the limitations for dissolved iron:  These are discussed in
detail in later sections of this report.

Description of Cold Rolling Operations

Cold rolling is that operation where unheated metal is passed  through
work rolls to reduce its thickness, to produce a smooth dense surface,
and to develop controlled mechanical properties in the steel.

There  are several types of cold rolling processes.  Cold reduction is
a special form of cold rolling in which the thickness of  the  product
is reduced by relatively large amounts in each pass through the  rolls.
In  the  production  of most cold rolled materials, the cold reduction
process  is used to reduce the thickness  of   the  hot  rolled  product
between  25%  and  90%.   After cleaning and  annealing, a considerable
amount   of  cold  rolled  product  is  tempered.   In  tempering,  the
thickness  of the material is reduced a small amount to impart desired
mechanical properties and surface characteristics•.

Cold rolled strip, cold rolled sheet, and cold rolled flat bar are the
principal  cold reduced flat products.  Carbon and  alloy  steels  are
rolled.    Most  products rolled are carbon steel  in sheet form and are
used as  base material for such coated products as long  terne  sheets,
galvanized  sheets,  aluminum  coated  sheets,  tin-plate, or tin-free
steel.   Hot rolled coils called "breakdowns"  are  the raw material used
in the cold rolling  operation.   Prior  to   rolling,  the  coils  are
descaled and pickled, usually  in a continuous pickling operation.

There  are several  types of cold reduction mills which vary  in  design
from single stand reversing mills to  continuous mills with up  to  six
stands in  tandem  (in series).  In  the single  stand reversing mill, the
product  is  rolled  back  and  forth between the work rolls until the
                                     13

-------
 desired thickness  and  mechanical  and  surface  characteristics  are
 achieved.  In the single stand nonreversing mill, the material makes a
 single  pass through the rolls and is recoiled.  If additional rolling
 is required, the coil  is  returned  to  the  head  of  the  mill  and
 reworked.   The  single  stand  nonreversing mill is generally used in
 tempering operations.

 Most cold reduced flat steel is rolled on continuous three,  four,  or
 five  stand  tandem  mills.    In  these mills the material continually
 passes from stand to stand until the desired  thickness  is  attained.
 Continuous rolling mills have been almost universally installed during
 the past fifteen years in new applications.

 A  typical  modern  cold  rolling  shop contains a continuous pickling
 operation (sulfuric or hydrochloric acid) to  remove  scale  and  rust
 from  the  hot  rolled  breakdown coil.   As  it leaves the pickler, the
 strip is oiled to prevent rusting and to act as  a  lubricant  in  the
 cold  rolling  mill.    The  coil  is  then  fed into a continuous cold
 rolling mill that can contain up to  six  rolling  stands  in  tandem.
 Each  stand contributes to the reduction in  thickness of the material;
 the first contributes the greatest reduction while the last stand acts
 as a straightening,  finishing,  and gauging roll.   Unlike hot  forming,
 no  scale  is  formed during this operation.   It should be pointed out
 that the limitations  and  standards  apply  only  to  the  wastewaters
 generated  in cold rolling operations,  even  though other processes may
 be integrated into a  complete "cold mill" complex.    Wastewaters  from
 the other processes have been regulated  separately.

 During  cold  rolling,  the steel becomes quite hard and unsuitable for
 most uses.   As a result,  the strip usually must be annealed to  return
 its  ductility  and  to effect  other  changes  in mechanical  properties.
 This is done in either  a batch  or continuous  annealing operation.

 In batch or  box  annealing,   a   large stationary  mass  of  steel  is
 subjected to  a  long  heat  treating  cycle and allowed to cool  slowly.
 In continuous annealing,  a single strip  of cold reduced product passes
 through a furnace in  a  relatively short   period  of   time.    The  heat
 treating  and  cooling   cycle  in  the   furnace  is   determined by the
 temperature  gradient  within  the  furnace  as well  as  the dimensions   and
 rate   of  travel  of the steel.   To prevent oxidation and the formation
 of  scale,  inert  atmospheres  are  maintained in  these   furnaces  at   all
 times.    Prior  to  annealing,  the material  must be cleaned   of all  dirt
 and oil  from  the pickling  operation to prevent surface blemishes.    In
 the   case  of   the  continuous   annealing  furnaces,   the   material  is
 uncoiled  and  is passed  through a continuous cleaning  operation prior
 to  entering   the  furnace.   Upon  leaving  the  furnace,  the  material  is
 oiled,  recoiled, and  is ready to be tempered.

 The temper mill  is a  single  stand  cold  rolling   mill  designed   to
produce  a slight reduction  in thickness of the steel.   This  reduction
develops the proper stiffness or  temper by cold working  the  steel  at a
 controlled rate.  The end  use of  the material  dictates  the   degree  of
 tempering to be performed.
                                    14

-------
An  oil-water emulsion is sprayed on the material before it enters the
rolls at each stand of a cold rolling mill and the material is  coated
with  oil  prior  to  recoiling.   This  oil  prevents  rust while the
material is in transit  or  storage  and  is  removed  before  further
processing or coating.

As mentioned earlier, there are three types of oil application systems
used  at  cold rolling mills.  The diagrams of these systems are shown
in Figures lli-1  through  III-3.   Additional  details  on  the  cold
rolling  operation  and  the  three  application systems are presented
later in this report.
                                     15

-------
                                   TABLE  III-l

                         COLD ROLLING OPERATIONS SAMPLED
                            Sampling Code      Plant Code       Type of Steel
A.  Recirculation Mills
B. Direct Application
                                (3)
D
I
P
X-2
BB-2
EE-2
FF-2
XX-2
101
                           102
                           105
                           301
                           302
                           304A
                           305B
                           306
                           307
                           308
                           310
                           315A & B
                           316
                           318
                           321 A,B & C
                               (4)
C. Combination
                           W-2
                           105
                           106
                           304B
                           305A
                           313B
                           DD"2
                           311
                           312A & B
                           31 3A
                           319
                           320A
248B (01)
432K
156B
060B (03)
060 (03)
112D (01)
384A
6841 (01)
020B (01,02,
     04,05),
020C (01-08)
384A (02&03)
584F (02,03&05)
020B (01,02,
04,05)
020C (01-08)
060E
0176 (08)
176 (08)
248B (03)
248B (03)
320 (02)
432C (01)
684 (02&03)
684B (01)
856P (01-21)
684D (01,02,04)
                   584F (04)
                   584F (04)
                   112B (01,03-06)
                   176  (02)
                   176  (02)
                   5 84 A
                   584E  (01)
                   432D  (01)
                   432D  (01)
                   948C  (04,02)
                   584A  (02)
                   856F  (01)
                   860B  (03)
Specialty
Specialty
Specialty
Carbon
Carbon
Carbon
Carbon
Carbon
Specialty
                                    Carbon
                                    Carbon
                                    Specialty
                                    Specialty
                                    Specialty
                                    Specialty
                                    Specialty
                                    Specialty
                                    Carbon
                                    Carbon
                                    Carbon
                                    Carbon
                                    Carbon
                                    Specialty
                 Carbon
                 Carbon
                 Carbon
                 Specialty
                 Specialty
                 Carbon
                 Carbon
                 Carbon
                 Carbon
                 Carbon
                 Carbon
                 Carbon
                 Carbon
                                        16

-------
TABLE III-l
COLD ROLLING OPERATIONS SAMPLED
PAGE 2             	-
(1) The sampling code is an alphabetic or numeric code assigned at the time
    of sampling.            .
(2) The plant code is a reference code designated for each mill responding to
    the basic questionaire.  For example, 060B (03) represents the third cold
    rolling mill at plant 060B.
(3) Plant FF-2 was resampled as Plant 102 during the Toxic Pollutant Survey.
    Since the analytical data collected during the survey is more recent and
    comprehensive, it is used to characterize the plant rather than the data
    for Plant FF-2.
(4) Plant VV-2 was resampled as Plant 105 during the Toxic Pollutant Survey.
    Since the analytical data collected during this survey is more recent and
    comprehensive, it is used to characterize the plant rather than the data
    for Plant VV-2.
    Plant YY-2 was resampled as Plant 311 during the Toxic Pollutant Survey.
    Since the analytical data collected during this survey is more recent and
    comprehensive, it is used to characterize the plant rather than the data
    for Plant YY-2.
(5)
                                         17

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                       COLD FORMING SUBCATEGORY

                             COLD ROLLING

                              SECTION IV

                          SUBCATEGORIZATION
Introduction

For  cold  rolling  operations,  the   main   element   that   affects
segmentation  is the method of oil application.  Flow rates were found
to differ depending  on  the  oil  application  system  used.   Hence,
limitations and standards were developed separately for recirculation,
combination, and direct application mills.

Basically,  the  difference in flow rates is the only factor affecting
segmentation of the cold rolling  subdivision.   Mill  age  and  size,
product type, raw materials, wastewater characteristics, treatability,
and  geographic location were considered, but the analysis showed that
none of these factors warrant further segmentation of the cold rolling
subdivision.  Each of these elements is reviewed below.

Factors Considered in Subcategorization

Manufacturing Process and Equipment

To determine if this factor had an effect on segmentation of the  cold
rolling  subdivision,  the  Agency  analyzed two elements.  First, the
type of cold rolling performed (i.e.,  temper,  tandem,  or  reversing
mill),  was  studied  to determine its effect on effluent flow rates or
quality.  The second element examined was  the  configuration  of  the
mill itself, such as the number of stands present.  These elements are
discussed below.

A.   Type of Cold. Rolling

     The Agency analyzed both the sampling data and DCP responses  and
     found  no relationship between the type of cold rolling operation
     (e.g., temper or tandem), and either the wastewater flow rates or
     effluent quality.  Although many mills  were  identified  by  the
     industry  in  DCPs only as "cold mills," data for mills that were
     clearly identified showed no  correlations  that  indicated  that
     further segmentation would be necessary.  For example, mills that
     perform  large  thickness reductions have similar discharge flows
     and achieve similar effluent quality as those mills, such as skin
     mills, which perform small thickness reductions.
                                    33

-------
B.   Mill Configuration

     The Agency also examined the effect of the number of mill  stands
     on  wastewater  quality  and  quantity.  All three types of mills
     were examined.  The mills analyzed varied from  small  one  stand
     operations  to  large  six  stand complexes.  To determine if the
     number of stands affected flow rate, the flow data for all  mills
     were tabulated according to the number of stands present as shown
     in  Table IV-1.  The data indicate that the mills with the fewest
     number of stands have the lower flow rates.  However, some of the
     larger multi-stand mills discharge at the same  low  flow  rates.
     The  single  stand  mills had the lowest discharge rates and were
     clearly  distinguishable  from  the  other  mills  in  both   the
     recirculation  and  direct application segments.  The Agency has,
     therefore,  established  separate  subsegments  for  single   and
     multiple  stand  mills  in  both  the  recirculation  and  direct
     application segments.  Combination mills  necessarily  have  more
     than  one  stand.  No clear distinction could be made between the
     various combination mills on the basis of the number of stands.

     The data were also analyzed to determine  if  mill  configuration
     has  an effect on wastewater quality.  Of the mills sampled, most
     were five stand mills.  However, there  were  a  few  mills  with
     fewer  stands and some with more than five stands.  The raw waste
     data  do  not  show  any   significant   variations   with   mill
     configuration.   Similar types of oils are used regardless of the
     number  of  mill  stands.    The   effluent   concentrations   of
     conventional  pollutants  (i.e., TSS and oil & grease) were found
     to be relatively consistent among and between the different types
     of mills (i.e., recirculation, direct application).  The sampling
     data demonstrate that acceptable effluent quality is dependent on
     design and operation of the treatment  system  and  not  on  mill
     configuration.

Final Product

Cold  rolling  operations  yield a wide variety of final products (see
Table III-2).  An analysis was done to determine if the final  product
rolled   (e.g.,   sheet,   strip)   affected  flow  rates,  wastewater
characteristics or other elements.  The three main  products  analyzed
were  sheet,  strip,  and'flat wire.  These three products account for.
83% of the total tonnage reported by  the  industry.   Other  products
were  not  reviewed,  because  multiple  products  are rolled at those
mills,  or because flow  rates  and  other  analytical  data  were  not
provided by the industry.  The data show that the final product rolled
does  not  have  a  significant  effect  on  either  discharge flow or
wastewater characteristics.  Hence, further segmentation on this basis
is not warranted.

Strip  and  sheet  mills  were  first  analyzed   because   of   their
similarities.    The   data   indicate   that  more  strip  mills  are
recirculation mills, while more sheet  mills  are  direct  application
mills.    This  resulted  in slightly higher average applied flow rates
                                    34

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 for the sheet mills.   This difference,  however, is not significant and
 is covered by the basic segmentation by mill type.  Aside  from  toxic
 organic pollutants found in the wastewaters from the various mills for
 all   products,    no   differences   were   found  in  the  wastewater
 characteristics  between the two mills.

 Wire mills are usually small operations with capacities in  the  range
 of  hundreds  of  tons  per  year as opposed to other operations which
 produce thousands of tons per day.  Also, reported applied flow  rates
 are  significantly higher at flat wire mills than at any other type of
 cold rolling operation.  For  example,   an  applied  rate  of  195,000
 gallons per ton  was reported for one wire mill.  This is approximately
 40  times  the  highest  flow rate reported by either a strip or sheet
 mill.   The reason for these higher than normal flow rates is the small
 capacity of these mills and not any special water requirements.   Wire
 mills  only process products in small batches.  Also, when the mill is
 operated, it is  run for only a small portion of a turn.  When the flow
 values were calculated on a gallon/ton basis it was assumed  that  the
 mill  operated  for  an entire eight hour turn.  Since this is not the
 case  for  wire   mills,  the  calculated  applied   flow   rates   are
 disproportionately  higher than for any other types of cold operation.
 Despite these inordinately high calculated applied flows,  the  Agency
 found  that  recirculation  mills  of  all  types  can achieve similar
 discharge flow rates through better operating practices.  Hence, it is
 not necessary to differentiate between products rolled  at  cold  mill
 operations.

 Raw Materials

 Carbon,  stainless and other types of steel are used as raw material in
 cold  rolling mills.,  It was found that while the type of steel rolled
 sometimes affects mill operation, it does not significantly affect the
 eventual  discharge  quantity  or  quality  after  treatment  in   BPT
 treatment  systems.   Although  specialty  steel  mills  tend  to have
 smaller production capacities than carbon steel mills,  the  discharge
 flow  rates  (gal/ton)  for  both  types  of mills are about the same.
 Additionally, the monitoring data for both  types  of  mills  indicate
 similar  types  of  pollutants  were  present  in  these  wastewaters,
 although at varying levels.   Accordingly, the  Agency  concluded  that
 further  segmentation  based upon type of raw material used (i.e., the
.type of steel rolled) is not appropriate.


 Wastewater Characteristics

 Within the cold  rolling subdivision,   no  differences  were  found  in
 wastewater  characteristics  between operations that process specialty
 steels and those that  process  carbon   steels.   The  same  types  of
 pollutants  were  found  in  the wastewaters from both types of mills.
 However,  the,Agency found that operations processing  specialty  steel
 products generate higher levels of chromium,  copper,  lead,  nickel, and
 zinc   than   do  carbon  mills.    At  the  levels  present  in  these
 wastewaters,  this  difference  has  no   effect  on  the  selection  of
                                    35

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treatment  components
limitations.
                       or  on  the development of appropriate effluent
Specialty steels are produced by adding alloying agents to  the  steel
as  it is being produced.  These steels normally contain higher levels
of certain metallic elements such as chromium and  nickel  which  give
the  steel  added  properties.   Because  the specialty steels contain
these metals, there is a greater tendency for them to be  released  as
they  progress  through  steel  finishing  operations,  such  as  cold
rolling.

The  data  gathered  during  the  sampling  visits  demonstrate   that
wastewaters from specialty operations contain higher concentrations of
certain  metals than do wastewaters from carbon steel operations.  The
data presented below for recirculation mills illustrate this point.
            Carbon Steel
             Operations
                             Specialty Steel
                               Operations
Chromium
Copper
Lead
Nickel
Zinc
            Avg.
            Cone.
           (mq/1)

            0.01
            1 .4
            1 .3
            0.6
            0.5
 Max.
 Cone.
(mq/1)

 0.03
 2.0
 2.3
 0.9
 0.5
                              Avg.
                              Cone.
                             (mq/1)
          Max.
          Cone.
         (mq/1)
 5.3
11 .7
 3.1
 5.8
 5.7
10,
28,
10,
1 1 ,
 9.5
As can be seen by these data,
generate,  on  average,  2.4
                               mills  that  process  specialty  steels
                               (lead)  to  530  (chromium) times as much
metals as do the carbon steel mills.  These data also  show  that  the
metals  in  both carbon and specialty steel wastewaters are present at
concentrations  higher  than  treatability  levels.    The   treatment
technologies  for  removal  of  these  metals  will  produce  the same
effluent quality.  At the levels at which these metals are present  in
both  carbon and specialty steel wastewaters,  they will not affect the
size or cost of the  treatment  systems.   These  metals  are  present
primarily in particulate form.

For  the  other  pollutants  found  in  cold   rolling  wastewaters, no
differences were found due to product type.    The  previously  limited
pollutants  (i.e.,  total suspended solids, oil and grease) were found
at similar levels at most operations.  Some  waste  streams  are  more
concentrated  than  others  because  of  collection  practices at some
mills.  Depending on the product  being  rolled,  different  oils  and
greases  are used at different mills and within a given mill.  Many of
the oils and greases are proprietary in nature and are  chosen  mainly
for  their  lubricating  and cooling properties.  Subcategorization on
the basis of the various types of oils used is not  practical  due  to
the  wide  variety  of oils used, the complex  nature of those oils and
the paucity of data available for characterizing these oils.   It  was
found  that acceptable levels of oil and grease can be attained in all
                                    36

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discharges provided that properly designed and operated separation and
removal facilities are used to treat the wastewaters.

Toxic  organic  pollutants  found  in  cold  rolling  wastewaters  are
believed  to result from the oil cleaning solutions used in the mills.
The Agency found that the presence of these compounds  is  widespread,
and that they appear at varying levels in almost all oil solutions and
raw   wastewaters   discharged  from  cold  rolling  operations.   The
characteristics of the wastewaters  from  mills  using  different  oil
mixtures  is  also varied.  Different organic pollutants were detected
at the different mills sampled.  No clear distinctions could  be  made
on the basis of toxic organic pollutants found in the oil solutions in
raw wastewaters sampled.

The Agency has concluded that further segmentation of the cold rolling
subdivision   is   not   warranted   on   the   basis   of  wastewater
characteristics.

Wastewater Treatability

The Agency analyzed the treatability of the wastewaters from different
cold rolling operations and found  no  significant  differences.   The
same  types  of  treatment  systems treat these wastewaters and attain
similar effluent quality.  It  should  be  noted,  however,  that  the
Agency  found  that non-emulsifiable oils are used at some mills.  For
these mills the emulsion breaking steps in the treatment  schemes  are.
not needed.

Size and Age

The  Agency  considered whether size and age might affect segmentation
of cold rolling operations.   The  Agency  examined  the  correlations
between   age   and  size/  and  among  elements  such  as  wastewater
generation, the ability to  install  treatment,  and  the  ability  to
recycle wastes adequately to achieve desired flow rates.  The analysis
did  not  show  any  relationships that affect the segmentation beyond
that already considered.

Size was considered as a possible factor for segmentation.   The  cold
rolling  mills vary greatly in physical size, layout and product size.
However,  these  factors  revealed  no  significant  relationships  to
process  water  usage,  discharge rates, effluent quality or any other
pertinent factor.  Figures IV-1 through IV-5 are  plots  of  discharge
flow  vs size and discharge flow vs age.  On the plots, the model flow
rates used as the basis for the limitations are also shown.  As can be
seen, the model flow rates are achieved by a significant percentage of
mills of all sizes.  Likewise, the plots of flow  vs.  age  reveal  no
correlation.   Hence,  the  age of a mill has no significant impact on
the discharge flow from that mill.

There is a slight,correlation between  mill  size  and  age.   The  25
largest  mills  have  an  average  age (not counting rebuilds) of 18.5
years, while the 25 smallest mills have an average age  of  27  years.
                                    37

-------
 This  indicates  that as technology and material resource requirements
 increased over the years,  the size of an  average  cold  rolling  mill
 gradually  increased  to accommodate the higher demand for cold rolled
 products and to take advantage of  the  economy  associated  with  the
 larger  mills.   This relationship, however,  has no effect on discharge
 flow rates or effluent quality.

 The effect of age on the ability, ease,   and  cost  of  installing  or
 retrofitting  treatment  systems  was also analyzed.   Table IV-2 lists
 those plants where retrofitted treatment systems  were  installed  for
 older mills.   The numerous examples effectively illustrate the ability
 to  retrofit treatment systems onto older mills.   Cost data received in
 the D-DCPs for all iron and steel subcategories were tabulated.   Those
 data  show  that  little  or  no cost was attributable to retrofitting
 pollution control  equipment  by  the  industry.    This  analysis  was
 detailed  in  Volume  I of this  development  document.   Based upon this
 analysis,  the Agency concludes that there are  no  significant  costs
 associated  with  retrofitting  pollution control technology and that
 technology can  be retrofitted on both newer  and older mills with about
 the same degree of difficulty.

 Further  analysis of the data did not reveal  any  relationship  between
 age  and  wastewater  characteristics  or treatability.    Older mills
 discharge the same kinds and amounts of  pollutants as newer mills  and
 the discharges  from both older and newer mills can be treated equally.
 This  is  also   true  for   the  larger and smaller mills.   Some of the
 largest  mills  have  installed  the  best recirculation   systems  and
 achieve   some  of  the  lowest  discharge flows  on a  gallon/ton basis.
 Wastewaters  from larger mills can be treated as  effectively  as   those
 from smaller  mills.

 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

Examination   of   the   raw    waste   characteristics,   process    water
application   rates,  discharge   rates,   effluent  quality  and pertinent
factors  associated with  plant  location reveals no general relationship
or pattern.   Cold rolling  mills  are  located  in   fourteen  states,  but
over  half  of   the  total  number  are  located in Pennsylvania and  Ohio.
Seventeen are located  west of the Mississippi River   (14  in Missouri
and   3   in  California).   No  significant  differences due  to  geographic
location were found when data for  all plants were reviewed.

The Agency also  examined   in  relation   to   geographic  location,  the
remand   issue  dealing  with  consumptive  use  of water  in  "arid" and
                                    38

-------
"semi-arid" regions of the country.  However, since cooling towers are
not components  of  the  model  treatment  systems  for  cold  rolling
operations/  there  is  no  consumptive use of water which will result
from compliance with the  limitations  and  standards.   Consequently,
further segmentation on this basis is not appropriate.

Process Water Usage

This  factor,  more  than  any other, affects the subcategorization of
cold rolling operations.  The applied and discharge flow rates  differ
significantly  depending on the type of oil application system used at
the mills and the number of mill stands (single stand vs multi-stand).

Flow rates for the different type mills are shown in Table  IV-3.   As
can  be  seen,  both  the  applied  and  discharge  flow  rates differ
significantly.  This relationship was the  basis  for  segmenting  the
cold  rolling  subdivision  of the cold forming subcategory into three
segments, i.e., recirculation  mills,  combination  mills  and  direct
application mills.

Although the wastewater characteristics are similar for all mills, the
Agency  concluded  that different effluent limitations are appropriate
to* account  for  the  wide  variations  in  flow  rates  among  these
operations.   This  relationship  is  reviewed in more detail later in
this report.
                                    39

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                                         TABLE IV-1

                                EFFECT OF MILL CONFIGURATION
                                 ON THE DISCHARGE FLOW RATE
                                        COLD ROLLING
Type of
 Mill

1.  Recirculation
    1 - Stand
    3 - Stand
    4 - Stand
    5 - Stand

2.  Combination
    2 - Stand
    4 - Stand
    5 - Stand
    6 - Stand
             (2)
3.  Direct Application
    1 - Stand
    2 - Stand.
    3 - Stand
    4 - Stand
    5 - Stand
(3)
                               Total No. of
                                 Operations
                               Reporting Flows
                                   18
                                   6
                                   8
                                   9
                      2
                      4
                      6
                      1
3
2
3
4
3
                                          No. of Operations
                                            Achieving the ,.>
                                           Model Flow RateU;
                                              13
                                              3
                                              4
                                              8
                        1
                        3
                        3
                        0
2
1
0
3
1
                                                 Percent
                                                   72
                                                   50
                                                   50
                                                   89
                           50
                           75
                           50
                           0
                                                                                      67
                                                                                      50
                                                                                      0
                                                                                      75
                                                                                      33
(1)  BPT and BAT flow basis
(2)  The flow at this plant may be reduced through better operating practice,
     i.e., closer control on recycle rates at recirculation stands and application
     rates on the direct application stand.  Mills with lesser number of stands
     have higher discharge flow rates than this 6 stand mill.
(3)  The flow at this plant may be reduced through closer control of the
     application rates.  Plants with moire and less stands are able to achieve
     the model flow rates.
                                             40

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                  TABLE  17-2

 EXAMPLES OF PLANTS THAT HAVE DEMONSTRATED THE
ABILITY TO RETROFIT POLLUTION CONTROL EQUIPMENT
                  COLD ROLLING
0206
060
060B
060D
122A
112B
176
384A
396D
432A
432B
432C
448A
528
584A
 584C
 584F
 684C
 684D
 684F
 760
 8560
 856P
 864B
 868A
 920A
 948A
 948C
Mill Age
 (Year)

1951
1936
1963
1926
1947
1936
1921
1938
1938
1947
1937
1957
1952
1955
1965
1947
1947
1937
1939
1937
1950
1938
1909
1947
1948
1930
1935
1954
Treatment Age
    (Year)

1975
1967
1968
1968
1971
1971
1963
1948
1959
1970
1966
1964
1969
1975
1971
1947 & 1977
1965
1950
1970
1969
1971
1959 & 1967
1968
1972
1971
1978
1976
1970
                    41

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                                         TABLE IV-3

                        RELATIONSHIP BETWEEN FLOW AND OPERATION TYPE
                        	COLD ROLLING
Recirculation Mills
  Single Stand
  Multi Stand

Combination Hills

Direct Application Mills
  Single Stand
  Multi Stand
                              Applied Process Flow
                              	(GPT)
1551
3524

3930
86*
383*
                 Discharge Flow*
                      (GPT)
3.7
9.9

258
86
383
                Model Flow
                   (GPT)
5
25

300
90
400
* "Average of the Best" flow (see Section X).
                                           42

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                              SECTION V

                       COLD FORMING SUBCATEGORY

                             COLD ROLLING

              WATER USE AND WASTEWATER CHARACTERIZATION
Introduction

This section presents a characterization of cold rolling  wastewaters.
The  wastewater  characterization  is based upon data obtained through
three field sampling programs.  The wastewaters  at  31  cold  rolling
operations  were  sampled  during  the  first  two  surveys,  while 52
operations were sampled during the third  survey.   During  the  first
sampling  survey,  the  Agency  investigated  the levels of pollutants
limited in the 1976 regulation.  During the second and third  surveys,
the  Agency  expanded  the monitoring programs to include sampling for
toxic pollutants.  Some mills were visited on more than  one  occasion
during  the  three sampling programs.  With a few exceptions, the more
recent data were used  to  characterize  the  wastewaters  from  those
mills.  Where significantly different results were found, or different
pollutants  were monitored at each visit, the results from both visits
are presented.
                                                          to   process
                                                         or nonprocess
                                                         into  contact
                                                         thus becoming
                                                         the  process.
                                                         for  cooling,
                                                         materials, or
                                                         which is used
The  water  use  rates  discussed  below  pertain  only
wastewaters,  and  do  not  include  noncontact  cooling
waters.  Process wastewater is that water  which  comes
with the process, product, by-product, or raw materials,
contaminated   with   pollutants   characteristic   of
Noncontact cooling water is defined as that water  used
which does not directly contact processes, products, raw
by-products.   Nonprocess water is defined as that water
for nonprocess operations (i.e., utilities).

Description of the Cold Rolling
Operation and Wastewater Sources

The major process water use in cold rolling mills is for  cooling  and
lubricating  the  rolls  and  the  material  being  rolled.   This  is
accomplished with  flooded  lubrication  systems,  where  a  water-oil
emulsion  is  sprayed  directly on the material and rolls.  Each stand
usually has separate sprays and, where recycle  is  used,  a  separate
recycle  system.   Past  practice  has been the direct sewering of the
emulsion.   However,  the  high  cost  of   rolling   oils   and   the
implementation  of  pollution  control  regulations have modified this
practice.  Recycle and recovery systems are currently in  common  use.
In   fact,   most  of  the  recently  built  cold  rolling  mills  use
recirculated oil solution systems to minimize oil usage and  pollutant
discharges.
                                    49

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 Considerable  heat is generated during heavy reductions  at  high speeds
 on  the various types of mills.   The temperatures of  both the  product
 and  the   rolls  are  raised.    This  heat  is  removed  by  the flooded
 lubrication  system and  by  noncontact  water  that   is   used  in   the
 internal   roll cooling system.   High quality rolling oils are added to
 form  the  emulsion sprayed on the rolls.   Oil and temperature  are   the
 basic  pollutants   in  the discharge.    However,   the oils  become
 contaminated with solids as  they pass over the rolls and the  product.
 Also,   the  oils   themselves can contain high levels of toxic organic
 pollutants.

 Recirculation  mills are more common throughout the   industry,   and   in
 the  aggregate,   higher  tonnages  are rolled on these mills.   In this
 operation, the oil emulsion   in  the  flooded  lubrication   system   is
 collected,   treated  or  conditioned,   and  recycled  to the mill  for
 reapplication  to  the rolls.   Generally,   each  stand  has  a  separate
 collection  tank   or  sump  and  pumps  to  return the emulsion to  the
 sprays.   A five stand tandem mill has five recycle   systems,   one   for
 each   stand.    With  this arrangement,   it . is  possible to renew  one
 emulsion  tank  at  a time,  or  all at once.   It is also possible  to   use
 different oil  emulsions in each tank,  if the product being rolled so
 requires.  These  mills usually  have periodic batch discharges of spent
 rolling emulsions,  although  a small amount is continuously  blown  down
 at  some  mills  to maintain rolling solutions at an acceptable quality.
 The emulsions  in  some mills  are treated  in filters and cooling systems
 prior  to  reuse, thereby assuring that the  rolling   solutions  contain
 minimal    amounts  of  impurities  and  remain  at   a fairly  uniform
 temperature.  Because of  the conservation practices   in   use  and   the
 high   degree  of   recycle,   very  low wastewater discharge  volumes  are
 achieved.

 The oils  used  for  cold  rolling  are frequently changed   to either
 replace   the  spent  emulsion   or  to meet  certain  product   quality
 requirements.  At some plants,  the oils may be  changed   on  a weekly
 basis,  while  at  others,   longer  periods of time  may  elapse between
 changes.   The waste solutions are usually collected  in  storage tanks
 and bled  into   the  wastewater  treatment  system  or sold to outside
 contractors for disposal  or  reclamation.

During the oil change it  is  common practice to clean  the   oil  system
before a fresh oil  solution  is  added.  Solvents containing  chlorinated
organic  compounds,   e.g.,   tetrachloroethylene and  trichloroethylene,
are commonly used  as  cleaning solutions.    The  cleaning  solution   is
also usually discharged to the  wastewater treatment  system.

The  Agency  sampled   the  oil   solutions,  raw wastes, and  treated  and
partially  treated  effluents  at  several cold rolling   operations.    The
resulting  data   demonstrate widespread contamination  of oil solutions
and effluents by  toxic  organic   pollutants.    Thirty   different  toxic
organics  were  found   at  varying   levels   at  the operations  sampled.
These data clearly  demonstrate  the  widespread  nature  and diversity  of
toxic  organic  pollutant  contamination   and   the need for  control of
these pollutants.
                                    50

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Flow data .and net concentrations of pollutants (net over water supply)
found at the recirculation operations  surveyed  for  this  study  are
summarized in Tables V-l and V-2.  Net concentrations are presented to
better  describe  the  actual  levels of pollutants contributed by the
rolling operations.  For certain plants the gross  values  are  shown,
since  data  on  the  makeup water flow rates were not available.  The
pollutants are nevertheless representative of the  contributions  from
the  operation.   The  water  supply  is  known  not  to contain these
pollutants at levels comparable to those found in  these  wastewaters.
As  shown  in Section VII, the water supply has little or no effect on
these pollutants.  Averages are also presented  to  show  the  typical
level  of  pollutants  that can be expected to be found in a discharge
from a recirculation cold rolling mill.

The second type of cold rolling operation  is  the  combination  mill,
which  is,  as  the  name  implies, a combination of recirculation and
direct application rolling stands.  These cold mills are  multi-stand,
with  the  last  stand  usually  being  the  direct application stand.
Although the applied flow rates are higher than for the other types of
mills, the discharge flow rates in gallons/ton for  combination  mills
are  substantially  less  than for direct application mills because of
the recirculation system.  Flow and net  concentration  data  for  the
combination mills surveyed are summarized in Tables V-3 and V-4.

The  third  type  of  cold rolling operation is the direct application
mill.  In  these  mills,  fresh  rolling  solutions  are  continuously
applied  to  the  rolls  or  product.   Treatment  plants and palm oil
recovery systems are usually  installed  to  reclaim  these  oils  for
reprocessing  and  potential reuse.  The high cost of rolling oils has
discouraged the use of once-through systems.  Once-through systems are
used only when a high quality product  is desired, which  requires  the
application  of a solution that  is free of contamination.  These mills
have the highest discharge flow rates  of  any  of  the  cold  rolling
operations.   Flow  data  and  net  concentration  data for the direct
application mills sampled for this study are presented in Table V-5.

Regardless of the type of .oil application systems used,  miscellaneous
oil  leaks  and spills can occur.  Low volume, oil-bearing wastewaters
originating in maintenance and roll finishing shops can be significant
and should be directed to treatment facilities.  Oil and  water  leaks
in oil basements can also contribute high oil loads.  These sources of
wastewater   were   considered    in  developing  the  limitations  and
standards.
                                     51

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                                          TABLE V-l
                       SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
                                  ORIGINAL GUIDELINES STUDY
                       	COLD ROLLING - RECIRCULATION	

                   Net Concentrations of Pollutants in Raw Wastewaters
                          (1)
D
0248B
11
57
I
043 2K
2
0.8
P
0156B
26-27
58,280
Plant Code
Reference Code
Sample Point(s)
Flow (gal/ton)
    Total Suspended 1.170   NA      NA
    Solids
    Oil & Grease    3,700   36,000  -
    Dissolved Iron  NA      NA      NA
    pH              6.8     NA      NA

119 Chromium        0.1     NA      NA
120 Copper          0.01    NA      NA
121 Cyanide, Total  0.0     NA      NA
122 Lead            0.0     NA      NA
124 Nickel          0.62    NA      NA
128 Zinc            0.03    NA      NA
  X-2    BB-2   EE-2      XX-2
060B-03 060-03 0112D-01 06841-01
  4-7    5-4    1-3       2-1    Average
  17.7   16.0    17.4     138     8361
                                             90

                                             41,100
                                             NA
                                             7.0

                                             NA
                                             NA
                                             NA
                                             NA
                                             NA
                                             NA
        55

        664
        0.05
        8.0

        NA
        NA
        NA
        NA
        NA
        NA
637

1,180
NA
6.9

NA
NA
NA
NA
NA
NA
260

619
NA
7.1

NA
NA
NA
NA
NA
NA
442

11,890
0.05
6.8-8.0

0.1
0.01
0.0
0.0
0.62
0.03
(1) All values are in mg/1 unless otherwise noted.

NA:  Not analyzed
                                            52

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                                         TABLE V-3

                      SUMMARY OF ANALYTICAL DATA  FROM SAMPLED PLANTS
                                 ORIGINAL GUIDELINES STUDY
                      	COLD ROLLING  - COMBINATION	

                   Net Concentration of Pollutants in Raw Wastewaters
                               (1)
Plant Code
Reference Code
Sample Point
Flow (gal/ton)

Total Suspended Solids
Oil & Grease
Dissolved Iron
PH
 DD-2
584E-01
   1
  512

987
1,399
7.8
5.7
(1) All values are in mg/1 unless otherwise noted.
                                     57

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                       COLD FORMING SUBCATEGORY

                             COLD ROLLING

                              SECTION VI

                        WASTEWATER POLLUTANTS
Introduction

The final selection of pollutants to be limited for the  cold  rolling
subdivision   is  based  primarily  upon  the  results  of  the  three
monitoring programs described in Section V.  The pollutants  found  in
the  first  guidelines  surveys were confirmed and augmented with more
extensive monitoring data that included analyses for toxic pollutants.
This section describes the pollutants chosen, and  the  rationale  for
selecting those pollutants.

Conventional and Nonconventional Pollutants

In  the  previous  regulation,  four  pollutants  were limited:  total
suspended solids, oil and grease, dissolved iron  and  pH.   Suspended
solids,  oil and grease and pH were limited at all cold rolling mills.
However, dissolved iron was limited only when cold rolling wastewaters
were treated in combination with acid pickling wastewaters.

Two of these pollutants, oil and  grease  and  suspended  solids,  are
characteristic  of  the  cold mill wastewaters.  Both originate in the
oil solutions that  are  sprayed  on  the  rolling  stands.   Oils  in
significant  levels  (up  to  40,000  mg/1) are contained in untreated
wastewaters.  Suspended  solids  are  also  present  in  cold  rolling
wastewaters in high levels, with concentrations of 1000 mg/1 common at
many mills.  The suspended solids also originate in the oil solutions,
as  the  oils pass over the stands and product and pick up small scale
particles or dirt from the product surface.  In  recirculation  mills,
the  solid  levels  are usually higher than for other mills because of
the buildup that can occur as  the  oil  solutions  are  recirculated.
Dissolved  iron  may  also be present in cold rolling wastewaters, but
generally at low levels.  Also, dissolved iron is no longer limited in
the acid pickling subcategory.  For these reasons and  the  fact  that
toxic  metals  are limited in this subdivision (see discussion below),
the Agency has decided not to limit dissolved iron in the cold rolling
subdivision.

Limitations for pH were included in the original  regulation  and  are
included  in  this  regulation.   Although  the  pH  of  raw cold mill
wastewaters is often within the range of 6  to  9  standard  units,  a
limitation  has been promulgated to ensure that the pH remains in this
range after treatment.   Most cold mill treatment systems include  acid
addition  for  treatment of the oily wastewaters, which reduces the pH
                                    61

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 to the 4-5 range.  The pH limit ensures that proper neutralization  is
 carried out prior to discharge.

 Toxic Pollutants

 Table  VI-1  is  a  list of the toxic pollutants found in cold rolling
 wastewaters, from surveys conducted by the Agency or reported  by  the
 industry  in  D-DCPs.   The  net  concentration  of each pollutant was
 calculated, and  those  that  were  found  at  average  concentrations
 greater  than  0.010  mg/1 are considered to be characteristic of cold
 mill  wastewaters.   Table  VI-2  presents  a  list  of  those   toxic
 pollutants.  It is important to note that net concentrations were used
 only  to  characterize  the  pollutants  generated  in  the  cold mill
 process.  All effluent limitations were developed  on  a  gross  basis
 taking into account the treatability of each pollutant.

 Some  pollutants  were  detected  at concentrations greater than 0.010
 mg/1 but are not listed  in  Table  VI-2.   The  Agency  believes  the
 presence  of those compounds is not due to the cold rolling operation.
 Methylene chloride was omitted, because this compound is commonly used
 as a cleaning agent in the laboratory,  and the Agency  attributes  its
 detection  to  this practice and not to the cold mills sampled.  Also,
 the phthalate compounds are not believed to be characteristic of  cold
 mill   wastewaters.     The   Agency   attributes   their  presence .to
 plasticizers in the  tubing  used  with  automatic  samplers  for  the
 Agency's surveys.

 As  noted  in  Table VI-2, many toxic organic and inorganic pollutants
 were detected in wastewaters from cold rolling operations.   The  major
 sources  of  these  pollutants  are  the  rolling  oils  and  cleaning
 solutions used at the mills.  The exact nature of these oils are often
 proprietary, making it difficult to relate any of  the  pollutants  to
 any one type of oil or brand name.

 The  Agency  did not promulgate effluent limitations and standards for
 each of the toxic pollutants listed in Table VI-2.   Lead and zinc were
 selected as indicator pollutants  for  other  toxic  metals  found  in
 carbon  steel cold rolling wastewaters, while chromium and nickel were
jselected as indicator pollutants for toxic metals found  in  specialty
~steel    cold    rolling    wastewaters.      Since   naphthalene   and
 tetrachloroethylene are common  to  most  cold  rolling  and  cleaning
 solutions,    respectively,   the   Agency  developed  limitations  and
 standards for these toxic organic  pollutants.    However,   because  of
 wide  variations  in  the occurence of  other toxic organic pollutants,
.the Agency has concluded that it is not feasible to  develop  national
 limitations  and  standards  for all toxic organic pollutants found in
 cold rolling wastewaters.   Instead,   it  believes  that  the  specific
 toxic  organic  pollutants  found at each plant should be limited on  a
 case-by-case basis.   The Agency believes that the use of the  selected
 indicator  pollutants  will  result in  comparable control  of the other
 toxic  pollutants  and  in  reasonable   monitoring  programs  for  the
 industry.
                                    62

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             TABLE VI-1

TOXIC POLLUTANTS KNOWN TO BE PRESENT
            COLD ROLLING
    4.   Benzene
    6.   Carbon Tetraehloride
   11,   1,1,1-Trichloroethane
   13.   1,1-Diehloroethane
   23.   Chloroform
   24.   Chlorophenol
   34.   2,4-Dimethylphenol
   38.   Ethylbenzene
   44.   Methylene Chloride
   57.   2-Nitrophenol
   59.   2,4-Diriitrophenol
   60.   4j6-binitro-o-cresol
   64.   Pentachlorophenol
   65.   Phenol
   66.   Bis(2-ethylhexyl) phthalate
   67.   Butyl benzyl phthalate
   68.   Di-n-octyl phthalate
   69.   Di-n-oetyl phthalate
   70.   Diethyl  phthalate
   71.   Dimethyl phthalate
   78.   Anthracene
   80.   Fluorene
   85.   Tetrachloroethylene
   86.   Toluene
   87.   Trichloroethylene
  114.   Antimony
  115.  , Arsenic
  117.   Beryllium
  118.   Cadmium
  119.   Chromium
  120.   Copper
  121.   Cyanide
  122.   Lead
  124.   Nickel
  126.   Silver
  128.   Zinc
  130.   Xylene
                    63

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                              .  TABLE VI-2

                           SELECTED POLLUTANTS
                              COLD ROLLING
Recirculation

     Total Suspended Solids
     Oil and Grease
     pH
001  Acenaphthene
Oil  1,1,1-Trichloroethane
013  1,1-Dichloroethane
023  Chloroform
039  Fluoranthene
055  Napthalene
060  4,6-Dinitro-o-cresol
065  Phenol
072  Benzo-a-anthracene
076  Chrysene
077  Acenaphthylene
078  Anthracene
080  Fluorene
081  Phenanthrene
084  Pyrene
085  Tetrachloroethylene
086  Toluene
087  Trichloroethylene
114  Antimony
115  Arsenic
118  Cadmium
119  Chromium
120  Copper
122  Lead
124» Nickel
128  Zinc
Combination

     Total Suspended Solids
     Oil 'and Grease
     PH
039  Fluoranthene
055  Napthalene
078  Anthracene
080  Fluorene
081  Phenanthrene
084  Pyrene
115, Arsenic
119  Chromium
120  Copper
124  Nickel
128  Zinc
Direct Application

     Total Suspended Solids
     Oil and Grease
     PH
006  Carbon Tetrachloride
Oil  1,1,1-Trichloroethane
055  Naphthalene
078  Anthracene
085  Tetrachloroethylene
086  Toluene
115 i Arsenic
117  Beryllium
119  Chromium
120  Copper
122  Lead
124  Nickel
128  Zinc
                                    64

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                       COLD FORMING SUBCATEGORY

                             COLD ROLLING

                             SECTION VII

                   CONTROL AND TREATMENT TECHNOLOGY
Introduction

A review of the control and treatment technologies currently in use or
available  for  use in the cold rolling subdivision provided the basis
for the selection and development of BPT, BAT, NSPS,  PSES,  and  PSNS
alternative  treatment systems.  The Agency reviewed the DCP responses
and plant visit  data  to  identify  those  treatment  components  and
systems  in  use  at  cold  rolling  operations.  Performance of these
treatment systems, demonstrated in this or in other operations  (refer
to   Volume   I)   were  used  in  evaluating  the  various  treatment
technologies.  This  section  presents  a  summary  of  the  treatment
practices  currently in use or available for treatment of cold rolling
wastewaters.

This section also presents the raw  wastewater  and  treated  effluent
data  for  the plants sampled and the long-term effluent data provided
in responses to the D-DCPs.  Also included  are  descriptions  of  the
treatment  systems  installed  at  each  of  the sampled plants and an
analysis of the impact of makeup waters on  raw  wastewater  pollutant
loadings.

Summary of. Treatment Practices in Use

Since  the characteristics of wastewaters generated in the three types
of cold rolling mills are similar,  the  same  treatment  is  employed
regardless  of  the  oil  application system used.  The same treatment
system may be used to treat wastewaters only from recirculation  mills
or  it  may  be  used  to  treat  a  combined  wastewater  from direct
application, combination, and recirculation mills.  Varying degrees of
recovery and reuse of oil emulsions  is  practiced.   While  this  may
affect  the  raw concentration of pollutants in the discharge, it does
not have a significant effect on the  treatment  components  selected.
Depending upon the extent of recycle or reuse practiced, the treatment
systems may be sized differently.

All treatment systems for cold rolling mills include physical/chemical
controls.   Also,  wastewaters from over 95% of all cold rolling mills
are treated in central treatment systems (i.e., other wastewaters  are
combined  with  cold rolling wastewaters prior to treatment).  As with
many other forming and finishing operations,  this  often  complicates
the  analysis  of the effluent data for the sampled mills, because the
high strength cold mill wastewaters are  sometimes  diluted  in  large
central treatment systems.
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Because of the predominance of central treatment systems, the data for
this  subcategory  and others were analyzed to determine the effect of
central treatment systems on the ability to achieve the same level  of
treatment   achieved   through  separate  treatment  of  cold  rolling
wastewaters.  This analysis demonstrated that similar flow  rates  and
effluent  levels  are achievable with both types of treatment systems,
provided that adequate pretreatment of the cold rolling wastewaters is
practiced.   Therefore,  the  Agency  did  not  differentiate  between
separate  and  central  treatment.  All treatment models shown in this
document reflect "stand-alone" systems, which can be  integrated  into
central   treatment  plants.   Due  to  the  nature  of  cold  rolling
wastewaters, the Agency believes  that  these  wastewaters  should  be
pretreated  for  the  removal  of  oil  and  grease  and toxic organic
pollutants prior to mixing with other wastewaters in central treatment
plants.

Additionally, wastewaters from many plants are  collected  and  hauled
off-site   for  disposal  or  reclamation  by  contractors.   Thirteen
recirculation mills have achieved no discharge of process  wastewaters
through  this  method.   Besides direct discharge mills, there are ten
mills that have only limited pretreatment  and  discharge  to  locally
owned public treatment works.


A  summary  of control and treatment technology currently practiced at
cold rolling mills follows:

1.    The first  level  of  pollutant  control  for'  recirculation  and
     combination  mills  is oil solution reuse.  This practice results
     in great cost savings and also results in significant  reductions
     in  flow and pollutant loads discharged from the operations.  The
     average recirculation rate of rolling  solutions  for  the  mills
     surveyed is 94.4% with a range of 58.4% to 100%.

2.    Several options exist for treatment of cold rolling wasters.  All
     are  physical/chemical  in  nature.    The   pollutants   in   the
     wastewaters  from  cold rolling operations are usually treated in
     separate unit operations.   These systems are summarized below  by
     the pollutant removed.

     a.   Oils and Greases

          Oils and greases present in  cold  rolling  wastewaters  can
          either  be emulsified or nonemulsified.   The characteristics
          of emulsified oils vary widely,  depending on  the  types  of
          oils  used  in the rolling solutions.  Floating or free oils
          resulting from mechanical lubrication systems are not  found
          in quantities as high as the emulsified oils.

          If all the oils and greases are nonemulsified, as at some of
          the  direct  application mills  surveyed,  oil skimming can be
          used for oil treatment.   These   wastewaters   are  discharged
         "through  a  tank  or   basin of  sufficient size and design to
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     allow the oil to separate and rise to the surface.   At  the
     surface,  the  oil  is  contained  by  underflow baffles and
     skimmed.

     However,  if  the  wastewaters  contain   emulsified   oils,
     chemical  treatment  is  required  to separate the oils from
     solution  prior  to  other  treatment  steps.   Either  acid
     pickling  rinsewater  or purchased acid is added to the oily
     cold rolling wastewaters in a mixing tank at a pH of 4-5  to
     chemically  break the oil emulsions.  Once the emulsions are
     "broken", coagulant or  flotation  aids  such  as  alum  and
     polyelectrolytes  may  be  added.   The wastewaters are then
     neutralized and passed through dissolved  air  flotation  or
     similar  oil  removal systems, where oils are separated from
     the wastewater.  Another alternative used for oil removal is
     sedimentation and skimming after emulsion breaking.

     Dissolved air (gas) flotation is used to separate  the  oils
     and other suspended solids and low density material from the
     wastewaters.   In  this process, the wastewater is saturated
     with gases  (air), pressurized  and  subsequently  introduced
     into  the  flotation  tank  at  atmospheric  pressure.   The
     dissolved gases are released from solution and form fine gas
     bubbles.  These gas bubbles attach to  the  oily  and  other
     suspended  material.   This  increases  the  buoyancy of the
     material,  thus  enhancing  separation  by  flotation.   The
     floating material is skimmed from the surface.

b.   Total Suspended Solids

     Moderate levels of suspended solids are  generated  in  cold
     rolling operations.  These solids are picked up on the rolls
     and  carried  from  the  process in the oil-water emulsions.
     Suspended solids removal,  in most cases,  is carried  out  in
     clarifiers  or  in  lagoons  after  the addition of lime and
     polymer in mixing tanks.   These chemicals  promote  settling
     and  neutralize the wastewaters.  Also,  suspended solids are
     removed by the oil removal systems, as some solids cling  to
     the  oil  particles  and are removed by the skimmers and air
     flotation devices.

     An alternative method used at a small  number  of  mills  to
     remove  suspended  solids  and  oil is ultra-high rate (UHR)
     filtration.   Primary settling and skimming is done prior  to
     filtration  to  reduce the levels of floating oils and heavy
     solids.   Polyelectrolyte addition prior  to  the  filter  is
     sometimes  used  to improve filter effluent quality and also
     to facilitate filter backwashing.   Clogging of the filter is
     minimized by adding steam to the backwash cycle in  addition
     to  air  and  water.   The UHR filter is  highly effective in
     reducing solids and  oils  and  can  be  installed  in  much
     smaller areas than conventional settling  basins.
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3.   Plants which discharge to publicly owned treatment works  usually
     have  an  intermediate  level  of  treatment.   Most have primary
     settling and oil skimming to reduce  the  loadings  of  suspended
     solids  and  oils  entering  POTWs.  An ultrafiltration system is
     used at one plant for pretreatment.

4.   Waste oil solutions are collected and hauled off-site for a large
     number of plants with small waste volumes.  Surface oil  skimming
     prior  to  disposal  is practiced at some mills for recovery of a
     portion of the used oil.

Control and Treatment Technologies
Considered for Toxic Pollutant Removal

Because toxic metal and toxic organic pollutants  have  been  detected
above   treatability  levels  in  the  discharges  from  cold  rolling
operations, the Agency considered advanced  levels  of  treatment  for
BAT, NSPS, PSES, and PSNS.

Methods  available to effectively reduce the levels of the toxic metal
pollutants in cold rolling wastewaters  include  filtration,  chemical
precipitation, and others as noted in Volume I.

Thirty  toxic  organic  pollutants  were found in the wastewaters from
cold rolling  mills.   These  pollutants  originate  in  the  oil  and
cleaning  solutions  used.  Toxic organic pollutants were found in the
wastewaters from each  type  of  cold  rolling  operation  at  varying
levels.   As  a  result, the Agency investigated alternative treatment
technologies for the removal of toxic organic pollutants.

The treatment alternatives  that  were  considered  for  cold  rolling
wastewaters  are  discussed below.  Although only one of these systems
has been demonstrated within the cold rolling  subdivision,  they  all
have been demonstrated in other industrial applications on wastewaters
with characteristics similar to those of cold rolling wastewaters.

A.   Filtration

     Filtration is commonly used  in  the  steel  industry  to  remove
     suspended  solids,  including particulate toxic metals, and oils.
     The filters in use in the industry include single and multimedia,
     and  gravity  and  pressure  type   systems.    All   have   been
     demonstrated  to  be equally effective.  As discussed previously,
     filters are being used to treat cold rolling wastewaters.

     Filtration removes suspended solids and oils from the  wastewater
     by  a  combination  of  physical  and  chemical mechanisms, e.g.,
     deposition,  entrapment,   and   other   surface   and   particle
     interactions.  The wastewater is passed through the filter media,
     where  the suspended solids and oils are removed and accumulated.
     On a periodic basis, depending on pressure drop across the filter
     or a  predetermined  timing  cycle,  the  filter  is  cleaned  by
     backwashing.    The  water  used for backwashing is collected in a
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     sedimentation tank.  The  sludge
     dewatered  and  disposed,  while
     filtration system.
underflow  from  this  tank  is
the overflow is returned to the
B.   Processing of Wastewater With Activated Carbon

     Activated carbon has been used in several  applications  for  the
     removal  of  organic  pollutants from wastewaters.  It is used to
     treat  wastewaters  from  cokemaking,  petroleum  refining,   and
     organic  chemical  manufacturing.  Operational guidelines for the
     use  of  activated  carbon  specify  that  where  the  water   or
     wastewater  to  be  processed has significant turbidity, chemical
     clarification followed by filtration should precede the activated
     carbon  unit.   Some  industrial   applications   have   chemical
     precipitation   followed  by  diatomaceous  earth  filtration  to
     achieve the clarity required for low  level  removal  of  organic
     pollutants.  The need for removal of particulates increases where
     removal of toxic organic pollutants to low levels is required.

     The  data  available  for carbon adsorption indicate that most of
     the toxic organic pollutants found in the  discharges  from  cold
     rolling  mills  respond well to carbon adsorption.  The data from
     other applications of this technology indicate that most  of  the
     organic  pollutants  can be treated to levels below 50 micrograms
     per  liter.   Reference  is  made  to  Volume  I  for  additional
     information on Activated carbon adsorption.

C.   Ultrafiltration

     Ultrafiltration (UF) techniques are based upon a  pressure-driven
     filtration   membrane  to  separate  multicomponent  solutes,  or
     solutes from solvents, according to  molecular  size  and  shape.
     Ultrafiltration  can  be  designed  to  separate the oil emulsion
     present in many of the discharges from cold  rolling  operations.
     At the same time, organic compounds of a certain molecular weight
     will  also  be removed.   Hence, ultrafiltration could prove to be
     an effective means of removing organic toxic pollutants from cold
     rolling wastewaters.

     One of the sampled plants,  Plant  101,  has  an  ultrafiltration
     system  installed  to  treat wastewaters from twelve cold rolling
     mills.  The data for this plant (see Table VII-3), show that  the
     ultrafiltration  unit  is effective in reducing the levels of oil
     and  grease  and  organic   matter.    However,   one   potential
     disadvantage  of this system is that the membrane is selective in
     the types of pollutants it will remove and  can  clog  easily  if
     free  oils  or  similar pollutants are present.  This problem was
     experienced at Plant 101.  Wastewaters from one of the cold mills
     are now hauled off-site, because the  ultrafiltration  system  is
     unable to effectively treat the wastewaters from this mill.

     Although  UF  has been demonstrated at Plant 101, this technology
     has not been used as the basis for the effluent  limitations  and
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     standards  developed  for  this subcategory.  The Agency does not
     believe that the data available at this time are  sufficient  for
     application of UF to the entire cold rolling subcategory.

D.   Vapor Compression Distillation

     Vapor compression  brine  concentrators  are  typically  used  to
     concentrate  high  TDS  waters  (3,000-10,000  mg/1)  to a slurry
     consistency (approximately 100,000 mg/1).  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.  The
     distillate quality water generated by this system can be recycled
     to the process, thereby eliminating the aqueous  discharge.   One
     desirable  feature  of  this  system is its relative freedom from
     scaling.   Because  of  a  unique  design,  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).
     Due
          to   cost  and energy  considerations,  only  limited  application
      is  made  of   vapor   compression   distillation    in    processing
      wastewaters.

Summary of Sampling Visit  Data

Recirculation  Mills

Fifty-seven  recirculation operations were visited during  this study,
with  twelve operations sampled twice.   The   raw   and  effluent  data
gathered  for  the  original   guidelines study are  summarized  in Table
VII-2.  Table  VII-3 presents the raw and effluent data  from the  toxic
pollutant  survey.   Table VI1-1  provides  a  legend  for  the various
control and treatment  technology  abbreviations  used  on   the  above
tables   and   in   other   tables  throughout   this  report.    A  brief
description of each wastewater treatment system  follows.  More details
are available  on the respective wastewater flow  diagrams.

Plant D (0248B-01)  - Figure VII-1

Oil skimming is used to remove insoluble oils, and  chemical   addition
is  used  to break  the oil emulsion found in the blowdown coolant from
the cold rolling operation.

Plant I. (0432K) - Figure VII-2

Oil skimming is used to remove insoluble oils, and  a paper   filter  is
used  to remove particulate matter before recirculating the  coolant to
the cold rolling operation.  The skimmed  oil  is   reprocessed  by  an
outside firm.   There is no other discharge from this system.
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Plant P (0156B) - Figure VII-3

The  effluent  from  the  mill is filtered removing oils and suspended
solids.  The filter effluent is recycled to the mill.

Plant X-2 (0060B-03) - Figure VI1-4

Treatment at this mill consists of air flotation, chemical  treatment,
clarification, and plant reuse.  The cold mill wastewaters are treated
in a central treatment unit together with acid pickling wastewaters.

Plant BB-2 (0060-03) - Figure VII-5

Cold  rolling  wastes are treated in combination with pickling wastes.
Treatment consists of  neutralization,  aeration,  clarification,  and
lagooning prior to discharge to the receiving stream.

Plant EE-2 (0112D-01) - Figure VII-6

Oil  skimming, chemical treatment, and lagooning are provided prior to
discharge.

Plant XX-2 (06841-01) - Figure VII-7

Treatment at this mill consists of primary settling, oil skimming, and
secondary settling in a lagoon.  The cold mill wastewaters are treated
in conjunction with wastewaters from other operations.

Plant 101 - and 301 (.0020B & CJ_ - Figure VII-8

Plant 301 is a revisit of 101.  Wastewaters at this plant originate at
twelve  different  cold  rolling  operations.   All  wastewaters   are
collected  in  a  holding tank and are treated by ultrafiltration on a
batch basis.  The effluent from this system is discharged to a POTW.

Plant 102 and FF-2 (0384A-02, 03) - Figure VII-9

Plant 102 is  a  revisit  of  FF-2.   Treatment  consists  of  primary
sedimentation,   mixing,   and   clarification.    The   cold  rolling
wastewaters are combined with wastewaters from a hdt strip mill  prior
to mixing and clarification.  Flow and production data shown on Figure
VII-9 are from the second visit (102).

Plant 105 (0584F-02, 03, 05) - Figure VII-10

This  plant  has  a  treatment/oil reclamation system that treats cold
mill wastewaters from three recirculated and  one  direct  application
mill.   Treatment  at  this  mill  consists  of oil holding tanks, oil
skimming and discharge to large  lagoons,  where  additional  oil  and
solids  removal  is  provided.   The  effluent sample at this mill was
taken prior to the lagoons.
                                    7]

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 Plant 302 (0060E)  - Figure VII-11

 The dirty rolling  oils and tramp oils from the No.   1   Sendzimir  mill
 pass  through a heat exchanger and collect in a settling tank equipped
 with oil  skimmers.   The collected tramp oils are hauled  to  disposal,
 while  the rolling oils are reclaimed.   The effluent from the settling
 tank flows to a magnetic separator and then recycles to the mill.

