Development Document for the Proposed Effluent Limitations Guidelines and Standards for the Iron and Steel Manufacturing Point Source Category


                 United States
                 Environmental Protection
                 Agency
Office of Water (4303)
Washington, DC 20460
EPA-821-B-00-011
December 2000
    &EPA      Development Document
                 for the Proposed  Effluent
                 Limitations Guidelines and
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                                  EPA-821-B-00-011
        DEVELOPMENT DOCUMENT
  FOR PROPOSED EFFLUENT LIMITATIONS
   GUIDELINES AND STANDARDS FOR THE
             IRON AND STEEL
MANUFACTURING POINT SOURCE CATEGORY
               December 2000
               Office of Water
        Office of Science and Technology
        Engineering and Analysis Division
      U.S. Environmental Protection Agency
            Washington, DC 20460

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                                                               Acknowledgment and Disclaimer
                      ACKNOWLEDGMENT AND DISCLAIMER

              This report has been reviewed and approved for publication by the Engineering
 and Analysis Division, Office of Science and Technology. The Agency would like to
 acknowledge the contributions of George Jett, Kevin Tingley, Yu-ting Liu, Elwood Forsht,
 William Anderson, Charles Tamulonis, Maria Smith, Jade Lee-Freeman, Jeanette Kranacs, Jan
 Matuszkp, Ahmar Siddiqui, Maria Gomez-Taylor, Carol Ann Siciliano, and Beverly Randolph
 toward the development of this'technical document.

              This report was prepared with the support of ERG, with subcontract support
 provided by Amendola Engineering, Inc., Hatch Engineering, GeoLogics Corporation, and
 DynCorp and statistical support provided by Science Applications International Corporation
 (SAIC) and Westat, under the direction and review of the Office of Science and Technology.
 Neither the United States  Government nor any of its employees, contractors, subcontractors, or
 their employees make any warrant, expressed or implied, or assume any legal liability or
 responsibility for any third party's use of or the results of such use of any information, apparatus,
 product, or process discussed in this report, or represents that its use by such party would not
 infringe on privately owned rights.

              The Agency wishes to thank the participating iron and steel mills for contributing
to this study. Their help has been invaluable.

              Cover photographs are courtesy of the Association of Iron and Steel Engineers
and California  Steel Industries, Inc.

              The primary contact regarding questions or comments on this document is:

                           George Jett            ;
                           U.S. EPA Engineering and Analysis Division (4303)
                           Ariel Rios Building
                           1200 Pennsylvania Avenue NW
                           Washington, DC 20460

                           (202) 260-7151 (telephone)
                           (202) 260-7185 (fax)
                          jett.george@epa.gov

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                                                        Table of Contents
                 TABLE OF CONTENTS
                                                               Page
 APPLICABILITY AND SUMMARY OF PROPOSED REGULATION ...  1-1
 1.1    Applicability .  .	  1-1
 1.2    Applicability Interface With Other Regulations	  1-2
       1.2.1  Metal Products and Machinery .	  1-3
       1.2.2  Electroplating		  1-4
       1.2.3  Metal Finishing 	'.'....'	  1-4
       1.2.4  Coil Coating	 .  1-5
       1.2.5  Ferroalloy Manufacturing . .	  1-5
       1.2.6  Metal Molding and Casting	  1-5
 1.3    Summary of Proposed Regulation  . .	  1-5
 1.4    Protection of Confidential Business Information  	  1-8
 1.5    References	  1-8

 BACKGROUND	'	  2-1
 2.1    Legal Authority	  2-1
       2.1.1  Legislative Background  .		 .  2-1
       2.1.2  Section 304(m) Requirements and Litigation	  2-4
 2.2    History of Iron  and Steel Category Rulemaking Activities	  2-4
       2.2.1  Prior Regulations	   2-4
       2.2.2  1982 Regulation	   2-6
       2.2.3  Preliminary Study of the Iron and Steel Category	   2-8

 DATA COLLECTION  . .	.	   3-1
 3.1    Surveys ....'.	   3-1
 3.2    Site Visits	   3-6
 3.3    Sampling	   3-7
 3.4    Other Data Sources .	:.......	".   3-9
 3.5    Public Participation  . . .	 3-10
 3.6    References	  .	-. 3-11

ANALYTICAL METHODS AND BASELINE VALUES .	   4-1
 4.1    Explanation and Importance of Baseline Values	   4-1
4.2    Reporting Conventions Associated with Analytical Results  ......   4-2
4.3    Nominal Quantitation Limits		   4-3'
4.4    Comparisons to  Baseline Values ......:	   4-4
       4.4.1  Comparison Type 1	•	   4-4
       4.4.2  Comparison Type 2	   4-4
4.5    Analytical Methods	   4-5
       4.5.1  Methods 1613B, 1625, 1664 (TCDF, Benzo(a)pyrene,
             Naphthalene, Phenol, HEM) .	   4-6

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                                                         Table of Contents
            TABLE OF CONTENTS (Continued)
                                                                 Page
       4.5.2  Method 1620 and 200.7 (Chromium, Lead, Mercury,
             Nickel, Selenium, Zinc)	 .  4-7
       4.5.3  Method 160.2, 209C, and 2540D (Total Suspended Solids) .  4-8
       4.5.4  Method 218.4 (Hexavalent Chromium)  .......	  4-8
       4.5.5  Method 239.2 (Lead)	 . .	  4-8
       4.5.6  Method 245.1 (Mercury)	  4-9
       4.5.7  Method 3120B (Chromium and Hexavalent Chromium) .  . .  4-9
       4.5.8  Method 3130B (Lead, Zinc)	 .  .	4-10
       4.5.9  Method 335.2 (Total Cyanide) .	 .'	 4-10
       4.5.10 Method 340.2 (Fluoride)	4-11
       4.5.11 Methods 350.2, 417/350.2, and 4500-NH3 (Ammonia as
             Nitrogen)  	4-11
       4.5.12 Methods 353.1, 353.2, and 353.3 (Nitrate/Nitrite)  ...... 4-12
       4.5.13 Methods 4500-CN M and D4374-98 (Thiocyanate)	4-12
       4.5.14 Method 625 (Naphthalene)	4-13
       4.5.15 Method 8270 (Benzo(a)pyrene)  	'.  . .  . . 4-13
       4.5.16 Methods 330.1, 330.2, 330.3, 330.4, 330.5 (Total
             Residual Chlorine)   	4-14
4.6    References . .	4-15

DESCRIPTION OF THE INDUSTRY	'.	  5-1
5.1    Types of Sites	  5-1
5.2    Manufacturing Operations	  5-4
       5.2.1  Cokemaking  	  5-4
       5.2.2  Sintering	  5-6
       5.2.3  Briquetting	  5-7
       5.2.4  Blast Furnace Ironmaking	  5-7
       5.2.5  Direct Reduced Ironmaking	  5-9
       5.2.6  Steelmaking: Basic Oxygen Furnaces (BOFs) and Electric
             Arc Furnaces (EAFs)	  5-9
       5.2.7  Vacuum Degassing	.5-11
     •5.2.8  Ladle Metallurgy and Secondary Steelmaking  	5-12
       5.2,9  Casting	 :	5-13
       5.2.10 Hot Forming	 5-14
       5.2.11  Finishing  . . . .  ,	5-17
5.3    References	5-20

SUBCATEGORIZATION	...	  6-1
6.1    Subcategorization Process	  6-1
6.2    Subcategory A:-Cokemaking	  6-4
                           11

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                                                        Table of Contents
           TABLE OF CONTENTS (Continued)
                                                                Page
6.3   Subcategory B: Ironmaking  . .'.	   6-4
6.4   Subcategory C: Integrated Steelmaking  .	   6-5
6.5   Subcategory D: Integrated and Stand-Alone Hot Forming  ......   6-6
6.6   Subcategory E: Non-Integrated Steelmaking and Hot Forming  ...   6-6
6.7   Subcategory F: Steel Finishing  .	   6-7
6.8   Subcategory G: Other Operations	 6-10

WASTEWATER CHARACTERIZATION	   7-1
7.1   Identification of Pollutants of Concern  .	   7-1
7.2   Calculation of Production-Normalized Flow Rates	   7-3
7.3   Cokemaking Subcategory	; . >	   7-5
7.4   Ironmaking Subcategory  	:	   7-8
      7.4.1  Sintering	   7-9
      7.4.2  Blast Furnace Ironmaking Segment  . .	;	7-10
7.5   Integrated Steelmaking Subcategory	 7-12
      7.5.1  Basic Oxygen Furnace (BOF) Steelmaking	7-12
      7.5.2'  Ladle Metallurgy  	7-14
      7.5.3  Vacuum Degassing	7-14
      7.5.4  Continuous Casting .  .	 7-15
7.6   Integrated and Stand-Alone Hot Forming Subcategory  	7-16
7.7   Non-Integrated Steelmaking and Hot Forming Subcategory  	7-18
      7.7.1  Electric Arc Furnace (EAF) Steelmaking	7-18
      7.7.2  Ladle Metallurgy  	7-18
      7.7.3  Vacuum Degassing	 7-18
      7.7.4  Continuous Casting .	7-19
      7.7.5  Hot Forming	 . . . !	7-21
7.8   Steel Finishing Subcategory	 .	.......... 7-22
      7.8,1  Acid Pickling		7-23
      7.8.2  Cold Forming  . . •	7-26
   •   7.8.3  Alkaline Cleaning  . .  . '.	 7-28
      7.8.4  Continuous Annealing	 . 7-29
      7.8.5  Hot Coating	7-30
      7.8.6  Electroplating	 . . 7-31
7.9   Other Operations Subcategory	 7-32
      7.9.1  Directed Reduced Ironmaking (DRI) Segment  .	7-33
      7.9.2  Forging Segment	7-33
      7.9.3  Briquetting Segment	7-34
7.10  References	 7-34
                           111

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                                                                    '  Table of Contents
10
                        TABLE OF CONTENTS (Continued)
                                                                              Page
TECHNOLOGY OPTIONS  . .	  8-1
8.1    Technology Overview	  8-1
       8.1.1  In-Process Technologies	  8-2
       8.1.2  End-of-Pipe Treatment Technologies	8-10
8.2    Development of Technology Options  	'	8-29
       8.2.1  Technology Options by Subcategory	 .	8-29
8.3    References		8-34

INCREMENTAL INVESTMENT AND OPERATING AND MAINTENANCE
COSTS FOR PROPOSED REGULATION	  9-1
9.1    Methodology	  9-1
       9.1.1  Investment Costs	,  9-3
       9.1.2  Operating and Maintenance Costs	  9-6
       9.1.3  One-Time Costs	  9-8
9.2    Results	 . .  9-9
       9.2.1  Cokemaking Subcategory - By-Product Segment	  9-9
       9.2.2  Ironmaking Subcategory	9-12
       9.2.3  Integrated Steelmaking Subcategory   	9-15
       9.2.4  Integrated and Stand-Alone Hot Forming Subcategory .... 9-16
       9.2.5  Non-Integrated Steelmaking and Hot Forming Subcategory .9-18
       9.2.6  Steel Finishing Subcategory	 9-19
       9.2.7  Other Operations Subcategory	 9-23
9.3    References	9-24

POLLUTANT LOADINGS  .	10-1
10.1   Sources and Use of Available Data	10-2
       10.1.1  Analytical Data Sources	10-2
       10.1.2  Calculation of Averages from Analytical Data	10-2
10.2   Methodology	10-3
       10.2.1  Baseline Pollutant Loading Calculation  	10-5
       10.2.2  Treated Pollutant Loading Calculation	: ...  10-7
10.3   Pollutant Loadings for the  Cokemaking Subcategory	10-10
       10.3.1  Baseline Pollutant Loadings	10-10
       10.3.2  Treated Pollutant Loadings	10-11
10.4   Pollutant Loadings for the  Ironmaking Subcategory	  . 10-14
       10.4.1  Baseline Pollutant Loadings	10-14
       10.4.2  Treated Pollutant Loadings	10-15
10.5   Pollutant Loadings for the  Integrated Steelmaking Subcategory .  . 10-16
       10.5.1  Baseline Pollutant Loadings .	10-16
       10.5.2  Treated Pollutant Loadings	10-17
                                        IV

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                                                                      Table of Contents
                        TABLE OF CONTENTS (Continued)
11
                                                                              Page
 10.6   Pollutant Loadings for the Integrated and Stand-Alone Hot
       Forming Subcategory  .		 10-18
       10.6.1 Baseline Pollutant Loadings :	10-18
       10.6.2 Treated Pollutant Loadings	10-19
 10.7   Pollutant Loadings for the Non-Integrated Steelmaking and Hot  '
       Forming Subcategory	 10-20
       10.7.1 Baseline Pollutant Loadings	10-21
       10.7.2 Treated Pollutant Loadings	10-21
 10.8   Pollutant Loadings for the Steel Finishing Subcategory	10-23
       10.8.1 Baseline Pollutant Loadings	10-23
       10.8f2 Treated Pollutant Loadings	 .10-23
 10.9   Pollutant Loadings for the Other Operations Subcategory .  . .  . . . 10-26
       10.9.1 Baseline Pollutant Loadings	.  . . .	10-26
       10.9.2 Treated Pollutant Loadings	10-26
 10.10  References	-. . .	 10-28

REGULATED POLLUTANTS	 11-1
 11.1   Regulated Pollutant Selection Methodology for Direct Dischargers . 11-1
 11.2   Cokemaking Subcategory	 11-3
 11.3   Ironmaking Subcategory  	11-4
 11.4   Integrated Steelmaking Subcategory	11-5
 11.5   Integrated and Stand-Alone Hot Forming Subcategory	 . .11-5
       11.5.1 Carbon and Alloy Steel Segment  .......:	 . 11-5
       11.5.2 Stainless Steel Segment 	11-6
11.6   Non-Integrated Steelmaking and Hot Forming Subcategory   .....11-6
       11.6.1 Carbon and Alloy Steel Segment	11-7
       11.6.2 Stainless Steel Segment	li-7
11.7   Steel Finishing Subcategory	11-7
       11.7.1 Carbon and Alloy Steel Segment 	11-8
       11.7.2 Stainless Steel Segment ....'-.'	  11-8
11.8   Other Operations Subcategory	11-10
       11.8.1 Direct Reduced Ironmaking Segment	 11-10
       11.8.2 Forging Segment		11-10
11.9   Regulated Pollutant Selection Methodology for Indirect
       Dischargers	......;...... 11-10
       11.9.1 POTW Pass-Through Methodology  .	,  . 11-12
11.10   Cokemaking Subcategory	 11-18
11.11   Ironmaking Subcategory  . ;	 . .  . 11-19
11.12   Integrated Steelmaking Subcategory	  .	 11-19
11.13  Integrated and Stand-Alone Hot Forming Subcategory  ....... 11-20

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                                                                     Table of Contents
                        TABLE OF CONTENTS (Continued)
                                                                             Page
12
       11.13.1      Carbon and Alloy Steel Segment	-11-20
       11.13.2      Stainless Steel Segment	11-20
11.14  Non-Integrated Steelmafang and Hot Forming Subcategory  .... 11-21
       11.14.1      Carbon and Alloy Steel Segment	11-21
       11.14.2      Stainless Steel Segment . . .	: .  . 11-21
11.15  Steel Finishing Subcategory	11-22
       11.15.1      Carbon and Alloy Steel Segment	'11-22
       11.15.2      Stainless Steel Segment	 11-22
11.16  Other Operations Subcategory .'	11-23
       11.16.1      Direct Reduced Ironmaking Segment	11-23
       11.16.2      Forging Segment	 -	11-23
11.17  References	 11-23

LIMITATIONS AND STANDARDS: DATA SELECTION AND
CALCULATION  	:	- -  12-1
12.1   Overview of Data Selection  .......:	12-1
12.2   Episode Selection for Each Subcategory and Option . .  . :	12-4
       12.2.1 Subpart A: Cokemaking Subcategory . . . .'	12-4
       12.2.2 Subpart B: Ironmaking Subcategory  	12-12
       12.2.3 Subpart C: Integrated Steelmaking Subcategory	12-15
       12.2.4 Subpart D: Integrated and Stand-Alone Hot Forming
             Subcategory  	• -  • 12-15
       12.2.5 Subpart E: Non-Integrated Steelmaking and Hot Forming
             Subcategory	1-2-16
       12.2.6 Subpart F: Steel Finishing Subcategory	 12-18
       12.2.7 Subpart G: Other Operations	..'	12-20
12.3   Data Substitutions	12-21
12.4   Data Aggregation	 • •  • 12-21
       12.4.1 Aggregation of Field Duplicates	  - 12-22
       12.4.2 Aggregation of Grab Samples  	•	12-23
       12.4.3 Aggregation of Data Across Outfalls ("Flow-Weighting")  12-24
12.5   Overview of Limitations	12-25
       12.5.1 Objective 	12-25
       12.5.2 Selection of Percentiles	12-26
       12.5.3 Compliance with Limitations	12-27
12.6   Summary of Proposed Limitations  . . '	 12-28
12.7   Estimation of Concentration-Based Limitations	12-30
       12.7.1 Calculation of Option Long-Term Averages  	12-30
       12.7.2 Comparison of Option Long-Term Averages to Baseline
             Values	12-31
                                        VI

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                                                                      Table of Contents
 13
14
                        TABLE OF CONTENTS (Continued)
                                                                             Page
       12.7.3 -Transfer of Option Long-Term Average	12-32
       12.7.4 Calculation of Option Variability Factors	  12-32
       12.7.5 Transfers of Option Variability Factors	12-33
       12.7.6 Summary of Steps Used to Derive Concentration-Based
             Limitations .	12-35
 12.8   Conversion to Production-Normalized Limitations  . .	12-36
       12.8.1 Conversion from Concentration-Based Limitations 	12-36
       12.8.2 Significant Digits for Production-Normalized Limitations  .  12-38
 12.9   Transfers of Limitations	-. .  .	12-38

 NON-WATER QUALITY ENVIRONMENTAL IMPACTS	 13-1
 13.1   Energy Requirement Impacts  	......	 . 13-1
       13.1.1 Cokemaking Subcategory	'...'.	13-1
       13.1.2 Ironmaking Subcategory-. . .	13-2
       13.1.3 Integrated Steelmaking Subcategory  	..13-2
      .13.1.4 Integrated and  Stand-Alone Hot Forming Subcategory .... 13-2
       13.1.5 Non-Integrated Steelmaking and Hot Forming Subcategory . 13-3
       13.1.6 Steel Finishing Subcategory	 13-3
       13.1.7 Other Operations Subcategory	  . . 13-3
       13.1.8 Energy Requirements Summary	•.'	13-4
 13.2   Air Emission Impacts	13-4
 13.3   Solid Waste Impacts	 .	.13-5
       13.3.1 Cokemaking Subcategory	;	13-6
       13.3.2 Ironmaking Subcategory	13-7
       13.3.3 Integrated Steelmaking Subcategory	13-7
       13.3.4 Integrated Steelmaking and Stand-Alone Hot Forming
             Subcategory	13-8
       13.3.5 Non-Integrated and Stand-Alone Hot Forming Subcategory . 13-8
       13.3.6 Steel Finishing Subcategory	13-8
       13.3.7 Other Operations Subcategory	13-9
 13.4  References	,	13-10

SELECTED OPTIONS AND PROPOSED EFFLUENT LIMITATIONS  AND
STANDARDS	14-1
 14.1  BPT		14-1
      14.1.1 Manufacturing Operations New to the Iron and Steel
            Category.	 14-1
      14.1.2 Manufacturing Operations Currently Regulated  	14-2
14^2  BCT .	14-4
14.3  BAT, NSPS, PSES, and PSNS	14-5
                                       vu

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                                                                     Table of Contents
                       TABLE OF CONTENTS (Continued)
15
                                                                            Page
16
      14.3.1 Cokemaking	14-7
      14.3.2 Ironmaking	14-12
      14.3.3 Integrated'Steelmaking	• •  14-16
      14.3.4 Integrated and Stand-Alone .Hot Forming	  14-18
      14.3.5 Non-Integrated Steelmaking and Hot Forming Subcategory  14-26
      14.3.6 Steel Finishing	- •	14-30
      14.3.7 Other Operations	14-43
14.4  References ...:....	-  • • •	14*45

IMPLEMENTATION OF PART 420 THROUGH  THE NPDES
AND PRETREATMENT PROGRAMS	.15-1-
15.1  NPDES Permit Program  . .  . :	-	15-1
15.2  National Pretreatment Standards	15-3
15.3  NPDES Permit and Pretreatment Production Rates	15-4
      15.3.1 Alternatives for Establishing Permit Effluent Limitations .  . 15-6
15.4  Applications of Best Professional Judgement  	15-10
15.5  Calculating NPDES and Pretreatment Effluent Limitations	15-11
      15.5.1 Direct Dischargers  .	.- • •  •	15~12
      15.5.2 Indirect Dischargers  	-	15-14
15.6  Water Bubble  	15-16
15.7  Monitoring Requirements	• • •  15-18
      15.7.1 Sample Types	15-18
      15.7.2 Monitoring Frequency	• •  15-19
      15.7.3 Compliance Monitoring Locations   	15-19
15.8  Best Management Practices	15-20
15.9  Bypasses and  Upsets	15-22
15..10 NPDES Permit and Pretreatment Variances	15-23
      15.10.1      Economic Variances	15-23
      15.10.2      Variances Based on Localized Environmental
                   Factors	15-24
      15.10.3      Fundamentally Different Factors Variances ..."..  15-25
      15.10.4      Thermal Discharge Variances .	15-25
      15.10.5      Net Credits  . . .	  15-26
15.11 References	•  15-26

GLOSSARY
                                       Vlll

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                                                          Table of Contents
                    TABLE OF CONTENTS (Continued)

Appendix A:  SURVEY DESIGN AND CALCULATION OF NATIONAL ESTIMATES
Appendix B:  REVISED EDITING CRITERIA FOR POTW PASS-THROUGH ANALYSIS
Appendix C:  REVISED DATA CONVENTIONS                        .
Appendix D:  AGGREGATED DATA LISTING
Appendix E:  MODIFIED DELTA-LOGNORMAL DISTRIBUTION '
Appendix F:  ATTACHMENTS FOR SECTION 12
                                 IX

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                                                                          List of Tables
                                  LIST OF TABLES
                                                                               Page
 3-1

 3-2

 3-3

 3-4

 3-5

 3-6

 3-7

 4-1

 5-1


 5-2

 5-3


 5-4


 6-1

 6-2

 6-3

7-1


7-2

7-3
 Iron and Steel Industry Strata	3-14

 Number of Site Visits Conducted in'Each State and in .Canada	 3-15

 Number of Site Visits Conducted at Each Type of Site	3-16

 Number of Sites Visited With Each Type of Manufacturing Process	3-17

 Manufacturing Processes Sampled	3-18

 Treatment Systems Sampled	 3-19

 Wastewater Analytical Methods Used During Sampling Program  	3r22

 Analytical Methods and Baseline Values	4-16

 1997 National Estimate of Types of Iron  and Steel Sites in the United
 States	-....'.	5-22

 Survey Response of Sites Producing Steel Types	5-23

 1997 National Estimate of Number of Direct, Indirect, and Zero
 Discharging Sites	  .	 . 5-24

 1997 National Estimate of Actual Production and Rated Capacity by
 Manufacturing Operation	5-25

 1982 Subcategorization	 6-11

 Proposed Subcategorization	 ,	6-14

 Subcategory Comparison of the 1982 and Proposed Regulations . . . . .  . . 6-17

 1997 National Estimate of Annual Discharge from  Manufacturing
 Operations by Discharge Type	7-35

Pollutants of Concern Cokemaking Subcategory - By-Product Segment   . .  7-36

Pollutants of Concern Ironmaking Subcategory - Sintering Segment	7-39
                                         x

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                                                                           List of Tables
                            LIST OF TABLES (Continued)
                                                                                Page
7-4

7-5

7-6


7-7


7-8


7-9


7-10


7-11


7-12


8-1

8-2

8-3


8-4



8-5
 Pollutants of Concern Ironmaking Subcategory - Blast Furnace Segment . .  7-42

 Pollutants of Concern Integrated Steelmaking Subcategory  	7-43

• Pollutants of Concern Integrated and Stand-Alone Hot Forming
 Subcategory - Carbon and Alloy Steel Segment	  7-44

 Pollutants of Concern Integrated and Stand-Alone Hot Forming
 Subcategory - Stainless Steel Segment  	7-45

 Pollutants of Concern Non-Integrated Steelmaking and Hot Forming
 Subcategory - Carbon and Alloy Steel Segment	  7-46

 Pollutants of Concern Non-Integrated Steelmaking and Hot Forming
 Subcategory - Stainless Steel Segment	•	7-47

 Pollutants of Concern Steel Finishing Subcategory - Carbon and Alloy
 Steel Segment	,	7-48

 Pollutants of Concern Stainless Finishing Subcategory - Stainless Steel
 Segment	  7-50

 Pollutants of Concern Other Operations Subcategory - Direct Reduced
 Ironmaking Segment	  7-52

 Iron and Steel In-Process Technologies	8-36

 Iron and Steel End-of-Pipe Treatment and Disposal Technologies	8-38

 Wastewater Treatment Technologies Reported by Industry Survey
 Respondents for By-Product Recovery Cokemaking Sites  	8-43

 High-Rate Recycle and Slowdown Treatment Technologies Reported by
 Industry Survey Respondents for Blast Furnace Ironmaking and Sintering
 Sites		8-44.

 High-Rate Recycle and Slowdown Treatment Technologies Reported by
 Industry Survey Respondents for Integrated Steelmaking Sites	 . .  8-45
                                         XI

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                                                                           List of Tables
                            LIST OF TABLES (Continued)
                                                                                Page
 8-6           High-Rate Recycle and Slowdown Treatment Technologies Reported by
              Industry Survey Respondents for Integrated and Stand-Alone Hot Forming
              Sites  .............:........	8-46

 8-7           High-Rate Recycle and Blowdown Treatment Technologies Reported by
              Industry Survey Respondents for Non-Integrated Steelmaking and Hot
              Forming Sites	8-47

 8-8           In-Process and End-of-Pipe Wastewater Treatment Technologies Reported
              by Industry Survey Respondents for Steel Finishing Sites  	8-48

 8-9           High-Rate Recycle Equipment and Blowdown Wastewater Treatment
              Technologies Reported by Industry Survey Respondents for Direct Reduced
              Ironmaking and Forging Sites	8-49

 9-1           Cost Factors to Determine Investment Costs	-	 9-25

 9-2.           Iron and Steel Investment Cost Equations	9-26

 9-3          Iron and Steel Operating and Maintenance (O&M) Cost Equations-	9-30

 9-4          Assumptions Used to Estimate Investment Costs . . .  .-	9-42

 9-5          Design Specifications for Cokemaking Granular Activated Carbon
             Treatment Systems . •.		 . 9-43

 9-6          Estimated Investment Costs for Cokemaking Granular Activated Carbon
             Systems (100,000 - 2,700,000 gpd)	9-44

 9-7          Design Specifications for Cokemaking Alkaline Chlorination Treatment
             Systems	9-49

9-8          Estimated Investment Costs for Cokemaking Alkaline  Chlorination          .  .
             Treatment Systems (100,000 -• 2,700,000 gpd)	9-50

9-9          Design Specifications for Metals Precipitation Systems for Bast Furnace
             and Sintering Wastewater	9-58

9-10          Estimated Investment Costs for Metals Precipitations Systems
             for Blast Furnace and Sintering Wastewater (150,000 - 2,000,000 gpd)   . . 9-59
                                        xu

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                                                                            List of Tables
                            LIST OF TABLES (Continued)
                                                                                 Page
9-11


9-12


9-13


9-14



9-15

9-16


9-17


9-18


9-19


9-20



9-21



9-22
Design Specifications for Alkaline Chlorination Systems for
Blast Furnace and Sintering Wastewater	9-65

Estimated Investment Costs for Alkaline Chlorination Systems for
Blast Furnace and Sintering Wastewater (150,000 - 2,000;000 gpd)	9-66

Design Specifications for Metals Precipitation Systems for Basic Oxygen
Furnace, Vacuum Degassing, and Continuous Casting Wastewater  	9-73

Estimated Investment Costs for Metals Precipitation Systems for Basic
Oxygen Furnace, Vacuum Degassing, and Continuous Casting Wastewater
(150,000 - 2,000,000 gpd)	".	9-74

Design Specifications for Multimedia Filtration Systems	9-80

Estimated Investment Costs for Multimedia Filtration Systems (150,000 -
20,000,000 gallons per day)	:	9-81

Summary of Costs for the Cokemaking Subcategory (in millions of
1997 dollars)	,	9-89

Summary of Costs for the Ironmaking Subcategory (in millions of
1997 dollars)  	9-89

Summary of Costs for the Integrated Steelmaking Subcategory
(in millions of 1997 dollars)				9-89

Summary of Costs for the Integrated and Stand-Alone Hot Forming
Subcategory
(in millions of 1997 dollars)	9-90

Summary of Costs for the Non-integrated Steelmaking
and Hot Forming Subcategory
(in millions of 1997 dollars)	 9-90

Summary of Costs for the Steel Finishing Subcategory (in millions of 1997
dollars)	!	9-91
                                         xiu

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                                                                         List of Tables
                           LIST OF TABLES (Continued)
                                                                              Page
9-23


10-1

1-0-2

10-3


10-4


10-5


10-6


10-7


10-8


10-9


10-10


10-11


10-12


1-0-13
Summary of Costs for the Other Operations Subcategory (in millions of
1997 dollars) 	....."	 9-91

Pollutants of Concern Not Detected in Effluent at Any Site  .	10-29

POTW Percent Removal Efficiency	........  10-33

Average Baseline Pollutant Concentrations Used for Data Transfers in the
Cokemaking Subcategory By-Product Cokemaking Segment	'  10-36

Proposed Arithmetic Long-Term Averages for the Cokemaking
Subcategory By-Product Cokemaking Segment	  10-38

Summary of Baseline and Post-Compliance Pollutant Loadings for the
By-Product Cokemaking Segment Direct Dischargers	10-43

Summary of Baseline and Post-Compliance Pollutant Loadings for the
By-Product Cokemaking Segment Indirect Dischargers	10-43

Summary of Pollutant Removals for the By-Product Cokemaking Segment
Direct Dischargers		  10-44

Summary of Pollutant Removals for the By-Product Cokemaking
Subcategory Indirect Dischargers	  10-44

Average Baseline Pollutant Concentrations for the Ironmaking
Subcategory Sintering Segment	,.  . .  10-45

Average Baseline Pollutant Concentrations for the Ironmaking
Subcategory Blast Furnace Segment	'.........  10-47

Proposed Arithmetic Long-Term Averages for the Ironmaking
Subcategory Sintering Segment	10-49

Proposed Arithmetic Long-Term Averages for the Ironmaking
Subcategory Blast Furnace Segment	  . .	  10-53

Summary of Baseline and Post-Compliance Pollutant Loadings for the
Ironmaking Subcategory Direct and Indirect Dischargers	10-55
                                       xiv

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                                                                           List of Tables
                            LIST OF TABLES (Continued)
                                                                                Page
10-14        Summary of Pollutant Removals for the Ironmaking Subcategory
             Direct and Indirect Dischargers	10-56

10-15        Average Baseline Pollutant Concentrations for the Integrated Steelmaking
             Subcategory	10-57

10-16        Proposed Arithmetic Long-Term Averages for the Integrated Steelmaking
             Subcategory	10-59

10-17        Summary of Baseline and Post-Compliance Pollutant Loadings for the
             Integrated Steelmaking Subcategory Direct and Indirect Dischargers  ... 10-61

10-18        Summary of Pollutant Removals for the Integrated Steelmaking
             Subcategory Direct and Indirect Dischargers  . .  . :	 10-61

10-19        Average Baseline Pollutant Concentrations for the Integrated and
             Stand-Alone Hot Forming Subcategory Carbon and Alloy Steel Segment  10-62

10-20        Average Baseline Pollutant Concentrations for the Integrated and
             Stand-Alone Hot Forming Subcategory Stainless Steel Segment 	10-63

10-21        Proposed Arithmetic Long-Term Averages for the Integrated and
             Stand-Alone Hot Forming Subcategory Carbon and Alloy Steel Segment  10-65

10-22        Proposed Arithmetic Long-Term Averages for the Integrated and
             Stand-Alone Hot Forming Subcategory Stainless Steel Segment ...... 10-66

10-23        Summary of Baseline and Post-Compliance Pollutant Loadings for the
             Integrated and Stand-Alone Hot Forming Subcategory Carbon and Alloy
             Steel Segment Direct Dischargers	10-67

10-24        Summary of Baseline and Post-Compliance Pollutant Loadings for the
             Integrated and Stand-Alone Hot Forming Subcategory Stainless Steel
             Segment Direct Dischargers	 10-67

10-25        Summary of Baseline and Post-Compliance Pollutant Loadings for the
             Integrated and Stand-Alone Hot Forming Subcategory Carbon and Alloy
             Steel Segment Indirect Dischargers	10-68
                                         xv

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                                                                          List of Tables
                           LIST OF TABLES (Continued)
                                                                               Page
10-26        Summary of Baseline and Post-Compliance Pollutant Loadings for the
             Integrated and Stand-Alone Hot Forming Subcategory Stainless Steel
             Segment Indirect Dischargers . .  ...	 .  10-68

10-27        Summary of Pollutant Removals for the Integrated and Stand-Alone Hot
             Forming Subcategory Carbon and Alloy Steel Segment Direct
             Dischargers	10-69

10-28        Summary of Pollutant Removals for the Integrated and Stand-Alone Hot
             Forming Subcategory Stainless Steel Segment Direct Dischargers	10-69

10-29        Summary of Pollutant Removals for the Integrated and Stand-Alone Hot
            - Forming Subcategory Carbon and Alloy Steel Segment Indirect
             Dischargers  '.'	  10-70

10-30        Summary of Pollutant Removals for the Integrated and Stand-Alone Hot
             Forming Subcategory Stainless Steel Segment Indirect Dischargers  ....  10-70

10-31        Average Baseline Pollutant Concentrations for the Non-Integrated
             Steelmaking and Hot Forming Subcategory Carbon and Alloy Steel
             Segment	  10-71

10-32        Average Baseline Pollutant Concentrations for the Non-Integrated
             Steelmaking and Hot Forming Subcategory Stainless Steel Segment ....  10-72

10-33        Proposed Arithmetic Long-Term Averages for the Non-Integrated'
             Steelmaking and Hot Forming Subcategory Carbon and Alloy Steel
             Segment	 .  10-73

10-34        Proposed Arithmetic Long-Term Averages for the Non-Integrated
             Steelmaking and Hot Forming Subcategory Stainless Steel Segment ....  10-74

10-35        Summary of Baseline and Post-Compliance Pollutant Loadings for the
             Non-Integrated Steelmaking and Hot Forming Subcategory Carbon and
             Alloy Steel Segment Direct Dischargers	  10-76

10-36        Summary of Baseline and Post-Compliance Pollutant Loadings for the
             Non-Integrated Steelmaking and Hot Forming Subcategory Stainless
             Steel Segment Direct Dischargers  	10-76
                                        xvi

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                                                                           List of Tables
                            LIST OF TABLES (Continued)
                                                                                Page
10-37        Summary of Baseline and Post-Compliance Pollutant Loadings for the
             Non-Integrated Steelmaking and Hot Forming Subcategory Carbon and
             Alloy Steel Segment Indirect Dischargers  	10-77

10-38        Summary of Baseline and Post-Compliance Pollutant Loadings for the
             Non-Integrated Steelmaking and Hot Forming Subcategory
             Stainless Steel Segment Indirect Dischargers	 10-77

10-39     '   Summary of Pollutant Removals for the Non-Integrated Steelmaking
             and Hot Forming Subcategory Carbon and Alloy Steel Segment Direct
             Dischargers	10-77

10-40        Summary of Pollutant Removals for the Non-Integrated Steelmaking and
             Hot Forming Subcategory Stainless Steel Segment Direct Dischargers  .  . 10-78

10-41        Summary of Pollutant Removals for the Non-Integrated Steelmaking
             and Hot Forming Subcategory Carbon and Alloy Steel Segment Indirect
             Dischargers  .	10-78

10-42        Summary of Pollutant Removals for the Non-Integrated Steelmaking and
             Hot Forming Subcategory Stainless Steel Segment Indirect Dischargers  . 10-78

10-43        Average Baseline Pollutant  Concentrations for the Steel Finishing
             Subcategory Carbon and Alloy Steel Segment	 10-79

10-44        Average Baseline Pollutant  Concentrations for the Steel Finishing
             Subcategory Stainless Steel  Segment	10-90

10-45        Proposed Arithmetic Long-Term Averages for the Steel Finishing
             Subcategory Carbon and Alloy Steel Segment	10-99

10-46        Proposed Arithmetic Long-Term Averages for the Steel Finishing
             Subcategory Stainless Steel  Segment  .	10-1.01

10-47        Summary of Baseline and Post-Compliance Pollutant Loadings for
             the Steel Finishing Subcategory Carbon and Alloy Steel Segment Direct
             Dischargers  .•	10-103

10-48        Summary of Baseline and Post-Compliance Pollutant Loadings for the
             Steel Finishing Subcategory Stainless Steel Segment Direct Dischargers  10-104
                                        xvii.

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                                                                          ' List of Tables
                            LIST OF TABLES (Continued)
                                                                                Page
10-49        Summary of Baseline and Post-Compliance Pollutant Loadings for
             the Steel Finishing Subcategory Carbon and Alloy Steel Segment
             Indirect Dischargers	10-104

10-50        Summary of Baseline and Post-Compliance Pollutant Loadings for the
             Steel Finishing Subcategory Stainless Steel Segment Indirect
             Dischargers	10-105

10-51  '      Summary of Pollutant Removals for the Steel Finishing Subcategory
             Carbon and Alloy Steel Segment Direct Dischargers	  10-105

10-52        Summary of Pollutant Removals for the Steel Finishing Subcategory
             Stainless Steel Segment Direct Dischargers	10-106

10-53        'Summary of Pollutant Removals' for the Steel Finishing Subcategory
             Carbon and Alloy Steel Segment Indirect Dischargers  	10-106

10-54        Summary of Pollutant Removals for the Steel Finishing Subcategory
             Stainless Steel Segment Indirect Dischargers  . .  .	10-107

10-55        Average Baseline Pollutant Concentrations for the Other Operations
             Subcategory Forging Segment	10-107

10-56        Proposed Arithmetic Long-Term Averages for the Other Operations
             Subcategory DRI Segment	  10-107

10-57        Proposed Arithmetic Long-Term Averages for the Other Operations
             Subcategory Forging Segment	  10-108

10-58        Summary of Baseline and Post-Compliance Pollutant Loadings for the
             Other Operations Subcategory Forging Segment Direct Dischargers .  . .  10-108

10-59        Summary of Pollutant Removals for the Other Operations Subcategory
             Forging Segment Direct Dischargers	10-108

11-1          Proposed Regulated Pollutants for the Cokemaking Subcategory	11-25

11-2          Pollutants Considered for Regulation for Direct Dischargers
             Cokemaking Subcategory - By-Product Recovery Segment  .  .	11-26
                                        XVlll

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                                                                             List of Tables
                             LIST OF TABLES (Continued)
                                                                                  Page
11-3          Proposed Regulated Pollutants for the Ironmaking Subcategory  ......  11-30

11-4          Pollutants Considered for Regulation for Direct Dischargers Ironmaking
              Subcategory - Sintering Segment	11-31

11-5          Pollutants Considered for Regulation for Direct Dischargers Ironmaking
              Subcategory - Blast Furnace Segment	1.1-35

11-6          Proposed Regulated Pollutants for the Integrated Steelmaking
              Subcategory	 411-37

11-7          Pollutants Considered for Regulation for Direct Dischargers Integrated
              Steelmaking Subcategory ".	11-38

11-8          Proposed Regulated Pollutants for the Integrated and Stand-Alone Hot
              Forming Subcategory		11-40

11-9          Pollutants Considered for Regulation for Direct Dischargers Integrated
              and Stand-Alone Hot Forming Subcategory - Carbon and Alloy Steel
              Segment	11-41

11-10         Pollutants Considered for Regulation for Direct Dischargers Integrated
              and Stand-Alone Hot Forming Subcategory - Stainless Steel Segment ...  11-42

11-11         Proposed Regulated Pollutants for the Non-Integrated Steelmaking and
              Hot Forming Subcategory	:	11-43

11-12  ,       Pollutants Considered for Regulation for Direct Dischargers Non-Integrated
              Steelmaking and Hot Forming Subcategory - Carbon and Alloy Steel
              Segment	11-44

11-13         Pollutants Considered for Regulation for Direct Dischargers
              Non-Integrated Steelmaking and Hot Forming Subcategory - Stainless
              Steel Segment	  .  11-45

11-14         Proposed Regulated Pollutants for the Steel Finishing Subcategory  . . .  :  11-47

11-15         Pollutants Considered for Regulation for Direct Dischargers Steel     .   .
              Finishing Subcategory - Carbon and Alloy Steel Segment	11-48
                                          xix

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                                                                            List of Tables
                            LIST OF TABLES (Continued)
                                                                                 Page
11-16        Pollutants Considered for Regulation for Direct Dischargers Stainless
             Finishing Subcategory - Stainless Steel Segment	11-50

11-17        Proposed Regulated Pollutants for the Other Operations Subcategory  . .  .11-53

11-18        Pollutants Considered for Regulation for Direct Dischargers Other
             Operations Subcategory - Direct Reduced Ironmaking Segment   	11-54

11-19        POTW Percent Removals  	.	11-55

11-20        POTW Pass-Through Analysis Results for the Cokemaking Subcategory  . 11-56

11-21        POTW Pass-Through Analysis Results for the Ironmaking Subcategory  . 11-57

11-22        POTW Pass-Through Analysis Results for the Integrated Steelmaking
             Subcategory .	11-58

11-23        POTW Pass-Through Analysis Results for the Integrated and Stand
             Alone Hot Forming Subcategory	:		 11-58

11-24        POTW Pass-Through Analysis Results for the Non-Integrated
             Steelmaking and Hot Forming Subcategory	 . 11-59

11-25   .     POTW Pass-Through Analysis Results for the Steel Finishing
             Subcategory .	 . .	11-60

12-1         Aggregation of Field Duplicates	 -12-23

12-2         Aggregation of Grab Samples	 12-24

12-3         Aggregation of Data Across Streams	12-25

12-4         Option Long-Term Averages Replaced by the Baseline Values '.	12-32

12-5         Gases where Option Variability Factors Could Not be Calculated	 12-33

12-6         O&G Long-Term Averages and Variability Factors  	....'. 12-34

12-7         Lead Long-Term Averages and Variability Factors	 12-35
                                         xx

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                                                                          List of Tables
                           LIST OF TABLES (Continued)
                                                                               Page
12-8

13-1


13-2

13-3


13-4

14-1


15-1


15-2


15-3


15-4


15-5


15-6
Transfers of Proposed Limitations  	 12-39

Summary of Pollutant Removals, Energy Requirements, and Sludge
Generation for the Selected Option by Subcategory  . .	13-11

Incremental Energy Requirements by Subcategory and Option  .  . .-. ... 13-12

Estimated Maximum VOC Emission Rate From Biological Treatment of
Cokemaking Wastewater	13-13

Incremental Sludge Generation by Subcategory and Option	13-14

Limitations for Best Practicable Control Technology Currently Available
(BPT) Under 1982 Rule  . .	14-46

Example 1:  Application of the Proposed 40 CFR Part 420
Direct Discharge Blast Furnaces and Sinter Plant  	15-28

Example 2:  Application of Proposed 40 CFR Part 420
Direct Discharge Stainless Steel Finishing Mill	15-29

Example 3:  Application of Proposed 40 CFR Part 420
Direct Discharge Integrated Steelmaking and Hot Forming	15-30

Example 4:  Application of Proposed 40 CFR Part 420
Indirect Discharge Coke Plant	 15-31

Example 5:  Application of Proposed 40 CFR Part 420.4
Example "Water Bubble" Trade for Zinc  	15-32

List of Approved Test Procedures for Pollutants Regulated Under the
Proposed Rule for the Iron and Steel Point Source Category  	15-33
                                        xxi

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                                                                        List of Figures
                                LIST OF FIGURES
 5-1

 5-2

 5-3

 5-4

 8-1

 8-2

 8-3


.8-4

 8-5

 8-6

 8-7

 8-8

 8-9 .

 8-10

 8-11

 8-12

 8-13

 8-14

 8-15
                                                                              Page
Iron and Steelmaking Operations	 5-26

Forming and Finishing Operations	5-27

Integrated Steel Manufacturing Sites	5-28

Cokemaking Sites	5-29

Process Flow Diagram of a Typical Biological Nitrification System	8-50

Process Flow Diagram of Typical Biological Denitrification Systems .... 8-51

Process Flow Diagram of a Typical Chemical Precipitation System for
Metals Removal	8-52

Minimum Solubilities of Various Metal Hydroxides	8-53

BAT-1 for By-Products Recovery Cokemaking ........	8-54

BAT-2 for By-Products Recovery Cokemaking .  . . s	8-55

BAT-3 for By-Products Recovery Cokemaking	8-56

BAT-4 for By-Products Recovery Cokemaking	, . 8-57

PSES-1 for By-Products Recovery Cokemaking	8-58

PSES-2 for By-Products Cokemaking	8-59

PSES-3 for By-Products Recovery Cokemaking	8-60

PSES-4 for By-Products Recovery Cokemaking	8-61

BAT-1 for Ironmaking (Blast Furnace and Sintering Operations)	 8-62

PSES-1 for Ironmaking (Blast Furnace and Sintering Operations)  	8-63

BAT-1 and PSES-1 for Integrated Steelmaking (All Segments)	8-64
                                       xxn

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                                                                         List of Figures
                           LIST OF FIGURES (Continued)
                                                                               Page
8-16


8-17


8-18

8-19

8-20

8-21

9-1


9-2

9-3

9-4

9-5

9-6

12-1
BAT -1 and PSES-1 for Integrated and Stand-Alone Hot Forming
(All Segments)	-	8-65

BAT-1 and PSES-1 for Non-Integrated Steelmaking and Hot Forming
(AU Segments)  	8-66

BAT-1 and PSES-1 for Carbon and Alloy Steel Finishing	8-67

BAT-1 and PSES-1 for Stainless Steel Finishing	.-.  . . 8-68

BPT-1 for Direct Reduced Ironmaking	8-69

BPT-1 for Forging	8-70

Activated Carbon Treatment for By-Products Recovery Cokemaking
Wastewater  	9-92

Alkaline Chlorination for By-Products Recovery Cokemaking Wastewater  9-93

Blowdown Metals Precipitation for Ironmaking Wastewater  '.	9-94

Alkaline Chlorination for Ironmaking Wastewater  .	 9-95

Blowdown Metals Precipitation for Steelmaking Wastewater	9-96

Filtration of Wastewater from All Subcategories .'	9-97

Alkaline Chlorination Model Technology Facility	12-5
                                       xxm

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                                         Section 1 -Applicability and Summary of Proposed Regulation
                                      SECTION 1

          APPLICABILITY AND SUMMARY OF PROPOSED REGULATION

              This section presents a brief overview of the Iron and Steel Category, discusses the
applicability of the effluent limitations guidelines and standards proposed for the category/and
presents the applicability interface between the proposed rule and other regulations for the metals
industry. This-section also briefly summarizes of the proposed rule and describes the Agency's
efforts to protect confidential business information.
1.1
Applicability
              The Iron and Steel Category comprises sites that produce raw materials used in
ironmaking and steelmaking or produce finished or semifinished steel products. Operations
include cokemaking, sintering, ironmaking, steelmaking, ladle metallurgy, vacuum degassing,
continuous and ingot casting, hot forming, salt bath and electrolytic descaling, acid pickling, cold
forming, alkaline cleaning, hot coating, and electroplating. The proposed rule revises the 1982
technology-based effluent limitations guidelines and standards for wastewater discharges
associated with the operation of new and existing facilities within the Iron and Steel Category.

              Manufacturing operations that may be subject to the proposed Iron and Steel rule
are generally reported under one or more of the following North American Industry Classification
System (NAICS) codes (Reference 1-1):

              •      324199, Other Petroleum and Coal Products.Manufacturing;

              •      331 111, Iron and Steel Mills;

              •      331210, Iron and Steel Pipe and Tube Manufacturing from Purchased
                    Steel;                                     •

              •      331221, Rolled Steel Shape Manufacturing;

              •      332812, Metal coating, engraving (except jewelry and silverware), and
                    allied services to manufacturers; and

              •      332813, Electroplating, plating, polishing,  anodizing,  and coloring.

              Specifically, the proposed Iron and Steel effluent limitations guidelines and
standards apply to wastewater discharges resulting from the following manufacturing operations:

              •      By-product recovery and other cokemaking operations manufacturing
                    metallurgical coke (both furnace and foundry coke);
                                           1-1

-------
                                          Section 1 - Applicability and Summary of Proposed Regulation
                     Sintering, briquetting, and other agglomeration operations conducted by
                     heating iron-bearing materials (e.g., iron ore, mill scale, blast furnace flue
                     dust, blast furnace wastewater treatment sludge), limestone, coke fines, and
                     other materials in a traveling grate combustion system to produce an
                     agglomerate for charging to a blast furnace;

                     Ironmaking operations in which iron ore and other iron-bearing materials
                     are reduced to molten iron in a blast furnace;

                     Direct reduced ironmaking in which iron pellets are produced through a
                     reaction of iron ore  with hot reducing gases;

                     Basic oxygen furnace (EOF) steelmaking, ladle metallurgy, vacuum
                     degassing, and continuous casting operations at integrated steel mills,  the
                     proposed rule also applies to BOF steelmaking conducted at any location;

                     Electric arc furnace  (EAF) steelmaking, ladle metallurgy, vacuum
                     degassing, arid continuous casting operations conducted at non-integrated
                     steel mills. The proposed rule also applies to EAF steelmaking conducted
                     at any location;

                     Primary, section, flat, pipe, and tube hot forming operations conducted at
                     integrated steel mills, non-integrated steel mills, and stand-alone hot
                     forming mills;

                     Steel forging operations performed at iron and  steel mills; and

                     Carbon, alloy, and stainless steel finishing operations, including salt bath
                     and electrolytic sodium sulfate descaling, acid pickling, cold forming,
                     alkaline cleaning,  continuous electroplating and hot coating (of flat steel
                     products only), and  continuous annealing at integrated, non-integrated, and
                     stand-alone facilities. ,
1.2
Applicability Interface With Other Regulations
              Several existing regulations currently establish effluent limitations guidelines and
standards for the metals industry. Regulations covering nonferrous materials, including aluminum
forming (40 CFR Part 467), copper forming (40 CFR Part 468), nonferrous metals manufacturing
(40 CFR Part 421), and nonferrous metals forming (40 CFR Part 471) do not interface with the
effluent limitations guidelines and standards proposed for the Iron and Steel Category.
Regulations that cover ferrous materials, however, do interface with the proposed rule for the
Iron and Steel Category.

              For facilities with process operations in more than one category, National Pollutant
Discharge Elimination System (NPDES) permit writers must use a building-block approach to
                                           1-2

-------
                                          Section 1 -Applicability and Summary of Proposed Regulation
develop technology-based effluent limitations. Similarly, pretreatment control authorities must
use the combined wastestream formula (Reference 1-2) to develop pretreatment requirements for
facilities with process operations in more than one category.  Permit writers and control
authorities should refer to the applicability statements of the regulations for further clarification.
1.2.1
Metal Products and Machinery
              Some steel finishing facilities covered .by the 1982 Iron and Steel rule perform
manufacturing operations such as cold forming, hot coating, and drawing. Some of these
operations and associated wastewater discharges closely resemble those covered by .the Metal
Products and Machinery (MP&M) rule to be proposed at 40 CFR Part 438.  Therefore, EPA has
determined that some processes regulated under the 1982 Iron and Steel Category would be more
appropriately regulated under the proposed MP&M Category.

              EPA proposes to regulate the following steel finishing operations under the
MP&M Category:                                                                    ,

              •      Batch electroplating of steel;

              •      Continuous electroplating or hot-dip coating of long steel products (e.g.,
                    wire,-rod, and bar);

              •   '   Cold forming of steel pipe and tube or long steel products;   .

              •      Batch hot-dip coating of steel; and

              •      Drawing and coating of steel wire.

              EPA proposes to regulate the following steel finishing operations under the Iron
and Steel Category:

              •      Hot forming of steel pipe and tube;

              •      Salt bath and electrolytic descaling, acid pickling,  and alkaline cleaning of
                    flat steel products (e.g., plate, sheet, and strip);

              •      Cold forming of flat steel products;

              •      Finishing with continuous electroplating of flat steel products; and

              •      Continuous hot-dip coating of flat steel products.

              The proposed Iron and Steel Category covers hot forming operations on steel pipe
and tube; the proposed'MP&M Category does not cover these operations. The proposed Iron
and Steel Category covers salt bath and electrolytic descaling operations, acid pickling, alkaline
                                           1-3

-------
                                           Section 1 - Applicability and Summary of Proposed Regulation
 cleaning operations, cold forming operations, finishing with continuous electroplating operations,
 and continuous hot coating operations on flat steel products because these operations are
 common to a relatively large number of integrated and non-integrated iron and steel mills.
 Because EPA is proposing to regulate these operations at integrated and non-integrated iron and
 steel mills, the Agency is also proposing to regulate these operations at stand-alone steel finishing
 mills.
 1.2.2
Electroplating
              Facilities that are covered by the Electroplating Category and discharge to a
publicly owned treatment works (POTW) are regulated under 40 CFR Part 413. This category
comprises indirect discharging job shop electroplaters and independent printed circuit board
manufacturers that were in operation prior to July 15, 1983. The electroplating rale specifically
excludes continuous strip  electroplating operations conducted at indirect discharging iron and
steel facilities; therefore, the electroplating rule does not overlap with the proposed Iron and Steel
rule.
1.2.3
Metal Finishing
              Wastewater discharges from facilities within the Metal Finishing Category are
regulated under 40 CFR Part 433.  This category comprises facilities that perform any of the
following six metal finishing operations on any basis material: electroplating, electroless plating,
anodizing, coating (chromating, phosphating, and coloring), chemical etching and milling, and
printed circuit board manufacturing. The Metal Finishing rale establishes effluent limitations
guidelines and standards for 40 surface treatment operations at facilities within this category.

              Electroplating operations at iron and steel mills are currently regulated under the
Metal Finishing Category; however, the Agency proposes to regulate the continuous
electroplating of flat steel products under the Iron and Steel Category because this process is
common to a relatively large number of integrated and non-integrated steel mills. Iron and steel
facilities successfully and cost-effectively co-treat Wastewater discharges from continuous strip
electroplating operations and other steel finishing operations.

              The proposed change in electroplating applicability will assist NPDES permit
writers and pretreatment control authorities. Currently, permit writers and control authorities are
required to combine production-based and concentration-based limitations and standards when
permitting iron and steel mills with electroplating operations because effluent limitations
guidelines and standards are production-based under the Iron and Steel Category and
concentration-based under the Metal Finishing Category. To provide consistency, the
electroplating limitations and standards in the proposed Iron and Steel rale are production-based.
                                            1-4

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                                          Section 1 -Applicability and Summary of Proposed Regulation
 1.2.4
Coil Coating
              Wastewater discharges from facilities within the Coil Coating Category are
regulated under 40 CFR Part 465. Coil coating facilities typically clean, conversion coat, and
apply organic polymeric materials (such as paint) to continuous strips of metal coil (typically steel,
galvanized metal, or aluminum). The Coil Coating Category comprises facilities that perform at
least two of these three operations. The proposed Iron and Steel rule is not intended to regulate
mild acid or mild alkaline cleaning operations conducted at coil coating facilities, nor is it intended
to regulate conversion coating or the application of organic polymeric material to steel; therefore,
the proposed Iron and Steel rule does not overlap with the Coil Coating rule.
1.2.5
Ferroalloy Manufacturing
              Wastewater discharges from facilities within the Ferroalloy Manufacturing
Category are regulated under 40 CFR Part 424. This category comprises facilities that smelt
ferroalloys in electric furnaces or other devices with wet air pollution control, recover and process
furnace slag, produce calcium carbide in covered electric furnaces with and without wet air
pollution control, and manufacture electrolytic manganese products and electrolytic chromium
products.  A ferroalloy is an iron-bearing product, not within the range of those products called
steel, which contains a considerable amount of one or more alloying elements, such as manganese,
silicon, phosphorus, vanadium, and chromium. t The Iron and Steel Category does not cover any
ferroalloy manufacturing operations.
1.2.6
Metal Molding and Casting
              Wastewater discharges from facilities within the Metal Molding and Casting
Category are regulated under 40 CFR Part 464. This category comprises facilities that remelt,
mold, and cast aluminum, copper, zinc, and ferrous metals and alloys into intermediate or finished
products.  The proposed Iron and Steel rule does not overlap with the Metal Molding and Casting
rule because the proposed rule applies only to those facilities that cast molten steel produced in
BOF and EAF steelmaking furnaces after any ladle metallurgy and vacuum degassing operations.
1.3
Summary of Proposed Regulation
              The proposed Iron and Steel rule revises the technology-based effluent limitations
guidelines and standards at 40 CFR Part 420 for wastewater discharges associated with the
operation of new and existing facilities within the Iron and Steel Category.  The proposed rule
includes the following features:                      -          .

              •       EPA is proposing new effluent limitations guidelines .and standards for
                     BAT, NSPS, PSES, and PSNS under a revised subcategory structure for
                     the industry. The Agency does not propose to revise BCT. (See.Section
                     2.1.1 for a discussion of these terms.)  The revised subcategory structure
                     does the following:                                              •
                                           1-5

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                      Section 1 -Applicability and Summary of Proposed Regulation
 —     Removes defUnct manufacturing processes;

 —     Eliminates manufacturing processes in the hot forming and finishing
        subcategories;             •

 —     Creates a new subcategory for non-integrated steelmaking and hot
        forming processes; and

 —     Creates new subcategories and segments for manufacturing
        processes not regulated under the 1982 rule, including continuous
        electroplating of flat steel products, direct reduced ironmaking,
        briquetting, and steel forging.

 The Agency is proposing BPT limitations for direct reduced ironmaking
 and forging, but proposes to leave the 1982 production-based BPT effluent
 limitations in place (see Section 2.1.1  for a discussion of BPT).  The
 Agency is considering converting the  existing production-based BPT
 limitations for total suspended solids and oil and grease to concentration-
 based limitations based on the production-normalized flows used to
 develop the limitations in the 1982 regulation.

 EPA is proposing two different BAT approaches for the Carbon and Alloy
 Steel Segment of the Integrated and Stand-Alone Hot Forming
 Subcategory. The options differ in the amount of time that facilities in the
 segment would have to achieve BAT limitations. Under one option, a
 facility would be subject to BAT limitations as  soon as these limitations are
 placed in the NPDES permit.  Under the other option, a facility could
 obtain additional time to achieve BAT limitations.

 The Agency is proposing  zero discharge as NSPS for the non-integrated
 steelmaking and hot forming subcategory.

 EPA is considering defining a reasonable measure of actual production for
 calculating NPDES and pretreatment permit production rates. The Agency
 is considering the following alternatives:

—     Retaining the essential requirements of the 1982 rale while
       providing additional instruction for avoiding unrealistically high
       •estimates of actual production;

—     Requiring the permit writer to establish multitiered permit limits;

—     Revising the definition of production to be the average daily
       operating rate for the year with the highest annual production over
       the past  five years; or
                      1-6

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                     Section 1 - Applicability and Summary of Proposed Regulation
—    Establishing production-based maximum monthly average effluent
       limitations and standards in combination with daily maximum
       concentration-based effluent limitations and standards.

EPA is proposing to regulate mercury and selenium based on toxicity and
presence in cokemaking wastewater.

EPA is proposing to regulate 2,3,7,8-tetxachlorodibenzofuran (2,3,7,8-
TCDF) in sinter plant wastewater and require compliance monitoring either
after the primary treatment of sinter plant wastewater or after sinter plant
and blast furnace wastewater discharges are co-treated, but before sinter
plant wastewater is combined with any other process or nonprocess
discharges. The Agency is considering limiting dioxins and furans in sinter
plant wastewater on the basis of 2,3,7,8-TCDD toxicity equivalents, which
would measure all of the 17 dioxin and furan congeners with chlorine
substitutions at the 2,3,7 and 8 lateral positions. This approach is
consistent with the international toxicity equivalents factors approach,
EPA's approach to regulating dioxins in other media and conducting risk
assessments, and EPA's source characterization work to assess the national
inventory of dioxin releases to the  environment.

EPA is considering developing a limit, based on acid purification
technology or product substitution, for nitrate/nitrite (in the form of
niteate-riitrite-N) for stainless steel  finishing operations with nitric acid and
combination acid pickling.

EPA is considering waiving the pretreatment standards for ammonia as
nitrogen for blast furnace wastewater indirectly discharged to POTWs that
have the capability to conduct nitrification.

Similar to the 1982 rule, the proposed rule expresses effluent limitations
guidelines and standards for wet air pollution control devices at steel
finishing operations  in mass of pollutant per day. The proposed rule
expresses all other proposed effluent limitations guidelines and standards
within the Iron and Steel Category in mass of pollutant per mass of
production.

The proposed rule revises the units of pollutant limitations from kilograms
of allowable pollutant discharge per thousand kilograms of production
(kg/kkg), also expressed as pounds of allowable pollutant discharge per
thousand pounds of production (lbs/1,000 Ibs), to pounds of allowable
pollutant discharge per ton of production (Ibs/ton).  The Agency made this
change to express effluent limitations in terms of the production value that
is standard throughout the industry.
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                                          Section 1 - Applicability and Summary of Proposed Regulation
                     The proposed rule makes the following revisions to the 1982 "Water
                     Bubble" provision:

                     —    Allows trades for cold rolling operations;

                     —    Allows trades for cokemaking operations only when more stringent
                           limits result;

                     —    Prohibits trades for sintering operations when less stringent limits
                           result; and

                     —    Prohibits, trades for oil and grease.

                     While the 1982 regulation often requires permit writers and control
                     authorities to apply pH limitations at internal discharge monitoring
                     locations, prior to additional treatment or mixing with other wastewater
                     discharges, the proposed rule allows permit writers and control authorities
                     to establish pH effluent limitations at final outfalls such that redundant and
                     unnecessary pH neutralization can be avoided.
1.4
Protection of Confidential Business Information
             EPA recognizes that certain data in the proposed rulemaking record have been
claimed as confidential business information (CBI). The Agency has removed CBI from the
public record in the Water Docket. In addition, the Agency has withheld from disclosure some
data not claimed as CBI because the release of these data could indirectly reveal CBI.
Furthermore, EPA has aggregated certain data in the public record, masked facility identities, or
used other strategies to prevent the disclosure of CBI.  The Agency's approach to CBI protection
ensures that, the data in the public record both explain the basis for the proposed rule and provide
the opportunity for public comment, without compromising data confidentiality.
1.5
1-1
1-2
References                                                   .

North American Industry Classification System, U.S. Office of Management and
Budget. Washington, D.C., 1997.

U.S. Environmental Protection Agency.  Guidance Manual for the Use of
Production-Based Pretreatment Standards and the Combined Wastestream
Formula. Washington, D.C., September 1985.
                                           1-8

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Section 2 - Background
SECTION 2

BACKGROUND

This section provides background information on the development of revised .
effluent limitations guidelines and standards proposed for the Iron and Steel Category. Sections
2.1 and 2.2 discuss the legal authority and legislative background for the proposed rule. Section
2.3 presents a history of Iron and Steel Category rulemaking activities.
2.1
Legal Authority
EPA is proposing revised effluent limitations guidelines and standards for the Iron
and Steel Category under the authority of Sections 301, 304, 306, 307, 308, 402, and 501 of the
Clean Water Act, 33 U.S.C. 1311, 1314, 1316, 1317, 1318, 1342, and 1361. '
2.1.1
Legislative Background
Congress adopted the Clean Water Act (CWA) to "restore and maintain the
chemical, physical, and biological integrity of the Nation's waters" (Section 101(a), 33 U.S.C.
1251 (a)). To achieve this goal, the CWA prohibits the discharge of pollutants into navigable
waters, except in compliance with the statute. The CWA confronts the problem of water
pollution on a number of different fronts; however, it relies primarily on establishing restrictions
on the types and amounts of pollutants discharged from various industrial, commercial, and public
sources of wastewater.

Congress recognized that regulating only those sources that discharge effluent
directly into the nation's waters would not be sufficient to achieve the goals of the CWA.
Consequently, the CWA requires EPA to promulgate nationally applicable pretreatment standards
that restrict pollutant discharges for those sources that discharge wastewater indirectly through
sewers flowing to publicly owned treatment works (POTWs) (Section 307(b) and (c), 33 U.S.C.
1317(b) and (c)). National pretreatment standards apply to wastewater pollutants that may pass
through or interfere with POTW operations. Generally, pretreatment standards are designed to
ensure that wastewater streams from indirect industrial dischargers are subject to similar levels of
treatment as direct industrial dischargers. In addition, POTWs must develop and enforce local
treatment limits applicable to their industrial indirect dischargers when necessary to prevent pass-
through and/or interference (40 CFR 403.5). .

Direct dischargers must comply with effluent limitations in National Pollutant
Discharge Elimination System (NPDES) permits; indirect dischargers must comply with
pretreatment standards. These limitations and standards are established by regulation for
categories of industrial dischargers and are based on the degree of control that can be achieved
using various levels of pollution control technology.
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                                                                         Section 2 - Background
              Best Practicable Control Technology Currently Available (BPT) -
              Section 304(b)(l) of the CWA

              EPA defines BPT effluent limitations for conventional, nonconventional, and
priority1 pollutants. In specifying BPT, EPA looks at a number of factors. EPA first considers the
cost of achieving effluent reductions in relation to the effluent reduction benefits. The Agency
also considers the age of equipment and facilities, the processes employed and any required
process changes, engineering aspects of the control technologies, non-water quality environmental
impacts (including energy requirements), and other factors the Agency deems appropriate (CWA
304(b)(l)(B)). Traditionally, EPA establishes BPT effluent limitations based on the average of
the best performances of facilities within the industry, grouped to reflect various ages, sizes,
processes; or other common characteristics.  Where existing performance is uniformly inadequate,
however, EPA may establish limitations based on higher levels of control than currently in place in
an industrial category if the Agency determines that the technology is available in another
category or subcategory and can be practically applied.

              Best Conventional Pollutant Control Technology (BCT) -
              Section 304(b)(4) of the CWA

             • The 1977 amendments to the CWA required EPA to identify effluent reduction
levels for conventional pollutants associated with BCT technology for discharges from existing
industrial point sources.  In addition to other factors specified in Section 304(b)(4)(B), the CWA
required that EPA establish BCT"limitations after consideration of a two-part "cost
reasonableness" test. EPA explained its methodology for the development of BCT limitations in
July 1986 (51 FR 24974).

              Section 304(a)(4) designates the following as conventional pollutants: biochemical
oxygen demand, total suspended solids, fecal coliform, pH, and any additional pollutants defined
by the Administrator as conventional. The Administrator designated oil and grease as,an
additional conventional pollutant on July 30, 1979 (44 FR 44501).

              Best Available Technology Economically Achievable (BAT) -
              Section 304(b)(2) of the CWA

              In general, BAT effluent limitations guidelines represent the best economically
achievable performance of facilities in the industrial subcategory or category.  EPA considers the
following factors in assessing BAT: the cost of achieving BAT effluent reductions, the age of
"In the initial stages of the CWA regulation, EPA efforts emphasized the achievement of BPT limitations for control of
the conventional pollutants (e.g., total suspended solids, pH, and biochemical oxygen demand). However, nothing on
the face of the statute explicitly restricted BPT limitations to such pollutants. Following passage of the CWA of 1977,
with its requirement for point sources to achieve best available technology limitations to control discharges of toxic
pollutants, EPA shifted the focus of the effluent limitations guidelines program to address the listed priority pollutants.
BPT guidelines may continue to include effluent limitations to address all pollutants.
                                            2-2

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Section 2 - Background
equipment and facilities involved, the processes employed, potential process changes, and non-
water quality environmental impacts, including energy requirements. The Agency retains
considerable discretion in assigning the weights of these factors. Unlike BPT limitations, BAT
limitations may be based on effluent reductions attainable through changes in a facility's processes
and operations. As with BPT, where existing performance in a category or subcategory is
uniformly inadequate, BAT may require a higher level of performance than is currently being
achieved based on technology transferred from a different category or subcategory. BAT may be
based upon process changes or internal controls, even when these technologies are not common
industry practice.

New Source Performance Standards (NSPS) -
Section 306 of the CWA

NSPS reflect effluent reductions that are achievable based on the best available
demonstrated control technology. New facilities have the opportunity to install the best and most
efficient production processes and wastewater treatment technologies. As a result, NSPS should
represent the most stringent controls attainable through the application of the best available
control technology for all pollutants (that is, conventional, nonconventional, and priority
pollutants). In establishing NSPS, EPA must take into consideration the cost of achieving the
effluent reduction and any non-water quality environmental impacts and energy requirements.

Pretreatment Standards for Existing Sources (PSES) -
Section 307(b) of the CWA

PSES are designed to prevent the discharge of pollutants that pass through,
interfere with, or are otherwise incompatible with the operation of POTWs. The CWA authorizes
EPA to establish pretreatment standards for pollutants that pass through POTWs or interfere with
treatment processes or sludge disposal methods at POTWs. Pretreatment standards are
technology-based and analogous to BAT effluent limitations guidelines.

The General Pretreatment Regulations, which set forth the framework for the
implementation of categorical pretreatment standards, are found at 40 CFR Part 403. Those
regulations contain a definition of pass-through that addresses local rather than national instances
of pass-through and establishes pretreatment standards that apply to all nondomestic dischargers
(52 FR 1586, January 14, 1987).

Pretreatment Standards for New Sources (PSNS) -
Section 307(c) of the CWA

Like PSES, PSNS are designed to prevent the discharges of pollutants that pass
through, interfere with, or are otherwise incompatible with the operation of POTWs. PSNS are
to be issued at the same time as NSPS. New indirect dischargers have the opportunity to
incorporate into their facilities the best available demonstrated technologies. The Agency
considers the same factors in promulgating PSNS as it considers in promulgating NSPS.
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Section 2 - Background
2.1.2
Section 304(m) Requirements and Litigation
Section 304(m) of the CWA, added by the Water Quality Act of 1987, requires
EPA to establish schedules for: (1) reviewing and revising existing effluent limitations guidelines
and standards; and (2) promulgating new effluent limitations guidelines and standards. On
January 2, 1990, EPA published an Effluent Guidelines Plan (55 FR 80) that established schedules
for developing new and revised effluent limitations guidelines and standards for several industry
categories, one of which was the Iron and Steel Category.

The Natural Resources Defense Council (NRDC) and Public Citizen, Inc. filed suit
against the Agency, alleging violation of Section 304(m) and other statutory authorities requiring
promulgation of effluent limitations guidelines and standards. See NRDC et al. v. Browner. Civ.
No. 89-2980 (D.D.C.). Under the terms of a consent decree dated January 31, 1992, which
settled the litigation, EPA agreed, among other things, to conduct a study of the iron and steel
industry. The Agency completed this study, discussed in Section 2.2.3 of this document, in 1995.
After the study, the Agency named the Iron and Steel rule as one of the new or revised rules to be
developed under the terms of the consent decree. On November 18, 1998, the court approved
modifications to the consent decree to revise the deadline for the Iron and Steel rule to October
2000 for proposal and April 2002 for final action. EPA provided notice of these modifications on
March 30, 1999 (64 FR 15158).
2.2
History of Iron and Steel Category Rulemaking Activities
This subsection presents a brief history of Iron and Steel Category rulemaking
activities. Section 2.2.1 discusses prior Iron and Steel Category wastewater discharge
regulations. Section 2.2.2 discusses the 1982 Iron and Steel rule. Section 2.2.3 discusses the
Preliminary Study of the Iron and Steel Category.
2.2.1
Prior Regulations
On June 28,' 1974, EPA promulgated effluent limitations for BPT and BAT, NSPS,
and PSNS for basic steelmaking operations (Phase I) of the integrated steel industry (39 FR
24114-24133, 40 CFR Part 420, Subparts A-L). The regulation covered the following 12
subcategories of the industry:

• By-product cokemaking;
• Beehive cokemaking;
• Sintering;
• Blast furnace (iron);
• Blast furnace (ferromanganese);
• Basic oxygen furnace (semi-wet air pollution control methods);
• Basic oxygen furnace (wet air pollution control methods);
• Open hearth furnace;
• Electric arc furnace (semi-wet air pollution control methods);
• Electric arc furnace (wet air pollution control methods);
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Section 2 - Background
• Vacuum degassing; and
• Continuous casting and pressure slab molding.

In response to several petitions for review, the United States Court of Appeals for
the Third Circuit remanded portions of that regulation on November 7, 1975. See American Iron
& Steel Inst. et al. v. EPA. 526 F.2d 1027 (3d Cir. 1975). While the court rejected all technical
challenges to the BPT limitations, it held that the BAT effluent limitations and NSPS for certain
subcategories were "not demonstrated." In addition, the court ruled that EPA had not adequately
considered the impact of plant age on the cost or feasibility of retrofitting pollution controls, had
failed to assess the impact of the regulation on water scarcity in arid and semi-arid regions of the
country, and had failed to make adequate "net/gross" provisions for pollutants found in intake
water supplies. '

On March 29, 1976,. EPA promulgated BPT and BAT effluent limitations, NSPS,
and PSNS for steel forming and finishing operations (Phase II) within the steel industry (41 FR
12990-13030, 40 CFR Part 420, Subparts M-Z). The regulation covered the following 14
subcategories of the industry:

• Hot forming - primary;
• Hot forming - section;
• Hot forming - flat;
• " Pipe and tube;
• Pickling - sulfuric acid - batch and continuous;
• Pickling - hydrochloric acid - batch and continuous;
• Cold rolling;
• Hot coating - galvanizing;
• Hot coating - terne;
• Miscellaneous runoff-storage piles, casting, and slagging;
• Combination acid picking - batch and continuous;
• Scale removal - Kolene and Hydride;
• Wire pickling and coating; and
• Continuous alkaline cleaning.
The U.S. Court of Appeals for the Third Circuit remanded portions of that
regulation on September 14, 1977. See American Iron & Steel Inst.. et al. v. EPA. 568 F.2d 284
(3d Cir. 1977): The court again rejected all technical challenges to the BPT limitations, though it
ruled that EPA had not adequately considered age/retrofit and water scarcity issues for BAT. In
addition, the court invalidated the regulation as it applied to the specialty steel industry for lack of
proper notice. The court also directed EPA to reevaluate its cost estimates in light of "site-
specific costs" and to reexamine its economic impact analysis for BAT. The court also held that
the Agency had no statutory authority to exempt plants in the Mahoning Valley region of Eastern
Ohio from compliance with the BPT limitations for the Iron and Steel Category.
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Section 2 - Background
On January 28, 1981, the Agency promulgated General Pretreatment Regulations
applicable to existing and new indirect dischargers within the iron and steel industry and other
major industries (40 CFR Part 403, 47 FR 4518).
2.2.2
1982 Regulation
On May 27, 1982, EPA promulgated effluent limitations for BPT, BAT, BCT, and
NSPS, PSES, and PSNS for the Iron and Steel Category (47 FR 23258, 40 CFR Part 420). The
regulation covered the following 12 subcategories of the industry:

• Cokemaking;
• Sintering;
• Ironmalang;
• Steelmaking;
• Vacuum degassing;
• Continuous casting;
• Hot forming;
• Salt'bath descaling;
• • Acid pickling;
• Cold forming; :
• Alkaline cleaning; and . .
• Hot coating.

The 1982 regulation was the first promulgated by EPA under the 1977
amendments to the CWA, and, thus, was the first to distinguish between conventional,
nonconventional, and priority pollutants in the regulatory scheme established by the 1977
amendments.

The American Iron and Steel Institute, certain members of the iron and steel
industry, and the NRDC filed petitions to review the 1982 regulation. Their challenges were
consolidated into one lawsuit by the Third Circuit Court of Appeals. See National Steel Corp. v.
EPA, No. 82-3225 and Consolidated Cases. On February 4, 1983, the parties in the consolidated
lawsuit entered into a comprehensive settlement agreement that resolved all issues raised by the
petitioners. In accordance with the settlement agreement, EPA modified and clarified certain
parts of the Iron and Steel rule and published additional preamble language regarding the rule.2
EPA published the amended Iron and Steel rale on May 17, 1984 (49 FR 21024). Some of the
modifications made to the rule include the following:

• EPA included a method for calculating production-based pretreatment
standards. This method largely mirrored the method given at 40 CFR
2EPA also agreed to take final action on an amendment to the General Pretreatment Regulations (40 CFR Part 403) to
permit the reclassification of noncontact cooling water flows contaminated with significant quantities of pollutants from
"dilute" to "unregulated" for purposes of the combined wastestream formula at 40 CFR 403.6 (e).
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                                                   Section 2 - Background
 122.45(b)(2) for calculating production-based effluent limitations for direct
 dischargers.

 While the "Water Bubble" provision (40 CFR 420.03) in the 1982 rule
 originally provided that the alternative effluent limitations established under
 the provision must result in no increase in the discharge of pollutants
 beyond that allowed by the generally applicable limitations, the amended
 provision provided that alternative effluent limitations must result in a
 specified decrease in the discharge of traded pollutants from the amount
 allowed by the generally applicable limitations.

 EPA included a provision at 40 CFR Part 420.06 to grant removal credits
 for total phenols when used as an indicator or surrogate pollutant.

 EPA raised BAT effluent limitations and NSPS, PSES, and PSNS for lead
 and zinc in the ironmaking and sintering subcategories.

 EPA modified BAT effluent limitations and PSES for total cyanide and
 established a new segment for existing indirect blast furnace dischargers.
 The new segment contained standards identical to the generally applicable
 PSES, except that the promulgated ammonia-N and total phenols standards
 were less stringent.

 EPA raised BPT and BAT effluent limitations and NSPS, PSES, and PSNS
 for zinc in the sulfuric and hydrochloric acid pickling segments of the acid
pickling subcategory.

 While the 1982 regulation originally limited all cold worked pipe and tube
 operations to zero discharge for BPT, BAT, and BCT effluent limitations
 and NSPS, PSES, and PSNS, the amended rule permitted nominal
 discharges (rather than contract hauling) of spent oil or water solution and
 specified that limitations and standards for types of process wastewater not
 covered under the 1982 regulation were to be developed on a case-by-case
 basis.

 EPA modified effluent limitations and standards for zinc under the hot
 coating subcategory, provided that facilities achieving zinc discharge levels
more stringent than the amended limitations and standards continued to do
 so. The amended rule also provided that the modified limitations for the
hot coating subcategory could be used as a basis for determining alternative
limitations under the "Water Bubble" provision, even for those facilities
 achieving discharge levels more stringent than the amended limitations and
 standards.
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                                                                         Section 2 - Background
               EPA based the pretreatment standards in the 1982 rule upon a reasonable measure
 of actual production, such as the production during the high month of the previous year or the
 monthly average for the highest of the previous five years (40 CFR 420.04)..

               Under the "Water Bubble" provision in the 1982 rule, any facility within the Iron
 and Steel Category may qualify for alternative effluent limitations for a number of processes
 representing the degree of effluent reduction attainable by the application of BPT, BAT, and
 BCT. The alternative effluent limitations for each pollutant are determined for a combination of
 outfalls by totaling the mass limitations of each pollutant allowed under the rule and subtracting
 from each total an appropriate net reduction amount. Permit writers may determine appropriate
 net reduction amounts based on additional available control measures that would substantially
 reduce the effluent without requiring significant additional expenditures. The 1982 provision
 prohibits alternative effluent limitations for the cokemaking and cold forming subcategories.

               The "Central Treatment Facilities" provision in the 1982 rule temporarily excluded
 21 facilities due to economic considerations, provided the owner(s) or operators) of the facilities
 requested that the Agency consider establishing alternative effluent limitations and supplied EPA
 with information consistent with 40 CFR 420.01(b)) on or before July 26,  1982.3
 2.2.3
Preliminary Study of the Iron and Steel Category
              Under the terms of the 1992 consent decree with the NRDC, EPA must initiate
preliminary reviews of a number of categorical effluent limitations guidelines and standards on a
set schedule. Pursuant to these legislative and judicial requirements, EPA published the
Preliminary Study of the Iron and Steel Category (EPA 821-R-95-037) in September 1995.  The
study includes the following:

              •      A preliminary assessment of the status of the industry with respect to the
                     Iron and Steel rule promulgated in 1982 and amended in 1984;

              •      Identification of better-performing mills using conventional and innovative
                     in-process pollution prevention and end-of-pipe treatment technologies;

              •      Estimation of possible effluent reduction benefits if the industry was
                     upgraded to the level of better-performing mills; and

              •      Identification of regulatory and implementation issues with the Iron and
                     Steel rule and possible solutions to these issues.
'Currently, each of these 21 facilities has a permit with effluent limitations derived from Part 420. The proposed rule
establishes new BAT limitations thatJiPA believes are economically achievable for all iron and steel subcategories.
Therefore, EPA believes that provisions for alternative effluent limitations are no longer necessary for these facilities and
proposes to withdraw this exclusion from Part 420.
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Section 2 - Background
The study found that the iron and steel industry had restructured during the decade
following the 1984 amendments to the Iron and Steel rule. The study found that the industry had
improved manufacturing techniques, water conservation, pollution prevention, and wastewater
treatment practices. The study also found that the industry had consolidated and modernized in
response to domestic and world competition. While the market for integrated mills continued to
decrease, the market for non-integrated mills using steel scrap as their primary material .continued
to expand due to improvements in the quality of steel manufactured from scrap. Cokemaking was
declining due to changes in ironmaking processes, while direct reduced ironmaking was
increasing. Also, continuous casting became the new industry standard due to the increased
energy efficiency of the process compared with ingot casting.

Overall, the study found that the industry was operating with greater efficiency.
Pollutant loadings had decreased due to increased wastewater recycle rates on manufacturing
processes and improved wastewater treatment processes. At the time of the study, many better-
performing mills were discharging wastewater loadings far below the limitations and standards
established in the 1982 rule; however, not all of the industry had improved wastewater treatment
or implemented proactive pollution prevention practices. At the time of the study, discharges
from some mills continued to exceed allowances specified in the 1982 rule.
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                                                                    Section 3 - Data Collection
                                      SECTIONS

                                 DATA COLLECTION

              EPA gathered and evaluated information and data from various sources in the
course of developing the proposed effluent limitations guidelines and standards for the iron and
steel industry. EPA used these data to develop the industry profile, to determine the applicability
of the rule, to subcategorize the industry, and to determine wastewater characteristics, technology
options, compliance costs, pollutant loading reductions, and non-water quality impacts. This
section discusses the following data collection activities:

       •  •     •      Surveys, including descriptions of the survey instruments and determination
                    of survey recipients (Section 3.1);

              •      Site visits, including descriptions of the types of sites visited, the
                    geographical locations, and the manufacturing processes at the sites visited
                    (Section 3.2);

              •      Sampling episodes, including the types of sites sampled, the manufacturing
                    processes and treatment systems sampled, and the sampling process
                    (Section 33);

              •      Other data sources (Section 3:4); and

              •    .  Public participation, including meetings with stakeholders  from industry
                    trade  associations, individual steel companies, environmental groups, and
                    nongovernmental organizations (Section 3.5).
3.1
Surveys
             The principal source of information and data used in developing effluent limitations
guidelines and standards is the industry response to surveys distributed by EPA under the
authority of Section 308 of the Clean Water Act.  EPA designed these surveys to obtain
information concerning manufacturing operations, wastewater generation and treatment,
discharge practices, and analytical data. The Agency developed related surveys to obtain financial
data for use in assessing economic impacts and the economic achievability of technology options.

             EPA developed an Information Collection Request (ICR) entitled UJL
Environmental Protection Agency Collection of 1997 Iron and Steel Industry Data that explains
the regulatory basis and intended use of the industry surveys. The Office of Management and
Budget (OMB) approved the ICR in August 1998 (OMB Control No. 2040-0193, approval
expires 08/31/2001) (Reference 3-1). The Agency published three Federal Register notices
announcing: (1) the intent to distribute the surveys (62 FR 54453; October 20, 1997), (2) the
submission of the ICR to the OMB (63 FR 16500; April 3, 1998), and (3) OMB's approval of the
ICR (63 FR 47023; September 3, 1998) (References 3-2 through 3-4). The Agency consulted
                                          3-1

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Section 3 - Data Collection
with industry trade associations and visited a number of sites to develop survey instruments and to
ensure an accurate mailing list.

EPA distributed four industry surveys. The first two surveys were similar in
content and purpose, designed to collect detailed technical and financial information from iron and
Steel facilities. Tn October 1998, EPA mailed the first survey, entitled U.S. EPA Collection of
1997 Iron and Steel Industry Data (detailed survey), to 176 iron and steel industry sites and the
second survey, entitled U.S. EPA Collection of 1997 Iron and Steel Industry Data (Short Form)
(short survey), to 223 iron and steel industry sites. The short survey is an abbreviated version of
the detailed survey and was designed for those iron and steel industry sites that do not have
manufacturing processes found only at integrated and non-integrated mills (the cokemaking,
ironmaldng, and steelmaking processes described in Section 5). Section 5 describes the types of
sites that received a detailed or short survey. EPA mailed the third and fourth surveys to subsets
of the facilities that received the first or second survey to obtain more detailed information on
wastewater treatment system costs, analytical data, and facility production. EPA mailed the third
survey, entitled U.S. EPA Collection of Iron and Steel Industry Wastewater Treatment Capital
Cost Data (cost survey), to 90 iron and steel industry sites. EPA mailed the fourth survey,
entitled U.S. EPA Analytical and Production Data Follow-Up to the Collection of 1997 Iron and .
Steel Industry Data (analytical and production survey), to 38 iron and steel industry sites.

The detailed and short survey were divided into two parts: Part A: Technical
Information and Part B: Financial and Economic Information. The "Part A" technical questions
in the detailed survey comprised four sections, with Sections 3 and 4 being combined in the short
survey, as follows:

• Section 1: General Site Information;

• Section 2: Manufacturing Process Information;

• SectionS: In-Process and End-of-Pipe Wastewater Treatment and
Pollution Prevention Information; and

• Section 4: Wastewater Outfall Information.

The financial and economic information in Part B of the detailed survey also
comprised four sections, as shown below:

• Section 1: Site Identification;
• Section 2: Site Financial Information;
• Section 3: Business Entity Financial Information; and
• Section 4: Corporate Parent Financial Information.
3-2

-------
                                                                     Section 3 - Data Collection
              Part B of the short survey contained a single section for site identification and
 financial information. More detailed descriptions of financial information data collection and
' analysis are included in the Economic Analysis of the Proposed Effluent Limitations Guidelines
 and Standards for the Iron and Steel Manufacturing Point Source Category (Reference 3-5).

              The detailed survey requested detailed descriptions of all manufacturing processes
 and treatment systems that EPA determined were included in the iron and steel industry: The
 short survey contained manufacturing process questions for only forming and finishing operations.
 EPA eliminated the cokemaking, ironmaking, and steelmaking questions from the short survey
 because they were not applicable to the types of facilities that received the short survey. The
 Agency also reduced the amount of detail requested in the short survey. EPA determined that if,
 for example, it received detailed descriptions of hot forming mills from an adequate number of
 integrated, non-integrated, and stand-alone hot-forming mills to understand the different
 processes, then it could make assumptions about industry trends from the reduced detail collected
 in the short survey.

              Part A Section 1 requested site contacts and addresses and general information
 regarding manufacturing operations, age, and location.  The Agency used this information to
 develop the subcategorization for the proposed regulation.

              Part A Section 2 requested information on products, types of steel produced,
production levels, unit operations, chemicals and coatings used,  quantity of wastewater
 discharged from unit operations, miscellaneous wastewater sources, flow rates, pollution
prevention activities, and air pollution control.  The Agency used data received in response to
these questions to evaluate manufacturing processes and wastewater generation, and to develop
regulatory options.  EPA also used these data to develop the proposed subcategorization and to
estimate compliance costs and pollutant removals associated with the regulatory options EPA
considered for proposal.

              Part A Section 3 requested detailed information (including diagrams) on the
wastewater treatment systems and discharge flow rates, monitoring analytical data, and operating
and maintenance cost data (including treatment chemical usage).  The Agency used data received
in response to these questions to identify treatment technologies in place, to determine the
feasibility of regulatory options, and to estimate compliance costs and pollutant removals
associated with the proposed regulatory options.

              Part A Section 4 requested permit information, discharge location, wastewater
sources to each outfall, flow rates, regulated pollutants and limits, and permit monitoring data.
The Agency used this information to calculate the effluent limitations guidelines and standards and
pollutant loadings associated with the proposed regulatory options.

              The cost survey requested detailed capital cost data on selected wastewater
treatment systems installed since 1993, including equipment, engineering design, and installation
.costs. EPA incorporated these data into a costing methodology and used them to determine
                                           3-3

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                                                                    Section 3 - Data Collection
incremental investment costs and incremental operating and maintenance costs associated with the
proposed regulatory options.

              The analytical and production survey requested detailed daily analytical and flow
rate data for selected sampling points and monthly production data and operating hours for
selected manufacturing operations. The Agency used the analytical data to estimate baseline
pollutant loadings and pollutant removals from facilities with treatment in place similar to! the
proposed options and to evaluate the variability associated with iron and steel industry discharges.
.The Agency used the production data collected to evaluate the production basis for applying the
proposed rule in National Pollutant Discharge Elimination System (NPDES) permits and
pretreatment permits.

              EPA sent the iron and steel industry surveys by mail to facilities that were
identified from the following sources:

              «      Association of Iron and Steel  Engineers' 1997 Directory: Iron and Steel
                     Plants Volume 1. Plants and Facilities (Reference 3-6);

              .      Iron and Steel Works of the World (12th edition) directory (Reference
                     3-7);                   •        '    '

                     Iron and Steel Society's Steel Industry of Canada. Mexico, and the United
                     States:  Plant Locations map (Reference 3-8);

              •      Member lists from the following trade associations:
                     —    American Coke and Coal Chemicals Institute (Reference 3-9),
                     —    American Galvanizers Association (Reference 3-10),
                     —    American Iron and Steel Institute (Reference 3-11),
                  .   —    American Wire Producers Association (Reference 3-12),
                     —    Cold Finished Steel Bar Institute (Reference 3-13),
                     —    Specialty Steel Industry of North America (Reference 3-14),   •
                     —    Steel Manufacturers Association (Reference 3-15),
                     —    Steel Tube Industry of North America (Reference 3-16), and
                     —    Wire Association International (Reference 3-17);

              •      Dun & Bradstreet Facility Index database (Reference 3-18);

              •      EPA Permit Compliance System (PCS) database (Reference 3-19);

              •      EPA Toxic Release Inventory (TRI) database (Reference 3-20);

              •      Iron arid Steelmaker Journal "Roundup" editions (Reference 3-21);

              •      33 Metalproducing Journal "Roundup" editions (Reference 3-22);
                                           3-4

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Section 3 - Data Collection
• . 33 Metalproducing Journal "Census of the North American Steel Industry"
(Reference 3-23); and

• Thomas Register (Reference 3-24).

The Agency cross-referenced these sources with one another to develop a list of
individual sites. Based on these sources, EPA identified 822 candidate facilities to receive
surveys. These candidates include facilities that EPA now proposes to include in the Metal
Products and Machinery (MP&M) Category and will be regulated under 40 CFR Part 438. To
minimize the burden on the respondents, EPA grouped them into 12 strata. In general, EPA
determined the strata based on its understanding of the manufacturing processes at each facility.
The Agency also developed two "certainty strata," one for the detailed survey and one for the
short survey. Table 3-1 presents the stratification of the iron and steel industry.

Depending on the amount or type of information EPA required for the rulemaking,
EPA either solicited information from all facilities within a stratum (i.e., performed a census) or
selected a random sample of facilities within each stratum. EPA sent a survey to all facilities in
the certainty strata (strata 5 and 8) because the Agency determined it was necessary to capture the
size, complexity, or uniqueness of the steel operations present at these sites. EPA also sent
surveys to all facilities in strata 1 through 4 (all cokemaking sites, integrated steel sites, and
sintering and direct reduced iron sites) because the number of sites in each stratum is relatively
low and because of the size, complexity, and uniqueness of raw material preparation and steel
manufacturing operations present. The Agency statistically sampled the remaining sites in strata
6, 7, and 9 through 12. EPA gave survey weights to each selected facility based on a facility's
probability of selection. If the Agency sent a survey to every facility in a stratum, each facility
represents only itself. For statistically sampled strata, each facility was given a survey "weight that
allows it to represent itself and other facilities within that stratum that were not selected to receive
an industry survey. See Appendix A for more details.

Of the 822 candidate facilities, EPA mailed either a detailed survey or a short
survey to 39-9 facilities. Detailed survey recipients included integrated mills, non-integrated mills,
stand-alone cokemaking sites, stand-alone sintering sites, stand-alone direct reduced ironmaking
sites, stand-alone hot forming sites, and stand-alone finishing sites. Short survey recipients
included stand-alone cold forming sites, stand-alone pipe and tube sites, stand-alone hot dip
coating sites, and stand-alone wire sites. Section 5 describes these types of sites. Eleven sites
receiving a survey did not return a completed survey and, thus, are considered non-respondents.
EPA did not consider 10 sites receiving surveys for further review: seven of these sites were
closed, two sites were considered part of another site owned by the same company, and one site
received two surveys under two mailing addresses and, therefore, only one survey was completed.
EPA received 378 completed surveys, including those from 33 sites that certified that they were
not engaged in iron and steel activities.

One hundred fifty-four of the returned surveys were from sites with operations that
were later determined to be within the scope of the MP&M Category. Similarly, two recipients of
MP&M surveys were determined to be within the scope of the Iron and Steel Category.
3-5

-------
                                                                      Section 3 - Data Collection
Therefore, the Agency used the data from 191 returned surveys and the two MP&M industry
surveys in the development of the proposed rule.

              Once the Agency completed a review of the detailed and short surveys and defined
the treatment technology options, EPA identified survey respondents who had installed
wastewater treatment systems hi the last 10 years (since 1990) that were similar to the technology
options and mailed them the cost survey. Of the 90 cost survey recipients, 88 returned completed
surveys. EPA selected 38 facilities to receive the analytical and production survey based on
survey respondents who had indicated that: (1) they had treatment trains similar to the treatment
technology options, (2) they had collected analytical data for that treatment train, (3) they had a
treatment train with a dedicated outfall from which EPA could evaluate performance, and (4) they
did not add excessive dilution water to the outfall before sampling. All 38 analytical and
production survey recipients returned completed surveys. EPA included in the public record all
information and data collected for which sites have not asserted claims of confidential business
information.
3.2
Site Visits
              EPA conducted 67 site visits at iron and steel facilities in 19 states and Canada
between January 1997 and May 1999. Table 3-2 presents the number of site visits performed in
each state.  The purpose of the site visits was to collect information about each site's
manufacturing operations, wastewater generation, wastewater management practices, and
wastewater treatment systems and to evaluate each facility for potential inclusion in the sampling
program. EPA also used information collected during site visits to aid in the development of the
industry surveys.  EPA selected sites to visit based on the type of site (as described in Section
5.1), the manufacturing operations at each facility, the type of steel produced (carbon, alloy,
stainless), and the wastewater treatment operations. The Agency wanted to visit all types of iron
and steel manufacturing operations as well as all types of wastewater treatment operations.
Before sites returned completed surveys, EPA used information collected from the sources used
to develop the survey database to select sites to visit,  After EPA evaluated the completed
surveys, the Agency used information provided by the sites to select additional sites to, visit.
Table 3-3 summarizes the number of site visits performed at each type of site.

              EPA collected detailed information during each site visit on the manufacturing
processes, wastewater generation, in-process treatment and recycling systems, management
practices and pollution prevention, end-of-pipe treatment technologies, and, if the facility was a
candidate for sampling, the logistics of collecting samples. The Agency observed the following
manufacturing processes:  coke plants, suiter plants, briquetting plants, blast furnaces, direct
reduced ironmaking plants, an iron-carbide plant, basic oxygen furnaces, electric arc furnaces,
vacuum degassers, ladle metallurgy stations, continuous and ingot casting facilities, hot forming
mills, and cold forming mills. The Agency also observed acid pickling,  descaling, and surface
cleaning and coating operations (i.e., manufacturing lines or areas with acid cleaning, alkaline
cleaning, annealing, electroplating, and/or hot dip coating operations). Table 3-4 summarizes the
number of sites visited that performed any of these manufacturing processes.
                                            3-6

-------
                                                                    Section 3 - Data Collection
              EPA observed in-process wastewater treatment and recycling systems,
 pretreatment systems, and end-of-pipe wastewater treatment systems that were either dedicated to
 a manufacturing process or shared by multiple processes. Wastewater treatment operations
 included biological treatment, metals precipitation, solids settling, alkaline chlorination, arid
 filtration systems.  EPA included in the public record all information and data collected during site
 visits for which sites have not asserted claims of confidential business information. -
 3.3
Sampling
              After evaluating information obtained during the site visits, EPA selected 16 sites
 at which to perform wastewater sampling. EPA selected sites for sampling using the following
 criteria:

              •      The site performed operations either currently regulated under 40 CFR
                     Part 420 or identified in the Preliminary Study as being operations
                     performed in the iron and steel industry;

              •      The site performed high-rate recycling, in-process treatment, or end-of-
                     pipe treatment operations that EPA believed may represent potential model
                     treatment technology; and

              •      The site's compliance monitoring data indicated that it was among the
                     better performing treatment systems in the industry, based on comparisons
                     of monitoring data from other facilities and with limits from the 1982
                     regulation.                         .

              Table 3-5 shows the type and number of manufacturing processes sampled during
the EPA sampling program.

              During each sampling episode, EPA collected samples of untreated process
wastewater, treatment system effluents, source water to characterize background concentrations,
and other samples to characterize the performance of individual treatment units. Table 3-6
summarizes the treatment systems sampled during the sampling program.

              In general, the Agency collected 24-hour composite samples from wastewater
sampling points each day of the sampling episode. Exceptions to this rule include samples
collected for volatile organics analysis and oil and grease (O&G), which EPA collected as multiple
grabs over each 24-hour period (laboratory personnel composited the volatile organics samples
before analysis, while EPA-mathematically composited the O&G analytical results after the
analyses were performed). EPA collected a one-time grab sample,from each water source
contributing to the manufacturing processes sampled. The Agency collected all waste oil and
treatment system sludge samples as one-time grab samples.

              EPA analyzed wastewater samples for up to approximately 300 analytes spanning
the following pollutant classes:  conventional, priority, and nonconventional pollutants, including
                                          3-7

-------
                                                                   Section 3 - Data Collection
metals, volatile organic constituents, semivolatile organic constituents, and dioxins and furans.
Analyte selection was based on knowledge of the manufacturing processes and raw materials
used.  EPA generally collected samples using the following guidelines:                       ,

             •      Five days of samples for conventional, nonconventional and priority
                    metals, and certain other nonconventional pollutants, including total
                    dissolved solid (TDS), chlorides, fluorides, sulfates, total organic carbon
                    (TOC), chemical oxygen demand (COD), total Kjeldahl nitrogen (TKN),
                    nitrate/nitrite, ammonia as nitrogen, and total phenols;

             •      Five days of samples from biological treatment systems for five-day
                    biochemical oxygen demand (BOD5) and five-day carbonaceous
                    biochemical oxygen demand (CBOD5);

             •      Five days of samples from cokemaking, blast furnace ironmaking, and
                    sintering wastewater for total sulfide, thiocyanate, amenable cyanide, total
                    cyanide, and weak acid dissociable (WAD) cyanide;

             •      Five days of samples from cokemaking wastewater for organics and
                    dioxins/furans, because the Agency believed limitations development for
                    these parameters was likely;

             •      Three days of samples from all noncokemaking wastewater for organics to
                  •  screen and provide sufficient data for potential limitations development;

             «      Two days of samples from blast furnace ironmaking, sintering, and basic
                  •  oxygen furnace steelmaking wastewater for dioxins/furans to screen and
                    provide sufficient data for potential limitations development;

             •      Five days of samples from carbon arid alloy steel finishing treatment
                    systems containing chromium-bearing wastewater from electroplating or
                    hot coating operations and stainless steel finishing treatment systems for
                    hexavalent chromium;

             •      On two occasions (one cokemaking plant and one direct reduced
                    ironmaking plant), the Agency performed a one-day screening for
                    pollutants of concern.
                                                                               sters
             Table 3-7 shows the EPA wastewater analytical methods used and paramete^
analyzed for during the sampling program, the manufacturing processes for which the analyte was
analyzed, and the general frequency with which samples were collected during the sampling
program. EPA analyzed one-time grab waste oil and sludge samples for metals, volatile and.
semivolatile organic constituents, total phenols, and dioxins/furans, depending on the treatment
system from which they were collected.
                                          3-8

-------
                                                                   Section 3 - Data Collection ,
              Analytical results from untreated samples contributed to EPA's characterization of
the industry, development of the list of pollutants of concern, and development of raw wastewater
characteristics. EPA used data from both untreated wastewater samples and treated effluent
samples to evaluate treatment system performance, to develop pollutant loadings and removals,
and, under the focused rulemaking approach described in Section 8, to develop the proposed
model treatment technology options for the iron and steel industry. EPA used data collected from
treated effluent sampling points to calculate the long-term averages (LTAs) and limitations for
each of the proposed regulatory options. During each sampling episode, EPA also collected flow
rate data corresponding to each sample collected and production information from each
associated manufacturing operation for use in calculating pollutant loadings and production-
normalized flow rates. EPA included in the public record all information and data collected
during sampling episodes for which sites have not asserted claims of confidential business
information.
3.4
Other Data Sources
              EPA evaluated existing data sources to gather technical and financial information
about the iron and steel industry, as discussed below.

              The Agency gathered technical information from iron and steel industry trade
journals published from 1985 through 1997 as well as information from Iron and Steel Society
conference proceedings. Trade journals included Iron and Steel Engineer, published by the
Association of Iron and Steel Engineers (AISE) (Reference 3-25), Iron and Steelmaker, published
by the Iron and Steel Society (ISS) (Reference 3-26), and New Steel (formerly Iron Age).
published by Chilton Publications (Reference 3-27). EPA obtained the following types of
information from these sources:  storm-water and wastewater issues, new and existing wastewater
treatment technologies, wastewater treatment and manufacturing equipment upgrades and
installations, and company mergers, acquisitions, and joint ventures. EPA also used these sources
to identify potential survey recipients and facilities for site visits.

              EPA consulted the following publications: Census Manufacturers - Industry Series
and Current Industrial Reports (U.S. Bureau of Census) (References 3-28 and 3-29); World Steel
Dynamics (Paine Webber) (References 3-30 through 3-36); and The Annual Statistical Report
(American Iron and Steel Institute) (Reference 3-37).  These sources provided a variety of
financial information, ranging from aggregate data on employment and payroll to steel shipments
by product, grade, and market.

              The Agency performed searches on the following on-line databases: Pollution
Abstracts, Water Resources Abstracts, Engineering Index, Materials Business File, National
Technical Information Service (NTIS), Enviroline, Compendex, and Metadex (References
3-38 through 3-45). The Agency also searched EPA's TRI (Reference 3-20) and PCS databases
(Reference 3-19). In addition, the Agency reviewed secondary sources, including data, reports,
and analyses published by government agencies, reports and analyses published by the iron and
steel industry and its associated organizations, and publicly available financial information
compiled by bpth government and private organizations.
                                          3-9

-------
                                                                    Section 3 - Data Collection
 3.5
Public Participation
              EPA has encouraged participation of all interested parties throughout the
 development of the proposed Iron and Steel Category effluent limitations guidelines and
 standards.  EPA has conducted outreach with the following trade associations (which represent
 the vast majority of the facilities that will be affected by this guideline):  American Iron and Steel
 Institute (AISI), Steel Manufacturers Association (SMA), Specialty Steel Industry of North
 America (SSINA), Cold Finished Steel Bar Institute (CFSBI), Wire Association International,
 Incorporated (WAI), American Wire Producers Association (AWPA), Steel Tube Institute of
 North America (STINA), American Galvanizers Association, Incorporated (AGA), and American
 Coke and Coal Chemicals Institute (ACCCI). EPA has met on several occasions with  various
 industry representatives to discuss aspects of the regulation development.  EPA has also
 participated in industry meetings and has given presentations on the status of the regulation
 development.

              Because some facilities affected by the proposal are indirect dischargers, the
 Agency also conducted outreach to publicly owned treatment works (POTWs).  EPA also made a
 concerted effort to consult with pretreatment coordinators and state and local entities who will be
 responsible for implementing the iron and steel regulation.

              EPA sponsored five stakeholders' meetings between December 1998 and January
 2000. Four were held in Washington, D.C. and the fifth was held in Chicago, Illinois.  The
 primary objectives of the meetings were to present the Agency's current thinking regarding the
 technology bases for the proposed revisions to 40 CFR Part 420 and to seek dialogue,  discuss
 issues, and obtain new ideas from interested stakeholders, including industry representatives and
 members of environmental groups such as the Natural Resources Defense Council (NRDC), the
 Environmental Defense Fund (now Environmental Defense), Atlantic States Legal Foundation,
 Friends of the Earth, and Save the Dunes.

              During the meetings, EPA presented process flow diagrams showing preliminary
 technology options and potential best management practices (BMPs) that may be incorporated
 into a revised Part 420 and/or included in NPDES permit and pretreatment guidance.  The
presentations were organized by type of manufacturing process. In addition to soliciting
 comments on the preliminary options, EPA requested ideas from the stakeholders to identify
useful incentives for greater pollution control.

              At the meetings, EPA encouraged participants to supplement their oral statements
with written comments and supporting data.  In that regard, EPA provided a set of data quality
protocols for use when submitting data for the iron and steel rulemaking effort. This handout,
along with all other handouts and meeting summaries, is posted on the EPA iron and steel
industry web site at http://www.epa.gov/OST/ironsteel/. All of the materials presented  at the
stakeholders' meetings, as well as meeting summaries and any written comments from participants
not containing confidential business information, are also in the public record for the proposed
regulation.
                                          3-10

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Section 3 - Data Collection
3.6

3-1

3-2

3-3
3-4
3-5
3-6

3-7

3-8

3-9

3-10

3-11

3-12

3-13

3-14

3-15
References

U.S. Environmental Protection Agency. Information Collection Request. U.S.
Environmental Protection Agency Collection of 1997 Iron and Steel Industry Data.
EPA ICR 1830.01. Washington, D.C., March' 1998.

Agency Announcement of Information Collection Activities: 1997 Iron and Steel
Industry Survey (EPA ICR No. 1830.01). Federal Register: October 20, 1997
(Volume 62, Number 202, Page 54453-54454).

Agency Announcement of Information Collection Activities: Submission for OMB
Review; Comment Request; Collection of 1997 Iron and Steel Industry Data (EPA
ICR 1830.01). Federal Register: April 3, 1998 (Volume 63, Number 64, Page
16500-16501).

Agency Information Collection Activities; OMB Responses. Federal Register:
September 3, 1998 (Volume 63, Number 171, Page 47023-47024).

U.S. Environmental Protection Agency. Economic Analysis of the Proposed
Effluent Limitations Guidelines and Standards for the Iron and Steel
Manufacturing Point Source Category. EPA 821-B-00-009, Washington, D.C.,
December 2000.

Association of Iron and Steel Engineers. Directory: Iron and Steel Plants
Volume 1. Plants and Facilities. Pittsburgh, PA, 1997 and 1998.

Iron and Steel Works of the World (11th and 12th edition). Metal Bulletin Books
Ltd., Surrey, England, 1994 and 1997.

Iron and Steel Society. The Steel Industry of Canada. Mexico, and the United
States: Plant Locations. Warrendale, PA, 1995.

American Coke and Coal Chemicals Institute. Member List. 1997.

American Galvanizers Association. Member List. 1997.

American Iron and Steel Institute. Member List. 1998.

American Wire Producers Association. Member List. 1997.

Cold Finished Steel Bar Institute. Member List. 1997.

Specialty Steel Industry of North America. Member List. 1997.

Steel Manufacturers Association. Member List. 1997.
3-11

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                                                                 Section 3 - Data Collection
3-16

3-17

3-18

3-19

3-20

3-21



3-22


3-23



3-24

3-25


3-26


3-27

3-28

3-29

3-30


3-31


3-32

3-33
Steel Tube Institute. Member List.  1997.

Wire Association International. Member List. 1997.

Dun & Bradstreet.  Facility Index Database. 1997.

U.S. EPA. Permit Compliance System (PCS) Database.

U.S. EPA. Toxic Release Inventory (TRI) Database. 1995. .

Iron and Steel Society. Iron and Steelmaker. "Roundup: Electric Arc Furnace,"
May 1996 and May 1997; "Roundup:  Blast furnace," August 1996 and August
1997; "Roundup: Continuous Caster," November 1996 and November 1997.

33 Metalproducing. "Roundup."  Penton Publications, Cleveland, OH, May 1989
and May  1991.

33 Metalproducing. "Census of the North American Steel Industry."  Penton
Publications, Cleveland, OH, March 1996,  July 1996, September 1996, October
1996, November 1996, and March 1997.

Thomas Register. Thomas Publishing Company, New York, NY, 1996.

Association of Iron and Steel Engineers (AISE).  Iron and Steel Engineer.
Pittsburgh, PA, 1985 through 1997.

Iron and Steel Society (ISS). Iron and Steelmaker. Warrendale, PA,  1985
through 1997.

New Steel (formerly Iron Age). 1985  through 1997.

U.S. Bureau of the Census.  Census Manufacturers - Industry Series.  1992.

U.S. Bureau of the Census.  Current Industrial Reports. 1992.

Paine Webber. World Steel Dynamics. "Steel's Thin-Slab/Flat-Rolling
Revolution: Provoking Changed." January 1996.

Paine Webber. World Steel Dynamics. "Steel Dynamics Inc. Progress Report."
May 1996.

Paine Webber.' World Steel Dynamics. "PriceTrack # 55." April 1997.

Paine Webber. World Steel Dynamics. "Trico Steel: Raising the Ante in Steel's
Flat-Rolling Revolution." June 1997.                                        .
                                        3-12

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                                                                   Section 3 - Data Collection
3-34

3-35


3-36


3-37

3-38

3-39

3-40

3-41

3-42


3-43

3-44

3-45
Paine Webber.  World Steel Dynamics. " PriceTrack #56." August 1997..

Paine Webber.  World Steel Dynamics. "Flat-Rolled Process-by-Process Costs."
December 1997.

Paine Webber.  World Steel Dynamics. "Long Product Process-by-Process
Costs." December 1997.

American Iron and Steel Institute.  The Annual Statistical Report.  1997.

Pollution Abstracts (on-line).

U.S. Geological Survey. Water Resources Abstracts (on-line).

Engineering Index (on-line).

Material Business File (on-line).

U.S. Environmental Protection Agency. National Technical Information Service
£N3IS) (on-line).

Congressional Information Service, Inc. Enviroline (on-line).

Engineering Information, Inc. Compendex (on-line).

Cambridge Scientific Abstracts. Metadex (on-line).
                                         3-13

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                                                                           Section 3 - Data Collection
                                           Table 3-1
                              Iron And Steel Industry Strata
Stratum
Number
1
2
3
4
5
6
7
8
9
10
11
12

Stratum Name
Integrated steel sites with cokemaking
Integrated steel sites without cokemaking
Stand-alone cokemaking sites
Stand-alone direct reduced ironmaking
and sintering sites
Detailed survey certainty stratum3' b
Non-integrated steel sites
Stand-alone finishing sites and stand-
alone hot forming sites
Short survey certainty stratum13' °
Stand-alone cold forming sites
Stand-alone pipe and tubes sites
Stand-alone hot coating sites
Stand-alone wire sites
Total
Number of Sites
in Stratum
9
. 12
16
5
60
69
54
13
62
164
106
252
822
Number of Sites
Receiving
Surveys
9
12'
16
5
60
40
35
13
37
59
49 ;
67
402
"This stratum includes facilities from strata 6 and 7.
"This stratum includes data transferred from one site that received an MP&M survey.
This stratum includes facilities from strata 9 through 12.
                                              3-14

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                                                 Section 3 - Data Collection
                        Table 3-2
Number of Site Visits Conducted in Each State and in Canada
State
Alabama
Arizona
Arkansas
California
Canada
Illinois
Indiana
Kentucky
Louisiana
Maryland
Michigan •
New York
Ohio
Oregon
Pennsylvania
'South Carolina
Texas
Utah
Virginia
West Virginia
Total
Number of Site
Visits Conducted
6
1
1
2
2
6
10
1
1
2
2
2
10
1
10
1
- .2
2
2
3
67
                          3-15

-------
                                                                       Section 3 - Data Collection
                                         Table 3-3
               Number of Site Visits Conducted at Each Type of Site
Type of Site
Integrated mill with cokemaking
Integrated mill without cokemaking
Stand-alone cokemaking plant
Stand-alone sintering plant3
Stand-alone direct reduced ironmaking plantb
Non-integrated mill
Stand-alone hot forming mill
Stand-alone finishing mill
Stand-alone pipe and tube mill
Stand-alone iron carbide mill
Total
Number of Site Visits Conducted
11
9
12
1
1
16
1
10
5
1
67
aEPA visited eight additional sintering plants at integrated mills.
bEPA visited one additional direct reduced ironmaking mill at a non-integrated mill.
                                            3-16

-------
                                                                   Section 3 - Data Collection
                                   Table 3-4
Number of Sites Visited With Each Type of Manufacturing Process
Manufacturing Process
Cokemaking
Sintering
Briquetting
Blast furnace ironmaking
Direct reduced ironmaking
Iron carbide
Basic oxygen furnace steelmaking
Electric arc furnace steelmaking
Vacuum degassing .
Ladle metallurgy
Casting3
Hot forming15
Cold forming
Acid pickling or descaling
Surface cleaning and coating0
Number of Sites with Each
Type of Manufacturing
Process
. 23
9 , '
4
20
2
1
19
18
17
33
33
36
34
28
28
      "Casting operations include ingot casting and continuous casting.
      bHot forming operations include hot rolling, forging, seamless pipe and tube, and butt-
      welded pipe and tube.
      "Surface cleaning and coating operations include acid cleaning, alkaline cleaning,
      annealing, electroplating, and hot coating operations.
                                      3-17

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                                                                     Section 3 - Data Collection
                                    Table 3-5
                    Manufacturing Processes Sampled
Manufacturing Process
Cokemaking
Sintering
Blast furnace ironmaking
Direct reduced ironmaking
Basic oxygen furnace steelniaking .
Vacuum degassing
Continuous casting
Hot forming3
Descaling
Acid pickling
Cold forming
Surface cleaning or coatingb
Number of Processes Sampled
4
2
3
1
5
2
6
' 7'
2
7
5 •
4
"Hot forming operations include hot rolling, forging, seamless pipe and tube, and butt-welded pipe
and tube.
""Surface cleaning and coating operations include acid cleaning, alkaline cleaning, annealing,
electroplating, and hot coating operations.
                                        3-18

-------
                                  Section 3 - Data Collection
         Table 3-6
Treatment Systems Sampled
Treatment
System
1
' 2
3
4
. 5
6
7
8
9
10
11
12
13
Treatment System Description
Coke plant treatment system with
ammonia stripping and biological
treatment
Coke plant treatment system with
ammonia stripping and biological
treatment
• Coke plant treatment system with
ammonia stripping, biological
treatment, and sand and granular
activated carbon filtration
Coke plant treatment system with
ammonia stripping and biological
treatment .
Sinter plant treatment and high-
rate recycle system
Blast furnace and sinter plant
blowdown treatment and high-rate
recycle' system .
Blast furnace treatment and high-
rate recycle system
Blast furnace treatment and high-
rate recycle system
Direct reduced iron treatment and
high-rate recycle system
Basic oxygen furnace treatment
and high-rate recycle system
Basic oxygen furnace blowdown
treatment system
Steelmakmg (vacuum degasser,
continuous caster) treatment and
high-rate recycle system
Basic oxygen furnace treatment
and high-rate recycle system
Samples Collected
Ammonia still influent, ammonia still effluent, biological
treatment system effluent
Ammonia still influent, ammonia still effluent, biological
treatment system effluent
Flushing liquor, by-products recovery Wastewater,
equalization tank effluent, biological treatment system effluent,
sand filter effluent, carbon filter effluent
Ammonia still influent, ammonia still effluent, biological
treatment system effluent
Sinter plant untreated wastewater, treatment system effluent
Blast furnace scrubber untreated wastewater, suiter plant
scrubber untreated wastewater, blast furnace treatment
blowdown, sinter plant treatment blowdown, combined final
effluent, treatment system sludge
Blast furnace untreated wastewater, recycle wastewater, filter
press sludge
Blast furnace untreated wastewater, treatment system
blowdown, treatment system filter cake
Clarifier influent, sand filter influent, treatment system effluent
Basic oxygen furnace untreated wastewater, recycle water
Classifier effluent, thickener effluent, treatment system
effluent, vacuum filter cake
Vacuum degasser untreated wastewater, clarifier overflow,
filter effluent, continuous caster untreated wastewater,
treatment system effluent
Basic oxygen furnace untreated wastewater, untreated gas
cooling water, thickener overflow, drum filter sludge, filter
press sludge
            3-19

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                                 Section 3 - Data Collection
Table 3-6 (Continued)
Treatment
System
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
Treatment System Description
Steelmaking (basic oxygen
furnaces, vacuum degasser,
continuous casters) treatment and
high-rate recycle system
Continuous caster treatment and
high-rate recycle system
Continuous caster treatment and
high-rate recycle system
Continuous caster treatment and
' high-rate recycle system
Continuous caster treatment and
high-rate recycle system
Hot strip mill treatment and high-
rate recycle system
Hot strip mill treatment and high-
rate recycle system
•Hot strip mill treatment and high-
rate recycle system
Hot strip mill blowdown treatment
and high-rate recycle system
Hot strip mill treatment and high-
rate recycle system
Hot mill treatment and high-rate
recycle system
Hot strip mill treatment and high-
rate recycle system
Oily wastewater treatment system
Plate mill treatment system
Steel finishing chemical
precipitation system
Steel finishing chemical
precipitation system with
chromium reduction pretreatment
Samples Collected
Continuous caster untreated wastewater, vacuum degasser
untreated wastewater, clarifier underflow, thickener underflow,
treatment system blowdown
Scale pit influent, treatment system effluent
Continuous caster untreated wastewater, sand filter effluent
Continuous caster scale pit influent, sand filter effluent, scale
pit waste oil
Continuous caster untreated wastewater, treatment system
effluent, scale pit waste oil
Hot strip mill untreated wastewater, treatment system effluent
Continuous caster untreated wastewater, vacuum degasser
untreated wastewater, hot strip mill untreated wastewater,
treatment system blowdown
Roughing mill untreated wastewater, finishing mill untreated
wastewater, roughing mill sand filter effluent, finishing mill
sand filter effluent, waste oil
Hot strip mill untreated wastewater, treatment system
blowdown, scale pit waste oil
Hot mill scale pit influent, treatment system effluent, scale pit
waste oil
Hot mill untreated wastewater, treatment system effluent,
blowdown polishing system blowdown, scale pit waste oil
Sand filter influent, treatment system effluent
Oily wastewater influent, treatment system effluent
Scale pit influent, scale pit effluent, scale pit waste oil
Acid pickling untreated wastewater, galvanizing untreated
wastewater, sand filter influent, sand filter effluent
Acid pickling untreated wastewater, chromium reduction , .
pretreatment influent, chromium reduction pretreatment
effluent, sand filter influent, sand filter effluent
         3-20

-------
                                  Section 3 - Data Collection
Table 3-6 (Continued)
Treatment
System
30
31-
32
33
34
35
36
Treatment System Description
Steel finishing chemical
precipitation system with
chromium reduction pretreatment
Steel finishing chemical
precipitation system
Steel finishing chemical
precipitation system with
chromium reduction pretreatment
Steel finishing chemical
precipitation system
Steel finishing chemical
precipitation system
Steel finishing chemical
precipitation system with oily
wastewater pretreatment and
chromium pretreatment
Steel finishing chemical
precipitation system
Samples Collected
Acid pickling untreated wastewater, cold forming untreated
wastewater, electrogalvanizing untreated wastewater, hot dip
coating untreated wastewater, oily wastewater, chromium
reduction pretreatment effluent, intermediate treatment, final
effluent
Acid pickling untreated wastewater, cold forming untreated
wastewater, treatment system effluent
Acid pickling untreated wastewater, descaling untreated
wastewater, chromium reduction pretreatment effluent,
treatment system effluent
Electroplating solution, treatment system influent, clarifier
effluent, sand filter effluent • •
Acid pickling untreated wastewater, oily wastewater, treatment
system effluent
Continuous annealing untreated wastewater, alkaline cleaning
untreated wastewater, electroplating untreated wastewater, hot
dip coating untreated wastewater, acid pickling untreated
wastewater, oily wastewater pretreatment influent, oily
wastewater pretreatment effluent, chromium reduction
pretreatment influent, chromium reduction pretreatment
effluent, treatment system influent, treatment system effluent
Acid pickling untreated wastewater, electrogalvanizing
untreated wastewater, treatment system effluent
         3-21

-------
                                                  Section 3 - Data Collection
                          Table 3-7
Wastewater Analytical Methods Used During Sampling Program
EPA Method
160.2
160.1
325.2 or 325.3 .
340.1,340.2,340.3
375.1,375.3,375.4
150.1
415.1
410.1, 410.2, or 410.4
351.1,351.2,351.3,
351.4
353.1, 353.2, or 353.3
350. 1,350.2, or 350.3
405.1
405.1
1664
1664
420.1 or 420.2
376.1,376.2
4500CNPartM
335.1, 335.2, and 1677
Parameter
Total suspended solids (TSS)
Total dissolved solids (TDS)
Chlorides
Fluorides
Sulfates
pH
Total organic carbon (TOC)
Chemical oxygen demand (COD)
. Total Kjeldahl nitrogen (TKN)
Nitrate/nitrite
Ammonia as nitrogen
Five-day biochemical .oxygen
demand (BOD5)
Five-day carbonaceous biochemical
oxygen demand (CBOD5)
Hexane extractable material (oil and
grease)
Silica-gel treated hexane extractable
material (total petroleum
hydrocarbons)
Total phenols
Total sulfide
Thiocyanate
Cyanide (amenable), cyanide (total),
and weak acid dissociable cyanide,
respectively
Manufacturing
Processes
All
All
All
All
All'
All
All
All
All
All
All
Cokemaking
Cokemaking
All
All
All,
Cokemaking, blast
furnace ironmaking,
sintering
Cokemaking, blast
furnace ironmaking,
sintering
Cokemaking, blast
furnace ironmaking,
sintering
Typical Sampling
Frequency
(Days/Episode)
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
                            3-22

-------
                                 Section 3 - Data Collection
Table 3-7 (Continued)
EPA Method
161.3B
218.4
1620
1624C
1625C
Parameter
Dioxins/furans
Hexavalent chromium
Metals
Volatile organics '
Semivolatile organics
Manufacturing
Processes .
Cokemaking, blast
furnace ironmaking, •
sintering, basic oxygen
furnace steelmaking
Chromium-bearing
electroplating and hot
coating wastewater
from carbon and alloy
finishing operations,
stainless steel finishing
operations
All
All
All
Typical Sampling
Frequency
(Days/Episode)
' 2 (blast furnace
ironmaking,
sintering, basic
oxygen furnace
steelmaking)
5 (cokemaking)
5
5
3 •
5 (cokemaking)
3
5 (cokemaking)
         3-23

-------

-------
Section 4 - Analytical Methods and Baseline Values
SECTION 4

ANALYTICAL METHODS AND BASELINE VALUES

This section describes the analytical methods associated with the concentration
data used to develop the proposed limitations and standards. Depending on the subcategory and
segment, the proposed rule requires dischargers to measure for up to seven metals, three organic
contaminants, 2,3,7,8-TCDF, ammonia as nitrogen, fluoride, oil and grease as hexane extractable
material (HEM), thiocyanate, total cyanide, total residual chlorine (TRC), total suspended solids
(TSS), and pH. In addition, the preamble to the proposed rule solicits comments on whether
nitrate/nitrite should be regulated.

This section discusses the methods used to analyze the samples that EPA and the
industry collected from iron and steel wastewater. Section 3 discusses these sampling efforts.
This section also discusses how EPA used the results of its wastewater analyses for purposes of
calculating the proposed limitations and standards (Section 12 describes the methodology used for
those calculations).

Section 4.1 briefly describes baseline values for the pollutants and their
importance. Section 4.2 describes the reporting conventions laboratories used in expressing the
results of the analysis. Sections 4.3 and 4.4 further explain nominal quantitation limits and
baseline values, respectively. Section 4.5 describes the specific analytical methods .and the
corresponding baseline value for each pollutant that EPA proposes to regulate (pH is excluded
from this discussion as the baseline value concept is not relevant1). Table 4-1 presents the
analytical methods and baseline values used for each pollutant in calculating limitations and
standards.
4.1
Explanation and Importance of Baseline Values
The database that EPA used to calculate the proposed limitations and standards
consists of two types of analytical data: 1) data collected and analyzed by EPA ("sampling
episodes"), and 2) industry-supplied data ("self-monitoring episodes"). EPA analyzed all of its
wastewater samples using methods identified in Table 4.1. EPA consistently used the same
method to analyze all samples for a particular pollutant. However, the methods used for the
industry-supplied data varied; these are also identified in Table 4.1. Generally, industry used
either EPA methods from Methods for Chemical Analysis of Water and Wastes (MCAWW) or
the American Public Health Association's Standard Methods for the Examination of Water and
Wastewater (References 4-1 and 4-2).
'For pH, the proposed limitations and standards are specified as a range of values between 6 and 9. In analyzing pH
levels, laboratories typically use methods such as EPA Method 150.1 or Standard Method 4500 H* B, which are
classical wet chemistry methods. The baseline concept is not relevant because the lowest pH readings would be
extremely acidic and unexpected in treated effluent from this industry regardless of the treatment technology.
4-1

-------
Section 4 - Analytical Methods and Baseline Values
As described further in Section 4.4, in using this database, EPA compared the
reported concentrations for each pollutant to a baseline value. Regardless of the data source,
EPA needed to use a single baseline value for each pollutant in these comparisons. EPA used the
nominal quantitation limits associated with the analytical methods employed in its sampling
episodes as the basis for determining each "baseline value." EPA determined that this was
appropriate because EPA consistently used a single method for each pollutant while industry used
a range of different methods. Consequently, the baseline value for each pollutant is the nominal
quantitation limit associated with the analytical method EPA used to analyze that pollutant in its
sampling episodes. Table 4-1 identifies these baseline values.

In general, the term "nominal quantitation limit" describes the smallest quantity of
an analyte that can be measured reliably with a particular analytical method. In some cases,
however, EPA used a value lower than the nominal quantitation limit as the .baseline value
because submitted data demonstrated that reliable measurements could be obtained at a lower .
level. In a few instances, EPA concluded that the nominal quantitation limit for a specified
method was less than the level that laboratories could reliably achieve. For those pollutants, EPA
modified the nominal quantitation limit upward and used a higher value as the baseline value.
Section 4.3 discusses these instances and the nominal quantitation limit for each pollutant further.
4.2
Reporting Conventions Associated with Analytical Results
Most of the analytical data were reported as liquid concentrations in
weighWolume units (e.g., micrograms per liter (|ig/L)). In a few instances, the results were
provided in weight/weight solids units (e.g., milligrams per kilogram (mg/kg)). In those instances,
EPA converted the solids results into weight/volume units by using a conversion factor based
upon the percent of solids in the sample. In addition, EPA converted data supplied in weight/tune
units to weight/volume units.2

The laboratories expressed the result of the analysis either numerically or as "not
quantitated"3 for a pollutant in a sample. When the result is expressed numerically, then the
pollutant was quantitated4 hi the sample. For example, for a hypothetical pollutant X, the result
would be reported as "15 ug/L" when the laboratory quantitated the amount of pollutant X in the
sample as being 15 |ig/L. For the nonquantitated results for each 'sample, the laboratories
reported a "sample-specific quantitation limit."5 For example, for the hypothetical-pollutant X,
2Some facilities reported the results in Ibs/day and included the flow rates for each day. EPA used this information to
convert the results to mg/L.

3Elsewhere in this document and in the preamble to the proposed rule, EPA refers to pollutants as "not detected" or
"nondetected." This section uses the term "not quantitated" or "nonquantitated" rather than nondetected.

4Elsewhere in this document and in the preamble to the proposed rale, EPA refers to pollutants as "detected." This
section uses the term "quantitated" rather than detected.

'Elsewhere in this document and in the preamble to the proposed rule, EPA refers to a "sample-specific quantitation
limit" as a "sample-specific detection limit" or, more simply, as a "detection limit."
4-2

-------
Section 4 - Analytical Methods and Baseline Values
the result would be reported as "<10 ug/L" when the laboratory could not quantitate the amount
of pollutant X in the sample. That is, the analytical result indicated a value less than the sample-
specific quantitation limit of 10 ug/L, meaning the actual amount of pollutant X in that sample is
between zero (i.e., the pollutant is not present) and 10 ug/L. The sample-specific quantitation
limit for a particular pollutant is generally the smallest quantity in the calibration range that can be
measured reliably in any given sample. If a pollutant is reported as not quantitated in a particular
wastewater sample, it does not mean that the pollutant is not present in the wastewater, merely
that analytical techniques (whether because of instrument limitations, pollutant interactions or
.other reasons) do not permit its measurement at levels below the sample-specific quantitation
limit. . •

In its calculations, EPA generally substituted the value of the reported sample-
specific quantitation limit for each nonquantitated result. In a few cases when the sample-specific
quantitation limit was less than the baseline value, EPA substituted the baseline value for the
nonquantitated result In a few instances when the quantitated value was below the baseline
value, EPA considered these values to be nonquantitated in the statistical analyses and substituted
the baseline value for the measured value. Section 4.3 further discusses these cases.
4.3
Nominal Ouantitation Limits
Protocols used for determining nominal quantitation limits in a particular method
depend on the definitions and conventions that EPA used at the time the method was developed.
As stated previously, the nominal quantitation limit is the smallest quantity of an analyte that can
be reliably measured with a particular method. The nominal quantitation limits associated with
the EPA methods addressed in the following sections fall into three general categories. The first
category includes Methods 1613B, 1625, and 1664, which use the minimum level (ML) definition
as the lowest level at which the entire analytical system must give a recognizable signal and an
acceptable calibration point for the analyte. The second category pertains specifically to Method
1620, and is explained in detail in Section 4.5.2. The third category pertains to the remainder of
the methods in which a variety of terms are used to describe the lowest level at which
measurement results are quantitated. These include the classical wetchemistry methods and.
several EPA methods for the determination of metals and organics. In some cases (especially with
the classical wet chemistry analytes), the methods are older (1970s and 1980s) and different
concepts of quantitation apply. These methods typically list a measurement range or lower limit
of measurement. The terms differ by method and, as discussed in subsequent sections, the levels
presented do not always represent the lowest levels laboratories can currently achieve. For those
methods associated with a calibration procedure, the laboratories demonstrated through a low
point calibration standard that they were capable of reliable quantitation at method-specified (or
lower) levels. In such cases, these nominal quantitation limits are operationally equivalent to the
ML (though not specifically identified as such in the methods). In the case of titrimetric or
gravimetric methods, the laboratory adhered to the established lower limit of the measurement
range published in the methods. Section 4.5 presents details of the specific methods.
4-3

-------
Section 4 - Analytical Methods and Baseline Values
4.4
Comparisons to Baseline Values
Depending on the analytical method, EPA performed one of two types of
comparisons of the concentration data to the baseline values. This subsection describes each type
of comparison and its application.
4.4.1
Comparison Type 1
Comparison Type 1 was used when the baseline value was based upon method-
defined minimum levels of Methods 1613B, 1625, or 1664 (see Section 4.5.1). For these
methods, the baseline values are based upon minimum levels (ML) that are developed through
inter-laboratory studies to determine the lowest measurable level (Section 4.5.1 provides a more
precise definition).

EPA applied Comparison Type 1 before using the data to calculate the long-term
averages and variability factors6 used for the proposed limitations and standards. EPA compared
each analytical result (i.e., quantitated value or sample-specific quantitation limit for a non-
quantitated value) to the baseline value for the pollutant. The objective of this comparison was to
identify any results reported below the method-defined ML of quantitation. Results reported
below the method-defined ML were changed to the ML to ensure that all results used by EPA
were quantitatively reliable. In addition, any quantitated value changed to the ML was also
considered to be nonquantitated7 in calculating the proposed limitations and standards. In most
cases, the quantitated values and sample-specific quantitation limits were equal to or greater than
the baseline values.

An example of Comparison Type 1: Suppose a facility dataset had five values for '
HEM, of which two were nonquantitated with sample-specific quantitation limits of 2 mg/L and 6
mg/L and the remaining three values were quantitated at 4 mg/L, 25 mg/L, and 50 mg/L. In
applying Comparison Type 1, EPA used the baseline value of 5 mg/L for HEM and compared this
to all five values. Because the sample-specific quantitation limit of 2 mg/L is less than 5 mg/L,
EPA changed this sample-specific quantitation limit to 5 mg/L. EPA also changed the quantitated
value of 4 mg/L to 5 mg/L and considered the value to be a sample-specific quantitation limit (i.e.,
nonquantitated) rather than a quantitated value. The remaining sample-specific quantitation limit
of 6 mg/L and the two quantitated values of 25 mg/L and 50 mg/L remained the same because
they were greater than the baseline value of 5 mg/L.
4.4.2
Comparison Type 2
Comparison Type 2 was used when the baseline value was based upon methods
that do not use the minimum level concept to define quantitation limits (i.e., all methods except
Methods 1613B, 1625, and 1664). The baseline values corresponding to Comparison Type 2
'Section 12 describes the calculations of long-term averages and variability factors.

7As explained in Appendix E, EPA applied different statistical assumptions to quantitated and nonquantitated results.
4-4

-------
Section 4 - Analytical Methods and Baseline Values
generally were the nominal quantitation limit associated with the method used for EPA's sampling
episodes. For example, total cyanide's baseline value of 0.02 mg/L is equal to the nominal
quantitation limit of 0.02 mg/L for total cyanide by Method 335.2, which was used to analyze
EPA samples. In the case of several pollutants, however, EPA determined that the baseline value
should differ from the nominal quantitation limit as specified in the method for the pollutant. EPA
made exceptions based upon its knowledge about the methods, experiences with laboratories
using those methods, and the need for a single baseline value for each pollutant. Section 4.5 notes
specific exceptions.

EPA applied Comparison Type 2 after using the data to calculate the long-term
average and the variability factors for each option and subcategory. In this comparison, EPA
compared the calculated long-term average to the baseline value for the pollutant. If the
calculated long-term average was less than the baseline value, EPA used the baseline value to
calculate the proposed limitation (which is calculated as the product of the long-term average and
the variability factor). EPA used this approach because some laboratories have demonstrated
that, under certain conditions, they can measure to levels lower than those specified in some of the
methods. EPA believes that these results are quantitatively reliable, and therefore can be used to
calculate long-term averages. However, EPA also recognizes that not all laboratories consistently
quantitate to these lower levels. To ensure the proposed limitations reflect "typical" laboratory
reporting levels for the approved methods, EPA established the long-term averages at values
equal to or greater than the reporting levels specified in the approved methods. Table 12-4
identifies the cases for which EPA used the baseline values instead of the calculated long-term
averages.

An example of Comparison Type 2: Suppose the long-term average for a
particular option was 2 mg/L, and the daily variability factor was 2.0. Further suppose that the
baseline value was 10 mg/L. Without this comparison, EPA would have proposed a limitation of
4 mg/L (=2 mg/L x 2.0), which is less than the baseline value of 10 mg/L. However, by
performing this comparison, EPA would have identified that the baseline value was greater than
the long-term average. As a result, EPA would .have substituted the baseline value for the long-
term average and proposed a limitation of 20 mg/L (=10 mg/L x 2.0).

The following subsection briefly describes the analytical methods and explains any
differences between the nominal quantitation limits and. the baseline values.
4.5
Analytical Methods
Table 4-1 summarizes the analytical methods, the associated pollutants measured
by the method, the nominal quantitation levels, the baseline levels, and the assumptions for values
reported below the baseline levels. The following subsections provide additional information
supporting Table 4-1 which is located at the end of Section 4. (The subsections are listed in the
order by method number.) ,

In developing the proposed limitations and standards, EPA generally used only
data from analytical methods approved for compliance monitoring or those that EPA has used for
4-5

-------
Section 4 - Analytical Methods and Baseline Values
decades in support of effluent limitations guidelines and standards development. The exceptions
included industry-supplied data from one facility. The facility did not .include any information on
the analytical methods corresponding to these reported concentration values. However, because
the data were collected at the sampling points specified for compliance monitoring, EPA has
assumed that the data were measured by analytical methods specified in or approved under 40
CFR Part 136 that facilities are required to use for compliance monitoring. (The remainder of this
section refers to such methods as 'NPDES-approved'8 or 'nonapproved.') For the final rule, EPA
intends to contact the facility to confirm its assumption for these data. Other exceptions were for
. nonapproved methods as explained in the following sections. Except for TSS determined by
Method 209C (see Section 4.5.3), EPA excluded data from nonapproved methods from its
calculations of limitations and standards. Pending receipt of additional information about such
data fronrthe industry, EPA will reevaluate the exclusion of these data for the final rule.
4.5.1
Methods 1613B, 1625,1664 (TCDF, Benzo(a)pyrene, Naphthalene, Phenol,
HEM)
As stated earlier, Method 1613B for dioxins, Method 1625 for semivolatile
organic compounds, and Method 1664 for HEM and silica gel treated n-hexane extractable
material (SGT-HEM)9 use the ML concept for quantitation of the pollutants measured by the
methods. The -ML is defined as the lowest level at which the entire analytical system must give a
recognizable signal and an acceptable calibration point for the analyte. When an ML is published
in a method, the Agency has demonstrated that at least one well-operated laboratory can achieve
the ML, and when that laboratory or another laboratory uses that method, the laboratory is
required to demonstrate, through calibration of the instrument or analytical system, that it can
make measurements at the ML.