 Plant 304A and B and 305 A and B (0176-08) - Figure VII-12

 Plant 305 is a revisit of Plant 304.   The 12" direct application  mill
 is   represented by  Plant 304B and 305A.  This mill is a once through
 operation discharging to a central treatment plant.   The W-F reversing
 recirculation mill  was sampled as  Plant  304A  and   305B.    Wastewater
 from  the  mill is  discharged  to a dirty water sump and then pumped
 through a filter.   The filter  effluent  is collected in a  clean water
 tank  and  recycled  to  the mill.  A small blowdown is taken from the
 dirty water tank every four to  six  weeks  and  conveyed  to  central
 treatment.

 Plant 306 and 307  (0248B-03) - Figure VII-13

 Plant 307 is'a revisit of Plant 306.  Waste oil solutions collect  in  a
 dirty  water  sump   and  pass  through hydromation filters.   The filter
 effluent  returns to the mill.   Once a week the contents of   the dirty
 water  sump  discharge  to  a  central treatment plant  in a  batch dump.
 Central treatment  consists of  a surge  tank,   emulsion  breaking,   oil
 removal,  and settling.

 Plant 308 (0320) -  Figure VII-14

 The   wastes   from   the  No.  2 tandem mill discharge to a  holding  tank
 where oils  are skimmed  and removed.    From  the  holding   tank,   the
 wastewater   flows to an indexing paper  filter and then recirculates to
 the  mill.

 Plant  310 (0432C) - Figure VII-15

 Waste  oil solutions from the 77" tandem cold mill are  discharged to  a
 steam  heated   oil  holding tank, where  the emulsion  is broken  and  oils
 are  removed.   The tank's contents  are then  pumped   through   a  double
 basket strainer  and a filter before being recycled  to  the mill.  About
 once   every   100 turns,  the tank is dumped to oil storage and  contract
 removal.

 Plant  3ISA and B (0684F)  - Figure  VII-16

 Wastewaters  from the 72"  tandem  mill   (315A),   the  84"  tandem  mill
 (315B)  and  other   cold  mill  and  coating   line wastes discharge to
primary oil  separators   where  oils  are   removed.   Neutralized  acid
pickling wastewaters  and the effluent from the  separators are  combined
 in  a  rapid   mix   tank   prior  to  introduction  to   flocculation  and
flotation  units.    A  portion  of  the   effluent  from  these   units
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discharges to the river, and the remainder passes through a deaeration
tank on its way to further treatment.

Plant 316 (0684B) - Figure VII-17

Treatment   at   this  plant  consists  of  a  lagoon  which  receives
wastewaters from pickling, annealing, galvanizing and terne  lines  as
well  as  the 54" tandem mill.  Collected oils are burned in the blast
furnace and treated effluent is discharged to the river.

Plant 318 (0856P) - Figure VII-18

Reversing mill wastewaters are pumped to  two  10,000  gallon  holding
tanks  for oil removal.  Collected oils are hauled off-site along with
an occasional blowdown of rolling oil solution.  Wastewater  from  the
holding  tanks is pumped through a filter and a magnetic separator and
then recycled to the mill.

Plant 321 A^. Ej_ and C  (0684D) z Figure VII-19

Wastewaters from the 28" 4 high reversing mill (321 A), the 34" 4  high
reversing  mill  (321B)  and  the  27" sendzimir mill (321C) each pass
through a recirculation tank -  filter  combination.   Most  of  these
wastewaters  are  recycled  to the respective mills.  A small blowdown
and leakage collects in an oil house sump, where the skimmed oils  are
removed  for  refining  and  the  soluble oils are disposed of through
contract hauling.

Combination Mills

Seven combination operations were sampled during this study.  The  raw
and effluent data for the original guidelines survey are summarized in
Table VI1-4.  Data from the toxic pollutant surveys are shown in Table
VII-5.

Plant DP-2  (0584E-01) Figure VII-20

Oil  skimming, chemical treatment, and final settling in a lagoon, are
provided prior to discharge.

Plant 311 and YY-2 (0432D) - Figure VII-21

Plant 311 is a revisit  of-.YY-2..-  Primary  settling,  oil  skimming,
chemical treatment, and final settling in a flocculating clarifier are
provided.    Other   wastewaters  are  combined  with  the  cold  mill
wastewaters at this central treatment system.

Plant 312A and B (0948C -04, 02) - Figure VII-22

The No. 2 tin  mill  (312A)  discharges  its  wastewaters  to  an  oil
separator  and  then  to  a central treatment facility.  This facility
consists of primary  mixers,  scalping  tanks,  secondary  mixers  and
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 clarifiers.    Sludge  from  the  scalping  tanks  and  clarifiers  is
 concentrated in a thickener and dewatered by a centrifuge.

 Wastes from the No. 3 sheet mill (312B) are treated in an oil  skimmer
 tank and discharged to the hot strip mill, wastewater treatment plant.

 Plant 313A (0584A-02) - Figure VII-23

 Roll  solutions  from  the #4 tandem mill discharge to a skim tank and
 combine with other wastewaters in a concentrate tank.   The concentrate
 tank discharges to central treatment for further processing.

 Plant 319 (Q856F-01)  - Figure VII-24

 The wastewater from this mill  is  treated  in  a  central  wastewater
 treatment  system  which  consists of neutralization,  flocculation and
 clarification.

 Plant 320A (0860B-03) - Figure VII-25

 Wastewaters from  the  combination  mill  are  treated  in  a  central
 wastewater  treatment  plant  which  consists  of  emulsion  breaking,
 surface skimming,  flocculation with lime and  polymer,   neutralization
 and clarification.

 Direct Application Mills

 Five  direct  application operations were visited.   Two operations  were
 sampled twice,  once during the  original  guidelines   study  and   once
 during  the  toxic pollutant  study.    Only  the data from the second
 visits are used to characterize these  mills.    The raw  and  treated
 effluent data for  these operations  are  presented in Table  VII-6.

 Plant 105  and W-2  (0584F-04)  - Figure  VII-10

 Refer to the  discussion presented  for recirculation mills

 Plant 106(01126-01. 03-06)  -  Figure Vll-26

 At   this  plant,  wastewaters   from  six  direct  application  mills are
 collected  in  a  sump where  floating  oils  are  collected;   filtered  with
 twelve   upflow  sand  filters;   combined with  neutralized  pickling and
 galvanizing wastes; and settled in  a  thickener.   The overflow from the
 thickener  is  then discharged.

 Plant  304B and  305A (0176-02) - Figure VII-12

Refer to the discussion presented for recirculation mills.

Plant 313B  (0584A-02) - Figure  VII-27

The two single stand skin pass  mills discharge to a  mill  sump  which
receives  wastewaters  from  the  rewinder, slitter and shear shops as
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well.  The combined  waStewater  is  then  pumped  to  the  cold  mill
wastewater  treatment  plant  which  consists  of  emulsion  breaking,
flocculation with lime and  polymer,  neutralization  with  lime,  and
surface skimming,

Summary of Lonq-Term Monitoring Data

Long-term effluent data were obtained for two cold rolling operations.
These  data are summarized in Table VII-7.  Data for the wastewater at
Plant 0684F were obtained before it entered  final  clarification  and
neutralization.  Data for Plant 0920G were provided for the wastewater
after  chemical  treatment and sedimentation.  These treatment systems
and sampling locations are illustrated in Figures VII-16 and    VII-28
for Plant 0684F and 0920G, respectively.

In  addition  to  the  long  term  data,  Plant  0684F was intensively
monitored  for  20  days.   The  sampling  program  was  designed   to
characterize  the  wastewater  treatment  system with respect to toxic
pollutant removals.   The  wastewater  treatment  system  consists  of
emulsion breaking with pickling rinse waters followed by dissolved air
flotation.   The  raw  data  and  summary from this sampling survey is
presented in Table VI1-8 along with a summary of long  term  data  for
total  suspended  solids,  and  oil  and  grease.  The data shows that
dissolved  air  flotation  is  capable  of  removing   toxic   organic
pollutants  to low levels and over the long term'performs consistently
well with respect  to  total  suspended  solids  and  oil  and  grease
removal.   During  the  sampling  period,  the  rolling solutions were
changed and the oil application  system  was  cleaned.   Although  the
waste  oil  was  discharged  to  a  holding  tank  and  bled  into the
wastewater treatment system, a noticeable  degradation  in  wastewater
quality  was  observed  during  this period.  The discharge of oil and
grease, and toxic organic pollutants  increased.   Tetrachloroethylene
was  also  detected  during  this  period.   The  data  indicate  that
indiscriminate dumping of  waste  oil  and  cleaning  solutions  could
result  in  the  discharge of high  levels of toxic organic pollutants.
It should be noted that the long term data for total suspended  solids
show  that  the  observed maximum concentration  {66 mg/1) exceeded the
concentration  basis   (60  mg/1)  for  the  daily   maximum   effluent
limitation.   This,  however,  is   a  single  exceedence  out  of  104
observations.  Exceedence at this frequency  (1  out  of   100)  is  not
unexpected.

Effect of Makeup Water Quality

Where the mass loading of a limited pollutant in the makeup water to  a
process   is  small   in  relation  to  the  raw  waste   loading of that
pollutant, the impact of makeup water quality on wastewater   treatment
system  performance   is  not  significant,   and,   in  many  cases, 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.
                                    75

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The  data  presented  in Tables  VII-9  through  VII-11   for   recirculation,
combination   and  direct  application mills,  respectively,  indicate  that
the  conventional  and  toxic  organic   pollutants   in   the   intake  water
supply  are  insignificant when  compared with  the concentrations  of the
same pollutants in  the raw  wastewaters.    For   certain   toxic   metals
(chromium,   lead  and nickel   for  combination mills, and chromium and
zinc for  direct application mills),  the levels in   the   make-up  water
appear  to be significant when  compared to  raw waste levels.  However,
the  raw waste levels  of  the above mentioned raw  metals at the  sampled
plants  are  hear  both background and treatability levels.   In the  case
of nickel for the combination mills, an abnormally  high   intake  value
tends  to  skew   the   results.   The toxic  metals limitations for  cold
rolling operations  are based upon   the  same  effluent   concentrations
used  to  develop  the  acid   pickling  limitations,  so  that  these
wastewaters may be  co-treated.  Therefore,  the   Agency   believes   that
the  effect  of   make-up  water  quality  for  the  combined wastewater
streams is not significant.  In the  rare case of treatment  for  stand
alone  cold  rolling   operations  (the Agency is not aware of any  such
plants), treatment  for toxic metals  would not be necessary, if the  raw
waste levels were below the BPT or BAT limitations,  as is the case  at
some  mills.    Thus,   the  Agency  has  determined   that  the effluent
limitations and standards should be  applied on a gross  basis,  except
to the extent provided by 40 CFR 122.63(h).
                                    76

-------
                       TABLE VII-1

         OPERATING MODES,  CONTROL AND TREATMENT
            TECHNOLOGIES AND DISPOSAL METHODS

                         Symbols
Operating Modes

1.   OT

2.   Rt,s,n
                            Once-Through

                            Recycle,  where t
                                           3
                                           a
type waste
stream recycled
Z recycled
                                   t:  U » Untreated
                                       T » Treated
     PProcess wastewater & or raw waste rlow
     F       Flume Only         Z of raw waste flow
     S       Flume and Sprays   Z of raw waste flow
     FC      Final Cooler       Z of FC flow
     BC      Barometric Cond.   Z of BC flow
     VS      Abs. Vent Scrub.   Z of VS flow
     FH      Fume Hood Scrub.   Z of FH flow

3.   REC,n          Reuse, where t « type
                                 n « Z of raw waste flow

                                 t:  U » before treatment
                                     T a after treatment
        4.   BDu


B.      Control Technology

        10.  DI

        11.  SR

        12.  CC

        13.  DR

C.      Disposal Methods

        20.  H

        21.  DW
                    Slowdown, where n =• discharge as Z of
                                        raw waste flow
                    Deionization

                    Spray/Fog Rinse

                    Countercurrent Rinse

                    Drag-out Recovery



                    Haul Off-Site

                    Deep Well Injection

                               77

-------
TABLE VXI-1
OPERATING MODES, CONTROL AND TREATMENT
TECHHOLOGIES AND DISPOSAL METHODS
PAGE 2
        Disposal Methods (coat.)

        22.  Qt,d           Coke Quenching, where t « type
                                                  d * discharge as Z
                                                      of makeup

                                                  t:  DW » Dirty Water
                                                      CW * Glean Water

        23.  EME            Evaporation, Multiple Effect

        24.  ES             Evaporation on Slag

        25.  E7C            Evaporation, Vapor Compression Distillation

        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  a Wastes
                                                      0  » Other, footnote


                                      78

-------
TAB12 711-1
OPEEATltfG MODES, CONTBOL AND TBEATMEHT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 3                     	;	
D.
Treatment Technology (coat.)
        43.  FLt
        44.  CY

       44a.  DT

        45.  CL

        46.  T

        47.  TB

        48.  SLn
        49.

        50.
     BL

     VF
        51.  Ft,m,h
                    Plocculation, where t » 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
             D » Deep Bed
             F - Flat Bed
         52.  CLt
         53.  CO
                       S =• Sand
                       0 « Other,
                           footnote
                 G » Gravity
                  P * Pressure
                    Chlorination, where t * type

                                        ts  A » Alkaline
                                            B a Breakpoint

                    Chemical Oxidation (other than CLA or CLB)
                                       79

-------
TABLE VII-1
OPERATING MODES, CONTBDL 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.  AH

63.  ACt




64.  IX

65.  RO

66.  D
Biological Oxidation, where  t »  type
                                                        t:  An * Activated Sludge
                                                            a  » No. of Stages
                                                            T  - Trickling Filter
                                                            B  - Biodise
                                                            0  » Other, footnote
Chemical Reduction  (e.g., chromium)

Dephenolizer

Ammonia Stripping, where t =» type

                         t:  F » Free
                             L m Lime
                             C « Caustic
Ammonia Product, where t =» type
                                                   t:   S
                                                       N
                                                       A
                                                       P
                                                       H
                               Sulfate
                               Nitric Acid
                               Anhydrous
                               Phosphate
                               Hydroxide
                               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
                                                       G
                                Powdered
                                Granular
                           Ion Exchange

                           Reverse Osmosis

                           Distillation

                                     80

-------
TABLE VII-1
OPEHATING MODES, CONTBOL AND TBEATMEUT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 5                   	.	
D.      Treatment Technology (eont.)

        67.  AA1            Activated Alumina
        68.  OZ

        69.  UV

        70.  CBTt,n
        71.  On

        72.  SB

        73.  AE

        74.  PS
Ozonation

Ultraviolet Radiation

Central Treatment, where t =
                         n '


                         t:
type
process flow as
Z 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

-------








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                                        TABLE VII-4

                       SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
                                 ORIGINAL GUIDELINES SURVEY
                       	COLD ROLLING - COMBINATION
Raw Wastewater

Plant Code
Reference Code
Sample Point
Flow, gal/ton
Total Suspended Solids
Oil & Grease
Dissolved Iron
pH

Treated Effluents

Plant Code
Reference Code
Sample Points
Flow, gal/ton
C&TT
Total Suspended Solids
Oil & Grease
Dissolved Iron
PH
                           mg/1
         DD-2
        584E-01
           1
         512
          lbs/1000 Ibs
987       2.11
1,399     2.99
7.8       0.017
       5.7
         DD-2
       584E-01
          2
         512
   Chem. Treat. &
   	Lagoons	
          lbs/1000 Ibs
mg/1

6
4
0.04
          0.013
          0.085
          0.000085
       7.7
NA:  Not analyzed
                                   93

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-------
                                        TABLE VII-7

                                 SUMMARY OF LONG-TERM DATA
                                        COLD ROLLING  	
Plant Code:
C&TT:

Pollutants

     Total Suspended
     Solids
     Oil & Grease
     PH
     Phenols
118  Cadmium
119  Chromium
120  Copper
121  Cyanide
122  Lead
124  Nickel
128  Zinc
80
          0684F-03
            EB,GF,SS
                                             (1)
                                  0920G-(01&02)
                                 EB,GF,CL,SS,CNT
No. of                   Stand.    No. of                Stand.
Samples   Max   Mean    Deviation  Samples   Max  Mean  Deviation
1,363  113
188
79
1,206
7
11
11
11
7
11
11
78
147
13.6
1.4
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0.13
0.13
0.063
1.16
0.08
80.0
17.7
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0.4
0.0069
0.044
0.071
0.029
0.059
0.054
4.6
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0.9
0.5
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0.037
0.037
0.020
0.039
0.022
10.6
195

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81.0  25.0  13.3

66.0  19.2  9.6
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(1) The wastestream receives additional treatment prior to discharge to a receiving stream.
                                             98

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PROCESS: Cold Rolling-Recirculation and
Direct Application
PLANT: 304A a B and 305A 8 B
304A a B
PRODUCTION! Recirculation Mill-3a4metrks tons/turn
IAD lnn>/«..rnl

Direct Application Mill-12.2 metric tons/turn
(13.4 tons/turn)
305A 8 B
Direct Application Mill- 21.8 metric tons/turn
23.6 tons/turn
Recirculation Mill - 47.5 metric tons/turn
52.4 tons/turn

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                       COLD  FORMING SUBCATEGORY

                              COLD ROLLING

                              SECTION VIII

             COST, ENERGY, AND NON-WATER QUALITY  IMPACTS
Introduction

This   section   presents   the   incremental  costs   incurred   in  the
application of the different  levels of pollution control technology to
the cold rolling subdivision  based  upon  the  application  of  model
treatment  systems.   Also  included are energy requirements/ the non-
water quality impacts,  and   descriptions  of  treatment  technologies
associated  with the application  of the BPT, BAT, NSPS, PSES, and PSNS
levels of treatment.  In addition, solid waste  generation  rates  and
the consumptive use of water  are  discussed.

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

The  effluent  treatment  costs   supplied by the industry for the cold
rolling subdivision during sampling visits  and  in   response  to  the
D-DCPs   are   presented   in  Tables   VIII-1   through  VII1-3  for
recirculation, combination and direct application mills, respectively.
These costs have been updated to  July 1, 1978 dollars.   Many  of  the
industry responses included total costs for central treatment systems.
Where  possible,  these  costs  were  analyzed  and   allocated to cold
rolling wastewaters.

Because of the extensive use  of central  treatment  for  cold  rolling
wastewaters, the Agency could not directly verify its model-based cost
estimates for separate treatment  of cold rolling wastes with cost data
reported  by the industry for central treatment systems.  However, the
Agency did compare its model-based treatment costs with industry costs
for several central  treatment  systems  by  summing  the  model-based
treatment  costs for each subcategory included in the existing central
treatment  systems.   The  results  of  this  comparison,  which   are
presented   in   Volume  I,   demonstrate  that  the  Agency's  costing
methodology accurately reflects industry costs for  central  treatment
facilities  in  general,  and for those systems including cold rolling
wastewaters in particular.  In fact, as shown by the data presented in
Volume I, the Agency's  cost  estimates  for  separate  treatment  for
finishing  operation wastewaters  are likely to be higher than industry
costs for central treatment.
                                   131

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Control and Treatment Technologies (C&TT)

A review of the treatment components  included  in  the  BPT  and  BAT
alternative  treatment  systems  is  presented  in  Table VII1-4.  The
following items are described for each treatment method  in  the  C&TT
table.

1 .   Description of treatment components
2.   Implementation time
3.   Land requirements

Cost, Energy, and Non-water Quality Impacts

General Discussion

This  section  addresses the additional costs that will be required to
install and operate the BPT, BAT,  NSPS,  PSES  and  PSNS  alternative
treatment  systems.   The alternative treatment systems for each level
of treatment are illustrated  in  Figure  VIII-1.   In  addition,  air
pollution,  water  consumption,  energy  requirements, and solid waste
disposal  impacts  associated  with  each  level  of   treatment   are
discussed.  Costs, solid waste generation and energy requirements were
estimated  from alternative, treatment systems developed .in Sections" IX
through XIII of this report and are presented in the tables  and  text
of this section.

Estimated Costs for the
Installation of Pollution Control Technologies

A.   Costs Required to Achieve the BPT Limitations

     On the basis of water pollution control facilities in-place as of
     July 1, 1981, the Agency estimates that the industry will need to
     spend $5.1 million (capital cost) to  bring  the  discharge  from
     cold rolling operations into compliance with the BPT limitations.
     The  total  estimated  capital  cost  for compliance with the BPT
     limitations is $27.7 million.  In addition, the Agency  estimates
     the  incremental annual cost to be $0.84 million, while the total
     annual costs are $3.6 million.  This total annual  cost  estimate
     takes  into  account  a $0.52 million credit for the recovery and
     sale of the waste oil solutions.

     To estimate the above costs, the Agency developed model plants  ,
     based  upon  average  plant  sizes,  at the model flow rates (see
     Section IX for development of these flow rates).   Plant-by-plant
     capital and annual cost estimates were then made by factoring the
     model  plant  costs by the ratio of the actual production at each
     plant to the model plant size using the "six-tenth"  rule.   This
     method  yields  cost  estimates  for  the  subcategory  which are
     representative  of  the  actual  costs  to  the  industry.   Cost
     comparisons  presented  in Volume I verified the accuracy of this
     costing methodology.  The in-place and required costs  are  based
     upon   information   available   to  the  Agency,  including  DCP
                                    132

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     responses.  A summary of  the  in-place  and  required  costs  is
     provided  in  Table VII1-5 for the recirculation, combination and
     direct application segments.  In addition, Tables VII1-6  through
     VI11-10  present  the  model  costs upon which these in-place and
     required costs were based.

     The cost estimates were based upon the assumption  that  separate
     wastewater  treatment  systems for cold rolling wastewaters would
     be installed at all plants.  However,  as  pointed  out  earlier,
     wastewaters  from  most  cold  rolling  operations are treated in
     central treatment systems.  Treatment in  central  systems  costs
     less   because  of  economies  of  scale  and  because  duplicate
     equipment  components  are  not  installed.   Hence,  the  Agency
     expects  that  the  actual  cost  of  compliance for cold rolling
     operations will be less than shown above.

B.   Costs Required to Install BAT Treatment Systems

     The Agency considered three BAT alternative treatment systems for
     cold rolling operations.   These  alternatives  are  outlined  in
     Section  X.  The model costs involved in applying each of the BAT
     alternative treatment systems to the BPT model  treatment  system
     are  presented  in Tables VIII-11 through VIII-15.  The estimated
     investment and annual costs  for  each  BAT  alternative  follow.
     These  subdivis-ion-wide  costs were determined in the same manner
     as the BPT costs, i.e., unit model costs were  scaled  to  actual
     plant  sizes.  Table VII1-16 provides a breakdown of the costs by
     cold rolling segment.
     Alternative

     BAT-1
     BAT-2
     BAT-3
   Costs - Millions of 1978 Dollars
     Capital                 Annual
In-Place   Required    In-Place  Required
  2.9
  2.9
  0.0
 10.1
111.1
268.3
0.2
1 .1
0.0
 1 .8
15.4
53.5
     BCT Cost Comparison
     The  BCT  limitations  for  each  segment  of  the  cold  rolling
     subdivision  are  the  same as the corresponding BPT limitations.
     Hence,  no  additional  costs  beyond  BPT  are  associated  with
     achieving the BCT limitations.
     Costs Required to Achieve NSPS

     The Agency developed four NSPS
     cold rolling operations.  The
     as  the BPT and BAT treatment
     are lower than the model flows
     stand recirculation mills, for
     as  the  BPT  and  BAT  flows.
     Tables VIII-17 through VI11-20
                alternative treatment systems  for
               NSPS treatment systems are the same
               systems.   The NSPS model flow rates
                for BPT and BAT,  except for single
                which the NSPS flows are the  same
                  The model costs are presented in
                  Only model treatment  costs  are
                                    133

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     presented  here, since projections of  capacity additions were not
     made as part of this study.  The model   costs' for   single  stand
     recirculating  mills  are   identical   to  the  BPT   and BAT costs
     presented above.

E.   Costs Required to Achieve the Pretreatment Standards

     Pretreatment standards apply to those  new  and  existing  plants
     that  discharge  to  POTW   systems.    The  Agency  developed four
     alternative  pretreatment   systems  for  new  and  existing  cold
     rolling   operations.   The model  costs  for  the  pretreatment
     alternatives for existing sources  (PSES) are identical to the BPT
     and BAT costs as presented  in  Tables   VII1-6  through  VII1-15.
     Model  costs  for  the  pretreatment alternatives for new sources
     (PSNS) are identical to NSPS costs and are  presented  in  Tables
     VII1-17  through  VII1-20.  Table VI11-21 provides a breakdown of
     these PSES costs by cold rolling segment.
     The subdivision-wide costs for each PSES alternative
     as follows:
                                system  are
     Alternative
•   Capital Costs
In-Place  Required
              Annual Costs
           In-Place  Required
     PSES 1
     PSES 2
     PSES 3
     PSES 4
  4.3
  4.3
  4.3
  4.3
  57.8
 143.8
2041.3
3948.0
0.6
0.6
0.6
0.6
  7.3
 19.4
264.0
576.4
Energy Impacts

Moderate  amounts of energy are required for the BPT, and BAT and PSES
alternative treatment  systems.   The  alternative  treatment  systems
using  activated  carbon  require more than twice the amount of energy
used at BPT; the  alternative  using  vapor  compression  distillation
requires  more  than  forty  times  the energy use at BPT.  The energy
requirements for the various levels of treatment are presented below:

A.   Energy Impacts at BPT

     The estimated energy requirement of 34.4 million  kilowatt  hours
     per  year  for  BPT  is  based.upon the installation of the model
     treatment system for  all  cold  rolling  operations  with  flows
     similar to that of the treatment model.  This estimate represents
     0.060%  of  the  57 billion kilowatt hours of electricity used by
     the steel industry in 1978.  The estimated energy  use  for  each
     segment  of  the  cold  rolling subdivision is presented in Table
     VII1-22 for BPT, BAT and PSES.   These  energy  requirements  are
     justified   when  compared  to  the  pollution  control  benefits
     associated with compliance with the BPT limitations.
                                    134

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B.   Energy Impacts at BAT
     The  additional  energy  needs  for  the  three  BAT  alternative
     treatment  systems,  along  with  the  percentage of  total energy
     consumption for each BAT alternative, are summarized  below.
         BAT
     Alternative

        1
        2
        3
     kwh per
      year

    7.05 million
   47.22 million
  807.82 million
        % of Industry
            Usage

            0.012
            0.083
            1.42
C.   Energy Impacts at NSPS and PSNS
     The Agency did not estimate the total impacts for NSPS and  PSNS,
     since  an  estimate  of  the  number  of  new source cold rolling
     operations was not made as part of this study.  The annual energy
     requirements associated with the model NSPS and PSNS alternatives
     are as follows;

                       Annual Energy Requirements
                        Thousands of kwh per year	••  •
     NSPS & PSNS
     Alternative

          1
          2
          3
          4
Recirculation
Single  Multi
  120
  128
  160
  432
128
136
228
688
       Combination
   936
 1,1 24
 1,436
19,620
              Direct Application
              Single       Multi
  216
  228
  352
1,400
   996
 1 ,212
 1,584
22,796
D.   Energy Impacts at PSES
     The energy usage associated with the PSES  alternative  treatment
     systems  are  presented below, along with the percentage of total
     electrical energy used by the industry in 1978.  The energy usage
     for PSES  Alternatives  2,  3,  and  4  are  incremental  to  the
     requirements for PSES 1.
          PSES
        Alternative

          1
          2
          3
          4
    Million
     kwh/yr

    1 .02
    1.10
    1.67
    7.66
            % of Industry
               Usage

               0.002
               0.002
               0.003
               0.013
                                    135

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Non-water Quality Impacts

In  this  analysis, the Agency investigated the impact of implementing
the alternative  treatment  systems  on  air  pollution,  solid  waste
disposal,  and  water  consumption.   A discussion of these impacts is
presented below.
A.   Air Pollution

     The water pollution control technologies evaluated in this
     are not significant sources of air pollution.

B.   Solid Waste Disposal
                                         study
     Treatment  at  both  the  BPT  and  BAT  levels  results  in  the
     generation  of  large  amounts  of  solid  waste  in  the form of
     sludges.  These sludges result  from  the  removal  of  suspended
     solids  and  oil  and  grease.   The  following  table presents a
     summary of the quantity of solid waste produced using the BPT and
     BAT alternative treatment systems.

                   Solid Waste Generation
                For Cold Rolling Operations
     Treatment
       Level

     BPT
     BAT 1 thru 3
     PSES 1
     PSES 2 thru 4
 Dewatered
  Solids
(tons/year)

  129,280
  negligible
    2,320
  negligible
   Oil and
   Grease
 (gal/year)

6,073,830
 negligible
  428,130
 negligible
     As shown above, the largest quantity of solid wastes is generated
     at the BPT  level,  while  the  BAT  treatment  systems  generate
     negligible  additonal  amounts.   In  addition,  solid  waste  is
     generated at the NSPS and PSNS levels, as  noted  below  for  the
     model plants.  The wastes generated at NSPS and PSNS Alternatives
     2, 3, and 4 are negligible.
                                   136

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                         Solid Waste Generation
                      For Cold Rolling Operations
Subdivision

Recirculation
  Single Stand
  Multi Stand

Combination
   Dewatered
Solids (tons/yr)
       40
      180
Direct Application
  Single Stand
  Multi Stand
     4180
      340
     1400
Oil and Grease
   (gal/yr)
    5,710
   55,700

   71,400
    5,710
   92,900
The NSPS and Pretreatment models are similar to BPT/BAT treatment
systems.   Table VII1-23 lists the quantities of dewatered solids
and oil and grease for each of the cold rolling segments.

Some of the solid wastes result from  the  use  of  lime  in  the
treatment  systems.   Lime  is  used to raise pH levels after the
emulsion breaking step and can produce up to 8-10 tons of  sludge
per  day  in  the form of untreated calcium hydroxide, along with
precipitated calcium carbonates.  If  acid  pickling  wastewaters
are  used  to  break the emulsions, the sludges will, also contain
metal hydroxides (and calcium  sulfate  where  sulfuric  acid  is
used).   Disposal  of  these sludges adds to the treatment costs.
Proper disposal of these sludges will prevent runoff and leachate
from entering streams.

Additional  solids  may  be  generated  depending  upon  the  BAT
alternative.   If  the filter system proposed in Alternative 1 is
installed, additional solid wastes  will  be  produced  when  the
filters are backwashed.  The volume of sludge generated at BAT is
small compared to the amount generated at the BPT level.

A  large  portion  of  the  waste  oil  produced  at cold rolling
operations is used, along with purchased fuel, to  fire  boilers,
or  sold  to outside contractors for reclamation and reuse.  Some
contractors have their processing facilities located at the steel
plant site and operate them in conjunction  with  the  wastewater
treatment  facilities.   As  a  result of these practices, only a
small portion of the waste oils produced  are  actually  disposed
of.

The   Agency   believes  that  the  effluent  reduction  benefits
associated with compliance with  the  limitations  and  standards
justify  the  adverse environmental impacts associated with solid
waste disposal.
                              137

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 C.    Water  Consumption

      No  significant  water  consumption  is  expected  to  occur   at   cold
      rolling   operations   as   a   result   of   the  installation of the
      alternative  treatment systems.  Recycle  systems  are  installed  at
      recirculation mills,  but  these  are usually  closed  systems with no
      inherent  water  consumption.   There are no other  opportunities for
      significant  water consumption in  cold rolling operations.

 Summary  of  Impacts

 The   Agency concludes that   the pollution control benefits  described
 below for  the   cold   rolling subdivision   outweigh    the    adverse
 environmental   impacts   associated  with   energy   consumption,   air
 pollution,  solid  waste disposal,  and water consumption.

                                     Direct Discharges
                               Effluent Loadings (Tons/Year)
                               Raw Waste           BPT/BCT
Flow, MGD
Suspended Solids
Oil and Grease
Toxic Metals
Toxic Organics
    29.6
22,502
86,492
    94
   337
 28.1
653
286
 21
  4.1
Flow, MGD
Suspended Solids
Oil and Grease
Toxic Metals
Toxic Organics
                                   Indirect Discharges
                               Effluent Loadings  (Tons/Year)
                               Raw Waste          PSES -1
    0.2
  275
3,986
    5.4
    2.1
0.2
4.4
1 .9
0.3
0.2
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.
                                   138

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-------
                               TABLE VIII-2

                         EFFLUENT TREATMENT COSTS
                        COLD ROLLING - COMBINATION
Plant Code
Reference Code

Initial Investment Cost
Annual Cost.
  CapitalU;
  Operation and Maintenance
  Energy & Power

TOTAL

$/Ton
  DD-2*
 584E-01

3,913,654

  351,837
  250,105
  191,552

  793,494

  0.52
 YY-2*
432D-01

166,907

  15,005
  7,898
  2,538

 25,441

 0.036
(1) Capital is based on the formula:  Initial Investment X 0.0899.

 *  Portion attributed to this subcategory only.
                                    140

-------
                               TABLE  VIII-3

                         EFFLUENT TREATMENT  COSTS
                    COLD ROLLING - DIRECT APPLICATION
Plant Code
Reference No.

Initial Investment Cost
Annual Costs
  Cost of Capital
  Depreciation
  Operation and Maintenance
  Energy and Power

TOTAL
$/Ton
  105*
 584F-04

2,804,245

Annual costs
not available
since company
accounting pro-
cedures do not
segregate production
and pollution
operating costs.

Unk
* Portion attributed to this subcategory only.
                                    141

-------
                                   TABLE VIII-4

                        CONTROL AND TREATMENT TECHNOLOGIES
                                   COLD ROLLING
Treatment  and/or
Control Methods Employed

A.  Oil separator - used  to
treat wastewaters from  the cold
rolling mill  to remove  any
floating oils that may  be present.
B.  Equalization tank - to
protect treatment system from
shock or high toxic loads.

C.  Alum addition — used in
conjunction with Step D to
break emulsion and coagulate
fine particles.

D.  Acid addition - used to lower
the pH to 4-5, in conjunction with
Step C, to break emulsion.

E.  Lime neutralization - to
raise pH to 6-9 in a mixing
tank, following Step D.

F.  Polymer addition - add
polymer or polyelectrolyte
to promote settling.

G.  Air flotation - effluent
from Step F treated with air
flotation, for solids and oil
separation.
 Implemen-
  tation
  Time

 Included
 in Step
 B Imple-
 mentation
 time.

 9 months
6 months
6 months
6 months
6 months
12
months
   Land
Requirements

Contained
within an
equalization
tank, Step B.
50'x50'
No additional
space required.
No additional
space required.


25'x25'
No additional
space required.
25'x25'
(for all
rolling
operations).
                                       142

-------
TABLE VIII-4
CONTROL AND TREATMENT TECHNOLOGIES
COLD ROLLING
PAGE 2                 	•__
Treatment and/or
Control Methods Employed

H.  Vacuum filtration dewaters
solids captured in step G.
I.  Filtration - effluent from
Step H is treated by passage
through a mixed-media filter
unit (last step in BAT-1).
J.  Activated carbon columns -
effluent from S tep I is passed
through activated carbon columns
(last step in BAT-2).

K.  Evaporation - effluent from
Step H is passed through a
vapor compression evaporation
system to achieve zero discharge-

L.  Recycle - distillate quality
water from Step K is recycled to
the cold rolling mill for
reuse (last Step in BAT-3).
Implemen-
 tation
  Time

15-18
months
15-18
months
                                      18
                                      months
                                       18
                                      months
                                       18
                                       months
   Land    •.
Requirements

10'xlO'
(batch)
20'x20'
(continuous)

25'x25'
(recirculation)
40'x40'
(combination)
50'x50'
(direct
application)

SO'xSO1
                      60'x60'
                       25'x25V
                                        143

-------
                               TABLE VIII-5

                             BPT COST SUMMARY
                               COLD ROLLING
                               Capital
Annual
Subdivision
Recirculation
Single Stand
Multi Stand
In-Place

559.3
4,217.7
Required
539.0
1,609.4
, In-Place

77.9
121.7
Required

77.4
276.7
Combination              7,573.2          0.0      1,291.8

Direct Application
  Single Stand           3,684.6        331.9        528.5
  Multi Stand            6,587.3      2,606.4        769.6

Cold Rolling Total      22,622.1      5,086.7      2,789.5
           0.0
         49.4
        442.0

        845.5
All costs are in 1000's of 7/1/78 dollars.
                                     144

-------
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-------
                       COLD FORMING SUBCATEGORY

                             COLD ROLLING

                              SECTION ix

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

The   Agency  has  promulgated  Best  Practicable  Control  Technology
Currently Available (BPT) limitations which are based  upon  the  same
model  treatment  system  used  as  the  basis for the BPT limitations
originally promulgated in March, 1976.  However, dissolved iron is  no
longer  being limited, and limitations have been established for toxic
metal and  toxic  organic  pollutants.   A  review  of  the  treatment
processes  and  effluent  limitations for the cold rolling subdivision
follows.

Identification of. BPT '

The BPT model treatment system is identical to the model used  in  the
previous   regulation.    This  system  includes  oil  separation  and
equalization; chemical addition (alum  and  acid)  to  break  any  oil
emulsions; flocculation with polymer and neutralization; and dissolved
air flotation.  This system is outlined in Figure IX-1.

The  treatment  configuration  described above is installed at several
cold rolling operations (i.e., 0060, 0584A, 0860B, and at  many  other
plants).  The system was developed based upon general practices within
the  subcategory  and  is  an  efficient  way  to  treat  cold rolling
wastewaters.  The BPT effluent limitations for the three types of cold
rolling operations  are  presented  in  Table  IX-1,  along  with  the
respective model effluent flows and concentrations.

Rationale for the Selection of BPT

Treatment Technology

As  noted  in  Sections  III  and  VII,  each  of the treatment system
components incorporated in the BPT model treatment system is in use at
a number of cold rolling operations.  The efficiency of the BPT  model
treatment   system   has   been   demonstrated   through  its  various
applications in the industry.

The  model  treatment  system  has   demonstrated   the   ability   to
significantly  reduce  total  suspended  solids  and  oil  and grease.
Moreover, the available data indicate that  the  BPT  model  treatment
system  is  also capable of effectively removing toxic metal and toxic
organic pollutants, along with the conventional pollutants.
                                    169

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 The Agency believes that other alternative means are also available to
 reduce or eliminate the discharge of toxic organic pollutants.   In the
 preamble to the proposed regulation (46 FR 1'858),  the Agency solicited
 comments regarding whether "clean" rolling  solutions  could  be  used
 instead  of  those containing toxic organic compounds.   No substantive
 comments were received.  The Agency  did,   however,   review  available
 information and believes that some facilities may  be able to change to
 "clean"  rolling  solutions.   The  Agency  also  concluded  that cold
 rolling operating requirements are so  complex,  and  highly  variable
 given  product  quality  considerations,   that  it  is  not possible to
 establish limitations based  upon  the  expectation   that  the  entire
 industry  can  use  "clean"  rolling  solutions.  Hence, the effluent
 limitations have not been established on this basis,  although  it  may
 be   an  available  option  for some cold rolling operations.   Cleaning
 solutions that do not contain chlorinated organic  compounds  are  also
 available.    These  solutions  can  be  used  at cold rolling mills to
 minimize  or  eliminate  the  discharge  of  toxic  organic  compounds
 originating  from  this  source.   Additionally,  the  discharge of toxic
 organic pollutants can be reduced through  better handling and disposal
 of  waste oils and  cleaning  solutions  which  contain   toxic  organic
 compounds.    These  wastes  should  be  collected  and   bled  into the
 wastewater treatment system at a  rate such that  the  influent pollutant
 loads remain within design constraints.   This will prevent the   system
 from  being overloaded,  and thereby,  ensure effective operation of the
 wastewater treatment system.   This in turn ensures  efficient  removal
 of  toxic organic pollutants.

 Model  Treatment' System Flows

 The  Agency  developed  the model  flows  recognizing  the  three types of
 cold   rolling    mills   (recirculation,    combination,    and   direct
 application).    The  model   flows  are different  from  the flows  used to
 establish  the orginal  BPT limitations and  were developed from  a  much
 larger   data base  than originally  used.   Furthermore,  the Agency has
 established separate subsegments  for  single and  multiple  stand  mills
 for the recirculation  and direct  application segments.

 In  developing the model  flow rates,  the Agency identified those plants
 which   it   believed  are representative of  well  operated plants within
 each  segment.    The  plants   that    were    not    considered    to   be
 representative   of   well   operated  plants  are operated  at much higher
 discharge flow  rates.    The  Agency   evaluated  these  high  flows   in
 conjunction   with   the  thickness  reduction and  flow  data presented in
 Table IX-7,  and  concluded that  these  flows  are unjustifiably  high   and
 not  required  for  product  quality considerations.  Thus,  these plants
 (identified  by   asterisks  on   Tables   IX-2   through  IX-6)   were   not
 included   in  the   development  of the model  flows.  The flow data  for
 those well operated plants  were used  to determine  the average  of   the
 best  flows.    Table  IX-2   lists  the discharge  flows for  single  stand
 recirculation mills.    Table   IX-3   lists   the  discharge flows   for
multiple stand recirculation mills.   The average of the  best  flows  for
single  stand  mills   is  3.7 gal/ton; while  the  same flow  for multiple
stand mills  is  9.9  gal/ton.  This analysis  demonstrates  the difference
                                     170

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in flows for these two operations and justifies the  establishment  of
separate subsegments for these operations.  Similar data are presented
in Tables IX-4 through IX-6 for combination mills, single stand direct
application   mills  and  multiple  stand  direct  application  mills,
respectively.  The average of the best flows and the model  flows  are
listed on these tables and are summarized by subsegment in Table IX-1 .
Again the model flows for single stand (90 gal/ton) and multiple stand
(400  gal/ton) direct application mills,  justify establishing separate
subsegments for these two operations.  The model flow for  combination
mills is 300 gal/ton.

The  Agency considered whether or not the thickness reduction achieved
at the  different  types  of  cold  rolling  mills  would  affect  the
achieyability  of  the  model treatment system flow rates.  The Agency
did so because it thought that this factor might possibly  affect  the
achievability of the model treatment system flow rates.  The amount of
heat  generated  in the process is related to thickness reduction, and
the amount of applied rolling  solution  is  determined,  to  a  large
extent,  by  the  need  to  cool  the work rolls and the product being
rolled.  However, as shown by the data presented in  Table  IX-7,  the
Agency  found  that the model treatment system flow rates are achieved
at mills producing a wide range of thickness reductions.   Based  upon
available  information,  the  Agency  believes  that  product  quality
considerations do not restrict the ability of the industry to  achieve
these  flows,  and  that  the  limitations and standards should not be
modified based upon the thickness reduction of the product rolled.
One company submitted information on
model  flows  may  have  on  product
preceeding  paragraph,  the  Agency
believes  that  the  model flows will
quality nor prevent the production of
The  Agency  believes  that the model
that  all  cold  rolling  operations
applicable BPT limitations.

Wastewater Quality
the possible adverse effects  the
 quality.   As  discussed  in the
evaluated  the  model  flows  and
 neither adversely affect product
 certain  cold  rolled  products.
 flows are well demonstrated, and
 are  able  to  comply  with  the
The  effluent  concentrations  used  as the basis to establish the BPT
limitations are presented in Table IX-1 along  with  the  limitations.
These  concentrations  were  developed from sampling data collected at
Plant 0684F.  The analysis of the data is presented in Appendix  A  of
Volume  I.  Table VII-8 presents a summary of the data acquired during
the sampling survey.   As  shown  in  the  table,  two  toxic  organic
pollutants  (naphthalene and tetrachloroethylene) and four toxic metal
pollutants  (chromium, lead, nickel and zinc) have  been  selected  for
limitations  at the BPT levels, in addition to total suspended solids,
oil and grease and pH.  The rationale for the selection of these toxic
pollutants and respective concentrations are discussed below.
                                    171

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Conventional  Pollutants  and Dissolved  Iron

The  BPT   limitations  originally  promulgated   in   1976,  established
effluent   limitations  for  total  suspended solids,  oil and grease, pH
and dissolved iron.  The Agency  has promulgated  BPT  limitations  for
all of those  pollutants, except  dissolved iron.  The concentration for
the oil and grease  limitations,  and the pH limitations are the same as
previously promulgated.  The  concentration for  total  suspended solids
has been relaxed  slightly  from  25   mg/1  to   30   mg/1,  which  will
facilitate   co-treatment  of  compatible  steel  finishing  operation
wastewaters.   Limitations for  these three conventional pollutants will
ensure that the treatment system will  be  operated  efficiently  with
respect* to these pollutants.  However, limitations  for oil and grease
are not adequate for ensuring  effective control  of   the  discharge  of
toxic organic pollutants.

Limitations   for  dissolved  iron  have not been retained.  The Agency
believes that the limitations  for  toxic metals (discussed below)  will
adequately control  the discharge of metal pollutants contained in cold
rolling  wastewaters.    This   will  also  facilitate co-treatment with
other compatible wastewaters,  since dissolved iron is  not  limited  in
any of the other subcategories.

Toxic Metal Pollutants

The  Agency   detected  eight toxic metal pollutants  in the wastewaters
from cold  rolling operations.  These toxic metals are  readily  removed
by  the  BPT   model  treatment system  described  above.  Although these
metals are generally in  a dissolved state, when  the  wastewaters  are
acidified  to break  the  oil emulsions, they will  be precipitated as
metal hydroxides during  the neutralization step  preceding  flotation.
The precipitates, along  with other suspended solids  and oily material,
are removed in the  dissolved air flotation unit.

Acid  pickling  wastewaters  are commonly used to acidify cold rolling
wastewaters to break the oil emulsions.   This  practice  reduces  the
need  to   purchase  acid,  and thereby, reduces operating costs.  Acid
pickling wastewaters contain many of the same  toxic  metals  as  cold
rolling  wastewaters,  although  at higher levels.  These toxic metals,
like those contained in  cold rolling wastewaters, are  precipitated  in
the  neutralization  step,  and  subsequently, removed  in the dissolved
air flotation  unit.  The data  available to the  Agency indicate  that
the   performance   of  dissolved air  flotation  is  similar  to  the
performance of clarifiers (used  in the model treatment system for acid
pickling wastewaters) with respect to  total suspended  solids  and  oil
and  grease.   Thus,  the removal of metal hydroxide precipitates will
also be similar.  The  toxic   metals   limited  in  the acid  pickling
subcategory   are lead and zinc,  for the sulfuric and hydrochloric acid
segments,   and  chromium and nickel, for the combination acid  segment.
For  those operations   that are co-treated with electroplating or hot
coating  wastewaters  that  have high   levels   of   toxic   metals,
pretreatment   of  the  toxic   metals   in  these  wastewaters  prior to
co-treatment with cold rolling wastewaters,  or  pretreatment  of  cold
                                    172

-------
rolling  wastewaters  prior  to  treatment  for  toxic  metals, may be
appropriate.  This is common practice in the industry.

To  facilitate  co-treatment  of  cold  rolling  and   acid   pickling
wastewaters, the Agency has selected lead and zinc as the toxic metals
to  be  limited  in the cold rolling subdivision.  Chromium and nickel
are limited in lieu of lead and zinc for operations rolling  specialty
steels.

The  Agency has evaluated the data acquired through sampling visits to
determine the appropriate  effluent  concentration.   The  methodology
used to analyze these data and the results are presented in Appendix A
of Volume I.  The data base is the same as used to establish the model
concentrations for the acid pickling subcategory.  The Agency believes
that  this  will  facilitate  the use of pickling wastewaters to treat
cold rolling  wastewaters.   This  is  consistent  with  the  Agency's
co-treatment  policy  and  will  not  result  in significantly greater
discharges of toxic metals than would occur if  the  wastewaters  were
treated  separately.   The  toxic metal concentrations used to develop
the BPT limitations are presented in Table IX-1.

Toxic Organic Pollutants

The Agency conducted  an  extensive  sampling  program  of  waste  oil
solutions,   raw   wastewaters,  and  treated  and  partially  treated
wastewaters at cold rolling mills.  Through  this  study,  the  Agency
found  that  contamination  of  cold  rolling  wastes by toxic organic
pollutants is pervasive.  Thirty toxic organic compounds were found at
varying levels.  Naphthalene was the most common pollutant found.   As
the  data presented in Section VII show, naphthalene was found in more
than 50% of the samples at levels greater than 0.1 mg/1.  The presence
of naphthalene is attributed to the oil solutions  used  at  the  cold
rolling operations sampled.                         .

Tetrachloroethylene  was  found  in  one-third  of  the samples.  This
pollutant is used as a solvent for cleaning the oil  systems  at  cold
rolling  mills.   Since cleaning is performed on a periodic basis, the
presence and levels of tetrachloroethylene  and  other  toxic  organic
pollutants  contained  in  cleaning  solvents  will  vary  over  time.
Solvents containing other chlorinated organic pollutants are also used
at cold rolling mills.

Naphthalene and tetrachloroethylene were both selected for  limitation
in  the  cold  rolling  subdivision.  Naphthalene is characteristic of
certain  oils  used,  and  tetrachloroethylene  is  characteristic  of
certain   cleaning   solutions   used   at  cold  rolling  operations.
Limitations  established  for  these  two  pollutants   will   control
indiscriminate dumping of waste oil and cleaning solutions, as well as
the normal operations of the wastewater treatment system.

The  Agency  also  conducted  an  intensive  sampling program at Plant
0684F.  This plant has the model BPT treatment  system  installed  for.
treatment  of  cold  rolling  wastewaters,  although  it also receives
                                     173

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 electroplating  wastewaters  which  cause  high  zinc  discharges   from   the
 system.    Preliminary  data  indicated   the  presence  of  toxic  organic
 pollutants.   The   primary   intent   of   the  sampling   survey  was   to
 determine  the   removal  efficiency   of dissolved   air flotation with
 respect  to toxic organic  pollutants.  The  treatment  system was  sampled
 for  20 days  for both  conventional and toxic  organic  pollutants.    The
 data indicates that  dissolved  air flotation is capable of removing
 toxic organic pollutants.   Since, most of these pollutants originate in
 the  oils used for   cold  rolling,  they are also   removed   from   the
 wastewater with the oils.

 The  oil  solution  used  at  this   mill  was changed  once during this
 intensive  sampling  period.  The waste oil  was collected in  a  storage
 tank and  bled into  the  wastewater   treatment system.  During this
 period,  contamination of  the  raw wastewater  to  the  treatment  system
 substantially   increased,   and  tetrachloroethylene  appeared  at high
 levels.  The effluent quality also noticeably degraded, although to a
 lesser   extent   than  the percentage increase in raw wastewater loads.
 The  treatment   system  was  apparently   overloaded   by the   increased
 discharge  of   waste  oils  and  cleaning  solution.    A  more  gradual
 bleeding of  these  wastes  to  the   treatment  system could  prevent
 deterioration in the  effluent quality.

 The  performance data  acquired for Plant 0684F, in conjunction with  the
 sampling  data   obtained  at  other  plants,  were used  to  establish  the
 model  concentrations  for  the  naphthalene and  tetrachloroethylene
 effluent  limitations.  A summary of  the statistical data is  presented
 in Table VII-8  and  a  discussion is presented in the  text of  Section
 VII.   After  evaluation  of  these data, the Agency  determined  that it
 would  be  appropriate  to  establish   only  maximum  limitations   for
 naphthalene  and tetrachloroethylene   as  shown  in  Table IX-1.   The
 Agency believes  that  these  effluent  limitations, in  conjunction  with
 the  limitations for oil and grease, will require efficient  operation
 of the wastewater treatment system and  better operating   practices   to
 control  the discharge of waste oils  and  cleaning solutions.   This will
 ensure that these pollutants  will be treated.


 Justification of BPT  Limitations

 Tables   IX-8  and   IX-9  present  sampled  plant  effluent  data which
 demonstrate  the  achievability  of  the   limitations.    The   Agency
 considers  these  plants  to  be  generally  well designed and properly
 operated and typical  of cold  rolling operations.  The  data  presented
 in  Table  IX-8 for  single stand recirculation mills  are for mills that
 achieve  zero  discharge  through  contract  hauling.   No  data  were
 available  for single stand recirculation mills, combination mills  and
multistand direct application  mills  that   could  be  used   in these
 tables.    The Agency  is confident that those mills that properly treat
 and discharge their wastewaters will be able to meed the  limitations.
The  achievability of the discharge flow rate for each segment  is well
demonstrated.  The effluent concentrations for the limited  pollutants
are   also   well  demonstrated  in  this  subcategory.   Since  these
                                    174

-------
wastewaters are similar in characteristics and treatability  the  same
effluent   concentrations   are   achievable.    Thus,   the  effluent
limitations established for each segment are achievable by  operations
in the respective segments.

The  Agency  believes  that  other  plants  which  do  not achieve the
limitations have inadequate treatment.  Effluent  flows  reported  for
some  cold  rolling  operations  are significantly less than the model
flow.  Yet the effluent limitations  are  not  achieved,  because  the
model  treatment  technology,  or  equivalent,  was  not installed, or
because the wastewater treatment technology in place was not  operated
properly.  The plants achieving the BPT flows are shown in Tables IX-2
through  IX-6.   Data  presented in Appendix A of Volume I and Section
VII detail the removal capabilities of  the  in  the  model  treatment
system.
                                    175

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B 0)
V i-l O
ft. at oj 
-------
                                         TABLE  IX-2

                              BPT  DISCHARGE  FLOW DETERMINATION
                        COLD ROLLING:  RECIRCULATION - SINGLE STAND
Plant Code

760 (03-07)
580C (04&05)
528 (02)
52'8 (01)
060E
528 (03)
284A (01)
580C (03)
176 (08)
256A (01&02)
256B (01)
856P (01-21)
112A (07)
684D (01-07)
020B (01,02,04,05), 020C (01-08)
760 (01)
760 (02)
248B (01)
Discharge Flow (GPT)

         0
         0
         0.02
         0.03
         0.05
         0.09
         0.1
         0.1
         0.27
         0.5
         0.8
         0.8
         3.5
         5.7
         8.8
        16.6
        26.3
        57.0*
    Basis
DCP
DCP
DCP
DCP
Sampling Visit
DCP
DCP
DCP
Sampling Visit
DCP
DCP
DCP
DCP
DCP
Sampling Visit
DCP
DCP
Sampling Visit
Average of all discharge flow values
"Average of the Best" flow values
                                 Use
 6.7 gal/ton
 3.7 gal/ton
 5.0 gal/ton
*Flow values marked with an asterisk were omitted from the "Average of the Best"
 flow calculation.
                                        177

-------
                                TABLE IX-3

                     BPT DISCHARGE FLOW DETERMINATION
                COLD ROLLING:  RECIRCOLATION -MULTI STAND
Plant Code

432C  (01)
060 (01)
060 (03)
060 (02)
584F  (02,03,05)
320 (02)
248B  (03)
684F  (03)
864B  (01)
864B  (03)
684F  (02)
384A  (03)
580C  (01)
580C  (02)
112D  (01)
060B  (03)
528B  (01)
384A  (02)
684B  (01)
864B  (02)
860B  (04)
6841  (01)
860B  (01)
948C  (03)
Discharge Flow (GPT)

          0.2
          0.4
          0.8
          Q.9
          1.1
          2.5
          4.1
          4.3
          5.1
          7.3
          8.7
         10.0
         12.5
         12.5
         17.5
         17.7
         30.2
         43.0
        144.0*
        354.0*
        687.0*
        751.0*
       1283..0*
       1369.0*
     Basis
Sampling Visit
DCP
DCP
DCP
Sampling Visit
DCP
Sampling Visit
DCP
DCP
DCP
DCP
DCP
DCP
DCP
Sampling Visit
Sampling Visit
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
Average of all discharge flow values • 199 gal/ton
"Average of the Best" flow values    =9.9 gal/ton
                                 Use « 25 gal/ton

*Flow values marked with an asterisk were omitted from the
 "Average of the Best" flow calculation.
                                 178

-------
                               TABLE IX-4

                    BPT DISCHARGE FLOW DETERMINATION
                       COLD ROLLING - COMBINATION
868A-03
868A-01
584A-02
856F-01
920C-01
432D-01
856F-02
948C-02
860B-03
868A-02
584E-01
948C-01
948C-04

Average of all flow values :
"Average, of the Best" value:
                        use:
                             Discharge Flow
                                  (GPT)

                                 25
                                 54
                                 55
                                 112
                                 114
                                 156
                                 179
                                 207
                                 325
                                 481
                                 512
                                 870
                                 1500*

                              353 GPT
                              258 GPT
                              300 GPT
Basis

DCP
DCP
Sampling Visit
Sampling Visit
DCP
San pi ing Visit
DCP
Sampling Visit
DCP
DCP
San pi ing Visit
DCP
Sampling Visit
* Flow value marked with an aserisk were omitted from the "Average of the Best"
  flow calculation.
                                      179

-------
                                TABLE IX-5

                     BPT DISCHARGE FLOW DETERMINATION
             COLD ROLLING;   DIRECT APPLICATION - SINGLE STAND
Plant Code

284A (02)
6841 (02)
176 (02)
Discharge Flow (GPT)

        0.5
        23
        233
     Basis
DCP
DCP
Sampling Visit
Average of all discharge flow values » 86 gal/ton
"Average of the Best" flow values    » 86 gal/ton
                                 Use » 90 gal/ton
                                 180

-------
                                TABLE  IX-6

                     BPT  DISCHARGE  FLOW DETERMINATION
             COLD ROLLING = DIRECT APPLICATION - MOLTI STAND
Plant Code

684C-02
860B-01
112B (01-06)
112A-02
384A-01
920A-01
856F-03
584F-03
112A-01
584A-01
112A-06
948A-02
948A-01
584C-01
920G-02
920G-01
112A-05
     Discharge
    Flow  (GPT)
     Basis
142
168
238
246
262
273
287
424
481
603
607
864
939*
1426*
1477*
1604*
3081*
DCP
DCP
DCP
DCP
DCP
DCP
DCP
Sampling Visit
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
Average of all discharge flow values =• 772 GPT
"Average of the Best" flow values    * 383 GPT
                                 Use =» 400 GPT
* Flow values marked with an asterisk were omitted  from  the
  "Average of the Best" flow calculation.
                                       181

-------
               TABLE IX-7

DISCHARGE FLOW AND THICKNESS PRODUCTION
	    COLD ROLLING

Subcategory
Recir culation: Single
Stand




Recirculation: Multi
Stand







Combination


•

Direct Application:
Multi Stand



BPT/BAT Plant
Model Flow (GPT) Reference Code
5 112AC07)
176C08)
284(01)
580CC03)
580C(04&05)
6840(01-07)
25 060(01)
060(02)
060(03)
248B(03)
384A(03)
4320(01)
584F(02,03,05)
864B(01)
864B(03)
300 432D(01)
584A(02)
868A(01)
868A(02)
920C(01)
400 384A(01)
584F(03)
684C(02)
860B(01)
920A(01)

Product(s)
Strip
Strip
Strip
Strip
Strip
Strip
Strip
Strip
Strip
Strip
Strip
Sheet
Strip
Strip
Strip
Strip
Strip
Strip
Strip
Strip
Strip
Strip
Sheet
Strip
Strip
Percent
Reduction
6
12-83
0-33
38-59
0-97
2-50
36-56
62-82
32-80
75
50-79
32-81
63-91
58-89
41-89
0-86
0-70
28-84
28-33
0-77
71-86
82-91
0-22
30
11-70
Discharge
Flow(GPT)
3.5
0.27
0.1
0.1
<0.1
5.7
0.4
0.9
0.8
4.1
10.0
0.2
1.1
5.1
7.3
156
55
54
25
114
262
424
142
168
273
                    182

-------

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-------
                       COLD  FORMING SUBCATEGORY

                             COLD ROLLING

                              SECTION X

         EFFLUENT QUALITY ATTAINABLE THROUGH  THE APPLICATION

       OF THE BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
 Introduction

 This  section  identifies  three BAT alternative  treatment  systems and
 the  resulting  effluent  levels  considered  for the  cold    rolling
 subdivision.    In  addition,  the  rationale  for  the  selection  of
 treatment  technologies,  their  discharge   flow  rates,   and   the
 limitations  are  presented.   Previously,  the   three  types   of cold
 rolling mills (recirculation,  combination,  and  direct  application)
 were   discussed   individually.    The   BAT   alternative treatment
 technologies apply to all three types.