For these methods, EPA's methodology is that if a quantitated value or sample-
specific quantitation limit was reported with a value less than the ML specified in a method, EPA
substituted the value of the ML and assumed that the measurement was nonquantitated. For
example, if the ML was 10 ug/L and the laboratory reported a quantitated value of 5 p.g/L, EPA
assumed that the concentration was nonquantitated with a sample-specific quantitation limit of 10
Of the analytes measured by these three methods, EPA is proposing to regulate
2,3,7,8-tetrachlorodibenzo-furan (TCDF) (Method 1613B); benzo(a)pyrene, naphthalene, and
phenol (Method 1625); and HEM (Method 1664). For these pollutants, EPA selected the ML as
basis for the baseline values. None of the reported values from these methods were less than the
ML; therefore, no substitutions were made to data from EPA's sampling episodes. However, in
calculating the limitations and standards for naphthalene, EPA also included data generated from
Method 625 (see Section 4.5.14).
8NPDES is the acronym for the National Pollutant Discharge Elimination System.

'SGT-HEM measures nonpolar. material (i.e., n-hexane extractable material that is not absorbed by silica gel). Method
1664 measures both oil and grease and nonpolar material.
4-6

-------
Section 4 - Analytical Methods and Baseline Values
4.5.2
Method 1620 and 200.7 (Chromium, Lead, Mercury, Nickel, Selenium, Zinc)
Method 1620 for metals determination uses the concept of an instrument detection
limit (IDL), which is.defined as "the smallest signal above background noise that an instrument
can detect reliably."10 EPA used Method 1620 to determine metals in the samples collected
during its sampling episodes. While Method 1620 is not an approved method for compliance
monitoring, it represents a consolidation of several 40 CFR 136 approved methods such as
Method 200.7 (inductively coupled plasma atomic emission (ICP) spectroscopy for trace
elements) and Method 245.1 (mercury by cold vapor atomic absorption technique). Some
industry-supplied results for chromium, lead, nickel, and zinc were determined by Method 200.7.
Other industry-supplied results for metals were determined by Methods 239.2, 245.1, 3120B,
3130B, as discussed in Sections 4.5.5 through 4.5.8. In calculating the proposed limitations and ,
standards, EPA included data from these methods and also chromium and nickel data for which
industry'did not identify the analytical methods used. . '

Data-reporting practices for Method 1620 analysis follow conventional metals
reporting practices used in other EPA programs, in which values are required to be reported at or
above the IDL. In applying Method 1620, each analytical laboratory participating in the data
gathering efforts by EPA's Engineering and Analysis Division (BAD) determine IDLs on a
quarterly basis. The IDLS are, therefore, laboratory- and time-specific. Though Method 1620
does contain MLs, these MLs predate EPA's recent refinement of the minimum level concept
described in Section 4.5.1. The ML values associated with Method 1620 are based on a
consensus reached by EPA and laboratories during the 1980s regarding levels that could be
considered reliable quantitation limits when using Method 1620. These limits do not reflect
advances in technology and .instrumentation since the 1980s. Consequently, EPA used the IDLs
as the lowest values for reporting purposes,' with the general understanding that reliable results
can be produced at or above the IDL.

EPA is proposing to regulate chromium, lead, mercury, nickel, selenium, and zinc.
For the samples collected during its sampling episodes, EPA used Method 1620 to measure these
analytes. The Agency used the Method 1620 ML values as the baseline values for these analytes,
with the exception of lead. In Method 1620, lead has an ML of 5 ug/L for graphite furnace"
atomic absorption (GFAA) spectroscopy analysis; EPA determined, however, that it was not
necessary to measure down to such low levels, and that lead could instead be analyzed by
inductively coupled plasma atomic emission (ICP) spectroscopy. Consequently, for the purposes
of EAD's data gathering efforts, the required ML for lead was adjusted to 50 ug/L.

Though the baseline values were derived from the ML (or adjusted ML) in Method
1620, EPA used the laboratory-reported quantitated values and sample-specific quantitation
limits, which captured concentrations down to the IDLs, in calculating the proposed limitations
and standards. EPA calculated each limitation and standard as the product of the long-term
'"Keith, L.H., W. Crummett, J. Deegan, R.A. Libby, J.K. Taylor, G. Wentler. "Principles of Environmental Analysis,"
Analytical Chemistry, Volume 55, 1983, Page 2217.
4-7

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Section 4 - Analytical Methods and Baseline Values
average and the variability factor. If the long-term average for a pollutant was less than the
baseline value, EPA used the baseline value instead of the long-term average in the calculations.
This was the case for lead for several subcategories (see Table 12-4).
4.5.3
Method 160.2,209C, and 2540D (Total Suspended Solids)
Total suspended solids (TSS) was determined by Method 160.2 for samples
collected by EPA and some samples collected by the industry. Industry also used Method 209C
and 2540D to measure TSS. (EPA also used TSS data for which industry did not identify the
analytical methods used.) Methods 160.2 and 2540D are NPDES-approved and are essentially
identical methods. While it is not currently NPDES-approved, Method 209C for TSS appears in
the 15th and 16th editions of Standard Methods and was approved in the CFR in 1986. Since
then, the method numbers have been updated.in more recent editions of Standard Methods and in
the CFR, but the analytical procedures hi Method 209C are identical to those of Method 2540D.
Therefore, EPA determined that the data from all three methods should produce similar results
and thus are usable for the purposes of rulemaking development.

Because EPA used Method 160.2 for its sampling episodes, the Agency selected
the nominal quantitation limit of 4 mg/L from Method 160.2 as the basis for the baseline value. In
calculating the proposed limitations and standards, EPA used the laboratory-reported quantitated
values and sample-specific quantitation limits. If the long-term average was less than the baseline
value, however, EPA substituted the baseline value for the long-term average. This was the case
for the TSS new source performance standard (NSPS) for the Stainless Steel Segment of the
Steel Finishing Subcategbry.'
4.5.4
Method 218.4 (Hexavalent Chromium)
For EPA-collected samples, hexavalent chromium was determined by Method
218.4, an NPDES-approved procedure that utilizes atomic absorption for the determination of .
hexavalent chromium after chelation and extraction. In developing the proposed limitations and
standards, EPA included industry-supplied data for which industry did not cite the analytical
methods used. Industry also supplied data determined by Method 3120. Because of concerns
about the use of this method (see Section 4.5.7), EPA excluded these data from the calculation of
the proposed limitations and standards.

In Method 218.4, the nominal quantitation limit or lower limit of.the measurement
range is 0.01 mg/L. Because EPA used this method, this nominal quantitation limit was used as
the baseline value used for all hexavalent chromium results. None of the hexavalent chromium
data determined by Method 218.4 had quantitated values or sample-specific quantitation limits
lower than the baseline value.
4.5.5
Method 239.2 (Lead)
In developing the proposed limitations and standards for lead, EPA included
industry-supplied data from Method 239.2. This NPDES-approved method utilizes atomic
4-8

-------
Section 4 - Analytical Methods'and Baseline Values
absorption as the determinative technique to measure lead. Its nominal quantitation limit of 0.005
mg/L is expressed in the method as the lower limit of the measurement range.1'

The industry-supplied lead data included results that were lower than the baseline
value. EPA used these values as reported in calculating the long-term averages and variability
factors. Before using the long-term averages to calculate the proposed limitations and standards,
EPA compared the long-term averages to the baseline value of 0.05 mg/L for lead (see Section
4.5.2). Because the calculated long-term averages were less than the baseline value, EPA used
the baseline value instead of the calculated long-term averages in developing the proposed Iea4
limitations and standards.
4.5.6
Method 245.1 (Mercury)
In developing the proposed limitations and standards for mercury, EPA included
industry-supplied data from Method 245.1. This NPDES-approved method utilizes cold vapor
atomic absorption as the determinative technique to measure mercury. Its nominal quantitation
limit of 0.0002 mg/L is expressed in the method as the lower limit of the measurement range12

The industry-supplied mercury data included results lower than the baseline value
(see Section 4.5.2). EPA used these data as reported in calculating the long-term averages and
variability factors. Before using the long-term averages to calculate the proposed limitations and
standards, EPA compared the long-term averages to the baseline value for mercury. None of the
long-term averages were less than the baseline value.
4.5.7
Method 3120B (Chromium and Hexayalent Chromium)
Industry-supplied results for chromium and hexavalent chromium were determined
by Method 3120B, an inductively coupled plasma (ICP) method. Its nominal quantitation limit of
0.01 mg/L is cited in the method as the lower limit of the measurement range.

Method 3120B is NPDES-approved for chromium determination and EPA
included these data in calculating the chromium limitations and standards. (As described in ,
Section 4.5.2, EPA used Method 1620 to determine chromium in the samples it collected.) None
of the chromium data from Method 3120B had quantitated values or sample-specific quantitation
limits lower than the baseline value of 0.01 mg/L (see Section 4.5.2).

Because of EPA's concerns about the quality of the hexavalent chromium
measurements from Method 3120B, EPA excluded them when developing the proposed
limitations and standards. Method 3120B is used for determination of total metals (including
chromium), but is not typically used for hexavalent chromium determination. It is technically
possible to analyze for hexavalent chromium by this method if, during sample preparation, the
''This method refers to the lower value of the "optimum concentration range."

12This method calls it a detection limit.
4-9

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Section 4 - Analytical Methods and Baseline Values
hexavalent chromium is separated from other forms of chromium (i.e., Cr+3). For the final rule,
EPA will reevaluate its decision to exclude these data pending a full review of the laboratory
reports (if industry provides them to EPA), to determine if the appropriate procedures were
followed, and to determine if all quality assurance/quality control (QA/QC) criteria were met.
The industry-supplied data from Method 3120B included quantitated values or sample-specific
quantitation limits lower than the baseline value for hexavalent chromium (see Section 4.5.4). If
EPA determines that it is appropriate to .use these data in calculating the limitations and standards,
EPA will use the quantitated values or sample-specific quantitation limits as reported. However,
before using the long-term averages to calculate the limitations and standards, EPA will compare
the long-term averages to the baseline value. If any long-term average is less than the baseline
value, then EPA will use the baseline value in calculating the limitations and standards.
4.5.8
Method 3130B (Lead, Zinc)
Method 31 SOB was used to determine lead and zinc in some industry-supplied
data. Method 3130B is an anodic stripping voltammetry (ASV) method that does not require
sample digestion. EPA has excluded these data in developing the proposed rule for three reasons.
First, EPA must still determine whether samples were acid digested. EPA requires acid digestion
of samples for determination of total lead and zinc to ensure that lead and zinc complexes are
broken down to a detectable form, and to reduce analytical interferences. Second, EPA must
determine whether the results are associated with acceptable laboratory and matrix QA/QC.
Finally, as there are no NPDES-approved ASV methods for the determination of lead or zinc in
wastewater, EPA must assess if the application of the ASV method to wastewater effluents
analyzed was appropriate (i.e., not subject to substantial interferences).

EPA will reconsider its decision to exclude data if and when industry provides the
associated laboratory reports and QA/QC data. If review of the reports and QA/QC data shows
that proper digestion was performed, that the method was in control, and that the method was
successfully applied to the effluents, EPA may use the data in developing the final rule.

The industry-supplied data from Method 3130B included quantitated values or
sample-specific quantitation limits lower than the baseline value for zinc (see Section 4.5.2). If
EPA determines that it is appropriate to use these data in calculating the limitations and standards,
EPA will use the quantitated values or sample-specific quantitation limits as reported. However,
before using the long-term averages to calculate the limitations and standards, EPA will compare
the long-term averages to the baseline value. If any long-term average is less than the baseline
value, then the baseline value will be used rather than the long-term average.
4.5.9
Method 335.2 (Total Cyanide)
EPA and industry determined total cyanide using Method 335.2, which is an
NPDES-approved method for determining total cyanide. Industry also used Method 4500 CN-E
to determine total cyanide.
4-10

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Section 4 - Analytical Methods and Baseline Values
The nominal quantitation limit for Method 335.2 is expressed in the method as the
lower limit of the measurement range.13 Because EPA used Method 335.2, the Agency used its
nominal quantitation limit of 0.02 mg/L as the baseline value for all total cyanide results.
Although some'laboratories have demonstrated that they can quantitate to lower levels, none of
the total cyanide data determined .from Method 335.2 had quantitated values or sample-specific
quantitation limits lower than the baseline value.

For total cyanide, industry also used the NPDES-approved 4500-CN procedures
for sample analysis. In the listings of data for the proposal, EPA has identified this procedure
with three different references provided by industry: 4500-CNC; 4500 CN E; and 4500-CNE.
Method 4500-CNC refers to the distillation process used to prepare samples for analysis and
Methods 4500 CN E and 4500-CNE refer to the colorimetric method of cyanide determination.
EPA compared the data determined from these analyses to the baseline value of 0.02 mg/L
associated with the nominal quantitation limit from Method 335.2. These values were used as
reported in calculating the long-term averages and variability factors.. Before using the long-term
averages to calculate the proposed limitations and standards, EPA compared the long-term
averages to the baseline value. None of the long-term averages were less than the baseline value.
4.5.10
Method 340.2 (Fluoride)
For samples collected by EPA, fluoride was determined by Method 340.2, an
NPDES-approved potentiometric method that uses a fluoride electrode. Industry did not supply
any additional data for this analyte. The nominal quantitation limit of 0.1 mg/L for Method 34Q.2
is expressed in the method as the lower limit of the measurement range,14 and was used as the
baseline value for fluoride. None of the fluoride data had quantitated values or sample-specific
quantitation limits lower than the baseline value.
4.5.11
Methods 350.2, 417/350.2, and 4500-NH3 (Ammonia as Nitrogen)
For EPA's sampling episodes, ammonia as nitrogen was determined by Method
350.2. Industry also supplied data determined by Methods 417/350.2 and 4500-NH3. In
developing the proposed limitations and standards, EPA also included industry-supplied data for
which industry did not identify the analytical methods used.

Method 350.2 uses either colorimetric, titrimetric, or electrode procedures to
measure ammonia, and has a lower measurement range limit of 0.05 mg/L for the colorimetric and
electrode procedures and 1.0 mg/L for the titrimetric procedure. Rather than use different
baseline values, EPA used 0.05 mg/L because it represented a value at which ammonia as N can
be reliably measured by several determinative techniques in Method 350.2, as well as in other 40
'3The method states that is "sensitive to about 0.02 mg/L for the colorimetric procedure; the titrimetric procedure is used
for measuring concentrations above 1 mg/L," so these do represent the lower limit of the measurement range.

14The method states that "Concentrations from 0.1... may be measured."
4-11

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Section 4 - Analytical Methods'and Baseline Values
CFR 136 approved methods.15 None of the ammonia-as-nitrogen data had quantitated values or
sample-specific quantitation limits lower than the baseline value.

One facility supplied concentration data and reported the method as '417/350.2.'
Based on additional information received from the facility, the method utilized is equivalent to
NPDES-approved Method 350.2; therefore, EPA included these data in developing the proposed
limitations and standards.

Some facilities used the 4500-NH3 procedure. In the listings of data for the
proposal, EPA has identified this procedure in four different ways: 4500-NH3; 4500NH, BE;
4500NH3-E; and 4500:NH3F. With the exception of Method 4500-NH3, which is a general
method citation applicable to a group of specific methods, all these citations refer to 40 CFR 136
approved procedures for ammonia as nitrogen. 4500-NH3-B refers to the primary distillation step
performed prior to analysis. 4500-NH3-E refers to the ammonia-selective electrode determinative
technique, and 4500-NH3-F refers to the spectrophotometric determination of ammonia by
reaction with phenate. For the final rule, EPA will verify that approved techniques were utilized
for the data identified only as Method 4500-NH3.

EPA compared the data determined by these three methods to the baseline value of
0.05 mg/L that was derived from Method 350.2 because this is the method associated with EPA's
sampling episodes. None of the ammonia-as-nitrogen data had quantitated values or sample-
specific quantitation limits lower than the baseline value.
4.5.12
Methods 353.1, 353.2, and 353.3 (Nitrate/Nitrite)
The preamble to the proposed rule solicits comments on whether nitrate/nitrite
should be regulated. Nitrate/nitrite can be determined by three EPA methods, each of which lists
slightly different nominal quantitation limits which are expressed in the methods as the lower limit
of the measurement range. Methods 353.1 and 353.2 are automated colorimetric procedures with
quantitation limits of 0.01 and 0.05 mg/L, respectively. Method 353.3 is a cadmium reduction,
spectrophotometric procedure with a nominal quantitation limit of 0.01 mg/L. If EPA determines
that regulation of nitrate/nitrite is necessary, it intends to use the Method 353.1 quantitation limit
of 0.01 mg/L as the baseline value. Before using the long-term averages to calculate the
limitations and standards, EPA will compare the long-term averages to the baseline value. If any
long-term average is less than the baseline value, then EPA will use the baseline value rather than
the long-term average in calculating the limitations and standards.
4.5.13
Methods 4500-CN M and D4374-98 (Thiocyanate)
Because no NPDES-approved method exists for thiocyanate, EPA is proposing
two consensus standards, Method 4500-CN M rStandard Methods for the Examination of Water
"To demonstrate compliance, facilities are required to use analytical methods that are capable of measuring the
concentration levels required by the promulgated limitations and standards.
4-12

-------
Section 4 - Analytical Methods and Baseline Values
and Wastewater. 20th Edition, 1998) and D4374-98 (Annual Book of ASTM Standards. Volume
11.02, 1999). In the preamble to the proposed rule, EPA solicits comments on these standards
and, specifically, invites the public to identify additional potentially applicable voluntary consensus
standards and to explain why such standards should be used to measure thiocyanate. For the data
used to calculate the proposed limitations and standards, EPA and industry used the 4500-CN M
procedure in determining the concentrations. EPA has not collected data to calculate the
proposed limitations for thiocyanate by ASTM Method D4374-98. Because it wishes to provide
facilities with additional options for test methods, EPA solicits comments on this method.
Method D4374-98 is an automated procedure that has been shown to generate reliable results,
with the added advantage of potentially eliminating more interferences than other methods from
sample matrices.

In the listings of the data used to. calculate the proposed limitations and standards,
EPA has identified this method in three ways: 4500-CN; 4500-CN M.; and 4500CN-M. EPA has
confirmed that the associated data were all generated by Method 4500-CN M. The nominal
quantitation limit for Method 4500-CN M is cited in the method as the lower limit of the
measurement range.16 Because EPA used Method 4500-CN M, the Agency used its nominal
quantitation limit of 0.1 mg/L as the baseline value for all thiocyanate results. None of the
tiiiocyanate data had quantitated values or sample-specific quantitation limits lower than this
baseline value.
4.5.14
Method 625 (Naphthalene)
In developing the proposed limitations and standards for naphthalene, EPA
included industry-supplied data from Method 625. This is an NPDES-approved GC/MS method
for semivolatile organics. Its nominal quantitation limit is expressed as the lower limit of the
measurement range, typically the concentration of the lowest calibration standard. EPA selected
0.01 mg/L as the baseline value based on the minimum level for Method 1625 (see Section 4.5.1).

The industry-supplied naphthalene data included quantitated values or sample-
specific quantitation limits lower than the baseline value. EPA replaced these data with the value
of the baseline value and assumed that the measurements were nonquantitated in developing the
limitations and standards. .
4.5.15
Method 8270 (Benzo(a)pyrene)
Industry supplied benzo(a)pyrene data generated from Method 8270 that is not
approved for NPDES compliance monitoring. EPA recognizes that a number of similarities exist
between Method 8270 and NPDES-approved methods. The estimated quantitation limit of 10
ug/L for benzo(a)pyrene in Method 8270 is the same as Method 1625's ML, which is also the
basis for the baseline value for this analyte. Many of the QC checks and procedures of Method
8270 are analogous to procedures utilized by the approved NPDES methods, Method 625 in
16The method lists this value as the lower limit under "application" in natural waters or wastewaters.
4-13

-------
Section 4 - Analytical Methods and Baseline Values
particular. However, one major drawback for Method 8270 is that it only requires a subset of
target analytes to be evaluated in the matrix spike, while Method 625 requires a full target analyte
matrix spike. Furthermore, the calibration requirement in Method 8270 could be interpreted to
mean that the calibration standard should be at or below the known or anticipated regulatory
compliance level.

Because of the reasons expressed above, EPA has concerns about the quality of
the benzo(a)pyrene data generated by Method 8270. Consequently, EPA excluded them from
developing the proposed limitations and standards. For the final rule, EPA will reconsider using
these data pending a full review of the laboratory reports (if industry provides them to EPA)
including initial precision and recovery (IPR) analyses, instrument tunes, calibrations, blanks,
laboratory control sample (LCS) analyses, matrix spikes, surrogates, and all sample data. EPA
will review any submitted calibration data to confirm that the GC/MS was calibrated at the ML of
10 ug/L, thereby demonstrating that reliable measurements could be made to this level. EPA will
also evaluate the data to determine if appropriate extraction and cleanup procedures were used in-
analyzing the samples.

The industry-supplied data from Method 8270 included quantitated values or
sample-specific quantitation limits lower than the baseline value. If EPA determines that it is
appropriate to use these data in calculating the limitations and standards, EPA may replace these
data with the value of the baseline value and assume that the measurements are nonquantitated.
4.5.16
Methods 330.1,330.2, 330.3,330.4, 330.5 (Total Residual Chlorine)
The proposed limitations and standards for total residual chlorine are based upon
limitations and standards developed during the 1982 Iron and Steel rule. The term "total residual
chlorine" is used interchangeably with "chlorine" and, in aqueous samples, represents a measure
of both free and combined chlorine that is present in the sample.

To comply with;the proposed limitations and standards* a facility will be required
to use an NPDES-approved method such as Method 330.1, 330.2, 330.3, 330.4, or 330.5 to
ensure that it implemented appropriate analytical protocols.

If EPA collects or the industry supplies appropriate data from the model
technologies prior to promulgation of the final rule, EPA will compare the long-term average to
the baseline value of 0.1 mg/L derived from the quantitation limits in Methods 330.3 and 330.4.
If any values are less than the baseline value, they will be used as reported. However, EPA will
compare the baseline value to the long-term averages used in calculating the final limitations and
standards. If any long-term average is less than the baseline value, the baseline value will be used
for purposes of calculating the limitations and standards.
4-14

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                                                  Section 4 - Analytical Methods and Baseline Values
4.6

4-1


4-2
References

U.S. Environmental Protection Agency. Methods for Chemical Analysis of Water
and Wastes.  EPA 821-C-99-004. Washington, D.C., June 1999.

American Public Health Association, American Water Works Association, and
Water Environment Federation.  Standard Methods for the Examination by Water
and Wastewater. 20- Edition.  Washington. B.C.. 1998.
                                         4-15

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                          Section 4 - Analytical Methods and Baseline Values
                Table 4-1
Analytical Methods and Baseline Values
Analyte
Ammonia as Nitrogen
Fluoride
Hexane Extractable
Material (HEM)
Nitrate/Nitrite
Thiocyanate
Total Cyanide
Total Residual Chlorine
Total Suspended Solids
(TSS)
Chromium
rlexavalent Chromium
Chemical
Abstract
Service
(CAS)
Number
7664417
16984488
C036
COOS
302045
57125
7782505
C009
7440473
18540299
Baseline
Value
(mg/L)
0.05
0.1
5
0.01
0.1
0.02
0.1
4
0.01
0.01
Samples
Collected and
Analyzed by
EPA, Industry
Industry
EPA
EPA
C
EPA
EPA
Industry
Proposed
EPA, Industry
Industry
e
EPA, Industry
Industry
EPA
Industry
EPA
Industry
Method
Used to
Analyze
Samples
350.2
417/350.2
4500-NH3
4500-NH3F
4500NH,
BE
4500NH3-E
NA
340.2
1664
353.1
4500-CN
4500-CN
M.
4500CN-M
D4374-98
335.2
4500 CN E
4500-CNC
4500-CNE
330.1 -
330.5
160.2
160.2
209C
2540 D
NA
1620
200.7
3120B
NA
218.4
3120B
NA
Nominal
Quantitation
Value (mg/L)
for Method
0.05
0.05
0.1"
0.1
0.8
0.8
NA
0.1
5
0.01
0.1
0.1
0.1
0.0001
0.02
.005
.005"
.005
O.lf
4
4
4
4
NA
0.01
0.01
• o.oi
NA
0.01
NI
NA
Assumption for
Reported Values "
< Baseline Value
(BV)
A1UBV
AllaBV
AllsBV
All ;>BV
All sBV
All ;>BV .
All^BV
AllsBV
AllsBV
C
AllsBV
AlliBV
AJliBV
See §4.5.13
AllsBV
AllsBV
AllsBV
Used as reported
C
A1UBV
Used as reported
Used as reported
All ;>BV
Used as reported
Used as reported
Used as reported
All ;>BV
All ;>BV
All^BV
Excluded data
All sBV
                   4-16

-------
                                                                           Section 4 - Analytical Methods and Baseline Values
                                                Table 4-1 (Continued)
Analyte
Lead
VIercury
Nickel
Selenium
Zinc
3enzo(a)pyrene
•Japhthalene
Total Phenol
2,3,7,8-
Tetrachlorodibenzofuran
(TCDF)
Chemical
Abstract
Service
(CAS)
Number
7439921
7439976
7440020
7782492
7440666
50328
91203
108952
51207319
Baseline
Value
(mg/L)
0.05
0.0002
0.04
0.005
0.02
0.01
0.01

0.01
lOpg/L
Samples
Collected and
Analyzed by
EPA
Industry
EPA
Industry
EPA
Industry
EPA
EPA
Industry
EPA
Industry
EPA
Industry
EPA
EPA
Method
Used to
Analyze
Samples
1620
200.7
239.2
3130B
1620 .
245.1
1620
200.7
NA
1620
1620
200.7
3130B
1625
8270
1625
625
1625
1613B
Nominal
Quantitation
Value (mg/L)
for Method
0.05
0.05
0.005
MI
0.0002
0.0002
0.04
0.04
NA
0.005
• 0.02
0.02
NI
0.01
0.01
0.01 •
0.01
0.01
lOpg/L
Assumption for
Reported Values "
< Baseline Value
(BV)
Used as reported
Used as reported
Used as reported
Excluded data
Used data as
reported
A11>BV
Used as reported
Used as reported
Used as reported
AllsBV
Used as reported
Used as reported
Excluded data
Used as reported
Excluded data
All kBV
Modified to BV
AllsBV
AllsBV
NA - The facility did not provide the specific analytical method. However, because the data were collected at the sampling points specified for
complaiance monitoring, EPA assumed that the methods would have been NPDES-approved methods that facilites are required to use for compliance
monitoring
NI - EPA needs information form the facility about the laboratory analysis.                          -
"If the entry in this column indicates that EPA "used as reported" for a particular analyte, then EPA used either the quantitated value or the sample-
specific quantitation limit reported by the laboratory.
bFor some of the industry-submitted data, "4500-NH3" was cited as the method used. This reference is vague in mat it potentially refers to seven
different procedures. Consequently, EPA has listed the lowest of the measurement ranges cited in the methods.
'EPA is soliciting comment on whether'nitrate/nitrite should be regulated (see Section Ix.G.2.a in the preamble to the proposed rulemaking). EPA
used data sources other than its sampling episodes as a basis for evaluating this pollutant. If EPA decides to regulate this pollutant, Method 353.1 is
likely to be the basis of the baseline value used in calculating the final limitations and standards for nitrate/nitrite.
dMethod 4500-CN-C is the distillation process by which to prepare samples for analysis by either 4500-CN-D or -E.  Because EPA does not have
complete information on which determinative technique industry used, the quantitation limit reflected in the citation for 4500-CN-C is the lower
quantitation limit of the two procedures.
°EPA is proposing effluent limitations and standards for total residual chlorine based upon data from the 1982 rule (see Section 12.2.1.1  for further
discussion). In measuring for total residual chlorine in its sampling episodes for the final rule, EPA intends to use Methods 330.1 - 330.5.
'Baseline  value and nominal quantitation limit are based on capabilities of approved EPA methods.
                                                              4-17

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Section 5 - Description of the Industry
SECTIONS

DESCRIPTION OF THE INDUSTRY

The United States is the third largest steel producer in the world with 12 percent.
of the market, an annual output of approximately 105 million tons per year, and nearly 145,000
employees. The iron and steel rule would apply to approximately 254 iron and steel sites. The
254 sites are owned by 115 companies, as estimated by the EPA survey. The global nature of the
industry is illustrated by the fact that 18 companies have foreign ownership. Twelve other
companies are joint entities, with at least one U.S. company partner. Excluding joint entities and
foreign ownership, 85 are U.S. companies, more than half of which are privately owned.

• This section describes the iron and steel industry, including types of sites and the
manufacturing operations performed. All estimates included in this section represent 1997 data.
5.1
Types of Sites
For purposes of the proposed rule, EPA classified manufacturing facilities in the
iron and steel industry into three groups on the basis of raw material consumption and
manufacturing processes: integrated steel mills, non-integrated steel mills, and stand-alone
facilities. Integrated and non-integrated mills produce molten steel by different methods. Stand-
alone facilities include certain raw material preparation facilities and steel forming and finishing
mills. Stand-alone facilities do not produce molten steel.

Integrated steel mills produce molten iron in blast furnaces using coke, limestone, •
beneficiated iron ore, and preheated air as the principal raw materials. Other raw materials may
include sinter, other iron-bearing materials, oxygen, and alternate sources of carbon. These mills
charge molten iron (or hot metal) and steel scrap to basic oxygen furnaces (BOFs) to produce
molten steel. Depending on final product specifications, the molten steel then undergoes various
refining steps prior to casting, hot forming, and finishing operations. Several integrated mills also
have cokemaking and sintering plants that produce raw materials for blast furnace operations.
There are 20 integrated steel mills located in the United States that account for approximately 60
percent of annual raw steel production.

Non-integrated steel mills produce molten steel by melting steel scrap in electric
arc furnaces (EAFs). Some non-integrated steel mills also use high-quality iron materials such as
pig iron or direct reduced iron with scrap. As at integrated mills, the molten steel undergoes
various refining, casting, hot forming, and finishing operations. There are about 94 non-
integrated steel mills located in the United States that account for approximately 40 percent of
annual raw steel production.

Figure 5-1 shows the steelmaking, refining, and casting operations that occur at
integrated and non-integrated steel mills. Figure 5-2 shows the various hot forming and finishing
operations that steel may undergo to form semi-finished or finished products. . . .•
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                                                              Section 5 - Description of the Industry
               Stand-alone mills that do not produce molten steel conduct many of the hot
 forming and steel finishing operations conducted at integrated and non-integrated steel mills. A
 number of stand-alone operations produce raw materials for ironmaking and steelmaking (e.g.,
 by-product and non-recovery coke plants, sinter plants, and direct reduced iron plants).  There are
 approximately 138 different types of stand-alone facilities located in the United States, described
 below:

               •       Coke plants and sinter plants manufacture feed materials for blast furnaces.

               •       Direct reduced ironmaking plants manufacture feed materials for electric
                      arc furnaces.

               •       Stand-alone hot forming mills receive cast products from integrated and
                      non-integrated steel mills. These facilities perform hot forming operations
                      and, depending on the product, a limited number may perform steel
                      finishing operations.

               •       Finishing operations include acid pickling and descaling, cold rolling and
                      annealing, acid and alkaline cleaning, and coating operations such as
                      electroplating and hot coating.  Stand-alone carbon steel finishing mills may
                      perform acid pickling, cold rolling and annealing, acid and alkaline
                      cleaning, electroplating, and hot coating on carbon steel products received
                      from other mills.  Stand-alone stainless steel finishing mills typically
                      perform acid pickling and descaling and cold rolling and annealing
                      operations on stainless steel products received from other mills.

               •       Stand-alone pipe and tube mills include:

                      —    Facilities that manufacture butt-welded or seamless pipe and tube
                            through hot forming operations,

                      —    Facilities that manufacture pipe and tube using other operations
                            such as electric resistance welding, and

                      —    Facilities that receive pipe and tube and perform other operations,
                            such as drawing.

                      Only the stand-alone pipe and tube mills that manufacture butt-welded or
                      seamless pipe and tube through hot forming operations are included in the
                      proposed regulation for the Iron and Steel Category.

              Table 5-1 presents EPA's national estimates of the types of iron and steel sites in
the United States. Non-integrated steel mills outnumber integrated steel mills by more than four
to one.  Stand-alone finishing facilities form the second largest group,  and stand-alone hot
forming facilities form the third largest group. This reflects two trends in the industry over the
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Section 5 - Description of the Industry
past 25 years - a shift of steel production from older, larger integrated steel mills to newer, smaller
non-integrated steel mills, and the emergence of specialized, stand-alone finishing facilities that
process semi-finished sheet, strip, bars, and rods obtained from integrated or non-integrated
facilities.

Integrated steel mills are primarily located east of the Mississippi River in Illinois,
Indiana, Michigan, Ohio, Pennsylvania, West Virginia, Maryland, Kentucky, and Alabama; one
integrated steel mill is located 'in Utah. Figure 5-3 shows the locations in the United States of
integrated steel mills. Stand-alone coke plants and those at integrated steel mills are located in
Illinois, Indiana, Michigan, Ohio, New York, Pennsylvania, Virginia, Kentucky, Alabama, and
Utah. Figure 5-4 shows the locations in the United States of stand-alone and colocated coke
facilities. Non-integrated steel mills are located throughout the continental United States, as are
stand-alone hot forming and finishing mills. '

For purposes of the proposed iron and steel rule, EPA classified steel produced at
integrated and non-integrated steel mills as carbon steels, alloy steels, and stainless steels. Carbon
steels owe their properties to varying concentrations of carbon, with relatively low concentrations
of alloying elements (i.e., less than 1.65 percent manganese, 0.60 percent silicon, 0.60 percent
copper). Alloy steels contain concentrations of manganese, silicon, or copper greater than those
for carbon steels, or other specified alloying elements added to impart unique properties to the
steel. Stainless steels are a subset of alloy steels that are corrosion resistant and heat resistant.
The principal alloying elements are chromium, nickel, and silicon. Industry practice is to call
steels stainless when the chromium content is 10 percent or greater.

Table 5-2 lists the types of steels manufactured or processed at integrated and
non-integrated steel mills and stand-alone hot forming, finishing, and pipe and tube mills, as
reported in industry surveys. All integrated steel mills produce carbon steels. Some also produce
alloy steels and process stainless steels. Based on industry survey responses, 56 of the 66
surveyed non-integrated steel mills, 14 of the 17 surveyed stand-alone hot forming mills, and 28
of the 38 surveyed stand-alone finishing mills produce or process carbon steels.

Steel mills may discharge wastewater directly to surface water (direct discharge),
to publicly owned treatment works (POTWs) (indirect discharge), or not at all (zero or alternative
discharge). Table 5-3 shows the discharge status of integrated and non-integrated steel mills and
stand-alone facilities that would be subject to a revised 40 CFR Part 420. A single mill may
discharge process wastewater from one operation directly to surface waters and from another
operation indirectly to a POTW. All but one integrated mill are direct dischargers; two discharge
both directly and indirectly. The Agency's national estimate for non-integrated steel mills is, out
of 94 mills, 46 are direct dischargers, 32 are zero or alternative dischargers, and 19 are indirect
dischargers. For the 70 stand-alone finishing mills, the Agency national estimate is 34 indirect
dischargers, 28 direct dischargers, and 11 zero or alternative dischargers.
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5.2
Manufacturing Operations
The following subsections describe the types of manufacturing operations
performed at integrated and non-integrated steel mills and stand-alone iron and steel facilities.
Information presented includes production and capacity, wastewater generation, discharge
destinations, and discharge type. Table 5-4 presents the various manufacturing operations, the
national estimate of sites for each type of operation, the national estimate of production, and the
national estimate of production capacity by operation.
5.2.1
Cokemaking
Blast furnaces use carbon in the form of metallurgical coke to reduce iron oxides
to metallic iron. Foundries also use metallurgical coke for similar purposes. There are two types
of coke plants operated in the United States: (1) the traditional by-product recovery coke plant, in
which coke, coke oven gas, and several chemical by-products are derived from coal; and (2) non-
recovery or heat recovery coke plants, hi which the only by-product is. heat, which is used to
generate steam and electric power. There are 24 by-product recovery coke plants and two non-
recovery coke plants located in the United States. By-product recovery plants produce
approximately 90 percent of the coke. Coke used for blast furnace operations is called furnace
coke, while coke used for foundry operations is calledfoundry coke. Presently, foundry coke is
produced only in by-product coke plants, whereas furnace coke is produced in both by-product
recovery and non-recovery coke plants. Of the 24 coke plants, 19 primarily produce blast furnace
coke, four primarily produce foundry coke, and one routinely produces both.

By-Product Recovery Coke Plants

By-product recovery coke plants comprise coal handling and preparation facilities,
one or more coke batteries (i.e., groups of 40 or more vertical, slot-type coke ovens located side
by side) equipped with coal charging and coke pushing equipment, coke oven gas collection and
cleaning facilities, by-product recovery systems, coke quenching stations, and associated air and
water pollution control facilities and solid waste processing operations.

Blends of high-, low-, and medium-volatile, coals and other carbonaceous materials
such as petroleum coke are pulverized and screened to desired size (e.g., > 80 percent, minus 1/8
inch) and charged into the tops of coke ovens with charging machines called larry cars. The
ovens are operated on a sequential batch basis. The ovens are positive pressure ovens in which,
the coal charge is heated in the absence of air to drive off volatile materials and water to leave the
carbonaceous residue called coke. Different blends of coals are used to produce foundry coke.
The coking time is approximately 16 hours for furnace coke and typically 28 to 30 hours for
foundry coke. Coking temperatures in the ovens range from approximately 1,650 to 2,000 °F.

When the coking cycle is completed, the oven doors are removed and the
incandescent coke is pushed from the oven into a rail car called a coke quench car. Plants usually
control air emissions from pushing operations with baghouses or wet scrubbers. The quench car
is positioned under a quench station where large volumes of water quench the coke to halt further
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Section 5 - Description of the Industry
combustion. All United States coke plants recycle and evaporate to extinction coke quench
water. Make-up water for coke quenching stations is typically plant service water (i.e., the plant's
water supply). The coke is then sized and-stored for future use. Relatively fine coke particles
collected in quench station sumps are called coke breeze. Coke breeze is used as a charge
material for production of foundry coke, for sinter plant operations, or sold for other uses.

Coke oven gas from the coke ovens is scrubbed in gas collector mains located on
top of the cpke battery with a fluid called flushing liquor, to condense tars and moisture derived
from the coal. The flushing liquor is processed in tar decanter tanks that essentially use gravity to
separate tar from the flushing liquor stream. Flushing liquor is recycled to the collector mains at a
high rate. Excess flushing liquor, also called waste ammonia liquor, comprises principally'the
moisture in the coal charged to the coke ovens. Excess flushing liquor is rejected from the
flushing liquor circuit and is the principal process wastewater stream generated at by-product
coke plants. Sludge collected at the bottom of the tar decanters is a listed hazardous waste and is
typically mixed with coke breeze and other carbonaceous material and recycled to the coke ovens
with the coal charge. Crude coal tars collected from the tar decanters is typically stored in tanks
on site and sold as a by-product.

The coke oven gas is further processed to remove additional materials that are also
sold as by-products. Primary gas coolers and tar precipitators remove additional tars. Scrubbing
the gas with sulfuric acid to-produce ammonium sulfate removes ammonia, and scrubbing it with a
recirculated wash oil solution removes light oil (an unrefined oil rich in benzene, toluene, xylene,
and solvent naphthas). The collected tars and naphthalene from final gas cooling operations are
typically mixed with coal tars recovered from tar decanters and sold with the tars. Many by-
product recovery coke plants have coke oven gas desulfurization systems that recover sulfur
removed from the coke oven gas as elemental sulfur. Ammonia is also steam stripped from the
excess flushing liquor and returned to the coke oven gas before the gas is scrubbed with sulfuric
acid.

The by-product recovery cokemaking industry uses a variety of chemical
processing technologies to recover materials such as crude coal tar, crude light oil (e.g.,
aromatics, paraffins, cycloparaffins and naphthenes, sulfur compounds), anhydrous ammonia or
ammonium sulfate, naphthalene, and sodium phenolate. These technologies include:

• Crude coal tar recovery. Coal tar from the flushing liquor and primary
coolers is collected for resale or further processing on or off site. By-
products recovery coke plants recover crude coal tar in tar decanters.

• Crude light oils recovery. Light oils are scrubbed from the coke oven gas,
recovered for resale, reused as a solvent for phenolics, or sent for further
refining on or off site.

• Recovery of ammonia and ammonia compounds. Free ammonia is
commonly steam stripped from waste ammonia liquors. A number of sites
remove fixed ammonia by elevating the pH of the wastewater with lime
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Section 5 - Description of the Industry
slurry or caustic soda solutions. The liberated ammonia is combined with
coke oven gas (COG) and removed with ammonia contained in the COG
with sprays of sulfuric acid or phosphoric acid in an absorber, or by
scrubbing ammonia from gas with fresh water, which is recirculated to
produce concentrated ammonium hydroxide.

• Recovery of phenol, phenolates, and carbolates. Vapor recirculation or
liquid/liquid extraction with suitable solvents removes and recovers _
phenolic compounds. In vapor recirculation, the steam leaving the free leg
of the ammonia still is scrubbed with dilute caustic soda to form sodium
phenolate. This steam recirculates to the ammonia stills for further
treatment and recovery. In liquid/liquid extraction, the benzol, light oil, or
other suitable solvent extracts phenolic compounds from the wastewater.
The phenolized solvent is separated and extracted with caustic. Again,
sodium phenolates separate out, and the phenolized solvent is reused in the
recovery .system.

• Recovery of sulfur and sulfur compounds. Desulfurization systems recover
elemental sulfur or sulfur compounds from COG. Techniques developed -
include iron oxide boxes using Fe2O3 on wood shavings, absorption and
desorption with soda ash, Wilputte vacuum carbonate systems, Seaboard
aerified solution systems, and Claus sulfur recovery systems.

• Naphthalene. Crystals of naphthalene are condensed in the final cooler and
recovered from the recirculating final cooler wastewater by skimming,
filtration, or centrifugation. Naphthalene may be recovered by
solidification at temperatures below 74°C (165°F).

Non-Recovery Coke Plants

Non-recovery coke plants carbonize coal in large dome-shaped oven chambers.
Volatile components evolved from the coal are partially combusted in the oven chamber, thus
providing some of the heat for coking. The gas is also used to underfire the ovens. Heat in the
waste gases is partially recovered in waste heat boilers to generate steam, which can be used for
electric power generation or for other uses. Because non-recovery plants combust all materials
evolved from the coal, there are no by-products recovered other than heat in the waste gases and
coke breeze. The pushing and quenching operations are similar to those performed at by-product
recovery coke plants.
5.2.2
Sintering
Sintering is an'agglomeration process in which iron-bearing materials (generally
fines) are mixed with iron ore, limestone, and finely divided fuel such as coke breeze. During iron
and steel production operations, blast furnaces, basic oxygen furnaces, continuous casters, and
hot forming mills generate large quantities of particulate matter (e.g., fines, mill scale, flue dust,
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Section 5 - Description of the Industry
wastewater sludge). Mills remove the particulate matter from process gases by dry or wet air
pollution control devices to reduce air emissions or to clean the gases for reuse as fuel. Sintering
operations recover mill scale from process wastewater discharged from continuous casting and
hot forming operations. These operations can recover a large percentage of this iron-rich
material, provided the oil content is low enough to prevent objectionable fumes.

Sinter plants consist of raw material handling facilities and raw material storage
bins, sinter strand (traveling grate combustion device), a mixing drum for each sinter strand, a
windbox (draws air through the traveling grate), a discharge end, and a cooling bed for sintered
product. The particulate matter is mixed in sinter machines and charged to the traveling grate at a
depth of approximately one foot. The mixture is ignited, and air is drawn through the bed as it
travels toward the discharge end to promote combustion and fusing of the iron-bearing materials.
The sinter product serves as a supplementary raw material for blast furnace operations.

Out of the nine sinter plants operating in 1997, seven operate wet air pollution
control systems and eight operate dry air pollution control systems. Since 1997, one facility with
wet air pollution controls has been shut down on an indefinite basis.
5.2.3
Briquetting
Briquetting is another agglomeration process used to recycle and reuse fine
materials that otherwise could not be charged to blast furnaces or steelmaking furnaces. The
operation forms materials into discrete shapes of sufficient size, strength, and weight for charging
to a subsequent process (e.g., blast furnaces, BOFs). Materials can be similar to those charged to
sintering operations. Briquetting operations can be performed with or without heating the raw
materials, and do not generate process wastewater.
5.2.4
Blast Furnace Ironmaking
Blast furnaces produce molten iron, which makes up two-thirds to nearly three-
quarters of the metallic charge to basic oxygen steelmaking furnaces; the balance is cold steel
scrap. The blast furnace has several zones: crucible-shaped hearth (bottom of the furnace),
intermediate zone called a bosh (between the hearth and the stack), a vertical shaft called the
stack (between the bosh"and top of furnace), and the furnace top, which contains the mechanism
for charging the furnace. The hearth and bosh walls are lined with carbon-type refractory blocks,
and the stack is lined with high-quality fireclay bricks. To protect these refractory materials from
burning out, cooling water circulates through exterior plates, staves, or sprays. Blast furnace
sizes range between 70 and 120 feet in height, with hearth diameters between 20 and 45 feet. The
rated capapity of blast furnaces ranges from under one million tons per year to over four million
tons per year.

The raw materials charged to the top of the blast furnace include coke, limestone,
beneficiated iron ores or iron pellets, and sinter. Iron pellets, the dominant burden material
(material charged to the furnace) in North America, include acid pellets and fluxed pellets, which
are typically produced at or near iron ore mine sites. Coke supports the furnace burden. Iron-
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bearing materials are reduced to molten iron and slag as they descend through the furnace. A
continuous feed of alternating layers of coke, iron-bearing materials, and limestone are charged to
the top of the furnace. Hot blast (preheated air) at temperatures between 1,650 and 2,300°F and
injected fuel (e.g., pulverized coal, oil, natural gas) are blown into the bottom of the furnace (top
of the hearth) through a bustle pipe and tuyeres (orifices) located around the circumference of the
furnace. The preheated air reacts with the coke to produce the reducing agent, carbon monoxide.
The reducing gases ascend through the furnace to react with the iron-bearing materials to produce
the molten iron and slag. The limestone is a fluxing agent that forms the fluid slag, which
combines with unwanted impurities in the ore. The molten iron, at approximately 2,800 to
3,000°F, accumulates in the hearth and is tapped at regular intervals into refractory-lined cars for
transport to the steelmaking furnaces. Molten slag, which floats on top of the molten iron, is also
tapped and processed for sale as a by-product.

Blast furnace slag uses include railroad ballast, aggregate in cement manufacturing,
and other construction uses. There are 20 integrated steel mills with blast furnace operations in
the United States.
furnace:
Below is a simplified summary of the chemical reactions that occur in the blast
H2 -> 2Fe3O4 + H2O
3Fe2O3 + CO~> 2Fe3O4 + CO2
H2 -> 3FeO + H2O
Fe3O4 + CO~>3FeO + CO2
FeO + H2->Fe + H2O
FeO + CO~>Fe + CO2

3Fe + CO--> Fe3C + H2O
3Fe + 2CO-> Fe3C + CO2

CO2 + C->2CO .
H2O + C--> CO + H2

FeO + C--> Fe + CO

3Fe + C->Fe3C

The hot blast exits the furnace top as blast furnace flue gas in enclosed piping. A
combination of dry dust catchers and high-energy venturi scrubbers clean and cool the gas.
Stoves combust the cleaned gas to preheat the incoming air and for use as fuel elsewhere in
integrated mills. Direct contact water is applied in the gas coolers and high-energy scrubbers.. All
sites operating blast furnaces use wet air gas cleaning systems.
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Section 5 - Description of the Industry
Blast furnace manufacturing operations may use wastewater or plant service water
for slag cooling or quenching. Nineteen of the 20 integrated facilities surveyed use water for slag
cooling at blast furnace operations. ,
5.2.5
Direct Reduced Ironmaking
Another method of producing iron is through direct reduction. .This process
produces relatively pure iron in solid pellet form by reducing iron at a temperature below the
melting point of the iron produced. Direct reduced iron (DRI) is used as a substitute for scrap
steel in EAF steelmaking to minimize contaminant levels in the melted steel and to allow
economic steel production when market prices for scrap steel are high. There are two direct
reduced ironmakmg plants in the United States.

The prime ingredient in DRI is iron oxide ore. The DRI process removes the
oxygen from the iron ore. The DRI process uses a slightly inclined rotating kiln, where the raw
materials and heat are added. Raw materials include iron ore, coal, and recycled material. The
heat may be supplied by oil or gas burners. One common DRI process uses natural gas as both an
energy source and a reducing gas. The process involves blending oxide pellets and lump ores arid
charging this mixture to the top of the furnace. The top zone of the furnace is where reduction
occurs and the bottom zone of the furnace is where cooling occurs. While in the furnace, the
blended ore mixture is saturated with a reducing gas mixture of carbon monoxide and hydrogen,
which is produced from the natural gas in gas reformers. This gas is preheated to a temperature
of approximately 1,500°F. The descending iron ore pellets are reduced as they descend through
the kiln. The oxide ore and the reducing gas remain in the furnace for several hours, resulting in
direct reduced iron.
5.2.6
Steelmaking: Basic Oxygen Furnaces (BOFs) and Electric Arc Furnaces
(EAFs) .
Steelmaking in the United States is performed in either BOFs or EAFs. BOF and
EAF processes are batch operations with tap-to-tap (batch cycle) times of about 45 minutes for
BOFs and in the range of 1 to more than 1.5 hours for EAFs. BOFs typically produce high-
tonnage carbon steels, while EAFs produce carbon steels and low-tonnage alloy and stainless
steels.

Basic Oxygen Furnace (BOF)

The open hearth furnace process for steelmaking was replaced after World War II
with the basic oxygen process (BOP). This process involves blowing oxygen through a lance into
the top of a pear-shaped vessel. Lime addition to the charge removes phosphorus and sulfur
impurities in the form of slag. Compared with the open hearth furnace, steelmaking using BOP
became a much quicker process, with tap-to-tap times of approximately 60 minutes compared to
12 or more hours. In addition, up to 35 percent of the charge could be steel scrap.
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After its invention, the BOP was modified. In addition to blowing oxygen.directly
onto the charge, the process involved also blowing burnt lime through the lance with the oxygen.
This process allowed refining of pig iron smelted from high-phosphorus ores. The next process
modification, developed in Canada and Germany in the mid-1960s, was the bottom-blown
steelmaking process. This process used two concentric tuyeres, the outer with hydrocarbon gas
and the inner with oxygen. This new process became know as Q-BOP. Both the BOP and
Q-BOP process are types of BOF steelmaking which are used today.

The BOF steelmaking process refines the product of the blast furnace (hot metal),
which contains approximately 3.5 to 4.4 percent carbon, <0.05 percent sulfur, and <0.04 percent
phosphorus. In steelmaking operations, the furnace charge consists of approximately two-thirds
molten iron and .one-third scrap steel. The furnace melts the charge and refines it by oxidizing
silicon, carbon, manganese, phosphorus, and a portion of the iron in the molten bath. Various
alloying elements are added to produce different grades of steel. Common alloying elements
include aluminum, boron, chromium, copper, magnesium, molybdenum, niobium, nickel, silicon,
and vanadium.

Vessels used in the BOF process are generally vertical cylinders surmounted by a
truncated cone. Typical heat sizes hi BOFs range between under 100 tons per heat to over 300
tons per heat. .

Scrap and molten iron are first placed in the vessel. Oxygen is then injected into
the molten bath either through the top of the furnace (top blown), bottom of the furnace (bottom
blown), or both (combination blown). A violent reaction occurs immediately, bringing the molten
metal and hot gases into intimate contact, causing impurities to bum off quickly. Management of
furnace slag processes controls residual sulfur. The slag is separated and removed from the
molten steel. Finally, alloys are added to the bath or as the steel is tapped (poured) into ladles.
Slag material is charged back to the blast furnace to recover iron or used as railroad ballast. The
BOF allows close control of steel quality and the ability to process a wide range of raw materials.

Off-gases from BOFs exit the vessel at temperatures of approximately 3,000°F.
This gas contains approximately 90 percent carbon monoxide and 10 percent carbon dioxide, and
may also contain ferrous oxide dust. BOF off-gas control systems include two types: full or open
combustion and suppressed combustion. The full combustion system bums the off-gas above the
mouth of the vessel using excess air. Air pollution control systems then clean the off-gas. The
suppressed combustion system lowers a ring-shaped hood over the vessel mouth, collecting the
gases, which are used as heating-sources.

Sites may operate wet, semi-wet, or both types of air pollution control systems at
BOF processes. Fourteen of the 20 sites operating BOFs in 1997 used wet air pollution control,
and eight used semi-wet air pollution control. United States facilities control off-gases from
BOFs by one of three methods: semi-wet, wet-open, or wet-suppressed. In semi-wet combustion,
BOF off-gases are conditioned with moisture prior to processing in electrostatic precipitators or
bag houses. In wet-open combustion, excess air is admitted to the off-gas collection system,'
allowing carbon monoxide to combust prior to high-energy wet scrubbing. In wet-suppressed
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combustion, excess air is not admitted to the off-gas collection system prior to high-energy wet
scrubbing. • •

Similar to blast furnaces, BOF manufacturing operations may use wastewater or
plant service water for slag cooling or quenching. Eighteen of the 20 integrated facilities
surveyed use water instead of air for slag cooling in BOF operations.

Electric Arc Furnace (EAF)

The EAF is designed to produce specific grades of steel. The first EAFs
developed in the late 1800s and early 1900s could melt approximately one ton per heat Typical
heat sizes in current EAFs range between under one ton per heat to over 350 tons per heat.

The furnace is a cylindrical vessel with a dish-shaped refractory hearth and three
electrodes that lower from the dome-shaped, removable roof. Depending on heat sizes, shell
diameters range from 8 feet for a. 10-ton vessel to 30 feet for a 300-ton vessel. Tar-bonded
magnesite bricks form the lining of the furnace. The walls typically contain water-cooled panels
that are covered to minimize heat loss. The electrodes may also be equipped with water cooling
systems.

The cycle in EAF steelmaking consists of scrap charging, melting, refining,
deslagging, and tapping. In addition to scrap steel, the charge may include pig iron and alloying
materials. As the steel scrap is melted, additional buckets of scrap may be. added to the furnace.
The EAF generates heat by passing an electric current between electrodes through the charge in
the furnace. Lime-rich slag removes the steel impurities (e.g., silicon, sulfur, and phosphorus)
from the molten steel. Oxygen,may be added to the furnace to speed up the steelmaking process.
At the end of a heat, the furnace tips forward and the molten steel is poured off. Non-integrated
steelmaking facilities typically operate EAFs.
5.2.7
Vacuum Degassing
Vacuum degassing is a refining process hi which gases are removed from molten
steel under vacuum after steelmaking and prior to casting to produce steels of high metallurgical
quality. Vacuum degassing may be used to control composition and temperature, remove oxygen
(deoxidation) and hydrogen (degassing), decarburize, and otherwise remove impurities from the
steel. Steam jet ejectors generate the vacuum for high-tonnage vacuum degassing units. The
gases and water used to condense the steam come in direct contact in barometric condensers.
While the molten steel is under vacuum, elements that have a relatively higher vapor pressure
(such as manganese and zinc) volatilize and exit with the gases. Vacuum degassers are common
at integrated and non-integrated mills that produce low carbon, stainless, and certain alloy steels.
Vacuum degassers often operate as part of ladle metallurgy stations where additional steel refining
is conducted. EPA estimates that 44 sites operate vacuum degassing systems.
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5.2.8
Ladle Metallurgy and Secondary Steelmaking
Ladle metallurgy and secondary steelmaking are steel refining operations that
molten steels undergo under atmospheric conditions (i.e., no vacuum is applied) prior to
continuous or ingot casting. The purpose of ladle metallurgy and secondary steelmaking may
include one or more of the following:

• To control gases in the steel;

• To remove, add, or adjust concentrations of metallic or nonmetallic
compounds (alloying); and

• To adjust physical properties (e.g., temperature)..

Common types of ladle metallurgy include argon or nitrogen bubbling or stirring,
argon-oxygen decarburization, lance injection, magnetic stirring, and other alloy addition
operations. Common types of secondary steelmaking include electroslag refining and other alloy
addition operations. EPA estimates that 103 sites use ladle metallurgy and/or secondary
steelmaking; some sites may operate more than one type of process. The following table lists the
types of ladle metallurgy and secondary steelmaking performed at iron and steel sites in 1997.

1997 National Estimate for Types of Ladle Metallurgy
and Secondary Steelmaking Processes
Type of Ladle Metallurgy or Secondary
Steelmaking
Argon bubbling
Argon-oxygen decarburization
Electroslag remelting
Lance injection
Other3
Number of Sites
66
!6
10
19
37
Source: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and
Short Surveys).
° Other types of ladle metallurgy include alloy addition, reheating, magnetic stirring, ladle
stirring, and carbon addition/adjustment.
5-12

-------
Section 5 - Description of the Industry
EPA estimates that only four of the 103 sites with ladle metallurgy and secondary
steelmaking operations operate wet air pollution control systems.
5.2.9
Casting
An integral part of the steelmaking process is converting molten steel into a
semifinished product or shape that is suitable for further processing. There are two main casting
operation types: continuous and ingot casting. Molten steel is tapped from the EOF or EAF into
ladles large enough to hold an entire heat. The ladles are then processed in ladle metallurgy
stations and/or vacuum degassers prior to teeming (pouring) the steel into ingot molds or direct
casting it into semi-finished shapes using continuous casters. EPA estimates that 113 sites
operate casters.

Continuous Casting

Continuous .casting is the most efficient and most common method of casting
performed at steel mills. In the continuous casting process, molten steel is poured from the ladle
into a refractory lined tundish (mold). The molten metal from the tundish pours through nozzles
into an oscillating water-cooled copper mold, where the metal partially solidifies. The copper
molds oscillate to prevent the molten steel from sticking to their sides. Lubricants spray into the
molds to keep the steel moving through the mold. After passing through the water-cooled molds,
the partially solidified product passes into a secondary cooling zone, where sprays of contact
water cool the semi-finished product enough to solidify. The product then passes into the cut-off
zone where it is cut to the desired length.

Casting machines are either single-strand or multiple-strand. The four main types
of continuous casters are based on the shape of the cast product: billet, bloom, round, and slab.
Billet casters form squares or rounds between 3 and 7 inches and are multiple-strand casters.
Bloom casters form sections ranging between 7 by 7 inches and 14.6 by 23.6 inches and are
usually three-strand. Round casters form steel for seamless tube production with diameters
between 5 and 9 inches, and are usually multiple-strand. Slab casters form sections up to 12
niches thick and 100 niches wide, and are usually single- or twin-strands. In addition, casters may
form beams that are fed directly to I-beam or H-beam rolling mills. Modern slab casters used to
manufacture flat-rolled products universally have a curved-mold design, while those used for bar
products may have a straight vertical mold design with vertical cutoff or bending with horizontal
cutoff. The following table presents .continuous casting products and the number of sites casting
these products in 1997.
5-13

-------
.Section 5 - Description of the Industry
1997 National Estimate For Types of Continuous Casting Products
Type of Cast Product
Slab
Thin slab
Round billet
Rectangular or square billet
Bloom
Other3 '
Number of Sites
28
8
6
47
12
7
Source: U.S. EPA. U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed
and Short Surveys).
'Other types of cast products include beam blanks and near net-shape products.

Continuous casters usually include two separate closed-loop noncontact cooling
water systems: one for the copper mold (mold-cooling water system) and one for all other
mechanical equipment (machine-cooling water system). Facilities use direct contact water
systems for spray cooling and for flume flushing to remove scale from the caster run-out table.

Ingot Casting

Ingot casting involves teeming the molten steel into ingot molds, and then cooling
and stripping the ingots out of the molds. The ingots are then heated and rolled into blooms,
billets, or slabs during hot forming. Continuous casting, on the other hand, directly forms the
molten steel into blooms, billets, or slab, which eliminates the ingot casting steps, increases
productivity, and conserves energy. Continuous casting has replaced nearly all ingot casting
operations. Ingot casting is used typically for small, specialty batches and for certain applications
for producing plate.
5.2.10
Hot Forming
Hot forming is a process in which preheated (typically in the range of 1,800°F),
solidified steel is reduced in cross-section through a series of forming steps, in which mechanical
pressure is applied through work rolls. These products have numerous cross-sections, lengths,
and tonnages. While several different types of hot forming mills are in operation today, the hot
forming mills can be grouped into one of the following four types:

• Primary mills; .
• Section mills;
• Flat mills (plate, hot strip, and sheet); and
• Pipe and tube mills (seamless and butt-weld).
5-14

-------
Section 5 - Description of the Industry
In general, hot forming primary mills reduce ingots to slabs or blooms, or blooms
to billets. Section mills reduce billets to form rod, bar products, structural shapes (e.g., channels,
angles), or other forms. Flat mills reduce slabs to plates or strips. Products from section and flat
mills may be used to manufacture pipe and tubes. Seamless pipe and tube manufacturing involves
piercing round billets, and butt-welded pipe and tube manufacturing begins with strip.

Flat mills, specifically hot strip mills,'are the most common type of hot forming mill
at integrated steel mills. Hot rolled strip begins with slab, which is heated in one or more furnaces
and then undergoes scale breaking in a two-high rolling mill with vertical rolls. The rolls loosen
the scale, and high-pressure water jets remove the scale. The slab rolls through four-high
roughing stands to a thickness around 1.2 inches. The slab then passes to the finishing train, '
where a crop-shear cuts both ends and high-pressure steam jets remove scale. Six or seven four-
high finishing stands roll the strip to a thickness between 0.06 and 0.4 niches. Both the roughing
and finishing stands are usually arranged in tandem. .

Forging is another form of steel forming where steel shapes are produced by
hammering or by processing in a hydraulic press. Most forging operations are performed on
preheated steel. The following table presents the national estimate for types of hot forming
operations and the number of sites performing these operations in 1997.

1997 National Estimate for Hot Forming Operations
Hot Forming Operation
Rolling mill
Pipe and tube mill
Forging
Number of Sites
. 122
6
14
Source: U.S. EPA. U.S. EPA Collection of 1997 Iron and Steel Industry
Data (Detailed and Short Surveys).

The following table presents the national estimate for types of hot forming
products and the number of sites producing these products in 1997.
5-15

-------
Section 5 - Description of the Industry
1997 National Estimate for Hot Forming Products
Type of Hot Forming Product
Bar
Beam3
Billet
Bloom3
Plate
Railroad rail3
Reinforcing bar
Rod
Sheet
Slab3
Small structural
Strip
Tube and pipe
Other"
Number of Sites
67
8
25
• 7
21
4
25
17
11
16
23
25
21
44
Source: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data
(Detailed and Short Surveys).
3 Estimate is based on detailed survey only. Short surveys did not collect this
level of detail.
b Other hot forming products include various miscellaneous product shapes.

Hand chipping, machine chipping, manual scarfing, grinding, milling, and machine
scarfing are methods used to remove surface defects from blooms, billets, and slabs prior to hot
rolling. Scarfing removes a thin layer of the steel surface by localized melting and oxidation. The
process may be done manually (continuously moving an oxyacetylene torch along the length of
the product), or using a scarfing machine located near the entry of the hot forming mill.

Exhaust gases from scarfers contain metal fumes comprising mainly iron oxides
and the alloying elements of the steel. These gases are saturated at a temperature of 60 °C
(140°F) when exiting the scarfer hood. Because the gases are saturated, the following three types
of gas cleaning equipment systems are generally used:

1. Wet precipitator - intermittent spray wash;
5-16

-------
Section 5 - Description of the Industry
2. Wet precipitator - continuous wash; and
3. High energy venturi scrubber.

The wet precipitator - intermittent spray wash sprays water on a timed cycle to clean the fume
residue that is collected dry on the precipitator plates. The wet precipitator - continuous wash
continuously sprays water to remove collected fume residue from precipitator plates. The high
energy scrubber requires 45 to 50 inches of water column pressure drop to clean the gases.

Butt-weld pipe or tube is made from hot rolled strip with square or slightly beveled
edges called skelp. The width, of skelp corresponds to the circumference of the pipe, while the
gauge corresponds to the wall thickness. Skelp is preheated to welding temperature in a reheat
furnace and drawn through a die or roll forming a cylindrical shape. The edges are pressed
together forming a butt-weld. Seamless tubular products are usually made by a piercing process.
The process heats, pierces, and shapes a solid round bar or billet to the desired diameter and wall
thickness.

Hot forming mills use water for scale breaking, flume flushing, and direct contact
cooling. The water often recirculates in cooling water systems. Sites may have multiple hot
forming contact water and/or rolling solution systems.
5.2.11
Finishing
Steel finishing operations follow hot forming operations; therefore, integrated steel
mills and those stand-alone steel finishing mills that receive steel from integrated steel mills are
most likely to perform steel finishing operations. Integrated steel mills in the United States
principally produce flat-rolled steel products that require finishing, such as hot rolled strip (hot
bands), pickled and oiled strip, cold rolled and annealed strip and sheet, hot coated strip
(principally zinc and zinc/aluminum), electroplated strip (principally chromium, tin, zinc), and
plates. Several non-integrated steel mills produce flat-rolled products, but most produce bar and
bar products and structural and other shapes. Non-integrated steel mills are more likely to ship
hot rolled products without further surface treatments or finishing.

The type of steel finishing operation is closely related to the type of steel
processed. For carbon steels, acid pickling with hydrochloric acid, cold rolling and annealing,
temper rolling, acid and/or alkaline cleaning, hot coating, and electroplating are performed. For
stainless steels, descaling (molten salt bath and electrolytic sodium sulfate), sulfuric, nitric,
nitric/hydrofluoric acid and sometimes hydrochloric acid pickling, cold rolling and annealing, and
temper rolling are likely to be performed. A number of steel finishing mills also perform surface
coating of electrical steels.

Acid Pickling and Descaling

Acid pickling and descaling operations clean the steel surface prior to further
processing (e.g., cold forming, application of protective and decorative coatings). The steel
surface must also be cleaned at various production stages to ensure that oxides that form on the
5-17

-------
Section 5 - Description of the Industry
surface are not worked into the finished product, causing marring, staining, or other surface
imperfections.

The acid pickling process chemically removes oxides and scale from the surface of
the steel by the action of water solutions 'of inorganic acids. While acid pickling is only one of
several methods of removing undesirable surface oxides, it is most widely used because of
comparatively low operating costs and ease of operation. Carbon steel is usually pickled with
hydrochloric acid; stainless steels are pickled with sulfuric, hydrochloric, nitric, and hydrofluoric
acids. The Agency estimates that 38 of the 75 acid pickling sites use hydrochloric acid, 33 use
sulfuric acid, 28 use hydrofluoric acid, and 28 use nitric acid. The pickling process uses various
organic chemicals that inhibit the acid from attacking the base metal while permitting it to attack
the oxides. Wetting agents improve the effective contact of the acid solution with the metal
surface. After the pickling bath, the steel passes through one or more rinse operations.

In addition to the acid pickling operations, finishing mills may regenerate or
recover the spent acid by removing the iron. Acids can then be reused by the mill. Hydrochloric
acid and sulfuric acid are the more commonly regenerated or recovered acids, although stainless
steel finishing mills also recover nitric and mixed nitric/hydrofluoric acids.

Two common types of descaling operations are blast cleaning and salt bath
descaling. Blast cleaning (mechanical descaling) uses abrasives such as sand, steel, iron grit, or
shot to clean the steel surface. The abrasives come in contact with the steel using either a
compressed air blast cleaning apparatus or by a rotary-type blasting cleaning machine. Salt bath
descaling, a surface treatment operation, processes stainless or alloy steel products in molten salt
solutions. This operation uses the physical and chemical properties of molten salt baths to loosen
heavy scale from selected stainless and high-alloy steels; the scale is removed in subsequent water-
quenching steps. Two processes, oxidizing and reducing, are commonly referred to by the names
of proprietary molten salt descaling baths, Kolene® and Hydride®, respectively. Descaling may
also be performed using an electrolytic solution of sodium sulfate.

EPA estimates that, of the 69 sites operating acid pickling and descaling systems,
41 use wet air pollution control and 14 use dry air pollution control.

Cold Forming

Cold forming mills process hot rolled and pickled steels at ambient temperatures to
impart desired mechanical and surface properties in the steel. Most cold rolling operations reduce
the thickness of the steel much less than hot forming. The following table shows common
products formed during cold forming.
5-18 '

-------
Section 5 - Description of the Industry
1997 National Estimate for Type of Cold Forming Product
Type of Cold Forming Product
Plate
Sheet
Strip
Number of Sites
5
21
47
Source: U.S. EPA. U.S. EPA Collection of 1997 Iron and Steel Industry Data ;
(Detailed and Short Surveys).

Common cold rolling mills in the iron and steel industry include tandem and temper
mills. Tandem mills modify steel sheet properties, including strength, surface properties, and
thickness. They are typically used in a series of three to five stands. Temper mills slightly
improve the finish of steel sheet, such as shiny, dull, or grooved surfaces, and generally do not
modify shape or thickness. They primarily improve flatness, alter mechanical properties, and
minimize surface disturbances. Temper mills are typically used with only one or two stands.

Sendzimir cold rolling mills, commonly referred to as Z-mills, are another type of
cold rolling operation. They have various configurations; typically, however, steel passes through
work rolls that are supported and driven by first- and second-intermediate rolls. The mill design
allows for quick adjustments to vary the width, thickness, and hardness of the rolled steel. These
mills typically use hydraulic fluid or oil emulsions rather than aqueous rolling solutions.

Cold forming operations generate heat that is dissipated by flooded lubrication
systems. These systems use palm oil or synthetic oils that are emulsified in water and directed in
jets against the rolls and the steel surface during rolling.

Surface Treatment and Annealing Operations

Surface treatment and annealing operations include a wide range of operations,
including alkaline cleaning, annealing, hot coating, and electroplating. Facilities performing
finishing operations often have a number of these operations on a single line.

Alkaline cleaners remove mineral and animal fats and oils from the steel surface.
Caustic, soda ash, alkaline silicates, and phosphates are common alkaline cleaning agents. Passing
the steel through alkaline solutions of specified compositions, concentrations, and temperatures is
often enough to clean the product; however, for large-scale production or a cleaner product, sites
may use electrolytic cleaning. Sometimes adding wetting agents to the cleaning bath facilitates
cleaning. .

The annealing process heats steel to modify its bulk properties, which makes the
steel easier to form and bend. Steel is heated and kept at a designated temperature and then
5-19

-------
Section 5 - Description of the Industry
cooled at a designated rate. Through the annealing process, the metal grain size increases, new
bonds are formed at the higher temperature, and the steel becomes more ductile. Sites perform
annealing through a batch or continuous process; they may follow annealing operations with a
water quench to cool the steel for further processing.

Steel coating operations, such as hot coating and electroplating, improve resistance
to corrosion or improve appearance. Hot coating operations involve immersing precleaned steel
into molten baths of tin, zinc (hot galvanizing), combinations of lead and tin (terne coating), or
combinations of aluminum and zinc (galvalume coating), any associated cleaning or fluxing (used
to facilitate metal application) steps prior to immersion, and any post-immersion steps (e.g.,
chromium passivation). Based on survey responses, the metals used for hot coating operations
include zinc, zinc/aluminum alloy, aluminum, chromium, lead, antimony, tin/lead alloy, and
zinc/nickel alloy.

Electroplated steel production uses electrodes to deposit a metal coating onto the
steel. Historically, electroplating at steel mills was limited to tin and chromium electroplating for
food and beverage markets and relatively low-tonnage production of zinc electroplated
(electrogalvanized) steel for the automotive market. In recent years, electrogalvanized steel
production has increased substantially in response to automobile manufacturers' demand. New
coatings consisting of combinations of iron, nickel, and other metals have been developed. Based
on survey responses, the metals used for electroplating operations include zinc, chromium,; tin,
nickel, brass, cobalt, copper, nickel/tin alloy, zinc/nickel alloy, and zinc/iron/aluminum alloy.

EPA estimates that, of the 98 sites performing surface treatment operations, 38
operate wet air pollution control systems and 16 operate dry systems.
5.3

5-1

5-2

5-3

5-4

5-5
References

U.S. Environmental Protection Agency. Development Document for Effluent
Limitations Guidelines and Standards for the Iron and Steel Manufacturing Point
Source Category. Volume 1. EPA 440/1-82/024, Washington, D.C., May 1982

U.S. Environmental Protection Agency. Preliminary Study of the Iron and Steel
Category: 40 CFR Part 420 Effluent Limitations Guidelines and Standards. EPA
821-R-95-037, Washington, B.C., September 1995.

Association of Iron and Steel Engineers. The Making. Shaping and Treating of
Steel riOth edition). ISBN 0-930767-00-4, Pittsburgh, PA, 1985.

Georgetown Steel Corporation. "Beginning with Iron Ore: The DRI Process,"
Georgetown Steel Corporation brochure. Georgetown, SC.

The Forging Industry Association. The Forging Industry Association's How Are
Forgings Produced?, http://www.forging.org/facts/wwhy6.htm, 2000.
5-20

-------
                                                           Section 5 - Description of the Industry
 5-6
 5-7
.5-8
American Iron and Steel Institute. AISFs Everything You Always Wanted to
Know About Steel.. . A Glossary of Terms and Concepts. Courtesy of Michelle
Applebaum, Managing Director (Summer 1998). Salomon Smith Barney Lie,
http://www.steel.org/learning/glossary/, 2000.

Association of Iron and Steel Engineers. The Making. Shaping and Treating of
Steel (11th edition). Ironmaking Volume. Pittsburgh. PA. 1999.

Encyclopaedia Britannica. Britannica.com. http:\\www.britannica.com, Chicago,
IL.     - .          •
                                          5-21

-------
                                                                   Section 5 - Description of the Industry
                                            Table 5-1
   1997 National Estimate of Types of Iron and Steel Sites in the United States
Type of Site
Integrated steel mill with coke plant
Integrated steel mill without coke plant
Stand-alone coke plant3
Stand-alone sintering plantb
Stand-alone direct reduced ironmakingplanf
Non-integrated steel mill
Stand-alone hot forming mill
Stand-alone finishing mill
Stand-alone pipe and tube mill
TOTAL"
Total Number of Sites Operating in 1997
(% of Industry Total)
9 (3.5%)
11(4.5%)
15 (6.0%)
2 (<1%)
1 (<1%)
94 (37%)
39 (15.5%)
70(28%)
11 (4.5%)
254
Source: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys).
'One of the stand-alone coke plants is a non-recovery coke plant. One additional non-recovery coke plant started
operations after 1997 and is not reflected in this table.
bOne stand-alone suiter plant has been shut down indefinitely since 1997.
eA stand-alone direct reduced ironmaking plant started operations after 1997.
dColumns do not sum to totals because of rounding each number and because two sites are counted as one integrated
steel mill.
                                               5-22

-------
                                                                Section 5 - Description of the Industry
                                          Table 5-2
                   Survey Response of Sites Producing Steel Types
Type of Site'
Integrated steel mill with coke plant
Integrated steel mill without coke
plant
Non-integrated steel mill
Stand-alone hot forming mill
Stand-alone finishing mill
TOTAL
Total Number of
Sites Responding
to Survey
9
11
66
17
38
141
Number of Survey-Responding Sites Producing
Each Type of Steel
Carbon Steel
9
11
56
• 14
28
118
Stainless Steel
1
2
16
7
13
39
Alloy Steel
6
5
43
13
1-2
79
Source: U.S. EPA. U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys').
Totals for stand-alone pipe and tube mills not disclosed to prevent compromising confidential business information.
                                             5-23

-------
                                                                    Section 5 - Description of the Industry
                                             Table 5-3

                1997 National Estimate of Number of Direct, Indirect,
                                 and Zero Discharging Sites
Type of Site
Integrated steel mill with coke plant
Integrated steel mill without coke plant
Stand-alone coke plant
Stand-alone sintering plant
Stand-alone direct reduced ironmaking
plant
Non-integrated steel mill
Stand-alone hot forming mill .
Stand-alone finishing mill
Stand-alone pipe and tube mill
TOTAL d
Total Number
of Sites3
9
11
15
2
1
94
39 '
70
11
254
Number (%)
of Direct
Dischargers
8 (89%)
11(100%)
9 (60%) .
1 (50%)
Oc
46 (49%)
22 (56%)
28 (40%)
8 (72%)
133 (53%)
Number (%)
of Indirect
Dischargers
3 (33%)
0°
5 (33%)
Oc
1 (100%)
19 (20%)
6 (15%)
34 (49%)
3 (27%)
70 (28%)
Number (%)
of Zero or
Alternative
Dischargers"
Oc
Oc
1 (7%)
1(50%)
Oc
32 (34%)
12(31%)
1 1 (16%)
oc
56 (22%)
Source: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys).
'The sum of direct dischargers, indirect dischargers, and zero dischargers may not equal the total number of sites. Sites
may directly and indirectly discharge wastewater from their site.
bZero dischargers include sites that do not discharge process wastewater as well as sites that are completely dry.
cCells with a zero (0) value indicate that none of the survey respondents have the characteristic. However, it is possible
for nonsurveyed facilities to have the characteristic corresponding to that cell.
•"Columns do not sum to totals because of rounding each number and because two sites are counted as one integrated
mill.
                                                5-24

-------
                                                             Section 5 - Description of the Industry
                                       Table 5-4

                 1997 National Estimate of Actual Production and
                   Rated Capacity by Manufacturing Operation
Manufacturing Operation
Cokemaking
Sintering
Blast furnace ironmaking
BOF steelmaking
EAF steelmaking
Vacuum degassing
Ladle metallurgy
Casting
Hot forming
Acid pickling and descaling
Cold forming
Surface cleaning and coating
Briquetting or other
agglomeration process
Direct reduced ironmaking
Total Number of
Sites with this
Operation
24
9
20
20
96
44
103
113
153
69
103
98
4
2
Total 1997 Production
(million standard tons)
20.4
12.4
54.5
65.9
50.8
18.0
102
110
127
483
72.8
35.3
nd
nd
Total 1997 Rated
Capacity
(million standard tons)
22.6
17.9
68.6
78.3
75.8
39.1
158
142
177a
67.9a
105
40.1
nd
nd
Source: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys).
"This estimate is from the detailed survey only.
nd - Not disclosed to prevent comprimising confidential business information.
                                           5-25

-------
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5-26

-------
   Structural shapes
• (beams, angles, tees,
zees, channels, piling)
  Rails and joint bars
 (standard rails, crane
   rails, joint bars)
         Bars
     (round, square,
  hexagonal, octagonal,
flat, triangular, half round)
                                      Pipe and tubes
                                           Sheets, coils
                                                              to- Finished
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                                    Figure 5-2.  Forming and
                                       Finishing Operations
                                 FIGS 2
                                              10/11/00
           5-27

-------

-------
                                                                  Section 6 - Subcategorization
                                       SECTION 6

                                SUBCATEGORIZATION

              This section presents the proposed subcategorization for the Iron and Steel
 effluent limitations guidelines and standards., Section 6.1 presents EPA's subcategorization
 criteria and the proposed subcategories and discusses differences between the 1982
 subcategorization and the proposed subcategorization.  Sections 6.2 through 6.8 present each
 proposed subcategory in detail and review the segments and manufacturing operations within each
 subcategory.
6.1
Subcategorization Process
              To develop the regulation, the Agency had to determine whether different effluent
limitations and standards were appropriate for distinct subcategories within the industry. The
Clean Water Act (Section 304(b)(2)(b), 33 U.S.C. § 1314 (b)(2)(B)) requires the Agency to
consider certain factors for subcategorization, as well as process and engineering factors.  These
factors include:               ,.  .                           ,

              •      Age of equipment and facilities;
              •      Location;
              •      Size of site;
              •      Manufacturing processes employed;                                   •
              •      Wastewater characteristics;
              •      Economic impacts; and
              •      Non-water quality impacts.

              In considering these factors, EPA analyzed industry survey data and EPA sampling
data for trends in discharge flow rates, pollutant concentrations, and treatability to determine
where subcategorization was warranted. Based on this analysis, the Agency has adopted a revised
subcategorization of the industry for the proposed rule. The revised subcategorization not only
reflects the production and wastewater treatment changes in the industry since the last
rulemaking, but also simplifies the regulation and incorporates the experience that the Agency and
other regulatory entities have gained from implementing the 1982 Iron and Steel effluent
limitations guidelines and standards.

              Of all the subcategorization criteria, EPA identified manufacturing processes as the
most significant factor for subcategorization, and divided the industry into seven primary process
subcategories on this basis.  In addition, EPA used manufacturing operations, type of product,
and wastewater characteristics, including flow rates with respect to  production and type of
pollutant present, to segment within certain subcategories. The Agency decided to further divide
segments in some cases, based on different wastewater pollutant characteristics, wastewater flow
rates, and/or process operations. Section 7 discusses in detail wastewater sources, production-
normalized flow rates, and pollutants for each segment.  Tables 6-1  and 6-2 present the 1982 and
                                          6-1

-------
Section 6- Subcategorization
proposed Subcategorization, respectively. Table 6-3 compares the subcategorization for the 1982
and the proposed regulations.

Manufacturing process changes in the iron and steel industry have resulted in
changes to the current subcategorization and the proposal of the new subcategorization. EPA
removed three segments from the proposed subcategqrization because the manufacturing
operations are no longer practiced in the United States: the Beehive Cokemaking Segment of the
Cokemaking Subcategory, the Ferromanganese Blast Furnace Segment of the Ironmaking
Subcategory, and the Open Hearth Furnace Segment of the Integrated Steelmaking Subcategory.
In addition, the Agency added one segment and one Subcategory to include iron and steel
manufacturing processes that are not covered under the 1982 regulation: the proposed
Cokemaking Subcategory includes a segment for non-recovery cokemaking operations, and the
Other Operations Subcategory has been created to regulate direct reduced ironmaking,
briquetting, and forging.

Changes to the proposed subcategorization are also a result of applicability
changes for iron and steel and other effluent limitations guidelines and standards. In contrast to
the 1982 regulation, the proposed regulation covers cold forming only as it pertains to cold rolling
of flat products. The Agency has determined that operations associated with cold forming of pipe
and tube and cold drawing or extrusion operations are more appropriately regulated by the
proposed Metal Products and Machinery regulation, because the products produced and
wastewater characteristics generated by these operations more closely resemble those seen in the
metal products and machinery industry. For similar reasons, electroplating of flat products at iron
and steel facilities, currently regulated by the concentration-based Metal Finishing regulation (40
CFR Part 433), is more appropriately regulated by the iron and steel effluent limitations guidelines
and standards. EPA has consequently added electroplating to the Steel Finishing Subcategory to
simplify coverage of this manufacturing operation at iron and steel facilities.

Wastewater characteristics also had an impact on modifications to the
subcategorization. The Agency determined that subcategorization and segmentation based on
wastewater characteristics is warranted because wastewaters from the various processes contain
different pollutants that generally require different wastewater control systems. However, EPA
also designed the proposed regulation to facilitate co-treatment of compatible wastewaters, by
including manufacturing operations that generate wastewaters amenable to co-treatment in the
same Subcategory. Sections 6.2 through 6.8 discuss these changes. Sections 7 and 10 discuss
wastewater characteristics and pollutant loadings, respectively.

Another appropriate revision to the 1982 subcategorization is segmentation based
on the type of steel processed. In the 1982 regulation, segments exist for carbon steel and
specialty steel (stainless and alloy steels). For the proposed regulation, the Agency determined
that, for three subcategories, it is appropriate to have separate segments for carbon and alloy
steels and for stainless steels. 'EPA determined that this change better reflects pollutants found
within each segment. For example, chromium and nickel are currently regulated in the stainless
steel segment but not in the carbon and alloy steel segment.
6-2

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Section 6 - Subcategorization
EPA evaluated other factors and determined them to be insignificant to
subcategorization. The Agency evaluated the age of facilities relative to production-normalized
wastewater discharge rates (volume of water discharged with respect to production). The
comparison between the age of the facilities and the respective process wastewater discharge rates
showed no relationships between mill age and the volume of process wastewater discharged.
Therefore, the Agency determined that the age of facilities and equipment did not have an impact
on wastewater generation or discharge. The results of EPA's analysis of facility age versus
wastewater discharge rate are located in the Iron and Steel Administrative Record for the
proposed rule.

The Agency also evaluated facility age with respect to installing or upgrading
wastewater treatment equipment and found that, while a site or a plant may have been operating
for several decades, manufacturing and treatment systems are regularly upgraded. In certain
cases, older sites actually have modern wastewater treatment systems and have demonstrated
model BAT treatment. Consequently, the Agency has determined that subcategorization based on
facility age was not warranted. In addition, since system upgrades frequently occur within the
industry, the Agency included sufficient costs in its evaluation of technology options to account .-
for treatment system modifications at all iron and steel facilities regardless of their age.

The Agency also evaluated location of sites with respect to the amount of process
wastewater discharged. While the Agency realizes that facilities located in arid and semi-arid
regions of the country may have lower discharge flow rates due to water loss from evaporation,
EPA developed the flow allowances in the proposed regulation to be achievable in any region of
the country. Therefore, the Agency determined that location was not a significant criteria for
subcategorization. The results of EPA's analysis of location versus wastewater discharge rate are
located in the Iron and Steel Administrative Record for the proposed rule.

While larger iron and steel sites discharge greater total volumes of wastewater, the
size of a site (e.g., acreage, number of employees) did not have an impact on production-
normalized wastewater discharge rates or pollutant concentrations. Consequently, the Agency
determined that size was also not a significant factor for subcategorization. Similarly, EPA
evaluated non-water quality impacts, such as solid waste and air emission effects, and determined
that theses did not constitute a basis for subcategorization in the proposed rule. However, EPA
did evaluate non-water quality impacts during EPA's rulemakihg process, as discussed in detail in
Section 13. With the exception! of the Integrated and Stand-Alone Hot Forming Subcategory,
economic impacts were determined not to have an impact on subcategorization. Section 9
presents a detailed discussion of economic impacts.

Since the elements to these factors have not changed since the 1982 rule, refer to
Volume I of the Technical Development Document for the 1982 regulation (pages 155 to 163,
EPA 440/1-82/024, May 1982) for a more detailed review of the above factors.
6-3

-------
Section 6 - Subcategorization
6.2
Subcategorv A: Cokemaking
Cokemaking operations include foundry and blast furnace coke production at
integrated and stand-alone facilities. The Cokemaking Subcategory has been segmented into by-
product recovery and non-recovery cokemaking operations. The Non-recovery Cokemaking
Segment includes non-recovery cokemaking processes that have either existed for many years or
are currently emerging in the industry. Other than low-volume boiler blowdown and process area
storm water, non-recovery cokemaking processes do not generate wastewater like the by-
product recovery processes do. This major difference in wastewater flow necessitated the
segmentation of this subcategory. Two stand-alone facilities in the United States practice non-
recovery cokemaking.

By-product recovery coke plants comprise 23 of the 25 cokemaking facilities in
the United States. All 9 integrated facilities with coke plants and 14 of the 16 stand-alone
cokemaking facilities operate by-product ovens. By-product recovery cokemaking generates,
process wastewater from the release of moisture and volatile compounds from coal and from the
by-product recovery operations.

To reflect slightly different wastewater generation rates, the 1982 regulation
further segments by-product recovery cokemaking operations by those coke plants that
manufacture coke for blast furnaces and merchant coke plants. Merchant coke plants provide
more than 50 percent of the coke produced to operations, industries, or processes other than
ironmaking blast furnaces associated with steel production. In 1982, EPA determined that the
model flow rates for blast furnace and merchant coke plants, including control water, were 153
gallons per ton (gpt) and 170 gpt, respectively. Since EPA did not observe these differences in
wastewater generation rates when analyzing the 1997 industry survey data, the Agency eliminated
this segment. .
6.3
Subcategorv B: Ironmaking
Ironmaking operations include sintering and blast furnace ironmaking at integrated
steel plants and stand-alone facilities. The 1982 regulation distinguishes sintering and blast
furnace operations as two subcategories; EPA combined these operations into one subcategory in
the proposed regulation because of similar wastewater pollutant characteristics and the potential
for co-treatment of sintering and blast furnace wastewaters. However, the Agency divided the
subcategory into two segments, sintering and blast furnace ironmaking, based on differences in
flow rates and manufacturing processes. The Agency decided to further divide the sintering
segment due to differences in wastewater generation, as discussed below.

Facilities use two types of air pollution control systems to treat air emissions from
sinter plants: wet and dry. Sinter plants that operate dry air pollution controls do not generate
process wastewater. In 1997, "the period for which industry survey data were collected, eight
sinter plants were in operation (a ninth plant providing data had beeri inactive since 1995), six at
integrated facilities and two stand-alone facilities. Of the eight plants, six operated wet air
pollution control systems and two operated dry air pollution control systems. Since the industry
6-4

-------
Section 6 - Subcategorization
survey data were collected, one plant operating a wet air pollution control system has converted
to a dry system and another plant operating a wet air pollution control system has been
deactivated indefinitely. The four remaining sinter plants with wet air pollution control systems
are located at integrated steel plants; three of these sites co-treat sinter plant wastewater with
blast furnace wastewater, and the fourth site co-treats sinter plant wastewaters with wastewaters
from several other operations. Twenty integrated steel plants operated 40 blast furnaces in 1997.
Every blast furnace in the United States operates a wet gas cleaning system to cool and clean the
furnace off-gases prior to reuse.
6.4
Subcategorv C: Integrated Steelmaking
• ' Integrated Steelmaking operations include basic oxygen furnace (BOF)
Steelmaking., ladle metallurgy, vacuum degassing, and continuous casting manufacturing processes
at integrated steel plants. EPA combined these operations into one subcategory because of
similar wastewater pollutant characteristics and the potential for co-treatment of compatible
wastewaters. EPA'decided to further subcategorize the subcategory to the manufacturing process
level, because of differences in wastewater generation rates. These manufacturing processes are
discussed below. . .

•Facilities use three types of air pollution control systems to treat furnace off-gases
from BOF Steelmaking operations: semi-wet, wet-open combustion, and wet-suppressed
combustion. Each type of air pollution control system operates differently and generates different
wastewater flow rates. However, the wastewater characteristics are similar. Twenty integrated
steel plants and one non-integrated steel plant operate a total of 24 BOF shops. Of the 24 BOF
shops, eight use semi-wet air pollution control systems, eight use wet-open combustion air
pollution control systems, seven use wet-suppressed combustion air pollution control systems,
and one uses a combination wet-open/wet-suppressed combustion air pollution control system.

Twenty integrated steel mills operate a total of .30 continuous casters. Twenty-five
of these continuous casters cast slabs for the production of flatr-rolled products (e.g., strip and
plate); the remaining five continuous casters cast blooms and billets. The Agency determined that
the type of product cast did not have a significant impact on wastewater generation and that no
further division of continuous casting is necessary.

The 1982 regulation distinguishes Steelmaking, vacuum degassing, and continuous
casting operations as three separate subcategories. The new Subcategorization consolidates these
operations into the Integrated Steelmaking Subcategory due to similarities in their wastewater.
EPA proposes to regulate electric arc furnace (EAF) Steelmaking (which was part of the 1982
Steelmaking Subcategory) under the Non-Integrated Steelmaking and Hot Forming Subcategory,
as well as vacuum degassing, ladle metallurgy, and continuous casting operations at non-
integrated plants. The Agency proposes segregating Steelmaking operations at integrated plants
and non-integrated plants to simplify the structure of the regulation and because different
wastewater generation rates were observed between integrated and non-integrated plants.
6-5

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Section 6 - Subcategorization
6.5
Subcategory D; Integrated and Stand-Alone Hot Forming
Integrated and stand-alone hot forming operations include all hot forming
processes at integrated steel plants and stand-alone hot forming mills. Four different types of hot
forming mills are operated at integrated and stand-alone facilities: flat mills (hot strip and sheet
mills and plate mills), primary mills (slabbing and blooming mills), section mills (bar and rod
mills), and hot formed pipe and tube mills. The 1982 regulation segregates the Hot Forming
Subcategory into four different segments based on differences in flow rates:

1. Primary mills
• Carbon and specialty primary mills with scarfing,
• Carbon and specialty primary mills without scarfing;

2. Section mills
• Carbon section mills,
• Specialty section mills;

3. Flat mills
• Carbon and specialty hot strip and sheet mills,
• Carbon plate mills,
• Specialty plate mills; and

4. Pipe and tube mills.
IT
In the proposed regulation, EPA proposes two segments, Carbon and Alloy Steel
and Stainless Steel, for the Integrated and Stand-Alone Hot Forming Subcategory because of
differences hi pollutants present in the wastewater. EPA did not propose to segment this
Subcategory based on mill type because the Agency has determined that all hot forming mills can
achieve the same wastewater discharge rate with the proper use of wastewater recycle. The 1982
Hot Forming Subcategory also regulates hot forming processes at non-integrated plants; however,
EPA proposes to regulate non-integrated hot forming processes under the Non-Integrated
Steelmaking and Hot Forming Subcategory to simplify the structure of the regulation.
6.6
Subcategory E: Non-Integrated Steelmaking and Hot Forming
Non-integrated Steelmaking and. hot forming operations include EAF Steelmaking,
ladle metallurgy, vacuum degassing, continuous casting, and hot forming operations performed at
non-integrated mills. EPA has combined these operations into one subcategory because of similar
wastewatqr pollutant characteristics and the potential for co-treatment of these wastewaters.
EPA proposes two segments, Carbon and Alloy Steel and Stainless Steel, in this subcategory due
to differences in wastewater pollutant characteristics. EPA decided to further divide these
segments based on differences in manufacturing operations.

Departing from the structure of the 1982 regulation, EPA proposes the Non- •
Integrated Steelmaking and Hot Forming Subcategory to simplify the regulatory structure by
6-6

-------
Section 6 - Subcategorization
grouping the basic steelmaking and hot forming operations performed at non-integrated plants
under one subcategory. In addition, the Agency proposes to separate the non-integrated and'
integrated steelmaking .and hot forming operations because of major differences in the flow rates.
Non-integrated facilities demonstrate substantially lower wastewater flow rates due to their lower
water application rates, use of high-rate water recycle systems, and good water management
practices.
6.7
Subcategorv F; Steel Finishing
Since extensive co-treatment of steel finishing wastewaters is currently practiced
by the industry, the Agency proposes a simplified regulatory structure for steel finishing
operations because of the compatibility of wastewaters for treatment. In addition, EPA proposes
that the proposed regulation no longer apply to several types of products (e.g., bars, billets, rods,
and wire) that are currently regulated by the 1982 regulation. The Agency has determined that
finishing operations for these products .are more appropriately regulated by the proposed Metal
Products and Machinery rule (see Section 1).

Steel finishing operations include salt bath and electrolytic sodium sulfate (ESS)
descaling, acid pickling, cold forming, alkaline cleaning, continuous annealing, hot coating, and
electroplating at integrated, non-integrated, and stand-alone facilities. EPA divided this
subcategory into Carbon and Alloy Steel and Stainless Steel Segments due to variations in
wastewater pollutant characteristics and flow rates.

Carbon and Alloy Steel Finishing

After reviewing the industry survey data, the Agency identified nine discrete
manufacturing operations for the Carbon and Alloy Steel Segment of the Steel Finishing
Subcategory:

1. Hydrochloric acid pickling;
2. Sulfuric acid pickling;
3. Acid regeneration; • _'
4. Cold forming;
5. Alkaline cleaning;
6. Continuous annealing;
7. Hot coating;
8. Electroplating; and
9. Wet air pollution control devices.

EPA decided to further subcategorize to the manufacturing process operation level for this
subcategory because of differences in wastewater flow rates. These operations are described
below.

• EPA has defined acid pickling lines as including annealing and other surface
cleaning and surface preparation operations located on the same line. The Agency grouped three
6-7

-------
Section 6 - Subcdtegorization
acid pickling manufacturing operations in this segment: hydrochloric acid pickling, sulfuric acid
pickling, and acid regeneration. Different acid types generate different wastewater flow rates.
The following table shows the acid pickling manufacturing operations and the associated product
types in the Carbon and Alloy Steel Segment.

Carbon and Alloy Steel Acid Pickling Operations and Product Types
Acid Pickling Operation
Hydrochloric Acid Pickling
Sulfuric Acid Pickling
Acid Regeneration
Product Type
• Strip, sheet
• Bar, billet, rod, coil
• Pipe, tube
• Plate
• Strip, sheet
• Bar, billet, rod, coil
• Pipe, tube
• Plate
• Fume Scrubbers
Cold forming operations in the proposed rule apply to only cold rolling of flat
products. Other cold forming operations are to be regulated by the proposed Metal Products and
Machinery effluent guidelines limitations and standards. Cold forming operations in this segment
include single and multiple rolling stands on a given mill. Furthermore, three methods of rolling
solution application are included: direct, recirculation, or combinations of direct and recirculation.

Alkaline cleaning operations in this segment include stand-alone alkaline cleaning
lines and continuous annealing/alkaline cleaning lines (i.e., alkaline cleaning lines with continuous
annealing located on the same continuous line). The two product types for carbon and alloy steel
alkaline cleaning are: 1) strip and sheet; and 2) pipe and tube. Although the wastewater
characteristics are similar, different product types generate different wastewater flow rates.

Stand-alone continuous annealing operations in this segment include lines with and
without a water quench. Quench water is the only source of wastewater from these lines.

Hot coating operations in this segment include continuous process lines having
surface cleaning and surface preparation operations located on the same line. The proposed
regulation covers hot coating of flat steel product only (i.e., strip, sheet, and plate).

Electroplating operations in this segment include continuous process lines having
surface cleaning and surface preparation operations located on the same line. Electroplating
operations include tin/chrome electroplating of strip and sheet, other metal electroplating of strip
and sheet, and electroplating of plate. Different operations generate different wastewater flow
rates. '
6-8

-------
Section 6 - Subcategorization
Although electroplating at iron and steel facilities is currently regulated by 40 CFR
Part 433, Metal Finishing, the Agenc)' has determined that it is appropriate to-regulate
electroplating of flat products in the proposed regulation because a large number of iron and steel
facilities perform these operations. With pretreatment where appropriate, electroplating
wastewaters are compatible with wastewaters from other steel finishing operations. Additionally,
by covering electroplating in the iron and steel regulation, all operations at iron and steel mills will
have production-based limitations. Currently, the electroplating limitations in the Metal Finishing
effluent limitation guidelines and standards are concentration-based, requiring permit writers to
combine production- and concentration-based limitations when permitting iron and steel facilities
with electroplating operations. Therefore, the proposed regulation simplifies the current
permitting process for flat product electroplating.

Stainless Steel Finishing

After reviewing the survey data, the Agency identified six discrete manufacturing
operations for the Stainless Steel Finishing Segment of the Steel Finishing Subcategpry:

1. Acid pickling and other descaling;
2. Acid regeneration;
3. Cold forming;
4. Alkaline cleaning;
5. Continuous annealing; and
6. Wet air pollution control devices.

Differences in wastewater flow rates and process operations were the basis for the
divisions in the Stainless Steel Finishing Segment. Certain manufacturing operations have been
further divided on the basis of product type to account for wastewater flow rate differences within
a given operation. Although the wastewater characteristics are similar among the operations,
different operations generate different wastewater flow rates.

After reviewing the industry survey data, the Agency did not identify any stand-
alone salt bath or ESS descaling lines. The information in the industry survey responses indicated
that salt bath and ESS descaling operations currently take place on stainless steel acid pickling
lines. Therefore, salt bath and ESS descaling will be accounted for in stainless steel acid pickling
operations. EPA has defined acid pickling operations as including annealing and other surface
cleaning and surface preparation operations located on "the acid pickling line. The Agency
grouped two operations for stainless steel acid pickling: acid pickling and other descaling
operations and acid regeneration. The following table shows acid pickling manufacturing
operations and their associated product types in the Stainless Steel Segment.
6-9

-------
                                                                   Section 6 - Subcategorization
                Stainless Steel Acid Pickling Operations and Product Types
              Acid Pickling Operation
                                                 Product Types
 Acid Pickling and Other Descaling
                                       • Strip, sheet
                                       • Bar, billet, rod, coil
                                       • Pipe, tube
                                       • Plate
 Acid Reeeneration
                                         Fume Scrubbers
              Cold forming operations in the proposed rule apply to only cold rolling of flat
products.  Other cold forming operations are to be regulated by the proposed Metal Products and
Machinery effluent guidelines limitations 'and standards.  Cold forming operations in this segment
include single and multiple rolling stands on a given mill. Furthermore, three methods of rolling
solution application are included:  direct, recirculation, or combinations of direct and
recirculation.

              Alkaline cleaning operations in this segment include stand-alone alkaline cleaning
lines and continuous annealing/alkaline cleaning lines (i.e., alkaline cleaning lines with continuous
annealing located on the same continuous line). Operations with different product types generate
different wastewater flow rates. The two product types for stainless steel alkaline cleaning are: 1)
strip and sheet; and 2) pipe and tube.

              Stand-alone continuous annealing operations in this segment include lines with and
without a water quench. Quench water is the only source of wastewater from these lines.
6.8
Subcategorv G: Other Operations
              The Other Operations Subcategory includes the following three segments: direct
reduced ironmaking, forging, and briquetting operations.  The Agency determined that it is
necessary to segment this subcategory on the basis of manufacturing process differences and
wastewater flow rate differences.  These manufacturing operations are not covered by the 1982
regulation; however, because these manufacturing operations are directly related to iron and steel
production and are performed at iron and steel sites, the Agency determined that it is appropriate
to regulate them under the proposed regulation.
                                           6-10

-------
      Table 6-1
1982 Subcategorization
Subcategory
A
B
C
D
E
F
G
Cokemaking
Sintering
Ironmaking
Steelmaking
Vacuum Degassing
Continuous Casting
Hot Forming


Segment
By-Product
Beehive
—
Iron Blast Furnace
Ferromanganese Blast Furnace
Basic Oxygen Furnace
Open Hearth Furnace
Electric Arc Furnace
—
___
Primary
Section

Flat


Pipe and Tube Mills
Manufacturing Process
Iron and Steel
Merchant
•
—
—

Semi-Wet
Wet-Suppressed Combustion
Wet-Open Combustion
Wet
Semi-Wet
Wet
—
.
Carbon and Specialty Mills
without Scarfers
Carbon and Specialty Mills
with Scarfers
Carbon Mills
Specialty Mills
Hot Strip and Sheet Mills
Carbon Plate Mills
Specialty Plate Mills . .
—
        6-11

-------
Table 6-1 (Continued)
Subcategory
H
I
Salt Bath Descaling
Acid Pickling
Segment
Oxidizing
Reducing
Sulfuric Acid
Hydrochloric Acid
Combination Acid
Manufacturing Process
Sheet, Plate - Batch
Rod, Wire, Bar - Batch
Pipe, Tube - Batch
Continuous
Batch
Continuous
Rod, Wire; Coil
Bar, Billet, Bloom
Strip, Sheet, Plate
Pipe, Tube, Other
Fume Scrubber
Rod, Wire, Coil
Strip, Sheet, Plate
Pipe, Tube, Other
Fume Scrubber
Acid Regeneration
Rod, Wire, Coil
Bar, Billet, Bloom
Strip, Sheet, Plate -
.Continuous
Strip, Sheet, Plate - Batch
Pipe, Tube, Other
Fume Scrubber
         6-12

-------
Table 6-1 (Continued)
Subcategory
J
K
L
Cold Forming
Alkaline Cleaning
Hot Coating
Segment
Cold Rolling .
Cold Worked Pipe and Tube
Batch
Continuous
Galvanizing, Teme, and Other
Metal Coatings
Fume Scrubbers-
Manufacturing Process
Recirculation: Single Stand
Recirculation: Multiple Stand
Combination
Direct Application: Single
Stand
Direct Application: Multiple
Stand
Water Solutions
Oil Solutions
-
---
Strip, Sheet, and
Miscellaneous Products
Wire Products and Fasteners
.
        6-13

-------
                                             Table 6-2
                                    Proposed Subcategorization
Subcategory
A
B
C
D
E
Cokemaking
Ironmaking
Integrated Steelmaking
Integrated and Stand-
Alone Hot Forming
Non-Integrated
Steelmaking and Hot
Forming
Segment
By-Product Recovery
Non-Recovery
Sintering
Blast Furnace

Carbon and Alloy Steel
Stainless Steel
Carbon and Alloy Steel
Stainless Steel
Manufacturing Process
•
—
Wet Air Pollution Controls
Dry Air Pollution Controls
—
Basic Oxygen Furnaces
Semi-Wet
Wet-Suppressed Combustion
Wet-Open Combustion
Ladle Metallurgy
Vacuum Degassing
Continuous Casting
—
—
Electric Arc Furnaces
Ladle Metallurgy
Vacuum Degassing
Continuous Casting
Hot Forming
Electric Arc Furnaces
Ladle Metallurgy
Vacuum Degassing
Continuous Casting
Hot Forming
_
                                               6-14

-------
                          Table 6-2 (Continued)
   Subcategory
        Segment
    Manufacturing Process
Steel Finishing
Carbon and Alloy Steel
Hydrochloric Acid Pickling
  Strip, Sheet
  Bar, Billet, Rod, Coil
  Pipe, Tube
  Plate
                                                 Sulfuric Acid Pickling
                                                   Strip, Sheet
                                                   Bar, Billet, Rod, Coil
                                                   Pipe, Tube
                                                   Plate
                                                 Acid Regeneration
                                                   Fume Scrubbers
                                                 Cold Forming
                                                   Single Stand - Once Through
                                                   Single Stand - Recirculation
                                                   Multiple Stand - Once Through
                                                   Multiple Stand - Recirculation
                                                   Multiple Stand - Combination
                                                Continuous Annealing
                                                   With Water Quench
                                                   Without Water Quench
                                                Alkaline Cleaning
                                                   Sheet, Strip
                                                   Pipe, Tube
                                                Hot Coating
                                                   Galvanizing, Terne, and Other
                                                   Metals
                                                Electroplating
                                                   Sheet, Strip: Tin, Chromium
                                                   Sheet, Strip: Zinc, Other Metals
                                                   Plate
                                                Wet Air Pollution Control Devices
                                                   Fume Scrubbers
                                   6-15

-------
Table 6-2 (Continued)
Subcategory
F
G
Steel Finishing (cont.)
Other Operations
Segment
Stainless Steel
Direct Iron Reduction
Forging
Briquetting
Manufacturing Process
Acid Pickling and Other Descaling:
Strip, Sheet
Bar, Billet, Rod, Coil
Pipe, Tube
Plate
Acid Regeneration
Fume Scrubbers
Cold Forming
Single Stand - Once Through
Single Stand - Recirculation
Multi Stand - Once Through
Multi Stand - Recirculation
Multi Stand - Combination
Continuous Annealing
With Water Quench
Without Water Quench
Alkaline Cleaning
Sheet, Strip
Pipe, Tube
Wet Air Pollution,Control Devices
• Fume Scrubbers
—
---
—
        6-16

-------
                        Table 6-3
Subcategory Comparison of the 1982 and Proposed Regulations
1982 Regulation
A. Cokemaking
B. Sintering
C. Ironmaking
D. Steelrhaking
E. Vacuum Degassing
F. Continuous Casting
G. Hot Forming
H. Salt Bath Descaling
[. Acid Pickling
J. Cold Forming
£. Alkaline Cleaning
L. Hot Coating

Proposed Regulation
A. Cokemaking
B. Ironmaking
C. Integrated
Steelmaking
D. Integrated and
Stand- Alone Hot
Forming
E. Non-Integrated
Steelmaking and
Hot Forming
F. Steel Finishing
G. Other Operations
                         6-17

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-------
                                                           Section 7 - Wastewater Characterization
                                       SECTION?

                        WASTEWATER CHARACTERIZATION

              This section presents information on manufacturing process wastewater flow rates
 and the pollutants generated from iron and steel manufacturing operations. All estimates
 presented in this section are based on industry information collected for the 1997 calendar year.
 The selected pollutants of concern (POCs) for each subcategory and segment and the selected
 model treatment system flow rates for each technology option are also presented.  Sections 7.1
 and 7.2, respectively, discuss the methodologies for selecting POCs and model flow rates.
 Sections 7.3 through 7.9 present wastewater sources, pollutants of concern, and wastewater flow
 rates for each of the seven subcategories.
 7.1
Identification of Pollutants of Concern
              EPA selected POCs for each subcategory to screen for possible regulation and also
 to use them as the list of pollutants for which to perform the loading reduction calculations and
 the environmental assessment analysis. From the list of POCs for each subcategory, EPA
 determined the list of pollutants to regulate. Section 11 describes the selection of regulated
 pollutants.  The Agency took the following approach in identifying POCs.

 .  -           EPA used analytical data collected during the sampling episodes conducted at 16 •
 iron and steel facilities as the dataset for the screening (see Section 3). EPA analyzed untreated
 wastewater samples from each manufacturing process characterized to identify pollutants present ,
 in wastewaters from each process.  For each manufacturing process analyzed, EPA selected POCs
 using the following detection criteria:

              •      The pollutant was detected at greater than or equal to 10 times the
                    minimum level (ML) concentration in at least 10 percent of all untreated
                    process wastewater samples; and

             ,•      The mean detected concentration in untreated process wastewater samples
                    was greater than the mean detected concentration in the source water
                    samples.
considerations:
             In addition to the criteria outlined above, the Agency made the following
                    EPA considered three pollutants as POCs for all manufacturing processes,
                    independent of the above criteria: total suspended solids (TSS), oil and
                    grease measured as hexane extractable material (HEM), and total
                    petroleum hydrocarbons measured as silica gel treated hexane extraptable
                    material (SGT-HEM).  These analytes are present to some degree in nearly
                                          7-1

-------
Section 7 - Wastewater Characterization
all steel industry process wastewater and are important indicators of overall
wastewater treatment system performance.

EPA did not evaluate pH as a candidate POC, since pH is not expressed in
terms of quantity or concentration. However, the pH level is an important
wastewater characteristic and an important indicator of wastewater
treatment system performance in many applications in the steel industry, so
EPA is proposing to regulate pH. •

• Except where noted, EPA excluded the following pollutants from
consideration as POCs for all manufacturing process divisions because they
• • are either dissolved substances or common elements found in wastewater,
and because some of them are not treatable: TSS,.calcium, chloride,
sodium, total sulfide, and sulfate.

Because the Agency generally considers wastewater from manufacturing processes
within a segment of a subcategory to be compatible and co-treatable, EPA generated segment-
level POC lists to use in subsequent analyses. See Section 6 for a discussion of subcategorization
and segmentation. Below is the rationale for determining how each segment-level POC list was
developed for each segmented subcategory:

Cokemaking Subcategorv. EPA selected POCs for the By-Product
Segment of this subcategory. EPA did not select POCs for the Non-
Recovery Segment, as non-recovery cokemaking operations do not
generate process wastewater.

. Ironmaking Subcategorv. Because the characteristics of wastewater. in this
subcategory's two segments are somewhat different, EPA selected two
lists of POCs for this subcategory, one for the Blast Furnace Segment and
one for the Sintering Segment.

. Integrated Steelmaking Subcategorv. Because wastewater from each of
the three manufacturing processes that generate process wastewater (basic
oxygen furnaces, vacuum degassing, and continuous casting) in this
subcategory are commonly co-treated, EPA selected POCs for each
manufacturing process, and then compiled the list of POCs for the
subcategory from those pollutants that were selected as POCs in at least
one of the three manufacturing processes.

. Integrated and Stand-Alone Hot Forming Subcategorv. Because the
characteristics of wastewater from this subcategory are affected by the type
of steel'processed, EPA selected two lists of POCs for this subcategory,
one for the Carbon and Alloy Steel Segment and one for the Stainless Steel
Segment.
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Section 7 - Wastewater Characterization
Non-Integrated Steelmaking and Hot Forming Subcategory. For the same
reason as stated above, EPA selected two lists of POCs for the Carbon and
. Alloy Steel Segment and the Stainless Steel Segment. Moreover, because
wastewater streams from each of the three manufacturing processes that
generate process wastewater (vacuum degassing, continuous casting, and
hot forming) within each segment are compatible and are commonly co-
treated, the list of POCs for each segment comprises those pollutants that
were selected as POCs in at least one of the three manufacturing processes.

Steel Finishing Subcategory. EPA selected two lists of POCs for the .
Carbon and Alloy Steel Segment and the Stainless Steel Segment. EPA
compiled the lists of POCs for the two segments in the same way as for the
Non-Integrated Steelmaking and Hot Forming Subcategory.

Other Operations Subcategory. EPA selected POCs for the Direct
Reduced Ironmaking Segment of this Subcategory. EPA did not sample
forging operations during the sampling program and, therefore, did not
select POCs for the Forging Segment. EPA did-not select POCs for the .
Briquetting Segment, as briquetting operations do not discharge process
wastewater.
7.2
Calculation of Production-Normalized Flow Rates
EPA's selection of model treatment system flow rates has a large impact on
development of the effluent limitations guidelines and standards. This section reviews the
Agency's methodology for selecting the process wastewater flow rate for each manufacturing
operation that is used in developing the proposed effluent limitations guidelines and standards.
These flow rates are expressed as production-normalized flow rates (PNFs) in terms of gallons of
water discharged per ton of production (gpt) for all operations except certain wet air pollution
control devices associated with steel finishing operations, where the flow rates are expressed in
gallons per minute (gpm), since they are independent of production.

Because the Agency considers good water management practices and decreased
wastewater discharge volumes to be key components of effective pollution control, it has selected
its model discharge flow rates based on the better performing mills within a given Subcategory or
segment. EPA also considered whether all facilities within any given segment can achieve the
selected PNFs. The Agency has concluded that all of the selected model flow rates that are
described in the subsequent subsections are both well demonstrated and achievable.

The Agency analyzed industry survey data for each manufacturing unit or process
line within the Subcategory or segment to determine model treatment system flow rates. EPA .
.used the industry survey data to identify every source of process wastewater generated by a
manufacturing operation. With each source of process wastewater identified, the Agency
calculated the total process wastewater discharge flow rate for each manufacturing operation.
7-3

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Section 7 - Wastewater Characterization
Table 7-1 provides EPA's estimates for the annual discharge rate by operation and discharge type
(direct or indirect) and the number of zero or alternative dischargers for each operation. Most
zero or alternative dischargers are non-integrated, stand-alone hot forming, or stand-alone
finishing facilities.

To normalize flow rates across the industry and for a range of facility sizes, EPA
then calculated PNFs for each manufacturing operation in a given segment. Calculating PNFs for
the individual operations allowed EPA to develop a profile of PNFs across a given segment. The
Agency analyzed these profiles for trends and similar characteristics to develop a well-
demonstrated model flow rate for each segment.

EPA did not include nonprocess wastewater sources in the calculation of PNFs.
The largest source of nonprocess wastewater is-noncontact cooling water, but other sources
include storm water and recovered ground water. Nonprocess wastewaters were not included in
the calculation of PNFs because: 1) EPA calculated the amount of wastewater directly generated
from manufacturing operations that displayed wastewater characteristics requiring treatment, and
2) nonprocess wastewater differs from process wastewater in that it does not directly contact
processed or raw materials as part of the manufacturing operations, and often does not require
treatment. EPA recognizes that storm water from iron and steel sites can become contaminated
with a variety of pollutants from raw materials and finished products that are stored outdoors, and
may require treatment before discharge. However, EPA determined that it was not appropriate to
include weather-variable storm water flows in the PNFs. .

For those manufacturing operations where high-rate recycle is a principal
component of the model treatment technology, the Agency selected PNFs by analyzing recycle .
system recirculating water rates and blowdown flow rates. EPA selected a model flow rate from
the best performing mills exclusive of those systems achieving zero discharge. The Agency
justifies this approach because the owner or operator directly controls the volume of the discharge
by controlling the process water treatment and recycle system. This is accomplished by managing
the amounts of make-up water and storm water entering the system, removing and/or minimizing
the potential for nonprocess wastewater entering the system, and by controlling recirculating
water chemistry to prevent fouling and scaling, where necessary. EPA also included sufficient
costs in the cost models to account for flow rate reductions. To identify the best performing
mills, EPA looked at each segment independently to identify discriminating characteristics that
influence the amount of wastewater generated and discharged.

For most manufacturing operations where high-rate recycle is not a principal,
component of the technology options, the Agency chose to use a PNF approximating the median
PNF reported by the industry in those subcategories and segments. EPA determined that
selecting median flow rates for once-through systems accurately represents well-demonstrated
flow rates because 50 percent of the subcategory or segment is able to achieve the model flow
rate. However, for a few segments (e.g., carbon and alloy hydrochloric acid pickling - strip and
sheet, carbon and alloy sulfuric acid pickling - strip and sheet) where data clearly indicated a well-
demonstrated flow rate below the median, the Agency selected a model flow rate less than the
.• 7-4

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Section 7 - Wastewater Characterization
median. For those manufacturing operations where the selected model flow rate is greater than
the median, the Agency determined that the costs associated with meeting the median flow rate
would preclude certain sites from'being able to. obtain the model flow rate. EPA looked at each
segment independently to identify discriminating characteristics that influence the amount of
wastewater generated and discharged. The Agency included sufficient costs in its models to.
account for flow rate reductions, and, in some cases, transferred flow rates from the 1982
regulation. •

The following seven subsections present wastewater sources, pollutants of
concern, and wastewater flow rates for each proposed subcategory.
7.3
Gokemaking Subcategorv
Sources
The proposed Cokemaking Subcategory covers the by-product and non-recovery
cokemaking segments. EPA analyzed industry survey responses for 16 stand-alone coke plants
and nine coke plants at integrated mills to develop the model PNF; one stand-alone non-recovery
coke plant began operations after 1997 but was still used in the flow, rate analysis. Three sites are
zero discharge sites: two do not generate process wastewater (non-recovery cokemaking sites)
and one disposes of its wastewater by a combination of coke quenching and deep-well injection.
The Agency evaluated the 23 sites that generate process wastewater to develop a profile of the
wastewater generated at cokemaking facilities.

. By-product cokemaking operations generate wastewater from a number of
sources. The greatest volume of wastewater generated at by-product sites is waste ammonia
liquor, which is the condensed combination of coal moisture and volatile compounds released
from the coal during the coking process. Nearly all sites reported other sources of wastewater,
including the following:

• Coke oven gas desulfurization;

• Crude light oil recovery;

• Ammonia still operation;

• Final gas coolers;

• National emission standards for hazardous air pollutants (NESHAP)
controls for benzene;

• Barometric condensers; • .

• Coke oven gas condensates;
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                                                          Section 7 - Wastewater Characterization
              •      Equipment cleaning;

              •      Excess coke quenching water; and

              •      Wet air pollution control devices used to control emissions from coal
                     charging and coke pushing.

              Pollutants of Concern

              Based on an analysis of EPA sampling data and industry-provided data from the
analytical and production survey (see Section 3), EPA determined that by-product cokemaking
wastewater contains O&G, ammonia-N, cyanides, thiocyanates, phenolics, benzene, toluene,
xylene, benzo(a)pyrene, and numerous other volatile organic compounds and polynuclear
aromatic compounds.  From the sampling data, EPA selected 71 POCs for the By-Product
Segment of the Cokemaking Subcategory, presented in Table 7-2. EPA included total Kjeldahl
nitrogen (TKN), weak acid dissociable (WAD) cyanide, and thiocyanate as POCs because they
are widely present in cokemaking wastewater (each was detected at significant concentrations in
all  16 untreated cokemaking wastewater samples collected) and are  important indicators of
biological treatment effectiveness.  However, since no method minimum levels (MLs) were
specified at the time of this analysis, they could not be evaluated with the POC selection criteria.
Even though nitrate/nitrite failed the screening criteria, EPA selected it as a POC because of its
importance as an indicator of biological treatment effectiveness.

              Wastewater Flow Rates

              After identifying the wastewater sources identified by the industry survey
respondents, the Agency determined representative flow rates for each of the sources.  The total
model flow rate for by-product cokemaking was the sum of each of these sources. The waste
ammonia liquor, crude light oil recovery, final gas cooler condensate, barometric condenser
blowdown, and control water PNFs are unchanged from the model PNFs in the 1982 regulation.
Review of the industry survey data determined that the current flow  rates are still applicable and
achievable. EPA did not consider a flow allowance for coke oven gas condensates when
developing the model PNF for the 1982 regulation.  However, in the industry survey, 14 sites
reported collecting and treating coke oven gas condensates; reported flow rates ranged from less
than 1 gpt to approximately 4 gpt.  Therefore, the Agency determined that a flow allowance of 3
gpt was appropriate for coke oven gas condensates. EPA decreased the flow allowance for
ammonia still steam from 13 gpt in the 1982 regulation to 10 gpt in the proposed regulation,
because six of the 11 sites that reported a flow rate for ammonia still steam indicated flow rates
below 10 gpt.

              EPA proposed that the miscellaneous flow rate be increased from 20 gpt in the
1982 regulation to 25 gpt. This increase accounts for additional wastewater  treated at coke plant
treatment systems, primarily collected storm water and other miscellaneous waters collected from
the site. Many sites have improved their collection of miscellaneous waters since the
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'Section 7- Wastewater Characterization
promulgation of the 1982 regulation. The Agency believes that collecting and treating these
waters prior to discharge is a good operating practice and thus proposes an increased flow
allowance for these miscellaneous wastewaters.

Excess coke quenching water is another potential source of wastewater reported in
the industry surveys. Water used for coke quenching is typically plant service water or treated
coke plant wastewater. The Agency does not advocate the practice of coke quenching with
untreated wastewater because of the potential for air pollution and ground water contamination
associated with this practice. To the Agency's knowledge, coke quenching with untreated .
process wastewaters is no longer practiced at any of the coke plants that responded to the
industry survey. Standard industry practice is to recycle coke quenching water to extinction;
therefore, the Agency did not give an allowance for excess coke quenching water. Similarly, it is
also standard industry practice to dispose of wastewater from wet air pollution control (WAPC)
systems from coke pushing by coke quenching. The Agency supports this practice because this
type of WAPC wastewater does not contain volatile pollutants found in waste ammonia liquor
and other untreated wastewaters. Because coke quenching has been designated as a zero
discharge operation, EPA gave no additional flow allowance for WAPC wastewater from coke
pushing.

EPA also proposes supplemental allowances for those sites that operate wet coke
oven gas desulfurization systems or NESHAP control systems that generate process wastewater.
Since these operations are not practiced by a large percentage of the industry, the Agency found it
inappropriate to use these operations to develop the model by-product cokemaking PNF.
However, the Agency does realize that these operations generate process .wastewater and has
developed additional allowances for those sites that operate wet desulfurization systems or
NESHAP control systems. An additional 15 gpt would be allowed for wet desulfurization, while
an additional 10 gpt would be allowed for NESHAP controls. Approximately 50 percent of the
sites reporting these wastewater sources achieve both of these flow rates; therefore, the Agency
has determined that these flow rates are well demonstrated and appropriate for the industry. The
proposed regulation also contains provisions that would allow National Pollutant Discharge
Elimination System (NPDES) and pretreatment permitting authorities to develop, on a site-
specific basis, supplemental mass effluent limitations and standards for Wastewater resulting from
coke plant ground water remediation systems and air pollution control systems not considered in
the proposed rulemaking. .:

EPA determined that biological wastewater treatment systems used to treat
cokemaking wastewaters often use control water for toxicity control. To determine an
appropriate flow rate, EPA analyzed control water flow rates from the industry survey and the
1982 development document (Reference 7-1). After comparing these data, the Agency
determined that the 50-gpt flow allowance from the 1982 development document was still
appropriate because of the number of sites currently using that approximate volume of control
water to effectively operate their treatment system. Moreover, one coke plant demonstrating best
available technology economically achievable (BAT) treatment is using control water at a rate of
approximately 50 gpt to achieve its treatment effectiveness.
7-7

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                                                          Section.7 - Wastewdter Characterization
              The following table presents the model PNFs for each source and the overall by-
product cokemaking model PNF.

                     By-Product Cokemaking Wastewater Flow Rates
Wastewater Source
Waste ammonia liquor
Crude light oil recovery
Final gas cooler condensate
Coke oven gas condensate
Barometric condenser blowdown
Steam and caustic solution from ammonia still
Miscellaneous3
Total base flow
Control water (dilution water added to control
toxicity prior to biological treatment)
Total base flow with control water
PNF(gpt)
32
25 . -
10
3
3
10
25
108
50
158
          "Miscellaneous sources include such flows as equipment cleaning water, storm water, and
          other wastewater collected and treated from cokemaking or by-product recovery operations.

              EPA determined that the selected cokemaking model flow rate is well
demonstrated because each of the sites identified as operating a BAT treatment system is able to
achieve the model flow rate.  The Agency considers these sites to be the best performing in the
subcategory and has concluded that the flow rates that they are achieving are obtainable for every
site.

              Non-recovery cokemaking has been designated as a zero discharge operation
because it does not generate  process wastewater other than boiler blowdown and process area
storm water, which are disposed of by coke quenching.
7.4
Tronmaking Subcategorv
              Separate discussions are provided below forrthe Sintering and Blast Furnace
Ironmaking Segments of the Ironmaking Subcategory.
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Section 7 - Wastewater Characterization
7.4.1
Sintering

Sources
The Agency analyzed data from nine sites that provided industry survey
information for sintering operations. Sinter plants generate wastewater from air pollution control
systems designed to control emissions from the sinter strand wind box and material processing.
Seven sites indicated that they used WAPC systems to control air emissions from the sintering
process, while two sites used dry air pollution control (DAPC) systems. EPA analyzed
wastewater flow rate data for the six sinter plants that provided data for WAPC systems in 1997
(one site operating a WAPC reported being inactive in 1996 and 1997). Currently, only four
plants operate a WAPC system (see Section 6). All of the plants operated WAPC systems that.
recycle wastewater as part of the treatment system; blowdown from the recycle systems is the
primary source of wastewater from sintering operations. All of the sinter plants generating
process wastewater reported using wet scrubbers to control wind box emissions, and some sites
also reported using scrubbers to control emissions at the discharge end of the sinter strand.

Facilities identified other sources of sintering wastewater in the industry surveys,
including sinter cooling water, belt sprays, and equipment cleaning wafer. However, respondents
did not provide flow rate data for these sources. The Agency believes the wastewaters would be
discharged with the WAPC flow and would not have a significant impact on the model PNF.

Pollutants of Concern

Based on an analysis of EPA sampling data and industry-provided data from the
Analytical and Production Survey, EPA determined that sintering wastewater contains the
following principal pollutants: TSS, O&G, ammonia-N, cyanide, phenolic compounds, and metals
(principally lead and zinc). EPA also found that sintering wastewater contains polychlorinated
dibenzo-/7-dioxins and polychlorinated dibenzofurans (PCDDs and PCDFs, or dioxins and furans).

EPA selected 65 POCs for the Sintering Segment of the Ironrnaking Subcategory,
presented in Table 7-3. EPA selected TKN, WAD cyanide, and thiocyanate as POCs because
they are widely present in sintering wastewater (each was detected in all 10 untreated sintering
wastewater samples collected). However, since no method MLs were specified at the time of this
analysis, these pollutants could not be evaluated with the POC selection criteria.

Wastewater Flow Rates

The Agency based its selection of the model PNF on WAPC systems that operated
with greater than 95 percent wastewater recycle. The Agency considers plants with this recycle
rate representative of the best plants in this segment. Two sites reported operating their WAPC
systems at this selected recycle rate and were achieving discharge rates of 0 gpt and 73 gpt,
respectively. Using the data from these sites, the Agency selected a model sintering PNF of 75
gpt- : ,
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Section 7 - Wastewater Characterization
The Agency determined that a 75-gpt model flow rate, coupled with a 95 percent
recycle rate, is appropriate for the BAT model treatment systems, because it represents the best
demonstrated sintering wastewater treatment system flow rate. The two sites used to develop the
model flow rate are representative of other sinter operations in that they include wastewaters from
the wind box and other sources. These sites are typical of sinter plants operating WAPC systems,
are located in different regions of the country, and are owned by different companies.
Furthermore, EPA determined that this model flow rate is achievable by sinter plants that treat
sintering wastewaters in a dedicated treatment system or a combined treatment system, as the
model sites represent each of these treatment options. EPA also determined that sites not
achieving the model PNF will be able to achieve the model flow rate by increasing their
wastewater recycle to the selected recycle rate.

The Agency found that sinter plants with dry air pollution controls discharge no
process wastewater. Therefore, the Agency has designated sinter plants with dry air pollution
controls as zero discharging operations.
7.4.2
Blast Furnace Ironmaking Segment
Sources
Twenty integrated mills indicated in their industry survey responses that they
conducted blast furnace ironmaking, with 40 blast furnaces active in 1997. Wastewater from blast
furnace ironmaking is primarily generated from wet gas cleaning and cooling systems designed to
clean and cool the furnace off-gas prior to its use as a fuel in the blast furnace stoves. The gas
cleaning systems use high-energy scrubbers and gas coolers that use water to treat the gas. The
blowdown from the gas cleaning systems is the largest source of wastewater from blast furnace
ironmaking. Blast furnace gas seals, blast furnace drip legs, equipment cleaning water, and excess
slag quenching water comprise the other, relatively minor sources of process wastewater.

Pollutants of Concern

Based on an analysis of EPA sampling data and industry-provided data from the
Analytical and Production Survey, EPA determined that the principal pollutants from blast
furnaces are TSS, ammonia-N, cyanides, phenolic compounds, and metals (copper, lead, and
zinc).

EPA selected 27 POCs for the Blast Furnace Segment of the Ironmaking
Subcategory, presented in Table 7-4. EPA selected TKN, WAD cyanide, and thiocyanate as
POCs because they are widely present in blast furnace wastewater (each was detected in at least
60 percent of the untreated blast furnace wastewater samples collected). However, since no
method MLs were specified at the time of this analysis, these pollutants could not be evaluated
with the POC selection criteria.
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Section 7 - Wastewater Characterization
Wastewater Flow Rates

To analyze the wastewater discharge rates from blast furnace ironmaking, the
Agency evaluated each of the wastewater treatment systems in operation. Depending on the site,
these systems could potentially treat wastewater from one blast furnace or several blast furnaces.
EPA calculated PNFs for each wastewater treatment system identified (24 systems were identified
across the industry); therefore, a single site could have multiple PNFs.

Six water systems are achieving zero discharge and four water systems are
achieving reduced discharge of blast furnace wastewater by using all or a portion of gas cleaning
blowdown for slag quenching. One additional site achieves zero discharge by discharging gas
cleaning biowdown to one unlined and one synthetically lined pond where the wastewater
infiltrates and evaporates. The Agency does not advocate the practice of using untreated gas
cleaning blowdown for slag quenching in unlined slag pits because of ground water contamination
and the potential for air pollution associated with this practice. Therefore, the Agency has not
selected zero discharge as its model PNF for this segment.

Because slag quenching and infiltration are not endorsed methods of wastewater
disposal, EPA used the total amount of wastewater generated from blast furnace operations to
develop PNFs. • Consequently, EPA used the total gas cleaning blowdown rate from each site,
even if it was used for slag quenching, to calculate the PNFs. With this in mind, the Agency
evaluated the wastewater recycle at each of the gas cleaning systems. All but two systems recycle
gas cleaning wastewater.

EPA based the selection of a blast furnace model flow rate on a recycle rate of 98
percent. Analysis of the data the Agency considers representative of the best plants in this
segment showed eight systems recycling 98 percent or more of process wastewater. Each of
these systems achieved a discharge rate of 25 gpt or less. The flow rate data for these systems are
shown below.
Water System
A
B
C
D
E
F
G
H
Number of Furnaces
3
3 '
1
2
2
2
2
2
PNF (gpt)
4
6
6
10
17
23 .
24
25
The Agency determined that these sites were representative of this segment
because they include furnaces of various production capacities, are located in different geographic
7-11

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Section 7 - Wastewater Characterization
locations, and are owned by different companies. Additionally, these sites demonstrate that water
systems with a single or multiple blast furnaces can achieve the selected model flow rate. EPA
also has concluded that operating blast furnace wastewater treatment system with a 98 percent
recycle rate is representative of BAT treatment.
7.5
Integrated Steelmaking Subcategorv
The Agency did not find any reason to further segment the Integrated Steelmaking
Subcategory. However, EPA identified several manufacturing process divisions within the
subcategory. This subsection provides separate discussions for basic oxygen furnace (EOF)
Steelmaking, ladle metallurgy, vacuum degassing, and continuous casting.
7.5.1
Basic Oxygen Furnace (EOF) Steelmaking
Sources
Twenty integrated sites and one non-integrated site indicated in their survey
responses that they conducted EOF Steelmaking operations; 24 EOF shops were identified, as
active in 1997. The primary source of wastewater from EOF steelmaking is air pollution control
systems designed to treat furnace off-gases prior to release into the atmosphere. Each active EOF
shop uses one of three types of WAPC systems: semi-wet, wet-open combustion, or wet-
suppressed combustion. These WAPC systems operate differently. Semi-wet systems apply
water to the furnace off-gases to condition the off-gases prior to treatment in an electrostatic
precipitator (ESP). A wet-suppressed system is a high-energy wet scrubbing system that limits
excess air entering the furnace mouth, minimizing carbon monoxide combustion and thus
minimizing the volume of gas requiring treatment. A wet-open system is a gas cleaning system
that admits excess air to allow the combustion of carbon monoxide prior to high-energy
scrubbing. EPA separated and analyzed the flow rate data for EOF steelmaking based on the type
of WAPC system used at the EOF shop because of differences in water application rates,
discharge rates, and industry-demonstrated recycle rates. Other wastewater sources include slag
quenching water, hood cooling water losses, cooling tower, blowdown, and equipment cleaning
water.

Pollutants of Concern

Based on an analysis of EPA sampling data and industry-provided data from the
Analytical and Production Survey, EPA determined that the principal pollutants from BOFs are
TSS and metals (lead and zinc). EPA selected 28 POCs for EOF steelmaking, presented in Table
7-5. .
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Section 7 - Wastewater Characterization
Wastewater Flow Rates .. •

During the analysis, EPA identified eight BOF shops operating semi-wet air
pollution control systems. Two sites reported zero discharge of process wastewater, while one
site reported a discharge of 1 gpt. One other site reported a discharge of less than 10 gpt. Sites
achieve zero or relatively low discharges from their semi-wet systems by balancing the applied
water with water that evaporates in the conditioning process. Although the 1982 regulation
designates semi-wet air pollution control as zero discharge, currently not all of the sites are able
to achieve this discharge status because of safety considerations. Some sites operate their semi-
wet systems with excess water, which is subsequently discharged, to flush the air pollution control
ductwork and prevent the buildup of debris within the ductwork. If this wet debris accumulates,
it has the potential to fall back into the BOF, causing explosions and process upsets. The Agency
recognizes the benefit of using excess water in these systems and has selected a semi-wet air
pollution control model PNF of 10 gpt. The Agency justifies the increased allowance in this case
because of the safety and manufacturing considerations impacted by the operation of the air
pollution control system. The Agency determined that all sites can achieve this proposed model
flow rate.

, EPA also identified seven BOF shops operating wet-suppressed combustion air
pollution control systems. All of the shops operate their treatment systems with wastewater
recycle. The Agency based the model flow rate selection on those BOF shops that operate
recycle systems with 97.5 percent rec3'cle or more; EPA considers these shops to be the best
performing for this manufacturing operation. After analyzing the data from these shops, the
Agency selected a wet-suppressed combustion air pollution control model PNF of 20 gpt. Three
shops operating with this recycle rate report flow rates below or slightly above the selected model
flow rate. Two shops reported discharge rates of 17 gpt and 22 gpt; one shop achieved a
discharge rate of 14 gpt by using carbon dioxide injection in the high-rate recycle system. Carbon
dioxide injection allows carbonates to precipitate in the treatment system clarifiers (in effect water
softening), thus minimizing the need for blowdown from the system. The BOF shops used to
select the model flow rate are typical of all wet-suppressed shops: they generate wastewater from
the WAPC system and other miscellaneous sources, they are located in different geographic
regions, and they are owned by different companies. EPA determined that shops operating with
97.5 percent recycle and 20-gpt flow rates are representative of BAT operations., The model flow
rate is also consistent with the proposed model treatment for wet-suppressed air pollution control
systems that utilizes carbon dioxide injection as part of the treatment process.

EPA identified eight BOF shops operating wet-open combustion air pollution
control systems. All of the shops operate their treatment systems with wastewater recycle. One
shop is able to achieve zero discharge of process wastewater by using carbon dioxide injection,
which eliminates the need for system blowdown. As with wet-suppressed systems, the Agency
has selected a model PNF of 20 gpt for wet-open combustion air pollution control, based on the
use of carbon dioxide injection. The Agency concluded that all sites with proper wastewater
recycle and carbon dioxide injection can achieve the proposed model flow. EPA determined that
the one wet-open shop currently achieving the model flow rate is representative of all of the wet-
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Section 7 - Wastewater Characterization
open shops in the United States for the same reasons provided above for wet-suppressed shops.
The only difference between this shop and the others is its use of carbon dioxide in the treatment
system. Furthermore, the Agency did not propose zero discharge of process wastewaters for wet-
open systems because the cost was prohibitive, and EPA did not conclude that zero flow could be
achieved by all wet-open combustion sites.
7.5.2
Ladle Metallurgy
The Agency found that, other than for vacuum degassing, no process wastewater
is generated or discharged in ladle metallurgy operations. Therefore, the Agency has designated
ladle metallurgy as a zero discharge operation.
7.5.3
Vacuum Degassing

Sources
Thirteen integrated sites indicated in their industry survey responses that they
conducted vacuum degassing operations in 1997. Wastewater is generated in vacuum degassing
operations from vacuum systems (e.g., barometric condensers, steam ejectors) that are used to
refine the molten steel. These systems use water.to create the vacuum necessary to draw the
molten steel from the ladle to remove the impurities; the water becomes contaminated with
dissolved off-gases from the steel. No other sources of wastewater were reported.

Pollutants of Concern

Based on an analysis of EPA sampling data and industry-provided data from the
Analytical and Production Survey, EPA determined that the principal pollutants from vacuum
degassing are TSS and metals (lead and zinc), which volatilize from the steel. EPA selected 15
POCs for vacuum degassing, presented in Table 7-5.

Wastewater Flow Rates

EPA calculated PNFs for 12 integrated sites that provided flow rate information.
All of the sites operate wastewater treatment systems with wastewater recycle. After analyzing
the data, the Agency based the selection of a model flow rate on recycle systems with 99 percent
recycle or greater and selected a model vacuum degassing PNF of 15 gpt. EPA considers sites
operating with this recycle rate to be the best performing for this manufacturing operation. Four
sites operating with the selected recycle rate reported flow rates less than 15 gpt. The Agency
concludes that the selected flow rate is well demonstrated because the better performing sites in
the segment are able to achieve it and is achievable by those sites currently discharging at a rate
greater than the model PNF.
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Section 7 - Wastewater Characterization
7.5.4
Continuous Casting

Sources
Twenty integrated sites indicated in their industry survey responses that they
conducted continuous casting operations; EPA identified 30 continuous casters at integrated mills
that were active in 1997. The largest amount of wastewater is generated in continuous casting
from the contact spray cooling of the steel product as it passes through the molds and from flume
flushing for the removal of scale. The only other source of process wastewater identified in
industry survey responses was equipment cleaning water.

The Agency did not include nonprocess wastewater sources in determining the
model PNF, as discussed in Section 7.2. Nonprocess wastewater sources often treated with
process wastewater include low-volume losses from closed caster mold and machine cooling
water systems.

Pollutants of Concern .

Based on an analysis of EPA sampling data and industry-provided data from the
Analytical and Production Survey, EPA determined that the principal pollutants from continuous
casting are TSS, O&G, and low levels of particulate metals. EPA selected 13 POCs for
continuous casting, presented in Table 7-5. Although EPA found lead at relatively low
concentrations in sampled continuous casting wastewater, the Agency considers lead a POC for
this operation because industry-supplied effluent data indicate that lead was detected in 129 of the
262 samples (49 percent) from integrated continuous casting operations.

Wastewater Flow Rates

During the analysis, the Agency identified that six of the 20 sites operate combined
wastewater treatment and/or recycle systems for vacuum degassing, continuous casting, and/or
hot forming operations. The common characteristics of the process wastewater from each of
these operations allows the sites to commingle and treat the wastewater simultaneously. When
determining the PNF for a particular manufacturing operation that shares a combined treatment
and/or recycle system with one or more other manufacturing operations, the Agency developed a
PNF based on the percentage of wastewater entering the treatment and/or recycle system from
each operation.

EPA calculated PNFs for 29 casters for which flow rate data were provided. The
Agency selected the model flow rate based on six continuous casters operating with 97 percent
recycle or greater; EPA considers these casters to be the best performing for this manufacturing
operation. Based on the performance of these casters, EPA selected a model PNF of 20 gpt for
continuous casting at integrated sites. The flow rate data for these casters are provided below.
7-15

-------
Section 7 - Wastewater 'Characterization
Continuous Caster
A
B
C
D
E
F
Recycle Rate (%)
98.7
99.2
97.2
97.5
98.1
98.3 .
PNF (gpt)
14
14
17
20
20
20
EPA concluded that these continuous casters are typical of all the casters in the United States.
because they all generate wastewater from contact cooling and flume flushing, they are located in
different geographic regions, and they are owned by different companies.
7.6
Integrated and Stand-Alone Hot Forming Subcategorv
Sources
Fifty-seven integrated and stand-alone sites indicated in their industry survey
responses that they conducted hot forming operations; EPA identified 71 hot forming operations
at integrated and stand-alone mills that were active in 1997. The Agency was unable to analyze
data from three processes due to incomplete industry survey responses.

The Agency identified spray water, used for cooling and descaling of the steel
during the hot forming process, as the primary wastewater source. For the purposes of this
subcategory, EPA uses spray water as a generic term because there are many different sources of
spray water within a hot forming mill. Spray water includes the following: high-pressure
descaling sprays, roll and/or roll table spray cooling, die spray cooling, scarfer emissions control,
hot shear spray cooling, flume flushing, low-pressure/laminar flow cooling, and product cooling
on runout tables. Other sources of wastewater included in the development of the model PNFs
were roll shop wastewater, wastewater collected in basement sumps, scarfer water, and
equipment cleaning water.

The Agency did not include nonprocess wastewater sources in determining the
model PNF, as discussed hi Section 7.2. Nonprocess wastewater from hot forming operations
often treated with process wastewater includes noncontact cooling water from reheat furnaces.

Pollutants of Concern

Based on an analysis of EPA sampling data and industry-provided data from the
.Analytical and Production Survey, EPA determined that the principal pollutants from carbon steel
integrated and stand-alone hot forming facilities are TSS, O&G, and particulate metals. EPA
7-16

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Section 7 - Wastewater Characterization
selected 11 POCs for the Carbon and Alloy Steel Segment of the Integrated and Stand-Alone Hot
Forming Subcategory, presented in Table 7-6. Although EPA found lead at relatively low
concentrations in sampled hot forming wastewater, the Agency considers lead a POC for this
segment because industry-supplied effluent data indicate that lead was detected in 246 of the 331
samples (74 percent) from integrated and stand-alone hot forming operations.

Based on an analysis of industry-provided data from the Analytical and Production
Survey, EPA determined that the principal pollutants from stainless steel integrated and stand-
alone hot forming facilities are TSS, O&G, and low levels of particulate metals. EPA did not
sample any stainless steel integrated or stand-alone hot forming facilities. However, EPA did
sample stainless steel non-integrated hot forming operations. Therefore, EPA chose the same
POCs selected for the hot forming manufacturing operation of the Stainless Steel Segment of the
Non-Integrated Steelmaking and Hot Forming Subcategory for the Stainless 'Steel Segment of the
Integrated and Stand-Alone Hot Forming Subcategory, since the hot forming processes
performed and type of steel formed are identical. Fifteen POCs were selected for each of these
manufacturing operations, presented, in Table 7-7.

Wastewater Flow Rates

During the analysis, the Agency determined that 12 of the 57 sites operate
combined wastewater treatment and/or recycle systems for their hot forming operations. When
determining the PNF. for a particular manufacturing operation that shares a combined treatment
and/or recycle system with one or more other manufacturing operations, the Agency developed a
PNF based on the percentage of wastewater entering the treatment and/or recycle system from
each operation. .

EPA selected the model flow rate based on wastewater treatment systems
operating with 96 percent recycle. The Agency determined that systems operating with this level
of recycle were the best performing mills in the Subcategory. EPA selected 100 gpt as the model
PNF for integrated and stand-alone hot forming. Twenty-one of the 68 operations reported PNFs
less than or equal to 100 gpt, including seven operations that reported zero discharge. All of the
operations currently meeting the model PNF operate high-rate recycle systems with recycle rates
of at least 95 percent. The mills iused to develop the model flow rate are representative of
integrated and stand-alone hot forming mills across the industry: they generate wastewater from a
variety of sources, including contact water, rolls shops, and basement sumps; they hot form a
range of products (e.g., strip, plate, pipe, tube, bar); and they are located in different geographic
locations. For those operations with recycle systems that are not achieving the model flow rate,
the Agency included sufficient costs to upgrade all of the systems to achieve this rate. For those
operations with once-through treatment systems, the Agency included sufficient costs to install
and operate high-rate recycle systems that would be able to achieve the model flow rate.

The Agency did not select zero discharge as the model PNF for integrated and
stand-alone hot forming sites due to the costs. The Agency determined that the capital costs
7-17

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Section 7 - Wastewater Characterization
involved with retrofitting existing recycle systems to operate at a 100 percent recycle rate would
be cost-prohibitive.
7.7
Non-Integrated Steelmaking and Hot Forming Subcategorv
The Agency designated Carbon and Alloy Steel and Stainless Steel Segments for
the Non-Integrated Steelmaking and Hot Forming Subcategory because of differences in
pollutants present in the wastewater. However, EPA also identified several manufacturing
process divisions for both segments. Below are separate discussions for electric arc furnace
(EAF) Steelmaking, ladle metallurgy, vacuum degassing, continuous casting, and hot forming.
7.7.1
Electric Arc Furnace (EAF) Steelmaking
The Agency evaluated data from 69 facilities that indicated in their industry survey
response that they performed non-integrated Steelmaking. The analysis included a total of 76
EAF shops and 132 EAFs. All EAFs in the United States are equipped with dry or semi-wet air
pollution controls, and none discharge process wastewater. One EAF shop has a wet scrubber
system that functions as a backup. Acpordingly, the Agency is proposing to designate all EAFs as
zero discharge operations. .
7.7.2
Ladle Metallurgy
The Agency found that no ladle metallurgy operations other than vacuum
degassing generate of discharge process wastewater. Therefore, the Agency has designated ladle
metallurgy as a zero discharge operation.
7.7.3
Vacuum Degassing

Sources
The Agency evaluated data from the 22 non-integrated sites that indicated in their
industry survey response that they performed vacuum degassing. Because some plants operate
more than one vacuum degassing operation, the total number of processes evaluated was 30. The
Agency was unable to analyze data from five operations due to incomplete survey responses.

The primary source of wastewater from vacuum degassing operations is blowdown
from the vacuum system. Other sources of wastewater reported include boiler blowdown and
WAPC wastewater.

Pollutants of Concern

From industry-provided data from the Analytical and Production Survey, EPA
determined that the principal pollutants for vacuum degassing operations are TSS and metals.
EPA did not perform a POC analysis for this segment because the Agency did not sample non-
7-18

-------
Section 7 - Wastewdter Characterization
integrated vacuum degassing operations during its sampling program. However, based on
process chemistry and the steel material processed, EPA determined that it is unlikely that
wastewater associated with this operation would contain pollutants not already selected as POCs
in the other manufacturing processes in the Non-Integrated Steelmaking and Hot Forming
Subcategory.

Wastewater Flow Rates

During the analysis, the Agency determined that 15 of the 22 sites operate recycle
systems for their vacuum degassing operations. Seven of the 15 sites operate combined
wastewater treatment and/or recycle systems. When determining the PNF for a particular vacuum
degassing operation whose wastewater treatment and/or recycle system is combined with others
systems within the plant, the Agency developed a vacuum degassing PNF based on the relative
percentage of process wastewater conveyed to the treatment or recycle system from vacuum
degassing operations. EPA assigned vacuum degassing operations that discharge process
wastewater to evaporation ponds a PNF of zero. The Agency designated sites that attained zero
discharge by using process wastewater as makeup water for other processes zero dischargers, but
used the volume of blowdown water from the these operations in determining the model flow
rate.

EPA selected 10 gpt as the model PNF for non-integrated vacuum degassing
operations. Ten of the 30 vacuum degassing operations reported PNFs equal to or less than 10
gpt, including two operations that reported zero discharge. Of the 10 operations currently
operating with a PNF of less than or equal to 10, five have once-through systems, while five have
recycle systems. All of the recycle systems currently achieving the model PNF have recycle rates
of at least 99.5 percent. The Agency concluded that 10 gpt is a flow rate that well-operated high-
rate recycle vacuum degassing systems can achieve. .

The Agency did not select zero discharge as the model PNF for non-integrated
vacuum degassing operations because of the feasibility of achieving zero discharge on an industry-
wide basis. Three of five operations report attaining zero discharge through either evaporation or
discharge to another process. The Agency concluded natural evaporation or discharge to another
process are not viable treatment options at all facilities. The Agency also does not feel that
contract hauling of wastewater from non-integrated operations is a cost-effective option, due to
the potentially large volumes of wastewater generated by these operations. Finally, the Agency
does not believe it is feasible for all existing non-integrated mills to manage process area storm
water such that they can continuously achieve zero discharge. .
7.7.4
Continuous Casting

Sources
The Agency analyzed data from the 59 non-integrated sites that indicated in their
industry survey responses that they performed continuous casting operations. Because some sites
,7-19

-------
                                                         Section 7 - Wastewater Characterization
operate more than one caster, the total number of operations analyzed was 76. The Agency was
unable to analyze data from one continuous casting operation due to an incomplete industry
survey response.                   .

              During the analysis, the Agency identified spray water, used to cool and descale
the steel during the casting process, as the primary wastewater source from casting operations.
The only other source of process wastewater identified in industry survey responses and included
in the development of the model PNF was equipment cleaning water.

              The Agency did not include nonprocess wastewater sources in determining the
model PNF, as discussed in Section 7.2. Nonprocess wastewater sources treated with process
wastewater include low volume losses from closed caster mold and machine cooling water
systems.

              Pollutants of Concern

              From an analysis of EPA sampling data and industry-provided data from the
Analytical and Production Survey, EPA determined that the principal pollutants in continuous
casting wastewater are TSS, metals, and O&G.  EPA selected eight POCs for the Carbon and
Alloy Steel Continuous Casting segment of the Non-Integrated Steelmaking and Hot Forming
Subcategory, presented hi Table 7-8.  EPA also selected 21 POCs for the Stainless Steel
Continuous Casting segment of the Non-Integrated Steelmaking and Hot Forming Subcategory,
presented in Table 7-9. EPA selected lead and zinc as POCs for continuous casting operations for
both segments because both pollutants are regulated under the 1982  regulation (no distinction
was made between steel type hi the 1982 regulation), and data-collected in support of the 1982
regulation indicated that these pollutants were present in wastewater discharged from continuous
casting operations. Although EPA did not detect lead, and only detected zinc at relatively low
concentrations, hi the limited sampling data collected from continuous casting wastewater, the
Agency considers lead and zinc POCs for the following reason: industry-supplied data indicate
that, hi effluent samples submitted from carbon and alloy steel non-integrated continuous casting
operations, lead was detected hi 65 of the 70 samples (93 percent) and zinc was detected in 69 of
the 70 samples (99 percent), and, in samples submitted from stainless steel operations, lead was
detected hi 12 of the 15 samples (80 percent) and zinc was detected  hi 14 of the 15 samples (93
percent).

              Wastewater Flow Rates

              During the analysis, the Agency determined that 22 sites operate combined
wastewater treatment and/or recycle systems for vacuum degassing, continuous casting,  and/or
hot forming operations. The common characteristics of the process  wastewater from these three
operations allows facilities to commhigle and treat these wastewaters simultaneously.  When
determining the PNF for a particular operation associated with a combined treatment and/or
recycle system, the Agency developed a PNF based on the percentage of wastewater entering the
treatment and/or recycle system from each operation.
                                          7-20

-------
Section 7 - Wastewater Characterization
EPA selected 10 gpt as the model PNF for non-integrated continuous casting.
Twenty-eight of the 76 non-integrated continuous casting operations reported PNFs equal to or
less than 10 gpt. The Agency identified 16 caster water systems that operated without
wastewater discharge. An additional nine sites discharged from their caster water system, but
used the discharge as makeup water for other processes. EPA designated sites that reported
having no process wastewater discharge from their entire site as having no discharge from their
continuous caster(s). EPA considers 10 gpt to be well demonstrated not only because the better
performing non-integrated continuous casters are demonstrating this flow rate, but also because
of the large percentage (37 percent) of the total casters achieving this flow rate.

The Agency did not select zero discharge as the model PNF for non-integrated
continuous casting operations for the same reasons cited in Section 7.3.3 for vacuum degassing.
7.7.5
Hot Forming
Sources
The Agency analyzed data from the 64 non-integrated sites that indicated in their
industry survey response that they performed hot forming. Because some plants operate more
than one hot forming operation, the total number of operations analyzed was 96. The Agency
was unable to analyze data from two operations due to incomplete survey responses.

During the analysis, the Agency identified spray water used to cool and descale the
steel during the hot forming process as the primary source of wastewater. For the purposes of
this manufacturing operation, spray water is a generic term that includes many different sources of
spray water within a hot forming mill. Spray water includes the following: high-pressure
descaling sprays, roll and/or roll table spray cooling, die spray cooling, scarfer emissions control,
hot shear spray cooling, flume flushing, low-pressure/laminar flow cooling, and product cooling
on runout tables. Other sources of wastewater included in the development of the model PNFs
were blowdown from roll shop wastewater, wastewater collected in basement sumps, scarfer
water, and equipment cleaning and wash down water.

The Agency did not include nonprocess wastewater sources in determining the
model PNF, as discussed in Section 7.2. Nonprocess wastewater from hot forming operations
that is treated with process wastewater includes noncontact cooling water from reheat furnaces,
which is sometimes included in the process water recycle loop or recycled separately with a
blowdown to the process water loop.

. Pollutants of Concern

From an analysis of EPA sampling data and industry-provided data from the
Analytical and Production Survey, EPA determined that the principal pollutants for hot forming
mills are TSS, metals, and O&G. EPA selected eight POCs for carbon and alloy steel hot forming
operations in the Non-Integrated Steelmaking and Hot Forming Subcategory, presented in Table
7-21

-------
Section 7 - Wastewater Characterization
7-8. The Agency considers lead and zinc POCs because, even though EPA did not detect lead
and detected zinc at relatively low concentrations in the limited sampling data, industry-supplied
effluent data indicate that lead was detected in 17 of the 23 samples (74 percent) and zinc was
detected in 22 of the 23 samples (96 percent) from carbon and steel non-integrated hot forming
operations. EPA selected 15 POCs for stainless steel hot forming operations in the Non-
Integrated Steelmaking and Hot Forming Subcategory, presented in Table 7-9. .

Wastewater Flow Rates

During the analysis, the Agency identified 41 sites that operate combined
Wastewater treatment and/or recycle systems for vacuum degassing, continuous casting, arid/or
hot forming operations. The common characteristics of the process wastewater from these three
operations allows facilities to commingle and treat the wastewater simultaneously. When
determining the PNF for a particular hot forming operation associated with a combined treatment
and/or recycle system, the Agency developed a PNF based on the percentage of wastewater
entering the treatment and/or recycle system from the hot forming operation.

EPA selected 50 gpt as the model PNF for non-integrated hot forming mills.
Forty-two of the 94 non-integrated hot forming operations reported PNFs equal to or less than 50
gpt. During the analysis, the Agency identified eight operations that operate without discharging
wastewater. An additional 16 sites listed discharges from their hot forming water system, but
used the discharge as makeup water for other processes or allowed the excess wastewater to
evaporate. EPA used the volume of blowdown water from the these hot forming operations in
determining the model flow rate. EPA designated sites that reported no process wastewater
discharge from their entire site as having no discharge from their hot forming mill(s). EPA
considers 50 gpt to be well demonstrated not only because the better performing non-integrated
hot forming mills are demonstrating this flow rate, but also because of the large percentage (45
percent) of the total hot forming mills achieving this flow rate.

The Agency did not select zero discharge as the model PNF for non-integrated hot
forming mills for the same reasons cited in Section 7.7.3 for vacuum degassing.
7.8
Steel Finishing Subcategorv
The Agency established the Carbon and Alloy Steel and Stainless Steel Segments
for the Steel Finishing Subcategory because of differences in pollutants present in the wastewater.
EPA also identified several manufacturing process divisions between the segments. Below are
separate discussions for acid pickling, cold forming, alkaline cleaning, stand-alone continuous
annealing, hot coating, and electroplating.
7-22

-------
Section 7 - Wastewater Characterization
7.8.1
Acid Pickling

Sources
The Agency analyzed data from the 61 sites (integrated, non-integrated, and stand-
alone) that indicated in their industry survey responses that they performed acid pickling.
Because some plants operate more than one acid pickling line, the number of process lines
analyzed was 130. The Agency was unable to analyze data from three lines due to incomplete
. industry survey responses.

For the proposed rulemaking, EPA defined acid pickling lines to include alkaline
cleaning and salt bath and electrolytic sodium sulfate (ESS) descaling operations that occur on the
line that includes acid pickling. In a small number of instances, continuous annealing operations
with an associated water quench take place on acid pickling lines. In these instances, EPA
included discharge from the annealing rinse as a wastewater source from acid pickling lines. The
Agency also evaluated acid regeneration operations to determine the volume of wastewater
generated and discharged during these operations.

During the analysis, the Agency identified three major sources of wastewater from
acid pickling lines. The first is rinse water usedto clean the acid solution from the steel. Rinse
water comprises the largest volume of wastewater from acid pickling lines to wastewater
treatment operations. The second is spent pickle liquor, a solution composed primarily of acid
that is no longer an effective pickling agent. The third major source of wastewater is generated
by the WAPC devices located above the pickling tanks. Other minor sources of Wastewater
included in the development of model PNFs were process wastewater from other operations (e.g.,
salt bath descaling) on the acid pickling lines (spent process baths and rinses); raw material
handling, preparation, and storage; tank clean-outs; and equipment cleaning water. Except for
blowdown from surface cleaning tanks, these wastewater sources are noncontinuous sources of
wastewater that minimally contribute to the total wastewater flow.

Pollutants of Concern

Based on an analysis of EPA sampling data and industry-provided data from the
Analytical and Production Survey, EPA determined that the principal pollutants from carbon and
alloy steel acid pickling are TSS, lead, and zinc. EPA selected 19 POCs for acid pickling
operations in the Carbon and Alloy Steel Segment of the Steel Finishing Subcategory, presented
in Table 7-10. EPA selected sulfate as a POC because it is present in sulfuric acid pickling
wastewater, which the Agency did not sample.

Using the same analysis, EPA also determined that the principal pollutants from
stainless steel acid pickling, ESS descaling, and salt bath descaling operations are TSS, chromium,
hexavalent chromium, and nickel. EPA selected 30 POCs for stainless steel acid pickling and
descaling operations in the Stainless Steel Segment of the Steel Finishing Subcategory (as selected
hi at least one of the three pickling or descaling operations listed), presented in Table 7-11. EPA
7-23

-------
Section 7 - Wastewater Characterization
selected total cyanide as a POC because it can be present in reducing salt bath descaling .
wastewater, which the Agency did not sample.

Wastewater Flow Rates

When responding to the industry survey, sites had the option of indicating several
different discharge destinations for process wastewater.. These destinations included the
following: on-site regeneration and reuse, discharge to another process or rinse, discharge to
treatment, discharge without treatment to publicly owned treatment works (POTWs), discharge
to privately owned treatment works (PrOTWs), recycle and reuse, and several zero discharge
methods including contract hauling. If a.discharge was listed as recycle and reuse, discharge to
another process or rinse, or zero discharge or alternative disposal method, such as contract
hauling, EPA did not use the discharge in developing the model PNF. Several sites often
responded that discharges were split between discharge to treatment and zero discharge methods
of disposal such as contract hauling, but did not provide the portion of flow going to each. In
these cases, EPA accounted for all of the flow in model PNF development.

The Agency analyzed data from 219 WAPC devices that were reported as being
operated on acid pickling lines. After reviewing the 1997 industry survey data and comparing it
to the data used to develop the 1982 rule, the Agency determined that the model flow rate of 15
gpm in the 1982 rule is still applicable.

The following tables list the model PNFs for carbon and alloy and stainless steel
pickling operations. The Agency did not identify any sites that performed plate pickling
operations on carbon and alloy steels. Consequently, the Agency transferred the model plate
pickling flow rate from the Stainless Steel Segment to the carbon and alloy steel hydrochloric and
sulfuric acid plate pickling manufacturing operations. Similarly, the Agency did not identify any
sites that performed pipe and tube pickling operations on stainless steels, and, transferred the
model specialty steel pipe and tube flow rate from the 1982 development document.

Carbon and Alloy Steel Hydrochloric Acid Pickling Model Flow Rates
Carbon and Alloy Hydrochloric
Acid Fielding
Strip, sheet
Bar, billet, rod, coil
Pipe, tube
Plate
Fume scrubber (gal/min)
Model
PNF (gpt)
50
490"
l,020a
35b
15a
Operations Currently Operating
at or Below the Model PNF
' . 18
1
2
N/A
8
Number of
Operations Analyzed
48
1
3
0
14
"Value transferred from the 1982 development document.
""Value transferred from Stainless Steei Segment
7-24

-------
                                                             Section 7 - Wastewater Characterization
               Carbon and Alloy Steel Sulfuric Acid Pickling Model Flow Rates
Carbon and Alloy Sulfuric Acid
Pickling
Strip, sheet
Bar, billet, rod, coil
Pipe, tube
Plate
Fume scrubber (gal/min)
Model
PNF (gpt)
230
280a
500"
35"
15"
Operations Currently Operating
at or Below the Model PNF
4
"• 2
.1
N/A
34
Number of
Operations Analyzed
10
7
1
0
6()
 'Value transferred from the 1982 development document.
 bValue transferred from Stainless Steel Segment.
                          Stainless Steel Pickling Model Flow Rates
Stainless Steel Acid Pickling
Strip, sheet
Bar, billet, rod, coil
Pipe, tube
Plate
Fume scrubber (gal/min)
Model
PNF (gpt)
700
230a
770a
35
15a
Operations Currently Operating at
or Below the Model PNF
.19
1
0
' 3
36
Number of
Operations
Analyzed
50
2
0
3
54
 "Value transferred from 1,982 development document.

               EPA selected a model flow rate of 50 gpt for hydrochloric acid pickling of strip or
 sheet because 18 of the 48 process lines were demonstrating this model flow rate. The Agency
, selected a model flow rate below the median value of 79 gpt for hydrochloric acid pickling of strip
 and sheet, because the better performing mills were achieving this discharge rate. EPA selected
 230 gpt as the model flow rate for sulfuric acid pickling of strip and sheet instead of the median
 PNF of 265 gpt.  The Agency concluded that the selected flow rate roughly approximating, but
 slightly lower than, the median PNF is well demonstrated and achievable for all operations in the
 segment. The remaining model flow rates for hydrochloric acid pickling and sulfuric acid pickling
 were either transferred from the  1982 development document or from the Stainless Steel Segment
 (pickling).                                         .

               EPA selected  700 gpt as the model flow rate for stainless steel acid picklhig of
 strip and sheet instead of the  median PNF of 874 gpt. The Agency considers the sites achieving
 the model flow rate (38 percent "of the total) to be the better performing operations in this
 segment. EPA selected 35 gpt for stainless, steel acid picklhig of plate instead of the median of 33
 gpt. Each of the sites that pickles plate was already achieving this flow rate and the Agency
                                           7-25

-------
Section 7 - Wastewater Characterization
determined that it would be cost-prohibitive to reduce the flow rate further. EPA transferred the
remaining model flow rates for stainless steel acid pickling from the 1982 development document.

The Agency identified six zero discharge acid pickling lines during its analysis of
the acid pickling subcategory. The Agency did not select zero discharge as the model flow for
any of the acid pickling operations because sites would have to use options such as contract
hauling of waste to achieve zero discharge. In addition, the Agency concluded that it was not
feasible to achieve zero discharge on an industry-wide basis.

The Agency analyzed data from WAPC devices (e.g., absorber vent scrubbers)
that acid regeneration operations reported operating. After reviewing the 1997 industry survey
data and comparing it to the data used for the 1982 regulation, the Agency determined that the
model flow rate of 100 gpm contained in the 1982 rule is still applicable.
7.8.2
Cold Forming

Sources
The Agency considered data from the 64 sites (integrated, non-integrated, stand-
alone) that reported performing cold forming in their industry survey responses. Because some
plants operate more than one cold forming operation, the total number of operations analyzed was
234. The Agency was unable to analyze data from two operations due to incomplete industry
survey responses.

During the analysis, the Agency identified blowdown from the contact water and.
rolling solution systems as the primary source of wastewater. For the purposes of this
manufacturing operation, the Agency made no distinction between contact spray water systems
and rolling solution systems, which can include blowdown from roll and/or roll table spray cooling
and product cooling. Other sources of wastewater included in the development of model PNFs
were equipment cleaning water, wastewater from roll shops, and basement sumps.

Pollutants of Concern

Based on an analysis of EPA sampling data and industry-provided data from the
Analytical and Production Survey, EPA determined that the principal pollutants from cold
forming wastewater are TSS, O&G, and metals (lead and zinc for carbon and alloy steels and
chromium and nickel for stainless steels; chromium may also be a contaminant from cold rolling of
carbon steels resulting from wear on chromium-plated work rolls). EPA also found priority
organic pollutants including naphthalene, other polynuclear aromatic compounds, and chlorinated
solvents in cold rolling wastewater. EPA selected 26 POCs for cold forming operations in the
Carbon and Alloy Steel Segment of the Steel Finishing Subcategory, presented in Table 7-10, and
40 POCs for cold forming operations in the Stainless Steel Segment of the Steel Finishing
Subcategory, presented in Table 7-11.
7-26

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Section 7 - Wastewater Characterization
Wastewater Flow Rates

The following table presents the selected model PNF, number of operations
currently operating at the model PNF, and number of lines analyzed for. carbon and alloy cold
forming operations. Each of the selected model flow rates for carbon and alloy cold forming,
except for single stand, recirculation, is slightly above the median PNF for each operation. EPA
determined that it would be cost-prohibitive for all sites to achieve the median flow rate.. For
single stand, recirculation, EPA selected a flow rate below the median of 7 gpt. The Agency
concluded that it was appropriate for single stand, recirculation, to have a lower flow rate than
single stand, direct application. Therefore, EPA selected the model flow rate based on the three
best performing mills in the,category. The Agency did not select zero discharge as the model
PNF for carbon and alloy cold forming operations because sites with a discharge from their
recycle system(s) achieved zero discharge through either contract hauling or discharge to another
process. The Agency concluded that contract hauling of waste is a not a universally applicable
wastewater management approach and also recognizes that discharge to another process is not a
viable option at all sites.

Carbon and Alloy Steel Cold Forming Model Flow Rates
Carbon and Alloy Cold Forming
Single stand, recirculation :
Single stand, direct application
Multiple stand, reqirculation
Multiple stand, direct application
Multiple stand, combination
Model
PNF
(gpt)
1
3
25
275
143
Operations Currently
Operating at the Model PNF
3 '
15
16
11
5
Number of Operations
Analyzed
18 .
26
28
19
8
The following table presents the selected model PNF, number of operations
currently operating at the model PNF, and number of operations analyzed for stainless cold
forming. The selected model flow rates for stainless cold forming are slightly above the median
flow rates. EPA determined that it would be cost-prohibitive for all sites to achieve the median
flow rate. The Agency did not select zero discharge as the model PNF for stainless steel cold
forming operations for the reasons cited above. After reviewing the industry survey data, the
Agency did not identify any sites operating multiple stand, direct application, or multiple stand,
combination, rolling mills for stainless steels. The Agency transferred the model flow rates for
these operations from the Carbon and Alloy Steel Segment, because of similarities in the
manufacturing processes.
7-27

-------
                                                           Section 7 - Wastewater Characterization
                      Stainless Steel Cold Forming Model Flow Rates
Stainless Steel Cold Forming
Single stand, recirculation
Single stand, direct application
Multiple stand, recirculation
Multiple stand, direct application
Multiple stand, combination
Model
PNF
(gpt)
3
35
16
275"
143a
Operations Currently Operating
at the Model PNF
7
1
6
N/A
N/A
Number of Sites
Reporting
13
1
7
0
0
•Value transferred from the Carbon and Alloy Steel Segment.
N/A=Not applicable.
7.8.3
Alkaline Cleaning
              Sources
              The Agency considered data from the 32 sites (integrated, non-integrated, and
stand-alone) that indicated in their industry survey response that they performed alkaline cleaning
operations on stand-alone process lines that do not have other processes such as pickling or
coating. Because some plants operate more than one stand-alone alkaline cleaning operation, the
total number of operations analyzed was 49. The Agency was unable to analyze data from one
operation  due to an incomplete survey response.

              EPA has defined alkaline cleaning operations to include annealing operations on
the same line; as a result,  this segment includes both stand-alone alkaline cleaning lines and
continuous annealing/alkaline cleaning lines. The Agency included annealing rinses, when present,
in determining PNFs for the alkaline cleaning lines.

              The primary sources of wastewater identified for alkaline cleaning operations were
blowdown from the alkaline cleaning solution  tanks and rinse water used to clean the alkaline
cleaning solution from the steel.  Other minor  sources of wastewater included the following: rinse
water from annealing operations (when operated with a water quench); runoff from raw material
handling,  preparation, and storage; tank clean-outs; and equipment cleaning and wash down
water.
              Pollutants of Concern
              Based on an analysis of EPA sampling data and industry-provided data from the
Analytical and Production Survey, EPA determined that the principal pollutant from alkaline
cleaning operations is O&G removed from the steel.  Because alkaline cleaning baths do not
aggressively attack or dissolve the surface of the steel processed, metals are not as prevalent as in
acid pickling wastewater.  EPA selected 12 POCs for alkaline cleaning operations in the Carbon
                                           7-28

-------
Section 7 - Wastewater Characterization
and Alloy Steel Segment of the Steel Finishing Subcategory, presented in Table 7-10. EPA
selected 10 POCs for alkaline cleaning operations in the Stainless Steel Segment of the Steel
Finishing Subcategory., presented in Table 7-11.

Wastewater Flow Rates

When developing the model PNF for alkaline cleaning, the Agency included all
process wastewater flows that were conveyed to treatment. If a wastewater discharge was
contract hauled or recycled and reused, the Agency did not include the flow in the development of
the model PNF. If a site's industry survey response indicated that a flow was both contract
hauled and discharged to treatment, but did not specify the portion of flow going to each, the
Agency used the'combined flow to develop the PNF. Each of the selected model flow rates for
alkaline cleaning approximates the median flow rate. ' •

EPA selected 320 gpt as the model PNF for alkaline cleaning of carbon and alloy
steel strip and sheet. Twelve of the 24 lines reported PNFs of less than 320 gpt. None of these
sites reported lines operating without a discharge.

EPA selected 20 gpt as the model PNF for alkaline cleaning of carbon and alloy
steel pipe and tube. Four of the six sites reported lines with PNFs of less than or equal to 20 gpt.
One site reported operating without a discharge by contract hauling its wastewater. The Agency
did not select zero discharge as the model flow for alkaline cleaning of pipe and tube because sites
would have to use disposal methods such as contract hauling to achieve zero discharge.

EPA selected 2,500 gpt as the model PNF for alkaline cleaning of stainless strip.
Nine of the 15 sites reported lines with PNFs of less than or equal to 2,500 gpt. None of the sites
reported operating without a discharge. The Agency did not identify any sites that practiced
alkaline cleaning of stainless steel pipe and tube. EPA transferred the model pipe and tube flow
rate of 20 gpt from the Carbon and Alloy Steel Segment.
7.8.4
Continuous Annealing

Sources .
The Agency considered data from the 11 sites that indicated in their industry
survey responses that they performed stand-alone continuous annealing operations (i.e., not on
the same process line with operations such as alkaline cleaning or acid pickling). Because some
sites operate more than one stand-alone continuous annealing operation, the total number of
operations analyzed was 28. The Agency was unable to analyze data from two operations due to
incomplete survey responses.

Stand-alone continuous annealing operations only include annealing operations
that are not considered to be part of any other finishing line operated by the site. Annealing
operations with a water quench that generate a discharge on acid pickling, cold forming, hot
7-29

-------
Section 7 - Wastewater Characterization
coating, alkaline cleaning, and electroplating lines are included in the model flow rate for these
operations. Both the Carbon and Alloy Steel and Stainless Steel Segments have stand-alone
continuous annealing operations that are divided into two categories: lines that do and lines that
do not use water to quench the steel after the annealing process.

Pollutants of Concern

EPA did not identify any POCs for this manufacturing process because EPA did
not sample any annealing quenching operations. However, because quenching is simply a direct-^
contact water cooling process with no chemicals involved, the Agency determined that
wastewater associated with this operation is unlikely to contain pollutants not already selected as
POCs in other finishing manufacturing process divisions.

Wastewater Flow Rates

EPA selected 20 gpt (the median flow rate) as the model PNF for stand-alone
continuous annealing with a water quench. Seven of the 14 lines with a water quench reported
PNFs of less than or equal to 20 gpt. None of the sites reported operating without a discharge.
Stand-alone continuous annealing lines that operate without a water quench do not generate
process wastewater and have been designated as a zero-discharge operation.
7.8.5
Hot Coating

Sources
The Agency considered data from the 26 sites (integrated, non-integrated, and
stand-alone) that indicated in their industry survey responses that they performed hot coating.
Because some plants operate more than one hot coating line, the total number of lines analyzed
was 40. The Agency was unable to analyze data from five lines due to incomplete survey
responses. Hot coating operations are performed on carbon and alloy steels only. EPA has
defined hot coating lines as including acid cleaning, annealing, alkaline cleaning, and other surface
cleaning and preparation operations on the same line.

The primary source of wastewater from hot coating operations is the surface
preparation operations, such as acid and alkaline cleaning, that the steel undergoes before hot
coating. Four of the operations reported a discharge from their hot coating tanks. Thirty-two of
the operations reported having a rinse following the coating operation. Tank clean-outs, fume
scrubbers, and equipment cleaning are other sources of wastewater reported by a number of sites.

Pollutants of Concern

Based on an analysis of EPA sampling data and industry-provided data from the
Analytical and Production Survey, EPA determined that the principal pollutants from hot coating
wastewater are TSS, O&G, metals from the surface preparation operations, and hexavalent
7-30

-------
Section 7 - Waste-water Characterization
chromium from lines with chromium brightening or passivation operations. EPA selected 23
POCs for hot coating operations in the Carbon and Alloy Steel Segment of the Steel Finishing
Subcategory, presented in Table 7-10.

Wastewater Flow Rates

The Agency analyzed data from WAPC devices that were reported as being
operated on hot coating lines. After reviewing the 1997 industry survey data and comparing it to
the data used for the 1982 rule, the Agency determined that the model flow rate of 15 gpm
contained in the 1982 rule is still applicable.

In developing the model PNF, the Agency only considered flow rates that were
conveyed to treatment systems. When responding to the industry survey, sites had the option of
indicating if they discharged process wastewater to. treatment and/or disposed of it via several
different zero discharge methods. If a site listed a zero discharge disposal method for a discharge,
EPA did not use that discharge hi the development of the model PNF. If a site's industry survey
response indicated that a flow was both discharged to treatment and disposed of using a zero
discharge method, but did not specify the portion of flow rate going to each, the Agency used the
combined flow to develop the PNF.

EPA selected 550 gpt as the model PNF for hot coating operations. Twenty-eight
of the 40 lines reported having PNFs of less than or equal to 550 gpt. Two of the lines reported
operating without a discharge by using contract hauling. EPA determined that it would be cost-
prohibitive for all sites to achieve the median PNF of 182 gpt. The Agency did not select zero
discharge as the model flow for hot coating because sites would have to use disposal methods
such as contract hauling to achieve zero discharge. '
7.8.6
Electroplating

Sources
The Agency considered data from the 23 sites (integrated, non-integrated, and
stand-alone) that indicated in their industry survey responses that they performed electroplating.
Because some plants operate more than one electroplating line, the total number of operations
analyzed was 44. The Agency was unable to analyze data from two operations due to incomplete
survey responses. EPA has defined electroplating lines as annealing, alkaline cleaning, acid
cleaning, and other surface cleaning and surface preparation operations on the same line.

The primary sources of wastewater from electroplating operations are acid and
alkaline cleaning operations performed on the same process line, plating solution losses, and fume
scrubbers. Tank clean-outs and equipment cleaning are other sources of wastewater reported by
a number of sites.
7-31

-------
Section 7 - Wastewater Characterization
Pollutants of Concern

Based on an analysis of EPA sampling data and industry-provided data from the
Analytical and Production Survey, EPA determined that the principal pollutants from
electroplating wastewater are TSS and O&G generated from the precleaning operations and the
metals from plating solution losses, rinsing, and fume scrubbers. EPA selected 19 POCs for
electroplating operations in the Carbon and Alloy Ste'el Segment of the Steel Finishing
Subcategory (as selected in at least one of the following types of electroplating: tin, tin-chromium,
zinc, or zinc-nickel), presented in Table 7-10.

Wastewater Flow Rates

The Agency analyzed data from WAPC devices that were reported as being
operated on electroplating lines. After reviewing the 1997 industry survey data and comparing it
to the data used for the 1982 regulation, the Agency determined that the model flow rate of 15
gpm contained in the 1982 effluent guidelines is still applicable.

In developing the model PNF, the Agency only considered flow rates that were
conveyed to treatment systems. When responding to the industry survey, sites had the option of
indicating whether they discharged their process wastewater to treatment and/or disposed of it via
several different zero discharge disposal methods. If a, site listed a zero discharge disposal method
for discharge, EPA did not use that discharge in the development of the model PNF. If a site's
industry survey response indicated that a flow was both discharged to treatment and disposed of
using a zero discharge method, but did not specify the portion of flow going to each, the Agency
used the combined flow to develop the PNF. - .

The model PNF for electroplating operations varies by the type of metal applied
and the product type. The Agency chose a model PNF of 1,100 gpt for tin and chromium lines
plating strip steel. Ten of the 20 lines reported PNFs equal to or less than 1,100 gpt. The Agency
chose a model PNF of 550 gpt for lines plating strip steel with metals other than tin or chromium.
Sixteen of the 20 lines reported PNFs equal to or less than 550 gpt. EPA determined that it
would be cost-prohibitive for all sites to achieve the median PNF of 214 gpt. The Agency chose a
model PNF of 35 gpt for electroplating of steel plate. Because the data for plate electroplating
are confidential, they are not presented here. EPA concluded that the selected flow rates are
achievable by well-operated electroplating operations.
7.9
Other Operations Subcategorv
The subcategory the Agency proposes for other operations encompasses segments
for direct reduced ironmaking, forging, and.briquetting.
7-32

-------
Section 7 - Wastewater Characterization
7.9.1 : Directed Reduced Ironmaking (DRI) Segment

Sources

Three DRI plants provided industry survey data. One plant was operated at a non-
integrated site and two were operated as stand-alone DRI sites. One plant began operations after
1997, but was considered for the development of the model flow rate. WAPC systems are the
only reported process wastewater source for DRI operations. The WAPCs control furnace
emissions and emissions from material handling and storage.

. Pollutants of Concern

Based on an analysis of EPA sampling-data and industry-provided data from the
Analytical and Production Survey, EPA determined that the principal pollutant from DRI
operations is TSS. EPA selected 10 POCs for the DRI Segment of the Other Operations
Subcategory, presented in Table 7-12.

Wastewater Flow Rates

An evaluation of the three sites that conducted DRI operations found that they
recycle scrubber wastewater. Based on the practice of wastewater recycle, the Agency selected a
model PNF of 90 gpt;. two of the three DRI plants are achieving this model flow rate.
7.9.2
Forging Segment

Sources
The Agency determined that forging operations are similar to other hot forming
operations with respect to wastewater characteristics based on process considerations. Sixteen
industry survey respondents indicated that they conducted forging operations in 1997 at eight .
non-integrated and four stand-alone sites. Contact water and hydraulic system wastewater
comprise most of the process wastewater from forging operations. Contact water is used for
flume flushing, descaling, die spray cooling, and product quenching. Some sites identified
equipment cleaning water and basements sumps as other sources of wastewater from forging
operations.

Pollutants of Concern

Based on an analysis of industry-provided data, EPA determined that the principal
pollutants from forging are TSS, O&G, and metals. EPA did not identify any POCs for the
Forging Segment because EPA did not sample any forging operations.
7-33

-------
                                                         Section 7 - Wastewdter Characterization
             Wastewater Flow Rates

             EPA calculated 15 PNFs based on available industry survey data.  The Agency
based its development of model treatment for forging operations on similar wastewater treatment
for hot forming operations. As with hot forming, the Agency determined that wastewater
treatment systems treating forging wastewaters demonstrate a recycle rate of 96 percent. High-
rate recycle is a principle component of forging wastewater treatment and EPA used it to select a
model flow rate.  EPA selected a model PNF of 100 gpt for forging operations. This model flow
rate is demonstrated at nine of the 16 forging operations that were analyzed.
7.9.3
Briquetting Segment
             The Agency found that briquetting operations do not generate or discharge
process wastewater.  Therefore, the Agency has designated briquetting as a zero discharge
operation.
7.10

7-1
References

U.S. Environmental Protection Agency. Development Document for Effluent
Guidelines and Standards for the Iron and Steel Manufacturing Point Source
Category. Volume 1. EPA 440/1-82/024, Washington, D.C., May 1982.
                                         7-34

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                                                    7-35  •

-------
                                  Section 7 - Wastewater Characterization
                  Table 7-2

             Pollutants of Concern
Cokemakmg Subcategory - By-Product Segment
Pollutant Group
Conventional pollutants
Nonconventional pollutants
Priority metals
Nonconventional metals
Priority organic constituents
Pollutant of Concern
Biochemical oxygen demand 5-day (BOD5)
Biochemical oxygen demand 5-day (BOD5) - carbonaceous
Oil and grease (O&G)
Total suspended solids (TSS)
Amenable cyanide
Ammonia as nitrogen
Chemical oxygen demand (COD)
Nitrate/nitrite
Total petroleum hydrocarbons (TPH)
Thiocyanate
Total Kjeldahl nitrogen (TKN)
Total organic carbon (TOC)
Total phenols
Weak acid dissociable (WAD) cyanide
Arsenic
Mercury
Selenium
Boron
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(ghi)perylene
Benzo(a)pyrene
Chrysene
2,4-dimethylphenol
                     7-36

-------
                         Section 7 - Wastewater Characterization
Table 7-2 (Continued)
Pollutant Group
Priority organic constituents (cont.)
Nonconventional organic constituents

.



Pollutant of Concern
Fluoranthene
Fluorene
Indeno(l,2,3-cd)pyrene
Naphthalene
Phenanthrene
Phenol
Pyrene
Benzene
1 ,2-Dichloroethane
Ethylbenzene
Toluene
Aniline
2,3-Benzofluorene
Biphenyl
Carbazole
o-Cresol
p-Cresol . .- ,
Dibenzofuran
Dibenzothiophene ;
n-Eicosane
n-Hexadecane
4,5-Methylene phenanthrene
2-Methyhiaphthalene
1 -Methylphenanthrene
1 -Naphthylamine
beta-Naphthylamine
n-Octadecane
Perylene . - • .
2-Phenylnaphthalene
2-Picoline . ' . .
Pyridine
         7-37

-------
                          Section 7 - Wastewater Characterization
Table 7-2 (Continued)
Pollutant Group
Nonconventional organic constituents
(continued)
Other priority pollutants
Pollutant of Concern
Styrene
Thianaphthene
o-Toluidine
2-Propanone
Carbon disulfide
2-Butanone
m-Xylene
m- + p-Xylene
o-Xylene
o- + p-Xylene
Total cyanide
          7-38

-------
                                  Section 7 - Wastewater Characterization
                 Table 7-3

           Pollutants of Concern
Ironmaking Subcategory - Sintering Segment
Pollutant Group
Conventional pollutants
Nonconventional pollutants
Priority metals •
Nonconventional metals


Pollutant of Concern
Oil and grease (O&G)
Total suspended solids (TSS)
. Amenable cyanide
Ammonia as nitrogen
Chemical oxygen demand (COD)
Fluoride
Nitrate/Nitrite
Total petroleum hydrocarbons (TPH)
Thiocyanate - - .
Total Kjeldahl nitrogen (TKN)
Total .organic carbon (TOC)
Total phenols "
Weak acid dissociable (WAD) cyanide
Arsenic - '
Cadmium
Chromium
Copper
Lead
Mercury
Selenium
Silver
Thallium
Zinc
Aluminum
Boron
Iron :
Magnesium
Manganese
Titanium
                    7-39

-------
                         Section 7 - Wastewater Characterization
Table 7-3 (Continued)
Pollutant Group
Priority organic constituents
Nonconventional organic constituents
Pollutant of Concern
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Chrysene
2,4-Dimethylphenol
Fluoranthene
4-Nitrophenol
Phenanthrene
Phenol
Pyrene
n-Tetracosane
n-Docosane
n-Eicosane
n-Hexadecane
n-Octadecane
"o-Cresol
p-Cresol
Pyridine
1,2,3,7,8-Pentachlorodibenzo-p-dioxin
1,2,3,4,7,8-Hexachlorodibenzo-p-dioxin
1,2,3,6,7,8-Hexachlorodibenzo-p-dioxin
1 ,2,3,7,8,9-Hexachlorodibenzo-p-dioxin
1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin
Octachlorodibenzo-p-dioxin
2,3,7,8-Tetrachlorodibenzofuran
1 ,2,3,7,8-Pentachlorodibenzofuran
2,3,4,7,8-Pentachlorodibenzofuran
1,2,3,4,7,8-Hexachlorodibenzofuran
1,2,3,6,7,8-Hexachlorodibenzofuran
1,2,3,7,8,9-Hexachlorodibenzofuran
          7-40

-------
                         Section 7 - Wastewater Characterization
Table 7-3 (Continued)
Pollutant Group
Nonconventional organic constituents
(continued)
Other priority pollutants .
Pollutant of Concern
2,3,4,6,7,8-Hexachlorodibenzofuran
1,2,3,4,6,7,8-Heptachlorodibenzofuran
1,2,3,4,7,8,9-Heptachlorodibenzofuran
Octachlorodibenzofuran
Total cyanide
         7-41

-------
                                    Section 7 - Waste-water Characterization
                    Table 7-4

              Pollutants of Concern
Ironmaking Subcategory - Blast Furnace Segment
Pollutant Group
Conventional pollutants
Nonconventional pollutants
Priority metals .
Nonconventional metals
Nonconventional organic constituents
Other priority pollutants
Pollutant of Concern
Oil and grease (O&G)
Total suspended solids (TSS)
Amenable cyanide
Ammonia as nitrogen
Chemical oxygen demand (COD)
Fluoride
Nitrate/Nitrite
Total petroleum hydrocarbons (TPH)
Thiocyanate
Total Kjeldahl nitrogen (TKN)
Total organic carbon (TOC)
Weak acid dissociable (WAD) cyanide
Chromium
Copper
Lead
Nickel
Selenium
Zinc
Aluminum
Boron
Iron
Magnesium
Manganese
Molybdenum
Titanium
1 ,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin
Total cyanide .
                      7-42

-------
                               Section 7 - Wastewat'er Characterization
              Table 7-5

       Pollutants of Concern
Integrated Steelmaking Subcategory
Pollutant Group
Conventional pollutants
Nonconventional
pollutants
Priority metals
Nonconventional metals
Priority organic
constituents
Pollutant of Concern
Oil and grease (O&G)
Total suspended solids (TSS)
Ammonia as nitrogen
Chemical oxygen demand (COD)
Fluoride
Nitrate/Nitrite
Total petroleum hydrocarbons
(TPH)
Total organic carbon (TOC)
Antimony
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Silver
Zinc
Aluminum
Cobalt
Iron
Magnesium
Manganese
Molybdenum
Tin
Titanium
Vanadium
Phenol
EOF
Furnaces
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Vacuum
Degassing
•
•
•
•
•

•





•
•



•
•

•

•
•
•
•


Continuous
Casting
•
•

•
•

•
•
•




•



•
•

•

V
•




                7-43

-------
                                      Section 7 - Wastewater Characterization
                      Table 7-6

                Pollutants of Concern
Integrated and Stand-Alone Hot Forming Subcategory
           Carbon and Alloy Steel Segment
Pollutant Group
Conventional pollutants
Nonconventional pollutants
Priority metals
Nonconventional metals
Pollutant of Concern
Oil and grease (O&G) .
Total suspended solids (TSS)
Ammonia as nitrogen
Chemical oxygen demand (COD)
Fluoride • • '
Total petroleum hydrocarbons (TPH)
Lead
Zinc
Iron
Manganese
Molybdenum
                        7-44

-------
                                       Section 7 - Wastewater Characterization
                      Table 7-7

                Pollutants of Concern
Integrated and Stand-Alone Hot Forming Subcategory
                Stainless Steel Segment
Pollutant Group
Conventional pollutants
Nonconventional pollutants
Priority metals
Nonconventional metals
Pollutant of Concern
Oil. and grease (O&G)
Total suspended solids (TSS)
Chemical oxygen demand (COD)
Fluoride'
Total petroleum hydrocarbons (TPH)
Total organic carbon (TOC)
Antimony
Chromium
Copper
Nickel
Zinc
Iron
Manganese
Molybdenum
Titanium
                         7-45

-------
                                        Section 7 - Waste-water Characterization
                        Table 7-8

                  Pollutants of Concern
Non-Integrated Steelmaking and Hot Forming Subcategory -
             Carbon and Alloy Steel Segment
Pollutant Group
Conventional pollutants
Nonconvenu'onal pollutants
Priority metals
Nonconventional metals
Pollutant of Concern
Oil and grease (O&G) '
Total suspended solids (TSS)
Ammonia as nitrogen
Chemical oxygen demand (COD)
Total petroleum hydrocarbons (TPH)
Total organic carbon (TOC)
Lead
Zinc
Iron
Manganese
Continuous Casting
•
•
•
•
•
•
•
•


Hot Forming
•
•


•
•
•
•
•
•
                           7-46

-------
                                         Section 7 - Wastewater Characterization
                         Table 7-9

                   Pollutants of Concern
Non-Integrated Steelmaking and Hot Forming Subcategory -
                  Stainless Steel Segment
Pollutant Group
Conventional pollutants
Nonconventional
pollutants
Priority metals
Nonconventional metals
Priority organic
constituents
Pollutant of Concern
Oil and grease (O&G)
Total suspended solids (TSS)
Ammonia as nitrogen
Chemical oxygen demand (COD)
Fluoride
Nitrate/Nitrite
Total petroleum hydrocarbons
(TPH)
Total organic carbon (TOC)
Antimony
Chromium
Copper
Lead
Nickel
Zinc
Aluminum
Boron
Hexavalent chromium
Iron
Manganese
Molybdenum
Titanium
Tribromomethane
Continuous Casting
•
•
•
•
•
•
•
•

•
•
•
•
•
•
•
•
•
•
•
•
•
Hot Forming
•
•

•
•

•
•
•
•
•

•
•
•


•
•
•
•

                           7-47

-------
                                          Section 7 - Wastewater Characterization
                         Table 7-10

                    Pollutants of Concern
Steel Finishing Subcategory - Carbon and Alloy Steel Segment
Pollutant Group
Conventional pollutants
Nonconventional pollutants
Priority metals
Nonconventional metals
Priority organic constituents
Pollutant of Concern
Oil and grease (O&G)
Total suspended solids (TSS)
Ammonia as nitrogen
Chemical oxygen demand
(COD)
Fluoride
Nitrate/Nitrite
Total petroleum hydrocarbons
(TPH)
Total organic carbon (TOC)
Total phenols
Sulfate
Antimony
Arsenic
Chromium
Copper
Lead
Nickel
Selenium
Zinc
Aluminum
Boron
Hexavalent chromium
Iron
Manganese
Molybdenum
Tin
Titanium
Bis(2-ethylhexyl) phthalate
1,1,1 -Trichloroethane
Acid
Pickling ,
•
•
•
•
•
•
"
•

•

•
•
•

•

•



•
•


•


Cold
Forming
•
•
•
"
•

^
•
•


•
•
•

•

•
•


•
•


•
•
•
Alkaline
Cleaning
•
•
•
•
•

^
•





•



•



•
•

•



Coating
•
•
•
'
•
•
"
•


•
•
•
•
•
•

•
•
•
•
•
•
•
•
•


plating
•
•
•
'
•
•
V
•




•
•
•
•
•
•


•
•
•
•

•


                             7-48

-------
                                                                     Section 7 - Waste-water Characterization
                                     Table 7-10 (Continued)
Pollutant Group
Nonconventional organic
constituents
Pollutant of Concern
alpha-Terpineol
Benzoic acid
n,n-Dimethylfbrmamide
n-Dodecane
n-Eicosane
n-Hexadecane
n-Octadecane
n-Tetradecane
2-Propanone
Acid
Pickling


•





•
Cold
Forming
•
•

•
•
•
•
•

Alkaline
Cleaning









Hot
Coating









Electro-
plating









Note: Pollutants of concern were not selected for the annealing manufacturing process.
                                                 7-49

-------
                                         Section 7 - Wastewater Characterization
                       Table 7-11

                  Pollutants of Concern
Stainless Finishing Subcategory - Stainless Steel Segment
Pollutant Group
Conventional pollutants
Nonconventional
pollutants
Priority metals
Nonconventional metals
Pollutant of Concern
Oil and grease (O&G)
Total suspended solids (TSS)
Ammonia as nitrogen
Chemical oxygen demand •
(COD)
Fluoride
Nitrate/Nitrite
Total petroleum hydrocarbons
(TPH)
Total cyanide
Total organic carbon (TOC)
Total phenols
Antimony
Arsenic
Cadmium
Chromium
Copper
Lead
Nickel
Selenium
Zinc
Aluminum
Barium
Boron
Cobalt
Hexavalent chromium
Iron
Magnesium
Manganese
Acid Pickling
•
•
•
•
•
•
•
•
•

•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Alkaline
Cleaning
•
•
•
•
•

•

















•
•
•
Cold Forming
•
•
•
•
•

•

•
•
•
•
•
•
•

•

•
•



•
•

•
                           7-50

-------
                                                                     Section 7 - Wastewater Characterization
                                      Table 7-11 (Continued)
Pollutant Group
Nonconventional metals
(continued)
Priority organic
constituents
Nonconventional organic
constituents





Pollutant of Concern
Molybdenum
Tin
Titanium
Vanadium
Naphthalene
Phenol
Ethylbenzene
Toluene
2,6-Di-tert-butyl-p-
benzoquinone
2-Methylnaphthalene
Benzoic acid
Hexanoic acid
n-Docosane
n-Dodecane
n-Eicosane
n-Hexadecane
n-Octadecane
n-Tetracosane
n-Tetradecane
2-Propanpne
m-Xylene
o- + p-Xylene
Acid Pickling
•
•
•
•


















Alkaline
Cleaning


•










-








Cold Forming
•
•
•

•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Note: Pollutants of concern were not selected for the annealing manufacturing process.
                                                 7-51

-------
                                            Section 7 - Wastewater Characterization
                            Table 7-12

                       Pollutants of Concern
Other Operations Subcategory - Direct Reduced Ironmaking Segment
Pollutant Group
Conventional pollutants
Nonconventional pollutants
Nonconventional metals
Pollutant of Concern
Oil and grease (O&G)
Total suspended solids (TSS)
Ammonia as nitrogen
Chemical oxygen demand (COD)
Fluoride
Total petroleum hydrocarbons (TPH)
Aluminum
Iron
Manganese ,
Titanium
                               7-52

-------
                                                                 Section 8 - Technology Options
                                       SECTIONS

                               TECHNOLOGY OPTIONS

              This section describes the technology options that EPA evaluated in developing
 the effluent limitations guidelines and standards proposed for the iron and steel industry.  To
 determine the model treatment technologies, model discharge flow rate, and effluent quality for
 the proposed regulation, EPA developed a database of the following:

              •      In-process technologies and process modifications;
              •      Process water recycle technologies;
              • '     End-of-pipe wastewater treatment technologies;
              •      Process wastewater discharge flow rates; and
              •      Treated process wastewater effluent quality.

 EPA collected most data were collected from the analytical and production survey and the EPA
 wastewater sampling programs. As described in Section 3, the Agency also used other data
 sources.

              Although EPA has wide discretion to establish BAT effluent limitations guidelines
 on a range of technologies, including transfer of technologies from other .industries and in-process
 controls, even when not common industry practice, the technology options considered for this
 proposed regulation are generally well demonstrated in the iron and steel industry. The Clean
 Water Act does not require that dischargers achieve technology-based effluent limitations and
 categorical pretreatment standards by using the technologies considered by EPA when
 promulgating the effluent limitations guidelines and standards regulations. Rather, the Clean
 Water Act requires compliance with numerical NPDES permit and pretreatment limits derived
 from the effluent limitations guidelines and standards. Direct and indirect dischargers can use any
 combination of process modifications, in-process technologies, and wastewater treatment
 technologies.

              Section 8.1 summarizes the in-process and end-of-pipe treatment technologies
 considered by EPA, and Section 8.2 summarizes the technology options (model treatment
 systems) EPA evaluated for the proposed effluent limitations guidelines and standards.
8.1
Technology Overview
             This section discusses the types of technologies in place at iron and steel sites and
other industrial wastewater treatment. Many wastewater treatment technologies apply to multiple
subcategories; therefore, this section presents technologies in general order by manufacturing
process and then by the typical treatment train for each technology. Section 8.1.1 discusses in-
process technologies, and Section 8.1.2 discusses end-of-pipe technologies..
                                          8-1

-------
Section 8 - Technology Options
8.1.1
In-Process Technologies
Wastewater management practices for wet air pollution controls (WAPCs) for
blast furnaces, sintering operations, and wet-open or wet-suppressed basic oxygen furnaces
(BOFs) focus on the treatment and recycle of large volumes of contaminated gas cleaning
wastewater. The use of high-rate recycle can reduce annual discharges by 95 percent or greater.

Common pollutants in blast furnace gas cleaning wastewater include total
suspended solids (TSS), ammonia, cyanides, phenolic compounds, and metals. Wastewater from
•sintering operations also contains these pollutants, along with oil and grease (O&G) and dioxins
and furans. Wastewater from gas cooling and cleaning systems associated with BOFs is.
contaminated with TSS and metals. To limit the pollutant loadings and volume of water
discharge associated with the WAPC from the above-mentioned operations, high-rate recycle
systems consisting of solids removal devices such as classifiers and clarifiers for removal of
suspended solids are used to treat wastewater before reuse for gas cooling and cleaning. Blast
furnace recycle systems also use cooling towers prior to reuse in gas cleaning systems. Carbon
dioxide injection prior to clarification can be used for wet-open combustion and wet-suppressed
combustion BOF recycle systems to remove scale-forming metal ions from wastewater before
reuse. Solids recovered from classifiers, clarifiers, and scale pits have a significant iron content
and may be processed at sintering or briquetting operations and then charged to a blast furnace.
To prevent the accumulation of other contaminants in the high-rate recycle system, a small
'portion of the high-rate recycle stream is continuously discharged (blowdown), and makeup water
is added. Blowdown is then treated at an end-of-pipe treatment system before discharge.

High-rate recycle systems are also used for vacuum degassing, continuous casting,
and hot forming operations. Typical vacuum degassing high-rate recycle systems consist of
clarifiers and cooling towers, with blowdown treated individually or with blowdown from
continuous caster recycle systems. Typical components of high-rate recycle systems are scale pits
with oil skimming, additional O&G and solids removal through clarification or filtration, and
cooling towers. Principal pollutants from vacuum degassing wastewater are TSS and metals.
Common pollutants from continuous casting and hot forming operations are TSS, O&G, and
metals. Scale recovered from scale pits has a significant iron content and may be processed at
sintering or briquetting operations and then charged to a blast furnace.

The following paragraphs provide additional information regarding equipment
associated with the high-rate recycle systems discussed. Section 8.1.2 provides information on
clarifiers, multimedia filtration, solids-handling equipment, and cooling towers, all of which are
also common end-of-pipe treatment technologies.

• Scale Pits with Oil Skimming. Scale pits provide primary sedimentation
and oil separation for untreated process wastewater generated by
continuous casting and hot forming operations. Scale pits remove large,
easily settleable iron scale. Pits are scraped or dredged and the iron scale is
recovered for reuse or landfilled on or off site. Skimmed oil is typically
collected on site and shipped off site for reclamation.
3-2

-------
Section 8 - Technology Options
Classifiers. Classifiers provide primary sedimentation of high-volume
untreated wastewater from wet-suppressed and wet-open EOF WAPC
systems. Solids can be removed using screw or rake systems.
Carbon Dioxide Injection. Carbon dioxide injection is one method to
remove scale-forming metal ions (hardness) from BOF recycle water in
wet-open and wet-suppressed combustion systems. Carbonate
precipitation occurs in the recycle system through injection of carbon
dioxide (CO2) prior to clarification. Carbon dioxide is injected through a
very fine bubble diffusion assembly which is located in a basin with a
minimum water depth of 10 feet. Liquid CO2 can be stored on site and
preheated prior to injection to create CO2 gas. A series of baffles or a
mixer directly above the CO2 injection point help keep the bubbles
submerged as long as possible. This action forms carbonic acid and
bicarbonate alkalinity as illustrated by Equation 8-1 below:
HO + CO
>H2CO --------
(8-1)
Cafbonate reacts with magnesium and calcium ions to form insoluble
precipitate, which is removed in the clarifier, by Equation 8-2 below:
Ca2+ + Mg2* + 2HCO3 + heat > CaCO31 + CO2 +H2O
. (8-2)
Carbon dioxide injection can potentially reduce effluent hardness levels to
10- 15mg/LasCaCO3. -

Stainless, alloy, or carbon steel finishing mills process hot rolled steel through a
combination of acid pickling, cold rolling, alkaline cleaning, hot coating, and electroplating
operations. Based on responses to the industry survey, hot coating and electroplating are only
performed on carbon and alloy steel. Pollutants include oils from cold rolling operations and
alkaline cleaning, hexavalent chromium from hot dip coating and electroplating of carbon steel or
acid pickling of stainless steel, and metals from acid pickling and electroplating. In-process
alternatives for finishing mills include countercurrent rinsing to limit water usage, ion exchange,
and evaporation to recover acids and metals before end-of-pipe treatment. Training,
housekeeping, and record-keeping can also be effective management alternatives for steel
finishing operations. Below are additional details on each of these in-process practices.

• Countercurrent Rinsing. Countercurrent cascade rinsing refers to a series
of consecutive rinse tanks that are plumbed to cause water to flow from
one tank to another in the direction opposite of the product flow. Fresh
water flows into the rinse tank located farthest from the process tank and
overflows, in turn, to the rinse tanks closer to the process tank. This
technique is called countercurrent rinsing, because the product and the
rinse water move in opposite directions. Over time, the first rinse becomes
contaminated with drag-out solution and reaches a stable concentration
8-3

-------
                                            Section 8 - Technology Options
that is lower than the process solution.  The second rinse stabilizes at a
lower concentration, which enables less rinse water to be used than if only
one rinse tank were in place. The more countercurrent cascade rinse tanks
(three-stage, four-stage, etc.), the less water is needed to adequately
remove the process solution.

The rinse rate needed to adequately dilute drag-out solution depends on the
concentration of process chemicals in the initial process bath, the
concentration of chemicals that can be tolerated in the final rinse tank to
meet product specifications, the amount of drag-out carried into each rinse
stage, and the number of countercurrent cascade rinse tanks.  These factors
are expressed in Equation 8-3 below:
                                                               (8-3)
where:
       Vr
       C0

       Q
       n
       V,
Flow through each rinse stage, gal/min
Concentration of the contaminant(s) in the initial
process bath, mg/L
Tolerable concentration of the contaminant(s) in the
final rinse to give acceptable product cleanliness,
mg/L
Number of rinse stages used
Drag-out carried into each rinse stage, expressed as
a flow, gal/min.
This mathematical rinsing model is based on complete rinsing (i.e.., removal
of all contaminants from the product) and complete mixing (i.e.,
homogeneous rinse water). Under these conditions, each additional rinse
stage can reduce rinse water use by 90 percent.  These conditions are not
achieved unless there is sufficient residence time and agitation in the rinse
tank. For less efficient rinse systems, each added rinse stage reduces rinse
water use by 50 to 75 percent.

Countercurrent cascade rinsing systems have a higher capital cost than an
overflow rinse and require more space due to the additional rinse tanks.
Also, when countercurrent cascade rinsing is used, the low flow rate
through the rinse tanks may not provide the needed agitation for drag-out
removal. In such cases, air or mechanical agitation is added to increase
rinsing efficiency.

Recycle of Fume Scrubber Water. The steel finishing industry commonly
uses fume scrubbers to capture acid gases.  Scrubber water, which may
                       8-4

-------
                                             Section 8 - Technology Options
 contain a dilute caustic solution, is neutralized and continuously recycled to
 adsorb acid.  Makeup water is added to replace water lost through
 evaporation and water which is blown down to treatment. Slowdown is
 discharged to end-of-pipe treatment to prevent salts buildup.

 Hydrochloric Acid Regeneration. This process consists of thermal
 decomposition of spent pickle liquor, which contains free hydrochloric
 acid, ferrous chloride, and water!  The liquor is heated to remove some of
 the water through evaporation and to concentrate the solution. The
 concentrated solution is then further heated to 925 °C to 1,050°C. At this
 temperature, water is completely evaporated and the ferrous chloride
 decomposes into iron oxide (ferric oxide, Fe2O3) and hydrogen chloride
 (HC1) gas. Equation 8-4 below shows the decomposition process:
4 Fed, + 4 H,O + O, —-> 8 HC1 + 2 Fe,O,
                                                                (8-4)
The iron oxide is separated and removed from the system. The hydrogen
chloride gas is reabsorbed in water (sometimes rinse water or scrubber
water is used), to produce hydrochloric acid solution (generally from 15
percent to 21 percent HC1) which is reused in the pickling operation.
There are several types of "roaster" types of process in operation. The
basic differences among the processes are the design and operation of the
roaster/reactor and the recovery equipment (Reference 8-3).

Effluent-Free Pickling Process with Fluid Bed Hydrochloric Acid
Regeneration. This pickling process can be operated such that no
wastewater is discharged from spent pickle liquor, rinse wastewater, and
scrubber water from a hydrochloric acid pickling line.  The process is
configured as a closed system that uses a fluidized bed reactor "roaster"
configuration (hydrochloric acid regeneration is explained in detail above)
to thermally decompose spent pickle liquor to hydrochloric acid and iron
oxide (Reference 8-4).

Spent pickle liquor is fed via a settling tank and venturi loop into the
fluidized bed inside the reactor. The thermal energy from the fluidized bed
off-gases is used to  concentrate the pickling liquor by evaporation before it
is fed to the reactor. The fluidized bed consists of granulated iron oxide.
Residual acid and water are evaporated at 850°C and the iron chloride is
converted to hydrochloric acid gas. Growth and new formation of iron
oxide grains in the fluidized bed are controlled so that a dust-free
granulated product is obtained. The iron oxide grains can be used as a raw
material to manufacture other products (e.g., as an additive for the
production of magnetic tapes, abrasives, tiles, glass, cosmetics and
pigments).
                       5-5

-------
                                             Section 8 - Technology Options
Since the fluidized bed process operates at approximately 850 °C, rinse and
scrubber water from the pickle line can be used at the regeneration plant to
cool fluidized bed off-gases, which contain hydrochloric acid vapor and a
small amount of iron oxide dust. The off-gases are cooled to
approximately 100°C in a venturi scrubber.  The thermal energy of the-off-
gases is used to concentrate the pickling liquor by evaporation before it is
fed to the reactor.  From the venturi scrubber, the cooled gas stream goes
to the absorber, where hydrogen chloride is absorbed with rinse water from
the pickling line and fresh water to produce hydrochloric acid. The acid
can be recycled directly to the pickling process or placed in a storage tank
for later use. Once the fluidized bed off-gases have passed through the
scrubbing stages and'mist collector, the off-gases are virtually free of
hydrochloric acid and are released to the atmosphere.

Sulfuric Acid Recovery.  To recover sulfuric acid, spent pickle liquor high
in iron content is pumped into a crystallizer, where the iron is precipitated
(under refrigeration or vacuum) as ferrous sulfate heptahydrate crystals.
As the crystals are  formed,  water is removed with the crystals, and the free
acid content of the solution increases to a level .that is useable in the
pickling operation.  The crystals are separated from solution, and the
recovered acid" is pumped back into the pickling tank. The by-product
ferrous sulfate heptahydrate is commercially marketable.  The crystals are
dried, bagged, and marketed, or sold in bulk quantities. Ferrous sulfate,
commonly referred to as "copperas," is used in appreciable quantities in
numerous industries, including the manufacture of inks, dyes, paints,
fertilizers, and magnetic tapes. It is also used as a coagulant in water and
wastewater treatment (Reference 8-3).

Add Purification and Recycle. Acid purification technology is applicable
to various acid pickling solutions, such as  sulfuric acid, and
nitric/hydrofluoric acids used in stainless steel finishing mills. Acid is
purified by adsorption on a bed of alkaline anion exchange resin that
separates the acid from the metal ions. Acid is desorbed from the resin
using water.  The process begins by passing spent acid upward through the
resin. A metal-rich, mildly acidic solution passes through the resin and is
collected at the top of the bed. Water is then pumped downward through
the bed and desorbs the acid from the resin.  The purified acid solution is
collected at the bottom of the bed. This technology can recover
approximately 80 percent of the free acid remaining in a spent acid
treatment solution.

Nitric-Acid-Free Pickling. Nitrates were identified as a pollutant of
concern for stainless steel acid pickling operations where nitric acids and
combinations of nitric and hydrofluoric acids are used for surface
treatments for various grades of stainless steels.  When consumed in
                       8-6

-------
                                              Section 8 - Technology Options
 drinking water, nitrates may cause health problems in humans, particularly
 infants. The Agency is considering regulating nitrates/nitrites and is •
 investigating in-process treatment alternatives to eliminate nitrate
 discharges. The Agency is aware of a proprietary commercial technology
 that uses a nitric acid free solution that contains an inorganic mineral acid
 base, hydrogen peroxide, stabilizing agents, wetting agents, brighteners,
 and inhibitors. This process requires the same equipment as conventional
 acid pickling processes, with the addition of agitation to the bath to
 circulate fresh acid to the metal surface.  The process is also compatible
 with acid regeneration. Acid purification and recycle, discussed above, is
 also an in-process treatment technology that can reduce nitrate discharges
 significantly.

 Effluent-Free Exhaust Cleaning for Stainless Steel Pickling.  Stainless
 steel pickling operations using mixed acid, nitric acid, or hydrofluoric acid
 produce exhaust gases that contain nitrogen oxide and hydrogen fluoride.
 WAPCs are typically used to treat these exhaust gases, thereby generating
 wastewater. The Agency is aware of a commercially available technology
 that uses selective catalytic reduction (SCR) technology to treat exhaust
 gases from stainless steel pickling operations in lieu of WAPCs (Reference
 8-5).

In-Tank Filtration.  Paper, cloth, or plastic filters are used to extend
process bath life through removal of accumulated suspended solids or
precipitant. Dissolved contaminants, such as organic constituents, are
removed through devices such as granular  activated carbon filters.

Magnetic Separation of Fines in Cold Rolling Solution. Magnetic
separators are sometimes used in the iron and steel industry  to extend the
life of cold rolling solutions. Magnetic separators are either installed in
rolling solution collection tanks or in a side-stream system connected to
these tanks. The most effective systems use vertical or horizontal
configurations of magnetic rods to remove  fines. Well-designed magnetic
separators can control the iron content in the rolling solutions to below 100
parts per million (Reference 8-6 ).

Ion Exchange. Ion exchange is a reversible chemical reaction that
exchanges ions in a feed stream for ions of like charge on the surface of an
ion-exchange resin.  Resins are broadly divided into cationic or anionic
types.  Typical cation resins exchange H1" for other cations, while anion
resins exchange OH~ for other anions.  Many types of process wastewater
are excellent candidates for ion exchange, including the rinse water from
plating processes of lead, nickel, tin, tin-lead, chromium, and zinc.
                       8-7

-------
                                             Section 8 - Technology Options
Ion exchange can be used for both water recycling and/or metal recovery.
For water recycling, cation and anion columns are placed in series. The
feed stream is deionized and the product water is reused for rinsing. The
regenerant from the cation column typically contains metal species (with
the exception of chromium, which is captured in the anion column), which
can be recovered in elemental form via recovery. The anion regenerant is
typically discharged to wastewater treatment.  When metal recovery is the
only objective, a single or double cation column unit containing selective
resin is used.  These resins attract divalent cations while allowing
monovalent cations to pass, a process usually referred to as metal
scavenging. Water cannot be recycled because contaminants other than the
target cations remain in the stream exiting the column.

Ion exchange equipment ranges from small, manual, single-column units to
multi-column, highly automated units.  For continuous service, two sets of
columns are necessary.  One set handles the service flow, and the other set
is regenerated. Thus, two-column metal scavenging and four-column
deionizing systems are common. Automatic systems direct the wastewater
flow and initiate regeneration with little or no operator interaction.
Equipment size is based on flow volume and concentration. Resin capacity
varies but often ranges from 1 to 2 pounds per cubed feet.  Columns are.
typically sized to handle wastewater flow for at least a period of time equal
to the time required for regeneration. Automatic systems are sized to
provide continuous service.  Regeneration volume typically ranges from 2
to 4 resin bed volumes of dilute acid or caustic.

Evaporation with Condensate Recovery. Evaporation is a common
chemical recovery technology.  There are two basic types of evaporators:
atmospheric and vacuum. Atmospheric evaporators, the more prevalent
type, are relatively inexpensive to purchase and easy to operate. Vacuum
evaporators are mechanically more sophisticated and are more energy-
efficient. Vacuum evaporators are typically used when evaporation rates
greater than 50 to 70 gallons per hour are required.  Additionally, with
vacuum evaporators, evaporated water can be recovered as a condensate
and reused on site.

A disadvantage of evaporation-based recovery is that all drag-out,
including unwanted contaminants, are returned and accumulate in the
process bath.  For this reason, deionized water is preferred as rinse water
to prevent the introduction of water contaminants in the process bath.

Best Management Practices. There are many plant maintenance and good
housekeeping management practices that can be applied at all iron and steel
facilities: training and supervision, production planning and sequencing,
process or equipment modification, raw material and product substitution
                      8-8

-------
                                              Section 8 - Technology Options
 or elimination, and loss prevention and housekeeping (Reference 8-7).
 These alternatives are discussed below:

 —    Training and Supervision. Training and supervision ensures that
       employees are aware of,, understand, and support the company's
       waste minimization goals. These goals are translated into practical
       information that will enable employees to minimize waste
       generation through the proper and efficient use of tools, supplies,
       equipment, and materials.

 —    Production Planning and Sequencing. Production can be planned to
       minimize the number of steps and eliminate unnecessary procedures
       (e.g., plan production to eliminate additional cleaning steps between
       incompatible operations).

 —    Process or Equipment Modification. Processes and equipment can
       be modified to minimize the amount of waste generated (e.g.,
       reducing drag-out by slowing the withdrawal speed of part,
       installing electrolytic recovery units).

—    Raw Material and Product Substitution or Elimination.  Where
       possible, raw materials or products should be replaced with other
       materials that produce either less waste and/or less toxic waste
       (e.g., replacing chromium-bearing solutions with non-chromium-
       bearing and less toxic solutions, consolidating types of cleaning
       solutions and machining coolants).

—    Oil Management and Preventive Maintenance. Where possible,
       sites should remove oil in recycle treatment, recycle used oil, and
       ensure integrity of process area containment systems.

—    Loss Prevention and Housekeeping. Loss prevention and
       housekeeping includes performing preventive maintenance and
       managing equipment and materials to minimize leaks, spills,
       evaporative losses, and other releases (e.g., inspecting the integrity
       of tanks on a regular basis, using chemical analyses instead of
      ' elapsed time or amount of product processed as the basis for
       disposal of a solution). Solution testing is one important loss
       prevention alternative.  The chemical make-up of cleaning solutions
   ,    changes over time due to evaporative losses, additions of water,
       drag-out of cleaning chemicals, consumption of bath chemistry,
       chemical reactions, and drag-in of impurities.  Because of these
       factors, cleaning baths lose strength, performance declines, and
       solutions require disposal. Many sites operate cleaning baths with a
       schedule consisting of three steps: formulate, use, and discard.
                      8-9

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Section 8 - Technology Options
This procedure can be expensive and inefficient from a production
standpoint, and creates large volumes of waste. For this reason,
sites should frequently determine the strength of the cleaning
solution and appropriate chemical additions needed to continue
solution use. By implementing a program of testing and record
keeping, sites can reduce the disposal frequency of cleaning baths.

— Waste Segregation and Separation. Mixing different types of
wastes or mixing hazardous wastes with nonhazardous wastes
should be avoided. Recyclable materials should not be mixed with
incompatible materials or wastes. For example, hexavalent-
chromium-bearing wastewater can be separated for preliminary.
treatment.

Other in-process treatment technologies that could be applied to pickling and
electroplating wastewater generated by the steel finishing industry include electrowinning and
reverse osmosis. Electrowinning can recover metals from ion exchange regenerants and return
.the metals to the plating bath. Reverse osmosis is a membrane technology that can be used to
recover metal salts and generate a treated water stream that can be recycled for use as a rinse
water. Neither of these technologies were reported in industry survey responses as a metals
recovery technology; however, these technologies are commonly used in similar electroplating
operations and are therefore applicable to the iron and steel finishing industry (Reference 8-8).
For more information on these processes and other potentially applicable in-process treatment
technologies, refer to the Development Document for the Proposed Effluent Limitations
Guidelines and Standards for the Metals Products and Machinery Point Source Category
(Reference 8-8).
8.1.2
End-of-Pipe Treatment Technologies
The following subsections discuss the various end-of-pipe wastewater treatment
technologies applicable to iron and steel facilities.

• Flow equalization;
• Cooling technologies;
• Coke plant treatment technologies;
• Cyanide treatment technologies;
• Oily wastewater treatment technologies;
• Metals treatment technologies;
• Solids handling technologies; and
• Polishing technologies.

Table 8-2 summarizes the end-of-pipe wastewater treatment and disposal technologies for all of
these subsections.
8-10

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Section 8 - Technology Options
Flow Equalization

Flow equalization is a critical treatment component to achieve consistent
wastewater treatment performance for ehd-of-pipe treatment systems at all iron and steel facilities.
Flow equalization before ammonia distillation and biological treatment at by-product recovery
cokemaking facilities, and before chemical precipitation and clarification systems at integrated,
non-integrated, and stand-alone facilities dampen fluctuations (reduce variability) in flow and
influent wastewater quality. For by-product recovery cokemaking, flow equalization can also
eliminate shock loadings of inhibitory substances to the biological treatment system. The effluent
quality and thickening performance of secondary clarifiers following biological treatment is also
improved as a result of constant solids loadings. "Flow equalization improves the performance of
chemical precipitation systems as a result of improved chemical feed control and process
reliability. Eliminating rapid flow increases to gravity clarification equipment lessens the chance
of disrupting the sludge bed. For multimedia filtration systems, flow equalization results in a
constant media filtration surface area requirement and more uniform filter-backwash cycles.

The key design parameter for flow equalization is the required tank volume.
Another key component of the equalization tank system is mixing. Two types of mixing are
typically observed in equalization systems: conventional top or side-mount impeller mixers and a
pump system that continuously removes a portion of the wastewater from the tank and
reintroduces it into the untreated wastewater flow.
: ' **•
Cooling Technologies

Cooling technologies are used to attain water temperatures appropriate to facilitate
end-of-pipe treatment and for reuse in high-rate recycle systems. Cooling is used in recirculation
systems for blast furnace, vacuum degassing, continuous casting, and hot forming operations.
Cooling is also commonly used prior to biological treatment systems at by-product recovery
cokemaking plants to prevent water temperatures detrimental to biomass.

« Cooling Towers, Counterflow induced draft cooling towers are common
in the iron and steel industry. The counterflow arrangement is superior to
the cross-flow tower for greater cooling ranges (Reference 8-9).
Performance of a given cooling tower is governed by the ratio of the
weights of air to water and the time of contact between water and air. The
time of contact between water and air is governed largely by the time
required for the water to discharge from the nozzles and fall through the
tower to the basin. The time of contact is therefore obtained in a given
type of unit by varying the height of the tower.

• Shell-and-Tube Heat Exchangers. This is an indirect contact device that
facilitates the transfer of heat from one fluid stream to another.
Counterflow, shell-and-tube heat exchangers are common in the. iron and
steel industry. Liquid to be cooled or heated is pumped through tubes that
run the length of the shell of the heat exchanger while another liquid to be'
8-11

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Section 8 -.Technology Options
cooled or heated is pumped through the shell and passes over the tubes.
Baffles placed along the shell direct the flow in the shell over the tubes to
promote turbulence and support tubes in horizontal units.

Coke Plant Treatment Technologies

By-product recovery cokemaking operations produce wastewater containing
nutrients such as ammonia and dissolved organic matter, including phenols, volatile organic
. compounds (VOCs), and polyaromatic hydrocarbons (PAHs), which if discharged untreated can
result in growth of microbial populations and vegetation that deplete the oxygen concentration of
the receiving stream to levels which can not support aquatic organisms. In the cokemaking
industry, tar filtration, ammonia distillation, and biological treatment systems can be used to
remove nutrients and dissolved organic matter from wastewater. Each of these types of treatment
systems is described below.

• Tar Removal Tar decanters are used to recover oil and tar from excess
ammonia liquor generated during cokemaking. A mechanical filter can be
placed on the tar decanter effluent to prevent residual tar and oil from
entering the ammonia distillation system. The multiple tube filter uses a
filter element made from porous aluminum oxide ceramic that can remove
particulate as fine as 0.3 microns with flow rates of approximately 2 gallons
per minute per square foot (gal/min/ft2). At the end of each filtration cycle,
collected solids are removed from the filter by backwashing. Removing the
large-chained organic compounds present in tar significantly reduces the
carbonaceous biochemical oxygen demand (CBOD5) of cokemaking
wastewater.

• Free and Fixed Ammonia Distillation (Stripping). Ammonia stripping is
the transfer of gas (ammonia) dissolved in a liquid (waste ammonia liquor)
into a gas stream (steam). In the cokemaking industry, flushing liquor is
pumped to the top of a tray-type distillation tower and steam is injected
into the base. As the rising steam passes through the boiling ammonia
liquor moving down the tray tower, ammonia is transferred from the liquid
to the gas phase, eventually passing out the top of the tower. The hot,
ammonia-rich steam is collected, cooled, and typically treated with sulfuric
acid to form ammonium sulfate, a by-product that can be shipped off site
for use as a fertilizer. Liquid collected from the bottom of the stripping
tower is cooled and transferred to a holding tank prior to further on-site
treatment to remove any residual ammonia, or before discharge to the
publicly owned treatment works (POTW).

The efficiency of the stripping tower is a related to the number of trays
(transfer units) that the liquid must pass over before reaching the bottom.
Therefore, the higher the tower, the more trays and greater ammonia
removal efficiency. The tower diameter is a function of the flow rate to the
8-12

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                                             Section 8 - Technology Options
 system. Ammonia stripping towers in the cokemaking industry typically
 range in height from 30 feet to over 100 feet, with diameters ranging
 between 4 and 8 feet.

 Biological Nitrification.  Biological nitrification is the aerobic process of
 converting ammonia to nitrate in a conventional activated sludge system
 configured with an aeration tank, a clarifier, and return sludge equipment.
 Figure 8-1 presents a process flow diagram of a typical biological
 nitrification system. Diffused-or mechanical aeration achieve the aerobic
 environment in the reactor and also serves to maintain the mixed liquor in a
 completely mixed regime. After a specified period of time, the mixture of
 new bacterial cells and old bacterial cells passes into a  settling tank where
 the cells are separated from the treated wastewater.  A portion of the
 settled cells is recycled to maintain the desired concentration of organisms
 in the reactor, and a portion is wasted. In the activated sludge nitrification
 process, the ammonium ion is converted to nitrate in two steps by
 autotrophic bacteria, as summarized by the following reactions (Reference
 8-10):
NH
3/2 O2 — > NO2- + 2H+
                                H2O
NCV+1/2O,—>NO,
(8-5)

(8-6)
In addition to obtaining energy from the reaction shown above, the bacteria
assimilates a portion of the nitrogen into the cell tissue as shown by the
following reaction:                                        "
4CO  + HCO
              4- NH4+
                H2O — -> C5H7NO2 + 5O2
(8-7)
As shown in Equation 8-7, the nitrifying autotrophic bacteria use carbon
dioxide and bicarbonate as a carbon source. The most important factor in
controlling the nitrification system is the sludge retention time (SRT).
Other significant factors on affecting nitrification include hydraulic
retention time (HRT), ammonia and nitrite concentrations, the BOD/TKN
ratio, dissolved oxygen concentration, temperature, and pH.

Biological Denitrification.  Biological denitrification (anaerobic) is
applicable to the treatment of cokemaking wastewater following biological
nitrification. Denitrification is a metabolic process in which nitrate is
converted to nitrogen gas in the presence of a combined hydrogen source
and a lack of free oxygen.  The bacteria that are able to reduce nitrate are
facultative heterotrophs of the genera Pseudomonas, Micrococcus,
Achromobacter, and Bacillus (Reference 8-11).  The reaction involves the
transfer of electrons from organic carbon (oxidation) to nitrate (reduction)
promoting its conversion to nitrogen gas.  The biochemical pathway in
                      8-13

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                                                                 Section 8 - Technology Options
                    which nitrate is substituted for oxygen as the final electron acceptor in the
                    electron transport chain is thermodynamically less favorable than if oxygen
                    were the final electron acceptor. In the presence of free oxygen,
                    denitrification ceases and typical aerobic oxidation predominates.
                    Denitrification is typically referred to as anoxic respiration since it is an
                    aerobic process in the absence of free oxygen.

                    The anoxic process, like the aerobic process, utilizes organic carbon to
                    maintain cellular respiration and synthesis of biomass.  The carbon can be
                    derived from either the endogenous decay of biomass or from an external
                    source,  such as added methanol or organic materials already in the waste.
                    The majority of denitrification systems operating in the United States use
                    methanol as their carbon source.. The equations below show the balanced
                    stoichiometric reactions for the conversion of nitrate to nitrogen gas with
                    either methanol (Equation 8-8) or acetic acid  (Equation 8-9) as the carbon
                    source (Reference 8-10).
                    N03- + 1.08 CH3OH + H+ —>
                           0.065 C5H7O2N + 0.47 N2+ 0.76 CO2 + 2.44 H2O
(8-8)
                    NOf + 0.65 CH3COOH —-> 0.5 N2+ 1.3 CO2 + 0.9 H2O + 0.8 OHT  (8-9)

                    For denitrification of cokemaking wastewater, two treatment options are
                    applicable: 1) a unit in which all the flow from the biological nitrification
                    system enters the denitrification system; or 2) a recycle system in which a
                    portion of the effluent from the biological nitrification system is returned to
                    the beginning of the treatment system and mixed with fresh wastewater.
                    Figure 8-2 presents denitrification systems. For the end-of-pipe
                    denitrification system, a supplemental carbon source such as methanol
                    would be required to convert nitrate to nitrogen gas.  For the recycle
                    system, recycle equipment and tanks would be required to handle recycle
                    volumes approximately 3 to 4 times the original wastewater flow.

              Cyanide Treatment Technologies

              Cyanide is present in process wastewater from by-product recovery cokemaking,
blast furnace, and sintering operations.  In biological treatment, many microorganisms can
acclimate to relatively high concentrations of cyanides and have been documented to successfully
treat wastewaters with concentrations up to 30 mg/L (Reference 8-12). The following treatment
options are applicable to by-product recovery cokemaking (as add-ons to biological treatment),
blast furnace ironmaking, and sintering wastewater for cyanide removal.

              •      Cyanide Precipitation. Cyanide precipitation combines cyanide in the
                    waste ammonia liquor from cokemaking with iron to form an insoluble
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                                             Section 8 - Technology Options
 iron-cyanide complex that can be precipitated and removed by gravity
 settling. The process can be illustrated by the following chemical reaction:
3CN- + Fe+3
                 FeCN,
(8-10)
 Excess iron is typically added in the form of ferric sulfate (Fe2(SO4)3) and
 the pH is adjusted to approximately 4.5 using sulfuric acid.  Following
 complex formation, polymer is added to flocculate the iron-cyanide
 particulates, allowing them to settle in a gravity clarifier. Effluent from the
 gravity clarifier can be pH adjusted to neutral prior to discharge, or the pH
 can be raised to approximately 9 to precipitate any residual metals.

 Alkaline Chlorination.  Alkaline chlorination can be' applied to both
 cokemaking and blast furnace ironmaking wastewater for the destruction of
 cyanide, phenolics, and ammonia.  An alkaline chlorination unit uses
 sodium hypochlorite or chlorine gas in a carefully controlled pH
 environment to remove cyanide and ammonia. The process oxidizes
 cyanide to bicarbonate and nitrogen gas, and ammonia to nitrogen gas and
 water, as illustrated by the following chemical reactions (Reference 8-12):
Cyanide:

CN- + ocr — -> CNO  + cr

CNQ- + 1.5OC1- —> HCO3- + 1/2N2 H- l.SCr + 1/2H+

Ammonia:

2NH/ + 3HOC1 —> N2 + 3H2O + 3HC1 + 2H*
                                                              (8-11)

                                                              (8-12)



                                                              (8-13)
The alkaline chlorination process oxidizes cyanides to carbon dioxide and
nitrogen, and ammonia to nitrogen and hydrochloric acid. The equipment
consists of two reaction tanks, each with an agitator and a pH and
oxidation-reduction potential (ORP) controller.  The first step (tank 1) of
the reaction oxidizes cyanides to cyanate. To affect the reaction, sodium
hypochlorite is metered into the reaction tank as necessary to maintain the
ORP at 350 to 400 millivolts, and aqueous sodium hydroxide is added to
maintain a pH of 10 to 11. In the second step (tank 2), the ORP and the
pH level are maintained at 600 millivolts and 8 to 9, respectively, to oxidize
cyanate to carbon dioxide and nitrogen. Each step has an agitator designed
to provide approximately one turnover per minute.

Alkaline chlorination can be performed at ambient temperature and
automatically controlled and is capable of achieving effluent levels of
cyanide that are below detection. However, the reaction must occur at
                      8-15

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Section 8 - Technology Options
carefully controlled pH levels and has the possibility of chemical
interferences when treating mixed wastes. The effectiveness of the unit
depends on the pretreatment and segregation of cyanide waste streams and
the careful control of the pH. The size and type of system is solely
dependent on the cyanide waste stream flow volume. Another
disadvantage is that oxidation of organic compounds using chlorine has the
potential to form trihalomethanes.

Ozone Oxidation. Another less common cyanide treatment method is
ozone oxidation. Ozone gas is bubbled through a wastewater solution
containing cyanide. A portion of the ozone in the gas phase is transferred
to the liquid where it reacts with cyanide, converting it to cyanate.
Additional ozone reacts with the cyanate for complete conversion to
nitrogen gas, ammonia, and bicarbonate as shown by the reaction below:
— ->CNO-
(8-14)
3CNCT + 203 + 20H- + 2H2O — > 3HC(V + NH3 + N2 + 2O2 (8- 1 5)

The reaction rate is limited by mass-transfer of ozone to the liquid, the
cyanide concentration, and temperature (Reference 8-13). Ozone is not
effective in treating metallocyanide complexes, such as ferrocyanide, unless
ultraviolet light is added to the reaction vessel.

One advantage of ozone over chlorine is the type of residuals formed.
Oxidation of organic compounds using chlorine has the potential to form
trihalomethanes, which are suspected carcinogens. Ozone oxidation of
organic compounds forms short chained organic acids, ketones, and
aldehydes instead. Equipment required for ozone oxidation of cyanides
includes an ozone generator, gas diffusion system, a mixed reaction tank,
and off-gas controls to prevent the release of unreacted ozone. The major
disadvantages of the ozone oxidation process are the operating costs and
the capital costs of the ozone generating and transfer equipment and off-
gas control system.

Oily Wastewater Treatment Technologies

Hot forming and cold rolling operation wastewaters contain high levels of O&G.
For hot forming operations, scale pits and roughing clarifiers fitted with oil skimmers remove
nonemulsified O&G from high-rate recycle systems. Section 8.1.1 discusses these technologies.
Oily wastewater generated by cold rolling operations contain some emulsified oils that require
chemical treatment prior to removal. The following describes technologies that can be used to
remove both emulsified and nonemulsified oils.
8-16

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                                              Section 8 - Technology Options
 Oil Removal by Gravity Flotation.  O&G present in iron and steel
 wastewater can either be emulsified or nonemulsified. The characteristics
 of emulsified oils vary widely, depending on the types of oils used in the
 process.  If wastewater contains emulsified oils, chemical treatment is,
 required to separate the oils from solution prior to other treatment steps.
 Oil skimming can be used for nonemulsified oil treatment. .The wastewater
 is discharged through a tank or basin of sufficient size and design to allow
 the oil to separate and rise to the surface.  At the surface, the oil is
 contained by the underflow baffles and skimmed.  Common separation
 devices that can be used for separation of nonemulsified oils include
 American Petroleum Institute (API) separators, disk, belt,  and rotating
 drum oil skimmers, and coalescers.

 Skimming is a simple method for separating floating oil from cleaning
 solutions. Skimming devices are typically mounted onto the side of a tank
 and operate on a continuous basis.  The disk skimmer consists of a
 vertically rotating disk (typically 12 to 24 inches in diameter) that is
 partially submerged into the liquid of a tank (typically to a depth of 4 to 12
 inches below the liquid  surface). The disk continuously revolves between
 spring loaded wiper blades that are located above the liquid surface. The
 adhesive characteristics of the floating oil cause the oil to adhere to the
 disk. The oil is removed from the disk as the disk surface passes through
 the wiper blades and is diverted to a run-off spout for collection.
 Maximum skimming rates are typically in the range of 2 to  10 gallons per
 hour of oil.' Belt and drum skimmers operate in a similar manner, with
 either a continuous belt  or drum rotating partially submerged in a tank. As
 the surface of the belt or drum emerge from the liquid, the oil that adheres
 to its surface is scraped  (drum) or squeezed (belt) off and diverted to a
 collection vessel.

 Coalescers are typically  designed as tanks containing a coalescing media
 that accelerates phase separation. Cleaning solution and oil are removed
 from the process tank by a suction skimmer and pumped to the coalescer.
 The media in the coalescers is a material such as polypropylene, ceramic, or
 glass which attracts oil in preference to water (i.e., oleophilic). The
 oil/cleaner mixture passes through the unit and the oil adheres to the
 coalescing media. The oil forms droplets that conglomerate and rise to the
 surface of the tank where the oil is removed by a skimming device or weir
 (Reference 8-14).

API Oil/Water Separators. The API oil/water separator is typically a
rectangular basin, designed with baffles to trap sediments and retain
floating oils, that can achieve 150-micron droplet oil removal as per API
standards/This separator is used for wastewater containing oil with heavy
solids content or when long retention times are required.  Standard
                      8-17

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                                             Section 8 -'Technology Options
configurations of these systems include surface oil skimmers, sloped
bottoms, and augers to remove collected sludge.

Oil Removal by Emulsion Breaking and Dissolved Air Flotation. If
wastewater contains emulsified oils, chemical treatment is required to
separate the oils from solution prior to other treatment steps. Chemical
treatment is used to break stable oil/water emulsions (oil dispersed in
water, stabilized by electrical charges and emulsifying agents).  A stable
emulsion will not separate without chemical treatment. Chemical emulsion
breaking is applicable to wastewater streams containing emulsified coolants
and lubricants.  This technology is also applicable to cleaning solutions that
contain emulsified oils.

The major equipment required for chemical emulsion breaking includes
reaction chambers with agitators, chemical storage tanks, chemical feed
systems, pumps, and piping. Factors to be considered for destroying
emulsions are type of chemicals, dosage and sequence of addition, pH,
mixing, heating requirements, and retention time. Chemicals (e.g.,
polymers, alum, ferric chloride, and organic emulsion breakers) destroy
emulsions by neutralizing repulsive charges between particles, precipitating
or salting out emulsifying agents, or weakening the interfacial film between
the oil and water so it is readily broken.  Reactive cations (e.g., H+, AT3,
Fe"1"3) and cationic polymers are particularly effective in destroying dilute
oil/water emulsions.  Once the charges have been neutralized or the
interfacial film broken, the small oil droplets and suspended solids either
adsorb on the surface of the floe that is formed or break out and float to
the top. Different types of emulsion-breaking chemicals are used for
different types of oils. If more than one chemical is required, the sequence
of addition can affect both breaking efficiency and chemical dosages.

Solid wastes generated by chemical emulsion breaking include surface oil
and oily sludge, which are usually contract hauled for disposal by a licensed
contractor. If the recovered oil has a sufficiently low percentage of water,
the oil may be burned for its fuel value or processed and reused.

Dissolved air flotation combined witii chemical emulsion breaking is an
effective method of oil removal. With dissolved air flotation, air is injected
into a fluid under pressure.  The amount of air that can dissolve in a fluid
increases with increasing pressure.  When the pressure is released, the air
comes out of solution as bubbles that attach to O&G particles, thus
"floating" the O&G to the surface.  There are two types of operational
modes for dissolved air flotation systems, full flow pressurization and
recycle pressurization. In full flow pressurization, all influent wastewater is
pressurized and injected with air. The wastewater then enters the flotation
unit where the pressure is relieved and bubbles form causing the O&G to
                      8-18

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                                              Section 8 - Technology Options
 rise to the surface.  In a recycle pressuriz'ation system, part of the clarified
 effluent is recycled back to the influent of the dissolved air flotation unit,
 then pressurized and supersaturated with air. The recycled effluent then
 flows through a pressure release valve to the flotation unit.

 Oil Removal by Ultrafiltration. Ultrafiltration is a pressure-driven
 membrane process that separates emulsified oils without the need for
 chemical emulsion breaking.  Using an applied pressure difference across a
 membrane, solvent and small solute species pass through the membrane
 and are collected as permeate while larger compounds are retained by the
 membrane and are recovered as concentrate.

 Ultrafiltration is used to remove materials ranging from 0.002 to 0.2-
 microns or molecular-weights from 500 to 1,000,000 (e.g. oil emulsion and
 colloidal silica) (Reference 8-15). Prefiltration of the Ultrafiltration influent
 is advisable to remove  large particles and free oil to prevent membrane
 damage and membrane fouling.- Many Ultrafiltration membranes are
 typically made of homogeneous polymer or copolymer material. The
 transmembrane pressure required for Ultrafiltration typically ranges
 between 15 to 200 pounds per square inch and is  dependant on membrane
 pore size.   -

 Ultrafiltration results in a concentrated oil phase that is 2 to 5 percent of
 the influent volume (Reference 8-8). Oily concentrates are typically
 contract hauled or incinerated and the permeate (water phase) can either be
 treated further to remove water soluble metals and organic constituents or
"be directly discharged,  depending on local and state requirements.

 The Ultrafiltration system includes a number of components such as pumps
 and feed vessels, piping or tubing, monitoring, and control units for
 temperature, pressure and flow rate, process and cleaning tanks, and
 membranes. Membranes are specifically designed to handle various waste
 stream parameters, including temperature, pH, and chemical compatibility.
 Membranes can be purchased in several different configurations, including
 hollow fiber, tubular, flat plate, and spiral wound (Reference 8-15). The
 configuration selected for each application is dependent on the type of
 application. For example, tubular membranes are commonly used to
 separate suspended solids, whereas spiral wound membranes are used to
 separate oil from water. The spiral wound design Ultrafiltration membranes
 have a high membrane packing density and effective mass transfer
 characteristics.
                      8-19

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Section 8 - Technology Options
Metals Treatment Technologies

Dissolved and total metals are present in high-rate recycle system blowdown
wastewater from blast furnace, sintering, basic oxygen furnace (BOF), vacuum degassing, and
continuous casting operations at levels that require treatment before discharge. Pickling,
electroplating, and other steel finishing processes also generate wastewater containing dissolved
and total metals. If left untreated, metals can accumulate in the environment to levels which
become toxic to humans, terrestrial and aquatic organisms, and plants.

Chemical precipitation followed by gravity sedimentation is the treatment
technology most commonly used by the industry to remove dissolved and total metals from
wastewater. Hexavalent chromium reduction is used as a pretreatment step prior to hydroxide
precipitation for hexavalent-chromium-bearing wastewater generated in steel finishing. The
following discusses hexavalent chromium reduction, chemical precipitation, and solids removal
technologies, including gravity clarification and membrane separation.

• Hexavalent Chromium Reduction. Reduction is a chemical reaction in
which electrons are transferred from one chemical (the reducing agent) to
the chemical being reduced. Sulfur dioxide, sodium bisulfite, sodium
metabisulfite, and ferrous sulfate form strong reducing agents in water.
They are used at iron and steel finishing sites to reduce hexavalent
chromium to the trivalent form, which allows the metal to be removed from
solution by chemical precipitation. The reaction in these processes is
illustrated for the following sulfur dioxide reaction (reduction using other
reagents is chemically similar):
2H2CrO4 + 3SO2 — > Cr2(SO4)3
2H2O
(8-16)
An operating pH level between 2 and 3 is normal. At pH levels above 5,
the reduction rate is slow and oxidizing agents such as dissolved oxygen
and ferric iron interfere with the reduction process by consuming the
reducing agent. :

A typical treatment involves retention in a reaction tank for 45 minutes.
The reaction tank is equipped with pH and ORP controls. Sulfuric acid is
added to maintain a pH of approximately 2.0, and a reducing agent is
metered to the reaction tank to maintain the ORP at 250 to 300 millivolts.
The reaction tank is equipped with an impeller designed to provide
approximately one bath volume per minute.

Chemical reduction of hexavalent chromium is a proven technology that is
widely used at iron and steel finishing sites. Operation at ambient
conditions requires little energy and the process is well suited to automatic
control.
8-20

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                                              Section 8 - Technology Options
 Chemical Precipitation.  Chemical precipitation involves the removal of
 metallic contaminants from aqueous solutions by converting soluble, heavy
 metals to insoluble salts. The precipitated solids are then removed from
 solution by flocculation followed by sedimentation and/or filtration.
 Precipitation is caused by the addition of chemical reagents that adjust the
 pH of the water to the minimum solubility of the metal. The standard
 reagents include the following:

 —    Lime (calcium hydroxide);
 —    Caustic (sodium hydroxide);
 —:    Magnesium hydroxide;  .
 —    Soda ash (sodium carbonate);
 —    Trisodium phosphate;                   .
 —    Sodium sulfide; arid
 —    Ferrous sulfide.

 These reagents precipitate metals as hydroxides, carbonates, phosphates,
 and sulfides. Metals commonly removed from solution by precipitation
 include arsenic, barium,  cadmium, chromium, copper, lead, mercury,
 nickel, selenium, silver, thallium, and zinc.

 Figure 8-3 presents a flow diagram of the typical precipitation process for
 metals removal. A chemical precipitant is added to the metal containing
 water in a stirred reaction vessel. The dissolved metals are converted to an
 insoluble form by a chemical reaction between the soluble metal and the
 precipitant.  The suspended particles are then flocculated and either settled
 in the batch tank or passed to a membrane filter. Granular media filtration
 can be used to polish any suspended metal precipitates that do not settle in
 the reaction tank.

 Hydroxide precipitation is the prevalent type of chemical precipitation.
 Hydroxide precipitation normally involves the use of calcium hydroxide
 (lime), sodium hydroxide (caustic), or magnesium hydroxide as a
 precipitant to remove metals as insoluble metal hydroxides. The reaction is
 illustrated by the following equation for precipitation of a divalent metal
 using sodium hydroxide:
      2NaOH —> M(OH)2 + 2Na+
(8-17)
The effluent metals concentration attained by hydroxide precipitation is
dependent on the metals present, precipitant used, the reaction conditions,
especially pH, and the presence of other materials that may inhibit
precipitation. Effluent metals concentrations of less than 1 mg/L, and
sometimes less than 0.1 mg/L,.are achievable by hydroxide precipitation.
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                                             Section.8 - Technology Options
 The solubility of the metal is directly related to the pH of its environment.
 Many metals can form low solubility hydroxides in the pH range of 8.5 to
 11.5. However, several metallic compounds are amphoteric and exhibit a
. rigid point of minimum solubility. Any further addition of alkali can
 drastically increase the solubility of the compound.  Different metals have
 various minimum solubility points, which can pose a challenge when
 aqueous waste streams have highly variable metal compositions.  Figure
 8-4 shows the minimum solubilities of some common metals at various pH
 values.

 The solubility curves in Figure 8-4 indicate achieving the minimum
 solubility of all metals at a single operating pH would be difficult. At a pH
 at which the solubility of one metal hydroxide  may be minimized, the
 solubility of another may be relatively high. In the majority of cases, a pH
 between 9 and 11, selected on the basis of jar  tests or operating experience
 with the water, produces an acceptable effluent quality.  For a waste
 containing several metals, however, more than one precipitation stage with
 different pH control points may be required to remove all the metals of
 concern to the desired level.

 Removal of precipitated metals typically involves the addition of
 flocculating agents or polymers to destabilize  the hydrodynamic forces that
 hold the particle in suspension. For a continuous system, polymer is
 normally added in-line between the reaction tank and the fiocculation tank.
 In the fiocculation tank, the mixer is slowed to promote agglomeration of
 the particles until their density is greater than  water and they settle from
 solution in the clarifier.

 Clarification.  Gravity sedimentation to remove solids is a common
 method of clarification used hi recycle and end-of-pipe systems within the
 iron and steel industry. High-efficiency clarifiers are used for end-of-pipe
 treatment and ironmaking and integrated steelmaking recycle systems that
 do not require water quality equivalent to filtered effluent for reuse in
 manufacturing processes.  In continuous casting and hot forming recycle
 systems, it is good practice to pump contact cooling waters that collect in
 scale pits to a roughing clarifier for coarse solids removal prior to filtration,
 cooling, and recirculation.  To improve the performance of high-efficiency
 and roughing clarifiers, coagulants such as polymers are added. These
 coagulant aids enhance solids removal by aiding in the formation of larger,
 more readily settleable particles. Two important design parameters for
 roughing and high-efficiency clarifiers  include both the surface area of the
 clarifier and the detention time. Like high-efficiency clarifiers, roughing
 clarifiers are normally designed on the basis of a surface-loading rate     .
 expressed as gallons  per day per square foot of surface area (gal/day/ft2)
 and provide 90 to 150 minutes of detention based on the average flow rate
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                                             Section 8 - Technology Options
 (Reference 8-9). The surface-loading rate depends on the type of material
 to be separated. The table below shows the range of surface loading rates
 for high-efficiency clarifiers (Reference 8-11).
Suspension
Activated sludge solids
Alum floe
Iron floe
Lime floe
Untreated wastewater
Range gal/day/ft2
590 - 785
613 - 1,200
613 - 1,200
730 - 1,460
613-1,200
Peak Flow gal/day/ft2
1,460
1,200
1,200
1,460
1,200
 However, unlike more efficient clarifiers, roughing clarifiers are designed
 to remove large solids that rapidly settle. Therefore, surface loading rates
 may be three to four times those observed for high-efficiency clarifiers  .
, presented in the table. When the area of the tank has been established, the
 detention period in the tank is governed by the water depth. Open-top
 circular or rectangular shaped clarifiers are typically used for sedimentation
 of biological treatment solids from nitrification in the cokemaking industry.

 For sedimentation of iron-cyanide solids from the treatment of cokemaking
 wastewater, inclined tube or lamella clarifiers are commonly used.
 Depending on land availability and wastewater flow rates, open-top,
 inclined tube, or lamella clarifiers are used for sedimentation of metal
 hydroxides generated from treatment of ironmaking, steelmaking, and steel
 finishing wastewater.  The inclined tubes in the clarifier are oriented at
 angles varying between 45 and 60 degrees from the horizontal plane.
 Although the tube may be shaped in many forms, rectangular or square
 shapes are more common. Water enters the tank and solids settle to the
 tank bottom. As the water continues upward through the tubes, additional
 solids settle on the lower side of the tube. The clarified effluent continues
 up through the tube and passes over the weir.  The solids collect and
 agglomerate on the lower side of the tube and because of the tube
 inclination, slide downward through the tube.  They then drop back into the
 settling tank, where they collect on the bottom, and are scraped away into
 a sludge hopper before discharge to the thickener. The area covered by the
 lamella plates is typically 65  to 80 percent of the clarifier area required for
 a circular clarifier. Their design promotes laminar flow within the tubes,
 even when the water throughput is relatively high.

 Microflltration for Precipitated Metals Removal.  Chemical precipitation
 converts soluble metals into insoluble solids.  One alternative to
 conventional clarifiers for removal of the insoluble solids is microfiltration.
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Section 8 - Technology Options
• Microfiltration has been observed at facilities manufacturing metal products
and machinery and could potentially be used to remove solids from
chemical precipitation effluents at iron and steel facilities (Reference 8-8).
Microfiltration is a pressure-driven membrane process used to separate
solution components based on molecular size and shape. Using an applied
pressure difference across a membrane, solvent and small solute species
pass through the membrane and are collected as permeate while larger
compounds are. retained by the membrane and are recovered as
concentrate.

Microfiltration is used to remove materials ranging from 0.1 to 1.0-microns
• • (e.g., colloidal particles, heavy metal particulafes and their hydroxides).
Numerous microfiltration membranes are isotropic in morphology and are
typically made of homogeneous polymer material. Prefiltration is advisable
for suspended solids loads above 200 mg/1. The transmembrane pressure
required for microfiltration typically ranges between 3 to 50 pounds per
square inch (psi) and is dependant on membrane pore size.

Microfiltration results in a concentrated suspended solid slurry that is
typically discharged to dewatering equipment, such as a sludge thickener
and filter press. The permeate can either be treated further for pH
adjustment or be directly discharged, depending on local and state
requirements. The microfiltration system includes a number of components
such as pumps and feed vessels, piping or tubing, monitoring and control
units for temperature, pressure and flow rate, process and cleaning tanks,
and membranes. Membranes are specifically designed to handle various
waste stream parameters, including temperature, pH, and chemical
compatibility. Membranes can be purchased in several different
configurations, including hollow fiber, tubular, flat plate, and spiral wound.
The configuration selected for each application depends on the type of
application. For example, tubular membranes are commonly used to
separate suspended solids, whereas spiral wound membranes are used to
separate oils from water. The tubular design microfiltration membranes are
the least likely to foul with heavy suspended solids loadings and are easy to
clean.

Polishing Technologies

Polishing technologies are the final treatment steps designed to remove residual,
low concentrations of target pollutants from iron and steel wastewaters prior to discharge.
Examples of polishing technologies include multimedia filters following clarification to remove
small concentrations (less than 20 mg/L) of entrained suspended solids or carbon adsorption to
remove trace concentrations of organic pollutants remaining in cokemaking wastewater following
biological treatment. The following paragraphs describe each of these polishing technologies
observed at iron and steel facilities.
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                                              Section 8 - Technology Options
 Multimedia Filtration (mixed-media filtration). Multimedia filtration,
 one of the oldest and most widely applied types of filtration for the removal
. of suspended solids from aqueous liquid streams, utilizes a bed of granular
 particles as the filter medium. Granular media filters are used to remove
 suspended solids from cokemaking wastewater following biological
 treatment, from high-rate recycle cooling water and blowdown water from
 blast furnace ironmaking, sintering, continuous casting, and hot forming
 operations. The bed may consist of one type of medium (e.g., sand) of
 same particle size, or multiple particle size. Different types of media (e.g.,
 sand and gravel, sand and anthracite) with differing densities and different
 particle sizes, comprise the bed of a multimedia filter (Reference 8-9).
 Multimedia filters can be more efficient but more expensive and complex
 than single-media filters.  The filter bed is contained within a basin or tank
 •and is supported by an underdrain system, which allows the filtered liquid
 to be drawn off while retaining the filter medium in place. As suspended
 particle-laden water passes through the bed of the filter medium, particles
 are trapped on top of and within the bed. Once the pressure drop across
 the filter is large enough to impede flow, the filter is backwashed and the
 backwash water is typically sent to clarifiers or gravity thickeners.

 Granular Activated Carbon. Activated carbon adsorption has been
 observed as a polishing treatment step to remove residual concentrations of
 phenol and PAHs from cokemaking wastewater following biological
 treatment. It removes dissolved organic compounds from wastewater
 streams via adsorption.  Activated carbon can also be used as a final
 treatment step to remove dioxins and furans from sinter plant wastewater
 or phenols from blast furnace ironmaking wastewater. Adsorption is a
 natural process by which molecules of a dissolved compound collect on
 and adhere to the surface of an adsorbent solid. Adsorption occurs when .
 the. attractive forces at the carbon surface overcome the attractive forces of
 the liquid. Activated carbon is a well-suited medium for this process due to
 its large internal surface area, high attraction to adsorbates (pollutants to be
 removed), and hydrophobic nature (i.e., water will not occupy bonding
 sites and interfere with the adsorption of pollutants). Pollutants in the
 wastewater bond to the activated carbon grains until all the-surface bonding
 sites are occupied. When all bonding sites are occupied, the carbon is
 considered to be "spent." Spent carbon requires regeneration, which
 reduces adsorption capacity. After several regenerations,  the carbon is
 disposed of.

 A granular carbon system generally consist of vessels in which the carbon is
placed,  forming a "filter" bed. Vessels are .usually circular for pressure
 systems or rectangular for gravity flow systems. For wastewater treatment,  -
 activated carbon is packed into one or more filter beds or columns. Typical
treatment systems consist of multiple filter beds in series. Wastewater flows
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Section 8 - Technology Options
through the filter beds and is allowed to come in contact with all portions
of the activated carbon. The activated carbon in the upper portion of the
column is spent first (assuming operation is downflow mode), ,and
progressively lower regions of the column are spent as the adsorption zone
moves down the unit. When pollutant concentrations at the bottom of the
column begin to increase above acceptable levels, the entire column is
considered spent and must be replaced.

All vessels must be equipped with carbon removal and loading mechanisms
to allow for the removal of spent carbon and the addition of new material.
Vessels are backwashed periodically to remove the accumulated suspended
solids in the filter bed. Surface wash and air scour systems can also be used
as part of backwash cycle. The activated carbon systems may include
carbon storage vessels and thermal regeneration facilities.

Solids Handling Technologies

Solids are generated from a number of the proposed treatment technologies
including 1) biological treatment and cyanide precipitation of cpkemaking wastewater, 2) clarifiers
for treatment of high-rate recycle water in the ironmaking and steelmaking processes, including
backwash from multimedia filters, and 3) chemical precipitation and multimedia filtration of high-
rate recycle blowdown and steel finishing process waters for metals removal, including backwash
from multimedia filters. Dilute sludges from each of these processes are often concentrated by
gravity thickening prior to dewatering by a variety of presses and filters. Filter cake collected
from the dewatering equipment can be further processed by sludge dryers to removal additional
moisture. The following paragraphs describe the solids handling technologies that are used to
reduce the volume of treatment sludges generated by iron and steel facilities.

• Gravity Thickening. Gravity thickening is a physical liquid-solid
separation technology used to dewater wastewater treatment sludge.
Sludge is fed from a primary settling tank or clarifier to a thickening tank,
where gravity separates the supernatant from the sludge, increasing the
sludge density. The supernatant is returned to the primary settling tank.
The thickened sludge that collects on the bottom of the tank is pumped to
additional dewatering equipment or contract hauled for disposal.

Gravity thickeners are generally used in facilities where the sludge is to be
further dewatered by a mechanical device, such as a filter press. Increasing
the solids content in the thickener substantially reduces capital and
operating costs of the subsequent dewatering device and also reduces the
hauling cost. Typically, gravity thickeners achieve sludge with 8 to 10
percent solids by weight (Reference 8-17).

Rotary Vacuum Filtration of Sludge. The rotary vacuum precoat filter
consists of a perforated plate steel drum deck covered with a filter cloth. A
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                                              Section 8 - Technology Options
 diatomaceous earth precoat is used to prevent small suspended particles
 from passing through the filter and into the center of the drum where
 filtrate is removed. A knife blade is used to shave filter cake from the
 surface of the diatomaceous earth precoat filter, preventing the filter cake
 from reaching a thickness that would not adhere to the filter.  Rotary drum
 filters typically rotate between 0.25 and 6.5 revolutions per minute
 (RPMs), depending on the concentration of suspended solids in the
 wastewater (Reference 8-11). Filtrate that passes through the filter cake
 and diatomaceous earth precoat enters the center of the vacuum drum and
 is collected in horizontal pipes connected to a center drain shaft.  Solids
 collected from the rotary vacuum filter can be recycled to sintering
 operations to recover iron.

 Pressure Filtration of Sludge. The plate-and-frame filter press is
 commonly used for sludge dewatering in  the iron and steel industry.  A
 filter press consists of a series of parallel  plates pressed together by a
 hydraulic ram (older models may have a hand crank), with cavities between
 the plates. The filter press plates are covered with a filter cloth and are   -
 concave on each side to form cavities. At the start of a cycle, a hydraulic
 pump clamps the plates tightly together and a feed pump forces a sludge
 slurry into the cavities of the plates. The  liquid (filtrate) escapes through
 the filter cloth and grooves molded into the plates and is transported by the
 pressure of the feed pump (typically around 100 psi) to a discharge port.
 The solids are retained by the cloth and remain in the cavities.  This process
 continues until the cavities  are packed with sludge solids.  An air blow-
 down manifold is used on some units at the end of the filtration cycle to
 drain remaining liquid from the system, thereby improving sludge dryness
 and aiding in the release of the cake.  The pressure is then released and the
 plates are separated.

 The sludge solids or cake is loosened from the cavities and falls into a
 hopper or drum.  A plate filter press can produce a sludge cake with a
 dryness of approximately 25 to 40 percent solids for metal hydroxides
 precipitated with sodium hydroxide (caustic), and 35 to 60 percent solids
 for metal hydroxides precipitated with calcium hydroxide (lime). The
 solids content attained depends on the length of the drying cycle.  Filter
presses are available in a wide range of capacities (0.6 ft3 to 20 ft3).  A
typical operating cycle is from 4 to 8 hours, depending on the dewatering
 characteristics of the sludge. Units are usually sized based on one or two
 cycles per day (Reference 8-11).              ,

Belt Filtration for Sludge Dewatering. The belt pressure filter consists of
two continuous belts set one above the other.  Conditioned sludge is fed in
between the two belts. Three process zones exist. First, the sludge passes
through the drainage zone where dewatering is effected by the force of
                      8-27

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                                            Section 8 - Technology Options
gravity. Then, the sludge passes into the pressure zone where pressure is
applied to the sludge by means of rollers in contact with the top belt.
Finally, the sludge is passed to the shear zone where shear forces are used
to bring about the final dewatering. The dewatered sludge is then removed
by a scraper. Belt filtration can produce a sludge cake with a dryness of
approximately 25 to 30 percent solids (Reference 8-18).

Centrifugation of Sludge. A sludge dewatering device collects wet sludge
in a cone-shaped drum. The drum is rotated to generate centrifugal forces
to concentrate solids to the walls of the drum. These solids are continually
removed from the centrifuge by an auger, screw conveyor, or similar
device. Centrifugation dewaters sludges, reducing the volume and creating
a semi-solid cake. Centrifugation of sludge can typically achieve a sludge
of 20 to 35 percent solids (Reference 8-11).

Sludge Drying. Wastewater treatment sludges are often hauled off site to
disposal sites.  The transportation and disposal costs depend mostly on the
volume of sludge. Therefore, sludge dehydration equipment following
dewatering can further reduce the volume of the sludge and the overall
disposal cost. The solids content of the sludge dewatered on a filter press
is usually in the range of 25 to 60 percent.  Dehydration equipment can
produce a waste material with a solids content of approximately 90 percent
(Reference 8-11).

There are several design variations for sludge dehydration equipment.  A
commonly used type is a sludge drying unit that uses an auger or conveyor
system to move a thin layer of sludge through a drying region and
discharge it into a hopper.  Various heat sources are used for sludge
drying, including electric, electric infrared, steam, and gas.  Some
continuous units are designed such that the sludge cake discharge from a
filter press drops into the feed hopper of the dehydration unit, making the
overall dewatering process more automated. System capacities range from
less than 1 fWhr to more than 20 fWhr of feed. Sludge dehydration
equipment requires an air exhaust system due to the fumes generated
during drying. Energy requirements depend mostly on the water content of
the feed stock and the efficiency of a given unit.
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Section 8 -.Technology Options
8.2
Development of Technology Options
In developing the proposed regulation, EPA used a focused ralemaking approach,
conducting several data gathering and analysis activities concurrently and assessing only a limited
number of technology options. This is unlike the traditional approach where EPA conducts these
efforts consecutively and considers a wider range of wastewater management and treatment
technology options. This focused rulemaking approach is feasible for the Iron and Steel
regulation because the Agency has acquired a good understanding of the industry, its associated
pollutants, and the available control and treatment technologies from its prior rulemaking efforts.
EPA evaluated responses to industry surveys, data collected from Agency site visits and sampling
episodes, and technical literature to determine potential in-process and end-of-pipe treatment
technologies to form the basis of the proposed regulation. Of these technologies, EPA developed,
options incorporating pollutant control technologies that demonstrate effective past or current use
in the iron and steel industry, consistent effluent quality with a high degree of pollutant reduction
for pollutants of concern (supported by analytical data), and minimal non-water quality
environmental impacts. The Agency did not perform detailed analyses on pollution control
technologies that, after preliminary analyses, were determined to require significant capital and
operating and maintenance costs without substantial pollutant removals. Because of the focused
rulemaking approach, generally only one option is presented for each subcategory.

Extensive stakeholder involvement was also an important element of the focused
rulemaking process. EPA met with industry representatives, citizen and environmental groups,
and other stakeholders at various stages of the rulemaking process to discuss the preferred
technology options and to identify issues of concern. Input from stakeholders allowed EPA to
refine its proposed technology options. Stakeholders generally supported the chosen options
because they were in place and demonstrating satisfactory performance levels.

While EPA establishes effluent limitations guidelines and standards based on a
particular set of in-process and end-of-pipe treatment technology options, EPA does not require a
discharger to use these technologies. Rather, the technologies that may be used to treat
wastewater are left entirely to the discretion of the individual treatment plant operator, as long as
the numerical discharge limits are achieved, as required by Section §301(b) of the Clean Water
Act. ''••..
8.2.1
Technology Options by Subcategory
To establish the proposed limitations and standards, EPA reviewed data
corresponding to "state-of-the-art" pollution control technologies in the iron and steel industry.
Below is a summary of the technology options for the proposed effluent limitations guidelines and
standards in each subcategory. Tables 8-1 and 8-2 show the in-process and end-of-pipe treatment
technologies, respectively, that are applicable to the subcategories. The tables also identify
whether a technology was included in the development of technology options.
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Section 8 - Technology Options
Non-Recovery Cokemaking

Non-recovery cokemaking manufactures metallurgical coke by indirectly heating
(with combustible gases) high-grade bituminous coal in an enclosed oven chamber without
oxygen. Volatile gases are immediately combusted within and around the oven to provide the
heat required for coke production. Non-recovery cokemaking plants also maintain a slight
negative pressure in the coke ovens at all times, thereby eliminating door, refractories, and
charging .lid leakages associated with by-product recovery ovens. Unlike by-product recovery
cokemaldng, no process wastewater is generated at non-recovery plants. Plant service water is
used in coke quenching operations at non-recovery plants. However, runoff from quenching
operations is collected, and reused until evaporation. Accordingly, zero discharge of process
wastewater pollutants was the only technology option considered for this segment.

Cokemaking (By-Product Cokemaking)

As with non-recovery cokemaking, by-product cokemaking manufactures coke by
indirectly heating coal without oxygen; however, volatile gases are driven off and refined in a coal
chemical plant to manufacture products such as clean coke oven gas, tar, sulfur, ammonium
sulfate, and light oil. Waste ammonia liquor, wastewater generated from by-product recovery
processes, along with wastewater from WAPCs on coal oven preheating and charging operations,
are co-treated at an end-of-pipe wastewater treatment plant. Wastewater from WAPCs on
pushing operations is typically blown down to a coke quench station, combined with plant service
water or other sources, and used until evaporated on coke. Of the iron and steel subcategories,
by-product recovery cokemaking comprises the widest range of treatment technologies used by
the industry. Biological treatment, used by 13 of the 14 direct dischargers and 3 of the 8 indirect
dischargers; is the most common treatment technology. One direct discharger uses physical-
chemical treatment in lieu of biological treatment. Of the 16 sites using biological treatment, all
but one uses ammonia distillation prior to biological treatment. All five indirect dischargers
without biological treatment use an ammonia still. Other treatment technologies in use at mills in
North America during 1997 include alkaline chlorination, cyanide precipitation, and sand filtration
followed by granular activated carbon filtration. Table 8-3 lists the various wastewater treatment
technologies reported by direct and indirect discharge by-product recovery cokemaking facilities
in industry responses.

Figures 8-5 through 8-8 show the BAT technology options for the 14 direct
discharging by-product recovery cokemaking facilities throughout the United States. Figures 8-9
through 8-12 show the PSES options for the eight indirect discharging by-product recovery
cokemaking facilities. BAT-1 includes oil and tar removal, flow equalization prior to ammonia
stripping, free and fixed ammonia stripping, indirect cooling, flow equalization before biological
treatment, biological treatment, and sludge dewatering. BAT-2 equals BAT-1 with cyanide
precipitation and sludge dewatering prior to biological treatment. BAT-3 equals BAT-1 with
alkaline chlorination to remove residual cyanide and ammonia, following biological treatment.
BAT-4 equals BAT-3 with both multimedia filtration and granular activated carbon after alkaline
chlorination to remove any residual toxic organic compounds that may be present.
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Section 8 - Technology Options
EPA evaluated four PSES options for the indirect discharging by-product recovery
cokemaking facilities. For PSES, treatment is carried out to ensure that pollutants discharged by
the industry do not "pass through" POTWs to waters of the United States or interfere with
POTW operations or sludge disposal practices. PSES-1 includes tar removal, flow equalization,
and free and fixed ammonia stripping. PSES-2 is equal to PSES-1 with cyanide precipitation,
sludge dewatering, and multimedia filtration. PSES-3 is equivalent to BAT-1. PSES-4 is
equivalent to BAT-3. ' . -

, Ironmaking

The technology options evaluated for this subcategory represent treatment of
wastewaters associated with blast furnace and sintering operations, whether treated individually or
co-treated. All sites with sintering operations with dry air pollution controls reported zero
discharge of process wastewater in industry survey responses. Accordingly, EPA used zero
discharge based on dry air pollution controls as the only technology option for sintering
operations with dry air pollution control. Industry survey responses indicated that all. sites with
both sintering operations with WAPCs and blast furnace operations on site co-treat wastewater.
Table 8-4 lists the high-rate recycle equipment and wastewater treatment technologies used at 14
sites. (One site in the cost and loads analysis currently discharges to slag quench, as discussed in
Section 9, and was not included in the count of 14 sites). According to industry survey responses,
9 of these sites operated dedicated blast furnace treatment systems, 3 operated combined sintering
and blast furnace treatment systems, 1 site co-treated wastewaters from sintering, blast furnace,
and other iron and steel manufacturing processes, and 1 site operated a dedicated sinter plant
treatment system. Of the 14 sites with blast furnace ironmaking operations that discharge
wastewater to surface water or a POTW, 12 sites had Clean Water Act Section 301(g) variances
for ammonia and total phenol. Table 8-4 does not include the treatment technology used by five
blast furnace ironmaking sites that achieve zero discharge through slag quenching and one blast
furnace ironmaking site that achieves zero discharge through discharge to an evaporation pond.

Figures 8-13 and 8-14 present BAT and PSES technology options evaluated by the
Agency, respectively. BAT-1 for blast furnace ironmaking and sintering consists of high-rate
recycle using a clarifier for solids removal with sludge dewatering; a cooling tower to lower the
water temperature to acceptable levels' for reuse in blast furnace gas cleaning; blowdown
treatment with chemical precipitation for metals removal, alkaline chlorination for removal of .
cyanide, ammonia, and phenol; and multimedia filtration as a polishing step.

EPA is proposing one PSES options for the indirect discharging blast furnace
ironmaking and sintering facilities. The PSES-1 option is equivalent to BAT-1, but without
alkaline chlorination and multimedia filtration.

Integrated Steelmaking

The technology options evaluated for this subcategory represent treatment of
wastewaters associated with BOF steelmaking, vacuum degassing, and continuous casting
operations at integrated steelmaking facilities, whether treated individually or co-treated. Industry
survey responses indicate that co-treatment is a common practice, but depends largely on
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Section 8 - Technology Options
proximity of manufacturing processes. All sites with ladle metallurgy operations reported zero
discharge of process wastewater in industry survey responses. Accordingly, EPA used zero
discharge as the only technology option for ladle metallurgy operations. Table 8-5 lists the high-
rate recycle equipment and wastewater treatment technologies reported by the 20 integrated sites '
employing basic oxygen furnace steelmaking, vacuum degassing, and/or continuous casting and
one non-integrated facility that operates a basic oxygen furnace. . '

Figure 8-15 presents the BAT and PSES technology options evaluated by the
Agency. Wastewater from WAPCs for BOFs are treated in a high-volume classifier or equivalent
primary solids removal device .before discharge to a high-efficiency clarifier. Carbon dioxide
injection prior to clarification can be used for wet-open combustion and wet-suppressed
combustion BOF recycle systems to remove scale forming metal ions from wastewater before
reuse. Vacuum degassing wastewater is typically treated by a clarifier and cooling tower before
recirculation. Continuous casting wastewater from the spray water system is treated in a scale pit
with oil skimming to recover mill scale and remove O&G, a roughing clarifier for coarse solids
removal, filtered, and cooled before reuse. Slowdown from each of these high-rate recycle
systems can be treated in a dedicated chemical precipitation system or co-treated. The PSES-1
option is equivalent to the BAT-1 option.

Integrated and Stand-Alone Hot Forming

Equivalent technology options were evaluated for each segment of this
subcategory: Carbon and Alloy Steel and Stainless Steel. For both segments, high-rate recycle
and treatment of wastewater from contact water systems used for scale removal, roll cooling,
product cooling, flume flushing, and other miscellaneous sources (e.g., roll shops, basement
sumps) is common. Thirty of 38 surveyed sites from both segments have high-rate recycle
systems in place. Table 8-6 lists the high-rate recycle equipment and wastewater treatment
technologies reported by 38 integrated and stand-alone hot forming sites.

Figure 8-16 presents the BAT and PSES technology options evaluated by the
Agency for the Carbon and Alloy Steel and Stainless Steel Segments of this subcategory. BAT-1
includes high-rate recycle using a scale pit with oil slamming, a roughing clarifier with oil
skimming, sludge dewatering, a multimedia filter for polishing, and a cooling tower to lower the
water temperature to acceptable levels for reuse and treatment of blowdown with multimedia
filtration. PSES-1 is identical to BAT-1.

Non-Integrated Steelmaking and Hot Forming

Equivalent technology options were evaluated for each segment of this
subcategory: Carbon and Alloy Steel and Stainless Steel. For both segments, high-rate recycle
and treatment of wastewater from vacuum degassing, continuous casting, and hot forming
operations at non-integrated facilities are common. Forty four of 46 surveyed sites from both
segments reported having high-rate recycle systems in place for these operations. All sites with
electric arc furnaces (EAFs) and ladle metallurgy stations reported zero discharge of process
wastewater in industry survey responses. Accordingly, EPA used zero discharge as the only
technology option for EAF and ladle metallurgy operations. Table 8-7 lists the high-rate recycle
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Section 8 - Technology Options
equipment and wastewater treatment technologies reported used by the 46 non-integrated
steelmaking and hot forming sites.

Figure 8-17 shows the BAT and PSES options evaluated by the Agency for
non-integrated steelmaking and hot forming sites. This figure applies for both stainless and
carbon steel products. BAT-1 and PSES-1 for both segments include high-rate recycle of vacuum
degassing, continuous casting, and hot forming operations. Continuous casting wastewater from
the spray water system is treated in a scale pit with oil skimming to recover mill scale and remove
O&G. Effluent from the continuous casting scale pit is combined with untreated vacuum
• degassing wastewater in a roughing clarifier for coarse solids removal. A portion of the clarifier
effluent is recycled to the vacuum degassing process. The remainder of the clarifier effluent is
filtered, cooled, and either recirculated to continuous casting or discharged. Wastewater from hot
forming operations is treated in a separate scale pit with oil skimming to recover mill scale and
remove O&G. Scale pit effluent is treated in a roughing clarifier prior to multimedia filtration and
cooling. The Agency considered BAT-2 for stainless steel sites: BAT-1 plus metals precipitation
for the blowdown stream. A portion of the cooling tower effluent is recirculated to hot forming,
while the balance is discharged. Sludge from both casting and hot forming clarifiers is dewatered.
The Agency realizes that many sites may be configured such that the combined treatment of the
BAT and PSES model plants may not be possible. In such cases, separate treatment equipment
for manufacturing processes, as required, equivalent to the combined treatment system would
achieve model'treatment system effluent quality.' EPA considered these variables when costing
sites for treatment systems, as discussed in Section 9.

Steel Finishing

Separate technology options for this subcategory were evaluated for two
segments: Carbon and Alloy Steel and Stainless Steel.. The Carbon and Alloy Steel Segment
technology options treat wastewater from acid pickling (typically with hydrochloric or sulfuric
acids) and associated annealing operations, cold forming, alkaline cleaning, hot coating, and
electroplating operations. The Stainless Steel Segment technology options treat wastewater from
salt bath and electrolytic sodium sulfate (ESS) descaling, acid pickling (typically with sulfuric,
nitric, and nitric/hydrofluoric acids), annealing operations, cold forming, and alkaline cleaning.
For both segments, sites used in-process and end-of-pipe wastewater treatment. For in-process
wastewater treatment, sites used countercurrent rinsing, recycle of fume scrubber water, and
reuse of acid (acid regeneration, purification, recycle, or recovery).

Table 8-8 lists the in-process and end-of-pipe wastewater treatment technologies
reported by 86 water discharging carbon, alloy, and stainless steel finishing sites that provided
survey responses. Figures 8-18 and 8-19 show the BAT and PSES technology options for the
Carbon and Alloy Steel and Stainless .Steel Segments, respectively. As presented in the figures,
the technology options for both segments are identical, except that acid purification units have
been incorporated into BAT-1 and PSES-1 for sites pickling stainless steel with sulfuric and
nitric/hydrofluoric acid. Otherwise, both segments include the following in-process treatment
technologies: countercurrent rinsing and recycling of fume scrubber water. End-of-pipe
wastewater treatment for BAT-1 and PSES-1 for both segments consists of a diversion tank, oil
removal for segregated oily wastes, flow equalization, hexavalent chromium reduction for
8-33

-------
Section 8 - Technology Options
hexavalent-chromium-bearing streams, multiple-stage chemical precipitation for all waste streams,
gravity clarification, and sludge dewatering.

Other Operations (Direct Reduced Ironmaking)

EPA evaluated BPT options for direct reduced ironmaking (DRI) because the
Agency is setting limits for the first time for the conventional pollutants in this segment. The
treatment technologies that serve as the basis for the development of the proposed BPT include
high-rate recycle with solids removal using a classifier and clarifier, cooling, sludge dewatering,
and treatment of blowdown with multimedia filtration. Both sites operating in 1997 reported
using this high-rate recycle technology for wastewater generated from DRI WAPCs, with one site
reporting the use of multimedia filtration as blowdown treatment (see Table 8-9). Figure 8-20
shows the BPT technology option for DRI.

Other Operations (Forging)

EPA evaluated BPT options for forging because the Agency is setting limits for the
first time for the conventional pollutants in this segment. BPT for forging operations consists of
oil/water separation and high-rate recycle. Table 8-9 lists the technology reported by sites to treat
wastewater generated from forging contact water systems. Figure 8-21 shows the BPT
technology option for forging.

Other Operations (Briquetting)

EPA evaluated BPT options for briquetting because the Agency is setting limits for
the first time for the conventional pollutants in this segment. The four existing briquetting sites in
the United States reported zero discharge of process wastewater. Accordingly, the Agency used
zero discharge based on dry air pollution controls as the only technology option to develop the
basis for BPT limitations and standards for briquetting operations.
8.3

8-1.

8-2.

8-3.

8-4.
References

Association of Iron and Steel Engineers. The Making- Shaping, and Treating of
Steel: ISBN 0-930767-00-4; Pittsburgh, PA; 1985.

U.S. Environmental Protection Agency. Development Document for Effluent
Guidelines and Standards for the Nonferrous Metals Forming and Metal Powders
Point Source Category. EPA/440/1-86/019, Washington, D.C., September, 1986.