 Identification of_ BAT

 Based upon the information contained in Sections  III through VIII, the
 Agency developed the following treatment technologies (as   add-ons  to
 the  BPT  treatment system model) as BAT alternative treatment  systems
 for cold rolling operations.

 1.   BAT Alternative 1

     The first BAT  Alternative  includes  mixed-media  filtration  to
     further  treat  the  effluent  from  the  BPT  treatment   system.
     Filtration of the BPT discharge removes toxic metal pollutants in
     particulate form and suspended solids and oils that entrain toxic
     organic pollutants.

 2.   BAT Alternative 2

     This alternative includes granular activated carbon following the
     filtration step outlined above to reduce toxic organic pollutants
     present in the filtered discharge.
3.   BAT Alternative 3

     Alternative 3 is a zero discharge system  which  treats
     discharge in a vapor compression distillation system.
the  BPT
The  three  BAT  alternative  treatment  systems  described  above are
illustrated  in  Figure  VIII-1.    The  treatment  technologies  shown
represent  those  technologies  in  use  at  one  or  more  plants  or
demonstrated  in  other  wastewater  treatment  applications.    These
                                    187

-------
systems  are  capable of attaining the respective BAT effluent levels.
The applicability of each treatment method is reviewed  below.   Table
X-l  contains  effluent  limitations,  model  flows and concentrations
associated with BAT Alternatives 1 and 2.  BAT Alternative  3  results
in zero discharge.

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

Rationale for the Selection of the BAT Alternatives

This section presents the rationale for selecting the BAT  alternative
treatment  systems,  and  a  discussion  on  the model flow rates, the
pollutants to be limited and the concentration levels of  the  limited
pollutants.

Treatment Technologies

Mixed-media  filtration has been selected as Alternative 1, due to its
ability to reduce the levels of  particulate  toxic  metal  and  toxic
organic  pollutants entrained in the oils.  Although filtration is not
expected to remove substantial amounts of toxic organic pollutants, it
is expected to significantly reduce the pollutant load of conventional
and toxic  inorganic  pollutants  discharged  from  the  cold  rolling
operations.

Four   plants   have  filtration  systems  which  treat  cold  rolling
wastewaters, one of which  has  been  .sampled.   At  this  plant,  the
filtration  step  was used as an intermediate treatment step, with the
filter discharge receiving additional treatment in a  thickener.   The
oil and solids concentrations entering the filter were extremely high,
which   greatly   hindered   the   efficiency   of  the  filter.   The
configuration and operation of this treatment system is different than
BAT Alternative 1, in which the filter is used as the final  treatment
step, and therefore, treats a much lower pollutant load.  As a result,
the  filtration  data  for  this plant have not been used to establish
performance levels.  The levels achieved  with  filtration  are  based
upon  the performance of filter systems in other subcategories.  Refer
to Volume I for more details.

Alternative  2  includes  granular  activated  carbon  following   the
mixed-media  filtration system described above.  The carbon system was
selected  for  removal  of  toxic  organic   pollutants   based   upon
performance of activated carbon systems on similar wastewaters.

Although  toxic organic pollutants have been found in raw cold rolling
wastewaters, at present, carbon systems are not installed at any  cold
rolling  mills.
treat cokemaking
categories  with
expected  to  be
wastewaters.
However,  activated  carbon  is successfully used to
wastewaters  and  wastewaters  in  other  industrial
similar  organic contamination.  Activated carbon is
equally  effective   for   treating   cold   rolling
                                   188

-------
Alternative  3  makes  use of  a  vapor  compression distillation system,  as
it  is  one  of the  least  costly evaporation systems  available.   However,
it   is  energy intensive   and  expensive to operate.   This system was
considered,  since it may be  the only   technically   feasible  way  to
achieve  zero discharge  at all cold  rolling operations.

Flows

The   Agency  is   unaware   of  flow  reduction  methods  that  may  be
universally  applicable  to    existing    cold  rolling    operations.
Recirculation  of rolling solutions is widely practiced.   However, due
to  the.configuration of certain mills, not all combination  or  direct
application  mills  can convert to  the recirculating  mode.   At others,
major  reconstruction of the  mill   would  be  necessary  resulting  in
prohibitively  high costs.

As   a  result,  the   Agency  has used the same well demonstrated model
flows  that were used to develop the BPT  limitations.  The  development
of  these flows is discussed in Section IX.

Wastewater Quality

The   toxic  pollutants limited at BPT  were also   considered  for
limitation at  the BAT level.   The rationale  for   selection  of  these
pollutants was presented in Section IX.

Following are  the average effluent  concentrations  included  in each BAT
alternative.   The maximum values appear  below enclosed  in parentheses.
                                  BAT Concentration Bases  (mg/1)
                                 BAT-1      BAT-2          BAT-3
     Naphthalene
     Tetrachloroethylene
     Chromium
     Lead
     Nickel
     Zinc
(0.1)
(0.15)
0.1(0.3)
0.1(0.3)
0.1(0.3)
0.1(0.3)
(0.3)
(0.15)
0.1(0.3)
0.1(0.3)
0.1(0.3)
0.1(0.3)
No  effluent concentrations are presented for BAT Alternative 3, since
this alternative results in zero discharge.

Toxic Organic and Inorganic Pollutants

Toxic organic and toxic metal pollutants are present in  the  raw  and
treated wastewater from cold rolling operations.  For this reason, the
Agency  examined  BAT alternative treatment systems with the intent of
further reducing the levels of toxic pollutants.

Alternative 1 is designed to remove particulate  metals  and  organics
that may be entrained in oils.  The Agency has used the available data
to  establish  the  effluent  concentrations  for  toxic  metals.  The
                                    189

-------
analysis of these data and the results are presented  in Appendix A  of
Volume  I.   As at BPT, the toxic metal concentrations are the same as
those used in the acid pickling subcategory to facilitate the  use  of
pickling  wastewaters  to  treat  cold rolling wastewaters.  For toxic
organic pollutants, the Agency projects that filtration  will  produce
similar effluent quality as achieved through the BPT  treatment system.
The concentration for the toxic organic pollutants are, therefore, the
same  concentrations  used  to  establish  the  BPT   limitations.  The
concentrations used to develop the effluent limitations are  presented
in Table X-l.

Alternative  2  consists  of  filtration  and carbon  adsorption.  This
system is also effective at removing toxic metals, oils, and suspended
solids.  However, activated carbon was considered primarily to further
reduce organic contamination in the wastewaters.  The Agency used data
from the two activated carbon systems installed in the industry (which
treat cokemaking  wastewaters)  and  available  treatability  data  to
estimate   the  performance  of  activated  carbon  for  cold  rolling
wastewaters.  The average performance data are presented and  reviewed
in  Table  VI-1  of  Volume  I.  These data were used, since activated
carbon performance data specific to cold rolling wastewaters  are  not
available.    The   concentrations   used   to  develop  the  effluent
limitations are listed in Table X-l.
Finally, Alternative 3 is a zero discharge system.  Vapor
distillation has not been demonstrated in the industry.

Effluent Limitations for Alternative Treatment Systems
compression
The  effluent  limitations  associated  with BAT alternative treatment
systems were calculated by multiplying the model  effluent  flows  for
each  alternative  treatment  system  by  the  concentration  of  each
pollutant and an appropriate conversion factor.   Table  X-l  presents
the  effluent limitations developed for BAT Alternatives 1 and 2.  BAT
Alternative 3 results in zero discharge.

Selection of a BAT Alternative

None of the BAT alternatives were selected.   BAT  Alternative  1  was
rejected,  since  the  data  indicates  that  no  substantial effluent
reduction over that achieved at BPT would result from its application.
BAT Alternative 3 was not selected  because  of  its  high  costs  and
energy consumption.

In   the   absence  of  performance  data  specific  to  cold  rolling
wastewaters, the Agency is not confident that the effluent limitations
associated with  BAT  Alternative  2  are  achievable.   Cold  rolling
wastewaters  are  not the same ,as cokemaking wastewaters.  The.general
wastewater treatability data, that were also considered in  projecting
the  performance  of  activated  carbon,  was  developed  using single
compound solutions.  Although these data indicate  achievable  levels,
the  particular  application  of  activated  carbon  to  cold  rolling
                                    190

-------
wastewaters could produce  a  different  effluent  quality  and  thus,
affect a discharger's ability to comply with the limitations.

Based  upon  the  above  considerations the Agency has promulgated BAT
limitations for the toxic organic and toxic metal  pollutants  at  the
same  levels as the respective BPT limitations.  These limitations are
presented in Table X-1.

Site Specific BAT Limitations

As noted in Section IX, the contamination of cold rolling  wastewaters
by  toxic  organic pollutants is highly variable, both in terms of the
toxic  organic  pollutants  found  and  the  levels  at  which   these
pollutants  are  found.   The Agency has promulgated daily maximum BAT
limitations for naphthalene and tetrachloroethylene, which are  common
to  many  cold  rolling  solutions  and oil system cleaning solutions,
respectively.  However, upon  review  of  data  at  the  cold  rolling
operations  sampled for toxic pollutants, the Agency concluded that it
is not possible to establish nationwide effluent limitations  for  the
other  toxic organic pollutants found because of their highly variable
occurrence.  Limitations for other toxic organic pollutants should  be
established  at the permit writing stage.  Reference is made to Volume
I for NPDES guidance on  possible  approaches  to  establishing  those
limitations.

Demonstration of BAT Effluent Limitations

Tables  IX-7 through IX-9 present a list of those plants for which the
Agency has data that achieve the BAT effluent limitations.
                                    191

-------
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                        COLD FORMING SUBCATEGORY

                              COLD  ROLLING

                               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.  In   no
 case may BCT be less stringent than BPT.

 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.)

Because of the remand in American Paper Institute y_._  EPA (No. 79-115),
the Agency  did  not  promulgate  BCT  limitations  except   for  those
operations  for  which  the BAT limitations are no more stringent than
the  respective  BPT  limitations.   Cold  forming  is  one   of   the
subcategories  where BAT was promulgated equal to BPT.  The Agency has
concluded that  BCT  limitations  more  stringent  than  BPT  are  not
appropriate.
                                    193

-------
194

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                       COLD FORMING SUBCATEGORY

                             COLD ROLLING

                             SECTION XII

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

This   section  identifies  the  NSPS  alternative  treatment  systems
considered by .the Agency, the resulting alternative standards  for cold
rolling operations, the rationale for selecting the  NSPS  model  flow
rates, and the effluent standards.

The  NSPS  alternative  treatment systems described below apply to all
three types of cold rolling  operations.   Discussions  with   industry
representatives,  mill  manufacturers,  and  an  analysis  of  the DCP
responses indicate recirculation type cold rolling mills are likely to
be the  most  prevalent  type  of  mill  constructed  in  the  future.
Recirculation  systems  are  used  on all types of steels and  at mills
that process all types of products and  thicknesses.   Although  clean
water  may be required on the entry or exist stands of some mills, the
Agency believes that for new sources, this water can  be  treated  and
reused   to  a  high  degree.   Nevertheless,  to  accommodate future
installations of all types of  cold  rolling  mills,  the  Agency  has
promulgated NSPS for the same segments as existing sources.

Identification of NSPS

The  four NSPS alternative treatment systems are illustrated in Figure
VIII-1.  These systems are the same as the  BPT  and  BAT  alternative
treatment  systems  discussed  in  detail  in  Sections IX and X.  The
standards, model flows and concentration bases are presented in Tables
XII-1 and XII-2, for each of the alternative treatment systems, except
for NSPS Alternative 4, which achieves zero discharge.  The costs  for
the alternatives are presented in Section VIII.

NSPS Alternative 1

Alternative  1  consists of an equalization basin equipped with an oil
skimmer, chemical  addition  steps  to  break  the  oil  emulsions,  a
flocculation tank and an air flotation system.

NSPS Alternative 2

Alternative  2  includes the components of Alternative 1 plus  a mixed-
media filtration system to further reduce the pollutant  levels.   The
standards achieved with this alternative are presented in Table XII-2.
                                    195

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NSPS Alternative 3.

Alternative  3  includes all of the components of Alternative 2, except
that the filtered effluent is further treated   in  granular  activated
carbon  columns.   The  standards  achieved  with this alternative are
presented in Table XI1-2.

NSPS Alternative 4.

In this alternative, the discharge from Alternative  1 is processed  by
vapor  compression  distillation.   The  condensate  is recycled to the
process for reuse.  Zero discharge is achieved.

Rationale for Selection of NSPS

The NSPS alternative treatment systems for cold rolling operations are
similar to the BPT and BAT alternative treatment systems described  in
Sections  IX and X, respectively.  The detailed rationale presented in
these sections  is applicable to NSPS.   The  pollutants  selected  for
limitation  and the effluent quality resulting from  the application of
the NSPS alternative treatment systems are the same  as the  respective
BPT  and  BAT concentrations.  Detailed discussions  on the development
of the effluent concentrations are also presented in Sections  IX  and
X.

Treatment Technology

As noted in Sections IX and X, the use of gas flotation and filtration
is  demonstrated  not  only within the steel industry, but also within
the cold rolling subdivision.  Carbon adsorption and vapor compression
distillation have not been demonstrated at cold rolling operations.

Flow Rates

The  NSPS  model  flow  rates  have  been  developed  using  the  best
demonstrated   flow  rates  for  each  segment  of   the  cold  rolling
subdivision.   The  discharge  flows  reported  by   the  industry  are
presented  in  Tables IX-2 through IX-6 in Section IX for each segment
and subsegment.  The NSPS model flow for  single  stand  recirculation
mills  is the same as the BPT model flow, i.e., 5 gal/ton.  The Agency
believes it is appropriate to set the NSPS model flow at  that  level.
The  best  demonstrated  flows  for  each  of  the  other segments and
subsegments, along with the number and percentage of  mills  achieving
these flow rates, are listed in Table XI1-3.

Selection of an NSPS Alternative

The  Agency  selected NSPS Alternative 1 (depicted in Figure XII-1) as
the NSPS model treatment system  upon  which  NSPS  are  based.   This
treatment  system includes well demonstrated technologies and provides
for removal of suspended solids, oils, toxic organic  pollutants,  and
toxic  metals  found  in  cold  rolling  wastewaters.   The other NSPS
alternatives  were  rejected  for  the  same  reasons  set  forth  for
                                   196

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rejecting  these  alternatives  at  the  BAT level.  These reasons are
discussed in Section X.  Moreover, neither carbon adsorption nor vapor
compression distillation  has  been  demonstrated  for  treating  cold
rolling  wastewaters.   As  noted  in  Section X, NSPS for these toxic
organic pollutants not specifically limited must  be  developed  on  a
site-specific basis.

Demonstration gf_ NSPS

Tables  XII-4  and  XII-5  present  data  from  sampled  plants  which
demonstrate the NSPS.  The tables are the same as those  presented  in
Section  IX  (Tables IX-8 and IX-9).  Thus the discussion presented in
Section IX regarding these tables is also relevant to NSPS.
                                  197

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                                        TABLE XI1-3

                           DEMONSTRATION OF NSPS MODEL FLOW RATES
Recirculation
  Single Stand
  Multi Stand
Combination
Direct Application
  Single Stand
  Multi Stand
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290
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Note:  Refer to Tables IX-2 through IX-6 for a list
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                                           200

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                       COLD FORMING SUBCATEGORY

                             COLD ROLLING

                             SECTION XIII

                    PRETREATMENT STANDARDS FOR THE
             DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS
Introduction

This section presents pretreatment alternatives  available  for  those
cold  rolling  operations  with discharges to publicly owned treatment
works  (POTWs).   The  Agency  has  given  separate  consideration  to
pretreatment  of  cold rolling wastewaters from new sources (PSNS) and
from existing sources (PSES).

General Pretreatment Standards

For detailed information on Pretreatment Standards refer to 46 FR 9404
et seq.,  "General  Ptetreatment  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 cold rolling operations,
the Agency considered the objectives and requirements of  the  General
Pretreatment Regulations.  The Agency determined that the discharge of
untreated  cold  rolling  wastewaters  to  POTWs  would result in pass
through of toxic pollutants.

Identification of Pretreatment Alternatives

Treatment Technologies

The pretreatment alternatives considered are identical to the BPT  and
the  combined  BPT  and BAT alternative treatment systems discussed in
Sections IX and X.  These treatment systems are discussed in detail in
those sections.

Flow Rates

The model flow rates used to develop the  pretreatment  standards  for
new  sources  (PSNS)  are identical to the NSPS model flow rates.  The
development of these model flows is described in Section XII.

The model flow rates used in the PSES alternatives are  equal  to  the
model  BPT flow rates.   The development of these flows is described in
Section IX.
                                   205

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PSES/PSNS  Alternative  1

This alternative  consists  of  an  equalization  basin   equipped  with  an
oil  skimmer,   chemical addition   steps  to break the  oil  emulsions, a
flocculation   tank   and an   air  flotation   system.    The   standards
achievable with  this  alternative are presented in Tables XIII-1 and
XIII-3   for  PSES  and  PSNS,  respectively.    The   model   flow   and
concentration  bases are also  presented in those tables.

PSES/PSNS  Alternative  2

In  this  alternative,   the   effluent  from   Alternative   1 is further
treated  in mixed-media filters to  further reduce the pollutant levels.
The standards,  model flow  and concentration   bases   are presented  in
Tables XIII-2  and XII-4, for  PSES  and PSNS, respectively.

PSES/PSNS  Alternative  3

In  Alternative 3,  the filtered  effluent  from Alternative  2 is further
treated  in granular activated carbon columns.    The  standards,  model
flows and  concentration bases are  presented in  Tables  XIII-2  and XIII-
4, for PSES and PSNS,  respectively.


PSES/PSNS  Alternative  4

In  this   alternative,  the effluent from  Alternative 1  is  processed by
vapor compression distillation.    The  condensate  is   reused in  the
process.   Thus, zero discharge is  achieved.

Selection  of Pretreatment Alternatives

PSES  Alternative 1  and PSNS Alternative  1 (depicted in Figure XIII-1)
were  selected  as  the basis   of  the   promulgated   PSES and  PSNS,
respectively,   for  all  cold rolling operations.  The selected PSES and
PSNS model treatment   systems  will  prevent  pass   through   of  toxic
pollutants  at  POTWs   and  are  the  same  as   the  model BPT and BAT
treatment  systems.  The  removal  rates of  toxic metals   from   untreated
cold  rolling   wastewaters for the selected PSES and PSNS  are compared
to the POTW removal rates for those metals.   The average removal  rate
for  the  subcategory  and the removal rate for recirculation  mills are
presented.
                                    206

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                                       PSES/PSNS
                                     Alternative  1
Chromium
Lead
Nickel
Zinc
Recirculation
    Mills

    90%
    97%
    92%
    98%
Average

   36%
   68%
   38.7%
   67%
  POTW
Removal

  65%
  48%
  19%
  65%
As shown above, the selected pretreatment  alternatives  will  prevent
pass  through  of toxic metals at POTWs to a greater degree than would
occur if cold rolling wastewaters were discharged untreated to POTWs.

The achievability of the PSES and PSNS is reviewed in Sections IX,  X,
and  XII.  The PSES and PSNS for cold rolling operations are presented
in Tables XIII-1 and XIII-3 respectively.
                                  207

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                       COLD FORMING SUBCATEGORY

                      COLD WORKED PIPE AND TUBE

                              SECTION I

                               PREFACE
The USEPA has promulgated effluent limitations and standards  for  the
iron and 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   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).

This part of the Development Document highlights the technical aspects
of EPA's study of the Cold Worked Pipe and  Tube  Subdivision  of  the
Cold  Forming 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.
                                   215

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                       COLD FORMING  SUBCATEGORY

                      COLD WORKED  PIPE AND TUBE

                              SECTION II

                             CONCLUSIONS
Based on this current study, a review of previous  studies and comments
received  on  the regulation proposed on January 7,  1981  (46 FR 1858),
the Agency has reached the following conclusions with  respect  to  the
cold worked pipe and tube subdivision of the  cold  forming subcategory:

1.    In the previous study, cold worked pipe  and tube  operations, were
     part of the pipe and tube subcategory.   However,  data obtained as
     part  of  this  study  indicate  that  cold   worked  pipe and tube
     operations  are  different  than  hot  forming  pipe   and   tube
     operations,  and  that it is more appropriate to  include the cold
     pipe and tube operations in a separate subdivision   in  the  cold
     forming subcategory.

2.    The cold worked pipe and tube subdivision  is  segmented into those
     operations using water and those  using  soluble  oil  solutions.
     Differences    in    wastewater    characteristics,     wastewater
     treatability, and process water usage  are the   basis  for  this
     division.

3.    For those operajtjjons_jisfng^--wa3:g:r,i:'r-the Agency  has promulgated  a
     ^]^o^~dji^chjir]geJ._._ii^iJt_^X6ri".   The  Agency has also  established, a
     zero "discharge limitation for  those  plants  using   soluble  oil
     solutions.   These  plants  recycle  most  of  the  solutions with a
     small amount, 0.5  gal/ton,  disposed  of  by contract  hauling.
     Incineration  of  the  spent  solution   is an alternate method of
     disposal.

4.    The Agency has promulgated BCT and BAT effluent   limitations  and
     PSES  and  PSNS  equal to the BPT limitations.  Data obtained for
     cold worked pipe and tube operations demonstrate  that toxic metal
     pollutants are in wastewaters from both  types of  operations  and
     toxic organic pollutants are found only  at those  operations using
     oil.

5.    The Agency estimates that industry will  incur the following costs
     in complying with the cold worked pipe and tube limitations.   The
     Agency  has  determined  that  the  effluent  reduction  benefits
     associated  with  compliance  with  the  effluent limitations and
     standards justify the costs presented below:
                                    217

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6.
7.
8.
                 Costs (Millions of July 1, 1978 Dollars)

                 Investment Costs        Annual       ...Costs.
              In-Place

     Using Water
     BPT        3.30
                      Required


                        0.76
     Using Soluble Oil Solutions
     BPT        3.06         0.02
     TOTAL
           6.36
0.78
In-Place


  0.43


  0.40

  0.83
Required


   0.10


   0.00

   0.10
The Agency  has  also  determined  that  the  effluent  reduction
benefits  associated  with  compliance  with new source standards
(NSPS, PSNS) justify those costs.

The Agency estimates that compliance with the BPT limitations for
cold worked pipe and tube operations will result,  in  significant
removals  of conventional and toxic pollutants.  A summary of the
removals occurring as a result of the BPT limitations follows:
     Using Water
     Raw Waste
     BPT
                     Process
                       Flow
                      (MGD)
                 19.2
                  0
                                Direct Dischargers
                              Effluent Loadings  (Tons/Year)	
                               Toxic      Toxic     Conventional
                              Orqanics   Metals      Pollutants
     Using Soluble Oil Solutions
     Raw Waste        24.5
     BPT               0
         0
         0
                                20.4
                                 0
        6.8
        0
                 220
                   0
      1 ,878
          0
               2,681,185
                       0
The NSPS and PSNS for both types of cold  worked  pipe  and
plants are identical to the corresponding BPT limitations.
                                     tube
The Agency has promulgated PSES equal to the BPT limitations  for
cold  worked  pipe  and  tube operations using water and oil.  It
estimates that compliance with PSES will  result  in  removal  of
conventional  and toxic pollutants.  A summary of the removals as
a result of PSES follows:
                                    218

-------
                                    Indirect Dischargers
                               Effluent Loadings  (Tons/Year)
     Using Water

     Raw Waste
     PSES
                     Process
                       Flow
                       (MGD)
3.0
0
            Toxic
          Organics
0
0
          Toxic
          Metals
1.0
0
         Conventional
          Pollutants
289
  0
     Using Soluble Oil Solutions
     No operations discharge to POTWs.

9.   The remand issues that are directly applicable to the cold worked
     pipe and tube subdivision are discussed in detail in this report.
     A summary of these issues follows:

     a.   The remand required  examination  of  the  degree  of  water
          consumption  that  would result from the installation of the
          treatment systems.  Since the alternative treatment  systems
          considered  for  cold worked pipe and tube operations do not
          include recycle or cooling systems, no impact is expected on
          water consumption as a result  of  the  application  of  the
          promulgated effluent limitations.

     b.   The Agency evaluated the adequacy of its cost estimates with
          regard to Site-specific factors.   As  discussed  in  greater
          detail  in  Volume  I,   the  Agency  concluded that its Cost
          models are adequate to account for site-specific factors.

     c.   Neither relaxed effluent limitations nor alternate  effluent
          limitations  based  upon  retrofit  costs  are necessary for
          older  cold  worked  pipe  and  tube  operations.    Analysis
          indicates  that  the  age  of  cold  worked  pipe  and  tube
          operations has no significant effect upon the ease  or  cost
          of retrofitting pollution control equipment.

10.   Table II-l  presents the limitations and  standards  corresponding
     to  the  BPT,  BAT,  BCT, NSPS,  PSES, and PSNS treatment levels for
     cold worked pipe and tube operations using water and soluble  oil
     solutions.
                                    219

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                               TABLE II-l

                   EFFLUENT LIMITATIONS AND STANDARDS
                        COLD FORMING SUBCATEGORY
                             WORKED PIPE AND TUBE
Treatment Level
Effluent Limitations and Standards
Operations Using Water
                            No discharge of process wastewater pollutants
                              to navigable waters.
                            No discharge of process wastewater pollutants
                              to publicly owned treatment works.
Operations Using Soluble Oil Solutions
                            No discharge of process wastewater pollutants
                              to navigable waters.
                            No discharge of process wastewater pollutants
                              to publicly owned treatment works.
                                      220

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                        COLD  FORMING SUBCATEGORY

                       COLD WORKED  PIPE  AND TUBE

                              SECTION III

                              INTRODUCTION
General Discussion

In  cold  worked pipe  and tube operations,  hot  formed  seamless pipe  at
ambient temperature  is expanded or drawn  into   tubes,   and   cold   flat
steel  strip   (skelp)   is  formed  into   hollow  cylindrical  products
followed by electrical or fusion welding  of the  seam.   During   this
operation,   contact   cooling  water  or  soluble oil  solutions  are
continuously flushed over the pipe and tube products for  cooling  and
lubrication.    These   water  and  oil  solutions are  the  regulated
wastewaters from cold,  worked pipe and tube  operations.

In 1976, the Agency sent basic questionnaires .(DCPs) to  approximately
85%  of  the   cold  worked  pipe  and tube  mills  in' the United States.
Responses to the DCPs  for one hundered twenty-six cold worked pipe and
tube mills provided information regarding applied and  discharge   flow
rates,  wastewater  treatment  systems installed, mill capacities, and
modes of  operation.    The  data  contained in  the  DCPs  have   been
tabulated and  summarized in Tables III-1  and III-2.

Detailed  data collection  portfolios  (D-DCPs)  were sent to selected
pipe and tube  mills to gather information on treatment costs,  and  on
the pipe and tube mill  process.  Responses  were received for five  pipe
and  tube  mills using oil.  Tables III-3 and III-4 summarize the  data
base for this  report as derived from these  sources of  information.

Pipe  and  tube  operations  are  no  longer  treated  as  a  separate
subcategory.   Hot worked pipe and tube operations are included in the
hot forming subcategory, while cold worked  pipe  and  tube  operations
are  included  in  the cold forming subcategory.  Cold worked pipe and
tube operations are further segmented based upon  whether water or  oil
is used as the lubricant.

Description of Pipe and Tube Mills

Cold Expanded  Pipe

The  properties  of  hot  rolled seamless pipe  can be improved by  cold
working the product.    Cold  working  the   pipe  increases  its  yield
strength  and  generally  improves  the  product.   One method of  cold
working is the seamless pipe method  in  which  the  hot  rolled   pipe
(after  cooling)  is conveyed to a cold expander  mill.  The hot rolled
pipe is dropped into an expander trough and clamped with one end   held
firmly  against  a backstop.   A long ram  is positioned at the opposite
                                    221

-------
end of the pipe, and an expander plug  is forced  through the pipe  using
extreme pressure.  The plug  is  lubricated  through the ram head with  a
water  soluble  oil.  After  cold expansion,  the  seamless pipe enters a
rotary straightener and then is hydrostatically  tested.

Cold Drawn Tube

While most quality requirements for seamless pipe and tubing  products
can  be  met  by  the  hot   rolling  processes,  some  pipe  and   tube
specifications require closer tolerance, enhanced physical and surface
properties, thinner walls, and  smaller diameters than can be  produced
by  hot  worked  methods.    These  specifications  can  be met by cold
drawing the hot rolled tubes in a finishing  operation.

The process consists of pulling a cold tube  through  a  die,  with  a
smaller  opening  than  the  outside diameter of the tube being drawn.
The hot rolled tubes are crimped and pointed on  the  leading  end,  so
that  the pipe section can pass through the  die  and permit the jaws of
the puller mechanism to grip the end of the  tube.  The inside  surface
of the tube is supported by  a mandrel anchored on the end of a rod, so
that  the  mandrel  remains  in  the plane of  the  die during the drawing
operation.  Another method involves using  an internal bar rather   than
a  stationary mandrel.  This bar travels along with the tube, as  it is
drawn through the die.  Tubes of certain grades  are annealed prior to
the cold drawing operation.  All tubes are pickled to remove scale and
oxides,  rinsed,  and  then  dipped into a  lubricant tub (flour, tallow
and water, or a special oil  emulsion for a bright finish) prior to the
cold drawing operation.

Other cold tube reducing methods, such as  the "Rockrite" process,  are
also  used  for  cold  drawing.   The  "Rockrite" process accomplishes
simultaneous reduction of tube  diameter and  wall thickness by  a   cold
swaging  action,  which  uses   compressive  forces rather than tensile
forces, as used in conventional cold drawing.  Two semi-circular   dies
have  matched,  tapered,  semi-circular  grooves  machined  into  their
curved faces.  In operation, one die is placed on top of the other, so
that the matched semi-circular  grooves make  a circular pass.  The dies
are geared to each other in  such a manner  that they rotate in opposite
directions when they are moved  laterally,  and  a  converging  circular
pass  is traced by the die grooves.  When  a  tube is held stationary on
the centerline of this pass, the converging  path of  the  die  grooves
reduces  its diameter.  If a stationary mandrel  of the proper taper is
also positioned in the center line of the  pass,  the inside of the tube
is supported between the die and mandrel.  When  in operation, the dies
are  in  constant  lateral   and  rotary  reciprocal  motion.   Coolant
solutions are constantly poured onto the dies.

Electric Resistance Welded Tubing

Electric  resistance  welded  tubing  is   referred  to  as ERW tubing.
Strip,  sheet, or plate in coil  form is used  as a starting material for
the ERW process.  The steps  used in the manufacture of ERW tubing are:
form'ing,  welding,  sizing,  cutting,  and finishing.
                                   222

-------
 The width of the strip is  determined  by  the  circumference  of  the
 tubing  to  be  welded.   If  extra  wide  strip is used, it is passed
 through a slitting-line for cutting to proper width and then recoiled.
 The proper width strip is fed into forming rolls.   The  forming  rolls
 consist  of an edge trimmer (to smooth and clean the edge of the strip
 for welding and forming), closing, and fin pass rolls.  After the  fin
 rolls,   the strip enters the welding section where the tube is held in
 pressurized  squeeze  rolls,  as  the  edges  are  heated  to  welding
 temperature.    The heat for welding is provided by low-frequency power
 through electrode wheels, by  radio-frequency  power  through  sliding
 contacts,  or by coil induction.   Typical power for welding is supplied
 at  450,000  cycles  per  second.   The welded tube then passes under a
 cutting tool,  which removes the  flash  resulting   from  the  pressure
 during   welding.    The  welded seam or entire tube is then annealed or
 normalized,  depending on the required metallurgy.   After cooling,   the
 tube  is  sized  on  horizontal   and vertical sizing rolls to obtain a
 round finished product of the desired  diameter.    After  sizing,   the
 tube  is  cut  to length and straightened and end-finished if required.
 The tubes  are  then inspected and packed for shipment.

 Electric Welded Pipe

 The electric weld process or fusion weld is used to  produce  pipe  in
 various diameters.    If  the desired  pipe circumference exceeds the
 plate width, two  or more plates  may be welded together to provide   the
 necessary   width.    The steps required to make plates into pipe by the
 electric  weld process  are  shearing/   planing,   crimping,   bending,
 welding, expanding,  and finishing.

 Plate  is  transferred to the edge-planing machine,  where it is aligned
 so  that the two edges will  be parallel  and square  with the ends after
 planing.   .Forming  plate  into  circular pipe is  usually performed in
 three operations  called crimping,  "U"-ing,   and "0"-ing.'   The first
 operation,  crimping,   consists  of  bending the edges  in a press, so as
 to  avoid a  flat surface near the longitudinal  seam of  the  pipe.    The
 crimped plate  is  then  conveyed   to   a  "U"-ing machine.    In  this
 operation, the plate is centered over  a  series of  parallel  rocker-type
 dies, which lie along the axis of  the plate.   A large   "U"-shaped   die
 operated by a press,  as long  as the  longest  length of plate,  is moved
 down  on the plate,  forcing  it  between   the dies   which  automatically
 conform themselves   to the  operations and assist  in  forming  the plate
 into  the "U"-shape.   The plate is  then transferred  to  what   is  called
 the   "0"-ing machine.   The machine  consists of two  semi-circular dies,
which are as long  as  the plate.  Rollers  mounted on vertical   spindles
prevent  the plate from falling  and keep  it  in correct alignment as  it
enters  the "0"-ing machine.  The "U"-shaped plate  rests  in  the  bottom
die,  and  the  top die  is forced down by  a press, deforming  the plate
until it is the shape of  an  almost  closed  circle, which  is  then  ready
for  welding.   The  pipe  is  held  in  position  for  welding  by  a
longitudinal rod,  which maintains   the  proper  gap  for  welding.   A
specially  designed  welding head deposits flux along  the  joint, feeds
the metal electrode, and transmits welding current to   the  joint  and
electrode.    Molten filler metal is deposited  from the metal electrode
                                   223

-------
to the work and replaces the fluid flux and forms the weld.  After the
pipe is welded on the outside, it is then welded on the inside  by  an
automatic welding machine mounted on the end of a long cantilever arm.
The  pipe  is  drawn  over this arm by a carriage.  After welding, the
scaly deposit left from the flux is removed  by  a  cantilevered  tube
device.

The  final pipe diameter is obtained by either hydraulically expanding
the shell against a retaining jacket or mechanically expanding  it over
an inside mandrel.  In hydraulic expansion, the ends are  expanded  to
the  proper diameter by mandrels.  Retainer rings encircle the  body of
the pipe, which is filled with water and hydraulically expanded to the
limits of the bands.  This also  serves  as  a  hydraulic  test.   The
expansion,  by  either method, sizes, rounds, and straightens the pipe
and provides  a  good  test  of  the  weld.   Attention  is  given  to
nondestructive  inspection of the weld by X-ray examination.  The pipe
is then placed in special machines which face the ends, to ensure that
they are smooth and at right angles.  If the joints are to be   welded,
the ends are beveled in this operation prior to shipment.

More  specific  details  of  a  typical ERW operation are presented in
Figure III-l.
                                     224

-------
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                       COLD FORMING SUBCATEGORY

                      COLD WORKED PIPE AND TUBE

                              SECTION IV

                          SUBCATEGORIZATION
Introduction

Originally, cold worked pipe and tube operations were included in  the
pipe  and  tube  subcategory.   Based  upon  data  obtained  since the
promulgation  of  the  previous  regulation,  the  Agency  has   found
significant  differences  between  the hot worked and cold worked pipe
and  tube  subdivisions.   Accordingly,  cold  worked  pipe  and  tube
operations   now   constitute   a  subdivision  of  the  cold  forming
subcategory.  The cold forming subcategory also includes cold  rolling
operations.   As the Agency found variations in the final products and
manufacturing processes  between  the  cold  forming  operations,  the
subcategory  was subdivided into the cold rolling and cold worked'pipe
and tube subdivisions.

The Agency also believes that within the cold  worked  pipe  and  tube
subdivision,  further  segmentation is appropriate based upon the type
of process solution used (see discussion below).  The Agency  examined
other  factors,  including raw materials, size and age, and geographic
location, but found that they have no significant  effect  on  further
segmentation.   Each  of  these factors is discussed in greater detail
below.

Manufacturing Process and Equipment

Cold working operations manufacture cold drawn or welded pipe and tube
from cold semi-finished products, strip, or skelp.  Several  processes
are  employed  to  manufacture  these  products.   Electric resistance
welding, fusion  welding,  and  cold  drawing  are  all  cold  working
operations   which   encompass   similar   equipment   and  processes.
Therefore,  the  Agency  believes  that   no   further   division   or
segmentation is appropriate on this basis.

Final Products                      '    ..

Products of various dimensions can be manufactured in cold worked pipe
and  tube  mills.   Different  types  of  equipment  are  used  in the
manufacture of these products.  Some processes use water solutions tot
lubrication and cooling purposes; others use  soluble  oil  solutions.
Although  the  quality  and  quantity of waste solutions may vary,  the
Agency did not find any correlation between the products  manufactured
and the waste solutions generated.
                                    239

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Raw Materials

The raw materials used in cold worked pipe and tube operations  include
steels   of   various   material   specifications.  The differences in  the
steels   processed have  no significant  effect  on  the   wastewater
characteristics.   The  raw materials  used , in  the manufacture of  a
finished product have  little  bearing  upon  the   subdivision   or
segmentation of  cold worked pipe and tube operations.

Wastewater  Characteristics

A   review   of  the DCP data indicates the need for  further segmentation
based upon  the  process  wastewaters  generated  in  the   colcl   worked
subdivision.   The  plant  survey  data   indicates  that   soluble   oil
solutions   are  used  in jspjrie^^cold  working  mills   for   process
requirements,  while  c^lyjwater^i-s\used at the remaining cold  working
mills.   On  this  basis,  the segmentation  of the  cold  working   process
was made.

Wastewater  Treatability

As   indicated  above,   the  treatability  of cold  worked  pipe and tube
wastewaters differs  between mills using  water and  mills using   soluble
oil  solutions.     There   are   substantial   differences   in   the
characteristics  of these  wastewaters and  thus  different  treatment
technologies would apply.   The wastewaters from those  mills  using oils
consist  of soluble oil solutions,  whereas the wastewaters  from mills
using water consists  of  water  contaminated  with  tramp  oils   and
particulate matter.   Soluble  oil solutions are effectively  treated by
dissolved gas  floatation whereas waters  contaminated with tramp oils
and particalate  matter are effectively  treated by gravity separation.
The cold   worked subdivision  is  segmented   to  recogonize  this
difference.

Size and Age

The Agency considered the impact of size and age on  the segmentation
of  cold worked pipe  and tube mills.   Size  has no apparent effect  upon
segmentation.   Analysis  failed to reveal  any correlation between  the
size of a pipe and tube mill and process water usage.  Shown on Figure
IV-1  is  a plot of   discharge  flow  (in  galIons/ton)versus  size
(expressed  as  capacity  in   tons/day)  for cold  worked  pipe and tube
mills using water.   (No figure.is  provided  for   cold  working mills
using  soluble  oil  solutions,  as 90% of these mills currently  achieve
zero discharge which  is  the BPT  requirement.)   As  can  be  seen   by   the
plot, the size of  a  pipe and tube mill has  no bearing  upon the  ability
to  recycle  and subsequently eliminate the  discharge.   Thus,  the Agency
concluded that further  segmentation  based  upon the size of cold worked
pipe and tube mills  is  not  appropriate.

The  Agency  next  examined  age   as   a  possible   basis   for   further
segmentation.  According  to DCP  data,  the  oldest mill  now in operation
was built in 1925, and  the  newest  was  built   in   1978.   The  Agency
                                     240

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compared  discharge  flow  versus  age  in  a  manner  similar  to the
discharge flow versus size comparison noted above, and this comparison
is also illustrated in Figure.IV-1.   As  with  the  flow  versus  size
plot,  no  relationship  between  age  and process flow is evident.  A
figure is not provided for the cold worked  mills  using  soluble  oil
solutions,  as  90%  of  these  mills currently achieve zero discharge
which is the BPT requirement.  Hence, the Agency  concludes  that  the
age  of  a  mill  has  no  affect  on the ability to treat and recycle
process wastewaters.  Further analysis also indicated  that  mill  age
does not affect wastewater quantity.

The  Agency also addressed the issue of retrofitting pollution control
equipment as part of its plant age analysis.  The ability to  retrofit
pollution  control  equipment has been demonstrated at several plants.
These plants serve to illustrate that pollution control equipment  can
be  retrofitted on existing production facilities without unreasonable
difficulty or expense.  In addition, the Agency analyzed the  cost  of
retrofit, to determine whether older plants require additional capital
expenditures  for the installation of pollution control equipment over
that required by new  plants.   This  retrofit  cost  information  was
obtained  from  the  industry  through the D-DCPs.  Since the industry
indicated that no retrofit costs were incurred, the  Agency  concludes
that  the  cost  of  retrofitting pollution control equipment on older
mills is either minimal or not significant.

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

The location of cold worked pipe and tube mills has no apparent effect
upon  segmentation.  The Agency analyzed the relationship between mill
location and process water 'use.  No discernible pattern was  revealed.
Most  pipe  and  tube  mills  are located in'twelve states east of the
Mississippi River  and  in  Texas,  California,  Colorado,  Utah,  and
Louisiana.   It  should  be  .noted  that cold worked mills using water
achieve zero discharge,  and  cold  worked  mills  using  soluble  oil
solutions  have  a minimal blowdown which is disposed ,of by hauling at
the BPT level.  As explained in Section IX, the Agency has  determined
that  it  is  appropriate  to  establish  the  BPT limitations at  zero
discharge based upon contract hauling of this  blowdown.   Since   both
operations  readily  attain  zero  discharge  regardless of geographic
location, this factor has no effect on segmentation.
                                    241

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Process Water Usage

DCP and D-DCP data, as well  as  sampled  plant  data,  were  used  in
determining  the  applied  and discharge flow rates (gal/ton) for each
mill.  Flow averages and ranges in each of the two  cold  worked  mill
segments  are  presented  in Table IV-1.  The flow differences between
the types of cold worked pipe and tube mills (water  or  oil)  can  be
readily  noted  on  this table.  The Agency segmented this subdivision
based upon process water usage.
                                  242

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                                        TABLE IV-1

                                 FLOW AVERAGES AND RANGES
                                 COLD FORMING SUBCATEGORY
                              COLD WORKED PIPE AND TUBE MILLS

                              (All  flows expressed in gal/ton)
                                         Applied Flow
                                    Discharge Flow
Cold Worked Pipe and Tube
(Using Water)

Cold Worked Pipe and Tube
(Using Soluble Oil Solutions)
Average
3,263.8
Range' 2)
320-51,483
Average'1'
2,428.5
Ranse(2)
0-26,926
2,061.6
1,143-6,000
5.6
0-97.8
(1) Confidential information was included in the average calculations.
(2) Ranges do not include confidential values.
                                             243

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                          244

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                       COLD FORMING SUBCATEGORY

                      COLD WiDRKED PIPE AND TUBE

                              SECTION V

              WATER USE AND WASTEWATER CHARACTERIZATION
Introduction

Process water use and characterization of the wastewaters generated by
the pipe and tube mills  are  the  principal  considerations  used  in
determining  pollutant  loads,  developing treatment alternatives, and
estimating the costs of compliance with the limitations and standards.
This section describes the wastewater treatment  systems  in  use  for
cold  worked  pipe and tube operations and the wastewaters originating
from the processes.  The description of the wastewaters is limited  to
those  process  waters  which  come  into  contact  with  the process,
product, by-product or raw materials, thus becoming contaiminated with
pollutants characteristic of the process.  This excludes  waters  used
for  noncontact  cooling  and  nonprocess  systems,  i.e.,  utilities.
Wastewater characterization is based  upon  analytical  data  obtained
during field sampling surveys.

Water Use

Wastewaters are generated in cold worked operations as a result of the
continuous  flushing  of  the  product, welders, or rolls, either with
water or soluble oil solutions.  Also, wastewaters are discharged from
hydrostatic testing operations.

The cold worked pipe and tube mills generally have  three  main  water
systems.

1.   Noncontact cooling water for annealing or normalizing furnaces.

2.   Water or soluble oil solutions used for cooling or lubrication of
     welders, rollers, etc.

3.   Hydrostatic testing waters.

The noncontact cooling  waters  are  handled  in  once-through,  tight
recycle,   or   closed   loop   systems,  depending  upon  mill  water
availability.  As noted above, the waters are noncontact and, as such,
exhibit only a temperature  increase and are not considered herein.

Hydrostatic testing waters  are typically  reused  in  the  testing  of
large  tonnages  of  steels.   These  wastewaters are small  in volume,
variable, and are not included in the limitations  set  forth  herein.
Limitations   for   those   wastewaters  should  be  established  on   a
case-by-case basis.
                                   245

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 The contact wastewaters originating in cold  worked  operations  using
 water  are  usually  discharged  to trenches beneath the pipe and tube
 mill stands and subsequently flushed into scale pits.   Scale  settles
 out  in  these  pits,  while  an oil skimming device is used to remove
 insoluble oils.  The treated wastewater from the scale pit is recycled
 to the process at most operations.

 The soluble oil solutions used in cold worked operations using oil are
 continuously recycled through settling and  storage  tanks.   In  some
 instances, these solutions are filtered or cooled as they are recycled
 from the settling tank.  The solids which accumulate in settling tanks
 are  periodically  removed.  The solutions are recycled until they are
 removed for disposal by contractors.

 Wastewater recycle is practiced 'in the two cold worked pipe  and  tube
 mill  segments.  .Many  of the mills using water and almost all of the
 mills using soluble oil solutions include high rate recycle.   The  use
 of  recycle  is  considered  a  good  conservation practice and,  being
 widely demonstrated in both types of cold worked pipe  and  tube  mill
 operations,   has  been  included  in  the  BPT and BAT model  treatment
 systems.

 In summary,  the water and  oil  solutions used in cold worked  pipe  and
 tube  mills   are  recycled to  a high degree with only minimal blowdown
 from oil  solution  mills.   This blowdown is hauled offsite  for disposal
 at 79% of the oil  solution plants.   About  95%  of  the oil   solution
 plants,   including  those   that  haul   their  wastes off-site,  have  no
 discharge to navigable waters.    Four   water  solution   plants,   which
 constitute  40% of  those  plants   that   reported  flow data,  have  no
 discharge.   The other mills using water operate with partial  recycle
 or  in  a once-through  mode.    There  are  no  apparent  factors that
 distinguish  these  mills from those which  achieve zero discharge.   As  a
 result, the  Agency believes that  all mills using  water are   able   to
 recycle   their   wastewaters to   achieve  zero discharge.   Based on the
 above, the Agency  believes  that zero discharge  is  attainable   for  all
 cold  worked pipe  and tube  mills, and has  promulgated such  limitations
 at the BPT level.

 Wastewater Characterization

 The cold worked process using water  and   cold   worked  process   using
 soluble  oil solutions both  generate a  fine scale  as  well as  insoluble
 and water soluble oils and  greases.  Free  oils and greases are present
 in wastewaters from both types  of  operations   as  a   result  of  oil
 spills,  line  breaks, and equipment leaks and washdown.   In  addition,
water soluble and emulsified oils are found in the mills using soluble
oil solutions.  The pH of cold worked pipe and tube wastewaters may be
slightly  acidic  due  to  carry-over  of  acid  from  prior  picklina
operations.                                                          y

Table  V-l  presents  the raw wastewater data for cold worked pipe and
tube mills using water taking into account the  respective  pollutants
                                    246

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in  the  intake  water  supply.   The  data
pollutants are contributed by these mills.
indicate that toxic metal
Table V-2 presents the available r.aw waste data for cold  worked  pipe
and  tube  mills using oil.  The data show that the oil solutions used
in cold worked pipe and tube mills contain significant levels of toxic
organic and metal pollutants.

Since similar oil solutions are used in both  cold  rolling  and  cold
worked  pipe  and  tube operations/ similar pollutants are expected in
all cold worked wastewaters.  Extensive data have been  collected  for
cold  rolling  operations.   These  data indicate that the presence of
toxic organic  pollutants  is  prevasive  and  highly  variable.   The
wastewater  data  obtained  for  the oil solutions used in cold worked
pipe of tube operation show similar characteristics.
                                    247

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                                TABLE V-l

              SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
                          TOXIC POLLUTANT STUDY
                 COLD FORMING - COLD WORKED PIPE  AND TUBE
              	         (USING WATER)
Raw Wastewater

Reference No.
Plant Code
Sample Points
Applied Flow (gal/ton)

 23 Chloroform
 44 Methylene Chloride
 66 Bis-(2-Ethylhexyl)
     phthaiate
119 Chromium
120 Copper
122 Lead
124 Nickel
128 Zinc
256F (04-06)
    331A
     B
     Unk

    0.013
    0.022

    0.001
   <0.015
    0.044
   <0.025
    0.050
    0.387
 0.002
 0.00

 0.014
 0.018
 0.095
 0.00

-------
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                                                      249

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-------
                        COLD FORMING SUBCATEGORY

                       COLD WORKED PIPE AND TUBE

                               SECTION VI

                         WASTEWATER POLLUTANTS
 Introduction

 As  noted  in Section V,  the  Agency   believes   that   zero  discharge   of
 process   wastes   can  be  achieved   at   all   cold  worked  pipe and tube
 operations.  Nevertheless,  the Agency   has   evaluated   the  wastewater
 data   in  order to characterize these wastewaters.   This information  is
 used to determine the pollutant  load reductions  presented  in  Section
 VIII.

 Conventional Pollutants

 Oil and grease, and suspended solids are characteristic of cold worked
 pipe   and tube   wastewaters.    Oils and greases  originate in the oil
 solutions and from equipment leaks  at the process.   Suspended solids
 are present in these wastewaters as a result of  contamination by scale
 and  dirt as  the oil  solutions and water are flushed  over the stands
 and product.

 Toxic  Pollutants

 Tables VI-1 and VI-2 lists  the toxic pollutants  found to  be present  in
 wastewaters from  cold worked pipe and tube mills using  water and  oil,
 respectively.   The  data   were  acquired through sampling conducted  by
 the Agency.  Pollutants found at concentrations  greater than 0.01 mg/1
 are considered characteristic of these wastewaters.  Tables  VI-3  and
 VI-4   list  those  toxic pollutants  for  both types  of cold worked pipe
 and tube  operations which   were  detected  at  average  concentrations
 greater than 0.01  mg/1.

 Some pollutants were detected at concentrations  greater than 0.01 mg/1
 but  are  not  listed  on Tables VI-1 -  VI-4. , The  agency believes the
 presence  of those  compounds is not  due to the cold  worked  operation.
 Methylene  chloride was omitted  because  this compound is  commonly used
 as a .cleaning agent in the  laboratory and the  Agency   attributes  its
 detection  to  this practice and not to  the  cold worked mills  sampled.
Also, the phthalate compounds are not believed to be characteristic  of
 cold worked mill wastewaters.  Their origin   is  probably  related   to
plasticizers in the tubing  used with automatic samplers.

For  those  operations  using  water, only toxic metal  pollutants were
found as presented in Table VI-3.  As noted  in Table VI-4,  many  toxic
organic  and  metal  pollutants  were  detected  in  the   wastes  from
operations using oil.   The major sources of  these pollutants   are  the
                                    251

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oils  used  at  the  mills.   The  exact nature of these oils is often
proprietary, making it difficult to relate any of  the  pollutants  to
any one type of oil or brand name.
                                    252

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               TABLE VI-1
  TOXIC POLLUTANTS KNOWN TO BE PRESENT
COLD FORMING - COLD WORKED PIPE AND TUBE
               (USING WATER)	
               23
              1.19
              120
              122
              124
              128
Chloroform
Chromium
Copper
Lead
Nickel
Zinc
                    253

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               TABLE VI-2
  TOXIC POLLUTANTS KNOWN TO BE PRESENT
COLD FORMING - COLD WORKED PIPE AND TUBE
      (USING SOLUBLE OIL SOLUTIONS)
       4   Benzene
       11   1,1,1-Trichloroethane
       38   Ethylbenzene
       39   Fluoranthene
       55   Naphthalene
       65   Phenol
       72   Benzo (a) anthracene
       73   Benzo (a) pyrene
       78   Anthracene
       80   Fluorene
       84   Pyrene
       85   Tetrachloroethylene
       86   Toluene
       87   Trichloroethylene
       119  Chromium.
       120  Copper
       122  Lead
      124  Nickel
      128  Zinc
                    254

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               TABLE VI-3

          SELECTED  POLLUTANTS
COLD FORMING - COLD WORKED PIPE AND TUBE
              (USING WATER)	.
                120  Copper
                124  Nickel
                128-Zinc
                      255

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               TABLE VI-4
           SELECTED  POLLUTANTS
COLD FORMING - COLD WORKED PIPE AND TUBE
      (USING  SOLUBLE OIL  SOLUTIONS)
      39   Fluoranthene
      65   Phenol
      72   Benzo (a) Anthracene
      78   Anthracene
      80   Fluorene
      84   Pyrene
      85   Tetrachloroethylene
      86   Toluene
      87   Trichloroethylene
      119  Chromium
      120  Copper
      122  Lead
      124  Nickel
      128  Zinc
                   256

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                       COLD FORMING SUBCATEGORY

                      COLD WORKED PIPE AND TUBE

                             SECTION VII

                   CONTROL AND TREATMENT TECHNOLOGY
Introduction

This  section  presents  the treatment practices currently used within
the cold  worked  pipe  and  tube  subdivision  of  the  cold  forming
subcategory.   Data  from the DCPs and plant visits provided the bases
for the summary of treatment technologies used for cold worked mills.

The Agency determined the treatment practices  in  existence  at  cold
worked pipe and tube operations to form the basis for evaluating other
technologies,   establish   limitations,   and   estimate  incremental
pollution control costs.  The alternative treatment systems  developed
and  the  corresponding  effluent  characteristics  are  summarized in
Sections IX through XIII.  The costs are summarized in Section VIII.

Summary of_ Treatment Practices Currently Employed

The treatment provided at most pipe and tube  operations  consists  of
sedimentation  (primarily  by  scale pits), oil removal (by skimming),
and recycle.  Following is a  description  of  the  various  treatment
technologies  employed  by cold worked pipe and tube operations.  This
description is a summary of the data reported by the industry  in  the
DCPs and further clarified by the industry in comments provided on the
regulation  proposed  in January 1981.  These comments resulted in the
reclassification of certain mills into the water or oil  subdivisions.
The descriptions that follow reflect these changes.  (See Tables III-l
and  II1-2  for  treatment technologies used by each of the individual
mills)..

A.   Cold Worked Pipe and Tube Plants Using Water

     1.   Sedimentation-Primary Scale Pit

          The  primary  scale  pit  serves  to  collect  the   heavier
          suspended  particulate matter and allows tramp oils to float
          to the surface.  Approximately 40%  of  the  pipe  and  tube
          plants using water have primary scale pits.

     2.   Oil Skimmer

          Oil skimmers are used to remove the oils which accumulate  in
          the scale pits.  Approximately 47%  of  the  pipe  and  tube
          plants using water have some type of oil skimming equipment.
                                    257

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      3.   Recycle

           Recycling all or part of the process waters conserves  water
           and  minimizes  or  eliminates  the discharge of pollutants.
           Approximately 40% of these plants recycle  all  or  part  of
           their process water.

 B.    Cold Worked Pipe and Tube Plants Using Soluble Oil Solutions

      1.   Sedimentation-Primary Scale Pit

           Approximately 53% of these plants use primary scale pits  to
           provide for removal of particulate matter and insoluble oil.

      2.   Oil Skimming

           About 11% of these plants use  some  type  of  oil  skimming
           device to remove insoluble oils.
      3.    Recycle

           All  of the plants recycle  some  portion  of
           solutions.

      4.    Contractor Removal
their  process
           A small  fraction of  the oil  solution (about 0.5-gal/ton)   is
           not    recycled  but   is  discharged  to  storage  tanks  and
           subsequently hauled  off-site by a contractor for reclamation
           or disposal.   About  79% of the  plants dispose of  spent  oil
           solutions   in  this   manner.    Three  other  plants   have no
           discharge  of wastewaters from the plant site.   One of  these
           plants  disposes   the  spent   oil   solution  by   ground
           application.   In total  95% of the pipe and   tube  operations
           using  oil,  reported  achieving zero discharge.

Summary of Sampling  Visit Data

Eight  cold worked   pipe and  tube mills  using oil  and two using  water
were visited during  the original  and current guidelines  survey.   Table
VII-1  provides  a   legend for  the   various  control   and treatment
technology abbreviations used  in  this  and other tables throughout this
report.    Table  VI1-2  presents a summary of the raw  and effluent data
for the cold worked  mills using water.  Table VI1-3 presents the  raw
and effluent data for  the cold worked mills  using oil.

Plant  HH-2  was reevaluated and  determined  to be nonrepresentative of
cold worked pipe-and  tube  operations.    The  raw wastewater   sampled
during   this   visit   was  a   mixture  of   many different  finishing
operations,  (i.e., acid  pickling  and alkaline cleaning).    These  data
were  found  not  to  be   characteristic   of  cold worked pipe and tube
operations and were subsequently  eliminated  from the data  base.   It is
                                    258

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believed that the data  collected  during  these  more  recent  visits
better describe the cold worked pipe and tube wastewaters.

Plants Visits

Plant 331A (0256F 04-06) - Figure VII-1

Plant  331A  is  a  cold  worked  pipe  and tube mill using water that
produces stainless welded tubes.  All process water  requirements  for
each  of  the  three  mills  are  furnished  by individual closed-loop
systems.  The tube cooling water is recirculated from a  reservior  in
the  mill  base.  City water is occasionally used to makeup looses due
to evaporation.  Also, torch cooling water is recriculated  through  a
chiller.

Plant 331B (0256F 01-03) - Figure VII-2

Plant  33IB  is cold worked pipe and tube mill using oil that produces
carbon steel welded tubes.  A soluble  oil  solution  is  recirculated
from a sump through a cooling tower for use at three individual mills.
The  system  is a self-contained recirculation cooling system in which
only minor evaporative losses result.  These losses are replaced  with
fresh oil solution.  There are no effluent discharges.

Plant 332 (0684L 01-04) - Figure VI1-3

This  cold  worked pipe and tube mill using oil produces welded tubes.
The process uses an oil solution which passes over the product and  is
then  filtered  before entering an oil pit.  From here the solution is
recirculated to the mill where it is reused.  Each of the  four  mills
                and oil pit.  Periodically some of the oil solution is
                 holding  tank  and  is  then  hauled  off-site  by.  a
has  a  filter
blowndown to
contractor.
Plant 333 (0684A) - Figure VII-4

Plant  333 is a cold worked pipe and tube mill using oil that produces
electric welded pipe and tube products.  Cold carbon steel enters  the
mill  without  any prior application of oil.  Throughout the process a
recirculated soluble oil solution is applied to the  steel.   The  oil
solution  is  recirculated through a basin to allow particulate matter
to settle out of the solution.  Sediment is continuously  removed  and
fresh oil is added directly into the basin.  Wastewater from the basin
is discharged to a sewer which flows to the Mahoning River.