U.S. Environmental Protection Agency. Development Document for Effluent
Guidelines and Standards for the Iron and Steel Manufacturing Point Source
Category. EPA/440/1-82/024, Washington, D.C., May 1982.

Rituper, R., "High-Performance Effluent-Free Pickling Plants with Fluid Bed
Hydrochloric Acid Regeneration." Iron and Steel Engineer. November 1995.'
8-34

-------
                                                                Section 8 - Technology Options
 8-5.
 8-6.
 3-7.
 8-9.
 8-10.
 8-11.
8-12.
8-13.
8-14.
 3-15.
8-16.
8-17.
8-18.
  "Waste-Free Exhaust Air Cleaning In Stainless  Steel Pickling Plant." Metallurgical
  Plant And Technology International (Germany), vol. 16, no. 5, October 1993.

  Keyser, A. G., Kunkel, K. F., and Snedaker, L. A. "Impact of Rolling Emulsion
  Contaminants on Downstream Surface Quality." AISE Steel Technology, p. 43,
  September 1998.

  Freeman, H.M. Hazardous Waste Minimization. McGraw-Hill; Inc., New York,
"NY, 1990.

  U.S. Environmental Protection Agency. Development Document for the Proposed
  Effluent Limitations Guidelines and Standards for the Metal Products and
  Machinery Point Source Category. December 2000,  EPA-821-B-00-005.

  Perry's Chemical Engineers Handbook. Sixth Rditirm.  McGraw-Hill Inc., New
  York, NY, 1984, pp. 6-8, 12-15 to 12-17, and 25-57.

  Eckenfelder, W.W. Principals of Water Quality Management. CBI Publishing
  Company, Inc., Boston, MA, 1980.

  Metcalf and Eddy, Inc. Wastewater Engineering: Treatment. Disposal Reuse.
 TilirdJEdition.  McGraw-Hill Inc., New York, NY, 1991.

 Benefield, L; and J. Judkins.  Process Chemistry for Water and Wastewater
 Treatment. Prentice-Hall, Inc., Englewood Cliffs, NJ, 1982.

 Mauk, C.E. "Chemical Oxidation of Cyanide Species by Ozone with Irradiation
 from Ultraviolet Light". Trans. Society of Mining Engineers. Volume 260, pg
 279, 1976. .   •

 Great Lakes Environmental.  Equipment Guide for Oil Water Separators and
 Industrial Wastewater Treatment Equipment Systems. Addison. IL, July 1996.

 Freeman, H.M.  Standard Handbook of Hazardous Waste Treatment and Disposal.
 McGraw-Hill, Inc., New York, NY, 1989.

 LaGrega, M.D:, Buckingham, P., and Evans, J. Hazardous Waste Management
 McGraw-Hill, Inc., New York, NY, 1994, p.  192.

 Hoffland Environmental, Inc. HEI Sludge Thickener.
 http://www.hofFiandenv.com/Equipment_Line/Sludge_Thickener.htm.

 Hoftstra Engineering University. Web Page. Sludgenet.
 http://147.45.150.5/~mgelfa20/sendesin/pagel.htm.
                                        8-35

-------
Section 8 - Technology Options
Table 8-1
Iron and Steel In-Process Technologies
Technology
Applicable Subcategories
Comments
High-rate recycle of
wastewater
Ironmaking
Integrated Steelmaking
Integrated and Stand-Alone
Hot Forming
Non-Integrated Steelmaking
and Hot Forming
Other Operations
Has a significant impact on both the volume of water and the
pollutant loadings discharged from a number of iron and steel
operations. High-rate recycle is well demonstrated in each of
the applicable subcategories. Included in the technology
options. '
Countercurrent cascade
rinsing
Steel Finishing
Reduces the amount of water necessary for rinsing. Included
in the technology options.
Fume scrubber recycle
Steel Finishing
Recycle system can significantly reduce the volume of water
discharged from WAPC equipment. Included in the
technology options.
Hydrochloric acid
regeneration
Steel Finishing
Can reduce the amount of spent acid generated by the facility.
Also reduces the amount of neutralization treatment chemicals
needed and the.mass of chlorides discharged. However, this
process is energy-intensive and is only economically
achievable at certain sites. Not included hi the technology
options.
Effluent-free pickling
process with fluid bed
hydrochloric acid
regeneration
Steel Finishing
Would achieve zero discharge for hydrochloric acid pickling
operations. However, this process is energy-intensive and was
not included in the technology options. Also, the quantity of
rinse and scrubber water that can be used to cool off-gases
depends on the iron content of the pickle liquor, thereby
limiting applicability.
Sulfuric acid recovery
Steel Finishing
Can reduce the amount of spent acid generated by the facility.
Also reduces the amount of neutralization treatment chemicals
needed and the mass of sulfates discharged. However, this
process is energy-intensive and was not included in the
technology options.
Acid purification
Steel Finishing
Can reduce the amount of spent acid generated by the facility.
Also reduces the amount of neutralization treatment chemicals
needed and the mass of anions such as nitrate, sulfate and
fluoride discharged. Included in the technology options.
Nitric acid free
pickling
Steel Finishing
The Agency is currently considering regulating nitrates/nitrites
and is investigating the applicability of this technology. For
proposal, acid purification was included in the technology
options and this technology has not .been included.
Effluent-free exhaust
cleaning for stainless
steel pickling
Steel Finishing
Would eliminate wastewater generated from scrubbing of
exhaust gases from stainless steel pickling operations. Has .
significant capital and operating and maintenance costs as well
as possible cross-media impacts. Is not included in the
technology options. •
8-36

-------
                                                                            Section 8 - Technology Options
                                     Table 8-1 (Continued)
     Technology
 Applicable Subcategories
                       Comments
In-tank filtration to
extend the life of
concentrated baths
 Steel Finishing
Not applicable at all sites and not included in the technology
options.
Magnetic separation of
fines in cold rolling
solution
 Steel Finishing
Not included in the technology options.  Additional data would
need to be collected to perform an evaluation.
Ion exchange
Steel Finishing
Would not be economically achievable at high flow rates and
is therefore not applicable at all sites. Not included in the
technology options.
Evaporation with
condensate recovery
Cokemaking
Ironmaking
Integrated Steelmaking
Integrated and Stand-Alone
Hot Forming
Non-Integrated Steelmaking
and Hot Forming
Steel Finishing
Energy-intensive and can have cross-media impacts. Not
included in the technology options.
Best management
practices/plant
maintenance and good
housekeeping practices
Cokemaking
Ironmaking.
Integrated Steelmaking
Integrated and Stand-Alone
Hot Forming
Non-Integrated Steelmaking
and Hot Forming
Steel Finishing
The benefits of these practices are not quantifiable. Not
included in the technology options.
                                                8-37

-------
                                                 Section 8 - Technology Options
                           Table 8-2
Iron and Steel End-of-Pipe Treatment and Disposal Technologies
Technology
Applicable Subcategories
Comments
Flow Equalization
Equalization
Cokemaking
Ironmaking
Integrated Steelmaking
Integrated and Stand-Alone Hot Forming
Non-Integrated Steelmaking and Hot
Forming
Steel Finishing
Other Operations
Included in the technology optipns.
Cooling Technologies
Cooling towers
Shell-and-tube heat
exchangers
Cokemaking
Ironmaking
Integrated Steelmaking
Integrated and Stand-Alone Hot Forming
Non-Integrated Steelmaking and Hot
Forming .
Other Operations
Cokemaking
Included in the technology options.
Included in the technology options.
Coke Plant Treatment Technologies
Tar removal
Ammonia steam stripping
Biological nitrification
Denitrification
Cokemaking
Cokemaking
Cokemaking
Cokemaking
Demonstrated in the cokemaking
industry, improving the performance of
the free and fixed ammonia still.
Included in the options.
Applicable to wastewater containing high
concentrations of ammonia. Well
demonstrated in the cokemaking industry
and included hi the technology options.
Applicable to wastewater with high
concentrations of ammonia such as those
found after steam stripping of waste
ammonia liquor. Included in treatment
options.
Capital and operating costs are excessive
for removal of nitrate. Not included in
the options.
                              8-38

-------
                               Section 8 - Technology Options
Table 8-2 (Continued)
Technology
Applicable Subcategories
Comments
Cyanide Treatment Technologies •
Cyanide precipitation
Alkaline chlorination
Cyanide oxidation fry ozone
Cokemaking
Cokemaking
Ironmaking
Cokemaking
Ironmaking
Can remove cyanide from excess
• ammonia liquor. Demonstrated at
cokemaking facilities and included in the
technology options.
Included in the technology options.
The generation of ozone requires
expensive equipment and safety controls.
An equivalent technology (cyanide
destruction through alkaline chlorination)
was included in the technology options.
Not included in the technology options.
Oil Wastewater Treatment Technologies
Oil skimming
Chemical emulsion
breaking followed by
gravity oil/water separation
API oil/water separator
Chemical emulsion
breaking followed by
dissolved air flotation
Lfltrafiltration
Integrated and Stand- Alone Hot Forming
Non-Integrated Steelmaking and Hot
Forming
Steel Finishing
Steel Finishing
Steel Finishing
Other Operations .
Steel Finishing
Steel Finishing
Effective for non-emulsified oils.
Included in the technology options.
Included in the technology options.
Included in the technology options.
Energy-intensive relative to gravity
flotation and therefore not included in the
technology options
May be cost-prohibitive at high flow
rates. Not included in the technology
options.
         8-39

-------
                               Section 8 - Technology Options
Table 8-2 (Continued)
Technology
Applicable Subcategories
Comments
Metals Treatment Technologies
Chemical reduction of
hexavalent chromium
Chemical precipitation and
gravity sedimentation
Chemical precipitation and
microfiltration
Steel Finishing
Ironmakrng
Integrated Steelmaking
Integrated and Stand-Alone Hot Forming
Non-Integrated Steelmaking and Hot
Forming
Steel Finishing
Other Operations
Ironmakrng
Integrated Steelmaking
Integrated and Stand-Alone Hot Forming
Non-Integrated Steelmaking and Hot
Porming
Steel Finishing
Other Operations
Included in the technology options.
Included in the technology options.
May be cost-prohibitive at high flow
rates. Not included in the technology
options.
Sludge Dewatering Technologies
Gravity thickening
Vacuum filtration
Cokemaking
Ironmaking
Integrated Steelmaking
Integrated and Stand-Alone Hot Forming
Non-Integrated Steelmaking and Hot
Forming
Steel Finishing
Other Operations
Cokemaking
Ironmakrng
Integrated Steelmaking
Integrated and Stand-Alone Hot Forming
Non-Integrated Steelmaking and Hot
Forming
Steel Finishing
Other Operations
Included in the technology options.
Included in the technology options.
          8-40

-------
Section 8 - Technology Options
Table 8-2 (Continued)
Technology
Applicable Subcategories
I
Comments
Sludge Dewatering Technologies (cont.)
Pressure filtration
Cokemaking
Ironmaking
Integrated Steelmaking
Integrated and Stand-Alone Hot Forming
Non-Integrated Steelmaking and Hot
Forming
Steel Finishing
Other Operations
Included in the technology options.
Belt filtration
Cokemaking
Ironmaking
Integrated Steelmaking
Integrated and Stand-Alone Hot Forming
Non-Integrated Steelmaking and Hot
Forming
Steel Finishing
Other Operations
Demonstrated for dew'atering of
biological treatment sludge from
cokemaking. Included in the options.
Centrifugation
Cokemaking
Ironmaking
Integrated Steelmaking
Integrated and. Stand-Alone Hot Forming
Non-Integrated Steelmaking and Hot
Forming
Steel Finishing
Other Operations
Energy-intensive, and therefore not
included in the technology options.
Equivalent sludge dewatering
technologies (gravity thickening and
pressure filtration) are included in the
technology options.
Sludge drying
Cokemaking
Ironmaking
Integrated Steelmaking
Integrated and Stand-Alone Hot Forming
Non-Integrated Steelmaking and Hot
Forming
Steel Finishing
Other Operations
Energy-intensive, and therefore not
included in the technology options. May
be cost-effective for some sites in certain
situations.
8-41

-------
                                                                           Section 8 - Technology Options
                                    Table 8-2 (Continued)
       Technology
      Applicable Subcategories
                                                                               Comments
Polishing Technologies
Multimedia filtration
Cokemaking
Ironmaking
Integrated Steelmaking
Integrated and Stand-Alone Hot Forming
Non-Integrated Steelmaking and Hot
Forming
Steel Finishing
Other Operations
Usually used in conjunction with another
end-of-pipe technology (e.g., following
chemical precipitation) or used to
remove solids in the high-rate recycle
treatment system. Included in the
technology options. Also called mixed-
media filtration.
Sand filtration
Cokemaking
Ironmaking
Integrated Steelmaking
Integrated and Stand-Alone Hot Forming
Non-Integrated Steelmaking and Hot.'
Forming
Steel Finishing
Other Operations
Usually used in conjunction with another
end-of-pipe technology (e.g., following
•chemical precipitation). Similar to
multimedia filtration, which has been
included in the technology options. Not
included in the technology options.
Granular activated carbon
Cokemaking
Ironmaking
                                                                  Included in the technology options.
                                                 8-42

-------
                                                                  Section 8 - Technology Options
                                        Table 8-3

       Wastewater Treatment Technologies Reported by Industry Survey
             Respondents for By-Product Recovery Cokemaking Sites
Treatment Technology
Tar/oil removal
Flow equalization before ammonia still
Free and fixed ammonia still*
Cooling
Cyanide precipitation
Dephenolization
Alkaline chlorinationb
Flow equalization before biological treatment
or after ammonia still
Biological nitrification
Multimedia or sand filtration
Carbon adsorption
Sludge dewatering
Number of By-Products Recovery
Cokemaking Surveyed Sites Using the
Technology
Direct Discharge
(14 total sites)
13 ,
12
13
10
1 !
1
0
13
13
4
4
12
Indirect Discharge
(8 total sites)
3
4
8
1
2
1
0
5
3
1
0
2
"One indirect discharger operates an air stripping unit, instead of an ammonia still.
b Although this technology is not practiced by industry survey respondents, the Agency is aware of one site in North
America that practices alkaline chlorination.

Source: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Survey).
                                           8-43

-------
                                                                SectionS- Technology Options
                                       Table 8-4

           High-Rate Recycle and Blowdown Treatment Technologies
                  Reported by Industry Survey Respondents for
                  Blast Furnace Ironmaking and Sintering Sites
Treatment Technology
Number of Blast Furnace Ironmaking
and Sintering Surveyed Sites
Using the Technology
(14 total sites)'
High-Rate Recycle
Clarifier
Cooling tower
Sludge dewatering .
14
11
"12
Blowdown Treatment
Chemical precipitation
Alkaline chlorination
Multimedia filtration6
Granular activated carbon
10
1 '
4
1
1 Includes three sites that co-treat blast furnace and sintering wastewater and one site that treats sintering wastewater
only.
b Multimedia filtration of recycled flow or low-volume blowdown flow.
Note: Summary includes direct and indirect dischargers.

Source: U.S. EPA. U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Survey).
                                          8-44

-------
                                                                    Section 8 - Technology Options
                                         Table 8-5

     High-Rate Recycle and Slowdown Treatment Technologies Reported by
          Industry Survey Respondents for Integrated Steelmaking Sites
Treatment Technology
Number of Integrated Steelmaking
Surveyed Sites Using the Technology
(21 total sites)3
High-Rate Recycle
Classifier*"
Scale pif
CO2 injection
Clarifier
Cooling towerd
Sludge dewatering . . ,
12
20
. 5
.19
19
13
Blowdown Treatment
Chemical precipitation ,
Multimedia filtration6
: , 7
18
"One site is a non-integrated mill with a EOF.
bCIassifier used for EOF wastewater only except for one site that uses for continuous casting wastewater.
°Scale pit for continuous caster wastewater only.
^Cooling tower used for vacuum degassing and continuous caster wastewater.
'Multimedia filtration of recycled flow or low-volume blowdown flow.  • •                    '
Note: Summary includes direct and indirect dischargers and excludes zero discharge treatment systems.

Source: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Survey).
                                            8-45

-------
                                                            . Section 8 - Technology Options
                                     Table 8-6

           High-Rate Recycle and Slowdown Treatment Technologies
                 Reported by Industry Survey Respondents for
                 Integrated and Stand-Alone Hot Forming Sites
Treatment Technology
Number of Integrated and Stand-Alone
Hot Forming Surveyed Sites Using the
Technology
Direct Discharge
(32 total sites)
Indirect Discharge
(6 total sites)
High-Rate Recycle
Scale pit
Clarifier
Sludge dewatering
Cooling tower
25
15
12
20
3
4
i ;
4
Slowdown Treatment
Chemical precipitation
Multimedia filtration3
2
10
0
1
Once-Through Treatment"
Scale pit
Clarifier
Sludge dewatering
Multimedia filtration
7 '
0
0
0
1
0
0
0
"Multimedia filtration of recycled flow or low-volume blowdown flow.
bOnce-through treatment applies to eight sites.

Source: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Survey).
                                       8-46

-------
                                                                Section 8 - Technology Options
                                       Table 8-7

            High-Rate Recycle and Slowdown Treatment Technologies
                   Reported by Industry Survey Respondents for
                Non-Integrated Steelmaking and Hot Forming Sites
Treatment Technology
Number of Non-Integrated Steelmaking and Hot
Forming Surveyed Sites Using the Technology
Direct
Discharge
(33 total sites)
Indirect
Discharge
(11 total sites)
Direct &
Indirect
Discharge
(2 sites)
High-Rate Recycle
Scale Pit with oil skimming
Clarifier '
Cooling tower3
29.
17
'24
10
3
9
2
2
.2
Slowdown Treatment
Chemical precipitation
Multimedia filtration15
7
25
1
4
1
2
Once-Through Treatment0
Scale pit
Clarifier
Cooling Tower
2
0
0
0
0
0



"Cooling tower used for vacuum degassing and/or continuous casting wastewater.
""Multimedia filtration of recycled flow or low-volume blowdown flow.
cOnce-through treatment only applies to two sites, both direct dischargers.

Source: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Survey).
                                         8-47

-------
                                                                    Section 8 - Technology Options
                                         Table 8-8

 In-Process and End-of-Pipe Wastewater Treatment Technologies Reported by
               Industry Survey Respondents for Steel Finishing Sites
Treatment Technology
Number of Steel Finishing
Sites Surveyed Using the Technology
Direct Discharge
(57 total sites)
Indirect Discharge
(32 total sites)
In-Process Treatment
Countercurrent rinsing
Recycle of fume scrubber water
Acid purification and recycle3
14
33
7
10
14
5
End-of-Pipe Treatment
Oil removal11
Flow equalization
Hexavalent chromium reduction0
Chemical precipitation
Gravity sedimentation/clarification
Sludge dewatering
25
34
23
54
54
49
9
,19
5
20
17
18
"Applies to sites with sulfuric acid and nitric/hydrofluoric acid baths for stainless products.
bOil removal technologies in place were primarily oil water separators and oil skimming; however, one site used
ultrafiltration.
'Applies to sites with hexavalent-chromium-bearing wastewater.
Note: 47 sites reported the use of fume scrubbers.

Source: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Survey).
                                            8-48

-------
                                                            Section 8 - Technology Options
                                    Table 8-9

     High-Rate Recycle Equipment and Blowdown Wastewater Treatment
          Technologies Reported by Industry Survey Respondents for
                 Direct Reduced Ironmaking and Forging Sites
Treatment Technology
DRI
Number of Sites Surveyed
Using the Technology
(2 sites)
High-Rate Recycle
Classifier and clarifier
Cooling Tower
2
2
Blowdown Treatment
Multimedia Filtration
FORGING
Oil Removal3
1
(7 sites)
7
"Oil removal may be used as high-rate recycle or blowdown treatment.
Note: Summary includes direct and indirect dischargers.

Source: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Survey).
                                       8-49

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                                               Section 9 - Incremental Investment 'and Operating and
                                              	Maintenance Costs for Proposed Regulation
                                      SECTION 9

  INCREMENTAL INVESTMENT AND OPERATING AND MAINTENANCE COSTS
                           FOR PROPOSED REGULATION

              This section presents EPA's estimates of incremental investment costs and
incremental operating and maintenance costs for the industry to comply with each regulatory
option considered for the proposed rule.  EPA estimated the compliance costs for each
technology option to determine potential economic impacts on the industry and to weigh these
costs against the effluent reduction benefits resulting from the proposed technology option. All
estimates are based on data collected for the-calendar year 1997.  Section 10 presents Agency
estimates of annual pollutant loadings and removals for each technology option. The Agency is
reporting estimates of potential economic impacts associated with the total estimated annualized
costs of the proposed regulation separately (Reference 9-1).

             . Section 9.1 describes EPA's methodology to estimate costs to achieve the effluent
quality for each technology option in each subcategory (Section 8 discusses these options).
Section 9.2 summarizes the results of the cost analyses, by subcategory, for each technology.
option evaluated.
9,1
Methodology
             EPA developed site-specific cost estimates using data collected from industry
survey responses and Agency site visits and sampling episodes. Section 3 provides more
information on Agency data collection efforts. EPA also solicited data from vendors of various
wastewater treatment technologies, obtained data collected by state agencies, surveyed the
technical literature, and enlisted the services of a design and engineering firm, that has installed
wastewater treatment equipment hi the iron and steel industry.

             As discussed in Section 8, the Agency developed technology options for each iron
and steel subcategory.  EPA established a pollution control performance standard for each
technology option based on the following components:

             •      Effluent concentrations.  EPA identified sites with treatment technologies
                    representing each technology option and then evaluated these data to
                    identify sites with the best wastewater treatment performance. The Agency
                    evaluated long-term average effluent concentrations from the analytical
                    data from sites with the best wastewater treatment performance to develop
                    model effluent concentrations. Using this same dataset, EPA calculated
                    long-term averages and variability factors for the development of
                    limitations (see Section 12). For each technology option, EPA compared
                    the model effluent concentrations with effluent concentrations provided by
                    each site to assess wastewater treatment performance.
                                          9-1
-------
                                                Section 9 - Incremental Investment and Operating and
                                               	Maintenance Costs for Proposed Regulation
              •      Technology in place. EPA considered the in-process controls and end-of-
                     pipe treatment units comprising each technology option as model pollution
                     control technologies. EPA evaluated industry survey responses to
                     determine wastewater treatment technologies used at sites.  The Agency
                     compared model treatment with technology in place at sites to measure
                     wastewater treatment performance. For some survey respondents,
                     available analytical data for outfalls contained substantial amounts of
                     noncontact cooling water or nonprocess wastewater. In these cases, the
                     Agency used technology-in-place solely to assess wastewater treatment
                     performance. Tables 8-3 through 8-9 in Section 8 summarize the results of
       •  •            the technology in place analysis for each iron and steel  subcategory.

              •      Production-normalized flow rates (PNFs).  The Agency developed model
                     PNFs representing appropriate process water management and water
                     conservation practices for each  technology option, with emphasis on high-
                     rate recycle. When developing model PNFs, the Agency took into account
                     the nature of subcategory process operations, the rates  at which water was
                     applied to processes, recirculating process water quality requirements, and
                     good water management-practices.  For more information on the
                     development of model PNFs, refer to Section 7. For each technology
                     option, the model PNFs were compared with PNFs calculated from
                     industry survey responses to assess water management  practices at sites.

              The Agency analyzed these components of pollution control performance to judge
whether wastewater treatment units, entire treatment systems, or modifications in operating
practices would be necessary for individual sites to achieve model effluent concentrations and
PNFs with a particular technology option. If EPA determined that a site exceeded model effluent
concentrations or PNFs, the Agency compared the technology in place at the site with the model
treatment system of the technology option. EPA then determined the amount  of investment;
operating and maintenance, and/or one-time costs for those equipment items, water management
practices, or operating and maintenance practices that were not consistent with the model
treatment systems.  There are many possible combinations and variations of the treatment system
components of the technology options considered that sites can use to achieve the proposed
limitations and standards. Not all sites would be required to install all of the treatment system
components to achieve model effluent concentrations and PNFs. For the purposes of preparing
these cost estimates, EPA assumed that sites not achieving  the model effluent concentrations and
PNFs would install treatment identical to the corresponding technology option.

             EPA developed a computerized design and cost model to estimate costs using the
methodology described above. Sections 9.1.1, 9.1.2, and 9.1.3 describe how EPA developed cost
equations for use in the cost model to estimate investment,  operating and maintenance, and one-
time costs associated with various treatment technologies, respectively. For certain hot forming,
continuous casting, and blast furnace operations lacking high-rate recycle systems, EPA
                                          9-2
-------
                                                Section 9 - Incremental Investment and Operating and
                                               	Maintenance Costs for Proposed Regulation
developed cost estimates on a site-specific basis independent of the cost models noted above (see
Section 9.1.1).

              EPA estimated costs for the iron and steel industry, for the base year 1997. The
Agency included sites that operated during the 1997 calendar year in the cost analysis if they met
the following criteria:

            .  •      If a site operated at least one day during the 1997 calendar year; and
              «      If a site (or operation) shut down after 1997.

If a site (or operation) commenced operations after 1997, EPA did not include the site (or
operation).

              For some sites, 1997 data did not represent normal operating conditions; for those
sites, EPA used data from alternate years.  Several sites operated only part of 1997 because of
strikes, shut downs, or start-ups.  For these sites, EPA used production, analytical, and flow rate
data from years that the sites indicated reflected normal operations. If sites installed or
significantly altered wastewater treatment systems either during or after 1997, EPA used the data
that represented the most  current wastewater treatment configuration.

              EPA excluded from the cost analysis sites reporting zero discharge of wastewater.
The Agency assumed that these sites can: continue to operate in this manner and will therefore
achieve model effluent concentrations and PNFs.                        '
9.1.1
Investment Costs
              For each wastewater treatment facility in each subcategory, EPA determined the
equipment items required to achieve the model effluent concentrations and PNFs following the
methodology described in Section 9.1.  Agency investment cost estimates include costs for the
following components:

              •      Equipment: Purchased equipment items, including freight;

              •      Installation: Mechanical equipment installation, piping installation,
                    civil/structural, work (site preparation and grading, construction of
                    equipment foundations and structural supports), costs for materials and
                    labor to construct buildings or enclosed shelters, and electrical and process
                    control instrumentation;

              •      Indirect costs: Costs for temporary facilities during construction and
                    installation, spare parts, engineering procurement and contract
                    management, commissioning and start-up, and labor costs for site
                    personnel to oversee equipment installation (owner team costs); and
                                          9-3
-------
                                               Section 9 - Incremental Investment and Operating and
                                               ^_	Maintenance Costs for Proposed Regulation
                    Contingency:  Additional costs included in estimates to account for
                    unforeseen items in vendor and/or contractor estimates.
below:
             The Agency developed investment cost estimates using data sources discussed
                    Vendor and Capital Cost Survey Data.  The Agency developed cost
                    estimates for purchased equipment and ancillary equipment (pumps, piping,
                    sumps, etc.) for various sizes of technology option components using data
                    from capital cost survey responses and vendor quotes.

                    Engineering and Design Firm.  EPA used a design and engineering firm
                    for cost factors to estimate costs associated with the following: shipping of
                    equipment, labor for mechanical equipment installation, site preparation
                    and grading, equipment foundations and structural support, buildings to
                    house treatment equipment and provide enclosed shelter, purchase and
                    installation of piping, and electrical and process control instrumentation.
                    Table 9-1 lists the cost factors used to estimate installed costs of individual
                    treatment units.  These cost factors are based on an evaluation of past
                    project costs and budgetary estimates for wastewater treatment
                    installations in the iron and steel industry. The Agency estimated the
                    investment costs of treatment units for various design flow rates by
                    multiplying the purchased equipment cost by approximately 3.5.  EPA then
                    plotted the investment cost versus the design flow rate to develop cost
                    equations for use hi the computerized cost model. The Agency assumed a
                    linear relationship between investment costs and flow rates, where the
                    range of flows was relatively low. For treatment units that were costed
                    across a wide range of flow rates, EPA extrapolated separate lines for
                    incremental flow ranges. Otherwise, the Agency used the median cost per
                    gallon per minute to estimate investment  costs. A detailed summary of the
                    individual treatment units is provided in the Iron and Steel Administrative
                    Record.

                    EPA also used an engineering and design firm to estimate investment costs
                    for design flow rates spanning the range of actual industry flow rates for
                    the following treatment systems:

                    —    Granular activated carbon filtration of cokemaking wastewater
                          (component of BAT-4, By-Product Cokemaking Segment);

                    —    Alkaline chlorination of cokemaking wastewater (component of
                          BAT-3 and PSES-4, By-Product Cokemaking Segment);
                                          9-4
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                                               Section 9 - Incremental Investment and Operating and
                                                      Maintenance Costs for Proposed Regulation
                    —     Metals precipitation of blast furnace and sintering wastewater
                           (component of BAT-1 and PSES-1, Ironmaking Subcategory);

                    —     Alkaline chlorination of blast furnace and sintering wastewater
                           (component of BAT-1, Ironmaking Subcategory);

                    —     Metals precipitation of basic oxygen furnace steelmaking, vacuum
                           degassing, and continuous casting wastewater (component of
                           BAT-1 and PSES-1, Integrated Steelmaking Subcategory; and
                           BAT-2, Non-Integrated Steelmaking and Hot Forming
                           Subcategory); and                         .

                    —     Polishing of wastewater through multimedia filtration (component.
                           of BAT-4, By-Product Cokemaking Segment; BAT-1, Ironmaking
                           Subcategory; BAT-1 and PSES-1, Integrated and Stand-Alone Hot
                           Forming Subcategory; and BAT-1 and PSES-1, Non-Integrated
                           Steelmaking and Hot Forming Subcategory).

                    The engineering and design firm developed investment costs for these
                    treatment systems by determining equipment requirements and
                    specifications according to the specified design flow rates. The firm did
                    not use cost factors to estimate installation costs; instead, it provided line-
                    item estimates for mechanical equipment installation, piping installation,
                 .   equipment foundations (including site preparation and grading), equipment
                    structural support, buildings, and electrical and process control
                    instrumentation.  Figures 9-1 through 9-6 present these treatment systems
                    and Table 9-4 presents the assumptions used to develop these cost
                    estimates. Tables 9-5 through 9-16 present corresponding design
                    specifications and itemized cost sheets.  EPA then developed cost curves
                    and model equations as described above.

              Table 9-2 summarizes the investment cost equations used to estimate costs for
technology option components, the applicable subcategories and technology options, and the
sources of these estimates.

             EPA identified several sites with once-through wastewater treatment systems that
would need to invest in high-rate recycle systems to achieve model PNFs. EPA determined
equipment items necessary to achieve high-rate recycle and gathered site-specific information
from Agency surveys, site visits, and sampling episodes conducted during this rulemaking.
Because these systems are complex and not amenable to a standardized costing approach, the
Agency requested the engineering and design firm to estimate investment costs on a site-specific
basis using available site-specific information and data.
                                          9-5
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                                                Section 9 - Incremental Investment and Operating and
                                               	Maintenance Costs for Proposed Regulation
              When estimating costs for sites for entire high-rate recycle or wastewater
treatment systems, the Agency took into account land availability, when possible. For sites for
which EPA estimated costs for add-on technologies to existing wastewater treatment systems, the
Agency assumed that additional space for those technologies was available.

              EPA sized wastewater treatment components for each site according to flow rates
reported in the industry survey responses. When industry survey responses indicated that existing
treatment systems also treated nonprocess water such as ground water, storm water, or
noncontact cooling water, the Agency also considered those flows. For sites that EPA estimated
would install new blowdown treatment systems to achieve model treatment system effluent
quality, the Agency sized these blowdown treatment systems according to model PNFs (in gallons
per ton). Blowdown treatment systems were sized according to the flow rate determined by
multiplying a site's reported production rate by the model PNF.
9.1.2
Operating and Maintenance Costs
              EPA developed estimates of incremental operating and maintenance costs by
evaluating operating and maintenance cost data from the detailed and short surveys, supplemented
with data from other sources. EPA used specific data from survey responses whenever possible.
The Agency estimated operating and maintenance costs for the following items:

              •      Labor. Labor costs associated with general operating and maintenance of
                    treatment equipment. EPA used a labor rate of $29.67 per hour to convert
                    the labor requirements of each technology into annual costs which it
                    determined by the following.  The Monthly Labor Review, which is
                    published by the U.S. Bureau of Labor Statistics of the U.S. Department of
                    Labor (Reference 9-2), provided the base labor rate.  The Agency averaged
                    monthly values for 1997 for production labor in the blast furnace and basic
                    steel products to obtain  a base labor rate of approximately $20.90 per hour.
                    Forty-two percent of the base labor rate was then added for overhead (e.g.,
                    health insurance, vacation) to obtain the $29.67-per-hbur labor rate.
                    Industry survey responses indicated  labor rates between $13.00 and
                    $85.64.  The median labor rate reported by industry surveys was $28.95.
                    Data collected from the  industry survey, site visits, and other contacts with
                    the industry show that the great majority of wastewater treatment systems
                    are staffed on a 24-hour basis.  This  includes complex wastewater
                    treatment systems  for by-product recovery cokemaking, ironmaking, and
                    steelmaking operations;  hot forming operations with mechanical treatment
                    systems; and steel finishing operations where wastewater from multiple
                    processes are cotreated.  Consequently, the Agency used 24-hour staffing
                    as the baseline labor staffing complement, where reported. Incremental
                    labor costs associated with the assigned wastewater treatment system
                    upgrades were estimated and added to the baseline labor costs to assess
                  .  incremental cost impacts of the proposed regulation.
                                          9-6
-------
                            Section 9 - Incremental Investment'and Operating and
                           	Maintenance Costs for Proposed Regulation
 Maintenance.  Costs (excluding labor costs) associated with upkeep of
 equipment, repairs, operating supplies, royalties, and patents.  When these
 costs could not be estimated based on industry survey responses, the
 Agency assumed annual maintenance costs to be 6 percent of the
 investment cost of equipment (Reference 9-3).  Maintenance costs reported
 by industry ranged from 0.2 percent to 6.3 percent of investment costs.
 The median maintenance cost, as a percentage of investment costs,
 reported by industry was 1.1 percent.

 Chemicals. Costs for chemicals used for various wastewater technologies.
 EPA evaluated industry survey responses to determine chemical usage
 rates for well-operated treatment systems. When these costs could not be
 estimated based on industry survey responses, the Agency obtained
 chemical prices from the Chemical Marketing Reporter from December
 1997 (Reference 9-4).

 Energy. Energy requirements and.costs associated with operation of
 treatment equipment. In general, additional energy requirements were a
 result of new or upgraded high-rate recycle and treatment systems having
 electric motors to drive water pumps, chemical mixers, aeration equipment
 such as blowers and compressors, and cooling tower fans. When energy
 costs for equipment could not be estimated based on industry survey
 responses, EPA obtained electricity prices from the U.S. Department of
 Energy's Energy Information Administration's Average Industrial Electrical
 Costs in 1998. The average electrical cost to  industrial users between 1994
 and  1997 was $0.047 per kilowatt  hour (kWh) (Reference 9-5).  Section
 13 presents the estimated energy requirements for each technology option
 and a more detailed discussion of methodology. The median electrical cost
 reported in industry surveys was $0.04  per kWh.

Sludge/Residuals (Hazardous/Nonhazardous) Disposal. Cost of
 disposing of generated sludge. The Agency calculated incremental sludge
 generation rates associated with each technology option. Section 13
presents the methodology and results for this analysis.  After considering
 sludge generation rates, sludge disposal destinations, and sludge disposal
costs, the Agency determined that the incremental cost associated with
sludge disposal from these technology options is minimal. Therefore, EPA
has not included costs associated with sludge disposal in cost estimates for
the proposal, except for incremental costs associated with sludge disposal
of technology options PSES-3 and PSES-4 of the By-Product Segment of
the Cokemaking Subcategory. The Agency calculated site-specific sludge
disposal costs for these technology options because several sites would
generate and dispose of sludge associated with biological treatment, where
no sludge of this nature was previously generated at the site.
                      9-7
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                                               Section 9 - Incremental Investment and Operating and
                                               	Maintenance Costs for Proposed Regulation
              •      Sampling/Monitoring. Sampling and monitoring costs to determine
                    compliance with permits or performance of treatment systems. Because of
                    the operational complexity associated with alkaline chlorination, biological
                    treatment, and cyanide precipitation, the Agency estimated additional costs
                    to sample and monitor treatment performance. EPA estimated additional  ,
                    compliance sampling and monitoring costs for dioxins and furans, which
                    are not currently regulated under 40 CFR 420, for sinter plants because of
                    the significant costs associated with these analyses. These costs were
                    estimated to be $12,000 per year per site.  For other pollutants such as
                    ' thiocyanate, mercury, selenium, and fluoride that are not currently
                    regulated under 40 CFR 420, the Agency did not estimate incremental
                    sampling and monitoring costs because many of these pollutants are
                    currently sampled and monitored by sites because of water quality
                    standards.  Moreover, the Agency did not incorporate monitoring cost
                    savings realized by sites because of the elimination of naphthalene,
                    tetrachloroethylene, and benzene as a result of the proposed regulation.

              Table 9-3 presents the equations used to calculate individual equipment operating
and maintenance costs, along with the range over which the equatipns have been developed. The
table provides information sources for each of the cost equations in the footnotes. A more
detailed description of the development of these costs for each equipment item is provided in the
Iron and Steel Administrative Record.
9.1.3
OnerTime Costs
              When assessing costs for technology options consisting of biological treatment,
chemical precipitation, or multimedia filtration, EPA found that analytical data from some survey
responses showed that, despite the facilities having technology in place equivalent to a technology
option, their PNFs or effluent concentrations exceeded model values. In such cases, the Agency
evaluated treatment system design and operating parameters to determine additional investment
and operating and maintenance costs required to achieve the model PNFs and effluent quality. If
design and operating parameters were equivalent to model treatment operating parameters or
when these parameters were not provided in a site's survey response, the Agency allocated a
single-occurrence cost associated with hiring an outside consultant to upgrade wastewater
treatment system performance (e.g., improve site operation and maintenance to optimize
biological treatment system performance).  For chemical precipitation systems, the Agency also
assumed a 15 percent increase in operating and maintenance costs (primarily due to additional
chemical use).         '

              For technology options incorporating high-rate recycle, EPA evaluated
production-normalized flow rates and recycle technology in place to determine whether a site
required investment and operating and maintenance costs to achieve the model PNFs.  The
Agency found many instances where facilities have installed high-rate recycle systems, but the
discharge flow rates exceed the selected model discharge flow rates on a production-normalized
                                           9-8
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                                                Section 9 - Incremental Investment and Operating and
                                               	Maintenance Costs for Proposed Regulation
basis. If the system was able to recirculate the incremental flow necessary to achieve the model
PNF, EPA did not assign an investment cost for new facilities in the main treatment and recycle
circuit.  In cases where the increase in recycle rate was minimal with respect to the total
recirculating flow rate, EPA assigned a one-time cost for consultant and mill services to evaluate
the treatment and recycle system and to modify water management practices and operations to
achieve the model discharge flow rate.  If the treatment and recycle system lacked sufficient
hydraulic capacity to recirculate the incremental flow necessary to achieve the model discharge
flow rate, EPA sized and costed additional process water treatment and recycle facilities for the
main treatment and recycle circuit.  The Agency assumed that the one-time costs would include
relatively minor costs associated with controlling make-up water flow rates and eliminating
sources of extraneous water.  Incremental operation and maintenance costs were not assigned.
The Agency .assumed the increased costs  associated with modifying the recycle rate would be
minimal and offset by likely savings in process water chemical treatment.

             EPA assumed these one-time costs  for minimal improvements in wastewater
treatment performance or recycle rates to be $50,000. This estimate is based on a 10-week study,
comprising 400 hours of direct labor (160 hours of field work and 240 hours of office work) at a
labor rate of $100 per hour, approximately $5,000 for airfare, food, lodging, and other direct
costs (equipment rental, analytical costs, telephone costs), and $5,000 for miscellaneous expenses.
9.2
Results
             This section presents Agency national estimates of incremental investment and
operating and maintenance costs by technology option for each industry subcategory.  Agency
cost estimates for this rulemaking are factored estimates and are considered to be accurate within
±25 to ±30 percent (Reference 9-3).
9.2.1
Cokemaking Subcategory - By-Product Segment
             The Agency estimated the cost impacts of four BAT and PSES technology options
for 22 by-products recovery cokemaking sites in the United States that discharge wastewater. Of
these 22 sites, 14 are direct dischargers and 8 are indirect dischargers. The table below
summarizes the technology options evaluated.  Agency cost estimates for these options are
discussed in the subsections below and presented in Table 9-17.
                                           9-9
-------
                                                Section 9 - Incremental Investment and Operating and
                                               	Maintenance Costs for Proposed Regulation.
                       Technology Options for By-Product Segment
Treatment Unit
Tar/oil removal
Equalization/ammonia still feed tank
Free and fixed ammonia still
Temperature control
Cyanide precipitation with sludge
dewatering
Equalization tank
Biological treatment with secondary
clarification
Sludge dewatering
Alkaline chlorination (2-stage)
Multimedia filtration
Granular activated carbon
BAT-1
•
•
•
•

•
•
•



BAT-2
•
•
•
•
•
•
•
•



BAT-3
•
•
•
•

•
•
•
•


BAT-4
•
•
•
•

•
•
•
•
•
•
PSES-1
•
•
•








PSES-2
•
•
•

•




•

PSES-3
•
•
•
•

•
•
•



' PSES-4
•
•
•
•

•
•
•
•


              BAT-1

              EPA analyzed long-term average effluent data and wastewater treatment operating
parameters provided in industry survey responses from all 14 direct discharging sites. Based on
this analysis, EPA made the estimates discussed below.

              One site would install additional aeration capacity for biological treatment to
achieve the model treatment concentration for ammonia as nitrogen. The Agency believes that
the current operating hydraulic retention time (HRT) and solids retention time (SRT) at this site
are insufficient to consistently achieve model treatment concentrations. Consequently, the
Agency estimated investment costs for additional biological treatment basin capacity required to
achieve a 50-hour HRT and an SRT of 100 days, which are based on industry survey responses
from by-product cokemaking sites with model treatment and performance. EPA also estimates
that this site would incur a one-time cost to reduce the use of control water and would install an
equalization tank ahead of existing ammonia stills to minimize influent and effluent variability for
ammonia-N.

              The Agency also estimates that:

              •      One site would incur a one-time cost to reduce the use of control water
                    and install a heat exchanger prior to biological treatment, to ensure proper
                    temperature control;

              •      One site would incur a one-time cost to reduce the use of control water;
                    and
                                          9-10
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                                                Section 9 - Incremental Investment and Operating and
                                                	Maintenance Costs for Proposed Regulation
              •      Three sites have model treatment technology in place, but would incur a
                     one-time cost to improve the operation of existing biological treatment
                     systems.

              One site does not operate biological treatment following ammonia distillation.
 Instead, this site operates an ammonia still followed by a dephenolization system, sand filtration,
 and granular activated carbon filtration. The Agency assumed that the owner or operator of this
 site would replace the existing physical chemical treatment system with a biological treatment
 system to achieve ammonia as nitrogen and total phenol model treatment concentrations.
 Although this would require an investment of approximately $4 million, the Agency estimates that
 this site would realize annual operating and maintenance cost savings.

              The Agency estimates that the remaining seven sites have existing wastewater
 treatment systems that would achieve compliance with BAT-1 model effluent concentrations and
 PNFs. Therefore, EPA estimates that these sites would not incur any costs to comply with  "
 BAT-1.                       '               .           .

              BAT-2

              In addition to the costs associated with complying with BAT-1, EPA estimates
 that eight sites would install a cyanide precipitation system.  Effluent total cyanide concentrations
 reported in industry survey responses indicate that these sites would not achieve model effluent
 concentrations.   Six sites discharge wastewater with total cyanide concentrations below the
 model BAT-2 effluent concentrations and would not require this technology.

             BAT-3

             In addition to the costs associated with BAT-1, EPA estimates that all 14 direct
 discharge sites, would install alkaline chlorination systems to achieve BAT-3-model effluent
 concentrations and PNFs.

             BAT-4

             In addition to the costs associated with BAT-3, EPA estimates that 11 sites would
install granular activated carbon systems and nine sites would install multimedia filtration systems
to comply with BAT-4. Two sites use sand or multimedia filtration systems and two sites operate
sand filters followed by granular activated carbon filters. One site operates a granular activated
carbon filtration as a bypass system and has sufficient design capacity to treat its effluent.

             PSES-1

             Of the eight indirect discharging sites, three use biological treatment. Two sites
operate an ammonia still followed by cyanide precipitation; one of these sites also operates a sand
filtration system following cyanide precipitation. The remaining three sites operate an ammonia
                                          9-11
-------
                                               Section 9 - Incremental Investment and Operating and
                                               	Maintenance Costs for Proposed Regulation
still. The Agency estimates that two sites would incur a one-time cost to improve ammonia still
performance, and would increase annual operating and maintenance costs by 15 percent for
additional steam consumption. The Agency estimates that three sites with conventional activated
sludge systems would incur a one-time-cost to improve biological treatment system performance.

              PSES-2

              In addition to the costs associated with PSES-1, the Agency estimates that four
sites would install cyanide precipitation and multimedia filtration systems to comply with PSES-2.
Four sites can achieve PSES-2 model effluent concentrations and PNFs for ammonia, cyanide,
and benzo-a-pyrene.  Therefore,  EPA estimates that these sites would not incur any cost as a
result of complying with PSES-2.

              PSES-3

              The Agency estimates that five sites would install biological treatment systems to
comply with PSES-3. The Agency estimated investment costs of installing biological treatment
systems designed and operated based on a 50-hour HRT and an  SRT of 100 days, along with
associated equalization, clarification and sludge handling systems.  EPA also estimates that three
sites with existing biological treatment would incur a one-time cost to improve system
performance.          •

              PSES-4

              EPA estimates that, in addition to the costs incurred to comply with PSES-3, all
eight indirect discharging sites would install alkaline chlorination systems to achieve PSES-4
model effluent concentrations and PNFs.

              Non-Recovery Segment

              The Agency is aware of one non-recovery cokemaking plant that operated in 1997.
This site does not discharge process wastewater and would therefore not incur any additional
costs to achieve zero discharge.
9.2.2
Ironmaking Subcategory
             Of the 20 integrated sites hi the United States, 9 discharge blast furnace
wastewater only and three discharge blast furnace and sintering wastewater. The Agency is aware
of one stand-alone sinter plant that operated in 1997 and discharged wastewater.  Of the 14 sites
that discharge blast furnace or suiter plant wastewater, 9 operated dedicated blast furnace
treatment systems (one is an indirect discharging site); 3 operated combined sintering and blast
furnace treatment systems, 1 co-treated wastewater from sintering, blast furnace, and other iron
and steel manufacturing processes, and 1 operated a dedicated sinter plant treatment system. Of
the 14 sites with blast furnace ironmaking operations that discharge wastewater, 10 sites had
                                          9-12
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                                               Section 9 - Incremental Investment and Operating and
                                               	Maintenance Costs for Proposed Regulation
Clean Water Act section 301(g) variances for ammonia and phenol (see Section 15).  The Agency
assumed that sites with these variances in existing permits would reapply for and be granted
301(g) variances during permit renewal. Therefore, EPA did not estimate costs for alkaline
chlorination systems to achieve BAT-1 model treatment for sites with cyanide concentrations
below or equivalent to BAT-1 model treatment concentrations.  The table below  summarizes the
technology options for treatment of blast furnace and sintering wastewater, whether co-treated or
treated separately. Agency cost estimates for these options are discussed in the subsection below
and presented in Table 9-18.

                     Technology Options for Ironmaking Subcategory
Treatment Unit
Clarifier
Sludge dewatering
Cooling tower
(blast furnace only)
High-rate recycle
BAT-1
. •
•
•
•
PSES-1
•
•
•
•
Slowdown treatment
Metals precipitation
Alkaline chlorination
(2-stage)
Multimedia filtration
•
•
•
•


             BAT-l/PSES-1

             EPA evaluated industry survey responses from 13 direct discharging sites and one
indirect discharging site. The Agency estimates that two sites with existing once-through
treatment systems would install high-rate recycle systems to achieve model treatment. Based on
effluent concentrations reported in the survey responses for lead and zinc, the Agency assumed
one of these sites would also install a blowdown treatment metals precipitation system to achieve
model treatment concentrations.  To estimate the investment costs for these high-rate recycle
systems, the Agency used site knowledge and an engineering and design firm to estimate
investment costs (independent of the cost model) for each site.

             In addition to the wastewater treatment modifications above and after taking
Section 301 (g) variances into consideration, the Agency also estimates that:

             •      One site would install a blowdown treatment system comprising metals
                    precipitation, solids handling, alkaline chlorination, and multimedia
                                          9-13
-------
                            Section 9 - Incremental Investment and Operating and
                           	Maintenance Costs for Proposed Regulation
 filtration to achieve model effluent concentrations and incur a one-time
 cost to achieve the model PNF.

 One site would install a blowdown treatment system comprising alkaline
 chlorination and multimedia filtration system and incur a one-time cost to
 improve its existing metals precipitation system.  Based on chemical usage
 rates reported by this site, EPA estimates that annual operating and
 maintenance costs would increase by 15 percent.

 One site would install a multimedia filtration system to achieve model lead
 and zinc concentrations.

 One site would install a blowdown metals precipitation system and solids •
 handling system prior to an existing sand filtration system.

 One site would install a multimedia filtration and solids handling system
 and incur a one-time cost for flow reduction of blast furnace and sintering
 operations.

 One site would install a blowdown metals precipitation, solids handling,
 and multimedia filtration system to achieve model lead and zinc
 concentrations and incur a one-time cost to achieve the model PNF for
 discharge of sintering wastewater.

 One site would install a blowdown metals precipitation, solids handling,
 and multimedia filtration system to achieve model lead and zinc
 concentrations and incur a one-time cost to achieve the model PNF.

 One site would incur a one-time cost for to reduce flow and install a
 multimedia filtration system.

Two sites would incur a one-time cost to modify operating practices of
 existing metals precipitation systems.  Based on chemical usage rates
reported by these sites, EPA estimates that annual operating and
maintenance costs would increase by 15 percent.

Two sites would incur a one-time cost to reduce flow and improve
operation of its existing metals precipitation system.
                      9-14
-------
                                                Section 9 - Incremental Investment and Operating and
                                               _^	Maintenance Costs for Proposed Regulation
9.2.3
Integrated Steelmaking Subcategory
              According to industry survey responses, there are 20 integrated sites with basic  ,
oxygen furnaces (BOFs) and continuous casting operations.  Thirteen of these sites have vacuum
degassing operations.  The Agency is also aware of one non-integrated site that operates a EOF.
EPA estimated incremental costs for these 21 sites. The table below summarizes the technology
options for treatment of wastewater from BOF, vacuum degassing, and continuous casting
operations, whether co-treated or treated separately. Agency cost estimates for these options are
discussed in the subsection below and presented in Table 9-19,

               Technology Options for Integrated Steelmaking Subcategory
Treatment Unit
Classifier (BOF only)
Scale pit with oil skimming
(continuous casting only)
Clarifier
Sludge dewatering
Multimedia filtration3 (continuous casting
only)
Cooling tower (vacuum degassing and
continuous casting)
High-rate recycle
BAT-1
•
•
•
•
•
•
•
PSES-1
•
•
• .
•
•
•
•
Slowdown treatment
Metals precipitation
•
•
           a May be used in recycle circuit or as blowdown treatment.

              BAT-l/PSES-1

              The Agency estimates that 8 of the 21 sites would install blowdown metals,
precipitation systems to achieve BAT-l/PSES-1 model treatment concentrations and incur one-
time costs to achieve model PNFs. EPA estimates that two of these sites would invest additional
capital to reroute existing discharges to these add-on metals precipitation systems.  Based on site
visits and information provided in industry survey responses, the Agency estimates that
approximately 300 feet of piping would be required to reroute this wastewater at both sites and
estimates an additional $250,000 of investment costs at each site to purchase and install this
piping.                     •                                                   .

              The Agency is aware of one site that performs once-through treatment of
continuous casting wastewater. To estimate the investment costs to install a high-rate recycle
                                          9-15
-------
                                                Section 9 - Incremental Investment and Operating and
                                                       Maintenance Costs for Proposed Regulation
system at this site, the Agency used site knowledge and an engineering and design firm to estimate
investment costs independently of the cost model.

              In addition to the wastewater treatment modifications mentioned above, the
Agency also estimates that:

              •     One site would install a blowdown metals precipitation system to achieve
                    model treatment.

              •     One site would incur a one-time cost to improve the operation of its
                    existing metals precipitation system. Based on chemical usage rates
                    reported by this site, EPA estimates the site would increase annual
                    operating and maintenance costs by 15 percent.

              •     The Agency believes that one site would not incur any costs as a result of
                    complying with BAT-1 and that nine sites would achieve BAT-1 model
                    PNFs after incurring one-time costs.
0.2.4
Integrated and Stand-Alone Hot Forming Subcategory
              The Agency estimates that 44 carbon steel integrated and stand-alone hot forming
sites discharge wastewater to surface water in the United States and seven sites discharge
wastewater to POTWs. EPA estimates that the three integrated and stand-alone hot forming sites
that manufacture stainless steel products are indirect discharging sites. No survey respondent
with stainless steel hot forming operations reporte'd direct discharge of wastewater.

              The table below summarizes the technology options evaluated for the carbon and
alloy and stainless segments of this subcategory. Agency cost estimates for these options are
discussed in the subsections below and presented in Table 9-20.

                   Technology Options for Integrated and Stand-Alone
                                Hot Forming Subcategory -
Treatment Unit
Scale pit with oil skimming
Roughing clarifier with oil removal
Sludge dewatering
Multimedia filtration0
High-rate recycle
BAT-1
•
•
•
•
•
PSES-1
•
•
•
•
•
Blowdown treatment
Multimedia filtration1
•
•
                   * May be used in recycle circuit or as blowdown treatment.
                                          9-16
-------
                                               Section 9 - Incremental Investment and Operating and
                                              	Maintenance Costs for Proposed Regulation
              BAT-1 (Carbon and Alloy Segment)

              The Agency estimates that 12 sites would install high-rate recycle systems to
replace existing partial or once-through treatment systems. To estimate the investment costs to
install a high-rate recycle system for 10, of these sites, the Agency used site knowledge and an
engineering and design firm to estimate investment costs independently of the cost model. EPA
also estimated costs for one of these sites to segregate hot forming and finishing wastewater that
was co-treated in an end-of-pipe system. The Agency distributed costs associated with this
modification to the Integrated and Stand-Alone Hot Forming Subcategory and Steel Finishing
Subcategory according to the relative percentage of wastewater flow reported by this site from
both subcategories. The Agency used the cost model to estimate investment costs for the other
two sites with once-through treatment systems. EPA also estimates that one site would invest
approximately $2 million to, reroute hot forming wastewater discharge to an existing sand
filtration system.

              In addition to the wastewater treatment modifications mentioned above, the .
Agency also estimates that:

              •      Ten sites would incur one-time costs to achieve model PNFs;

              •      Two sites would  incur one-time costs to improve operation of existing
                    multimedia filtration systems.to achieve model effluent concentrations;

              »    .  Five sites would install blowdown multimedia filtration systems and incur
                    one-time costs to achieve model effluent concentrations and PNFs;

              «      Two sites would install blowdown filtration units to achieve model effluent
                    concentrations; and

              «      Twelve sites would not incur any costs to comply with BAT-1.

              The Agency estimates that six of the sites mentioned above would install
multimedia filtration systems  to treat flow rates below 50 gallons per minute (gpm).  Based on
vendor information obtained for small-scale multimedia filtration systems, the Agency estimates
an investment cost of $200,000 would be required to purchase and install these systems.

              PSES-1 (Carbon and Alloy Segment)

              Of the seven indirect discharging carbon steel integrated and stand-alone hot
forming sites, the Agency estimates that one site would incur a one-time cost to achieve the model
PNF.  EPA also estimates that two sites would install blowdown filtration systems to treat flow
rates less than 50 gpm and incur a one-time cost to achieve model treatment concentrations  and
that four sites would not incur any costs to comply with PSES-1.

                                         9-17
-------
                                                Section 9 - Incremental Investment and Operating and
                                                	Maintenance Costs for Proposed Regulation
              PSES-1 (Stainless Segment)

              Of the three indirect discharging stainless sites, the Agency estimates that one site
 would install a high-rate recycle system to replace an existing once-through system, and that two
 sites would incur a one-time cost to achieve the model PNF.
 9.2.5
Non-Integrated Steelmaking and Hot Forming Subcategory
              The Agency estimates that 39 carbon steel mini-mills discharge wastewater from
vacuum degassing, continuous casting, or hot forming operations, whether co-treated or treated
separately, to surface waters of the United States and 15 discharge wastewater from these
operations to POTWs.  The Agency also estimates that four stainless steel mini-mills discharge
wastewater from vacuum degassing, continuous casting, or hot forming operations, whether co-
treated or treated separately, to surface waters of the United States arid four discharge
wastewater from these operations to POTWs.

              The table below summarizes the technology options evaluated for the carbon and
alloy and stainless segments. Agency cost estimates for these options are discussed in the
subsections below and presented in Table 9-21.

          Technology Options for Non-Integrated  Steelmaking and Hot Forming
Treatment Unit
Scale pit with oil skimming (continuous
casting and hot forming only)
Clarifier
Sludge dewatering
Cooling tower
Multimedia filtration"
High-rate recycle
BAT-1
•
•
•
•
•
•
BAT-2
•
•
•
•
•
•
PSES-1
•
•
•
•
•
•
Blowdown treatment
Metals precipitation3-1"
Multimedia' filtration2

•
•
•

•
       "May be used in recycle circuit or as blowdown treatment.
       'Applies to Stainless Steel Segment only.                       •  ; .  .

              BAT-1 (Carbon and Alloy Segment)

              The Agency estimates that two sites would replace existing once-through
treatment systems with high-rate recycle systems and three sites would install blowdown
                                          9-18
-------
                                               Section 9 - Incremental Investment and Operating and
                                               	Maintenance Costs for Proposed Regulation
 multimedia filtration systems to treat flow rates below 50 gpm to achieve model treatment
 concentrations.  EPA estimates that nine sites would install blowdown multimedia filtration
 systems and incur a one-time cost to achieve model treatment; of these nine sites, seven would
 treat flow rates below 50 gpm.  The Agency believes that there are four mini-mills that would not
 incur any costs to comply with BAT-1. The Agency believes that 21 mini-mills would achieve
 model PNFs after incurring a one-time cost.       .

              PSES-1 (Carbon and Alloy Segment)

              The Agency estimates that two sites would install a blowdown multimedia
 filtration system to treat flow rates below 50 gpm to achieve model effluent concentrations, 10
 sites would install a blowdown multimedia filtration system to treat flow rates below 50 gpm and
 incur a one-time flow reduction cost, and three sites would incur a one-time cost to achieve model
 PNFs.

              BAT-1 (Stainless Segment)                                        .

              The Agency estimates that two sites would incur one-time costs to achieve model
 PNFs, one site would install a blowdown multimedia filtration system and incur a one-time cost to
 achieve model effluent concentrations and PNFs, and one site would not incur any costs to
 comply with BAT-1.

              BAT-2 (Stainless Segment)

              The  Agency estimated costs for metals precipitation but the demonstrated .
 technology showed the pollutant removals were insignificant, as discussed in Section 10.

              PSES-1 (Stainless Segment)

              The  Agency estimates mat four sites would incur a one-time cost to achieve model
PNFs.
9.2.6
Steel Finishing Subcategory
             The Agency estimates that 51 carbon steel and 18 stainless steel finishing mills
discharge wastewater to surface water in the United States and 31 carbon steel and 14 stainless
steel finishing mills discharge wastewater to POTWs.

             The table below summarizes the technology options evaluated for the carbon and
alloy and stainless segments. The Agency evaluated PNFs from manufacturing lines at each site
for comparison with model PNFs. For lines with PNFs within 25 percent of the model PNF, EPA
allocated a one-time cost to sites to achieve model PNFs. The Agency assumes relatively minor
costs are associated with controlling rinse water flow rates to achieve these flow reductions and
would be included in the one-time cost.  For manufacturing lines with PNFs greater than 25
                                         9-19
-------
                                                Section 9 - Incremental Investment and Operating and
                                               	Maintenance Costs for Proposed Regulation
percent, the Agency estimated costs to install countercurrent rinse tanks at $250,000 per line.
This estimate is based on installation of an additional 10,000-gallon rinse tank with associated
pumps and blowers for bath agitation. Also in this estimated cost, the Agency assumed lost line
revenue from downtime for two days for tank installation, at'an average of $448/ton of cold rolled
coil sheet steel based on a median production rate of 95 tons/day for all 'finishing sites (Reference
9-6). Furthermore, EPA did not assign, incremental operating and maintenance costs for
installation of countercurrent rinse tanks. The Agency assumed that operating and maintenance
costs incurred because of installation of these tanks would be minimal and offset by likely savings
in rinse water usage and process water chemical treatment. The Agency will pursue further data
gathering after-proposal to more accurately estimate costs associated with installation of an
additional rinse tank. Agency cost estimates for the evaluated technology options are discussed in
the subsections below and presented in Table 9-22.

                   Technology Options for Steel Finishing Subcategory
Treatment Unit | BAT-1
PSES-1
In-Process Controls
Countercurrent rinses
Recycle of fame scrubber water
Acid purification units
(stainless steel only)
•
•
•
•
•
•
Wastewater Treatment . '
Diversion tank
Oil removal
Hydraulic and waste loading
equalization
Hexavalent chromium reduction
Multiple-stage pH control for
metals precipitation
Clarification
Sludge dewatering
•
•
•
•
•
•
•
V
•
•
•
«/
•
•
              BAT-1 (Carbon and Alloy Segment)

              The Agency estimates that eight sites would incur a one-time flow reduction cost
for a single line to achieve model PNFs. Based on industry survey responses, six sites would
incur a one-time cost to optimize existing metals precipitation systems.  The Agency assumed a
15 percent increase in annual operating and maintenance costs for these sites.  EPA estimates that
                                          9-20
-------
                                                Section 9 - Incremental Investment and Operating and
                                                	Maintenance Costs for Proposed Regulation
 three sites would require wastewater treatment modifications and incur a one-time cost to achieve
 model effluent concentrations and PNFs.  One of these sites was costed to segregate hot forming
 and finishing wastewater that was co-treated in an end-of-pipe system. EPA distributed costs
 associated with this modification to the Integrated and Stand-Alone Hot Forming Subcategory
 and Steel Finishing Subcategory according to the relative percentage of wastewater flow reported
 by this site from both subcategories.

              In addition to the in-process control and wastewater treatment modifications
 mentioned above, the Agency also estimates that:

              «      Six sites would install countercurrent rinse tanks on a single line;

              •      Thirteen sites would install countercurrent rinse tanks and incur a one-time
                     cost to achieve model PNFs on multiple lines;

              •      Four sites would install  countercurrent rinse tanks on multiple lines and
                     incur a one-time cost and a 15 percent increase in annual operating and
                     maintenance costs to optimize existing metals precipitation systems; and

              •      Eleven sites would not incur any cost to comply with BAT-1.

              PSES-1 (Carbon and Alloy Segment)

              The Agency estimates that four sites would require wastewater treatment
modifications to achieve model treatment. EPA estimated costs for three of these sites to install
metals precipitation systems, clarifiers, and associated sludge handling systems and for the other
site was to install a clarifier.

              In addition to the wastewater treatment modifications mentioned above, the
Agency also estimates that:                                        .

              •       Six sites would incur a one-time cost to achieve model PNFs on a single
                     line;

              •    .   Two sites would, incur a 15 percent increase in annual operating and
                    maintenance costs to optimize existing metals precipitation systems;

              •      Two sites would install metals precipitation systems, clarifiers, and
                    associated sludge handling systems, install countercurrent rinse tanks, and
                    incur a one-time cost to achieve model PNFs;

              •      Three sites would install a countercurrent rinse tank on a single line;
                                          9-21
-------
                                                Section 9 - Incremental Investment and Operating and
                                                	Maintenance Costs for Proposed Regulation
              •      Two sites would install a countercurrent rinse tank on a single line, incur a
                     one-time cost to achieve model PNFs, and incur a 15 percent increase in
                     annual operating and maintenance costs to optimize existing metals
                     precipitation systems;

              •      Two sites would install countercurrent rinse tanks on multiple lines; and  •

              •      Ten sites would not incur costs to comply with PSES-1.

              BAT-1 (Stainless Segment)

              The Agency estimates that nine sites contract hauled or treated spent acid pickling
baths.  Of these nine sites, EPA assumed that seven would install a single acid purification unit
and countercurrent rinse tanks on multiple lines as a result of BAT-1 model effluent
concentrations and PNFs, while two would install multiple acid purification units and install
countercurrent rinse tanks on multiple lines.

              In addition to the in-process control modifications mentioned above, the Agency
also estimates that:

              •      Two sites would incur a one-time cost to achieve model PNF for a single
                     line;

              •      Three sites would install countercurrent rinse tanks on multiple lines and
                     incur a one-time cost to achieve model PNFs;

              •      Two sites would install countercurrent rinse tanks on multiple lines and
                     incur a one-time cost and a 15 percent increase in annual operating and
                     maintenance costs to optimize existing metals precipitation systems; and

              •      Two sites would not incur a cost to comply with BAT-1.

              PSES-1 (Stainless Segment)

              The Agency estimates that five sites contract hauled or treated spent acid pickling
baths, assuming that these sites would install acid purification units, to achieve model effluent
concentrations. Of these five sites, the Agency also estimates that two would incur a one-time
cost and a 15 percent increase in annual operating and maintenance costs to optimize existing
metals precipitation systems.

              In addition to the in-process control and wastewater treatment modifications
mentioned above, the Agency also estimates that:
                                           9-22
-------
                                                Section 9 - Incremental Investment and Operating and
                                               	Maintenance Costs for Proposed Regulation
                     Two sites would incur a one-time cost and a 15 percent increase in annual
                     operating and maintenance costs to optimize existing metals precipitation
                     systems;

                     One site would install countercurrent rinse tanks on a single line;

                     One site would install countercurrent rinse tanks on multiple lines, incur a
                     one-time cost to achieve model PNFs on multiple lines, and incur a 15
                     percent increase in annual operating and maintenance costs to optimize an
                     existing metals precipitation system; and
9.2.7
«      Five sites would not incur a cost to comply with PSES-1.

Other Operations Subcategory

Direct Reduced Ironmaking (DRI) Segment
              The table below presents the BPT technology option evaluated for this segment.
EPA is not discussing or presenting cost estimates because data aggregation or other masking
techniques are insufficient to protect confidential business information. The Agency evaluated   -
effluent total suspended solids concentrations reported by sites, PNFs, and technology in place to
determine appropriate costs to achieve model treatment.

                          Technology Options for DRI Segment
Treatment Unit
Classifier
Clarifier
Sludge dewatering
Cooling tower
High-rate recycle
BPT/PSES-1,
•
•
•
•
•
Slowdown treatment
Multimedia filtration
•
              Forging Segment

              Of the eight direct discharging forging operations and four indirect discharging
forging operations, the Agency estimates that six sites would incur a one-time cost to achieve
model PNFs;  EPA assigned a one-time cost of $20,000 for consultant and mill services to
evaluate how to modify contact water management practices to achieve the model PNF for
                                          9-23
-------
                                               Section 9 - Incremental Investment and Operating and
                                              	Maintenance Costs for Proposed Regulation
forging. Forging operations at iron and steel sites are small-scale operations that range in
production from 500 to 90,000 tons of steel per year. Sites estimated to incur a one-time cost
forge well below 20,000 tons of steel per year. Consequently, the Agency's estimate is based on
a short-term study, consisting of 150 hours of direct labor (50 hours of field work and 100 hours
of office work) at a labor rate of $100 per hour. The Agency also estimates approximately
$2,500 for airfare, food, lodging, and other direct costs (equipment rental, analytical costs,
telephone  costs) and $2,500 for miscellaneous expenses. Table 9-23 presents Agency cost
estimates for the BPT option.

                        Technology Options  for Forging Segment
9.3

9-1
9-2

9-3


9-4

9-5


9-6
Treatment Unit
High-rate recycle
BPT
•
Slowdown treatment
Oil/water separator
•
References

U.S. Environmental Protection Agency. Economic Analysis of the Proposed
Effluent Limitations Guidelines and Standards for the Iron and Steel
Manufacturing Point Source Category. EPA 821-B-00-009, Washington, B.C.,
December 2000.

U.S. Department of Labor, Monthly Labor Review.  Washington, D.C., 1997.

Perry, R. and Green, D. Perry's Chemical Engineer's Handbook. Sixth Edition.
McGraw-Hill, Inc., 1984.

Chemical Market Reporter.  Schnell Publishing Company, December 1997.

U.S. Department of Energy. Electric Power Annual 1998.  Volume I.
Washington, D.C., 1998.
U.S. Department of Commerce. Current Industrial Reports. Steel Mill Products
1997. MA33B, September 1998.
                                         9-24
-------
                                                   Section 9 - Incremental Investment and Operating and
                                                   	Maintenance Costs for Proposed Regulation
                                          Table 9-1
                     Cost Factors to Determine Investment Costs
Category
Direct costs'
Indirect costs
Item
Equipment cost
Freight
Installation labor
Site preparation
Equipment foundations and structural support
Buildings .
Piping
Electrical and process control
Subtotal
Temporary facilities (l%)b
Spare parts (1.5%)b
Engineering procurement and contract management
(12%)b
Commissioning and start-up (3%)b
Owner team (10%)b
Subtotal (27.5% of subtotal of direct costs)
Total project cost
Cost Factor
(% of equipment cost)
100
3 .
40
15
40
15
35 ~
30
278
3
4
34
8
28
77
355
"Direct cost factors include contingency costs.                                    '
bPercentage of subtotal of direct costs; standard factors used by engineering and design firm.
                                             9-25
-------
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where flow is 4% of flow to the clarifier
Chemicals ($/yr): (cost included with biological nitr
precipitation, and clarification)
O&M labor ($/yr): DPY/2 x 1 hour x $29.67/hr =
Maintenance equipment and vendors ($/yr): 0.06 x j
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included with belt filter O&M)
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                                      9-39
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Maintenance equipment and vendors ($/yr):
0.06 x (10,529 x flow (gpm) + 56,925)
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                                                 9-40
-------
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                                                    N.•? s i
                                                     IDES
                                            9-41
-------
                             Section 9 - Incremental Investment and Operating and
                            	Maintenance Costs for Proposed Regulation
                    Table 9-4
Assumptions Used to Estimate Investment Costs
Category
Spatial limitations
Solids handling
Civil/structural costs
Piping/installation
Electrical/process
control instrumentation
Assumption
Additions to the wastewater treatment system will be located within 500 feet of the
existing system.
An approximate length of 500 feet is used for the supply of water to the new water
treatment facility.
Equipment is located so that the length between processing tanks, sumps, and processing
equipment will be within 20 feet.
Outfalls or sewers leading to outfalls are located within 100 feet of the exit of the new
water treatment facility.
Motors are located within 150 feet from motor control center, 160 feet of conduit per
motor, 260 feet of control cable per motor.
Sludge or filter backwash generated from add-on treatment systems will be thickened and
dewatered with existing equipment in existing high-rate recycle systems, except for blast
furnace operations, where separate sludge dewatering facilities were costed for blowdown
treatment systems to segregate high zinc-content sludges from wastewater sludges that
may be recycled to the blast furnaces.
Site preparation is minimal; no major demolition, excavation of existing foundations or
movement of railroad tracks.
Soil conditions are such that no piles are required,
No excavation of hazardous materials.
1,000 feet of 2-inch carbon steel pipe has been included for plant air distribution. There
is no allowance for an air compressor.
Pipe has been sized to keep the water velocity less than 8 feet per second.
2-inch nominal piping and under is priced as schedule 80 threaded carbon steel.
Pipe over 2 inches is priced as standard schedule carbon steel pipe with welded joints.
316 stainless steel pipe is used for chlorine, caustic, and acid piping.
Costs for supports and painting are included.
Insulation costs are not included.
10% of the total cost allowed for manual valves.
5% of the total cost allowed for instrumentation.
Electrical and other utility services are available at the site.
                        9-42
-------
                                 Section 9 - Incremental Investment and Operating and
                                	Maintenance Costs for Proposed Regulation
                         Table 9-5
Design Specifications for Cokemaking Granular Activated
                Carbon Treatment Systems
Item
Pump station 1
Pump station 2
Filter backwash pump
Equalization basin
Sump 1
Backwash surge basin
Activated carbon
system
Type
Vertical turbine
Vertical turbine
Vertical turbine
Concrete
Concrete
Concrete
Filters
100,000 gpd
Number
2 pumps
2 pumps
2 pumps
1
1
1
2
Size
1.5 HP
1/3 HP
5 HP
3,500ft3
450ft3
450ft3
4' x 3V
7.5 HP
400,000 gpd
Number
2 pumps
2 pumps
2 pumps
1
1
1
2
Size
7.5 HP
1/3 HP
5 HP
13,500 ft3
700ft3
700ft3
7' x 7V
7.5 HP
2,700,000 gpd
Number
2 pumps
2 pumps
2 pumps
1
1
1
3
Size
40 HP
2HP
2BHP
90,000 ft3
4,000 ft3
4,000 ft3
15' x 10/
20 HP
                            9-43
-------
                                       Section 9 - Incremental Investment and Operating and
                                       	 Maintenance Costs for Proposed Regulation
                               Table 9-6

Estimated Investment Costs for Cokemaking Granular Activated Carbon.
                    Systems (100,000 - 2,700,000 gpd)
100,000 gpd
Category
Major
equipment
Installation
Item
Activated carbon system
Activated carbon
Pump station 1
Pump station 2
Filter backwash pumps
Quantity
2
1
2
2
2 .
Rate
$80,000
$5,000
$1,100
$2,500
$3,000
Total freight
Subtotal
Cost
$160,000
$5,000
$2,200
$5,000
$6,000
$5,300
$183,500
Mechanical equipment installation
Activated carbon system
Pump station 1
Pump station 2
Filter backwash pumps
2
2
2
2
$11,000
$1,500
$1,500
$2,000
$22,000
$3,000
$3,000
$4,000
Piping installation
Piping/supports
Control valves/instrumentation
1
1
$58,000
$10,200
$58,000
$10,200
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
Activated carbon system
Equalization basin
Sump 1
Backwash surge basin
1
1
1
1
$27,400
$66,600
$19,000
$19,000
• $27,400
$66,600
$19,000
.$19,000
                                  9-44
-------
                Section 9 - Incremental Investment and Operating and
              	Maintenance Costs for Proposed Regulation
Table 9-6 (Continued)
100,000 gpd
Installation
(cont.)
Indirect costs
Total costs
Equipment structural support
Pump station 1 platform
Pump station 2 platform
Filter backwash pumps
1
1,
1
$4,000
$2,000
$8,000
$4,000
$2,000
$8,000
Buildings
Activated carbon system
1
$21,000
$21,000
Electrical and process control
Power/equipment
Control/instrumentation
Building services ,
l'
1
1
$48,100
$40,600
$4,400
Subtotal
Temporary facilities (1%)
Spare parts (1.5%)
Engineering procurement and contract management (12%)
Commissioning (3%)
Owner team (10%)
Subtotal
Total direct and indirect costs
Contingency (20%) ,
Total Project Cost
$48,100
$40,600
$4,400
$360,300
$5,400
$8,200
$65,300
$16,300
$54,400
$149,600
$693,400
$138,700
$832,100
400,000 gpd
Category
Major
equipment
Item
Activated carbon system
Activated carbon .
Pump station 1
Pump station 2
Filter backwash 'pumps
Quantity
2
1
2
2
2
Rate
$90,000
$15,000
$6,400
$1,100
$6,500
Total freight
Subtotal
Cost
$180,000
$15,000
$12,800
$2,200
$13,000
$6,700
$229,700
          9-45
-------
                Section 9 - Incremental Investment and Operating and
                        Maintenance Costs for Proposed Regulation
Table 9-6 (Continued)
400,000 gpd
Category
Installation
Indirect costs



Item
Quantity
Rate
Cost
Mechanical equipment installation
Activated carbon system
Pump station 1
Pump station 2
Filter backwash pumps
'2
2
2
2
$12,000
$2,000
$1,500 '
$2,000
$24,000
$4,000
$3,000
$4,000
Piping installation
Piping/supports
Control valves/instrumentation
1
1
$91,100
$16,100
$91,100
$16,100
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
Activated carbon system
Equalization basin
Sump 1
Backwash surge basin
1
1
1
1
$35,000
$152,300
$22,000
$22,000
$35,000
$152,300
$22,000
$22,000
Equipment structural support
Pump station 1 platform
Pump station 2 platform
Filter backwash pumps
• 1
1
1
$8,000
$2,000
$8,000
$8,000
$2,000
$8,000
Buildings
Activated carbon system
1
$28,000
$28,000
Electrical and process control
Power/equipment
Control/instrumentation
Building services
1
1
1
$48,100
$40,600
$5,800
Subtotal
Temporary facilities (1%)
Spare parts (1.5%)
Engineering procurement and contract management (12%)
Commissioning (3%)
Owner team (10%)
Subtotal
$48,100
$40,600
$5,800.
$514,000
$7,400
$11,200
$89,200
$22,300
$74,400
$204,500
          9-46
-------
                Section 9 - Incremental Investment and Operating and
                       Maintenance Costs for Proposed Regulation
Table 9-6 (Continued)
400,000 gpd
Category .
Total costs
Item
Quantity
Rate
Total direct and indirect costs
Contingency (20%)
Total Project Cost
Cost
$948,200
$189,600
$1,137,800
2,700,000 gpd
Category
Major
equipment
Installation








Item
Activated carbon system
Activated carbon
Pump station 1
Pump station 2
Filter backwash pumps
Quantity
3
1
2
2
2
Rate
$86,000
'$100,000
$10,600
$3,000
$1,500
Total freight
Subtotal . .
Cost
$258,000
$100,000
$21,200
$6,000
$3,000
$11,600
$399,800
Mechanical equipment installation
Activated carbon system
Pump station 1
Pump station 2
Filter backwash pumps
3
2
2
2
$12,000
$2,500
$2,000
$1,500
. $36,000
$5,000
$4,000
$3,000
Piping installation
Piping/supports
Control valves/instrumentation
1
1
$175,400
$31,000
$175,400
$31,000
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
Activated carbon system
Equalization basin
Sump 1
Backwash surge basin
1
1
1
1
$60,100
$657,400
$59,100
$59,100
$60,100
$657,400
$59,100
$59,100
Equipment structural support
Pump station 1 platform
Pump station 2 platform
Filter backwash pumps
1
1
.1
$12,000
$12,000
$4,000
$12,000
$12,000
$4,000
Buildings
Activated carbon system
1
$54,000
$54,000
         9-47
-------
                Section 9 - Incremental Investment and Operating and
               	Maintenance Costs for Proposed Regulation
Table 9-6 (Continued)
2,700,000 gpd
Category
Installation
(cont.)
Indirect costs
Total costs
Item
Quantity

Rate

Cost
Electrical and process control
Power/equipment
Control/instrumentation
Building services
1
1
1
$82,500
$44,400
$11,300
Subtotal
Temporary facilities (1%) .
Spare parts (1.5%)
Engineering procurement and contract management (12%).
Commissioning (3%)
Owner team (10%)
Subtotal
Total direct and indirect costs • • •
Contingency (20%)
Total Project Cost
$82,500
$44,400
$11,300
$1,310,300
$17,100 ,
$25,700
$205,200
$51,300
$171,000
$470,300
$2,180,400
$436,100
$2,616,500
           9-48
-------
                                                Section 9 - Incremental Investment and Operating and
                                                       Maintenance Costs for Proposed Regulation
                                       Table 9-7

                       Design Specifications for Cokemaking
                     Alkaline Chlorination Treatment Systems
Item
Pump station 1
Pump station 2
Pump station 3
Pump station 4
Pump station 5
pH adjust pump
Clarifierpump
NaOH pump 1
NaOH pump 2
Equalization basin
Reactor clarifier
Chlorination
mixing tank
Chlorination
system
Retention tank
Dechlorination
tank
Dechlorination
system
NaOH tank 1
Type
Vertical turbine
Vertical turbine
Vertical turbine
Vertical turbine
Vertical turbine
Diaphragm
Progressive capacity
Diaphragm/ANSI
Diaphragm
Concrete
Mild steel
Concrete/lined
Building
Concrete/lined
Concrete/lined
Building/tank pad
Carbon steel
100,000 gpd
Number
2 pumps
2 pumps
2 pumps
2 pumps
2 pumps
2
2
2
2
1
1
1
1
1
1
1
2
Size
1/2 HP
1/2 HP
1/2 HP
1/2 HP
1.5 HP
3 HP
3 HP
2 HP
(diaphragm)
3HP
4,000 ft3
12' diameter x
12' side
lOftx lOftx
5 ft/5 HP •
10ftx9ftx
20 ft/3 HP
50 ft x 10 fix
10ft
10 ft x 10 fix
5ft/5HP
8ftx8ftx 15
ft/lOftx 10ft ,
10 ft diameter
x 10 ft side
400,000 gpd
Number
2 pumps
2 pumps
2 pumps
2 pumps
2 pumps
2
2 '
2
2
1
1
1
1
1
1
1
2
Size
1.5 HP
3 HP
2HP
2HP
5HP
3 HP
3HP
2 HP (ANSI)
3 HP
4,000 ft3
22 ft diameter
x 12 ft side
20 ft x 10 fix
10ft/ 15 HP
10ft x 9ft x
20 ft/3 HP
50 ft x 20 ft x
20ft
20 fix 10 fix
10ft/ 15HP
Sftxgftx 15
ft/ 10 ft x 10ft
10 ft diameter
x 10 ft side
2,700,000 gpd
Number
2 pumps
2 pumps
2 pumps
2 pumps
2 pumps
2
2
2 "
2
1
1
2
1
1
2
1
2
Size
10 HP
15BHP
15HP
15 HP
30BHP
. 3 HP .
5BHP
2 HP (ANSI)
3HP
90,000 ft3
60' diam.
25 ft x 20 ft x
13 ft/2 @ 20 HP
15 ft x 20 ft x 20
ft/2 @ 3 HP
lOOftxSOftx
25 ft
25 ft x 20 ft x 13
ft/2@20HP
Sftxgftx 15ft/
lOftx 10ft
10' diameter x 10'
side
FRP - Fiberglass, reinforced plastic.
ANSI - American National Standards Institute.
                                         9-49
-------
                                    Section 9 - Incremental Investment and Operating and
                                   	Maintenance Costs for Proposed Regulation
                             Table 9-8

           Estimated Investment Costs for Cokemaking
Alkaline Chlorination Treatment Systems (100,000 - 2,700,000 gpd)
100,000 gpd
Category
Major
equipment
Installation
Item
Reactor clarifier
Chlorination/dechlorination mixing systems
NaOH tanks
Pump station 1
Pump station 2
Pump station 3
Pump station 4
Pump station 5
pH adjust pumps
Clarifier pumps
NaOH pumps 1
NaOH pumps 2
Quantity
1
1
2
2
2
2
2
2
2
2
2
2
Rate
$40,000
$33,300
. $10,000
$1,000
$1,000
$1,000
$1,000
$1,100
$2,200
$3,500
$3,500
$2,200
Total freight
Subtotal
Mechanical equipment installation
Reactor clarifier
Chlorination/dechlorination mixing systems
NaOH tanks
Pump station 1 •
Pump station 2
Pump station 3
Pump station 4
Pump station 5
pH adjust pumps
Clarifier pumps
NaOH pumps 1
NaOH pumps 2
1
1
2
2
2
2
2
2
2
2
2
2
$100,000
$10,000
$1,000
$1,500
$1,500
$1,500
$1,500
$1,500
$2,000
$2,000
$2,000
- $2,000

Cost
$40,000
$33,200
$20,000
$2,000
$2,000
$2,000
$2,000
$2,200
$4,400
$7,000
$7,000.
$4,400
$3,800
$130,000

$100,000
$10,000
$2,000
$3,000
$3,000
$3,000
$3,000
$3,000
$4,000
$4,000
$4,000
$4,000
                                9-50
-------
                Section 9 - Incremental Investment and Operating and
                        Maintenance Costs for Proposed Regulation
Table 9-8 (Continued)
100,000 gpd
Category
Installation
(cont.)












Item
Quantity
Rate
Cost
Piping installation
Piping/supports
Control valves/instrumentation
1 .
1
$65,500
$11,600
$65,500
$11,600
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
Reactor clarifier/ clarifier pumps
NaOH pumps
NaOH tanks
Chlorination mixing tank
Chlorination system
Retention tank
Dechlorination mixing tank
Dechlorination system
pH adjust pumps •
Equalization basin
1
2
1
1
1
1
1
1
1
1
$8,800
$3,500
$4,200
$20,500
$12,600
$110,800
$20,500
$12,500
$3,500
$59", 100
$8,800
$7,000
$4,200
$20,500
$12,600
$110,800
$20,500
$12,500
$3,500
$59,100
Equipment structural support
Pump station 1 platform .
Pump station 2 platform
Pump station 3 platform
Pump station 4 platform
Pump station 5 platform
1
1
1
1
1
$4,000
$4,000
$4,000
$4,000
$4,000
$4,000
$4,000
$4,000
$4,000
$4,000
Buildings
Chlorination system
Dechlorination system
1
1
$2,000
$2,000
$2,000
$2,000
Electrical and process control
Power/equipment
Control/instrumentation
Building Services
1
1
1
$99,400
$90,300
$600
Subtotal
.$99,400
$90,300
$600
$693,900
         9-51
-------
                Section 9 - Incremental Investment and Operating and
                        Maintenance Costs for Proposed Regulation
Table 9-8 (Continued)
100,000 gpd
Category
Indirect costs
Total costs
Item
Quantity
Rate
Temporary facilities (1%)
Spare parts (1.5%)
Engineering procurement and contract management (12%)
Commissioning (3%)
Owner team (10%)
Subtotal
Total direct and indirect costs
Contingency (20%)
Total Project Cost
400,000 gpd
Category
Major
equipment
Item
Reactor clarifier
Chlorination/dechlorination mixing systems
NaOH tanks
Pump station 1 . .
Pump station 2
Pump station 3
Pump station 4
Pump station 5
pH adjust pumps
Clarifier pumps
NaOH pumps 1
NaOH pumps 2
Quantity
1
1
2
2
2
2
2
2
2
2
2
2
Rate
$52,000
$118,800
$10,000
$5,000
$5,000
$5,000
$5,000
$5,100
$2,200
$3,500
$5,000
$2,200
Total freight
Subtotal

Cost
.$8,200
$12,400
$98,900
$24,700
$82,400
$226,600
$1,050,500
$210,100
$1,260,600

Cost
$52,000
$118,800
$20,000
$10,000
$10,000
$10,000
$10,000
$10,200
$4;400
$7,000
$10,000
$4,400
$8,000
$274,800
           9-52
-------
                Section 9 - Incremental Investment and Operating and
                        Maintenance Costs for Proposed Regulation
Table 9-8 (Continued)
400,000 gpd
Category
Installation
Item
Quantity
Rate
Mechanical equipment installation
Reactor clarifier .
Chlorination/dechlorination mixing systems
NaOH tanks
Pump station 1
Pump station 2
Pump station 3
Pump station 4
Pump station 5
pH adjust pumps
Clarifier pumps '
NaOH pumps 1
NaOH pumps 2
1
1
2
2
2
.2
2
2
2
2
2
2
$105,000
$35,600
$1,000
$2,000
$2,000
. $2,000
$2,000
. $2,000
$2,000
$2,000
$1,500
$2,000
Cost

$105,000
$35,600
$2,000
$4,000
$4,000
$4,000
$4,000
$4,000
$4,000
$4,000
$3,000
$4,000
Piping installation
Piping/supports
Control valves/instrumentation
1
1
$106,900
$18,900
$106,900
$18,900
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
Reactor clarifier/clarifier pumps
NaOH pumps
NaOH tanks
Chlorinatioh mixing tank
Chlorination system
Retention tank
Dechlorination mixing tank
Dechlorination system
pH adjust pumps
Equalization basin
1
2
1
1
1
1
1 .
1
1 •
1
$19,300
$3,500
$4,200
$41,000
$12,900
$221,600
$41,000
$12,900
$3,500
$59,200
$19,300
$7,000
$4,200
$41,000
$12,900
$221,600
$41,000
$12,900
$3,500
$59,200
          9-53
-------
                Section 9- Incremental Investment and Operating and
               	Maintenance Costs for Proposed Regulation
Table 9-8 (Continued)
400,000 gpd
Category
Installation
(cont.)
Indirect costs
Total costs
Item
Quantity
Rate
Cost
Equipment structural support
Pump station 1 platform
Pump station 2 platform
Pump station 3 platform
Pump station 4 platform
Pump station 5 platform
1
1
1
1
1
$6,000
$8,000
$6,000
$6,000
$12,000
$6,000
$8,000
$6,000
$6,000
$12,000
Buildings
Chlorination system
Dechlorination system
1
1
$2,000
$2,000
$2,000
$2,000
Electrical and process control
Power/equipment
Control/instrumentation
Building services
1
1
1
$99,500-
$90,300
$600
Subtotal -
Temporary facilities (1%)
Spare parts (1.5%)
Engineering procurement and contract management ( 1 2%)
Commissioning (3%)
Owner team (10%)
Subtotal
Total direct and indirect costs
Contingency (20%)
Total Project Cost
$99,500
$90,300
$600
$958,300
$12,300
'$18,500
$148,000
$37,000
$123,300
$339,100
$1,572,200
$314,400
$1,886,600
           9-54
-------
                Section 9 - Incremental Investment and Operating and
                        Maintenance Costs for Proposed Regulation
Table 9-8 (Continued)

2,700,000 gpd
Category
Major
equipment
Installation









Item
Reactor clarifier
Chlorination/dechlorination mixing systems
NaOH tanks
Pump station 1 :
Pump station 2
Pump station 3
Pump station 4
Pump station 5 .
pH adjust pumps
Clarifier pumps
NaOH pumps 1
NaOH pumps 2
Quantity
1
1
2
2
2
2
2
2
2
2
2
2
Rate
$155,000
$798,000
$10,000
$9,000
$10,500
$10,500
$10,500
$11,000
$2,200
$5,500
$8,500
$3,500
Total freight
Subtotal
Cost
$155,000
$798,000
$20,000
$18,000
$21,000
$21,000
$21,000
$22,000
$4-,400
$11,000
$17,000
$7,000
$33,500
$1,148,900
Mechanical equipment installation
Reactor clarifier
Chlorination/dechlorination mixing systems
NaOH tanks
Pump station 1 "
Pump station 2
Pump station 3
Pump station 4
Pump station 5
pH adjust pumps
Clarifier pumps
NaOH pumps 1 -
NaOH pumps 2
1
1
2
2
2
2
2
2
2
2
2
2
$300,000
$239,400
$1,000
$2,500
$2,500
$2,500
$2,500
$2,500
$2,000
$2,000
$2,000
$2,000
$300,000
$239,400
$2,000
$5,000
$5,000
$5,000
$5,000
$5,000
$4,000
$4,000
$4,000
$4,000
          9-55
-------
                Section 9 - Incremental Investment and Operating and
               	Maintenance Costs for Proposed Regulation
Table 9-8 (Continued)
2,700,000 gpd
Category
Installation
(cont.)
Item
Quantity
Rate
Cost
Piping installation
Piping/supports .
Control valves/instrumentation
1
1
$191,200
$33,700
$191,200
$33,700
Civil/sjtructural (includes costs associated with site preparation and grading)
Equipment foundations
Reactor clarifier/clarifier pumps
NaOH pumps
NaOH tanks
Chlorination mixing tank
Chlorination system
Retention tank
Dechlorination mixing tank
Dechlorination system
pH adjust pumps
Equalization basin
Equipment structural support
Pump station 1 platform
Pump station 2 platform
Pump station 3 platform
Pump station 4 platform
Pump station 5 platform
1
.2
1
2
1
1
2
1
1
. 1
$78,-8QO
• $3,500
$5,300
$97,400 .
$32,800
$1,000,800
$97,400
$11,500
$3,500
$657,400
$78,800
$7,000
$5,300
$194,800
$32,800
$1,000,800
$194,800
$11,500
$3,500
$657,400

1
1
1
1
1
$16,000
$16,000
$16,000
$16,000
$16,000
$16,000
$16,000
$16,000
$16,000
$16,000
Buildings
CKlorination system
Dechlorination system
1
1
$6,000
$2,000
$6,000
$2,000
Electrical and process control
Power/equipment
Control/instrumentation
Building services
1
1
1
$195,800
$1 17,000
$1,500
Subtotal
$195,800
$117,000
$1,500
$3,396,300
           9-56
-------
                Section 9 - Incremental Investment and Operating and
               	Maintenance Costs for Proposed Regulation
Table 9-8 (Continued)
2,700,000 gpd
Category
Indirect costs
Total costs
Item Quantity Rate
Temporary facilities (1%)
Spare parts (1.5%) • ,
Engineering procurement and contract management (12%)
Commissioning (3%)
Owner team (10%)
Subtotal
Total direct and indirect costs
Contingency (20%)
Total Project Cost
Cost
$45,500
$68,200
$545,400
$136,400
$454,500
$1,250,000
$5,795,200
$1,159,000
$6,954,200
           9-57
-------
                                                 Section 9 - Incremental Investment and Operating and
                                                	Maintenance Costs for Proposed Regulation
                                        Table 9-9

            Design Specifications for Metals Precipitation Systems for
                      Blast Furnace and Sintering Wastewater
Item
Pump station 1
Pump station 2
Clarifierpump
Filter press pump
NaOH pump
Acid pump
Sump
Equalization basin
Reactor darifier
Clarifier overflow
NaOH tank
Acid tank
pH control tank
Filter press
Type
Vertical turbine
Vertical turbine
Diaphragm/ANSI
Diaphragm
ANSI
Diaphragm
Concrete
Concrete
Mild steel
Concrete
Carbon steel
FRP
Stainless
Pneumatic
150,000 gpd
Number
2 pumps
2 pumps
2
2
2
2
1
1
1
1
2
2
1
1
Size
1/2 HP
2 HP
1/3 HP
(diaphragm)
1/3 HP
1/3 HP
1/3 HP
10ft3
5,100 ft3
15 ft diameter
x 12 ft side/
1 HP & 2.5 HP
450ft3
10 ft diameter
x 10 ft side
10 ft diameter
x 10 ft side
90 tf/lHP
18 ft x 7ft x
6 ft/10 HP &
7.5 HP
750,000 gpd
Number
2 pumps
2 pumps
2
2
2
2 '
1
• 1
1
1
2
2
1
1
Size
3HP
10 HP
1HP
(diaphragm)
1/3 HP
1/2 HP .
1/3 HP
40ft3
26,000 ft3
35 ft diameter
x 12 ft side/
1HP&5HP
1,260ft3
10 ft diameter
x 10 ft side
10 ft diameter
x 10 ft side
450 ft3/! HP
18ftx?ftx
6 ft/10 HP &
7.5 HP
2,000,000 gpd
Number
2 pumps
2 pumps
2
2
2
2
1
1
1
1
2
2
1
1
Size
7.5 HP
25 HP
1/2 HP (ANSI)
3BHP
1.5BHP
3BHP
80ft3
67,000 ft3
51 ft diameter x
12 ft side/2 HP &
10 HP
14,000 ft3
10 ft diameter x
10 ft side
10 ft diameter x
10 ft side
l,200ftV3HP
18ftx7ftx6ft/
10 HP & 7.5 HP
FRP - Fiberglass, reinforced plastic.
ANSI - American National Standards Institute.
                                          9-58
-------
                                      Section 9 - Incremental Investment and Operating and
                                     	Maintenance Costs for Proposed Regulation
                             Table 9-10
    Estimated Investment Costs for Metals Precipitations Systems
for Blast Furnace and Sintering Wastewater (150,000 - 2,000,000 gpd)
150,000 gpd
Category
Major
equipment
Installation
Item
Reactor clarifier
pH control tank
Acid/NaOH tanks
Filter press
Pump station 1
Pump station 2
Clarifier pumps
Filter press pumps
NaOH pumps
Acid pumps
Quantity
1
i
4
1
2
2
2
2
2
2
Rate
$-40,000
$8,900 .
$10,000
$175,000
$1,500
$3,000.
$2,200
$2,200
$5,500
$2,200
Total freight
Subtotal
Cost
$40,000
$8,900
$40,000
$175,000
-; $3,000
$6,000
$4,400
$4,400
$11,000
$4,400
$8,900
$306,000
Mechanical equipment installation •
Reactor clarifier
pH control tank
Acid/NaOH tanks
Filter press
Pump station 1
Pump station 2
Clarifier pumps
Filter press pumps
NaOH pumps
Acid pumps
1
1
. 4 • -
1
2
2
2
2
2
2
$110,000.,
$2,300
$1,000
.$52,500
$1,500
$1,500
$2,000
$2,000
$1,500
$2,000
$110,000
$2,300
$4,000
$52,500
$3,000
$3,000
$4,000
$4,000
$3,000
- $4,000
                                9-59
-------
                 Section 9 - Incremental Investment and Operating and
                	Maintenance Costs for Proposed Regulation
Table 9-10 (Continued)
150,000 gpd
Category
Installation
(cont.)
Indirect costs
Total costs '
Item
Quantity
Rate
Cost
Piping installation
Piping/supports
Control valves/instrumentation
1
1
$78,500
$13,800
$78,500
$13,800
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
Reactor clarifier/overflow tank
Clarifier pumps
pH control tank
Acid/NaOH tanks and pumps
Filter press
Equalization basin
Sump/filter press pumps
1
1
1
1
1
1
1
$37,800
$3,500
$1,800
$14,000
$7,000
$90,300
$6,700
$37,800
$3,500
$1,800 .
$14,000
$7,000
$90,300
$6,700
Equipment structural support
Pump station 1 platform
Pump station 2 platform
1
1
$2,000
$4,000
$2,000
$4,000
Electrical and process control
Power/equipment
Control/instrumentation
1
1
$82,200
$78,800
Subtotal
Temporary facilities (1%)
Spare parts (1.5%)
Engineering procurement and contract management (12%)
Commissioning (3%)
Owner team (10%)
Subtotal
Total direct and indirect costs
Contingency (20%)
Total Project Cost
$82,200
$78,800
$610,200
$9,200
$13,700
$109,900
$27,500
$91,600
$251,900
$1,168,100
$233,600
$1,401,700
           9-60
-------
                 Section 9 - Incremental Investment and Operating and
                	. Maintenance Costs for Proposed Regulation
Table 9-10 (Continued)
750,000 gpd
Category
Major
equipment
Installation





Item
Reactor clarifier
pH control tank
Acid/NaOH tanks
Filter press
Pump station 1
Pump station 2
Clarifier pumps
Filter press pumps
NaOH pumps
Acid pumps
Quantity
1
. 1
4
1
2
2
2
2
2
2
Rate
$75,000
$23,500
$10,000
$175,000
$5,500
$8,000
$3,500
$2,200
$8,000
$2,200
Total freight
Subtotal
Cost
$75,000
$23,500
$40,000
$175,000
$11,000
$16,000
$7,000
$4,400
$16,000
$4,400
$11,200
$383,500
Mechanical equipment installation
Reactor clarifier
pH control tank
Acid/NaOH tanks
Filter press
Pump station 1
Pump station 2
Clarifier pumps
Filter press pumps
NaOH pumps
Acid pumps
1
1
4
1
2
2
2-
2
' 2
2
$162,000 -
$6,000
$1,000
$52,500
$2,000
$2,000
$2,000
$2,000
$1,500
$2,000
$162,000
$6,000
$4,000
$52,500
$4,000
$4,000
$4,000
$4,000
$3,000
$4,000
Piping installation
Piping/supports
Control valves/instrumentation
1
1
$114,000
$20,100
$114,000
$20,100
          9-61
-------
                 Section 9 - Incremental Investment and Operating and
                	Maintenance Costs for Proposed Regulation
Table 9-10 (Continued)
750,000 gpd
Category
Installation
(cont.)
Indirect costs
Total costs
Item
Quantity
Rate

Cost
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
Reactor clarifier/overflow tank
Clarifier pumps
pH control tank
Acid/NaOH tanks and pumps
Filter press
Equalization basin
Sump/filter press pumps
1
1
1
1
1
1
1
$59,000
$3,500
$5,300
$14,000
$7,000
$257,600
$7,500

$59,000
$3,500
$5,300
$14,000
$7,000
$257,600
$7,500
Equipment structural support
Pump station 1 platform
Pump station 2. platform
1
1
$4,000
$8,000
$4,000
$8,000
Electrical and process control
Power/equipment
Control/instrumentation
1
1
$82,200
$78,800
Subtotal
Temporary facilities (1%)
Spare parts (1.5%)
Engineering procurement and contract management (12%)
Commissioning (3%)
Owner team (10%)
Subtotal
Total direct and indirect costs
Contingency (20%)
Total Project Cost
$82,200
$78,800
$908,500
$12,900
$19,400
$155,000
$38,800
$129,200
8355,300
$1,647,300
$329,500
$1,976,700
           9-62
-------
                 Section 9 - Incremental Investment and Operating and
                	Maintenance Costs for Proposed Regulation
Table 9-10 (Continued)
2,000,000 gpd
Category
Major
equipment
Installation





Item
Reactor clarifier
pH control tank
Acid/NaOH tanks
Filter press
Pump station 1
Pump station 2
Clarifier pumps
Filter press pumps
NaOH pumps
Acid pumps
Quantity
1
'l
4
1
2
2
2
2
2
2
Rate
$130,000
$47,400
$10,000
$175,000
$9,000
$9,500
$5,500
$2,200
$8,500
$7,500-
Total freight
Subtotal
Cost
$130,000
$47,400
$40,000
$175,000
$18,000
$19,000
$11,000
$4,400
$17,000
$15,000
$14,300
$491,100
Mechanical equipment installation
Reactor clarifier
pH control tank
Acid/NaOH tanks
Filter press
Pump station 1
Pump station 2
Clarifier pumps
Filter press pumps
NaOH pumps
Acid pumps
1
1
4
1
2 .
2
2
2
2
2
$253,000
$12,000
$10,000
$52,500
$2,500
$2,500
$1,500
$2,000
$2,000
$2,000
$253,000
$12,000
$40,000
$52,500
$5,000
$5,000
$3,000
$4,000
$4,000
$4,000
Piping installation .
Piping/supports
Control valves/instrumentation
1
1
$139,200
$24,600
$139,200
$24,600
          9-63
-------
                 Section 9 - Incremental Investment and Operating and
                        Maintenance Costs for Proposed Regulation
Table 9-10 (Continued)
2,000,000 gpd
Category
Installation
(cent.)
Indirect costs
Total costs
Item
Quantity
Rate
Cost
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
Reactor clarifier/overflow tank
Clarifier pumps
pH control tank
AcioVNaOH tanks and pumps
Filter press
Equalization basin
Sump/filter press pumps
1
1
1
1
1
1
1
$224,800
$7,000
$10,500
$17,500
$8,7.00
$508,300
$12,500
$224,800
$7,000
$10,500
$17,500
$8,700
$508,300
$12,500
Equipment structural support
Pump station 1 platform
Pump station 2 platform
1
1
$6,000
$8,000
$6,000
$8,000
Electrical and process control
Power/equipment
Control/instrumentation
1
1
$105,900
$78,800
Subtotal
Temporary facilities (1 %)
Spare parts (1.5%)
Engineering procurement and contract management (12%)
Commissioning (3%)
Owner team (10%)
Subtotal
Total direct and indirect costs
Contingency (20%)
Total Project Cost
$105,900
$78,800
$1,534,300
$20,300
$30,400
$243,000
$60,800
$202,500
$557,000
$2,582,400
$516,500
$3,098,900
           9-64
-------
                                                Section 9 - Incremental Investment and Operating and
                                                       Maintenance Costs for Proposed Regulation
                                      Table 9-11

           Design Specifications for Alkaline Chlorination Systems for
                      Blast Furnace and Sintering Wastewater
Item
Pump station 1
Pump station 2
Pump station 3
Pump station 4
pH adjust pump
NaOH pump
Equalization basin
Chlorination
mixing tank
Chlorination
system
Retention tank
Dechlorination
tank
Dechlorination
system
NaOH tank
Type
Vertical turbine
Vertical turbine
Vertical turbine
Vertical turbine
Diaphragm
Diaphragm
Concrete
Concrete
Building'
Concrete
Concrete
Building/tank pad
Carbon steel
150,000 gpd
Number
2 pumps
2 pumps
2 pumps
2 pumps
2
2
1
1
1
1
1
1
2
Size
1 HP
1 HP
1 HP
lHPb
3 HP
1/2 HP
5,100 ft3
11 ftx lOftx
5 ft/5 HP
10ftx9ftx
20 ft/3 HP
SOft.x 11 ftx
10ft
llftxlOftx
5 ft/5 HP
SftxSftx 15
. ft/10 ftx 10ft
10 ft diameter
x 10 ft side
750,000 gpd
Number
2 pumps
2 pumps
2 pumps
2 pumps
" .2
2
1
1
1
1 •
1
1
2
Size
4 HP
3 HP
3 HP
3 HP .
3HP •
1/2 HP
25,000 ft3
20 ftx 15 ftx
10 ft/20 HP
10ftx9ftx
20 ft/3 HP
50 ft x 30 ft x
20ft
20 ftx 15 ftx
' 10 ft/20 HP
8 ft x 8 ft x 15
ft/10 ftx 10 ft
10 ft diameter
x 10 ft side
2,000,000 gpd
Number
2 pumps
. 2 pumps
2 pumps
2 pumps
2
2
1
1
1
1
1
r
2
Size
10 HP
7.5 HP . •
7.5 HP
7.5 HP
3 HP
1/2 HP
67,000 ft3
25 ft x 20 ft x 15
ft/3 @ 20 HP
15 ftx 20 ftx 20
ft/2 @ 3 HP
80 ft x 50 ft x 20
ft
25 ftx 20 ftx 15
ft/3 @ 20 HP
8 ft x 8 ft x 15
ft/10 ft x 10 ft
10 ft diameter x
10 ft side
FRP - Fiberglass, reinforced plastic.
ANSI -American National Standards Institute.
                                          9-65
-------
                                    Section 9 - Incremental Investment and Operating and
                                           Maintenance Costs for Proposed Regulation
                            Table 9-12

Estimated Investment Costs for Alkaline Chlorination Systems for
Blast Furnace and Sintering Wastewater (150,000 - 2,000,000 gpd)
150,000 gpd
Category
Major
equipment
Installation
Item
Chlorination/dechlorination mixing systems
NaOH tanks
Pump station 1
Pump station 2
'Pump station 3
Pump station 4
pH adjust pumps
NaOH pumps
Quantity
1
2
2
2
2
2
2
2
Rate
$44,700
$10,000
$1,500
$1,500
$1,500
$1,500
$2,200
$2,200"
Total freight
Subtotal
Cost
$44,700
$20,000
$3,000
$3,000
$3,000
$3,000
$4,400
$4,400
$2,600
$88,100
Mechanical equipment installation
Chlorination/dechlorination mixing systems
NaOH tanks
Pump station 1
Pump station 2
Pump station 3
Pump station 4
pH adjust pumps
NaOH pumps
1
2
2
2
2
2
2
2
$13,400
$1,000
$1,500
$1,500
$1,500
$1,500
$2,000
$2,000
$13,400
$2,000
$3,000
$3,000
$3,000
$3,000
$4,000
$4,000
Piping installation
Piping/supports
Control valves/instrumentation
1
1
$69,700
$12,300
$69,700
. . $12,300
                               9-66
-------
                 Section 9 - IncrementaLInyestmerit and Operating and
                        Maintenance Costs for Proposed Regulation
Table 9-12 (Continued)
150,000 gpd
Category
Installation
(cont.)
Item
Quantity
Rate
Cost
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
NaOH pumps
NaOH tanks
Chlorination mixing tank
Chlorination system
Retention tank
Dechlorination mixing tank
Dechlorination system
pH adjust pumps
Equalization basin
1
1
1
1
1
1
1
1
1
$3,500
$4,200
$25,100
$12,600
$118,500
. $25,100
$12,500
$3,500
$77,800
$3,500
$4,200
$25,100
$12,600
$118,500
$25,100
$12,500.
$3,500
$77,800
Equipment structural support
Pump station 1 platform
Pump station 2 platform
Pump station 3 platform
Pump station 4 platform
1
1
1
1.
$4,000
$4,000
$4,000
$4,000
$4,000
$4,000
$4,000
$4,000
Buildings •
Chlorination system
Dechlorination system
1
1
$2,000
$2,000
$2,000
$2,000
Electrical and process control
Power/equipment
Control/instrumentation
Building Services
. 1
1
1
$71,900
$67,300
$600
Subtotal
$71,900
$67,300
$600
$560,000
           9-67
-------
                 Section 9 - Incremental Investment and Operating and
                	Maintenance Costs for Proposed Regulation
Table 9-12 (Continued)
150,000 gpd
Category
Indirect costs
Total costs
Item
Quantity
Rate
Temporary facilities (1%)
Spare parts (1. 5%) .
Engineering procurement and contract management (12%)
Commissioning (3%)
Owner team (10%)
Subtotal •
Total direct and indirect costs
Contingency (20%)
Total Project Cost
Cost
$6,500
$9,700
$77,800
$19,400
$64,800
$178,200
$826,300
$165,300
$991,600
750,000 gallon per day
Category
Major
equipment
Installation
Item
Chlorination/dechlorination mixing systems
NaOH tanks
Pump station 1
Pump- station 2
Pump station 3
Pump station 4
pH adjust pumps
NaOH pumps
Quantity
1
2
2
. 2
2
2.
2
2
Rate
$223,500
$10,000
$5,000
$5,000
$5,000
$5,000
$21200
$2,200
Total freight
Subtotal
Cost
$223,500
$20,000
$10,000
$10,000
$10,000
$10,000
$4,400 ,
$4,400
$8,800
$301,100
Mechanical equipment installation
Chlorination/dechlorination mixing systems
NaOH tanks
Pump station 1
Pump station 2
Pump station 3
Pump station 4 •
pH adjust pumps
NaOH pumps
1
2
2
2.
2
2
2
2
$67,000
$1,000
$2,000
$2,000
$2,000
$2,000
$2,000
$2,000
$67,000
. $2,000
$4,000
$4,000
• $4,000
$4,000
$4,000
$4,000
           9-68
-------
                 Section 9 - Incremental Investment and Operating and
               	   hfaintenance Costs for Proposed Regulation
Table 9-12 (Continued)
750,000 gallon per day
Category
Installation
(cont.)




Item
Quantity
Rate
Cost
Piping installation .
Piping/supports
Control valves/instrumentation
1
1
$104,000
$18,400
$104,000
$18,400
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
NaOH pumps .
NaOH tanks
Chlorination mixing tank
Chlorination system
Retention tank .
Dechlorination mixing tank
Dechlorination. system :
pH adjust pumps
Equalization basin
1
1
1
1
1
1 •
1
1
1
$3,500
$4,200
$64,800
$12,600
$385,100
$64,800
.$12,600
$3,500
$264,400
$3,500
$4,200
$64,800
$12,600
$385,100
$64,800
$12,600
$3,500
$264,400
Equipment structural support
Pump station 1 platform
Pump station 2 platform
Pump station 3 platform
Pump station 4 platform
1
1
1
1
$8,000
$8,000
$8,000
$8,000
$8,000
$8,000
$8,000
$8,000"
Buildings
Chlorination system
Dechlorination system
1
1
$2,000
$2,000
$2,000
$2,000
Electrical and process control
Power/equipment
Control/instrumentation
Building Services
1
1
1
$74,000
$67,300
$600
Subtotal
$74,000
$67,300
$600
$1,208,800
           9-69
-------
                 Section 9 - Incremental Investment'and Operating and
                	Maintenance Costs for Proposed Regulation
Table 9-12 (Continued)
750,000 gallon per day
Category
Indirect costs
Total costs
Item
Quantity
Rate
Temporary facilities (1%)
Spare parts (1.5%)
Engineering procurement and contract management ( 1 2%)
Commissioning (3%)
Owner team (10%)
Subtotal
Total direct and indirect costs
Contingency (20%)
Total Project Cost

Cost
$15,100
$22,600
$181,2.00
$45,300
$151,000
$415,200
$1,925,100
$385,000
$2,310,100
2,000,000 gpd
Category
Major
equipment
Installation
Item
Chlorination/dechlorination mixing systems
NaOH tanks
Pump station 1
Pump station 2
Pump station 3
Pump station 4 .
pH adjust pumps
NaOH pumps
Quantity
1
2
2
2
2
2
2
2
Rate
$590,100
$10,000
$9,000
$9,000
$9,000
$9,000
$2,200
$2,200
Total freight
Subtotal
Cost
$590,100
$20,000
$18,000
$18,000
$18,000
$18,000
$4,400
$4,400
$20,700
$711,600
Mechanical equipment installation
Chlorination/dechlorination mixing systems
NaOH tanks
Pump station 1
Pump station 2
Pump station 3
Pump station 4
pH adjust pumps
NaOH pumps
1
2
2
2
2
2
2
2
$177,000
$1,000
$2,500
$2,500
$2,500
$2,500
$2,000
$2,000
$177,000
$2,000
$5,000
$5,000
$5,000
$5,000
$4,000
$4,000
            9-70
-------
                 Section 9 - Incremental Investment and Operating and
                .   	Maintenance Costs for Proposed Regulation
Table 9-12 (Continued)
2,000,000 gpd
Category
Installation
(cont.)
Item
Quantity
Rate
Piping installation
Piping/supports
Control valves/instrumentation
1
1
$126,900
$22,400

Cost

$126,900
$22,400
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
NaOH pumps
NaOH tanks
Chlorination mixing tank
Chlorination system
Retention tank
Dechlorination mixing tank .
Dechlorination system
pH adjust pumps
Equalization basin
1
1
1
1
1 '
1
1
1
1
Equipment structural support
Pump station 1 platform
Pump station 2 platform
Pump station 3 platform
Pump station 4 platform.
1
1
1
1
$3,500
$4,200
$120,3.00
$31,100
$746,600
$120,300
$12,500
$3,500 .
$544,900

$16,000
$16,000
$16,000
$16,000

$3,500
$4,200
$120,300
$31,100
$746,600
$120,300
$12,500
$3,500
$544,900

$16,000
$16,000
$16,000
$16,000
Buildings
Chlorination system
Dechlorination system
1
1
$6,000
$2,000
$6,000
$2,000
Electrical and process control
Power/equipment
Control/instrumentation
Building Services
1
1
1
$114,000
$86,500
$1,500
Subtotal
$114,000
$86,500
$1,500
$2,217,200
           9-71
-------
                 Section 9 - Incremental Investment and Operating and
                	Maintenance Costs for Proposed Regulation
Table 9-12 (Continued)
2,000,000 gpd
Category
Indirect costs
Total costs
Item Quantity . Rate
Temporary facilities (1%)
Spare parts (1.5%)
Engineering procurement and contract management ( 1 2%)
Commissioning (3%)
Owner team (10%)
Subtotal
Total direct and indirect costs
Contingency (20%)
Total Project Cost
Cost
$29,300
$43,900
$351,500
$87,900
$292,900
$805,500
$3,734,400
$746,900 .
$4,481,300
          9-72
-------
                                              Section 9 - Incremental Investment and Operating and
                                             	Maintenance Costs for Proposed Regulation
                                     Table 9-13

    Design Specifications for Metals Precipitation Systems for Basic Oxygen
       Furnace, Vacuum Degassing, and Continuous Casting Wastewater
Item
Pump station 1
Pump station 2
Clarifier pumps
NaOH pump
Acid pump
Equalization basin
Reactor clarifier
Clarifier overflow.
NaOH tank
Acid tank
pH control tank
Type
Vertical turbine
Vertical turbine
Diaphragm/ANSI
ANSI
Diaphragm
Concrete
Mild Steel
Concrete
Carbon steel
FRP
Stainless
150,000 gpd
Number
2 pumps
2 pumps
2 pumps
2 pumps
2 pumps
1
1
1
2
2
1
Size
1/2 HP
. 2 HP
1/3 HP
(diaphragm)
1/3 HP
1/3 HP
5,100 ft3
15 ft diameter
x 12 ft side/
1 HP & 2.5 HP
450 rf/2 HP
10 ft diameter
x 10 ft side
10 ft diameter
x 10 ft side
90 ftVlHP
750,000 gpd
Number
2 pumps
2 pumps
2 pumps
2 pumps
2 pumps
1
1
1
2
2
1
Size
3 HP
10HP
1HP
(diaphragm)
1/2 HP ,
1/3 HP
26,000 ft3
35 ft diameter
x 12 ft side/
1HP&5HP
1, 260 ft3/! 0 HP
10 ft diameter
x 10 ft side
10 ft diameter
x 10 ft side
450 ftVlHP
2,000,000 gpd
Number
2 pumps
2pumps
2 pumps
2 pumps
2 pumps
1
1
1
2
-2
1
Size
• 7.5 HP
25 HP
1/2 HP (ANSI)
1.5 BHP
3BHP
67,000ft3
51 ft diameter x
12 ft side/2 HP &.
10 HP
14,000 ft3/20 HP
10 ft diameter x
10 ft side
10 ft diameter x
10 ft side
1200 ft3/3 HP
FRP - Fiberglass, reinforced plastic.
ANSI - American National Standards Institute.
                                        9-73
-------
                                       Section 9 - Incremental Investment and Operating and
                                      	Maintenance Costs for Proposed Regulation
                               Table 9-14

 Estimated Investment Costs for Metals Precipitation Systems for Basic
Oxygen Furnace, Vacuum Degassing, and Continuous Casting Wastewater
                        (150,000 - 2,000,000 gpd)
150,000 gpd
Category
Major
equipment
Installation
Item
Reactor clarifier
pH control tank
Acid/NaOH tanks
Pump station 1
Pump station 2
Clarifier pumps
NaOH pumps
Acid pumps
Quantity
1
1
4
2
2 •
2
1
2
Rate
$40,000
$8,900
$10,000
$1,500
$3,000
$2,200
$5,500
$2,200 .
Total freight
Subtotal
Cost
$40,000
$8,900
$40,000
$3,000
$6,000
$4,400
$11,000
$4,400
$3,500
$121,200
Mechanical equipment installation
Reactor clarifier
pH control tank
Acid/NaOH tanks
Pump station 1
Pump station 2 •
Clarifier pumps
NaOH pumps
Acid pumps
1
1
4
2
2
2
2
2
$110,000
$2,300
$1,000
$1,500
$1,500
$2,000.
$1,500
$2,000 •
$110,000
$2,300
$4,000
$3,000
$3,000
$4,000
$3,000
$4,000
Piping installation
Piping/supports
Control valves/instrumentation
1
1
$77,800
$13,700
$77,800
$13,700
                                  9-74
-------
r
                                                             Section 9 - Incremental Investment and Operating and
                                                            	Maintenance Costs for Proposed Regulation
                                            Table 9-14 (Continued)
150,000 gpd
Category
Installation
(cont.)
Indirect costs
Total costs
Item
Quantity
Rate

Cost
Civil/structural (includes costs associated with site preparation'and grading)
Equipment foundations
Reactor clarifier/overflow tank
Clarifier pumps
pH control tank
Acid/NaOH tanks and pumps
Equalization basin
1
1
1
1
1
$37,800
$3,500
$1,800
$14,000
$90,300
Equipment structural support
Pump station 1 platform
Pump station 2 platform
1
1
$2,000
$4,000

$37,800
$3,500
$1,800
$14,000
$90,300

$2,000
$4,000
Electrical and process control
Power/equipment
Control/instrumentation
1
1
$68,400
$63,500
Subtotal
Temporary facilities (1%)
Spare parts (1.5%)
Engineering procurement and contract management (12%)
Commissioning (3%)
Owner team (10%)
Subtotal
Total direct and indirect costs
Contingency (20%)
Total Project Cost
$68,400
$63,500
$510,000
$6,300
$9,500
$75,800
$18,900
$63,100
$173,600
$804,900
$161,000
$965,900
                                                        9-75
-------
        Section 9 - Incremental Investment and Operating and
Table 9-14 (Continued)
II 750,000 gpd
|j Category
Major
II equipment
	
Installation












Item
Reactor clarifier
pH control tank
Acid/NaOH tanks
Pump station 1
Pump station 2
Clarifier pumps.
NaOH pumps
Acid pumps
Quantity
1
1
4
2
2
2
2
2 '.
Rate
$75,000
$23,500
$10,000
$5,500
$8,000
$3,500
$8,000
$2,200
Total freight
Subtotal
Cost
$75,000
$23,500
, $40,000
$11,000
$16,000
$7,000
$16,000
$4,400
$5,800
$198,700
Mechanical equipment installation |
Reactor clarifier
pH control tank
Acid/NaOH tanks
Pump station 1
Pump station 2
Clarifier pumps
NaOH pumps
Acid pumps
1
1
4
2
2
2
2
2
$162,000
$6,000
" $1,000
$2,000
$2,000
$2,000
$1,500
$2,000
$162,000 ||
$6,000 II
$4,000
$4,000
$4,000
$4,000
$3,000
$4,000
Piping installation
Piping/supports
Control valves/instrumentation
1
1
$113,300
$20,000
$113,300
. $20,000
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
leactor clarifier/overflow tank
Clarifier pumps
)H control tank
Acid/NaOH tanks and pumps
Equalization basin
1
1
1
1
1
$59,000
$3,500
$5,300
$14,000
. $257,700
$59,000
' $3,500
$5,300
$14,000
$257,700 1
9-76
-------
                 Section 9 - Incremental Investment and Operating and
                        Maintenance Costs for Proposed Regulation
Table 9-14 (Continued)
750,000 gpd
Category
Installation
(cont.)


Indirect costs
Total costs
Category
Major
equipment
Item
Quantity

Rate
Equipment structural support
Pump station 1 platform
Pump station 2 platform
1
1
$4,000
$8,000
Electrical and process control
Power/equipment
Control/instrumentation
1
1
$68,400
$63,500
Subtotal
Temporary facilities (1%)
Spare parts (1.5%) ' "•
Engineering procurement and contract management (12%)
Commissioning (3%)
Owner team (10%)
Subtotal
Total direct and indirect costs .
Contingency (20%)
Total Project Cost 	 : 	
2,000,000 gpd
Item
Reactor clarifier
pH control tank
Acid/NaOH tanks
Pump station 1
Pump station 2
Clarifier pumps
NaOH pumps
Acid pumps
Quantity
I
1
4
2
2
2
• 2
2
Rate
$130,000
$47,400
-. $10,000
$9,000
$9,500
$5,500
$8,-500
$7,500
Total freight
Subtotal

Cost

$4,000
$8,000

$68,400
$63,500
$807,700
$10,100
$15,100
$120,800
$30,200
$100,600
$276,800
$1,283,200
$256,600
$1,539,800
1 . 5
Cost
$130,000
$47,400
$40,000
$18,000
$19,000
$11,000
$17,000
$15,000
$8,900
$306,300
            9-77
-------
                 Section 9 - Incremental Investment and Operating and
                	Maintenance Costs for Proposed Regulation
Table 9-14 (Continued)
2,000,000 gpd
Category
Installation








Item
Quantity
Rate
Cost
Mechanical equipment installation
Reactor clarifier
pH control tank
Acid/NaOH tanks
Pump station 1
Pump station 2
Clarifier pumps
NaOH pumps
Acid pumps
1
1
4
2.
2
2
2
2
$253,000
$12,000
$10,000
$2,500
$2,500
$1,500
$2,000
$2,000
$253,000
$12,000
$40,000
$5,000
$5,000
$3,000
$4,000
$4,000
Piping installation
Piping/supports
Control valves/instrumentation
1
1
$92,100
$63,500
$92,100
$63,500
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
Reactor clarifier/overflow tank
Clarifier pumps
pH control tank
Acid/NaOH tanks and pumps
Equalization basin
1.
1
1
1
1
$224,800
$7,000
$10,500
$17,500
$508,300
$224,800
$7,000
$10,500
$17,500
$508,300
Equipment structural support
Pump station 1 platform
Pump station 2 platform
1
1
$6,000
$8,000
$6,000
$8,000
Electrical and process control
Power/equipment
Control/instrumentation
1
1
$92,100
$63,500
Subtotal
$92,100
$63,500
$1,419,300
          9-78
-------
                 Section 9- Incremental Investment and Operating and
                        Maintenance Costs for Proposed Regulation
Table 9-14 (Continued)
2,000,000 gpd .
Category
Indirect costs
Total costs
Item Quantity Rate
Temporary facilities (1%)
Spare parts (1.5%)
Engineering procurement and contract management (12%)
.Commissioning (3%)
Owner team (10%)
Subtotal
Total direct and indirect costs
Contingency (20%)
Total Project Cost

Cost
$17,300
$25,900
$207,100
$51,800
$172,600
$474,700
$2,200,300
$440,100
$26,401,400
            9-79
-------
                                                    « ^;
                                                    §3,
IT)

         
                                  2 E
                                               9-80
-------
                                   Section 9 - Incremental Investment and Operating and
                                   	Maintenance Costs for Proposed Regulation
                           Table 9-16

Estimated Investment Costs for Multimedia Filtration Systems
             (150,000 - 20,000,000 gallons per day)
150,000 gpd
Category'
Major
equipment
Installation
Item
Filters
Pump station 1
Pump station 2
Filter backwash pumps
Quantity
2
2
2
2
Rate
$100,000 .
$1,500
$2,200
$3,000
Total freight
Subtotal
Cost
$200,000
$3,000
$4,400
$6,000
$6,400
$219,800
Mechanical equipment installation
Filters
Pump station 1
Pump station 2 .
Filter backwash pumps
2
2
2
2
$11,000
. $1,500
$2,000
$1,500
$22,000
$3,000
$4,000
$3,000
Piping installation
Piping/supports
Control valves/instrumentation
1
1
$82,800
$14,600
$82,800
$14,600
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
Filtration plant
Sump 1
Filter backwash surge basin
1
1
1
$81,900
$19,000
$19,000
$81,900
$19,000
$19,000
Equipment structural support
Pump station 1 platform
Pump station 2 platform
Filter backwash pumps
1
1
1
$3,500
$4,000
$4,000 ,
$3,500
$4,000.-
$4,000
Buildings
Filtration plant
1
$24,500
$24,500
                              9-81
-------
                 Section 9 - Incremental Investment and Operating and
                	Maintenance Costs for Proposed Regulation
Table 9-16 (Continued)
150,000 gpd
Category
Installation
(cont.)
Indirect costs
Total costs
Item
Quantity
Rate
Cost
Electrical and process control
Power/equipment
Control/instrumentation
Building services
1
1
1
$43,600
$40,600
$5,100
Subtotal
Temporary facilities (1%)
. Spare parts (1.5%)
Engineering procurement and contract management (12%)
Commissioning (3%)
Owner team (10%)
Subtotal
Total direct and indirect costs
Contingency (20%)
Total Project Cost
• $43,600 .
$40,600
$5,100
$374,600
$6,000
$8,900
$71,300
$17,300
$59,400
$163,400
$757,800
$151,600
$909,400
500,000 gpd
Category
Major
equipment
Installation
Item
Filters
Pump station 1
Pump station 2
Filter backwash pumps
Quantity
2
2
2
2
Rate
$105,000
$5,000
$3,500
$5,000
Total freight
Subtotal
Cost
$210,000
$10,000
$7,000
$10,000
$7,100
$244,100
Mechanical equipment installation
Filters
Pump station 1
Pump station 2
Filter backwash pumps
2
2
2
2
$13,000
$2,000
$2,000
$1,500
$26,000
$4,000
$4,000
$3,000
           9-82
-------
                 Section 9 - Incremental Investment and Operating and
                	Maintenance Costs for Proposed Regulation
Table 9-16 (Continued)
500,000 gpd
Category
Installation
(cont.)

Indirect costs
Total costs
Item
Quantity
Rate
Piping installation
Piping/supports - ,
Control valves/instrumentation
1
1
$98,600
$17,400

Cost

$98,600
$17,400
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
Filtration plant
Sump 1
Filter backwash surge basin
1
1
1
$97,800
$22,000
$22,000
$97,800
$22,000
$22,000
Equipment structural support
Pump station 1 platform
Pump station 2 platform
Filter backwash pumps
1
1
1
$7,000
$4,000
$4,000
Buildings - '
Filtration plant
1
$28,000
$7,000
$4,000
$4,000

$28,000
Electrical and process control
Power/equipment
Control/instrumentation
Building services
1
1
1
$43,600
$40,600
$5,800
Subtotal
Temporary facilities (1%)
Spare parts (1.5%)
Engineering procurement and contract management (12%)
Commissioning (3%)
Owner team (10%)
Subtotal
Total direct and indirect costs
Contingency (20%)
Total Project Cost
$43,600
$40,600
$5,800
$427,800
$6,700
$10,100 .
$80,600
$20,200
$67,200
$184,800
$856,700
$171,300
$1,028,000
            9-83
-------
                 Section 9 - Incremental Investment and Operating and
                        Maintenance Costs for Proposed Regulation
Table 9-16 (Continued)
1 2,000,000 gpd
II Category
Major
I equipment
Installation










1
Item
Filters
Pump station 1
Pump station 2
Filter backwash pumps
Quantity
2
2
2
2
Rate
$107,500
$9,000
$1,500
$9,000
Total freight
Subtotal
Cost
$215,000
$18,000
$3,000
$18,000
$7,600
$261,600
Mechanical equipment installation
Filters
Pump station 1
Pump station 2
Filter backwash pumps
2
2
2
2
$12,000
$2,500
$1,500
$2,000
$24,000
$5,000
$3,000
$4,000
Piping installation
Piping/supports
Control valves/instrumentation
1
1
$161,400
$28,500
$161,400
$28,500
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
Filtration plant
Sump 1
Filter backwash surge basin
1
1
1
$212,300
$53,200
$53,200
$212,300
$53,200
$53,200
Equipment structural support
Pump station 1 platform
Pump station 2 platform
Filter backwash pumps
1
1
1
$10,500
$4,000
$8,000
$10,500
$4,000
.$8,000
Buildings
Filtration plant
1
$60,000
$60,000
Electrical and process control
Power/equipment
Control/instrumentation
Building services
1
1
1
$68,800
$44,400
$12,500
Subtotal
$68,800
$44,400
$12,500
$752,800
          9-84
-------
                 Section 9 - Incremental Investment and Operating and
                	Maintenance Costs for Proposed Regulation
Table 9-16 (Continued)
2,000,000 gpd
Category
Indirect costs
Total costs
Item
Quantity
Rate
Temporary facilities (1%)
Spare parts (1.5%)
Engineering procurement and contract management (12%)
Commissioning (3%) •
Owner team (10%)
Subtotal
Total direct and indirect costs
Contingency (20%)
Total Project Cost
Cost
$10,100
$15,200
$121,700
$30,400
$101,400
$278,800
$1,293,200
$258,600
$1,551,800
, 7,500,000 gpd
Category
Major
equipment .
Installation
Item
Filters .
Pump station 1 - . .
Pump station 2
Filter backwash pumps
Quantity
8
2
2
2
Rate
$107,500
$9,000
$5,000
$9,000
Total freight
Subtotal
Cost
$860,000
$18,000
$10,000
$18,000
$27,200
$933,200
Mechanical equipment installation
Filters
Pump station 1
Pump station 2
Filter backwash pumps
8
2
2
2
$12,000
$2,500
$2,000
$2,500
$96,000
$5,000
$4,000
$5,000
Piping installation
Piping/supports •
Control valves/instrumentation
1
1
$258,500
$45,600
$258,500
$45,600
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
Filtration plant
Sump 1
Filter backwash surge basin '
1
1
1
$337,200
$53,200
$53,200.
$337,200
$53,200
$53,200
          9-85
-------
                 Section 9 - Incremental Investment and Operating and
                	Maintenance Costs for Proposed Regulation
Table 9-16 (Continued)
7,500,000 gpd
Category
Installation
(cont.)
Indirect costs
Total costs
Item
Quantity
Rate
Cost
Equipment structural support
Pump station 1 platform
Pump station 2 platform
Filter backwash pumps
1
1
1
$10,500
$4,000
$8,000
$10,500
$4,000-
$8,000
Buildings
Filtration plant
1
$95,000
$95,000
Electrical and process control
Power/equipment
Control/instrumentation
Building services
1
1
1
$130,300
$63,500
.$19,800
Subtotal
Temporary facilities (1%)
Spare parts (1.5%)
Engineering procurement and contract management (12%)
Commissioning (3%)
Owner team*(10%)
Subtotal
Total direct and indirect costs
Contingency (20%)
Total Project Cost
$130,300
$63,500
$19,800
$1,188,800
$21,200
$31,800
$254,600
$63,700
$212,200
$583,500
$2,705,500
$541,100
$32,466,000
20,000,000 gpd
Category
Major
equipment
Item
Filters
Pump station 1
Pump station 2
Filter backwash pumps
Quantity
8
2
2
2
Rate
$107,500
$25,000
$5,000
$10,000
Total freight
Subtotal
Cost
$860,000
$50,000
$10,000
$20,000
$28,200
$968,200
           9-86
-------
                 Section 9 - Incremental Investment and Operating and
                        Maintenance Costs for Proposed Regulation
Table 9-16 (Continued)
20,000,000 gpd
Category
Installation
Indirect costs
Item
Quantity
Rate
Mechanical, equipment installation
Filters
Pump station 1
Pump station 2
Filter backwash pumps
8
2
2
2
$12,000
$4,000
$2,000
- $4,000
Piping installation
Piping/supports
Control valves/instrumentation
1
1 '
$417,300
$73,600

Cost

$96,000
• $8,000
$4,000
$8,000

$417,300
$73,600
Civil/structural (includes costs associated with site preparation and grading)
Equipment foundations
Filtration plant
Sump 1
Filter backwash surge basin
1
1
1
$466,700
$83,600
$83,600
$466,700
$83,600
$83,600
Equipment structural support
Pump station 1 platform
Pump station 2 platform
Filter backwash pumps
. 1
1
1
$14,000
$14,000
$10,000
Buildings
Filtration plant
1
$132,000
$14,000
$14,000
$10,000

$132,000
Electrical and process control
Power/equipment
Control/instrumentation
Building services
1
1
1
$177,100
$63,500
$27,500
Subtotal
Temporary facilities (1%) •
Spare parts (1.5%)
Engineering procurement and contract management (12%)
Commissioning (3%)
Owner team (10%)
Subtotal
$177,100
$63,500
$27,500
$1,678,900
$26,500
$39,700
$317,600
$.79,400
$264,700
$727,900
            9-87
-------
                 Section 9 - Incremental Investment and Operating and
                	Maintenance Costs for Proposed.Regulation
Table 9-16 (Continued)
20,000,000 gpd
Category
Total costs
Item
Total direct and indirect costs
Quantity

Rate

Contingency (20%)
Total Project Cost
Cost
$3,375,000
$675,000
$4,050,000
          9-88
-------
                                " Section 9 - Incremental Investment and Operating and
                               	Maintenance Costs for Proposed Regulation
                         Table 9-17

     Summary of Costs for the Cokemaking Subcategory
                 (in millions of 1997 dollars)
Option
BAT-1
BAT-2
BAT-3
BAT-4
PSES-1
PSES-2
PSES-3
PSES-4
Investment Cost
8.0
12.4
42.3
66.5
0
6.0
18.6
32.1
Operating and
Maintenance Cost
0.1
3.0
7.2
14.9 .
0.3
. 1.8
3.3
5.8
One-Time Cost
0.3
0.3
0.3
0.3
0.2
0.2
0.2
0.2
                         Table 9-18

      Summary of Costs for the IronmaMrig Subcategory
                 (in millions of 1997 dollars)
Options
BAT-1 and PSES-1
Investment Cost
25.8
Operating and
Maintenance Cost
2.7
One-Time Cost
0.7
                         Table 9-19

Summary of Costs for the Integrated Steelmaking Subcategory
                 (in millions of 1997 dollars)
Options
BAT-1 and PSES-1
Investment Cost
16.8
Operating and
Maintenance Cost
2.9
One-Time Cost
2.1
                           '9-89.
-------
                                           Section 9 - Incremental Investment and Operating and
                                          	Maintenance Costs for Proposed Regulation
                                   Table 9-20

                   Summary of Costs for the Integrated and
                    Stand-Alone Hot Forming Subcategory
                          (in millions of 1997 dollars)
Option
Investment Cost
Operating and
Maintenance Cost
One-Thne Cost
Carbon and Alloy Segment
BAT-1
PSES-1
115.3
0.3
16.1
0.1
1.0
0.1
Stainless Segment3 .
PSES-1
1.1
0.2
0.1
"No sites reported direct discharge of wastewater within the Stainless Segment.
                                  Table 9-21

            Summary of Costs for the Non-integrated Steelmaking
                        and Hot Forming Subcategory
                          (in millions of 1997 dollars)
. Option
Investment Cost
Operating and
Maintenance Cost
One-Time Cost
Carbon and Alloy Segment .
BAT-1
PSES-1 '
18.9
2.5
2.0
0.4
3.9
0.8
Stainless Segment
BAT-1
BAT-2
PSES-1
0.4
3.7
0
0.1
0.6
0
0.2
0.2
0.4
                                      9-90
-------
                                              Section 9 - Incremental Investment and Operating and
                                             	Maintenance Costs for Proposed Regulation •
                                     Table 9-22

             Summary of Costs for the Steel Finishing Subcategory
                            (in millions of 1997 dollars)
Option
Investment Cost
Operating and
Maintenance Cost
Carbon and Alloy Segment
BAT-1'
PSES-1
16.0
6.0
•2.5
1.2
One-Time Cost

1.6
0.8
Stainless Segment
BAT-1

16.4
4.0
(1.1)
0.2
0.8 '
0.4
( ) Indicates a cost savings.
                                     Table 9-23

            Summary of Costs for the Other Operations Subcategory
                            (in millions of 1997 dollars)
Option
Investment Cost
Operating and
Maintenance Cost
One-Time Cost
Direct Reduced Ironmaking Segment
BPT
a
a

Forging Segment

0
0
0.1
"Data aggregation or other masking techniques are insufficient to protect confidential business information.
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-------
                                                                 Section 10 - Pollutant Loadings
                                      SECTION 10

                               POLLUTANT LOADINGS

              This .section presents annual pollutant loading and removal estimates for the iron
and steel industry for each of the regulatory options in each subcategory.  EPA estimated the
pollutant loadings and removals from iron and steel sites to evaluate the effectiveness of the
treatment technologies, to estimate benefits gained from removing pollutants discharged from
sites, and to evaluate the cost-effectiveness of the regulatory options in reducing the pollutant
loadings. EPA defined baseline and post-compliance pollutant loadings as follows:

              •       Baseline loadings - Pollutant loadings in iron and steel wastewater being
                     discharged to surface water or through publicly owned treatment works
                     (POTWs) to surface water.