Plant 335 (0856N) - Figure VII-5

This  cold  worked  pipe and tube mill using oil produces carbon steel
welded pipe utilizing electric resistance welding.  An oil solution is
continuously applied to the steel during the process.  The solution is
recycled through an oil pit which discharges  to  a  second  oil  pit.
Solution  is  returned  from  the second oil pit with part of the flow
entering the first  oil  pit  directly.   The  remaining  flow  passes
                                    259

-------
 through  a  cooling  tower  before  returning  to  the  first oil pit.
 Normally,  there is no discharge from the recycle system.   In the event
 there is an overflow, it would be discharged to the pipe mill lagoon.

 Plant 336A (0856Q-03) - Figure VII-6

 Plant 336A is a cold worked  pipe  and  tube  mill  using  water  that
 produces  carbon steel welded tubes.  Process wastewater is treated in
 two scale pits, each receiving discharges from different sources.  One
 treats the discharge from the expander and scrubber  while  the  other
 treats  wastewater  from  the hydrostatic tester.   The wastewaters are
 combined after passing through the scale pits.   Before final discharge
 to  the  Monongahela  River,   the  total  flow,   which  now   includes
 discharges  from other plant  operations, passes through a settling pit
 equipped with an oil skimmer.

 Plant 336B (0856Q-04) - Figure VII-7

 Plant 336B is a cold  worked   pipe  and  tube  mill  using  oil  which
 manufactures   specialty   steel    welded  tubes,   utilizing  electric
 resistance welding.   The oil  solution passes over  the product  and  is
 discharged to a recirculation pit.   From the recirculation pit the oil
 solution  returns  to the process.   Occassionally,  the oil solution is
 blowndown  for removal by contractor.

 Plant 337  (0548C)  -  Figure VII-8

 This  cold  worked pipe and tube mill using oil  produces  carbon  steel
 welded tubes.   Cold  steel enters  the electric weld mills  without prior
 cleaning.    Oil  is   continuously  applied to the  steel throughout the
 process.    The  three  electric  weld  mills are   serviced   by   one
 recirculating  system.    The  oil  solution passes through  a cyclone and
 filter before it is  recirculated  to the mills.   Approximately twice a
 year  the oil  solution is replaced and reclaimed.

 Plant 338  (0240B-03,  05)  - Figure VII-9

 At  plant   338,   two  cold worked pipe and tube mills using oil which
 produce carbon steel  welded tubes were sampled.  At each  of the  mills
 oil   solution   is  continuously applied to the  carbon  steel throughout
 the process.   After  the  solution  has  passed over the product it enters
 an oil  recirculation pit where the  solution is  then recycled  to  the
 process.    Each  of   the  two   mills   maintains  its own  recirculation
 system.  Approximately twice a year the oil  solution is blowndown  and
 removed by  a  contract hauler.

 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
                                   260

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respective  effluent limitations and standards should be developed and
applied on a gross basis.

Tables VII-4 and VI1-5 present an analysis of the  effect  of  make-up
water  quality  on the raw waste loadings of each pollutant limited in
the regulation of the cold worked pipe and tube operations using water
and oil, respectively.  The data presented in the tables were obtained
from  cold  rolling  sampling  surveys  because   no   make-up   water
characteristics   were   available  for  cold  worked  pipe  and  tube
operations.  The analysis clearly  demonstrated  that  the  levels  of
pollutants in the intake water are insignificant compared to raw waste
loadings.    The  Agency  has  determined  that  the  limitations  and
standards should be applied on a gross basis,  except  to  the  extent
provided by 40 CFR 12.2.63(h).
                                   261

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                        TABLE  VII-1

          OPERATING MODES, CONTROL AND TREATMENT
             TECHNOLOGIES  AND  DISPOSAL METHODS

                          Symbols
A.
B.
C.
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: U = Untreated
T » Treated
n
% of raw waste flow
% of raw waste flow
% of raw waste flow
% of FC flow
% of BC flow
% of VS flow
% of FH flow
3.   REt,n
4.   BDn
                            Reuse, where t - type
                                         n - % of raw waste flow

                                         t:  U s 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
                             262

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TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 2	
C.
D.
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

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 = type

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

        32.  Scr

        33.  OB

        34.  SS

        35.  PSP

        36.  SSP

        37.  EB

        38.  A

        39.  AO

        40.  GF

        41.  M

        42.  Nt
                                     263

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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  = Alum
                                            P  = Polymer
                                            M  3 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)
                                   264

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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 = 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

                             265

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

        67.  AA1            Activated Alumina

                            Ozonation
68.  OZ

69.  UV

70.  CNTt,n
        71.  On

        72.  SB

        73.  AE

        74.  PS
Ultraviolet Radiation

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

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

Other, where n = Footnote number

Settling Basin

Aeration

Precipitation with Sulfide
                                  266

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                                        TABLE VI1-2

                              SUMMARY OF ANALYTICAL DATA FROM
                                   TOXIC POLLUTANT STUDY
                         COLD FORMING  - COLD WORKED PIPE AND  TUBE
                                       (USING WATER)	
Raw Wastewater
    Reference Code
    Plant Code
    Sample Point
    Applied Flow (GPT)
120 Copper
124 Nickel
128 Zinc
                                    256F (04-06)
                                        331A
                                         B
                                        Unk
                                mg/1       lbs/1000 Ibs
                                 856Q-03
                                  336A
                                    E
                                   Unk
0.044           Unk
0.050           Unk
0.387           Unk
mg/1 lbs/1000 Ibs
0.095
<0.050
0.073
Unk
Unk
Unk
                                                                                 Average
                                                                                        (1)
                                                                                    0.070
                                                                                    0.025
                                                                                    0.230
Effluent
    Reference Code
    Plant Code
    Sample Point
    Discharge Flow (GPT)
    C&TT
120 Copper
124 Nickel
128 Zinc
                                    256F (04-06)
                                        331A

                                          0
                                         SS
                                 mg/1
                                 856Q-03
                                   336A
                                    G
                                   Unk
                             PSP,  CNT  2(Unk),
           	        SS, SL(UNK)
           lbs/1000 Ibs    mg/1     lbs/1000  Ibs
                                                          0.113
                                                          0.050
                                                          0.072
                                       Unk
                                       Unk
                                       Unk
Unk: Unknown
    : Zero discharge of pollutants to navigable waters.

(1) The less than value was included in the average calculation as a zero.
                                           267

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                       COLD FORMING SUBCATEGORY

                      COLD WORKED PIPE AND TUBE

                             SECTION VIII

             COST, ENERGY, AND NON-WATER QUALITY IMPACTS
Introduction

This section addresses the cost, energy, and non-water quality impacts
of  applying  different levels of pollution control technology to cold
worked pipe and tube operations.  The following topics are  discussed:
actual  treatment  costs  incurred  by plants surveyed;  the treatment
technologies and systems recommended for use in the cold  worked  pipe
and  tube  subdivision;   and  the  cost,  energy, and other non-water
quality impacts associated with the  application  of  BPT,  BAT,  BCT,
NSPS,  PSES,  and  PSNS.  In addition, the consumptive use of water is
addressed.

Actual Costs Incurred
At the Plant Surveyed for This Study

The water pollution control costs for the plants surveyed during  this
study  are  presented  in Table VIII-1.  These costs were derived from
data presented in  response  to  the  D-DCPs.   The  costs  have  been
adjusted to July 1978 dollars.

Control and Treatment Technology

The  treatment  components  and  systems  considered by the Agency are
presented in Tables VIII-2 and VIII-3.  These tables provide  a  basic
summary  of  the  treatment  technologies which comprise the treatment
models for the cold worked pipe  and  tube  subdivision  of  the  cold
forming subcategory.

The following items are described for each step:

1 .    Description of treatment and/or control methods
2.    Implementation time
3.    Land requirements

Figure VIII-1 illustrates the alternative treatment  system  developed
for  cold worked pipe and tube operations using water.  For operations
using oil, the alternative treatment systems are presented in  Figures
VIII-2 and VIII-3.

Cost, Energy, and Non-water Quality Impacts

The  installation  of  BPT, BCT, BAT, NSPS, PSES, and PSNS systems may
require additional  investmant and energy consumption  and  may  affect
                                    281

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solid  waste  disposal  and  water  consumption.  The Agency estimated
costs and energy requirements on the basis  of  alternative  treatment
systems  developed  in Sections IX through XIII of this report.  These
costs and energy requirements are presented in this section.

Estimated Costs for the
Installation of Pollution Control Technologies

A.   Cost Required to Achieve the BPT Limitations

     In order to develop BPT compliance costs,  the  Agency  developed
     BPT  model  treatment  systems  sized for the average cold worked
     pipe and tube plants found in  the  United  States.   Because  of
     different  flow  rates,  separate  models  were necessary for the
     water and soluble oil mill processes.  The model sizes (tons/day)
     were developed on the basis of the average production  capacities
     of  water  and  soluble  oil plants.  The treatment model applied
     flows were also developed using industry average flow rates.  The
     components and effluent flows discussed in Section IX  were  then
     used to complete the development of the treatment models.

     The BPT model costs are presented in Tables VII1-4 and VII1-5 for
     the  pipe  of  tube mills using water and oil, respectively.  Not
     all plants will incur all of these  cost  outlays,  as  many  are
     already  operating  at  or  near  BPT.   The  industry-wide  cost
     represents the sum of the costs for the  individual  mills.   The
     costs  for  the individual mills were calculated by adjusting the
     model costs to the size of mill using the 0.6 rule.

     The Agency estimates the capital costs of the BPT model treatment
     system for all cold worked pipe and tube plants using water to be
     $4.06 million.  Of this total,  $3.30  million  is  for  treatment
     facilities  in-place  as  of  July 1981,   and  $0.76  million  is
     associated with treatment which remains  to  be  installed.   The
     estimated   industry-wide   annual   cost   to  achieve  the  BPT
     limitations  for  cold  worked  pipe  and  tube   (using   water)
     wastewaters  is  $0.53  million.   The annual cost associated with
     the treatment facilities  remaining  to  be  installed  is  $0.10
     million.

     The   Agency   estimates  the  capital  costs  to  meet  the  BPT
     limitations for all of the cold worked pipe and tube plants using
     soluble oil solutions to be $3.09 million.   All of the  necessary
     treatments  technology  except  for  $0.02   million  is currently
     in-place.   The estimated industry wide annual operating  cost  of
     the  BPT limitations for cold worked pipe and tube (using -soluble
     oil solutions) wastewaters is $0.40 million.   Costs for  contract
     disposal   of  the  waste oil  solutions are  included in the annual
     costs.
                                    282

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B.   Costs Required to Achieve the BAT Limitations

     No BAT alternative treatment systems were evaluated for the  cold
     worked  pipe of tube subdivision.  The BPT model treatment system
     achieves zero discharge.  Since these wastewaters  contain  toxic
     organic  and  metal  pollutants  zero  discharge  has  also  been
     promulgated as the BAT limitation.  No additional cost beyond BPT
     will be required.  The BPT model costs are  presented  in  Tables
     VIII-4 and VIII-5.

C.   Cost Required to Achieve the BCT Limitations

     The BCT limitations for both types of cold worked pipe  and  tube
     plants   are   equal   to   the  corresponding  BPT  limitations.
     Therefore, no additional costs beyond BPT will be incurred.

D.   Costs Required to Achieve NSPS and PSNS

     New source performance standards and pretreatment  standards  for
     new sources apply to those facilities which are constructed after
     the proposal of these standards,  NSPS and PSNS for pipe and tube
     operations  using  water have been established at zero discharge.
     On a model"plant basis, the estimated capital cost  of  NSPS  and
     PSNS  technology is $0.50 million.  The corresponding annual cost
     is approximately $0.06 million.

     The Agency  considered  two  alternative  treatment  systems  for
     plants  using  soluble  oil  solutions.  The first alternative is
     identical to the corresponding BPT model treatment system.  On  a
     model  plant  basis,  the estimated capital cost of NSPS and PSNS
     technology  is  $0.42  million,  while   the   annual   cost   is
     approximately $0.06 million.  The second alternative is discussed
     in   Section   XII.   The  corresponding  model  costs  for  this
     alternative are presented in Table  VIII-5.   The  total  capital
     cost for this alternative is $0.66 million and the annual cost is
     $0.09 million.

E.   Costs Required to Achi€»ve PSES

     For  the  reasons  set  out  in  Section  XIII,  the  Agency   is
     establishing pretreatment standards at zero discharge.  The model
     treatment  costs  are  presented  in Tables VIII-4 and VIII-5 for
     mills using water and oil,  respectively.   Since  there  are  no
     existing  cold  worked  pipe  and  tube operations using oil that
     discharge to POTWs, there are no industry-wide costs for PSES.

     For those operations using water and discharge to POTWs the total
     capital expenditures are $0.09 million all of which  is  in-place
     as  to July 1981.  The annual costs associated with these capital
     expenditures amount to $0.01 million.
                                    283

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Energy Impacts

Moderate amounts of energy are  required  by  the  various  levels  of
treatment for cold worked pipe and tube operations.  All of the energy
expenditures  occur  at the BPT treatment level for those plants using
water and for those plants using soluble oil solutions  which:  dispose
of  wastewaters  by contract hauling.  For new plants using oil/ which
treat  wastewaters  rather  than  haul  off-site,  the  major   energy
expenditures will occur at the NSPS and PSNS levels of treatment.

A.   Energy- Impacts at BPT

     The estimated energy requirements are based upon  the  assumption
     that  treatment systems similar to the treatment models presented
     in this report are installed.  On this basis/ the energy use  for
     the BPT model treatment system for all pipe and tube plants using
     water  is  estimated at 104,000 kilowatt-hours of electricity per
     year.  Similarly/ the energy use  for  the  BPT  model  treatment
     system  for  all pipe and tube plants using soluble oil solutions
     is estimated at 152,000 kilowatt-hours of electricity  per  year.
     Both  estimates  are  insignificant  compared  to  the 57 billion
     kilowatt-hours used by the steel industry in 1978.

B.   Energy Impacts at BAT

     As the BAT alternative treatment system for pipe and tube  plants
     using  water  and those using soluble oil solutions are identical
     to the corresponding  BPT  model  treatment  systems,  no  energy
     expenditures in excess of those incurred at BPT are required.

C.   Energy Impacts at BCT

     As the BCT alternative treatment systems for  mills  using  water
     and  mills  using  oil  are  identical  to  the corresponding BPT
     models/ no energy expenditures in excess of those incurred at BPT
     are required.

D.   Energy Impacts at NSPS and PSNS

     The Agency did not estimate the subdivision-wide  energy  impacts
     for NSPS and PSNS since a determination of the number of new pipe
     and  tube  plants  which  will be installed in the future was not
     made as part of this study.

     For those  pipe  and  tube  plants  using  water,  NSPS  is  zero
     discharge.   The  model  treatment system is identical to the BPT
     model treatment system for mills using water.  On a  model  plant
     basis/  this  treatment  model  will  use 8,000 kilowatt-hours of
     electricity per year.
     For those pipe and tube plants using soluble oil  solutions,
     energy requirements for the two NSPS/PSNS alternatives are:
the
                                    284

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     Model

     NSPS and PSNS 1

     NSPS and PSNS 2

E.   Energy Impacts at PSES
kw-hr per year

      8,000

     44,000
     For pipe and tube plants using soluble oil  solutions,  the  PSES
     energy  requirements   (on  a  model  plant  basis)  would be 8000
     kilowatt-hours per year.  The energy  usage  for  pipe  and  tube
     plants  using  water   is the same.  Based upon these model energy
     requirements, it  is   estimated  that  16,000  kilowatt-hours  of
     energy  will  be  expended  by  those operations using water.  No
     energy will be required by those operations using oil since there
     are no operations discharging to POTWs.

Non-water Quality Impacts

In general, the Agency expects  that  the  non-water  quality  impacts
associated  with  the  alternative  treatment systems will be minimal.
The three impacts evaluated are air pollution, solid  waste  disposal,
and water consumption.

A.   Air Pollution

     No air pollution impacts are expected to occur  for  cold  worked
     pipe  and  tube  mills  as  a  result  of the installation of the
     treatment models.

B.   Solid Waste Disposal

     The treatment steps included in the BPT model  treatment  systems
     will  generate  quantities  of  solids  and  oils and greases.   A
     summary of the solid waste  generation  for  all  pipe  and  tube
     operations at the BPT level of treatment follows.
     Treatment Level

     BPT Using Water

     BPT Using Soluble Oils
      Solid Waste Generation
Cold Worked Pipe and Tube Plants
	(Tons/Year)	;

              1,820

              7,980
     The  BAT  level of treatment for cold worked pipe and tube plants
     will not generate additional  solid  waste  beyond  the  quantity
     generated at BPT.

     PSES for both types of cold worked pipe and tube plants have been
     set  at  zero  discharge.    The  model  pretreatment systems will
     generate 140 and 420 tons/year  of  solid  waste  for  operations
     using water and oil, respectively.
                                   285

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     The  estimated  amounts of solid wastes generated by the NSPS and
     PSNS model treatment systems for cold worked pipe and tube  mills
     are as follows:
     Treatment Level
    Solid Waste Generation
       Treatment Model
    	(Tons/Year)	
     NSPS and PSNS (using water)
     NSPS and PSNS 1  (using oil)
     NSPS and PSNS 2 (using oil)

C.   Water Consumption
            140
            420
            480
     No significant water consumption is expected to  occur  for  cold
     worked pipe and tube mills as a result of the installation of the
     treatment systems considered by the Agency.

Summary of Impacts

The  Agency  concludes  that the effluent reduction benefits described
below for the cold worked  pipe  and  tube  subdivision  outweigh  the
adverse  impacts  associated  with  energy consumption, air pollution,
solid waste disposal, or water consumption.

                                 Direct Dischargers
                     	Effluent Loads (Tons/Year)	
      Using Water

     Flow, MGD
     TSS
     Oil & Grease
     Toxic Metals
     Toxic Organics
                               Raw Waste
       19.2
      522
    1,357
        6.8
        0
      Using Soluble Oil Solutions
     Flow, MGD
     TSS
     Oil & Grease
     Toxic Metals
     Total Organics
       24.5
   26,546
2,654,638
      220
       20.4
                       BPT/BCT/BAT
0
0
0
0
0
0
0
0
0
0
                                   286

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                           Indirect Dischargers
                       Effluent Loads (Tons/year)
Using Water

Flow, MGD
TSS

Oil & Grease
Toxic Metals
Toxic Organics
Raw Waste

   3.0
  80.3

 209
   1.0
   0
PSES

  0
  0

  0
  0
  0
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.                                            :
                              287

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                      TABLE VIII-1

                EFFLUENT TREATMENT COSTS
                COLD FORMING SUBCATEGORY
COLD WORKED - PIPE AND TUBE (USING SOLUBLE OIL SOLUTIONS)

     (All costs are expressed in July,  1978 dollars)
       Reference No.                      0240B

       Initial Investment Cost            13,390

       Annual Costs
         Cost of Capital                   1,340
         Depreciation                        670
         Operation and Maintenance           235
         Energy, Power, Chemicals, etc.       35
         Other                               210

       TOTAL                               2,490

       $/Ton                                1.93
       Note:  All cost values were taken from the D-DCP.
                            288

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                                        TABLE VIII-2

                             CONTROL AND TREATMENT TECHNOLOGIES
                                  COLD FORMING SUBCATEGORY
                                 COLD WORKED-PIPE AND TUBE
                                        (USING WATER)
C & TT
Step
A
Description
SCALE PIT WITH

CLAM SHELL - provides
Implementation
Time (Months)
6-8
Land
Usage .(ft*)
625
B
for primary settling of suspended
particles.  Settled solids are
removed by clam shell

SURFACE SKIMMER - removes floating oils
and greases from the wastewater surface.

RECYCLE - returns the wastewater to the
process.
                                                        12-14
No additional
land required

625
                                          289

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                                        TABLE VII1-3

                             CONTROL AND TREATMENT TECHNOLOGIES
                                  COLD FORMING SUBCATEGORY
                                 COLD WORKED PIPE AND TUBE
                                    (USING SOLUBLE OILS)
C & TT
Step
Description
H
SCALE PIT WITH CLAM SHELL - provides
for primary settling  of  suspended
particles.  Settled solids are
removed by clam shell.

SURFACE SKIMMER - removes floating
tramp oils and greases from the
wastewater surface.

RECYCLE - returns virtually all  the
wastewater to the process.

STORAGE TANK AND CONTRACTOR REMOVAL -
spent oil solutions are  stored and
hauled off-site as required.

EQUALIZATION TANK - collects and
stores the wasteload  for future
batch treatment.

ACID ADDITION - acid  is  added to a.
reactor vessel to break  the oil emulsion.

ALUM ADDITION - alum  is  used in conjunc-
tion with Step E to aid  in breaking the
oil emulsions.

LIME ADDITION - lime  neutralizes the
wastes in the flocculator mixing tank.

POLYMER ADDITION - polymer is added to
the waste solution in conjunction with
Step G to promote settling.

AIR FLOTATION - forces suspended and
oily materials to rise to the surface
where they can be removed from the
wastewater.
Implementation
Time (Months)

  6-8
                                                        12-14


                                                        6-8
Land
Usage (ft )

  625
                   No additional
                   land required


                     625


                     400
                                          290

-------
TABLE VII1-3
CONTROL AND TREATMENT TECHNOLOGIES
COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
(USING SOLUBLE OILS)
PAGE 2
          SETTLING BASIN - additional suspended
          solids reduction is accomplished.

          FILTRATION - effluent from Step J is
          passing through a filtration unit to
          further reduce suspended matter.
*:
Since the wasteload is so small, implementation time and land usage
for Steps E through L have been combined.  They total approximately
one year and 2500 ft .
                                           291

-------
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-------
                       COLD FORMING SUBCATEGORY

                      COLD WORKED PIPE AND TUBE

                              SECTION IX

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

Upon  reevaluation  of  pipe  and  tube  operations,  the  Agency  has
concluded  that  the  Best  Practicable  Control  Technology Currently
Available (BPT) limitations originally promulgated for  the  pipe  and
tube  subcategory  are  not  appropriate for cold worked pipe and tube
operations.   As explained previously, the  original  limitations  were
developed  based  primarily upon hot forming pipe and tube operations.
The BPT limitations for cold  worked  pipe  and  tube  operations  are
reviewed below.

Identification of BPT

Based  upon  the information contained in Sections III through VIII of
this report, the BPT model treatment systems for the cold worked  pipe
and tube subdivision are as follows.

A.   Cold Worked Pipe and Tube Plants Using Water

     The BPT model treatment  system  includes  settling  of  the  raw
     wastewater  in  a  primary  scale  pit equipped with oil skimming
     equipment.  All of the treated wastewater  is then recycled to the
     process.  This system achieves zero wastewater discharge  and  is
     illustrated  in Figure-IX-1.  Forty percent of the water solution
     plants reporting flow data  achieve zero discahrge.

B.   Cold Worked Pipe and Tube Plants Using Soluble Oil Solutions

     The BPT model treatment system  includes settling of the raw waste
     solution  in a  primary  scale  pit  equipped  with  oil  skimming
     equipment  which  removes tramp oils.  Nearly all of the solution
     is  then  recycled  to  the process.   The  spent  solution   is
     periodically  removed  by   a  contract hauler so that  there is no
     discharge to navigable  waters.   Ninety-five  percent of  those
     mills  using oil solutions  achieve zero discharge.  The treatment
     system described is illustrated in Figure  IX-2.

     The Agency  considered  treatment  and  discharge   (to navigable
     waters)   of  the  blowdown   (0.5  gal/ton)  from  mills using oil
     solutions.  The treatment considered  consists  of batch treatment
     on  a  weekly  basis   in  a dissolved air  flotation sytstem.  The
                                    299

-------
      capital and annual costs (see NSPS discussions in  Sections  VIII
      and  XII)  for  this  system  significantly exceeded the cost for
      disposal by contract hauling.  For this reason, and the fact that
      zero discharge is achieved at 95% of the plants in  the  industry
      (79%  by  contract  hauling), the Agency decided not to establish
      the BPT model treatment system on  the  basis  of  treatment  and
      discharge.

      The  BPT limitations do not require the installation of the model
      treatment systems.   Any treatment which achieves the  limitations
      is acceptable.

 Rationale for BPT Treatment Systems

 As   noted  in  Section  VII,   each  of the components in the BPT model
 treatment  systems  is  demonstrated  at  a  number  of   cold   worked
 operations.

 Justification of. the BPT Limitations

 The BPT limitation for cold worked pipe  and tube plants  using water  is
 ??r?^   discharge.    Demonstration  of   the achieveability of  this
 limitation  is presented  in  Table  IX-1.

 The discharge flow of  0.5 gal/ton,  from   cold  worked  pipe   and  tube
plants   using soluble  oils,  is   periodically  hauled  off-site  for
disposal, so  there is  no discharge  from   cold  worked   operations   to
navigable  waters.   Approximately  79%  of  the cold worked pipe and  tube
plants  using  soluble oils presently  have  spent  oil  solutions   hauled
off-site  for  disposal.   An additional  16% achieve zero discharge  by
other means,  e.g.,   land  application  of   the  spent  oil   solutions.
Incineration   is   another  method  of  disposing of spent oil solutions
which achieves the zero discharge  limitation.  A  list  of   those  oil
         ?v achieving  the BPT limitation  (zero discharge) is presented
         IX—2.
                                   300

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                               TABLE IX-1

                JUSTIFICATION OF BPT EFFLUENT LIMITATIONS
                        COLD FORMING SUBCATEGORY
                        COLD WORKED PIPE AND TUBE
                              (USING WATER)	'
BPT Effluent Limitations - -

Mills Achieving Limitations

0256F (04-06)*
0060P (01-09)
0908
0908A (01-02)
Zero Discharge
              Basis
             Visit
             DCP
             DCP
             DCP
*  Sampled Plant Code 331A
                                       301

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                                TABLE IX-2

                 JUSTIFICATION OF  BPT  EFFLUENT LIMITATIONS
                         COLD FORMING SUBGATEGORY
                         COLD  WORKED PIPE AND TUBE
                	' (USING OIL SOLUTIONS)
BPT Effluent Limitations
                                         Zero Discharge
Mills Achieving Limitations
                           Sampled Plant
                               Code
                                                         Basis
0060
0080A
0240B
0240C
0256F
0432A
0548C
0636
0648K
0684L
0684M
0684N
0684W
0856N
0856Q
0916A
(01-03)
(01-05)
(01-04)
(01-03)
(05)
(01-03)
(01-04)
(01-15)
(01-04)
(01-06)
(01-08)
(01-02)
(02)
338

331B




332
                           335
                           336B
DCP
DCP
Visit
DCP
Visit
DCP
Visit
DCP
DCP
Visit
DCP
DCP
DCP
Visit
Visit
DCP
                                     302

-------
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                       COLD FORMING SUBCATEGORY

                      COLD WORKED PIPE AND TUBE

                              SECTION X

                 EFFLUENT QUALITY ATTAINABLE THROUGH
           THE APPLICATION OF THE BEST AVAILABLE TECHNOLOGY
                       ECONOMICALLY ACHIEVABLE
The Best Available Technology Economically Achievable  (BAT)  effluent
limitations  are to be attained by July 1, 1984.  BAT is determined by
reviewing subcategory practices and identifying the best  economically
achievable  control  and  treatment  technologies  employed within the
subcategory.  In addition, a technology that is  readily  transferable
from another subcategory or industry may be identified as BAT.

Since   toxic   metals   are  present  in  significant  quantities  in
wastewaters from cold worked pipe and  tube  mills  using  water,  the
Agency has also estalished BAT at zero discharge.  This is the same as
the  BPT  limitation.   The  model  treatment system is illustrated in
Figure IX-1.

Toxic organic and toxic metal pollutants are  present  in  significant
quantities  in  wastewaters from cold worked pipe arid tube mills using
oil.  The Agency has, therefore, established  ®AT _as^ ;zefp  discharge.
which  is  the  same  as  the  BPT limitation.  In the BAT  (BPT) model
treatment system for the  cold  worked  pipe  and  tube  plants  using
soluble  oil  solutions   (Figure  IX-2), most of the waste solution is
recycled, with a  small  amount  collected  by  contract  haulers  for
off-site  disposal.   Disposal  of these waste solutions could also be
accomplished through incineration.
                                     305

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                       COLD FORMING SUBCATEGORY

                      COLD WORKED PIPE AND TUBE

                              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.  In  no
case may BCT be less stringent than BPT.

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.)

BCT Limitations

The BCT model treatment system for cold worked pipe  and  tube  plants
using  water,  (illustrated in Figure IX-1), achieves zero discharge by
recycling 100% of the process  water.   In  the  BCT  model  treatment
system,  for  cold  worked  pipe  and  tube  plants  using soluble oil
solutions, (illustrated in Figure IX-2) the spent  oil  solutions  are
hauled off-site.  Thus, there is no discharge of wastewaters.

Because  the  BPT limitations for these operations are zero discharge,
the Agency has established the  BCT  limitations  at  zero  discharge.
Accordingly,  there  are  no  additional costs incurred for compliance
with the BCT limitation over that for BPT.
                                     307

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                       COLD FORMING SUBCATEGORY

                      COLD WORKED PIPE AND TUBE

                             SECTION XII

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

The effluent standards which must be achieved by new  sources  specify
the degree of effluent reduction achievable through the application of
the  Best  Available Demonstrated Control Technology (BDT), including,
where applicable, a standard permitting no  discharge  of  pollutants.
This  section  identifies the alternatives considered for NSPS and the
resulting effluent levels for cold worked pipe  and  tube  operations.
In  addition,  the  rationale  for  selection  of  the  NSPS treatment
systems, flow values, and effluent standards are presented.

Identification of NSPS

Pipe and Tube Plants Using Water

The NSPS model treatment system for plants using water is identical to
the BPT model treatment system corresponding  to  those  same  plants.
This  system, which is illustrated in Figure IX-1, consists of a scale
pit, oil skimmer, and recycle mechanism.  As this is a  total  recycle
system, there is no .discharge.

Pipe and Tube Plants Using Soluble Oil Solutions

A.   NSPS Alternative 1

     The first NSPS alternative treatment system considered for plants
     using oil solutions is  identical  to  the  BPT  model  treatment
     system.   This  system,  which  is  illustrated  in  Figure IX-2,
     consists of a scale pit, oil skimmer, and recycle mechanism.  The
     entire process flow, except for 0.5 gal/ton, is recycled  to  the
     process.   The  0.5  gal/ton  of  spent oil solution is sent to a
     storage tank.   The  solutions  are  removed  from  the  tank  by
     contract  hauler  as  required.   Thus there is no discharge from
     cold worked operations with this alternative

B.   NSPS Alternative 2

     In  response  to   industry   comments,   an   NSPS   alternative
     incorporating   treatment  and  discharge  of  the  oil  solution
     blowdown was considered by the Agency (Figure VII1-3).   In  this
     alternative,  the  oil solutions pass through a scale pit with an
     oil skimmer.  Most of the oil is recycled to the process with 0.5
                                   309

-------
      gal/ton directed to an equalization and storage tank, with a  one
      week  detention  time.   The  spent  oils  are treated in a batch
      treatment system on a weekly basis.  The flow  rate  through  the
      batch  treatment  system  is  only  2.0 gal/min for an eight hour
      treatment cycle .   The first component in.  this  batch  treatment
      system  is  a  reactor into which acid and alum are added.  These
      chemicals are  added  to  break  the  oil  emulsions.   Lime  and
      polymer/polyelectrolyte  are  then  introduced  in a flocculator.
      The    lime    neutralizes    the     solution,     while     the
      polymer/polyelectrolyte   is  used  to  coagulate  the  oils  and
      suspended solids.   The wastewaters are then  treated  in  an  air
      flotation  unit  to  remove the suspended and oily meterial.  The
      floated wastes are skimmed off the surface  and the heavier sludge
      is drawn off the bottom  of  the  flotation  unit.   The  treated
      effluent   is  then  discharged  to  a  receiving  stream.   This
      alternative treatment system is commonly used in this  and  other
      industries  to  treat oily wastes.   The technology is used as the
      BPT (BCT and BAT)  model treatment system  for  the  cold  rolling
      subdivision of the cold forming subcategory.

Rationale for Selection of NSPS

Treatment Systems

The NSPS-alternative treatment systems considered  for cold worked pipe
and   tube  operations  are  presently  in  use  in this subdivision or
commonly used at  similar  operations  in  other  cold  worked  metals
manufacturing processes.

Flows

The   applied   and discharge flows (zero  discharge)  developed  for these
NSPS  models are representative of actual flows found  in  cold  worked
pipe  and  tube  plants.   Process information provided by the industry
for these plants was used  in   developing  the  average  values.    The
attainment of  zero discharge  in  this subdivision  is well demonstrated
as discussed  in Section IX.

Selection of  NSPS Alternative

Pipe  and  Tube Plants Using  Water

There is  only one NSPS  treatment  system  considered,  which  is  a  zero
discharge   system.   Zero  discharge  is also  established at BPT and BAT,
and is well demonstrated.   That system is illustrated  in Figure IX-1.

Pipe and  Tube Plants Using  Oil                                ,

Alternative 1,  which  is  also  based upon   zero   discharge,   is  the
selected NSPS alternative for plants  using soluble  oil  solutions.   The
NSPS  model   treatment  system  is   illustrated  in  Figure  IX-2.   This
alternative was  selected  because  zero discharge  is  achieved at  95%  of
the   existing    oil    solution   plants.   This  requirement   is   also
                                    310

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established at BPT and BAT.  Moreover, the capital  and  annual  costs
associated with this model treatment system is significantly less than
the costs for Alternative 2, which is based on treatment and discharge
of the spent oil solutions.

Demonstration of NSPS

Tables  IX-1,  for  water,  and  IX-2, for oil, present lists of those
plants that demonstrate NSPS for cold worked pipe and tube operations.
                                    311

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                       COLD FORMING SUBCATEGORY

                      COLD WORKED PIPE AND TUBE

                             SECTION XIII

               PRETREATMENT STANDARDS FOR COLD WORKING
           PIPE AND TUBE OPERATIONS DISCHARGING TO PUBLICLY
                        OWNED TREATMENT WORKS
Introduction

This section presents pretreatment alternatives for cold  worked  pipe
and  tube operations with discharges to publicly owned treatment works
(POTWs).  Consideration has been given to  the  pretreatment  of  cold
worked  process  waste  solutions  from  new  sources  (PSNS) and from
existing sources (PSES).

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/1 (January 28, 1981).  See also 46 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 cold worked pipe and tube
operations, the Agency considered the objectives and  requirements  of
the  General  Pretreatment  Regulations.   The  Agency determined that
uncontrolled discharges of cold worked pipe and  tube  wastewaters  to
POTWs would result in pass through of toxic pollutants.

Identification of_ Pretreatment Alternatives

A.   Pipe and Tube Plants Using Water

     Available data demonstrate that many cold worked operations using
     water have total recycle systems, while  very  few  discharge  to
     POTWs.    Toxic   metal   pollutants  are  .found  in  significant
     quantities in_these_wastewaters.As  a-result  the  Agency  has
     promulgated PSESZand-PSNS as zero discharge, which is the same as
     BAT.   As  shown is Section'IX'the' achievability of this standard
     is well demonstrated.

B.   Pipe and Tube Plants Using Soluble Oil Solutions

     Waste  oil  solutions  from  most  plants  are  currently  hauled
     off-site  fqr  disposal  by  contractors.    None  of these plants
     discharge spent oil solutions to a POTW.  To  insure  that  these
     solutions,  which  may  contain large quantities of toxic organic
                                    313

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     and  metal  pollutants  and  emulsified  oils  not  treatable  by
     municipal  systems,  do  not pass through POTWs, a zero discharge
     standard  has  been  promulgated  for  these  operations.    This
     requirement  is the same as that established at BAT.  As shown in
     Section  IX  the  achieveability  of  this   standard   is   well
     demonstrated.

For PSNS the Agency evaluated a second alternative pretreatment system
which  is  identical  to  NSPS  Alternative  2.  In this alternative a
discharge is  allowed.   However,  the  Agency  did  not  select  this
alternative  since the selected zero discharge alternative is feasible
and well demonstrated.  In addition, the  zero  discharge  alternative
requires  less  capital  and  annual costs.  This is discussed in more
detail in Section XII.

The removal of toxic metal pollutants for the selected PSES  and  PSNS
alternatives are compared to POTW removal rates for these metals:
     Copper
     Nickel
     Zinc
PSES/PSNS

   100%
   100%
   100%
POTW

 58%
 19%
 65%
As  shown  above, the selected PSES and PSNS Alternatives will prevent
pass through of toxic metals at POTWs compared to untreated discharges
of cold worked pipe and tube wastewaters 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.
                                  314

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                    ALKALINE CLEANING SUBCATEGORY

                              SECTION I

                               PREFACE
The USEPA has promulgated effluent limitations and standards  for  the
steel  industry pursuant to Sections 301, 304, 306, 307 and 50] of the
Clean  Water  Act.   The  regulation  contains  effluent   limitations
guidelines 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).

This part of the Development Document highlights the technical aspects
of EPA's study of the Alkaline Cleaning 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.
                                    315

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                    ALKALINE CLEANING SUBCATEGORY

                              SECTION II

                             CONCLUSIONS
Based upon  information  and  data  obtained  during  this  study  and
previous  studies,  and information obtained during the public comment
period, the Agency has reached the following conclusions.

1.    Untreated  alkaline   cleaning   wastewaters   do   not   contain
     significant  levels  of  toxic,  conventional, or nonconventional
     pollutants.  However, since these wastewaters are co-treated with
     other steel finishing wastewaters, the Agency has promulgated BPT
     limitations for alkaline cleaning operations for total  suspended
     solids,  oil  and grease, and pH that are consistent with the BPT
     limitations for these pollutants for steel finishing  operations.
     Since  the BPT level of treatment provides adequate controls, the
     Agency has not promulgated more stringent  BAT  limitations.   In
     addition,  the  Agency has not established pretreatment standards
     for new and existing sources.

2.    Alkaline cleaning operations are conducted on both  a  batch  and
     continuous  basis.  The Agency believes that it is appropriate to
     subdivide the subcategory on that basis for existing sources (BPT
     and BCT).  However, the  Agency  has  determined  that  the  same
     effluent flow rates and effluent quality can be achieved for both
     batch  and  continuous  new  source  operations,  and  NSPS  were
     promulgated on that basis.

3.    The model  treatment  system  used  as  the  basis  for  the  BPT
     limitations  promulgated in 1976 for alkaline cleaning operations
     has not been changed.  The model  treatment  system  consists  of
     equalization,  oil  separation,  polymer  and  acid  addition and
     sedimentation.  Sludges are dewatered with vacuum filters.   This
     model  treatment  system  is  consistent with the model treatment
     systems for other finishing operations.

4.    The Agency has not promulgated effluent limitations and standards
     for dissolved chromium, nickel, and iron.  These pollutants  were
     limited  in  the  originally  promulgated  BPT  regulation.  Data
     gathered for this study demonstrate  that  these  pollutants  are
     found  only  at low concentrations in untreated alkaline cleaning
     wastewaters.

5.    Based upon facilities in  place  as  of  July  1981,  the  Agency
     estimates the following costs will be incurred by the industry to
     bring  alkaline  cleaning operations into compliance with the BPT
     limitations:
                                   317

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                   Costs  (Millions of July  1,  1978 Dollars)
6.
7.
8.

Total
$12.3
Investment
Required
$ 0.6
Costs
In-Place
$11 .7
Annual Costs
Total Required In-Place
$1.7 $0.1
$1 .6
BPT

These costs are based upon  more  costly  separate  treatment  of
alkaline  cleaning  wastewaters,  although  central  treatment of
alkaline  cleaning  wastewaters  is  practiced   throughout   the
industry.

The Agency has promulgated BCT effluent limitations for  alkaline
cleaning  operations  that  are  identical  to  the  BPT effluent
limitations.  No additional treatment beyond BPT is required.

The Agency has promulgated NSPS for alkaline cleaning  operations
based  upon  best  demonstrated flows and the BPT model treatment
system effluent quality.
With respect to the "remand issues/' the Agency has
following conclusions.
reached  the
     a.   The ages of alkaline cleaning lines do not affect  the  ease
          or  cost of retrofitting pollution control equipment.  Thus,
          less stringent effluent limitations and standards  were  not
          promulgated for "older" alkaline cleaning lines.

     b.   The Agency examined the consumptive use of  water  resulting
          from compliance with the effluent limitations and standards.
          Since evaporative cooling systems are not included in any of
          the   model   treatment   systems,   compliance  with  these
          requirements will result in  little  or  no  consumption  of
          water.


9.    Table II-l  presents the treatment model  flow,  effluent  quality
     data,  and the BPT effluent limitations for the alkaline cleaning
     subcategory.  Table ,11-2  presents  the  treatment  model  flow,
     effluent  quality data, and the BCT effluent limitations and NSPS
     for the alkaline cleaning subcategory.
                                    318

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                    ALKALINE CLEANING SUBCATEGORY

                             SECTION III

                             INTRODUCTION
General Discussion

Alkaline cleaning is that process in which steel products are  cleaned
prior  to  entering  other finishing operations such as hot coating or
electroplating.  Although several cleaning solutions are used  in  the
cleaning  baths, most operations have similar operating and wastewater
characteristics.

Since the cleaning  solutions  used  for  alkaline  cleaning  are  not
aggressive,  high  levels  of  pollutants are not generated.  The most
significant  pollutants  contributed  by  the  process  are  suspended
solids,  oil  and  grease,  and  relatively  low  levels of some toxic
metals.  These pollutants originate in the alkaline cleaning bath  and
in the rinsing steps which usually follow the cleaning bath.

Almost  all  alkaline cleaning operations are included in larger steel
finishing mills.  For example,  an  alkaline  cleaning  operation  may
precede  a  pickling operation which may in turn precede a hot coating
operation.  While the entire steel finishing operation may be operated
in an integrated manner, finishing operations have been subcategorized
in  such  a  way  that  appropriate  effluent  limitations  could   be
established  for  each  discrete operation.  This procedure allows for
consideration of  plant-specific  process  configurations  during  the
preparation of NPDES permits.

Alkaline  cleaning  operations  are  conducted  in  both the batch and
continuous modes.  These operations are illustrated in  Figures  III-1
and  III-2  which  also  detail  complete  finishing operations (i.e.,
cleaning, pickling).  The information developed and presented in  this
report applies only to alkaline cleaning operations.

Development of Limitations

Effluent  limitations  applicable to alkaline cleaning operations were
previously promulgated on March 29, 1976 for total  suspended  solids,
dissolved  iron,  dissolved  chromium,  dissolved nickel, and pH.  For
this study, the Agency  conducted  additional  sampling  and  gathered
detailed  information  from  the steel industry to provide an expanded
data base.  The primary source of new information  is  the  industry's
response  to  the  basic  data collection portfolios (DCPs) which were
sent to approximately 85% of the active alkaline  cleaning  operations
in  the  United  States.   Information  was  provided for 176 alkaline
cleaning operations through the DCP responses.  The data for batch and
continuous mills have been tabulated and summarized  in  Tables  III-l
and III-2, respectively.
                                   321

-------
Detailed  data   collection  portfolios   (D-DCPs) were sent  to selected
operations to gather  information  on  long-term  effluent  quality,  cost
information  on   the  wastewater   treatment  systems  installed, and the
cleaning  operation.   Detailed   data   for   twenty   alkaline ; cleaning
operations  at   three plant sites were solicited through D-DCPs.  The
responses provided data to verify cost estimates   and  to establish
retrofit costs.

The  previous  limitations  and   standards   for  the alkaline cleaning
subcategory  were based  solely   upon   data  obtained  through  field
sampling  at  one plant.  The Agency determined that data  obtained at
that plant are not typical of alkaline   cleaning  wastewaters  as  the
sampling  occured during a dump of the  alkaline cleaning bath.  During
this study, two  additional  lines were sampled,  and  the one  line
originally sampled was revisited.  This sampling program increased the
existing  data base for the pollutants  previously limited and provided
data for other   toxic pollutants as   well.   All   alkaline  cleaning
operations  sampled,  with  a basic  description of each, are listed in
Table III-3.  As  shown in Table III-3,  Plant 0432K was  sampled  twice
and  designated   as   Plant  I  on the first  visit and Plant 157 on the
second visit.    The   updated  data  bases  for  this  subcategory  are
presented in Tables II1-4 and II1-5.

Description of Alkaline Cleaning  Operations

Alkaline cleaning is  used where vegetable, mineral and animal fats and
oils  must  be  removed  from  the -  steel  surface  prior   to  further
processing.   Immersion  in   solutions   of   various   compositions,
concentrations, and temperatures  is  often used to achieve the cleaning
process.  Electrolytic cleaning may  be  used  for large scale production
or where a cleaner product is required.  The alkaline cleaning bath is
a  solution  or  dispersion  of   carbonates,  alkaline  silicates  and
phosphates in water.  Wetting agents are often added to  the  cleaning
bath to facilitate cleaning.
                                    322

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                    ALKALINE CLEANING SUBCATEGORY

                              SECTION IV

                          SUBCATEGORIZATION
The  Agency  examined the factors that might affect the subdivision of
the alkaline cleaning subcategory and found  that  only  the  mode  of
operation  (batch  and  continuous) has an impact on existing sources.
Both modes of operation were found to produce the same  pollutants  at
similar  levels.  However, the waste volumes for continuous operations
were found to be greater.  The Agency has  determined  that  the  same
effluent  flow  rates  and  effluent  quality  can be achieved for new
source batch and continuous operations.  Therefore, the  NSPS  is  the
same for both continuous and batch operations.

The  Agency  also  analyzed  other  factors  to  determine  if further
subdivision was appropriate, but none were found to have a significant
effect.  The Agency analyzed the impact of line age, type of  product,
raw  materials, wastewater characteristics, treatability of wastewater
pollutants and the geographic location of the plants.   However,  none
of  these  factors  were  found  to warrant further subdivision of the
alkaline cleaning subcategory.  Each  of  these  factors  is  reviewed
below.

Manufacturing Process and Equipment

The  Agency  examined  differences in the alkaline cleaning operations
which might affect subdivision.  For example, there are  two  ways  in
which the alkaline cleaning process is performed.  The cleaning can be
achieved  in either batch fashion, where the product is moved manually
in and out of cleaning and rinse tanks, or it can be  completed  in   a
continuous  fashion  on  sheet,  strip  or  wire  products.   Alkaline
cleaning operations can also  be   integrated  into  larger  production
lines.   Industry  responses  to   the DCPs show that alkaline cleaning
lines are used in conjunction with  coating,  annealing,,  galvanizing,
plating  and  pickling  lines.   The  Agency  considered whether these
different  types  of  operations   may  affect  the  flow  (applied  or
discharge)  or  wastewater  characteristics  and  thus warrant further
subdivision.   The  Agency  found  that  these   variations   have    a
significant 'effect  on  the effluent volume but not on the pollutants
contained in the process wastewaters.   Batch  operations  have  lower
average  flow  rates  (250  gal/ton)  and  discharge lesser amounts of
pollutants than continuous operations, which have an average discharge
flow of about 350 gal/ton.   No  significant  differences  were  found
among  alkaline  cleaning operations that are part of larger complexes
(Table IV-1).  For these reasons,  the Agency  concluded  that  further
subdivision  of  the existing alkaline cleaning subcategory into batch
and continuous subdivisions, based upon differences  in wastewater flow
rates, is appropriate.
                                    337

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 Final Products

 The products processed in alkaline cleaning operations vary from sheet
 and strip to chain link fence.  The Agency concluded that the  product
 being cleaned does not significantly affect the quality or quantity of
 the  wastewaters generated.  Thus, further subdivision based upon this
 factor is not warranted.

 Three lines were sampled for this study.  While the Agency found  that
 the  wastewater  quality  varied between these lines, these variations
 were not significant.  The concentrations of toxic pollutants remained
 below or near  treatability  levels.    Hence,   even  if  the  type  of
 pollutants  present in the wastewaters from lines processing different
 products varied,  there would be no effect on the  treatment  required,
 the  treatment  system  selected,   or  the ability to achieve the same
 level of treatment.

 The Agency also analyzed the potential for  variations  in  wastewater
 ±low  depending  on  the  final  product  being processed.   The Agency
 originally thought that some of the processed  product shapes (such  as'
 sheet and strip)  might be easier to rinse than other products (such as
 tubes  and wire).   However,  when the  discharge flow data were analyzed
 no significant flow variations related to  product  type  were  found.
  u"yu ^lls  Producing different products achieve the flow values upon
 which the  limitations  and  standards  are based.    These  data  are
 summarized  in Table  IV-1.    For continuous  mills,  strip,  sheet,  and
 wire are the primary  products processed.   Low  discharge flow rates are
 demonstrated for  each.   The Agency found that  the model  BPT  flow  of
 250  gal/ton  for batch mills is demonstrated for all  product types that
 are  batch cleaned.

 The   applied  and   discharge  flow  rates  for wire products  appear  to be
 significantly higher  than  for any  other  product  type,   often   in  the
 range of thousands   of   gallons   per   ton.   The Agency found  similar
 applied  flow rates, on  a gallon per minute  basis,  for  these  lines   as
 found at other  lines.  Due  to the low  tonnage processed  (less than 1
 ton/turn), the flow on  a gallon per ton  basis  is  extremely  high.    The
 cleaning  process at  these  lines is used  intermittently.  As a  result,
 pollutants from the process are generated during  a small   portion   of
 the   eight   hour  turn.   Flow   calculations   are  based upon constant
 production over the eight hour   period.   Thus,   the  results  of   the
 calculations  are   higher  than actual flow rates on a  gal/ton basis.
 The  Agency   could  not  adjust  these  flow    values   due   to    the
 unavailability  of  data  on  the length of  time each alkaline cleaning
 operation was actually  in use.

 The Agency believes that changes in the  operating  practices  at  the
smaller  wire  lines can be implemented.  The cleaning baths and rinse
 tanks should be equipped with product activated flow  or  spray  rinse
valves, so that flows occur only when the tanks are being used.  These
Changes would enable these lines to achieve flow rates comparable with
those  from other lines.  These practices should not cause problems to
                                   338

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the alkaline cleaning process and, if implemented properly, should not
cause disruptions in other parts of the finishing line.

Raw Materials

Carbon, stainless, and other types of steel are processed in  alkaline
cleaning  operations.   For  purposes  of  this  discussion,  any line
processing more than 50% carbon steel is considered to be  a  "carbon"
steel  line.   The Agency found that the type of steel being processed
does not significantly affect the quality or  quantity  of  wastewater
generated.   For  this  reason,  the  Agency  concluded  that  further
subdivision based upon the type of raw material used  (i.e.,  the  type
of steel processed) is not appropriate.

During  its  study,  the Agency sampled one specialty line, one carbon
steel line and one operation which was  not  clearly  designated.   No
significant  differences  were noted in the wastewater characteristics
of these lines.  All types of lines use similar cleaning solutions and
operating practices and achieve similar flow rates regardless  of  the
type  of  steel  used.  Based upon the available data, the Agency does
not believe  that  there  are  significant  variations  in  wastewater
quality between carbon and specialty lines.

The  Agency also analyzed wastewater flow variations which result from
processing carbon and specialty steels.  The Agency found  that  there
are  no  significant  differences  between  flow  rates for carbon and
specialty lines.  There is a difference between carbon  and  specialty
average  flow rates for batch operations.  However, this difference is
attributable to the extremely small data base for the specialty  lines
(3  lines) and not to any particular variation in the operation of the
lines.

Carbon and specialty steel alkaline cleaning lines do  vary  in  size.
The  Agency found that continuous operations were, on the average, ten
times larger than batch operations.  This difference  does  not  affect
further subdivision beyond the flow differences related to the mode of
operation.  Separate cost estimates were made for batch and continuous
operations to develop more representative required investment costs.

Wastewater Characteristics

Wastewaters  from  alkaline  cleaning  operations  originate  from two
sources:  the cleaning solutions and the  rinse  step or  steps  that
follow the cleaning operation.  The characteristics of the wastewaters
leaving  the  process  depend  primarily  upon three  elements;  (1) the
solutions used  in the cleaning baths;  (2) the degree  of carry-over  of
the pollutants  from the cleaning tanks to the rinse step;' and,  (3) the
frequency of dumping the cleaning solution tanks.

Based  upon  the  analysis  of  data   for this subcategory, the Agency
believes that there are no significant variations  in the  wastewater
characteristics   from  various alkaline cleaning operations.  Although
the types of toxic pollutants present  in  the  wastewaters  may  vary
                                    339

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 between  lines,  the concentration of these pollutants remain below or
 near treatability levels.

 Wastewater Treatabilitv

 The Agency analyzed the treatability of wastewaters from the different
 types of alkaline cleaning operations.  Based upon the data  developed
 during  the plant visits and the data supplied in the DCPs, the Agency
 found  that  there  are  no  significant  differences  in   wastewater
 treatability  among  the  different  types of cleaning operations.  As
 noted above, pollutants found in various alkaline cleaning wastewaters
 are present at levels below or near treatability levels.    If  treated
 separately,  wastewaters  from most alkaline cleaning lines would only
 require pH control.   For these reasons,  the Agency has concluded  that
 further   subdivision   of  this  subcategory  based  upon  wastewater
 treatability is not appropriate.

 Size and Age

 Consideration was also given to the impact of  size  and   age  on  the
 subdivision  of the alkaline cleaning subcategory.   The result of this
 analysis did  not  indicate  that  subdivision  on  those  bases  were
 appropriate.

 While  alkaline cleaning operations vary in physical  size,  layout, and
 product size,  the Agency found that these factors do  not  significantly
 affect  process water usage,  discharge flow rates,  or  effluent quality.
 Figure  IV-1  shows a   plot  which  analyzes  the  relationship  between
 discharge  flow  and  production  capacity  for  batch operations.   A
 similar plot  for continuous  operations is illustrated in  Figure  IV-2.
 Cleaning lines  over  a  wide size range have achieved the model  flow
 rates of 250   gal/ton   for   batch  operations  and  350   gal/ton   for
 continuous  operations.    Additionally,  the Agency  found  that the  size
 of  the  operation does not  affect wastewater  characteristics,   as   all
 lines   are    operated    in    similar   manners,  and  the   wastewater
 characteristics remain  relatively constant regardless of  size.

 The relationship between flow  and  age   was   analyzed in   a  similar
 fashion.  Also  illustrated  in Figure  IV-1  and  Figure  IV-2 are plots of
 flow vs.  age for  batch  and continuous operations, respectively.  These
 plots   demonstrate   that  the model  plant flows  are  achieved at lines
 over a  broad range of ages.   Therefore,  the Agency  concluded  that  age
 has  no  significant impact on  discharge flow.

 The  Agency investigated the  effect of age on  the feasibility and  cost
 of  retrofitting  pollution  control   equipment  at  alkaline  cleaning
 lines.   Comparison  of  the  age  of a  cleaning  line  with  the year in
which pollution control  facilities were   installed  demonstrates   that
pollution  control  equipment can be  retrofitted, see  Table IV-2.  The
discussion above  indicates that  similar  levels of pollutant  discharge
are  achievable  at alkaline  cleaning lines of all ages.  As a result,
the Agency has concluded that retrofitting pollution control to  older
alkaline cleaning lines  is feasible.
                                    340

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Most  alkaline  cleaning  wastewaters are treated in central treatment
facilities.  As a result, the industry was either  unable  to  provide
retrofit  costs  or  reported  that  costs  were  not significant.  In
addition, as discussed in Section VIII, a comparison of  actual  costs
incurred   by   the   industry   with  the  Agency's  estimated  costs
demonstrates that the  Agency's  estimates  sufficiently  account  for
retrofit  and , other  site-specific  costs.  The Agency thus concludes
that the cost of retrofitting pollution control equipment at  alkaline
cleaning lines has been accounted for.

From  the  analyses conducted above, the Agency concludes that age and
size do not affect the ability of alkaline cleaning lines  to  achieve
the  flow  rates  and  effluent  levels  which  form  the basis of the
limitations and standards.  Additionally, age and size do  not  affect
the  ability  to  install the appropriate pollution control technology
for alkaline cleaning operations.  Accordingly, the  Agency  concluded
that further subdivision based upon size or age is not appropriate.

Geographic Location

An  examination  of  the  raw  waste  characteristics,  process  water
application  rates,  discharge  rates,  effluent  quality  and   other
pertinent  factors  relative  to  plant  location  revealed no general
relationship or pattern.   Alkaline  cleaning  lines  are  located  in
sixteen  states.   Most  of these lines are located in the major steel
producing areas of Illinois, Indiana, Pennsylvania, and  Ohio.   Table
IV-3   summarizes   the   location  of  alkaline  cleaning  operations
responding to the DCPs.

A small number of lines are located in what could be considered "arid"
or "semi-arid" regions.  For this  reason,  the  Agency  gave  special
attention  to the consumptive use of water in these regions.  However,
because no cooling systems are required to achieve the limitations and
standards, additional water consumption is not expected to result from
compliance with the limitations or standards.

Process Water Usage

The Agency found that water use varies in  this  subcategory  only  in
relation  to  the  mode  of operation, i.e., batch or continuous.  The
Agency also found that water conservation practices are  available  to
achieve  a  fairly  uniform  discharge flow rate for new source lines.
Hence, further subdivision on the basis of water use is not  warranted
for existing sources.
                                    341

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                                          TABLE IV-1
                                 ALKALINE CLEANING OPERATIONS
 Plant
 Code

 09200
 0584F-02
 0728
 0584F-04
 0584F-03
 0240C
 0112A-11
 0112A-15
 0112A-12
 0112A-14
 0240B-01
 0240B-02
 0060N-01
 0060N-02
 0240B-03
 02560-01
 0760
 0868A-03
 0060D-02
 0868A-04
 0580
 0580B-02
 0580D-02
 0580E-06
 0868A-06
 0384A
 0460H
 0948F
 0856F
 0548B-01
 0112A-13
 0860B-10
 0068-03
 0868A-05
 0864B-04
0864B-05
0864B-06
0580-05
0580B-01
0580D-01
0432K

Discharge
Flow(GPT)
1
2
2
3
6
7
12
12
13
15
24
28
42
42
53
59
88
96
109
133
150
150
150
150
162
168
170
176
204
216
221
231
236
243
245
250
285
300
300
300
305
Type of
Finishing
Operation
w/Electroplat ing
w/Hot Coating
Stand Alone
w/Hot Coating
w/Hot Coating
w/Hot Coating
w/Cleaning Line
w/Cold Coating
w/Cold Coating
w/Cold Coating
Stand Alone
Stand Alone
Stand Alone
Stand Alone
Stand Alone
w /Bright Anneal
w/Copper Coating
w/Cold Coating
w /Anne a ling Line
w/Cold Coating
w/Brass Plating
w/Cold Coating
w/Cold Coating
w/Cold Coating
w/Cold Coating
w/Hot Coating
w/Cold Coating
w/Cold Coating
Stand Alone
w/Acid Pickling
w/Cold Coating
Stand Alone
w/Acid Pickling
w/Galv. Line
w/Annealing Line
w/Degr easing Line
w/Hot Coating
w/Cold Coating
w/Cold Coating
w/Cold Coating
w/Degreasing Line

Product
Type
Sheet
Strip
Pipe
Strip
Strip
Tubes
Strip
Strip
Strip
Strip
Tubes
Tubes
Tubes
Pipe
Tubes
Strip
Coil
Strip
Strip
Strip
Wire
Wire
Wire
Wire
Strip
Strip & Sheet
Wire
Pipe & Tube
Sheet
Tubes
Strip
Sheet
Rod
Sheet
Sheet
Strip
Coil
Wire
Wire
Wire
Coil
 Type of
 Operat ion

 Cont inuous
 Cont inuous
 Batch
 Cont inuous
 Cont inuous
 Batch
 Cont inuous
 Cont inuous
 Cont inuous
 Cont inuous
 Batch
 Batch
 Batch
 Batch
 Batch
 Continuous
 Cont inuous
 Cont inuous
 Cont inuous
 Cont inuous
 Cont inuous
 Cont inuous
 Cont inuous
 Cont inuous
 Cont inuous
 Batch
 Batch
 Cont inuous
 Cont inuous
 Batch
 Cont inuous
 Cont inuous
 Batch
 Cont inuous
 Cont inuous
 Cont inuous
 Cont inuous
Cont inuous
Cont inuous
Cont inuous
Cont inuous
                                        342

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                                TABLE IV-2

                      ALKALINE CLEANING SUBCATEGORY
            PLANTS WITH RETROFITTED POLLUTION CONTROL SYSTEMS
Batch

Plant
Code

112C
1121
240B
248C
256N
384A
460D
476A
548
548A
580A
636
728
776D
776G
856Q
  Plant
Age (Year)

   1914
   1922
   1938
   1973
   1965
   1968
   1959
   1960
   1927
   1957
   1962
   1943
   1952
   1948
   1950
   1947
Treatment Plant
  Age (Year)

      1977
      1950
      1968
      1975
      1973
      1970
      1970
      1977
      1969
      1967
      1967
      1974
      1971
      1973
      1976
      1963
Goneinuous
112A
1121
2560
432A
448A
580A
580E
584F
856D
856Q
860B
864B
868A
920G
920L
     Plant
   Age (Year)

   1936
   1927
   1966
   1951
   1954
   1962
   1950
   1948
   1938
   1960
   1937
   1948
   1938
   1937
   1961
      Treatment Plant
        Age (Year)

      1971
      1950
      1978
      1970
      1969
      1967
      1970
      1970
      1960
      1963
      1967
      1972
      1971
      1977
      1975
                                343

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                                TABLE IV-3

                 LOCATION OF ALKALINE CLEANING OPERATIONS
Location

Pennsylvania
Ohio
Indiana
Maryland
Massachusetts
Michigan
West Virginia
Alabama
California
Texas
Wisconsin
Georgia
Illinois
Kentucky
Connecticut
Mississippi

# of States =» 16
Total Number

     55
     23
     18
     15
     11
     10
      8
      8
      7
      5
      5
      3
      3
      3
      1
      1

     176
% of Total

    31.3
    13.1
    10.2
     8.5
     6.3
     5.7
     4.5
     4.5
     4.0
     2.8
     2.8
     1.7
     1.7
     1.7
     0.6
     0.6

    100%
                               344

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                              346

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                    ALKALINE CLEANING SUBCATEGORY

                              SECTION V

              WATER USE AND WASTEWATER CHARACTERIZATION
Introduction

Process  water use within the alkaline,cleaning subcategory is a major
factor in determining pollutant loads  and  estimating  the  cost  for
removal of pollutants.  The Agency analyzed the data from the sampling
surveys  and  the  DCP  responses to evaluate process water use within
this subcategory  and  to  obtain  the  total  subcategory  wastewater
volume.

Alkaline Cleaning Operations

As  noted  earlier,  alkaline  cleaning  is  accomplished in batch and
continuous operations.  In both operations, the product is cleaned  in
alkaline  solutions  prior to entering other finishing operations.  As
explained in the preceding sections, wastewater characteristics do not
vary significantly from operation to operation.  However,  flow  rates
do  vary  between the batch and continuous modes of operation.  In the
proposed regulation, a model flow of 50 gal/ton  was  used  to  derive
limitations  and standards for all types of operations.  Comments were
received which stated that such a tight  flow restriction could  cause
product  quality  problems.  The Agency believes that given the nature
of the process, these concerns are valid and  to  -alleviate  any  such
problems,  the  Agency has revised the model flow rates at BPT and BCT
upon "average of the best" considerations  (see Section IX discussion).
Model flow rates of 250 gal/ton and 350 gal/ton are used to derive the
BPT  and  BCT  limitations  for  batch  and   continuous   operations,
respectively.  At NSPS, a lower flow is used to derive the promulgated
standards.   A  model  flow of 50 gal/ton has been selected based upon
the best demonstrated flow  rates  at  several  batch  and  continuous
operations.  The Agency believes that new alkaline cleaning operations
will  be  able  to  design operations and conserve sufficient water to
achieve NSPS, which are based upon the tighter  model  discharge  flow
rate.

Wastewaters  are  discharged  from  two  sources  in alkaline cleaning
lines:   the cleaning solution tank and the subsequent rinsing  steps.
The cleaning solution tank contains a caustic solution which generally
has  high  levels of sodium compounds and other constituents depending
on the type of solution used.  At some lines, the cleaning solution is
reused continuously.  Fresh solution is added to make up  for  dragout
and  evaporative  losses.   The  baths  are discharged periodically to
limit the buildup of contaminants (dissolved solids and oils),  or  as
soon  as  the cleaning ability of the solution is impaired.  A process
being developed includes an ultrafiltration system  that  continuously
treats the alkaline cleaning solutions and permits higher reuse rates.
                                    347

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 Because  most  alkaline  cleaning  baths  are  used  to  process  high
 tonnages,  pollutants can build up  in  these  baths  to  high  levels.-
 Typical  levels  of   pollutants  found  in alkaline cleaning baths are
 shown  below:
                 Pollutant  or
           Wastewater  Characteristic

           Alkalinity
           Iron,  total
           Oil  &  Grease
           pH  (units)
           Total  Dissolved  Solids
           Total  Suspended  Solids
           Temperature
Typical Values (mq/1)

         1,000
           100
         1>500
           12-13
        25,000
         1,000
         70°-200°F
The other source of wastewaters from the alkaline  cleaning  process   is
the  rinse  step(s) following the cleaning operation.  After  immersion
of the product  into the cleaning bath, rinsing  is  required  to   remove
residual  cleaning  solution from the product.  The rinsing is  usually
done in dip tanks or spray chambers, and there  can be  either   one   or
several tanks depending upon the degree of rinsing required.  Although
some  lines  have standing rinse tanks (no continuous flow  through  the
tanks), many lines have rinse tanks with  continuous  water feed   and
overflow.   This  is  done  to  keep the rinsewater relatively  free of
contaminants and to cool the product, if necessary.

During the course of this study, the Agency obtained sampling data  for
three different lines.  The  rinsewater  was  sampled  at   each  line.
Because  the  discharges  from  batch  and  continuous  operations  are
similar, the data for these operations have been combined.  It   should
be  noted  that  Plant  0432K  was  visited  twice,  but only the data
gathered during the  most  recent  visit  are   included.    During   the
original  survey at Plant 0432K, the spent alkaline solution was being
discharged, and thus the sample analysis showed extremely high   levels
of  total  suspended  solids  (about  500  mg/1).   The level that  was
detected at that time exceeds the average concentration  of  suspended
solids  found in alkaline cleaning wastewaters by  a factor  of 50.   The
data gather at the three sampled lines are  presented  in   Table  V-l.
Net  concentrations are listed in this table to better demonstrate  the
additions of pollutants contributed by alkaline  cleaning   operations.
Averages  are  also listed, where appropriate, to  show a typical level
of pollutants that can be expected in rinsewaters  from  the  alkaline
cleaning  process.    As  shown,   alkaline  cleaning  operations do  not
normally add significant levels of pollutants to the rinse waters.
                                   348

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                                           TABLE V-l
                          SUMMARY OF ANALYTICAL DATA OF SAMPLED PLANTS
                                 ALKALINE CLEANING StIBCATEGORY
                     NET CONCENTRATIONS OF POLLUTANTS IN RAW WASTEWATERS
(1)
Reference.No.
Plant Code
Sample Points
Flow (gal/ton)
Type of Mill

Dissolved Iron
Oil & Grease
Suspended Solids
pH, units

 23 Chloroform
 36 2,6-Dinitrotoluene
 39 Fluoranthehe
 64 Pentachlorophenol
 65 Phenol
 66 Bis(2-ethylhexyl)phthalate
 68 Di-n-butyl phthalate
 69 Di-n-octyl phthalate
 71 Dimethyl phthalate
 73 Benzo(a)pyr~ene
 84 Pyrene
 85 Tetraehloroethylene
114 Antimony
119 Chromium
121 Cyanide, Total
122 Lead
124 Nickel
125 Selenium
128 Zinc
0176-01
152
(V-W)
815
Continuous
0.10
4.0
-
8.9-9.1
0.020
ND
0.0
ND
ND
- •
0.0
ND
ND
ND
0.0
0.027
NA
0.0
0.034
0.040
0.025
NA
' -
01121-04
156
(C-A)
67
Batch
0.30
5.5
11.0
7.2-8.1
0.0
ND
0.0
0.029
ND
0.020
0.0
ND
ND
ND
0.0
0.0
NA
0.055
0.003
0.075
0.015
NA
0.22
0432K
157
(C-A)
254
Continuous'
0.03
18.3
16.7
10.3-11.7
0.003
0.047
0.051
ND
0.021
0.49
0.086
0.031
0.12
0.010
0.032
-
0.030
-
0.0
-
0.0
0.070
- '

Average

379
-
0.14
9.3
9.2
7.2-11.7
0.008
0.016
0.017
<0.010
0.007
0.17
0.029
0.010
0.040
0.003
0.011
0.009
0.030
0.018
0.012
0.038
0.013
0.070
0.073
NA:  Not analyzed
NR:  Not reported
ND:  Not detected
- :  Calculation yielded a negative value.

(1)  All values are in mg/1 unless otherwise noted.
(2)  The concentrations listed for Plant 0796A are all gross effluent
     values due to the unavailability of influent data.
                                          349

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                    ALKALINE CLEANING SUBCATEGORY

                              SECTION VI

                        WASTEWATER POLLUTANTS
This section describes the  wastewater  pollutants  characteristic  of
alkaline  cleaning operations and the basis for the Agency's selection
of those pollutants for which limitations have been promulgated.   The
first  step  in  this  process  involved  the development of a list of
pollutants considered to be representative or  characteristic  of  the
alkaline  cleaning  process.   This  list  is based upon data gathered
during the original guidelines study and through DCP responses.

This initial list of pollutants was confirmed by data  collected  from
field  sampling  visits  conducted during this study.  A review of the
monitoring data for the wastewater.samples collected during all of the
field sampling programs formed the basis for the  final  selection  of
pollutants for which limitations and standards were promulgated.

Five  pollutants were limited in the prior regulation: total suspended
solids, dissolved iron, dissolved chromium, dissolved nickel, and. pH.
This  regulation  contains limitations for total suspended solids, oil
and grease, and pH.   Additional  information  on  these  changes  are
provided below.

The  Agency  deleted  limitations  and standards for dissolved nickel,
chromium, and iron.  In the prior regulation,  these  pollutants  were
limited  because  high  levels  were detected at the, one line that was
sampled (Plant I).  However, the wastewater  monitored  at  this  line
included  wastewaters  from  pickling and alkaline cleaning'operations
and included dumped alkaline cleaning baths.  The Agency believes that
the levels of these three pollutants are most likely  attributable  to
the  pickling wastewaters or the alkaline cleaning bath and not to the
alkaline cleaning rinse waters.  This conclusion  is  based  upon  the
additional  data collected at the three plants visited for this study.
Those data show that the concentrations of these three  pollutants  in
the rinse waters from alkaline cleaning operations are low.

Wastewaters  from  alkaline  cleaning  operations are relatively clean
compared  to  wastewaters  from  other  steel   industry   operations.
However,  there  is  the  potential for high concentrations of various
pollutants in the discharge from  the  lines,  particularly  when  the
spent  solutions  are  being  discharged.   Suspended  solids, oil and
grease, toxic metals (antimony, lead, selenium, and zinc) and high  pH
are  found  in  alkaline  cleaning  wastewaters.  These pollutants are
primarily generated in the the cleaning baths.

The suspended solids and toxic metal  pollutants  originate  when  the
dirt,  soot  and  scale  are  removed  from  the  steel product in the
cleaning bath.  Because the solution is not as aggressive as  some  of
                                    351

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 the other cleaning steps (i.e.,  pickling and salt bath descaling),  the
 solutions  do  not  contain  high  concentrations  of most toxic metal
 pollutants.  Suspended solids and oils and greases are  the  principal
 pollutants  washed  off the surface of the metal.  The discharges from
 the cleaning lines also have a high pH.   The  high  pH  values  result
 from the alkaline solutions used in the process;  pH levels of 9-12  are
 common to alkaline cleaning wastewaters.

 Sampling  of  toxic  pollutants   was also performed during this study.
 The Agency did not expect to  find  toxic  pollutants  at  significant
 levels.    A  list  was developed which summarizes the toxic pollutants
 known to be present in alkaline   cleaning  wastewaters  (Table  VI-1).
 This  list  is  based  upon data gathered from the sampling visits  and
 responses by the industry.

 Using the sampling data,  the Agency calculated a  net concentration  for
 each pollutant found in the raw  wastewaters.    A   net  raw  value  was
 used,  because this value best describes  the contribution of pollutants
 from  the  alkaline cleaning process.  All pollutants found in the  raw
 wastewater,  at an average net concentration of 0.010 mg/1 or  greater,
 at   any   of  the  lines sampled  are listed in Table VI-1.   The list of
 toxic pollutants,  which the Agency concluded as  being  characteristic
 of   the   alkaline  cleaning  subcategory,   is presented in Table VI-2.
 Also included in this table are  the nontoxic pollutants determined  to
 be  characteristic of the  process.

 Five  additional  pollutants were  detected at an  average concentration
 greater  than 0.010 mg/1 but are  not listed in  Tables  VI-1   or  VI-2.
 The  Agency  believes  that  their  presence  is   not  attributable to
 alkaline cleaning operations.  Methylene  chloride was detected at high
 concentrations but was omitted,  because this  compound is commonly used
 as  a cleaning agent in the  laboratory  and  its presence is ascribed  to
 this  practice,   not  to  the alkaline cleaning operation.   Also, four
 phthalate  compounds were  detected  at levels greater  than  0.010  mg/1.
 The Agency  believes their presence is  probably related to plasticizers
 in  the tubing used in collecting the samples.

 Based  upon   the analyses conducted above  and in  Section  V,  the Agency
 concluded  that none of the  toxic pollutants are present  in  the  rinse
 waters  from  alkaline cleaning lines at  concentrations  sufficient to
 warrant  limitation at BAT.  .After  BPT  treatment,   all   the  pollutants
 are present   in  concentrations that  are  below practical  treatability
 levels.  Aside from  reducing  the  BPT/BCT  effluent   volume   through
 recycle  or   water   conservation  practices,  there are no  economically
 achievable treatment  technologies  which the  Agency   is   aware   of  to
 reduce   the   loading   of  those  pollutants  by  a significant  amount.
Recycle  is being practiced  at only  one  plant in   this   subcategory.
However,  the   alkaline   cleaning   wastewaters  at  this plant are  mixed
with other wastewaters, and  the  combined waste  stream   is   reused  at
different  processes.   The  Agency  has no  other  information regarding
the recycling  of   alkaline   cleaning   wastewaters  and  whether   water
conservation  practices   (such   as   counter-current  rinsing)   can  be
applied at these operations.  As a  result,  the  Agency  has been  unable
                                   352

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to assess the feasibility of reducing discharge flow rates of existing
alkaline .  cleaning   operations  using  these  practices.   The  data
nevertheless demonstrate that low flow rates are achieveable.   Plants
are achieving flows below 50 gal/ton.
                                   353

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               TABLE  VI-1
TOXIC POLLUTANTS KNOWN TO BE PRESENT IN
    ALKALINE CLEANING WASTEWATERS
           Toxic Pollutant
       23  Chloroform
       36  2,6-Dinitrotoluene
       39  Fluoranthene
       64  Pentachlorophenol
       65  Phenol
       73  Benzo(a)pyrene
       84  Pyrene
       85  Tetrachloroethylene
      114  Antimony
                    :-&
      119  Chromium
      121  Cyanide, Total
      122  Lead
      124  Nickel
      125  Selenium
      128  Zinc
                 354

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          TABLE VI-2
     SELECTED POLLUTANTS
ALKALINE CLEANING SUBCATEGORY
      Dissolved Iron
      Oil & Grease
      Total Suspended Solids
      pH
  36  2,6-Dinitrotoluene
  39  Fluorahthene
  84  Pyrene
 114  Ant imony
 119  Chromium
 121  Cyanide, Total
 122  Lead
 124  Nickel
 125  Selenium
 128  Zinc
                355

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                    ALKALINE CLEANING SUBCATEGORY

                             SECTION VII

                   CONTROL AND TREATMENT TECHNOLOGY
Introduction

A review of the control and treatment technologies currently in use or
available  for  use  in the alkaline cleaning subcategory provided the
basis for selecting the  BPT,  BCT,  and  NSPS  alternative  treatment
systems..   This  review  involved  summarizing questionnaire and plant
visit data in order to identify those treatment components and systems
in use at alkaline  cleaning  operations.   The  Agency  analyzed  the
treatment  components  and  systems  most  appropriate for the various
levels of treatment.  This section also presents  the  raw  wastewater
and  treated  effluent  analytical  data  for the plants sampled and a
short description of the treatment at each of the sampled plants.

Summary of_ Treatment Practices Currently Employed

As  explained  previously,  wastewater  in   the   alkaline   cleaning
operations  is  generated  in the cleaning tanks and the rinse step(s)
following  the  cleaning  operation.   The  wastewater  and  treatment
techniques  practiced  at  the operating alkaline cleaning lines vary,
but most  are  treated  in  central  treatment  systems  with  similar
components.   The  Agency  used data from the DCPs and plant visits to
identify  the  treatment  methods  practiced  at   alkaline   cleaning
operations.  Based upon these data, the Agency developed the following
summary of disposal and treatment techniques:
Lines with
treatment of any kind

Lines discharging
to POTWs

Lines with
wastes hauled

Lines that do not
have any treatment

Total
    Operations
   With Treatment
or Disposal Practice

   110
    46
    10
   170
 % of
Total

 64.7
 27.0
                         2.4
  5.9
 100%
All  alkaline  cleaning  lines that provide treatment do so in central
treatment  systems.    These   treatment   systems   usually   receive
                                   357 •

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 wastewaters   from   operations   that   have  similar  or  compatible
 wastewaters and,  thus,  are designed primarily to reduce the levels  of
 suspended  solids,  oils  and  greases,  and toxic metals as well as to
 neutralize the pH of the discharge.  The types of  treatment  provided
 for the lines surveyed are outlined below.

 The  first  treatment  step  that is carried out at many operations is
 equalization.   Because of the potential  for batch discharges  and  for
 wastewaters  from  other  operations  to  be  combined  with  alkaline
 cleaning  wastewaters,   equalization  is  often  provided   prior   to
 subsequent treatment.

 Because  of  the   presence of oils and greases in the wastewaters,  oil
 separation is  usually practiced.   While  several methods of oil removal
 are used in this  subcategory (e.g., API  separation,  trough type,  belt
 type  skimmer),   surface  skimming  in  the equalization basin is most
 often practiced.

 After  equalization  and   oil   separation,    the   wastewaters   are
 neutralized.    The.  DCP  responses  indicate  that this is done in two
 ways.   If the  other wastewaters entering the central  treatment  system
 are  acidic,   then the  alkalinity of the wastewaters  from the alkaline
 cleaning operations  is  neutralized  to  the  required  pH  range  by
 comingling  with   those other wastewaters.   This practice is common at
 many mills,  as it reduces chemical costs.   If acidic   wastewaters  are
 not  present in the central  treatment systems,  then acid must be added
 to-neutralize  the alkaline cleaning wastewaters.   The operating  costs
 of   this  system  are higher  than  other types  of neutralization systems
 because of the amount of acid  required   to  neutralize  the  alkaline
 cleaning  wastewaters.    Only  11% of the alkaline cleaning lines have
 auxiliary acid addition systems installed in  the the   event  that  the
 acidity of the other wastewaters  entering the central treatment system
 is   not  sufficient to  completely  neutralize  the  alkaline cleaning
 wastewaters.

 After  neutralization and oil  skimming, polymers are usually added in a
 mixing  tank  to promote  flocculation and  sedimentation in clarification
 systems.   Various  .chemical   agents   are  used  to   achieve   optimum
 settling,  depending on  the  exact   nature  of  the  wastewaters.   One
 operation  reported  the  use of  anionic   polymers to  promote  solids
 flocculation   and   sedimentation.    This  alkaline cleaning operation
 discharges to  a central  treatment  facility, where the anionic polymers
 are mixed  with the  combined wastewaters.

After equalization,  oil  skimming and  chemical addition,  removal  of  the
suspended  solids and metals is  commonly practiced in  central  treatment
systems  that include alkaline  cleaning wastewaters.   Eighteen alkaline
cleaning operations  have settling  lagoons as  a  sedimentation  device;
nineteen   have  flocculation-clarifiers   alone, or in  conjunction with
settling lagoons;  and   eight  have  thickeners  to  achieve   suspended
solids  and  metals  removal.   Also,  filters  are installed at eight
operations.  The choice  of clarification or   filtration  depends  upon
the  amount of land  available for  installation  of  the  treatment  system
                                    358

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and the other types of wastewaters that are
treatment systems.
treated  in  the  central
In  the clarification or filtration step, sludges generated as solids,
oils, and precipitated metals are removed from the wastewaters.  Large
volumes of sludge can be  generated  depending  upon  the  wastewaters
being  treated  and  the  type  of  neutralization  carried out.  Both
centrifuges and vacuum filters are used for sludge dewatering.

Advanced Treatment Systems Considered
for the Alkaline Cleaning Subcateqorv

As shown in Section V, the Agency detected  toxic  organic  and  toxic
metal  pollutants  below  or  near  treatability  levels  in untreated
alkaline cleaning wastewaters.  For this reason, the  Agency  did  not
consider  additional  wastewater  treatment,  beyond  BPT,  that would
achieve further concentration  reductions  of  the  toxic  pollutants.
Instead,  the Agency considered advanced treatment systems which would
reduce or eliminate the wastewater flow  from  the  alkaline  cleaning
operation and thus reduce the pollutant load being discharged.

A description of the advanced treatment alternatives considered by the
Agency  for  alkaline  cleaning  operations is presented below.  These
systems have been demonstrated, to varying degrees,  in  the  alkaline
c-leaning   subcategory   or   in   other  industrial  applications  on
wastewaters  with  characteristics  similar   to   alkaline   cleaning
wastewaters.

1.   Ultrafiltration

     Ultrafiltration  (UF) is a pressure driven process for  separating
     high molecular weight solutes or colloids from water solutions by
     means  of  a  permeable  membrane.  The wastewater is filtered by
     passing it through the membrane under low pressure.

     This process is now being used  on  alkaline  cleaning  baths  in
     other   industries.    These   baths   are   quite   amenable  to
     ultra-filtration, resulting in the  concentration  of  the  dilute
     oily  waste  and  the recycle of the alkaline cleaning chemicals.
     Since UF membranes allow only the low  molecular  weight  solutes
     and  water  to  pass through, the emulsified oil and particulates
     are held back and concentrated.  The concentrate is not  returned
     to  the  cleaning  bath.   The  main  components  of the cleaning
     solutions, the alkali and builders, are generally  low  molecular
     weight solutes.  These materials pass through the membrane freely
     and are returned to the cleaning bath.  By using this system, the
     amount of pollutants discharged from the cleaning bath is reduced
     significantly.  This technology reduces the chemical costs needed
     to  make  up the solutions, improves the cleaning characteristics
     of the bath and reduces  the  pollutant  load  generated  by  the
     alkaline cleaning process.
                                   359

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     While  no  data are presently available regarding the application
     of  this technology to alkaline cleaning solutions,  it is expected
     that  this system will  work   quite  effectively.    Although   this
     technology  is  capital intensive,  a payback  period of less than  3
     years is predicted because of the  savings achieved  due to   the
     reuse  of the cleaning solutions.   While the installation of  this
     treatment system  would  reduce the  volume  of   spent   cleaning
     solutions requiring treatment,  it  does not address rinsewaters.

2.   Vapor Compression Distillation (Evaporation)

     Vapor compression distillation is  typically  used  to concentrate  a
     high  dissolved  solids wastestream  (3,000-10,000 mg/1)  to a slurry
     consistency  (approximately 100,000 mg/1).  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.   The
     distillate quality water  generated by  this system can  be recycled
     to  the  alkaline  cleaning   operation  thereby   eliminating   all
     discharges to   navigable  waters.   One  desirable feature of  this
     unit  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  this system   requires  a  high   calcium  to
     sodium ratio (hard  water).

     Due  to economic  considerations, only  limited  application is made
     of  vapor  compression  distillation   in  processing  wastewater.
     Vapor   compression  distillation may be the only possible means to
     achieve zero discharge of process  water  for  alkaline   cleaning
     operations.

3.   Counter-Current Rinse System

     The installation of counter-current  (cascade) rinse  systems  can
     substantially  reduce  the  rinsewater flows  discharged from the
     alkaline cleaning process.  This system would replace  or  modify
     the   existing   rinsing   system  to  achieve  a  multiple  tank
     arrangement in series.  The water flow to the  tanks  is  reduced
     and  cascades  from  one  tank  to  the  next.   The product being
     cleaned travels  in the opposite direction to the water  flow  and
     thus  encounters  progressively  cleaner  water.    This  type  of
     arrangement reduces the wastewater flow (i.e.,  the waste volume),
     concentrates the pollutants in  the  first  rinsing  chamber   and
     achieves  a more thorough rinsing because of  the multiple rinsing
     achieved in.the  series of tanks.  Although this type  of  rinsing
     is  ideally  suited  for  continuous  operations  it  can also be
     implemented at batch  type  operations.   The  rinsing  operation
     carried  out  in  the alkaline cleaning process is similar to the
     rinsing operations in pickling  and  hot  coating   which  include
     cascade rinse systems.  There is a  great potential for the use of
     this  system.    However,   the Agency does not have information on
     the  use of cascade rinsing in this  subcategory.
                                   360

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4.    Reuse Systems

     As  the  wastewaters  from  alkaline  cleaning   operations   are
     relatively  clean after treatment, there is a great potential for
     reuse.  While reuse rates up to  100%  were  demonstrated,  these
     high  rates  where  achieved mainly because the alkaline cleaning
     wastewaters were diluted  with  other  wastes  in  large  central
     treatment  systems.   A  reuse rate of 50% to other processes has
     been demonstrated at numerous lines.

5.    Recycle Systems

     The  low  pollutant  concentrations  associated   with   alkaline
     cleaning wastewaters provide a great potential for the recycle of
     the  treated  effluent.   A  recycle  system  could significantly
     decrease the discharge from alkaline cleaning operations.  With a
     recycle rate of 90%, the model BPT/BCT effluent flows of 250  and
     350  gal/ton could be reduced to 25 and 35 gal/ton, respectively.
     Only limited use has been made of this technology in the alkaline
     cleaning subcategory.  The one plant using  recycle  (0112D)  has
     two  lines in operation.  Fifty and ninety percent of the process
     water required by these two lines is central  treatment  effluent
     supplied  using  recycle systems.  In addition to flow reduction,
     recycle  systems  also  decrease   the   pollutant   load   being
     discharged.

Summary of_ Sampling Visit Data

Three  alkaline  cleaning  lines  were  visited  for  this study:  two
continuous operations and one batch operation.  Table VII-1 provides a
legend for the various control and treatment technology  abbreviations
used  to describe the treatment components at these operations.  Table
VII-2 presents"the raw wastewater and effluent monitoring data for the
alkaline cleaning lines described  above.   The  concentration  values
presented  in  Table  VII-2  represent,  except where footnoted, gross
average values.  In some cases these data were obtained  from  central
treatment systems.

A  brief  discussion  of  each  wastewater  treatment  system follows.
Additional details for each wastewater system  are  presented  in  the
respective flow diagrams.

Plant 152  (0176-01) - Figures VII-1 and VII-2

Wastewaters  from  alkaline  cleaning  operations  are discharged to a
complex central treatment system.  The sources of wastewaters  to  the
central  treatment  system are shown  in Figure VII-1 and the schematic
for the treatment system  is  shown  in  Figure  VII-2.   The  alkaline
cleaning  wastewaters,  which  comprise  approximately  1% of the total
flow to the central treatment system,  are discharged directly  to  the
central treatment system without pretreatment.
                                    361

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 These wastewaters are mixed with wastewaters from approximately twenty
 other   sources   and   undergo   equalization   and   neutralization,
 flocculation with  polymers,  and  clarification  with  oil  skimming.
 Sludge  formed  in  the  treatment  process is dewatered in mechanical
 centrifuges.  The  effluent  from  this  system  is  discharged  to  a
 receiving stream.

 Plant 156 (01121-04) - Figure VII-3

 A  complex  central  treatment system is also used at this plant.   The
 alkaline cleaning wastewaters comprise less than 1% of the total flow.
 The  alkaline  cleaning  solutions  and  rinses  are   combined   with
 wastewaters   from   other  sources  and  then  undergo  equalization,
 neutralization and primary clarification in  a  thickener.    From  the
 clarifier,  the  wastewaters  enter  a  high-density-sludge (HDS)  unit
 where the suspended solids and metals are removed.   The overflow  from
 the  HDS unit is then filtered.   The filtrate is discharged to a final
 polishing  lagoon,    where   additional   settling   and   temperature
 equalization is carried out prior to discharge to a receving stream.

 Plant 157 and I, (0432K)  - Figure VII-4

 The alkaline cleaning wastewaters from this line are also treated  in  a
 central   treatment   system.    The  two  sources of  wastewater from the
 alkaline cleaning operation are  treated differently.

 The rinsewater  from the process  is treated with rinsewaters from other
 process  lines and undergoes neutralization  and  settling  in  lagoons
 prior to discharge.    The spent cleaning solutions are collected and
 used to  help neutralize spent  pickle liquor generated in nearby pickle
 lines.   After being  mixed  with the waste pickle liquor,   the  combined
 wastes   enter  the   settling  lagoons  where some sedimentation occurs.
 The alkaline cleaning  wastes at  this plant make up  less  than 1% of the
 total flow to the central  treatment  system.

 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
 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-3, untreated wastewaters from  alkaline cleaning
 operations do not contain significant quantities  of  conventional  or
 toxic  pollutants.   In some  cases, these wastewaters  are equivalent to
make-up waters or water supplies  in terms of the  levels  of  suspended
 solids,   oil  and  grease, and toxic metals.  Thus, net credits may be
appropriate for wastewaters from alkaline cleaning operations   treated
separately.   However,  since  wastewaters from most  alkaline cleaning
operations are co-treated  with  wastewaters  which   have  significant
                                    362

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levels  of  the limited pollutants for these subcategories, the Agency
has determined that the limitations and standards should be applied on
a gross basis for those alkaline cleaning operations with  wastewaters
treated  in  central  systems, except to the extent provided by 40 CFR
122.63(h).
                                     363

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                                TABLE VII-1

                  OPERATING MODES,  CONTROL AND TREATMENT
                     TECHNOLOGIES AND DISPOSAL METHODS

                                  Symbols
         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: U 3 Untreated
T 3 Treated
n
% of raw waste
% of raw waste
% of raw waste
%- of FC flow
% of BC flow
% of VS flow
% of FH flow
flow
flow
flow
             REt,n
        4.   BDn


B.      Control Technology

        10.  DI

        11.  SR

        12.  -CC

        13.  DR

C.      Disposal Methods

        20.  H

        21.  DW
Reuse, where t
                  type
                  % of raw waste  flow
             t:  U = before  treatment
                 T = after treatment

Slowdown, where n =* discharge as % of
                    raw waste flow
Deionization

Spray/Fog Rinse

Countercurrent Rinse

Drag-out Recovery



Haul Off-Site

Deep Well Injection
                                     364

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TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 2           '	-'
        Disposal Methods (conto)

        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

        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 = Other, footnote
                                     365

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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 = Alum
                                            P s 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 3 type
                                      m s media
                                      h » head

                          m               h
             D s Deep Bed      S =• Sand      G = Gravity
             F 3 Flat Bed      0 = Other,      P = Pressure
                                   footnote

        52.   CLt            Chlorination,  where t = type

                                                t:   A = Alkaline
                                                    B = Breakpoint

        53.   CO             Chemical  Oxidation (other than CLA or CLB)
                                   366

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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 = 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 = Free
                                                 L s Lime
                                                 C = Caustic

                    Ammonia Product, where  t = type
                                                          3 Sulfate
                                                          3 Nitric  Acid
                                                        A = Anhydrous
                                                        P » Phosphate
                                                        H = Hydroxide
                                                        0 » Other,  footnote
                                                type

                                                Q = Qualifying
                                                N = Nonqualifying
Deaulfurization, where t =

                       t:


Cooling Tower

Acid Regeneration

Acid Recovery and Reuse

Activated Carbon, where  t
                     Ion Exchange

                     Reverse Osmosis

                     Distillation
                                                 type
                                                     Powdered
                                                     Granular
                                    367

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TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 5
D.
Treatment Technology (eont.)
        §7*  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
process flow as
% of total flow
                                                     t:  1s Same Subcats,,
                                                         2 s Similar Subcats.
                                                         3 » Synergistic Subcats.
                                                         4 » Cooling Water
                                                         5 * Incompatible Subcats.
                    Other,  where n = Footnote number

                    Settling Basin

                    Aeration

                    Precipitation with  Sulfide
                                  368

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                    ALKALINE CLEANING SUBCATEGORY

                             SECTION VIII

             COST, ENERGY,  AND NON-WATER QUALITY IMPACTS
Introduction

This section  presents  the  incremental  costs  to  the  industry  of
applying  the  different levels of pollution control technology to the
alkaline cleaning subcategory.   The  analysis  also  describes  energy
requirements, non-water quality impacts, and the techniques, magnitude
and   costs   associated  with  application  of  the  limitations  and
standards.

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

The water  pollution  control  costs  reported  by  the  industry  for
operations  sampled during this study and for the operations for which
D-DCP responses were received are  presented  in  Table  VII1-1.   The
costs were updated to July 1978 dollars from the data supplied for the
plants  at the time of sampling or from the data supplied in the D-DCP
responses.  Standard capital recovery factors were used  to  make  the
annual  capital  charges  comparable.   Also,  where central treatment
systems are present, the industry often supplied total cost  data  for
the  entire  treatment  system.   The  Agency analyzed these costs and
estimated that portion attributable to alkaline cleaning operations as
accurately as possible.  Accordingly, only  those  costs  due  to  the
treatment of the alkaline cleaning wastes are listed.

Because  of  the  extensive  use  of  central  treatment  for alkaline
cleaning  wastewaters,  the  Agency  could  not  directly  verify  its
model-based cost estimates for separate treatment of alkaline cleaning
wastewaters  with  cost  data  reported  by  the  industry for central
treatment systems.  However, the Agency did  compare  its  model-based
separate  treatment  cos'ts  with  industry  costs  for several central
treatment systems by summing the model-based separate treatment  costs
for  each  subcategory  included  in  the  existing  central treatment
systems.  The results of  .this  comparison,  presented  in  Volume  I,
demonstrate  that the Agency's costing methodology accurately reflects
industry costs for central treatment facilities in  general,  and  for
those  systems  including alkaline cleaning wastewaters in particular.
In fact, as shown by the data presented in Volume I, the Agency's cost
estimates for separate treatment for finishing  operation  wastewaters
are  likely  to  be significantly higher than actual costs  incurred by
industry for central treatment.

A  descriptive  summary  of  the  model  treatment  system  components
considered  is  presented in Table VIII-2.  The technologies described
therein represent treatment alternatives either in use or available to
                                   375

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alkaline  cleaning  operators.   In addition   to   listing   the   treatment
methods available,  these  tables  also  describe  for  each  method:

1.   Description of Treatment  Step
2.   Implementation Time
3.   Land Requirements

Figures VIII-1  and  VIII-2 illustrate  the alternative  treatment, systems
developed for batch and continuous  alkaline cleaning  operations.

Cost, Energy, and Non-water Quality Impacts

General Introduction

The  installation   of  the  alternative  treatment    systems   involve
additional   expenditures of  money  and   energy.    The  Agency  also
considered the  effects  of  these   systems   on  air   pollution/  water
consumption,  and solid waste  disposal.  The Agency estimated the cost
and energy requirements based  upon  the treatment models  developed  in
Sections  IX through  XIII.  These cost estimates are presented below.

Estimated Costs for  the
Installation of Pollution Control Technologies

A.   Costs Required  to Achieve the BPT Limitations

     Based upon the  status of facilities as  of July 1981,  the  Agency
     estimates  that  the  industry  will   need  to spend $0.6 million
     dollars  (capital  cost)  to  upgrade   existing  water  pollution
     control  facilities  in  the  alkaline  cleaning  subcategory  to
     achieve the BPT limitations.  The total capital  cost  of  BPT  is
     about  $12.-3 million.  Additionally, about $0.1 million of annual
     expenditures are required.

     To develop the above costs,  the Agency developed model  treatment
     systems  based  upon  average  plant production and average water
     utilization rates (applied flow).  The model BPT treatment system
     costs are presented in Tables VII1-3 and  VII1-4  for  batch  and
     continuous operations, respectively.  Plant by plant capital cost
     estimates  were  then  made  for   each  plant  by factoring plant
     production to the model plant size  by  the  "six-tenth"  factor.
     This   procedure yielded a cost estimate for the subcategory which
     the Agency believes is representative of the actual  costs  which
     the  industry  will  incur.    The  cost  comparisons presented in
     Volume  I  verify  the  accuracy   of  this  costing  methodology.
     Because the DCP responses listed  the treatment components already
     installed  in  the  subcategory,   the Agency was able to separate
     total estimated costs into the cost  of "in-place" components  and
     the "cost required".

     The  cost  estimates  for this subcategory  were developed with  the
     assumption that separate wastewater  treatment   systems  would   be
     installed  at   each  plant.    If   more  than one line exists at a
                                   376

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     plant, the combined tonnage was used and one treatment system was
     costed for that-plant:.  This  methodology  reduced  somewhat  the
     overstatement  of costs in this subcategory.  However, as pointed
     out earlier, wastewaters from  all  of  the  operations  in  this
     subcategory  with  treatment  are  treated  in  central treatment
     systems.  Treating wastewaters  in  a  central  treatment  system
     reduces costs because of economies of scale and because duplicate
     equipment  components  are  not  needed.   Additionally,  as  the
     effluent data in Section  VII  indicate,  plants  that  discharge
     wastewaters  separately  may not need to treat their wastewaters,
     except for neutralization to meet the pH limitations.  Therefore,
     the Agency's estimates are believed to be  conservative.   Actual
     costs  for  this  subcategory  are  expected  to be less than the
     estimates presented above.

B.   Costs Required to Achieve BAT Limitations

     The Agency  considered  two  BAT  treatment  systems  based  upon
     recycle  of  the  BPT  effluent  and  treatment  of the blowdown.
     Alternative 1 is  based  upon  filtration  of  the  blowdown  and
     Alternative 2 is based upon vapor compression distillation of the
     blowdown  to  achieve  zero discharge.  The model treatment costs
     associated with these alternatives are presented in Tables VIII-5
     and VIII-6 for batch  and  continuous  operations,  respectively.
     The  cost  of  BAT Alternatives 1 and 2 for the alkaline cleaning
     subcategory for the industry would amount to a capital investment
     of $7.6 and $57.7 million respectively.  The annual  expenditures
     associated with BAT Alternatives 1 and 2 would amount to $1.0 and
     $8.1  million,  respectively.   The Agency did not promulgate BAT
     limitations for alkaline cleaning operations.

C.   Costs Required to Achieve BCT Limitations

     The Agency has promulgated BCT limitations that are the  same  as
     the  BPT  limitations  and  can  be  achieved  with the BPT model
     technology and facilities.  Therefore, there  will  be  no  added
     cost beyond BPT to achieve compliance with the BCT limitations.

D.   Costs Required to Achieve NSPS

     The Agency considered two NSPS treatment systems for the .alkaline
     cleaning subcategory.  These treatment systems use the  best  and
     most  efficient  treatment,  components and applied water use rate
     demonstrated in the alkaline cleaning subcategory.   These  model
     treatment systems utilizes similar components as those comprising
     the  BPT  model  treatment  system  as well as filtration.  Model
     costs have been developed  for  the  alternative  NSPS  treatment
     systems  and  are presented in Tables VII1-7 and VII1-8 for batch
     and continuous operations, respectively.
                                    377

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 E.    Costs Required to Achieve Pretreatment Standards

      The Agency has not promulgated subcategory specific  pretreatment
      standards  for  alkaline  cleaning  operations.   Only the general
      pretreatment regulation, 40 CFR Part  403,  will  apply.    Hence,
      there  are  no additional pretreatment costs associated with this
      regulation.

 Energy Impacts

 Very little energy  would  be  required  to  operate   the  alternative
 treatment  systems  for alkaline cleaning operations  considered by the
 Agency.   The energy use at each level  of  treatment is presented below.

 A.    Energy Impacts at BPT

      The  Agency   estimated  the  energy   requirements  for  the   BPT
      limitations   based upon  the assumption that  all  alkaline cleaning
      operations will  install  treatment systems  similar  to  the  model
      and  that the operations will  have  discharge flows comparable to
      the model BPT flows.   The Agency  estimates that  the BPT treatment
      systems  for  all    alkaline   cleaning   operations   will   use
      approximately 3.5  million kilowatt-hours of  electrical energy per
      year.    This is  less than 0.01% of the 57  billion kilowatts hours
      used by the  steel  industry in  1978.

 B.    Energy Impacts at  BAT

      Additional energy  would  be required  due to  the   installation  of
      the  BAT model  treatment systems.   The electricity required per
      year  and that amount  expressed  as  a  percent   of.   the  electricity
      used,  by the steel  industry in  1978  for the  two  alkaline  cleaning
      subdivisions are shown below.
     Type of
     Operation

     Batch                4,000
     Continuous           8,000

C.   Energy Impacts at BCT
Energy (kwh/yr)
BAT 1     BAT 2
 % of 1978
Industry Usage
BAT 1     BAT 2
           92,000
        1,768,000
<0.001
<0.001
<0.001
 0.003
     No additional energy will be required due to the installation  of
     a  BCT  model treatment system, since it is the same as the model
     BPT treatment system.
D.   Energy Impacts at NSPS

     The energy required to achieve the NSPS and the annual costs
     that electricity are shown below for the model size plants.
                                         for
                                   378

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                                 Energy (kwh/yr)  Annual Cost ($)

                              NSPS-1     NSPS-2    NSPS-1      NSPS-2
     Batch Operations
     Continuous Operations

Non-water Quality Impacts
                              16,000
                              36,000
 20,000
124,000
400
900
  500
3,100
There  are  no  significant  air  pollution, solid waste disposal, and
water consumption impacts associated with the model treatment systems.
                                                      associated  with
                                                      for the alkaline
A.   Air Pollution

     There are no significant air pollution  impacts
     any  of  the  treatment  components  considered
     cleaning subcategory.

B.   Solid Waste Disposal

     Sedimentation  of  alkaline  cleaning  wastewaters  treated  with
     wastewaters   from   other   subcategories  will  result  in  the
     generation of sludge. However, since alkaline cleaning operations
     add little, if any,  suspended  solids  to  the  wastewaters,  no
     significant  sludge generation is 'attributed to alkaline cleaning
     operations.  Solid waste disposal impacts  for  those  operations
     that   are  co-treated  with  alkaline  cleaning  operations  are
     addressed  in  the  respective  subcategory  reports  for   these
     operations.

     There  will  be  minimal, solid waste disposal impacts at the NSPS
     level of treatment due to the low level of waste generation.

C.   Water Consumption

     Because none of the treatment  systems  considered  for  alkaline
     cleaning  operations  include cooling systems, little or no water
     consumption is anticipated due to the installation of  the  model
     treatment  systems.  Therefore, this consideration did not affect
     the selection of the model treatment system or the development of
     the effluent limitations and standards.


Summary of Impacts

While the Agency  does  not  project  significant  effluent  reduction
benefits  with  the  implementation  of  the  BPT limitations for well
operated and maintained alkaline  cleaning  operations,  the  effluent
data acquired by the Agency show that alkaline cleaning operations can
discharge  significant levels of conventional pollutants, particularly
when the spent alkaline solutions are being  discharged.   The  Agency
believes  the minimal adverse impacts cited above are justified by the
effluent  reduction  benefits  resulting   from   the   treatment   of
                                    379

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wastewaters  from  those  plants  discharging  significant  levels  of
pollutants and by the need to provide  BPT  effluent  limitations  for
alkaline  cleaning operations.  These limitations should be consistent
with the suspended solids and  oil  and  grease  BPT  limitations  for
wastewaters   from   other   finishing  operations  which  are  almost
universally co-treated with alkaline cleaning wastewaters.
                                   380

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                                        TABLE  VIII-1

                               WATER POLLUTION CONTROL COSTS
                               ALKALINE CLEANING SUBCATEGORY

                      (All costs are expressed in July, 1978 dollars)
Plant Code:
Reference Code:

Initial Investment
Cost

Annual Costs
  Capital
  Operation and Maintenance
  Energy, Power, Chemicals, etc.
  Other

TOTAL

$/Ton
 152*
0176-01

17,996
  156*
01121-04

5,627
157*
0432K

7,484
240B(01-04)

610,573
1,618
3,493
206
—
5,317
1.70
506
255
10.5
16
788
0.15
673
508
NA
—
881
0.03
54,891
63,233
11,007
5,714
134,845
**
* :  Estimated costs attributable to this subcategory.  Costs were apportioned
     on the basis of flow.
**:  This company has claimed its production as confidential information

Note:  Capital are based upon the formula, Initial Investment x 0.0899.
                                      381

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                                       TABLE VIII-2

                            CONTROL AND TREATMENT TECHNOLOGIES
                               ALKALINE CLEANING SUBCATEGORY
                         Description
Implementation
Time  (months)
      EQUALIZATION TANK WITH  OIL  SKIMMER r This  treat-          3
      ment  component provides normalization of the
      flow  and wastewater  characteristics, especially
      where batch dumps are common.  The oil  skimmer
      primarily removes floating  oils.

B.    ACID  NEUTRALIZATION  - Acid  is added to  the waste-         6
      water in a mixing tank  to reduce the pH within the
      range of 6.0 to 9.0.

C.    POLYMER ADDITION - Polymer  is added to  the same           6
      mixing tank used in  Step B.  Polymer promotes
      solids flocculation  and settling.

D.    CLARIFIER - This treatment  component allows               15-18
      the flocculated solids  from Step C to settle
      out of the wastewater.

E.    VACUUM FILTER - Dewaters solids which settled in          15-18
      Step  D.  The filtrate is returned  to Step D.

F.    RECYCLE - Reduces the clarifier effluent by 902           12-15
      and is returned to the  process.  This step
      decreases the final discharge flow and  load.

G.    FILTER - Further reduces solids, oils,  and some           15-18
      metallic compounds in the effluent from Step F.

H.    VAPOR COMPRESSION DISTILLATION - Vapor  compression        18-20
      distillation concentrates the dissolved solids in
      the Step F effluent to  a slurry consistency.  This
      treatment produces a high quality distillate.

I.    RECYCLE - This step recycles 100% of discharge            12-15
      from Step H to the process.  Thus, zero discharge
      from the alkaline cleaning process is achieved.
    Land
   Usage (ft*)

225 (batch)
400 (continuous)
                 625
                 No additional
                 space required.
                 400 (batch)
                 1296 (continuous)
                 100 (batch)
                 400 (continuous)

                 625
                 500
                 2025  (batch)
                 3025  (continuous)
                No additional
                space required.
                                      382

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                                      TABLE VIII-3

                     BPT TREATMENT MODEL COSTS:  BASIS 7/1/78 DOLLARS
Subcategory: Alkaline Cleaning
Subdivision: Batch

C&TT Step A B
Investment ($ x 10~3) 45.0 49.0
— o
Annual Costs ($ x 10 )
Capital 4.0 4.4
Operation & Maintenance 1.6 1.7
Land
Sludge Disposal
Hazardous Waste Disposal
Oil Disposal
Energy & Power 0.1 0.1
Steam
Waste Acid
Crystal Disposal •
Chemical 0.2
TOTAL 5.7 6.4
Model Size-TPD :
Oper. Days /Year:
Turns/Day :
CD
52.0 92.0

4.7 8.3
1.8 3.2




0.2 0.2



0.3
7.0 11.7
150
250
2
E
143.0

12.9
5.0
O.l'
0.1


0.9




19.0
Credits
  Scale
  Sinter
  Oil
  Acid Recovery

TOTAL CREDITS

NET TOTAL
                                                                                Total

                                                                                 381.0
                                                                                  34.3
                                                                                  13.3
                                                                                   0.1
                                                                                   0.1
                                (1)
                                                                                   1.5



                                                                                   0.5

                                                                                  49.8
5.7
6.4
7.0
        11.7
                                                                        19.0
49.8
(1):   Total  land  requirement for model.

                                    KEY TO C&TT STEPS

                 A:  Equalization With Skimming
                 B:  Neutralization With Acid
                 C:  Polymer Addition
D:  Clarification
E:  Vacuum Filtration
                                         383

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                                        TABLE VIII-4

                      BPT TREATMENT MODEL  COSTS;  BASIS  7/1/78 DOLLARS
Subcategory: Alkaline Cleaning
Subdivision: Continuous
Model
Oper.
Size-TPD :
Days/Year:
Turns/Day :.
C&TT Step A B
Investment ($ x 10~3) 126.0 92.0
Annual Costs ($ x 10"3)
Capital 11.3 8.3
Operation & Maintenance ,4.4 3.2
Land
Sludge Disposal
Hazardous Waste Disposal
Oil Disposal
Energy & Power 0.2 0.3
Steam
Waste Acid
Crystal Disposal
Chemical 2.9
TOTAL 15.9 14.7
C
99.0
.
8.9
3.5




0.2



4.1
16.7
D
274.0

24.6
9.6




0.4




34.6
1,500
250
2
E
241.0

21.7

o.'i(:
1.3


1.3




32.8
Credits
  Scale
  Sinter
  Oil
  Acid Recovery

TOTAL CREDITS

NET TOTAL
                                                                                 Total

                                                                                  832.0


                                                                                   74.8

                                                                                   2o;}<
                                                                                   1.3


                                                                                   2.4


                                                                                   7.0

                                                                                  114.7
15.9
14.7
16.7      34.6      32.8
                                                                                 114.7
(1):  Total land requirement for model.
                                     KEY TO  C&TT STEPS
                 A:  Equalization With Skimming
                 B:  Neutralization With Acid
                 C:  Polymer Addition
                      D:  Clarification
                      E:  Vacuum Filtration
                                          384

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                  390

-------
                    ALKALINE CLEANING SUBCATEGORY

                              SECTION IX

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

The Best Practicable  Control  Technology  Currently  Available
limitations were .originally promulgated in March 1976.»
(BPT)
More stringent BPT limitations were proposed on January 7, 1981 (46 FR
1858).  2 Based upon comments received on the proposed regulation, the
Agency has further studied alkaline cleaning operations and  concluded
that   the   originally   promulgated  limitations  and  the  proposed
limitations  should  be  modified  to  reflect  the  impact  that  the
different modes of operation have on rinse water flows.

In  the  originally promulgated regulation, the Agency established BPT
limitations  for  dissolved  iron,  dissolved  nickel,  and  dissolved
chromium.   During the toxic pollutant survey, the Agency did not find
these pollutants in the raw wastewaters at  levels  treatable  by  any
means other than recycle.  Accordingly, the Agency is not promulgating
limitations  for  those  pollutants.   A review of the model treatment
processes  and  effluent  limitations  for   the   alkaline   cleaning
subcategory follows.

Identification of BPT

The  BPT  model  treatment  system  includes  the following wastewater
treatment steps:   equalization;  oil  skimming;  neutralization  with
acid;  and  addition  of  a  polymer  followed  by  sedimentation in a
flocculation-clarifier.  The sludges  generated  in  this  system  are
dewatered  by vacuum filters.  The Agency believes that this treatment
system is appropriate as  the  model  treatment  system  for  the  BPT
limitations,  because  it  removes the conventional pollutants in this
process wastewater  and  is  consistent  with  the  central  treatment
systems  used  by  the industry to treat alkaline cleaning wastewaters
and wastewaters from other steel finishing  operations.   Figure  IX-1
*EPA 440/1-76/048-b, Development Document for Interim  Final  Effluent
Limitations  Guidelines  and Proposed New Source Performance Standards
for the Forming, Finishing and Specialty Steel Segment of the Iron and
Steel Manufacturing Point Source Category.
2EPA  440/l-80/024b,  Development  Document  for   Proposed   Effluent
Limitations   Guidelines   and   Standards  for  the  Iron  and  Steel
Manufacturing Point Source Category  (6 Volumes)
                                    391

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 depicts  the  model  treatment  system.    The  BPT  limitations do not
 require the installation of the model  treatment system;  any  treatment
 system which achieves the limitations  is adequate.

 Rationale for BPT

 Treatment System

 As   noted  in  Section  VII,   each   of  the BPT model  treatment system
 components  is  in  use  at  a  large   number  of   alkaline   cleaning
 operations.

 Treatment Model Effluent Flows

 Tables  IX-1   and  IX-2  present flow  data  for  batch  and continuous
 alkaline cleaning operations,  respectively.   The average of all  lines
 is   very  similar;   1067  gal/ton   for  batch  and   1140  gal/ton  for
 continuous operations.   Along with  the average flow of all lines,   the
 "average  of  the best"  flows  is presented on each  table.   The "average
 of the best"  calculation is based upon flows from   those  lines  which
 the  Agency   considers   to be  the best  flows.    In  both  types of
 operations,  this calculation  was the average of those  flows  of   less
 than  1000 gal/ton.   The Agency believes flow rates over 1000 gal/tons
 at alkaline  cleaning  operations do  not reflect good water  management
 practices.    The  resulting  "average  of the best"  value was the  basis
 for  the 250  gal/ton for batch and 350  gal/ton for continuous BPT  model
 effluent flows.    For  both  types   of  alkaline cleaning  operations
 processing  all   types  of products,  flow data from  about 75 percent of
 the  lines  were used to  develop the  BPT model treatment system effluent
 flow  rates.    Thus,  the  Agency   believes    that   product   quality
 considerations should not affect the attainment of  the model treatment
 system flow rates  at  any alkaline cleaning operations.

 Effluent Quality

 Tables A-6 and A-7  of Appendix  A to Volume  I  present the basis  for  the
 model   effluent   concentrations used  to develop  the total  suspended
 solids  and oil and  grease BPT   limitations.    The   data   presented  in
 Appendix  A   are applicable   to alkaline cleaning  wastewaters.   These
 concentrations are  as follows?
Total Suspended Solids
Oil and Grease
Daily
Maximum

.70 mg/1
30 mg/1
 30 Day
Average

 30 mg/1
 10 mg/1
                                    392

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BPT Limitations

The BPT limitations are presented below:
                            BPT Effluent Limitations
                      kg/kkq (lbs/1000 Ibs) of Product
                           Daily
                          Maximum
                30 Day
               Average
Batch
TSS
Oil and Grease
pH

Continuous

TSS
Oil and Grease
PH
0.0730         0.0313
0.0313         0.0104
    6.0 to 9.0
0.102          0.0438
0.0438         0.0146
    6.0 to 9.0
Demonstration of BPT Limitations

Table IX-3 presents sampled plant effluent data which support the  BPT
effluent  Limitations.   Two  of the three sampled plants achieved the
limitations.  With additional sedimentation or filtration,  Plant  157
could also meet the BPT limitations.  Since wastewaters from virtually
all  alkaline  cleaning  operations  are  treated in central treatment
systems, it  is  not  possible  to  demonstrate  compliance  with  the
limitations  for stand alone operations.  Additionally, as the data  in
Section VII indicate, alkaline cleaning  operations  discharging  only
rinsewater  will  be  able  to meet the effluent limitations with only
sample pH adjustment  (neutralization).  Thus, the Agency believes that
stand alone alkaline cleaning operations will be able to meet the  BPT
effluent limitations.
                                    393

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                                TABLE IX-1

                       ALKALINE CLEANING SUBCATEGORY
                 FLOW ANALYSIS AND BPT FLOW JUSTIFICATION
                 	BATCH OPERATIONS
 Model BPT Effluent  Flow:   250  GPT

 Plant Code

 05806-10
 0580G-04
 0580G-11
 05806-02
 0580A-03
 0068-01
 0548B-02
 0548
 0580G-01
 0460D
 04606
 0068-03
 0548B-01
 0460H
 0384A
 01121-04
 0240B-03
 0060N-01
 0060N-02
 0240B-02
 0240B-01
 0240C
 0728
Discharge Flow (OPT)

       8000 *
       5000 *
       4000 *
       2000 *
       1951 *
       1829 *
       1290 *
       961
       600
       275
       270
       236
       216
       170
       168
       67
       53
       42
       42
       28
       24
       7
       2
Average of all lines « 1067 GPT **
"Average of the best" lines   »  236 GPT **

 * Value was excluded from the "Average of the best" calculation.
** This average includes four confidential flow values which are
   not listed above.
                                 394

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                                TABLE  IX-2

                      ALKALINE CLEANING SUBCATEGORY
                 FLOW ANALYSIS AND BPT FLOW JUSTIFICATION
                          CONTINUOUS OPERATIONS	.
Model BPT Effluent Flow:  350 GPT

Plant Code        Discharge Flow (GPT)
0580A-01
0580G-06
0580G-07
0580G-08
0580G-09
0580-01
0580G-03
0580G-05
0580A-02
0580-02
0860B-11
0176-06
0860B-02
0580-04
0580-03
0580-07
0860B-04
0860B-03
0176-03
0868A-01
0860B-07
0112A-10
0856E-01
0176-04
0176-01
0920G-01
0860B-01
0868A-07
0176-02
0868A-02
0068-02
0860B-05
0864B-02
0860B-06
0176-05
09206-02
0112A-08
0584F-07
0856E-04
16849 *
6000 *
6000 *
6000 *
6000 *
4000 *
3750 *
3750 *
3426 *
1875 *
1835 *
1763 *
1692 *
1500 *
1333 *
1333 *
1210 *
1120 *.
1108 *
946
935
906
894
828
815
776
766
762
710
701
693
649
595
567
558
538
508
503
487
Plant Code

0860B-08
0112A-09
0528
0864B-03
02560-02
0920G-03
0580-05
0580B-01
0580D-01
0864B-06
0864B-01
0920L-01
0432K
0864B-05
0864B-04
0868A-05
0860B-10
0112A-13
0856F-01
0948F-01
0868A-06
0580-06
0580B-02
0580D-02
0580E-01
0868A-04
0060D-02
0868A-03
0760-01
02560-01
0112A-14
0112A-12
0112A-11
0112A-15
0584F-03
0584F-04
0584F-02
09200-01
Discharge Flow (GPT)

     480
     421
     387
     385
     372
     354
     300
     300
     300
     285
     267
     266
     254
     250
     245
     243
     231
     221
     204
     176
     162
     150
     150
     150
     150
     133
     109
     96
     88
     59
     15
     13
     12
     12
     6
     3
     2
      1
 Average of all lines - 1140 GPT **     +
 "Average of the best" lines =  351 GPT

  *: Value was excluded from the "Average of the best" calculation.
 **: This average includes seven confidential flow values not listed above.
  +: This average includes four confidential flow values not listed above.
                                   395

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                                         TABLE IX-3

                         JUSTIFICATION OF BPT EFFLUENT LIMITATIONS
                         	ALKALINE CLEANING SUBCATEGORY
                                                                                (1)
Operation

Batch
Continuous

Plant Discharge Data

152(0176-01)

156(01121-04)
TSS
0.0313
0.0438
0.00048
<0. 00028
O&G
0.0104
0.0146
0.0153
0.0011
6-9
6-9
7.2-7.9
7.3-7.7
C&TT
Components
E,SS,NA,FLP
E,SS,NA,FLP
E,NC,NW,
FLP,CL,VF
E,NW,NL,
T,FDS
,CL,VF
,CL,VF

(1) kg/kkg of Product
                                      396

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25
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                    ALKALINE CLEANING SUBCATEGORY

                              SECTION X

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

As  noted  earlier,  the  toxic  metals contained in alkaline cleaning
process wastewaters are found at average  levels  of  less  than  0.15
mg/1.  The discharge of these metals can only be reduced through waste
volume  reduction  techniques  including  recycle  and counter current
rinse systems.  Accordingly,  the  Agency  considered  two  BAT  model
treatment  systems,  both  of  which  incorporate  90%  recycle.   The
blowdown  from  the  recycle  system  would  be  further  treated   by
filtration  in BAT Alternative 1 and by vapor compression distillation
in BAT Alternative 2.  However, because the Agency could not find  any
direct  recycle  of  alkaline  cleaning wastewaters or counter-current
rinse systems, and no significant quantities of toxic  pollutants  are
present  in  these  wastewaters,  the  Agency  did  not promulgate BAT
limitations based upon these syterns.