              «       Post-compliance loadings - Estimated pollutant loadings in iron and steel
                     wastewater after implementation of the proposed rule, also referred to as
                     treated loadings. EPA calculated these loadings assuming that all iron and
                     steel sites would operate wastewater treatment and pollution prevention
                     technologies equivalent to the technology option for which they have been
                     costed.                                .

              •       Pollutant removals - The difference between baseline loadings and post-
                     compliance loadings for each regulatory option.

              EPA estimated baseline and post-compliance pollutant loadings and the expected
pollutant removal for each subcategory and segment and each technology option presented in
Section 8. This section discusses the methodology that EPA used to estimate pollutant loadings
and presents the resultant estimated baseline and treated loadings and pollutant removals as
follows:

              •       Section 10.1 discusses the data sources that EPA used to estimate pollutant
                     loadings and removals;      ~      '

              »       Section 10.2 discusses the general methodology EPA used to estimate
                     pollutant loadings, including selecting pollutants considered for loadings
                     estimation and baseline and treatment effectiveness concentrations; and

              •       Sections 10.3 through 10.9 present the methodology used to estimate
                     pollutant loadings and the resulting pollutant reductions for each regulatory
                     option in each subcategory; and

              •       Section 10.10 presents the references used in this section.
                                          10-1
-------
                                                                Section 10 - Pollutant Loadings
 10.1
Sources and Use of Available Data
              EPA used data from several sources to estimate baseline and post-compliance
 pollutant loadings. These sources included EPA site visits and sampling episodes at iron and steel
 sites, responses to the Detailed and Short Surveys and the Analytical and Production Survey, and
 publicly available National Pollutant Discharge Elimination System (NPDES) and pretreatment
 permit application data. Section 3 discusses data sources used to develop this regulation in detail.
,10.1.1
Analytical Data Sources
              EPA used flow rate data from the industry surveys.  For pollutant concentration
 data, EPA-used industry-provided data from the industry survey and data from EPA's wastewater
 sampling program. EPA received self-monitoring data with individual data points for 1997 from a
 select group of sites that received the Analytical and Production Survey.  Other sites provided
 only summary self-monitoring data (a 1997 annual average).  EPA used publicly available permit
 application data where necessary (i.e., if self-monitoring or sampling data did not sufficiently
 represent operating conditions).
10.1.2
Calculation of Averages from Analytical Data
              For each site and pollutant of concern (POC) in the loadings analysis, EPA
calculated an average baseline pollutant concentration and an arithmetic long-term average (LTA)
concentration, discussed below. For the average baseline concentrations the Agency did not edit
the analytical data from EPA sampling episodes, self-monitoring data, or permit application data
prior to calculating averages. For the arithmetic LTA, EPA edited data as described in
Section 12.

              Baseline Analytical Data

              To calculate baseline concentrations, if a site provided both individual and
summary data for the same pollutant, the Agency used the individual data points instead of the
summary data.  If a site had sampling data in addition to self-monitoring data for the same
pollutant, EPA first averaged the sampling data and self-monitoring data and then averaged the
resulting averages. When combining sampling and self-monitoring data averages, EPA did not
eliminate any sampling data or self-monitoring data prior to averaging them, even if they were
duplicate samples (from the same day and sampling point). If only sampling data were available,
EPA averaged the results from the sampling trip. EPA used permit application data if no other
data were available.

              When sites provided self-monitoring individual data points for 1997, the Agency
calculated an arithmetic average of all the data. When sites provided industry self-monitoring
summary data (where results were already averaged), the Agency used those numbers. For permit
application data, sites monitored multiple times for some pollutants but only one time for other
pollutants.
                                          10-2
-------
                                                                 Section 10- Pollutant Loadings
              Depending on the data source, the Agency treated pollutant data below the sample
 detection-limit differently. With EPA sampling .data, when concentrations were below the sample
 detection limit, EPA used the reported sample detection limit as the concentration for that
 pollutant. With individual self-monitoring data, when concentrations were below the sample
 detection limit, the Agency used what the site reported as the sample detection limit. When sites
 provided summary data, EPA used the concentrations that the sites submitted, which could have
 been calculated by any method. .Of those sites that submitted summary data, 26 percent used the
 method detection limit as the concentration for that pollutant; 26 percent used the sample
 detection limit; 7 percent used one-half the method detection limit; 3 percent used one-half the
 sample detection limit; and 38 percent used zero. Using zero as the concentration for the
 pollutant estimated the minimum amount of the pollutant, and using the method or sample
 detection limit estimated the maximum amount

              Arithmetic LTA Analytical Data

              For model effluent pollutant concentrations, EPA calculated 1997 arithmetic LTAs
 from the same datasets used to calculate the LTAs and variability factors in Section 12. If
 concentrations of pollutants were below, the sample detection limit, EPA used the sample
 detection limit. The Agency used multiple sites' data for some options. In these cases, EPA first
 averaged the data for each site, and then averaged the sites averages with each other. EPA edited
 the data model effluent data sets as discussed in Section 12.
 10.2
Methodology
              EPA estimated pollutant loadings for all the sites in each subcategory, based on the
analytical data and flow rates obtained by EPA using me following equation:
              Load = Flow x Cone  x  8.345(10"6)
                                                      Ibs
                                                  gal •  (mg/L)
                                                   SW
                                                                    (10-1)
where:
              Load
              Flow
              Cone
              8.345(10-6)
              SW
                    Pollutant loading, Ibs/yr
                    Flow rate, gal/yr
                    Pollutant concentration, mg/L
                    Conversion factor, Ibs/gal and mg/L
                    Survey weight, available in Appendix A of this document.
             From the industry surveys, EPA determined which subcategories and segments
apply to each site based on the manufacturing operations in place.  EPA then estimated pollutant
loadings for the entire industry based on the survey weights developed for each facility.  For
baseline loadings, EPA used site-specific analytical and flow data representing each site's
treatment in place, as discussed below in 10.2.1. For treated loadings, EPA used the data
obtained for the treatment options, as discussed below in 10.2.2.
                                          10-3
-------
                                                                Section 10- Pollutant Loadings
              For each site, EPA determined which manufacturing operations in each
subcategory and segment generated wastewater and calculated pollutant loadings for each
operation. For example, for integrated steelmaking, one site could have one basic oxygen furnace
(EOF) and two continuous casting lines. In this case, EPA calculated the flow rate and pollutant
concentration for the EOF and casting lines separately and then summed them to calculate the
pollutant loading for the site and subcategory.

              EPA estimatedpollutant loadings for a subset of the POCs identified in Section 7.
From the list of POCs, EPA eliminated pollutants that were never found at concentrations above
the detection limit in the effluent for any site, by subcategory and segment. EPA used data from
the EPA sampling program and self-monitoring data; however, for many POCs (particularly
organic compounds), the only available data were from the EPA sampling program.

              If a POC was not detected in the baseline effluent at any site, EPA excluded it
from the loadings analysis. Table 10-1 lists the pollutants that were never detected in the effluent
at any site for each subcategory and segment. Because these pollutants were detected in the
untreated wastewater at multiple sites and passed all POC criteria, they remain POCs. While the
effluent data reflect current wastewater technology in place, POC criteria were developed with
raw wastewater data from EPA's sampling program and associated criteria for source water
screening (see Section 7). Because most sites have some technology in place, the baseline effluent
data are different from the data used for POC selection.

              EPA estimated both baseline and treated pollutant loadings for the iron and steel
industry for the base year 1997.  The Agency included sites (or operations) that operated during
the 1997 calendar year in the  cost and loadings analyses, using the following criteria:

              •      If a site operated at least one day during the 1997 calendar year;  and

              •      If a site (or operation) shut down after 1997.

If a site (or operation) commenced after 1997,  EPA did not include the site (or operation).

              For some sites, 1997 data did not represent normal operating conditions, and
alternate years' data were used according to the sites' choice of representative time. EPA was
aware that several sites had operated only part of 1997 because of strikes, shut-downs, or start-
ups.  For these sites, EPA used production, analytical, and flow rate data from years that the sites
indicated were representative of normal operations. If sites installed or significantly altered
wastewater treatment systems either during or after 1997, EPA used the data that represented
their current wastewater treatment configuration.

              EPA was aware of a unique case in which a site's self-monitoring data from 1997
conflicted with self-monitoring data from 1996 by an order of magnitude.  EPA contacted the site
and, at their direction, used three years of analytical data to better represent the treatment system
performance.                                                            ,
                                          10-4
-------
                                                                Section 10 - Pollutant Loadings
              Some sites co-treat their wastewater from multiple subcategories, as discussed in
Section 9. EPA evaluated entire co-treatment systems to determine what treatment improvements
were necessary. For'pollutant loadings, EPA had sufficient flow rate and analytical data to
calculate loadings and reductions for co-treated wastewaters by subcategory. However, the
Agency allocated four sites that co-treat their ironmaking, steelmaking, and/or hot forming
wastewaters flow reductions that were not standard for that subcategory, and considered them
individually.  For these sites, EPA assessed flow reductions for the entire co-treatment system, not
just for one subcategory, and determined the flow reduction attainable by each co-treatment
system on a case-by-case basis. The Agency then allocated pollutant loadings across
subcategories, based on the percentage of the co-treated flow generated by the manufacturing
operations.  .

              For indirect discharging options, EPA accounted for treatment at the POTW using
the following equation:
                Load = (1 - POTW % Removal) *  (Original Load)
                                                                     (10-2)
where:
              Original load

              POTW percent removal
                                  Pollutant loading from Equation 10-1, in
                                  Ibs/yr
                                  Mass-based percent removal, shown in Table
                                  10-2.
              The POTW percent removal values are based on data from the Fate_QfPrjorit£
Pollutants in Publicly Owned Treatment Works and National Risk Management Research
Laboratory (TSfRMRL) Treatability Database and are discussed in Section 11 (References 10-1 and
10-2).  The baseline and post-compliance pollutant loadings and associated removals for indirect
dischargers presented in this section represent removals of pollutants being discharged from
POTWs using the above equation.
10.2.1
Baseline Pollutant Loading Calculation
              EPA used flow rate and analytical data from each site's industry survey to estimate
the baseline loading, site by site and pollutant by pollutant, using Equation 10-3:
         Site Baseline Load =  Flow x Baseline Cone  x  8.345(10~6)
                                                                      Ibs
                                                                  gal •  (mg/L)
                                                                     (10-3)
                                          10-5
-------
                                                                  Section 10 -Pollutant Loadings
 where:
               Site Baseline Load   =
               Site Flow

               Baseline Cone =
               8.345(10-6)
       Baseline pollutant load discharged to surface water
       by a site, in Ibs/yr
=      Subcategory-specific process wastewater flow for
       site, reported in survey, gallons per year
Site baseline concentration, mg/L
=      Conversion factor, Ibs/gal and mg/L.
               In the industry survey, all sites reported flow rates and most sites reported baseline
 concentration data. Sites reported flow from operations in either gallons per minute or gallons
 per day, along with the corresponding days per year and hours per day, as necessary.  EPA used
 the flows as reported by the sites.  For pollutant concentrations, EPA used the analytical data
 included with the survey outfall data.

               Sites tend to monitor pollutants listed in their permits, and therefore did not
 monitor all the POCs for which pollutant loads were calculated. For pollutants where site-specific
 data were not available, EPA transferred data from sites with similar operations and treatment in
 place. EPA calculated an average baseline concentration for each pollutant in a subcategory to
 use as a data transfer. Where appropriate, EPA calculated an average baseline concentration for
 each type of site (e.g., those with biological treatment, metals precipitation, oil skimming). In
 some cases, EPA calculated an average baseline concentration by discharge type.  EPA excluded
 the analytical data from sites selected as the model treatment sites from the average baseline
 calculation. Data transfers for each subcategory are discussed later in this section.

               For some pollutant parameters, EPA performed  a logic check to ensure that
 average concentrations  of pollutants derived from different datasets or data transfers did'not
 violate certain rules. For example, many sites had self-monitoring data for oil and grease
 (measured as hexane extractable material), or O&G; however, they did not for total petroleum
 hydrocarbons (measured as silica gel treated hexane extractable material),  or TPH. EPA
'transferred average TPH data to fill the gap. In some cases, the data transfer concentration for
 TPH was greater than the self-monitoring concentration for O&G, which would be unnatural
 because TPH is a subset of O&G.  In these cases, EPA used the self-monitoring concentration for
 O&G as the concentration for TPH. The logic checks for data for each site included the
 following rules:

               •      Phenol could not have a concentration higher than total phenols;

               •      Amenable cyanide or weak acid dissociable (WAD) cyanide could not have
                     a concentration higher than total cyanide;

               •      TPH could not have a concentration higher than O&G; and

               •      Hexavalent chromium could not have a concentration higher than total
                     chromium.
                                           10-6
-------
                                                                      Section 10 - Pollutant Loadings
               If a rule was violated, EPA would adjust one concentration, always deferring to
 the site data.- EPA encountered the following data conflicts, and resolved them as shown below.
                 Conflict
                                               EPA Action
  The self-monitoring concentration for a bulk
  parameter is less than the data transfer
  concentration for a pollutant within the bulk
  parameter.
                          Use the self-monitoring concentration as the baseline concentration
                          for both the bulk parameter and the specific pollutant.
  The self-monitoring concentration for a
  pollutant within a grqup is greater than the
  data transfer concentration fora bulk
  parameter.
                          Use the self-monitoring concentration as the baseline concentration
                          for both the specific pollutant and the bulk parameter.
  From the EPA sampling data, the site
  concentration for total recoverable phenols is
  less than the site concentration for phenol (no
  self-monitoring data are available for either
  pollutant).	
                          The method for phenol is a gas chromatograph/mass spectrometry
                          (GC/MS) method. The method for total recoverable phenols is a
                          colorimetric method (Reference 10-1). The GC/MS is expected to
                          be more accurate than colorimetric; therefore, use the concentration
                          of phenol for both analyses.	•
               For each subcategory and segment, EPA multiplied the pollutant load for each site
by the survey weight and estimated the baseline load for each subcategory and segment using the
following equation:                                                      •
                    Baseline Load = ]T (Site  Baseline Load  x SW)                    (10-4)
where:
               Baseline Load        =

               Site Baseline Load   =

               SW
                             Industry baseline pollutant loading for each
                             subcategory, Ibs/yr
                             Baseline load as calculated for each site in Equation
                             .10-3, Ibs/yr
                             Survey weight, available in Appendix A of this
                             document.
               For indirect dischargers, the site's baseline load was adjusted by the POTW
percent removal, according to Equation 10-2.
10.2.2
Treated Pollutant Loading Calculation
               EPA estimated treated pollutant loadings using model PNFs and arithmetic LTAs
representing each option.  For each option, EPA selected the model PNF, as discussed in Section
7. For each option, EPA used the methodology for selecting sites, as discussed in Section 9.
Model effluent pollutant concentrations were then calculated from the model site(s) data, as
discussed in Section 10.1.2.

               Section 9 explains how EPA evaluated whether a site performed as well or better
than the model treatment technology for an option. EPA based'the calculation of treated loadings
                                             10-7
-------
                                                                 Section 10- Pollutant Loadings
on the costing decisions presented in Section 9. If a site performed as well or better than the
model site(s), pollutant loadings remained unchanged and no pollutant removals were calculated.
If the site did not perform as well as the model site(s), EPA estimated a treated load for the site,
based on the reduced PNF and/or upgrade to technology in place.

              To improve wastewater treatment, EPA allocated costs to sites for the following
scenarios:  1) install or improve wastewater treatment to reduce effluent pollutant concentrations,
2) reduce wastewater flow rates through recycling or in-process controls, or 3) improve
wastewater treatment and reduce flow rates. Section 9 discusses decisions on wastewater
treatment costs.  These decisions directly affected EPA's estimates of treated pollutant loadings.
In scenario 1, EPA allocated costs to sites to improve wastewater treatment and set treated
pollutant concentrations equal to the option arithmetic LTAs.  In scenario 2, EPA allocated costs
to sites to reduce wastewater flow rates and set treated flow rates equal to model PNFs." In
scenario 3, both pollutant concentrations and flow rates were set equal to the model
concentrations and PNFs, respectively.

              In some cases with scenario  1, a site's baseline concentration for one pollutant was
lower than the arithmetic LTA, but the rest of its pollutant concentrations were higher.  In these
cases, EPA allocated costs to the site for the necessary treatment technology, and if a site's
baseline concentration for a particular pollutant was less than the model concentration or flow
rate, EPA deferred to the lower number to calculate the treated load for that pollutant.

              When estimating pollutant load reductions associated with model treatment
technologies incorporating high-rate recycle (scenario 2), EPA used the following conventions:

              (1)     For pollutants that are removed or treated in the main recycle loop (e.g.,
                     total suspended solids (TSS), O&G, metals in particulate form),the
                     concentrations discharged in the blowdown flow were held constant. The
                     pollutant load reduction was assumed to be proportional to the reduction in
                     flow.

              (2)     For pollutants that are not removed through a treatment mechanism in the
                     main recycle loop (e.g., ammonia-N in blast furnace recycle systems,
                     dissolved substances), the mass loadings of those pollutants discharged
                     from the main recycle loop were held constant and the concentrations in
                     the reduced blowdown flow were assumed to increase in direct proportion
                     to the decrease in blowdown flow.

              The Agency believes this approach is somewhat conservative because it did not
account for incidental removals of certain pollutants such as ammonia-N associated with increased
recycle.
              EPA estimated treated pollutant loadings for each subcategory using the following
equation:
                                           10-8
-------
                                                                 Section 10- Pollutant Loadings
             Treated Load = PNF x PROD x DPY x CONC x 8.345(10'6}
                                   Ibs-
                                 gal-mg/L
(10-5)
 where:
               Treated Load =

               PNF
               PROD
               DPY
               CONC
               8.345(10'6)  '  =
Treated pollutant loading discharged to surface water by a
site, Ibs/yr
Model production normalized flow (PNF), gpt
Average production during 19971, tons/day
Number of days of operation in 19971, days/yr
Option arithmetic LTA, mg/L
Conversion factor, Ibs/gal and mg/L.
              For treated pollutant loadings for each option considered, EPA used arithmetic
 LTAs and model PNFs represented by the model treatment technology.  For model treatment
 system effluent concentrations, EPA used the arithmetic averages discussed in Section 10.1.2.
 For model PNFs, EPA used the PNFs presented in Section 7. EPA calculated an annual flow
 based on the PNF (either model PNF or the site PNF, depending on which was lower) and
 production.  EPA used the annual production and days per year reported in the  industry survey
 for-19'971.

              For each technology option considered, EPA could only calculate a pollutant
 reduction for those POCs that were treated by the option.  If the available monitoring data for an
 option did not demonstrate removal of a POC, then EPA did not calculate a reduction for that
 POC.  For example, treatment technologies in some subcategories were not designed to remove
 fluoride. For a site that was allocated a flow reduction, filtration, and a cooling tower, EPA did
 not calculate removal of fluoride. Instead, EPA used the site's baseline loading for fluoride as the
 post-compliance loading.  Subcategory-specific examples are presented later in this section.

              After determining a site's treated load, EPA multiplied the site load by the industry
 survey weight and estimated the treated load for each subcategory using  the following equation:
                   Treated Load  = ^ (Site Treated Load x SW)                    (10-6)
where:
              Treated Load        =

              Site Treated Load    =

              SW              •   =
      Industry-treated pollutant loading for each
      subcategory, Ibs/yr
      Treated load as calculated for each site in Equation
      10-5, Ibs/yr          '
      Survey weight, available in Appendix A of this
      document.                                '
'For some facilities, 1997 production data did not represent normal operating conditions, and alternate years' data were
used, as discussed in Section 10.2.
                                          10-9
-------
                                                                  Section 10- Pollutant Loadings
              The site's treated load was adjusted by the POTW percent removal for indirect
 dischargers, according to Equation 10-2.
 10.3
Pollutant Loadings for the Cokemaking Subcateftory
               EPA estimated the pollutant loadings for 22 by-product cokemaking sites: 14
 direct dischargers and eight indirect dischargers.  One by-product cokemaking site did not
 discharge wastewater. Sites with non-recovery cokemaking operations are zero discharge sites;
 therefore, EPA did not calculate pollutant loadings or removals for these sites. EPA estimated
 pollutant loadings for 41 of the 71 POCs, because the other POCs were not detected in baseline
 effluent.
 10.3.1
Baseline Pollutant Loadings
               EPA estimated baseline loadings for cokemaking using .the flow rates reported in
 the industry survey and used available site data (self-monitoring, sampling, or permit application
 data) for the baseline concentrations. All 22 sites in the pollutant loadings analysis had baseline
 concentration data for ammonia-N. Most sites also monitored for benzo(a)pyrene, biochemical
 oxygen demand (BOD), total cyanide, total recoverable phenolics, and total suspended solids
 (TSS). Several sites monitored for arsenic, benzene, and naphthalene. For all POCs other than
 ammonia, EPA used average baseline pollutant concentrations to fill data gaps.

               To estimate average pollutant concentrations, EPA examined technology in place:
 13 of the 14 direct dischargers had ammonia stills and biological treatment in place, and one site
 had an ammonia still followed by physical/chemical treatment (dephenolizer, sand filter, and
 clarifier). All of the eight indirect dischargers had ammonia stills, but three also had biological
 treatment. EPA  calculated an average baseline pollutant concentration for two types of sites:
 those with ammonia stills and biological treatment in place and those with just ammonia stills.  For
 many pollutants, particularly many of the priority organic constituents, the only data available
 were from EPA sampling episodes.

               For sites with just ammonia still treatment, EPA averaged ammonia still effluent
. data from sampling episodes at four cokemaking plants for the average baseline concentration.
 For sites with ammonia stills and biological treatment, EPA  averaged available data, including
 self-monitoring data for some pollutants and biological treatment effluent sampling data from
 three cokemaking plants for all pollutants.  (The fourth plant with sampling data was selected as
 one of two model sites, and its sampling and self-monitoring data were excluded from average
 data calculations). Table 10-3 presents the average baseline pollutant concentrations for both
 types of sites used for the 39 POCs with calculated loads.

               The direct discharger with physical/chemical treatment in place provided summary
 data for ammonia-N, benzene; benzo(a)pyrene, naphthalene, total cyanide, total recoverable
 phenols, and total suspended solids.  The concentrations of these pollutants were similar or higher
 than the average concentrations of poorly performing biological treatment sites. For the remainder
                                           10-10
-------
                                                               Section 10- Pollutant Loadings
of the pollutants, EPA used the data from sites with biological treatment in place because of
limited available data.

             The wastewater treatment systems at four direct discharging sites have treatment
technology in place similar to the BAT-1 model sites (see Section 8 for discussion of the
regulatory options).  These four sites recently upgraded their biological treatment, but no data
were available for the newly enhanced treatment system's. Based on the recent treatment
enhancements, EPA assumed the treatment technologies at these sites would perform as well as
the BAT model  technology.  For these sites, EPA did not take credit for any removals as a result
of the proposed  regulation.

             Using the site baseline concentrations and flow rates in Equations 10-3 and 10-4,
EPA calculated pollutant loadings for the Cokemaking Subcategory. For indirect dischargers,
EPA adjusted the pollutant loadings using POTW percent removals and Equation 10-2.
10.3.2
• Treated Pollutant Loadings
             EPA estimated treated pollutant loadings for the Cokemaking Subcategory using
the model PNFs and arithmetic LTAs.  Loads were estimated for the options presented in
Section 8. EPA estimated loading reductions based on the results of the costing analysis in
Section 9, for the four BAT model technologies listed in the table below.

        BAT Technology Options for By-Product Recovery Cokemaking Segment
Treatment Unit
Tar/oil removal
Equalization/ammonia still feed tank
Free and fixed ammonia still
Temperature control
Cyanide precipitation with sludge dewatering
Equalization tank •
Biological treatment with secondary clarification
Sludge dewatering
Alkaline chlorination (2-stage)
Mixed-media filtration
Granular activated carbon
BAT-1
•
•
•
•

•
•
•



BAT-2
•
•
•
•
•
•
•
•



BAT-3
•
•
•
•

•
•
•
•


BAT-4
•
•
•
•

•
•
•
•
•
•
             EPA used the arithmetic LTAs for BAT-1 to estimate treated pollutant loadings.
For most pollutants, the treated pollutant loadings for BAT-2, BAT-3, and BAT-4 are the same
as BAT-1 because the model technologies are equivalent to BAT-1 with add-on technologies.
For example, BAT-2 is equivalent to BAT-1 with the addition of cyanide precipitation. EPA used
the arithmetic LTA of the BAT-2 site for total cyanide and used the BAT-1 arithmetic LTA for
                                         10-11
-------
                                                             Section 10- Pollutant Loadings
the remaining POCs. EPA followed this same procedure for all the options.  For BAT-3, EPA
used the model arithmetic LTA for total cyanide, ammonia-N, and total recoverable phenols from
the BAT-3 model site and used BAT-1 LTAs for all the other POCs.  For BAT-4, EPA used the
model arithmetic LTAs for mercury and TSS and used BAT-3 LTAs for all other POCs. Table
10-4 lists the arithmetic LTAs used to calculate load for all options for this subcategory.

             PSES options for by-product cokemaking are structured similarly to the BAT
options. Options were add-on technologies to PSES-1, as shown in the table below.

        PSES Technology Options for By-Product Recovery Cokemaking Segment
Treatment Unit
Tar/oil removal
Equalization/ammonia still feed tank
Free and fixed ammonia still
Temperature control
Cyanide precipitation with sludge dewatering
Equalization tank
Biological treatment with secondary clarification
Sludge dewatering
Alkaline chlorination (2-stage)
Multimedia filtration "
PSES-1
•
•
•







PSES-2
•
•
•

•




•
PSES-3
•
•
•
•

•
•
•


PSES-4
•
•
•
•

•
•
•
•

             The PSES-3 and PSES-4 options are equivalent to BAT-1 and BAT-3,
respectively. For PSES-1 and PSES-2, the data from the model sites demonstrated removal of
only the following POCs considered for regulation, though many others are treated.
Option
PSES-1
PSES-2
POCs Treated By the Option
Ammqnia-N
Chemical oxygen demand (COD)
Total cyanide
Ammonia-N
Chemical oxygen demand (COD)
Total cyanide
Total suspended solids (TSS)
                                       10-12
-------
                                                                 Section 10 - Pollutant Loadings
              In cases where EPA's data indicates that a POC was not treated by the option,
 EPA used the site's baseline concentration. Table 10-4 presents the arithmetic LTAs used to
 calculate loads for all technology options for cokemaking.                        .

              EPA used the model PNFs presented in Section 7 for post-compliance flow rates,
 when sites were identified as above the regulatory PNF. EPA calculated a flow reduction for sites
 identified in Section 9 as receiving flow reductions. The Agency estimated flow reductions for
 three direct discharging sites: two for reduced control water volume and one for reduced steam
 volume at the ammonia still. (EPA assumed the reduced steam volume based on the installation
 of biological treatment at the site, which would allow for a higher ammonia still effluent
 concentration from the still and less steam use). For indirect dischargers, EPA did not estimate
 any flow reductions. The flow reduction for direct dischargers was 1.6 million gallons for the
 year, a 5 percent reduction.

              EPA estimated that the three sites with flow reductions would still achieve the
 model LTAs.  For the two sites with control water flow reductions, EPA determined that the sites
 would also require enhanced biological treatment, as discussed in Section 9. These sites are
 expected to meet the arithmetic LTA even with flow reductions, because their treatment
 configuration would resemble the model sites. The model sites achieve the arithmetic LTAs using
 control water at volumes equal to or less than-the regulatory control water volume.

              Similarly, the site with a reduced flow from ammonia still steam is expected to
 meet the arithmetic LTA. EPA allocated this site costs to install an entire biological treatment
 system that would resemble  the model sites, as discussed in Section 9.       '  •

              For four sites, EPA used the arithmetic LTAs as the sites' baseline concentrations,
 based on recent treatment system enhancements. These sites did not require flow reductions or
 treatment to lower effluent pollutant concentrations at BAT-1. At BAT-2, BAT-3, and BAT-4,
 these sites were allocated costs for improved treatment to lower pollutant effluent concentrations.

              Using the model arithmetic LTAs and PNFs in Equations 10-5 and 10-6, EPA
 calculated treated pollutant loadings for the Cokemaking Subcategory.  For indirect dischargers,
EPA adjusted the pollutant loadings using POTW percent removals and Equation 10-2. Pollutant
removals were calculated as  the difference between the treated and baseline loadings.

              The following tables summarize the baseline and post-compliance pollutant
loadings and associated removals for the By-Product Recovery Cokemaking Segment:

              •      Table 10-5 - Presents the baseline and post-compliance pollutant loadings,
                    in Ibs/yr, for all options for direct dischargers;

              ••    "  Table l'0-6 - Presents the baseline and post-compliance pollutant loadings,
                    in Ibs/yr, for all options for indirect dischargers;
                                         10-13
-------
                                                                 Section 10- Pollutant Loadings
                     Table 10-7 - Presents the pollutant removals, in Ibs/yr, for all options for
                     direct dischargers; and

                     Table 10-8 - Presents the pollutant removals, in Ibs/yr, for all options for
                     indirect dischargers.
10.4
Pollutant Loadings for the Ironmaking Subcategory
              EPA estimated loadings for the 15 ironmaking sites that generate and discharge
process wastewater. The remaining sites are zero dischargers, because they use dry air pollution
control, they use their wastewater to slag quench, or both.  One of the sites that discharges its
wastewater to slag quench was allocated costs to treat dioxins/furans but was not included in the
loadings analysis. In 1997, this site was a zero discharger, but to comply with the proposed
regulation, it would have a small, intermittent discharge stream. For wastewater streams from
blast furnace operations, EPA estimated pollutant loadings for 25 of the 27 POCs. For those
from sintering operations, EPA estimated pollutant loadings for 43 of the 65 POCs.
10.4.1
Baseline Pollutant Loadings
             •EPA estimated baseline concentrations using the flow rates reported in the industry
survey and used available site data (self-monitoring, sampling, or permit application data) for
baseline concentrations.  Fourteen of the 15 sites had baseline concentration data (self-monitoring,
sampling, or permit application data) for lead, total cyanide, total phenols, TSS, and zinc.
Thirteen had baseline concentration data for ammonia-N, and three had data for iron.  One site
with blast furnace wastewaters did not provide monitoring data, and EPA had no sampling data
for that site. EPA used average baseline concentrations to fill data gaps for all POCs that sites did
not monitor.

             For sintering, EPA used primarily sampling data to fill data gaps. Sampling data
were available for one site with sintering operations.  EPA used the average POC concentrations
of the sampling data as the average baseline concentration for sintering wastewaters.

             For blast furnace ironmaking, EPA also used primarily sampling data to fill data
gaps. Sampling data were available for two sites.  One of the sites is located in Canada, and EPA
used the data from this site to estimate average pollutant concentrations because the data are
representative of blast furnace ironmaking wastewaters. EPA excluded the Canadian site from the
remainder of the loadings analysis because it is outside the scope of this proposed U.S. regulation.

             For both direct and indirect dischargers with blast furnace wastewaters, EPA used
sampling data from the two sites for the average baseline concentration.  Section 10.1.2 describes
how EPA calculated the average. Tables 10-9 and 10-10 present sintering and blast furnace
average baseline pollutant concentrations,  respectively, used for POCs with calculated loads.

             The wastewater treatment systems  at one direct discharging site has treatment
technology in place similar to the BAT-1 arithmetic LTAs, but does not have high-rate recycle in
                                          10-14
-------
                                                                Section 10 - Pollutant Loadings
place.  The site recently upgraded treatment for blast furnace wastewaters, but no data were
available for this treatment system.  Based on the treatment in place, EPA used the baseline data
from sites representing model treatment for BAT-1 to estimate the pollutant loadings for this site.
The site was still allocated flow reduction technology.
10.4.2
Treated Pollutant Loadings
              EPA estimated treated pollutant loadings for the Ironmaking Subcategory using
the model PNFs and arithmetic LTAs.  Loadings reductions were based on the results of the
costing analysis in Section 9. EPA estimated loads for the options presented in Section 8, as
summarized in the table below:

                    Technology Options for Ironmaking Subcategory
Treatment Unit
Clarifier
Sludge dewatering
Cooling tower
(blast fiirnace only)
High-rate recycle
BAT-1
•
•
•
•
PSES-1
•
•
•
•
Slowdown treatment
Metals precipitation
Alkaline chlorination
(2-stage)
Multimedia filtration
•
•
•
•


              The model site selected to represent the option technology provided analytical data
for ammonia-N, total cyanide, and phenol. For the arithmetic LTAs for the remaining POCs, EPA
selected a site that had all other treatment units in place except alkaline chlorination (clarifier,
cooling tower, high-rate recycle, metals precipitation, and multimedia filtration). For PSES-1,
EPA selected one site to represent the model effluent .treatment technology. For the 12 sites with
Clean Water Act 301(g) variances for ammonia and phenol discussed in Section 9, EPA used the
sites' baseline concentration for these two pollutants to calculate treated loadings. Tables 10-11
and 10-12 present the arithmetic LTAs used to calculate loads for all technology options
considered.

            . The one site that did not provide monitoring data was allocated a flow reduction,
but not treatment upgrades because it had sufficient treatment technology in place. EPA used
data from the site representing the option for baseline concentrations. These same pollutant
concentrations were used to calculate the treated loading but with the lower regulatory PNF.
                                          10-15
-------
                                                                 Section 10- Pollutant Loadings
              EPA used the model PNFs presented in Section 7 for post-compliance flow rates
but only for sites that were allocated flow reductions in the costing analysis.  EPA assessed flow
reductions for four direct dischargers with co-treatment systems for ironmaking, steelmaking,
and/or hot forming wastewaters based on the flow reduction for the entire co-treatment system
and the percentage of the co-treated flow generated by the manufacturing operations. Overall
flow reduction was 6 percent.

              The following tables summarize the baseline and post-compliance pollutant
loadings and associated removals for the Ironmaking Subcategory:

              •      Table 10-13 - Presents the baseline and post-compliance pollutant loadings,
                     in Ibs/yr, for all options for direct and indirect dischargers; and

              •      Table 10-14 - Presents the pollutant removals, in Ibs/yr, for all options for
                     direct and indirect dischargers.
10.5
Pollutant Loadings for the Integrated Steelmaking Subcategorv
              EPA estimated loadings for the 21 discharging sites with integrated steelmaking
operations. This subcategory includes the following operations: basic oxygen furnace (EOF)
steelmaking, vacuum degassing, and continuous casting.  Of the 21 discharging sites, some
generate wastewater from all three operations, and some only from continuous casting. EPA
considered BOF, vacuum degassing, and continuous casting wastewater streams separately for
each site.  EPA estimated pollutant loadings for 26 of 28 POCs for the Integrated Steelmaking
Subcategory, because the other POCs were not detected in baseline effluent.
10.5.1
Baseline Pollutant Loadings
              EPA estimated baseline loadings for the Integrated Steelmaking Subcategory using
the flow rates reported in the industry survey and used available site data (self-monitoring,
sampling, or permit application data) for the baseline concentrations. Ten of the 21 sites did not
provide monitoring data, and EPA had no sampling data for these sites. The remaining 11 sites all
provided self-monitoring data for lead and zinc. Several sites provided self-monitoring data for
the following pollutants: aluminum, cadmium, TPH (measured as silica gel treated hexane
extractable material (SGT-HEM)), and TSS. For all POCs that sites did not monitor, EPA used
average baseline concentrations to fill data gaps.

              EPA calculated the average baseline concentration using sampling'data and self-
monitoring data for the direct dischargers. Except for the pollutants listed in the above
paragraph, EPA used sampling data to calculate an average baseline concentration.  Sampling
data were available for three sites, all with BOF, vacuum degassing, and continuous casting
operations. Table 10-15 presents the average baseline pollutant concentrations used to fill data
gaps for the POCs with calculated loads.
                                          10-16
-------
                                                                Section 10- Pollutant Loadings
              Two sites, a direct discharger and the indirect discharger, had similar treatment
 technology in place compared to the model site and are expected to treat pollutants to
 concentrations similar to the arithmetic LTAs.  EPA assumed the treatment technologies at these
 sites would perform as well as the option technology. For these sites, EPA did not take credit for
 any removals as a result of the proposed regulation.
 10.5.2
Treated Pollutant Loadings
              EPA estimated treated pollutant loadings for integrated steelmaking sites using the
model PNFs and arithmetic LTAs. Loadings reductions were based on the results of the costing
analysis in Section 9. Loads were estimated for the options presented in Section 8: BAT-1 and
PSES-1 (where BAT-1 = PSES-1).  The table below summarizes the options.

               Technology Options for Integrated Steelmaking Subcategory
Treatment Unit
Classifier (EOF only)
Scale pit with oil skimming
(continuous casting only)
Clarifier
Sludge dewatering
Multimedia filtration2 (continuous casting
only)
Cooling tower (vacuum degassing and
continuous casting)
High-rate recycle
BAT-1
•
•
•
•
•
•
•
PSES-1
•
•
•
•
•
•
•
Slowdown treatment
Metals precipitation
•
•
           a May be used in recycle circuit or as blowdown treatment.

             The available data from the site selected to represent the option did not
demonstrate removals of the following POCs in the loadings analysis: arnmonia:N, nitrate/nitrite,
and phenol. For these POCs, EPA used the site's baseline concentration for the post-compliance
loading calculation.  For all other POCs, the treatment train was expected to provide treatment.
Table 10-16 presents the proposed arithmetic LTAs used to calculate loads for the Integrated
Steelmaking Subcategory.

             EPA used the model PNFs presented in Section 7 for post-compliance flow rates
but only for sites that were  allocated flow reductions in Section 9.  Seventeen direct dischargers
were allocated flow reductions. EPA assessed flow reductions for four direct dischargers with
cortreatment systems for iroranaking, steelmaking, arid/or hot forming wastewaters based on the
                                         10-17
-------
                                                                  Section 10 - Pollutant Loadings
flow reduction for the entire co-treatment system and the percentage of the co-treated flow
generated by the manufacturing operations. The overall flow reduction was 83 percent.

              The following tables summarize the baseline and post-compliance pollutant
loadings and associated removals for the Integrated Steelmaking Subcategory:

              •      Table 10-17 - Presents the baseline and post-compliance pollutant loadings,
                     in Ibs/yr, for all options for direct and indirect dischargers; and

              •    •  Table 10-18 - Presents the pollutant removals, in Ibs/yr, for all options for
                     direct and indirect dischargers. •
10.6
Pollutant Loadings for the Integrated and Stand-Alone Hot Forming
Subcategorv
              EPA estimated loadings for the 51 carbon and alloy steel and three stainless steel
sites that generate and discharge process wastewater.  Loads calculations were based on data
from the surveyed sites: 36 carbon and alloy steel and two stainless steel. For carbon and alloy
steel sites, 32. surveyed sites discharge directly and one site discharges indirectly. For stainless
steel sites, two surveyed sites discharge indirectly. EPA estimated pollutant loadings for all POCs
for the Carbon and Alloy Steel Segment and all POCs for the Stainless Steel Segment.
10.6.1
Baseline Pollutant Loadings
              EPA estimated baseline loadings for integrated and stand-alone hot forming sites
using the flow rates reported hi the industry survey and used available site data (self-monitoring,
sampling, or permit application data) for the baseline concentrations. Twenty-four of the sites did
not provide monitoring data, and EPA had no sampling data for these sites. Neither of the two
stainless sites provided analytical data. Fourteen carbon and alloy steel sites provided self-
rnonitoring data: one indirect discharger and  13 direct dischargers.  Most of the sites monitored
for TSS and COD; several monitored for iron, lead, and total recoverable phenolics. For all POCs
that sites did not monitor, EPA used average baseline concentrations to fill data gaps.

              EPA calculated the average baseline concentration using sampling data and self-
monitoring data for the direct dischargers.  Except for COD, TSS, and several metals listed in the
above paragraph, EPA used sampling data to calculate an average baseline concentration.
Sampling data were available for four sites: three direct discharging carbon and alloy steel sites
and one direct discharging specialty site. Tables 10-19 and 10-20 present the average baseline
pollutant concentrations used to fill data gaps for the POCs with calculated loads for the Carbon
and Alloy Steel and Stainless Steel Segments, respectively.

              One of the sampled sites is located in Canada, and EPA used the data from the
Canadian site to estimate average pollutant concentrations because it represents hot forming
wastewater characteristics. The site was not included in the loadings analysis, because it is
outside the scope of this proposed U.S. regulation.
                                          10-18
-------
                                                                  Section 10-'Pollutant Loadings
  10.6.2
Treated Pollutant Loadings
               EPA estimated treated pollutant loadings for integrated and stand-alone hot
  forming sites using the model PNFs and arithmetic LTAs. Loadings reductions were based on the
  results of the costing analysis in Section 9.  Loads were estimated for the options presented in
  Section 8: BAT-1 and PSES-1 (where BAT-1 = PSES-1) for both carbon and alloy steel and
  stainless steel. The model technology for stainless steel in the Integrated and Stand-Alone Hot
  Forming Subcategory is identical to non-integrated steelmaking and hot forming for stainless  '
  steel. EPA transferred the stainless steel arithmetic LTAs  from non-integrated steelmaking and
  hot forming.  The table below summarizes the options.

       Technology Options for Integrated and Stand-Alone Hot Forming Subcategory
                    Carbon and Alloy Steel and Stainless Steel Segments
Treatment Unit
Scale pit with oil skimming
Roughing clarifier with oil removal
Sludge dewatering
Cooling tower
Multimedia filtration*
High-rate recycle
BAT-1
•
•
•
•
•
•
PSES-1
•
•
•
•
•
•
Slowdown treatment - . '
Multimedia filtration3
•
•
                    May be used m recycle circuit or as blowdown treatment

              For carbon and alloy steel options BAT-1 and PSES-1, the available data did not
demonstrate removals of ammonia-N or fluoride. For stainless steel options BAT-1 arid PSES-1,
the available data did not demonstrate removal of fluoride. EPA used the site's baseline
concentration for these POCs for the post-compliance loading calculation.  For all other POCs,
the treatment train was expected to provide treatment and arithmetic LTAs were used.  Tables
10-21 and 10-22 present the arithmetic LTAs used to  calculate loads for carbon and alloy steel
and stainless steel, respectively, for all technology options considered.

            .  EPA used the model PNFs presented in Section 7 for post-compliance flow rates,
but only for sites allocated a flow reduction.  For carbon and alloy steel sites, direct dischargers
were allocated an .overall flow reduction of 84 percent, and indirect dischargers were allocated an
overall flow reduction of 74 percent.  Flow reductions for four of the direct disphargers are from
sites with co-treatment system's for ironmaking, steelmaking, and/or hot forming wastewaters.
For these four sites, EPA estimated a flow  reduction for the entire  co-treatment system and then
allocated the subcategory-specific portion of the reduction based on the flow generated by the
                                         10-19
-------
                                                                 . Section 10- Pollutant Loadings
manufacturing operations. EPA allocated the indirect stainless steel dischargers an overall flow
reduction of 90 percent.

              The following tables summarize the baseline and post-compliance pollutant
loadings and associated removals for the Integrated and Stand-Alone Hot Forming Subcategory:

              .      Table 10-23 - Presents the baseline and post-compliance pollutant loadings,
                     in Ibs/yr, for all options for direct dischargers in the Carbon and Alloy Steel
                     Segment;

                     fable 10-24 - Presents the baseline and post-compliance pollutant loadings,
                  •   in Ibs/yr, for all options for direct dischargers in the Stainless Steel
                     Segment;

              •      Table 10-25 - Presents the baseline and post-compliance loadings, in Ibs/yr,
                     for all options for indirect dischargers in the Carbon and Alloy Steel
                     Segment;

              •      Table 10-26 - Presents the baseline and post-compliance loadings, in Ibs/yr,
                     for all options for indirect dischargers in the Stainless Steel Segment;

                     Table 10-27 - Presents the pollutant removals, in Ibs/yr, for all options for
                     direct dischargers in the Carbon and Alloy Steel Segment;

                     . Table  10-28 - presents the pollutant removals, in Ibs/yr, for all options for
                     direct dischargers in the Stainless Steel Segment;

                     Table 10-29 - presents the pollutant removals, in Ibs/yr, for all options for
                     indirect dischargers in the Carbon and Alloy Steel Segment; and

                     Table 10-30 - presents the pollutant removals, in Ibs/yr, for all options for
                     indirect dischargers in the Stainless. Steel Segment.
 10.7
Pollutant Loadings for the Non-Integrated Steelmaking and Hot Forming
Subcategorv
               EPA estimated loadings for the 54 carbon and alloy steel and 8 stainless steel sites
 that generate and discharge process wastewater from non-integrated operations.  The loads were
 based on data from sites that responded to the industry survey:  41 carbon and alloy and eight
 stainless steel. Thirty-one surveyed carbon and alloy steel sites discharge directly and 10
 discharge indirectly.  Five surveyed stainless steel sites discharge directly and three discharge
 indirectly.  EPA estimated pollutant loadings for the 10 POCs for the Carbon and Alloy Steel
 Segment and 21 of the 22 POCs for the Stainless Steel Segment.
                                            10-20
-------
                                                                 Section 10 -.Pollutant Loadings
10.7.1
Baseline Pollutant Loadings
              EPA estimated baseline loadings for non-integrated steelmaking and hot forming
sites using the flow rates reported in the industry survey and used available site data (self- •
monitoring, sampling, or permit application data) for the baseline concentrations.  Twenty-eight
of the surveyed sites did not provide monitoring data, and EPA had no sampling data for these
sites. Fifteen carbon and alloy steel and six stainless steel sites provided analytical .data. Most of
the sites monitored for chromium, copper, TPH (measured as SGT-HEM), iron, nickel, lead, and
zinc. Several monitored for aluminum, antimony, and molybdenum. For all POCs that sites did
not monitor, EPA used average baseline concentrations to fill data gaps.

              EPA calculated the average baseline concentration using sampling data and self-
monitoring data for the direct dischargers. Except for the pollutants listed in the above
paragraph, EPA used sampling data to calculate an average baseline concentration.  For the
Carbon and Alloy Steel Segment, EPA used data from one direct discharging site.  For the
Stainless Steel Segment, EPA used sampling data from two direct discharging specialty sites.
Tables 10-31 and 10-32 present the average baseline pollutant concentrations used to fill data
gaps for the POCs with calculated loads for carbon and alloy steel and stainless steel, respectively.
10.7.2
Treated Pollutant Loadings
              EPA estimated treated pollutant loadings for non-integrated steelmaking and hot
forming sites using the model PNFs and arithmetic LTAs.  Loadings reductions were based on the
results 0f the costing analysis in Section 9.  Pollutant loads were estimated for the options
presented in Section 8 shown in the table below.

          Technology Options for Non-Integrated Steelmaking and Hot Forming
                   Carbon and Alloy Steel and Stainless Steel Segments
Treatment Unit
Scale pit with oil skimming (continuous
casting and hot forming only)
Clarifier
Sludge dewatering
Cooling tower
Multimedia filtration3
High-rate recycle
BAT-1
•
•
•
•
•
•
BAT-2
•
•
•
•
•
•
PSES-1
•
•
•
•
•
•
Slowdown treatment
Metals precipitation"-11
Multimedia filtration3

•
•
•

•
        "May be used in recycle circuit or as blowdown treatment.
        bApplies to Stainless Steel Segment only.
                                          10-21
-------
                                                                  Section 10 - Pollutant Loadings
              For both the Carbon and Alloy Steel and Stainless Steel Segments, BAT-1 =
PSES-1. For carbon and alloy steel options BAT-1 and PSES-1, the available data did not
demonstrate removal of ammonia-N. For stainless steel BAT-1, BAT-2, and PSES-1, available
data did not demonstrate removals of the following POCs:  ammonia-N, nitrate/nitrite, and
fluoride. For these POCs, the site's baseline concentration was used for the post-compliance
loading calculation. For all other POCs, the treatment train was expected to provide treatment.
For stainless steel, BAT-2 = BAT-1 plus metals precipitation.  The BAT-2 model technology did
not achieve significantly better effluent quality based on the available data, and removals
calculated over BAT-1 are too small to be reflected in the aggregate loads tables in this section.
Tables 10-33 and 10-34 present the arithmetic LTAs used to calculate loads for the Carbon and
Alloy Steel and Stainless Steel Segments, respectively, for all technology options considered.

              For carbon and alloy steel sites, the following overall flow reductions were
achieved: 90 percent for direct dischargers, and 32 percent for indirect dischargers. For stainless
steel sites, the following overall flow reductions were achieved: 52 percent for direct dischargers,
and 89 percent for indirect dischargers.

              The following tables summarize.the baseline and post-compliance pollutant
loadings and associated removals for the Non-Integrated Steelmaking and Hot Forming
Subcategory:

              •       Table 10-35 - Presents the baseline and post-compliance pollutant loadings,
                     in Ibs/yr, for all options for direct dischargers in the Carbon and Alloy Steel
                     Segment;

             •       Table 10-36 - Presents the baseline and post-compliance pollutant loadings,
                     in Ibs/yr, for all options for direct dischargers in the Stainless Steel
                     Segment;

             •       Table 10-37 - Presents the baseline and post-compliance pollutant loadings,
                     in Ibs/yr, for all options for indirect dischargers in the Carbon and Alloy
                     Steel Segment;

             •       Table 10-38 - Presents the baseline and post-compliance pollutant loadings,
                     in Ibs/yr, for all options for indirect dischargers in the Stainless Steel
                     Segment;

             •       Table 10-39 - Presents the pollutant removals, in Ibs/yr, for all options for
                     direct dischargers in the Carbon and Alloy Steel Segment;

             •       Table 10-40 - Presents the pollutant removals, in Ibs/yr, for all options for
                     direct dischargers in the Stainless Steel Segment;
                                          10-22
-------
                                                                   Section 10 - Pollutant Loadings
                      Table 10-41 - Presents the pollutant removals, in Ibs/yf, for all options for
                      indirect dischargers in the Carbon and Alloy Steel Segment; and

                      Table 10-42 - Presents the pollutant removals, in Ibs/yr, for all options for
                      indirect dischargers in the Stainless Steel Segment.
 10.8
 Pollutant Loadings for the Steel Finishing Subcategory
               EPA estimated loadings for the 114 sites that generate and discharge process
 wastewater from steel finishing operations.  Loads were based on the 93 -sites that responded to
 the industry survey: 66 carbon and alloy steel and 27 stainless steel.  Forty-three surveyed carbon
 and alloy steel sites discharge directly and 23 discharge indirectly. Nineteen surveyed stainless
 steel sites discharge directly and 8 discharge indirectly. For each site, EPA considered process
 lines separately, including the following operations: acid pickling, alkaline cleaning, annealing,
 electroplating, hot dip cleaning, and cold forming. EPA estimated pollutant loadings for 30 POCs
 for the Carbon and Alloy Steel Segment and 35 POCs for the Stainless Steel Segment.
 10.8.1
Baseline Pollutant Loadings
               EPA estimated baseline loadings for steel finishing sites using the flow rates
reported in the industry survey and used available site data (self-monitoring, sampling, or permit
application data) for the baseline concentrations. Thirty-nine surveyed sites provided data
representative of steel finishing wastewaters: 18 direct dischargers for the Carbon and Alloy Steel
Segment; nine direct dischargers for the Stainless Steel Segment; 10 indirect dischargers for the
Carbon and Alloy Steel Segment; and two indirect dischargers for the Stainless Steel Segment.

               To fill data gaps, EPA calculated an average baseline concentration with sampling
and self-monitoring data.  EPA calculated averages for each segment, type of operation (cold
rolling, alkaline cleaning, acid pickling, etc.), and discharge type. EPA had sampling data for
three carbon and alloy steel direct dischargers, one carbon and alloy steel indirect discharger, and
two stainless steel direct dischargers. Tables 10-43 and 10-44 present the average baseline
pollutant concentrations for Carbon and Alloy Steel and Stainless Steel Segments, respectively,
used for data transfers for the POCs with calculated loads.
10.8.2
Treated Pollutant Loadings
              EPA estimated treated pollutant loadings for steel finishing using the model PNFs
and arithmetic LTAs. Loadings reductions were based on the results of the costing analysis in
Section 9.  Loads were estimated for the options presented in Section 8, as shown in the table
below.                             .
                                           10-23
-------
                                                               Section 10- Pollutant Loadings
                  Technology Options for Steel Finishing Subcategory
                  Carbon and Alloy Steel and Stainless Steel Segments
Treatment Unit
BAT-1
PSES-1
In-Process Controls
Countercurrent rinses
Recycle of fume scrubber water
Acid purification units
(stainless steel only)
•
•
•
•
•
•
Wastewater Treatment
Diversion tank
Oil removal
Hydraulic and waste loading
equalization
Hexavalent chromium reduction
Multiple-stage pH control for
metals precipitation
Clarification
Sludge dewatering
•
•
•
•
•
•
•
•
•
•
•
•
•
•
             EPA selected two sites to represent the BAT-1 and PSES-1 options for the
Carbon and Alloy Steel Segment and one site to represent BAT-1 and PSES-1 options for the
Stainless Steel Segment. For steel finishing technology options, available data did not
demonstrate removals of the following POCs in the loadings analysis, as shown below.
Segment
Carbon and Alloy Steel
Option
BAT-1 and PSES-1
Pollutants Treated By the Option
Acetone
alpha-Terpineol
Ammonia-N
Bis(2-ethylhexyl) phthalate
Fluoride
n-Dodecane
n-Hexadecane
Nitrate/nitrite
Total phenols
                                         10-24
-------
                                                                  Section 10- Pollutant Loadings
Segment
Stainless Steel
Option
BAT-landPSES-1
Pollutants Treated By the Option
Acetone
Ammonia-N
Hexanoic acid
n-Dodecane
n-Hexadecane
Total cyanide
Total phenols
              For these POCs, the site's baseline concentration was used for the post-compliance
loading calculation. For all other POCs, the arithmetic LTAs were used. Tables 10-45 and 10-46
present the arithmetic LTAs used to calculate loads for the Carbon and Alloy Steel and Stainless
Steel Segments, respectively, for all technology options considered.

              EPA estimated that the following overall flow reductions could be achieved for
carbon and alloy steel sites:  59 percent for direct dischargers, and 30 percent for indirect
dischargers. For stainless steel sites, the following overall flow reductions were achieved: 47
percent for direct dischargers, and 23 percent for indirect dischargers.

              The following tables  summarize the baseline and post-compliance pollutant
loadings and associated pollutant removals for the Steel Finishing Subcategory:

              »      Table 10-47 - Presents the baseline and post-compliance pollutant loadings,
                     in Ibs/yr, for all options for direct dischargers in the Carbon and Alloy Steel
                     Segment;

              « „     Table 10-48 - Presents the baseline and post-compliance pollutant loadings,
                     in Ibs/yr, for all options for direct dischargers in the Stainless Steel
                     Segment;

              «      Table 10-49 - Presents the baseline and post-compliance pollutant loadings,
                     in Ibs/yr, for all options for indirect dischargers in the Carbon and Alloy
                     Steel Segment;

              «      Table 10-50 - Presents the baseline and post-compliance pollutant loadings,
                     in Ibs/yr, for all options for indirect dischargers in the Stainless Steel
                     Segment;

              «      Table 1.0-51 - Presents the pollutant removals, in Ibs/yr.  for all options for
                     direct dischargers in the Carbon and Alloy Steel  Segment;
                                          10-25
-------
                                                                 Section 10 - Pollutant Loadings
                     Table 10-52 - Presents the pollutant removals, in Ibs/yr, for all options for
                     direct dischargers in the Stainless Steel Segment;

                     Table 10-53 - Presents the pollutant removals, in Ibs/yr, for all options for
                     indirect dischargers in the Carbon and Alloy Steel Segment; and

                     Table 10-54 - Presents the pollutant removals, in Ibs/yr, for all options for
                     indirect dischargers in the Stainless Steel Segment.
10.9
Pollutant Loadings for the Other Operations Subcategory
        •  '    EPA estimated loadings for the two DRI sites and eight forging sites that generate
and discharge process wastewater.  One DRI site discharges directly and one discharges
indirectly. Five forging sites discharge directly and three discharge indirectly.

              EPA did not have sufficient monitoring data to estimate pollutant loadings for
many of the POCs for the DRI Segment. Based on available data, EPA only had data to estimate
loadings for the three pollutants, aluminum, iron, and total suspended solids, for DRI sites. For
forging sites, EPA only had data to estimate loadings for O&G as HEM.

              The only pollutant loadings EPA calculated for forging indirect dischargers were
for O&G as HEM, which is a conventional pollutant.  Because POTWs are designed to treat
conventional pollutants, the removal of O&G as HEM is incidental, and BPT limits do not apply
to indirect dischargers.  Pollutant loadings and removals for the indirect dischargers in the forging
segment are not presented.
10.9.1
Baseline Pollutant Loadings
              EPA used site-specific data where available for baseline concentrations.  For POCs
that sites did not monitor, EPA used the average of available baseline concentration data.  Both
DRI sites provided data for the POCs for which loads were calculated, and no average baseline
concentration was calculated. EPA determined the average baseline concentration from the three
forging sites that provided data. Table 10-55 presents the average forging baseline pollutant
concentrations for the POCs for which loads were calculated.
10.9.2
Treated Pollutant Loadings
              EPA estimated treated pollutant loadings for the Other Operations Subcategory
using the model PNFs and arithmetic LTAs.' Loadings reductions were based on the results of the
costing analysis in Section 9. Loads were estimated for the options presented in Section 8 as
shown below.
                                          10-26
-------
                                                               Section 10 - Pollutant Loadings
                         Technology Options for DRI Segment
Treatment Unit
Classifier
Clarifier
Cooling tower
High-rate recycle
BPT
•
•
•
•
Slowdown treatment
Multimedia filtration
•
                        Technology Options for Forging Segment
Treatment Unit
High-rate recycle
BPT
•
Blowdown treatment
Oil/water separator
•
             For DRI, EPA selected one site to represent the model, effluent treatment
technology. For forging, EPA transferred an arithmetic average from the integrated and stand-
alone hot forming subcategory carbon and alloy segment. Tables 10-56 and 10-57 present the
arithmetic LTAs used to calculate BPT loads for the DRI and Forging Segments, respectively.

             The pollutant loadings and associated removals for DRI are not shown because
they contain confidential business information. Table 10-58 presents baseline and treated
pollutant loadings for forging direct dischargers; Table 10-59 presents removals. EPA did not
present loadings for the forging indirect discharging sites, because O&G does not pass through.
                                         10-27
-------
                                                               Section 10- Pollutant Loadings
10.10        References

10-1         U.S. Environmental Protection Agency. Fate of Priority Pollutants in Publicly
             Owned Treatment Works. EPA 440/1-82/303. Washington, D.C., September
             1982.

10-2         U.S. Environmental Protection Agency. National Risk Management Research
             Laboratory (MRMRD Treatability Database Version 5.0. Cincinnati, OH, 1994.

10-3         American Public Health Association, American Water Works Association, and
             Water Environment Federation. Standard Methods for the Examination of Water
             and Waste-water 19th Edition, Washington, D.C., 1995.
                                        10-28
-------
                                                                       Section 10 - Pollutant Loadings
                                         Table 10-1
            Pollutants of Concern Not Detected in Effluent at Any Site
 Subcategory
  Operation
           Type
                                                                          Pollutant
Cokemaking
By-Product
Cokemaking
Bulk conventional/
•nqnconventional pollutants
Silica gel treated hexane extractable
material (SGT-HEM)
                              Priority and nonconventional
                              volatile organic constituents
                                             Carbon disulfide
                                                            1,2-Dichloroethane
                                                            Ethylbenzene
                                                            m-Xylene
                                                              ..+ p-Xylene
                                                            o-Xylene
                                                            o- + p-Xylene
                              Priority and nonconventional
                              semivolatile organic constituents
                                             Acenaphthene
                                                            Acenaphthylene
                                                            Anthracene
                                                            Benzidine
                                                            2,3-benzofluorene
                                                            Benzo(ghi)perylene
                                                            Biphenyl
                                                            2-Butanone
                                                            Carbazole
                                                           . Dibenzothiophene
                                                            Fluorene
                                                            n-Hexadecane
                                                            Indeno( 1,2,3-cd)pyrene
                                                            4,5-Methylene phenanthrene
                                                            1 -Methylphenanthrene
                                                            alpha-Naphthylamine
                                                            beta-Naphthylamine

                                                            Perylene
                                             10-29
-------
                               Section 10- Pollutant Loadings
Table 10-1 (Continued)
Subcategory
Cokemaking
^___A \
(cont.j



Ironmaking






















Operation
By-Product
Cokemaking
(cont.)


Nonrecovery
Cokemaking
Blast Furnace
Ironmaking

Sintering




















Type
Priority and nonconventional
semivolatile organic constituents
(cont.)


NA -
Bulk conventional/
nonconventional pollutants
Dioxins and furans
Bulk conventional/
nonconventional pollutants
Priority and nonconventional
metals
Priority and nonconventional
volatile organic constituents









Dioxins and furans







Pollutant
2-Picoline
Styrene
Thianaphthene '
Toluene
NA
Silica gel treated hexane extractable
material (SGT-HEM)
1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin
Silica gel treated hexane extractable
material (SGT-HEM)
Silver
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Chrysene
n-Docosane
n-Eicosane
n-Hexadecane
n-Octadecane
Pyrene
n-Tetracosane
1,2,3,4,7,8-Heptachlorodibenzo-p-dioxin
1 ,2,3,4,7,8,9-Heptachlorodibenzofuran

1,2,3,4,7,8-Hexachlorodibenzo-p-dioxin
1,2,3,6,7,8-Hexachlorodibenzo-p-dioxin
1,2,3,7,8,9-Hexachlorodibenzo-p-dioxin
1,2,3,7,8,9-Hexachlorodibenzofuran
1,2,3,7,8-Pentachlorodibenzo-p-dioxin
         10-30
-------
                               Section 10'-Pollutant Loadings
Table 10-1 (Continued)
Subcategory
Ironmaking
(cont.)
Integrated
Steelmaking
Integrated and
Stand-Alone
Hot Forming
Non-Integrated
Steelmaking
and Hot
Forming
Non-integrated
Steelmaking
and hot
forming
Finishing
. Operation
Sintering
(cont.)
NA
Carbon and
Alloy Steel
Stainless Steel
Carbon and
Alloy Steel
Stainless Steel
Carbon and
Alloy Steel
Stainless Steel
Type
Dioxins and furans (cont.)
Priority and nonconventional
metals
NA .
NA
NA
Priority and nonconventional
volatile organic constituents
Priority and nonconventional
metals
Priority and nonconventional
volatile organic constituents
Priority and nonconventional
semivolatile organic
constituents
Priority and nonconventional
metals
Priority and nonconventional
volatile organic constituents


Pollutant
Octachlorodibenzo-p-dioxin
Octachlorodibenzofuran
Beryllium
Nickel
NA
NA
NA
Tribromomethane
Selenium
1,1,1 -Trichloroethane
Benzoic acid
N,N-Dimethylformamide
n-Eicosane
n-Octadecane
n-Tetradecane
Cadmium
Selenium
Vanadium
Ethylbenzene
Toluene
m-Xylene •
o- + p-Xylene
         10-31
-------
                                                                                 Section 10 - Pollutant Loadings
                                       Table 10-1 (Continued)
   Subcategory
  Operation
             Type
                                                                                     Pollutant
  Finishing
  (cont.)
Stainless Steel
(cont.)
Priority and nonconventional
semivolatile organic constituents
(cont)
                                                                     Benzoic acid
                                                                     2,6-Di-tert-butyl-p-benzoquinone
                                                                     n-Docosane
                                                                     n-Eicosane
                                                                     Naphthalene
                                                                     n-Octadecane
                                                                     2-Methylnaphthalene
                                                                     Phenol
                                                                     n-Tetracosane
                                                                     n-Tetradecane
  Other
  Operations
DRI
Priority and nonconventional
metals
                                                                     Titanium
Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Un to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewater Sampling Program, 1997-1999.

NA- No POCs were excluded for this segment                                                             .
                                                     10-32
-------
                                   Section 10 - Pollutant Loadings
            Table 10-2
POTW Percent Removal Efficiency
Pollutant
CAS
Number3
Percent
Removal
Data Source
Conventional and Classic Pollutants
Amenable cyanide
Ammonia-N (NH3-N)
BOD 5-day carbonaceous
Chemical oxygen demand (COD)
Fluoride
Hexane extractable material (HEM)
Nitrate/nitrite (NO2 + NO3-N)
Silica gel treated hexane extractable
material (SGT-HEM)
Thiocyanate
Total cyanide
Total Kjeldahl nitrogen (TKN)
Total organic carbon (TOC)
Total phenols
Total suspended solids (TSS)
Weak acid dissociable cyanide
C025
7664417
CG02
C004
16984488
C036
C005
C037
302045
57125
C021
C012
C020
C009
C042
93%
39%
. 91%
.•81%
54%
87%
90%
87%
70%
70%
90%
70%
77%
90%
93%
. Transfer from WAD cyanide
50-POTW Study - data > 1 0 x ML
Transfer from BOD5 (50-POTW Study - data >10 x
ML)
50-POTW Study - data >10 x ML
NRMRL Treatability Database (all wastewaters)
Used O&G percent removal (50-POTW Study - data
>10xML) ,
Transfer from TKN
Used O&G percent removal (50-POTW Study - data
>10 x ML) -
Transfer from total cyanide
50-POTW Study - data >10 x ML
Based on data from POTWs receiving iron and steel
wastewater
50-POTW Study - data > 1 0 x ML
50-POTW Study - data >10 x ML
50-POTW Study - data > 1 0 x ML
Based on data from POTW receiving iron and steel
wastewater
Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Chromium
Chromium, hexavalent
Cobalt
Copper
Iron
Lead
Magnesium .
Manganese
7429905
7440360
7440382
7440393
7440417
7440428
7440439
7440473
18540299
7440484
7440508
7439896
7439921
7439954
7439965
91%
67%
66%
55%
61%
24%
90%
80%
6%
10%
84%
82%
77%
14%
36%
50-POTW Study - data >10 x ML
50-POTW Study- data >2 x ML
50-POTW Study - data >2 x ML
50-POTW Study - data >2 x ML
NRMRL Treatability Database (industrial wastewater)
50-POTW Study - data >2 x ML
50-POTW Study - data >10 x ML
50-POTW Study - data >10 x ML
NRMRL Treatability Database (all wastewater)
50-POTW Study - data >2 x ML
50-POTW Study - data >10 x ML
50-POTW Study - data >10 x ML
50-POTW Study - data >10 x ML
50-POTW Study - data >10 x ML
50-POTW Study - data >10 x ML

              10-33
-------
                                Section 10 - 'Pollutant Loadings
Table 10-2 (Continued)

Pollutant
i
CAS
Number3

Percent
Removal
Data Source
Metals (continu^) 	 — 	 	 	
Mercury
Molybdenum
Nickel '
Selenium
Silver
Thallium
Tin
Titanium
Vanadium
Zinc
Organic Pollutants
2.4-Dimethylphenol
2-Methylnaphthalene
2-Phenylnaphthalene
alpha-Terpineol
Acetone
Aniline
Benzene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzyl alcohol
Bis(2-ethylhexyl) phthalate
Carbazole
Chrysene
Dibenzofuran
Fluoranthene
Hexanoic acid
n-Dodecane
n-Eicosane

n-Octadecane

o-Cresol 	 	
7439976
7439987
7440020
7782492
7440224
7440280
7440315
7440326
7440622
7440666
90%
19%
51%
34%
88%
54%
43%
92%
8%
79%
50-POTW Study - data >10 x ML
50-POTW Study - data > 1 0 x ML
50-POTW Study - data >10 x ML
NRMRL Treatability Database (domestic wastewater)
50-POTW Study - data >10 x ML
NRMRL Treatability Database (all wastewater)
50-POTW Study - data >2 x ML
50-POTW Study - data >1 0 x ML
50-POTW Study - data >2 x ML
50-POTW Study - data >10 x ML

105679
91576
612942.
98555
67641
62533
71432
56553
50328
205992
207089
100516
117817
86748
218019
132649
206440
142621
112403
112958
544763
593453
91203
95487
51%
28%
85%
94%
84%
93%
95%
98%
95%
95%
95%
78%
60%
62%
97%
98%
42%
84%
95%
92%
71%
71%
95%
53%
50-POTW Study - data >2 x ML
NRMRL Treatability Database (industrial wastewater)
Centralized Water Treaters (CWT) Project - no source
listed
NRMRL Treatability Database (industrial wastewater)
NRMRL Treatability Database (all wastewater)
NRMRL Treatability Database (all wastewater)
50-POTW Study - data >10 x ML
NRMRL Treatability Database (domestic wastewater)
NRMRL Treatability Database (all wastewater)
NRMRL Treatability Database (all wastewater)
NRMRL Treatability Database (all wastewater)
NRMRL Treatability Database (all wastewater)
50-POTW Study - data >10 x ML
CWT Project: Generic Removal Group: Anilines
NRMRL Treatability Database (domestic wastewater)
NRMRL Treatability Database (all wastewater)
50-POTW Study - data >2 x ML
NRMRL Treatability Database (all wastewater)
NRMRL Treatability Database (industrial wastewater)
NRMRL Treatability Database (industrial wastewater)
CWT Project: Generic Removal Group: n-Pariffins
CWT Project: Generic Removal Group: n-Pariffins
50-POTW Study - data >10 x ML
NRMRL Treatability Database (industrial wastewater)
           ,10-34
-------
                                                                                Section 10 - Pollutant Loadings
                                       Table 10-2 (Continued)
Pollutant
CAS
Number3
Percent
Removal
Data Source
Organic Pollutants (continued)
o-Toluidine
p-Cresol
Phenanthrene
Phenol
Pyrene
Pyridine
95534
106445
85018
108952
129000
110861
93%
72%
95%
95%
84%
95%
Transfer from aniline
NRMRL Treatability Database (industrial wastewater)
50-POTW Study- data >10x ML
50-POTW Study - data >10 x ML
NRMRL Treatability Database (domestic wastewater)
NRMRL Treatability Database (industrial wastewater)
Dioxins/Furans
2,3,7,8-TCDF
51207319
83%
Transfer from 1,2,3,4,6,7,8-HPCDF (Source: NRMRL)
"CAS Number denotes Chemical Abstract Service Number.

Sources: U.S. EPA's Fate of Priority Pollutants in Publicly Owned Treatment Works and U.S. EPA's NRMRL Treatability Database (References
10-1 and 10-2).     .                                                                           ,
                                                   10-35
-------
                                               Section 10- Pollutant Loadings
                          Table 10-3

Average Baseline Pollutant Concentrations Used for Data Transfers
                in the Cokemaking Subcategory
                By-Product Cokemaking Segment
Pollutant of Concern
Ammonia Still
Treatment Effluent
Concentration (mg/L)
Biological Treatment
Plant Effluent
Concentration (mg/L)
Conventional and Classic Pollutants
Total suspended solids
Hexane extractable material (HEM)
Ammonia-N
Nitrate/nitrite
Thiocyanate
Total cyanide
Amenable cyanide
Weak acid dissociable (WAD) cyanide
Total phenols
5-day (carbonaceous) biochemical oxygen demand (BOD3)
Chemical oxygen demand (COD)
Total organic carbon (TOC)
105
21.8
195
0.67
256
3.55 ,
1.59
0.975
270
1400
2640
798
46.1
5.04
49.1
41.5
8.44
5.12
1.26
0,081
0.176
66.4
437
• 36.6
Nonconventional Metals
Boron
0.376
0.253
Priority Metals
Arsenic
Mercury
Selenium
0.0497
0.002
0.827
0.0155
0.000270
0.476
Nonconventional Organic Constituents
Acetone
2-Methylnaphthalene
2-Phenylnaphthalene
Aniline
Dibenzoruran
n-Eicosane
n-Octadecane
o-Cresol
0.0547
0.0336
0.0677
2.93
0.0338
0.191
0.385
12.3
0.0506
0.0147
0.0102
0.0102
0.0101 .
0.0101
0.0101
0.012
                             10-36
-------
                                                                                    Section 10- Pollutant Loadings
                                         Table 10-3 (Continued)
Pollutant of Concern
Ammonia Still
Treatment Effluent
Concentration (mg/L)
Biological Treatment
Plant Effluent
Concentration (mg/L)
Nonconventional Organics (continued)
o-Toluidine
p-Cresol
Pyridine
0.276
71.4
0.159 -
0.0101
0.0102
0.0103
Priority Organics Constituents
Benzene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Fluoranthene •
Naphthalene
Phenanthrene
Pyrene . • • •
Phenol , • •
2,4-Dimethylphenol
0.0125
0.0687
0.0683
0.06.1 1
0.0429
0.0756 .
. • 0.0835
0.06
0.0554
0.066
158
1.77
0.00549
0.0101
0.00860
0.00806
0.00756
0.0103
0.0101
0.00763 ,
0.0101
0.0101
0.0319
0.0101
Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Up to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewater Sampling Program, 1997-1999.
                                                      10-37
-------
                                       Section 10 - Pollutant Loadings
                  Table 10-4

Proposed Arithmetic Long-Term Averages for the
           Cokemaking Subcategory
       By-Product Cokemaking Segment
Pollutant of Concern
Option
Arithmetic Long-Term
Average (mg/L) .
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material
(HEM)
Ammonia-N
Nitrate/nitrite
Thiocyanate
Total cyanide
Amenable cyanide


BAT-1, BAT-2, BAT-3
BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2
BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4 '
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1
BAT-2
BAT-3, BAT-4
PSES-1
PSES-2, PSES-3
PSES-4
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
96.1
5.65
a
.55.1
. 96.1
6.72
a
a
6.72
2.57
0.278
36.04
36.04
2.57
166
a
a
166
. 0.733
a
a
0.733
5.17
. 2.26
1.30
6.22
5.17
1.3.
0.977
a
a
0.977 •
                    10-38
-------
                               Section 10- Pollutant Loadings
Table 10-4 (Continued)
Pollutant of Concern
Option
Arithmetic Long-Term
Average (mg/L)
Conventional and Classic Pollutants (continued) ,
Weak acid dissociable (WAD)
cyanide
Total phenols
5-day (carbonaceous) biochemical
oxygen demand (BOD5)
.Chemical oxygen demand (COD)
Total organic carbon (TOC)
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2
BAT-3, BAT-4
PSES-1
PSES-2
PSES-3
PSES-3
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1 • .
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3,'BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
5.17
a
a ,
5.17
0.0629
0.0376
a
a
0.0629
0.0376
86.5
a
a
86.5
33.1
304
304
86.5
15.3
a
a
15.3
Nonconventional Metals • • ,
Boron
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4 :
.0.5
a .
a
0.5
Priority Metals
Arsenic
Mercury
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3
BAT-4
PSES-1
PSES-2
PSES--3, PSES-4
0.00753
a
a
0.00753
0.00025
0.00018
a
a
0.00025
         10-39
-------
                               Section 10- Pollutant Loadings
Table 10-4 (Continued)
Pollutant of Concern
Option
Arithmetic Long-Term
Average (mg/L)
Priority Metals (continued)
Selenium
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
0.109
a
a
0.109
Nonconventional Organic Constituents
Acetone
2-Methylnaphthalene
2-Phenylnaphthalene
Aniline
Dibenzofuran
n-Eicosane


n-Octadecane

•

o-Cresol



BAT-1, BAT-2, BAT-3,
BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3,
BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3,
BAT-4
PSES-1
PSES-2
PSES-3,- PSES-4
BAT-1, BAT-2, BAT-3,
BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3,
BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3,
BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3,
BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3,
BAT-4
PSES-1
PSES-2 '
PSES-3, PSES-4
0.05
a
a
0.05
0.0101
a
a
0.0101
0.0101
a
a
0.0101
0.0101
a '
a
0.0101
0.0101
a
a
0.0101
0.0101,
a
a
0.0101
0.0101
a
a
0.0101 .
0.0152
a
a
0.0152
         10-40
-------
                               Section 10- Pollutant Loadings
Table 10-4 (Continued)
Pollutant of Concern
Option
Arithmetic Long-Term
Average (mg/L)
Nonconventional Organic Constituents (continued)
o-Toluidine
p-Cresol
„•
Pyridine
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT- 1 , BAT-2, BAT-3; BAT-4
PSES-1
PSES-2
PSES-3, PSES-4 • 1.
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
0.0101 .
a
a
0.0101
0.0101
a
a
0.0101
0.0101
a
a
0.0101
Priority Organic Constituents
Benzene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluqranthene
Chrysene



BAT-1 .
PSES-1
PSES-2
PSES-3, PSES-4-
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2 ,
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3, BAT-4 .
PSES-1
PSES-2
PSES-3, PSES-4
B BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4 '
0.00183
a
• a
0.00183
0.0101
a
a
0.0101
0.0076
a
a
0.0076
0.0101
a
a
0.0101
0.0101
a
a
0.0101
0.0101
a
a
0.0101
         10-41
-------
                                                                                        Section 10 - Pollutant Loadings
                                           Table 10-4 (Continued)
Pollutant of Concern
Option
Arithmetic Long-Term
Average (mg/L)
Priority Organic Constituents (continued)
Fluoranthene
Naphthalene
Phenanthrene
Pyrene
Phenol . •!•
2,4-Dimethylphenol
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3,"PSES-4
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
BAT-1, BAT-2, BAT-3, BAT-4
PSES-1
PSES-2
PSES-3, PSES-4
0.0101
a
a
0.0101
0.0121
a
a
0.0121
0.0101
a
a .
0.0101
0.0101
a
a
o.oioi
0.0376
a
a
0.0376
O.O'l'Ol
a
a
0.0101
"Data for PSES-1 and PSES-2 model sites did not demonstrate removal of these pollutants. For the treated pollutant loading, EPA used the sites
baseline effluent concentrations.

Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Up to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastcwatcr Sampling Program, 1997-1999.                                            .
                                                         10-42
-------
                                               Section 10 - Pollutant Loadings
                           Table 10-5

Summary of Baseline and Post-Compliance Pollutant Loadings for the
        By-Product Cokemaking Segment Direct Dischargers
Pollutant Group
Total conventionals
Total priority metals
Total nonconventional metals
Total nonconventional organic
constituents
Total priority organic constituents
Total nonconventional other
Total cyanide
Chemical oxygen demand (COD)
Total organic carbon (TOC)
•Total phenols
Baseline -Load
(Ibs/yr)
2,310,000
7,900
7,710
. 3,500
4,880
2,710,000
61,400
4,660,000
448,000
1,630
Treated Load Discharged to Surface Water (Ibs/yr)
BAT-1
2,100,000 .
5,420
7,520
3,360
4,750
2,320,000
56,800
2,050,000
300,000
863
BAT-2
2,100,000
5,420
7,520
3,360
4,750
2,320,000
43,300
2,050,000
300,000
863
BAT-3
2,100,000
5,420
7,520
3,360
4,750
2,290,000
21,200
2,050,000
300,000
617
BAT-4
1,630,000
5,420
7,520
3,360
4,750
2,290,000
21,200
2,050,000
300,000
617
                          Table 10-6

Summary of Baseline and Post-Compliance Pollutant Loadings for the
       By-Product Cokemaking Segment Indirect Dischargers
Pollutant Group
Total conventionals
Total priority metals
Total nonconventional metals
Total nonconventional organic
constituents
Total priority organic constituents
Total nonconventional other
Total cyanide
Chemical oxygen demand (COD) '
Total organic carbon (TOC)
Total phenols ,
Baseline Load
(lbs/yr)
392,000
2,230
1,110
70,000
.20,100
460,000
7,240
1,490,000
658,000
158,000
Treated Load Discharged from POTW (lbs/yr)
PSES-1
392,000
2,230
1,110
,70,000
20,100
279,000
4,450
794,000
658,000
158,000
PSES-2
374,000
2,230
1,110
70,000
20,100
285,000
2,430
652,000
658,000
158,000
PSES-3
57,400
309
1,050
.112
72.0
14,500
.4,030
68,200
19,100
47.0
PSES-4
57,400
309
1,050
112
. 72.0
8,700
1,380
68,200
19,100
31.0
                             10-43
-------
                                                   Section 10- Pollutant Loadings
                              Table 10-7

  Summary of Pollutant Removals for the By-Product Cokemaking Segment
                          Direct Dischargers
Pollutant Group
Total conventionals
Total priority metals
Total nonconventional metals
Total nonconventional organic
constituents
Total priority organic constituents
Total nonconventional other
Total cyanide
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Total phenols
Pollutant Removals (Ibs/yr)
BAT-1
206,000
. 2,480
191
141
130
388,000
4,590
2,620,000
148,000
764
BAT-2
206,000
2,480
191
141
130
388,000
18,100
2,620,000
148,000
764
BAT-3
206,000
2,480
191
141
130
422,000
40,200
2,620,000
148,000
1,010
BAT-4
. 676,00
2,480
191
141
130
422,000
40,200
2,620,000
148,000
1,010
                              Table 10-8

Summary of Pollutant Removals for the By-Product Cokemaking Subcategory
                         Indirect Dischargers
Pollutant Name
Total priority metals
Total nonconventional metals
Total nonconventional organic
constituents
Total priority organic constituents
Total nonconventional other
Total cyanide
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Total phenols
Pollutant Removals, Ibs/yr
PSES-1
-
•
-
-
182,000
2,790
692,000
-
-
PSES-2
-
-
•
-
175,000
4,820
834,000
-
-
PSES-3
1,920
57
69,800
20,000
446,000
3,210
1,420,000
639,000
158,000
PSES-4
1,920
57
69,800
20,000
452,000
5,870
1,420,000
639,000
158,000
                                 10-44
-------
                                                     Section 10 - Pollutant Loadings
                        .       Table 10-9

Average Baseline Pollutant Concentrations for the Ironmaking Subcategory
                           Sintering Segment
Pollutant of Concern
Type of Discharge3
Average Baseline
Concentration
(mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material (HEM)
Total Kjeldahl nitrogen (TKN)
Ammonia-N
Nitrate/nitrite
Thiocyanate
Total cyanide
Amenable cyanide
Weak acid dissociable (WAD) cyanide
Total phenols
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Fluoride
Direct
Direct
Direct
Direct .
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Direct
35.4
6.03
45.9
46.1
3.02
0.204
0.0568
0.0342 .
0.0212
0.0912
79.7
17
25.3
Nonconventional Metals
Aluminum
Boron
Iron
Magnesium
Manganese
Titanium
Direct
Direct
Direct
Direct
Direct
Direct
1.18
1.49
1.47 '.
45.2
4.83
0.0178
Priority Metals
Arsenic
Cadmium
Chromium
Copper
Lead
Direct
Direct
Direct
Direct
Direct
0.0229
0.0345
0.00444
0.0829
0.229
                                 10-45
-------
                                                                                    Section 10- Pollutant Loadings
                                         Table 10-9 (Continued)
Pollutant of Concern
Type of Discharge8
Average Baseline
Concentration
(mg/L)
Priority Metals (continued)
Mercury
Selenium
Thallium
Zinc
Direct
Direct
Direct
Direct
0.00047
0.068
0.754
0.505
Nonconventional Organic Constituents
o-Cresol
p-Cresol
Pyridine
1 ,2,3,4,6,7,8-Heptachlorodibenzofuran
1,2,3,4,7,8-Hexachlorodibenzofuran
1 ,2,3,6,7,8-Hexachlorodibenzofuran
1,2,3,7,8-Pentachlorodibenzofuran
2,3,4,6.7,8-Hexachlorodibenzofuran
2,3,4,7,8-Pentachlorodibenzofuran
2,3,7,8-Tetrachlorodibenzofuran
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Direct
0.0137
0.017
0.176"
1.99E-07
1.38E-07
1.15E-07
1.33E-07
8.60E-08
2.04E-07
1.53E-07
Priority Organic Constituents
Fluoranthene
Phenanthrene
Phenol
2,4-Dimethylphenol
4-Nitrophenol
Direct
Direct
Direct
Direct
Direct
0.0146
0.0201
0.0324
0.0309
0.366
"The sintering segment only included direct dischargers; therefore, EPA did not calculate an average baseline pollutant
concentration for indirect dischargers.                    •*

Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Un to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastcwatcr Sampling Program, 1997-1999.
                                                      10-46
-------
                                                    Section 10 - Pollutant Loadings
                              Table 10-10

Average Baseline Pollutant Concentrations for the Ironmaking Subcategory
                        Blast Furnace Segment
Pollutant of Concern
Type of Discharge
Average Baseline Concentration
(mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material (HEM)
Total Kjeldahl nitrogen (TKN)
Ammonia-N
Nitrate/nitrite
Thiocyanate
Total cyanide
Amenable cyanide
Weak acid dissociable (WAD) cyanide
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Fluoride
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
40.7
40.7
5.54
5.54
112
112
65.5
35.7
2.45
2.45
0.148
0.148
0.658
0.26
0.0304
0.0304
0.0150
0.0150
274
274
12.6
12.6
9.89
9.89
                                 10-47
-------
                                                                                    Section 10- Pollutant Loadings
                                        Table 10-10 (Continued)
Pollutant of Concern
Type of Discharge
Average Baseline Concentration
(mg/L)
Nonconventional Metals
Aluminum
Boron
Iron
Magnesium
Manganese
Molybdenum
Titanium
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.171
0.171
1.21
1.21
4.29
4.29
59.5
59.5
1.76
1.76
0.0408
0.0408
0.00380
0.00380
Priority Metals
Chromium
Copper
Lead
Nickel
Selenium
Zinc
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.00691
0.00691
0.00654
0.00654
0.0528
0.1
0.0214
0.0214
0.003
0.003
0.967
0.08
Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Pala Follow-Un to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewater Sampling Program, 1997-1999.
                                                      10-48
-------
                                        Section 10- Pollutant Loadings
                  Table 10-11

Proposed Arithmetic Long-Term Averages for the
            Ironmaking Subcategory
               Sintering Segment
Pollutant of Concern
Option
Arithmetic Long-Term
Average (mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material (HEM)
Total Kjeldahl nitrogen (TKN)
Ammonia-N
Nitrate/nitrite
Thiocyaiiate
Total cyanide
Amenable cyanide
Weak acid dissociable (WAD) cyanide
t
Total phenols
Chemical oxygen demand (COD)
Total organic carbon (TOC)

Fluoride

BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1 .
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
18.7
18.7
5.85
5.85
65.7
65.7
0.278
70.5
7.31
7.31
0.118
0.118
- 1.3
0.0725
0.0244
0.0244
0.0171
0.0171
0.01
0.01
42.9
42.9
. 13.2
13.2
-14
14
                    10-49
-------
                               Section 10- Pollutant Loadings
Table 10-11 (Continued)
Pollutant of Concern
Option
Arithmetic Long-Term
Average (mg/L)
Nonconventional Metals
Aluminum
Boron
Iron
Magnesium
Manganese
Titanium
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
' PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1",
0.586
0.586
, 0.365
0.365
2.58
2.58
27.1
27.1
0.308
0.308
0.0016
0.0016
Priority Metals
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Selenium
Thallium
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1 •
BAT-1
PSES-1
BAT-1
PSES-1
0.0046
0.0046
0.00636
0.00636
0.0149
0.0149
0.0084
0.0084
0.00338
0.0169
0.000223
0.000223
6.0075
0.0075
0.0578
0.0578
          10-50
-------
                                Section 10 - Pollutant Loadings
Table 10-11 (Continued)
Pollutant of Concern
Option
Arithmetic Long-Term
Average (mg/L)
Priority Metals (continued)
Zinc
Fluoranthene
BAT-1
PSES-1
BAT-1
PSES-1
0.037
0.422
0.01
0.01
Nonconventional Organic Constituents
o-Cresol
p-Cresol
1,2,3,4,6,7,8-Heptachlorodibenzofuran
1,2,3,4,7,8-Hexachlorodibenzofuran
1 ,2,3,6,7,8-Hexachlorodibenzofuran

2,3,4,6,7,8-Hexachlorodibenzofuran

1,2,3,7,8-Pentachlorodibenzofuran

2,3,4,7,8-PentacbJorodibenzofuran

2,3,7,8-Tetrachlorodibenzofuran

BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1 •
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
0.01
0.01
0.01
0.01
5E-08
5E-08
5E-08
. 5E-08
5E-08
5E-08
5E-08
5E-08
5E-08
5E-08
5E-08
5E-08
IE-OS
1E-08
          10-51
-------
                                                                                    Section 10 - Pollutant Loadings
                                        Table 10-11 (Continued)
Pollutant of Concern
Option
Arithmetic Long-Term
Average (mg/L)
Priority Organic Constituents
Phenanthrene
Pyridine
Phenol
2,4-Dimethylphenol
4-Nitrophenol
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
0.01
0.01
0.0193
0.0193
0.01
0.01
0.01
0.01
0.05
0.05
Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Un to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewater Sampling Program, 1997-1999.
                                                      10-52
-------
                                       Section 10 - Pollutant Loadings
                 Table 10-12

Proposed Arithmetic Long-Term Averages for the
           Ironmaking Subcategory
            Blast Furnace Segment
PoUutant of Concern
Option
Arithmetic Long-Term Average
(mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material (HEM)
Total Kjeldahl nitrogen (TKN)
Ammonia-N
Nitrate/nitrite
Thiocyanate . ;
Total cyanide
Amenable cyanide
Weak acid dissociable (WAD) cyanide
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Fluoride
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1 .
PSES-1 '
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
18.7
18.7
5.85
5.85
65.7
65.7
0.278
"70.5
7.31
7.31
0.118
0.118
1.3 -
0.0725
0.0244
0.0244
0.0171
0.0171
42.9
42.9
13.2
13.2
14
14
                    10-53
-------
                                                                                    Section 10 - Pollutant Loadings
                                        Table 10-12 (Continued)
Pollutant of Concern
Option
Arithmetic Long-Term Average
(mg/L)
Nonconventional Metals
Aluminum
Boron
Iron
Magnesium
Manganese
Molybdenum
Titanium
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
0.586
0.586
0.365
0.365
2.58
2.58
27.1
27.1
0.308
0.308
0.0386
0.0386
0.0016
0.0016
Priority Metals
Chromium
Copper •
Lead
Nickel
Selenium
Zinc
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
0.0149
0.0149
0.0084
0.0084
0.00338
0,0169
0.016
0.016
0.0075
0.0075
0.037
0.422
Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Up to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewatcr Sampling Program, 1997-1999.
                                                      10-54
-------
                                                          Section 10- Pollutant Loadings
                                  Table 10-13

     Summary of Baseline and Post-Compliance Pollutant Loadings for the
                           Ironmaking Subcategory
                        Direct and Indirect Dischargers
Pollutant Group
Total conventionals
Total priority metals
Total nonconventional metals
Total nonconventional organic
constituents •
Total priority organic constituents
Total nonconventional other
Total cyanide
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Total phenols
Total dioxins/furans
Total Kjeldahl nitrogen (TKN)
Baseline Load
'(Ibs/yr)a
2,430,000
17,400
3,250,000
477
1,060
1,880,000
9,550
12,300,000
705,000
216
0.00268
. 5,360,000
Treated Load Discharged to
Surface Water at BAT-1 and
PSES-1 (lbs/yr)a
172,000
741
252,000
115
320
1,310,000
3,300
474,000
94,000
216
0.000908
453,000 .
"Data aggregated to protect confidential business information.
                                     10-55
-------
                                                           Section 10- Pollutant Loadings
                                   Table 10-14

       Summary of Pollutant Removals for the Ironmaking Subcategory
                        Direct and Indirect Dischargers
Pollutant Name
Total conventional
Total priority metals
Total nonconventional metals
Total nonconventional organic constituents
Total priority organic constituents
Total nonconventional other
Total cyanide
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Total phenols
Total dioxins/furans
Total Kjeldahl nitrogen (TKN)
Pollutant Removals (Ibs/yr)
BAT-1 and PSES-1"
2,260,000
16,700 .
2,990,000
362
' 741
564,000
6,2.50
11,700,000
611,000
.
0.00178
4,900,000
"Data aggregated to protect confidential business information.
                                       10-5.6
-------
                                         Section 10 - Pollutant Loadings
                  Table 10-15

Average Baseline Pollutant Concentrations for the
       Integrated Steelmaking Subcategory
Pollutant of Concern
Type of Discharge
Average Baseline
Concentration (mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material (HEM)
Silica gel treated hexane extractable material
(SGT-HEM)
Ammonia-N
Nitrate/nitrite
Chemical oxygen demand (COD) •
Total organic carbon (TOC)
Fluoride
Direct, Indirect •
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
' 24:0
5.29
. 5.29
0.549
0.670
26.8
8.46
23.7
Nonconventional Metals
Aluminum
Cobalt .
Iron
Magnesium
Manganese
Molybdenum
Tin
Titanium .
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
1.49
0.0101
7.59
6.07
0.400
0.326
0.00932
0.00702
Priority Metals
Antimony
Cadmium
Chromium
Copper
Lead
Mercury '
Silver
Ziiic •
. Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
0.0147
0.00690
0.00986
0.0212
0.0972
0.000204
0.00652
1.36
                      10-57
-------
                                                                                Section 10-'Pollutant Loadings
                                      Table 10-15 (Continued)
              Pollutant of Concern.
Type of Discharge
  Average Baseline
Concentration (mg/L)
 Priority Organic Constituents
 Phenol
  Direct, Indirect
          0.0316
"Sources: U.S. EPA. U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Fo!low-Up to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastcwater Sampling Program, 1997-1999.
                                                   10-58
-------
                                         Section IjO'- Pollutant Loadings
                  Table 10-16

Proposed Arithmetic Long-Term Averages for the
       Integrated Steelmaking Subcategory
Pollutant of Concern
Option
Model Effluent Concentration
(mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material (HEM)
Silica gel treated hexane extractable
material (SGT-HEM)
Total organic carbon (TOC)
Ammonia-N
Nitrate/nitrite
Chemical oxygen demand (COD)
Fluoride
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
- PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
7.35
7.35
6.10
6.10
5.89
5.89
9.60
9.60
0.142
0.142
1.76
1.76
30.9
30.9
24.4
24.4
Nonconventional Metals
Aluminum
Cobalt
Iron
Magnesium
Manganese
Molybdenum
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
.BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
0.292
0.292
0.0105
0.0105
1.57
1.57
57.8
57.8
0.0965
0.0965
0.456
0.456
                     10-59
-------
                                                                                   Section 10- Pollutant Loadings
                                        Table 10-16 (Continued)
Pollutant of Concern
Option
Model Effluent Concentration
(mg/L)
Nonconventional Metals (continued)
Tin
Vanadium
BAT-1 . '
PSES-1
BAT-1
PSES-1
0.00416
0.00416
0.0154
0.0154
Priority Metals
Antimony
Cadmium
Chromium
Copper
Lead
Mercury
Silver
Zinc
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
BAT-1
PSES-1
0.0799
0.0799
0.001
0.001
0.0122 .
0.0122
0.0104 ,t
0.0104
0.0141
0.0141
0.0002
0.0002
0.00508
0.00508
0.0932
0.0932
Priority Organic Constituents
Phenol
BAT-1
PSES-1
0.01
0.01
Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Up to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA "Iron and Steel Industry
Wastewatcr Sampling Program, 1997-1999.
                                                      10-60
-------
                                                          Section 10 - Pollutant Loadings
                                  Table 10-17

     Summary of Baseline and Post-Compliance Pollutant Loadings for the
                     Integrated Steelmaking Subcategory
                        Direct and Indirect Dischargers
Pollutant Group
Total conventionals
Total priority metals
Total nonconventional metals
Total priority organic constituents
Total nonconventional other
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Silica gel treated hexane extractable material
(SGT-HEM)
Baseline Load (Ibs/yr)
2,500,000
107,000
2,990,000
2,850
3,120,000
3,370,000
975,000
588,000 '
Treated Load Discharged to
Surface Water (Ibs/yr)
BAT-1 and PSES-1"
650,000
15,000
528,000
2,850
1,600,000
648,000
189,000
360,000
, "Data aggregated to protect confidential business information.

                                 Table 10-18

  Summary of Pollutant Removals for the Integrated Steelmaking Subcategory
                       Direct and Indirect Dischargers
?;,
Pollutant Group
Total conventionals ' •
Total priority metals
Total nonconventional metals
Total priority organic constituents
Total nonconventional other
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Silica gel treated hexane extractable material (SGT-HEM)
Pollutant Removals (Ibs/yr)
BAT-1 and PSES-1"
1,850,000
92,300
2,470,000
.
1,520,000 '
2,720,000
786,000
228,000
"Data aggregated to protect confidential -business information.
                                     10-61
-------
                                                                    Section 10 - Pollutant Loadings
                                        Table 10-19

Average Baseline Pollutant Concentrations for the Integrated and Stand-Alone
                               Hot Forming Subcategory
                            Carbon and Alloy Steel Segment
Pollutant of Concern
Type of Discharge
Average Baseline Concentration
(mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane exttactable material (HEM)
Silica gel treated hexane extractable
material (SGT-HEM)
Ammonia-N
Chemical oxygen demand (COD)
Fluoride
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
42.4
516
6.04
6.04
6.04
6.04
0.77
0.77
77.7
77.7
6.40
6.40
Nonconventional Metals
Iron
Manganese
Molybdenum
Direct
Indirect
Direct
Indirect
Direct
Indirect
7.06
36.4
0.0877
0.0877
0.0313
0.0313
Priority Metals
Lead
Zinc
Direct
Indirect
Direct
Indirect
0.0287 ,
0.004
0.0551
0.087
Sources: US. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Up to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewater Sampling Program, 1997-1999.
                                            10-62
-------
                                                      Section 10-Pollutant Loadings
                               Table 10-20

Average Baseline Pollutant Concentrations for the Integrated and Stand-Alone
                        Hot Forming Subcategory
                          Stainless Steel Segment
Pollutant of Concern
Type of Discharge
Average Baseline Concentration
(mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material (HEM)
Silica gel treated hexane extractable
material (SGT-HEM)
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Fluoride
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
42.4
516
6.04
6.04
6.04
6.04
77.7
77.7
23.3
23.3
6.40
6.40
Nonconventional Metals
Iron
Manganese
Molybdenum
Titanium
Direct '.
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
7.06
36.4
0.0877
0.0877
0.0313
0.0313
0.00092
0.00092
Priority Metals
Antimony
Chromium
Copper ,
Direct
Indirect
Direct
Indirect
Direct
Indirect
• 0.0360
0.0360
0.0104
0.027
0.0122
0.3
                                  10-63
-------
                                                                                    Section 10- Pollutant Loadings
                                        Table 10-20 (Continued)
Pollutant of Concern
Type of Discharge
Average Baseline Concentration
(mg/L)
Priority Metals (continued)
Nickel
Zinc
Direct
Indirect
Direct
Indirect
0.0847
0.138
0.0551
0.087
Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Up to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastcwatcr Sampling Program, 1997-1999.
                                                      10-64
-------
                                                                   Section 10- Pollutant Loadings
                                       Table 10-21

Proposed Arithmetic Long-Term Averages for the Integrated and Stand-Alone
                               Hot Forming Subcategory
                           Carbon and Alloy Steel Segment
Pollutant of Concern
Option
Model Effluent
Concentration (mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material (HEM)
Silica gel treated hexane extractable
material (SGT-HEM)
Ammonia-N
Chemical oxygen demand (COD)
Fluoride
BAT-1, PSES-1
BAT-1, PSES-1
BAT-1, PSES-1
BAT-1, PSES-1
BAT-1, PSES-1
BAT-1, PSES-1
12.3
6.56
5.69
0.615
36.5
1.33
Nonconventional Metals -.'-'..
Iron
Manganese
Molybdenum
BAT-1, PSES-1
BAT-1, PSES-1
BAT-1, PSES-1
2.45
0.0308
0.0890
Priority Metals
Lead
Zinc
BAT-1, PSES-1
BAT-1, PSES-1
0.0120
0.0874
Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Up to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and-U.S. EPA Iron and Steel Industry
Wastewater Sampling Program, 1997-1999.
                                           10-65
-------
                                                                    Section 10 - Pollutant Loadings
                                        Table 10-22

 Proposed Arithmetic Long-Term Averages for the Integrated and Stand-Alone
                               Hot Forming Subcategory
                                 Stainless Steel Segment
Pollutant of Concern
Option
Arithmetic Long-Term
:" Average (mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material (HEM)
Silica gel treated hexane extractable
material (SGT-HEM)
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Fluoride
BAT-1, PSES-1
BAT-1, PSES-1
BAT-1, PSES-1
BAT-1, PSES-1
BAT-1, PSES-1
BAT-1, PSES-1
7.14
8.78
7.13
44.6
11.2
14.9
Nonconventional Metals
Iron
Manganese
Molybdenum
Titanium
BAT-1, PSES-1
BAT-1, PSES-1
BAT-1, PSES-1
BAT-1, PSES-1
0.658
0.0492
1.23
0.009
Priority Metals
Antimony
Chromium
Copper
Nickel
Zinc
BAT-1, PSES-1
BAT-1, PSES-1
BAT-1, PSES-1
BAT-1, PSES-1
BAT-1, PSES-1
0.26
0.0255
0.00904
0.151
0.071
Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys'). U.S. EPA Analytical and Production
Data Follow-Uo to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewater Sampling Program, 1997-1999.
                                            10-66
-------
                                                       Section 10 - Pollutant Loadings
                                 Table 10-23

     Summary of Baseline and Post-Compliance Pollutant Loadings for the
            Integrated and Stand-Alone Hot Forming Subcategory
             Carbon and Alloy Steel Segment Direct Dischargers
Pollutant Group
Total conventionals
Total priority metals
Total nonconventional metals
Total nonconventional other
Chemical oxygen demand (COD)
Silica gel treated hexane extractable
material (SGT-HEM)
Baseline Load (Ibs/yr)
26,400,000
73,200
5,760,000
6,530,000
60,200,000
5,690,000
Treated Load Discharged to
Surface Water (Ibs/yr)
BAT-1
4,830,000
8,610
625,000
6,530,000
6,930,000
840,000
                                Table 10-24

    Summary of Baseline and Post-Compliance Pollutant Loadings for the
            Integrated and Stamd-Alone Hot Forming Subcategory
                 Stainless Steel Segment Direct Dischargers3
Pollutant Group
Chemical oxygen demand (COD)
Silica gel treated hexane extractable
material (SGT-HEM)
Total nonconventional metals
Total nonconventional other
Total organic carbon (TOC)
Total priority metals
Baseline Load (Ibs/yr)
0
0
0
0
0
0
Treated Load Discharged to
Surface Water (Ibs/yr)
BAT-1
0
0
0
0
0
0
"In 1997, no sites with integrated or stand-alone hot forming operations discharged directly.
                                   10-67
-------
                                                        Section 10- Pollutant Loadings
                                 Table 10-25

    Summary of Baseline and Post-Compliance Pollutant Loadings for the
            Integrated and Stand-Alone Hot Forming Subcategory
            Carbon and Alloy Steel Segment Indirect Dischargers3
Pollutant Group
Total priority and nonconventional
pollutants
Baseline Load (Ibs/yr)
37,700
Treated Load Discharged from
POTW (Ibs/yr)
PSES-1
17,300
'Data are aggregated to protect confidential business information.
                                Table 10-26

    Summary of Baseline and Post-Compliance Pollutant Loadings for the
            Integrated and Stand-Alone Hot Forming Subcategory
                Stainless Steel Segment Indirect Dischargers3
Pollutant Group
Total priority and nonconventional pollutants
Baseline Load (Ibs/yr)
1,380
Treated Load Discharged from
POTW (Ibs/yr)
PSES-1
449
•Data arc aggregated to protect confidential business information.
                                    10-68
-------
                                                        Section 10 - 'Pollutant Loadings
                                 Table 10-27

            Summary of Pollutant Removals for the Integrated and
                    Stand-Alone Hot Forming Subcategory
             Carbon and Alloy Steel Segment Direct Dischargers
Pollutant Group
Total conventionals
Total priority metals • • •
Total nonconventional metals
Total nonconventional other
Chemical oxygen demand (COD)
Silica gel treated hexane extractable material (SGT-HEM)
Pollutant Removals (Ibs/yr)
BAT-1
21,600,000
64,600
5,140,000
0
53,300,000
4,850,000
                                Table 10-28

            Summary of Pollutant Removals for the Integrated and
                   Stand-Alone Hot Forming Subcategory
                 Stainless Steel Segment Direct Dischargers3
Pollutant Group
Total conventionals
Total priority metals
Total nonconventional metals
Total nonconventional other
Chemical oxygen demand (COD)
Silica gel treated hexane extractable material (SGT-HEM)
Pollutant Removals (Ibs/yr)
BAT-1
0
0 .
0
0
0
0
"In 1997, no sites with integrated or stand-alone hot forming operations discharged directly.
                                    10-69
-------
                                                        Section 10 - Pollutant Loadings
                                 Table 10-29

              Summary of Pollutant Removals for the Integrated
                  and Stand-Alone Hot Forming Subcategory
            Carbon and Alloy Steel Segment Indirect Dischargers2
(Pollutant Group
Total priority and nonconventional pollutants
Pollutant Removals flbs/yr)
PSES-1
20,400
"Data are aggregated to protect confidential business information.
                                 Table 10-30

              Summary of Pollutant Removals for the Integrated
                 and Stand-Alone Hot Forming Subcategory
                Stainless Steel Segment Indirect Dischargers3
Pollutant Group
Total priority and nonconventional pollutants
Pollutant Removals, Ibs/yr
PSES-1
930
'Data are aggregated to protect confidential business information.
                                    10-70
-------
                                                                    Section 10- Pollutant Loadings
                                        Table 10-31

        Average Baseline Pollutant Concentrations for the Non-Integrated
                     Steelmaking and Hot Forming Subcategory
                            Carbon and Alloy Steel Segment
Pollutant of Concern
Type of Discharge
Average Baseline Concentration (mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Ammonia-N
Hexane extractable material (HEM)
Silica gel treated hexane extractable
material (SGT-HEM)
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
24.5
24.0
1
1
7:52
22.4
5.52
5.52
24.5
61
5
5
Nonconventional Metals
Iron
Manganese
Direct
Indirect
Direct
Indirect
2.35
2.14
0.0670
0.0670
Priority Metals
Lead •
Zinc
Direct
Indirect
Direct
Indirect
0.001
0.0275
0.896
0.129
Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Up to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewater Sampling Program, 1997-1999.
                                           10-71
-------
                                                                    Section 10- Pollutant Loadings
                                        Table 10-32

        Average Baseline Pollutant Concentrations for the Non-Integrated
                     Steelmaking and Hot Forming Subcategory
                                 Stainless Steel Segment
Pollutant of Concern
Type of Discharge
Average Baseline Concentration (mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material (HEM)
Silica gel treated hexane extractable
material (SGT-HEM)
Ammonia-N
Nitrate/nitrite
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Fluoride
Direct, Indirect
Direct, Indirect
Direct, Indirect .
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
122
56
12.7
1
. 0.132
306
75.6 .
0.77
Noncouventional Metals . ,
Aluminum
Boron
Hexavalent chromium
Iron
Manganese
Molybdenum
Titanium
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
0.413
0.691 •
0.0165
9.29
0.926
10.2
0.00603
Priority Metals t ,
Antimony
Chromium
Copper
Lead
Nickel
Total organic carbon (TOC)
Zinc
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
Direct, Indirect
0.0215
0.148
0.15
0.006
1.83
75.6
4.75
Sources: U.S. EPA, U.S. EPA Collection of 1997 Tron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Un to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewatcr Sampling Program, 1997-1999.
                                            10-72
-------
                                                                   Section 10 - Pollutant Loadings
                                       Table 10-33

        Proposed Arithmetic Long-Term Averages for the Non-Integrated
                     Steelmaking and Hot Forming Subcategory
                           Carbon and Alloy Steel Segment
Pollutant of Concern
Option
Arithmetic Long-Term Average (ing/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material (HEM)
Silica gel treated hexane extractable
material (SGT-HEM)
Arnmonia-N
Chemical oxygen demand (COD)
Total organic carbon (TOC)
BAT-1,PSES-1
BAT-1, PSES-1
. BAT-1, PSES-1
BAT-1,PSES-1
BAT-1, PSES-1
BAT-1, PSES-1
7.18
2.47
2.47
0.66
57
11
Nonconventional Metals
Iron
Manganese
BAT-1, PSES-1
BAT-1, PSES-1
1.3
0.82
Priority Metals
Lead
Zinc
BAT-1, PSES-1
BAT-1, PSES-1
0.001
0.0316
Sources: U.S.:EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Up to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Waste-water Sampling Program, 1997-1999.                                                         .
                                           10-73
-------
                                               Section 10- Pollutant Loadings
                         Table 10-34

Proposed Arithmetic Long-Term Averages for the Non-Integrated
           Steelmaking and Hot Forming Subcategory
                    Stainless Steel Segment
Pollutant of Concern
Option
Arithmetic Long-Term Average (mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material (HEM)
Silica gel treated hexane extractable
material (SGT-HEM)
Ammonia-N
Nitrate/nitrite
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Fluoride
BAT-1, PSES-1
BAT-2
BAT-1, PSES-1
BAT-2
BAT-1, PSES-1
.BAT-2
BAT-1, PSES-1
BAT-2
BAT-1, PSES-1
BAT-2
BAT-1, PSES-1
BAT-2
BAT-1, PSES-1
BAT-2
BAT-1, PSES-1
BAT-2
6.36
6.36
8.78
6.04
7.13
5.78
0.2
0.2
0.0571
0.0571
44.6
44.6
11.2
11.2 .
14.9
14.9
Nonconventional Metals
Aluminum
Boron
Hexavalent chromium
Iron
Manganese
Molybdenum
BAT-1, PSES-1
BAT-2
BAT-1, PSES-1
BAT-2
BAT-1, PSES-1
BAT-2
BAT-1, PSES-1
BAT-2
BAT-1, PSES-1
•BAT-2
BAT-1, PSES-1
BAT-2
0.109
-. 0.109
0.292
0.292
0.0164
0.0164
0.558
0.558
0.0492
0.0492
1.23
1.23
                            10-74
-------
                                                                                     Section 10 - Pollutant Loadings
                                         Table 10-34 (Continued)
Pollutant of Concern
Option
Arithmetic Long-Term Average (mg/L)
Nonconventional Metals (continued)
Titanium
BAT-1, PSES-1
BAT-2
0.009
0.005 .
Priority Metals
Antimony
Chromium
Copper
Lead
Nickel
Zinc
BAT-1, PSES-1
BAT-2
BAT-rl, PSES-1
BAT-2
BAT-1, PSES-1
BAT-2
BAT-1, PSES-1
BAT-2
BAT-1, PSES-1
BAT-2
BAT-1, PSES-1
BAT-2
0.255
0.0170
0.0255
0.0255
0.00904
0.00904
0.0143
0.002
0.151
0.151
0.0846
0.0846
Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Up to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewater Sampling Program, 1997-1999.
                                                       10-75
-------
                                                      Section 10- Pollutant Loadings
                                Table 10-35

    Summary of Baseline and Post-Compliance Pollutant Loadings for the
         Non-Integrated Steelmaking and Hot Forming Subcategory
             Carbon and Alloy Steel Segment Direct Dischargers
Pollutant Group
Chemical oxygen demand (COD)
Silica gel treated hexane extractable
material (SGT-HEM)
Total conventionals
Total nonconventional metals
Total nonconventional other
Total organic carbon (TOC)
Totalpriority metals
Baseline Load (Ibs/yr)
3,690,000
531,000
2,780,000
267,000
, 99,500
743,000
102,000
Treated Load Discharged to Surface
Water (Ibs/yr)
BAT-1
353,000
37,000
167,000
22,100
99,500
71,500
2,630
                               Table 10-36

    Summary of Baseline and Post-Compliance Pollutant Loadings for the
         Non-Integrated Steelmaking and Hot Forming Subcategory
                Stainless Steel Segment Direct Dischargers3
Pollutant Group
Total conventionals
Total priority and nonconventional pollutants
Baseline Load (Ibs/yr)
18,200
52,800
Treated Load Discharged
to surface Water (Ibs/yr)
BAT-1
. 79,300
35,100
BAT-2
79,300
35,100
"Data are aggregated to protect confidential business information.
                                   10-76
-------
                                                      Section 10- Pollutant Loadings
                                Table 10-37

    Summary of Baseline and Post-Compliance Pollutant Loadings for the
          Non-Integrated Steelmaking and Hot Forming Subcategory
            Carbon and Alloy Steel Segment Indirect Dischargers3
Pollutant Group
Total priority and nonconventional pollutants
Baseline Load
(Ibs/yr)
3,110
Treated Load Discharged from
POTW (Ibs/yr)
PSES-1
2,100
'Data are aggregated to protect confidential business information.

                                Table 10-38
    Summary of Baseline and Post-Compliance Pollutant Loadings for the
         Non-Integrated Steelmaking and Hot Forming Subcategory
                Stainless Steel Segment Indirect Dischargers3    .
Pollutant Group
Total priority and nonconventional pollutants
Baseline Load
(Ibs/yr)
13,900
Treated Load Discharged from
POTW Gbs/yr)
PSES-1
2,300
"Data are aggregated to protect confidential business information.

                               Table 10-39

    Summary of Pollutant Removals for the Non-Integrated Steelmaking
                       and Hot Forming Subcategory
            Carbon and Alloy Steel Segment Direct Dischargers3
Pollutant Group
Total conventional
Total priority metals . ,
Total nonconventional metals
Total nonconventional other
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Silica gel treated hexane extractable material (SGT-HEM)
Pollutant Removals (Ibs/yr)
BAT-1
2,610,000
99,500
244,000
0
3,340,000
671,000 .
494,000
                                   10-77
-------
                                                        Section 10 - Pollutant Loadings
                                 Table 10-40

     Summary of Pollutant Removals for the Non-Integrated Steelmaking
                   and Hot Forming Subcategory Stainless
                      Steel Segment Direct Dischargers3
Pollutant Group
Total conventionaJs
Total priority and nonconventional pollutants
Pollutant Removals (Ibs/yr)
BAT-1
103,000
17,700
BAT-2
103,000
17,700
"Data are aggregated to protect confidential business information.

                                 Table 10-41

                   Summary of Pollutant Removals for the
          Non-Integrated Steelmaking and Hot Forming Subcategory
            Carbon and Alloy Steel Segment Indirect Dischargers2
Pollutant Group
Total priority and nonconventional pollutants
Pollutant Removals (Ibs/yr)
PSES-1
1,010
"Data are aggregated to protect confidential business information.

                                 Table 10-42

                   Summary of Pollutant Removals for the
          Non-Integrated Steelmaking and Hot Forming Subcategory
                Stainless Steel Segment Indirect Dischargers2
1 Pollutant Group
Total priority metals
Pollutant Removals (Ibs/yr)
PSES-1
11,600
'Data are aggregated to protect confidential business information.
                                    10-78
-------
                                         Section 10- Pollutant Loadings
                  Table 10-43

Average Baseline Pollutant Concentrations for the
           Steel Finishing Subcategory
        Carbon and Alloy Steel Segment
Pollutant of Concern
Type of Operation3
Type of Discharge
Average Baseline
Concentration
(mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material
(HEM)
Silica gel treated hexane
extractable material (SGT-HEM)
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot Dip coating
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating
Acid pickling
Alkaline cleaning
Annealing
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
, Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
20.2
38.1
19.8
48.7
27.9
27.9
14.5
53.6
8.18
31.7
6.49
6.49
4.70
11.3
17.8
17.8
7.89
7.89
12.8
11.3
4.7 ,
5.59
4.7'
5.59
4.7
6.03
6
6
6.37
6.37
                     10-79
-------
                                Section 10 - Pollutant Loadings
Table 10-43 (Continued)
Pollutant of Concern
Type of Operation"
Type of Discharge
Average Baseline
Concentration
(mg/L)
Conventional and Classic Pollutants (continued)
Silica gel treated hexane
extractable material (SGT-HEM)
(cont.)
Ammonia-N
Nitrate/nitrite
Total Phenols
Cold forming
Electroplating
Hot dip coating
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating
Acid pickling
Alkaline'cleaning
Annealing
Cold forming
Electroplating
Hot dip, coating
Acid pickling
Alkaline cleaning
Annealing
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct . .
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
6
6.03
4.7
5.59
4.7
5.59 .
0.912
1.4
0.382
1.8
31,9
31.9
. 0.382
1.4
0.912
1.4
5.85
5.85
Q.214
0.0934
1.3
1.3
710
710
1.3
0.0934
0.214
0.128
3.04
3.04
0.144
0.389
0.181
0.181
0.0525
0.0525
          10-80
-------
                                Section 10 - 'Pollutant Loadings
Table 10-43 (Continued)
Pollutant of Concern
Type of Operation3
Type of Discharge
Average Baseline
Concentration
(mg/L)
Conventional and Classic Pollutants (continued)
Total Phenols (cont.)
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Fluoride

Cold forming
Electroplating
Hot dip coaling
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating
Acid picFding
Alkaline cleaning
Annealing

Cold forming

Electroplating

Hot dip coating

Acid pickling

Alkaline cleaning

Annealing

Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.150
0.389
0.172
0.005
0.191
0.191
39.9
211
272
272
58.0
58.0
272
211
39.9
50.2
39.9
50.2
10
65.6
88
88
13.3
13.3
88
65.6
10
5.11
10
5.11
1.9
0.814
1.74
1.74
136
258
          10-81
-------
                                Section 10- Pollutant Loadings
Table 10-43 (Continued)
Pollutant of Concern
Type of Operation*
Type of Discharge
Average Baseline
Concentration
(mg/L)
Conventional and Classic Pollutants (continued)
Fluoride (cont.)
Cold forming
Electroplating
Hot dip coating
. Direct
Indirect
Direct
Indirect
Direct
Indirect
1.74
0.814 '
1.9
0.681
1.9
0.681
NonconVentional Metals
Aluminum
Boron
Hexavalent chromium
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating
Acid pickling
Alkaline cleaning
. Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.16
1.67
0.0738
0.0738
0.0738
0.0738
0.0738
1.67
0.16
0.031
0.16
0.031
0.0649
0.0577
0.193
0.193
0.118
0.118
0.193
0.0577
0.0649
0.054 '
0.0649
0.054
0.0076
0.0978
0.009
0.0978
          10-82
-------
                                Section 10 - Pollutant Loadings
Table 10-43 (Continued)
Pollutant of Concern
Type of Operation3
Type of Discharge
Average Baseline
Concentration
(mg/L)
Nonconventional Metals (continued)
Hexavalent chromium (cont.)
Iron
Manganese


Annealing
Cold forming
Electroplating
Hot dip coating
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating
Acid pickling
Alkaline cleaning
Annealing •
Cold forming
Electroplating

Hot dip coating

Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.0298
0.0298
0.0132
0.0978
0.01
0.0978
0.0112
0.0112
0.912
2.08
1.45
1.45
0.923
0.923
1.36
2.08
0.969
0.008
0.628
0.628
0.0376
0.055
0.17
0.17
0.252
0.252
0.17
0.055
0.0376
0.0121
0.0376
0.0121
          10-83
-------
                                Section 10 - Pollutant Loadings
Table 10-43 (Continued)
Pollutant of Concern
Type of Operation8
Type of Discharge
Average Baseline
Concentration
(mg/L)
Nonconventional Metals (continued)
Molybdenum
Tin
Titanium
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.0308
0.0356
0.0552
0.0572
0.149
0.149
0.0552
0.0356
0.0308
0.0454
0.0308
0.0483
0.00213
0.002
0.00204
0.00204
0.0036
0.0036
0.0298
0.002
0.0299
0.22
0.0299
0.22
0.00481
0.00437
0.004
0.004
0.0046
0.0046
0.004
0.00437
0.00481
0.00301
0.00481
0.00301
          10-84
-------
                                Section 10 - Pollutant Loadings
Table 10-43 (Continued)
Pollutant of Concern
Type of Operation3
Type of Discharge
Average Baseline
Concentration
(mg/L)
Priority Metals .
Antimony
Arsenic
Chromium
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating ,
Acid pickling
Alkaline cleaning

Annealing

Cold forming

Electroplating

Hot dip coating

Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
'Direct
Indirect
Direct
Indirect
Direct
Indirect •
Direct
Indirect
Direct
Indirect
0.0495
0.0134
0.00952
0.00952
0.0179
0.0179 •
0.0479
0.0134
0.0495 .
0.0218
0.0495
0.0218
0.00192
0.00362
0.00126
0.00514
0.00145
0.015
0.00126
0.00362
0.00192
0.0138
0.00192
0,0138
0.12
0.167
0.125
0.222
0.122
0.1
0.0844
0.0774
0.0811
0.049
0.0973
0.06
          10-85
-------
                                Section 10- Pollutant Loadings
Table 10-43 (Continued)
Pollutant of Concern
Type of Operation"
Type of Discharge
Average Baseline
Concentration
(mg/L)
Priority Metals(continued)
Copper
Lead
Nickel

Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
.Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.0110
0.0276
0.0137
0.0178
0.0258
0.005
0.0137
0.0396
0.0102 '
0.115
0.01
0.06
0.00452
0.0371
0.00791
0.0547
0.002
0.01
0.0126
0.0625
0.00663
0.0106
0.0155
0.18
0.133
0.117
0.0293
0.0951
0.208
0.63
0.017
0.102
0.0280
0.128
0.0159
0.08
          10-86
-------
                                Section 10 - Pollutant Loadings
Table 10-43 (Continued)
Pollutant of Concern
Type of Operation0
Type of Discharge
Average Baseline
Concentration
(mg/L)
Priority Metals (continued)
Zinc
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot -dip coating
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.136
0.0523 .
0.0961
0.0659
0.00894
0.0120
0.127
0.277
0.209
0.0875
0.0589
0.635
Nonconventional Organic Constituents
2-Propanone .
Alpha-Terpineol
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating
Acid pickling ,
Alkaline cleaning
Annealing
Cold forming
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.0632
0.176
0.451
0.451
0.0503
0.0503
0.451
0.176
0.0632
0.04
0.0632
0.04
0.01
0.0192
0.0762
0.0762
0.01
0.01
0.0762
0.0192
          10-87
-------
                                Section 10 - Pollutant Loadings
Table 10-43 (Continued)
Pollutant of Concern
Type of Operation"
Type of Discharge
Average Baseline
Concentration
(mg/L)
Nonconventional Organic Constituents (continued)
Alpha-Terpineol (cont.)
n-Dodecane
n-Hexadecane
n-Hexadecane (cont.)
Electroplating
Hot dip coating
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating

Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.01
0.0608
0.01
0.0608
0.01
0.0169
0.01
0.01
0.01
0.01
0.01
0.0169
0.01
0.0608
0.01
0.0608
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.0608
0.01
0.0608
          10-88
-------
                                                                                             Section 10- Pollutant Loadings
                                             Table 10-43 (Continued)
Pollutant of Concern
Type of Operation2
Type of Discharge
Average Baseline
Concentration
(mg/L)
Priority Organic Constituents
Bis(2-ethylhexyl) phthalate
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Electroplating
Hot dip coating-
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.01
0.0178
0.01
0.01
0.0158
0.0158
0.01
0.0178
0.01
. 0.0354
0.01
0.0354
"Acid pickling includes hydrochloric acid strip, sulfuric acid strip, sulfuric acid bar, sulfuric acid pipe and tube, other acid strip, other acid bar, and
other acid pipe and tube.  Alkaline cleaning includes bar, strip or coil, and pipe and tube. Cold forming includes recirculation single-stand,
recirculation multi-stand, combination, direct application single-stand, and direct application multi-stand. Electroplating includes tin and chrome,
other metals, and other plating.                                                                   .

Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Up to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.SJ EPA Iron and Steel Industry
Wastewater Sampling Program, 1997-1999.                                     •
                                                           10-89
-------
                                          Section 10 - Pollutant Loadings
                   Table 10-44

Average Baseline Pollutant Concentrations for the
           Steel Finishing Subcategory
             Stainless Steel Segment
Pollutant of Concern
Type of Operation3
Type of Discharge
Average Baseline
Concentration
(mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material (HEM)
Silica gel treated hexane extractable
material (SGT-HEM)
Ammonia-N
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
14.6
22.4
2.77
2.77
27.9
27.9
33
33
7.33
7.33
17.8
17.8
7,89
7.89
7.85
7.85
6.20
6.20
6
6
6.37
6.37
6.5
6.5
17.1
17.1
0.382
1.8 '
31.9
31.9
                      10-90
-------
                                Section 10- Pollutant Loadings
Table 10-44 (Continued)
Pollutant of Concern
Type of Operation"
Type of Discharge
Average Baseline
Concentration
.(mg/L)
Conventional and Classic Pollutants (continued)
Ammonia-N (cont.)
Nitrate/nitrite
Total cyanide
Total phenols
Chemical oxygen demand (COD)
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
22.5
22.5 -
506
506
1.3
1.3
710
710
519
519
2.36
2.36
0.04
0.0360
2.36
2.36
0.0300
0.0300
0.0517
0.0517
0.181
o:isi
0.0525
0.0525
0.05
0.05
44.3
44.3
272 .
272
58.0
58.0 •
85.6
85.6
          10-91
-------
                               Section 10 - Pollutant Loadings
Table 10-44 (Continued)
Pollutant of Concern
• Type .of Operation3
Type of Discharge
Average Baseline
Concentration
(mg/L)
Conventional and Classic Pollutants (continued)
Total organic carbon (TOC)
Fluoride
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Nonconventional Metals
Aluminum
Barium
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Direct
Indirect
Direct
Indirect
Direct
Indirect.
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
10.2
10.2
88
88
13.3
13.3
16.6
16.6
75.1
258,
11.3
11.3
136
258
6.96
6.96

Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.0730
0.0730
0.0738
0.0738
0.0738
0.0738
0.0916
0.0916
0.0179
0.0179
0.211
0.211
0.0228
0.0228
0.0239
0.0239
          10-92
-------
                                Section 10 - Pollutant Loadings
Table 10-44 (Continued)
Pollutant of Concern
Type of Operation"
Type of Discharge
Average Baseline
Concentration
(mg/L)
Nonconventional Metals (continued)
Boron
Cobalt
Hexavalent chromium
[ron


Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing

Cold forming

Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect -
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct •
Indirect
Direct
Indirect
0.142
0.142
0.193
0.193
0.118
0.118
0.0585
0.0585
.0.0114
0.0114
0.009
0.009
0.0112
0.0112
0.012
0.012
0.039,7
0.0397
0.01
0.01
0.0298
0.0298
0.0085
0.0085
0.486
2.79
0.0377
0.0377
0.923
. 0.923
0.736
0.736
          10-93
-------
                               Section 10- Pollutant Loadings
Table 10-44 (Continued)
Pollutant of Concern
Type of Operation3
Type of Discharge
Average Baseline
Concentration
(mg/L)
Nonconventional Metals (continued)
Magnesium
Manganese
Molybdenum
Tin
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
21.7
21.7
10.7
10.7
31.9
31.9
43
43
0.168
0.0387
0.17
0.17
0.252 .
0.252
0.261
0.261
0.449
0.449
0,0552
0.0572
0.149
0.149
0.168
0.168
0.0034
0.0034
0.00204
0:00204
0.0036
0.0036
0,004
0.004
          10-94
-------
                               Section 10 - Pollutant Loadings
Table 10-44 (Continued)
Pollutant of Concern
Type of Operation3
Type of Discharge
Average Baseline
Concentration
(mg/L)
Nonconventional Metals {continued)
Titanium
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.0044
0.0044
0.004
0.004
0.0046
0.0046
0.005
0.005
Priority Metals
Antimony
Arsenic

Chromium



Acid pickling
Alkaline cleaning.
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning

Annealing

Cold forming

. Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct .
Indirect
Direct
Indirect
Direct
Indirect
0.0140
0.0140
0.00952
0.00952
0.0179
0.0179
0.0168
0.0168
0.00152
0.015
0.00126
0.00514
0.00145
0.015
0.00188
0.00188
0.0903
0.0765
0.0223
0.0223
0.122
0.1
0.0673
0.0673
          10-95
-------
                                Section 10 - Pollutant Loadings
Table 10-44 (Continued)
Pollutant of Concern
Type of Operation8
Type of Discharge
Average Baseline
Concentration
(mg/L)
Priority Metals (continued)
Copper
Lead
Nickel
Zinc
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct ,
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.0224
0.0129
0.0191
0,0191
0.0258
0.005
0.0236
0.0236
0.00722
0.0553
0.0051
0.0051
0.002
0.01
0.0135
0.0135
0.122
0:339
0.184
0.184
0.208
0.63
0.158
0.158
0.0135
0.0347
0.0296
0.0296
0.00894
0.0120
o;oo9
0.009
          10-96
-------
                               Section 10- Pollutant Loadings
Table 10-44 (Continued)
Pollutant of Concern
Type of Operation"
Type of Discharge
Average Baseline
Concentration
(mg/L)
Nonconventional Organic Constituents
2-Propanone
Hexanoic acid
n-Dodecane
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.0502
0.0502
0.451
0.451
0.0503
0.0503
0.0505
0.0505
0.015
0.015
0.01
0.01
0.01
0.01
0.01
0.01
0.0189
0.0189
0.01
0.01
0.01
0.01
0.01
0.01
          10-97
-------
                                                                                           Section 10- Pollutant Loadings
                                            Table 10-44  (Continued)
Pollutant of Concern
Type of Operation8
Type of Discharge
Average Baseline
Concentration
(mg/L)
Nonconventional Organic Constituents (continued) .
n-Hexadecane
Acid pickling
Alkaline cleaning
Annealing
Cold forming
Direct
Indirect
Direct
Indirect
Direct
Indirect
Direct
Indirect
0.0258
0.0258
0.01
0.01-
0.01
0.01
0.01
0.01
'Acid pickling includes strip, bar, and plate. Alkaline cleaning includes bar, strip or coil, and pipe and tube. Cold forming includes recirculation
single-stand, recirculation multi-stand, combination, direct application single-stand, and direct application multi-stand.

Sources: US. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow.TJn to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewatcr Sampling Program, 1997-1999.
                                                          10-98
-------
                                             Section 10- Pollutant Loadings
                       Table 10-45

     Proposed Arithmetic Long-Term Averages for the
Steel Finishing Subcategory Carbon and Alloy Steel Segment
Pollutant of Concern
Type of Operation0
Option
Arithmetic
Long-Term
Average
(mg/L)
Conventional and Classic Pollutants '
Total suspended solids (TSS)
Hexane extractable material
(HEM)
Hexane extractable material
(SGT-HEM)
Ammonia-N
Nitrate/nitrite
Total phenols
Chemical oxygen demand (COD)
Total organic carbon (TOC)
Fluoride
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating .
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
.BAT-1,
PSES-1
6.97
6.33
6.33
0.34
0.0623
0.0820
61.3 ,
10.9
0.349
Nonconventional Metals
Aluminum
Boron
Hexavalent chromium
Iron
Manganese
Molybdenum
Tin
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
0.0945
0.0433 '
0.0109
0.558
0.0387
0.00617
0.0124
                          10-99
-------
                                                                                             Section 10- Pollutant Loadings
                                            Table 10-45 (Continued)
Pollutant of Concern
Type of Operation0
Option
Arithmetic
Long-Term
Average
(mg/L)
Nonconventional Metals (continued)
Titanium
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
BAT-1,
PSES-1
0.0045
Priority Metals
Antimony
Arsenic
Chromium
Copper
Lead
Nickel
Zinc
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkalirie cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
0.0147
0.0019
. 0.0387
0.00883
0.0175
0.0362
0.0425
Nonconventional Organic Constituents
2-Propanone
Alpha-Terpineol
n-Dodecane
n-Hexadecane
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
0.052
0.01
0.0119
0.0128
Priority Organic Constituents
Bis(2-Ethylhexyl) phthalate
Acid pickling, alkaline cleaning, annealing, cold
forming, electroplating, and hot dip coating
BAT-1,
PSES-1
0.01
'Acid pickling includes hydrochloric acid strip, sulfiiric acid strip, sulfiiric acid bar, sulfuric acid pipe and tube, other acid strip, other acid bar, and
other acid pipe and tube. Alkaline cleaning includes bar, strip or coil, and pipe and tube. Cold forming includes recirculation single-stand,
rccirculation multi-stand, combination, direct application single-stand, and direct application multi-stand. Electroplating includes tin and chrome,
other metals, and other plating.

Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and; Production
Data Follow-Ur> to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewater Sampling Program, 1997-1999.
                                                           10-100
-------
                                         Section 10- Pollutant Loadings
                  Table 10-46

Proposed Arithmetic Long-Term Averages for the
           Steel Finishing Subcategory
             Stainless Steel Segment
Pollutant of Concern
Type of Operation3
Option
Arithmetic
Long-Term
Average
(mg/L)
Conventional and Classic Pollutants
Total suspended solids (TSS)
Hexane extractable material (HEM)
Silica gel treated hexane extractable
material (SGT-HEM)
Amnjonia-N
Nitrate/nitrite
Total cyanide
Total phenols
Chemical oxygen demand (COD) .
Total organic carbon (TOC)
Fluoride
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and' cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming • ,
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
. and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
3.42
6.35
5.89
11.6
93.9
0.0160
0.05
14.4
3.43
16.6
Nonconventional Metals
Aluminum
Barium
Boron
Cobalt
Hexavalent chromium
Iron
Acid pickling,- alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming '
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-r,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
0.0763
0.00,833
0.151
0.012
0.0816
0.0693
                    10-101
-------
                                                                                           Section 10 - Pollutant Loadings
                                            Table  10-46 (Continued)
Pollutant of Concern
Type of Operation8
Option
Arithmetic
Long-Term
Average
(mg/L)
Nonconventional Metals (continued)
Magnesium
Manganese
Molybdenum
Tin
Titanium
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
1.32
0.001
1.03
0.003
0.004
Priority Metals
Antimony
Arsenic
Chromium
Copper
Lead
Nickel
Zinc
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
0.00691
0.00173
, 0.110
0.0231
0.0025
, 0.0444
0.00474
Nonconventional Organic Constituents
2-Propanone
Hexanoic acid
n-Dodecane
n-Hexadecane
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
Acid pickling, alkaline cleaning, annealing, .
and cold forming
Acid pickling, alkaline cleaning, annealing,
and cold forming
BAT-1,
PSES-1
BAT-1,
PSES-1
BAT-1,
PSES-1
, BAT-1,
PSES-1
0.05
0.028'
0.0421
0.0669
(si) Acid pickling includes strip, bar, and plate. Alkaline cleaning includes bar, strip or coil, and pipe and tube.  Cold forming includes recirculation
single-stand, recirculation multi-stand, combination, direct application single-stand, and direct application multi-stand.

Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Up to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewater Sampling Program, 1997-1999.
                                                          10-102
-------
                                                              Section 10 -Pollutant Loadings
                                    Table 10-47

         Summary of Baseline and Post-Compliance Pollutant Loadings
                        for the Steel Finishing Subcategory
               Carbon and Alloy Steel Segment Direct Dischargers
Pollutant Group
Chemical oxygen demand (COD)
Hexavalent chromium3
Silica gel treated hexane extractable
material (SGT-HEM)
Total conventionals
Total nonconventional metals
Total nonconventional organic
constituents
Total nonconventional other
Total phenols
Total organic carbon (TOC)
Total priority metals
Total priority organic constituents .
Baseline Load (lbs/yr)
27,200,000
2,690
1,300,000
4,560,000
310,000
57,300 ;
1,240,000
36,700
8,060,000
78,900
2,430
Treated Load Discharged to
Surface Water (lbs/yr)
BAT-1
10,400,000
1,080 -
540,000
1,760,000
115,000
57,300
1,240,000
36,700
3,010,000
29,600
2,430
"Hexavalent chromium was not included in the total nonconventional metals or the total priority metals, because total chromium is included in these
totals.
                                       10-103
-------
                                                            Section 10- Pollutant Loadings
                                   Table 10-48

         Summary of Baseline and Post-Compliance Pollutant Loadings
                  for the Steel Finishing Subcategory Stainless
                       Steel Segment Direct Dischargers3
Pollutant Group
Total conventionals
Total priority and nonconventional
pollutants
Baseline Load (Ibs/yr)
1,220,000
30,900,000
Treated Load Discharged to Surface
Water (Ibs/yr)
BAT-1
496,000
16,700,000
'Data arc aggregated to protect confidential business information.


                                   Table 10-49

        Summary of Baseline and Post-Compliance Pollutant Loadings
                       for the Steel Finishing Subcategory
             Carbon and Alloy Steel Segment Indirect Dischargers
Pollutant Group
Chemical oxygen demand (COD)
Hexavalent chromium1
Silica gel treated-HEM (SGT-HEM)
Total nonconventional metals
Total nonconventional organic
constituents
Total nonconventional other
Total phenols
Total organic carbon (TOC)
Total priority metals
Total priority organic constituents
Baseline Load (Ibs/yr)
169,000
591
6,680
2,970
475.
12,200
296
65,680
1,010
92.0
Treated Load Discharged from
POTW (Ibs/yr)
PSES-1
90,970
325
4,600
1,640
475
12,200
296 I
29,900
664 ;
92.0 ,
'Hexavalent chromium was not included in the total nonconventional metals or the total priority metals, because total chromium is included in these
totals.
                                      10-104
-------
                                                            Section 10 - Pollutant Loadings
                                   Table 10-50

         Summary of Baseline and Post-Compliance Pollutant Loadings
                       for the Steel Finishing Subcategory
                  Stainless Steel Segment Indirect Dischargers3
Pollutant Group
Total priority and nonconventional
pollutants - • .
Baseline Load (Ibs/yr)
304,000
Treated Load Discharged from
POTW (U>s/yr)
BAT-1
274,.000
"Data are .aggregated to protect confidential business information.
                                   Table 10-51

      Summary of Pollutant Removals for the Steel Finishing Subcategory
              Carbon and Alloy Steel Segment Direct Dischargers
Pollutant Group
Total conventionals
Total priority metals
Total nonconventional metals
Total nonconventional organic constituents
Total priority organic constituents
Total nonconventional other •
Chemical oxygen demand (COD)
Total phenols
Total organic carbon (TOC)
Silica gel treated hexane extractable material (SGT-HEM)
Hexavalent chromium3
Pollutant Removals (Ibs/yr)
BAT-1
2,800,000
49,300
195,000
0
0
0
16,800,000
0
5,050,000
764,000
1,610
"Hexavalent chromium was not included in the total nonconventional metals or the total priority metals, because total
chromium is included in these totals.
                                      10-105
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                                                             Section 10- Pollutant Loadings
                                    Table 10-52

      Summary of Pollutant Removals for the Steel Finishing Subcategory
                   Stainless Steel Segment Direct Dischargers3
Pollutant Group
Total conventionals
Total priority and nonconventional pollutants
Pollutant Removals (Ibs/yr)
BAT-1
719,000
14,200,000
'Data ate aggregated to protect confidential business information.
                                    Table 10-53

      Summary of Pollutant Removals for the Steel Finishing Subcategory
             Carbon and Alloy Steel Segment Indirect Dischargers
Pollutant Group
Total priority metals
Total nonconventional metals
Total nonconventional organic constituents
Total priority organic constituents
Total nonconventional other
Chemical oxygen demand (COD)
Total phenols
Total organic carbon (TOC)
Silica gel treated hexane extractable material (SGT-HEM)
Hexavalent chromium'
Pollutant Removals (Ibs/yr)
PSES-1
345
1,330
0 '
o
0
78,200
0
35,700
2,080
265
"Hcxavalent chromium was not included in the total nonconventional metals or the total priority metals, because total chromium is included in these
totals.
                                       10-106
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                                                                    Section 10- Pollutant Loadings
                                        Table 10-54

       Summary of Pollutant Removals for the Steel Finishing Subcategory
                    Stainless Steel Segment Indirect Dischargers3
Pollutant Group
Total priority and nonconventional pollutants
Pollutant Removals (Ibs/yr)
PSES-1
31,000
"Data are aggregated to protect confidential business information.
                                       Table 10-55

                 Average Baseline Pollutant Concentrations for the
                  Other Operations Subcategory Forging Segment
(Pollutant of Concern
Hexane extractable material (HEM)
Type of Discharge
Direct, Indirect
Average Baseline Concentration (mg/L) |j
81
1
Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Up to the Collection of 1997 Tron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewater Sampling Program, 1997-1999.                           '
                                       Table 10-56

                 Proposed Arithmetic Long-Term Averages for the
                    Other Operations Subcategory DRI Segment
Pollutant of Concern
Aluminum
Iron
Total suspended solids (TSS)
Option
BPT
BPT
-BPT
Arithmetic Long-Term Average
(mg/L)
0.0403
2.40
10.3
Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Up to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewater Sampling Program, 1997-1999.
                                           10-107
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                                                           Section 10- Pollutant Loadings
                                   Table 10-57

               Proposed Arithmetic Long-Term Averages for the
                Other Operations Subcategory Forging Segment
1 Pollutant of Concern
Hexane extractable material
Option
BPT
Arithmetic Long-Term Average
(mg/L)
6.56
Sources: U.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys), U.S. EPA Analytical and Production
Data Follow-Uo to the Collection of 1997 Iron and Steel Industry Data (Analytical and Production Survey), and U.S. EPA Iron and Steel Industry
Wastewater Sampling Program, 1997-1999.
                                  Table 10-58
                                                                        i
                                                                        i
 Summary of Baseline and Post-Compliance Pollutant Loadings for the Other
         Operations Subcategory Forging Segment Direct Dischargers
Pollutant Group
Hexane extractable material (HEM) :
Baseline Load (Ibs/yr)
1,100
Treated Load Discharged to
Surface Water (Ibs/yr)
BPT
. . 652
                                  Table 10-59
    Summary of Pollutant Removals for the Other Operations Subcategory
                      Forging Segment Direct Dischargers
1 Pollutant Group
Hexane extractable material (HEM)
Pollutant Removals (Ibs/yr)
BPT
444
                                      10-108
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                                                                Section 11 - Regulated Pollutants
                                      SECTION 11

                              REGULATED POLLUTANTS

              This section describes the selection of regulated pollutants for each subcategory at
each statutory level (i.e., Best Practicable Control Technology Currently Available (BPT), Best
Control Technology for Conventional Pollutants (BCT), Best Available Technology Economically
Achievable (BAT), Pretreatment Standards for New Sources (PSNS), Pretreatment Standards for
Existing Sources (PSES), and New Source Performance Standards (NSPS)). Regulated
pollutants are pollutants for which EPA proposes to establish numerical effluent limitations and
standards.  EPA selected pollutants for regulation based on the following factors: applicable Clean
Water Act provisions regarding the pollutants subject to each statutory level, the pollutants of.
concern (POCs) identified for each subcategory and segment, and co-treatment of compatible
wastewater from different manufacturing operations. This section presents the following
information:

              •      Section 11.1 presents EPA's methodology for selecting regulated
                     pollutants for direct dischargers (those subject to BPT, BAT, or NSPS);

              •      Sections 11.2 through 11.8 discuss the regulated pollutants selected for
                     direct dischargers for each proposed subcategory;

              •      Section 11.9 presents EPA's methodology for selecting regulated
                     pollutants for indirect dischargers (those subject to PSES or PSNS); and

              •      Sections 11.10 through 11.16 discuss the regulated pollutants selected for
                     indirect dischargers for each proposed subcategory.
11.1
Regulated Pollutant Selection Methodology for Direct Dischargers
              The list of POCs for each subcategory represents those pollutants that are present
at treatable concentrations in a significant percentage of untreated wastewater from that
subcategory; Section 7 discusses the selection of POCs for each subcategory.  Effluent monitoring
for all POCs is not necessary to ensure that iron and steel wastewater pollution is adequately
controlled, since many of the pollutants originate from similar sources, have similar treatabilities,
are removed by similar mechanisms, and are treated to similar concentrations. Therefore, it may
be sufficient to monitor for one pollutant as a surrogate  or indicator of several others. .From the
POC list for each subcategory, EPA selected a subset of pollutants considered for regulation
(DCNIS05070 in Section 5.4 of the Iron and Steel Administrative Proposal Record). Factors
EPA considered in selecting pollutants considered for regulation from the list of POCs for each
subcategory include the following:

              •      The pollutant was detected in the untreated wastewater at the BAT
                     facility(ies) at treatable levels in a significant number of samples. EPA'
                                          11-1
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                                                                Section 11 - Regulated Pollutants
                     eliminated pollutants that were not detected at greater than 10 times the
                     minimum level in at least 10 percent of the untreated wastewater samples
                     from the BAT facility(ies)'.

              •      The pollutant is not used as a treatment chemical in the selected treatment
                     technology option. EPA excluded all pollutants that may serve as
                     treatment chemicals: aluminum, boron, iron, magnesium, manganese, and
                     sulfate (several other pollutants are commonly used as treatment chemicals
                     but were already excluded as POCs). EPA eliminated these pollutants
                     because regulating these pollutants could interfere with their beneficial use
                     as wastewater treatment additives.

              •      The pollutant is not considered a' nonconventional bulk parameter.  EPA
                     excluded many nonconventional bulk parameters (e.g., chemical oxygen
                     demand (COD), total Kjeldahl nitrogen (TKN), total organic carbon
                     (TOC), nitrate/nitrite, total petroleum hydrocarbons (TPH), total phenols)
                     because it determined it is more appropriate to target specific compounds
                     of interest rather than a parameter that measures a variety of pollutants  for
                     this industry.  The specific pollutants that comprise the bulk parameter may
                     or may not be of concern to EPA.

              •      The pollutant is not considered to be volatile.  Volatile pollutants are likely
                     to be volatilized in the treatment system and are therefore not considered to
                     be treated by the selected technology.  For purposes of this evaluation, a
                     pollutant was considered to be volatile if its Henry's Law Constant is
                     greater than 10"4 atm-nrVmol. If EPA could not obtain a Henry's Law
                     Constant for a particular pollutant, it assumed the pollutant was not
                     volatile.

              •      The pollutant is effectively treated by the selected treatment technology
                     option. EPA excluded all pollutants for which the selected treatment
                     option was ineffective (i.e., pollutant concentrations remained the same or
                     increased across the treatment system).

              From the list of pollutants considered for regulation, EPA determined the
pollutants to regulate. Generally, EPA selected at least one pollutant from each pollutant group
considered for regulation to ensure control of all remaining POCs in the pollutant group.  For
example, when one or more metals is proposed for regulation for a chemical precipitation system,
EPA presumes that controlling those metals will control all other metals considered for regulation.
The Agency did not propose for regulation POCs considered for regulation, but for which the
model treatment technology was not designed or intended to treat (e.g., chemical precipitation
systems are not designed to treat  organic constituents, so EPA did not select organic constituents
for regulation at options using only chemical precipitation).
                                           11-2
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                                                               Section 11 - Regulated Pollutants
              The Clean Water Act establishes three classes of pollutants (conventional,
 nonconventional, and priority) and dictates which classes of pollutants EPA may regulate at each
 statutory level for direct dischargers.

              •      BPT - Conventional, nonconventionalj and priority pollutants;
              •      BCT - Conventional pollutants;
              «      BAT - Nonconventional and priority pollutants; and
              •      NSPS - Conventional, nonconventional, and priority pollutants.

 Section 14 presents the technology options proposed for each statutory level. As discussed in
 Section 14, EPA is not proposing to revise BPT limitations for those manufacturing processes
 currently subject to BPT limitations at 40 CFR Part 420; EPA is only proposing BPT limitations
 for those manufacturing processes in the Other Operations Subcategory, as these processes are
 not currently regulated under Part 420. In addition, EPA did not identify any technologies that
 better removed conventionals than BPT and at the same time passed the cost-effectiveness test;
 therefore, EPA proposes that BCT limitations be set equal to BPT limitations for every
 subcategory. Sections 11.2 through 11.8 discuss the selection of pollutants proposed for
 regulation for direct dischargers on a subcategory basis.
11.2
Cokemaking Subcategorv
              EPA selected proposed regulated pollutants for the By-Product Recovery Segment
of the Cokemaking Subcategory only; EPA proposes zero discharge of pollutants from the Non-
Recovery Segment.  Table 11-1 lists pollutants proposed for regulation for this subcategory.  The
rationale for the selection of regulated pollutants for direct dischargers under this subcategory is
presented below.

              BAT

              For this subcategory, EPA proposes establishing BAT limitations for ammonia as
nitrogen, total cyanide, phenol, benzo(a)pyrene, naphthalene, thiocyanatCj mercury, selenium, and
total residual chlorine (TRC).  Except for TRC, these pollutants are characteristic of cokemaking
wastewater.  TRC is an indicator of post-alkaline chlorination residual chlorine concentration.
Facilities would not need to meet the TRC limit if they certify to the permitting authority that they
do not use alkaline chlorination in their wastewater treatment. These proposed regulated
pollutants are key indicators of the performance of the ammonia distillation, biological treatment,
and alkaline chlorination processes, which are the key components of the model BAT and NSPS
treatment systems for by-product coke plants.

              The Agency selected the pollutants to regulate from the list of POCs considered
for regulation, shown in Table 11-2. EPA believes that controlling the regulated pollutants will
control all the remaining POCs considered for regulation for this segment.  Controlling
benzo(a)pyrene, phenol, and naphthalene will effectively control all other remaining organic  .
constituent POCs. EPA believes the removal mechanisms in biological treatment systems that
                                          11-3
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                                                                Section 11 -Regulated Pollutants
remove these parameters will also remove the remaining organic constituent POCs. Controlling
mercury and selenium will also control the remaining metal POC, arsenic.  Likewise, controlling
total cyanide and thiocyanate will control the remaining cyanide compounds: amenable cyanide
and weak acid dissociable (WAD) cyanide.

              NSPS

              To ensure that the regulations for new sources represent the most stringent
numerical values attainable through the application of the best available control technology for all
pollutants, EPA proposes to regulate the same pollutants as for BAT, as well as total suspended
solids (TSS) and oil and grease (O&G).
11.3
Ironmaking Subcategorv
              EPA selected regulated pollutants for both the Blast Furnace and the Sintering
Segments of the Ironmaking Subcategory. Table 11-3 lists pollutants proposed for regulation for
this subcategory.  The rationale for the selection of regulated pollutants for direct dischargers
under this subcategory is presented below.

              BAT

              EPA proposes establishing BAT limitations for ammonia as nitrogen, lead, zinc,
total cyanide, phenol, and TRC for both the Blast Furnace and Sintering Segments. In addition,
2,3,7,8-tetrachlorodibenzoniran (TCDF) is proposed for the Sintering Segment only.  EPA
proposes to limit TRC to ensure that residual concentrations of chlorine are kept to a minimum to
avoid effluent toxicity.  Facilities would not need to meet the TRC limit if they certify to the
permitting authority that they do not use alkaline chlorination in their wastewater treatment.

           .  The Agency selected the pollutants to regulate from the list of POCs considered
for regulation, shown in Tables 11-4 and 11-5.  EPA believes that controlling the regulated
pollutants will also control all the remaining POCs considered for regulation for this subcategory.
Ammonia as nitrogen, phenol, and total cyanide are characteristic of blast furnace ironmaking
wastewater and are key indicators of the performance of the alkaline chlorination process.  Lead
and zinc are the principal metals present in wastewater from this subcategory; controlling these
metals will control of the remaining metal POCs considered for regulation, as well as fluoride,
which is also treated by the model technology.  Likewise, controlling total cyanide will also
control the remaining cyanide compounds considered for regulation: amenable cyanide,
thiocyanate, and WAD cyanide. 2,3,7,8-TCDF is the principal PCDD/PCDF present in sintering
wastewater and will indicate contrbl of the remaining PCDDs/PCDFs. EPA is not proposing to
regulate pyridine, the remaining organic constituent, because the model treatment system is not
designed to treat organics and because the total estimated industry treated effluent loading of
pyridine is minimal (0.07 Ib-equivalents/year).
                                          11-4
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                                                                Section 11 - Regulated Pollutants
              NSPS

              To ensure that the regulations for new sources represent the most stringent
numerical values attainable through the application of the best available control technology for all
pollutants, EPA proposes to regulate the same pollutants as for BAT, as well as TSS and O&G.
11.4
Integrated Steelmaking Subcategorv
            .  The regulated pollutants selected for the Integrated Steelmaking Subcategory
apply to all three manufacturing processes included in this subcategory: basic oxygen furnace
(EOF) Steelmaking, vacuum degassing, and continuous casting.  EPA proposes to regulate ladle
metallurgy at zero discharge of pollutants.  Table 11-6 lists pollutants proposed for regulation for
this subcategory.  The rationale for the selection of regulated pollutants for direct dischargers
under this subcategory is presented below.                                              r

              BAT/NSPS

              For this subcategory, EPA proposes establishing BAT and NSPS limitations for
lead and zinc.  These metals are key indicators of the performance of'the solids removal and
metals precipitation processes of the model BAT and NSPS treatment system.

              The Agency selected the pollutants to regulate from the list of POCs considered
for regulation,  shown in Table 11-7. EPA believes that controlling the regulated pollutants will
control all the other metal POCs considered for regulation in this subcategory.  EPA is not
proposing to regulate ammonia as nitrogen, because the model treatment system is not designed
to treat it and because the total estimated industry treated effluent loading of ammonia as nitrogen
is minimal (85  Ib-equivalents/year).
11.5
Integrated and Stand-Alone Hot Forming Subcategorv
              EPA selected regulated pollutants for both the Carbon and Alloy Steel and the
Stainless Steel Segments of the Integrated and Stand-Alone Hot Forming Subcategory. Table
11-8 lists pollutants proposed for regulation for this subcategory.  The rationale for the selection
of regulated pollutants for direct dischargers under this subcategory is presented below.

11.5.1         Carbon and Alloy Steel Segment

              BAT

              For this segment, EPA proposes BAT limitations for lead and zinc. These metals
are key indicators of the performance of the solids removal and metals precipitation processes of
the model BAT and NSPS treatment systems.
                                          11-5
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                                                               Section 11 - Regulated Pollutants
              The Agency selected the pollutants to regulate from the list of POCs considered
for regulation, shown in Table 11-9. EPA believes that controlling the regulated parameters will
also control all of the other metal POCs considered for regulation in this subcategory, as well as
fluoride, which is also treated by the model technology. The model treatment system is not
specifically designed to treat ammonia as nitrogen, but the total estimated industry effluent
loading is minimal at 1,086 Ib-equivalents/year.

              NSPS

              To ensure that the regulations for new sources represent the most stringent
numerical values attainable through the application of the best available control technology for all
pollutants,'EPA proposes to regulate the same pollutants as for BAT, as well as TSS and O&G.
11.5.2        Stainless Steel Segment

              BAT

              For this segment, EPA proposes establishing BAT limitations for chromium and
nickel, rather than lead and zinc, because of their'prominence in stainless steel.  These metals are
key indicators of the performance of the solids removal and metals precipitation processes of the
model BAT and NSPS treatment systems.

              The Agency selected the pollutants to regulate from the list of POCs considered
for regulation, shown in Table 11-10. EPA believes that controlling the regulated pollutants will  ,
also control all other metal POCs considered for regulation in this subcategory, as well as
fluoride, which is also treated by the model technology.

              NSPS

              To ensure that the regulations for new sources represent the most stringent
numerical values attainable through the application of the best available control technology for all
pollutants, EPA proposes to regulate the same pollutants as for BAT, as well as TSS and O&G.
11.6
Non-Integrated Steelmaking and Hot Forming Subcategorv
              EPA selected regulated pollutants for continuous casting and hot forming
operations in both the Carbon and Alloy Steel and the Stainless Steel Segments of the Non-
Integrated Steelmaking and Hot Forming Subcategory. EPA proposes to regulate electric arc
furnace (EAF) Steelmaking and ladle metallurgy manufacturing operations at zero discharge of
pollutants.  Table 11-11 lists pollutants proposed for regulation for this subcategory. The
rationale for the selection of regulated pollutants for direct dischargers under this subcategory is
presented below.
                                          11-6
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                                                                Section 11 - Regulated Pollutants
 11.6.1        Carbon and Alloy Steel Segment

              BAT

              For this segment, EPA proposes BAT limitations for lead and zinc. These
 pollutants are key indicators of the performance of the solids removal and metals precipitation
 processes of the model BAT treatment system.

              The Agency selected the pollutants to regulate from the list of POCs considered
 for regulation, -shown in Table 11-12. EPA is not proposing to regulate ammonia as nitrogen,
 because the model treatment system is not designed to treat it and because the total estimated
 industry treated effluent loading of ammonia as nitrogen is minimal (179 Ib-equivalents/year).

              NSPS

              EPA is proposing zero discharge of pollutants for NSPS.

 11.6.2        Stainless Steel Segment

              BAT

              For this segment, EPA proposes BAT limitations for chromium .and nickel, rather
 than lead and zinc, because of their prominence in stainless steel. These pollutants are key
 indicators of the performance of the solids removal and metals precipitation processes of the
 model BAT treatment system.

              The Agency selected the pollutants to regulate from the list of POCs considered
 for regulation, shown in Table 11-13.  EPA believes  that controlling the regulated pollutants will
 also control all other metal POCs considered for regulation in this subcategory, as well as
 fluoride, which is also treated by the model technology.

       •       NSPS
11.7
EPA is proposing zero discharge of pollutants for NSPS.

Steel Finishing Subcategorv
              EPA selected regulated pollutants for both the Carbon and Alloy Steel and the
Stainless Steel Segments of the Steel Finishing Subcategory. Table 11-14 lists pollutants
proposed for regulation for this subcategory. The rationale for the selection of regulated
pollutants for direct dischargers under this subcategory is presented below.
                                          11-7
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                                                               Section 11 - Regulated Pollutants
11.7.1        Carbon and Alloy Steel Segment

              BAT

              For this segment, EPA established BAT limitations for hexavalent chromium,
chromium, lead, and zinc.  These metals are key indicators of the performance of the solids
removal and metals precipitation processes of the model BAT and NSPS treatment systems.
                                                                               !
              The Agency selected the pollutants to regulate from the list of POCs considered
for regulation, shown in Table 11-15.  EPA believes that controlling the regulated pollutants will
also control all other metal POCs in this subcategory, as well as fluoride, which is also trpated by
the model technology. The model treatment system is not specifically designed to treat brganics,
but the only organic constituent considered for regulation, n-eicosane, was removed by 93 percent
in the model treatment system and was never detected in the effluent of any carbon and alloy steel
finishing treatment systems. The model treatment system also is not specifically designed to treat
ammonia as nitrogen, but it removed ammonia by 24 percent and the total estimated industry
effluent loading is minimal (813 Ib-equivalents/year).

              The 1982 regulation also limits naphthalene and tetrachloroethylene for cold
forming wastewater; EPA does not propose regulating these parameters. EPA did not select
either naphthalene or tetrachloroethylene as a POC for the Carbon and Alloy Steel Segment of the
Steel Finishing Subcategory.  As a result of the 1982 regulation, most cold forming facilities
started using cold rolling lubricant formulations that did not contain these toxic organic
constituents. Because EPA is not proposing to revise BPT for this subcategory, facilities
continuing to use naphthalene and tetrachloroethylene in their cold forming solutions would still
be subject to 1982 BPT limits (which are equivalent to 1982 BAT limits) on these pollutants.

              NSPS

              To ensure that the regulations for new sources represent the most stringent
numerical values attainable through the application of the best available control technology for all
pollutants, EPA proposes to regulate the same pollutants as for BAT, as well as TSS and O&G.

11.7.2        Stainless Steel Segment

              BAT

              For this segment, EPA established BAT limitations for hexavalent chromium,
chromium, nickel, ammonia as nitrogen, and fluoride. These pollutants are key indicators of the
performance of the solids removal and metals precipitation processes of the model BAT and
NSPS treatment systems. Because ammonia as nitrogen is chiefly present only in wastewater
from nitric acid pickling operations, ammonia as nitrogen is only regulated for acid pickling.and
other descaling operations  and wet air pollution control devices associated with these operations.
                                          11-8
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                                                                 Section 11 - Regulated Pollutants
              The Agency selected the pollutants to regulate from the list of POCs considered
 for regulation, shown in Table 11-16.  EPA believes that controlling regulated pollutants will also
 control all other POCs considered for. regulation in this subcategory.

              EPA is considering developing a limit for nitrate/nitrite for stainless steel finishing
 operations with combination acid pickling.  EPA identified nitrate/nitrite as a POC for stainless
 steel acid pickling operations that use nitric acids and' combinations of nitric and hydrofluoric
 acids to treat the surfaces of various grades of stainless steels. Nitrates originate from the nitric
 acids used in the process and are released from three  sources: waste or spent pickling acids, pickle
 rinse waters, and acid pickling fume scrubbers. Some stainless steel finishing facilities dispose of
 their nitrate-bearing wastewater via off-site hauling. Many other stainless steel finishing facilities
 treat spent nitric a'cid and nitric/hydrofluoric acid, pickle liquors on site with the pickling rinse
 waters and fume scrubber waters from other stainless steel finishing operations. Nitrates are
 soluble in water and, thus, are not removed to any appreciable degree in the metals precipitation
 systems used to treat chromium and nickel in stainless steel finishing wastewater.

              EPA collected information from mills with stainless steel finishing operations with
 on-site chemical precipitation treatment of spent nitric and nitric/hydrofluoric acids in combination
 with pickle rinse waters and acid pickling fume scrubber blowdown. The treated effluent nitrate
 concentrations from these mills ranged from about 500 mg/L to more than  1,000 mg/L.

              Several stainless steel acid pickling lines use acid purification systems to recover
 and reuse nitric and nitric/hydrofluoric acids.  This technology removes dissolved metals (iron,
 chromium, nickel) from a side stream of the strong acid pickling solution and returns the purified
 acid to the acid pickling bath. This essentially extends the life of the pickling acids, thereby
 reducing the consumption of virgin nitric acid. A reject stream containing dilute acid and the
 dissolved metals is periodically sent to wastewater treatment.

              The model BAT technology for stainless steel finishing operations includes acid
purification units for recovery and reuse of spent nitric and nitric/hydrofluoric acid pickling
 solutions. EPA believes facilities using acid purification technology can achieve long-term
 average concentrations of nitrates in the treated stainless steel acid pickling wastewater effluent in
the range of 200 mg/L to 300 mg/L.

              The 1982 regulation also limits naphthalene and tetrachloroethylene for cold
 forming wastewater and total cyanide for salt bath descaling operations; EPA does not propose
regulating these parameters. EPA did not select tetrachloroethylene as a POC for this segment;
EPA did select naphthalene as a POC for this  segment, but did not consider it for regulation
because it was not detected in the  influent of the model treatment facilities (naphthalene was also
not detected in the effluent of any facility in this segment). As a result of the 1982 regulation,
most cold forming facilities started using cold rolling lubricant formulations that did not contain
these toxic organic constituents: EPA also does not propose regulating total cyanide because, as
a result of the 1982 regulation, many facilities changed their descaling solutions or started using
new descaling processes such as electrolytic sodium sulfate descaling. Because EPA is not
                                           11-9
-------
                                                               Section 11 - Regulated Pollutants
proposing to revise BPT for this subcategory, facilities continuing to use cyanide in their reducing
salt bath descaling operations or naphthalene and tetrachloroethylene in their cold forming
solutions would still be subject to 1982 BPT limits (which are equivalent to 1982 BAT limits) on
these pollutants.

              NSPS

              To ensure that the regulations for new sources represent the most stringent
numerical values attainable through the application of the best available control technology for all
pollutants, EPA proposes to regulate the same pollutants as for BAT, as well as TSS arid O&G.
11.8
Other Operations Subcategorv
              EPA selected regulated pollutants for the Direct Reduced Ironmaking and the
Forging Segments of the Other Operations Subcategory.  The Briquetting Segment is proposed to
be regulated at zero discharge of pollutants. Table 11-17 presents the list of pollutants proposed
for regulation for the Other Operations Subcategory. The rationale for the selection of regulated
pollutants for direct dischargers under this subcategory is presented below.

11.8.1        Direct Reduced Ironmaking Segment

              BPT/BCT/NSPS

              The Agency proposes to regulate TSS for the Direct Reduced Ironmaking
Segment.  This pollutant is a key indicator of the performance of the solids removal and filtration
processes of the model treatment systems.

              The Agency selected TSS to regulate from the  list of POCs considered for
regulation, shown in Table 11-18. EPA believes that controlling TSS will also incidentally control
all other POCs considered for regulation in this segment.                     .

11.8.2        Forging Segment

              BPT/BCT/NSPS

              The Agency proposes to regulate TSS and O&G for the Forging Segment.  EPA is
not proposing BAT limitations for this segment because it identified no priority or
nonconventional POCs for the segment.
11.9
Regulated Pollutant Selection Methodology for Indirect Dischargers
              Unlike direct dischargers whose wastewater receives no further treatment once it
leaves the facility, indirect dischargers send their wastewater to publicly owned treatment works
(POTWs) for further treatment.  However, POTWs typically install secondary biological
                                         11-10
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                                                               Section 11 - Regulated Pollutants
 treatment systems which are designed to control conventional pollutants (biochemical oxygen
 demand (BOD5), TSS, O&G, pH, and fecal coliform), the principal parameters in domestic
 sewage. Except for nutrient control for ammonia and phosphorus, POTWs usually do not install
 (advanced or tertiary treatment) technology to control priority and nonconventional pollutants,
 although secondary biological treatment systems may achieve significant removals for some
 priority pollutants. Instead, the Clean Water Act envisions that, implementation of pretreatment
 programs and industrial compliance with categorical pretreatment standards, will adequately
 control priority and nonconventional pollutants in municipal effluents.

              Therefore, for indirect dischargers, before establishing national technology-based
 pretreatment standards, EPA examines whether the pollutants discharged by the industry "pass
 through" POTWs to waters of the United States or interfere with POTW operations'or sludge
 disposal practices.  Generally, to determine if pollutants pass through POTWs, EPA compares the
 percentage of the pollutant removed by well-operated POTWs achieving secondary treatment
 with the percentage of the pollutant removed by facilities meeting the proposed BAT effluent
 limitations.  A pollutant is determined to "pass through" POTWs when the median-percentage
 removed by well-operated POTWs is less than the median percentage removed by direct
 dischargers complying with BAT effluent limitations. In this manner, EPA can ensure that the
 combined treatment at indirect dischargers and POTWs is at least equivalent to treatment by
 direct dischargers.                                                         •

              For specific pollutants, such as volatile organic compounds, EPA may use other
 means to determine pass-through. These evaluations may include chemical and physical
 properties (e.g., Henry's Law constants, octanol/water partition coefficients, and water solubility
 constants) and empirical data to estimate amounts of volatilization, biodegradation, and/or
 partitioning to the residue solids phase.

              This approach to the definition of pass-through satisfies two competing objectives
 set by Congress: (1) that standards for indirect dischargers be equivalent to standards for direct
 dischargers,  and (2) that the treatment capability and performance of POTWs be recognized and
 taken into account in regulating the discharge of pollutants from indirect dischargers.  Rather than
 compare the mass or concentration of pollutants discharged by POTWs with the mass or
 concentration of pollutants discharged by BAT facilities, EPA compares the percentage of the
pollutants removed by BAT facilities to the POTW removals.  EPA takes this approach because
comparing the mass or concentration of pollutants in POTW effluents with pollutants in BAT
facility effluents would not take into account the mass of pollutants discharged to the POTW from
other industrial and nonindustrial sources, nor the dilution of the pollutants in the POTW effluent
to lower concentrations from the addition of large amounts of other industrial and nonindustrial
water.

             In selecting the regulated pollutants under the pretreatment standards, EPA starts
with the priority and nonconventional pollutants regulated for direct dischargers under BAT for
each subcategory and submits those pollutants to the pass-through test. Those pollutants that
EPA determines pass through POTWs are the pollutants it proposes to regulate. The following
                                         11-11
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                                                             Section 11 - Regulated Pollutants
subsections describe the methodology used in determining median percent removals for "well-
operated" POTWs and the median percent removals for the BAT technologies. Sections 11.10  .
through 11.16 present the results of the POTW pass-through analysis for each subcategory, along
with discussions of regulated pollutant selection for PSES and PSNS.
11.9.1
POTW Pass-Through Methodology
             The following subsections describe the methodology used in determining median
percent removals for 'Veil-operated" POTWs and the proposed BAT technologies and the
methodology used for the volatile override test of the pass-through analysis.

             Determination of Percent Removals for Well-Operated POTWs

             The following explains the methodology used to estimate percent removals for
well-operated POTWs for the proposed Iron and Steel rule.  EPA is considering revising its
determination of percent removals for "well-operated" POTWs. Interested parties should consult
Appendix B and provide comment.

             For the proposed Iron and Steel rule, EPA used its traditional methodology to
determine POTW performance (percent removal) for priority and nonconventional pollutants.
POTW performance is a component of the pass-through methodology used to identify the
pollutants to  be regulated for PSES and PSNS. It is also a component of the analysis to
determine net pollutant reductions (for both total pounds and toxic pound-equivalents) for various
indirect discharge technology options (see Section 10).  However, as discussed hi more detail in
Appendices B and C, EPA is considering revising its traditional methodology for determining
POTW performance (percent removals) for priority and nonconventional pollutants.

             The primary source of the POTW percent removal data is the Fate of Priority
Pollutants in  Publicly Owned Treatment Works (Reference 11-1), commonly referred to as the
"50-POTW Study." However, the 50-POTW Study did not contain data for all pollutants for
which the pass-through analysis was required. Therefore, EPA obtained additional data from
EPA's National Risk Management Research Laboratory (NRMRL)'s Treatability Database   s
(formerly called the Risk Reduction Engineering Laboratory (RREL) Treatability Database), as
well as data from POTWs that accept iron and steel plant wastewater.  EPA used data from the
latter source  only if no data were available from the 50-POTW Study or the NRMRL database.
These sources and their uses are discussed below.

             The 50-POTW Study presents data on the performance of 50 well-operated
POTWs that  use secondary biological treatment in removing pollutants. At the time of the 50-
POTW sampling program, which spanned approximately 2.5 years (July 1978 to November
1980), EPA collected samples at selected POTWs across the United States. At most of these
POTWs, EPA collected a minimum of 6 days of 24-hour composite influent and effluent
wastewater samples. EPA analyzed each sample for the conventional pollutants (excluding fecal
coliform), selected nonconventional pollutants, and 126 priority pollutants. The conventional
                                        11-12
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                                                                Section 11 - Regulated Pollutants
 pollutants, listed at 40 GFR 401.16, are BOD5, TSS, O&G, pH, and fecal coliform.  The selected
 nonconyentional pollutants included COD, TOC, total phenols, ammonia as nitrogen, iron,
 aluminum, and magnesium, among others. The priority pollutants consist of the 126 compounds
 (listed in Appendix A of 40 CFR Part 423) that are a subset of the 65 priority pollutants and
 classes of pollutants referred to in Section 307(a) of the Clean Water Act and listed at 40 CFR
 401.15. A total of 102 of the 126 priority pollutants were detected at least once in POTW
 influents (Reference 11-1).

              Each laboratory reported results for the pollutants that it tested.  If the laboratory
 found a pollutant to be present, the laboratory reported a result. If the laboratory found the
 pollutant not to be present, the laboratory reported either that the pollutant was "not detected' or
 a value with a "less than" sign •(<) indicating that the pollutant was below that value. The value
 reported along with the "less than" sign was the lowest level to which the laboratory believed it
 could reliably measure. EPA subsequently established these lowest levels as the minimum levels
 of quantitation (MLs). hi some instances, different laboratories reported different MLs for the
 same pollutant using the same analytical method.

              Because of the variety of reporting protocols among the 50-POTW Study
 laboratories (Reference 11-1), EPA reviewed the percent removal calculations used in the pass-
 through analysis for previous industry studies, including those performed when developing the
 effluent limitations guidelines and standards for Organic Chemicals, Plastics, and Synthetic Fibers
 (OCPSF), Commercial Hazardous Waste Combustors, and Centralized Waste Treatment (CWT)
 industries.  EPA found that, for 12 parameters, different analytical MLs were reported for
 different rulemaking studies (nine of the metals, cyanide, and one of the organics). To provide
 consistency for data analysis and establishment of removal efficiencies, EPA reviewed the 50-
 POTW Study and standardized the reported MLs for use in the CWT final rule and other
 rulemaking efforts.

           .   In using the 50-POTW Study data to estimate percent removals, EPA established
 data-editing criteria for determining pollutant percent removals. As noted in the 50-POTW
 Study, analytical laboratories reported pollutant concentrations below the ML qualitatively, as
 "not detected" or "trace," and reported a measured value above this level (Reference 11-1).
 Subsequent rulemaking studies such as the 1987 OCPSF study used the analytical method ML
 established in 40 CFR Part 136 for laboratory data reported below the analytical ML. Using the
 ML may overestimate the effluent concentration and underestimate the percent removal. (If the
 actual effluent concentration is less than the minimum level, then the calculated percent removal
 based on the actual value would be higher.) Because the data collected for evaluating POTW
percent removals included both effluent and influent levels that were close to the analytical ML,
 EPA devised  hierarchial data-editing criteria to exclude data with low influent concentration
 levels, thereby minirnizing the possibility that low POTW removals might simply reflect low
influent concentrations instead of being a true measure of treatment effectiveness.

              EPA used hierarchic data-editing criteria for the pollutants in the 50-POTW Study.
For the proposed Iron and Steel rule, the data-editing criteria included the following:
                                          11-13
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                                                                Section 11 - Regulated Pollutants
              •      Both influent and effluent data on a given date were deleted if either datum
                     has a notation of analytical interference;

              •      The standardized pollutant-specific analytical ML was substituted for
                     values reported as "not detected," "trace," "less than (followed by a
                     number)," or a number less than the standardized analytical ML;

              •      Detected pollutants had to have at least three pairs (influent/effluent) of
                     data points to be included;

              •      The average pollutant influent level had to be greater than or equal to 10
                     times the pollutant minimum level (10 x ML); and

              •      If none of the average pollutant influent concentrations were at least 10
                     times the minimum level, then data with average influent values greater
                     than twice the minimum level (2 x ML) or greater than or equal to 20 ug/L
                     were included, along with the corresponding average effluent values.

              EPA then calculated each POTW percent removal for each pollutant based on its
average influent and effluent values. The national POTW percent removal used for each pollutant
in the pass-through test is the median value of all the POTW pollutant-specific percent removals.

              The rationale for retaining POTW data using the " 10 times the pollutant minimum
level" editing criterion was based on the BAT organic pollutant treatment performance editing
criteria initially developed for the 1987 OCPSF regulation (40 CFR Part 414; 52 FR 42522 at
42545 to 48). BAT treatment system designs in the OCPSF industry typically removed at least 90
percent of toxic pollutants. Since most of the OCPSF effluent data from BAT biological
treatment systems had values of "not detected,"1 the average influent concentration for a
compound had to be at least 10 times  the analytical  ML for the difference to be meaningful
(demonstration of at least 90 percent removal) and qualify effluent concentrations for calculation
of effluent limits (Reference 11-2).

              EPA also used data  from the NRMRL Treatability Database (Reference ,11-3) to
augment the POTW database for the pollutants that the 50-POTW Study did not cover. This
database provides information, by pollutant, on removals obtained by various treatment
technologies. The database provides the specific data source and the industry from which the
wastewater was generated. For each POC that EPA considered for the proposed rule not found
in the 50-POTW Study database, EPA used data from the NRMRL database, using only
treatment technologies representative of typical POTW secondary treatment operations (i.e.,
1 Of the 57 regulated organic pollutants, limits for 34 (60 percent) were based on long-term averages (LTAs) of "not
detected" or the analytical minimum level (Development Document for Effluent Limitations Guidelines and Standards
for the Organic Chemicals. Plastics, and Synthetic Fibers Point Source Category - the OCPSF DD, Vol. I. EPA 440/1 -
87/009, October 1987, pages VH-208 to VII-210).
                                           11-14
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                                                               Section 11 -Regulated Pollutants
activated sludge, activated sludge with filtration, and aerated lagoons). EPA further edited these
files to include information pertaining only to domestic or industrial wastewater. EPA used pilot-
scale and full-scale data only, and eliminated bench-scale data and data from less reliable
references. Zero and negative percent removals were eliminated, as well as data with less'than
two pairs of influent/effluent data points.  Finally, EPA calculated the average percent removal for
each pollutant from the remaining pollutant removal data.                     .

              EPA used one additional source to determine POTW percent removals: data
collected from POTWs receiving wastewater from iron and steel sites. The Agency used these
data for determining the POTW percent removal for TKN and WAD cyanide. The following
table presents the data for these pollutants.

                 1997 POTW Data for TKN and WAD  Cyanide Removals
POTW
Influent
(mg/L)
Effluent
(mg/L)
Percent Removal
TKN
Middletown, OH POTW
City of Warren, OH POTW
Greater Chicago, EL POTW (Calumet)
Average (TKN)
24.6
17.4
23.7

4.3
1.8
0.63

83%
89%
97%
90%
WAD Cyanide
City of Warren, OH POTW
Average (WAD Cyanide)
0.16

0.009

93%
93%
              In addition to the sources listed above, EPA transferred some POTW percent  •
removals from another pollutant. Table 10-2 in Section 10 lists which pollutants received a
transferred POTW percent removal and from which surrogate pollutant.                •    •

              EPA selected the final percent removal for each pollutant based on data hierarchy,
which was related to the quality of the data source. The Agency used the following hierarchy to
select a POTW percent removal for a pollutant:

              •      The median percent removal from the 50-POTW Study was chosen using
                    all POTW data with influent levels greater than or equal to 10 times the
                    pollutant minimum analytical detection limit;

              •      The median percent removal from the 50-POTW Study was chosen using
                    all POTW data with influent levels greater than two times the pollutant
                    minimum analytical detection limit or 2 ug/L;
                                         11-15
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                                                               Section 11 -Regulated Pollutants
              •      The average percent removal from the NRMRL Treatability Database was
                    chosen using only domestic wastewater;

              •      The average percent removal from the NRMRL Treatability Database was
                    chosen using domestic and industrial wastewater;

              •      The average percent removal from POTWs receiving iron and steel
                    industry wastewater was chosen; and

              •      The pollutant was assigned an average group percent removal, "generic"
                    percent removal, or surrogate pollutant percent removal.

              The CWT rule developed pollutant groups by combining pollutants with similar
chemical structures. EPA calculated the average group percent removal by using all pollutants in
the group with selected percent removals from either the 50-POTW Study or the NRMRL
Treatability Database. EPA then averaged percent removals together to determine the average
group percent removal. Chapter 7 of the U.S. EPA Development Document for Proposed
Effluent Limitations Guidelines and Standards for the Centralized Waste Treatment Industry
(Volume I) (Reference 11-4) presents pollutant groups and generic removals used in the pass-
through analysis.

              Table 10-2 hi Section 10 presents the final POTW percent removal assigned to
each pollutant. Table 11-19 presents the POTW percent removals for pollutants proposed for
regulation at BAT, along with the source and data hierarchy of each removal.

              Methodology for Determining Treatment Technology (BAT) Percent
              Removals

              EPA calculated treatment percent removals for each selected BAT option using
the data used to determine the option LTAs and variability factors.  Therefore, the data used to
calculate treatment option percent removals was subjected to the same data-editing criteria as the
data used in calculating LTAs and variability factors (described in Section 12). This editing
included excluding the influent and effluent data for pollutants that were not detected in the
influent at treatable levels, excluding data for pollutants that were not treated by the technology,
and excluding data that were associated with process upsets.

              EPA used the influent and effluent concentrations (paired data) at sites
incorporating BAT to calculate the percent removal, if available. If there were multiple BAT sites
with pollutant data, EPA calculated a percent removal for each site and used the median percent
removal for the pass-through analysis.  For the Cokemaking (ammonia as nitrogen and total
cyanide only), IronmaMng (ammonia as nitrogen, lead, total cyanide, and zinc only), and Non-
Integrated Steelmaking and Hot Forming (Carbon and Alloy Segment) Subcategories, influent
data were not available for BAT sites and the average influent concentration was calculated using
EPA's iron and steel sampling data.
                                         11-16
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                                                               Section 11 - Regulated Pollutants
             After editing the data, EPA used the following methodology to calculate percent
removals:
                    For each pollutant and each BAT facility (or sampled facility), EPA
                    averaged the influent and effluent data to give an average influent
                    concentration and an average effluent concentration.

                    EPA calculated percent removals for each pollutant and each BAT facility
                    (or sampled facility) from the average influent and average effluent
                    concentrations using the following equation:
                      Percent Removal =
  Cfavg) - Ce(avg)
       Cj(avg)
x 100
(11-1)
                    where:
                           Q(avg)
                           Ce(avg)
       Average influent concentration, mg/L
       Average effluent concentration, mg/L.
                    EPA used the above equation for all pollutants and subcategories, except
                    for benzo(a)pyrene, mercury, naphthalene, phenol, selenium, and
                    thiocyanate for the Cokemaking Subcategory.  The Agency calculated
                    percent removals for these pollutants using paired data from the
                    cokemaking BAT site, where control water is added to the treatment
                    system resulting in dilution of the influent. To ensure that the calculated
                    BAT percent removal was actual treatment, rather than dilution, EPA
                    performed a mass loadings analysis and calculated the percent removal
                    using the following equation:
                                         rc.xF.i   - rc XF i
                     Percent Removal =  L  '   |Javg	L e   eJavg  x 100
                                          (11-2)
                    where:
                           Q
                                                    Javg
Influent concentration
Influent flow rate
Effluent concentration
Effluent flow rate.
             3.      EPA calculated the BAT median percent removal for each pollutant for
                    each selected BAT option from the facility-specific percent removals.
                                         11-17
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                                                               Section 11 - Regulated Pollutants
              Volatile Override for Cokemaking

              EPA applies the volatile override test when the overall percent removal estimated
for well-operated POTWs is substantially caused by emission of the pollutant to the air rather than
by actual treatment. Therefore, even though the POTW percent removal data indicate that
volatile pollutants would not pass through, regulation of these pollutants is warranted to ensure
their "treatment."

              The EPA-selected technology option for the Cokemaking Subcategory is designed
to control the emission of volatile pollutants. As such, for the proposed rulemaking, EPA believes
the volatile override test is appropriate and has determined pass-through for the Cokemaking
Subcategory by comparing percent removals and Henry's Law Constants.

              The selected BAT technology option for the Cokemaking Subcategory is the only
option designed to treat volatile pollutants; therefore, it is the only Subcategory for which the
volatile override test is applicable. Because this analysis applies only to pollutants that potentially
volatilize and do not pass through based on percent removal comparison, it applies only to
benzo(a)pyrene.  For this analysis, EPA considered pollutants with a Henry's Law Constant
greater than 10"4 atm-mVmol to pass through POTWs based on the volatile override.
11.10
Cokemaking Subcategorv
              EPA selected proposed regulated pollutants for only the By-Product Recovery
Cokemaking Segment of the Cokemaking Subcategory; EPA proposes zero discharge of
pollutants from the Non-Recovery Segment. Table 11-1 lists the pollutants proposed for
regulation for this Subcategory. The rationale for the selection of regulated pollutants for indirect
dischargers under this Subcategory is presented below.

              PSES/PSNS                       .

              Of the nine pollutants selected for regulation at BAT, EPA evaluated eight of these
for pass-through. The only pollutant regulated at BAT but not evaluated for pass-through was
total residual chlorine (TRC).  TRC is not characteristic of cokemaking wastewater, but indicates
post-alkalhie-chlorination residual chlorine concentration.  EPA did not evaluate TRC for pass-
through because the selected PSES option does not include alkaline chlorination. Table 11-20
presents pass-through results for the Cokemaking Subcategory.

              Of the eight pollutants evaluated, six were found to pass through:

              •,      Nonconventionals - Ammonia as nitrogen, thiocyanate, and total  cyanide;
              •       Priority organic constituents - Naphthalene and phenol; and
              •       Priority metal - selenium.
                                          11-18
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                                                               Section 11 - Regulated Pollutants
 Therefore, EPA proposes to regulate these six parameters for PSES and PSNS.  EPA notes that
 ammonia as nitrogen is a key indicator of the performance of the PSES and PSNS treatment
 systems because it reflects the performance of the ammonia stills, which not only control ammonia
 as nitrogen, but also acid gases (hydrogen cyanide, hydrogen sulfide) and volatile organic
 pollutants (benzene, toluene, xylenes). Some portions of these gases would otherwise be emitted
 to the air in coke plant and municipal sewer systems and in biological processes at POTWs.
 11.11
Ironmaking Subcategorv
              EPA selected regulated pollutants for both the Blast Furnace and the Sintering
Segments of the Ironmaking Subcategory. Table 11-3 lists the pollutants proposed for regulation
for this subcategory. The rationale for the selection of regulated pollutants for indirect
dischargers under this subcategory is presented below.

              PSES/PSNS

              Of the seven pollutants selected for regulation at BAT, EPA evaluated six of these
for pass through.  The only pollutant regulated at BAT, but not evaluated for pass-through, was
TRC. TRC is not characteristic of ironmaking wastewater, but is an indicator of post-alkaline-
chlorination residual chlorine concentration.  Since the selected PSES option for ironmaking does
not contain alkaline chlorination, TRC will not be regulated. Table 11-21 presents pass-through
results for the ironmaking subcategory.

              Of the six pollutants evaluated, four were found to pass through. Listed below are
the pollutants found to pass through for the Ironmaking Subcategory:

              •      Nonconventional - Ammonia as nitrogen;
              •      Nonconventional organic constituent - 2,3,7,8-TCDF; and
              •      Priority metals - Lead and zinc.

              EPA proposes to regulate these parameters for PSES and PSNS (2,3,7,8-TCDF
for the Sintering Segment only).
11.12
Integrated Steelmaking Subcategorv
             The regulated pollutants selected for the Integrated Steelmaking Subcategory
apply to all three manufacturing processes included in this subcategory: basic oxygen furnace
(BOF) steelmaking, vacuum degassing, and continuous casting. EPA proposes to regulate ladle
metallurgy at zero discharge of pollutants.  Table 11-6 lists pollutants proposed for regulation for
this subcategory. The rationale for the selection of regulated pollutants for indirect dischargers
under this subcategory is presented below.
                                         11-19
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                                                               Section 11 - Regulated Pollutants
             PSES/PSNS                                                     '

             Two pollutants were selected for regulation at BAT: lead and zinc. Both were
found to pass through POTWs.  Table 11-22 presents the pass-through results for the Integrated
Steelmaking Subcategory.
11.13
EPA proposes to regulate lead and zinc at PSES and PSNS.

Integrated and Stand-Alone Hot Forming Subcategbry
             EPA selected regulated pollutants for both the Carbon and Alloy Steel and the
Stainless Steel Segments of the Integrated and Stand-Alone Hot Forming Subcategory.  Table
11-8 lists the pollutants proposed for regulation for this Subcategory. The rationale for the
selection of regulated pollutants for indirect dischargers under this subcategory is presented
below.

11.13.1      Carbon and Alloy Steel Segment

             PSES

             Two pollutants were selected for regulation at BAT for the Carbon and Alloy Steel
Segment: lead and zinc. Neither pollutant was found to pass through POTWs. Table 11-23
presents the pass-through results for the Integrated and Stand-Alone Hot Forming Subcategory.

             EPA proposes not to revise PSES for this segment. The Agency believes that
pretreatment local limits implemented on a case-by-case basis can more appropriately address any
individual toxic parameters present at these facilities. The Agency also does not believe that it is
practicable for a direct discharging facility covered by this segment to become an indirect
discharging facility because its flows would be too large  for a POTW to handle.

             PSNS    '

             EPA does not propose to revise PSNS for this segment because EPA does not
foresee the construction of any new indirect discharging facilities that would be subject to this
segment.                                                                      ;

11.13.2      Stainless Steel Segment

             PSES/PSNS

             Two pollutants were selected for regulation at BAT for the Stainless Steel
Segment: chromium and nickel.  Both pollutants were found to pass through POTWs. Table
11-23 presents pass-through results for the Integrated and Stand-Alone Hot Forming  '
Subcategory.
                                         11-20
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                                                               Section 11 - Regulated Pollutants
              EPA proposes not to revise PSES or PSNS for this segment.  The Agency believes
 that pretreatment local limits implemented on a case-by-case basis can more appropriately address
 any individual toxic parameters present at these facilities. The Agency also does not believe that
 it is practicable for a direct discharging facility covered by this segment to become an indirect
 discharging facility because its flows would be too large for a POTW to handle.
 11.14
Non-Integrated Steelmaking and Hot Forming Subcategorv
              EPA selected regulated pollutants for continuous casting and hot forming
 operations in both the Carbon and Alloy Steel and the Stainless Steel Segments of the Non-
 Integrated Steelmaking and Hot Forming Subcategory. EPA proposes to regulate EAF
 Steelmaking and la'dle metallurgy manufacturing operations at zero discharge of pollutants. Table
 11-11 lists the pollutants proposed for regulation for this subcategory.  The rationale for the
 selection of regulated pollutants for indirect dischargers under this subcategory is presented
 below.

 11.14.1       Carbon and Alloy Steel Segment     <

              PSES.

              Two pollutants were selected for regulation at BAT for the Carbon and Alloy
 Segment:  lead and zinc. Neither pollutant was found to pass through POTWs. Table 11-24
 presents pass-through results for the Non-Integrated Steelmaking and Hot Forming Subcategory.

              EPA does not propose to revise PSES for this segment.

              PSNS

              EPA is proposing zero discharge of process wastewater for PSNS.

 11.14.2       Stainless Steel Segment

              PSES                     .••':•

              Two pollutants were selected for regulation at BAT for the stainless segment:
 chromium and nickel. Both pollutants were found to pass through POTWs. Table 11-24 presents
pass-through results for the Non-Integrated Steelmaking and Hot Forming Subcategory.

              EPA proposes to regulate chromium and nickel at PSES.

              PSNS    .      •

              EPA is proposing zero discharge of process wastewater for PSNS.
                                         11-21
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                                                               Section 11 - Regulated Pollutants
11.15
Steel Finishing Subcategorv
              EPA selected regulated pollutants for both the Carbon and Alloy Steel and the
Stainless Steel Segments of the Steel Finishing Subcategory. Table 11-14 lists the pollutants
proposed for regulation for this subcategory. The rationale for the selection of regulated
pollutants for indirect dischargers under this subcategory is presented below.          :

11.15.1       Carbon and Alloy Steel Segment

              PSES

              Four pollutants were selected for regulation at BAT for the carbon and alloy
segment. Of the four, chromium, hexavalent chromium, and zinc were found to pass through
POTWs. Table 11-25 presents pass-through results for the Steel Finishing Subcategory.

              EPA does not propose to revise PSES for this segment; the PSES limits currently
in 40 CFR Part 420 for each manufacturing process except electroplating would continue to apply
under this proposal. Limits for the electroplating manufacturing process are  currently included in
40 CFR Part 433. The PSES limits  in 40 CFR Part 433 are concentration-based, as opposed to
those in 40 CFR Part 420, which are mass-based. To ensure a consistent basis for facilities
operating other operations in addition to electroplating, EPA is proposing to convert the existing
40 CFR Part 433 PSES concentration-based limits to mass-based limits by multiplying by the
proposed BAT production-normalized flow rate and the appropriate conversion factor.  Nine
pollutants are regulated under PSES at 40 CFR Part 433, some of which do hot apply to
electroplating operations as performed in the iron and steel industry.  EPA proposes to specify
PSES limits for four of the pollutants: chromium, lead, nickel, and zinc.  EPA identified these four
metals as POCs for electroplating manufacturing operations (see Section 7).  EPA does not
believe this action will result hi incremental cost increases to the industry.

              PSNS .

              EPA is proposing to regulate the same pollutants as for BAT.

11.15.2       Stainless Steel Segment

              PSES

              Five pollutants were  selected for regulation at BAT for the stainless segment. Of
the five, fluoride, chromium, hexavalent chromium, and nickel were found to pass through.  Table
11-25 presents pass-through results for the Steel Finishing Subcategory.

              EPA does not propose to revise PSES for this segment.
                                          11-22
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                                                              Section 11 - Regulated Pollutants
 11.16
 PSNS

 EPA is proposing to regulate the same pollutants as for BAT.

 Other Operations Subcategorv
              EPA selected regulated pollutants for the Direct Reduced Ironmaking and the
 Forging Segments of the Other Operations Subcategory. EPA proposes to regulate the
 Briquetting Segment at zero discharge of pollutants. Table 11-17 lists the pollutants proposed for
'regulation for this subcategory. The rationale for the selection of regulated pollutants for indirect
 dischargers under this subcategory is presented below.

 11.16.1       Direct Reduced Ironmaking Segment

           •   PSES/PSNS

              For the Direct Reduced Ironmaking Segment, no pollutants were selected for
 regulation at BAT and only conventional pollutants were selected for BPT; therefore, EPA did
 not perform a pass-through analysis for this segment. The Agency reserves PSES/PSNS for the
Direct Reduced Ironmaking Segment.

 11.16.2       Forging Segment

              PSES/PSNS

              For the Forging Segment, no pollutants were selected for regulation at BAT and
only conventional pollutants were selected for BPT; therefore, EPA did not perform a pass-
through analysis for this segment.  The Agency reserves PSES/PSNS for the Forging Segment.
11.17
11-1.
11-2.
11-3.
References

U.S. Environmental Protection Agency. Fate of Priority Pollutants in Publicly
Owned Treatment Works.' EPA 440/1-82/303. Washington, D.C., September
1982.

U.S. Environmental Protection Agency. Development Document for Effluent
Limitations Guidelines and Standards for the Organic Chemicals. Plastics, and
Synthetic Fibers Point Source Category (Volume 1). EPA-440/1-87/009.
Washington, D.C., October 1987.

U.S. Environmental Protection Agency. National Risk Management Research
Laboratory (NRMRL) Treatability Database Version 5.0. Cincinnati, OH, 1994.
                                        11-23
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                                                             Section 11 - Regulated Pollutants
11-4.
U.S. Environmental Protection Agency. Development Document for Proposed
Effluent Limitations Guidelines and Standards for the Centralized Waste
Treatment Industry (Volume D.  EPA-821-R-98-020. Washington, D.C.,
December 1998.
                                        11-24
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                                                                    Section 11 - Regulated Pollutants
                                          Table 11-1
         Proposed Regulated Pollutants for the Cokemaking Subcategory
Pollutant
Total suspended solids (TSS)
Oil and grease (O&G)
Ammonia as nitrogen
Total cyanide
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•
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Notes: EPA is proposing zero discharge of pollutants for the Non-Recovery Cokemaking Segment of this sub-category, and is not proposing to revise
BPT or BCT for this subcategory.
                                            11-25
-------

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                                           11-29
-------
                                                             Section 11 - Regulated Pollutants
                                     Table 11-3
                                                                           I!




        Proposed Regulated Pollutants for the Ironmaking Subcategory
Pollutant
Total suspended solids (TSS)
Oil and grease (O&G)
Ammonia as nitrogea
Total cyanide
Lead
Zinc
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BAT


•
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•

•
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•
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•
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•
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Note: EPA is not proposing to revise BPT or BCT for this subcategory.
                                        11-30
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                                           11-33
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> 
-------
                                                           Section 11 - Regulated Pollutants
                                    Table 11-6
  Proposed Regulated Pollutants for the Integrated Steelmaking Subcategory
Pollutant
Lead
Zinc
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•
•
PSES
•
•
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•
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•
•
Note: EPA is not proposing to revise BPT or BCT for this subcategory.
                                      11-37
-------

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                                               11-39
-------
                                                          Section 11 - Regulated Pollutants
                                   Table 11-8
                                                                        i
    Proposed Regulated Pollutants for the Integrated and Stand-Alone Hot
                             Forming Subcategory
Pollutant
BAT
NSPS
Carbon and Alloy Steel Segment
Total suspended solids (TSS)
Oil and grease (O&G)
Lead
Zinc


•
•
•
•
•
•
Stainless Steel Segment
Total suspended solids (TSS)
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Chromium
Nickel


•
•
•
•
•
•
Note: EPA is not proposing to revise BPT, BCT, PSES, or PSNS for this subcategoiy.
                                      11-40
-------
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                                                        11-42
-------
                                                              Section 11 - Regulated'Pollutants
                                     Table 11-11

  Proposed Regulated Pollutants for the Non-Integrated Steelmaking and Hot
                               Forming Subcategory
Pollutant
BAT
PSES
Carbon and Alloy Steel Segment
Lead
Zinc .
•
•


Stainless Steel Segment
Chromium
Nickel
•
•
•
•
Note:   EPA is proposing zero discharge of pollutants for NSPS and PSNS.               •
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       EPA is not proposing to revise BPT or BCT for this subcategory.
                                         11-43
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                                              11-46
-------
                                                             Section 11 - Regulated Pollutants
                                    Table 11-14
       Proposed Regulated Pollutants for the Steel Finishing Subcategory
Pollutant
BAT
Carbon and Alloy Steel Segment
Total suspended solids (TSS)
Oil and grease (O&G)
Chromium
Hexavalent chromium
Lead
Zinc


•
•
•
•
'Stainless Steel Segment
Total suspended solids (TSS)
Oil and grease (O&G)
Ammonia as nitrogen
Fluoride
Chromium
Hexavalent chromium
Nickel


•
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Note: EPA is not proposing to revise BPT, BCT, or PSES for this subcategory.
                                        11-47
-------
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                                             11-52
-------
                                                               Section 11 - Regulated Pollutants
                                      Table 11-17
      Proposed Regulated Pollutants for the Other Operations Subcategory
Pollutant
BPT
BCT
NSPS
Direct Reduced Iron Segment
Total suspended solids (TSS)
• | : •
•
Forging Segment
Total suspended solids (TSS)
Oil and grease (O&G)
•
•
•
•
•
•
Note:   EPA is proposing zero discharge of pollutants for the Briquetting Segment.
       EPA is not proposing limits at BAT, PSES, or PSNS for this subcategory.
                                         11-53
-------
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                         11-54
-------
                                                                          Section 11 - Regulated Pollutants
                                            Table 11-19
                                   POTW Percent Removals
Pollutant
Ammonia as nitrogen
Benzo(a)pyrene
Chromium
Fluoride
Hexavalent chromium
Lead
Mercury
Naphthalene
Nickel
Phenol
Selenium
2,3,7,8-
tetrachlorodibenzofuran
(TCDF)
Thiocyanate
Total cyanide
Zinc
Subcategory
A,B,F
A
D,E,F
F
F
B,C,D,E,F
A
A
D,E,F
A,B
A
B

A
A,B
B,C,D,E,F
Percent
Removal
39
95
80 .
54
6
77
90
95
51
95
34
83

70
70
79
Source
50 POTW Study (10 x ML)
NRMRL (all wastewater)
50 POTW Study (10 xML)
NRMRL (all wastewater)
NRMRL (all wastewater)
50 POTW Study (10 x ML)
50 POTW Study (10 x ML)
50 POTW Study (10 x ML)
50 POTW Study (10 x ML)
50 POTW Study (10 x ML)
NRMRL (domestic wastewater)
Transfer from 1,2,3,4,6,7,8-HPCDF
(NRMRL)
Transfer from total cyanide
50 POTW Study (10 x ML)
50 POTW Study (10 x ML)
ML - Minimum level.
A - Cokemaking.
B - Ironmaking.
C - Integrated Steelmakirig.
D - Integrated and Stand-Alone Hot Forming.
E - Non-Integrated Steelmaking and Hot Forming.
F - Steel Finishing.
                                                11-55
-------
                                                                            Section 11 - Regulated Pollutants
                                             Table 11-20
                                                                                               f
    POTW Pass-Through Analysis Results for the Cokemaking Subcategory



Pollutant
Ammonia as
nitrogen
Total cyanide
Thiocyanate
Mercuiy
Selenium
Benzo(a)pyrene
Naphthalene
Phenol


BAT %
Removal
>99.9%

96%
99.9 %
83%
73%
;>88 %
^99.9 %
;>99.9 %

POTW %
Removal
(Reference)
39 % (A)

70 % (A)
70 % (C)
90 % (A)
34% (B)
95 % (B)
95 % (A)
95 % (A)

Henry's Law
Constant
(atm/gmole/m3)
a

	 a
a
a
a
4.9E-07"
a
a
BAT%
removal >
POTW %
Removal?
Yes

Yes .
Yes
No
Yes
No
Yes
Yes
Henry's
Law
Constant
> 1E-04 ?
-

-
-
-
-
No
-
-
Does
Pollutant
Pass
Through?
\ Yes

1 Yes
Yes
No
Yes
No
Yes
Yes
•EPA did not perform a volatile override analysis for pollutants already determined to pass through based on BAT and POTW percent removal
comparison and for nonvolatile pollutants.                                                    •
'Source: U.S. EPA. Development Document for Proposed Effluent Limitations Guidelines and Standards for the Centralized Waste Treatment
Industry. December 1998 (Reference 11-4).
(A) U.S. EPA's 50-POTW Study, with data-editing criteria such that only data pairs (influent and effluent) with influent 2 10 * ML were used.
(B) U.S. EPA's NRMRL Database.
(C) Transfer from another pollutant.
                                                   11-56
-------
                                                                      Section 11 - Regulated Pollutants
                                          Table 11-21
     POTW Pass-Through Analysis Results for the Ironmaking Subcategory
Pollutant
Ammonia as nitrogen
Total cyanide
Lead
Zinc
Phenol
2,3,7,8-Tetrachlorodibenzofiiran (TCDF)a
BAT % Removal
99.8%
0%
99.8 %
. 99.8 %
s90 %
>94 %
POTW % Removal
(Reference)
39% (A)
70 % (A)
77 % (A)
79% (A)
95 % (A)
83 %(B)
Does Pollutant Pass
Through?
Yes
. No
Yes
Yes
No
Yes
°2,3J,S-TCDF is regulated for the Sintering Segment of the Ironmaking Subcategory only.
(A) U.S. EPA's 50-POTW Study, with data-editing criteria such that only data pairs (influent and effluent) with influent 2 10 x ML were used.
(B) Transfer from another pollutant.
                                             11-57
-------
                                                             Section 11 - Regulated Pollutants
                                    Table 11-22
     POTW Pass-Through Analysis Results for the Integrated Steelmaking
                                    Subcategory
Pollutant
Lead
Zinc
BAT % Removal
99.8 %
>99.9 %
POTW % Removal
(Reference)
77 % (A)
79 % (A) .
Does Pollutant
Pass Through?
YJes
^es •
(A) U.S. EPA's 50-POTW Study, with data-editing criteria such that only data pairs (influent and effluent) With influent
i 10 * ML were used.
                                    Table 11-23

POTW Pass-Through Analysis Results for the Integrated and Stand Alone Hot
                               Forming Subcategory
Pollutant
BAT %
Removal
POTW % Removal
(Reference)
Does Pollutant
Pass Through?
Carbon and Alloy Steel Segment
Lead"
Zinc
18 %
70%
77 % (A)
79 % (A)
No
ISfo
Stainless Steel Segment
Chromium
Nickel
97%
96%
80 % (A)
51 % (A)
^es
Yes
•No BAT data for this pollutant passed the influent ^ 10 x ML criteria; therefore, paired data with influent concentration
< 10 x ML were used to calculate percent removal.
(A) U.S. EPA's 50-POTW Study, with data-editing criteria such that only data pairs (influent and effluent) with influent
a 10 x ML were used.                                                            ;
                                         11-58
-------
                                                                 Section 11 - Regulated Pollutants
                                       Table 11-24

   POTW Pass-Through Analysis Results for the Non-Integrated Steelmaking
                            and Hot Forming Subcategory
Pollutant
BAT%
Removal
POTW % Removal
(Reference)
Does Pollutant
Pass Through?
Carbon and Alloy Steel Segment
Lead3
Zinc
98 %
97%
77 % (A)
79% (A)
Yes
Yes
Stainless Steel Segment
Chromium
Nickel
97 %
96 %
80% (A)
51% (A)
Yes
Yes
a No BAT data for this pollutant passed the influent z 10 x ML criteria; therefore, paired data (stainless) influent
concentration and influent data (carbon) were < 10 x ML.
(A) U.S. EPA's 50-POTW Study, with data-editing criteria such that only data pairs (influent and effluent) with influent
s 10 x ML were used.
                                          11-59
-------
                                                                   Section 11 - Regulated Pollutants
                                        Table 11-25

   POTW Pass-Through Analysis Results for the Steel Finishing Subcategory
Pollutant
BAT %
Removal
POTW % Removal
(Reference)
Does Pollutant
Pass Through?
Carbon and Alloy Steel Segment
Chromium
Hexavalent chromium
Lead8
Zinc
99.6 %
98 %
74 % .
99%
80 % (A)
6 % (B)
77 % (A)
79% (A)
Yes
Yes
No
Yes
Stainless Steel Segment
Ammonia as nitrogen
Fluoride
Chromium
Hexavalent chromium
Nickel
7%
81 %
99.9 %
99 %
99.6 %
39 % (A)
54% (B-)
80% (A)
6 % (B)
51% (A)
No
Yes
Yes
Yes
Yes
"No BAT data for this pollutant passed the influent s 10 * ML criteria; therefore, paired data (carbon) influent
concentration and influent data (stainless) < 10 x ML were used to calculate the percent removal.         ;,
(A) U.S. EPA's 50-POTW Study, with data-editing criteria such that only data pairs (influent and effluent) v^ith influent
& 10 * ML were used.                                                                   '
03) U.S. EPA's NRMRL Database.                               .                         !
                                            11-60
-------
                                   Section 12 - Limitations and Standards: Data Selection and Calculation
                                       SECTION 12

     LIMITATIONS AND STANDARDS: DATA SELECTION AND CALCULATION

              This section describes the data sources, data selection, data conventions, and
 statistical methodology used by EPA in calculating the long-term averages, variability factors, and
 proposed limitations. The proposed effluent limitations and standards1 for each subcategory and
 option are based on long-term average effluent values and variability factors that account for
 variation in treatment performance within a particular treatment technology over time.

              Section 12.1 briefly describes the data sources (a more detailed discussion is'
 provided in Section 3) and gives a general overview of EPA's evaluation and selection of facility
 datasets that are the basis of the proposed limitations. Section 12.2 provides a more detailed
 discussion of the selection of facility datasets for each subcategory and option.  Sections 12.3 and
 12.4 describe data substitution and aggregation used in calculating the proposed limitations.
 Section 12.5 provides a general overview of limitations in terms of EPA's objective, selection of
 percentiles as their basis, and compliance with final limitations.  Section 12.6 provides an
 overview of the proposed limitations and Section 12.7 describes the calculation of the
 concentration-based limitations. Section 12.8 describes the conversion of these concentration-
 based limitations into the proposed production-normalized limitations. Section 12.9 describes the
 transfers of limitations from one option to another and the few cases where EPA has converted
 limitations from the. 1982 regulations2 using the revised production-normalized flows.  The
 attachments for Section 12 are provided in Appendix F.
12.1
Overview of Data Selection
              To develop the long-term averages, variability factors, and proposed limitations,
EPA used wastewater data from facilities with components of the model technology for each
subcategory and option. These data were collected from two sources. The first source was
EPA's sampling episodes for which data were collected from 1997 to 1999.  The second source
was self-monitoring data, which were provided by facilities either in response to the detailed,
short, or. analytical and production follow-up surveys, or in conjunction with EPA site visits or
other industry contacts.  These data were collected from 1996 to 1998. This section refers to the
first source as 'sampling episodes' and the second source as 'self-monitoring episodes.' This
section provides a general overview of EPA's review of the data from these two sources and
selection of facilities representing each option. For the final rule, EPA intends to further review
and possibly revise, the data selection methodology.

              EPA qualitatively reviewed the data from these two sources and  selected episodes
to represent each option based on a review of the production processes and treatment
technologies in place at each facility. EPA only used data from facilities that had some or all
'In the remainder of this chapter, references to 'limitations' includes 'standards.'

2In'this section, the regulations promulgated in 1982 are referred to as the 1982 regulations.
                                          12-1
-------
                                  Section 12 - Limitations and Standards: Data Selection and\Calculation
components of the model technologies for the option (model technologies for each option are
described in Section 8).  After EPA identified those facilities with components of the model
treatment in place for each option, EPA selected facilities that met several other criteria as
described in the following paragraphs.

              The first criteria was that the influents and effluents from the treatment  |
components had to represent wastewater from that subcategory and option, with no incompatible
wastewater from other subcategories or large amounts of noncontact cooling water or
stormwater. Typically, facilities may commingle wastewater streams with noncontact cooling
water, stormwater, or wastewaters from different subcategories. Application of this criterion
resulted in EPA selecting only those facilities where the commingled wastewaters did not result in
substantial  dilution, more concentrated wastewaters, or wastewaters with different types of
pollutants than those generated in the subcategory.

              The second criterion was that the facility had to demonstrate good operation of the
treatment component, as indicated by pollutant removals across the treatment system and
treatment system effluent quality (e.g., datasets for episodes with generally high pollutant  •
concentrations for all pollutants were excluded). EPA made its determinations regarding whether
a facility met this criterion based upon site visit reports, survey responses, and the chemical
analytical data collected during sampling episodes or obtained as self-monitoring data from the
facilities.

              A third criterion was that the facility had to demonstrate water usage practices
representative of a well-operated system in terms of production-normalized flow rates.3 These
flows were required to be near the model production-normalized flow rate selected for each
option (see Section 7 for discussion of flow rates). Such facilities typically practice higlj-rate
recycle (generally 95 percent or greater recycle rate) or other water usage practices (depending on
the manufacturing process) geared toward more efficient water use. In contrast, episodes with
unusually high production-normalized flow rates were considered to be not representative of
other facilities in the subcategory because they did not practice good water usage and, because of
dilution, analytical data from these processes may represent lower concentrations than those
achievable by facilities using less water.           -                                i

              A fourth criterion was that the data could not represent periods of process or
treatment upsets. EPA did not use data from its sampling episodes that were collected during
times of production or wastewater treatment shut downs.  For self-monitoring data, EPA used
facility responses to the survey and contacted the facility when necessary to determine whether
data submitted were representative of normal operating conditions.

              EPA determined that the datasets from the episodes that met all four criteria
demonstrated the best performance. Thus, EPA used these datasets to develop the proposed
3These flow rates were the operating conditions during EPA's sampling episodes or as reported in the survey responses.
                                           12-2
-------
                                   Section 12 - Limitations and Standards: Data Selection and Calculation
 limitations for each subcategoiy option. EPA selected some episodes for more than one
 subcategory because these facilities met the criteria for more than one subcategory.

              Generally, if EPA selected data from a sampling episode, it also selected any self-
 monitoring episode data submitted from the same treatment system from the same facility. EPA's
 sampling episodes typically provided data for all of the pollutants proposed for regulation (see
 Section 11).  In contrast, the industry self-monitoring data were only for a limited subset of
 pollutants (most facilities monitor only for pollutants specified in their permits). EPA analyzed
 the data from each episode separately in calculating the proposed limitations. This is consistent
 with EPA's practice for other industrial categories. Data from different sources generally
 characterize different time periods and. different chemical analytical methods. EPA's concern in
 combining data from different time periods is that operating conditions are usually different due to
 changes such as management, personnel, and procedures.

              In developing the proposed limitations, EPA generally used the self-monitoring
 data when they were measured by analytical methods specified in or approved under 40 CFR Part
 136 that facilities are required to use for compliance monitoring.  Section 4 describes all but one
 of the exceptions to this general rule. The remaining exception was EPA's exclusion of all
 industry self-monitoring data for oil and grease because facilities generally used methods which
 require freon, an ozone-depleting agent,  as an extraction solvent.  For the samples collected in its
 sampling episodes, EPA used a more recent method, Method 1664, which uses normal hexane («-
 hexane) as the extraction solvent and measures oil and grease (O&G) as hexane extractable
 material (HEM).  While developing Method 1664, EPA received comments about potentially
 differing results using the new method that could bring a permittee into noncompliance under
 certain circumstances.4'5 Although EPA has determined that the methods are comparable  and that
 direct replacement of the new method is warranted, EPA expects that facilities will choose to use
 Method 1664 rather than the freon methods as freon becomes more expensive and difficult to
 obtain. Further, EPA has determined that it collected sufficient data to establish the oil and grease
 limitations using only the HEM data. Thus, EPA has chosen to develop the oil and grease
 limitations solely on the HEM measurements from Method 1664.

              After selecting the EPA sampling and self-monitoring datasets for the best
performers, EPA reviewed the pollutant concentrations in each dataset. If an' episode's pollutant
 concentrations for a particular pollutant were substantially higher than for other episodes selected
 for the option, EPA excluded the data for that pollutant from that episode. EPA also excluded
4U.S. Environmental Protection Agency. Approval of EPA Methods 1664. Revision A. and 9071B for Determination of
Oil and Grease and Non-polar Material in EPA's Wastewater and Hazardous Waste Programs. EPA-821-F-98-005,
February 23,1999. (Also located at www.epa.gov/ost/mcrhttds/1664fs.hrml and DCNIS04884 in Section 3.1 of the
proposal record.)                       •

5U.S. Environmental Protection Agency. Analytical Method Guidance for EPA Method 1664A Implementation and Use
C40 CFR part 1361. EPA/821-R-00-003. February 2000. (Also located at http://www.epa.gov/ost/methods/
1664guide.pdf.)
                                           12-3
-------
                                  Section 12 - Limitations and Standards: Data Selection and\ Calculation
outliers within episode datasets when it deemed such exclusions were appropriate. The$e
exclusions, along with justifications, are described in detail in the next section.
12.2
Episode Selection for Each Subcategory and Option
              This section describes the data selected for each pollutant for each technology
option in each subcategory.  This discussion is divided into subparts corresponding to the
subcategories and options where'EPA is proposing numerical limitations. (See Section 8 for
those options for which EPA is proposing no discharge of process wastewater pollutants to
•waters of the United States).

              In the following sections and the public record, EPA has masked the identity of the
episodes and.sample points to protect confidential business information (CBI):  EPA sampling
episodes are identified as ESExx and the industry self-monitoring episodes as ISMxx where 'xx'
is a unique two-digit number assigned to each episode (for example, ESE01 and ISM51). The
sample points are identified with SP-c where 'c' is a character (for example, SP-A). The daily
data and sample points corresponding to these episodes are listed in Appendix D. Attachment 12-
1 in Appendix F provides summary statistics for all episodes, sorted by subcategory and[option.
12.2.1
Subpart A: Cokemaking Subcategory
              For the By-Product Recovery Segment in the Cokemaking Subcategory,* as
described in the following subsections, EPA evaluated four options: BAT-3, BAT-1, PSES-1, and
PSES-3. The data for the BAT-3 and BAT-1 options were used to calculate the proposed
limitations for direct dischargers. The data from the BAT-1 and PSES-1 options were used to
calculate the two sets of co-proposed standards for indirect dischargers. (The technical |
components for BAT-1 are the same as those for PSES-3.)

              BAT-3

              The proposed BAT-3 option technology is the basis of the proposed limitations for
direct dischargers in the By-Product Recovery Segment. This option has an alkaline chlprination
component, plus the components of the BAT-1 option (see Section 8 for detailed descriptions of
the BAT-3 and BAT-1 model technologies). As described below, of the pollutants proposed for
regulation, alkaline chlorination is the relevant technology component for the proposed ammonia
as nitrogen, phenol, total cyanide, and total residual chlorine (TRC) limitations.  The BAT-1
components are the basis for the proposed limitations for benzo(a)pyrene, O&G, mercury,
naphthalene, selenium, TSS, and thiocyanate.  (EPA proposed O&G and TSS standards [only for
new direct dischargers.)                                                         i
*For the Non-recovery Segment in this subcategory, EPA has proposed no discharge of process wastewater pollutants
to waters of the United States as explained in Section 8.
                                          12-4
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
               EPA was only able to identify one facility (episode ISM52) with the alkaline
 chlorination component. This facility is located in Canada and EPA was unable to obtain the
 facility's permission to sample its wastewaters (EPA's statutory authority under the Clean Water
 Act Section 308 to require facilities to produce information does not apply to Canadian mills).
 The cokemaking wastewater at this facility passed through a biological treatment system and then
 was commingled with blast furnace ironmaking wastewater. This commingled stream was treated
 with alkaline chlorination and then mixed with a second stream consisting of wastewaters from
 the Integrated Steel Subcategory and Carbon and Alloy Steel Segment of the Integrated and
• Stand-Alone Hot Forming Subcategory.  The wastewaters from both streams were commingled
 and sent through filters before reaching the discharge point, which was the facility's monitoring
 point.  (See Figure 12-1.) Although the cokemaking wastewater was treated by all the
 components of the BAT-3 model technology, the wastewater was commingled with ironmaking
 wastewaters that were .not treated by the biological treatment component. Because cokemaking
 and ironmaking contribute some of the same pollutants to the wastewaters, EPA excluded the
 data for pollutants that were not treated by the alkaline chlorination component of the model
technology.
         BOF Slowdown

 Continuous Caster Slowdown


     Hot Strip Mill Slowdown •
Blast Furnace
 Slowdown
Coke Plant
Slowdown
>
r
Biological
Treatment
                                                              Monitoring
                                                              Location
                                                         Outfall
                         Figure 12-1. Alkaline Chlorination Model Technology Facility
                                           12-5
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                                   Section 12 - Limitations and Standards: Data Selection and 'Calculation
              Of the parameters monitored for episode ISM52,7 only ammonia as nitrogen, total
cyanide, and total phenols are treated by alkaline chlorination.  For these parameters only, EPA
assumed that the entire loading was contributed by cokemaking and blast furnace ironmaking
operations.  This assumption is supported by facility personnel (DCNIS04112), process
chemistry considerations, and EPA sampling data showing that these parameters are not present
to a significant degree in the Integrated Steel and Integrated and Stand-Alone Hot Formiiig
Subcategories (DCN 1505030 in Section 5.4 of the proposal record). Because the cokemaking
and ironmaking wastewaters were commingled with the second wastestream, the pollutant
concentrations were diluted at the monitoring point. The facility provided EPA with the ^laily
flow at the monitoring point, and also provided the blowdown rates of the coke plant and blast
furnaces, which remained constant during the self-monitoring episode. EPA used this information
in conjunction with the pollutant concentrations to estimate the ammonia as nitrogen, total
cyanide, and total phenols8 concentrations achievable by alkaline chlorination. In its estimation
procedure, EPA divided the pollutant concentration at the monitoring point by the ratio of the
flow processed in alkaline chlorination to the total effluent flow (DCN 1504933 in Section 5.6 of
the proposal record). For example, if the total  cyanide concentration is 2 mg/L, the combined'
flow from cokemaking and blast furnace (flow  processed by alkaline chlorination) is 0.5 million
gallons per day (mgd), and the flow at the monitoring point is 1 mgd, then the ratio of the two
flows is 0.5/1 = 0.5. Then, the  estimated concentration corresponding to the flow treated by
alkaline chlorination is (2 mg/L)/0.5 = 4 mg/L. Because this estimation is only appropriate for
pollutants treated by alkaline chlorination, EPA selected ammonia as nitrogen and total cyanide
data from this episode to calculate the proposed BAT-3 limitations. The estimated.concentration
values are listed in Appendix D.

              Of the pollutants that EPA is proposing to regulate for this segment, ammonia as
nitrogen, total cyanide, and phenol are the only three treated differently by this technology than by
the BAT-1 technology.  As discussed above, ammonia as nitrogen and total cyanide were
estimated from the data for episode ISM52.9 Phenol is proposed for regulation instead of total
phenols, but data were not available from episode ISM52.  Phenol is treated both by the alkaline
chlorination and biological treatment components of the model technology.  The biological
treatment component is  also part of the model  BAT-1 technology.  For phenol, because the
The facility provided its self-monitoring data for ammonia as nitrogen, total cyanide, total phenols, benzene, i
benzo(a)pyrene, naphthalene, total suspended solids, O&G, lead, and zinc.

*EPA is not proposing to regulate total phenols. However, EPA used this estimation procedure for the total phenols data
in determining pollutant loadings reductions in Section 10.
                                                                                          .
'EPA excluded all pollutant concentrations for one sampling day that had a reported flow rate three times greater than
others in that time period. The facility's treatment system would have had difficulties hi treating such a high yvastewater
volume. (DCN 1504991 in Section 5.6 of the proposal record.) EPA will contact this facility before the final rule to
determine the reason for the unusually large flow rate for this day.                                !
                                            12-6
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
 BAT-3 technology is more sophisticated than the BAT-1 technology, EPA determined that it was
 appropriate to transfer the proposed BAT-1 limitation10 to the BAT-3 option.

               Total residual chlorine (TRC) is not treated by the BAT-3 technology, but EPA
 proposes to regulate TRC to ensure that residual concentrations of chlorine from the alkaline
 chlorination process are kept to a minimum to avoid effluent toxicity. EPA is proposing that
 facilities would not need to meet the TRC limitation if they certify to the permitting authority that
 they do not employ  alkaline chlorination in their wastewater treatment. Because EPA did not
 receive any TRC data from episode ISM52, EPA proposed limitations for TRC based upon the
 1982 regulations for the Ironmaking Subcategory. (After adjusting the 1982 mass-based
 limitations for the production-normalized flows used in 1982, the  1982 limitations are the same on
 a concentration-basis for both the sintering and konmaking subcategories!) The 1982 regulations
 for TRC were based upon model technologies that included a component for alkaline chlorination.
 EPA determined that the 1982 TRC limitation for ironmaking was based on the alkaline
 chlorination process itself, and therefore the 1982 limitation from ironmaking would apply to
 alkaline chlorination performed at cokemaking operations. Thus,  EPA used the 1982 regulations
 from the Ironmaking Subcategory as the basis for the proposed limitations. (Section 12.9
 describes the adjustment for differences in production flows between the two subcategories.)

               For the remaining pollutants (benzo(a)pyrene, O&G, mercury, naphthalene,
. selenium, TSS, and thiocyanate) proposed for regulation, EPA transferred the proposed
 limitations from the  BAT-1 option.  (As explained previously, EPA excluded the data from
 episode ISM52 for pollutants other than those treated by the alkaline chlorination component.)
 EPA determined that these transfers were appropriate because the BAT-1  component of the
 BAT-3 technology treats these remaining pollutants and the alkaline chlorination component does
 not provide additional removals of these pollutants.   '

               BAT-1 (PSES-3)

               The proposed BAT-1 option technology was used as the basis for the proposed
 limitations for direct dischargers. The proposed limitations based on the BAT-1 option
 technology were also used as pretreatment standards for the PSES-3 option, which is based on
 the same physical, chemical, and biological technology. As mentioned in previous Section 12.2,
 PSES-3 pretreatment standards were co-proposed with PSES-1 pretreatment standards for
 physical and chemical technology. The proposed BAT-1 limitations for some pollutants were also
 transferred to the BAT-3 option, as explained in the previous section.

              Based on an evaluation of industry survey responses, EPA determined that all but
 two of the direct-discharging facilities with processes in the By-Product Recovery Segment have
 '"Phenol was not measured above the detection level in any BAT-1 sample. The long-term average of 10.08 ug/L is an
 average across sample-specific detection limits for the BAT-1 samples. With one exception, all sample-specific
 detection limits were equal to 10 ug/L which is also the minimum level for the analytical method. The other sample-  •
 specific detection limit was 10.4 ug/L and resulted from a 1.04-fold dilution to correct for a smaller extraction (960 mL)
 than the 1000 mL specified by the analytical method.
                                           12-7
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                                  Section 12 - Limitations and Standards: Data Selection and Calculation
 the model technology associated with the BAT-1 option, namely ammonia stripping and biological
 treatment.  Of these facilities, EPA selected data from three facilities that met the criteria
 described in Section 12.1. These data were from two sampling episodes (ESE01 and ESE02) and
 two self-monitoring episodes (TSM50 and ISM51). (One sampling episode and self-monitoring
 episode were from the same facility.) These facilities treat wastewater from by-product recovery
 operations as well as small amounts of groundwater or control water added for biological
 treatment optimization. One facility (episode ESE02) had the BAT-1 model technology;
 however, its performance was uniformly poor as evidenced by high concentration discharges. For
.this reason, EPA excluded all data except mercury from this episode in calculating the proposed
 limitations (see discussion below about the mercury data). Where data for a particular pollutant
 were available from the remaining three episodes, EPA generally included the data in calculating
 the proposed limitations.  However, for episode ISM51, EPA excluded the portion of the dataset
 corresponding to the time period when the facility was operating a treatment system different
 from the BAT-1 model technology.  In addition, EPA found that episode ISM51 demonstrated
 poor performance of the model technology for several pollutants and excluded the data for those
 pollutants from the calculations. For the final rule, EPA intends further review of this episode and
 its data to determine if the performance should be considered uniformly poor and the data for all
 pollutants excluded from calculating the limitations.                                 '

              •Thus, data from one to three episodes with the BAT-1 technology were vised to
 develop the proposed limitations for benzo(a)pyrene, mercury, naphthalene, selenium, and
 thiocyanate. In addition, the data from these episodes were used to calculate the proposed TSS
 and O&G standards for new direct dischargers. Data from these episodes were  also used to
 calculate the proposed pretreatment standards for ammonia as nitrogen, total cyanide,
 naphthalene, phenol, selenium, and thiocyanate (because the PSES-3 technology has the same
 components as the BAT-1 technology). The following paragraphs describe the episodes selected
 for each pollutant.

              For benzo(a)pyrene, EPA had concentration data from its sampling episode
 (ESE01) and from the two self-monitoring episodes. EPA excluded the benzo(a)pyrene data
 from one self-monitoring episode (ISM50) because of concerns about the analytical methods (see
 section 4.4.15, DCNs IS07040 and IS07051 in Sections 8.4 and 8.5 of the proposal record). EPA
 excluded the data from the other self-monitoring episode (ISM51) because all reported data were
 associated with a new non-BAT-1 treatment system.

              For mercury, EPA had concentration data from one EPA sampling episode
 (ESE01) and one self-monitoring facility (ISM51). Because the data were all non-detected,
 variability cannot be calculated (as explained in Appendix E). Thus, EPA included one additional
 facility (episode ESE02) to develop variability factors for the proposed limitations.  EPA! excluded
 this episode from the long-term average calculations because this facility did not operate its
 treatment systems to the non-detectable levels demonstrated by the other two episodes.  ;
 However, because episode ESE02 has the BAT-1 technology, EPA concluded that the variability
 of the wastewaters at this episode would be similar to the variability of well-operated facilities.
 Thus, this episode was used to calculate variability factors for the proposed mercury limitations.
                                          12-8
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
               For naphthalene, EPA had concentration data from one EPA sampling episode
  (ESE01) and two self-monitoring episodes (ISM50 and ISMS 1). EPA excluded the data from
  self-monitoring episode ISM51 because all reported data were associated with a new non-BAT-1
  treatment system. EPA calculated the proposed limitations using the data from episode ESE01.

               For selenium and thiocyanate, EPA had concentration data from EPA sampling
  episode ESE01 and self-monitoring episode ISM51. EPA excluded the data from self-monitoring
  episode ISM51 because all reported data were associated with a new non-BAT-1 treatment
  system. EPA calculated the proposed limitations for selenium and thiocyanate using the data from
  episode ESE01.

               For the. O&G standards proposed for new direct dischargers, EPA used
  concentration data from its sampling episode (ESE01) for O&G measured as HEM. As explained
  in Section 12.1, industry did not measure O&G as HEM and thus none of the self-monitoring
  episodes were included in calculating the proposed O&G standards.

               For the TSS standards proposed for new direct dischargers, EPA had
  concentration data from one sampling episode (ESE01) and two self-monitoring episodes (ISM50
  and ISM51). For episode ESE01, EPA excluded two duplicate pairs (samples collected from the
  same stream at approximately the same time and under approximately the same field conditions)
 because the results indicated poor precision.11 (EPA intends to re-evaluate this decision for the
 final rule.) For episode ISMS 1, EPA had concentration data corresponding to two chemical
 analytical methods: 160.2 and 2540D (see section 4.4.3 for a description of these methods). The
 data from Method 160.2 from that episode were excluded because the average was more than five
 times higher than either of the other episodes (DCNIS07052 in Section 8.5 of the proposal
 record). The data from Method 2540D from that episode were excluded because the data
 represented the new treatment system.

              For the ammonia as nitrogen pretreatment standards for the PSES-3 option, EPA
' had concentration data from one sampling episode and two self-monitoring episodes.  EPA
 proposed pretreatment standards for indirect dischargers using the data from the two self-
 monitoring episodes.  (The proposed limitations for direct dischargers were based upon the BAT-
 3 option.) EPA excluded data from the sampling episode (ESE01) because the levels were
 uniformly low at all influent and effluent sampling points in comparison to other BAT-1 episodes.
 EPA also excluded some ammonia as nitrogen data from one self-monitoring episode (ISMS 1)
 because the data represented the facility's new non-BAT-1 treatment system. EPA excluded the
 data for two days from another self-monitoring episode (ISM50) because the concentration levels
 of 14.5 and 38.7 mg/L reported for the first two consecutive samples were substantially greater
 than the data for the remaining 54 sampling days. In addition, these two data values were greatly
 in excess (about four and ten times, respectively) of concentrations in the following weeks.  For
 the final rule, EPA intends to contact the facility to determine if a particular process condition
 resulted in these extreme values.                                               •
 "The first pair had values of 78 mg/L and 13 mg/L. The second pair had values of 110 mg/L and 18 mg/L.
                                          12-9 .
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                                  Section 12 - Limitations and Standards: Data Selection and Calculation
              For the phenol pretreatment standards, EPA had concentration data from EPA
sampling episode ESE01. Industry did not monitor for phenol and thus none of the self:
monitoring episodes were included in calculating the proposed phenol pretreatment standards.
The industry supplied data were for total recoverable phenolic material  ("total phenols") rather
than phenol, which is a single organic analyte.

              For the total cyanide pretreatment standards, EPA had data from one sampling
episode (ESE01) and two self-monitoring episodes (ISM50 and ISM51).  EPA proposed
pretreatment standards for indirect dischargers using these data.  (The proposed limitations for
direct dischargers were based upon the BAT-3 option.)  EPA excluded  some data from ^episode
ISM51 because the data represented the new treatment technology rather than the BATf 1
technology. Of the remaining eight data points from episode ISM51, which were measured with
Standard Method 4500, EPA excluded the first-six, which were all reported as detected at the
same value of 12 mg/L. Because data are seldom reported at the same value unless they are non-
detected or very close to the lowest level that can be measured by the chemical analytical method,
EPA determined that these data should be excluded because of concerns about the level! of
precision attained by the laboratory, 'in addition, EPA excluded the remaining two data jvalues (8
and 8.7 mg/L) which were also measured with Standard Method 4500, because EPA concluded
that all results were probably unreliable from this method during the self-monitoring episode.
                                                                              i

              PSES-1

              EPA co-proposed pretreatment standards for indirect dischargers based on the
PSES-1 technology (physical and chemical technology) and the PSES-3 technology (physical,
chemical, and biological technology which has the same components as the BAT-1 option
technology and is described in Section 12.2.1.2.) Eight facilities (corresponding to eight
episodes) had the PSES-1 option technology and met the criteria in Section 12.1. Four of these
episodes were EPA sampling episodes (ESE01, ESE02, ESE03, and ESE11) and four were self-
monitoring episodes (ISM53, ISM54, ISM55, and ISM56). None of the facilities commingled
cokemaking wastewater with wastewater from other subcategories.  When data were available,
EPA used the data from the indirect dischargers (i.e., the self-monitoring episodes) to calculate
the proposed  PSES-1 pretreatment standards for ammonia as nitrogen, total cyanide, thiocyanate,
selenium, naphthalene, and phenol. For the final rule, EPA intends to consider whether |self-
monitoring episode ISM54 should be excluded because  of its unusually  high influent wastewater
flow (and consequently, high production-normalized flows).

              The direct dischargers represented in the four sampling episodes had employed the
proposed model technology that was the basis for the proposed pretreatment standards.  EPA
used their data to calculate the proposed pretreatment standards only when no data were available
from the indirect dischargers. For the final rule, EPA intends to reconsider the exclusions of data
from three  of these episodes (DCNIS07053 in Section  8.5 of the proposal record lists the data
and summary statistics for these three episodes). EPA intends to continue to exclude the data
from the fourth sampling episode (ESE11) to protect confidential business information (CBI).
Because EPA sampled this facility for a single day, it is not possible to adequately aggregate the
data for public review while still protecting CBI. While, EPA can and has used CBI data in
                                         12-10
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
 developing limitations and standards, EPA has determined in this case that sufficient data are
 available to develop the proposed pretreatment standards without the data from this sampling
 episode.1? Thus, EPA intends to continue to exclude the data from developing the pretreatment
 standards, but EPA will compare these data to the final pretreatment standards to evaluate the
 facility's treatment performance.

              For ammonia as nitrogen, EPA had data from four self-monitoring episodes
 (ISM53, ISM54, ISM55, and ISM56) at indirect-discharging facilities.  EPA excluded data from
 self-monitoring episode ISM56 because this facility employs biological treatment in addition'to
 ammonia stripping (ammonia stripping is the PSES-1 model treatment technology), and biological
 treatment provides additional removal of ammonia.

              For selenium, the indirect-discharging facilities did not collect any data for this
 pollutant in their self-monitoring episodes. Therefore, EPA selected one of the three sampling
 episodes (ESE01) to calculate the PSES-1 pretreatment standards. EPA only chose selenium data
 from this single episode because the selenium concentrations from each episode were similar.  For
 the final rule, EPA will reconsider the exclusion of the selenium data from the remaining two
 sampling episodes (see DCNIS07053 in Section 8.5 of the proposal record for. summary
 statistics).

              For total cyanide, EPA had data from all four self-monitoring episodes.  EPA
 excluded data from ISM53 and ISM55 because these two facilities employ cyanide precipitation
 in addition to ammonia stripping; cyanide precipitation is not part of the PSES-1 treatment
 technology and provides additional removal of total cyanide.  For the final rule, EPA will
 reconsider the exclusion of the total cyanide data from episode ISM54 (see DCN IS07055 in
 Section 8.5 of the proposal record for summary statistics).

              For phenol and thiocyanate, the indirect-discharging facilities did not collect any
 data for these pollutants in their self-monitoring episodes.  Therefore, EPA selected one of the
 three sampling episodes (ESE03) to calculate the PSES-1 pretreatment standards. EPA excluded
 the data for thiocyanate and phenol from episode ESE02 because the thiocyanate concentrations
 from,this episode were an order of magnitude less than data from the other sampling episodes and
 because phenol concentrations were all reported as greater  than the highest calibration value of
 the analysis (200 mg/L).  EPA also excluded the data from episode ESE01 because the high
 concentration levels for thiocyanate and phenol indicated poor treatment for these parameters.

              For naphthalene, EPA also used sampling episode ESE03 to develop the proposed
pretreatment standards. For the final rule, EPA will reconsider the exclusion of the naphthalene
 data from sampling episodes ESE01 and ESE02 and self-monitoring episode ISM54 (see DCNs
IS07053 and IS07055 for summary statistics).  Except for one data point, EPA used all the data
from episode ESE03 to calculate the proposed pretreatment standards for naphthalene.  EPA
I2If the facility chooses to waive its CBI claim for the concentration data from this sampling episode, EPA will consider
using these data in calculating the final limitations.
                                          12-11
-------
                                  Section 12 - Limitations and Standards: Data Selection and Calculation
excluded one data point (0.018 mg/L) for naphthalene because it was substantially lower than the
sample-specific detection limits (both were 0.1 mg/L) in the episode dataset.

12.2.2        Subpart B: Ironmaking Subcategory
                                                                              i,
              The Ironmaking Subcategory has two segments: the Sintering Segment and the
Blast Furnace Segment.  EPA is proposing limitations for the same pollutants for both B except as
noted in the preamble to the proposed rule.  EPA used the same concentration data but different
production normalized flows for the two segments (see Section 12.8.1). EPA determined that it
was appropriate to use the same concentration data for both segments because wastewaters from
these two segments are compatible, and all facilities with co-located blast furnaces and sinter
plants co-treat the wastewaters from each operation.
                                                                              i<
              Using the criteria in Section 12.1, EPA selected data from facilities with high-rate
recycle and the relevant portions of the model technology for each pollutant. As described in the
following subsections, EPA evaluated two options: BAT-1 and PSES-1.  The data for the first
option were used to calculate the proposed limitations for direct dischargers, and data for the
second option were used to calculate the proposed pretreatment standards for indirect
dischargers.

              BAT-1

              The proposed BAT-1  option technology is the basis of the proposed limitations for
the direct dischargers in the Ironmaking Subcategory; EPA identified one facility with all of the
model technologies in place.  However, data submissions from this episode indicated that the
facility was not operating its treatment system effectively, and several EPA attempts to inquire
about process conditions at the facility went unanswered. Thus, EPA  excluded data from this
facility for this option (DCN 1504992 in Section 5.6 of the proposal record). Instead, EPA used
data from other sources in calculating the proposed limitations for ammonia as nitrogen] total
cyanide, lead, zinc, O&G, 2,3,7,8-tetrachlorodibenzo-furan (2,3,7,8-TCDF), phenol, TRC, and
TSS as described in the following paragraphs. (EPA proposed O&G and TSS standards only for
new direct dischargers.)                                                        •!         '

              For ammonia as nitrogen and total cyanide, EPA selected episode ISM52 as the
model facility for this option. Although the data from episode ISM52 are from effluent from
commingled wastewaters for cokemaking, blast furnace ironmaking, integrated steel, and
integrated and stand-alone hot forming subcategories (see Figure  12-1 and description in Section
12.2.1.1), EPA has determined that the pollutant concentrations for ammonia as nitrogen and
total cyanide are representative of ironmaking wastewaters (for both sintering and blast furnaces)
because the alkaline chlorination component of the model technology treats only ammonia as
nitrogen, total cyanide, and phenol.  As explained in Section 12.2.1.1, EPA used the daily flow at
the monitoring point, the blowdown rates of the coke plant arid blast furnaces, and pollutant
concentrations to estimate the ammonia as nitrogen and total cyanide concentrations achievable
                                          12-12
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
 by alkaline chlorination13 (which is one of the components of the model technology for this
 subcategory).14  While phenol is also, treated by alkaline chlorination, industry did not supply any
 data for phenol. In calculating the proposed limitations, EPA used the phenol long-term average
 from two options in the 1982 rulemaking that included components for alkaline chlorination.  This
 long-term average (0.01 mg/L) was the same for both the sintering and ironmaking subcategories
. for the 1982 rule.  (This value corresponds to sintering option BAT-3 on page 402 and
 ironmaking option BAT-4 on page 406 in Appendix C of Volume I of the 1982 Development
 Document).

              TRC is not treated by the BAT-1 technology, but EPA proposes to regulate TRC
 to ensure residual concentrations of chlorine are kept to a minimum to avoid effluent toxicity.
 (EPA is proposing that facilities would not need to meet the TRC limitation if they certify to the
 permitting authority that they do not employ alkaline chlorination in their wastewater treatment).
 Because EPA did not receive any TRC data from industry, EPA proposed limitations for TRC
 based upon the 1982 regulations for the 1982 Ironmaking Subcategory.  (After adjusting the 1982
 mass-based limitations for the production-normalized flows used in 1982, the limitations are the
 same on a concentration-basis for the sintering and ironmaking subcategories.) The 1982  •
 regulations for TRC were based upon model technologies that included a component for alkaline
 chlorination. Thus, EPA used the  1982 regulations from the Ironmaking Subcategory as the basis
 for the proposed limitations (Section 12.9 describes the adjustment for differences in production
 flows between the two subcategories.)

              For lead and zinc, EPA  excluded the data from episode ISM52 because the
 commingled streams all contribute to the pollutant concentrations (as explained in Section
 12.2.1.1). Thus, EPA used blast furnace  ironmaking data from another self-monitoring episode
 (ISM61) that did not have the alkaline chlorination component of the model technology. This is a
reasonable substitution because this episode only had the metals precipitation and filtration
components; alkaline chlorination does not provide any additional removals of the metals.

              For O&G, which is proposed for new direct dischargers, -industry did not measure
O&G as HEM (see Section 12.1), and the standards for this option were  calculated using O&G
data measured as HEM in a sampling episode that demonstrated the PSES-1 option technology
(for further discussion of the O&G data, see Section 12.2.2.2).  EPA concluded that transfer of
these data are appropriate given that the technology basis, for BAT-1 includes additional treatment
steps and should provide better removals than PSES-1.  As such, EPA expects that facilities
utilizing the BAT-1 technologies can achieve O&G effluent concentration levels at least as low as
the values from facilities using the PSES-1 technologies.
I3EPA also used this estimation procedure for the total phenols data in determining the pollutant loadings reductions in
Section 10.

14Also as explained in Section 12.2.1.1, EPA excluded all pollutant concentrations for one sampling day with a high flow
rate.
                                         12-13
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                                 Section 12 - Limitations and Standards: Data Selection and Calculation
             For 2,3,7,8-TCDF, which is proposed for sintering wastewater only, EPA did not
receive any data from the industry for the BAT-1 option technology. However, EPA collected
data for the PSES-1 option technology, and the limitations for this option were transferred from
the PSES-1 option (for further discussion of the 2,3,7,8-TCDF data, see Section 12.2.2J2).  The
PSES-1 technology is identical to BAT-1 except that PSES-ldoes not include alkaline
chlorination; EPA determined that this limitations transfer is appropriate because alkaline
cUorination does not provide treatmentfor 2,3,7,8-TCDF.

             For TSS, industry did not provide any data from the BAT-1 model technology.
The 1982 regulations for TSS for new sources that are direct dischargers are based upon a
technology similar to BAT-1. After adjusting for differences in production-normalized flows for
each subcategory; the 1982 regulations for the ironmaking and sintering subcategories are the
same on a concentration basis. Thus, EPA has transferred the  1982 TSS regulations for' new
sources that are direct dischargers as the basis for the proposed standards. (Section 12.9
describes the adjustment for differences in the proposed production flows for this subcategory.)

             PSES-1
                                                                              r
             The proposed PSES-1 option technology is the basis of the proposed pretreatment
standards for the indirect dischargers in the Ironmaking Subcategory. EPA selected onej facility
(corresponding to two episodes) as the best performer for this option. This facility commingles
blast furnace ironmaking and sintering wastewaters.  EPA had final effluent data from its sampling
episode ESE08 and self-monitoring episode ISM62 supplied by the facility.  EPA determined that
these data represent the pollutant concentrations for this subcategory because both processes in
the subcategory are represented.              .              .                      |

             For lead, zinc,'and ammonia as nitrogen, EPA used the data from both episodes to
calculate the proposed pretreatment standards. None of the data were excluded.
                                                                         . "    |
             For 2,3,7,8-TCDF, EPA has proposed a daily maximum pretreatment standard that
applies only to sintering wastewater. EPA proposes to require compliance monitoring at internal
outfalls before any non-process or additional process wastewaters other than blast furnace
wastewater flows are combined with the sinter plant wastewater.  This proposed 2,3,7,8-TCDF
pretreatment standard is based upon data from treated effluent  from commingled sintering and
blast furnace wastestreams from sampling episode ESE08.  (During this sampling episode, EPA
did not collect samples of treated sintering wastewater.) These data were all reported at non-
detected concentration levels of 2,3,7,8-TCDF. EPA also collected data in a sampling episode at
a facility that had sintering operations only.  At this facility, EPA found detected concentrations of
2,3,7,8-TCDF in the treated effluent (these concentrations are  listed in DCN 1500490 in Section
4.4 of the proposal record). However, EPA has excluded these data because the facility did not
have the model treatment technology in place. EPA expects to gather additional information on
dioxin and furan concentrations in sinter plant-only effluent and on the regulatory approach
through the public comment process.
                                         12-14
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                                  Section 12 - Limitations and Standards: Data Selection and Calculation
              While EPA is not proposing pretreatment standards for O&G, EPA is transferring
 the standards calculated from the O&G data measured as HEM from this proposed option to
 BAT-1 (see Section 12.2.2.1). These proposed standards are for new direct dischargers.
 Industry did not provide any O&G data measured as HEM (see Section 12.1).  Thus, EPA used
 the O&G data measured as HEM from sampling episode ESE08 to calculate the proposed
 standards for O&G for BAT-1.
 12.2.3
 Subpart C: Integrated Steelmaking Subcategory
              For the Integrated Steelmaking Subcategory, EPA is calculating the proposed
 limitations for direct dischargers and indirect dischargers using data from the BAT-1 option for
 three general processes: basic oxygen furnaces (wet-open combustion), vacuum degassing, and
 continuous casting. (The technology components are the same for the BAT-1 and PSES-1
 options.)  For the BAT-1 option in this Subcategory, EPA selected effluent data from one facility
 (corresponding to one sampling episode (ESE04) and one self-monitoring episode (ISM60)) to
 calculate the proposed limitations for lead and zinc.  EPA selected this facility using the criteria
 described in Section 12.1. This facility had separate treatment systems for its basic oxygen
 furnaces (BOF), continuous casting, and vacuum degassing wastewaters (some underflows were
 treated together). The effluents from each treatment system were sampled before they were
 discharged to a common outfall. EPA mathematically composited the data from each sampling
 point to obtain a single daily concentration value for each pollutant at the outfall (see Section
 12.4.3 for the aggregation procedure). (The facility uses a similar mathematical compositing
 procedure before reporting the monitoring data to its permitting authority.) EPA determined that
•these data represent the pollutant concentrations for all processes in this Subcategory because all
 processes in the Subcategory are represented except for BOFs with wet-suppressed and semi-wet
 air pollution control systems. However, because the pollutants generated in BOF Steelmaking are
 dependent only upon the materials processed and the chemistry of the Steelmaking reaction, EPA
 has determined that the concentrations achievable by the model treatment technology would also
 apply to BOFs with wet-suppressed and semi-wet air pollution control systems.
12.2.4
Subpart D:  Integrated and Stand-Alone Hot Forming Subcategory
              The Integrated and Stand-Alone Hot.Forming Subcategory has two segments:
Carbon and Alloy Steel Segment and the Stainless Steel Segment. EPA evaluated two options:
CARBONJBAT-1 (for the Carbon andAalloy Steel Segment and SPECIALTY_BAT-1 (for the
Stainless Steel Segment).  The following two subsections describe the data for the two segments.

              CARBON_BAT-1

              CARBON_BAT-1 is the proposed option for the direct dischargers in the Carbon
and Alloy Steel Segment of the Integrated and Stand-Alone Hot Forming Subcategory.  EPA
selected two facilities corresponding to two sampling episodes (ESE04 and ESE07) and one self-
monitoring episode (ISM66) to calculate the proposed limitations for lead, zinc, O&G, and TSS.
EPA proposed O&G and TSS standards only for new direct dischargers.  EPA selected these •
episodes using the criteria  described in Section 12.1.  In addition, both facilities employ high-rate
                                         12-15
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                                 Section 12 - Limitations and Standards: Data Selection and[Calculation
recycle and process only wastewater from hot strip mill operations. EPA used all of the data from
the two sampling episodes in calculating the proposed limitations.  EPA excluded the data from
ISM66 because the data were collected after wastewater from the Steel Finishing Subcafegory
were commingled with the effluent from the hot strip mill effluent; the EPA sampling data were'
collected upstream'of where the finishing wastewater was added.

             For zinc, the two episodes had substantially different concentration values.
Episode ESE04 had all non-detected measurements with sample-specific detection limits ranging
from 2.8 to 4 ug/L. In contrast, episode ESE07 had all detected measurements ranging from 140
to 246 ug/L. EPA used the data from both episodes in calculating the proposed limitations. As a
result, two of the detected measurements are greater than the proposed daily maximum limitation.
For the final rule, EPA will review the data and process information to determine whether both
datasets should be used in calculating the limitations.  •

             SPECIALTY_BAT-1

             The proposed SPECIAL!Y_B AT-1 option technology is the basis of the proposed
limitations for the direct dischargers in the Stainless Steel Segment of the Integrated and Stand-
Alone Hot Forming Subcategory.  EPA did not sample any stainless steel integrated or stand-
alone hot forming operations and did not obtain any self-monitoring data from this segment
Because water use and wastewater characteristics of stainless steel hot forming  operations at non-
integrated steel mills are similar to those at integrated and stand-alone hot forming mills, EPA
transferred the proposed limitations from the Stainless Steel Segment of the Non-integrated
Steelmaking and Hot Forming Subcategory to this segment.  (EPA also used the data from that
subcategory in selecting the pollutants of concern (POCs) for this segment that are identified in
Section  11.) The data for the proposed limitations are discussed further in Section 12.215.2.
12.2.5
Subpart E:  Non-Integrated Steelmaking and Hot Forming Subcategory
             The Non-integrated Steelmaking and Hot Forming Subcategory has two Segments:
the Carbon and Alloy Steel Segment and the Stainless Steel Segment. EPA evaluated tlie data for
two options: CARBON_BAT-1 (for the Carbon and Alloy Steel Segment) and
SPECIALTY_BAT-1 (for the Stainless Steel Segment). The following two subsections describe
the data for the two segments.

             CARBONJ8AT-1

             The proposed CARBON_BAT-1 option technology is the basis of the proposed
limitations for the direct dischargers in the Carbon and Alloy Steel Segment of the Non-integrated
Steelmaking and Hot Forming  Subcategory. This segment has three manufacturing processes that
discharge wastewater: vacuum degassing, continuous casting, and hot forming.  Using the criteria
described in Section 12.1, EPA selected data from one facility corresponding to one self-
monitoring episode (ISM63) to calculate the proposed limitations for lead and zinc. This facility
treats vacuum degassing, continuous casting, and hot forming wastewater hi its model technology
treatment system. A small amount of noncontact cooling water is also treated in the treatment
                                         12-16
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                                  Section 12 - Limitations and Standards: Data Selection and Calculation
 system. EPA determined that these data represent the pollutant concentrations for all processes in
 this segment because all major wastewater-generating processes in the subcategory are
 represented. EPA used all of the data from this episode in calculating the proposed limitations.

              SPECIALTY_BATrl

              The proposed SPECIAL!Y_BAT-1 option technology is the basis of the proposed
 limitations and standards for the direct and indirect dischargers in the Stainless Steel Segment of
.the Non-integrated Steelmaking  and Hot Forming Subcategory. Using the criteria described in
 Section 12.1, EPA selected one facility corresponding to two episodes: one sampling episode
 (ESE09) and one self-monitoring episode (ISM64). The data from this facility represented
 wastewaters from continuous casting and hot forming.  EPA determined that these data represent
 the pollutant concentrations for all processes because the continuous casting and hot forming
 wastestreams comprise the majority of wastestreams covered in this segment and the proposed
 technology components will treat the metals from all three wastestreams to the same levels
 regardless of the influent concentration levels. EPA proposed limitations for chromium and
 nickel. In calculating the proposed limitations, EPA used the chromium data from the sampling
 episode and the nickel data from both episodes (the self-monitoring episode did not include data
 for chromium).                             .       •

             In the following discussion, the Integrated and Stand-Alone Hot Forming
 Subcategory will be identified as the 'Integrated Hot Forming' Subcategory and the Non-
integrated Steelmaking aiid Hot Forming Subcategory as the 'Non-integrated' Subcategory.

             EPA transferred the proposed limitations for chromium and nickel to the
Integrated Hot Forming Subcategory.  EPA also used the data from sampling episode ESE09 to
calculate the O&G and TSS standards for the Integrated Hot Forming Subcategory.  (As
explained in Section 12.1, industry did not supply any O&G data measured as HEM.) For the final
rule, EPA will reconsider the exclusion of the TSS data from episode ISM64. Because the data
are from the same .facility and are similar to the data obtained during the sampling episode, EPA
does not expect the limitations would change significantly by adding the additional TSS data (see
DCNIS07057 in Section of 8.5 of the proposal  record for summary statistics).

             While EPA has proposed no discharge of process wastewater pollutants to  waters
of the United States for new sources in the Non-integrated Subcategory, EPA used the  O&G and
TSS data from this subcategory to develop the proposed standards for the new direct dischargers
in the Integrated Hot Forming Subcategory.  EPA has determined this is appropriate because the
wastewaters are similar in both subcategories. EPA has proposed different types of limitations for
the two subcategories based upon observed practices. Some facilities in the Non-integrated
Subcategory do not discharge any wastewaters while all facilities in the Integrated Hot Forming
Subcategory discharge wastewaters.
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
12.2.6        Subpart F: Steel Finishing Subcategory

              The Steel Finishing Subcategory has two segments: the Carbon and Alloy Steel
Segment, and the Stainless Steel Segment. As described in the following subsections, EPA
evaluated two options: CARBON_BAT-1 (for the Carbon and Alloy Steel Segment) and
SPECIALTY_BAT-1 (for the Stainless Steel Segment). The following two subsections describe
the data for each segment.

              CARBON_BAT-1

              The proposed CARBON_BAT-1 option technology is the basis of the proposed
limitations and standards for the direct and new indirect dischargers in the Carbon and Alloy Steel
Segment of the Steel Finishing Subcategory. This segment includes manufacturing processes such
as acid pickling and cold forming (see Section 6 for the complete list). EPA selected two facilities
corresponding to two sampling episodes (ESE0415 and ESE05) and two self-monitoring! episodes
(ISM57 and ISM58) to calculate the proposed limitations for chromium, hexavalent chromium,
lead, zinc, O&G, and TSS. (EPA proposed O&G and TSS standards only for new direct
dischargers.) Both facilities treated a number of finishing operations in their model treatment
systems: acid pickling, cold forming, alkaline cleaning, continuous annealing, electroplating, and
hot dip coating.  EPA determined that these data represent the pollutant concentrations for all
processes in this segment because between the two facilities, all manufacturing processes in the
Subcategory are represented.

              For chromium, EPA used the data from both sampling episodes and both self-
monitoring episodes in calculating the proposed limitations.

              For hexavalent chromium, EPA used the data from both sampling episodes in
calculating the proposed limitations.16 EPA excluded the hexavalent chromium data frorii self-
monitoring episode ISM58 because of concerns about the analytical method (see Sectioti 4.4.7
and DCNIS07058 in Section 8.5 of the proposal record).  The other self-monitoring data did not
include data for hexavalent chromium.               ,

              For lead and zinc, EPA used the data from both sampling episodes and self-
monitoring episode ISM57 in calculating the proposed limitations.  EPA excluded the data from
15EPA collected data for five days for this sampling episode. For four days, EPA obtained samples at a single location.
On the fifth day, EPA could not sample at .that location and instead obtained samples of the three wastestrearns that
combined at that location. EPA then field composited the samples to obtain a single composite sample representing that
location. In this document, EPA has identified the samples for the five days with the same sample point. Elsewhere in
the record, EPA may have used a different sample point number for the fifth day.

I6EPA excluded a sample-specific detection limit of 100 ug/L that was a duplicate sample from episode ESE05. The
corresponding duplicate had a sample-specific detection limit of 10 ug/L which was used in the calculations, EPA
excluded the duplicate value of 100 ug/L because it was substantially greater than any detected value (the mpdmum was
15 ug/L) and because all other sample-specific detection limits were all equal to 10 ug/L.               j;
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
 episode ISM58 because of concerns about the analytical method (see Section 4.4.8 and DCN
 IS07058 in Section 8.5 of the proposal record).

              For O&G, EPA used the O&G data measured as HEM from the two sampling
 episodes in calculating the proposed standards.  (As explained in Section 12.1, industry did not
 supply any O&G data measured as HEM in its self-monitoring data.)

              For TSS, EPA used all of the data from all four episodes in calculating the
 proposed standards.

              SPECIALTY_BAT-1

              The proposed SPECIALTYJBAT-1 option technology is the basis for the
 proposed limitations and standards for the direct and new indirect dischargers in the Stainless
 Steel Segment of the Steel Finishing Subcategory. EPA selected two facilities corresponding to
 one sampling episode (ESE06) and one self-monitoring episode (ISM59). EPA proposed  '
 limitations for ammonia as nitrogen, chromium, fluoride, hexavalent chromium, nickel, O&G, and
 TSS. (EPA proposed O&G and TSS limitations only for new sources that are direct dischargers.)
 In calculating the proposed limitations, EPA used all of the data from the sampling episode. In
 addition, EPA used the ammonia as nitrogen, chromium, hexavalent chromium, nickel, and TSS
 data from the self-monitoring episode.  The self-monitoring episode did not include data for
 fluoride or O&G measured as HEM (see Section 12.1).

             Episode ESE06 consists of data from electrolytic sodium sulfate descaling, acid
 pickling, and cold forming.  Episode  ISM59 consists of data from salt bath descaling, acid
 pickling, cold forming, continuous  annealing, alkaline cleaning, and various other finishing
 operations (a small amount of stormwater is also processed in the treatment system). EPA
.determined that these data represent the pollutant concentrations for all processes in this segment
 because all processes in the subcategory are represented.

             In developing the proposed limitations, EPA generally only used data from
 analytical methods approved for compliance monitoring or those that had been in use by EPA for
 decades in support of effluent guidelines development.  The exceptions included industry supplied
 data from episode ISM59. The facility did not include any information on the analytical methods
 corresponding to the reported concentration values. However, because the data were collected at
 the sampling points specified for compliance monitoring, EPA has assumed that the methods were
 selected from the methods specified in or approved under 40 CFR Part 136 that facilities are
 required to use for compliance monitoring. See 40 CFR 122.44(1).  For the final rule, EPA
 intends to contact the facility to confirm its assumption for these data.

             For chromium,  EPA noted differences between the two episodes for total
 chromium with episode ESE06 having detected measurements that were generally greater than
 the detected values from episode ISM59. (The values for episode ESE06 ranged from 69.5 to
 298 ug/L and from 34 to 122 ug/L  for episode ISM59.) The largest value from episode ESE06
 was two times greater than any other value. This concentration value resulted from a batch
                                         12-19
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                                 Section 12 - Limitations and Standards: Data Selection and Calculation
discharge from the chromium pretreatment step.  EPA has no reason to conclude that this is not
part of normal operations and thus has retained this value in calculating the proposed limitations.

             For hexavalent chromium, the two episodes had substantially different  ;
concentration values. Episode ESE06 had detected measurements ranging from 66 to 215 ug/L.
In contrast, episode ISM59 had detected measurements that were all less than the minimum value
for episode ESE06.  (The values for episode ISM59 ranged from 16 to 44 ug/L.) EPA notes that
the data for episode ESE06 were generally high even on the days when the facility did njot
discharge from the chromium pretreatment step.  EPA also notes that some hexavalent chromium
values for episode ESE06 are greater than their corresponding chromium values (which
theoretically should not occur). EPA used the data from both episodes in calculating the
proposed limitations. For the final rule, EPA will review the data and process information to
determine whether both datasets should be used in calculating the limitations.
12.2.7
Subpart G: Other Operations
             The Other Operations Subcategory has three segments: the Direct Reduced Iron
(DRT) Segment, the Forging Segment, and the Briquetting Segment. For the Briquetting
Segment, EPA is proposing no discharge of process wastewater pollutants to waters of'the
United States as discussed in Section 8. The next two subsections describe the data used to
calculate the proposed limitations for the remaining two segments.

             DRI_BPT

             The proposed DRI_BPT option technology is the basis for the proposed
limitations for the direct dischargers in the DRI Segment of the Other Operations Subcajtegory.
EPA selected data from one facility that had the model technology for TSS (and met the criteria in
Section 12.1), which is the only pollutant that EPA is proposing to regulate. This treatment
system treats water only from direct reduced ironmaking processes (a small amount of stormwater
and equipment cleaning water is also treated in the treatment system).  For this facility, EPA had
data from one sampling episode (ESE10) and one self-monitoring episode (ISM65) that it used to
calculate the proposed limitations for TSS. EPA included all of these data in calculating the
proposed TSS limitations.

             FORGING

             For the Forging Segment, EPA proposed limitations for O&G and TSS for direct
dischargers. EPA did not sample forging operations or obtain any forging self-monitoring data
"from facilities with the model technology. Because EPA has determined that the characteristics of
forging operation wastewater are similar to hot forming operation wastewater (see Section 8),
EPA transferred the proposed limitations from both segments of the Integrated and Stand-Alone
Hot Forming Subcategory. Because, depending on the materials used, the forging operations can
create wastestreams similar to either of the Hot Forming Segments, EPA averaged the proposed
limitations from the two segments.
                                         12-20
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
 12.3
 Data Substitutions
              EPA used all of the data described in Section 12.2 in calculating the proposed
 limitations. In general, for these data, EPA used the reported measured value or sample-specific
 detection limit in its calculations. However, in a few cases, EPA substituted other values for
 reported values. These substitutions can be divided into three cases.

              In the first case, EPA compared each laboratory-reported sample result to a
 baseline value (defined in Section 4). In some instances, EPA substituted a larger value for the
 measured value or sample-specific detection limit. This substitution is described in Sections 4.4.1
 and 4.5.1.

              In the second case, EPA compared the reported results to blank samples. If the
 process sample resulted in a concentration between the detection limit and ten times the amount
 detected in the blank sample, EPA considered the result to be non-detected and established a
 sample-specific detection limit equal to the baseline value (defined in Section 4).  EPA made the
 substitutions because .the presence of pollutant could be due to blank contamination. In
 calculating the proposed limitations, this substitution occurred only for chromium data collected
 during one sampling episode (ESE09) of the Integrated and Stand-Alone Hot Forming
 Subcategory.                                                        -

              The third case resulted from slight discrepancies hi numerical representation that
 resulted from converting the database from one software package to another. As a result, values
 such as 0.01 are represented as 0.00999 in the database that EPA used in calculating the proposed
 limitations. This discrepancy is often associated with sample-specific detection limits. While any
 effect on the numerical results should be minimal, for the final rule, EPA will correct the database.
12.4
Data Aggregation
              In some cases, EPA determined that two or more samples had to be
mathematically aggregated to obtain a single value that could be used in other calculations.  In
some cases, this meant that field duplicates and grab samples were aggregated for a single sample
point. In addition, for one facility, data were aggregated to obtain a single daily value
representing the facility's effluent from multiple outfalls. Appendix D lists the data after these
aggregations were completed and a single daily value was obtained for each day for each
pollutant.  (DCNIS07001 in Section 8.1  of the proposal record provides a list of the
unaggregated data.)

              In all aggregation procedures, EPA considered the censoring type associated with
the data. EPA considered measured values to be detected. In statistical .terms, the censoring type
for such data was 'non-censored' (NC). Measurements reported as being less than some sample-
specific detection limit (e.g., <10 mg/L) were censored .and were considered to be non-detected
                                          12-21
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
(ND). In the tables and data listings in this document and the record for the rulemaking, EPA has
used the abbreviations NC and ND to indicate the censoring types.17

              The distinction between the two censoring types is important because the
procedure used to determine the variability factors considers censoring type explicitly.  This
estimation procedure modeled the facility data sets using the modified delta-lognormal
distribution. In this distribution, data are modeled as a mixture of two distributions. Thus, EPA
concluded that the distinctions between detected and non-detected measurements were important
and should be an integral part of any data aggregation procedure.  (See Appendix E for a detailed
discussion of the modified delta-lognormal distribution.)

              Because each aggregated data value entered into the modified delta-lognormal
model as a single value, the censoring type associated with that value was also importanit.  In
many cases, a single aggregated value was created from unaggregated data that were all-either
detected or non-detected. In the remaining cases with a mixture of detected and non-detected
unaggregated values, EPA determined that the resulting aggregated value should be considered to
be detected because the pollutant was measured at detectable levels.

              This section describes each of the different aggregation procedures.  They are
presented in the order that the aggregation was performed. That is, field duplicates  were
aggregated first, grab samples second, and finally multiple outfalls.
12.4.1
Aggregation of Field Duplicates
              During the EPA sampling episodes, EPA collected a small number of fielji
duplicates. Generally, ten percent of the number of samples collected were duplicated,  field
duplicates are two samples collected for the same sampling point at approximately the same tune,
assigned different sample numbers, and flagged as duplicates for a single sample point at a facility.
              Because the analytical data from each duplicate pair characterize the same
conditions at that time at a single sampling point, EPA aggregated the data to obtain one data
value for those conditions. The data value associated with those conditions was the arithmetic
average of the duplicate pair.                                                      i

              In most cases, both duplicates in a pair had the same censoring type.  In these
cases, the censoring type of the aggregate was the same as the duplicates.  In the remaining cases,
one duplicate was a non-censored value and the other duplicate was a non-detected value.  In
these cases, EPA determined that the appropriate censoring type of the aggregate was
'non-censored' because the pollutant had been present in one sample. (Even if the other
"Laboratories can also report numerical results for specific pollutants detected in the samples as "right-censored."
Right-censored measurements are those that are reported as being greater than the highest calibration value of the
analysis (e.g., >1000 ug/L). None of the data used in calculating the proposed limitations included any right-censored
data.
                                           12-22
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
 duplicate had a zero value18, the pollutant still would have been present if the samples had been
 physically combined.) Table 12-1 summarizes the procedure for aggregating the analytical results
 from the field duplicates.  This aggregation step for the duplicate pairs was the first step in the
 aggregation procedures for both influent and effluent measurements.

                     Table 12-1. Aggregation of Field Duplicates
If the field duplicates are:
Both non-censored
Both non-detected •
One non-censored and one
non-detected
Censoring type
of average is:
NC
ND
NC
Value of aggregate is:
arithmetic average of measured values
arithmetic average of sample-specific
detection limits
arithmetic average of measured value
and sample-specific detection limit
Formulas for
aggregate value of
duplicates:
(NC,+NC2)/2
(DL,+ 01^)72
(NC + DL)/2
NC - non-censored (or detected).             ND - non-detected.           DL - sample-specific detection limit.

12.4.2        Aggregation of Grab Samples

              During the EPA sampling episodes, EPA collected two types of samples: grab and
composite.  Typically, EPA collected composite samples.  Of the pollutants proposed for
regulation, O&G was the only one for which the chemical analytical method specifies that grab
samples must be used. For O&G, EPA collected multiple (usually four) grab samples during a
sampling day at a sample point. To obtain one value characterizing the pollutant levels at the
sample point on a single day, EPA mathematically aggregated the measurements from the grab
samples.

              The procedure arithmetically averaged the measurements to obtain a single value
for the day. When one or more measurements were non-censored, EPA determined that the
appropriate censoring type of the aggregate was 'non-censored' because the pollutant was
present.  Table 12-2 summarizes the procedure.
18This is presented as a 'worst-case' scenario. In practice, the laboratories cannot measure 'zero' values. Rather they
report that the value is less than some level (see Section 4).
                                          12-23
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                                  Section 12 - Limitations and Standards: Data Selection and Calculation
                     Table 12-2.  Aggregation of Grab Samples
If the grab or multiple
samples are:
All non-censored
All non-detected '
Mixture of non-censored
and non-detected values
(total number of
observations is nf k+m)
Censoring type of
Daily Value is:
NC
ND
NC
Daily value is:
arithmetic average of measured
values
arithmetic average of sample-
specific detection limits
arithmetic average of measured
values and sample-specific
detection limits
Formulas for Calculating
Daily Value:
ING,
n
2>v
;=i
n ",
iNC, + f DL,
i=l i=l
n
NC-non-censored (or detected).             ND - non-detected.           DL - sample-specific detection limit.

12.4.3        Aggregation of Data Across Outfalls ("Flow-Weighting")

              After field duplicates and grab samples were aggregated, the data were further
aggregated across sample points for different outfalls. This step was necessary for one facility
(corresponding to two episodes:  sampling episode ESE04 with data for three outfalls and self-
monitoring episode ISM57 with  data for five outfalls) where data from multiple sample points
were aggregated to obtain a single daily value representing the episode's effluent from multiple
outfalls. In aggregating values across sample points, if one or more of the values were non-
censored, then the aggregated result was non-censored (because the pollutant was present in at
least one stream). When all of the values were non-detected, then the aggregated result was
considered to be non-detected. The procedure for aggregating data across streams is summarized.
in Table 12-3. The following example demonstrates the procedure for hypothetical pollutant X at
an episode with three outfalls all from the model technology on day 1 of the sampling episode.
Example of calculating an aggregated flow-weighted value:
       Day
        1
        1
        1
Sample Point
   •SP-A
    SP-B
    SP-C
Flow (gaD
10,000,000
20,000,000
5,000,000
Concentration
         10
         50
        100
Censoring
   ND
   NC ;
   ND
              Calculation to obtain aggregated, flow-weighted value:
 (10,000,000 galx 10 ug / L)+(20,000,000 galx 50 ug / L) + (5,000,000 galx 100 ug / L) ^          (12-1)
                 10,000,000 gal+ 20,000,000 gal + 5,000,000 gal
                                          12-24
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                                  . Section 12 - Limitations and Standards: Data Selection and Calculation
 Because one of the three values was non-censored, the aggregated value of 45.7 ug/L is non-
 censored.

                  Table 12-3. Aggregation of Data Across Streams
If the n observations are:
All non-censored
All non-detected
Mixture of k non-censored and
m non-detected
(total number of observations is n=k+m)
Censoring type is:
NC
ND
NC
Formulas for value of aggregate
n
£ NC.xflow.
i = l l 1
n
£ flow.
n
I DL. x flow.
1 — Jl
n
I flow.
k m
2, NCj x flow; + ^ DLj x floWj
i=l i=I
2_j flOWj
NC - non-censored (or detected).             ND - non-detected.           DL - sample-specific detection limit.

12.5          Overview of Limitations

              The preceding sections discuss the data selected as the basis for the proposed
limitations and the data aggregation procedures EPA used to obtain daily values in its
calculations.  This section (12.5) provides a general overview of limitations before returning to
the development of the proposed limitations for the iron and steel industry in Section 12.6. This
section describes EPA's objective for daily maximum and monthly average limitations, the
selection of percentiles for those limitations, and compliance with final limitations. EPA has
included this discussion in Section 12 because these fundamental concepts are often the subject of
comments on EPA's proposed effluent guidelines regulations and in EPA's contacts and
correspondence with the iron and steel industry.                            •'.-...
12.5.1
Objective
              In establishing daily maximum limitations, EPA's objective is to restrict the
discharges on a daily basis at a level that is achievable for a facility that targets its treatment at the
long-term average. EPA acknowledges that variability around the long-term average results from
normal operations. This variability means that occasionally facilities may discharge at a level that
is  greater than the long-term average. This variability also means that facilities may occasionally
                                          12-25
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
discharge at a level that is considerably lower than the long-term average. To allow for these
possibly higher daily discharges, EPA has established the daily maximum limitation. A facility that
discharges consistently at a level near the daily maximum limitation would not be operating its
treatment to achieve the long-term average, which is part of EPA's objective in establishing the
daily maximum limitations. That is, targeting treatment to achieve the limitations may reisult in
frequent values exceeding the limitations due to routine variability in treated effluent.

              In establishing monthly average limitations, EPA's objective is to provide an
additional restriction to help insure that facilities target their average discharges to achieve the
long-term average. The monthly average limitation requires continuous dischargers to provide
on-going control, on a monthly basis, that complements controls imposed by the daily maximum
limitation.  In order to meet the monthly average limitation, a  facility must counterbalancjs a value
near the daily maximum limitation with one or more values well below the daily maximum
limitation.  To achieve compliance, these values must result in a monthly average value at or
below the monthly average limitation.
12.5.2
Selection of Percentiles
              EPA calculates limitations based upon percentiles chosen with the intention, on
one hand, to be high enough to accommodate reasonably anticipated variability within control of
the facility and, on the other hand, to be low enough to reflect a level of performance consistent
with the Clean Water Act requirement that these effluent limitations be based on the "best"
technologies. The daily maximum limitation is an estimate of the 99th percentile of the
distribution of the daily measurements. The monthly average limitation is an estimate of the 95th
percentile of the distribution of the monthly averages of the daily measurements.

              The 99th and 95th percentiles do not relate to, or specify, the percentage of time a'
discharger operating the "best available" or "best available demonstrated" level of technology will
meet (or not meet) the limitations. Rather, the use of these percentiles relate to the development
of limitations. (The percentiles used as a basis for the limitations are calculated using the products
of the long-term averages and the variability factors as explained in the next section.)  If a facility
is designed and operated to achieve the long-term average on a consistent basis and the facility
maintains adequate control of its processes and treatment systems, the allowance for variability
provided in the limitations is sufficient to meet the requirements of the proposed rule. The use of
99 percent and 95 percent represents a need to draw a line at a definite point in the statistical
distributions (100 percent is not feasible because it represents an infinitely large value) and a
policy judgment about where to draw the line that would ensure that operators work hard to
establish and maintain the appropriate level of control. In essence, in developing the proposed
limitations, EPA has taken into account the  reasonable anticipated variability in discharges that
may occur at a well-operated facility.  By targeting its treatment at the long-term average, a well-
operated facility should be capable of complying with the limitations at all times becauseJEPA has
incorporated an appropriate allowance for variability into the limitations.               |

              Li conjunction with the statistical methods, EPA performs an engineering review
to verify that the limitations are reasonable  based upon the design and expected operation of the
                                           12-26
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
 control technologies and the facility process conditions. As part of that review, EPA examines
 the range of performance by the facility data sets used to calculate the limitations.  Some facility
 data sets demonstrate the best available technology.  Other facility data sets may demonstrate the
 same technology, but not the best demonstrated design and operating conditions for that
 technology. For these facilities, EPA will evaluate the degree to which the facility can upgrade its
 design, operating, and maintenance conditions to meet the limitations. If such upgrades are not
 possible, then the limitations-are modified to reflect the lowest levels that the technologies can
 reasonably be expected to achieve.                                              '  .
 12.5.3
Compliance with Limitations
            ' EPA promulgates limitations that facilities are capable of complying with at all
times by properly operating and maintaining their processes and treatment technologies.
However, the issue of exceedances19 or excursions is often raised by comments on proposed
limitations (as has been EPA's experience with proposals for other industries). For example,
comments often suggest that EPA include a provision that a facility is in compliance with permit
limitations if its discharge does not exceed the specified limitations, with the exception that the
discharge may exceed the monthly average limitations one month out of 20 and the daily average
limitations one day out of 100. This issue was, in fact, raised in other rules, most notably in
EPA's final Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) rulemaking.  EPA's
general approach there for developing limitations based on percentiles is the same in this proposal,
and was upheld in Chemical Manufacturers Association v. U.S. Environmental Protection
Agency. 870 F.2d  177, 230 (5th Cir. 1.989). The Court determined that:

              EPA reasonably concluded that the data points
              exceeding the 99th and 95th percentiles represent  either
              quality-control problems or upsets because there can be
              no other explanation for these isolated and extremely
              high discharges.  If these data points result from quality-
              control problems, the exceedances they represent are
              within the control of the plant. If, however, the data
              points represent exceedances beyond the control of the
              industry, the upset defense'is available.
              Idiat230.

              EPA's allowance for reasonable anticipated variability in its effluent limitations,
coupled with the availability of the upset defense reasonably accommodates acceptable
excursions. Any further excursion allowances would go beyond the reasonable accommodation
of variability and would jeopardize the effective control of pollutant discharges on a consistent
basis and/or bog down administrative and enforcement proceedings in detailed fact, finding
exercises, contrary to Congressional intent.  See, e.g., Rep. No. 92-414, 92nd Congress, 2nd
"Values that exceed the limitations
                                          12-27
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                                  Section 12 -.Limitations and Standards: Data Selection and Calculation
Sess. 64, reprinted in A Legislative History of the Water Pollution Control Act Amendments of
1972 at 1482; Legislative History of the Clean Water Act of 1977 at 464-65.

              EPA recognizes that the preceding discussion is inconsistent with Appendix A in
two of the 1982 development documents.  (The same appendix is attached to both documents.)
This appendix incorrectly implies that EPA condones periodic violations of monthly average
limitations in its statement that

              ... it would be expected that 95 percent of the
              randomly observed  30-day average values from a
              treatment system discharging the pollutant at a known
              mean concentration will fall below this bound. Thus, a
              well operated plant  would be expected, on the average,
              to incur approximately one violation of the 30-day                    \
              average limitation during a 20 month period.                          ;

This statement does not accurately reflect EPA's interpretation of its 1982 regulations, nor of
today's proposed limitations. Rather, EPA expects that facilities will comply with promulgated
limitations at all times. If the exceedance is caused by an upset condition, the facility would have
an affirmative defense to an enforcement action if the requirements of 40 CFR 122.41(n) are met.
If the exceedance is  caused by a design or operational deficiency, then EPA has determined that
the facility's performance does not represent the appropriate level of control (best available
technology for existing sources; best available demonstrated technology for new sources).  For
promulgated limitations and standards, EPA has determined that such exceedances can b$
controlled by diligent process and wastewater treatment system operational practices such as
frequent inspection and repair of equipment, use of back-up systems, and operator training and
performance evaluations.
12.6
Summary of Proposed Limitations
              The proposed limitations for pollutants for each option are provided as 'daily
maximums' and 'maximums for monthly averages' (except for pH as described below).
Definitions provided in 40 CFR 122.2 state that the daily maximum limitation is the "highest
allowable 'daily discharge'" and the maximum for monthly average limitation (also referred to as
the "monthly average limitation") is the "highest allowable average of 'daily discharges'[over a
calendar month, calculated as the sum of all 'daily discharges' measured during a calendar month
divided by the number of 'daily discharges' measured during that month." Daily discharges are
defined to be the '"discharge of a pollutant' measured during a calendar day or any 24-hour
period that reasonably represents the calendar day for purposes of samplings."
follows:
              EPA has proposed five types of limitations for the iron and steel industry as
              Type 1:       Proposed daily maximum and monthly average limitations
                           expressed in terms of allowable pollutant discharge (pounds) per
                                          12-28
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                                  Section 12 - Limitations and Standards: Data Selection and Calculation
                            unit of production (short tons). Most of the proposed'limitations
                            are of this type.            '                •

              Type 2:       Proposed daily maximum and monthly average limitations are
                            expressed in terms of allowable pollutant discharge (pounds) per
                            day. This second type is used for fume scrubber operations (both
                            wet pollution and acid regeneration) in the Steel Finishing
                            Subcategory.