BAT Alternatives

The  BAT  alternative  treatment  systems  evaluated  include  recycle
systems  to  reduce the BPT model flows of 250 gal/ton and 350 gal/ton
for batch and continuous operations to  25  gal/ton  and  35  gal/ton,
respectively.   Vapor compression distillation systems to achieve zero
discharge by evaporating, condensing, and reusing  the  effluent  from
the recycle systems described above constitute the second alternative.
Figure VIII-1 illustrates the two BAT treatment systems evaluated.

The effluent volumes and quality that could be achieved by these
systems are as follows:
                       Flow   -  (gal/ton)
                       Effluent
                    Concentration (1 )
                          mq/1	
BAT Alternative
Batch
                       25
Continuous   Lead
            35
              0.1
                                                     Zinc
0.1
 (1)  Long  term average;  batch  or  continuous
                                    399

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Selection of BAT

The  Agency  has  determined that alkaline cleaning wastewaters do not
contain significant quantities of toxic  pollutants  after  compliance
with  applicable BPT limitations.  Accordingly, since the BPT level of
treatment provides adequate control, the Agency  has  not  promulgated
more stringent BAT limitations.
                                  400

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                    ALKALINE CLEANING 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
comparesthecost  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 be less stringent  than BPT.

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 test.   (EPA had
argued  that a second cost test  was not  required.

Because of  the remand  in  American Paper  Institute v^. EPA  (No.  79-115),
the  Agency  did   not  promulgate  BCT   limitations except  for those
operations  for which the  BAT  limitations are  no  more  stringent  than
the  respective  BPT   limitations.   Alkaline  cleaning   is one of the
                                                                    has
the  respective  	  	
subcategories where BAT was promulgated equal to BPT.  The Agency
concluded  that  BCT  limitations  more  stringent  than  BPT  are not
appropriate.   No  additional  cost  for  compliance   with   BCT   is
anticipated'in this subcategory.
                                    401

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                    ALKALINE CLEANING SUBCATEGORY

                             SECTION XII

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

NSPS  are  to  represent  the  degree of effluent reduction achievable
through the application of the  best  available  demonstrated  control
technology (BDT), processes, operating methods, or other alternatives,
including,  where  practicable,  a standard permitting no discharge of
pollutants.  At this time, however, zero discharge is not  a  feasible
treatment  alternative  for  the  alkaline  cleaning  subcategory.  As
discussed in Section VII, except for evaporative systems, there are no
technologies  which  could  be  applied  to  all  operations  in  this
subcategory to attain zero discharge of process wastewater pollutants.
Evaporative  technologies are energy intensive and not demonstrated in
this subcategory, or in this industry.

Identification of NSPS Alternatives

The Agency has selected two NSPS alternative treatment  systems   based
on   the  best  flow  (gal/ton)  and  the  best  treatment  components
demonstrated in the alkaline cleaning subcategory.

A.   NSPS Alternative 1

     This treatment alternative  is similar to  the BPT model   treatment
     system  and  is shown  in Figure VII1-2.   The treatment components
     include equalization with oil skimming, neutralization with  acid,
     and  flocculation with  polymer.    Clarification  provides  solids
     removal,  followed by  vacuum  filtration for dewatering the sludge
     collected in the clarifier.

B.   NSPS Alternative 2

     This treatment alternative  includes  the   treatment   alternatives
     comprising   NSPS-1    with  the  addition of   filtration.    This
     alternative  is also  shown  in  Figure VII1-2.

The NSPS  corresponding  to these  two  alternatives are  shown   in   Table
XII-1     Respective   capital   and  annual  costs for  these alternatives
appear  in   Tables  VII1-7   and  VII1-8 for   batch    and   continuous
operations,  respectively.

Rationale for  the Selection of. NSPS

The NSPS  treatment  alternatives  include those  components which achieve
the  most  significant   removal   of  toxic  and  conventional pollutants.
                                      403

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 The Agency considered various other NSPS alternative treatment systems
 including those which achieve zero discharge.  However, these  systems
 were  generally  too  costly.   The rationale for the NSPS alternative
 treatment systems and the flow and effluent concentrations follows.

 Alternative Treatment Systems

 Both NSPS treatment alternatives include  standard  chemical  addition
 and sedimentation.   In addition, NSPS-2 includes filtration equipment.
 All  of  these  treatment components are well demonstrated in this and
 other steel industry subcategories.  Equalization is  used  to  reduce
 fluctuations  in flow and pollutant concentrations,  so that subsequent
 treatment components will operate more effectively.   Oil  skimming  is
 provided  to  reduce  any  floating  oils  that  may be present in the
 wastewaters.   Acid  is added in a reaction tank to neutralize the pH of
 the incoming wastewater to within the required range of  6.0  to  9.0.
 The  neutralization  step  is followed by polymer addition; polymer is
 added to aid solids and  metals  removal.    The  polymer  addition  is
 carried  out  in a  mixing tank to provide proper contact between the
 solids and the polymer.

 After  chemical  addition,    the   wastewaters   undergo   preliminary
 sedimentation  prior  to  filtration.    A  clarifier  is  used  in the
 alternatives,  since this unit will  reduce suspended  solids to a  level
 which  will   not interfere  with the filtration equipment.  Following
 sedimentation  the   wastewaters  are  filtered  to  remove  additional
 particulate   matter  and oils.   Filtration was chosen as a final  step,
 because it is demonstrated  in the steel  industry  and  because  it  is
 effective at  reducing   the  levels of  solids,  oils,  and metals.   The
 cost  estimates for  the filtration system were based  upon a multi-media
 pressure filter.  This type of  filter  is most often  used in the  steel
 industry.   However,   other types of filtration  systems can be used to
 treat alkaline cleaning  wastewaters.

 Flows

 Batch and Continuous  Operations

 A model  discharge flow of 50  gal/ton for  both  batch   and  continuous
 operations  is   the   basis  for  the  NSPS.   This flow  is  demonstrated at
 several  batch   and  continuous   operations.    Seven   batch  operations
 (approximately   26%   of  the  batch operations  submitting  flow data)  and
 nine   continuous  operations   (approximately   11%  of   the  continuous
 operations  submitting   flow  data)  demonstrate   the model  flow of 50
 gal/ton.  Table  XII-2   presents  a  list  of  these  plants   and   the
 respective flow rates  on a gallons per ton basis.

 Pollutants

 The  Agency selected  total suspended solids, oil and grease,  and pH as
 the pollutants to be  limited at NSPS.  Oil and grease was  included   to
provide  control  of  the oils removed from the product  in  the  alkaline
 cleaning process.  Also, oil and grease  is limited in  numerous  steel
                                    404

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finishing  operations.   Therefore,  the addition of oil and grease to
the list of limited pollutants  will  facilitate  the  development  of
combined  standards  for treatment systems.  Finally, pH is limited to
ensure that the wastewaters are properly neutralized.

Effluent Concentrations

The alternative NSPS for the above treatment systems are presented  in
Table  XII-1.    Refer  to Sections IX and X for information concerning
clarification and filtration effluent concentration levels.

Selection of NSPS

The Agency selected NSPS Alternative 1 as the  basis  for  NSPS.   The
Agency  has  promulgated  NSPS  for alkaline cleaning operations based
upon the best  demonstrated  flows  noted  above,  and7  in  order  to
facilitate  co-treatment  of  new source alkaline cleaning wastewaters
with' wastewaters from other new  source  steel  finishing  operations,
effluent  quality  for  total  suspended  solids  and  Oil  and grease
consistent with those used to develop NSPS  for  other  subcategories.
These  standards  are  achievable  by  the model treatment technology.
(See discussion in Section IX and Appendix  A  of  Volume  I).   Tn®s®
concentrations  are   the  same  as  those  used  to  develop  the  BPT
limitations for alkaline cleaning operations.   The  promulgated  NSPS
are  presented  in  Table  XII-3.   This  table also lists plants-that
demonstrate the NSPS.  The NSPS model treatment  system  is  shown  in
Figure XII-1.
                                     405

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                                         TABLE XII-1

                              NEW SOURCE PERFORMANCE STANDARDS
                                ALKALINE CLEANING SUBCATEGORY
 NSPS-1
Discharge Flow
(Gal/Ton)

Total  Suspended
Solids

Oil & Grease
pH, Units
Ave.
Max.

Ave.
Max.
                                              Batch & Continuous  Operations
              Concentrat ion
               Basis (mg/1)
30
70

10
30
                       Effluent
                       Standards
                   (kg/kkg of Product)

                         50
0.00626
0.0146
                                                                    0.00209
                                                                    0.00626
              Within the range of 6.0 to 9.0
NSPS-2
Discharge Flow
(Gal/Ton)

Total Suspended
Solids

Oil & Grease
pH, Units
Ave.
Max.
Ave.
Max.
15
40
10
                                           50
                                           0.00313
                                           0.00834
                                           0.00209

              Within the range  of  6.0  to  9.0
                                        406  '

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                                   TABLE XII-2

                        OPERATIONS DEMONSTRATING THE NSPS
                               DISCHARGE FLOW RATE
                          ALKALINE CLEANING SUBCATEGORY
Model NSPS Flow:  50 GPT
                 Batch
                                       Continuous
Plant Code

0060N-01
0060N-02
0240B-02
0240B-01
0240C
0728
Discharge Flow (GPT)

        42
        42
        28
        24
        7
        2
Plant Code

0112A-14
0112A-12
0112A-11
0112A-15
0584F-03
0584F-04
0584F-02
0584F-01
Discharge Flow (GPT)

        15
        13
        12
        12
        6
        3
        2
        1
NOTE: The flow data for confidential operations are not listed.
                                         407

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                                   TABLE XII-3

                              JUSTIFICATION OF NSPS
                          ALKALINE CLEANING SUBCATEGORY
                                    30-Day Average NSPS (kg/kkg of Product)
All Operations

Operations Achieving
the NSPS	

152  0176-01
156  01121-04
                                TSS
 0.00626
 0.00048
<0.00028
                   Oil & Grease
0.00209
**
0.0011
                                                                           PH
6.0 - 9.0
7.2 - 7.9
7.3 - 7.7
**:  Standard is not supported.
                                         408

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                    ALKALINE CLEANING SUBCATEGORY

                             SECTION XIII

                      PRETREATMENT STANDARDS FOR
             DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS
Introduction

The  Agency  has  not  promulgated pretreatment standards for alkaline
cleaning operations.  Instead, the General  Pretreatment  Regulations,
40 CFR Part 403, will apply.  The general pretreatment and categorical
pretreatment  standards  applying  to alkaline cleaning 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  considering   pretreatment   standards   for   alkaline   cleaning
operations,  the  Agency  gave primary consideration to the objectives
and requirements of the General Pretreatment Regulations.

Rationale

As discussed throughout this report, toxic pollutants are  present  in
untreated  alkaline  cleaning  wastewaters  at  levels  below  or near
treatability  levels  of  course,  the  conventional  pollutants  will
receive  comparable  treatment in the POTW.  Hence, the Agency has not
promulgated  pretreatment  standards  for  new  or  existing  alkaline
cleaning operations.
                                   411

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                       HOT COATING SUBCATEGORY


                              SECTION I


                               PREFACE
The USEPA has promulgated effluent limitations and standards  for  the
iron  and  steel  industry pursuant to Sections 301, 304, 306, 307 and
501  of  the  Clean  -Water  Act.   The  regulation  contains  effluent
limitations   guidelines   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).

This part of the Development Document highlights the technical aspects
of EPA's study of the Hot Coating 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.
                                    413

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                       HOT COATING SUBCATEGORY

                              SECTION II

                             CONCLUSIONS
Based upon this current study,  a  review  of  previous  studies/  and
comments received on the regulation proposed on January 7, 1981  (46 FR
1858), the Agency has reached the following conclusions.

1.   The Agency has established separate limitations for  rinse  water
     discharges  and  discharges  from  fume scrubbers for hot coating
     operations.  The original  subdivision  of  this  subcategory  is
     being retained for rinsewater discharges.  A separate subdivision
     has been established for fume scrubber discharges.

2.   The limitations for hot coating operations contained in the  1976
     regulation  were  applicable  to  galvanizing  and  terne-coating
     operations  only.   This  regulation  contains  limitations   for
     galvanizing,  terne,  and  hot  coating operations applying other
     metals.  Coating metals identified as part of  the  other  metals
     subdivision   include   aluminum,   lead,  and  tin,  along  with
     combinations of these metals or combinations with zinc.

3.   The Agency concluded that the model -wastewater flow rates used to
     develop the previously promulgated BPT limitations for the strip,
     sheet and  miscellaneous  products  subdivision  are  appropriate
     irrespective   of   the  type  of  coating  applied.   The  model
     wastewater flow rates for operations coating nails, fasteners and
     wire products were increased to  reflect  the  larger  data  base
     available to the Agency during this study.       :

4.   The concentration basis for the  effluent  limitations  has  been
     revised  for  all  pollutants to reflect additional effluent data
     acquired as part of this study.  Except for hexavalent  chromium,
     which   remains  unchanged,  the  concentration  bases  are  more
     stringent than those used to develop limitations contained in the
     1976 regulation.

5.   An  allowance  for  fume  scrubber  wastewaters  has  again  been
     provided.   The  Agency has concluded that the applied flow rates
     for fume scrubbers are not related to  product  type,  production
     rate,  or  air  flow through the scrubber.  Therefore, daily mass
     limitations (kg/day) have been promulgated  for  fume  scrubbers.
     These  limitations  are  to  be  added to the limitations for the
     rinsewaters, where fume scrubbers are installed.

6.   The Agency has promulgated _BPT  effluent  limitations  for  total
     suspended  solids, oil and grease, pH, lead, and zinc for all hot
     coating subdivisions.  Limitations for hexavalent  chromium  have
     also  been  promulgated  for those galvanizing lines that include
                                   415

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     chromate dip and rinse steps.  The  Agency  believes  that  these
     limitations will control the discharges of other toxic pollutants
     found in hot coating wastewaters.

     The Agency  promulgated  BAT  limitations  for  toxic  pollutants
     (lead/ zinc and hexavalent chromium) that are the same as the BPT
     limitations  for the subdivisions covering rinsewater discharges.
     The Agency found  that  conventional  rinsewater  flow  reduction
     methods  may  not  be appropriate for all coating operations, and
     that technologies evaluated for toxic metals removal beyond  that
     provided  by  the model BPT treatment systems either provide only
     marginal incremental removal or cannot be readily retrofitted  at
     all  existing operations.  For the fume scrubber subdivision, the
     promulgated BAT limitations are 15 percent of  the  corresponding
     BPT  limitations.  These limitations are based upon an 85 percent
     reduction in fume scrubber wastewater discharge achieved  through
     recycle.

     The Agency  has  promulgated  BCT  limitations  for  conventional
     pollutants (TSS and oil and grease) which are the same as the BPT
     limitations for these pollutants.

     A summary of the effluent loadings remaining after implementation
     of BPT,  BCT, BAT and PSES follows:
                             Direct Discharge Loadings (Tons/Yr)
                             Raw Waste          BPT/BCT         BAT
     Flow, MGD
     TSS
     Oil and Grease
     Toxic Metals
   22.9
2,658
1,060
1,829
 22.8
588
109
 12.2
 18.3
471
 87.0
  9.8
                               Indirect Discharge Loadings (Tons/yr)

                                Raw Waste              PSES
     Flow, MGD
     TSS
     Oil and Grease
     Toxic Metals
      7.5
    612
    217
    269
        5.6
      142
       26.3
        3.0
10.   Based upon facilities in place as of  July 1,  1981,  the  Agency
     estimates  the  following  costs to the industry will result from
     compliance with the BPT and BAT limitations and PSES for the  hot
     coating subcategory.  The Agency has determined that the effluent
     reduction  benefits  associated with compliance with the effluent
     limitations and standards justify the costs presented below:
                                   416

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     BPT
     BAT
     PSES
   Total

    33.7
     0.87
     5.05
                       Costs (Millions of July 1, 1978 Dollars)
                     Investment Costs	   	  Annual Costs
In-Place

 29.1
  0.36
  2.68
Required

  4.60
  0.51
  2.37
The Agency has also determined that the
associated  with  compliance  with  new
justify those costs.
Total

 5.07
 0.12
 0.74
                                                      In-Place   Required
4.31
0.05
0.39
0.76
0.07
0.35
                               effluent  reduction  benefits
                               source standards (NSPS, PSNS)
11.  The Agency has promulgated NSPS that are 25 percent  of  the  BPT
     and  BAT  limitations  for  the  subdivisions covering rinsewater
     discharge.   These  standards  are  based  upon  the  same  model
     treatment  system,  except that rinsewater discharges are reduced
     by  use  of  cascade  rinsing.   NSPS  for  the   fume   scrubber
     subdivision are the same as the corresponding BAT limitations.

12.  The Agency has promulgated pretreatment  standards  covering  new
     and  existing  sources (PSNS and PSES) that discharge wastewaters
     to POTWs.  The PSES are the same as the  BAT  limitations,  while
     the  PSNS are the same as the NSPS.  The standards are based upon
     the same model treatment systems.
13.  With regard to the remand issues, the Agency found
     to hot coating operations that:
                                               with  respect
     c.
Age  does  not  significantly  affect either the cost or the
ability to retrofit pollution control equipment to  existing
production  facilities.   The Agency did, however, find that
it may not be feasible to retrofit cascade rinse systems  at
all existing hot coating lines, because of configuration and
space limitations.

Its estimates of the cost of installing the model wastewater
treatment systems  are  sufficient  to  cover  site-specific
conditions.   The  Agency  compared  its  model  based  cost
estimates with actual costs reported by the  industry.   The
comparison  showed that the Agency's cost estimates exceeded
the reported costs by 49 percent.  The costs provided by the
industry included site specific and retrofit costs.   Hence,
the Agency concludes that its model-based cost estimates are
sufficient  to  cover site-specific and retrofit costs.  For
more detail on cost comparisons refer to Section VIII.

The impact of these limitations  and  standards  upon  water
consumption is insignificant.  The recycle components of the
model  treatment  systems  do not elevate the temperature of
the  water  to   the   point   where   evaporation   becomes
significant.
                                    417

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14.  The Agency received comments from a small segment of the industry
     suggesting that limitations should be based upon the basis  of  a
     load  per  surface area coated rather than on load per production
     weight basis.  The Agency found that the available  surface  area
     data was insufficient, since such records are not usually kept by
     the  industry  and the Agency does not have an adequate data base
     to develop limitations and standards  on  the  basis  of  surface
     area.    Moreover,   the  Agency  believes  that  its  method  of
     establishing limitations and standards on the basis  of  quantity
     of product (kg/kkg) is appropriate.


15.  Table II-l presents the treatment model flow and effluent quality
     data used to develop the BPT and BCT effluent limitations for the
     hot  coating  subcategory,  and   Table   I1-2   presents   these
     limitations.    Table  I1-3  presents the treatment model flow and
     effluent  quality  data  used  to  develop   the   BAT   effluent
     limitations  and  the  NSPS,  PSES,  and PSNS for the hot coating
     subcategory.    Table  II-4   presents   these   limitations   and
     standards.
                                    418

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                       HOT COATING SUBCATEGORY

                             SECTION III

                             INTRODUCTION
Background

The  Hot Coating Subcategory has been modified to include galvanizing,
terne  coating,  and  hot  coating  with  other  metals.   The   prior
regulation  (41  FR  12990) limited only galvanizing and terne coating
operations.

The originally promulgated limitations were primarily based upon  data
obtained  through  field sampling at six hot coating facilities.  This
study includes field sampling at two  of  the  same  plants  and  five
additional  hot coating operations.  In addition, an overall review of
flow and wastewater treatment  components  used  at  the  hot  coating
plants  surveyed  by  basic  data  collection  portfolios  (DCPs)  was
completed.  Summaries of the responses to  these  DCPs  are  shown  as
Table  III-l for galvanizing operations, Table III-2 for terne coating
operations, and Tab,le 111-3 for hot  coating  operations  which  apply
aluminum,  cadmium,  lead,  tin  or  combinations of these metals with
zinc.   These  tables  identify  products,  coatings,   ages,   sizes,
operating  modes, applied and discharged wastewater flows, control and
treatment technologies, and  ultimate  discharge  mode  for  each  hot
coating   production   line   for   which  data  have  been  received.
Ninty-eight percent of the responses contained  sufficiently  detailed
data  for  use  in  these  summaries.  The remaining lines were either
inactive at the time of the request, or were .being phased out.

DCP responses were solicited from about five-sixths  of  the  domestic
hot coating line operators which represents 97 percent of the nation's
hot  coating capacity.  The Agency's data collection effort focused on
acquiring data from the ten largest  steel  companies,  from  selected
other  companies  known to have wastewater treatment systems in place,
and, from a  representatve  group  of  the  smaller  operators.   This
approach  has  provided  data on lines as small as 525 pounds per turn
and as large as 940 tons per turn.  The largest steel  corporation  in
the  country  provided  data  for 28 hot coating lines varying in size
from a 1.8 ton per turn wire coating  line  to  a  321  ton  per  turn
continuous  strip  and  sheet  galvanizing  operation.   The Agency is
confident that the DCP responses are representative of all hot coating
operations, including those plants not solicited for data.   Following
a  review  of  the  DCP responses, detailed data collection portfolios
(D-DCPs)  requesting  information  on  existing  wastewater  treatment
practices,   and  cost  and  effluent  data  were  forwarded  to  nine
operations, including one  operation  which  was  previously  sampled.
Overall,  field  sampling  covered  14%  of  the  plants  with  annual
capacities totaling about 17% of the estimated  domestic  hot  coating
capacity.   Detailed  pollutant concentration and load data as well as
                                    423

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cost data were sought from plants accounting for an additional  17%  of
the  national  production  capacity, and basic data were requested for
plants comprising 97% of national capacity.   Table   II1-4  summarizes
the data base for the entire hot coating subcategory.

The Agency obtained both in-process and end-of-pipe samples during the
field   sampling   visits.   Data  for  raw  wastewater  and  effluent
characteristics,  water  use  and  cost    information   supplied   for
individual  plants  from  historical records were also obtained during
such visits.  NPDES permit application data were of limited value  for
the  purposes  of this study since most of these data are for outfalls
serving more than one operation.  However, NPDES self monitoring  data
for   selected  plants  with  well  designed  and  operated  treatment
facilities were evaluated to characterize  the performance of the model
wastewater treatment systems.

The  alternative  treatment  systems  and  effluent   limitations  were
derived  from  available  data  for the actual performance of existing
plants.  Other plants  were  reviewed  for  demonstrated  technologies
which,  together  with  field  sampling  data,  provide  the basis for
various BAT, BCT, NSPS, PSES, and PSNS treatment systems.

Descriptions of Hot Coating Operations

Hot coating processes in the steel industry involve the  immersion  of
clean steel into baths of molten metal for the purpose of depositing a
thin  layer  of  the  metal  onto  the  steel surface.  These coatings
provide desired qualities, such as  resistance  to  corrosion,  safety
from  contamination,  or  a  decorative  bright  appearance.  Finished
products retain the strength  of  steel  while  gaining  the  improved
surface  quality  of  the  coated  metal for a fraction of the cost of
products made entirely of that metal alone.

All methods for applying protective coatings to steel products require
careful attention to proper surface preparation - the primary and most
important  step  in  the  coating  process.   Without  proper  surface
preparation, good adhesion is impossible.  Surface preparation methods
vary  depending upon the type of coating applied and upon the shape of
the surface being coated, but  all  methods  aim  at  cleanliness  and
uniformity  of  the  surface.   The  most  common methods used are acid
pickling to remove scale or rust,  alkaline  or  solvent  cleaning  to
remove  oils  and  greases, and physical desurfacing with abrasives to
eliminate surface imperfections.

The two major classes of .metallic coating operations  in  the  industry
are  hot coating and cold coating.  Zinc,  terne, and aluminum coatings
are most often applied from molten metal baths, while tin and chromium
are usually applied electrolytically  from  plating  solutions.   Cold
Coating operations are being addressed separately as part of the Metal
Finishing Industry.
                                    424

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Hot Coating

Hot-dipped  coating  using  baths  of molten metal is practiced in the
steel industry as a batch-dip operation  for  sheet,  plate,  pipe  or
other pre-formed products, or on a continuous basis for coiled wire or
strip  and  sheet.  Operating processes vary, depending on the coating
being applied.  Refer to Figures III-l, III-2 and  III-3  for  typical
process  flow  diagrams for galvanizing (zinc) coating operations, and
to Figures III-4 and III-5, for terne coating and aluminizing  process
flow  diagrams.   While aluminum is shown as an example of other metal
coating, similar processes are used for the cadmium, lead,  hot-dipped
tin,  and mixtures of various metals.  Other coating lines may also be
batch dip or continuous operations.

Galvanizing

The batch-dip operation normally follows hot rolling, batch annealing,
cold  rolling,  and  pre-forming  or   sizing   operations.    Rolling
lubricants  are  removed  by  alkaline  cleaning,  and  final  surface
preparation is usually provided by mild acid  pickling  in  stationary
tubs  with  slight  agitation.   Following pickling, residual acid and
iron salts are removed by an alkaline dip, water rinsing, or prolonged
immersion in  boiling  water.   The  latter  practice  has  the  added
advantage  of  minimizing  hydrogen  embrittlement-   Clean base metal
forms are then conveyed, manually or by moving belt,-through the  flux
box  section  of  the  coating  pot, and immersed in the molten metal.
Coated products are withdrawn from the bath and dried by  a  warm  air
blast,  or  chemically treated with ammonium chloride, sulfur dioxide,
chromate or  phosphate  solutions  to  provide  special  finishes  and
surface  characteristics.   The  product may then be rinsed with water
and prepared for shipment.

Continuous hot-dip galvanizing accounts for more  than  60%  of  total
galvanizing production.  The simplest version starts with annealed and
tempered  steel  which  receives a mild muriatic acid  (HC1) pickle and
rinse, then proceeds directly through a layer of fluxing agent to  the
molten zinc bath.  The coated product is dried and recoiled, or cut to
size  for  shipment.   More  elaborate  continuous   galvanizing  lines
include additional stages preceding and following  the  hot-dip  step.
At  least  one strip galvanizer  incorporates a sequence of pickling in
hot sulfuric acid; rinsing and scrubbing with brushes; a  dip  into   a
hot  alkaline  cleaning  solution; scrubbing  in alkaline solutions; an
electrolytic hot alkaline  cleaning step, rinsing  and  scrubbing  with
brushes;  a   light  pickle in hot sulfuric acid; rinsing and scrubbing
with brushes; a dip into a hot zinc sulfate  flux bath; a hot dip  into
molten  zinc;  dip  and  spray with chromate or phosphate solutions;  a
final water rinse; drying  with hot air; and  recoiling.

Other producers use a so-called  "furnace  line"  to  .anneal  the  steel
product prior to  coating with zinc.  Without  annealing,  incoming  coils
to  hot  coating  operations  are  very hard  following cold reduction.
Furnace line  operators  include annealing as  follows:  cold rolled  coils
are given  a  hot  alkaline   cleaning,  rinsing,  and  scrubbing;  and
                                    425

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 pickling  in  hot  acid  followed  by water rinses.   The strip is then
 placed in a controlled atmosphere heating chamber (annealing  furnace)
 up  to  60  meters  (200 ft.) in length with a series of independently
 controlled heat zones to provide temperatures required for  annealing,
 yet sufficient cooling so that strip exits the furnace at temperatures
 slightly  above  the  molten  bath  temperature.    A mixture of NX gas
 (principally nitrogen, with  controlled  amounts   of  methane,  carbon
 monoxide,  and  carbon  dioxide)  and  cracked ammonia is used in some
 annealing furnaces to  prevent  oxidation  and decarburization.    The
 strip is discharged from the exit end of the furnace below the surface
 of  the molten zinc bath.   A sinker roll submerged near the surface of
 the zinc bath is used for controlling the thickness   and  distribution
 of  the coating.  Forced air blasts are used to cool the exiting strip
 and to help solidify the zinc coating.   Chromate  or  phosphate chemical
 treatments may be provided at this point to retard formation of  white
 corrosion  products on« the coating.   A final rinse and drying step may
 also follow.   Finished coated strip is recoiled or cut to  size  ready
 for shipment.

 Another  type  of furnace line subjects cold rolled  strip to a complex
 furnace  gas   containing  hydrogen  chloride.   After  annealing   and
 cooling,   a mild hydrochloric acid pickling is completed just prior to
 the flux section of a conventional molten zinc pot.   In place  of  the
 usual exit rolls for controlling coating thickness,  flexible wipes are
 used to yield very thin,  but extremely adherent zinc coatings.

 Terne Metal

 Terne   is an  inexpensive,   corrosion-resistant hot-dipped  coating
 consisting of  lead and tin in a ratio typically in the range  of   five
 or   six  to one.   Lead alone does not alloy with  iron,  but does form a
 cohesive solution with tin,  which in turn alloys   readily  with  iron,
 although  requiring  higher   temperatures than for tin alone.   Most of
 the terne coated material   is  used   in  the  automobile  industry  to
 manufacture   gasoline   tanks,   with   lesser  amounts  going  into  the
 production of  automotive  mufflers,   oil   pans,  air  cleaners,   and
 radiator  parts.    Other   end  products  made   of terne metal  include
 roofing materials,  portable  fire extinguishers, and  burial  caskets.

 As  in  the case of hot-dipped galvanizing  processes,   both   batch  and
 continuous terne  coating processes are used,  although  the continuous
 process is used to supply  by far the larger portion  of  the  market.
 Both metals used in terne  coating are corrosion-resistant,  as is  their
 combination.   But since both  lead and tin are  cathodic to iron  in most
 environments,   corrosion is  actually accelerated  if  any  portion of  the
 base metal is  exposed.  For  this reason,  terne coatings  are  usually
 thicker    than    other   metallic coatings.    For   maximum  corrosion
 resistance, even  the thickest  terne  coatings benefit from painting   or
 other protective  finishing.

 The  batch-dip   terne  coating  operation  normally  is performed  on  cold
reduced,  batch  annealed, and  temper   rolled  coils   cut   into   sheets.
Oils  and greases  are removed  by  alkaline or solvent (mineral spirits)
                                    426

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cleaning, and final surface preparation requires a  hydrochloric  acid
dip just prior to coating.  Excess acid is squeezed from the sheets by
rubber  rolls.   The  sheets  are  then  conveyed  through  a flux box
containing a hot solution of zinc chloride in hydrochloric acid, or  a
molten  zinc  chloride salt bath to remove residual iron oxides and to
provide dry steel  surface.   The  sheets  are  then  passed  downward
through  a molten terne metal bath maintained at 325°C to 360°C <6170F
to 680°F), where the coating is applied, then upward  through  an  oil
bath floating atop the terne pot.  This oil tends to maintain the high
temperature  long  enough  for  oil  rolls  to  control deposition and
coating thickness evenly  over  the  sheet  surfaces.   Although  most
batch-dipped  terne coatings use a single unit as described above, the
wider range of coating weights sometimes requires  a  pass  through  a
second  molten  metal bath of the same type, but including another oil
bath instead of the zinc chloride flux box prior to the application of
the second coat.

The steel strip fed to a continuous terne coating  operation  receives
the same preliminary treatment as the steel processed on the batch-dip
line   except  that  it  remains  in  the  coil form, and the cleaning
procedure prior to pickling  is most often done electrolytically.   The
normal  sequence is oil and  grease removal in an electrolytic alkaline
unit; rinsing and scrubbing  with  brushes;  pickling;  terne  coating|
and,  oiling  by  a  process similar to batch dipping.  After cooling,
residual oils are removed  in a "branner",  which  consists  of  tandem
sets of  cleaning rolls made  of thousands of tightly compressed  flannel
discs.   Middlings  from   grain  milling,  called bran, are fed to the
first set of  rolls to  absorb  moisture  and  excess  oil,  while  tne
remaining  rolls  distribute a  light oil film evenly over the entire
coated surface.  The final product is then recoiled, or  cut  to  size
for  shipment  as  terne   coated flats.  Additional detail for  a terne
line is  illustrated in Figure III-4.

Aluminum

Another  metallic   coating applied  using  the  hot-dip  technique   is
aluminum.    Products  made of aluminum  coated steel  include bright and
matte finished sheets and strip  used as building materials  in   marine,
industrial,  or other environments where a  high  degree  of resistance  to
corrosion   is required.   Aluminum coated wire is  used  for chain-linK
and  field  fencing, barbed wire,  telephone  wire, and screening.

The  batch  coating  process uses   either  a   conventional  molten  metal
bath,   as   in  zinc or  terne coating,  or  a special  cementation  process
called  calorizing.  Thoroughly  cleaned,   degreased,   and  dried  steel
products  are packed   in  a  rotating  drum,   along with  a mixture  of
aluminum powder,  aluminum oxide,  and  ammonium-chloride.  As   the  drum
rotates  inside   a furnace at 940°C-955°C (1,724<>F-1,751<>F)  a reducing
gas  is  passed into the  drum, and the  mixture is tumbled for  4-5 hours.
A cohesive solution of  aluminum in  iron,  richest  in aluminum  near  the
surface,  forms   the   coating.    This   type  of  coating is  especially
effective in protecting steel from   oxidation  at  high  temperatures,
                                     427

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 hence  it is used in pyrometer and superheater tubes,  and in a variety
 of oil refinery applications.

 The continuous aluminum coating process starts with cold rolled  steel
 strip  or steel wire.   The strip lines are usually furnace lines,  with
 an annealing step just prior to the hot-dip in molten   aluminum.    The
 sequence is much the same as zinc coating on a furnace line.   The cold
 rolled steel coils are cleaned in a hot alkaline solution, rinsed,  and
 given  a  mild  pickling  in  hot acid, followed by a  final rinse.   An
 annealing furnace softens the  otherwise hard  carbon  steel,   and  the
 coating  is  applied  immediately  following  the  furnace.  The  strip
 exiting the aluminum bath is cooled,  oiled if required,   and  recoiled
 or  cut  to size for shipment.   There is usually no chemical  treatment
 or final rinse following the aluminizing dip.

 In making aluminum-coated wire products  by  the  hot-dipped   process,
 clean,   cold-drawn  carbon-steel  wire  is  passed  through the molten
 aluminum bath  at 660°C-680°C (1,220°F,  256°F).    This   temperature   is
 high    enough   to  soften  the  carbon-steel  wire  sufficiently   that
 annealing is not required,  but  the tensile strength of   the   wire   is
 reduced,  rendering it  unsuited  for certain applications.   This problem
 is readily corrected by cold-drawing the coated wire,  which not only
 raises  the tensile strength, but also provides   a  very   bright  final
 finish  to the  coating.
Additional
III-5.
detail  for  an  aluminizing line is illustrated in Figure
Other Hot-Dipped Metal Coatings

Other  hot  coating  operations   involve  combinations  of  zinc   and
aluminum,  zinc and cadmium, or zinc, tin and cadmium.  There are also
some wire coating operations which use molten tin, or cadmium alone as
the coating agent.  However, the  latter  processes  comprise  a  minor
fraction   of   hot-dipped   coating  operations.   Most  tin  plating
production at steel plants is electrolytic, as is all chromium plating
and a limited amount of zinc coating.
                                    428

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                       HOT COATING SUBCATEGORY

                              SECTION IV

                          SUBCATEGORIZATION
Plants involved in forming and finishing steel assume a  wide  variety
of configurations, from simple layouts (e.g., a wire drawing operation
starting  with  purchased rod or heavy wire brought in from elsewhere)
to extremely complex (e.g., an integrated steel plant with  all  steel
melting, refining, forming and finishing operations at a single site).
Moreover,  forming and finishing operations at any particular site may
be of one.type (pipe and tubemaking, cold rolling, coating), or may be
a sequence involving many operations (primary breakdown of ingots into
slabs, rolling of  slabs  into  coils  of  strip,  pickling  and  cold
reduction  of strip, cleaning and hot-dipping of strip to form a final
galvanized product).   The  basic  subcategorization  of  forming  and
finishing  operations  into  subprocesses  has  been  retained.   This
section deals with coating operations only, and in particular with hot
dipped  metallic  coatings.   Factors  evaluated   with   respect   to
subcategorization and further subdivision are discussed below.

Factors Considered in Subcateqorization

Manufacturing Process and Ectuipment

The   manufacturing   or  production  processes  associated  with  the
production  of  steel  products  serves  as  a  basis   for   defining
subcategories.   The  types  of  equipment  used,  and  the  processes
themselves,  vary  sufficiently  to  justify  their  separation   into
different subcategories.

Coating  operations within the steel industry are usually performed by
either of the following methods:

Hot Dip Process

Steel is immersed in a molten bath of the coating metal, then  removed
from  the bath in such a way that the coating is uniformly distributed
over  the metal surface as free of discontinuities as  possible.   Most
zinc  coatings, and .all aluminum and terne  (a lead/tin alloy) coatings
are applied in this manner.  In the past, tin was also  applied  as   a
hot-dipped  coating, but the electrolytic tin plate process has almost
completely supplanted this practice, except for  hot  dip  coating  of
wire  and wire products.  Other metallic coatings which are applied by
the hot dip process include aluminum, cadmium, lead, and  combinations
of these metals with each other-or with zinc.
                                    445

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Electrolytic  Process

Most  tin   coatings,   all  chromium  coatings  and  some  zinc  coatings  are
applied electrolytically.   These  electrolytic  coating operations  have
not  been   included   in  the   iron  and steel industrial  category.   The
discharge from  these  operations will be addressed  as  part  of  the Metal
Finishing industrial  category.

Only hot dip  coating  operations are addressed  herein.    Since  these
operations  are similar regardles's of the type  of metal coating being
applied, manufacturing process does not warrant  further  subdivision of
the hot coating subcategory.

Raw Materials

The primary raw material,  carbon  steel, is common  to  all   hot coating
operations  covered   in  this  subcategory.    The  Agency is unaware of
operations coating specialty steels.  However, the other different  raw
materials used  in hot  coating processes indicated  a potential need   to
subdivide  the  hot coating subcategory by coating metal.  In addition
to the coating  metals, the other  raw materials used include fluxes  and
oils.   (Pickling  and alkaline  cleaning   normally   conducted    in
conjunction  with  hot coating   operations  are addressed in separate
subcategories).  All  terne coating  and wire galvanizing  lines surveyed
were found to be using fluxes,   as were  virtually   all  galvanizing
operations  coating miscellaneous shapes.  Fluxes  are used in only  21%
of strip and sheet galvanizing operations.  Such differences  indicated
a potential need for subdivision  of hot coating  operations by the type
of metallic coating being  applied.  However, the Agency evaluated   the
effluent  data  from   operations  coating with  the  different metals  and
found that the  toxic metals present in the wastewaters  from   each   of
these  operations were similar and  appeared above  treatability levels.
Thus these wastewaters all  require treatment,  despite   the varying
levels  of  toxic  metals  present  in  these  wastewaters.    The only
exception was the presence of hexavalent chromium  in  wastewaters  from
galvanizing  operations with chromate rinses.  As  a result, the Agency
subdivided the  hot coating subcategory to separately  limit galvanizing
operations,  and terne  and  other coating operations.

Final Products

A variety of final products are made  when  coatings  are  applied   to
different  steel  shapes.  The most common hot coated products include
galvanized steel strip, sheet, pipe, tube, rods, bars, fasteners, wire
and wire products, nails, plate,  couplings,   and  various structural
shapes.    Strip  and   sheet  may  in turn be formed into useful shapes,
such as auto parts, architectural components,  containers,  gutters,  and
channels.   In some cases,  certain   formed  shapes  are  redipped  into
molten  baths  to ensure that the coatings are completely  covering  the
base metal.
                                    446

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Hot coated products  other  than  galvanized  products  include  terne
coated  strip  and  sheet  which  is used for automobile parts, burial
caskets, fire extinguishers, steel bands and roofing materials.

Aluminum coatings are applied to steel strip and sheet for  decorative
and  corrosion  resistant  qualities.   These  flat  products are then
formed  into  architectural  shapes,  gutters,  channels,  auto   body
components,  and  other uses.  Nails, bolts, nuts, fasteners, and wire
are also aluminized by hot coating processes.

Wire and wire products (chain-link  fence,  wire  cloth)  are  usually
galvanized,  but  other  hot  coatings  are  also applied, namely tin,
cadmium, aluminum, and combinations  using  tin,  cadmium,  and  zinc.
Another  product  involving  combinations of metals is strip which has
been coated with "galvalume", a combination of aluminum and zinc.

The large differences in the applied flow rates in relation to type of
product being coated has led to further subdivision by  product  type,
i.e.,  strip, sheet, and miscellaneous products, and wire products and
fasteners.  This is discussed in more detail below.

Wastewater Characteristics and Treatabilitv

Wastewater characteristics and treatability are related to the coating
metal.  Except for hexavalent chromium,  the  Agency  found  that  the
wastewaters  from  all  coating operations contain similar toxic metal
pollutants.  Although the predominant metal  and  the  levels  present
varied  by  the  type  of  coating applied, the toxic metal pollutants
appeared above treatability levels.  These toxic metals  are  amenable
to  the  same  treatment  technologies,  and regardless of the type of
coating applied, the same effluent levels can be achieved.

Hexavalent chromium was found  in  the  wastewaters  from  galvanizing
operations   with   chromate   rinses.   Separate  treatment  of  this
wastewater is necessary to  reduce  the  hexavalent  chromium  to  the
trivalent  state.   Subsequent  removal  of  the trivalent chromium is
accomplished using the same treatment technologies used  for  treating
other toxic metal pollutants.

The   Agency   has   concluded  that  wastewater  characteristics  and
treatability warrant subdivision by product type,  i.e.,  galvanizing,
and terne and other metal coatings.

Size and Age

The  Agency  considered  the  impact  of  size  and age on the need to
further subdivide hot coating operations and found the  impact  to  be
much less signficant than the other factors evaluated.  No impact from
age  of  hot  coating  lines  was  found.   Some  of the most advanced
wastewater treatment systems treat wastewaters from old coating lines.
Very often wastewaters from  a  variety  of  finishing  operations  of
varying ages and sizes are treated in the same system.  Raw wastewater
quality  and  treatability were likewise found to be unaffected by the
                                    447

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age or size of  a  given   hot   coating   line.    Applied   rinseweiter   and
scrubber  flow  rates  for all  hot  coating  operations  were  compared  with
size and age  (year of installation  of  the oldest   active   hot   coating
operation  at   the plant site) of the  coating  lines.  Refer  to  Figures
IV-1  and  IV-3   for  rinsewater  and   scrubber   flows,   respectively/
reported  by  the industry for strip,  sheet  and miscellaneous products
and to Figure IV-2 and  IV-4 for the same   flow information  for   wire
product  and  fastener   coating   lines.    As  shown  in  the figures,  no
correlation exists between age  and process  flows.    Plants   of   all
"ages" appear to  have both extremes of applied flow.

The  figures  for the   applied   rinse flow  versus production capacity
demonstrate  that all   coating   operations,   large  and   small,   have
comparable  applied   rinse flow rates  within each product subdivision.
Hence, no correlation exists  between flow rates and  size within   the
two  product  subdivisions.   Flows (gal/ton)  for  wire products and
fasteners tended  to be  3 to  4   times those  for  strip,   sheet   and
miscellaneous  products.   This   difference  is,  however,  addressed by
subdivision of the subcategory by product type rather than by size.

Figures IV-1 and  IV-2 also indicate that  size  is  related  to  discharge
mode,  i.e.,  directly   to a  receiving stream  or  indirectly  to  a POTW.
The  large  hot   coating operations    (strip,    sheet,    and   larger
miscellaneous  shapes  which  are produced at  rates  exceeding 200  tons
per turn) rarely  discharge wastewaters to POTWs,   while   approximately
40%  of  the  wire  and  wire products   lines discharge to municipal
treatment  plants.    Such differences are  accounted  for   in    the
development  of   separate effluent limitations  and standards  for the
wire products  and  fasteners segment.    Thus,   subdivision by   size
becomes  unnecessary  since   potential  size-related distinctions  have
been covered by subdivision according  to  type  of  product  being  coated.
Size and age in themselves do not  affect the attainability   of   the
final limitations and standards.

The  Agency also  investigated the effect  of  age on the feasibility and
cost of retrofitting  pollution control equipment  at  hot coating lines.
Comparison of the age of  a hot coating  line  with   the  year  in which
pollution   control   facilities  were  installed (see   Table  IV-1),
demonstrate that  pollution control  equipment can  be  retrofitted.    As
noted  above,  the wastewater characteristics  and treatability  are the
same for old and  new  operations.  Additionally,   no  differences   were
found in the effluent from facilities  treating wastewaters from plants
of  all ages.  As a result, the Agency has concluded that  retrofitting
wastewater pollution  control  systems   to   hot  coating  operations  is
feasible.

The  actual  costs  of   retrofitting   wastewater   treatment  systems  to
existing production units were  acquired   from industry   as  part  of
detailed data collection  portfolios (D-DCPs).  Operators were asked  to
identify  costs   which   would  not  have been incurred if  treatment was
installed concurrently  with production units or during major  rebuilds
of  production  facilities.   Nine  plants  responded to this  portion  of
the D-DCP.   Four  plants  could not determine  retrofit  costs  for  hot
                                   448

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coating  treatment since a central treatment plant had been installed,
and costs, if any, could not be segregated.  No  retrofit  costs  were
reported  for  two plants, the smallest galvanizer and a terne coating
line.  In one case, a  lagoon  was  added  to  an  existing  treatment
facility,  but  this  was  considered  by the plant to be an upgrading
cost, not a retrofit cost.  Retrofit costs  for  the  remaining  three
plants  were  listed  as  unknown.  One of these plants with a central
treatment system with installation costs of $1,650,000 estimated  that
25-50  percent  could  be  saved  if a greenfield treatment system was
built adjacent to the production units.  Treatment had to be installed
1500 to 2000 feet from the wastewater sources, most of which were acid
pickling operations.   The  Agency  estimates  that  $670,000  of  the
$1,650,000  investment  cost  for  this  central  treatment  plant  is
attributable to the treatment of  hot  coating  wastewaters.   On  the
basis  of  model  treatment system (see Section VIII), the Agency also
estimated that the costs for treating the  wastewaters  from  the  hot
coating  operations  at this site amount to $974,500.  This cost is 45
percent  greater  than  plant  reported  costs.   Even  though   plant
personnel  estimate that 25-50 percent of their costs are attributable
to "retrofit", the money spent is considerably less than the  Agency's
estimated  costs  based  on  the treatment models used throughout this
study.  It is likely that a portion of the so-called "retrofit"  costs
are  really  site-specific  costs.  New  plants  have,  in  the  past,
constructed central treatment systems at considerable  distances  from
the wastewater sources (e.g., Plants 0856F and 0112D).

A   similar  situation  was  reported  by  Plant  1.18(NN-2).   Initial
investment  costs  reported  for  this  plant   treating   galvanizing
wastewater  alone,  were  $1,500,930.  This compares with the Agency's
estimated cost of $1,575,300 based on  model  costs.   This  treatment
plant  is  also  situated  a considerable distance from the production
units, yet reported costs were 5% less than the model-based estimates.
Hence, the Agency's model-based cost estimates are sufficient to cover
site-specific  and  retrofit  costs  for  both  separate  and  central
treatment  systems.   The  Agency  concludes  that older plants do not
incur any unique or substantial costs to  retrofit  pollution  control
equipment.

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  is  not  appropriate.   Additionally,  the  Agency
concluded  that  size has no significant effect on further subdivision
or segmenting of the subcategory.
Geographic Location

Hot  coating  operations   are   widespread,   with
distinctions  noted  due  to  geographic  location.
no   significant
DCP  respondents
                                   449

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included  plants  from  twenty-one  different  states,  and  a  recent
membership  list  of  the  American  Hot  Dip  Galvanizers Association
indicates that galvanizing is practiced in forty-one different states.
However, about 60% of all hot coating operations are situated in  four
states   -   Pennsylvania,   Illinois,  Ohio  and  California.   Since
operations are nearly always confined within an enclosed building, the
effects of climate and adverse weather are greatly minimized.  Special
consideration of water problems for "arid" or "semi-arid"  regions  is
not  appropriate  since  the  model treatment systems do not result in
significant  water  consumption.   Plants   located   in   "arid"   or
"semi-arid"   regions   are  presently  operating  coating  lines  and
wastewater treatment systems comparable to  those  employed  in  other
parts  of  the  nation  and will have no unusual problems in upgrading
existing  systems.   Hence,  the   Agency   concluded   that   further
subdivision  of  the  hot  coating  subcategory  based upon geographic
location is not warranted.

Process Water Usat

The Agency reviewed the  process  water  applied  rates  and  effluent
discharge  rates  using data obtained from industry in the DCPs.  This
review revealed that the rinsewater application  and  discharge  rates
are  related  to  product  type,  as discussed previously.  Operations
coating fasteners, rods, wire and  wire  products  reported  uniformly
higher  rinsewater  flow  rates  than operations coating strip, sheet,
pipes, tubes and other miscellaneous products.  The higher flow  rates
for  the  former  products  are related to the larger surface area per
unit of weight associated with these products.  The rinse  water  flow
rates  within  these  product groupings do not vary substantially with
the type  of  metal  coating.   As  a  result  of  the  difference  in
rinsewater  flows,  the  Agency subdivided the hot coating subcategory
into two product  groupings,  i.e.,  sheet,  strip  and  miscellaneous
products  and  wire  'products  and fasteners.  The flow allowances for
rinsewaters are established on a gallon  per  ton  of  product  basis,
since these flows are related to the production rate.

The  wastewater  discharges  from  fume scrubbers were also evaluated.
The Agency determined that these scrubber  water  discharges  are  not
related  to  product  type  nor to production rates.  In addition, the
Agency concluded that no definitive correlation exists  between  these
discharges  and  the  design  gas  flow rate through the scrubbers, or
scrubber type.   As  a  result,  the  Agency  established  a  separate
subdivision  for  fume  scrubber discharges and set the discharge flow
allowance on a gallon per minute basis.  The effluent limitations  and
standards  for this subdivision are established on a daily mass basis.
These limitations are to be added to the  limitations  for  rinsewater
discharges, where fume scrubbers are installed.

The   subdivisions   selected  by  the  Agency  for  the  hot  coating
subcategory are as follows:
                                   450

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Galvanizing Coating Operations
     Strip, sheet, and miscellaneous products
     Wire products and fasteners
Terne Coating Operations
Other Metal Coating Operations
     Strip, sheet, and miscellaneous products
     Wire products and fasteners
                               451

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                                         TABLE IV-1
                         HOT COATING PLANTS THAT HAVE DEMONSTRATED
                    THE ABILITY TO RETROFIT POLLUTION CONTROL EQUIPMENT
Plant Reference
	Code	

0112B
0112G
01121
01121
0384A
0384A
0448A
0460A
0476A
047 6 A
0492A
0580A
0584C
0640
0640
0856D
0856D
0856D
0868A

Product
Strip
Fasteners
Fasteners
Fasteners
Strip
Strip
Sheet
Wire
Wire
Pipe
Pipe
Wire Cloth
Strip
Fencing
Wire
Strip
Strip
Strip
Sheet
Coating
Operation
Galvanizing
Galvanizing
Galvanizing
Aluminiz ing
Galvanizing
Aluminiz ing
Ga Ivaniz ing
Galvanizing
Galvanizing
Galvanizing
Galvanizing
Galvanizing
Galvanizing
Galvanizing
Galvanizing
Terne Coating
Galvanizing .
Other (Al/Zn)
Galvanizing
Plant Age
(Year)
1962
^1.930
1922
1955
1951
1961
1967
1930
vT!930
1930
1962
1962
1956
1936
1936
1964
1947
1949
1948
Treatment Age
   (Year)

   1971
   1973
   1977
   1977
   1970
   1970
   1970
   1968
   1977
   1977
   1976
   1967
   1965
   1961
   1961
   1979
   1979
   1979
   1977
                                           452

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                       HOT COATING SUBCATEGORY

                              SECTION V

              WATER USE AND WASTEWATER CHARACTERIZATION
The Agency evaluated process water use and  total  wastewater  volumes
based  upon  data  obtained  from the basic DCP responses received for
most domestic hot coating operations.  Where fume scrubbers are  used,
the  Agency  determined  the additional wastewater volumes and quality
attributable  to  fume  scrubber  operation.   The  Agency  identified
existing  wastewater  control and treatment technology for each plant,
and determined the disposal method for process wastewaters.

Wastewater characterization is based  upon  monitoring  data  obtained
during  field  sampling programs.  Additional pollutant load, effluent
quality and.cost data were sought  for  nine  hot  coating  operations
through detailed data collection portfolios (D-DCPs).

Water  use  rates discussed below pertain only to process wastewaters,
and do not include noncontact or nonprocess cooling waters.

Water Use in. Hot Coating Operations

Variations in applied water flow  rates  are  shown   in  Tables  III-l
through  III-3  for the various hot  coating operations.  Figures UJ-1"
through II1-5 illustrate why such variations are necessary.  Note that
Figure III-l  (galvanizing) depicts at least eight potential sources of
process wastewaters including two mild pickling steps; a  three  stage
alkaline  cleaning  intermediate  step;  and,  at  least one source of
noncontact cooling water.  Total wastewater flow from this  line  would
be  quite  high.   On  the  other  hand,  Figure  III-3 also depicts  a
galvanizing operation with only three potential sources,  and  two  ot
these   three  are  noncontact  cooling  water.   The actual  process
wastewater flow from this line would be a fraction of the  flow  from
the line shown in Figure III-lf yet  both could be producing galvanized
ware of comparable size, shape and quantity.

Line  configuration  is determined by product requirements, as are the
number and nature of the intermediate steps in the   process.   As  the
process  becomes  more complex,  the  opportunity, arises to reduce flows
by recycle of a portion of   the  wastewater,  and  at the  same  time
recover  chemical  values.   An  example appears  in Figure  III-l, where
three consecutive steps  in preparing the  product  for  final  coating
involve the use of alkaline  cleaners.   Note  that wastewater overflows
from  the hot electrolytic alkaline  cleaning  tank for reuse in the hot
alkaline scrubber, which in  turn   is reused  as  makeup   to   the  hot
alkaline  dip tank.    Instead of  three separate wastewater discharges
from  this cleaning step, each contributing  high  levels of  alkalis  and
phosphates,   a   single  intermittent  discharge  occurs.    Such   flow
reduction and chemical  conservation  techniques  can be used  to  minimize
                                    457

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 the total process wastewater discharge  from  complex  coating  lines.
 Discharges  from  acid  pickling  and .alkaline cleaning operations are
 subject to the limitations established for those subcategories.   Only
 rinse  waters and fume scrubber waters from the coating operations are
 subject  to  the  limitations  established   for   the   hot   coating
 subcategory.

 The  major wastewater flows originating from hot coating operations in
 the steel industry fall into several distinct groupings:

 1.    Continuously running dilute rinse waters  from  rinses  following
      chemical  treatment  or  surface  passivation  steps;  and, final
      product rinses after hot dipping.  These waters contain suspended
      and dissolved solids, chlorides, sulfates,  phosphates, silicates,
      oily matter, and varying amounts of dissolved metals (iron, zinc,
      chromium,   lead,  tin,  aluminum,  cadmium)   depending  on  which
      coating metal is used.

 2.    Concentrated intermittent discharges (including fluxes),  chemical
      treatment  solutions,  and regenerant solutions  from  in-line  ion
      exchange systems.   These discharges contain  higher concentrations
      of  the pollutants  noted  above.    Discharge volumes from these
      sources can  be minimized by close attention   to  maintenance  and
      operating  conditions,  and through provision of dragout  recovery
      units.   Hot  dipped coating baths themselves  are never discharged.
      Instead, they are  recovered and continuously regenerated  as  part
      of  the coating  operation,   or  sold to outside contractors for
      processing and recovery.

 3.    Fume scrubber wastewaters produced  by the continuous scrubbing of
      vapors  and mists collected from the coating  steps.   Scrubbers may
      be once-through or recirculating, and  produce  wastewaters  that
      may be  used  as process rinses,  since only volatile components are
      present in   the air  to be scrubbed.   Less than 40 percent  of all
      hot coating  lines  have wet fume scrubbers.   A few plants  have dry
      fume absorbers.    Vapor   and   mist  control   for  some   coating
      operations include tank covers  or fans to divert fumes out  of the
      work area.

Applied Flow Rates

Responses  to   DCPs   were  reviewed for applied rinse  and  fume  scrubber
flow  rates.   Separate  compilations  were made  for  various  final  coated
products  and for  direct*and POTW dischargers.  Data are summarized  in
Table   V-l   in  terms   of   gallons, of  process  water applied per  ton  of
coated  product  for the  rinses  and in gallons per minute for  the   fume
scrubbers.   Wire  products and  fasteners  have   consistently  higher
average flow rates than  do  strip, sheet  or miscellaneous shapes.   The
Agency   could   not  determine   whether this  is due  entirely to rinsing
requirements, or  to  a greater  likelihood  for   wire  mills  to  include
noncontact cooling waters  in DCP responses.  In either  case, some  wire
mills   were  operating   successfully with  considerably   less  water.
However, even a comparison  of minimum applied  flows bears out the  fact
                                   458

-------
that wire and related products require more water than strip, sheet or
miscellaneous  shapes.   In  addition   to   surface   area,   another
contributing  factor  may be that all but one out of 83 wire mills use
fluxes, thus increasing the rinsing requirements, while  only  20%  of
the  strip  and sheet mills use fluxes.  For these reasons, the Agency
has  promulgated  limitations  and  standards  for  wire  and  related
products which are based upon the higher water usage rates observed.

Unlike the rinse waters, the fume scrubbers were found to be unrelated
to  product  type  or  production rates.  In addition these discharges
could not be correlated with design gas flow through the scrubbers  or
the  type of scrubber used.  Consequently, the fume scrubber flows are
expressed as gallon per minute and the limitations  and  standards  in
terms of a mass loading of kg per day.

Wastewater Characterization

The  Agency  obtained  information on wastewater quality from sampling
programs at eleven selected hot coating operations, two of which  were
revisited two years after an initial sampling survey.  The Agency also
solicited  long-term  data for nine hot coating operations.  A summary
of pollutants found   in  galvanizing,  terne-coating  and  aluminizing
operation*  wastewaters   is   shown   in  Tables  V-2,  V-3  and  V-4
respectively.

The large variations  in the levels of most pollutants as shown in  the
tables  are  due  mainly  to coating line.configuration.  For example,
molten lead is used at some plants to anneal wire  products  prior  to
coating.   If  a  pickling  or  rinsing  step  follows lead annealing,
considerable lead may be found in the wastewater.  Otherwise, lead  is
present  only  as  a  contaminant  in the zinc metal used for coating.
Zinc was found only at low levels at several of the galvanizing  lines
listed.   In  those   cases  where  zinc  content   is  high   in the. raw
wastewaters, it is often the result of the repickling and coating of  a
previously  galvanized  product  which  failed  to  pass    inspection.
Similar relationships were noted for chromium and  nickel.