              Type 3:       Proposed daily maximum limitations for 2,3,7,8-
                            tetrachlorodibenzq-furan (TCDF) are expressed as less than the
                            minimum level ("
-------
                                   Section 12 - Limitations and Standards: Data Selection and Calculation
12.7
Estimation of Concentration-Based Limitations
              In estimating the concentration-based limitations (except TCDF which is described
in the previous section), EPA determines an average performance level (the "option lon^-term
average" discussed in the next section) that a facility with well-designed and operated model
technologies (which reflect the appropriate level of control) is capable of achieving. This long-
term average is calculated from the data from the facilities using the model technologies for the
option (these data are described in Section 12.2).  EPA expects that all facilities subject to the
limitations will design and operate their treatment systems to achieve the long-term average
performance level on a consistent basis because facilities with well-designed and operated model
technologies have demonstrated that this can be done.

              In the second step of developing a limitation, EPA determines an allowance for the
variation in pollutant concentrations when processed through extensive and well designed
treatment systems. This allowance for variance incorporates all components of variability
including shipping, sampling, storage, and analytical variability. This allowance is incorporated
into the limitations through the use of the variability factors (the "option variability factor"
discussed in Section 12.7.4) which are calculated from the data from the facilities using the model
technologies.  If a facility operates its treatment system to meet the relevant long-term average,
EPA expects the facility will be able to meet the limitations. Variability factors assure that normal
fluctuations in a facility's treatment are accounted for in the limitations. By accounting for these
reasonable excursions above the long-term average, EPA's use of variability factors resets in
limitations that are generally well above the actual long-term averages.

              Facilities that are designed and operated to achieve long-term average effluent
levels used in developing the limitation should be capable of compliance with the proposed
limitations, which incorporate variability, at all times.

              The following sections describe the calculation of the option long-term averages
and option variability factors.                                                  '     j
12.7.1
Calculation of Option Long-Term Averages
              This section discusses the calculation of long-term averages by episode ^"episode-
specific long-term average") and by option ("option long-term average") for each pollutant.
These long-term averages discussed in this section were used to calculate the proposed
limitations.20

              First, EPA calculated the episode-specific long-term average by using either the
modified delta-lognormal distribution or the arithmetic average (see Appendix E). In Attachment
20For existing purposes, EPA used the arithmetic averages of the data. Because the costing analyses were performed  •
earlier than the calculation of the proposed limitations, most of the data exclusions were not incorporated in'the costing
analyses. However, before incorporating the data exclusions into the proposed limitations, EPA concluded that the
impact of the data exclusions on the costing analyses would not be sufficient to result in selection of a different option.
                                            12-30
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
 12-1 in Appendix F, EPA has listed the arithmetic average (column labeled 'Obs Mean') and the
 estimated episode-specific long-term average (column labeled 'Est LTA').  If EPA used the
 arithmetic average as the episode long-term average, then the two columns have the same value..

              Second, EPA calculated the option long-term average for a pollutant as the
 median of the episode-specific long-term averages for that pollutant from selected episodes with
 the technology basis for the option (see Sections 12.1 and 12.2).  The median is the midpoint of
 the values ordered (i.e., ranked) from smallest to largest. If there is an odd number of values
 (with n=number of values), then the value of the (n+l)/2 ordered observation is the median. If
 there are an even number of values, then the two values of the n/2 and [(n/2)+l] ordered
 observations are arithmetically averaged to obtain the median value.                         •

              For example, for subcategory Y option Z, if the four (i.e., n=4) episode-specific
 long-term averages for pollutant X are:
                                      Episode-Specific Long-Term Average
                                                    20 mg/1
                                                    9 mg/1
                                                    16 mg/1
                                                    10 mg/1
then the ordered values are:
Order
1
2
3
4
Facility
A
B
G
D
                                      Episode-Specific Long-Term Average
                                                    9 mg/1
                                                    10 mg/1
                                                    16 mg/1
                                                    20 mg/1

And the pollutant-specific long-term average for option Z is the median of the ordered values
(i.e., the average of the 2nd and 3rd ordered values): (10+16)/2 mg/1 = 13 mg/1.

              The option long-term averages were used in developing the proposed limitations
for each pollutant within each regulatory option.
12.7.2
Comparison of Option Long-Term Averages to Baseline Values
              After calculating the option long-term averages for each pollutant, EPA compared
these values to the baseline values provided in Section 4. If the option long-term average was less
than the baseline value, EPA substituted the baseline value for the option long-term average.
                                         12-31
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                                  Section 12 - Limitations and Standards: Data Selection and Calculation
(This comparison is described in more detail in Section 4.4.)  Table 12-4 identifies the cases for
                                                                      21
which the baseline value was substituted for the calculated long-term average.

   Table 12-4.  Option Long-Term Averages Replaced by the Baseline Values
Pollutant
Lead
TSS
Baseline
Value
(ug/L)
50
4000
Subcategory
Finishing
Integrated and Stand-Alone Hot
Forming
Integrated Steelmaking
Ironmaking
Non-Integrated Steelmaking and
Hot Forming
Finishing
Option
CARBON BAT-1
CARBON-BAT-1 •
BAT-1
BAT-1
PSES-1
CARBON_BAT-1
SPECIALTY BAT-1
Calculated Option
Long-Term
Average (ug/L)
2.0
12.3
12.9
3.5
33.0
1.0
3,454
12.7.3        Transfer of Option Long-Term Average

              For the BAT-1 option in the Ironmaking Subcategory, EPA did not receive any
data for phenol from the model technology.  (See Section 12.2.2.1.)  For this single case, EPA
transferred the option long-term average from an option in the 1982 rulemaking. This long-term
average (0.01 mg/L) was the same for both the sintering and ironmaking subcategories for the
1982 rule.                                                                       !
12.7.4
Calculation of Option Variability Factors
              In developing the option variability factors used in calculating the proposed
limitations, EPA first developed daily and monthly episode-specific variability factors using the
modified delta-lognormal distribution. This estimation procedure is described in Appendix E.
Attachment 12-2 in Appendix F lists the episode-specific variability factors.

              After calculating the episode-specific variability factors, EPA calculated the option
daily variability factor as the mean of the episode-specific daily variability factors for that
pollutant in the Subcategory and option. Likewise, the option monthly variability factor was the
mean of the episode-specific monthly variability factors for that pollutant in the subcategory and
option.  Attachment 12-3 in Appendix F lists the option variability factors.
5IEPA made this substitution only for the purposes of calculating the proposed limitations. Elsewhere in its evaluation of
the industry (such as costing and benefits estimation), EPA used the values as calculated.              I
                                           12-32
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                                    Section 12 - Limitations and Standards: Data Selection and Calculation
 12.7.5
Transfers of Option Variability Factors
               After estimating the option variability factors, EPA identified several pollutants for
 which variability factors could not be calculated in some options. This resulted when all episode
 datasets for the pollutant in the option had too few detected measurements to calculate episode-
 specific variability factors.(see data requirements in Appendix E).  For example, if a pollutant had
 all non-detected values for all of the episodes in an option, then it was not possible to calculate
 option variability factors. When EPA could not calculate the option variability factors or
 determined that the calculated option variability factors should be replaced, EPA selected
 variability factors  from other sources to provide an adequate allowance for variability in the
 proposed limitations. This section describes these cases.

               Table 12-5 lists the pollutants for which EPA was unable to calculate option
 variability factors. The following paragraphs describe EPA's determination for each case.

  Table 12-5. Cases where  Option Variability Factors Could Not be Calculated
Subcategory
Cokemaking
Steel Finishing
Ironmaking
Other Operations
Non-Integrated
Steelmaking and
Hot Forming
Option
BAT-1
SPECIALTY_BAT-1
PSES-1 ;
DRIJBPT
CARBON_BAT-1
Pollutant
Benzo(a)pyrerie
Phenol
Oil & Grease
Oil & Grease
Oil & Grease
Lead
Source of Variability Factors
naphthalene, same option
OCPSF phenol values from biological treatment
(2.49705, 1.40602)
median of Oil & Grease variability factors from
all non-cokemaking subcategories (see Table
1-2-6) .
median of lead VFs across'subcategories and
options where lead has proposed limitations
              For benzo(a)pyrene in the BAT-1 option of the Cokemaking Subcategory, EPA
transferred the option variability factors for naphthalene from the same option. EPA expects that
these two pollutants would have similar variability in the effluent concentrations because they are
chemically similar.                                                       .

              Likewise for phenol in the BAT-1 option of the Cokemaking Subcategory, EPA
transferred the variability factors that were used to develop the promulgated limitations for the
Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) industry. These variability factors for
phenol are listed in Table VII-66 'Individual Toxic Pollutant Variability Factors for BAT
Subcategory One' on page VII-222 of the OCPSF Development Document.22 EPA has
determined that it is reasonable to transfer the variability factors from that industry to the
"U.S. Environmental Protection Agency. Development Document for Effluent Limitations Guidelines and Standards for
the Organic Chemicals. Plastics, and Synthetic Fibers Point Source Category. Volume I, Volume II.
EPA 440/1-87/009,1987.
                                          12-33
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                                  Section 12 - Limitations and Standards: Data Selection and Calculation
Cokemaking Subcategory because of similarities in the model technologies.  (Both OCPSF and
iron and steel assume weekly monitoring in calculating the monthly variability factors.)

             For O&G, because there were too few detected measurements, option variability
factors could not be calculated for two options: SPECIALTYJBAT-1 in the Steel Finishing
Subcategory and PSES-1 in the Ironmaking Subcategory. For these options, EPA used the
median of the option variability factors from all subcategories where EPA proposes to regulate
O&G, except the Cokemaking Subcategory. (These option variability factors are listed in Table
12-6.) EPA excluded the Cokemaking Subcategory from the median calculations because the
BAT-1 option in cokemaking includes biological treatment, which is not a component of the other
model technologies.

        Table 12-6.  O&G Long-Term Averages  and Variability Factors
Subcategory
Cokemaking
Steel Finishing
Integrated and Stand-Alone
Hot Forming
Non-Integrated
Steelmaking and Hot
Forming
Ironmaking
Option
BAT-1
CARBON_BAT-1
SPECIALTY_BAT-1
CARBON_BAT-1
SPECIALTYJBAT-1
PSES-1
Long-Term
Average (mg/L)
7.24
6.28
6.20
6.58
9.20
5.88
Median Variability Factors (excluding Cokemaking)
Variability Factors
Daily
2.57
1.19
N/A
1.44
3.07
N/A
1.44
Monthly
| 1.39
; 1.07
,N/A
1.14
1.56
r
;N/A
1 1.14
N/A - Variability Factors could not be calculated for this option.

              For lead, EPA determined that the median of the lead variability factors should be
used for the PSES-1 option of the Non-integrated Steelmaking and Hot Forming Subcategory.
(See Table 12-7.) Further, EPA determined that these median variability factors should be applied
to all subcategories where lead has proposed limitations.  EPA made this determination because
the variability factors vary widely (from 1.65 to 8.57 for the daily variability factors) from option
to option, but the long-term averages are all equal to the same value of 50 ug/L.  (This is because
all of the calculated long-term averages were below the baseline value of 50 ug/L as explained in
Section 12.7.2.)  Before making this determination, EPA compared the largest detected value for
each option to the proposed daily maximum limitation of 146 ug/L derived from the baseline value
and the median variability factor. All of the detected concentrations were substantially below the
proposed daily maximum limitation.                                               !
                                          12-34
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
         Table 12-7. Lead Long-Term Averages and Variability Factors
Subcategory
Steel Finishing
Integrated and Stand-
Alone Hot Forming
Integrated Steel
Ironmaking
Non-Integrated
Steelmaking and Hot
Forming
Option
CARBON_BAT-1
CARBON_BAT-1
BAT-1
BAT-1
PSES-1
CARBON_BAT-1
Baseline
Value
(new LTA)
ug/L
. 50
50
50
50
50
50
Maximum
Detected
Value
(ug/L)
12
. 12
33
23
68
all non-
detected
Calculated
Long-Term
Average
(ug/L)
2.00
12.85
26.78
3.47
33.05
1.0
Median Variability Factors:
Variability Factors
Daily
1.65
6.80
1.75
8.57
2.92
n/a
2.92
Monthly
1.11
2.35
1.22
2.70
1.52
n/a
1.52
12.7.6
Summary of Steps Used to Derive Concentration-Based Limitations
              This section summarizes the steps used to derive the proposed concentration-based
limitations. For each pollutant in an option for a subcategory, EPA performed the following steps
in calculating the proposed concentration-based limitations:

Step 1        EPA calculated the episode-specific long-term averages and daily and monthly
              variability factors for all selected episodes with the model technology for the
              option in the subcategory. (See Section 12.2 for selection of episodes and
              Attachment 12-2 hi Appendix F for episode-specific long-term averages and
              variability factors.)

Step 2        EPA calculated the option long-term average as the median of the episode-specific
              long-term averages.  (See Attachment 12-3 in Appendix F.)

Step 3        EPA calculated the option variability factors for each pollutants as the mean of the
              episode-specific variability factors from the episodes with the model technology.
              (See Attachment 12-3 in Appendix F.)  The option daily variability factor is the
              mean of the episode-specific daily variability factors. Similarly, the option monthly
              variability factor is the mean of the episode-specific  monthly variability factors.

Step 4 .     "  For the pollutants for which Steps 1 and 3 failed to provide option variability
              factors, EPA determined variability factors on a case-by-case basis. (See Table 12-
              5.)                   ..  '  •                                                .
                                         12-35
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
 Step 5        EPA calculated each proposed concentration-based daily maximum limitation for
              a pollutant using the product of the option long-term average and the option daily
              variability factor. (See Attachment 12-3 in Appendix F.)

 Step 6        EPA calculated each proposed concentration-based monthly average limitation for
              a pollutant using" the product of the option long-term average and the option
              monthly variability factor. (See Attachment 12-3 in Appendix F.)       [

, Step 7        EPA compared the proposed daily maximum limitations to the data used to
              develop the limitations. EPA performed this comparison to determine if EPA used
              appropriate distributional assumptions for the data used to develop the limitations,
        •  '    in other words, whether the curves EPA used provide a reasonable "fit" to the
              actual effluent data.23  (See DCNIS07030 in Section 8.3 of the proposal record.)

              The next section describes the conversion of the concentration-based limitations to
 the production-normalized limitations that are provided in the proposed regulation.     |
 12.8
Conversion to Production-Normalized Limitations
                                                                      *-          k
              •The previous discussions about the limitations'were based upon concentration
 data. However, except for 2,3,7,8-TCDF and pH (see Section 12.6), EPA proposed limitations
 expressed as pounds per short ton (Ibs/ton) and pounds per day (Ibs/day).  The current Part 420
 regulation and other previous mass-based regulations have presented pollutant limitations in terms
 of kilograms of allowable pollutant discharge per thousand kilograms of production (Teg/jkkg), also
 expressed as pounds of allowable pollutant discharge per thousand pounds of production
 (lbs/1,000 Ibs). Today's proposed regulation presents pollutant limitations in terms of pbunds of
 allowable pollutant discharge per ton of production (Ibs/ton). The Agency made this change to
 express the limitations in terms of the production value that is a standard throughout the industry.
 In section Xffl.B of the preamble to the proposed rule, the Agency has requested comments on
 this format.

              This section describes the conversion from concentration-based limitations to the
 production-normalized limitations in the proposed regulation. This section also provides EPA's
 methodology for determining the number of significant digits to use for the proposed production-
 normalized limitations.
 12.8.1
Conversion from Concentration-Based Limitations
              In calculating the proposed production-normalized limitations, EPA used the
 concentration-based limitations, the production flow rates, and one of two conversions factors.
 MEPA believes that the feet that EPA performs such an analysis before proposing limitations may give the impression
 that EPA expects occasional exceedances of the limitations. This conclusion is incorrect. EPA promulgates] limitations
 that facilities are capable of complying with at all times by properly operating and maintaining their treatment
 technologies. This concept is explained in greater detail in DCN IS07030 in Section 8.3 of the proposal record.
                                           12-36
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                                   Section 12 - Limitations and Standards: Data Selection and Calculation
 The concentration-based limitations are calculated as described in the previous section and are
 listed in Attachment 12-3 in Appendix F. The following paragraphs briefly describe the
 production flow rates and the conversion factors used to calculate the production-normalized
 limitations.

               The production flow rates used in the calculation are expressed as production-
 normalized flow rates (PNFs) in terms of gallons of water discharged per ton of production (gpt)
 for all operations except certain fume scrubbers (wet air pollution control devices and acid  •
 regeneration for steel finishing operations) where the flow rates are expressed in gallons per
 minute (gpm). The production-normalized flow rates are provided in Attachment 12-4 in
 Appendix F (the derivation of these flow rates is explained in Section 7).

              EPA used two different conversion factors depending on whether the production-
 normalized flow rates were expressed as gallons per ton (gpt or gal/ton) or gallons per minute
 (gpm or gal/min).  Both conversion factors assume that the concentration-based limitations are
 expressed as micrograms per liter (ug/L).24 These two conversion factors are listed below:
            Conversion factor 1 :
                                   used to obtain proposed limitations expressed as pounds per
                                   ton (Ib/ton) for all processes except fume scrubbers and acid
                                   regeneration:
                 .   ^          3.7854L
         ConversionFactor 1  =	:— x
                                  gal
                                               Ib
                                         453.593xl06mg
                                                         - 8.3454x10"
 L/gal
mg/lb
(12-2)
              Conversion Factor 2: used to obtain proposed limitations expressed as pounds per
                                  day (Ib/day) for fume scrubbers and acid regeneration
                                  processes:                                 ~           .
Conversion Factor 2= Conversion Factor
                                                  J^= 1.2017X 10~5 L/gaI min  (12-3)
                                            hr     day                 mg/lb day
              The following is an example of applying the first conversion factor:

                     For the Ironmaking Subcategory option BAT-1, suppose the concentration
                     based daily maximum limitation is 100 ug/L.  Using the production value of
                     75 gpt for the Ironmaking Subcategory, the production-normalized daily
                     maximum limitation (limitlpn) is:                                     .
         Limit\m = 100^ x 75—^— x 8.3454x 10~9
               p        L      short ton .
                                                              = 0.0000626—    (12-4)
                                                                          ton
24To convert concentration-based limitations expressed as milligrams per liter (mg/L) rather than ug/L, both conversion
factors were multiplied by 1000.
                                          12-37
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                                  Section 12 - Limitations and Standards: Data Selection and* Calculation
              EPA used the production flows and conversion factors to calculate each
production-normalized limitation using the following basic equation:

Production-normalized limitation =
     Concentration-based limitation x Production-normalized flow rate x conversion factor
12.8.2
Significant Digits for Production-Ndrmalized Limitations
             After completing the conversions described in the previous section, EPA rounded
the proposed production-normalized limitations to three significant digits. EPA used a rounding
procedure where values of five and above are rounded up and values of four and below are
rounded down.  For example, a value of 0.003455 would be rounded to 0.00346, while a value of
0.003454 would be rounded to 0.00345. The production-normalized limitations listed in
Attachment 12-5 in Appendix F have three significant digits.          .
12.9
Transfers of Limitations
             In some cases, EPA was either unable to calculate a limitation using the available
data for an option or determined that the treatment provided by facilities employing the option did
not represent the appropriate level of treatment for the model technologies. In these casks, EPA
based the proposed limitations for one option upon data from another option or from the 1982
regulation. In effect, EPA has transferred the limitations from one option to another. Table 12-8
identifies each case and the section that provides EPA's rationale for the transfer.
                                         12-38
-------
                                   Section 12 - Limitations and Standards: Data Selection and Calculation
                  Table 12-8.  Transfers of Proposed Limitations
Target Subcategory/Option
Cokemaking By-ProducbTBAT-3
Cokemaking By-Producb'BAT-3
(cent.)
Ironmaking/ BAT-1
Integrated and Stand-Alone Hot
Forming / SPECIALTY_BAT-1
(Stainless Steel Segment)
Other Operations/Forging
Transfers
discussed in
Section:
12.2.1.1
12.2.1.1
12.2.2.1
12.2.4.2
12.2.7.2
Source of Limit Transfer
BAT-1 (same subcategory)
.1982 Regulation
(ironmaking/sinter
subcategories)
PSES-1 (same subcategory)
1982 Regulation
(ironmaking/sinter
subcategories)
Non-Integrated Steelmaking and
Hot Forming/
SPECIALTY_BAT-1
Average of the proposed BAT-1
limitations for the two options
(CARBON_BAT-1 and
SPECIALTY_BAT-1) in the
Integrated and Stand-Alone Hot
Forming Subcategory
Pollutant
Berizo(a)pyrene
Oil & Grease
Mercury
Naphthalene
Phenol
Selenium
Thiocyanate
TSS
TRC1
2378-TCDF
(Sintering
Subcategory only)
Oil & Grease
TRC1
TSS
Chromium
Oil & Grease
Nickel
TSS
Oil & Grease
TSS
'EPA proposed only daily maximum limitations for TRC because the 1982 regulations do not include monthly average
limitations.

              For the proposed limitations transferred from other options (rather than the 1982
regulation), EPA transferred the concentration-based limitations (listed in Attachment 12-3 in
Appendix F) and converted them to production-normalized limitations using the appropriate
production values identified hi Attachment 12-4 in Appendix F. (The proposed limitations for
2,3,7,8-TCDF were not converted to production-normalized limitations because the limitations
are expressed as less than the minimum level ("
-------
                                 Section 12 - Limitations and Standards: Data Selection and Calculation
              For the proposed limitations transferred from the 1982 regulation, EPA adjusted
the production-normalized limitations for the proposed production-normalized flow (listed in
Section 12-4) and the change in units from the pounds per 1000 pounds in the 1982 regulation to
the proposed pounds per ton. For example, in converting the total residual chlorine (TRJC) daily
maximum limitation ('limitl') of 0.000146 lb/1000 Ib from the Ironmaking Subcategory to the
Cokemaking Subcategory, EPA adjusted for the production-normalized flows by using the ratio
of the proposed production-normalized flow of 158 gal&on for the Cokemaking Subcategory to
the production-normalized flow of 70 gal/ton used in 1982 to develop the ironmaking limitation.
EPA then multiplied by 2  to convert from lb/1000 Ib to Ib/ton. After these conversion, EPA
obtained the proposed value of 0.000165 Ib/ton:
TRC proposed daily maximum limitation for cokemaking
                         gal
                                '   ..  1000 Ib'
            = 0.000146
  Ib
1000 Ib
                                  158
                                   70
 ton
gal
ton
                                                     ton
= 0.000165 J2-      (12-5)
            ton
             As explained in Section 12.2, EPA has concluded that the transfers of these
proposed limitations are appropriate after considering the technology bases. 'As such, EPA has
every reason to conclude that facilities employing the option technology could achieve the .
proposed limitations.                          •

             In the proposed regulation, EPA modified the expression of some limitations (such
as BPT limitations for most subcategories) from those in the 1982 regulation.  EPA has done this
so that the limitations correspond to the proposed subcategorization described hi Section 6. In
this modification, EPA has expressed the limitations in terms of Ib/ton rather than lb/1000 Ib (or
kg/1000 kg) used in the 1982 regulation. The corresponding numerical values are now twice as
large as those in the 1982 regulation.  However, while the numerical values in the proposed
regulation are greater than those in the 1982 regulation, they are mathematically equivalent
because of the change in the units from lb/1000 Ib to Ib/ton.  For example, a limitation of 0.0300
lb/1000 Ib in the 1982 regulation is the same as 0.0600 Ib/ton in the proposed regulation^  The
Agency made this change to express the limitations in terms of the production value that is a.
standard throughout the industry. In section XIII.B of the preamble to  the proposed rule, the
Agency has requested comments on this format.
                                         12-40
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                                               Section 13 - Non-Water Quality Environmental Impacts
                                      SECTION 13

                NON-WATER QUALITY ENVIRONMENTAL IMPACTS

               Sections 304(b) and 306 of the Clean Water Act require EPA to consider
 non-water quality environmental impacts, including energy requirements, associated with effluent
 limitations guidelines and standards. In accordance with these requirements, EPA has considered
 the potential impacts of the proposed regulation on energy consumption, air emissions, and solid
 waste generation.  Agency estimates of these impacts for each subcategory are presented in Table
 13-1 and summarized in Sections 13.1, 13.2, and 13.3.
 13.1
Energy Requirement Impacts
              Table 13-1 summarizes energy requirements, as reported in the industry surveys,
 by subcategory. Table 13-2 presents the incremental energy requirements for each option within
 each subcategory. EPA determined the incremental energy requirements only for those new
 treatment units that would be necessary to upgrade to the model treatment systems.  The energy
 requirements for each option are discussed in the subsections below. In general, additional energy
 requirements are a result of the electric motors in new or upgraded cooling water recycle and
 treatment systems to drive water pumps, chemical mixers, aeration equipment such as blowers
 and compressors, and cooling tower fans. Energy requirements are calculated by summing the
 total horsepower (HP) needed for each recycling or treatment step, converting horsepower to
 kilowatts (kW),  and multiplying by the operational time (hours). The equation below shows the
 conversion from total system horsepower to annual electrical usage (Reference 13-1) in kilowatt-
 hours per year (kWh/yr).
                      Energy Required = 0.7456
                                   kW
                                   HP
x HP x HPY
(13-1)
 where:
              HP    =
              HPY  =
             Total horsepower required by additional equipment
             Hours per year of equipment operation.
 13.1.1
Cokemaking Subcategory
              This subcategory contains 14 direct dischargers and eight indirect dischargers.
. Additional energy requirements are shown in Table 13-2 for BAT-1 (tar removal, ammonia
 distillation, and biological treatment) and BAT-2 (tar removal, ammonia distillation, cyanide
 precipitation, and biological treatment) can be attributed to two direct dischargers installing
 aerobic biological nitrification basins and seven installing cyanide precipitation. The significant
 increase in energy requirements between BAT-2 and BAT-3 is a result of alkaline chlorination
 being added to all 14 direct dischargers. Added energy1 requirements for BAT-4 are for pumping
 effluent from the alkaline chlorination system through 12 new multimedia filtration and carbon
 adsorption systems.    .         '   '        .                                          •
                                          13-1
-------
                                               Section 13 - Non-Water Quality Environmental Impacts
              None of the eight indirect dischargers are expected to install additional equipment
to comply with PSES-1 (tar removal, flow equalization and ammonia distillation) and, therefore,
there will be no additional energy requirements. Additional energy requirements for PSES-2, 0.3
million kWh/yr, are based on four facilities adding cyanide precipitation and multimedia filtration.
For PSES-3, EPA estimated additional energy requirements totaling 12 million kWh/yr based on
five facilities installing indirect cooling, flow equalization, and biological treatment. EPA
estimated additional energy requirements for PSES-4, 17 million kWh/yr for five facilities
installing indirect cooling, flow equalization, biological treatment, and alkaline chlorination, plus
three facilities installing alkaline chlorination only.
                                                                               i
              Neither of the two non-recovery cokemaking facilities generate wastewater and,
therefore, EPA estimates there will be no additional energy requirements for that segment.
13.1.2
Ironmaking Subcategory
              There are 13 direct dischargers in this subcategory.  EPA estimates that the
additional energy requirements shown in Table 13-2 for BAT-1 (high-rate recycle and blowdown
treatment) are the result of two new high-rate recycle systems. The treatment and recycle systems
include solids removal using scale pits, roughing clarifiers or multimedia filters, induced draft
cooling towers to lower the water temperature, and pump stations to return the treated and
cooled water to the ironmaking process. EPA estimates that the indirect discharging irohmaking
facilities will not need to add treatment units to upgrade to the model PSES-1 treatment system.
13.1.3
Integrated Steelmaking Subcategory
              This category includes 20 direct dischargers.  The Agency estimates that the
additional energy requirements shown in Table 13-2 are a result of one new high-rate continuous
caster recycle system and nine chemical precipitation systems for treatment of blowdown water.
The treatment and recycle systems include solids removal using a classifier and clarifier, induced
draft cooling towers for vacuum degassing and continuous casting wastewater, and pump stations
to return the treated and cooled water to the Steelmaking process.  Chemical precipitation systems
remove metals from the recycle system blowdown water and include reaction tanks with mixers,
clarifiers, thickeners, and filter presses. EPA estimates that direct dischargers in this subcategory
will use approximately 8 million kWh/yr of additional energy requirements to upgrade to the BAT
model system. EPA estimates that indirect discharging integrated Steelmaking facilities will not
need additional treatment units to upgrade to the model PSES-1 treatment system and, therefore,
no additional energy requirements are expected.
13.1.4
Integrated and Stand-Alone Hot Forming Subcategory
              This subcategory includes 44 direct dischargers and 10 indirect dischargers.  BAT-
1 for the integrated and stand-alone hot forming mills requires the greatest amount of additional
electrical energy of the proposed subcategories (see Table 13-2). EPA estimates that 169 million
kWh/yr of additional electricity will be required to comply with the BAT-1 model system, an
increase of 29 percent.  The Agency estimates that 12 sites would install high-rate recycle systems
                                          13-2
-------
                                                Section 13 - Non-Water Quality Environmental Impacts
 to replace existing partial or once-through treatment systems and two of these mills will install
 new recycle systems consisting of roughing clarifiers with oil removal, multimedia filtration,
 induced draft cooling towers, and pump stations to recycle the treated and cooled water to the
 steelmaking process. EPA estimates that an additional seven mills will install new multimedia
 filters for removal of suspended solids from recycle system blowdown water. A number of mills
 will recycle in excess of a total of 20,000 gallons per minute (gpm) of wastewater, in the
 Agency's estimate.

              For PSES-1, EPA expects two carbon manufacturing facilities to install a
 multimedia filter and another stainless steel manufacturing facility to install a cooling water
 recycle system consisting of a roughing clarifier, multimedia filter, cooling tower, and pump
 station. -As shown in Table 13-2, EPA estimated that indirect dischargers will require an
 additional 1 million kWh/yr of additional electricity to comply with this model option.
 13.1.5
Non-Integrated Steelmaking and Hot Forming Subcategory
              This subcategory has 43 direct dischargers, 19 indirect dischargers, and 34 zero
dischargers. The additional 8 million kilowatt-hours of energy that EPA estimates is required for
BAT-1 (see Table  13-2) for the non-integrated steelmaking and hot forming operations are
primarily due to the addition of multimedia filters to remove suspended solids from cooling water
recycle system blowdown. EPA estimates that 13 carbon and stainless steel sites will install
multimedia filtration systems as a result of the regulation. The Agency also estimates that two
sites manufacturing carbon steel products will install new high-rate recycle systems as well as
multimedia filters for blowdown treatment to meet BAT-1 requirements.

              EPA estimated no additional energy requirements for sites to comply with
pretreatment standards for the two indirect discharging non-integrated steelmaking and hot
forming sites manufacturing stainless steel.                                     .
13.1.6
Steel Finishing Subcategory
              This subcategory has 69 direct dischargers, 45 indirect dischargers, and 27 zero
dischargers. EPA estimates that one carbon finishing facility will consume approximately 2
million kWh/yr of additional energy (see Table 13-2) to reduce its recycle system blowdown to
meet the proposed production-normalized flow rates (PNF). EPA expects the proposed
pretreatment standards (PSES-1) for the steel finishing subcategory to increase energy
requirements by approximately 0.1 million kilowatt-hours per year.
13.1.7
Other Operations Subcategory
              The Other Operations Subcategory includes two direct reduced ironrnaking (DRI)
facilities, 14 forging facilities, and 4 briquetting facilities.  EPA estimates that additional power
would be required for one DRI facility under BPT. All forging operations currently have the BPT
in place and, therefore, no additional energy is required. The briquetting facilities do not
                                          13-3
-------
                                              Section 13 - Non-Water Quality Environmental Impacts
discharge process wastewater, and EPA does not expect facilities in this segment to install
additional treatment equipment.                                                  [
13.1.8
Energy Requirements Summary
                                                                              &
             Based on information provided in the industry surveys, the iron and steel industry
currently consumes approximately 3.2 billion kWh/yr of electricity for wastewater treatment. •
EPA estimates that compliance with the proposed Iron and Steel regulation will result in a net
increase in energy consumption of 231 million kWh/yr of electricity for the entire industry, or
approximately 7 percent. As described previously, the projected increase in energy consumption
is primarily due to the incorporation of components such as pumps, mixers, blowers, and fans.

             In 1997, the United States consumed approximately 3,122 billion kilowatt hours of
electricity (Reference 13-2). The 231-million-kWh/yr increase in electricity as a result of the
proposed regulation corresponds to approximately 0.007 percent of the national requirements.
The increase in energy requirements due to the implementation of the proposed rule will in turn
increase air emissions from the electric power generation facilities.  The increase in air emissions
is expected to be proportional to the increase in energy requirements, or approximately 0.007
percent.
13.2
Air Emission Impacts
             Various subcategories within the iron and steel industry generate proces? waters
that contain significant concentrations of organic and inorganic compounds, some of which are
listed as Hazardous Air Pollutants (HAPs) in Title III of the Clean Air Act Amendments of 1990.
The Agency developed National Emission Standards for Hazardous Air Pollutants (NESHAPs)
under Section 112 of the Clean Air Act, which addresses air emissions of HAPs for certain
manufacturing operations. .Subcategories within the iron and steel industry where NESHAPs are
applicable include cokemaking (58 FR 57898, October 1993) and steel finishing with chromium
electroplating (60 FR 4948, January 1995).

             For the Cokemaking Subcategory, EPA is currently developing maximum
achievable control technology (MACT) standards for pushing, quenching, and battery stacks
operations. Like effluent limitations guidelines and standards, MACT standards are technology-
based.  The Clean Air Act sets maximum control requirements on which MACT standards can be
based for new and existing sources.  By-products recovery operations in the Cokemaking
Subcategory remove the majority of HAPs through processes that collect or produce tar, heavy
and light oils, ammonium sulfate, anhydrous ammonia, and elemental sulfur. Ammonia, hydrogen
sulfide, and hydrogen cyanide removal by steam stripping could generate a potential air quality
issue if uncontrolled; however, these stripping operations at cokemaking facilities capture vapors
and return them to the coke oven gas, which is combusted to heat the coke ovens and for other
uses.                     '                                                   :

             Biological treatment of cokemaking wastewater can potentially emit HAPs if •
significant concentrations of volatile organic compounds (VOCs) are present.  To estimate the
                                          13-4
-------
                                               Section 13 - Non-Water Quality Environmental Impacts
 maximum air emissions from biological treatment, EPA multiplied the individual concentrations of
 all VOCs in cokemaking wastewater entering the biological treatment system by the maximum
 design flow (2.52 million gallons per day) and the maximum operational period (365 .days/year)
 reported in the industry surveys to determine annual VOC loadings to the biological treatment
 unit. The Agency determined the concentrations of the individual VOCs entering the biological
 treatment system from the EPA sampling data. .Table 13-3 shows the average .influent
 concentration of the individual VOCs and the annual pollutant loadings based on a biological
 treatment system influent flow of 1,750 gallons per minute. Even with the conservative
 assumption that all the VOCs entering the biological treatment system are emitted to the
 atmosphere (no biological degradation), the maximum VOC emission rate would be  .
 approximately 1,800 pounds or 0,9 tons per year. This is well below threshold levels that would
 classify the site as a major source of VOCs (i.e., 25 tons for the combination of all HAPs, or 10
 tons for any individual HAP).

              For integrated and non-integrated steelmaking operations, the only organic
 pollutant of concern (POC) detected in untreated basic oxygen furnace (EOF) wastewater from
 stainless steel product manufacturing was phenol. Phenol was detected at relatively low
 concentrations (0.012 mg/L to 0.33 mg/L). Because phenol is a semivolatile organic compound
 with a low Henry's Law constant, it is not expected to partition to the air. No volatile pollutants
 of concern were detected in any of the steelmaking  wastewater. The other primary pollutants in
 the steelmaking process wastewater are suspended solids, dissolved metals, and oils. Under
 ambient conditions, these pollutants show insignificant volatilization because of their vapor
 pressure, even in open-top treatment traits.

             Wet air pollution control (WAPC) equipment is commonly used in a number of the
 iron and steel subcategories to control air emissions. None of the proposed pollution prevention,
 recycling, or wastewater technology options will have a negative impact on the performance of
 these WAPC systems. In fact, some of the proposed pollution prevention alternatives may
 enhance the performance of these systems by reducing pollutant loadings. Therefore, EPA does
 not expect any adverse air impacts to occur as a result of the proposed regulation.
13.3
Solid Waste Impacts
             A number of the proposed treatment technologies will generate solid waste,
including Resource Conservation and Recovery Act (RCRA) hazardous and nonhazardous sludge
and waste oil. Most solid waste generated by the iron and steel industry is nonhazardous, except
for certain treatment sludges generated by electroplating operations in the steel finishing industry
and iron-cyanide sludge generated during treatment of cokemaking wastewater,  Nonhazardous
solid wastes include sludge from biological treatment systems for cokemaking wastewater and
sludge from multimedia filtration, chemical precipitation, and clarification systems from iron and
steelmaking wastewater. Federal and state regulations require iron and steel facilities to manage
their RCRA hazardous and nonhazardous sludges to prevent releases to the environment.

             The following subsections provide both current sludge generation rates estimated
from the industry surveys and the incremental increases expected as a result of the proposed
                                       .   13-5
-------
                                              Section 13 - Non-Water Quality Environmental Impacts
regulation for each iron and steel subcategory. Incremental increases in sludge generation are
based on the pollutant loading and removal information provided in Section 10.  Based on the
information summarized in Table 13-1, EPA estimates that annual sludge generation across the
entire iron and steel industry will increase by 0.5 percent as a result, of the proposed regulation.
13.3.1
Cokemaking Subcategory
              Biological nitrification, proposed as the primary technology basis for ammonia,
phenolics, and biochemical oxygen demand (BOD) removal from cokemaking wastewater,
combined with technologies such as cyanide precipitation and multimedia filtration, will produce a
wastewater treatment sludge requiring disposal or further processing.  Table 13-4 shows
additional sludge generation for the entire cokemaking industry by technology option.

              EPA estimates that compliance with BAT-1 and BAT-3 will generate
approximately 130 tons (dry) per year of additional biological treatment sludge.  BAT-3 adds
alkaline chlorination following biological treatment to remove residual cyanide and ammonia to
BAT-1; however, alkaline chlorination is not expected to generate significant amounts of
additional sludge. Based on the industry survey data, EPA estimates that the cokemaking
industry currently generates more than 23,000 tons per year (dry) of biological treatment sludge.
As such, the increased biological treatment sludge generated by the BAT-1 and BAT-3 treatment
options is approximately 0.6 percent of the total sludge currently generated by the industry.

              Sludge generation calculated for BAT-2 is a result of both biological treatment for
ammonia, phenolics, and BOD removal and chemical precipitation to remove cyanide. Based on
the pollutant loading and removal data presented in Section 10, EPA estimates that compliance
with BAT-2 will generate an additional 12 tons per year (dry) of iron-cyanide sludge, in, addition
to the 130 tons per year (dry) of biological treatment sludge. Based on the industry survey data,
EPA estimates that the cokemaking industry currently generates approximately 460 tons per year
(dry) of iron-cyanide sludge. Compliance with BAT-2 will increase iron-cyanide sludge
production throughout the cokemaking industry by 3 percent. The nonhazardous biological
treatment sludge can be disposed of in a Subtitle D landfill, recycled to the coke  ovens for
incineration, or land applied. Depending on RCRA hazardous characterization results (40 CFR
262.11), iron-cyanide sludge collected from the cyanide precipitation process may be disposed of
in a Subtitle C or Subtitle D landfill.
    s                                          -                               ;
              BAT-4 generates the largest amount of sludge, 370 tons per year (dry), due to the
removal and treatment of total suspended solids (TSS) by the multimedia filters following
biological treatment and alkaline chlorination.                                      ;

              EPA does not expect any of the eight indirect dischargers to install additional
equipment to comply with PSES-1  (tar removal, flow equalization and ammonia distillation) and,
therefore, no additional sludge is expected. EPA estimates that four facilities will add cyanide
precipitation and multimedia filtration to comply with PSES-2 generating approximately 100 tons
per year (dry) of additional sludges. The Agency expects approximately 2,990 additional tons of
                                          13-6
-------
                                               Section 13 - Non-Water Quality Environmental Impacts
 sludge per year (dry) to be generated, based on five facilities installing new biological treatment
 systems to comply with PSES-3 and PSES-4.

              Neither of the two non-recovery cokemaking facilities generate wastewater and,
 therefore, are not expected to generate additional sludge.

              Table 13-1 shows that the selected options (BAT-3 and PSES-3) would increase
 biological sludge generation by approximately 3,100 tons per year. Information provided in the
 industry survey shows that 65 percent of all biological sludge is sent to the coke batteries for
 incineration, while 15 percent is land applied and 20 percent is landfilled.
 13.3.2
Ironmaking Subcategory
              Additional wastewater treatment sludge will be generated by the blast furnace
 ironmaking and sintering operations as a result of compliance with both BAT-1 and PSES-1.
 BAT-1, which includes solids removal in the high-rate recycle system, as well as chemical
 precipitation, settling, and multimedia filtration for treatment of blowdown water, will generate
 approximately 4,430 additional tons/year (dry) of wastewater treatment sludge, as shown in Table
 13-4. PSES-1, which includes the same solids-generating treatment units as BAT-1, with the
 exception of multimedia filtration following chemical precipitation and settling of high-rate recycle
 blowdown, is expected to generate an additional 230 tons per year (dry) of wastewater treatment
 sludge.

              The data provided in Table  13-1 shows that blast furnace ironmaking and sintering
 operations generated approximately 86,000 tons (dry) of mill scale, grit, and sludge in 1997.  The
 proposed BAT-1 and PSES-1 options  for blast furnace ironmaking and sintering would increase
 annual sludge generation by 4,700 tons/year, an increase of approximately 5 percent. Information
 provided in the industry surveys shows that 36 percent of the mill scale and sludges generated by
 the Ironmaking Subcategory is disposed of by landfilling.  The remainder is recycled to sinter or
 briquetting, or sent off site to a.commercial recycler.
13.3.3
Integrated Steelmakiiig Subcategory
              To comply with the proposed BAT-1 effluent limits, EPA estimates that one direct
discharger will install a new continuous caster recycle water system and nine facilities will install
chemical precipitation to treat blowdown water, resulting in additional 3,560 tons/year (dry) of
wastewater treatment sludge (Table 13-4).  Indirect discharging integrated steelmaking facilities
have the model equipment in place and, therefore, EPA does not expect them to generate
additional sludge. As shown in Table 13-1, integrated steelmaking operations currently generate
approximately 940,000 tons/year of mill scale, sludges, and filter cakes. The additional generation
of sludge represents a 0.4 percent increase.
                                          13-7
-------
                                              Section 13 - Non-Water Quality Environmental Impacts
13.3.4       Integrated Steelmaking and Stand-Alone Hot Forming Subcategory

             To comply with the proposed BAT-1 effluent limits, the Agency estimates mat 12
sites will install high-rate recycle systems to replace existing partial or once-through treatment
systems. EPA estimates that two of these mills will install new recycle systems consisting of
roughing clarifiers and multimedia filters that will generate sludges. EPA also estimates that
another seven facilities manufacturing carbon steel products will install multimedia filtration
systems to remove suspended solids and metals from recycle system blowdown water. Treatment
of multimedia filter backwash water will produce an additional 12,500 tons/year of wastewater
treatment sludge (Table 13-4). EPA estimates that, to comply with PSES-1, a carbon steel
manufacturing facility will install a new multimedia filter. A stainless steel manufacturing facility
will install a roughing clarifier and multimedia filter, generating an additional 930 tons pier year of
sludge.

             Incremental sludge production (Table 13-1) is estimated to be 12,500 tons per year
or a 5 percent increase over the current mill scale, sludge, and filter cake production amounts
generated by this subcategory.
13.3.5
Non-Integrated and Stand-Alone Hot Forming Subcategory
              EPA estimates that 13 carbon and stainless steel sites will install multimedia
filtration systems as a result of the regulation. The Agency also estimates that two non-jintegrated
steelmakmg and hot forming facilities manufacturing carbon products will install new high-rate
recycle systems as well as multimedia filters for blowdown treatment to meet BAT-1   ;
requirements.  These solids removal systems are expected to. generate an additional 1,300
tons/year of dry wastewater treatment sludge, as shown in Table 13-4.               • J

              EPA is proposing to revise PSES-1 for non-integrated and stand-alone hot forming
operations manufacturing stainless steel products.  EPA estimates that an additional 70 jtons per
year of treatment sludge will be generated by three non-integrated and stand-alone hot forming
operations manufacturing stainless steel products, based on the pollutant loading and removal data
presented in Section, 10.  Additional sludge generation is a result of improved treatment
performance for existing treatment systems.                                       \

              Treatment sludges from BAT-1 and PSES-1 will increase solid waste production
by approximately 0.05 percent over the current 2,537,000 tons per year (see Table 13-1).
13.3.6
Steel Finishing Subcategory
              Both RCPvA hazardous and nonhazardous sludges are generated at steel finishing
facilities. RCRA sludge may be classified as hazardous as a result of listing or characterization
based on the following information:                                     .         j  '

                     If the site performs electroplating operations, the sludge resulting from
                     treatment of this wastewater is a RCRA F006 listed hazardous waste (40
                                         • 13-8
-------
                                                Section 13 - Non-Water Quality Environmental Impacts
                     CFR260.11).  If wastewater from other operations is mixed with the
                     electroplating wastewater and treated, all sludges generated from the
                     treatment of the combined wastewater are also RCRA F006 listed
                     hazardous wastes.               .

              •      Sludge generated from the treatment of wastewater associated with tin
                     plating on carbon steel and zinc plating on carbon steel is not a RCRA
                     listed hazardous waste.

              •      If the sludge from wastewater treatment exceeds the standards for the
                     Toxicity Characteristic Leaching Procedure (i.e., is hazardous), or exhibits
                     other RCRA-defined hazardous characteristics (i.e., reactive, corrosive, or
                     flammable), it is considered a characteristic hazardous waste (40 CFR
                     261.24).                                            -

              Based on information collected during site visits and sampling episodes to iron and
steel operations, the Agency believes that the majority of sludge generated at steel finishing sites
would not be classified as hazardous.  Information provided in the industry surveys indicates that
less than 5 percent of the total sludges and solid waste generated by finishing facilities is
hazardous under RCRA.

            .  For carbon and alloy and stainless steel finishing sites, BAT-1 consists of in-
process controls to limit water usage and recycle process chemicals, plus end-of-pipe wastewater
treatment. Wastewater treatment includes oil removal, chromium reduction when necessary,
multiple-stage pH control for metals precipitation, and solids removal by gravity clarification.
EPA estimates that the 69 direct discharging steel finishing facilities (both carbon and alloy and
stainless steel) will improve the performance of their metals removal systems, resulting in
approximately 2,200 tons per year (dry) of additional treatment sludge (Table 13-4).  For PSES-
1, EPA estimates that an additional 77 tons per year of wastewater treatment sludge will be
generated as a result of six steel finishing facilities installing chemical precipitation and/or
clarification systems.

              EPA estimates steel finishing facilities currently generate over 690,000 tons per
year (dry) of sludge.  The proposed BAT-1 option for steel finishing would increase annual sludge
generation by approximately 0.3 percent.
13.3.7
Other Operations Subcategory
              Other operations include DRI, forging, and briquetting processes. Based on the
current equipment in place at DRI and forging facilities, EPA believes that one DRI facility
complying with BPT will generate additional sludge; however, the amount of sludge generated
cannot be disclosed because it contains confidential business information.
                                          13-9
-------
                                              Section 13 - Non-Water Quality Environmental Impacts
13.4

13-1.

13-2.
References

Perry's Chemical Engineers Handbook. Sixth Edition. McGraw Hill Press, 1984.

Energy Information Administration. Electric Power Annual 1998 Volume I,
Table Al.
                                         13-10
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                                             13-12
-------
                                               Section 13 - Non-Water Quality Environmental Impacts
                                      Table 13-3

    Estimated Maximum VOC Emission Rate From Biological Treatment of
                              Gokemaking Wastewater
Compound
Benzene
Acetone
Aciylonitrile
Carbon disulfide
1,1,2,2-TCA
Influent Concentration
(mg/L)a
nd
nd
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nd
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Flow Rate
(gpm)b
nd
nd
nd
nd
nd
Estimated
Emission Rate
(lbs/yr)
nd
nd •
nd
nd
nd
Total 1,808
aU.S. EPA Iron and Steel Industry Wastewater Sampling Program, 1997-1999.
bU.S. EPA, U.S. EPA Collection of 1997 Iron and Steel Industry Data (Detailed and Short Surveys).
nd - Not disclosed to prevent compromising confidential business information.
                                         13-13
-------
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                                                                 Section 14 - Selected Options
                                     SECTION 14

       SELECTED OPTIONS AND PROPOSED EFFLUENT LIMITATIONS AND
                                     STANDARDS

              As discussed in Section 2, EPA must promulgate six types of effluent limitations
 guidelines and standards for each major industrial category, as appropriate:

                    Best Practicable Control Technology Currently Available (BPT);
            .  •      Best Control Technology for Conventional Pollutants (BCT);
              •      Best Available Technology Economically Achievable (BAT);
              •      New Source Performance Standards (NSPS);
              •      Pretreatment Standards for Existing Sources (PSES); and
              •      Pretreatment Standards for New Sources (PSNS).

              BPT, BCT, BAT and NSPS limitations regulate only those sources that discharge
 effluent directly into waters of the United States. PSES and PSNS limitations restrict pollutant
 discharges for those sources that discharge effluent indirectly through sewers flowing to publicly
 owned treatment works (POTWs). Sections 14.1 and 14.2 discuss BPT and BCT effluent
 limitations guidelines, respectively. Section 14.3 discusses BAT, NSPS, PSES, and PSNS
 technology bases and effluent limitations guidelines and standards.
14.1
BPT
             As discussed in Section 2, BPT generally represents the average of the best
performances of facilities within the industry, grouped to reflect various ages, sizes, processes, or
other common characteristics. BPT focuses on end-of-pipe treatment rather than process changes
or internal controls, except when the process changes or internal controls are common industry
practice.  EPA is required under Section 304(b) of the Clean Water Act (CWA) to perform a
limited cost-benefit balance when setting BPT limitations to ensure that costs are not wholly out
of proportion to the effluent reduction benefits achieved; the Agency is not required to quantify
benefits in monetary terms.  See Weyerhaueser Company v. Costle. 590 F.2d 1011 (D.C. Cir.
1978).  When balancing BPT costs with effluent reduction benefits, EPA considers the volume
and nature of existing wastewater discharges, the volume and nature of discharges expected after
the application of BPT, the general environmental effects of pollutants discharged, and the cost
and economic impact of required pollution control.
14.1.1
Manufacturing Operations New to the Iron and Steel Category
             EPA is proposing BPT limitations for non-recovery cokemaking, sintering
operations with dry air pollution controls, direct reduced ironmaking, briquetting, and forging
operations because there are no BPT limitations in the 1982 Iron and Steel regulation applicable
to these operations.
                                         14-1
-------
                                                                 Section 14 -Selected Options
             The Agency is proposing zero discharge of process wastewater pollutants to
waters of the United States as the BPT limitations for non-recovery cokemaking, sintering
operations with dry air pollution controls, and briquetting.                           !

             The proposed BPT limitations for the Direct Reduced Ironmaking Segment of the
Other Operations Subcategory are based on model treatment consisting of solids.removal,
clarification, high-rate recycle, and blowdown filtration. EPA set BPT limitations for to;tal
suspended solids (TSS); the Agency has determined that the controlling TSS will incidentally
remove all other pollutants of concern (POCs) considered for regulation in this subcategory,
including oil and grease (O&G). EPA estimates that application of the proposed BPT limitations
would result hi no facility closures. The following table presents the proposed BPT limitations.

                             Other Operations Subcategory
                BPT Limitations for Direct Reduced Ironmaking Segment
Pollutant
Total suspended solids (TSS)
BPT Limitations
(Ibs/ton of product)
Maximum Daily
0.0200
Maximum Monthly Average
0.00929
             The proposed BPT limitations for the Forging Segment of the Other Operations
Subcategory are based on high-rate recycle and oil/water separation. EPA estimates that
application of the proposed BPT limitations would result in a 72 percent reduction of O&G in
direct discharges from forging operations, with no facility closures. The following table; presents
the proposed BPT limitations.                                                   ;

                             Other Operations Subcategory
                         BPT Limitations for Forging Segment
Pollutant
Oil and grease (O&G)
Total suspended solids (TSS)
BPT Limitations
(Ibs/ton of product)
Maximum Daily
0.0149
0.0235
Maximum Monthly Average
0.00889
0.0118
14.1.2
Manufacturing Operations Currently Regulated
             For manufacturing operations currently subject to BPT limitations in the ^1982 rule,
the Agency is not proposing to revise BPT limitations for TSS and O&G. Table 14-1 presents
these BPT limitations. For electric arc furnace (EAF) operations, the 1982 Steelmaking; .
Subcategory requires zero discharge for BPT in the semi-wet operations but allows discharge for
BPT in the wet operations. Since wet EAFs no longer exist in the United States, the proposed
                                          14-2
-------
                                                                 Section 14 - Selected Options
.rule is requiring zero discharge for all EAFs. For continuous electroplating operations currently
 subject to BPT limitations under 40 CFR Part 433 but proposed for regulation under the revised
 iron and steel rule, EPA has assigned BPT limitations for TSS and O&G based on the limitations
 at Part .433 for those operations.

              EPA recognizes the difficulty in implementing the proposed regulation if BPT
 limitations remain unchanged and reflect a different subcategorization: permit writers and industry
 representatives would be required to implement the existing 40 CFR Part 433 BPT limitations for
 electroplating and the 1982 iron and steel BPT limitations for 12 subcategories and more than 50
 segments, in addition to the proposed BAT limitations for 7 subcategories and far fewer
 segments. Consequently, EPA developed the following alternative approach for codifying BPT
 limits. EPA solicits comment on this alternative approach.

              Alternative Approach: Codify BPT Limitations as the TSS and O&G
              Concentrations Used to Develop the 1982 Iron and Steel Rule

              To simplify the Iron and Steel regulation and ease the implementation of BPT
limitations in the National Pollutant Discharge Elimination System (NPDES) permit program,
EPA is considering replacing the 1982 mass-based BPT limitations for TSS and O&G with
corresponding concentration-based limitations. The concentration-based BPT limitations would
equal the treated effluent concentrations used to develop the 1982 regulation for all operations
that EPA proposes to regulate under the Iron and Steel rale. These concentrations  are shown as
the daily maximum and maximum monthly average TSS and O&G concentrations (mg/L) for the
 12 subcategories of the  1982 regulation (Reference 14-1). For electroplating operations currently
regulated under Part 433, EPA would set the corresponding BPT concentration limitations equal
to either the concentrations at Part 433 or the concentrations for steel finishing operations in the
1982 regulation (Reference 14-1).

              Under this alternative approach, the TSS and O&G concentrations from the 1982
regulation would be codified as BPT limitations hi the seven subcategories of the proposed
regulation to. simplify the regulation and ease implementation. Permit writers and industry
representatives would not have to then classify operations under both the complicated
subcategorization and segmentation of the 1982 regulation and the less complicated
subcategorization and segmentation of the proposed regulation.

              Under this alternative approach, permit writers would develop NPDES permit
effluent limitations by first applying the  corresponding BAT limitations for priority and
nonconventional pollutants for each internal  or external process wastewater outfall. Then, the
permit writer would develop mass effluent limitations for TSS and O&G by applying the
respective concentration-based  BPT effluent limitations guidelines to a reasonable measure of
actual process wastewater discharge flow, taking into account process wastewater regulated by
the Iron and Steel rule and process wastewater that may be unregulated by the Iron  and Steel rule
(see proposed regulation at 40 CFR Part 420.03(f». As with BAT limitations, the Agency'
intends that only the mass limitations derived for TSS and O&G as described above should be
included in NPDES permits.
                                         14-3
-------
                                                                  Section 14 - Selected Options
              Depending upon site-specific circumstances, this alternative approach could result
 in either more or less stringent limitations for TSS and O&G than would be derived from the 1982
 BPT limitations. For example, if a facility has (1) process wastewater discharge flow rates, that
 are lower than the model BPT production-normalized flow rates used to develop the 1982
 regulation and (2) no unregulated process wastewater, the resulting TSS and O&G permit
 limitations would be more stringent hi proportion to the lower discharge flow. On the o|her hand,
 if the facility had higher process wastewater discharge flow rates or a substantial volume! of
 unregulated process wastewater, the resulting effluent limitations would be higher in proportion
.to the higher discharge flow. The Agency has determined.that, in many instances, the volume of
 regulated process wastewater that is either currently discharged or will be discharged to fcomply
 with BAT limitations will be somewhat less than model BPT flow rates. Consequently, EPA
 expects that the resulting NPDES permit effluent limitations for TSS and O&G will be somewhat
 more stringent but still within the range of those derived from the current BPT limitations.
                                                                               r
              The Agency has determined that there would be no additional costs to comply with
 NPDES permit effluent limitations derived with this alternative approach. To calculate the costs
 to achieve BPT limitations,  EPA considered both the incremental investment costs and  i
 incremental operation and maintenance costs to achieve BAT limitations, where appropriate.
 EPA would not expect facilities to incur additional monitoring costs associated with    \
 concentration-based BPT limitations because facilities already monitor for these pollutants under
 the 1982 regulation; EPA does not propose to establish any new monitoring requirements for
 conventional pollutants. Nonetheless, for the purpose of calculating the cost per pound of
 conventional pollutants removed, EPA estimated both the costs associated with implementing
 BPT technologies (even though they are already subsumed in the BAT costs) and the total pounds
 of pollutants removed by these technologies. The estimated costs and removals reflect only the
 subcategories and segments for which EPA is considering revising BPT limitations.  The total
 estimated cost is $53.8 million (1997 pretax total annualized cost1) for a total estimated removal
 of 30.3 million pounds of conventional pollutants. EPA determined that the total cost is;
 reasonable in relation to the effluent reduction benefits.  If EPA were to adopt this alternative
 approach, the Agency would revise BCT limitations to reflect the new BPT levels because
 nothing more stringent than those levels appears  to pass the BCT cost-reasonableness test. (See
 Section 14.2 for more information on BCT limitations).
 14.2
BCT
              As discussed in Section 2, the BCT methodology promulgated in 1986 (51 FR
 24974) sets forth the Agency's consideration of costs in establishing BCT effluent limitations
 guidelines. BCT is not an additional set of limitations; it replaces BAT for the control of
 conventional pollutants. EPA evaluates the reasonableness of BCT candidate technologies (those
 that are technologically feasible) by applying a two-part cost reasonableness test:       |
 'EPA annualized the costs presented in Section 9 for presentation in this section (Reference 14-2).
                                          14-4
-------
                                                                  Section 14 - Selected Options
               •      POTW test: EPA calculates the cost per pound of conventional pollutant
                     removed by industrial dischargers in upgrading from BPT to a BCT
                     candidate technology, and then compares this cost to the cost per pound of
                     conventional pollutant removed in upgrading POTWs from secondary
                     treatment. The upgrade cost to industry must be less than the POTW
                     benchmark of $0.25 per pound (in 1976 dollars).

               •    ,  Industry cost-effectiveness test:  The ratio of the incremental BPT to BCT
                     cost divided by the BPT cost for the industry must be less than 1.29 (i.e.,
                     the cost increase must be less than 29 percent).

 EPA may propose BCT limitations only if a candidate BCT technology passes both parts of the
 cost-reasonableness test.                                               -

              In developing BCT limitations for the Iron and Steel Category, EPA considered
 whether any existing technologies achieve greater removals of conventional pollutants than the
 technologies that form the basis for BPT and whether those technologies are cost-reasonable
 according to the prescribed BCT cost test. The Agency identified no existing technologies that
 (1) achieve greater removals of conventional pollutants than the technologies that form the basis
 for BPT and (2) pass the BCT cost-reasonableness test.  Accordingly, EPA proposes to establish
 BCT effluent limitations that are equal to BPT limitations in the 1982 Iron and Steel rule.  For
 non-recovery cokemaking, sintering operations with dry air pollution controls, direct reduced
 ironmaking, briquetting, and forging operations, EPA proposes to establish BCT effluent
 limitations that are equal to the BPT limitations the Agency is proposing for these operations.
 (See Section 14.1 for more information on BPT limitations.)                  .
 14.3
BAT. NSPS. PSES. and PSNS
              Sections 14.3.1 through 14.3.7 discuss the selected technology options and
"corresponding mass-based effluent limitations guidelines and standards for each iron and steel
 subcategory,  EPA developed these proposed effluent limitations guidelines and standards using
 production-normalized flow rates and long-term effluent data corresponding to selected
 technology options. For more information on the evaluation of production-normalized flow rate
 and long-term average data, refej to Sections 7 and 12.  The overall technology bases for the
 development of BAT, NSPS, PSES, and PSNS are discussed below.

              BAT

              As discussed in Section 2, BAT represents the best economically achievable
 performance of facilities in an industrial category. BAT may include process changes or internal
 controls, even when they are not common industry practice. The statutory assessment of BAT
 considers costs but does not require a balance of costs with effluent reduction benefits.  See
 Weyerhauser Company v. Costle. 590 F.2d 1011 (D.C. Cir.  1978). EPA has, however, given
 substantial weight to the reasonableness of costs in developing BAT limitations. The Agency
 considered the volume and nature of existing wastewater discharges, the volume and nature of
                                          14-5
-------
                                                                 Section 14 - Selected Options
discharges expected after the application of BAT, the general environmental effects of pollutants
discharged, and the cost and economic impact of required pollution control.  Despite this
expanded consideration of costs, the primary determinant of BAT is effluent reduction capability.
Under the CWA, the achievement of BAT has become the principal national means of controlling
toxic water pollution.                                                          I

             EPA has determined that the selected BAT model technologies (discussed in
Section 8) are technically feasible and economically achievable (Reference 14-2) for the -respective
segments to which they apply. EPA has determined, for the reasons described in Section 13, that
none of the proposed technology options presents unacceptable adverse non-water quality
environmental impacts. EPA considered age, size, processes, and other engineering factors
pertinent to facilities in the proposed segments when evaluating technology options. None of
these factors provided a basis for selecting different technologies than those EPA proposes as its
model BAT technologies.                                                      (

             NSPS
                                                                             !
             As discussed in Section 2, NSPS reflect effluent reductions that are achievable
based on the best available demonstrated control technology. EPA is required to consider the
best demonstrated process changes, in-plant controls, and end-of-pipe treatment technologies to
reduce pollution to the maximum extent feasible for NSPS. For the proposed Iron and Steel rale,
the Agency generally considered BAT model treatment systems to be the demonstrated NSPS
model treatment systems because most of the BATs are considered to represent the best
demonstrated technologies.                                                     >

             In selecting its proposed NSPS technologies, EPA considered all of the factors
specified in CWA Section 306, including the cost of achieving effluent reductions. The model
NSPS technologies that form the basis for the proposed standards are well demonstrated and used
within the iron and steel industry. Based on this demonstration, EPA has concluded that costs
associated with implementing NSPS do not present a barrier to entry. The Agency also
considered energy requirements and other non-water quality environmental impacts for the
proposed NSPS options and concluded that these impacts are acceptable and no greater than the
impacts expected from the proposed BAT technology options. EPA, therefore, concluded that
the proposed NSPS constitute the best available demonstrated control technology.

             PSES/PSNS

             As discussed in Section 2,  PSES and PSNS are designed to prevent the discharge
of pollutants that pass through, interfere with, or are otherwise incompatible with the operation of
POTWs. EPA has determined that several priority and nonconventional pollutants present in
untreated iron and steel industry process wastewater pass through POTWs and may limit POTW
sludge disposal alternatives of interfere with biological treatment at POTWs. (See Section 11 for
more information on the Agency's POTW pass-through analyses.) Accordingly, EPA is
proposing pretreatment standards for metals and other priority and noriconventional pollutants.
When developing pretreatment standards,  EPA considered the cost of achieving effluent
                                          14-6
-------
                                                                 Section 14 - Selected Options
 reductions, the age and size of equipment and facilities involved, the processes employed,
 potential process changes, the location of facilities, non-water quality environmental impacts
 (including energy requirements), and the engineering aspects of applying pretreatment
 technologies in relation to the POTWs. None of these factors provided a basis for selecting
 different technologies than those EPA proposes as its model PSES technologies.

              The Agency is proposing PSNS based on the same considerations made for PSES.
 EPA considered all of the factors specified in CWA Section 306, including the cost of achieving
 effluent reductions, when selecting its proposed PSNS technologies. The model PSNS
 technologies that form the basis for the proposed standards are well demonstrated and used within
 the iron and steel industry.  Based on this demonstration, EPA concluded that costs associated
 with" implementing PSNS do not present a barrier to entry.

 14.3.1         Cokemaking   .

              BAT-rBy-Product Recovery Segment

             EPA is proposing BAT-3 for the By-Product Recovery Segment of the
 Cokemaking Subcategory. The BAT-3 model treatment sequence consists of oil and tar removal,
 flow equalization prior to ammonia snipping, free and fixed ammonia stripping, indirect cooling,
flow equalization before biological treatment, biological treatment, sludge dewatering, and
alkaline chlorination.

             As discussed in Section 8, EPA evaluated four BAT options for the By-Product
Recovery Segment. The Agency determined that each option would result in the following
additional water usage reductions and pollutant removals:

             •  .    BAT-1 would reduce current annual water usage by 1.6 million gallons and
                    increase the current removal of priority and nonconventional pollutants by
                    14 percent;

             •      BAT-2 would achieve the same flow reduction as BAT-1, but BAT-2
                    includes cyanide precipitation treatment that would increase the cyanide
                    removal achieved through BAT-1 by 17 percent;

             «      BAT-3 would achieve the same flow reduction as BAT-1, but BAT-3
                    includes alkaline chlorination treatment that would increase the cyanide
                    removal achieved through BAT-1 by 50 percent; and

             •      BAT-4 would achieve the same flow reduction as BAT-1 and pollutant
                    removals that are nearly equivalent to those achieved through BAT-3.
                                         14-7
-------
                                                                     Section 14 - Selected Options
              The Agency determined that each BAT option would result in the following
additional annual pollutant removals (in toxic pound equivalents2) and associated compliance
costs (in 1997 dollars):,                      .                                      !
                                                                                  ii
                     BAT-1 would remove 56,300 toxic pound equivalents per year at an
                     annualized compliance cost of $0.9 million. EPA estimates that BAT-1
                     would cause no facility closures.                ,               \

              •      BAT-2 would increase the pollutant removal achieved through BAT-1 by
                     26 percent and increase the annualized compliance cost by $3.3 million.
                     EPA estimates that BAT-2 would cause no facility closures.     |

              •      BAT-3 would remove 0.43 million toxic pound equivalents per year at an
                     annualized compliance cost of $8.6 million. EPA estimates that BAT-3
                     would cause one facility closure.                               [

              •      BAT-4 would achieve pollutant removals that are nearly equivalent to
                     those' achieved through BAT-3 at an annualized compliance cost ;of $ 15.2
                     million.  EPA estimates that BAT-4 would cause one facility closure.

              EPA determined that, all four BAT options are economically achievable (Reference
14-2).  The Agency did not select BAT-1 or BAT-2 because BAT-3 would achieve higher
pollutant removals at an economically achievable cost.  EPA did not select BAT-4 because BAT-
3 achieves nearly equivalent pollutant removals at a significantly lower cost.  The Agency
determined that BAT-3 is the best available technology economically achievable for the By-
Product Recovery Segment of the Cokemaking Subcategory. The following table presents
proposed BAT limitations.
2EPA converted the pollutant loads presented in Section 10 into toxic equivalents for the regulatory options presented in

an assigned toxic weighting factor to obtain the "pound equivalent" pollutant removals. The assigned toxic jweighting
factor for each pollutant is based on the pollutant's relative toxicity to copper. The toxic weighting factors assigned to
each pollutant of concern can be found in the Iron and Steel Administrative Record and the Economic Analysis of the
Proposed Effluent Limitations Guidelines and Standards for the Iron and Steel Manufacturing Point Source Category
(Reference 14-2).                                                                    ;
                                            14-8
-------
                                                                  Section 14 - Selected Options
                                Cokemaking Subcategory
                    BAT Limitations for By-Product Recovery Segment
Pollutant
Ammonia as nitrogen
Benzo-a-pyrene
Cyanide
Mercury
Naphthalene
Phenol
Selenium
Thiocyanate
Total residual chlorine3
BAT Limitations
(Ibs/ton of product)
Maximum Daily
0.00137
0.0000909
0.0104
0.000000864
0.000103
0.0000332
0.000185
0.00164
0.000659
Maximum Monthly Average
0.000618
0.0000304
0.00394
0.000000523
0.0000345
0.0000187
.0.000159
0.00115
—
         'Applicable only when chlorination is practiced.

             EPA is proposing the following additional allowances for pollutant loadings based
on the production-normalized flow for the treatment systems:

             •      Increased loadings, not to exceed 9.5 percent of the above limitations, for
                    process wastewater from wet desulfurization systems if such systems
                    generate process wastewater;

             •      Increased loadings, not to exceed 6.3 percent of the above limitations, for
                    process wastewater from control measures necessary for compliance with
                    by-product recovery coke plant National Emission Standards for
                    Hazardous Air Pollutants (NESHAPs) if such systems generate process
                    wastewater; and                               ,     .

             «      Increased loadings for process wastewater from other wet air pollution
                    control systems (WAPCs) (not including coal charging and coke pushing
                    emission controls), coal tar processing operations, and coke plant ground-
                    water remediation systems if such systems generate process wastewater
                    that is co-treated with by-product recovery cokemaking process
    *  .              wastewater.

See Section 7 for more information on the Agency's determination of these additional allowances
for pollutant loadings.
                                          14-9
-------
                                                                 Section 14'- Selected Options
             NSPS~By-Product Recovery Segment                            t

             The treatment technologies that form the basis for NSPS for the By-Product
Recovery Segment of the Cokemaking Subcategory are the same as the BAT-3 model
technologies. EPA has determined that BAT-3 is the best demonstrated technology for pew
sources in the By-Product Recovery Segment; therefore, the Agency has set proposed NSPS
limitations for the By-Product Segment equal to BAT-3 limitations (see previous table for BAT
limitations). To ensure that the regulations for new sources represent the most stringent
numerical values attainable through the application of the best available control technology for all
pollutants, EPA is proposing NSPS limitations for two pollutants not regulated under BAT for
the By-Product Recovery Segment: TSS and O&G. The following table presents these Additional
limitations.                                     .                              \

                Cokemaking Subcategory-By-Product Recovery Segment
                         NSPS Limitations for TSS and O&Ga                !
Pollutant
Oil and grease (O&G)
Total suspended solids (TSS)
New Source Performance Standards
(Ibs/ton of product)
Maximum Daily
0.0246
0.0665
Maximum Monthly Average
0.0132
0.0337
         'Proposed NSPS limitations for the By-Product Recovery Segment of the Cokemaking Subcategory include the BAT
         limitations presented in the previous table in addition to these limitations for TSS and O&G.                j

             EPA is proposing the same additional allowances for proposed pollutant loadings
for NSPS as the Agency is proposing for BAT.                                    !
                                                                             I
             PSES—By-Product Recovery Segment                            i

             EPA is co-proposing PSES-1 and PSES-3 for the By-Product Recovery Segment
of the Cokemaking Subcategory. The PSES-1 model treatment sequence consists of tar removal,
flow equalization, and free and fixed ammonia stripping.  The PSES-3 model treatment sequence
consists of oil and tar removal, flow equalization prior to  ammonia stripping, free and fixed
ammonia stripping, indirect cooling, flow equalization before biological treatment, biological
treatment, and sludge dewatering.

             As discussed in Section 8, EPA evaluated four .PSES options for the By-Produpt
Recovery Segment of the Cokemaking Subcategory. The Agency determined that the application
of PSES options would result in the following additional annual pollutant removals (in toxic
pound equivalents) and associated compliance costs (in 1997 dollars):

             •      PSES-1 would remove 3,400 toxic pound equivalents per year at [an
                    annualized compliance cost of $0.3 million;                   [
                                         14-10
-------
                                                                 Section 14 - Selected Options
              •      PSES-2 would increase the pollutant removal achieved through PSES-1 by
                     2,200 toxic pound equivalents per year and increase the annualized
                     compliance cost by $1.9 million;

              •      PSES-3 would increase the pollutant removal achieved through PSES-2 by
                     42,900  toxic pound equivalents per year and increase the annualized
                     compliance cost by $2.8 million; and

              •      PSES-4 would increase the pollutant removal achieved through PSES-3 by
                     2,900 toxic pound equivalents per year and increase the annualized
                     compliance cost by $3.5 million.

              In consideration of the significant, additional costs required to achieve the pollutant
 removals under PSES-4, EPA determined that PSES-3 is the best technology option for the By-
 Product Recovery Segment. However, the Agency is co-proposing PSES-1 because this option
 may result in similar pollutant removals at a lower cost. Both options provide controls for POTW
 pass-through pollutants and are economically achievable (neither option would result in a facility
 closure). Between proposal and promulgation of the Iron and Steel rule, the Agency plans to
 further evaluate setting PSES equal to BAT-3, which contains the same technical components as
 PSES-4. The following table presents proposed PSES limitations for the By-Product Recovery
 Segment of the Cokemaking Subcategory.

                               Cokemaking Subcategory
                   PSES Limitations for By-Product Recovery Segment
Pollutant
Ammonia as nitrogen
Cyanide
Naphthalene ,
Phenol
Selenium
Thiocyanate
Pretreatment Standards for Existing Sources
(Ibs/ton of product)
Maximum Daily
PSES-1
0.0845
0.0244
0.00268
2.13
0.00125
0.402
PSES-3
0.00539
0.00616
0.000103
0.0000332
0.000185
0.00164
Maximum Monthly Average
PSES-1
0.0559
0.0128
0.000869
0.720
0.00104
0.317
PSES-3
0.00357
0.00422
0.0000345
0.0000187
0.000159
0.00115
             EPA is proposing the same additional allowances for proposed pollutant loadings
for PSES-3 as the Agency is proposing for BAT and NSPS. For PSES-1, EPA is proposing the
following additional allowances for pollutant loadings based on the production-normalized flow
for the treatment systems:                .         •
                                        14-11
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                                                                Section 14 - Selected Options
             •      Increased loadings, not to exceed 13.9 percent of the above limitations., for
                    process wastewater from wet desulfurization systems if such systems
                    generate process wastewater;                                I

                    Increased loadings, not to exceed 9.3 percent of the above limitations, for
                    process wastewater from control measures necessary for compliance with
                    by-product recovery coke plant NESHAPs if .such systems generate
                    process wastewater; and

             •      Increased loadings for process wastewater fronrother WAPC systems (not
                    including coal charging and coke pushing emission controls), coal tar
                    processing operations, and coke plant ground-water remediation systems if
                    such systems generate process wastewater that is co-treated withiby-
                    product recovery cokemaking process wastewater.

             PSNS-By-Product Recovery Segment

             The treatment technologies that form the basis for PSNS for the By-Product
Recovery Segment of the Cokemaking Subcategory  are the same as the PSES-3 model ..
technologies; therefore, EPA has set proposed PSNS limitations for the By-Product Recovery
Segment equal to PSES-3 limitations (see previous table for PSES-3 limitations). EPA is also
proposing the same additional allowances for proposed pollutant loadings for PSNS as the
Agency is proposing for PSES. Between proposal and promulgation of the Iron and Steel rule,
EPA plans to farther evaluate setting PSNS equal to  BAT-3, which has the same technical
components as PSES-4.

             BAT/NSPS/PSES/PSNS-Non-Recovery Segment

             EPA has determined that non-recovery cokemaking operations do not discharge
process wastewater.  Process area storm water and nonprocess wastewater in the form of boiler
blowdown are typically disposed of by coke quenching. Therefore, EPA is proposing zero
discharge of process wastewater pollutants to waters of the United States and POTWs ^s BAT,
NSPS, PSES, and PSNS for the Non-Recovery Segment of the Cokemaking Subcategory.
14.3.2
Ironmaking

BAT
             EPA is proposing BAT-1 for the Ironmaking Subcategory. BAT-1 model
treatment consists of high-rate recycle using a clarifier for solids removal, sludge dewatering, a
cooling tower, and blowdown treatment with chemical precipitation for metals removal, alkaline
chlorination, and multimedia filtration.  The application of BAT-1 would reduce current annual
water usage by 5 percent and reduce total loadings of priority and nonconventional pollutants by
68 percent. EPA has determined that BAT-1 is economically achievable (Reference 14-2);
application of this option would cause no facility closures.
                                         14-12
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                                                                       Section 14 - Selected Options
               The proposed BAT limitations presented in the following tables apply to process
wastewater from sintering operations with WAPCs and all blast furnace ironmaking operations,
whether these wastewater discharges are treated separately or co-treated. Section 15 discusses
the compliance monitoring point for 2,3,7,8-tetrachlorodibenzofuran (TCDF). The Agency is
proposing zero discharge of process wastewater pollutants to waters of the U.S. as BAT for
sintering operations with dry  air pollution controls.

                                  Ironmaking Subcategory
                         BAT Limitations for Sintering Operations3
Pollutant
Ammonia as nitrogen
Cyanide
Lead
Phenol
2,3,7,8-TCDF
Total residual chlorine0
Zinc
BAT Limitations
(Ibs/ton of product)
Maximum Daily '
0.000652
0.00493
0.0000913 .
0.0000463
-------
                                                                     Section 14 - Selected Options
              NSPS

              The treatment technologies that form the basis for NSPS for the Ironmaking
Subcategory are the same as the BAT-1 model technologies. EPA has determined that BAT-1 is.
the best demonstrated technology for new sources in the Ironmaking Subcategory; therefore, EPA
has set proposed NSPS limitations for the Ironmaking Subcategory equal to BAT-1 limitations
(see previous table for BAT limitations). The Agency has determined that BAT-1 represents the
best demonstrated technologies for the Ironmaking Subcategory.  Section 15 discusses the
compliance monitoring point for 2,3,7,8-TCDF.  As with BAT, the Agency is proposing zero
discharge of process wastewater pollutants to waters of the U.S. as NSPS for sintering operations
with dry air pollution controls.

              To ensure that the regulations for new sources represent the most stringent
numerical values attainable through the application of the best available control technology for all
pollutants, EPA is proposing NSPS limitations for two pollutants not regulated under BAT for
the Ironmaking Subcategory: TSS and  O&G. The following tables presents these additional
limitations for sintering and blast furnace operations.                                 \   '     •

                      Ironmaking Subcategory—Sintering Operations3
                           NSPS Limitations for TSS and O&G"
Pollutant
Oil and grease (O&G)
Total suspended solids (TSS)
New Source Performance Standards
(Ibs/ton of product)
Maximum Daily
0.00531
0.0251
Maximum Monthly Average
0.00420
0.00939
         "NSPS limitations in this table apply only to sintering operations with WAPCs.
         ""Proposed NSPS limitations for sintering operations in the Ironmaking Subcategory include the BAT limitations
         presented in the previous table for sintering operations in addition to these limitations for TSS and O&G.

                    Ironmaking Subcategory—Blast Furnace Operations
                           NSPS Limitations for TSS and O&Ga
Pollutant
Oil and grease (O&G)
Total suspended solids (TSS)
New Source Performance Standards
(Ibs/ton of product)
Maximum Daily
0.00177
0.00836
Maximum Monthly Average
0.00140
0.00313
         ^Proposed NSPS limitations for blast furnace operations in the Ironmaking Subcategory include the BAT limitations
         presented in the previous table for blast furnace operations in addition to these limitations for TSS and O&G.
                                           14-14
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                                                                   Section 14 - Selected Options
              PSES                                    '•        .

              EPA is proposing PSES-1 for the Ironmaking Subcategory. PSES-1 model
treatment consists of high-rate recycle using a clarifier for solids removal, sludge dewatering, a
cooling tower, and blowdown treatment with chemical precipitation for metals removal.  This
option is economically achievable and. provides controls for POTW pass-through pollutants.
Section 15 discusses the compliance monitoring point for 2,3,7,8-TCDF.

              Although setting PSES equal to BAT-1 would achieve additional removal of
ammonia-N through alkaline chlorination, EPA has determined that all POTWs receiving
wastewater from ironmaking operations are removing ammonia-N to levels comparable to the
levels that would be achieved through BAT-1. Between proposal and promulgation of the Iron
and Steel rule, the Agency plans to further evaluate setting PSES for the Ironmaking Subcategory
equal to BAT-1. The Agency is proposing zero discharge of process wastewater pollutants to
POTWs as PSES for sintering operations with dry air pollution controls.

              The Agency is proposing regulatory flexibility to waive ammonia-N pretreatment
standards for ironmaking operations if the indirect discharger certifies to its pretreatment control
authority under 40 CFR 403.12 that it discharges process wastewater to a POTW with the
capability to achieve ammonia-N removals that, when considered together with the indirect
discharger's removals, are at least equivalent to those expected under proposed BAT.
                                Ironmaking Subcategory
                    PSES/PSNS Limitations for Sintering Operations3
Pollutant
Ammonia as nitrogenb
Lead
2,3,7,8-TCDF
Zinc
Pretreatment Standards for Existing and New Sources
(Ibs/ton of product)
Maximum Daily
0.000652
0.0000913
-------
                                                                 Section 14 - Selected Options
                                Ironmaking Subcategory
                  PSES/PSNS Limitations for Blast Furnace Operations
Pollutant
Ammonia as nitrogen3
Lead
2,3,7,8-TCDF\
Zinc
Pretreatment Standards for Existing and New Sources
(Ibs/ton of product)
Maximum Daily
0.000217
0.0000304
-------
                                                                 Section 14 - Selected Options
through pollutants for PSES and PSNS. EPA has determined that BAT-1 is economically
achievable (Reference 14-2); application of this option would cause no facility closures.

             The following table presents proposed BAT, NSPS, PSES, and PSNS limitations
for the Integrated Steelmaking Subcategory. These limitations apply to wastewater from basic
oxygen furnaces with semi-wet, wet-suppressed combustion, or wet-open combustion pollution
controls; vacuum degassing; and continuous casting operations conducted at integrated iron and
steel mills.  The limitations apply to  wastewater discharges from these operations whether they
are treated separately or co-treated. The Agency proposes zero discharge of process wastewater
pollutants to waters of the United States and POTWs as BAT, NSPS, PSES, and PSNS for ladle
metallurgy operations (other than vacuum degassing) in the Integrated Steelmaking Subcategory.

                          Integrated Steelmaking Subcategory
                          BAT/NSPS/PSES/PSNS Limitations
Pollutant
Limitations for BAT, NSPS, PSES, and PSNS
(Ibs/ton of product)
Maximum Daily
Maximum Monthly
Average
Basic Oxygen Furnaces
Semi-wet Air Pollution Controls
Lead
Zinc
0.0000122
0.0000140
0.00000634
0.00000795
Wet-suppressed Combustion
Lead
Zinc
0.0000243
0.0000279
0.0000127
0.0000159
Wet-open Combustion
Lead
Zinc
0.0000243
0.0000279
0.0000127
0.0000159
Vacuum degassing
Lead
Zinc
0.0000183
0.0000209
0.00000951
0.0000119
Continuous Casting •
Lead
Zinc '
0.0000243
0.0000279
0.0000127
0.0000159
                                        14-17
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                                                                 Section 14 * Selected Options
14.3.4        Integrated and Stand-Alone Hot Forming                        ;
                                                                             I
              BAT—Carbon and Alloy Segment

              EPA is proposing BAT-1 for the Carbon and Alloy Steel Segment of the;
Integrated and Stand-Alone Hot Forming Subcategory.  BAT-1 model treatment consists of high-
rate recycle using a scale pit with oil skimming, a roughing clarifier with oil removal, sludge
dewatering, a multimedia filter for polishing, and treatment of blowdown with multimedia
'filtration. The following table presents proposed BAT limitations for the Carbon and Alloy Steel
Segment of the Integrated and Stand-Alone Hot Forming Subcategory.              |

                  Integrated and Stand-Alone Hot Forming Subcategory
                  BAT Limitations for Carbon and Alloy Steel Segment
Pollutant
Lead
Zinc
BAT Limitations
(Ibs/ton of product)
Maximum Daily
0.000122
0.000131
Maximum Monthly
Average
0.0000634
0.0000907
              EPA is proposing two different approaches for implementing BAT-1 forithe
Carbon and Alloy Steel Segment because the selected option may not be economically achievable
in April 2002, when the Agency is scheduled to take final action on the proposed Iron and Steel
rule. BAT Option A and BAT Option B differ in the amount of time facilities would have to
achieve proposed BAT limitations.                                              ;

              Under BAT Option A, each existing direct discharger in the Carbon and Alloy
Steel Segment would be subject to the proposed BAT limitations as soon these limitations are
incorporated into the facility's NPDES permit, as required by CWA section 301(b)(2). The
Agency has determined that BAT Option A is economically achievable; a facility-level economic
analysis projects no facility closures.  A firm-level economic analysis, however, does project that
one or more firms may experience financial distress (e.g., loss of financial independence; sale of
assets, or the likelihood of bankruptcy) as a result of the aggregate compliance costs-including
the compliance costs for the Integrated and Stand-Alone Hot Forming Subcategory~of the Iron
and Steel rule. The Agency's facility-level analysis indicates that facilities would be expected to
remain viable after compliance and would possess value as continuing concerns. Therefore, EPA
expects that a firm would respond to financial distress through the sale of assets, rather than
through the declaration of bankruptcy, which is far more disruptive in terms of economic impacts
on the subcategory as a whole.  For example, job losses would be more limited and any
community impacts associated with job losses would likewise be less severe from the sale of a
facility owned by a distressed firm when compared with the impacts associated with a bjankruptcy-
induced closure. The Agency has determined that this projected level of financial distress is not
                                         14-18
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                                                                   Section 14 - Selected Options
 significant and, therefore, has determined that Option A is economically achievable for the Carbon
 and Alloy Steel Segment as a whole.

              EPA has estimated that affected facilities could spend $21.2 million in total
 annualized costs to comply with BAT limitations based on BAT-1. When these costs are
 considered together with other estimated costs that firms could incur if the Iron and Steel rule is
 promulgated as proposed, the cumulative costs of the 'Iron and Steel rule could jeopardize the
 corporate financial health of one'or more firms.  While EPA considers these possible impacts
 acceptable for the proposed Iron and Steel rule, the Agency recognizes that new information
 received after proposal,- including information regarding changes in the financial health of the
 industry due to changes in the national economy and foreign trade, might lead EPA to reach a
 different conclusion at promulgation in April 2002. Therefore, EPA is proposing a second BAT
 approach for the Carbon and Alloy Steel Segment.

             BAT Option B is designed to minimize the possible adverse economic impacts of
 the proposed BAT option for the Carbon and Alloy Steel Segment of the Integrated and Stand-
 Alone Hot Forming Subcategory. The Agency is considering BAT Option B in the event that
 BAT Option A is not economically achievable for the Carbon and Alloy Steel Segment as a whole
 when the Iron and Steel rule is promulgated.

             As, described above, BAT Option A would make each existing direct discharger in
 the Carbon and Alloy Steel Segment subject to the proposed BAT limitations as soon these
 limitations are incorporated into the facility's NPDES permit. Although it is common practice for
permit writers to concurrently issue administrative orders and permits based on a new or revised
 effluent guidelines, the decision to do so is left to the discretion, of the permit writers. Therefore,
EPA cannot assume the availability of such relief when estimating the costs and impacts of the
proposed Iron and Steel rule. Under BAT Option B, existing direct dischargers in the Carbon and
Alloy Steel Segment could receive additional time to comply with proposed BAT limitations.

             Under BAT Option B, EPA would codify BAT limitations containing  three
separate components; these components would become progressively more stringent  over time.
Although applied in stages, the limitations would represent a continuum of progress that all
facilities under BAT Option B would be required to achieve by a later date determined by the
Agency.  The three components are described below:

             •      First component.  Each facility in the Carbon and Alloy Steel Segment
                    would be immediately subject to "stage 1" BAT limitations for each
                    regulated pollutant. These limitations would be based on the facility's
                    existing effluent quality or the facility's current technology-based permit
                    limitations, whichever would represent the more stringent limitations for
                    each regulated pollutant. The Agency expects that the permitting authority
                    would express "stage 1" BAT limitations in numeric format for each facility
                    on a case-by-case basis. Existing effluent quality would be determined at
                    the internal monitoring point for wastewater discharged from the hot
                    forming wastewater treatment plant.
                                         14-19
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                                                                   Section 14 - Selebted Options
              •      Second component. Each facility in the Carbon and Alloy Steel Segment
                     would be subject to enforceable interim milestones developed by the
                     permitting authority on the basis of best professional judgment to'reflect
                     reasonable progress toward compliance with the "stage 2" BAT limitations.
                     EPA intends that these milestones would be expressed as narrative or
                     numeric conditions in the facility's NPDES permit and would reflect each
                     step in a facility's progress toward achievement of "stage 2" performance
                     requirements.                          .                    \

              •      Third component.  Each facility in the Carbon and Alloy Steel Segment
                     would be subject to the ultimate ("stage 2") BAT limitations based on the
                     model BAT technology by a date determined by the Agency.

              Under the first component, each facility would be subject to these limitations as
 soon as they were placed in the facility's NPDES permit. The "stage 1" BAT limitations would
 ensure that, at a minimum, existing effluent quality is maintained while each facility moves toward
 achieving "stage 2" BAT limitations.  Because "stage 1" limitations would reflect a level of
 technology that is either already used or has been previously identified as BAT for each facility,
 EPA would conclude at promulgation that the technology bases for "stage 1" limitations are both
 technically available and economically achievable.  If EPA were to promulgate such limitations,
 the Agency would consider whether the application of these limitations would result in any
 adverse non-water quality environmental impacts and would also consider the other statutory
 factors specified in CWA section 304(b)(2)(B) and 306. EPA believes that "stage 1" limitations
 would be the best available technology economically achievable for facilities in the Carbon and
 Alloy Steel Segment if compliance with these limitations allows these facilities to focus resources
 on the research, development, testing, and installation of technologies ultimately needed; to
 achieve "stage 2" limitations. "Stage  1" limitations thus would reflect "reasonable further
 progress toward the national goal of eliminating the discharge of all pollutants," as called for by
 CWA section 301(b)(2)(A).  "Stage 1" limitations would also reasonably represent the first
' component of the BAT continuum of progress if the Agency were to determine that the model
 BAT technology  is not economically achievable at promulgation.                     ?
                                                                               i '
              EPA would promulgate "stage 2" limitations based on the model BAT technology
 for the Carbon and Alloy Steel Segment. Under Option B, facilities would be subject to "stage 2"
 limitations by a later date set by the Agency (e.g., April 30,2007).  EPA would select a (late by
 determining-based on the administrative record at promulgation~when the model BAT;
 technology would be economically achievable for the Carbon and Alloy Steel Segment as a whole.
 Thus, if EPA concludes  at the time of promulgation that five years would be sufficient time to
 allow facilities to raise the capital necessary to implement the model BAT technology in a way
 that ensures its economic achievability, then EPA would specify a "stage 2" compliance date five
 years from promulgation.

               EPA recognizes that some facilities in the Carbon and Alloy Steel Segment are
 already achieving or are capable of achieving limitations approaching "stage 2"  limitations.
 Consequently, "stage 1" limitations for each facility would correspond to that level of
                                          14-20
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                                                                  Section 14 - Selected Options
 achievement, as judged by the permitting authority based on monitoring .data supplied by the
 facility.  In this way, EPA would ensure that limitations were derived from the best available
 technology economically achievable for the segment as a whole, even if that technology varies on
 a facility-to-facility basis during the interim period before the "stage 2" limitations apply.

              EPA acknowledges that the uncertainties in the iron and steel market and the
 financial circumstances of individual firms may make it difficult to project-the economic
 achievability of particular technologies in future years, even in the comparative nearterm. The
 Agency would expect to take into account a variety of factors, including the costs of the BAT
 model technology over a specified number of years, the expected industry price and revenue
 cycle, the economic impact of other EPA regulations (if applicable within the time frame) on the
 Carbon and Alloy Steel Segment of the Integrated and Stand-Alone Hot Forming Subcategory,
 and resulting aggregate costs, closures, and firm failures.

              In the effluent limitations guidelines and standards for the pulp, paper and
 paperboard industry, EPA adopted an approach similar to BAT Option B as part of its Voluntary
 Advanced Technology Incentives Program (see 40 CFR 430.24(b)). Facilities choosing to •
 participate in the Voluntary Advanced Technology Incentives Program could enroll at one of
 three levels, or tiers, each with its own set of limits and time frames for compliance, and each
 based on a different model BAT technology (with technologies becoming more advanced as the
 time periods for compliance were extended). For each tier, EPA promulgated voluntary advanced
 technology BAT limitations that consisted of three separate components. Together, the three
 components combined to represent BAT for any bleached papergrade kraft and soda mill that
 elected to participate in the voluntary incentives program.  The first component consisted of
 "stage 1" existing effluent quality limitations that were similar in principle to the "stage 1"
 limitations described above for BAT Option B (see 40 CFR 430.24(b)(l))-  The second
 component consisted of enforceable interim milestones developed by the permitting authority
 using best professional judgement to reflect reasonable interim milestones toward achievement of
 the ultimate BAT limitations (see 40 CFR 430.24(b)(2)).  The program also included numeric six-
 year milestone limitations that would apply to facilities that enrolled in Incentives Tiers with
 deadlines of 2009 and 2014 (see 40 CFR 430.24(b)(3)). The third component consisted of
 numeric "stage 2" effluent limitations that reflected the limitations achievable by the model BAT
 technology for the particular tier. Taken together, these three components constitute reasonable
 further progress toward the national goal of eliminating the discharge of all pollutants and, for this
 reason, represent BAT.

              The incremental approach of BAT Option B is authorized by CWA section
 301(b)(2)(A), which expressly requires BAT to result in reasonable further progress toward the
national goal of eliminating pollutant discharges.  Although environmental improvements would
be realized only incrementally under BAT Option B, each facility would be continuously subject
to and required to comply immediately with BAT limitations as they progressively unfold,
 including each interim BAT limitation or permit condition representing that progress.

               EPA's promulgation of BAT Option B as a package of progressively more
stringent  limitations and conditions is consistent with the use of BAT as a "beacon to show what
                                         14-21
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                                                                  Section 14 - Selected Options
is possible." See Kennecott v. EPA. 780 F.2d 445, 448 (4th Cir. 1985). Using BAT Option B,
EPA would promulgate forward-looking effluent limitations guidelines and standards for the
Carbon and Alloy Steel Segment as a whole. The application of BAT Option B would also
promote a form of technological progress that is consistent with Congressional intent that BAT
should aspire to "increasingly higher levels of control" (Reference 14-3).              •
                                                                               [
              The application of BAT Option B would also be consistent with the overall goals
of the CWA (see CWA Section 101(a)). Agencies have considerable discretion to interpret
statutes to promote Congressional objectives: "[T]he breadth of agency discretion is, if anything,
at zenith when the action ... relates primarily to ... the fashioning of policies, remedies land
sanctions, including enforcement and voluntary compliance programs[,] in order to arrive at
maximum effectuation of Congressional objectives."  See U.S. Steelworkers of America v.
Marshall. 647 F.2d 1189, 1230-31 n.64 (D.C. Cir. 1980) (upholding OSHA rule staggering lead
requirements over 10 years) (quoting Niagara Mohawk Power Corp. v. FPC. 379 F.2d;153, 159
(D.C. Cir. 1967)), cert, denied, 453 U.S. 9113 (1981).  The codification of progressively more
stringent BAT limitations advances not only the general goal of the CWA, but also advances the
explicit goals of the BAT program.  See Chevron. U.S.A.. Inc. v. NRDC. 467 U.S. 837,  843-44
(1984).                                                                       -I

              The movement toward elimination of pollutant discharges in stages is also
consistent with the overarching structure of the effluent limitations guidelines and standards
program. Congress originally envisioned that the sequence of attaining BPT limits in 1977 and
BAT limits in 1983 would result in "levels of control which approach and achieve the elimination
of the discharge of pollutants" (Reference 14-3). This two-step approach produced dramatic
improvements in water quality but did not achieve the elimination of pollutant discharges.
Therefore, EPA periodically revisits and revises effluent limitations guidelines and standards with
the intention each time of making further progress toward the national goal. The current proposal
of the Iron and Steel rule represents the third set of effluent limitations guidelines and standards
proposed for the iron and steel industry. Achieving these incremental improvements through
successive rulemakings carries a substantial cost: the  rulemaking process can be highly complex,
in large part because of the massive record compiled to support the Agency's decisions and
because of the  substantial costs associated with achieving each additional increment of
environmental improvement. If EPA were to adopt BAT Option B for the Carbon and Alloy
Steel Segment of the Integrated and Stand-Alone Hot Forming Subcategory, the Agency would
achieve the goals that Congress envisioned for the BAT program at considerably less cost: one
rulemaking that looks both at the present and into the future.

              Finally, like other agencies, EPA has inherent authority to phase in regulatory
requirements in appropriate cases.  EPA has used this authority in other contexts.  For example,
EPA recently phased in, over two years, Toxic Substances Control Act (TSCA) rules pertaining
to lead-based paint activities. See 40 CFR 746.239 and 61 FR 45788, 45803 (Aug. 29, 1996).
Similarly, the Occupational Safety and Health Administration phased in, over 10 years, a series of
progressively more stringent lead-related controls. See 29 CFR 1910.1025 (1979 ed.).  In
upholding that rule, the U.S. Court of Appeals for the D.C. Circuit noted that "the extremely
remote deadline at which the [sources] are to meet the final [permissible exposure limits] is
                                          14-22
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                                                                  Section 14 - Selected Options
 perhaps the single most important factor supporting the feasibility of the standard." See United
 Steelworkers of America v. Marshall. 647 F.2d at 1278.

              EPA recognizes that CWA sections 301(b)(2)(C) & (D) require BAT limits to be
 achieved "in no case later than three years after the date such limits are promulgated under section
 304(b), and in no case later than March 31, 1989." (Section 301(b)(2)(F), which refers to BAT
 limitations for nonconventional pollutants, also contains the March 31, 1989 date but uses as its
 starting point the date the limitations are "established.") This language does not speak to whether
 EPA can promulgate BAT limitations that are phased in over time so that a direct discharger at all
 times is subject to and must comply immediately with particular BAT limitations applicable to
 them at any given point in tune.  Because Section 301(b)(2) provides no clear direction, EPA
 must make a reasonable interpretation of the CWA.  See Chevron. U.S.A.. Inc. v. NRDC. 467
 U.S. at 843-44. The Agency has determined that subjecting facilities to progressively more
 stringent BAT limitations over time would be the best way of achieving reasonable further
 progress toward eliminating all pollutant discharges, as intended by Congress. Using BAT Option
 B, EPA would achieve environmental reductions beyond those that would be achievable if EPA
 proposed a BAT option based only on what is immediately attainable. The Agency estimates that
 the total annualized compliance cost for BAT Option B would be $13.3 million, which represents
 a savings of $7.9 million over BAT Option A.

              NSPS-Carbon and Alloy Steel Segment

              The treatment technologies that form the basis for NSPS for the Carbon and Alloy
 Steel Segment of the Integrated and Stand-Alone Hot Forming Subcategbry are the same as the
 BAT-1 model technologies. EPA has determined that BAT Option A is the best demonstrated
 technology for new sources in the Carbon and Alloy Steel Segment; therefore, the Agency is
proposing BAT Option A as the basis for NSPS limitations for the Carbon and Alloy Steel
 Segment (see previous table, for BAT limitations). To ensure that the regulations for new sources
represent the most stringent numerical values attainable through the application of the best
available control technology for all pollutants, EPA is proposing NSPS limitations for two
pollutants not regulated under BAT for the Carbon and Alloy Steel Segment: TSS and O&G.
The following table presents these additional limitations.
                                         14-23
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                                                                   Section 14 - Selected Options
 Integrated and Stand-Alone Hot Forming Subcategory-Carbon and Alloy Steel Segment
                           NSPS Limitations for TSS and O&G
Pollutant
Lead
Oil and grease (O&G)
Total suspended solids (TSS)
Zinc
New Source Performance Standards ',
(Ibs/ton of product) \
Maximum Daily
0.000122 •
0.00793
0.0182
0.000131
Maximum Monthly Average
o.oooo634 ;
0.00628
0.0124
0.0000907 t
              PSES-Carbon and Alloy Steel Segment
                                                                                i.
              EPA is not proposing PSES limitations for the Carbon and Alloy Steel Segment of
the Integrated and Stand-Alone Hot Forming Subcategory.  EPA evaluated PSES-1 model
treatment, which consists of high-rate recycle using a scale pit with oil skimming, roughing
clarifier with oil removal, sludge dewatering, a multimedia filter for polishing, and treatment of
blowdown with multimedia filtration. Although the application of PSES-1 would reduce current
annual wastewater flow by 74 percent and reduce total loadings of priority and nonconvfentional
pollutants by 53 percent, EPA has determined that nationally applicable PSES are unnecessary at
this time because the Carbon and Alloy Steel Segment covers only 7 facilities, and the application
of PSES-1 would result in an average annual removal of only 21 toxic pound equivalents3 per
facility. The Agency has determined that a case-by-case application of local pretreatment
limitations would more appropriately address individual toxic parameters present at these
facilities.                                                   .

              PSNS-Carbon and Alloy Steel Segment

              EPA is not proposing PSNS limitations for the Carbon and Alloy Steel Segment of
the Integrated and Stand-Alone Hot Forming Subcategory for the same reasons the Agency is not
proposing PSES limitations for this segment. In addition, EPA does not foresee the construction
of any new indirectly discharging facilities that would be covered under this segment.
Additionally, EPA has determined that it would not be practicable for a direct discharger covered
under the Carbon and Alloy Steel Segment to become an indirect discharger because the flow
rates from the facility would be too great for treatment in a POTW.                   i
3These removals are much lower than those achieved by other categorical pretreatment standards promulgated by EPA.
For example, annual per-facility toxic pound equivalents for the Organic, Chemical, Plastics, and Synthetic Fibers
(OCPSF), Electroplating, Battery Manufacturing, and Porcelain Enameling rules range from 6,747 to 14,960. EPA
recently chose not to promulgate pretreatment standards for two industrial categories: Industrial Laundries (see 64 FR
45072) and Landfills (see 65 FR 3008) because the industrial laundries standards would remove only 32 and the landfill
standards would remove only 14 annual per-facility toxic pound equivalents.                        [
                                           14-24
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                                                                   Section 14 - Selected Options
              BAT-Stainless Steel Segment

              EPA is proposing BAT-1 for the Stainless Steel Segment of the Integrated and
 Stand-Alone Hot Forming Subcategory,  BAT-1 model treatment consists of high-rate recycle
 using a scale pit with oil skimming, a roughing clarifier with oil removal, sludge dewatering, a
 multimedia filter for polishing, and treatment of blowdown with multimedia filtration. EPA has
 determined that this option is economically achievable (Reference 14-2); no facility closures
 would result from the application of BAT-1.

                  Integrated and Stand-Alone Hot Forming Subcategory
                       BAT Limitations for Stainless Steel Segment
Pollutant
Chromium
Nickel
BAT Limitations-
(Ibs/ton of product)
Maximum Daily
0.0000808
0.000275
Maximum Monthly Average
0.0000362
0.000144
              NSPS~Stainiess Steel Segment

              The treatment technologies that form the basis for NSPS for the Stainless Steel
Segment of the Integrated and Stand-Alone Hot Forming Subcategory are the same as the BAT-1
model technologies; therefore, EPA has set proposed NSPS limitations for the Stainless Steel
Segment equal to BAT-1 limitations (see previous table for BAT limitations). To ensure that the
regulations for new sources represent the most stringent numerical values attainable through the
application of the best available control technology for all pollutants, EPA is proposing NSPS
limitations for two pollutants not regulated under BAT for the Stainless Steel Segment: TSS and
O&G.  The following table presents these additional limitations.

      Integrated and Stand-Alone Hot Forming Subcategory—Stainless Steel Segment
                          NSPS Limitations for TSS and O&Ga
Pollutant
Oil and grease (O&G)
Total suspended solids (TSS)
New Source Performance Standards
(Ibs/ton of product)
Maximum Daily
• 0.0236
0.0265
Maximum Monthly Average
0.0119
0.0109
   'Proposed NSPS limitations for the Stainless Steel Segment of the Integrated and Stand-Alone Hot Forming Subcategory include the BAT
   limitations presented in the previous table in addition to these limitations for TSS and O&G.
                                          14-25
-------
                                                                Section 14 - Selected Options
             PSES-Stainless Steel Segment                                   j
                                                                             r
                                                                             I
             EPA is not proposing PSES limitations for the Stainless Steel Segment of the
Integrated and Stand-Alone Hot Forming Subcategory. Although the application of PSES-1
would reduce current annual wastewater flow by 90 percent and reduce total loadings of priority
and nonconventional pollutants by 66 percent, EPA has determined that PSES are unnecessary at
this time because the Stainless Steel Segment covers only 3  facilities, and the application of
PSES-1 would result in an average annual removal of only 4 toxic pound equivalents per facility.
These removals are much lower than those achieved by other categorical pretreatment standards
promulgated by EPA (see the description of PSES for the Carbon and Alloy Steel Segmpnt of the
Integrated and Stand-Alone Hot Forming Subcategory, footnote number 3, for more   |
information). The Agency has determined that a case-by-case application of local pretreatment.
limitations would more appropriately address individual toxic parameters present at thesjs
facilities.                                                                     \

             PSNS-Stainless Steel Segment

             EPA is not proposing PSNS limitations for the Stainless Steel Segment of the
Integrated and Stand-Alone Hot Forming Subcategory for the same reasons the Agency;is not
proposing PSES limitations for this segment.

14.3.5       Non-Integrated  Steelmaking and Hot Forming Subcategory        \
                                                                            ' !' •
             BAT-Carbon and Alloy Steel Segment
                                                                             t
                                                                             r
             EPA is proposing BAT-1 for the Carbon and Alloy Steel Segment of the iNon-
Integrated Steelmaking and Hot Forming Subcategory. BAT-1 model treatment consist^ of solids
removal, scale pit with oil skimming (continuous casting and hot forming only), sludge :
dewatering, a cooling tower, multimedia filtration, high-rate recycle,  and treatment of blowclown
with multimedia filtration. The application of BAT-1 would reduce current annual wastewater
flow by 90 percent and reduce total loadings of priority and nonconventional pollutants by 72
percent. BAT-1 would remove 39,100 toxic pound equivalents per year at an annualized
compliance cost of $3.1 million (in 1997 dollars). The Agency has determined that BAT-1 is
economically achievable (Reference 14-2); application of this option would cause no facility
closures.                                                                     •
                                                                             I
             The following table presents proposed BAT limitations for the Carbon and Alloy
Steel Segment of the Non-Integrated Steelmaking and Hot Forming Subcategory. The Agency
proposes zero discharge of process wastewater pollutants to waters of the U.S. as BATifor
electric arc furnaces and ladle metallurgy operations (other than vacuum degassing) hi the Carbon
and Alloy Steel Segment of the Non-Integrated Steelmaking and Hot Forming Subcategory.
                                         14-26
-------
                                                                    Section 14 - Selected Options
                Non-Integrated Steelmaking and Hot Forming Subcategory
                   BAT Limitations for Carbon and Alloy Steel Segment
Pollutant
BAT Limitations
(Ibs/ton of product)
Maximum Daily
Maximum Monthly
Average
Vacuum Degassing and Continuous Casting'
Lead
Zinc
0.0000122
0.0000101
0.00000634
0.00000450
Hot Forming
Lead
Zinc
0.0000609
0.0000506
0.0000317
'" 0.0000225
          'Limitations are applicable to each vacuum degassing or continuous casting operation on site.
              NSPS-Carbon and Alloy Steel Segment

              EPA proposes zero discharge of process wastewater pollutants to waters of the
U.S. as NSPS for the Carbon and Alloy Steel Segment of the Non-Integrated Steelmaking and
Hot Forming Subcategory.  NSPS model process wastewater and water pollution control
technologies include treatment and high-rate recycle systems, management "of process area storm
water, and disposal of low-volume blowdown streams by evaporation through controlled
application on EAF slag, direct cooling of electrodes in electric arc furnaces, and other
evaporative uses.

              Operators of 24 existing non-integrated steel facilities have reported zero
discharge of process wastewater. These facilities are located in the following states: Alabama,
Arizona, Georgia, Illinois, Indiana, Louisiana, New Jersey, New York, North Carolina, Ohio,
Pennsylvania, South Carolina, Tennessee, Texas, Utah, and Washington. Under the Non-
Integrated Steelmaking and Hot Forming Subcategory, these facilities produce the following
carbon, alloy, and stainless steel products: bars, beams, billets, flats, plate, rail, rebar, rod, sheet,
slabs, small structurals, strip, and specialty sections.

             Consequently, the Agency has determined that zero discharge is well demonstrated
and appropriate as NSPS for non-integrated Steelmaking and hot forming operations that are
located in any area of the United States and manufacture any product.  EPA has determined that
there is no barrier to entry for new sources to achieve this option; the wastewater treatment
technologies and water management practices necessary to achieve zero discharge can be
designed and implemented at new facilities.
                                          14-27
-------
                                                                   Section 14 - Selected Options
               PSES-Carbon and Alloy Steel Segment

               EPA is proposing not to revise PSES limitations for the Carbon and Alloy Steel
 Segment of the Non-Integrated Steelmaking and Hot Forming Subcategory. As presented in the
 following table, EPA is recodifying 1982 PSES to fit the revised subcategorization and \
 segmentation of the proposed rule. EPA is reserving PSES for semi-wet EAF Steelmaking
 operations and proposing zero discharge of process wastewater pollutants to POTWs as PSES for
 ladle metallurgy operations (other than vacuum degassing) within the Carbon and Alloy! Steel
. Segment of the Non-Integrated Steelmaking and Hot Forming Subcategory. For hot forming
 operations, any existing source that discharges to POTWs must comply with 40 CFR Part 403.

        • '     Although the application of PSES-1 would reduce current annual wastewater flow
 by 7 percent and reduce total loadings of priority  and nonconventional pollutants by 4.3 percent,
 EPA has determined that PSES are unnecessary at this time because the Carbon and Alloy Steel
 Segment covers only  15 facilities, and the application of PSES-1 would result in an average
 annual removal of only 3 toxic pound equivalents per facility. These removals are much lower
 than those achieved by other categorical pretreatment standards promulgated by EPA (see Section
 14.3.4, footnote number 3, for more information). The Agency has determined that a case-by-
 case application of local pretreatment limitations would more appropriately address individual
 toxic parameters present at these facilities.     •                                    •
                                                                                t
                      Non-Integrated Steelmaking and Hot Forming
                        PSES for Carbon and Alloy Steel Segment
Pollutant
Pretreatment Standards for Existing Sources
(Ibs/ton of product)"
Maximum Daily
Maximum
Monthly Average
Vacuum Degassing and Continuous Casting1"
Lead
Zinc
0.0001878
0.000282
0.0000626
0.0000938
           •For hot forming operations, any existing source subject to regulation under the Carbon and Alloy Segment of the
           Non-Integrated Steelmaking and Hot Forming Subcategory that introduces pollutants into a POTW must comply
           with 40 CFR Part 403.                                                       [
           'Limitations are applicable to each vacuum degassing or continuous casting operation on site.              •

              PSNS-Carbon and Alloy Steel Segment

              EPA proposes zero discharge of process wastewater pollutants to waters of the
 United States and POTWs as both NSPS and PSNS for the Carbon and Alloy Steel Segment of
 the Non-Integrated Steelmaking and Hot Forming Subcategory. The Agency has determined that
 there is no barrier to entry for new sources to achieve this option; the wastewater treatment
 technologies and water management practices necessary to achieve zero discharge can be
 designed and implemented at new facilities. See the discussion of NSPS for this segment for more
 information on the Agency's basis for selecting zero discharge.                       :
                                          14-28
-------
                                                                  Section 14 - Selected Options
              BAT-Stainless Steel Segment

              EPA is proposing BAT-1 for the Stainless Steel Segment of the Non-Integrated
 Steelmaking and Hot Forming Subcategory. BAT-1 model treatment consists of solids removal,
 scale pit with oil skimming (continuous casting and hot forming only), sludge dewatering, a
 cooling tower, multimedia filtration high-rate recycle, and treatment of blowdown with
 multimedia filtration. The application of BAT-1 would reduce current annual water usage by 50
 percent and reduce total loadings of priority and nonconventional pollutants by 29 percent. BAT-
 1 would remove 1,560 toxic pound equivalents at an annualized compliance cost of $0.1 million
 ,(in 1997 dollars).  The Agency has determined that BAT-1 is economically achievable (Reference
 14-2); application of this option would cause no facility closures.

              The following table presents proposed BAT limitations for the Stainless Steel
 Segment of the Non-Integrated Steelmaking and Hot Forming Subcategory. The Agency
 proposes zero discharge of process wastewater pollutants to waters of the United States as BAT
 for EAFs and ladle metallurgy operations (other than vacuum degassing) within the Stainless Steel
 Segment of the Non-Integrated Steelmaking and Hot Forming Subcategory.

               Non-Integrated Steelmaking and Hot Forming Subcategory
                    BAT/PSES Limitations for Stainless Steel Segment
Pollutant
BAT/PSES Limitations
(Ibs/ton of product)
Maximum Daily
Maximum Monthly Average
Vacuum Degassing and Continuous Casting"
Chromium
Nickel
0.00000808
0.0000275
0.00000362
0.0000144
Hot Forming
Chromium
Nickel
0.0000404
0.000137
0.0000181
0.0000720
       "Limitations are applicable to each vacuum degassing or continuous casting operation on site.

              NSPS-Stainless Steel Segment

              EPA proposes zero discharge of process wastewater pollutants to waters of the
United States as NSPS for the Stainless Steel Segment of the Non-Integrated Steelmaking and
Hot Forming Subcategory. The Agency has determined that zero discharge is demonstrated and
appropriate as NSPS for non-integrated Steelmaking and hot forming operations that are located
in any area of the United States and manufacture any product.  EPA has determined that there is
no barrier to entry for new sources to achieve this option; the wastewater treatment technologies
and water management practices necessary to achieve zero discharge can be designed and
implemented at new facilities.  See the description of NSPS for the Carbon and Alloy Steel
                                         14-29
-------
                                                                 Section 14 - Selected Options
                                                                             I
Segment of the Non-Integrated Steelmaking and Hot Forming Subcategory for more inforrnation
on the Agency's basis for selecting zero discharge as NSPS for this subcategory.       !

             PSES-Stainless Steel Segment

             The treatment technologies that form the basis for PSES for the Stainless Steel
Segment of the Non-Integrated Steelmaking and Hot Forming Subcategory are the same as the
BAT-1 model technologies; therefore, EPA has set proposed PSES limitations for the Stainless
Steel Segment equal to BAT-1 limitations. Application of this option would reduce current
annual wastewater flow by 85 percent and reduce total loadings of priority and nonconvjentional
pollutants by 20 percent.  The Agency has determined that this option provides controls [for
POTW pass-through pollutants and is economically achievable (application of this option would
cause no facility closures). As with BAT, the Agency proposes zero discharge of process
wastewater pollutants to POTWs as PSES for EAFs and ladle metallurgy operations in the
Stainless Steel Segment of the Non-Integrated Steelmaking and Hot Forming Subcategory.

             PSNS-Stainless Steel Segment

             EPA proposes zero discharge of process wastewater pollutants to waters of the
United States and POTWs as both NSPS and PSNS for the Stainless Steel Segment of the Non-
Integrated Steelmaking and Hot Forming Subcategory. The Agency has determined that there is
no barrier to entry for new sources to achieve this option; the wastewater treatment technologies
and water management practices necessary to achieve zero discharge can be designed arid
implemented at new facilities. See the description of NSPS for the Carbon and Alloy Steel
Segment of the Non-Integrated Steelmaking and Hot Forming Subcategory for more information
on the Agency's basis for selecting zero discharge as NSPS for this subcategory.       j
                                                                             I:
                                                                             t
14.3.6       Steel Finishing                                                  [
                                                                             !'
                                                                             s
             BAT-Carbon and Alloy Steel Segment                           i

             EPA is proposing BAT-1 for the Carbon and Alloy Steel Segment of the! Steel
Finishing Subcategory. BAT-1 model treatment consists of recycle of fume scrubber water,
countercurrent rinses, a diversion tank, oil removal, hexavalent chrome reduction (wherfc
applicable), equalization,  chemical precipitation for metals removal, clarification, and sliidge
dewatering. The application of BAT-1 would reduce current annual wastewater flow by 65
percent and reduce total loadings of priority and nonconventional pollutants by 25 percent. BAT-
1 would remove 22,410 toxic pound equivalents per year at an annualized compliance cpst of
$4.0 million (in 1997 dollars). The Agency has determined that BAT-1 is economically achievable
(Reference 14-2); application of this  option would cause no facility closures. The following tables
present proposed BAT limitations for the Carbon and Alloy Steel Segment of the Steel Finishing
Subcategory.                                                                  j
                                         14-30
-------
                                                                                    Section 14- Selected Options
                                        Steel Finishing Subcategory
              Maximum Daily BAT Limitations for Carbon and Alloy Steel Segment
.Process' Operation
(i) Acid pickling— hydrochloric
(A) Bar, billet, rod, coil
(B) Pipe, tube
(C) Plate
(D) Strip, sheet
(ii) Acid pickling-sulriiric
(A) Bar, billet, rod, coil
(B) Pipe, tube
(C) Plate
(D) Strip, sheet
(iii) Acid regeneration0
(A) Fume scrubbers
(iv) Alkaline cleaning
(A) Pipe, tube
(B) Strip, sheet
(v) Cold forming
(A) Direct application-single 'stand
(B) Direct application-multiple stands
(C) Recirculation-single stand
(D) Recirculation-multiple stands
(E) Combination-multiple stands •
(vi) Continuous annealing lines
(vii) Electroplating
(A) Plate
(B) Strip, sheet: tin, chromium
(C) Strip, sheet: zinc, other metals
(viii) Hot coating
(A) Galvanizing, terne, and other metals
(ix) Wet air pollution control devices3
(A) Fume scrubbers
BAT Effluent Limitations (Ibs/ton of product)"*
Maximum Daily
Cr*
0.0000508
0.000106
0.00000363
0.00000518
0.0000290
0.0000518
0.00000363
0.0000238
0.0149
0.00000207
0.0000363
0.000000311
0.0000285
, Q.0000'00104
0.00000259
0.0000148
0.00000207
0.00000363
0.000114
0.0000570
0.0000570
0.00224
Cr
0.000227
0.000472
0.0000162
0.0000231
0.000130 .
0.000231
0.0000162
0.000106
0.0666 .
0.00000925
0.000162
0.00000139
0.000127 '
0.000000463
0.0000116
0.0000662
0.00000925
0.0000162
0.000509
0.000255
0.000255
0.00999
Pb
0.000596
0.00124
0.0000426
0.0000609
0.000341
0.000609
0.0000426
0.000280
0.175
0.0000243
0.000426
0.00000365
0.000335
0.00000122
0.0000304
0.000174
0.0000243
0.0000426
0.00134
0.000669
0.000669
0.0263
Zn
0.000637
0.00133
0.0000455
0.0000650
0.000364
0.000650
0.0000455
0.000299
0.187
0.0000260
0.000455
0.00000390
0.000357
0.00000130
0.0000325
0.000186
0.0000260
0.0000455
0.00143
0.000715
0.000715
0.0281
  * - Hexavalent chromium.
Cr - Chromium.
Pb-Lead.
Zn-Zinc.
"Limitations for hexavalent chromium are applicable only when hexavalent chromium is present in untreated wastewater as a result of process or other
operations.                                        "         •
'Limitations for chromium are applicable only when chromium is present in untreated wastewater as a result of process or other operations.
limitations are in pounds per day.
                                                    14-31
-------
                                                                                  Section 14 - Selected Options
                                      Steel Finishing Subcategory
Maximum Monthly Average BAT Limitations for Carbon and Alloy Steel Segment
Process Operation
(i) Acid pickling— hydrochloric
(A) Bar, billet, rod, coil
(B) Pipe, tube
(C) Plate
(D) Strip, sheet
(ii) Acid pickling-sulfuric
(A) Bar, billet, rod, coil
(B) Pipe, tube .
(C) Plate
(D) Strip, sheet
(iii) Acid regeneration0
(A) Fume scrubbers
(iv) Alkaline cleaning
(A) Pipe, tube
(B) Strip, sheet
(v) Cold forming
(A) Direct application-single stand
(B) Direct application-multiple stands
(C) Recirculation-single stand
(D) Recirculation-multiple stands
(E) Combination-multiple stands
(vi) Continuous annealing lines
(vii) Electroplating
(A) Plate
(B) Strip, sheet tin, chromium
(C) Strip, sheet: zinc, other metals
(viii) Hot coating
(A) Galvanizing, terne, and other metals
(ix) Wet air pollution control devices0
(A) Fume scrubbers
BAT Effluent Limitations (Ibs/ton of product)"'1!
Maximum Monthly Average
Cr*
0.0000463
0.0000963
0.00000330
0.00000472
0.0000264
0.0000472
0.00000330
0.0000217
0.0136
0.00000189
0.0000330
0.000000283
0.0000260
0.0000000944
0.00000236
0.0000135
0.00000189
0.00000330
0.000104
0.0000519
0.0000519
0.00204
Cr2
0.000117
0.000243
0.00000834
0.0000119
0.0000668
0.000119
0.00000834
0.0000548
0.0343
0.00000477
0.0000834
0.000000715
0.0000656
0.000000238
0.00000596
0.0000341
0.00000477
0.00000834 .
0.000262
0.000131
0.000131
0.00515
Pb
0.000311
0.000647
0.0000222
0.0000317
0.000178
0.000317
0.0000222
0.000146
0.0913 .
0.0000127
0.000222
0.00000190
0.000174
0.000000634
0.0000159
0.0000907
0.0000127
0.0000222
0.000698
0.000349
0.000349
0.0137
Zn
0.000262
0.000546
0.00p0187
0.0000267
0.000150
0.000267
0.0000187
0.000123
0.0770
0.0000107
0.000187
0.00000160
0.000147
0.00000535
0.0000134
0.0000765
0.00p0107
0.0000187
0.000588
0.000294
0.000294
0.0116
Cr** - Hcxavalcnt chromium.
Cr-Chromium.
Pb-Lead.                                                                                           I
Zn - Zinc.                                                                                           |        .
"Limitations for hexavalent chromium are applicable only when hexavalent chromium is present in untreated wastewater as a result of process or other
operations.                         '                                                                 i
"Limitations for chromium are applicable only when chromium is present in untreated wastewater as a result of process or other operations.
"Limitations are in pounds per day.
                                                    14-32
-------
                                                                  Section 14 - Selected Options
              The permit authority may allow for increased mass discharges on a site-specific
basis to account for unregulated process wastewater and nonprocess wastewater (e.g., oily
wastewater from hot forming mill basements and roll shops, tramp oil from mill oil collection
systems, utility wastewater, and groundwater remediation wastewater) if these wastewater
streams are co-treated with wastewater regulated under the Steel Finishing Subcategory and
generate an increase in effluent volume.  Such increased mass discharges are to be calculated as a
percentage increase over the otherwise applicable mass discharge based on increased effluent
volume.                                                  .                          •

              NSPS-Carbon and Alloy Steel Segment

              The treatment technologies that form the basis for NSPS for the Carbon and Alloy
Steel Segment of the Steel Finishing Subcategory are the same as the BAT-1 model technologies;
therefore, EPA has set proposed NSPS limitations for the Carbon and Alloy Steel Segment equal
to BAT-1 limitations (see previous tables for BAT limitations). To ensure that the regulations for
new sources represent the most stringent numerical values attainable through the application of
the best available control technology for all pollutants, EPA is proposing NSPS limitations-for   .
two pollutants not regulated under BAT for the Carbon and Alloy Steel Segment of the Steel
Finishing Subcategory: TSS and O&G. The following table presents these additional limitations.

                    Steel Finishing—Carbon and Alloy Steel Segment
                         NSPS Limitations for TSS and O&Ga
Process Operation
(i) Acid pickling— hydrochloric
(A) Bar, billet, rod, coil -
(B) Pipe, tube
(C) Plate
(D) Strip, sheet
(ii) Acid pickling— sulfuric
(A) Bar, billet, rod, coil
(B) Pipe, tube
(C) Plate
(D) Strip, sheet
(iii) Acid regeneration11
(A) Fume scrubbers • - •
(iv) Alkaline cleaning
(A) Pipe, tube
(B) Strip, sheet-
New Source Performance Standards (Ibs/ton of product)
Oil and Grease (O&G)
Maximum
Daily
0.0307
0.0638
0.00219
0.00313
0.0175
0.0313
0.00219
0.0144
9.01
0.00125
0.0219
Maximum
Monthly
Average
0.0274
0.0571
0.00196
0.00280
0.0157
0.0280
0.00196
0.0129
8.07
0.00112
0.0196
Total Suspended Solids (TSS)
Maximum
Daily
0.0566
0.118
0.00405
0.00578
0.0324
0.0578
0.00405
0.0266
16.6
0.00231
0.0405
Maximum
Monthly
Average '
0.0308
0.0641
0.00220
0.00314
0.0176
0.0314
0.00220
0.0145
9.05
0.00126
0.0220
                                         14-33
-------
                                                                   Section 14 - Selected Options
Process Operation
(v) Cold forming
(A) Direct application-single stand
(B) Direct application-multiple stands
(C) Recirculation-single stand
(D) Recirculation-multiple stands
(E) Combination-multiple stands
(vi) Continuous annealing lines
(vii) Electroplating
(A) Plate
(B) Strip, sheet: tin, chromium
(C) Strip, sheet: zinc, other metals
(viii) Hot coating
(A) Galvanizing, terne, and other metals
(he) Wet air pollution control devices'1
(A} Fume scrubbers
New Source Performance Standards (Ibs/ton of product)
Oil and Grease (O&G)
Maximum
Daily
0.000188
0.0172
0.0000626
0.00156
0.00895
0.00125
0.00219
0.0688
0.0344
0.0344
1.35
Maximum
Monthly
Average
0.000168
0.0154
0.0000560
0.00140
0.00801
0.00112
0.00196
0.0616
0.0308
0.0308
1.21
Total Suspended Solids (TSS)
Maximum .
Daily
0.000347
0.0318
0.000116
0.00289
0.0165
0.00231
0.00405
0.127
0.0636
0.0636
2.50
Maximum
Monthly
Average
0.000189
0,0173
0.0000628
0:00157
0.00899
0.00126
0^00220
0.0691
0^0346
. 0.0346
1.36
•Proposed NSPS Limitations for the Carbon and Alloy Steel Segment of the Steel Finishing Subcategory include tne
BAT limitations presented in the previous tables in addition to these limitations for TSS and O&G.
••Limitations are in pounds per day.

              As with BAT, the permit authority may allow for increased mass discharges on a
site-specific basis to account for unregulated process wastewater and nonprocess wastewater if
these wastewater streams are co-treated with wastewater regulated under the Steel Finishing
Subcategory and generate an increase in effluent volume.

              PSES-Carbon and Alloy Steel Segment

              EPA is not proposing PSES limitations for the Carbon and Alloy Steel Segment of
the Steel Finishing Subcategory. As presented in the following table, EPA is recodifying 1982
PSES to fit the revised subcategorization and'segmentation of the proposed rule.  Under this
proposal, the PSES limitations in the 1982 Iron and Steel rule will continue to apply for all
manufacturing processes in this segment except electroplating.  PSES limitations for
electroplating are currently included in 40 CFR Part 433.  Unlike the limitations at 40 CFR Part
420, these limitations are concentration-based. To ensure a consistent basis for facilities
conducting electroplating in addition to other steel finishing operations, EPA is proposing to
convert the existing concentration-based  limitations at Part 433. into mass-based limitations by
multiplying the proposed BAT production normalized flow rate and the appropriate conversion
factor. Nine pollutants, some of which do not apply to electroplating operations at iron and steel
facilities, are regulated under PSES at Part 433. EPA proposes to specify PSES limitations for
                                          14-34
-------
                                                                 Section 14 - Selected Options
four of these pollutants: chromium, lead, nickel, and zinc; these four metals were identified as
pollutants of concern for electroplating manufacturing operations in Section 7.

             EPA evaluated PSES-1 model treatment for this segment; this model treatment is
the same as the model treatment for BAT-1. Although the application of PSES-1 would reduce
current annual wastewater flow by 30 percent and reduce total loadings of priority and
nonconventional pollutants by 10 percent, EPA has determined that nationally applicable PSES
are unnecessary at this time because the application of PSES-1 would result in an average annual
removal of only 12 toxic pound equivalents per facility.  These removals are much lower than
those achieved by other categorical pretreatment standards promulgated by EPA (see Section
14.3.4,footnote number 3, for more information).

                              Steel Finishing Subcategory
                 PSES Limitations for Carbon and Alloy Steel Segment
Process Operation
PoUutant
Pretreatment Standards for Existing Sources
(Ibs/ton of product)"
Maximum
Daily
Maximum
Monthly Average
Sulfuric acid pickling (spent acid solutions and rinse water)
Rod, wire, and coil
Bar, billet, and bloom
Strip, sheet, and plate
Pipe, tube, and other products
Lead
Zinc
Lead
Zinc
Lead
Zinc
Lead
Zinc
0.001052
0.001402
0.000338
0.000450
0.001052
0.001402
0.000384
0.00510
0.000350
0.000468
0.000.1126
0.0001502
0.000226
0.000300
0.000626
0.000834
Hydrochloric acid pickling (spent acid solutions and rinse water)
Rod, wire, and coil
Strip, sheet, and plate
Pipe, tube; and other products
Lead
Zinc
Lead
Zinc
Lead
Zinc
0.00184
0.00246
0.00384
0.00510
0.0000188
0.0000126
0.000614
0.000818
0.000350
0.000468
0.001276
0.001702
Cold rolling
Recirculation - single stand
Recirculation - multiple stands
Combination
Direct application - single stand
Direct application - multiple stands
Lead
Zinc
Lead
Zinc
Lead
Zinc
Lead
Zinc
Lead
Zinc
0.0000188
0.0000126
0.0000938
0.0000626
0.001126
0.000752
0.000338
0.000226
0.001502
0.001002
0.0000062
0.0000042
0.0000312
0.0000208
0.000376
0.000250
0.0001126
0.0000752
0.000500
0.000334
                                        14-35
-------
                                                                       Section 14 - Selected Options
Process Operation
Cold worked pipe and tube mills - using water
Cold worked pipe and tube mills - using oil
solutions
Electroplating1'
Pollutant
Lead
Zinc
Lead
Zinc
Chromium
Lead
Nickel
Zinc
Pretreatment Standards for Existing Sources
(Ibs/ton of product)"
Maximum
Daily
0.0000188
0.0000126
0.0000188
0.0000126
2.77
0.69
3.98
2.61
Maximum
Monthly Average
0.00,00062
O.OQ00042
0.0000062
0.0000042
1.71'
0.43
2.38
1.48,
Hot coating
Galvanizing, teine coating, and other coatings -
strip, sheet, and miscellaneous products
Galvanizing and other coatings j wire products
and fasteners
Sulfuric acid pickling line fume
scrubbers **
Hydrochloric acid pickling line fume
scrubbers &d
Acid regeneration
(absorber vent scrubbers) **
Hot coating line fume scrubbers 23
Cr*
Lead
Zinc
Cr*
Lead
Zinc
Lead
Zinc
Lead
Zinc
Lead
Zinc
Cr+6
Lead
7inc
0.000300
0.00226
0.00300
0.001202
0.00902
0.01202
0.0810
0.1080
0.0810
0.1080
0.539
0.719
0.01078
0.0810
0 1080
0.0001002
O.OOP752
0.001000
O.OOf)4QO
0.001300
O.OQ400
0.027 1
0.03161 .
0.0271
0.03,61
0.18,02
0.240
O.OQ3586
0.0271
0.0361
Cr**-Hcxavalcnt chromium.
The limitations for hexavalent chromium are applicable only to galvanizing operations that discharge wastewater from the chromate rinse step.
^Limitations are in milligrams per liter.                                                           :'
•Limitations are applicable to each fume scrubber associated with a process operation.                              i
'Limitations are in pounds per day.
               PSNS-Carbon and Alloy Steel Segment

               The treatment technologies that form the basis for PSNS for the Carbon land Alloy
Steel Segment of the Steel Finishing Subcategory are the same as the BAT-1 model tecfmologies;
therefore, EPA has set proposed PSNS limitations for the Carbon and Alloy Steel Segment equal
to BAT-1 limitations (see tables above for BAT limitations).                          [
                                                                                    i
               As with BAT, the permit authority may allow for increased mass discharges on a
site-specific basis to account for unregulated process wastewater and nonprocess waste^vater if
these wastewater streams are .co-treated with wastewater regulated under the Steel Finishing
Subcategory and generate an increase in effluent volume.
                                             14-36
-------
                                                                 Section 14 - Selected Options
              BAT-Stainless Steel Segment                                      .

              EPA is proposing BAT-1 for the Stainless Steel Segment of the Steel Finishing
Subcategory. BAT-1 model treatment consists of recycle 'of fume scrubber water, countercurrent
rinses, acid purification, a diversion tank, oil removal, hexavalent chrome reduction (where
applicable), equalization, chemical precipitation for metals removal, clarification, and sludge
dewatering.  The application of BAT-1 would reduce current annual wastewater flow by 47
percent and reduce total loadings of priority and nonconventional pollutants by 45 percent. BAT-
1 would remove 69,700 toxic pound equivalents at an annualized compliance cost of $0.2 million
(in 1997 dollars). The Agency has determined that BAT-1 is economically achievable (Reference
14-2); application of this option would cause no facility closures. The following tables present
proposed BAT limitations for the Stainless Steel Segment of the Steel Finishing Subcategory.

                              Steel Finishing Subcategory
              Maximum Daily BAT Limitations for Stainless Steel Segment
Process Operation
(i). Acid pickling and other descaling
(A) Bar, billet
(B) Pipe, tube .'
(C) Plate
(D) Strip, sheet
(ii) Acid regeneration"1
(A) Fume scrubbers
(iii) Alkaline cleaning
(A) Pipe, tube
(B) Strip, sheet
(iv) Cold forming
(A) Direct application-single stand
(B) direct application-multiple stands
(C) Recirculation-single stand
(D) Recirculation-multiple stands
(E) Combination-multiple stands
(v) Continuous annealing
BAT Limitations (Ibs/ton of product)5*
Maximum Daily
NH3C
0.0437
0.146
0.00665
0.133
' —
—

—
Cr-6
0.000318
0.00107
0.0000484
0.000969
0.199
0.0000277
0.00346
0.0000484
0.000381
0.00000415
0.0000221
0.000198
0.0000277
Cr
0.000500
0.00167
0.0000760
0.001.52
0.313
0.0000434
0.00543
0.0000760
0.000597
0.00000652
0.0000348
0.000311
0.0000434
F
0.0446
0.149
0.00679
0.136
—


—
Ni
0.000147
0.000494
0.0000224
0.000449
0.0923
0.0000128
0.00160
0.0000224
0.000176
0.00000192
0.0000103
0.0000917
0.0000128
                                        14-37
-------
                                                                                      Section 14 - Selected Options
Process Operation
(vi) Wet air pollution control devices*
(A) Fume scrubbers
BAT Limitations (Ibs/ton of product)"'" j
Maximum Daily
NH3C
4.10
Cr^
0.0299
Cr
0.0469 .
F
4.19

0

' Ni
.0138
NHj - Ammonia nitrogen.
Cr**-Hexavalent chromium.                          •                                                     !
Cr-Chromium.                                                                                         \
F-Fluoride.                                                                                 .           t
Ni-Nickel.                                                                                            f
•Limitations for hexavalent chromium are applicable only when hexavalent chromium is present in untreated wastewater as a result of process or other
operations.                                                                                             [
'Limitations for chromium are applicable only when chromium is present in untreated wastewater as a result of process or other operations.
'Between proposal and promulgation of the Iron and Steel rule, the Agency plans to .further evaluate the regulation of ammonia-N und|r the Stainless
Steel Segment of the Steel Finishing Subcategory.
'Limitations are in pounds per day.                                                                           i
                                        Steel Finishing Subcategory
           Maximum Monthly Average BAT Limitations for Stainless Steel Segment
Process Operation
(i) Acid pickling and other descaling
(A) Bar, billet
(B) Pipe, tube
(C) Plate
(D) Strip, sheet
(ii) Acid regenerationd
(A) Fume scrubbers
(iii) Alkaline cleaning
(A) Pipe, tube
(B) Strip, sheet
(iv) Cold forming
(A) Direct application-single stand
(B) Direct application-multiple stands
(C) Recirculation-single stand
(D) Recirculation-multiple stands
(E) Combination-multiple stands
(v) Continuous annealing
BAT Limitations (Ibs/ton of product)"'1"
Maximum Monthly Average
NH3C
0.0287
0.0960
0.00436
0.0873
—
—

—
Cr*
0.000196
0.000655
0.0000298
0.000595
0.122
0.0000170
0.00213
0.0000298
0.000234
0.00000255
0.0000136
0.000122
0.0000170
Cr
0.000280
0.000939
0.0000427
0.000854
0.176
0.0000244
0.00305
0.0000427
0.000335
0.00000366
0.0000195
0.000174
0.0000244
F
0.0356
0.119
0.00542
0.108
...
—

— . •
,. Ni
01000104
0:000347
0^0000158
0X100315
Oi0649
0^00000901
0[00113
0.0000158
01.000124
G'00000135
01.00000721
0|.0000644
0.00000901
                                                      14-38
-------
                                                                         Section 14 - Selected Options
Process Operation
(vi) Wet air pollution control devices'1
(A) Fume scrubbers
BAT Limitations (Ibs/ton of product)"-"
Maximum Monthly Average
NH3C
2.69
Cr+6
0.0184
•Cr
0.0263
F
3.34
Ni
0.00973
 NH3 - Ammonia nitrogen.
 Cr** - Hexavalent chromium.
 Cr-Chromium.
 'F-Fluoride.
 Ni-Nickel.              .                                           .      .
 'Limitations for hexavalent chromium are applicable only when hexavalent chromium is present in untreated wastewater as a result of process or other
 operations.
 'Limitations for chromium are applicable only when chromium is present in untreated wastewater as a result of process or other operations.
 'Between proposal and promulgation of the Iron and Steel rule, the Agency plans to further evaluate the regulation of ammonia-N under the Stainless
 Steel Segment of the Steel Finishing Subcategory.                                  .     •
 dLimitations are in pounds per day.                                            '

               The permit authority may allow for increased mass discharges on a site-specific
 basis to account for unregulated process wastewater and non-process wastewater (e.g., oily
 wastewater from hot forming mill basements and roll shops, tramp oil from mill oil collection
 systems, utility wastewater, and groundwater remediation wastewater) if these wastewater
 streams are co-treated with wastewater regulated.under the Steel Finishing Subcategory and
 cause an increase in effluent volume. Such increased mass discharges are to be calculated as a
percentage increase over the otherwise applicable mass discharge based on increased effluent
volume.