Relatively  low  concentrations of toxic organic pollutants were found
in raw wastewaters from all hot coating operations  during   the  toxic
pollutant   survey.    The  phthalates  and  methylene  chloride  were
universally  present,  but  the  Agency   believes   that    they   are
attributable  to  sampling  and  analytical  techniques.  The remaining
toxic  organic tended  to be present in plant  intakes at levels equal to
or greater than those found in hot coating wastewaters.  In  any  event
these   toxic   pollutants   appear   at  levels   below  treatability.
Therefore, as noted  in Section VI, these pollutants were not  selected
for regulation.
                                    459

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                                TABLE  V-4

             NET RAW WASTEWATER - HOT COATING - ALUMINIZING
             SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS

                         TOXIC POLLUTANT SURVEY
Plant Codes

Sample Point(s)
Flow, gal/ton
Product
     Suspended Solids
     Oil and Grease
     Aluminum
     Hexavalent Chromium
     PH

 44  Methylene Chloride  .
 66  Bis-(2-ethyl hexyl) phthalate
 67  Butyl benzyl phthalate
 68  Di-n-butyl phthalate
 70  Diethyl phthalate

118  Cadmium
119  Chromium
120  Copper
122  Lead
128  Zinc
124  Nickel

     Iron,  Dissolved
           01121
            116
            E
           3882
         Fasteners
mg/1

231
19
12
0.002
6.4-10.5

0.015
0.052
0.060
0.038
0.011

<0.01
0.10
0.21
0.39
0.35
0.18

49
lbs/1000 Ib

  3.74
  0.308
  0.194
  0.000032
  0.000243
  0.000842
  0.000971
  0.000615
  0.000178

  <0.000162
  0.00162
  0.00340
  0.00631
  0.00567
  0.00291

  0.793
                                     464

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                       HOT COATING SUBGATEGORY

                              SECTION VI

                        WASTEWATER POLLUTANTS
For  hot  coating  operations,  the pollutants limited in the original
regulation were oil  and  grease,  suspended  solids,  lead,  chromium
(total  and  hexavalent), tin, zinc, and pH.  As a result of the toxic
pollutant survey and the addition  of  other  hot  coating  operations
besides   galvanizing  and  terne  coating,  other  pollutants,  (e-9-
aluminum, cadmium, copper, dissolved iron and nickel) were  considered
for addition to the list of selected pollutants in certain hot coating
alternative treatment systems.  The Agency also found other pollutants
to  be  present  in  significant quantities in hot coating wastewaters
(e.g., chlorides, sulfates, dissolved solids), but  did  not  consider
limitations  for them.  In general, these pollutants are not toxic and
difficult to remove.  Treatment for these pollutants is  not  commonly
practiced in any industry.

Raw  wastewater  quality  and  treated  effluent  characteristics  are
described in detail in Sections V and VII.  Refer to  Tables  V-2  and
VII-2  for  galvanizing,  Tables  V-3 and VII-3 for terne coating, and
Tables V-4 and VII-4 for aluminizing.

Conventional Pollutants

The Agency originally promulgated limitations  for  suspended  solids,
oil  and  grease  and  pH  in  1976.   Suspended  solids  not only are
routinely present in raw wastewaters, but also  are  generated  during
treatment,  as  dissolved  metals   are  precipitated  out of solution.
Thus, effective removal of suspended solids minimizes the discharge of
toxic metal pollutants.

Oil and grease was selected for  limitation  because  of  the  use  of
lubricants  and  oil  baths   in  the  hot coating processes,  Sampling
indicated the presence of oil  and grease at concentrations  up  to  200
mg/1.

Finally  pH  was  chosen primarily because of the detrimental effect of
extremes in pH levels, and because  control  of pH significantly affects
the removal of dissolved metals.  Without such  control,  unacceptable
discharges of toxic metals could occur.

These  pollutants   are   common  to   all hot coating  operations.   Thus,
effluent limitations  and  standards   for  these  pollutants   have   been
promulgated at the  BPT,  BCT and  NSPS levels.
                                    465

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 Toxic Pollutants

 Analytical  results  for  36 toxic pollutants found in raw and treated
 wastewaters are summarized in Table VI-1 through  VI-3.   Twnety-three
 different toxic organic pollutants wer.e identified as present and then
 quantified  at  the  seven  hot  coating  plants  sampled for priority
 pollutants, although only about half that number  were  identified  at
 any  single plant.   Twelve of the twenty-three organic pollutants were
 found at only one of the plants, generally at concentrations less than
 0.01  mg/1.  Nine of the twenty-three organic pollutants were found  at
 levels  in  excess  of  0.01  mg/1 in either raw or treated hot coating
 wastewaters,  but one of those,  methylene chloride, is believed  to  be
 an  artifact.    In  treated effluents,  methylene chloride, chloroform,
 1,1,1  trichloroethane and 4,6-dinitro-o-cresol were found in excess of
 0.01   mg/1,  with  only  methylene  chloride  exceeding   0.05   mg/1.
 Phthalates  were  also found universally where automatic samplers were
 used  to  collect samples,  indicating a problem with leaching of plastic
 tubing plasticizers into the sample.

 Of the 130  different  pollutants  listed  as  toxics,   35  (excluding
 methylene  chloride)   have  been  found  to  be  present in measurable
 concentrations in raw wastewater or treated effluent  from  the  seven
 plants surveyed during the toxic pollutant survey of this subcategory.
 Not  all   of   the  35  pollutants  are   directly  related to the plant
 operations.  As many  as 26 have been  identified in the  water  used  as
 makeup at the  surveyed plants,  although concentrations  tend to be less
 than   10  micrograms per liter for most  pollutants in the intake waters
 tested.

 No definite source  was ascribed to the  toxic organic pollutants  found
 in wastewaters  from  hot  coating operations.   Residual  oils applied
 during cold rolling operations  prior  to coating is one  possible source
 of low level contamination of coating wastewaters by so many different
 organics.    Trichloroethylene,    tetrachloroethylene,     and    1,1,1
 trichloroethane  may   be   present  in the  degreasing solvent used as a
 cleaner prior  to  coating.   Toxic metal  pollutants  are   more  directly
 related   to the coating operations.   Not only are certain  toxic metals
 like zinc,, cadmium, lead,  and chromium  used in the hot  dipped  coating
 processes,  but most  of the other toxic metals are also found as  trace
 contaminants in the baths  associated  with  hot   coating.    Chromium,
 copper,   lead,  nickel,  and  zinc  were  found   in  raw  and  treated
 wastewaters from  all  hot coating operations.   Most concentrations were
 reduced to  a considerable  extent by treatment.

 The wastewater  treatment systems used at these hot coating plants were
 not designed to control and treat the toxic organic pollutants   found
 in these wastewaters.   However,  most  plants show  some reduction  in the
quantity  of  these  pollutants   found   in   their   wastewaters.   Toxic
organic pollutants  in effluents  were  incidentally  treated  along   with
other  pollutants to  levels such  that no specific  organic  removal  step
 is practical other  than recycle.  Toxic  metals were also  removed  to
low  levels  through  the  use   of  precipitation,   flocculation,  and
sedimentation  (or filtration).   As a  result,  the Agency  believes   that
                                    466

-------
an acceptable control of the various toxic pollutants from hot coating
operations   can   be  achieved  by  establishing  limitations  for  a
relatively small number of indicator pollutants.   For  a  summary  of
pollutants  selected for limitation, refer to Table VI-4.  As noted in
the table, a common list of pollutants has been selected for  all  hot
coating  operations.   The  Agency  believes  that the limitations for
these pollutants will  result  in  the  control  of  the  other  toxic
pollutants  found  in  these  wastewaters.   In  addition the use of a
common list of pollutants will faciliate co-treatment  of  wastewaters
from  the  different  hot  coatings  lines, as well as with compatible
wastewaters from other subcategories.

At proposal of this regulation (46  FR  1858)  the  Agency  considered
establishing  effluent  limitations  for  cadmium  for discharges from
cadmium coating operations.  The information provided by the  industry
in  the  DCPs  indicate that there were two coating operations (Plants
0580G and 0792A) that used  cadmium  as  a  principal  coating  metal.
Recent  information  received  by the Agency indicate that Plant 0580G
has  been  permanently  retired.   Plant  0792A  has  been   shutdown.
However,  the  cadmium  coating  line  will  be  relocated  at another
existing plant site located in  Pennsylvania.   This  plant  has  been
retrofitted  within  the  past  three years with a BPT type wastewater
treatment facility designed to  remove  toxic  metals.   Further,  the
Agency  has  learned that this cadmium coating line is an intermittent
batch operation.  Water is used in this operation to quench  the  wire
product  following  coating.   Discharge  from this quench tank occurs
infrequently.  Due to the nature of this operation, and  the fact  that
the  Agency  is unaware of any hot dip, cadmium coating  line currently
in operation, the Agency has  decided  not  to  promulgate  nationally
applicable  effluent  limitations  and  standards  for cadmium coating
operations.  The Agency believes that, in  this  particular  instance,
effluent  limitations  and standards can be more effectively developed
on a site specific basis by the permit writer.

Data are also available for a variety of nontoxic pollutants for which
limitations are not being promulgated.  These pollutants were measured
to enable evaluation of factors such as scale formation  and  corrosion
where recycle of wastewater is considered, and  to aid  in evaluation of
chemical treatment costs and sludge  loads.  Additional measurements in
hot coating operations  included acidity/alkalinity, calcium, chloride,
iron, solids  (dissolved), and sulfate.
                                     467

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                                       468

-------
                               TABLE VI-2

       TOXIC POLLUTANTS IN HOT COATING - TERNE COATING WASTEWATERS

                       (All  concentrations  in mg/1)
Toxic Organics
23  Chloroform
30  1,2-Trans-dichloroethylehe
44  Methylene chloride
65  Phenol
85  Tetrachloroethylene

Toxic Metals and Cyanide

114  Antimony
115  Arsenic
117  Beryllium
118  Cadmium
119  Chromium
120  Copper
121  Cyanide
122  Lead
124  Nickel
125  Selenium
126  Silver
127  Thallium
128  Zinc
Q856D
 113
 Raw

0.050
0.009
1.25
0.008
0.007
0.006
0.001
<0.008
<0.080
2.675
0.040
0.003
0.030
0.2
<0.002
<0.10
<0.050
0.062
NOTE:  Plant's wastewater  treatment under  construction  at  time
       of sampling.  Raw. wastewater sample was  the  only one
       available.
                                     469

-------
                                TABLE VI-3

         TOXIC POLLUTANTS IN HOT COATING - ALUMINIZING WASTEWATERS
                       (All concentrations in mg/1)
 Toxic Organics
 23   Chloroform
 44   Methylene  Chloride
 60   4,6-Dinitro-o-cresol

 Toxic Metals and Cyanide

 118  Cadmium
 119  Chromium
 120  Copper
 121  Cyanide
 122  Lead
 124  Nickel
 126  Silver
 128  Zinc
           01121
            116
  Raw

<0.010
 0.010
 0.006
<0.010
 0.10
 0.22
 0.001
 0.39
 0.18
<0.02
 0.35
 Treated*

<0.010
 0.006
 ND
<0.010
<0.03
 0.02
 0.001
 0.05
 0.015
<0.02
 0.13
*:  Indicates water quality of central treatment effluent
ND:  Not detected
                                    470

-------
                               TABLE VI-4

                      SELECTED POLLUTANT PARAMETERS
                          HOT COATING OPERATIONS
                                     All Hot Coating Operations
Total Suspended Solids
Oils and Greases
pH, Units          '
Chromium, Hexavalent
Lead, Total
Zinc, Total
BPT

X
X
X
X
X
X
                                     BAT
X
X
X
                      PSES
X
X
X
NSPS

X
X
X
X
X
X
                                                                      PSNS
X
X
X
(1) Limitation only applies to operations which discharge wastewaters from a chromate
    rinsing step.
X:  Selected pollutant parameter subject to limitation or regulation.
                                       471

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-------
                       HOT COATING SUBCATEGORY

                             SECTION VII

                   CONTROL AND TREATMENT TECHNOLOGY
In  developing  the  alternative  treatment  systems,  limitations and
incremental  costs,  the  Agency  considered  the  level  of  existing
wastewater  treatment  at  most  plants.   The  alternative  treatment
systems were then formulated in an "add-on"  fashion  to  these  basic
levels.   This section summarizes treatment practices currently in use
in the industry.  Descriptions of plants sampled by the Agency and the
respective effluent data are also presented.  In addition, the  impact
of  make-up  water  quality  on  raw  wastewater pollutant loadings is
assessed.

Summary of Treatment Practices
Currently Employed for Hot Coating Operations

As noted previously, the  process  wastewaters  generated  during  hot
coating  operations  include  fume scrubbing wastewaters, and chemical
treatment solutions and rinses.   Wastewaters  are  often  treated  in
central  treatment  systems  along with wastewaters from other forming
and finishing operations.  DCP data indicate that more than 75% of all
hot coating wastewaters are  treated  jointly  with  wastewaters  from
pickling,  cold  rolling, hot forming, and other finishing operations.
Most of the remaining 25%,  are  providing  some  degree  of  separate
treatment prior to central treatment.

The more common hot coating treatment practices are listed below:

     No  matter  what  wastewater  treatment  technique  is  used,  an
     important  first  step is to minimize the quantity of wastewaters
     requiring treatment.  This is accomplished by  providing  dragout
     recovery  tanks  downstream of the main coating tanks; by reusing
     or recycling  the rinsewaters and fume  scrubber  wastewaters;  by
     employing  high  pressure spray rinses with recycling or reuse of
     rinsewaters;  and by attention to maintenance of equipment such as
     rolls and squeegees designed to reduce solution losses.  At  some
     hot   coating   lines  with  slower   line  speeds,  carryover  of
     wastewaters is minimized to the point that  only  low  levels  of
     pollutants are discharged.

     Cascade  rinse  systems  are  effective  methods  for  minimizing
     wastewater volumes.

     The first  treatment step for hot coating wastewaters   is  usually
     the   blending  of these wastewaters with alkaline wastewaters, to
     precipitate the dissolved metals.  This blending  of  wastewaters
     is practiced  at several hot coating plants.
1 .
2.
                                    473

-------
3.   Improved treatment effectiveness is attained  through  controlled
     neutralization/precipitation   of   these  wastewaters  using  an
     alkaline material such as lime or caustic  soda.   Use  of  these
     products  achieves  higher  pH  levels  than is normally possible
     through simply blending with alkaline wastewaters.  Polymers  are
     also   used  to  enhance  settling.   Flocculator-clarifiers  are
     installed at these  treatment  facilities  to  remove  the  large
     quantities   of   metal   hydroxide  precipitates.   Sludges  are
     sometimes dewatered using vacuum filters and are then transferred
     to landfill areas.  Wet sludges are  landfilled  or  lagooned  at
     many hot coating operations.

4.   Other  treatment  methods  depend  upon   the   source   of   the
     wastewaters.  These are tailored to specific needs, for example:

     Reduction of Hexavalent Chromium - Galvanizing and other metallic
     coating  operations  which  produce wastewaters contaminated with
     chromate or dichromate ions  have  separate  pretreatment  stages
     which  are  designed  to  reduce  toxic  hexavalent  chromium  to
     trivalent chromium prior to neutralization.  Most often,  pickling
     rinse solutions or spent pickle  liquors  are  blended  with  the
     chromium  wastewaters  to acidify the wastewaters and provide the
     required reductant.   In some cases,  additional  reducing  agents
     such as bisulphites or sulfur dioxide gases are used in place of,
     or  in  addition to,  pickling wastes.   Wastewaters containing the
     reduced chromium are then discharged to a  neutralization  stage,
     where  the  addition  of  lime  or  caustic soda precipitates the
     chromium as  hydroxide.    Alternatively,  the  chromates  may  be
     precipitated  out  of  solution  by the addition of barium salts,
     such as sulfates or carbonates.   A precipitate of barium chromate
     can be separated  out  for  subsequent  recovery  of  barium  and
     chromium.    Also,  ion  exchange  techniques  have  been  used at
     several coating lines to recover clean chromic acid  from  strong
     solutions  contaminated  by  iron  and  trivalent  chromium.   The
     recovered acid is reused in the  coating  or  chemical   treatment
     operations.

     Precipitation  of Aluminum,  Cadmium,  Copper,  Lead,  Tin,  and Other
     Metals - As described previously in Section VI,   the  sources  of
     these  toxic  metal  pollutants in hot  coating operations  are from
     rinsing or  quenching  of  the product after the coatings  have  been
     applied;  and,  in the  disposal  of spent coatings solutions.

     Hydrated  lime  or  caustic  soda  is  used to raise the pH of the
     wastewaters.    At  the  elevated   pH,    metal    hydroxides   are
     precipitated  and  are  removed  by  sedimentation.   This  treatment
     sequence is  very common  in this   industry.    An  alternate  heavy
     metal   precipitation   step  has   been  used in the metal  finishing
     industry, and the Agency  considers  it  to be applicable  to  similar
     wastewaters  from coating   operations.    The  treatment  procedure
     involves  the addition of  soluble sulfides (such as  sodium  sulfide
     or   sodium   hydrosulfide)   or  a  ferrous  sulfide  slurry  to  form
     insoluble  metal   sulfides  which   can  be  separated  prior    to
                                   474

-------
5.
 discharge.    Metal   sulfides  have  lower solubilities than metal
 hydroxides.    However,   data  from  pilot  studies  conducted  on
 steelmaking  wastewaters  indicate that precipitation with sulfides
 does  not  result in  substantially greater removal  of toxic metals.

 Ferrous    iron  is   also  present  in  hot  coating  wastewaters.
 Aeration,  with subsequent neutralization is  currently  the  most
 widely used  method  for treating ferrous iron.   This is usually
 done  in a rapid mixing tank where the pH  of  the  wastewater  is
 adjusted   to  8.5  with  lime.   The neutralized wastewater is then
 pumped to a  clarifier, thickener or settling  lagoon,   where  the
 precipitated  iron   in  the hydroxide form settles out along with
 other metal  hydroxide precipitates.  In a properly  designed  and
 operated   treatment  plant,  the  dissolved iron  in the discharge
 from  the  sedimentation unit should be significantly less  than  1
'mg/1.

 Oil   and   Grease -  The removal of oil and grease  from wastewaters
 can be effected by  the following techniques used  either alone  or
 in combination depending on the nature of the wastewater.

 Gravity   Separation  - With the exception of filtration, free oil.
 removal   processes   are   based  on   density   separation."   The
 wastewaters   are  treated  in a settling basin or clarifier where
 the free  oils  are   floated  to  the  surface  and  removed  with
 skimmers.  The heavier oil-coated particles settle to the bottom.
 Many   hot coating   wastewater  treatment  plants include surface
 skimmers  to  remove  floating oil.

 Suspended Solids  -  Suspended  solids  in   the   hot   coating
 subcategory   for  the most part consist of metals removed during
 rinsing,   and   metal   hydroxides   generated    during    lime
 neutralization   of  these  wastewaters.   Suspended,  solids  are
 usually   treated  by  gravity  separation.    Most   plants   use
 clarifiers  or  thickeners,  supplemented  with  the  addition of
 appropriate  organic flocculant aids.  Suspended solids  are  also
 removed at some plants by filtration.

 Co-treatment of wastewaters from many different sources into  one
 central   treatment  system are commonly practiced  in the industry.
 In these  systems, wastewaters  from  hot  coating  lines  usually
 represent a  minor  portion  of the total flow,  notably when hot
 forming wastewaters are  present.  Such terminal treatment systems
 may  incorporate any or all of  the  individual treatment  stages
 mentioned above prior to mixing with other wastewaters.  At some
 plants all wastewaters are combined before  treatment  commences.
 This   results   in  dilution  of  the  wastes -and  reduces  the
 effectiveness of  subsequent  treatment.   The only  way  to  be
 certain   that  such  loads are reduced is to provide pretreatment
 prior to  mixing with other incompatible wastewaters.
                                    475

-------
Plant Visits

Visits were made to eleven plants to study the  individual  operations
included  in  the hot coating subcategory.  The standard abbreviations
and symbols used for the control and treatment technologies are listed
in Table VII-1.   Tables  VII-2  through  VII-4  present  the  treated
effluent waste loads from these plants.

Plant 1-2 (0856P) - Figure VII-1

Wire  galvanizing wastewaters are diluted and treated by reaction with
other mill wastewaters in a terminal lagoon, with subsequent discharge
to a receiving stream.

Plant V-2 (0936) - Figure VII-2
_______     _____                                                  ^

Wastewaters from wire  hot  coating  and  pickling  are  combined  and
neutralized with caustic soda prior to discharge to a POTW.

Plant MM-2 (0856F) - Figure VII-3

Hot  and  cold  strip/sheet  coating  wastewaters  are  combined  with
wastewaters from other sources.  Treatment includes equalization,  oil
separation,  aeration,  sedimentation, lagooning, and recirculation to
service water with intermittent blowdown to the river.

Plant NN-2 (0920E) - Figure VII-4

This plant uses equalization, mixing, two-stage lime addition, polymer
feed,  and  clarification  for  treatment  of  batch  and   continuous
galvanizing  wastewaters . from  strip,  sheet  and miscellaneous shape
production lines.   Clarifier  underflows  are  vacuum  filtered  then
disposed  of  in  a landfill.  Overflows are discharged to a receiving
stream.

Plant 00-2 (0060) - Figure VII-5

At this plant/ mixing and dilution of rinsewaters from  terne  coating
of  strip/sheet  prior to discharge is practiced.  Solution dragout is
minimized through strict attention to maintenance of equipment.

Plant PP-2 (0856D) - Figure VI1-6

See Plant 00-2 (0060).

Plant 111 (0612) - Figure VII-7

Wiper waters from wire galvanizing operations are collected,  recycled
via hot rolling mills, with a small continuous bleed-off to treatment.
Pickling   rinses   and  spent  HC1  concentrates  are  combined  with
wastewaters from  nail  and  fence  galvanizing;  treated  with  lime;
aeration;  clarification;  and, pressure filtration through sand prior
to discharge.
                                    476

-------
Plant 112 (0396D) - Figure VII-8

Wastewaters from continuous galvanizing  are  combined  with  pickling
concentrates and rinses, treated with lime arid polymer, clarified, and
discharged to a POTW.

Plant 113 (0856D) - Figure VII-9

During   the   toxic  survey  (March,  1977),  wastewaters  from  this
continuous strip/sheet terne  coating  line  were  discharged  without
treatment.  A combined chemical treatment plant is under construction.
Meanwhile,  solution  dragout is minimized through strict attention to
maintenance of equipment.

Plant 114 (0948C) - Figure VII-10

Galvanizing wastewaters from continuous strip/sheet coating lines  are
blended with wastewaters from pickling, cold rolling, and electrolytic
coating  lines; equalized; treated with lime; settled; skimmed free of
oils; treated with polymer; clarified; and, discharged.

Plant 116 (01121) - Figure VII-11

Wastewaters from galvanizing, aluminizing, electrolytic  coating,  and
alkaline  degreasing  of  wire,  fasteners,  and  special  shapes, are
combined; treated with lime and  polymer;  clarified;  filtered;  and,
stored in a large lagoon for reuse or discharge.

Plant 118 (0920E) ^ Figure VII-12

Spent  galvanizing solutions, rinsewater, fume scrubber water and some
noncontact  cooling  water  from  continuous  strip/sheet  and   batch
miscellaneous  shape  coating lines; are blended; treated with lime in
two  stages;  fed  polymer;  clarified;  and  discharged.    Clarifier
underflows are vacuum filtered.

Plant 119 (0476A) - Figure VII-13

Wastewaters  from  pipe and tube pickling and galvanizing are combined
with wastewaters from other plant sources; equalized; skimmed free  of
oil;   aerated;   treated  with  lime  and  polymer;  clarified;  and,
discharged.

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.
                                    477

-------
As shown in Tables VI1-5 to VI1-7, the impact of make-up water quality
on  raw  wastewater  pollutant  loadings  for  the sampled hot coating
operations is not significant for any of the toxic  metal  pollutants.
The  suspended  solids  levels  in  make-up waters for galvanizing and
terne operations were found to be significant  when  compared  to  raw
waste  loadings  at  the  sampled  plants (39% and 34%, respectively).
However, the model  treatment  technology  includes  lime  or  caustic
precipitation  which  will  result in the formation of metal hydroxide
precipitates.  The  suspended  solids  concentrations  after  lime  or
caustic   addition   are   significantly   higher   than   raw   waste
concentrations; and the removal of the hydroxide floe will also result
in removal of suspended solids contained in make-up waters.  Thus, the
Agency concludes that the impact of make-up water quality on raw waste
loadings for hot coating  operations  are  not  significant,  and  the
limitations  and  standards should be applied on a gross basis, except
to the extent provided by 40 CFR 8122.63(h).
                                   478

-------
                       TABLE VII-1

         OPERATING MODES,  CONTROL AND  TREATMENT
            TECHNOLOGIES AND DISPOSAL METHODS

                         Symbols
Operating Modes

1.   OT

2.   Kt,s,n
               Once-Through

               Recycle, where t
                                   s
                                   n
                   type waste
                   stream recycled
                   % recycled
                                   t:  U = Untreated
                                       T = Treated

                                       n
     P
     F
     S
     FC
     BC
     VS
     FH

3.   REt,n
        Process Wastewater % of raw waste flow
        Flume Only         % of raw waste flow
        Flume and Sprays   % of raw waste flow
        Final Cooler       % of FC flow
        Barometric Cond.   % of BC flow
        Abs. Vent Scrub.   % of VS flow
        Fume Hood Scrub.   % of FH flow
               Reuse, where t
                            n
                 type
                 % of raw waste flow
4.
BDn
Control Technology

10.  DI

11.  SR

12.  CC

13.  DR

Disposal Methods

20.  H

21.  DW
             t:  U = before treatment
                 T = after treatment

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

               Spray/Fog Rinse

               Countercurrent Rinse

               Drag-out Recovery



               Haul Off-Site

               Deep Well Injection
                            479

-------
TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 2
        Disposal Methods (cont.)
        22.  Qt,d
        23.  EME

        24.  ES

        25.  EVC

        Treatment Technology
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.  SS

        35.  PSP

        36.  SSP

        37.  EB

        38.  A

        39.  AO

        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

Acidificatiori

Air Oxidation

Gas Flotation

Mixing

Neutralization, where t = type
                                                  t:   L = Lime
                                                      C = Caustic
                                                      A = Acid
                                                      W = Wastes
                                                      0 = Other, footnote
                                    480

-------
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 = 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 = Gravxty
                       0 = Other,     P = Pressure
                           footnote

                    Chlorination, where t = type

                                        t:  A = Alkaline
                                            B = Breakpoint

                    Chemical Oxidation (other than CLA or CLB)
                                     481

-------
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 s 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 3 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

                                    482

-------
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
                                    483

-------
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                               TABLE VII-4

             EFFLUENT WASTE LOADS  -  HOT COATING - ALUMINIZING
              SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
                          Toxic  Pollutant  Survey
Plant Codes

Sample Point
Flow, gal/ton
C&TT
Suspended Solids
Oils and Grease
Hexavalent Chromium
pH, units

118  Cadmium
119  Chromium
120  Copper
121  Cyanide
122  Lead
124  Nickel
126  Silver
128  Zinc

Dissolved Iron
    01121
     116
  (E/(F+B)!H
     3960
NL,FLP,CL,FDSP
                                    mg/1
 4
 0.003
 7.3 - 7.7

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 0.01
 0.002
 0.05
 0.02
<0.02
 0.13

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                 lbs/1000 Ibs

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                  0.0196
                  0.000038
                 <0.000165
                 <0.000067
                  0.000357
                  0.000006
                  0.00245
                  0.00130
                 <0.000324
                  0.000073

                  0.000818
                                     487

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                       HOT COATING SUBCATEGORY

                             SECTION VIII

             COST, ENERGY, AND NON-WATER. QUALITY IMPACTS
Introduction

This section presents the incremental costs to be incurred in applying
the different levels  of  pollution  control  technology  to  the  hot
coating subcategory.  The analysis also describes energy requirements,
non-water  quality  impacts  (including  air  pollution,  solid  waste
disposal and water consumption), and the costs  for  each  alternative
treatment  system.   Summaries  of  the  alternative  treatment system
applicable to each hot  coating  operation  are  depicted  in  Figures
VIII-1 and VIII-2.

Costs

The water pollution control costs for eight of the nine plants visited
during  the  study  are presented in Table VIII-1.  Unusable cost data
were provided for one plant.  With the exception  of  Plant  116  (see
footnote  2 on table), all costs apply to galvanizing operations only.
At Plant 116, the costs include treatment of aluminizing and  alkaline
cleaning  wastewaters  in  addition  to  galvanizing.   Terne  coating
wastewater treatment systems were under construction at  three  sites,
at  the  time  of plant visits.  Thus, cost data were not reported for
these operations.  The treatment  systems  net  raw  waste  and  gross
effluent  loads  are  described  in Sections V, VI, and VII.  The cost
data were supplied by the operators of  each  plant  in  current  year
dollars.   The  Agency  converted these data to July, 1978 dollars.  A
standard capital recovery factor  was  used  so  that  the  annualized
capital costs would be comparable.

Cost Comparisons for Facilities in Place

In  order  to  determine  whether  its cost estimates are accurate and
cover actual site-specific costs, the Agency compared  costs  reported
by  plants   (including  all  site-specific  and  retrofit  costs) with
model-based  estimates  of  facilities  in  place.   These  data   are
summarized below:
                                    505

-------
Plant
Coated

Product
For Sampled Plants
1121
396A
47 6A
612
856F
856P
920E

Subtotal

D-DCP Data

0580A
0728
0868A
0920F

Subtotal
Fasteners
Strip/Sheet
Pipe & Tube
Wire
Sheet
Wire
Strip/Sheet
Wire
Pipe
Strip
Strip(Terne)
   Plant
Reported Costs
   From
 Table VIII-1
 2,958,000*
   509,050
    61,500
   670,020
   944,270
    14,310
 1,500,930

 3,700,080
    55,137
   211,7852
   233,232
    36,800
TOTAL (excluding 1121
      476A and 868A)
TOTAL (including all
      plants)
                , 536,954


               3,442,302

               7,195,034
Model-based
Estimate of

Facilities In Place
   584,400*
   533,500
   281,000
   974,500
   961,400
    12,600
 1,575,300

 4,338,300
   110,000
    37,200
 1,667,700
   171,800

 1,986,700
                    4,376,300

                    6,909,400
1Costs  omitted  from  subtotal.   Plant  reported  costs are for many
operations other than hot coating, while model-based estimates are for
hot coating only.  See text discussion below for Plant 1121.
2Plant reported costs included a cooling tower, model-based  costs  do
not.

With  the  exception  of the two cases referred to in footnotes above,
model-based estimates tend to  be  higher  than  actual  plant  costs,
reflecting   that   model   estimates  adequately  take  into  account
site-specific costs.  The few widely divergent costs reflect  problems
in   apportioning  total  treatment  plant  costs  for  large  central
treatment systems back to individual small lines.  The owner of  Plant
1121  allocated  the  $9.7  million  capital  expense  of a plant-wide
treatment system by assigning $5.4 million to the  chemical  treatment
portion  of  this  system,  then  further  estimating that about 50-60
percent of  such  costs  pertain  to  treatment  of  wastewaters  from
galvanizing,  aluminizing, alkaline cleaning, and electrolytic coating
operations at  this  plant.   Since  sufficient  information  was  not
available, the Agency did not attempt to further allocate the reported
plant-wide  costs  .to  the  hot  coating  operation.  The $2.9 million
shown,  therefore,  includes  treatment  of  wastewaters   from   more
                                   506

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operations  than  the model-based estimate of $584,400 for hot coating
wastewaters only.

A large, plant-wide central treatment plant costing $7.1  million  has
been installed at Plant 0476A.  Problems were encountered in factoring
costs  for the 2200 GPM treatment facility back to the 20 GPM pipe and
tube galvanizing line.  Model-based estimates  which  are  based  upon
separate  treatment  are 4.6 times higher than apportioned costs where
galvanizing flows were less  than  one  percent  of  total  flows.   A
similar  situation  exists at Plant 0868A, where model-based estimates
are seven  times  higher  than  plant-apportioned  costs.   The  total
treatment  plant  cost  for  Plant 0868A is listed as $4.86 million in
Table VIII-1.  Conversely, Plant 0728 costs include  a  cooling  tower
necessary  to  recycle wastewater to processes other than galvanizing,
while the model-based  estimate  do  not  include  costs  for  cooling
equipment.   However,  these  were  exceptions to generally comparable
actual and estimated investment costs, and overall estimates based  on
model  treatment  systems appear reasonable and accurate.  For the two
plants  where  separate  treatment  of  hot  coating  wastewaters   is
practiced  (0920E  and  0920F),  model-based estimates are higher than
plant-reported  actual  costs.   Based  upon  the  above,  the  Agency
concludes  that  its  model  based  cost  estimates  are  sufficiently
generous to cover site specific and retrofit costs for the hot coating
subcategory.

Control and Treatment Technology (C&TT)

The wastewater treatment  components  in  use  or  available  for  hot
coating  line  operations are presented in Table VII1-4.  Table VII1-4
also presents the following information for each treatment step:

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

Model  costs  associated  with  the  alternative   treatment   systems
including   investment,   annualized   capital  costs,  operation  and
maintenance, and energy and  power  are  presented  in  Tables  VII1-5
through  VII1-34.   Columns  on  cost tables are identified by letters
corresponding to the appropriate treatment technology step  identified
in Table VIII-4.

Estimated Costs for the                                 .      •
Installation of Pollution Control Technologies

A.   Costs Required to Achieve the BPT Limitations

     The model BPT treatment system provides for the following control
     measures:  the blending  and  equalization  of  wastes  from  all
     rinsing   and   scrubbing   operations;  chromium  reduction  (if
     hexavalent  chromium  is  present,  e.g.,  bright  dip  rinse  at
     galvanizing  lines);  neutralization of all wastewaters with lime
     or  other  suitable  alkali;  the  addition   of   polymer   with
                                    507

-------
     flocculation  and  settling   in a clarifier; vacuum  filtration of
     underflow  sludges;  and  continuous  surface  skimming  for  oil
     removal.    All  flows  from  rinsing  and  scrubbing  operations
     including fume scrubbing are  discharged  once-through  following
     treatment.

     Cost estimates for these BPT  model treatment systems are provided
     in  Tables VII1-5 through VII1-14.  Using model costs as a basis,
     estimates were made of the cost  of  bringing  each  hot  coating
     plant into compliance with the BPT limitations.  The cost of each
     BPT  model  component  was calculated for each plant by adjusting
     the model cost to the actual  production capacities   reported  for
     each  plant  using  the  six-tenths  factor  rule.   Table VIII-35
     summarizes the expenditures which have been made  and  which  are
     still  necessary  (as  of  July 1, 1981) to bring all hot coating
     operations  into  compliance  with  the  BPT  limitations.    The
     estimated  required cost of compliance for hot coating operations
     to attain  the  BPT  limitations  is  about  $3.2  million.   The
     associated  annual  costs for these systems will be  $0.7 million.
     These  costs  are  conservative,  since   they   are  based   on
     co-treatment  of  only  hot   coating wastewaters at  a given plant
     site.  In actual practice, hot coating wastewaters are co-treated
     with those froln other  forming  and  finishing  operations.   The
     economies  of  scale  which   result reduce capital investment and
     annual operating costs.

B.   Costs Required to Achieve the BAT Limitations

     The Agency evaluated three alternative  treatment  systems  which
     are  designed  to  further reduce toxic pollutant discharges from
     hot coating operations.  Two of the  three  include  rinse  water
     reduction   to  minimize  flows  from  the  process.   All  three
     alternatives  include  recycle  of  scrubber  wastewaters,   with
     minimal  blowdown  to  treatment.    Due  to
     existing  BPT  treatment  system  is  able
     efficiently,   achieving   lower   effluent
     alternatives,  this reduced BAT effluent may
     either  by  filtration,  or  by  an  evaporation and condensation
     system designed to produce dry solids and water which  is  reused
     in  the process.  This latter treatment alternative  achieves zero
     discharge of pollutants to receiving streams,  but   requires  the
     expenditure of large amounts of energy and capital.

     BAT  model  alternative  treatment  system  costs are provided in
     Tables VIII-15 thorugh VII1-24.   The  total  capital  and  annual
     costs  for  all  hot coating operations to attain the alternative
     BAT- limitations are:
flow reductions, the
to   function   more
concentrations.   As
be  further  treated
                                     508

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        Alternatives

        BAT 1
        BAT 2
        BAT 3
Millions of 1978 Dollars
   Capital Cost ($)

         0.87
        12.8
       119.8
     Annual Cost ($)

            0.12
            1 .64
           18.7
     Costs Required to Achieve the BCT Limitations
     The  promulgated  BCT  limitations  are  identical  to  the   BPT
     limitations.    Thus,  no  additional  treatment  and  costs  are
     required.

     Costs Required to Achieve NSPS

     Four NSPS alternative treatment systems have been  evaluated  for
     hot  coating  operations.   These systems are the same as the BPT
     and  BAT  alternative  treatment  systems  previously  described.
     Model  capital  and annual operating costs are provided in Tables
     VIII-25 through. VIII-34o

     Costs Required to Achieve PSES and PSNS

     Pretreatment standards  apply  to  those  plants  discharging  to
     POTWs.   For  new  source  POTW dischargers, the PSNS alternative
     treatment systems are the same as the NSPS alternatives discussed
     in the preceding paragraph.  For PSES the Agency considered  four
     alternative  treatment  systems which are the same as the BPT and
     the three BAT alternative treatment systems.  The  model  capital
     and  annual  costs are the same as the BPT and the sum of the BPT
     and each BAT alternative treatment system.  These model costs are
     presented in Table VII1-5 through VII1-24.
     The subcategory-wide costs were calculated in the same manner
     the BPT costs and are as follows:
                                           as
                         Millions of 1978 Dollars
     Alternative

      PSES 1
      PSES 2
      PSES 3
      PSES 4
Capital Costs

  $ 4.97
  $ 5.05
  $ 6.55
  $27.97
Annual Costs

  $0.73
  $0.74
  $0.95
  $4.09
Energy Impacts

Moderate   amounts  of  energy  are  required  to  operate  wastewater
treatment systems for hot coating operations.  Most of the  energy  is
consumed  in  operating the BPT model treatment systems, many of which
are already in place.  The Agency estimates that BPT  model  treatment
systems   will   use   approximately   22  million  kilowatt-hours  of
                                   509

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electricity per year.  This  is  a  relatively  insignificant  .(0.04%)
portion of the 57 billion kilowatt-hours used in the steel industry in
1978.  Ninety percent of the electricity needed to operate hot coating
treatment   systems   is  associated  with  treatment  of  galvanizing
wastewaters.  Refer to Table VII1-2 for a breakdown  by  type  of  hot
coating line.

The additional requirements for upgrading BPT treatment systems to BAT
levels  are  shown  in  Table  VII1-3.  Note that two of the three BAT
alternative treatment systems require only  minor  incremental  energy
consumption.    Only   Alternative   3,   which  includes  evaporation
technology, consumes significant additional energy.

Energy impacts at the NSPS and PSNS  alternatives  are  slightly  less
than  the  requirements at the corresponding BPT, and combined BPT and
BAT alternatives, since flow reduction is included as the  first  step
to  minimize the volume of wastewater requiring treatment.  The Agency
did not, however, calculate total subcategory  impacts  for  NSPS  and
PSNS, since predictions of capacity expansion are not included in this
study.   The  energy  consumptions  on  a model basis are presented in
Table VII1-4.

The energy impacts for the PSES alternative pretreatment  systems  are
moderate.   The  energy requirements are presented in Table VII1-5 for
each of the alternatives.

Non-water Quality Impacts

Air Pollution

Air pollution impacts from hot coating treatment systems are  minimal.
Cooling  towers  are  not^included in the model treatment systems, and
the only treatment step which could potentially affect air quality  is
the  chromium  reduction  step  required  at  a few galvanizing lines.
Sulfur dioxide, which is  one  of  the  treatment  chemicals,  can  be
emitted  to  the  atmosphere  through  careless  use.   The  potential
emissions are/ however, minimal,  and  relatively  simple  precautions
will   eliminate   the   potential   for  liberating  sulfur  dioxide.
Well-maintained plants have demonstrated that no air pollution  impact
need occur.

Solid Wastes

The  major  non-water  quality impact associated with the treatment of
wastewaters from hot coating operations is the generation of  metallic
hydroxide  sludges during treatment.  The BPT level of treatment would
yield 400-500  tons  per  year  of  sludge  from  a  typical  800  TPD
galvanizing  operation.   On  a  dry  weight  basis, over 7700 tons of
solids per year are generated for the entire subcategory at BPT.  Most
hot coating wastewater treatment sludges are disposed of at  landfills
on  or  off  site.   Since  most  BPT  treatment systems are currently
installed, these sludges are currently being  produced  and  disposed.
The  Agency  recognizes  that  toxic  metals can be leached from these
                                    510

-------
sludges  and  that  improper  disposal  practices  could   result   in
discharges  to  navigable  waters or .contamination of groundwater.  To
the extent such situations arise, they will  be  addressed  under  the
Resource  Conservation  and  Recovery Act or the NPDES permit program.
The Agency has included costs  in  its  cost  estimates  for  properly
disposing of these wastes.

Solid  waste  generation  at  the BAT level is significantly less than
that cited for the BPT model treatment systems as  shown  below.   The
sludge  characteristics  for  Alternatives 1 and 2 are similar to BPT,
and the previous discussion on sludge disposal applies  to  those  two
alternatives  for  each  type of hot coating operation.  Alternative 3
converts all remaining pollutants in the  effluent  from  hot  coating
into  dry  solids.   These  sludges will be disposed of along with the
sludges generated at  BPT.   Solid  waste  production  at  BAT  is  as
follows?
       Alternative

          BAT 1
          BAT 2
          BAT 3
   (Dry)
 Tons/Year

   116.9
   533.3
22,700
The  Agency  believes,  however,  that the effluent reduction benefits
associated with compliance with the limitations and standards  justify
any   adverse   environmental  effects  associated  with  solid  waste
disposal.  Most of the solid  wastes  described  above  are  presently
being  generated  and  disposed  of.   The  Agency believes that these
wastes can be disposed of properly and in.a safe manner.

Water Consumption

Impacts on water consumption at the BPT and BAT levels are minimal  or
nonexistent.   Aside  from  recycle  of fume scrubber wastewaters, all
wastewaters  are  discharged  on  a  once-through  basis.   Since  the
temperature of the recycled scrubber wastewaters are not raised, there
are  no  significant  evaporative losses.  Hence, the Agency concludes
that there are no significant consumptive  uses  of  water  associated
with the treatment of hot coating process wastewaters.

Summary of. Impacts

The  Agency  concludes that the effluent reduction benefits associated
with compliance with these  limitations  and  standards  outweigh  the
adverse  non-water quality impacts associated with energy consumption,
air pollution, solid waste disposal, and water consumption:
                                   511

-------
                          Direct Dischargers
                    Effluent Loadings (Tons/Yr)
                  Raw
                 Waste        BPT/BCT       BAT 1
Flow, MGD
TSS
Oil & Grease
Toxic Metals
Toxic Organics
Nonconventional
  22.9
2658
1060
1830

 364
 22.8
588
109
 12

 27
 18.3
471
 87
 10

 22
                            Indirect Dischargers
                        Effluent Loadings (Tons/Yr)
Flow, MGD
TSS
Oil & Grease
Toxic Metals
Toxic Organics
Nonconventional
Raw
Waste
7.5
612
218
269

PSES 2
5.6
142
26
3
       80
The  Agency  also  concludes  that  the  effluent  reduction  benefits
associated  with  compliance  with  new  source standards (NSPS, PSNS)
outweigh the adverse non-water quality environmental impacts.
                                   512

-------
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                                                                  513

-------
                               TABLE VII1-2

                ENERGY REQUIREMENTS TO ACHIEVE BPT LIMITS
                         HOT COATING OPERATIONS
Process

Galvanizing

Strip/Sheet &
Misc. Products

Wire Products
& Fasteners

Terne Coating

Strip/Sheet


Other Coatings

Strip/Sheet &
Misc. Products

Wire Products
& Fasteners
Mode
w/scrubbers
wo/scrubbers
w/scrubbers
wo/scrubbers
w/scrubbers
wo/scrubbers
w/scrubbers
wo/ scrubbers
w/scrubbers
wo/scrubbers

kw
72
57
56
39
40
31
54
48
22
10
Power
Required
h£
97
76
75
53
54
41
72
65
30
13
Annual Cost
7/1/78 .
Dollars
11,300
8,800
8,700
6,100
6,200
4,800
8,300
7,500
3,400
1,500
NOTE:  Above energy requirements also apply to BCT, PSES-1, PSNS-1 arid NSPS-1.
                                    514

-------
                          TABLE VIII-3

ENERGY REQUIREMENTS TO ACHIEVE EFFLUENT LIMITATIONS AND STANDARDS
                       HOT COATING OPERATIONS



Power

Required
Process
Galvanizing
Strip/Sheet &
Miscellaneous Products




Wire Products &
Fasteners




Terne Coating
Strip/Sheet





Other Metal Coatings
Strip/Sheet &
Miscellaneous Products




Wire Products &
Fasteners




Alternative

BAT-l;PSES-2

BAT-2;PSES-3

BAT-3;PSES-4

BAT-l;PSES-2

BAT-2JPSES-3

BAT-3;PSES-4


BAT-1;PSES»2

BAT-2;PSES-3

BAT-3;PSES-4


BAT-l;PSES-2

BAT-2;PSES-3

BAT-3;PSES~4

BAT-l;PSES-2

BAT-2;PSES-3

BAT-3;PSES-4

Mode

w/scrubbers
wo /scrubbers
w/scrubbers
wo/ scrubbers
w/scrubbers
wo/scrubbers
w/scrubbers
wo/ scrubbers
w/scrubbers
wo/ scrubbers
w/scrubbers
wo/ scrubbers

w/scrubbers
wo/scrubbers
w/scrubbers
wo/ scrubbers
w/scrubbers
wo/scrubbers

w/scrubbers
wo/ scrubbers
w/scrubbers
wo/ scrubbers
w/scrubbers
wo/scrubbers
w/scrubbers
wo/ scrubbers
w/scrubbers
wo/scrubbers
w/scrubbers
wo/scrubbers
kw

5
-
10
4
602
496
5
-
8
2
393
228

4
' -
6
1
287
205

4
-
6
2
369
280
4
-
4
1
78
37
h£

7
-
14
5
807
665
7
• -
11
3
527
305

5
-
8
2
385
275

5
-
8
3
495
375
5
-
6
1
105
50
Annual Cost
7/1/78
Dollars

800
-
1 , 600
600
93,900
77,400
800
-
1,300
300
61,300
35,500

600
-
900
200
44,800
32,000

600
-
900
300
57,600
43,600
600
-
700
100
12,200
5,800
                                515

-------
TABLE VIII-3
ENERGY REQUIREMENTS TO ACHIEVE EFFLUENT LIMITATIONS AND STANDARDS
HOT COATING OPERATIONS
PAGE 2
Power
Required
Process
Galvanizing
Strip/Sheet &
Miscellaneous Products




Wire Products &
Fasteners




Terne Coating
Strip/Sheet





Other Metal Coatings
Strip/Sheet &
Miscellaneous Products




Wire Products &
Fasteners




Alternative

NSPS-2;PSNS-2

NSPS-3;PSNS-3

NSPS-4;PSNS-4

NSPS-2;PSNS-2

NSPS-3;PSNS-3

NSPS-4;PSNS-4


NSPS-2;PSNS-2

NSPS-3;PSNS-3

NSPS-4;PSNS-4


NSPS-2;PSNS-2

NSPS-3;PSNS-3

NSPS-4;PSNS-4

NSPS-2;PSNS-2

NSPS-3;PSNS-3

NSPS-4;PSNS-4

Mode

w/scrubbers
wo/scrubbers
w/scrubbers
wo/scrubbers
w/scrubbers
wo/scrubbers
w/scrubbers
wo /scrubbers
w/scrubbers
wo/scrubbers
w/scrubbers
wo/scrubbers

w/scrubbers
wo/scrubbers
w/scrubbers
wo/ scrubbers
w/scrubbers
wo/ scrubbers

w/scrubbers
wo/scrubbers
w/scrubbers
wo/scrubbers
w/scrubbers
wo/scrubbers
w/scrubbers
wo/scrubbers
w/scrubbers
wo/scrubbers
w/scrubbers
wo/ scrubbers
kw

53
42
58
46
649
538
41
26
44
28
429
254

27
19
29
20
310
224

41
34
43
36
406
313
17
7
18
8
91
44
h£
_^A_
71
56
78
62
870
721
55
35
59
38
575
341

36
25.
39
27
416
300

55
46
58
48
544
420
23
9
24
11
122
59
                                                                                Annual Cost
                                                                                  7/1/78
                                                                                  Dollars
                                                                                   8200
                                                                                   6600
                                                                                   9000
                                                                                   7200
                                                                                101,300
                                                                                 84,000

                                                                                   6400
                                                                                   4100
                                                                                   6900
                                                                                   4400
                                                                                 66,900
                                                                                 39,600
                                                                                   4200
                                                                                   2900
                                                                                   4500
                                                                                   3100
                                                                                 48,400
                                                                                 34,900
                                                                                   6400
                                                                                   5300
                                                                                   6700
                                                                                   5600
                                                                                 63,400
                                                                                 48,900

                                                                                   2600
                                                                                   1100
                                                                                   2700
                                                                                   1200
                                                                                 14,200
                                                                                   6900
                                           516

-------
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-------
                                        TABLE VIII-5

                BPT/NSPS/PSNS  TREATMENT MODEL COSTS;  BASIS 7/1/78 DOLLARS
    Subcategory    :  Hot Coating
    Subdivision    :  Galvanizing, Without Fume Scrubbers
                   :  Sheet/Strip/Miscellaneous
                                    Model Size-TPD s   800
                                    Oper. Days/Year:   260
                                    Turns/Day      :     3
C&TT Steps

Investment ($ x 10~3)

Annual Costs ($ x 10~3)

  Capital
  Operation & Maintenance
  Land
  Sludge Disposal
  Hazardous Waste Disposal
  Oil Disposal
  Energy & Power
  Steam
  Waste Acid
  Crystal Disposal
  Chemical

TOTAL

Credits
  Scale
  Sinter
  Oil
  Acid Recovery

TOTAL CREDITS

NET TOTAL
2.2

9.0
               C       D       E       F       G      Total

              112.4    22.0     9.2   245.9   153.5    739.4
4.7
1.8
0.1


0.2
13.0
5.1
0.4


2.3
10.1
3.9
0.1


1.2
2.0
0.8
0.1


0.5
0.8
0.3


0.4
0.2
22.1
8.6
0.1


0.9
13.8
5.4
0.1
6.9

3*5
66.5
25.9
0.9
6.9
0.4
8.8
20.8
 4.2

19.5
3.7

7.1
1.7    31.7
        29.7
         10.1

        119.5
9.0
20.8
19.5
7.1
1.7
31.7
29.7
119.5
KEY TO TREATMENT ALTERNATIVES
NSPS-1,PSNS-1 = BPT
                        KEY TO C&TT STEPS
   A:  Chemical Reduction
   B:  Equalization
   C:  Neutralization With Lime
   D:  Flocculation With Polymer
                                 E:  Surface Skimming
                                 F:  Clarification
                                 G:  Vacuum Filtration
                                            519

-------
                                        TABLE VIII-6

                 BPT/NSPS/PSNS  TREATMENT MODEL COSTS;   BASIS 7/1/78  DOLLARS
     Subcategory    :   Hot Coating
     Subdivision    :   Galvanizing,  With Fume Scrubbers
                    :   Sheet/Strip/Miscellaneous
                                     Model Size-TPD :  800
                                     Oper. Days/Year:  260
                                     Turns/Day      :    3
 C&TT Step

 Investment  ($ x 10~3)

 Annual  Costs ($ x 10~3)

   Capital
   Operation & Maintenance
   Land
   Sludge  Disposal
   Hazardous Waste Disposal
   Oil Disposal
   Energy  &  Power
   Steam
   Waste Acid
   Crystal Disposal
   Chemical

 TOTAL

 Credits
   Scale
   Sinter
   Oil
   Acid  Recovery

 TOTAL CREDITS

 NET TOTAL
A      B        C       D
51.7   198.9   141.5    22.0
2.2

9.0
                                E        F        G    _ Total

                               10.6   347.1   171.2    943.0
4.7
1.8
0.1


0.2
17.9
7.0
0.6


4.1
12.7
5.0
0.1


1.5
2.0
0.8
0.1


0.6
1.0
0.4


0.5
0.2
31.2
12.1
0.2


1.0
15.4
6.0
4.1 -
8.2

3,7
84.9
33.1
1.2
8.2
0.5
11.3
        29.6
 6.7

26.0
6.1

9.6
                                2.1
44.5
33.4
 15.0

154.2
9.0    29.6    26.0
                                                      9.6
                                 2.1
                                       44.5
                                33.4
                               154.2
KEY TO TREATMENT ALTERNATIVES

NSPS-1,PSNS-1 » BPT
                        KEY TO  C&TT  STEPS
   A:   Chemical Reduction
   B:   Equalization
   C:   Neutralization With Lime
   D:   Flocculation With Polymer
                                        E:
                                        F;
                                        G:
                             Surface  Skimming
                             Clarification
                             Vacuum Filtration
                                             520

-------
                                       TABLE VIII-7

                BPT/NSPS/PSNS TREATMENT MODEL COSTS;  BASIS 7/1/78 DOLLARS
    Subcategory    :   Hot Coating
    Subdivision    :   Galvanizing, Without Fume Scrubbers
                   :   Wire Products/Fasteners
                                Model  Size-TPD  :   100
                                Oper.  Days/Year:   260
                                Turns/Day   ,   :     3
C&TT Step                    A

Investment ($ x 10~3)        36.5

Annual Costs ($ x 10~3)

  Capital  ,
  Operation & Maintenance
  Land
  Sludge Disposal
  Hazardous Waste Disposal
  Oil Disposal
  Energy & Power
  Steam
  Waste Acid
  Crystal Disposal
  Chemical                     1-1

TOTAL                          6.0

Credits        I
  Scale
  Sinter
  Oil
  Acid Recovery

TOTAL CREDITS

NET TOTAL                      6.0
    B

    99.2
    14.6
74.2
D

20.0
8.4   198.2   120.9
 2.1

12.1
 1.9

 4.7
1.3    25.5
    14.6    12.1
         4.7
         1.3
       25.5
                                            19.7
                                            19.7
                                                                                    Total
                                        557.4
3.3
1.3
0.1


0.2
8.9
3.5
0.2


2.0
6.7
2.6
0.1


0.6
1.8
0.7
0.1


0.2
0.8
0.3


0.1
0.1
17.8
6.9
0.1


0.7
10.9
4.2
0.1
2.2

2.3
50.2
19.5
0.7
2.2
0.1
6.1
 5.1

83.9
                                         83.9
KEY TO TREATMENT ALTERNATIVES

NSPS-1,PSNS-1 = BPT
                                                      KEY TO C&TT STEPS
A?  Chemical Reduction
BJ  Equalization
GJ  Neutralization With Lime
DJ  Flocculation With Polymer
                         E:  Surface Skimming
                         F:  Clarification
                         G:  Vacuum Filtration
                                             521

-------
                                         TABLE  VIII-8

                  BPT/NSPS/PSNS TREATMENT MODEL COSTS;   BASIS  7/1/78  DOLLARS
     Subcategory    :  Hot Coating
     Subdivision    :  Galvanizing, With Fume Scrubbers
                    :  Wire Products/Fasteners
                                     Model Size-TPD :  100
                                     Oper. Days/Year:  260
                                     Turns/Day      :    3
 C&TT Step

 Investment ($ x 10~3)

 Annual Costs ($ x 10~3)

   Capital
   Operation & Maintenance
   Land
   Sludge Disposal
   Hazardous Waste Disposal
   Oil Disposal
   Energy & Power
   Steam
   Waste Acid
   Crystal Disposal
   Chemical

 TOTAL

 Credits
   Scale
   Sinter
   Oil
   Acid  Recovery

 TOTAL CREDITS

 NET TOTAL


KEY TO TREATMENT ALTERNATIVES

NSPS-1,PSNS-1 - BPT
A      B        C     	D

36.5   153.4   119.2    22.0
E       F       G      Total

 9.8    257.4    126.0     724.3
3.3
1.3
0.1


0.2
13.8
5.4
0.4


2.9
10.7
4.2
0.1


1.4
2.0
0.8
0.1


0.5
0.9
0.3


0.1
0.2
23.1
9.0
0.1


0.9
11.3
4.4
0.1
2.6

2.6
65.1
25.4
0.9
2.6
0.1
8.7
1.1             4.6

6.0    22.5    21.0
                         4.2

                         7.6
1.5
                                       33.1
                                                21.0
6.0    22.5    21.0
                        7.6
1.5
                                       33.1
                                               21.0
                        KEY TO C&TT STEPS
  9.9

112.7
                       112.7
   A:  Chemical Reduction
   B:  Equalization
   C:  Neutralization With Lime
   D:  Flocculation With Polymer
                                                                      E:  Surface Skimming
                                                                      F:  Clarification
                                                                      G:  Vacuum Filtration
                                             522

-------
                                       TABLE  VIII-9

                BPT/NSPS/PSNS TREATMENT MODEL COSTS; BASIS 7/1/78 DOLLARS
   Subcategory    :  Hot Coating
   Subdivision    :  Terne, Without Fume Scrubbers
                  :  All Products
                                                             Model Size-TPD :   365
                                                             Oper. Days /Year:   260
                                                             Turns /Day      :     3
C&TT Step

Investment ($ x 10~3)

Annual Costs ($ x 10~3)

  Capital               j
  Operation & Maintenance
  Land
  Sludge Disposal
  Hazardous Waste Disposal
  Oil Disposal
  Energy & Power
  Steam
  Waste Acid
  Crystal Disposal
  Chemical

TOTAL

Credits
  Scale
  Sinter
  Oil
  Acid Recovery

TOTAL CREDITS

NET TOTAL
A
93.7
8.4
3.3
0.2
1.9
B
69.8
6.3
2.4
0.1
0.6
C
20.0
1.8
0.7
0.1
0.2
D
8.4
0.8
0.3
0.1
0.1
E
187.3
16.8
6.6
0.1
0.6
F
97.8
8.8
3.4
0.1
1.2
1.4
Total
477.0
42.9
16.7
0.6
1.2
4^8
         1.9

13.8    11.3
1.9

4.7
                                                                                       1.8
                                                              1.3    24.1     14.9     70.1
13.8    11.3
                                                      4.7
        1.3    24.1    14.9     70.1
KEY TO TREATMENT ALTERNATIVES

NSPS-1,PSNS-1 = BPT
                                                      KEY TO C&TT STEPS
                                  A:   Chemical  Reduction
                                  B:   Equalization
                                  C:   Neutralization With Lime
                                  D:   Flocculation With Polymer
                                 E:  Surface Skimming
                                 F:  Clarification
                                 6:  Vacuum Filtration
                                             523

-------
                                        TABLE VIII-10

                  BPT/NSPS/PSNS TREATMENT MODEL  COSTS;   BASIS 7/1/78 DOLLARS
Subcategory : Hot Coating Model Size-TPD : 365
Subdivision : Terne, With Fume Scrubbers Oper. Days /Year: 260
: All Products Turns /Day : 3
C&TT Step
Investment (? x 10~3)
Annual Costs ($ x 10~3)
Capital
Operation & Maintenance
Land
Sludge Disposal
Hazardous Waste Disposal
Oil Disposal
Energy & Power
Steam
Waste Acid
Crystal Disposal
Chemical
TOTAL
A. B C D E F Total
127.0 87.3 22.0 8.4 213.8 9,8.8 557.3

H-* 7.8 2.0 0.8 19.2 8.9 50.1
4.4 3.1 0.8 0.3 7.5 3.5 19.6
0.3 0.1 0.1 0.1 0.1 0.7
1.7 17
• J. • / X • /
0.1 o.l
2.3 0.8 0.5 0.1 0.8 1.7 6.2



3.1 2.8 5.9
18.4 14.9 6.2 1.3 27.6 15.9 84.3
Credits
  Scale
  Sinter
  Oil
  Acid Recovery

TOTAL CREDITS

NET TOTAL


KEY TO TREATMENT ALTERNATIVES

NSPS-1,PSNS-1 » BPT
    18.4
14.9
6.2
                             1.3
                        27.6
                                            15.9
                     KEY TO C&TT STEPS
                                84.3
A:  Chemical Reduction
B:  Equalization
C:  Neutralization With Lime
D:  Flocculation With Polymer
                                                                      Es  Surface Skimming
                                                                      Fs  Clarification
                                                                      Gs  Vacuum Filtration
                                            '524

-------
                                       TABLE VIII-11

                BPT/NSPS/PSNS TREATMENT MODEL COSTS;  BASIS 7/1/78 DOLLARS
    Subcategory    :   Hot Coating
    Subdivision    :   Other Metals,  Without Fume Scrubbers
                   :   Sheet/Strip/Miscellaneous
                                Model Size-TPD :   500
                                Oper. Days/Year:   260
                                Turns/Day      :     2
C&TT Step

Investment ($ x 10~3)

Annual Costs ($ x 10~3)

  Capital
  Operation & Maintenance
  Land
  Sludge Disposal
  Hazardous Waste Disposal
  Oil Disposal
  Energy & Power
  Steam
  Waste Acid
  Crystal Disposal
  Chemical
TOTAL

Credits
  Scale
  Sinter
  Oil
  Acid Recovery

TOTAL CREDITS

NET TOTAL
    ABC

   113.1    77.8    20.0
                                     16.5
 2.6
13.1
                                                              8.4   213.8   138.2
2.3
5.2
                             1.5
                                27.6
               25.6
16.5    13.1
                                                      5.2
1.5    27.6    25.6
                                                                                    Total
                                                571.3
10.2
4.0
0.2


2.1
7.0
2.7
0.1


0.7
1.8
0.7
0.1


0.3
0.8
0.3


0.3
0.1
19.2
7.5
0.1


0.8
12.4
4.8
0.1
4.8

3.5
51.4
20.0
0.6
4.8
0.3
7.5
 4.9
89.5
                                                     89.5
KEY TO TREATMENT ALTERNATIVES

NSPS-1,PSNS-1 -. BPT
                     KEY TO C&TT STEPS
A:  Chemical Reduction
B:  Equalization
C:  Neutralization With Lime
D:  Flocculation With Polymer
                                 E:  Surface Skimming
                                 F:  Clarification
                                 6:  Vacuum Filtration
                                              525

-------
                                        TABLE VIII-I2
Subcategory : Hot Coating Model Size (TPD): 300
Subdivision : Other Metals, With Fume Scrubbers Oper. Days /Year : 260
: Sheet/Strip/Miscellaneous Turns /Day : 2
C&TT Step
Investment ($ x 10~3)
Annual Costs ($ x 10~3)
Capital
Operation & Maintenance
Land
Sludge Disposal
Hazardous Waste Disposal
Oil Disposal
Energy & Power
Steam
Waste Acid
Crystal Disposal
Chemical
TOTAL
A B C D E F Total
143.2 97.1 22.0 8.4 235.7 153.5 659.9

12.9 8.7 2.0 0.8 21.2 13.8 59.4
5.0 3.4 0.8 0.3 8.2 5.4 23.1
0.3 0.1 0.1 0.1 0.1 0.7
6.1 6.1

0.5 0.5
2.3 1.0 0.5 0.1 0.9 3.5 8.3



3.8 3.7 7.5
20.5 17.0 7.1 1.7 30.4 28.9 105.6
Credits
  Scale
  Sinter
  Oil
  Acid Recovery

TOTAL CREDITS

NET TOTAL
    20.5    17.0
                                                      7.1
1.7    30.4    28.9    105.6
KEY TO TREATMENT ALTERNATIVES

NSPS-1,PSNS-1 - BPT
                     KEY TO C&TT STEPS
A:  Chemical Reduction
B:  Equalization
C:  Neutralization With Lime
D:  Flocculation With Polymer
                                                                      E:  Surface Skimming
                                                                      F:  Clarification
                                                                      G:  Vacuum Filtration
                                             526

-------
                                       TABLE VIII-13

                 BPT/NSPS/PSNS TREATMENT MODEL COST;  BASIS 7/1/78 DOLLARS
Subcategory : Hot Coating
Subdivision : Other Metals , Without Fume Scrubbers
: Wire Products /Fasteners
C&TT Step
Investment ($ x 10~3)
Annual Costs ($ x 10~3)
Capital
Operation & Maintenance
Land
Sludge Disposal
Hazardous Waste Disposal
Oil Disposal
Energy & Power
Steam
Waste Acid
Crystal Disposal
Chemical
TOTAL
A B
37.6 29.2

3.4 2.6
1.3 1.0
0.1 0.1



0.5 0.3



0.3
5.3 4.3
C
20.0

1.8
0.7
0.1



0.1



0.5
3.2
Model Size (TPD): 15
Oper. Days /Year : 260
Turns /Day :
D E F
5.3 74.2 59.0

0.5 6.7 5.3
0.2 2.6 2.1
0.1 0.1
0.4


0.1 0.2 0.3




0.8 9.6 8.2
2
Total
225.3

20.3
7.9
0.5
0.4


1.5



0.8
31.4
Credits
  Scale
  Sinter
  Oil
  Acid Recovery

TOTAL CREDITS

NET TOTAL
     5.3
4.3
3.2
0.8
9.6
8.2
                                                     31.4
KEY TO TREATMENT ALTERNATIVES

NSPS-1,PSNS-1 = BPT
                     KEY TO C&TT STEPS
A:  Chemical Reduction
B:  Equalization
C:  Neutralization With Lime
D:  Flocculation With Polymer
                        E:  Surface Skimming
                        F:  Clarification
                        6:  Vacuum Filtration
                                             527

-------
                                        TABLE VIII-14

                  BPT/NSPS/PSNS TREATMENT MODEL COST;  BASIS 7/1/78 DOLLARS
Subcategory : Hot Coating Model Size (TPD): 15
Subdivision : Other Metals, With Fume Scrubbers Oper. Days/Year : 260
: Wire Products /Fasteners Turns /Day : 2
C&TT Step
Investment ($ x 10~3)
Annual Costs ($ x 10~3)
Capital
Operation & Maintenance
Land
Sludge Disposal
Hazardous Waste Disposal
Oil Disposal
Energy & Power
Steam
Waste Acid
Crystal Disposal
Chemical
TOTAL
A B C D E F Total
80.5 62.5 20.0 8.4 150.5 82.3 404.2

7.2 5.6 1.8 0.8 13.5 7.4 36.3
2.8 2.2 0.7 0.3 5.3 2.9 14.2
0.1 0.1 0.1 0.1 0.1 0.5
0.5 0.5


1.5 0.6 0.2 0.1 0.3 0.7 3.4



1.6 1.4 3.0
11.6 10.1 4.2 1.2 19.2 11.6 57.9
Credits
  Scale
  Sinter
  Oil
  Acid Recovery

TOTAL CREDITS

NET TOTAL


KEY TO TREATMENT ALTERNATIVES

NSPS-1,PSNS-1 - BPT
    11.6    10.1
4.2
1.2    19.2    11.6
                     KEY TO C&TT STEPS
                                                     57.9
A:  Chemical Reduction
B:  Equalization
C:  Neutralization With Lime
D:  Flocculation With Polymer
                                                                      E:  Surface Skimming
                                                                      F:  Clarification
                                                                      G:  Vacuum Filtration
                                             528

-------
                                                      TABLE VIII-15          '• .   .'....

                                  BAT/PSES TREATMENT MODEL COSTS;  BASIS 7/1/78  DOLLARS
                        Subcategory:   Hot Coating
                        Subdivision:   Galvanizing,  Without Fume Scrubbers
                                   :   Sheet/Strip/Miscellaneous
                                         Model Size-TPD  :  800
                                         Oper. Days/Year:  260
                                         Turns/Day       :    3
C&TT Step
Investment ($ x 10~ )
- Total
BPT
739.4
BAT
Alt. BAT Alternative 2
1 H
(1) 288.0
I
119.9
Total
407.9
H
288.0
BAT Alternative 3
J
2,276.7
K
28.5
Total
2,593:
Annual Costs ($ x 10~3)

  Capital                      66.5
  Operation & Maintenance      25.9
  Land                          0.9
  Sludge Disposal               6.9
  Hazardous Waste Disposal
  Oil Disposal                  0.4
  Energy & Power                8.8
  Steam
  Waste Acid
  Crystal Disposal
  Chemical                     10.1

TOTAL                         119.5

Credits
  Scale
  Sinter
  Oil
  Acid Recovery

TOTAL CREDITS

NET TOTAL                     119.5
           25.9
           10.1
            0.1
           36.1
10.8
 4.2
 0.1
                     0.6
                    15.7
36.7
14.3
 0.2
                               0.6
                              51.8
25.9
10.1
 0.1
                                        36.1
204.7      2.6      233.2
 79.7      1.0       90.8
  0.1      0.1        0.3
                                                    77.4
                                                   361.9
                                                                        77.4
                                                              3.7       401.7
           36.1
                    15.7
                             51.8
                                       36.1
                                                  361.9
                                                             3.7
                                                                      401.7
 (1)   Since the BAT-1 treatment component is fume scrubber recycle,
      it does not apply to those models without fume scrubbers.
                         KEY TO TREATMENT ALTERNATIVES
                                                                           KEY TO C&TT STEPS
                            PSES-1
                            PSES-2
                            PSES-3
                            PSES-4
BPT
BPT
BPT + BAT-2
BPT + BAT-3
 H:  Rinse Reduction      J:  Vapor Compression Distillation
 I:  Pressure Filtration  K:  Recycle
                                                            529

-------
                           TABLE VIII-16
Subcategory: Hot Coating Model Size - TPD: 800
Subdivision: Galvanizing, With Fume Scrubbers Oper. Days/Year : 260
: Sheet/Strip/Miscellaneous Turns/Day : 3
C&TT Step
Invostaent ($ x 10~3}
Annual Costs (? x 10~3)
Capital
Operation & Maintenance
Land
Sludge Disposal
Hazardous Waste Disposal
Oil Disposal
Energy & Power
Steaa
Waste Acid
Crystal Disposal
Chealcal
TOTAL
Credits
Scale
Sinter
Oil
Acid Recovery
TOTAL CREDITS
HET TOTAL
BAT
Total Alt. 1
BPT H Total
943.0 59.1 59.1

84. 9 5.3 5.3
33.1 2.1 2.1
1.2 0.1 0.1
8.2

0.5
11.3 0.8 0.8


15.0
154.2 8.3 8.3






154.2 8.3 8.3
KEY TO TREATMENT ALTERNATIVES

PSES-1 - BPT
PSES-2 » BPT + BAT-1
TJCT7O—O _ 1S«m _i_ T> Am n
BAT Alternative 2 BAT Alternative 3
Alternative 1 Plus: Alternative 1 Plus!
I J Total I K L Total
288.0 144.3 491.4 288.0 2,473.1 43.5 2,863.7

25.9 13.0 44.2 25.9 222.3 3.9 257.4
10-1 5.0 17.2 10.1 86.6 1.5 100.3
°-l 0.1 0.3 0.1 0.2 0.1 0.5


0.8 1.6 93.1 93.9



36.1 18.9 63.3 36.1 402.2 5.5 452.1






36.1 18.9 63.3 36.1 402.2 5.5 452.1
KEY TO C&TT STEPS
H: Recycle J: Pressure Filtration
I: Rinse Reduction K: Vapor Compression Distillati
   S-3  -  BPT + BAT-2
PSES-4  -  BPT -I- BAT-3
                                530

-------
                                                      TABLE VIII-17

                                  BAT/PSES THEATMEHT MODEL COSTS;   BASIS 7/1/78 DOLLARS
                        SubcaCegory:  Hot Coating
                        Subdivision:  Galvanizing,  Without Fume Scrubbers
                                   :  Wire Products/Fasteners
                              Model Size-TPD :   100
                              Oper. Days/Year:   260
                              Turns/Day      :     3
C&TT Step
Investment ($ x 10~3)
Total
BPT
557. A
BAT
Alt.
1
(1)
BAT
H
36.0
Alternative 2
I
49.5
Total
85.5
H
36.0
BAT Alternative 3
J
1,920.3
K
25.5
Total
1,981.
Annual Costs ($ x 10  )

  Capital                      50.2
  Operation & Maintenance      19.5
  Land                          0.7
  Sludge Disposal               2.2
  Hazardous Waste Disposal
  Oil Disposal                  0.1
  Energy & Power                6.1
  Steam
  Waste Acid
  Crystal Disposal
  Chemical                      5.1

TOTAL                          83.9

Credits
  Scale
  Sinter
  Oil
  Acid Recovery

TOTAL CREDITS

NET TOTAL                      83.9
3.2
1.3
0.1
4.6
4.4
1.7
0.1
         0.3
         6.5
7.6
3.0
0.2
                   0.3
                  1-1.1
3.2
1.3
0.1
                             4.6
172.6      2.3      178.1
 67.2      0.9       69.4
  0.1      0.1        0.3
                                        35.5
                                       275.4
                                                  3.3
                                                            35.5
                                                           283.3
4.6
         6.5
                  11.1
                             4.6
                                       275.4
                                                  3.3
                                                           283.3
 (1)  Since the EAT-1 treatment component is fume scrubber recycle,
     it does not apply to those models without fume scrubbers.
                         KEY TO TREATMENT ALTERNATIVES

                            PSES-1  »  BPT
                            PSES-2  -  BPT
                            PSES-3  =  BPT + BAT-2
                            PSES-4  «  BPT + BAT-3
                                                                             KEY TO.C&TT STEPS
         H:  Rinse Reduction      J:  Vapor Compression Distillation
         I:  Pressure Filtration  K:  Recycle
                                                               531

-------
                              TABLE  VIII-18
Subcategory: Hot Coating
Model Size - TPD: 100
Subdivision: Galvanizing, With Fume Scrubbers Oper. Days/Year : 260
: Wire Products/Fasteners Turns/Day : 3


C&TT Step
Investaent (S x 10~3)
Annual Coati C$ x 10~3)
Capital
Operation & Maintenance
Land
Sludge Disposal
Hazardous Waste Disposal
Oil Disposal
Energy & Power
Steam
Waste Acid
Crystal Disposal
Chemical
TOTAL
Credits
Scale
Sinter
Oil
Acid Recovery
TOTAL CREDITS
HET TOTAL
BAT
Total Alt. 1
BPT H Total
724.3 59.1 59.1

65.1 5.3 5.3
25.4 2.1 2.1
0.9 0.1 0.1
2.6

0.1
8.7 0.8 0.8



9.9
112.7 8.3 8.3






112.7 8.3 8.3
BAT Alternative 2 BAT Alternative 3
Alternative 1 Plus: Alternative 1 Plus:
I J Total I K L Total
36.0 110.1 205.2 36.0 2,242.0 26.2 2,363.3

3.2 9.9 18.4 3.2 201.6 2.4 212.5
1.3 3.9 7.3 1.3 78.5 0.9 82.8
0.1 0.1 0.3 0.1 0.1 0.1 0.4


0.5 1.3 60.5 , 61.3




4.6 14.4 27.3 4.6 340.7 3.4 357.0


'



4.6 14.4 27.3 4.6 340.7 3.4 357.0
KEY TO TREATHEHT ALTERNATIVES

   PSES-1  -  BPT
   PSES-2  "  BPT + BAT-1
   PSES-3  -  BPT + BAT-2
   PSES-4  «  BPT + BAT-3
              KEY TO CSTI STEPS
H:  Recycle
I:  Rinse Reduction
J:  Pressure Filtration
K:  Vapor Compression Distillation
L:  Recycle
                                   532

-------
                                                      TABLE VIII-19

                                  BAT/PSES TREATMENT MODEL COSTS;  BASIS 7/1/78 DOLLARS

                              Subcategory:  Hot Coating            .        Model Size-TPD :  365
                              Subdivision:  Terne, Without Fume Scrubbers  Oper. Days/Year:  260
                                         :  All Products                   Turns/Day      :    3
          C&TT Step
                              Total
                               BPT
Investment ($ x 10~3)         477.0

Annual Costs ($ x 10  )

  Capital                      42.9
  Operation & Maintenance      16.7
  Land   .                       0.6
  Sludge Disposal               1.2
  Hazardous Waste Disposal
  Oil Disposal                  0.1
  Energy & Power                4.8
  Steam
  Waste Acid
  Crystal Disposal
  Chemical                      3.8

TOTAL                          70.1

Credits
  Scale
  Sinter
  Oil
  Acid Recovery

TOTAL CREDITS

NET TOTAL                      70.1
 BAT
Alt.
  1

 (1)
 BAT Alternative 2
t_       I       Total

                177.6
          131.0
          11.8
           4.6
           0.1
          16.5
       46.6
        4.2
        1.6
        0.1
                    0.2
                    6.1
16.0
 6.2
 0.2
                              0.2
                             22.6
                                      131.0
11.8
 4.6
 0.1
                                       16.5
                                                                                        BAT Alternative 3
                                                1,873.7
                                                   32.0
                                                  266.1
                                                            25.5
168.4      2.3      182.5
 65.6      0.9       71.1
  0.1      0.1        0.3
                                                             3.3
                                                                       32.0
                                                                      285.9
                                                  16.5
                                                            6.1
                                                                     22.6
                                                                               16.5
                                                                                          266.1
                                                                                                     3.3
                                                                                                              285.9
(1)  Since the BAT-1 treatment component is fume scrubber recycle,
     it does not apply to those models without fume scrubbers.
                         KEY TO TREATMENT ALTERNATIVES

                            PSES-1  -  BPT
                            PSES-2  -  BPT
                            PSES-3  -  BPT + BAT-2
                            PSES-4  »  BPT + BAT-3
                                                                             KEY TO C&TT STEPS
                    H:   Rinse  Reduction      J:  Vapor  Compression  Distillation
                    I:   Pressure  Filtration   K:  Recycle
                                                             533

-------
                              TABLE VIII-20

          BAT/PSES  TREATMENT MODEL COSTS;  BASIS  7/1/78  DOLLARS
Subcategory: Hot Coating
Model Size - TPD: 365
Subdivision: Terne, With Fume Scrubbers Oper. Days/Year : 260



C&TT Step
Investment (S x 10~3)
Annual Costs ($ x 10~3)
Capital
Operation & Maintenance
Land
Sludge Diiposal
Uarardoui Waste Disposal
Oil Disposal
Energy & Power
Stem
Waste Acid
Crystal Disposal
Chemical
TOTAL
Credits
Scale
Sinter
Oil
Acid Recovery
TOTAL CREDITS
HET TOTAL
: All Products
BAT
Total Alt. 1
BPT G Total
557.3 53.8 53.8

50.1 4.8 4.8
19.6 1.9 1.9
0.7 0.1 0.1
1.7

0.1
6.2 0.6 0.6



5.9
84.3 7.4 7.4






84.3 7.4 7.4
Turns /Day : 3
BAT Alternative 2 BAT Alternative 3
Alternative 1 Plua: Alternative 1 Plus:
H I Total H J K Total
131.0 56.9 241.7 131.0 2,049.8 25.5 2,260.1

11.8 5.1 21.7 11.8 184.3 2.3 203.2
4.6 2.0 8.5 4.6 71.7 0.9 79.1
0.1 0.1 0.3 0.1 0.1 0.1 0.4



0.3 0.9 44.2 44.8




16.5 7.5 31.4 16.5 300.3 3.3 327.5






16.5 7.5 31.4 16.5 300.3 3.3 327.5
KEY TO TREATMENT ALTERNATIVES

   PSES-1  »  BPT
   PSES-2  "  BPT +• BAT-1
   PSES-3  -  BPT + BAT-2
   PSES-4  »  BPT + BAT-3
              KEY TO C&TT STEPS
G:  Recycle
H:  Rinse Reduction
I:  Pressure Filtration
J:  Vapor Compression Distillation
K:  Recycle
                                    534

-------
                                                      TABLE VIII-21

                                  BAT/PSES TREATMENT MODEL COSTS;  BASIS 7/1/78 DOLLARS
                        Subcafcegory:  Hot Coating
                        Subdivision:  Other Metals, Without Fume Scrubbers
                                   :  Sheet/Strip/Miscellaneous
                                          Model Size-TPD :  500
                                          Oper. Days/Tear:  260
                                          Turns/Day      :    2
C&TT Step
Investment ($ x 10~3)
Total
BPT
571.3
BAT
Alt.
1
(1)
BAT
G
180.0
Alternative 2
H
56.2
Total
236.2
G
180.0
BAT Alternative 3
I
2,026.5
J
25.5
Total
2,232.1
Annual Costs ($x 10  )

  Capital                      51.4
  Operation & Maintenance      20.0
  Land                          0.6
  Sludge Disposal               4.8
  Hazardous Waste Disposal
  Oil Disposal                  0.3
  Energy & Power                7.5
  Steam
  Waste Acid
  Crystal Disposal
  Chemical                      4.9

TOTAL                          89.5

Credits
  Scale
  Sinter
  Oil
  Acid Recovery

TOTAL CREDITS

NET TOTAL                      89.5
           16.2
            6.3
            0.1
           22.6
5.1
2.0
0.1
                     0.3
                     7.5
21.3
 8.3
 0.2
                               0.3
                              30.1
16.2
 6.3
 0.1
                                        22.6
182.2      2.3      200.7
 70.9      0.9       78,1
  0.1      0.1        0.3
                                                    43.6
                                                   296.8
                                                              3.3
                                                                        43.6
                                                                       322.7
                                                  22.6
                                                            7.5
                                                                     30.1
                                                                               22.6
                                                                                          296.8
                                                                                                     3.3
                                                                                                              322.7
(1)  Since the BAT-1 treatment component is fume scrubber recycle,
     it does not apply to those models without fume scrubbers.
                         KEY TO TREATMENT ALTERNATIVES
                                                                             KEY TO C&TT STEPS
                            PSES-1
                            PSES-2
                            PSES-3
                            PSES-4
BPT
BPT
BPT + BAT-2
BPT + BAT-3
G:  Rinse Reduction      I:  Vapor Compression Distillation
Hs  Pressure Filtration  J:  Recycle
                                                              535

-------
                    TABLE VIII-22




BAT/PSES TREATMENT MODEL COSTS;  BASIS 7/1/78 DOLLARS
Subcatcgory:
Subdivision:



CSTT Step
Investment ($ x 10~3)
Annul 1 Cost* ($ x 10~3)
Capital
Operation 6 Maintenance
Land
Sludge Disposal
Hazardous Haste Disposal
Oil Disposal
Energy & Power
Steaa
Waste Acid
Crystal Disposal
Chemical
TOTAL
Credits
Scale
Sinter
Oil
Acid Recovery
TOTAL CREDITS
MET TOTAL
:

Total
BPT
659.9

59.4
23.1
0.7
6.1

0.5
8.3



7.5
105.6






105.6
Hot Coating Model Size - TPD: 500
Other Metals, With Fume Scrubbers Oper. Days/Year : 260
Sheet/Strip/Miscellaneous Turns/Day
BAT BAT -Alternative 2
Alt. 1 Alternative 1 Plus:
G Total H I Total H
53.8 53.8 180.0 105.4 339.2 180.0

4.8 4.8 16.2 9.5 30.5 16.2
1.9 1.9 6.3 3.7 11.9 6.3
0.1 0.1 0.1 0.1 0.3 0.1



0.6 0.6 0.3 0.9




7.4 7.4 22.6 13.6 43.6 22.6






7.4 7.4 22.6 13.6 43.6 22.6
KEY TO TREATMENT ALTERNATIVES KEY TO C&TT



PSES-1 -
PSES-2 -
PSES-3 -
BPT G: Recycle I:
BPT + BAT-1 H: , Rinse Reduction J:
BPT + BAT-2 K:
: 2
BAT Alternative 3
Alternative 1 Plus:
J K Total
2,345.5 25.5 2,604.8

210.9 2.3 234.2
82.1 0.9 91.2
0.1 0.1 0.4



57.0 57.6




350.1 3.3 383.4






.350.1 3.3 383.4
STEPS
Pressure Filtration
Vapor Compression pistillati
Recycle
                           536

-------
                                                      TABLE VIII-23

                                  BAT/PSES TREATMENT MODEL COSTS;  BASIS 7/1/78 DOLLARS

                           Subcategory:  Hot Coating                           Model Size-TPD :    15,
                           Subdivision:  Other Metals,. Without Fume Scrubbers  Oper. Days/Year:   260
                                      :  Wire Products/Fasteners               Turns/Day      :     2
C&TT Step
Investment ($ x 10~ )
Total
BPT
225.3
BAT
Alt.
1
(1)
BAT
G
5.4
Alternative 2
• H
15.4
Total
20.8
G
5.4
BAT Alternative 3
I
1,024.3
J-
15.1
Total
1,044.
Annual Costs ($ x 10~ )

  Capital             .         20.3
  Operation & Maintenance       7.9
  Land                          0.5
  Sludge Disposal               0.4
  Hazardous Waste Disposal
  Oil Disposal
  Energy & Power                1.5
  Steam
  Waste Acid
  Crystal Disposal
  Chemical                      0.8

TOTAL                          31.4
                                              0.5
                                              0.2
                                              0.1
                                                   0.8
1.4
0.5
0.1
                                                       0.1
                                                            2.1
1.9
0.7
0.2
                                                                 0.1
                                                                      2.9
0.5
0.2
0.1
92.1      1.4       94.0
35.9      0.5       36.6
 0.1      0.1        0.3
                                                                                0.8
                                                                                       5.8
                                                                                          133.9
                                                                                                     2.0
                                                                                                           5.8
                                                                                                              136.7
Credits
  Scale
  Sinter
  Oil
  Acid Recovery

TOTAL CREDITS

NET TOTAL
                               31.4
                                                   0.8
                                                            2.1
                                                                      2.9
                                                                                0.8
                                                                                          133.9
                                                                                                     2.0
                                                                                                              136.7
(1)
Since the BAT-1 treatment component is fume scrubber recycle,
it does not apply to those models without, fume scrubbers.
                         KEY TO TREATMENT ALTERNATIVES

                            PSES-1  =  BPT
                            PSES-2  =  BPT
                            PSES-3  =•  BPT + BAT-2
                           , PSES-4  =  BPT + BAT-3
                                                                             KEY TO C&TT STEPS
                                                       G:  Rinse Reduction      I:   Vapor Compression Distillation
                                                       H:  Pressure Filtration  J:   Recycle
                                                          537

-------
                    TABLE VIII-24




BAT/ESES TREATMENT MODEL COSTS;  BASIS 7/1/78 DOLLARS





C&TT Stan
Inveatnont ($ x 10~3)
Annual Costs ($ x 10~3)
Capital
Subcategory:
Subdivision:
s

Total
BPT
404.2

36.3
Operation & Maintenance 14.2
Land
Sludge Disposal
0.5
0.5
Hot
Coating
Other Metals, With Fume
Wire

Products/Fasteners
BAT BAT

Scrubbers

Alternative
Model Size -
TPD: 15

Oper. Days /Year : 260
Turns /Day
2
Alt. 1 Alternative 1 Plus:
G
53.8

4.8
1.9
0.1

Total H
53.8 5.4

4.8 0.5
1.9 0.2
0.1 0.1

I
32.6

2.9
1.1
0.1

Total H
91.8 5.4

8.2 0.5
3.2 0.2
0.3 0.1

: 2
BAT Alternative 3
Alternative 1 Plus:
J K
1,454.8 24.0

130.8 2.2
50.9 0.8
0.1 0.1




Total
1,538.0

138.3
53.8
0.4

Hazardous Waste Disposal
Oil Disposal
Energy & Power
Steam
Haste Acid
Crystal Disposal
Chemical
TOTAL
Credits
Scale
Sinter
Oil
Acid Recovery
TOTAL CREDITS
HEX TOTAL

3.4



3.0
57.9






57.9

0.6




7.4






7.4

0.6




7.4 0.8






7.4 0.8

0.1




4.2






4.2
KEY TO TREATMENT ALTERNATIVES



PSES-1 -
PSES-2 -
PSES-3 »
BPT
BPT •

I- BAT-1
G: Recycle

0.7




12.4 0.8






12.4 0.8
KEY TO C&TT
I:
H: Rinse Reduction J:
BPT + BAT-2
K:

11.6;




193.4 3.1






193.4 3.1
STEPS
Pressure Filtration
Vapor Compression Di>
Recycle

12.2




204.7






204.7


stillatJ

                          538

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-------

FUME
SCRUBBER
(ONCE-THROU
CHROMATE
RINSEWATER

ALL OTHER
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FUME
SCRUBBER
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CHROMATE
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CHROMATE
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ALL OTHER
RINSEWATER
REDUCTION


552

-------
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-------
                       HOT  COATING  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  based on  the same
model treatment technologies used as the basis for  the BPT limitations
originally promulgated  in 1976  and those proposed in  January 1981   (46
FR  1858).   Reanalysis of the  flow data for this subcategory  indicate
that the model rinsewater flows for  strip,  sheet  and  miscellaneous
products used as the basis for  the original regulation is appropriate.
The  rinsewater  flows  for  wire  products  and  fasteners  have been
increased to reflect the larger data base  currently  available.    The
Agency determined, however, that discharges from fume scrubbers should
be separately limited.  Accordingly, the Agency has established a fume
scrubber  subdivision.   The  promulgated  BPT  limitations  have been
established on the basis of lime precipitation and  sedimentation.   A
review  of the treatment processes and effluent limitations associated
with the hot coating subcategory follows.

Identification of BPT

Based upon the information contained in Sections III  through VIII,  the
Agency determined that effective pollutant  load  reductions   for   hot
coating  operations, for the BPT level of treatment  can be accomplished
through the use of the following treatment systems:

A.   Galvanizing Operations

     This treatment system sequence includes: equalization of  various
     wastewater  sources;  blending;  separate  chromium reduction  for
     wastewaters from the chromate rinse  steps;  lime  neutralization
     with  mixing  in  a  reactor  tank;  polymer  addition to enhance
     flocculation  and  sedimentation;  automatic  oil  skimming;   and
     clarification  with sufficient retention time to settle suspended
     solids.  All wastewaters,  including  fume  scrubber  wastewaters,
     are   treated  once-through  by  this  system.   This  system  is
     illustrated in Figure IX-1.

B.   Terne and Other Metal Coating Operations

     All steps in the BPT model treatment system are  the same  as   for
     galvanizing,   except  that  a separate chromium  reduction step is
     not included.   All process  and  fume  scrubber  wastewaters   are
     treated  once-through by this system.   This system is illustrated
     in Figure IX-2.
                                    555

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Rationale for Selection of BPT
The following discussion  summarizes  the  factors  evaluated  by  the
Agency in selecting the model BPT treatment systems and the respective
BPT limitations.

BPT Model Flows

In  determining  the  BPT model flows all of the flow data reported by
•the .industry were used, except where the Agency determined  that  they
are  not representative of hot coating discharges.  In some cases, the
flows reported  by  industry  included  both  process  and  noncontact
cooling  water,  thus overstating process flow rates.  In other cases,
maximum design flows were given,  which  were  paired  with  "typical"
production  data,  yielding artificially high gallon/ton figures.  The
flow rate established as the BPT model flow  is  the  average  of  the
reported  flows  for  those  plants  which  are  representative of hot
coating operations.  A description of these data is presented  in Table
V-1.  A summary of flows shows the following comparisons:
Strip,Sheet,Misc. Products:
  Rinsewaters -Galvanizing
              -Terne
              -Other

Wire Products & Fasteners:
  Rinsewaters - Galvanizing
              - Other
                               Average
                               Applied
                              Flow Rates
                                GPT
595
522
345
2356
2-184
          GPM
Fume Scrubbers:
                 Galvanizing
                  SSM
                 Galvanizing
                 WPF

                 Terne
                 Other-SSM*
                 Other-WPF2
          98

          38


          92

         120
No. of Lines
Included in
 Average
 48 of 51
  5 of 6
  3 of 4
 56 of 58
 14 of 15
 10 Of 21

 12 of 12


  3 of 3

  3 Of 3
1A11 scrubbers are listed as "dry".
20nly one plant with three scrubbers reported data, and  it
shut down.
                           has  since
The  Agency  considers  those plants that were not used to develop the
model flow rates are  not  representative  of  well  operated  plants.
These plants reported flow rates that ranged from three to eight times
                                    556

-------
 greater  than  the  average  flow  for the respective subdivision.  As
 demonstrated at other hot coating operations, product quality  is  not
 adversely  affected  where low discharge flows are achieved.  Thus the
 Agency believes that the high discharge flow rates  reported  by  some
 plants are unnecessary for proper operation of the plant.

 Since  flow  rates,  by  product,  are  similar  regardless of applied
 coating,  a common BPT model flow was used for each  subdivision.    The
 model  flows  used  are  600  GPT  for strip, sheet, and miscellaneous
 product rinsewaters,  and 2400 GPT for wire product or fasteners.    The
 fume  scrubber  limitations  were based on a model flow of 100 gallons
 per minute per scrubber.

 Effluent  Quality

 The effluent concentrations  used  by  the  Agency  to  establish  the
 effluent   limitations for this subcategory are based on the evaluation
 of  long term data reported by the industry and sampling data  acquired
 by   the  Agency. ,  These effluent data are from treatment facilities in
 which  hot  coating   wastewaters   are   co-treated   with   pickling
 wastewaters.    These   data  are representative of  the effectiveness of
 the model  treatment upon hot coating wastewaters.    This  co-treatment
 practice   is commonly used in the industry to treat  these  wastewaters.
 These treatment practices are the same  as  the BPT  model  treatment
 system.    The  evaluation to these data are presented in Appendix A to
 Volume I.   The results for the pollutants limited  in this   subcategory
 are as follows:

                            Concentration (mg/1)
                         30-day Average    Daily Maximum
     TSS                     30
     O & G                   10
     Lead                     0.15
     Zinc                     0.10
     Chromium, hexavalent*    0.02
70
30
 0.45
 0.30
 0.06
*Hexavalent  chromium  is  limited  only  at  galvanizing  lines  with
discharge from the chromate rinse step of the coating operation.


Demonstration of BPT Limitations

The rationale for selecting these five pollutants  for  limitation  is
presented   in   detail   in   Section   VI.    These  pollutants  are
characteristic of hot coating wastewaters.  As  discussed  in  Section
VI,  the Agency believes that regulation of these five pollutants will
result in effective control of other toxic pollutants .present in these
wastewaters.  In addition, limiting a common set of pollutants for all
hot coating discharges facilitates co-treatment  of  the  various  hot
coating wastewaters,  as well as with compatible wastewaters from other
subcategories.
                                    557

-------
The  BPT limitations were developed using the model flows and effluent
concentrations discussed above.  These are presented  in  Table  IX-1.
The  achievability  of these effluent limitations at plants sampled by
the Agency are discussed below.   The  limitations  and  the  effluent
loads  for  the  sampled  plants are compared in Table IX-2 for strip,
sheet and miscellaneous product coating operations and Table IX-3  for
wire products and fasteners.


Total Suspended Solids (TSS)

Of the twelve plants surveyed  (two visited twice), only one Plant V-2,
was  not  achieving  adequate  suspended  solids  removal.   This poor
performance is  attributable   to  insufficient  retention  time  in  a
settling basin.  This plant discharges its wastewaters to a POTW.  One
other  plant  (Plant  MM-2)  was  not achieving the 30-day average TSS
limitations, but was discharging TSS loads at less than its respective
daily maximum limitation during the  2-3  day  sampling  survey.   The
other plants were well in compliance with the 30-day BPT limitations.

Oil and Grease

All  of  the sampled plants provided some degree of oil removal.  Some
plants accomplished this  by   skimming,  others  by  flocculation  and
settling.

The  two plants that were sampled on two separate occasions were found
to have discharges exceeding the  BPT  limitations  during  the  first
survey  (listed  as  Plants  NN-2  and  PP-2).   However, these plants
(listed as  118 and 113, respectively) had improved their  oil  removal
so  that  during  the  toxic pollutant survey their discharges were  in
compliance with the limitations.  The only other discharger failing  to
achieve the BPT limitations for oil and grease  was  Plant  MM-2.    An
excessive   contribution of  22.5 mg/1 oil and grease was found in plant
effluents.  The discharge from this plant contained cold rolling  mill
wastes  which  were  not  adequately  treated   in  this  system.  This
treatment system experienced wide fluctuations  in pH   indicating  some
control problems were being experienced at this plant.  All other data
support BPT limits on oil and  grease.

Zinc

Analysis  for  zinc was performed for ten of the plants  (including  the
two revisited plants).  The data demonstrate compliance with  the   BPT
limitations at all but one  plant  (Plant NN-2/118).

Lead

The  BPT  30-day  average   limitations for lead from hot  coating  lines
were  being met  by  seven of  the  plants  surveyed.   Three   other
operations,  although  exceeding  the  30-day average  limitations were
meeting the daily maximum  limits, averaging  54% over their  respective
30-day average limitations.
                                    558

-------
Hexavalent Chromium

Hexavalent  chromium was also effectively removed to  low concentration
levels, clearly demonstrating the achievability  of   the   limitations.
Data  from  the 12 sampling visits performed by the Agency demonstrate
that compliance with the BPT limitations was being achieved during   11
of these visits.  One plant exceeded the limitation for fume scrubbers
by  13%  -  26%  for  two  of its three scrubbers.  However, the total
allowance  for  fume  scrubbers  is  exceeded   by    less   than   4%.
Additionally,  long  term effluent data from Plant 0868A for the strip
galvanizing operation further demonstrates the  achievability  of  the
limitations.   Data  for  a  two  year  period demonstrated an average
effluent concentration of 0.001 mg/1 and a  maximum   concentration  of
0.005  mg/1.   These  concentrations  are well below  the concentration
basis used for the effluent limitations.
Of the plants visited, three were found to be operating outside the pH
limitations for at least part of the time, while the  other  six  were
achieving  pH limits of 6.0 to 9.0 during the sampling surveys.  Plant
V-2 is equipped with pH controls, but insufficient neutralizing agents
were being added to  elevate  pH  levels  to  near  neutral  prior  to
discharge  to  a  large POTW.  Plant MM-2 jointly treated a variety of
wastewaters in a large central treatment facility which  also  has  pH
control, but has apparently experienced some difficulty in controlling
wide fluctuations in pH.  Plant 112 was usually within pH constraints,
but  had  a  high reading of pH 9.5 for approximately six hours during
the sample runs.  The  BPT  pH  limitations  are  demonstrated  to  be
readily   achievable   through   the  application  of  proper  control
technology and monitoring equipment.
                                   559

-------
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-------
                        HOT COATING SUBCATEGORY

                               SECTION X

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

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

 This   section   identifies the BAT alternative  treatment   systems
 considered  for   the hot   coating   subcategory.    The  rationale   for
 selecting the BAT alternative  treatment  system  is  presented along  with
 the BAT limitations.

 The  BAT  'alternative treatment systems  for hot coating operations are
 summarized in Table VIII-4, steps H through  L   for  galvanizing,   and
 steps  G  through  K  for  all  other types of  coatings.   These alternative
 treatment systems are illustrated in Figure  VIII-1.    Tables   VIII-15
 through   VII1-24  provide   the model costs  for  each of the alternative
 treatment systems.   Table X-l  presents the  alternative limitations for
 each hot  coating  subdivision.   Figures X-l  and  X-2  illustrate  the   BAT
 model treatment systems.

 Identification of BAT

 Each  of  the  BAT   alternative treatment  systems  described below was
 developed to  be applied to  in  place model BPT treatment  systems.


BAT Alternative J_

The first BAT alternative relies on flow reduction  by  recycling   fume
scrubber  wastewaters  and  limiting blowdowns from  the scrubber system
to 15 gpm.  This reduced  scrubber   discharge   is   combined  with   the
rinsewater  (at the respective  BPT  model flow rate) and  treated in  the
BPT model treatment system).

BAT Alternative 2_

This alternative  includes  further  reductions  in  wastewater  flows
through   minimization   of   rinsewater   discharges.   This  reduced
rinsewater flow is combined with the blowdown from the   fume  scrubber
                                    565

-------
recycle  system  and  treated  in the BPT model treatment system.  The
effluent is then further treated by pressure filtration.

BAT Alternative 3

The third  alternative  includes  vapor  compression  distillation  to
achieve  zero  discharge.   This  technology is applied in lieu of the
filters in BAT alternative 2.  The wastewater is  evaporated,  with  a
clean  condensate returned to the process.  Residual solid material is
dried and landfilled.

Flow Rates

Wastewater discharge flow rates are reduced prior to  treatment  as  a
first  step  toward control of toxic pollutants.  Where fume scrubbers
are installed, these wastewaters are  recirculated  at  the  scrubbers
with  the  blowdown  being  directed  to  the treatment system.  These
wastewaters can be recycled at rates in excess of  85%,  as  shown  by
data  for  several  galvanizing,  operations.  The Agency believes this
recycle rate can be achieved by all operations  in  this  subcategory.
While  fume  scrubber wastewaters were discharged on a once thru basis
for the three terne  operations  studied,  two  of  these  plants  had
discharges  less than 15 GPM.  Scrubbers are not commonly installed at
lines coating with other metals.   The  applied  flows  and  discharge
rates,  and  percent  recycle  are  presented  in Table X-2.  The data
clearly demonstrate the achievability of the model blowdown flow  rate
(15  gpm)  used  for  fume  scrubbers  for each of the BAT alternative
treatment systems.

Several hot coating lines are  operated  with  dragout  recovery,  and
reuse  or  recirculation  of  the  rinsewater  to  further  reduce the
discharge of wastewaters.  BAT Alternatives 2 and 3 include  reduction
in discharges of rinsewaters and fume scrubber wastewaters.

The  information  submitted  by  the  industry  shows  that rinsewater
discharges are commonly reduced  by  reuse  or  recirculation  at  hot
coating  operatons.   Zero  discharge  has  been  reported  at several
plants.  These methods of flow reduction  evidently  have  no  adverse
effect  on  product  quality,  despite  the  low  discharge flow rates
achieved.  The Agency has used cascade  rinsing  to  model  rinsewater
flow reduction.  This method of flow reduction is used at pickling and
electroplating operations, both of which are similar processes.  Water
is  used  in  the  same manner to rinse the products after it has been
processed.  Cascade rinsing is equally,  if  not  more,  effective  in
cleaning  the product as conventional rinsing systems, and, therefore,
will have no adverse effect on product quality.  Additionally, the use
of cascade rinsing results in more  conservative  cost  estimates  for
achieving  the lower discharge flow rates included in BAT Alternatives
2 and 3.  Cascade rinsing can be applied to hot coating operations  to
reduce  rinsewater  flows.  However, as shown by the data in Table X-3
and demonstrated at hot coating and pickling operations,  the  reduced
rinsewater  flows  can  be  achieved  by  methods  other  than cascade
rinsing.   The  rinsewater  flows  are  reduced  to  150  gal/ton  for
                                    566

-------
 operations coating strip,  sheet and miscellaneous products.   For those
 operations  coating wire products and fasteners,  the rinse water flows
 are reduced to 600 gallons/ton.   The rinsewater flow data presented in
 Table X-3  demonstrate the achievability of the  discharge  flow  rates
 used as basis  for BAT Alternatives 2 and 3.

 Effluent Limitations

 The Agency has selected the same toxic metal  pollutants,  for which BPT
 limitations have  been  established,  for limitation at the BAT level.
 These pollutants  are lead and  zinc for  all   coating  operations,   and
 hexavalent  chromium  for  those galvanizing  operations using chromate
 rinses.    The   rationale  for   the  selection  of  these  toxic  metal
 pollutants  are  presented  in  Sections  VI   and  IX.    The  effluent
 concentrations, model flow rates and the effluent limitations for each
 of  the BAT alternative treatment systems are  presented in Table X-l.

 Selection  of BAT  Alternative

 The Agency selected BAT Alternative  1   as the  BAT  model   treatment
 system  upon   which  to  base   the  BAT  limitations.    Hence,  the BAT
 limitations for the toxic  metal   pollutants   for   the   fume   scrubbing
 subdivision are   more  stringent than the respective  BPT limitations,
 reflecting the flow  reduction  attained  through  recycle.    The  BAT
 limitations for  the other subdivisions,  which  include  only  rinsewater
 discharges,  are the same as the  BPT limitations for metal pollutants.
 No   additional  treatment   for  the  rinsewater  discharge  is required
 beyond BPT.

 BAT Alternative 2  was not  selected,  since the  Agency   has  .concluded
 that  it   may  not  be feasible  t'o retrofit cascade rinse systems at all
 existing   hot   coating  operations   at   a reasonable    cost.     Space
 limitations  and   the  configuration   of   some  hot  coating lines would
 require  in  some instances  reconstruction  of the entire  line   in  order
 to  retrofit cascade rinsing systems.   In  addition,  as  indicated by the
 toxic  metal   concentrations present  in  Table X-l,  filtration does not
 result  in  substantial  reduction  in  the discharge  of  toxic metals  over
 that   achieved  at   the  BPT level of treatment.   The retrofit problems
 associated  with cascade  rinsing  are not   experienced   in  any  of   the
 other  treatment systems considered by the Agency.   Cascade  rinsing is
 unique,  in  that,  it  is  the  only  technology which  requires modification
 to  the production process.  All  other model treatment systems used by
 the  Agency  are  end-of—pipe  systems.

BAT  Alternative 3  was rejected  due to its high energy  consumption and
associated  costs.

Demonstration of the.BAT Limitations

As noted above, the model BAT treatment system  flow  rates   for   fume
scrubbers  are  achieved  at Plants 0060G, 0112F, 0460C,  0492A,  0856P,
0864B, 0868A and 0920D.  The rinsewater flows  are  the   same   as  the
rinsewater  flows  used  at ,BPT, and its achievability  is discussed in
                                    567

-------
Section IX.  The effluent quality data used to develop the BPT and BAT
limitations are demonstrated on a long term  basis  at  plants  0584E,
0856D  and  0860B.   Other  short  term  sampling data as discussed in
Section IX also demonstrate the achievability of these concentrations.
                                   568

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569

-------
                                   TABLE X-2
                        JUSTIFICATION OF BAT FLOW BASIS
                            HOT COATING SUBCATEGORY
                       FUME HOOD SCRUBBER RECYCLE SYSTEMS
Plant

BAT Basis
0060G-1
0060G-2
0060G-3
0060G-4
0060G-5
0060S-1
0060S-2
0060S-3
0112F-1
0112F-2
0460C
0492A
0584C-1
0856F-2
0856P
0864B-3
0864B-5
0868A-3
0920D-1
0920D-2
Product

 All
 WPF
 WPF
 WPF
 WPF
 WPF
 WPF
 WPF
 WPF
 WPF
 WPF
 WPF
 SSM
 SSM
 SSM
 WPF
 WPF
 SSM
 SSM
 SSM
 SSM
Applied
GPM
100
66
66
66
165
79
j 200
79
| 60
30
50
250
1,200
170
30
5
10
90
135
Discharged
GPM
15
6
6
6
15
7
120
7
]•
0
0
30
0
0
0
5
10
0
0
Percent
Recycle
85.0
90.9
90.9
90.9
90.9
91.1
J90.0
91.1
186.7
100.0
100.0
88.0
100.0
100.0
100.0
0.0
0.0
100.0
100.0
    Plant Data
   Demonstrates:
Effluent Percent
 GPM     Reduction
 X
 X
 X
 X
 X
 X
 X

 X
 X

 X
 X
 X
 X
 X
 X
 X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X : Data supports stated BAT blowdown flow basis or recycle rate as indicated.

SSM: Strip, sheet and miscellaneous products.
WPF: Wire products and fasteners.
                                     570

-------
                                TABLE X-3
               JUSTIFICATION OF BAT-2 AND NSPS FLOW BASIS
                         HOT COATING SUBCATEGORY
                    RINSEWATER FLOW REDUCTION SYSTEMS
Plant

NSPS Basis:

0256G-1
0256G-2
0264-1
0264-2
0264-3
0264D-2
0384A-1
0384A-2
0384A-3
0460C
0460F-1
0460F-2
0460H-1
0460H-2
0476A-3
0640-1
0728
0856N-1
0856N-2
0856N-3
0860F-1
0860F-2
0860F-3
0860G-1
0860G-2

Product
SSM
WPF
SSM
SSM
WPF
WPF
WPF
WPF
SSM
SSM
SSM
WPF
WPF
WPF
WPF
WPF
SSM
WPF
SSM
SSM
SSM
SSM
WPF
WPF
WPF
WPF
WPF
Applied
GPT
600
2,400
107
107
1,580
1,210
451
2,641
31.6
21.9
16.8
1,080
706
627
507
507
56
529
480
112
214
218
3,130
5,760
5,760
8,182
3,025
Discharged
GPT
150
600
107
107
596
605
4.5
574
31.6
21.9
16.8
5.4
141
125
507
507
56
529
0
0
0
0
157
9.6
6.4
0
0
Percent
Reduction
75.0
75.0
0.0
0.0
62.3
50.0
99.0
78.3
0.0
0.0
0.0
99.5
80.0
80.0
0.0
0.0
0.0
0.0
100.0
100.0
100.0
100.0
95.0
99.8
99.9
100.0
100.0
                                                            Plant Data
                                                            Demonstrates:
GPT
X
X
X
(1)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
 Percent
Reduction
   X
   X
   X
   X
   X
   X
   X
   X
   X
   X
   X
   X
   X
   X
                                     571

-------
TABLE X-3
JUSTIFICATION OF BAT-2 AND NSPS FLOW BASIS
HOT COATING SUBCATEGORY
RINSEWATER FLOW REDUCTION SYSTEMS
PAGE 2
                                                            Plant Data
                                                            Demonstrates:
Plant
Product
0868A-2
0916A-3
0920D-1
0920D-2
0920E-1
0920E-2
0948C-1
0948C-2
0920F
(Terne)
0384ACA1)
0580G-4(Sn)
0792B(Sn)
0860F-4CA1)
SSM
SSM
SSM
SSM
SSM
SSM
SSM
SSM
SSM

SSM
WPF
SSM
WPF
Applied
  GPT

  135
  120
  768
  120
  116
  136
  140
  92
  301

  16
  300
  80
  10,800
Discharged
   GPT

   135
   0
   64
   120
   116
   136
   140
   92
   141
                                       16
                                       300
                                       0
                                       640
                             (2)
Percent
Reduction

  0.0
  100.0
  91.7
  0.0
  0.0
  0.0
  0.0
  0.0
  53.2

  0.0
  0.0
  100.0
  94.1
GPT

X
X
X
X
X
X
X
X
X

X
X
X
X
Percent
Reduction
                                                                     X
                                                                     X
                                 X
                                 X
(1) Plant exceeds limit by <1%.
(2) Flow included scrubber blowdown.  Demonstrates combined discharge
    flow basis of 600 GPT plus 15 GPM scrubber blowdown, equivalent to
    1080 GPT for this operation.

X  : Data supports stated BAT-2 and NSPS discharge flow basis or percent reduction as
     indicated.
SSM: Strip, sheet and miscellaneous products.
WPF: Wire products and fasteners.
( ): Coating metal shown within parentheses.  All others are
     galvanizing lines.
                                     572

-------
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                                                        574

-------
                       HOT COATING 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.  In no
case may BCT be less stringent than BPT.

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  conventional  pollutants   for   the   hot   coating
subcategory.  No additional treatment or costs beyond the BPT level is
needed to comply with these limitations.
                                    575

-------

-------
                       HOT COATING SUBCATEGORY

                             SECTION XII

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

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.

For  this  subcategory, several plants in the industry are reported to
operate with no discharge.  On the basis of  demonstrated  performance
at  Plant 0856N, the Agency believes that zero discharge is achievable
at some batch pipe and  tube  galvanizing  operations.   However,  the
technology employed at this plant may not be universally applicable to
all  hot  coating  operations.   A  "no discharge of pollutants" limit
would only be possible for all hot coating operations through the  use
of  advanced  technologies,  e.g., vapor compression distillation (BAT
Alternative 3).  However, this technology has not been demonstrated on
wastewaters from hot coating operations.

Identification of_ NSPS Technology

The Agency considered four alternative treatment systems for  new  hot
coating  operations.   The  model flow rates, concentration basis, and
the alternate NSPS are presented on Table XII-1.   These  alternatives
are depicted in Figures VIII-1 and 2.

NSPS Alternative J_ '

This  alternative  includes all of the treatment steps included in the
model BPT treatment systems and does  not  include  flow  minimization
prior  to  treatment.   Wastewaters  are  discharged on a once-through
basis.

NSPS Alternative ,2

This NSPS alternative includes flow minimizations as the initial step.
The discharge of rinsewater is minimized; and where fume scrubbers are
installed, the wastewaters are recycled to achieve a blowdown rate  of
15  gallons/minute.   The  remaining steps include hexavalent chromium
reduction   for   galvanizing   operations   with   chromate   rinses,
precipitation   and   flocculation   with   lime   and  polymers,  and
clarification with vacuum filtration of clarifier underflows.
                                    577

-------
NSPS Alternative  3.

Alternative   3  includes   all   steps   and    components    included    in
Alternative   2,   with   the  addition   of   filtration.    The   clarifier
overflow  is  further  treated  using  a deep bed pressure filter.

NSPS Alternative  4

This  alternative uses  vapor   conpression  distillation to  further
process   the effluent  from  NSPS 2.   The wastewater  is  evaporated, and
the condensed distillate  is  recycled  back  to the  coating operation for
reuse.  Zero discharge  is attained with this alternative.

Flow Rates

The discharge flow rates  used to establish the standards are  shown   in
Table  XII-1.  These flows are  the same as those  used to establish the
alternate BAT limitations.   The development  and demonstration of these
flows is  discussed in detail in Section X.   The achievability of these
discharge flow rates is well demonstrated  (see Table X-2 and  X-3).

Effluent  Quality

The same  pollutants  limited  at  BPT are also being  limited  for  new
sources/  i.e.,   TSS,   0  & G, lead, zinc and hexavalent chromium.'  The
concentration bases  for the  standards  are  the same as those   used  for-
the  corresponding  BPT  and BAT alternative treatment  systems.  These
concentrations are  presented   in  Table   XII-1.   Discussion  on  the
selection of the pollutants and  the  development of the concentration
basis are set forth  in  Sections VI, IX and X.

Selection of  NSPS

The Agency selected  NSPS  Alternative  2 as  the  NSPS  model   treatment
system  upon  which  the   new   source  performance standards are based.
Flow minimization  of rinsewater and fume scrubber flows  is   practiced
by  several   plants.    Cascade   rinsing, which was rejected as  a model
treatment technology at the BAT level  due  to retrofit problems, can  be
readily installed  at new   sources  without  problems  associated  with
retrofitting  that  technology.    Cascade  rinsing   is  equally, if not
more, effective   in  cleaning   the product  as   conventional   rinsing
systems.   Thus,   the   use of   cascade  rinsing  will  have no  adverse
effects on product quality and  can be  applied at  all new hot   coating
lines.    However,   as   shown  by  the  data  in Table X-3, it has been
demonstrated  that  the reduced rinsewater   flows   can  be achieved   by
methods   other  than cascade   rinsing.    NSPS  Alternative   3  was not
selected, since no substantial  reduction (over that achieved  by  NSPS
Alternative   2)   in  toxic metals  discharge  is achieved by filtration.
NSPS Alternative 4 was  rejected, since it  is not  demonstrated  within
the  subcategory.     The  model   treatment  systems  are illustrated  in
Figure XII-1   for the galvanizing operations  and Figure  XII-2  for terne
and other coatings.
                                    578

-------
Demonstration of NSPS

The selected NSPS model flow rates are demonstrated  at  plants   0264,
0264D,  0460C,  0460F, 0728, 0856N, 0860F, and 0860G; and  the  selected
model, effluent quality are demonstrated at plants 01121, 0476A,  0584F,
0612,  0856D,  0860B,  and   0948C.    Further   discussion    on   the
achievability  of  the  model  flow  rates  and  effluent  quality   is
presented in Sections IX and X.
                                   579

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

-------
                       HOT COATING SUBCATEGORY

                             SECTION XIII

            PRETREATMENT STANDARDS FOR HOT COATING PLANTS
            DISCHARGING TO PUBLICLY OWNED TREATMENT WORKS
Introduction

This section presents alternative pretreatment systems  available  for
hot  coating  operations  with  discharges to publicly owned treatment
works (POTWs).  The Agency separately considered pretreatment  of  hot
coating  wastewaters from new sources (PSNS) and from existing sources
(PSES).

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  through  removal  allowances,   and   POTW
pretreatment programs.

In establishing pretreatment standards for hot coating operations, the
Agency  considered  the  objectives  and  requirements  of the General
Pretreatment Regulations.  The  Agency  determined  that  uncontrolled
discharges  of  hot  coating wastewaters to POTWs would result in pass
through of toxic pollutants.

Identification of Pretreatment Alternatives

Existing Sources

The model pretreatment systems for existing sources are  the  same  as
the  model  BPT and BCT treatment systems presented in Sections IX and
X.  The PSES standards  associated  with  each  alternative  treatment
system for all hot coating operations are set out in Table XIII-1..

PSES Alternative ]_

This  alternative is identical to the BPT model treatment system.  The
wastewaters are discharged on a once  through  basis.   The  treatment
steps   included   chemical  reduction  of  hexavalent  chromium  (for
galvanizing operations  with  chromate  rinses),  lime  precipitation,
flocculation  with  polymers, and clarification with vacuum filtration
of underflows.
                                    585

-------
PSES Alternative 2_

Alternative 2 includes the same  treatment  steps  as  Alternative  1,
except  that the fume scrubber flow to the treatment system is reduced
to 15 gpm by recycle.  The rinsewaters continue to be discharged on  a
once-through basis.

PSES Alternative 3.

This  alternative  is  the  same  as  Alternative  No.  2, except that
additional flow reduction and treatment is included.  Rinsewaters  are
reduced  by  the  use of cascade rinsing, further reducing the overall
discharge of wastewaters.  In addition the effluent from the clarifier
is further treated using pressure filters.

PSES Alternative 4.

This alternative achieves zero discharge  through  the  use  of  vapor
compression distillation.

New Sources

The  alternative pretreatment systems for new sources are identical to
the NSPS alternative treatment systems presented in Section XII.

PSNS Alternative T_

This alternative includes all of the treatment steps included  in  the
model   BPT   treatment   system,   and  does  not  include  any  flow
minimization.  Wastewaters are discharged on a once-through basis.

PSNS Alternative 2

This alternative includes flow minimization through the use of cascade
rinsing and recycle of fume scrubber wastewaters.  The treatment steps
include  reduction  of  hexavalent   chromium,   lime   precipitation,
flocculation  using polymers, and clarification with -vacuum filtration
of the clarifier underflow.

PSNS Alternative 3_

In this alternative,  the  effluent  from  Alternative  1  is  further
treated  by  filtration.   The  clarified  effluent  is  treated using
pressure filters.
PSNS Alternative £

This alternative achieves zero discharge
compression distillation.
through  the  use  of  vapor
                                    586

-------
Selection of Pretreatment Alternatives

The  Agency  selected PSES Alternative 2 and PSNS Alternative 2 as the
bases  for  the  promulgated  PSES  and  PSNS,  respectively.    These
alternatives are the same as the BAT and NSPS model treatment systems.
These  alternatives  provide  for  substantial removal of toxic metals
without the high cost of  evaporative  technologies.   Filtration,  as
included  in  PSES Alternative 3 and PSNS Alternative 3, provides only
marginal incremental  toxic  metals  removal.   A  comparison  of  the
removal  rates  of toxic metals from untreated hot coating wastewaters
for the selected pretreatment alternatives to POTW removal  rates  for
these metals follows:
Chromium (hexavalent)
Lead
Zinc
    PSES
Alternative 2

   95-99%
   83-95%
   80-99%
    PSNS
Alternative 2    POTW

   96-99%          0%
   87-98%         48%
   97-99.9%       65%
As  shown  above, the selected PSES and PSNS alternatives will prevent
pass through of toxic metals  at  POTWs  to  a  significantly  greater
degree  than  would  occur  if hot coating wastewaters were discharged
untreated to POTWs and  are  the  same  as  the  BAT  and  NSPS  model
treatment    systems,   respectively -.     The   selected   pretreatment
alternatives are illustrated in Figure XIII-1 and the  PSES  and  PSNS
are  presented  in . Table XIII-1 under the headings PSES Alternative 2
and PSNS Alternative 2,  respectively.   The  achievability  of  these
standards is addressed in Sections IX, X, and XII.
                                    587

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