               NSPS-Stainless Steel Segment

               The treatment technologies that form the basis for NSPS for the Stainless Steel
Segment of the Steel Finishing Subcategory are the same as the BAT-1 model technologies;
therefore, EPA has set proposed NSPS limitations for the Stainless Steel Segment equal to BAT-
 1 Limitations (see previous tables for BAT limitations). To ensure that the regulations for new
sources represent the most stringent numerical values attainable through the application of the
best available control technology for all pollutants, EPA is proposing NSPS limitations for two
pollutants not regulated under BAT for the Stainless  Steel Segment of the Steel Finishing
Subcategory: TSS and O&G.  The following table presents these additional limitations.
                                             14-39
-------
Section 14 - Selected Options
Steel Finishing Subcategory— Stainless Steel Segment
NSPS Limitations for TSS and O&G"
i
Process Operation
(i) Acid pickling and other descaling
(A) Bar, billet
(B) Pipe, tube
(C) Plate
(D) Strip, sheet
(ii) Acid regenerationb
(A) Fume scrubbers
(iii) Alkaline cleaning
(A) Pipe, tube
(B) Strip, sheet
(iv) Cold forming
(A) Direct application-single stand
(B) Direct application-multiple stands
(C) Recirculation-single stand
(D) Recirculation-multiple stands
(E) Combination-multiple stands
(v) Continuous annealing
(vi) Wet air pollution control devices'1
(h\ purne scrubbers
New Source Performance Standards (Ibs/ton of product)
Oil and Grease (O&G)
Maximum
Daily
0.0172
. 0.0576
0.00262
0.0523
10.8
0.00149
0.187
0.00262
0.0206
0.000224
0.00120
0.0107
0.00149
1.61
Maximum
Monthly
Average
0.0136
0.0456
0.00207
0.0414
8.52
0.00118
0.148
0.00207
0.0163 .
0.000177
0.000947
0.00846
0.00118
1.28
Total Suspended Solids (TSS)
Maximum
Daily
0.0242
0.0809
0.00368
0.0735
15.1 .
0.00210
0.263
0.00368
0.0289
0.000315
0.00168
0.0150
0.00210
2.27
Maximum
Monthly
Average
0.0121
6.0406
0.00184'
0.0369
7.59 '
0.00105 ,
0.132
6.00184
0.0145
6.000158
6.000843
6.00754
0.00105
1.14
'Proposed NSPS Limitations for the Stainless Steel Segment of the Steel Finishing Subcategory include me BAI limitations j
tables in addition to these limitations for TSS and O&G.            .                                   j
'Limitations are in pounds per day.                                                      '      f

              As with BAT, the permit authority may allow for increased mass discharges on a
site-specific basis to account for unregulated process wastewater and nonprocess wastewater if
these wastewater streams are co-treated with wastewater regulated under the Steel Finishing
Subcategory and generate an increase in effluent volume.                            •

              PSES-Stainless Steel Segment

              EPA is not proposing PSES limitations for the Stainless Steel Segment of the Steel
Finishing Subcategory.  As presented in the following table, EPA is re-codifying 1982 PSES to fit
the revised subcategorization.and segmentation of the proposed rule.                 j,

              EPA evaluated PSES-1  model treatment for the Stainless Steel Segment of the
Steel Finishing Subcategory; this model treatment is the same as the model treatment for BAT-1.
                                           14-40
-------
                                                                  Section 14 - Selected Options
The application of PSES-1 would reduce current annual wastewater flow by 23 percent and
reduce total loadings of priority and nonconventional pollutants by 10 percent.  However, 548 of
the 653 total annual toxic pound equivalents that would be removed through PSES-1 are
attributable to one parameter—fluoride--from one iron and steel facility. Without considering this
parameter, the annual per-facility pollutant removal through PSES-1 drops from 46 to only 7
toxic pound equivalents.  This removal is much lower than those achieved by other categorical
pretreatment standards promulgated by EPA (see Section 14.3.4, footnote number 3, for more
information).  Consequently, EPA has determined that it would be more appropriate for the
pretreatment control authority for that facility to control pollutant release through its pretreatment
control mechanism than for the Agency to implement a national pretreatment standard.

                              Steel Finishing Subcategory
                      PSES Limitations for Stainless Steel Segment
Process Operation
Pollutant
Pretreatment Standards for Existing Sources
(Ibs/ton of product)
Maximum
Daily
Maximum
Monthly Average
Salt bath descaling - oxidizing •'..--
Batch - sheet and plate
Batch - rod and wire
Batch - pipe and tube • •
Continuous
Chromium
Nickel
Chromium
Nickel
Chromium
Nickel
Chromium
Nickel
0.00584
0.00526
0.00350
0.00316
0.01418
0.01276
0.00276
0.00248
0.00234
0.001752
0.001402
0.001052 .
0.00568
0.00426
0.001102
0.000826
Salt bath descaling - reducing
Batch ,
Continuous
Chromium
Nickel
Chromium
Nickel
0.00204
0.00244
0.01138
0.01366
0.000678
0.000814
0.0038
0.00456
                                        14-41
-------
                                                                                             Section 14 - Selected Options
Process Operation
Pollutant
Pretreatment Standards for Existing Sources
(Ibs/ton of product)
Maximum
Daily
Maximum
Monthly Average
Combination acid pickling (spent acid solutions and rinse water)
Rod, wire, and coil
Bar, billet, and bloom
Strip, sheet, and plate - continuous
Strip, sheet, and plate - batch
Pipe, tube, and other products
Chromium
Nickel
Chromium
Nickel
Chromium
Nickel
Chromium
Nickel
Chromium
Nickel
0.00426
0.00384
0.001920
0.001728
0.01252
0.01126
0.00384
0.00346
0.00644
0.00578
0.00^704
0.00^276
O.OOJ)768
0.00<)576
0.00500
0.00376 .
0.001536
0.001152 .
0.00258
0.001928
Cold rolling
Recirculation - single stand
Recirculation - multiple stands
Combination
Direct application - single stand
Direct application - multiple stands
Cold worked pipe and tube mills - using water
Cold worked pipe and tube mills -
using oil solutions
Fume scrubber "J>
Chromium
Nickel
Chromium
Nickel .
Chromium
Nickel
Chromium
Nickel
Chromium
Nickel
Chromium
Nickel
Chromium
Nickel
Chromium
Nickel
0.0000418
0.0000376
0.000208
0.00018.78
0.00250
0.00226
0.000752
0.000676
0.00334
0.0030
0.0000418
0.0000376
0.0000418
0.0000376
0.1802
0.1617
0.00000168
0.0000126
0.0000836
. . 0.00(30626
0.00 i 002
0.000752
0.006300 •
0.000226
0.001336
0.001002
0.0000168
0.0000126
0.0000168
0.0000126
0.0719
0.0539
'Limitations arc applicable to each fume scrubber associated with a process operation.
'Limitations are in pounds per day.
                                                           14-42
-------
                                                                 Section 14 - Selected Options
              PSNS-Stainless Steel Segment

              The treatment technologies that form the basis for PSNS for the Stainless Steel
 Segment of the Steel Finishing Subcategory are the same as the BAT-1 model technologies;
 therefore, EPA has set proposed PSNS limitations for the Stainless Steel Segment of the Steel
 Finishing Subcategory equal to BAT-1 limitations (see tables above for BAT limitations). As with
 BAT, the permit authority may allow for.increased ma'ss discharges on a site-specific basis to
 account for unregulated process'wastewater and nonprocess wastewater if these wastewater. ,
 streams are co-treated with wastewater regulated under the Steel Finishing Subcategory and
 generate an increase in effluent volume.

 14.3.7        Other Operations

              BAT~Direct Reduced Ironmaking Segment

              EPA is reserving BAT limitations  for the Direct Reduced Ironmaking Segment of
 the Other Operations Subcategory because the Agency has identified no priority or
 nonconventional pollutants of concern for this segment.

              NSPS—Direct Reduced Ironmaking Segment

              The treatment technologies that form the basis for NSPS for the Direct Reduced
 Ironmaking Segment of the Other Operations Subcategory are the same as the BPT-1 model
 treatment technologies for this segment, which consist of solids removal, sludge dewatering, a
 cooling tower, high-rate recycle, and treatment of blowdown with multimedia filtration. The
 following table presents the proposed NSPS limitations.

                             Other Operations Subcategory
               NSPS Limitations for Direct Reduced Ironmaking Segment
Pollutant
Total suspended solids (TSS)
New Source Performance Standards
(Ibs/ton of product)
Maximum Daily
0.0200
Maximum Monthly Average
0.00929
             PSES-Direct Reduced Ironmaking Segment

             EPA is reserving PSES limitations for the Direct Reduced Ironmaking Segment of
the Other Operations Subcategory because the Agency has identified no POTW pass-through
pollutants for this segment.
                                        14-43
-------
                                                               Section 14 - Selected Options
             PSNS—Direct Reduced Ironmaking Segment
                                                                           I
             EPA is reserving PSNS limitations for the Direct Reduced Ironmaking Segment of
the Other Operations Subcategory because the Agency has identified no POTW pass-thrjough
pollutants for this segment.                                                    '

             BAT-Forging Segment                                         '

             EPA is reserving BAT limitations for the Forging Segment of the Other Operations
Subcategory because the Agency has identified no priority or nonconventional pollutants of
concern for this segment.

             NSPS-Forging Segment

             The treatment technologies that form the basis for NSPS for the Forging [Segment
of the Other Operations Subcategory. are the same as the BPT-1 model treatment technologies for
this segment, which are based on high rate recycle and oiVwater separation. The following table
presents the proposed NSPS limitations.                                         !

                            Other Operations Subcategory
                        NSPS Limitations for Forging Segment
Pollutant
Oil and grease (O&G)
Total suspended solids (TSS)
New Source Performance Standards
(Ibs/ton of product)
Maximum Daily
0.0149
0.0235
Maximum Monthly Average
0.00889 ;,
0.0118

             PSES-Forging Segment

             EPA is reserving PSES limitations for the Forging Segment of the Other |
Operations Subcategory because the Agency has identified no POTW pass-through pollutants for
this segment                                                                [•

             PSNS-Forging Segment                                        i
                                                                           i
             EPA is reserving PSNS limitations for the Forging Segment of the Other [
Operations Subcategory because the Agency has identified no POTW pass-through pollutants for
this segment.
                                        14-44
-------
                                                               Section 14 - Selected Options
             BAT/NSPS/PSES/PSNS-Briquetting Segment

             EPA proposes zero discharge of process wastewater pollutants to waters of the
U.S. and POTWs as BAT, NSPS, PSES, and PSNS for the Briquetting Segment of the Other
Operations Subcategory.
14.4
14-1.
14-2.
14-3.
References

U.S. Environmental Protection Agency. Development Document for Effluent
Guidelines and Standards for the Iron and Steel Manufacturing Point Source
Category. EPA/440/1-82/024. Washington, D.C., May 1982, Volume I,
Table 1-1, pp. 13 to 17.

U.S. Environmental Protection Agency. Economic Analysis of the Proposed
Effluent Limitations Guidelines and Standards for the Iron and Steel
Manufacturing Point Source Category. EPA 821-B-00-009. Washington, D.C.,
December 2000.

Statement of Senator Muskie (Oct. 4, 1972), reprinted in A Legislative History of
the Water Pollution Control Act Amendments of 1972 r"1972 Leg.'Hist."). 170.
                                       14-45
-------
                                           Section 14-Selected Options
                    Table 14-1

Limitations for Best Practicable Control Technology
    Currently Available (BPT) Under 1982 Rule
Subcategory
Cokemaking
Ironmaking
Integrated
SteeLmaking
Process Wastewater Source
By-product cokemaking
(iron and steel coke plants)1" :
By-product cokemaking
(Merchant coke plants)0
Non-recovery cokemaking
Sintering operations
(with wet air pollution controls)
Blast furnaces
Sintering operations
(with dry air pollution controls)
Basic oxygen furnaces
(1) Semi-wet air pollution control11
(2) Wet-open combustion
(3) Wet-suppressed combustion
Vacuum degassing
Continuous casting
Ladle metallurgy
Pollutant
O&G
TSS
O&G
TSS
d
O&G
TSS
O&G
TSS
d
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
(d)
Maximum
daily3
0.0654
0.506
0.0698
0.540
d
0.0300
0.150
0.156
d
0.137
0.0624
0.0312
0.0468
0.156
(d)
Maximum
Monthly
Average"
! 0.0218
0.262
0.0232
0.280
d
0.0100
0.050
0.0520
d
0.0458
0.0208
; 0.0104
0.0156
0.052
; (d)
                      14-46
-------
                                 Section 14 - Selected Options
Table 14-1 (Continued)
Subcategory
Integrated and
Stand-Alone
Hot Forming .
Npnintegrated
Steelniaking and
Hot Forming

Process Wastewater Source
Primary mills, carbon and specialty
(1) Without scarfing
(2) With scarfing
Section mills, carbon and specialty
(1) Carbon
(2) Specialty
Flat mills
(1) Hot strip and sheet, carbon and specialty
Plate mills
(1) Carbon
(2) Specialty
Pipe and tube mills, carbon and specialty
Electric arc furnaces
Vacuum degassing
Continuous casting
Hot forming mills
Ladle metallurgy
Pollutant
O&G
TSS
O&G
TSS.
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
(e)
O&G
TSS
O&G
.TSS
O&G
TSS
(d)
Maximum
daily"
0.0748
0.300
0.442
0.111
0.179
0.714
0.112
0.448
0.214
0.854
0.114
0.454
0.0500
0.200
0.106
0.424
(e)
0.0312
0.0468
0.156
0.0748
0.300
(d)
Maximum
Monthly
Average2
0.112
0.166
0.268
0.128
0.320
0.170
0.0752
0.159
(e)
0.0104
0.0156
0.052
0.11-2
(d)
         14-47
-------
                                 Section 14 - Selected Options
Table 14-1 (Continued)
Subcategory
Steel Finishing









Process Wastewater Source
Salt bath descaling-oxidizing
(1) Batch, sheet and plate
(2) Batch, rod
(3) Batch, pipe arid tubes
(4) Continuous
Salt bath descaling-reducing
(1) Batch
(2) Continuous
Acid pickling-sulfuric
(1) Rod, coil
(2) Bar, billet, bloom
(3) Strip,' sheet and plate
(4) Pipe, tubes and other products
Acid pickling-hydrochloric
(1) Rod, coil
(2) Strip, sheet and plate
(3) Pipe, tubes and other products
Pollutant
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
Maximum
daily3
NA
0.408
NA
0.246
NA
0.992
NA
0.193
NA
0.190
NA
1.06
0.0700
0.164
0.0226
0.0526
0.0450
0.105 .
0.125
0.292
0.123
0.286
0.0700
.0.164
0.256
0.596
Maximum
Monthly
Average*
NA
0.175
NA
0.105
NA
0.426
NA
0.0826
NA '
0.0814
NA ,
0.456
10.0234
0.070
0.00750
0.0226
0.0150
; 0.045
0.0418
0.12.5
0.0408
0.123
0.0234
0.070
0.0852
0.256
          14-48
-------
                                 Section 14 - Selected Options
Table 14-1 (Continued)


Subcategory
Steel Finishing
(cont.)
































Process Wastewater Source
Acid pickling-combination
(1) Rod, coil

(2) Bar, billet, bloom

(3) Strip, sheet and plate-continuous

(4) Strip, sheet and plate-batch

(5) Pipe, tubes and other products

Cold rolling mills
(1) Recirculation-single stand

(2) Recirculation-multiple stands

(3) Combination

(4) Direct application-single stand

(5) Direct application-multiple stands

Alkaline cleaning
(1) Batch

(2) Continuous

Hot coating: galvanizing, teme, other metals
(1) Strip, sheet and miscellaneous products

Electroplating .



Pollutant

O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS

O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS
O&G
TSS

O&G
TSS
O&G
TSS

O&G
TSS
O&G
TSS

Maximum
daily"

0.128
0.298
0.0576
0.134
0.376
0.876
0.115
0.268
0.193
0.450

0.00104
0.0025
0.0522
0.0125
0.0626
0.150
0.0188
0.045
0.0834
0.200

0.0626
0.146
0.0876
0.204

0.150
0.350
52f
60f
Maximum
Monthly
Average"

0.0426
0.128
0.0192
0.0576
0.125 '
0.376
0.0384
0.115-
0.0644
0.193

0.000418
0.00125
0.00208
0.00626
0.0250
• 0.0752
0.00752
0.0226
0.0334
0.100

0.0208
0.0626
'0.0292
0.0876

0.0500
0.150
26f
31f
         14-49
-------
Section 14 - Sele
Table 14-1 (Continued)
Subcategory
Steel Finishing
(cent.)

Process Wastewater Source
Fume scrubbers: acid pickling, alkaline
cleaning, hot coating, other
Absorber vent scrubber: hydrochloric acid
regeneration
Pollutant
O&G
TSS
O&G
TSS
Maximum
daily0
5.39s
12.58s
35.86s'
84.04s
-.ted Options

Maximum
Monthly
Average"

1.76s
5.39s
11.99s
35.86s
Sources: 40 CFR Part 420 and Part 433.          '                                                                        >'
O&G - Oil and grease.                                                                                                  ;
TSS-Total suspended solids.                                                                                            ;
NA-Not applicable.                                                                                                    |  •
                                                                                                                      i,
•Pounds per ton of product.                                                                                              |
'For iron and steel coke plants, increased loadings, not to exceed 11 percent of the above limitations, shall be provided for process wastewaters from
wet desulfurization systems, but only to the extent such systems generate process wastewaters.                                    ,'
Tor merchant coke plants, increased loadings, not to exceed 10 per cent of the above limitations, shall be provided for process wastewaters from wet
desulfurization systems, but only to the extent such systems generate process wastewaters.              '                          |
'For these segments, except as provided in 40 CFR 125.30 through 125.32, any existing point source must have no discharge of process wastewater
pollutants to waters of the United States.
'1982 regulation allowed for no discharge of process wastewater from this operation.
'Limitations transferred from 40 CFR Part 433 and expressed in milligrams per liter.
'Values are expressed in pounds per day for this operation.
                                                               14-50
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                                                 Section 15 - Implementation of Part 420_ through the
                                                             NPDES and Pretreatment Programs
                                      SECTION 15

              IMPLEMENTATION OF PART 420 THROUGH THE NPDES
                         AND PRETREATMENT PROGRAMS

              Sections 301, 304, 306 and 307 of the Clean Water Act (CWA) provide that EPA
 must promulgate national effluent limitations guidelines and standards of performance for major
 industrial categories for three classes of pollutants:

              • ,    Conventional pollutants, which include total suspended solids (TSS), oil
      -  •  •           and grease (O&G), biochemical oxygen demand (BOD5), fecal coliform,
                     andpH;                                    .

              •      Designated priority pollutants (e.g., toxic metals such as chromium, lead,
                     nickel, and zinc; toxic organic constituents such as benzene, benzo-a-
                     pyrene, and naphthalene); and

              •      Nonconventional pollutants, which are designated as neither conventional
                     nor priority pollutants (e.g., ammonia as nitrogen, thiocyanate, fluoride,
                     iron, and 2,3,7,8-tetrachlorodibenzofuran (TCDF)).

              40 CFR Part 420, as well as other categorical effluent regulations promulgated by
EPA, contains six types of effluent limitations guidelines and standards:

              •       Best Practicable Control Technology Currently Available (BPT);
                     Best Control Technology for Conventional Pollutants (BCT);
              •       Best Available Technology Economically Achievable (BAT);
              «       New Source Performance Standards (NSPS);
              «      Pretreatment Standards for Existing Sources (PSES); and
              •       Pretreatment Standards for New Sources (PSNS).

              BPT, BCT, BAT, and NSPS limitations regulate only those sources that discharge
effluent directly into waters of the United States. PSES and PSNS limitations restrict pollutant
discharges for those sources that discharge indirectly through sewers flowing to publicly owned
treatment works (POTWs).
15.1
NPDES Permit Program
             Section 402 of the CWA establishes the National Pollutant Discharge Elimination
System (NPDES) permit program. The NPDES permit program is designed to limit the discharge
of pollutants into navigable waters of the United States through a combination of various
requirements, including technology-based and water-quality-based effluent limitations.' The
proposed Iron and Steel regulation contains the categorical technology-based effluent limitations
guidelines and standards applicable to the iron and steel industry to be used by permit writers to
                                         15-1
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                                                Section 15 - Implementation of Part 420 through the
                                               ^	NPDES and Pretreatment Programs
                                                                             {r
derive NPDES permit technology-based effluent limitations.  Water-quality-based effluent
limitations (WQBELs) are based on receiving water characteristics, designated water usps, and
ambient water quality standards. WQBELs are derived independently from the technology-based
effluent limitations set out in Part 420. The CWA requires NPDES permits to contain the more
stringent of the technology-based and the water-quality-based effluent limitations applicable to a
given discharge.

             Section 402(a)(l) of the CWA provides that, in the absence of promulgated
effluent limitations guidelines or standards, the Administrator or the Administrator's designee,
including designated state permit authorities, may establish effluent limitations for specific
dischargers on a case-by-case basis. Federal NPDES permit regulations provide that these limits
may be established using "best professional judgement" (BPJ), taking into account any proposed
effluent limitations guidelines and standards and other relevant scientific, technical, and economic
information.  Where EPA has promulgated technology-based effluent limitations guidelines and
standards, any more stringent effluent limitations must be either WQBELs or technology-based
effluent limitations derived under regulations established independently by the permit authority.

             Section 301 of the CWA, as amended by the Water Quality Act of 1987, required
that BPT effluent limitations were to be achieved by July 1,1977.  BAT effluent limitations for
priority and nonconventional pollutants and BCT effluent limitations for conventional pollutants
were to be achieved as expeditiously as possible, but not later than three years from date of
promulgation, and in no case later than March 31, 1989 (see  § 125.3).  Because EPA will
promulgate revisions to Part 420 after March 31, 1989 (after the statutory BAT compliance date
for priority pollutants), effluent limitations based on the revised effluent limitations guidelines
must be included in the next NPDES permits issued after promulgation of the regulation with no
compliance schedule.                                                 '          |  '

             The NPDES permit program defines major dischargers as those that, by nature of
their size and operations, can have a significant impact on human health or the environment. EPA
classified most direct dischargers in the iron and steel industry as major dischargers because they
are relatively large industrial complexes that have caused or have the potential to cause adverse
water quality impacts'. NPDES permits for major dischargers are issued and renewed according
to the federal NPDES regulations as well as regulations enacted by permit authorities to;maximize
opportunity for public review and comment. Chapter 11 of the U.S. EPA NPDES Permit
Writer's Manual (Reference 15-1) discusses the administrative process for drafting and issuing
NPDES permits, including preparation of the draft permit and fact sheet,  construction of the
administrative record, notification of the public, consideration of public comments, and issuance
of the final permit. The NPDES permit fact sheet or statement of basis sets out the regulatory and
technical bases for the terms and conditions in the permit.

             The NPDES permit regulations allow modification of permit effluent limitations
derived from the effluent limitations guidelines through the following specific variances :and other
procedures:                       ,                                                  '
                                          15-2
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                                                 'Section 1-5 - Implementation of Part 420 through the
                                                           • NPDES and Pretreatment Programs
              •      Section 30 l(c), economic variance from BAT;

              •      Section 301(g), water-quality-related variance from BAT for
                     nonconventipnal pollutants;

              •      Section 316(a), thermal variance from BPT, BCT, and BAT;

                     Fundamentally different factors variance (40 CFR Part 125, Subpart D);
                     and

                     Net credits (40 CFR Part  122.45(g)).

              Although EPA has not promulgated final regulations that establish criteria for
applying for and evaluating applications for Section 301(c) and 301(g) variances, the Agency has
published guidance materials for permit authorities regarding such variances. • Variances under
Section 316(a) for thermal discharges are not at issue in the 1982 regulation or the proposed
regulation because EPA has not promulgated or proposed effluent limitations guidelines and
standards for thermal discharges. See the sections below, the guidance materials, and 40 CFR
Part 125 for further information regarding the above-listed variances.

              The NPDES permit regulations at 40 CFR Part 125, Subpart K, establish criteria
and standards for Best Management Practices (BMPs), which are authorized under Section
304(e) of the CWA.  BMPs may be included in effluent limitations guidelines and standards  or
established on a case-by-case basis by permit authorities in individual NPDES permits.  BMPs are
designed typically to control discharges of pollutants from activities that are ancillary to the
manufacturing operations regulated by the numerical effluent limitations guidelines and standards
(e.g., EPA is not proposing BMPs, but provides in this section examples of BMPs that permit
writers can include in NPDES permits under appropriate circumstances.
15.2
objectives:
National Pretreatmemt Standards

40 CFR Part 403 sets out national pretreatment standards that have three principal
                    To prevent the introduction of pollutants that will interfere with POTW
                    operations, including the use or disposal of municipal sludge;

                    To prevent the introduction of pollutants that will pass through POTWs or
                    otherwise be incompatible with POTWs; and

                    To improve opportunities to recycle and reclaim municipal and industrial
                    wastewater and sludge.
                                         15-3
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                                                 Section 15 - Implementation of Part 420{ through the
                                                             NPDES and Pretreatment Programs
              The national pretreatment standards prohibit certain discharges that interfere with
POTW operations, and include federal categorical pretreatment standards designed to prevent
pass-through of pollutants introduced into POTWs by industrial sources. Part 420 sets put the
federal categorical pretreatment standards applicable to the iron and steel industry. Local control
authorities are required to implement the national pretreatment program, which includes: applying
federal categorical pretreatment standards to industrial users that are subject to those standards
and any local pretreatment standards that may be more restrictive than the federal categorical
standards. The proposed regulation revises the federal categorical pretreatment standards
applicable to iron and steel facilities regulated by Part 420. Facilities must meet effluent
limitations based on the federal categorical pretreatment standards not later than three years after
promulgation of the standards.                                                   ;
15.3
NPDES Permit and Pretreatment Production Rates
              The effluent limitations guidelines and standards for BPT, BAT, NSPS, PSES, and
PSNS in the proposed regulation are expressed as mass limitations in pounds/ton of product.
Each mass limitation is calculated by multiplying an effluent concentration (determined from the
analysis of treatment system performance) by a model flow rate appropriate for each sub^category,
expressed in gallons/ton of product or gallons/day. The production-normalized flow rates used to
develop many of the limitations in the proposed rule are considerably lower than those used to
develop limitations in the 1982 rule. Consequently, many of the proposed limitations are more
stringent than the 1982 limitations for the same operations, even though other components of the
technology options remain the same. The proposed limitations do not require facilities to install
any specific control technology or achieve any specific flow rate or effluent concentratiojn;
facilities can use various treatment alternatives or water conservation practices to meet the
limitations or standards.  Each model treatment system described in-Section 8 illustrates! at least
one means available to achieve the proposed effluent limitations guidelines and standards.

              The NPDES regulations at §122.45(f) require that NPDES permit effluent
limitations be specified as mass effluent limitations (e.g.', pounds/day or kilograms/day), 'except
under certain circumstances that do not apply to the proposed rule. To convert the proposed
effluent limitations (pounds/ton) to a monthly average or daily maximum permit limit, the
permitting authority would use a production rate with units of tons/day. The 1982 iron and steel
rule and Part 122.45(b)(2) of the NPDES permit regulations require that NPDES permit and
pretreatment limits be based on a "...reasonable measure of actual production." NPDES permits
for this industry have commonly used either the highest annual average production over the prior
five years prorated to a daily basis or the highest monthly production over the prior five years
prorated to a daily basis. Industry stakeholders have requested that: (1) EPA should specify the
method used to determine appropriate production rates for calculating allowable mass loadings,
so all permit writers use the same basis; and (2) EPA should use a high production basis, such as
the maximum monthly production over the prior five years or the maximum design production, to
ensure that facilities will not be out of compliance during periods of high production.
                                          15-4
-------
                                                  'Section 15 - Implementation of Part 420 through the
                                                              NPDES and Pretreatment Programs
              The NPDES permit regulations at 40 CFR 122.45(b)(2)(I) require that mass
 effluent limitations calculated for existing sources from production-based effluent limitations
 guidelines and standards must be based not on production capacity but on a "reasonable measure
 of actual production."  The 1982 iron and steel regulation at 40 CFR 420.04 sets out the basis for
 calculating mass-based pretreatment requirements and also dictates that pretreatment
 requirements must be based on a reasonable measure of actual production. The 1982 regulation
 provides the following examples of what may constitute a reasonable measure of actual
 production: the monthly average for the highest of the previous five years or the high month of
 the previous year.  Both values are converted to a daily basis (i.e., tons/day) to calculate monthly
 average and daily maximum mass permit effluent limitations. The national pretreatment
 regulations at 40 CFR 403.6(c)(3) have similar provisions for deriving mass-based pretreatment
 requirements.

              The above regulations require that effluent limitations guidelines and pretreatment
 standards for new sources be based on projected production. EPA is proposing that approach in
 the proposed iron and steel regulation.

              EPA believes that some NPDES and pretreatment permit production rates have
 not been calculated using a "reasonable measure of actual production."  In some cases, maximum
 production rates for similar process units discharging to one treatment system have been
 determined from different years or months. In EPA's view, this approach may provide an
 unrealistically high measure of actual production if the different process units could not
 reasonably produce at these high rates simultaneously.

              Ideally, permit writers would apply production-based effluent limitations-guidelines
 and standards using relatively constant production from day to day or month to month.  In this
 situation, the production rate used to calculate the permit limitations would then be the average
 rate. However, production rates in the iron and steel industry vary significantly over time
 (especially over a 5-year permit period), based on factors such as fluctuations in market demand
 for domestic products, maintenance, product changes, equipment failures, and facility
 modifications.

              To determine a production estimate for a mill, permit writers should develop a
reasonable measure of production for the facility during the next term of the permit. The permit
writer uses this production estimate along with the production-based limitations to establish a
maximum mass of pollutant that the facility may discharge each day and month. However, if the
permit production rate is based on the maximum month, the permit could allow excessive
pollutant discharges during the permit period. As a result, facilities may not have an incentive to
implement optimal waste management, water conservation, and wastewater treatment practices
during lower production periods.  On the other hand, if the permit production rate is based on  an
average of the highest year of production over the prior five years, facilities may have trouble
ensuring that their waste management, water conservation, and wastewater treatment practices
can accommodate shorter periods of higher production.  This situation might require facilities to
meet, during these periods of high production, a more stringent treatment level than that on which
                                          15-5
-------
                                                 Section 15 - Implementation of Part 420 through the
                                                    '	•  NPDES and Pretreatment Programs
the limits were based. To do this, facilities would likely have to develop more efficient treatment
systems, greater hydraulic surge capacity, and better water conservation and waste management
practices.                                                  .                     !
15.3.1
Alternatives for Establishing Permit Effluent Limitations
              EPA has solicited comment on several alternative approaches to establishing
permit limits; these approaches may result in more stringent mass-based permit limits for some
facilities (with better protection of the environment over the life of a permit) and may ressult in
higher costs. Each approach excludes production from unit operations that do riot generate or
discharge process wastewater.                                                  .   I
                                                                                i
              Alternative A
                                                                                i

              The approach under Alternative A is the basis for the proposed iron and steel
effluent limitations. This approach retains the essential requirements of the 1982 rule as[described
above (see §420.3). However, the proposed rule provides additional instructions for avoiding
approaches that result in unrealistically high estimates of actual production by considering only    .
the production from all production units that could operate simultaneously (see  §420.3(c)).  -
Alternative A may result in higher costs for those facilities whose permits are based on production
levels that are higher than those that could occur simultaneously at multiple process units.
However, EPA included these costs in the economic analysis for the 1982 regulation as jvell as
the proposed rule.                                                                {•

              Alternative B

              Under Alternative B, the Agency is considering requiring the permit writer to
establish multitiered permit limits.  Permit writers and control authorities currently use EiPJ to
establish multitiered permit limits.  The Agency has issued guidance for use in considering   .
multitiered permits (see Chapter 5 of the U.S. EPA NPDES Permit Writer's Manual and Chapter
7 of the Industrial User Permitting Guidance Manual (References 15-1 and 15-2)).     \
                                                                                \
              In situations where a single set of effluent limitations is not appropriate for the
entire period of a permit, permit writers may establish a tiered permit One set of limits would
apply for periods of average production, and other sets of limits would apply when the average
production rate significantly changes. EPA believes that a 10 to 15  percent deviation above or
below the long-term average production rate falls within the range of normal variability.j For
facilities that have predictable changes hi long-term production that  fall outside of this range,
permit writers should consider establishing a tiered or multitiered permit.  The iron and steel
industry has a variable historical production rate, and the permit modification process is pot fast
enough to respond to the need for higher or lower equivalent limits.  For example, many iron and
steel mills have a characteristic historical average monthly production rate that varies between 60
and 95 percent of plant capacity (note that for a mill operating at  60 percent of capacity! a
production increase to 95 percent of capacity would represent a nearly 60 percent increase in
                                           15-6
-------
                                                  Section 15 - Implementation of Part 420 through the
                                                              NPDES and Pretreatment Programs
 production). In this example, permit writers may establish alternate effluent limitations for
 average production rates at 75 and 95 percent of capacity.

               Alternative C

               Under Alternative C, EPA is considering revising the definition of production to
 provide a basis for deriving NPDES and pretreatment permit production rates that are "reasonable
 measures of actual production" and that can be applied consistently for iron and steel facilities
 subject to Part 420. The modified definition of the NPDES and pretreatment permit production
 basis would be the average daily operating rate for the year with the highest annual production
 over the prior five years, taking into account the annual hours of operation of the production unit
 and the typical operating schedule of the production unit, as illustrated by the following example.
Highest annual production from prior five years
Operating hours
Hourly operating rate
Average daily operating rate (24 hour day)
3,570,000
8,400
425
10,200
tons
hours
tons/hour
tons/day
              The above example is for a process unit that is typically operated 24 hours per day
with short-term outages for maintenance on a weekly or monthly basis.  For steel processing
facilities that Operate typically less than 24 hours per day, the average daily operating rate must be
based on the typical operating schedule (e.g., 8 hours per day for a facility operating one 8-hour
turn (or shift) per day; 16 hours per day for a facility operating two 8-hour turns per day), as
shown below.                 .
Highest annual production from prior five years
Operating hours
Hourly operating rate
Average daily operating rate (1 6-hour day)
980,000
4,160
235.6"
3,769
tons
hours
tons/hour
tons/day
              EPA recognizes that the approach in the above example could cause problems for
a facility that operated 16 hours/day at the time the permit was issued and then changed to a
24-hour/day schedule based on unforseen changes in market conditions. To address these
potential problems, facilities could combine this approach with the tiered permit approach under
Alternative B.

              For multiple similar process units discharging to the same wastewater treatment
system with one NPDES or pretreatment permit compliance point (e.g., two blast furnaces
operated with one treatment and recycle system for process wastewater), the permit writer'would
base the year with the highest annual production over the prior five years on the sum of annual   '
                                           15-7
-------
                                                 Section 15 - Implementation of Part 420 through the
                                                	NPDES and Pretreatment Programs
production for both furnaces. Then, as above, the permit writer would calculate the
operating rate for each furnace independently using the annual production for that year
annual operating hours for each furnace. The average daily operating rate for the
the two furnaces would be the sum of the daily production values. For example, consider the
following production data.
  average daily
     and the
combination of
Year
199-5
• 1996
1997
1998
1999
Furnace A
1.850.000
1,675,000
1,760,000
1,580,000
1,825,000
Furnace B
1,305,000
1.425.000
1,406,000
1,328,000
1,380,000
Total
(tons)
3,155,000
3,100,000
3,166,000
2,908,000
3.205.000
             Annual maximum production rates for each furnace and the total for both furnaces
are underlined. In this example, 1999 was the maximum production year for the combination of
the furnaces, and the data from each furnace for that year would be used to calculate the average
daily operating rates. Combining the 1995 data from Furnace A and the 1996 data from!
Furnace B (3,275,000 tons), might have produced an unrealistic measure of actual production if
the two furnaces could not produce at these high levels concurrently (e.g., if the downstream
intermediate production capacity effectively limits the combined production of the two furnaces).
On the other hand, if the two furnaces could.expect to produce at these high levels concurrently
over the next five-year permit period if strong market conditions prevailed, then the production
based on the combined 1995 Furnace A data and the 1996 Furnace B data might not be [
unrealistic.

             In contrast to the previous example, for multiple process units that are not similar
but have process wastewater discharges that are co-treated in one centralized wastewater
treatment system with one NPDES or pretreatment permit compliance point, the year with the
highest production over the prior five years would be determined separately for each production
unit or combination of similar production units with the highest annual production. The following
table lists production data for a facility that discharges process wastewater streams for basic
oxygen furnace (BOF) steelmaking, vacuum degassing, and continuous casting operations
through one NPDES or pretreatment permit compliance point.
                                          15-8
-------
                                                 Section 15 - Implementation of Part 420 through the
                                                	   NPDES and Pretreatment Programs
Year
1995
1996 .
1997
1998
1999
BOF
(tons)
2,675,000
2,900,000
3,150,000
3.280.000
3,225,000
Vacuum
Degasser
(tons)
1,305,000
1,600,000
1.690.000

1,668,000
1,380,000
Continuous
Caster
(tons)
2,658,000
2,885,000
3,140,000
3.270.000 .
3,215,000
              In this example, the permit writer would use 1998 production data for the BOF,
 1997 data for the vacuum degasser, and 1998 data for the continuous caster to develop the permit
 limitations. An analogous situation would occur in a steel finishing plant with acid pickling, cold
 rolling, and electroplating operations with wastewater discharges that are co-treated in one
 centralized wastewater treatment system with one permit compliance point.

              If EPA adopted the approach under Alternative C, the Agency would also add to
 the proposed regulation (§420.7) a requirement that facilities provide documentation of NPDES
 permit production rates with their NPDES permit renewal applications.

              Alternative D

              Under Alternative D, the Agency is considering establishing production-based
 maximum monthly average effluent limitations and standards in combination with daily maximum
 concentration-based effluent limitations and standards.  Under this approach, permit writers
 would determine the maximum monthly average NPDES and pretreatment permit mass basis
 requirements using the Part 420 production-based standards in combination with a reasonable
 measure of actual production, such as that discussed under Alternative C. However, the daily
 maximum requirements included in Part 420 would be effluent concentrations in lieu of the daily
 maximum production-based mass effluent limitations guidelines and standards. These daily
 maximum concentrations would be those concentrations used to develop the proposed
 production-based mass effluent limitations guidelines and standards.

              The Agency believes that, under most circumstances, the approach under
 Alternative D would effectively address potential issues regarding short-term peaks in production
 (see Section 15.3).  This approach would place no additional burden on the industry and permit
writers applying for and writing NPDES or pretreatment permits.  Permit authorities may need to
revise their automated compliance tracking systems to account for both mass-based and
 concentration-based limitations at the same outfall; however, setting both mass-based and
 concentration-based limits at the same outfall  is common in many NPDES and pretreatment
permits issued  prior to the proposed Iron and Steel rule.
                                         15-9
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                                                 Section 15 - Implementation of Part 420 through the
                                                            NPDES and. Pretreatment Programs
             This approach would also provide some flexibility for the industry when, due to
historical conditions, relatively high volumes of storm water from intense rainfall events £re
collected and treated with process wastewater. In some cases, the volume of storm water
collected and treated may cause short-term peak discharge flow rates that exceed the normal
process wastewater discharge flow and violate the daily-maximum limitations.  However^ the
Agency believes that treatment of such storm water volume is beneficial. The combination of
maximum monthly average mass-based limits and daily-maximum concentration-based lirnits
would provide the flexibility to account for this situation.                             i
                                                                               i
             EPA has solicited comments on these alternative approaches to determining the
proposed production bases for NPDES permit effluent limitations and pretreatment requirements.
The Agency has also sought comments on related costs and any technical difficulties associated
with meeting limits during short periods of high production. In addition, EPA has solicited other
options for consideration.                                                        I
15.4
Applications of Best Professional Judgement
              Section 402(a)(l) of the CWA and the NPDES permit regulations at §122.44(a)
and § 125.3 authorize permit authorities to use BPJ in the absence of categorical effluent |
limitations to establish NPDES permit effluent limitations. When developing the proposed Iron
and Steel regulation, the Agency attempted to minimize the need for BPJ determinations [by taking
into account all process wastestreams commonly generated at each manufacturing process and,
where evident, miscellaneous process-related wastestreams (e.g., those generated in roll shops
and from building basement sumps). The Agency recognizes, however, that some sites may
generate nonprocess wastestreams and wastestreams that meet the definition of process ;
wastewater (see §122.2) that were not accounted for hi the development of the proposecf effluent
limitations guidelines and pretreatment standards for existing sources. To assist permit vpiters in
addressing such wastestreams and to minimize the number of requests for fundamentally [different
factors variances, EPA has proposed at §420.3(f) a provision that would authorize permit writers
to provide for increased loadings for wastewater sources not included in the development of the
proposed regulation if these sources generate an increased discharge flow.              [

              Such wastewater sources may include ground water remediation flows that can
effectively be co-treated with process wastewater in the process wastewater treatment systems
(i.e., ground water remediation water at a coke plant). In these cases, the permit writer would
first calculate the-mass effluent limitations for the regulated process, then calculate mass loadings
for the wastestream using a reasonable measure of the wastewater flow rates and concentrations
used by the Agency to develop the effluent limitations guidelines and standards for that process.
The NPDES permit or pretreatment limitations would be the sum of those mass loadings; (see
Example 4 in Section 15.5.2). The provision at §420.3(f) is not meant to address co-treatment of
wastewater from multiple subcategories within Part 420 or co-treatment of wastewater from, other
categories (see Section 15.5).                                                     [
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                                                 Section 15 - Implementation of Part 420 through the
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 15.5
Calculating NPDES and Pretreatment Effluent Limitations
              To ensure a revised Part 420 is applied consistently and appropriately, the Agency
 is considering alternative approaches to defining the "reasonable measure of actual production"
 used to calculate NPDES and pretreatment permit limits (see Section 15.3). In any of these
 approaches, EPA proposes the revised Part 420 to be applied in a building-block manner. Permit
 writers would multiply the effluent limitations guidelines and standards for each process operation
 by the respective reasonable measure of actual production. Permit writers would sum the
 resulting mass effluent limitations for each process to determine the NPDES or pretreatment
 limits applicable to the wastewater treatment system discharge for those processes.

              This subsection provides examples for calculating NPDES and pretreatment permit
 limits where process wastewater discharges from the same operation and same category are co-
 treated, where wastewater discharges from operations hi different subcategories are co-treated,
 and where there are miscellaneous process wastewater discharges.  This subsection also provides
 an example of how to derive alternative effluent limitations guidelines and standards under the
proposed "water bubble" provision.

              When promulgating the 1982 regulation, EPA recognized that the iron and steel
industry extensively co-treated compatible wastestreams as a cost-effective means of wastewater
treatment. EPA structured the proposed regulation to facilitate co-treatment of compatible
wastestreams in centralized treatment systems and discourage co-treatment of wastestreams that
the Agency deems incompatible.  For example, the Agency determined that co-treatment of
wastestreams from by-product cokemaking operations and EOF steelmaking operations could
increase discharges of toxic pollutants from cokemaking operations. The following table presents
groups of subcategories for which the proposed regulation is structured to facilitate co-treatment.
In some cases, pretreating selected wastestreams would effectively minimize the overall pollutant
discharge.
                                         15-11
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       Section 15 - Implementation of Part 420 through the
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Group 1
Group 2

Group 3




Group 4





Cokemaking
Ironmaking

Carbon Steel




Stainless Steel






Sintering
Blast furnaces
Steelmaking


Hot forming
Steel finishing
Steelmaking


Hot forming
Steel finishing




BOF Steelmaking
Vacuum degassing
Continuous casting


BOF Steelmaking
Vacuum degassing
Continuous casting
















                                     allow
                                     this
              The Agency selected pollutants for regulation in each of these groups to
facilities to co-treat their wastestreams where feasible.  EPA is requesting comments on
approach.

15.5.1        Direct Dischargers

              Example 1:   Two iron and steel processes within the same category;
                           no nonregulated process wastewater.

              In this example, a facility has two blast furnaces and treats their process
wastewater in a dedicated blast furnace gas cleaning water treatment and recycle system.
reasonable measure of actual production (NPDES permit production rate) is 4,500 tons/day for
one furnace and 3,900 tons/day for the other. The facility also has a sinter plant with wet air
pollution controls equipped with a dedicated treatment and recycle system. The facility
discharges blowdown from that recycle system into the blast furnace treatment and recycle
system; the only discharge from these operations is the blowdown from the blast furnace
treatment and recycle system. The NPDES production rate for the sinter plant is 4,100 tons/day.
Table 15-1 presents the calculations illustrating how the effluent limitations guidelines arp applied
in this case. For this example, the TSS and O&G limitations are derived from the proposed
regulation and reflect the BPT limitations from the 1982 regulation. Note that the 2,3,7J8-TCDF
limitation applicable to suiter plant wastewater is applied to the combined wastewater discharge
                                        The
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                                                   Section 15 - Implementation of Part 420 through the
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 from the sinter plant and blast furnaces as a daily maximum concentration limit less than the
 defined minimum level of 10 parts per quadrillion (ppq).1

               Example 2:    Multiple processes within the same category;
                            presence of nonregulated process wastewater.

               In this example, the NPDES production rates for a stainless steel finishing mill with
 wastestreams treated in a centralized wastewater treatment system are as follows.
Descaling and acid pickling
Cold rolling— recirculation-multiple stands
Alkaline cleaning
900
870
870
tons/day
tons/day
tons/day
              The pickling line is equipped with two fume scrubbers.  The mill has a steel coating
 operation that is not regulated by Part 420 or any other categorical effluent limitation guideline.
 The reasonable measure of discharge flow for the nonregulated stream is 50 gallons per minute
 (gpm).  Table 15-2 presents the calculations illustrating how the limitations are applied in this
 case. As in Example 1, the TSS and O&G limitations are derived from the proposed regulation
 and reflect the BPT effluent limitations guidelines from the 1982 regulation.

              Effluent limitations for the 50 gpm of nonregulated process wastewater are
 calculated in accordance with the proposed §420.3 (d), which provides the permit writer with the
 authority to consider such flows when developing pretreatment limits or technology-based
 effluent limitations in NPDES permits.  In this example, the mass-based effluent limits were
 derived from the reasonable measure of actual flow (i.e., 50 gpm) and the  concentrations used to
 derive the effluent limitations guidelines and standards for stainless steel finishing operations (see
 Table 12-3). The resulting mass-based limits were added to the mass limits for the regulated
 processes to determine the NPDES permit limits applicable to the discharge from the wastewater
 treatment facility.     ,                                                                      .

              ExampleS:   Multiple processes from different subcategories;
   '.''••           no nonregulated process wastewater.

              This example is an integrated steel mill with separate treatment and recycle systems
 for EOF steelmaking with wet-open combustion air emission controls, a vacuum degassing plant,
 a continuous slab caster, and a hot strip mill. The blowdown  streams from the vacuum degassing
plant and the continuous caster cascade into the BOF treatment and recycle system.  The facility
 combines the blowdown streams from the hot strip mill and BOF recycle systems for treatment of
'Direct and indirect dischargers must demonstrate compliance with the effluent limitations and standards for 2,3,7,8-
TCDF at the point after treatment of sinter plant wastewater separately or in combination with blast furnace wastewater,
but prior to mixing with any other process or nonprocess wastewaters or noncontact cooling waters.
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                                                 Section 15 - Implementation of Part 420ithrough the
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toxic metals in a blowdown treatment system. The NPDES production rates for these operations
are listed below.                                                                 ;
EOF - wet-open combustion
Vacuum degassing
Continuous casting
Hot strip mill
8,500
6,800
8,450
8,375
tons/day
tons/day
tons/day
tons/day
              Table 15-3 presents the calculations illustrating how the effluent limitations
guidelines are applied in this example.        '                                      ;
15.5.2
Indirect Dischargers
              40 CFR Part 403 classifies wastewater that can be discharged from indusjrial
facilities to POTWs as follows:                                                    I

              •     Regulated - Wastewater regulated by categorical pretreatment standards,
                    such as those contained in the proposed rule;

              •      Unregulated - Wastewater that is not regulated by categorical pretreatment
                    standards and is not dilute wastewater; and                     !
                                                                                i

              •     Dilute - Sanitary wastewater, noncontact cooling water, boiler blowdown,
                    and other wastestreams listed in Appendix D to Part 403.        !

              For indirect iron and steel dischargers whose wastestreams are not co-treated with
wastewater from other industrial categories, the control authority would derive mass-based
pretreatment limits from the proposed pretreatment standards similarly to how NPDES permit
limits are derived for direct dischargers. In this case, all of the wastewater is regulated, iand the
pretreatment authority would apply the pretreatment limits either at the point of discharge from
the facility's wastewater treatment facility or at the point of discharge to the POTW, whichever
point the control authority determines is appropriate based on site circumstances.       ;

              Where the above circumstances apply and there are other wastestreams present
that would be regulated under the proposed rule (§420.3(d)), the pretreatment authority would
calculate the applicable categorical-pretreatment limits as described below in Example 4. In this
case, the pretreatment authority would add incremental mass limits for the wastestreams regulated
under §420.3(d) to the limits derived for the regulated wastewater to determine the appropriate
categorical pretreatment limits.                                                    \

              Where facilities combine regulated wastestreams under the proposed rule and  .   .
dilute wastewater, the pretreatment authority can either: (1) apply the categorical pretreatment
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                                                   Section 15 - Implementation of Part 420 through the
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 limits at an internal monitoring point where dilution is not a factor, under authority of
 §403.6(e)(2) and (4); or (2) apply the categorical pretreatment limits in terms of mass at a
 location after the regulated and dilute wastestreams are combined, provided the dilution is not so
 great as to interfere with compliance determinations.

              . Where facilities co-treat their iron and steel wastestreams with wastestreams from
 other industrial categories that are regulated under other categorical pretreatment standards, the
 pretreatment authority can either derive pretreatment standards for the combined wastestreams by
 using a building-block approach or use the "combined wastestream formula" set out at §403.6(e)
 and shown in the formula below:
                                                   F  -F
                                                   rT   rD
                                                                                    (15-1)
 where:
              CT


              Q


              F,

              FD


              FT
The alternate concentration limit for the combined wastestream,
mg/L

The categorical pretreatment standard concentration limit for a
pollutant in the regulated stream I, mg/L

The average daily flow of stream I, L/day

The average daily flow from dilute wastestreams as defined in Part
403, L/day

The total daily flow, L/day.
              See Reference 15-3 for more information on the combined wastestream formula.

              As with direct dischargers, in circumstances where the pretreatment .standards
applicable to one category regulate a different set of pollutants than the standards applicable to
another category, the control authority must ensure that the guidelines are properly applied.  If a
pollutant is regulated in one wastestream but not another, the control authority must ensure that
the nonregulated pollutant stream does not dilute the regulated pollutant stream to the point
where pollutants are not analytically detectable.  If this level of dilution occurs, the control
authority most likely would establish internal monitoring points, as authorized under 40 CFR Part
403.6(e)(2) and (4).                                 -                      '

              Example 4:   Indirectly discharging coke plant;.
                           co-treatment of ground water from remediation project.

              In this example, an indirectly discharging by-product coke plant has an active
ground water remediation project that generates a continuous flow of 35 gpm; this wastestream  •
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                                                 Section 15 - Implementation of Part 42"0 through the
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contains benzene, phenol, ammonia as nitrogen, and other pollutants characteristic of coke plant
wastewater. Because the untreated ground water is compatible for treatment with untreated coke
plant process wastewater, the Agency determined that it is appropriate to co-treat these two
waste streams. In this example, benzene in the ground water would be removed in the ammonia
still and returned to the coke oven gas, ammonia would be removed in the ammonia still and
downstream treatment, and phenol would be removed either at the coke plant (depending upon
the type of treatment provided) or at the POTW.  The Agency has determined that phenol is
compatible with biological treatment at POTWs and does not pass through.           \
                                                             •   •              \
              The approach used in this-example has the same effect as applying the cqmbined
wastestream formula from the pretreatment regulations reviewed above; however, the proposed
rule allows both direct and indirect dischargers to treat combinations of regulated and unregulated
wastestreams.  Table 15-4 presents the derivation of pretreatment limits for both PSES [options
being considered by the Agency.
15.6
Water Bubble
              The "water bubble" is a regulatory mechanism set out in the 1982 regulation (40
CFR 420.03) to allow an iron and steel facility to trade pollutants between multiple NPDES
permit compliance points within the facility.  Some facilities have used the water bubble to save
costs and others to improve prospects for compliance. The provision is structured to also benefit
the environment.                                                               "

              The water bubble provisions of the 1982 rule and the proposed rule allo;w
alternative effluent limitations where a facility, in effect, trades pollutant discharges from one
outfall or NPDES permit compliance monitoring point to another.  Unlike variances, facilities may
use the water bubble wherever they can meet the conditions governing the use of the water
bubble.                •                    .                                    ;
                                                                              i
              The water bubble provision in the 1982 rule has the following restrictions:

              •      Trades can be made only for like pollutants (e.g., lead for lead, nbt lead for
                    zinc);                                                     !

                    Alternative effluent limitations resulting from the application of the water
                    bubble must comply with applicable water quality standards;    !

              •      Each outfall must have specific fixed limitations for the term of t ae permit;

              •      Trades involving cokemaking and cold rolling operations are prohibited;

              •      Each trade must result in a minimum net reduction in pollutant loading (15
                    percent for TSS and O&G, and 10 percent for all other traded pollutants);
                    and                                                      ;
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                                                   Section 15- Implementation of Part 420 through the
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               •      Only existing sources may apply the water bubble.

               Currently, NPDES permits for only nine iron and steel facilities have alternative
 effluent limitations derived from the water bubble; however, the Agency anticipates that there may
 be increased interest in the water bubble with the promulgation of a revised rule. Therefore, EPA
 proposes to make the following changes to the water bubble provision:

               •      Allow trades for by-product cokemaking operations, but only where the
                     alternative limitations for cokemaking would be more stringent than the
                     generally applicable limitations. This change would provide additional
                     flexibility for certain facilities yet ensure that there would be no increased
                     discharge of toxic organic and other pollutants associated with cokemaking
                     operations.

              '•      Restrict trades in the same manner for sinter plants as for by-product
                     cokemaking operations due to the potential for discharges of dioxins and
                     furahs.

              •      Prohibit trades of O&G because of differences in the types'of oil and grease
                     used among, iron and steel operations (finishing operations tend to use and
                     discharge synthetic and animal fats and oils used to lubricate metals, the
                     hot-end operations tend to discharge petroleum-based oil and grease used
                     to lubricate machinery,  and cokemaking operations tend to discharge oil
                     and grease containing polynuclear aromatics generated by the combustion
                     ofcoal).

              •      Allow trades for cold rolling operations.

              •      Allow trades for new as well as existing sources. Because the existing
                     source environmental gain is 10 percent for all parameters except for TSS,
                     which is 15 percent, EPA is considering whether a higher net gain (e.g., 20
                     percent) is appropriate for new sources given their flexibility in design.

              EPA is proposing to change the 1982 regulation to prohibit trading of O&G
between outfalls.  As noted above, EPA is concerned that different types of oil and grease may be
discharged by different process units, and that trading might increase the amount of a more
environmentally harmful type of oil and grease (e.g., petroleum based), while reducing the amount
of a less harmful type (e.g., animal fats). EPA recognizes that facilities will generally identify
trades that save money.  The. Agency has no data to suggest that the most economically beneficial
trading opportunities (i.e., those facilities will likely use) would systematically either decrease or
increase discharges of the most harmful types of oil and grease.  Given that facilities must
decrease O&G discharge across all outfalls by 15 percent to trade under the existing rule, even if
an individual trade might increase discharges of petroleum-based oil and grease, the net effect
would still benefit the environment and save the facility costs.
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                                                 Section 15 - Implementation of Part 420 through the
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              When estimating the incremental investment and operating and maintenance costs
associated with the proposed regulation, the Agency assumed that no facilities would us£ the
water bubble.  Consequently, any use of the water bubble would represent cost savings.<
                                                                               i
              Table 15-5 presents an example of the water bubble used for a trade of zinc for the
facilities identified above hi Examples 1 and 3 (see Tables 15-1 and 15-3). Note that in this
example trade, EPA assigned the sinter plant/blast furnace operations more stringent limitations;
this outcome would be allowed with the proposed restriction on trades for sinter plant operations.
15.7
Monitoring Requirements
             The NPDES permit regulations at § 122.41 (j)(4) and the pretreatment regulations
at §403.12(b)(5)(vi) require that facilities conduct sampling and analyses for compliance!
monitoring purposes according to the techniques set out at 40 CFR Part 136, as amende*! Table
15-6 presents the sampling and analytical methods for those pollutants regulated under the
proposed rule (see Part 136 and the analytical methods for sample handling, sample holding time,
and approved sample containers). Note that there is no method specified in Part 136 for!
thiocyanate.  The Agency recommends that permit authorities specify analytical method 4500 CN
M from the most current edition of Standard Methods for the Examination of Water and
Wastewater (Reference 15-4).                                                    [
                                                                               i.
             The Agency has not proposed specific monitoring requirements or monitoring
frequencies in the Iron and Steel regulation; therefore, permit authorities may establish monitoring
requirements and monitoring frequencies at their discretion.  Sections 15.7.1 through 15.7.3
provide guidance on establishing these requirements.
15.7.1
Sample Types
             EPA recommends flow-proportioned, 24-hour composite samples for the|
following pollutants:
                    TSS;
                    Ammonia as nitrogen;
                    Total cyanide;
                    Phenol;
                    Thiocyanate;
                    2,3,7,8-TCDF;
                    Benzo-a-pyrene;
                    Naphthalene;
                    Hexavalent chromium;
                    Total chromium;
                    Total lead;
                    Total nickel;
                    Total mercury;
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                                                  Section 15 - Implementation of Part 420 through the
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               •      Total selenium; and                       .
               •      Total zinc.

               Part 136 requires facilities to collect grab samples for O&G.  Several iron and steel
 permits are written to require collection of three grab samples for O&G in a 24-hour monitoring
 day, with the results averaged to represent a daily sample. The sample types for pH can range
 from a one-time grab sample during a monitoring day for operations where pH is usually not a
 control parameter (e.g.,  continuous casting, hot forming) to continuous sampling where pH is a
 critical aspect of the wastewater to be treated or a critical control parameter for operation of
 wastewater treatment facilities (e.g., steel finishing and other subcategories where metals
 precipitation is a control technology).
 15.7.2
Monitoring Frequency
              The monitoring frequencies specified in iron and steel NPDES permits vary
 depending upon the size of the facility^ potential impacts on receiving waters, compliance history,
 and other factors, including monitoring policies or regulations required by permit authorities. A
 few iron and steel permits for large mills have required monitoring for all limited pollutants as
 frequently as five times per week.  Other permits for less complex facilities require twice monthly
 monitoring. When developing the proposed rule, EPA considered a monitoring frequency of once
 per week for limited pollutants, except for 2,3,7,8-TCDD, for which the Agency considered a
 monthly monitoring frequency. Most NPDES permits for iron and steel facilities require facilities
 to continuously monitor and record their discharge flow rates and report daily 24-hour total flow.

              Facilities may monitor effluent more frequently than specified in their permits;
 however, the results must be reported in accordance with §122.41(i)(4)(ii).
15.7.3
Compliance Monitoring Locations
              The NPDES permit regulations at §122.41Q)(1) require that samples and
measurements taken for the purpose of monitoring be representative of the monitored activity and
§125.3(e) requires that technology-based effluent limits be applied prior to or at the point of
discharge. The pretreatment regulations at §403(d) prohibit facilities from diluting their
wastewater to meet categorical pretreatment standards. The discharge from a wastewater
treatment facility is usually a point where measurements will be most representative of the treated
effluent.  Under circumstances where dilution with relatively low volumes of noncpntact cooling
water or storm water will not interfere with compliance determinations, permit writers may apply
the technology-based effluent limits at the point of discharge to a receiving water or to a POTW.

              In the proposed regulation at §420.6(b) EPA has given permit writers the
flexibility to apply pH effluent limitations at the point of discharge from a wastewater treatment
facility or at the point of discharge to a receiving water. This mechanism is designed to prevent
the need for facilities to reneutralize their treated wastewater to a pH of 6.0 to 9.0 if they can
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                                                 Section 15 - Implementation of Part 420. through the
                                                             NPDES and Pretreatmeift Programs
achieve the same end by mixing treated wastewater with nonregulated wastewater, suchas large
volumes of noncontact cooling water.                                             \
15.8
Best Management Practices
              BMPs are measures to prevent or mitigate water pollution from sources ancillary
to the industrial manufacturing or treatment process. The NPDES regulations at § 122.2 define
the term "best management practices" and provide the following measures as examples:.

              •       Schedules of activities; .                                     !
                                                                               !;
              •       Prohibition of practices;                                     j
                                                                               it

              •       Maintenance procedures;                                     ;

              •       Treatment requirements; and                                 [
                                                                               i
              •       Operating procedures and practices to control plant site runoff, spillage or
                     leaks, sludge or waste disposal, and drainage from raw material storage
                     areas.                                                     !
                                                                               !
              The NPDES regulations at §122.44(k) allows BMPs to be included as permit
conditions (when applicable) where they are authorized under Section 304(e) of the CWA when
numeric effluent limitations are not feasible or when BMPs are necessary to meet the limitations
or carry out the purpose and intent of the CWA.  Examples of when numeric effluent linptations
are not feasible include the following:                                             [
                                                                               I
              •      When chemical analyses are inappropriate or impossible;
              .      When a history of leaks and spills exists or when housekeeping is | sloppy;
              •      When a complex facility lacks toxic pollutant data; and
              •      When other discharge control options are prohibitively expensive'.

              Permit writers may include BMPs in permits in two ways: they may require the
development of a general BMP plan and/or require site-, process-, or pollutant-specific BMPs.
Because individual permits instead of general permits are issued to iron and steel facilities, permit
writers usually require site-specific or pollutant-specific BMPs where appropriate.     .
              The Guidance Manual for Developing Best Management Practices CBMP.sl
 (Reference 15-5) presents additional information about BMPs and describes industrial activities
 and materials that are best addressed by BMP plans. EPA has identified several recommended
 components for effective BMP plans for the iron and steel industry.  The minimum suggested
 components of a general BMP plan are presented below (Reference 15-5 discusses each) of these
 components in more detail).
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                                                  Section 15 - Implementation of Part 420 through the
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              •      General requirements:
                     —     Name and location of facility;
                     —     Statement of BMP policy and objective; and
                     —     Review by plant manager.

              •      Specific requirements:                                            '
                     —-     BMP committee;           .
                     — ,    Risk identification and assessment;
                    .—     Reporting of BMP incidents;
                     —     Materials compatibility;
                     —     Good housekeeping;
                     —     Preventive maintenance;
                     —     Inspections and records;
                     —     Security; and
                     —     Employee training.

              The Preliminary Study of the Iron and Steel Category (Reference 15-6) identifies
the activities listed below as possible BMPs for iron and steel facilities. EPA advises permit
writers to apply or require BMPs in instances where site-specific circumstances warrant the
application of BMPs such as the following:

              •       Control of spillage and losses from raw material handling operations (i.e.,
                     ore docks, coal handling);

              •       Control of runoff from raw material storage piles, including piles of coal,
                     coke, iron ore, limestone, and scrap steel;

              •       Control of fugitive discharges of process wastewater and process materials
                     to coke plant, blast furnace, and sinter plant noncontact cooling water;

              •       Control of coke oven and blast furnace gas condensates;

              •       Control of runoff/leachate and ground-water contamination from blast
                     furnace slag pits located at blast furnaces;

              •       Control of runoff from blast furnace and steelmaking slag processing
                     operations located at the furnaces and in remote areas;

              •   .    Control of runoff from electronic arc furnace (EAF) dust collection areas;

              •       Control of spillage and runoff from loading stations for rolling solutions
                     and pickling acids; and                     .
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                                                 Section 15 - Implementation of Part 420 through the
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                     Surveillance and corrective action programs for oil discharges
                     noncontact cooling water discharges.
                                                               from
              In addition, BMPs could also be applied in the form of periodic (e.g., once during
the term of a five-year permit) engineering reviews of the design and operation of wastewater
treatment systems to ensure facilities schedule increases in capacity, major maintenance
                                                                 items, and
replacement of treatment units as needed. Many existing steel industry wastewater treatment
systems were first designed and installed during the 1960s and 1970s.  The Agency believes that,
for the most part, these systems have been properly operated and well maintained. For these
facilities, BMPs would help identify those systems that require major maintenance or replacement
in the near term. •                                                              j
15.9
Bypasses and Upsets
              The CWA, the NPDES permit regulations at §122.41(m) and (n), and the
pretreatment regulations at §403.16 and §403.17 allow effluent discharges in excess of permit
limits under certain exceptional and limited circumstances. A bypass is an intentional diversion of
a wastestream from any portion of a treatment facility to prevent unavoidable loss of life, personal
injury, or severe property damage. Economic loss caused by delays in production does not
constitute severe property damage for the purposes of this regulation.  The key requirements for
the bypass provisions of a permit are (1) the bypass must be intentional; (2) prior notice;(10 days,
if possible) must be provided; and (3) there must be no feasible alternatives to the bypass.  A
facility cannot meet these requirements if it lacks adequate back-up equipment that it should have
installed to prevent a bypass during periods of normal operation or maintenance using reasonable
engineering judgement. Intentional bypasses are allowed only if required for essential  !
maintenance to ensure efficient operation, as long as these bypasses do not cause the facility to
exceed its effluent limitations.                                                    i
                                                                               i
                                                                               I
              An upset is an exceptional incident in which a facility unintentionally and
temporarily cannot comply with its technology-based permit effluent limitations due to factors
beyond its reasonable control. An upset does not include noncompliance due to operational error,
improperly designed treatment facilities, inadequate treatment facilities, lack of preventative
maintenance, or careless or improper operation.  An upset can be an affirmative defense for
effluent limitation exceedances provided that the permit holder demonstrates the following: the
cause of the upset can be identified, the permitted facility was being properly operated at the time
of the upset, and the permit holder made the  required 24-hour notification.  In any enforcement
proceeding, the burden of proof is on the permit holder to demonstrate an upset has occurred
through properly signed operating logs or other relevant evidence.                   :

              Because Section 510 of the CWA authorizes permit authorities to include more
stringent controls than in permits than one contained in the federal regulations, any bypass and
upset provisions must be included in permits issued by permit authorities to become available to
permit holders. Permit authorities should anticipate that permit holders with properly designed
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                                                 Section 15 - Implementation of Part 420 through the
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 and operated wastewater treatment systems would have very few, if any, bypasses or upsets, that
 meet the above criteria in the course of a five-year NPDES permit.
 15.10
NPDES Permit and Pretreatment Variances
              The CWA and the NPDES permit regulations allow certain variances from
 technology-based effluent limitations guidelines and standards for exceptional cases. The water
 bubble provisions of the 1982 rule and the proposed regulation at §420.4 allow alternative
 effluent limitations where a facility can trade pollutant discharges from one outfall or NPDES
 permit compliance monitoring point to another.  Unlike variances, facilities may use the water
 bubble wherever they can meet the conditions governing use of the water bubble. As opposed to
 the bypass and upset provisions that are applicable within the term of a permit, the permit writer
 develops the variance and alternative limitations at the time of draft permit renewal so that the
 variance and alternative limitations are subject to public review and comment at the same time the
 entire permit is put on public notice. The variance and alternative limitations remain in effect for
 the term of a permit, unless the permit writer modifies it prior to expiration.

              A permit applicant must meet specific data requirements before a variance is
 granted. As the term implies, a variance is an unusual situation, and the permit writer should not
 expect to routinely receive variance requests. The permit writer should consult 40 CFR § 124.62
 for procedures on making decisions on the different types of variances.
15.10.1
Economic Variances
              Section 301(c) of the CWA allows a variance for nonconventional pollutants from
technology-based BAT effluent limitations due to economic factors, at the request of the facility
and on a case-by-case basis.  There are no implementing regulations for §301(c); rather, variance
requests must be made and reviewed based on the statutory language in CWA §301(c). The
economic variance may also apply to non-guideline limits in accordance with 40 CFR
§122.21(m)(2)(ii). The applicant normally files the request for a variance from effluent limitations
developed from BAT guidelines during the public notice period for the draft permit.  Other filing
time periods may apply, as specified in 40 CFR § 122.21(m)(2). The variance application must
show that the modified requirements:

              1)    Represent me maximum use of technology within the economic capability
                    of the owner or operator; and

              2)    Result in further progress toward the goal of discharging no process
                    wastewater.                                     .

              Facilities in industrial categories other than utilities must conduct three financial
tests to determine if they are eligible for a 301(c) variance. Guidance for conducting the financial
tests is available from EPA's  Office of Wastewater Management. Generally, EPA will grant a
variance only if all three tests indicate that the required pollution control is not economically
                                         15-23
-------
                                                 Section 15 - Implementation of Part 420 through the
                                                             NPDES and Pretreatment Programs
achievable, and the applicant makes the requisite demonstration regarding "reasonable farther
progress."                                                                      i

              With respect to the second requirement for a 301(c) modification, the applicant
must, at a niinimurn, demonstrate compliance with all applicable BPT limitations and pertinent
water-quality standards. In addition, the proposed alternative requirements must reasonably
improve the applicant's discharge.                                                ;
15.10.2
Variances Based on Localized Environmental Factors
              Section 301(g) of the CWA allows a variance for certain nonconventional
pollutants (ammonia, chlorine, color, iron, and total phenols) from BAT effluent limitations
guidelines due to local environmental factors. The discharger must file a variance application that
shows the following:                                                            !

              •      The modified requirements result in compliance with BPT and water-
                    quality standards of the receiving stream;

              •      Other point or nonpoint source discharges will not need additional
                    treatment as a result of the variance approval; and              \

              •      The modified requirements will not interfere with protection of public
                    water supplies or with protection and propagation of a balanced population
                    of shellfish, fish, and wildfowl, and will allow recreational activitijes in. and
                    on the water. Also, the modified requirements will not result in quantities
                    of pollutants that may reasonably be anticipated to pose an unacceptable
                    risk to human health or the environment, cause acute or chronic toxicity, or
                    promote synergistic properties.

              Section 301 (g) also allows petitioners to add other nonconventional pollutants to
the variance list upon petition to the Administrator.  The petitioner must demonstrate that the
pollutants do not exhibit the characteristics  of toxic pollutants. Certain time restrictions and other.
conditions also apply (see Section 301(g)(4)(C)).
                                                                               I
              Permit writers must review the request to ensure that it complies with each of the
requirements for this type of variance.  The 301(g) variance request involves significant; water-
quality assessment, including aquatic toxicity, mixing zone, and dilution model analyseSi and the
possible development of site-specific criteria. In addition, many complex human health effects
must be assessed, including carcinogenicity, teratogenicity, mutagenicity, bioaccumulatijon, and
synergistic propensities. Permit writers should use EPA's Draft 30 Kg) Technical Guidance
Manual (Reference 15-7) in assessing variance requests.                             j

              Several Section 301(g) variances have been granted for iron and steel facilities.
Most of these have been for ammonia as nitrogen and total phenols discharged from blajst  furnace
                                          15-24
-------
                                                  Section 15 - Implementation of Part 420 through the
                                                 	NPDES and Pretreatment Programs
 operations.  The proposed regulation contains effluent limitations guidelines, and standards for
 phenol rather than total phenols.  Consequently, the ability of some permit holders to obtain
 Section 301 (g) variances may be limited because phenol is a designated priority pollutant for
 which 301(g) variances are not available.
 15.10.3
Fundamentally Different Factors Variances
              Section 301 (n) of the CWA allows variances based upon fundamentally different
 factors (PDF) for BAT and BCT pollutants, while 40 CFR Part 125, Subpart D provides the
 regulatory authority for BPT variances.  A direct discharger can receive an PDF variance from
 effluent limitations guidelines for priority, conventional, arid nonconventional pollutants if the
 facility is found to be fundamentally different from the factors considered in establishing the
 effluent guidelines.  There is no PDF variance allowed from NSPS. The facility must file the PDF
 variance for BPT by the close of the public comment period for the permit under 40 CFR
 §124.10, and request the PDF variance for BAT or BCT within 180 days of the guideline
 promulgation. Where an PDF variance request is approved, calculated alternative limits cannot be
 any less stringent than justified by the fundamental difference and cannot cause violations of
 water-quality standards. PDF variances may result in more or less stringent effluent limitations
 than those derived from the generally applicable-effluent limitations guidelines.

              Factors required to justify a BPT PDF variance related to a discharger's facilities,
 equipment, processes,  and compliance costs must be different from those considered in the
 development of the guidelines. Factors for BAT and BCT variance requests are similar except
 that cost cannot be considered. Additional factors that cannot be considered for any PDF
 variance request include the feasibility of installing the necessary treatment within the given time
 frame, a claim that the limits cannot be achieved with the given technology (unless supported with
 data), the discharger's  ability to pay, or the impact on local receiving water quality. Permit
 writers review PDF variances on a case-by-case basis. The burden of-proof lies with the facility
 requesting the variance.
15.10.4
Thermal Discharge Variances
              Section 316(a) of the CWA allows variances from effluent limitations for the
thermal component of a discharge. Regulations for submitting and reviewing thermal discharge
variance requests are promulgated at 40 CFR Part 125, Subpart H. Permits may include less
stringent alternative thermal effluent limits if the discharger demonstrates that such limits are more
stringent than necessary to ensure the protection and propagation of a balanced, indigenous
community of shellfish, fish, and wildlife in and on the body of water into which the discharge is
made, taking into account the cumulative impact of its thermal discharge together with all other
significant impacts on the species affected.                                      .
                                         15-25
-------
                                                 Section 15 - Implementation of Part 420 through the
                                                	NPDES and PretreatmeM Programs
15.10.5
Net Credits
              In some cases, solely as a result of the level of pollutants in the intake water,
facilities find it difficult or impossible to meet technology-based limits with BAT/BCT technology.
Under certain circumstances, the NPDES regulations allow credit for pollutants in intake water.
40 CFR § 122.45(g) establishes the following requirements for net limitations:         '

              •       Credit for generic pollutants, such as BOD5 or TSS, are authorized only
                     where the constituents resulting in the effluent biological oxygen demand
                     and TSS are similar between the intake water and the discharge;

              •       Credit is authorized only up to the extent necessary to meet the applicable
                     limitation or standard, with a maximum value equal to the influenj:
                     concentration;

              •       Intake water must be taken from the same body of water into which the
                     discharge is made; and                                       j
                                                                               i
              «       Net credits do not apply to the discharge of raw water clarifier sludge
                     generated during the treatment of intake water.

              Permit writers are authorized to grant net credits for the quantity of pollutants in
the intake water where the applicable effluent limitations guidelines and standards specify that the
guidelines are to be applied on a net basis or where the pollution control technology woijild, if
properly installed and operated, meet applicable effluent guidelines limitations and standards in the
absence of the pollutants in the intake waters.  EPA has  specified in the proposed rule that
effluent limitations guidelines and standards are to be applied on a gross basis.

15.11         References
                                                                               !
15-1          U.S. Environmental Protection Agency.  NPDES Permit Writer's Manual. EPA
              833/B-96-003. Washington, D.C., December 1996.
                                                                               t
15-2          U.S. Environmental Protection Agency.  Industrial User Permitting Guidance
              Manual. EPA833/R-89-001. Washington. D.C., September 29, 1989.  <
                                                                               !
15-3          U.S. Environmental Protection Agency.  Guidance Manual for the Use of
              Production-Based Pretreatment Standards and the Combined Wastestream
              Formula. EPA 833/B-85-201.  Washington, D.C.. September 1985.    !
                                                                               |
15-4          American Public  Health Association, American Water Works Association, and
              Water Pollution Control Federation. Standard Methods for the Examination of
              Water and Wastewater. 20th edition.  Washington, D.C., 1998.
                                          15-26
-------
                                                Section 15 - Implementation of Part 420 through the
                                                            NPDES and Pretreatment Programs
15-5
15-6
15-7
U.S. Environmental Protection Agency, Guidance Manual for Developing Best
Management Practices (BMPs). EPA 833/B-93-004, Washington, D.C., 1993.
U.S. Environmental Protection Agency. Preliminary Study of the Iron and Steel
Category: 40 CFR Part 420 Effluent Limitations Guidelines and Standards.
EPA 821-R-95-037. Washington, D.C., September 1995.

U.S. Environmental Protection Agency. Draft 301(g) Technical Guidance Manual.
Washington, D.C.,  1984.
                                        15-27
-------
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-------
                                                 Section 15 - Implementation of Part 420 through the
                                                           NPDES and Pretreatment Programs
                                    Table 15-6

List of Approved Test Procedures for Pollutants Regulated Under the Proposed Rule
                   for the Iron and Steel Point Source Category
Parameter and Units
Method
EPA
STD Method
ASTM
uses
Other
Conventional Pollutants
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2,3,7,8 TCDF (CAS 512073 19)
Ammonia as nitrogen, mg/L
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Manual distillation (at pH 9.5)6
followed by nesslerization
Titration
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7782505)
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DPD-FAS
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ilectrode, manual or
Automated
Colorimetric (SPADNS)
automated complexone
Thiocyanate (CAS 302045)
1613 B
350.2
350.2
350.2
350.3
350.1
330.1
330.3
330.2
330.4
330.5
340.2
340.1
340.3


•4500-NH, B
4500-NH3 C
4500-NH3 E
4500-NH3ForG
4500-NH3 H
4500-C1 D
4500-C1 B
4500-C1 C
4500-C1 F
4500-C1 G
4500-F B
4500-F C
4500-F D
4500-F E
4500-CN'M

D1426-93(A)
D1426-93(B)
D1253-86(92)
D1179-93(B)
D1179-93(A)


1-3520-85
1-4523-85

1-4327-85

'
97S.493
97S.493
Note 7
Note 16


                                      15-33
-------
                     Section 15 - Implementation of Part 420 through the
                                 NPDES and Pretre'atment Programs
Table 15-6 (Continued)

Parameter and Units
Priority Pollutants
Chromium, total*, mg/L (CAS 7440473)
Digestion4 followed by:
AA direct aspiration"
AA chelation-extraction
AA furnace
ICP/AES34
DCP,Mor
Colorimetric (Diphenylcarbazide)
Chromium VI dissolved, mg/L (CAS
18540299)
0.45 micron filtration followed by:
AA dictation-extraction or
Colorimetric (Diphenylcarbazide)
Lead, total4, mg/L (CAS 7439921)
Digestion4 followed by:
AA direct aspiration
AA furnace
ICP/AES"
DCP"
Voltametry"or
Colorimetric (Dithizone)
Mercury, total4, mg/L (CAS 7439976)
Cold vapor, manual or
automated
Nickel, total4, mg/L (CAS 7440020)
Digestion4 followed by:
AA direct aspiration36
AA furnace
ICP/AES34
DCP^.or
Colorimetric (heptoxime)
Selenium, total4, mg/L (CAS 7782492)
Digestion4 followed by:
AA furnace
ICP/AES3*, or
AA gaseous hydride

EPA

218.1
218.3
218.2
200.7
218.4
239.1
239.2 .
5200.7
245.1
245.2
249.1
249.2
5200.7
270.2
5200.7

STD Method

3111B
3111C
3113B
3120B
3500-CrD
3111C
3500-CrD
SllIBorC
3113B
3120 B
3500-Pb D
3112B
SllIBorC
3113B
3120B
3500-Ni D
3113B
3120B
3114B
Method
ASTM

D 1687-92(B)
D 1687-92(C)
D4190-82(88)
D1687-92(A)
D3559-90(AorB)
D3559-90(D)
D4190-82(88)
D3559-90(C)
D3223-91
D1886-90(AorB)
,D1886-90(C)
D4190-82(88)
D3859-93(B)
D3859-93(A)

uses

1-3236-85
1-1232-85
1-1230-85 •
1-3399-85 \
1-3462-85
1-3499-85
1-3667-85 ,

Other

974.273
Note 34

974.273
Note 34
977.223
Note 34

           15-34
-------
                                                              Section 15 - Implementation of Part 420 through the
                                                                           NPDES and Preireatment Programs
                                       Table 15-6 (Continued)

Parameter and Units
Priority Pollutants (continued)
Zinc, total4, mg/L (CAS 7440666)
Digestion4 followed by:
AA direct aspiration36
AA furnace
ICP/AES36
DCP,36 or
Colorimetric (Dithizone) or
(Zincon)
Cyanide, total, mg/L (CAS 57125)
Manual distillation with MgCl2 followed by
Titrimetric or
Spectrophotometric, manual or
automated20
Benzo-a-pyrene (CAS 50328)
GC
GC/MS
HPLC
Phenol (CAS 108952)
GC
GC/MS '
Naphthalene (CAS 91203)
GC
GC/MS
HPLC
Method
EPA



289.1
289.2
5200.7






31335.2
3I335.3

610
625, 1625
610

604
625, 1625

610
625, 1625
610
STD Method
ASTM



SlllBorC

3120 B

3500-Zn E
3500-ZnF .

4500-CNC
4500-CN D
4500-CN E

6410 B, 6440 B



6420B, 6410B


6410 B, 6440 B





D1691-90(AorB)


D41 90-82(88)



D2036-91(A)

D2036-91(A)

D4657-92










uses
Other



1-3900-85








1-3300-85














974.273,p.379


Note 34

Note 33


p.229













See 40 CFR Part 136 for footnotes and note references.
CAS: Chemical Abstracts Service.
                                                 15-35
-------
-------
                                                                         Section 16 - Glossary
                                      SECTION 16

                                      GLOSSARY


Acid Cleaning. Treatment of steel surfaces with relatively mild acid solutions for purposes of
removing surface dirt and light oxide coatings. Scale and/or heavy oxide removal is considered
acid pickling (see below). Acid cleaning operations are typically conducted for surface
preparation prior to application of hot dip or electrolytic metal coating and after cold forming and
annealing operations.

Acid Pickling. Scale and/or oxide removal from steel surfaces using relatively strong acid
solutions. Acid pickling operations are typically conducted after hot forming operations and prior
to subsequent steel finishing operations (e.g., cold forming, annealing, alkaline cleaning, metal
coatings).

Acid Regeneration.  Treatment of spent acid solutions by thermal and/or chemical means to
produce usable acid solutions and iron-rich by-products.

Act. The Clean Water Act.

Administrator. The Administrator of the U.S. Environmental Protection Agency.

Agency. U.S. Environmental Protection Agency (also referred to as "EPA").

Agglomeration. The process of binding materials. See definitions for briquetting, nodulizing,
pelletizing, and sintering.

Alkaline Cleaning. Application of solutions containing caustic soda, soda ash, alkaline silicates,
or alkaline phosphates to a metal surface primarily for removing mineral deposits, animal fats, and
oils.'

Alloy.  A substance that has metallic properties and is composed of two or more chemical
elements of which at least one is a metal.

Alloy Steel. Steel is classified as alloy when the maximum of the range given for the content of
alloying elements exceeds one or more of the following: manganese, 1.65%; silicon, 0.60%;
copper, 0.60%; or in which a definite range or a definite  minimum quantity of any of the following
elements is specified or required Within the limits of the recognized field of constructional alloy
steels:  aluminum, boron, chromium (less than 10%), cobalt, lead, molybdenum, nickel, niobium
(columbium), titanium, tungsten, vanadium, zirconium, or any other alloying element added to
obtain a desired alloying effect.
                                          16-1
-------
                                                                        Section 16- Glossary
Alloying Materials. Additives to steelmaking processes for improving the properties of the
finished products. Chief alloying elements in medium alloy steels are: nickel, chromium,
manganese, molybdenum, vanadium, silicon, and copper.

Alternate Effluent Limitations to Those Representing the Degree of Effluent Reduction
Attainable by the Application of Best Practicable Control Technology Currently Available.
Best Available Technology, and Best Conventional Technology. 40 CFR 420.03. Section
420.03 (commonly known as the "water bubble" .rule) provides a regulatory flexibility mechanism
whereby a discharger with multiple outfalls or NPDES permit compliance points may discharge
greater quantities of pollutants from outfalls where treatment costs may be high in exchange for a
larger decrease in discharges from outfalls at the same plant where treatment costs may be less.
The regulation stipulates that only intraplant trades and no interplant trades are allowed; that only
like pollutants can be traded (e.g., zinc for zinc, not zinc for lead or ammonia-N); that minimum
net reductions of 10% for toxic and non-conventional pollutants and 15% for conventional
pollutants must be achieved; and, that trades within certain subcategories (i.e., cokemaking and
cold forming) are restricted.                                          .           :

Ammonia Liquor for Flushing Liquor>. An aqueous solution used to condense moisjture and
tars from coke oven gas derived from coals  charged to a by-product recovery coke oven battery.
Excess ammonia liquor, or waste ammonia liquor, is flushing liquor rejected from the flushing
liquor recirculating loop through the coke oven gas collecting mains  and the coal tar decanter, and
generally comprises the free and bound moisture contained in the coal charge to the by-product
coke ovens.  Weak ammonia liquor is ammonia liquor that has been processed in a free br fixed
ammonia distillation column (ammonia still) for ammonia recovery to the coke oven gas stream
prior to recovery of ammonium sulfate, anhydrous ammonia, or other by-product ammonium
compounds.

Ammonia Still.  A steam-stripping column in which ammonia and acid gases (hydrogen cyanide,
hydrogen sulfide) are removed from waste ammonia liquor and other ammonia-containing
wastewaters. A "free" still operates with steam only, with no alkali addition, to remove iamnionia
and acid gases. A "fixed" still is similar to a "free" still except lime, or more commonly .sodium
hydroxide, is added to the liquor to liberate ammonia from its compounds so it can be steam
stripped.                                                                 '     \

Angle. A very common structural or bar shape with two legs of equal or unequal length
intersecting at 90°.

Annealing.  A heat treatment process hi which steel is exposed to an elevated temperature in a
controlled atmosphere for an extended period of tune and then cooled.  Annealing is performed to
relieve stresses; increase softness, ductility, and toughness; and/or to produce a specific
microstructure in the steel.  .
                                          16-2
-------
                                                                         Section 16- Glossary
Argon Bubbling. Injection of argon into molten metal for rapid and uniform mixing of alloys,
temperature homogenization, adjustment of chemical composition, and partial removal of non-
metallic inclusions.  Argon bubbling methods include argon stirring, trimming, and rinsing.

Argon/Oxygen Decarburization (AODX  A process by which an electric arc furnace heat is
decarburized by blowing argon and oxygen into the steel at varying ratios.

AWOC. Ambient Water Quality Criteria.

Baghouse. A dry air pollution control device comprising an enclosure containing multiple  fabric
filter elements (bags) for removal of partieulate matter from gas streams.

Bar. Produced from ingots, blooms, or billets covering the following range:  Rounds, 3/8 to 8-
1/4 inches inclusive; Squares, 3/8 to 5-1/2 inches; Round-cornered squares, 3/8 to 8 inches
inclusive; Hexagons, 1/4 to 4-1/16 inches inclusive; Flats, 13/64 inches and over in specified
thicknesses and not over 6 inches specified width.

Basic Oxygen Furnace (BOF).  Pear-shaped, refractory-lined vessel used for conversion of a
charge of molten iron and steel scrap into molten steel by the injection of high pressure oxygen
into the furnace bath.

Basic Oxygen Furnace (BOF) Shop.  A building or structure containing one or more basic'
oxygen furnaces and ancillary processes and equipment (e.g., hot metal desulfurization; hot metal
charging; scrap charging; oxygen and flux additions; furnace tapping; ladle preparation;
deslagging and slag handling; and primary and secondary air emission control equipment).

Basic Oxygen Steelmaking. The basic oxygen process is carried out in a basic lined furnace
which is shaped like a pear.  High pressure oxygen is blown vertically downward on the surface of
the molten iron through a water cooled lance.
    [. Best available technology economically achievable, as defined by section 304(b)(2)(B) of
the Clean Water Act See also Effluent Limitations Guidelines and Standards.

Battery. See By-Product Coke Battery.

BCT. Best conventional pollutant control technology, as defined by section 304(b)(4) of the
Clean Water Act.  See also Effluent Limitations Guidelines and Standards.

Beam. A member of the structural steel family. Beams come in three varieties: the standard H,
I, and the wide flange used for weight supporting purposes.
                                          16-3
-------
                                                                         Section 16- Glossary
 Billet  A semi-finished piece of steel formed by casting or from hot rolling an ingot or a bloom.
 It may be square, but is never more than twice as wide as thick.  Its cross-sectional area; is usually
 not more than 36 square inches.                                                  '

 Blast Cleaning. .Abrasive grit blasting of steel to remove scale; used in place of or in  :
 combination with acid pickling.                                                  '<_

 Blast Furnace. A large conical-shaped furnace used to reduce and melt iron-bearing materials to
' molten iron as the primary product. By-products include  combustible blast furnace gas "and blast
 furnace slag.

 Blast Furnace Charge.  The raw materials added to the blast furnace which react when heated to
 produce molten iron. The principal raw materials charged to blast furnaces include coke,
 limestone, beneficiated iron ores, and sinter.

 Blast Furnace Gas Seals. Water-flooded seals located on a blast furnace gas main for collection
 and removal of blast furnace gas condensate from the blast furnace gas main.  Blast furnace gas
 seal water is contaminated with pollutants associated with blast furnace operations (e.g.j
 ammonia-N, cyanide, phenolic compounds).

 Bloom. A semi-finished piece of steel formed by casting  or from hot rolling or forging pf an
 ingot. A bloom is square or not more than twice as wide  as thick. Its cross-sectional area is
 usually not less than 36 square inches.

 Slowdown. The partial discharge of water from a recirculating process or cooling water system
 for purposes of correcting hydraulic imbalances in the recirculating system or to control;
 concentrations of substances in the recirculating water.

 BMP.  Best management practices, as defined by section 304(e) of the Clean Water Act or as
 authorized by section 402 of the Clean Water Act.                                 '

 BOD;.  Five-day biochemical oxygen demand.  A measure of biochemical decomposition of
 organic matter in a water sample.  It is determined by measuring the dissolved oxygen consumed
 by microorganisms to oxidize the organic contaminants in a water sample under standard
 laboratory conditions of five days and 20 &C. BOD5 is not related to the oxygen requirements in
 chemical combustion.

 BPT. Best practicable control technology currently available, as defined by section 304(b)(l) of
 the Clean Water Act. See also Effluent Limitations Guidelines and Standards.         ',

 Briquetting. A process for agglomerating or forming materials into discrete shapes of sufficient
 size, strength, and weight for charging to a subsequent process (e.g., briquetting wastevi/ater
 sludges for charging to a blast furnace).                                           i
                                           16-4
-------
                                                                        Section 16- Glossary
 Building Evacuation. Control of process and fugitive air emissions from an entire building (e.g.,
 total building evacuation for an electric furnace shop).

 Butt-Welded Pipe/Tube. A continuous strip of hot-rolled skelp which is heated, formed into a
 circular shape, and then welded to form the pipe or tube.

 BV. Baseline value as defined in Section 4.

 By-Product Coke Battery. A coke-producing unit comprised of numerous adjoining, refractory-
 lined, slot-type ovens; coal charging and coke pushing facilities; coke quench stations; and coke
 oven gas collecting mains.                                   -

 By-Product Cokemaking. Process in which coal is distilled at high temperatures in the absence
 of air to produce coke and recover the volatile compounds as by-products (e.g., crude coal tar,
 crude light oil):

 CAA.  Clean Air Act (42 U.S.C. 7401 et seq., as amended inter alia by the Clean Air Act
 Amendments of 1990 (Pub. L.  101-549, 104 stat. 2394)).

 Carbon Steel. Steel which owes its properties chiefly to various percentages of carbon without
 substantial amounts of other alloying elements.  Steel is classified as carbon steel when no
 minimum content of elements other than.carbon is specified or required to obtain a desired
 alloying effect and when the maximum content for any of the following do not exceed the
 percentage noted: manganese,  1.65%; silicon, 0.60%; copper, 0.60 percent.

 Cast Iron. The metallic product obtained by reducing iron ore with carbon at a temperature
 sufficiently high to render the metal fluid and casting it in a mold.

 Casting. (1) A term applied to the act of pouring molten metal into a mold. (2) The metal object
produced by such pouring.

 Categorical Pretreatment Standards. Standards for discharges of pollutants to POTWs
promulgated by EPA, in accordance with Section 307 of the Clean Water Act, that apply to
 specific process wastewater discharges from particular industrial categories (40  CFR 403.6 and
40 CFR405-471).

 CBI. Confidential Business Information.

CFR.  Code of Federal Regulations, published by the U.S. Government Printing Office.  A
codification of the general and permanent rules published in the Federal Register by the executive
departments and agencies  of the federal government.
                                          16-5
-------
                                                                        Section 16- Glossary
Channels. A common steel shape consisting of two parallel flanges at right angles to the web. It
is produced both hi bar sizes (less than 3 in.) and in structural sizes (3 in. and over).    ;

Clarifier. A wastewater treatment unit, usually in the form of a circular, cone-bottom steel or
concrete tank with a center stilling well and mechanical equipment at the bottom for settling and
subsequent removal of suspended solids from the wastewater stream.  Clarifiers may also be
equipped with surface skimming devices for removal of floating materials and oil.      j.

Classifier. Mechanical device used for removal of heavy or coarse particulate  matter firom a
wastewater stream.

Coating.  The process of covering steel with another material, primarily for corrosion resistance.

COP. Chemical oxygen demand.  A nonconventional, bulk parameter that measures the oxygen-
consuming capacity of refractory organic and inorganic matter present in water or wastewater.
COD is expressed as the amount of oxygen consumed from a chemical oxidant in a specific test
(see Method 410.1).

Coil. Steel sheet that is wound, usually rolled hi a hot-strip mill.  Coils are typically more than
one-quarter mile long; coils are the most efficient way to store and transport sheet steel;

Coke. The carbon product resulting from the high temperature distillation of metallurgical coals
in by-product or non-recovery coke ovens.                            "            •

Coke Breeze. Undersized coke particles (also referred to as coke fines) recovered froiri coke
screening operations and coke quenching stations.  Coke breeze may be used as fuel in sintering
operations or may be sold as a by-product.                                     •  ;        •

Coke Oven Gas. Hot gas released in the  coke ovens, containing water vapor, hydrogen, methane,
nitrogen, carbon monoxide,  carbon dioxide, hydrocarbons. Also contains contaminants that may
be recovered as  by-products; tar vapors, light oil vapors (aromatics), consisting mainly 6f
benzene, toluene and xylene, naphthalene vapor, ammonia gas, hydrogen sulfide gas, and  .
hydrogen cyanide gas.

Coke Pushing.  The transfer of hot coke  from coke ovens into quench cars, using pusher-side
equipment such as a door remover and pusher.

Coke Quenching.  Rapid cooling of hot coke using water.

Cold Forming. Also known as cold working; a forming operation in which the shape of the
metal piece is changed by plastic deformation at a temperature below that at which    j
recrystallization occurs. The plastic deformation can be effected by forging, rolling, extrusion, or
drawing.
                                          16-6
-------
                                                                         Section 16- Glossary
 Cold Rolled Products. Flat-rolled products which have been finished by rolling the piece
 without heating (at approximately ambient temperature).

 Continuous Casting.  The process of casting liquid steel directly into semi-finished shapes such
 as slabs, billets, and rounds, thus eliminating ingot casting and associated ingot stripping,
 reheating, and primary rolling operations.

 Contract Haul. Collection of wastewater or sludge by a private disposal service, scavenger, or
 purveyor in containers for subsequent transportation, treatment, and disposal off site.

 Control Authority.  The term "control authority" as used in section 403.12 refers to:  (1) The
 POTW if the POTW's submission for its pretreatment program (§403.3(t)(l)) has been approved
 in accordance with the requirements of §403.11; or (2) the approval authority if the submission
 has not been approved.

 Control Water. Dilution water added to control toxicity prior to biological treatment systems.

 Conventional Pollutants.  The pollutants identified in section 304(a)(4) of the Clean Water Act
 and the regulations thereunder (i.e., biochemical oxygen demand (BOD5), total suspended solids
 (TSS), oil and grease, fecal coliform, and pH).    .

 CWA.  Clean Water Act  The Federal Water Pollution Control Act Amendments
 of 1972 (33 U.S.C. 1251 et seq.\ as amended, inter alia, by the Clean Water Act of 1977
 (Public Law 95-217) and the Water Quality Act of 1987 (Public Law 100-4).

 Cyanide. Total cyanide.

 DCN.  Document control number for a specific document located in the rulemaking record

Deep-Well Injection.. Long-term or permanent disposal of untreated, partially treated, or treated
wastewaters by pumping the wastewater into underground formations of suitable character
through a bored, drilled, or driven well.

Dephenolizer.  A coke plant by-product recovery unit in which phenol is removed from ammonia
liquor and is recovered as sodium phenolate by liquid extraction and vapor recirculation.

Descaling. The process of removing scale from the surface of steel. The most common method
of descaling is to crack the scale by use of roughened rolls and a forceful water spray (see also
electrolytic and salt bath descaling).

Desulfurization. Processes for removal of sulfur compounds from coke oven gases and molten
iron. Coke oven gas desulfurization usually involves scrubbing the sulfur-rich gas stream with an
absorbent solution, with subsequent recovery of elemental sulfur from the solution. Hot metal
                                          16-7
-------
                                                                      Section 16- Glossary
(molten iron) desulfurizatidn involves treatment of the molten metal with lime, with subsequent
collection of sulfur-rich participate matter in fabric filter emission control devices (baghouses).

Pioxin/furans. Chlorinated dibenzo-^-dioxins (CDDs) and chlorinated dibenzofurans (CDFs) are
closely related families of highly toxic and persistent organic chemicals formed as unwanted by-
products in some commercially significant chemical reactions, during high temperature;
decomposition and combustion of certain chlorinated organic chemicals, during combustion of
natural materials, and through other reactions involving chlorine and organic materials. There are
210 CDD/CDF compounds (or congeners) with four to eight chlorine substitutions.  Seventeen
(CDD/CDF) congeners chlorinated at the 2,3,7,&8 lateral positions are among the most
biologically active and toxic CDDs/CDFs. 2,3,7,8-Tetrachlorodibenzo-^-dioxin (2,3,7^8-TCDD)
is the most toxic of the CDDs/CDFs.  The relative toxicity of mixtures of CDDs/CDFs is
described through use of International Toxicity Equivalence Factors (I-TEFs/89).     j

Direct Application (Once-through). In cold rolling, use of water, detergent, rolling oil, or other
substance for the removal of loose organic compounds and fines, in which the substancib is not
recirculated.                                                                 "

Direct Discharger. An industrial discharger that introduces wastewater to a water of the United
States with or without treatment by the discharger.

Direct-Reduced Iron (DRT). Relatively pure iron produced by the reduction of iron ore below
the melting point of the iron produced. DRI is used as a substitute for scrap steel in electric arc
furnace steelmaking to minimize contaminant levels in the melted steel and to allow economic
steel production when market prices for scrap are high.

PL.  Sample-specific detection limit.

Prawing. A forming operation whereby deformation of the metal is accomplished by pulling the
material through a die by means of a tensile force applied on the exit side.
                                                                            f
Pry  Air Pollution Control Equipment. Control equipment in which gases are cleaned without
the use of water.

PSCFM. Dry standard cubic feet per minute.  A standard unit for measuring gas flow.

EAP. EPA's Engineering and Analysis Division.

Effluent  Limitations Guidelines and Standards. Regulations promulgated by U.S. EPA under
authority of Sections 301, 304, 306 and 307 of the Clean Water Act that set out minimtim,
national technology-based standards of performance for point source wastewater discharges from
specific industrial categories (e.g., iron and steel manufacturing plants).  Effluent limitations
                                         16-8
-------
                                                                        Section 16- Glossary
 guidelines and standards regulations are implemented through the NPDES permit and national
 pretreatment programs and include the following:

              •      Best Practicable Control Technology Currently Available (BPT)
              •      Best Available Technology Economically Achievable (BAT)
         -.    • •      Best Conventional Pollutant Control Technology (BCT)
              •      New Source Performance Standards (NSPS)
              •  '    Pretreatment Standards for Existing Sources (PSES)
              «      Pretreatment Standards for New Sources (PSNS)

 The pretreatment standards (PSES, PSNS) are applicable to industrial facilities with process
 wastewater discharges to publicly owned treatment works (POTWs). The effluent limitations
 guidelines and new source performance standards (BPT, BAT, BCT and NSPS) are applicable to
 industrial facilities with direct discharges of process wastewaters to waters of the United States.

 Electric Arc Furnace (EAF).  A furnace in which steel scrap and other ferrous and nonferrous
 materials are melted through application of electrical and chemical energy and converted into
 liquid steel.

 Electric-Resistance-Welded Pipe/Tube.  Pipe or tube formed from a plate or continuous strip of
 steel which is formed into a circular shape and welded together by the application of pressure and
 electrical energy. Heat is generated by the resistance to current flow (either transformed or
 induced) across the seam during welding.

 Electrolytic Descaling. The aggressive physical and chemical removal  of heavy scale from semi-
 finished specialty and high-alloy steels.with molten using electrolytic sodium sulfate solutions.

 Electroplating.  Operations including application metal coating onto precleaned steel through use
 of an electric current. Common metal coating types include: chromium  and tin.  Electroplating
 improves resistance to corrosion, and for some products, improves appearance and paintability.

 Electroslag Remelting (ESR). A specialty steel refining process used to produce ingots with
 stringent composition requirements. In the process, one or more steel electrodes of about the
 desired chemical composition are drip-melted through molten slag into a water-cooled copper
mold at atmospheric pressure.

Electrostatic Precipitator (ESP). An air pollution control device that imparts an electrical
 charge on solid particles in the gas stream which are then attracted to an oppositely charged
 collector plate.  The collector plates are intermittently rapped to discharge the collected dust to a
hopper below.

End-of-Pipe Treatment (EOF).  Refers to those processes that treat a facility waste stream for
pollutant removal prior to discharge.
                                          16-9
-------
                                                                        Section 16- Glossary
EPA. The U.S. Environmental Protection Agency (also referred to as "the Agency").

Extrusion. A forming operation whereby a material is forced, by compression, through a die
orifice.

Filtration. The passage of fluid through a porous medium to remove matter held in suspension.

Final Gas Cooler. A packed tower used for cooling coke oven gas by direct contact with water.
The gas is generally cooled to approximately 30°C (86°F) for recovery of light oil.     '

Finishing. Term used to generically describe steel processing operations conducted after hot
forming (e.g., acid pickling, scale removal, cold forming, annealing, alkaline cleaning, hot coating,
and electroplating).

Flat Products. Hot-rolled steel products including plate, strip, and sheet, that may or may not be
further finished (e.g. cold-rolled or acid pickled).

Flume Flushing. Process by which mill scale collected under hot forming mills and nujout tables
of continuous casters is transported with water to scale pits for subsequent recovery.  ,,

Flushing Liquor. (See ammonia liquor)

Flux. Material added to a blast furnace or steelmaking furnace for the purpose of remoying
impurities from the molten metal.                    ;    .   .       '               ;

Forging. A forming operation in which a metal piece is shaped by hammering.

Forming. Operations in which the shape of a metal piece is changed by plastic deformation.
Examples include forging, rolling, extrusion, and drawing.

Foundry Coke.  Coke produced for foundry operations.

Four-High Mill. A stand which has four rolls, one above the other.  This kind of mill has two
working rolls, each of which  is stiffened by a larger back-roll.  Four high rolls are used only on
mills which roll fiat products.                                                    :

FR. Federal Register, published by the U.S. Government Printing Office. A publication making
available to the public regulations and legal notices issued by federal agencies.         :

Free Leg. That section of an ammonia still from which ammonia, hydrogen sulfide, carbon
dioxide, and hydrogen cyanide are steam distilled  and returned to the gas stream without the
addition of an alkaline substance to release free ammonia.
                                          16-10
-------
                                                                         Section 16- Glossary
 FTE.  Full time equivalents (related to the number of employees).

 Fugitive Emissions. Emissions that are expelled to the atmosphere in an uncontrolled manner.

 Fume Scrubbers. See Wet Scrubbers

 Fundamentally Different Factors Variance. CWA Section 301(n). The Administrator, with
 the concurrence of the State, may establish an alternative requirement under Section 301(b)(2) or
 Section 307(b) of the Clean Water Act for a facility that modifies the requirements of national
 effluent limitation guidelines or categorical pretreatment standards that would otherwise be
 applicable to such facility, if the owner or operator of such facility demonstrates to the satisfaction
 of the Administrator that the facility is fundamentally different with respect to the factors (other
 than cost) specified in Section 304(b)  or 304(g) and considered by the Administrator in
 establishing such national effluent limitation guidelines or categorical pretreatment standards.

 Furnace Burden. The solid materials charged to a blast furnace comprising coke, iron ore and
 pellets, sinter, and limestone.

 Furnace Coke. Coke produced for blast furnace operations

 Galvanizing. Application of zinc to the surface of steel primarily for the purpose of corrosion
 protection.  Zinc may be applied by passing precleaned steel through a molten zinc bath (hot dip
 galvanizing) or electrochemically (electrogalvanizing).

 Ground Water. Water in a saturated zone or stratum beneath the surface of land or water.

 Hardness.  Defined hi terms of the method of measurement.  (1) Usually, the resistance to
 dentation. (2) Stifmess or temper of wrought products.  (3) Machinability characteristics.

 Hazardous Waste. Any material that meets the Resource Conservation and Recovery Act
 definition of "hazardous waste" contained in 40 CFR Part 261.

 Hearth.  In a reverberatory furnace, the portion that holds the molten metal or bath.

Heat.  Quantity of steel manufactured per batch in a BOF or an EAF.

Hexane Extractable Material (HEM). A method-defined parameter (EPA Method 1664) that
measures the presence of relatively nonvolatile hydrocarbons, vegetable oils, animal fats, waxes,
soaps, greases, and related material that are extractable in the solvent n-hexahe.  This parameter
does not include materials that volatilize at temperatures below 85°C. EPA uses the term "HEM"
 synonymously with the conventional pollutant oil and grease (O&G).
                                          16-11
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                                                                        Section 16- Glossary
Hot Blast. Preheated air blown into the blast furnace through a bustle pipe and numerous 'tuyeres
located around the circumference of the furnace. Temperatures are in the range of 550° C to
1,000°C, and pressures are in the range of 2 to 45 atmospheres.                    ;

Hot Coating (Hot Dip Coating). Operations including immersion of precleaned steel into baths
of molten metal. Common metal types include:  tin, zinc (galvanizing), combinations of lead and
tin (teme coating), and combinations of aluminum and zinc (galvalume® coating). Hot'coating is
typically used to improve resistance to corrosion, and for some products, to improve ap'pearance
and paintability.                                                                \

Hot Forming. Also known as hot working; a forming operation in which the shape of the metal
piece is changed by plastic deformation at a temperature above that at which recrystallization
occurs. The plastic deformation can be effected by forging, rolling, extrusion, or drawifig.
                                                                              >
ICR. Information Collection Request.

Incineration.  A controlled combustion process most commonly used for destruction of solid,
liquid, or gaseous wastes.

Indirect Discharge. An industrial discharger that introduces wastewater into a POTW.

Tngot. A large block-shaped steel casting.  Ingots are intermediates from which other sjteel
products are made. When continuous casters are not used, an ingot is usually the first solid form
the steel takes  after it is made in a furnace.

Ingot Mold.  Cast iron molds into which molten steel is teemed. After cooling, the mold is
stripped from the solidified steel which is then re-heated in soaking pits (gas or oil-fired furnaces)
prior to primary rolling into slabs or billets. Molds may be  circular, square, or rectangular in
shape, with walls of various thickness. Some molds are of larger cross section at the bottom,
other are larger at the top.

Integrated Steel Mill. Mills that make steel by processing iron ore and other raw materials in
blast furnaces and basic oxygen furnaces, rather than electric arc furnaces as at non-integrated
mills, or mini-mills.

Iron. Primarily the name of a metallic element.  In the steel industry, iron is the name of the
product of a blast furnace containing 92 to 94% iron, the product made by the reduction of iron
ore.  Iron in the steel mill sense is impure and contains up to 4% dissolved carbon along with
other impurities.

Iron and Steel Coke Plant.  -By-product cokemaking operations which provide more than fifty
percent of the coke produced to ironmaking blast furnaces associated with steel production.
                                          16-12
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                                                                         Section 16- Glossary
 Iron Ore. The raw material from which iron is made. It is primarily iron oxide with impurities
 such as silica.

 Ironmaking. The production of iron made by the reduction of iron ore. In the U.S. iron is made
 in blast furnaces.

 Ladle. A large vessel into which molten metal or molten slag is received and handled.

 Ladle Metallurgy. A secondary step in the steelmaking process usually performed in a ladle after
 the initial refining process in a steelmaking furnace (i.e., BOF, EAF) is complete.  Ladle
 metallurgy is conducted for one or more of the following purposes:  to control gases in the steel;
 to remove, add, or adjust concentrations' of metallic or non-metallic compounds (alloying); and to
 adjust physical properties (e.g., temperature).   '

 Landfill Leachate. Water or ground water collected from that portion of a solid or hazardous
 waste landfill containing disposed solid or hazardous wastes.

 Larry Car. A movable device located on top of a coke battery for receiving and charging
 screened coal to coke ovens through charging holes located at the top of the ovens,

 Light Oil.  An unrefined, clear, yellow-brown oil with an approximate specific gravity of 0.889
 produced as a by-product of by-product cokemaking operations.  It contains varying amounts of
 coal-gas products with boiling points ranging  from about 40 °C to 200 °C and from which
 benzene, toluene, xylene, and solvent naphthas are recovered.

 Lime. Calcium oxide (CaO), produced by burning limestone (principally comprised of calcium
 carbonate (CaCO3)) in a lime kiln. Lime is used as a flux (slagging agent) in BOF and EAF
 steelmaking; limestone is used as a flux in blast furnaces for production of molten iron.

 LTA.  Long-term average. For purposes of the pretreatment standards, average pollutant levels
 achieved over a period of time by a facility, subcategory, or technology option.

 Merchant Coke Plant.  By-product cokemaking operations other than those at iron and steel
 coke plants.

 figfL.  Micrograms/liter.

 mg/L. Milligrams/liter.          .

Microcleanliness.  An end result of secondary steelmaking processes which is characterized by a
removal of undesirable non-metallics, primary oxides, and sulfides from the molten steel.
                                         16-13
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                                                                        Section 16- Glossary
Mill Scale.  The iron oxide scale which breaks off of heated steel as it passes through a polling
mill. The outside of the piece of steel is generally completely coated with scale as a result of
being heated in an oxidizing atmosphere.                             •             '

Mini-Mill.  See Non-Integrated Steel Mill.
                                                                              f

Minimum Level (ML). The lowest concentration that can be reliably measured by an analytical
method.     •

Modifications for Certain Non-conveiitional Pollutants. CWA Section 301fgX The
Administrator, with the concurrence of the State, may modify the requirements of Section
301(b)(2)(A) of the Clean Water Act with respect to the discharge from any point source of
ammonia, chlorine, color, iron, and total phenols (4AAP) (when determined by the Administrator
to be a pollutant covered by Section 301 (b)(2)(F)) and any other pollutant which the   i
Administrator lists under 301(g)(4). In the iron and steel industry, variances under Section 301(g)
have been granted for discharges of ammonia-N and phenols (4AAP) from cokemaking.and
ironmaking operations. The variances granted under Section 301(g) must meet certain conditions
(e.g., the alternative discharges from BAT must meet local water quality standards, cannot be less
stringent than BPT, must not result in more stringent controls on other dischargers, and; must
satisfy other environmental and human health concerns).

Mold.  A form or cavity into which molten metal is poured to produce a desired shape. ; See ingot
molds.                              .                                          ;

Multiple Stand (Multi Stand). A type of cold rolling stand which has greater than on£ roll, one
above the other, used on flat products.                                            ;

   - Non-censored.                                                            :
NESHAP Control for Benzene. The National Emission Standards for Hazardous Air Pollutants
(NESHAPs) regulations set out at 40 CFR 61, Subpart J (6/6/89), Subpart L (9/14/89), Subpart
BB (3/7/90), and Subpart FF (3/7/90).                                            j

Noncontact Cooling Water.  Water used for cooling in process and nonprocess applications
which does not come into contact with any raw material, intermediate product, by-product, waste
product (including air emissions), or finished product.

Nonconventional Pollutants. Pollutants other than those defined specifically as conventional
pollutants (identified in section 304(a) of the Clean Water Act) or priority pollutants (identified in
40 CFR Part 423, Appendix A).                                                  ;
                                         16-14
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                                                                       Section 16- Glossary
 Nondetect Value (ND). Samples below the level that can be reliable measured by an analytical
 method. This is also known, in statistical terms, as left-censored (i.e., value having an upper
 bound at the sample-specific detection limit and a lower bound at zero).

 Non-Integrated Steel Mill (Mini-Mill). Steel mills that melt scrap metal in an electric arc
 furnace to produce commodity products.

 Nonrecovery Cokemaking. Production of coke from coal in which volatile components derived
' from the coal are consumed in the process and by-products are not recovered.

 NPDES Program.  The National Pollutant Discharge Elimination System (NPDES) program
 authorized by Sections 307, 318,402, and 405 of the Clean Water Act which applies to facilities
 that discharge wastewater directly to United States surface waters.

 NRDC.  Natural Resources Defense Council.                                ,

 NSPS.  New source performance standards, under section 306 of the Clean Water Act. See also
 Effluent Limitations Guidelines and Standards.

 Oil and Grease (O&GX  A method-defined parameter (EPA Method 413.1) that measures the
 presence of relatively nonvolatile hydrocarbons, vegetable oils, animal fats, (EPA nitrous 413.1)
 waxes, soaps, greases, and related materials that are extractable in Freon 113 (1,1,2-trichloro-
 1,2,2-trifluoroethane). This parameter does not include materials that volatilize at temperatures
 below 75°C. Oil and grease is a conventional pollutant as defined in section 304(a)(4) of the
 Clean Water Act and in 40 CFR Part 401.16. Oil and grease is also measured by the hexane
 extractable material (HEM) method (see Method 1664, promulgated at 64 FR 26315; May 14,
 1999). The analytical method for TPH and oil and grease has been revised to allow for the use of
 normal hexane in place  of Freon 113, a chlorofluorocarbon (CFC).  Method 1664 (Hexane
 Extractable Material) replaces the current oil and grease Method 413.1 found in 40 CFR 136.

 Oil Skimmer. A device which skims the top surface of wastewater for the purpose of removing
 floating oil.

 Open Hearth Furnace. A furnace for melting metal, in which the bath is heated by the
 convection of hot gases over the surface of the metal and by radiation from the roof.

 OSW. EPA's Office of Solid Waste.                                               .

 Oxidization. A chemical treatment which increases the positive valences of a substance. In a
 limited sense, adding oxygen to a substance, as in oxidizing C to CO, CO to CO2, Si to SiO2, Mn
 toMnO.
                                         16-15
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                                                                        Section 16 - Glossary
Pig Iron. Iron cast into the form of small blocks that weigh about 30 kilograms (kg) each. The
blocks are called pigs.

Pipe. A hollow, cylindrical product distinguished from tube by heavier wall thickness. Pipe is
usually measured by its inside diameter.  Tube is generally measured by outside diameter.

Plant Service Water. City, well, or surface water which has not been used elsewhere on site
(i.e., water prior to its use in a process or operation).

Plate.  A flat-rolled finished steel product within the following size and/or weight limitations:

              Width                '     •                    Thickness        ;

              over 48 niches wide                0.180 inches or thicker
              between 8 and 48 inches inclusive   0.230 inches or thicker          !
              over 48 inches wide                7.53 Ib/sq ft or heavier          ;
              between 8 and 48 inches inclusive   9.62 Ib/sq ft or heavier          ;

POC.  Polluant of concern.
                                                                              \"
Pollution Prevention.  The use of materials, processes, or practices that reduce or eliminate the
creation of pollutants or wastes.  It includes practices that reduce the use of hazardous and
nonhazardous materials, energy, water, or other resources, as well as those practices that protect
natural resources through conservation or more efficient use. Pollution prevention consists of
source reduction, in-process recycle and reuse, and water conservation practices.      i

Polychlorinated Biphenyl (PCS) Compounds.  Any of a family of halogenated aromatic
hydrocarbons that were produced and marketed in the United States  as a series of complex
mixtures under the trade name Aroclor; any specific chemical included within the following
Chemical Abstracts Service Registry Numbers:  1336-36-3 (total PCBs), 12674-11-2 (Aroclor
1016), 11104-28-2 (Aroclor 1221), 11141-16-5 (Aroclor 1232), 53469-21-9  (Aroclor 1242),
12672-29-6 (Aroclor 1254), or 11096-82-5 (Aroclor 1260), see 40 CFR 302; or, any of 209
synthetic congeners of biphenyl with 1 to 10 chlorine substitutions.

Potable Water. Water which can be consumed; drinking water.

Press Forging. The forging process in which metal stock is formed between dies, usually by
hydraulic pressure. Press forging is an operation that employs a single, slow stroke. Compare
with hammer forging.

Priority Pollutants.  The 126 toxic pollutants listed in 40 CFR Part 423, Appendix A. '
                                         16-16
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                                                                          Section 16- Glossary
 Privately Owned Treatment Works (PrOTW). Any device or system owned and operated by a
 private entity and used for storage, treatment, recycling, or reclamation of liquid industrial wastes.

. Process Wastewater. Any water which, during manufacturing or processing, comes into direct
 contact with or results from the storage, production, or use of any raw material, intermediate
 product, finished product, by-product, or waste product. Wastewater from slag quenching,
 equipment cleaning, direct-contact air pollution control devices, rinse water, storm water
 associated -with industrial activity, and contaminated cooling water are considered process
 wastewater. Process Wastewater may also include wastewater that is contract hauled for off-site
 disposal. Sanitary wastewater, uncontaminated noncontact cooling water, and storm .water not
 associated with industrial activity are not considered process wastewater.'

 PSES. Pretreatment standards  for existing sources of indirect discharges, under section 307(b) of
 the Glean Water Act. See also Effluent Limitations Guidelines and Standards.

 PSNS. Pretreatment standards  for new sources of indirect discharges, under sections 307(b) and
 (c) of the Clean Water Act.  See also Effluent Limitations Guidelines and Standards.

 Publicly Owned Treatment Works (POTW). Any device or system owned and operated by a
 public entity and used in the storage, treatment, recycling, or reclamation of liquid municipal
 sewage and/or liquid industrial wastes. The sewerage system that conveys wastewaters to
 treatment works is considered part of the POTW.                              •

 OA/QG. Quality Assurance/Quality Control.

 QC.  Quality Control.

 Quality.  Refers to the suitability of the steel for the purpose or purposes for which it is intended.

 Quenching. A process of rapid cooling from an elevated temperature by contact with liquids,
 gases, or solids.                                        .

 Recirculation. In cold rolling,  use and recirculation of water, detergent, rolling oil, or other
 substance for the removal of loose organic compounds and fines.

 Reduction. A chemical treatment which decreases the positive valences of a substance. In a
 limited sense, removing oxygen from a substance, as in reducing CO to C, CO2 to CO, SiO2 to Si,
 MnOtoMn.                                                 .

 Refining.  Oxidation cycle for transforming hot, metal (iron) and other metallics into steel by
 removing elements present, such.as silicon, phosphorus, manganese, and carbon.
                                          16-17
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                                                                         Section ['16- Glossary
Reheat Furnace.  A gas-fired, refractory-lined furnace used for heating steel shapes for
subsequent hot forming operations.                                               :

Rod. A hot-rolled steel section, usually round in cross-section, produced as a final product or as
an intermediate product for subsequent production of wire and wire products.        I

Rolling. A forming operation that reduces the thickness of a metal piece by passing it between
two or more rolls.

Roughing Stand.  The rolls used for breaking down the ingot, billet, or'slab in the preliminary
rolling of metal products.                                                        '

Runout Table. Area of a hot strip mill located after the finishing stands and before the, coilers
where laminar-flow cooling is applied to the strip. Generally, for any hot forming mill, this area of
the mill is downstream of the last stand of work rolls.  For continuous casters, this area tof the
process is after the torch cut-off.                                                  ;

Salt Bath Descaling. The aggressive physical and chemical removal of heavy scale from semi-
finished specialty and high-alloy steels with molten salt baths.or solutions containing neutral or
acidic salts.                                                                     [•

Scale. Iron oxides which form on the surface of hot steel when the steel is exposed to an
oxidizing atmosphere.

Scale Pit. An in-ground rectangular (and in some instances, circular) basin constructed; of
concrete for recovery of scale from process wastewaters used in hot forming and continuous
casting operations. Collected scale is mechanically removed and recovered for recycle through a
suiter plant or for sale as a by-product.                                            ;

Scarfing.  Removal of imperfections on the surface of semi-finished steel shapes by the'use of
oxygen/acetylene torches.

Scrap.  Iron or steel discard, cuttings, or junk metal which can be reprocessed.

Seamless Pipe/Tube. Tubular product produced by piercing (a hot forming process), which is
followed by farther processing to achieve correct wall and size dimensions, or by extrusion for
small diameter products.

Secondary Steelmaking. The practice of redistributing steel that does not meet the original
customer's specifications because of a defect in its chemistry, gauge or surface quality. Some
steel users may accept lower quality, off-spec steel, usually at a lower price.
                                          16-18
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                                                                          Section 16- Glossary
 Semi-Finished Shapes.  Steel in the form of ingots, blooms, billets, or slabs for forging or rolling
 into a finished product.

 Semi-Wet Air Pollution Control Equipment. A gas cleaning system in which furnace off-gases
 are conditioned with moisture prior to processing in electrostatic precipitators or baghouses.

 Sendzimir Mill.  Type of cold rolling mill used to finish hot-rolled strip to a specific width,
 thickness, and hardness.     ,

 Shear.  In a steel mill,- a machine for cutting steel products.  Steel shears may be classified:  as to
 kind of drive - hydraulic and electric; as to .the work done - cropping, squaring, slab, bloom, billet,
 bar shears; as to type of mechanism - rotary, rocking, gate, guillotine, alligator shears; as to
 movement of work while shearing - flying shears.

 Sheet.  Steel produced in coils or in cut lengths within the following size limitations:

          Width                                       Thickness
          between 12.and 48 inches inclusive
          over 12 inches
0.1800 to 0.2299 inch
0.0449 to 0.1799 inch
SIC.  Standard Industrial Classification, a numerical categorization scheme used by the U.S.
Department of Commerce to denote segments of industry.

Silica Gel Treated Hexane Extractable Material (SGT-HEMX  The freon-free oil and grease
method (EPA Method 1664) used to measure the portion of oil and grease that is similar to total
petroleum hydrocarbons. (Also referred to as nonpolar material (NPM)).

Single Stand. A type of cold rolling stand which has only one roll, used on flat products.

Sinter. In blast furnace usage, lumpy material which has been prepared from flue dust, other
iron-bearing materials, lime, and coke breeze. The dust is agglomerated by heating it to a high
temperature.  Sinter contains valuable amounts of combined iron.

Sintering. The process of burning a fuel (e.g., coke fines, coke breeze) with limestone fines and
a variety of fine iron-bearing materials including iron ore screenings, blast furnace gas cleaning
wastewater sludges, and mill scale to form an, agglomerated product suitable  for charging to a
blast furnace. The product is a clinker-like aggregate referred to as sinter or clinker.

Site. A site is generally one contiguous physical location at which manufacturing operations
related to the  iron and steel industry occur. This includes, but is not limited to, cokemaking,
ironmaking, steelmaking, rolling, and finishing, hi some instances, a site may include properties
located within separate fence lines, but located close to each other.
                                          16-19
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                                                                               &
                                                                         Section 16- Glossary
Skelp.  Flat, hot-rolled steel strip or sheet used to manufacture welded pipe of tube products.
                                                                               i
Slab. A semifinished block of steel formed from a rolled ingot or manufactured on a continuous
slab casting machine, with its width at least twice its thickness.
                                                              •
Slag. Vitrified mineral by-product produced in the reduction of metals from their ores. [ The
principal components of blast furnace slag are oxides of silica and alumina originating chiefly with
the iron-bearing materials and lime and magnesia originating with the flux. The major  l
components of steelmaking slags are calcium silicates, lime-iron compounds, and lesser Amounts
of free lime and magnesia. Usually, slags consist of combinations of acid oxides with basic
oxides; neutral oxides are added to aid fusibility.                                    ,.
                                      •  ,                                       i
                             •
Sludge Dewatering.  The mechanical or natural processes for removal of free water frojm
wastewater sludges. Mechanical equipment used for sludge dewatering may include rotary or leaf
vacuum filters,-filter presses, or belt filters. Wastewater sludges may be dewatered naturally in
sludge drying beds.                                                             ,

Specialty Steel. Steel products containing alloying elements which are added to enhance the
properties of the steel product when individual alloying elements (e.g., aluminum,-chromium,
cobalt, columbium, molybdenum, nickel, titanium, tungsten, vanadium, zirconium) exceed 3% or
the total of all  alloying elements exceeds 5 percent.

Stainless Steel. A trade name:given to alloy steel that is corrosion and heat resistant.  The chief
alloying elements are chromium, nickel, and silicon in various combinations with possible small
percentages of titanium, vanadium, and other elements. By American Iron and Steel Institute
(AISI) definition, a steel is called "stainless" when it contains 10% or more chromium.

Steel.  A hard, tough metal composed of iron alloyed with carbon and other elements to enhance
hardness and resistance to rusting.

Strand. A continuous casting mold and its associated mechanical equipment. Also, a  term
applied to the traveling grate of the sintering machine.                              ;

Stream Degassing. A category of vacuum degassing processes including ladle-to-mold
degassing, ladle-to-ladle degassing, and tap degassing.

Strip.  Steel produced in coils or in cut lengths within the following size limitations:   ;
          Width

          up to 3-1/2 inches inclusive
          between 3-1/2 and 6 inches inclusive
          between 6 and 12 inches inclusive
Thickness                :

0.0255 to 0.2030 inch inclusive
0.0344 to 0.2030 inch inclusive
0.0449 to 0.2299 inch inclusive
                                          16-20
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                                                                        Section 16 - Glossary
 Surface Water. Waters of the United States as defined at 40 CFR 122.2.

 Tandem Mill.  A'mill with a number of stands in succession, generally a cold rolling mill.

 Tapping. Process of opening a taphole in a blast furnace to remove hot metal and slag; process
 of pouring molten steel from a steelmaking furnace into a receiving ladle for transfer to a ladle
 metallurgy station or continuous caster, or into a teeming ladle for pouring into ingot molds.

 Tar. Black, viscous organic matter removed from coke oven gas in recirculating flushing liquor
 systems in the gas collector mains located on top of the by-product recovery coke battery. Tar is
 subsequently recovered in a tar or flushing liquor decanter where most of the tar is separated from
 recirculating flushing liquor by gravity separation.

 2.3.7.8-TCDF.  2,3,7,8-Tetrachlorodibenzo-furan.

 Technical Development Document (TDD). Development Document for the Proposed Effluent
 Limitations Guidelines and Standards for the Iron and Steel Point Source Category.

 Teeming. Pouring or casting of molten steel from a ladle into cast iron ingot molds of various
 dimensions for cooling and solidification of the steel.                 .

 Temper Mill. Relatively light cold rolling process (< 1% thickness reduction) performed to
 improve flatness, alter the mechanical properties of the steel, and minimize surface disturbances.
 Temper mills are usually single-stand mills.

 Three-High Mill.  A stand which has three rolls, one above the other.  The steel which is being
 rolled passes one way between the bottom and middle rolls, and the other way between the middle
 and top rolls.

 Total Organic Carbon (TOC). A nonconventional bulk parameter that measures the total
 organic content of wastewater (EPA Method 415.1). Unlike five-day biochemical oxygen
 demand (BOD5) or chemical oxygen demand (COD), TOC is independent of the oxidation state
 of the organic matter and does not measure other organically bound elements, such as nitrogen
 and hydrogen, and inorganics that can contribute to the oxygen demand measured by BOD5 and
 COD. TOC methods utilize heat and oxygen, ultraviolet irradiation, chemical oxidants, or
 combinations of these oxidants to convert organic carbon to carbon dioxide (CO2). The CO2 is
 then measured by various methods.

 Total Petroleum Hydrocarbons (TPH). - A method-defined parameter that measures the
presence of mineral oils that are extractable in Freon 113 (l,l,2-trichloro-l,2,2-trifluoroethane)
 and not absorbed by silica gel. The analytical method for TPH and oil and grease has been revised
 to allow for the use of normal hexane in place of Freon 113, a chlorofluorocarbon (CFC).
                                         16-21
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                                                                        Section 16- Glossary
Method 1664 (Hexane Extractable Material) replaces the current oil and grease Method 413.1
found in 40 CFR 136. (Also referred to as nonpolar material (NPM)).

Traveling Grate.  Part of a sinter machine or other agglomeration process consisting of zones for
drying, preheating, combustion, and cooling.

TRC. Total Residual Chlorine.                                                  (

TSS. Total Suspended Solids.                                                   ;
                                                                               i1
Tube. A hollow, cylindrical product distinguished from pipe by thinner wall thickness.  Tube is
usually'measured by its outside diameter. Pipe is generally measured by inside diameter^

Tundish.  A refractory-lined vessel located between the ladle and the continuous caster} Molten
steel is tapped from the ladle to the tundish for the purpose of providing a stable flow of metal
into the caster.                     .                                             ;

Tuyeres.  Water cooled openings located around the circumference of a blast furnace at the top.
of the hearth through which the hot blast enters the furnace.                          ;

Two-High Mill. A stand having only two rolls. Some two-high mills are reversing witii screw-
downs to adjust the rolls; others are one way only and may or may not have screw-downs for roll
adjustment and may or may not be a part of a continuous mill.                        J

Utility Operations. The ancillary operations at a steel mill necessary for mill operations, but not
part of a production process (e.g., steam production in a boiler house; power generation;; boiler
water treatment; intake water treatment).

Vacuum Degassing. A process for removing dissolved gases from liquid steel by subjecting it to
a vacuum.                                                                      !

Vacuum Ladle Degassing. A variation of vacuum degassing which includes induction 'stirring
and vacuum-oxygen decarburization.

Variability Factor (VF). A variability factor is used in calculating a limitation to allow for
reasonable, normal variation in pollutant concentrations when processed through well designed
and operated treatment systems. Variability factors account for normal fluctuations in treatment.
By  accounting for these reasonable excursions about the long-term average, EPA's use  pf
variability factors results in limitations that are generally well above the actual long-term average.

Venturi Scrubber. A wet air pollution control device that operates by causing intermixing of
particulates in a gas stream and water applied to the scrubber. The intermixing is accomplished by
                                          16-22
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                                                                        Section 16- Glossary
rapid contraction and expansion of the gas stream and a high degree of turbulence in the throat of
the scrubber.

Vertical Shaft Furnace. A type of furnace used for pelletizing.  Unbaked or green balls are
charged through the top of the furnace, descend through the furnace countercurrent to the hot
gases, and are discharged as pellets. The shaft furnace is well suited for pelletizing magnetite, but
not hematite or limonitic materials.

Volatile  Organic Compound (VOC).  A measure of volatile organic constituents performed by
isotope dilution gas chromatography/mass spectrometry (GC/MS), EPA Method 1624.  The
isotope dilution technique uses stable, isotopically labeled analogs of the compounds of interest as
internal standards in the analysis.

Wastewater. See Process Wastewater.                      =

Wastewater Treatment. The processing of wastewater by physical, chemical, biological, or
other means to remove specific pollutants from the wastewater stream or to alter the physical or
chemical state of specific pollutants in the wastewater stream. Treatment is performed for
discharge of treated wastewater, recycle of treated wastewater to the same process which
generated the wastewater, or for reuse of the treated wastewater in another process.

Water Bubble.  See Alternate Effluent Limitations to Those Representing the Degree of Effluent
Reduction Attainable by the Application of Best Practicable Control Technology Currently
Available, Best Available Technology, and Best Conventional Technology, 40 CFR 420.03.

Wet Air  Pollution Control Equipment. Venturi, orifice plate, or other units used to bring
water into intimate contact with contaminated gas for the purpose of contaminant removal from
the gas stream.                                                  •

Wet Precipitator.  An air pollution control device that uses a spray water wash to cleanse the
fume residue which is collected dry on precipitator plates. Two types of wet precipitators can be
used: intermittent (on a timed cycle) or continuous.

Wet Scrubbers. Venturi or orifice plate units used to'bring water into contact with dirty gas, to
remove it from the gas stream.

Wet-Open Combustion Gas Cleaning  System.  A BOF gas cleaning system in which excess air
is admitted to the off-gas collection system, allowing carbon monoxide to combust prior to high-
energy wet scrubbing for air pollution control.

Wet-Suppressed Combustion Gas Cleaning System. A BOF gas cleaning system in which the
admission of excess air to the off-gas collection system prior to high-energy wet scrubbing for air
                                         16-23
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                                                                       Section 16 -Glossary
pollution control is limited, thus minimizing combustion of carbon monoxide and the volume of
gas requiring subsequent treatment.                                              [

Windbox.  Sintering machine device for drawing air through the sinter strand to enhance the
combustion of fuel in the sinter mix.                                             1

Wire.  Small diameter steel section produced by cold drawing rod through one or more! dies.

Zero Discharge or Alternative Disposal Methods. Disposal of process and/or nonprpcess
wastewaters other than by direct discharge to a surface water or by indirect discharge to a POTW
or PrOTW. Examples include incineration, deep well injection, evaporation on slag or coke, and
contract hauling.
                                         16-24
-------
                          Appendix A - Survey Design and Calculation of National Estimates
                          Appendix A




SURVEY DESIGN AND CALCULATION OF NATIONAL ESTIMATES
-------
-------
                                      Appendix A - Survey Design and Calculation of National Estimates
                                     APPENDIXA

         SURVEY DESIGN AND CALCULATION OF NATIONAL ESTIMATES

          .In 1998, EPA distributed two industry surveys that were similar in content and
 purpose. The first survey, entitled U.S. EPA Collection of 1997 Iron and Steel Industry Data
 (detailed survey), was mailed to 176 iron-and steel industry sites. The second survey, entitled
 U.S. EPA Collection of 1997 Iron and Steel Industry Data (Short Form) (short survey), was
.mailed to 223 iron and steel industry sites.  Both surveys collected detailed technical and financial
 information from iron and steel industry sites. The short form is an abbreviated version of the
 detailed survey and was designed for those iron and steel sites that do not have manufacturing
 processes found only at integrated and non-integrated mills.  Section 3 of this document describes
 these surveys in greater detail.                                      .

              Section 1 of this appendix describes the sampling plan (identification of facilities in
 the industry, sample design, selection of the sample, and out-of-scope and nonresponding
 facilities). Section 2 of this appendix describes the calculation of sample weights.  Section 3 of
 this appendix describes the methodology for estimating national totals and their variance
 estimates.
1.0
SAMPLING PLAN
              This section describes the development of the sampling plan, which includes
identification of the iron and steel industry, selection of the facilities to receive the detailed and
short surveys, and the treatment of out-of scope and nonresponding facilities.
1.1
Sampling Frame
             To produce a mailing list of facilities for the detailed and short surveys, EPA
developed a sampling frame of the iron and steel industry. A sampling frame is a list of all
members (sampling units) of a population, from which a random sample of members will be drawn
for the survey. Therefore, a sample frame is the basis for the development of a sampling plan to
select a random sample. Using the sources identified in Table A-l, EPA developed a sample
frame of iron and steel facilities and divided it into 12 strata (categories) based on the types of
operations conducted at the facility. A sample frame size (N) is the total number of members in
the frame. Since the sample frame sufficiently covered the iron and steel population, the frame
size gave a good estimate of the population size (total number of elements in the population.)

             EPA cross-referenced the sources in Table A-l with one another to obtain facility
level information and to ensure the accuracy and applicability of each facility's information. After
removing the duplicate entries, EPA estimated 822 engaged in iron and steel manufacturing.
These facilities include some facilities that EPA now proposes to include in the Metal Products"
and Machinery (MP&M) Category and will be regulated under 40 CFR Part 438.
                                          A-l
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                                       Appendix A - Survey Design and Calculation of National Estimates
1.2
Sample Design
              To minimize the burden on the respondents to the industry surveys and improve
the precision of estimates from the survey, EPA grouped the facilities into 12 strata (categories),
with operations in each stratum  expected to be similar. In general, the strata were determined by
EPA's understanding of the manufacturing processes at each facility. This grouping of similar
facilities is known as stratification. Table A-2 describes the stratification of the iron and steel
industry. The Agency also developed two "certainty strata," one for the detailed survey and one
for the short form (strata 5 and 8, respectively).                                 .   '  -

              EPA selected a stratified random sample using the sampling frame.  A stratified
random sample separates the eligible population into nonoverlapping strata, that are as. j       ,
homogeneous as possible.  Together these strata .make up the whole eligible population.  A simple
random sample is then selected from each stratum.                                 ;
                                                                               i
              For the iron and steel industry surveys, there were 12 strata: seven for the detailed
survey and five for the short survey. Table A-2 includes the strata descriptions.

13           Sample Selection of Facilities

              EPA selected 402 facilities out of the 822 facilities identified in the sample frame.
Table A-2 provides the frame size and sample size for each of the 12 strata. Depending  on the
amount/type of information EPA determined it needed for this rulemaking and the number of
facilities in a stratum, the Agency either solicited information from all facilities within a stratum
(i.e., performed a census) or selected a random sample of facilities within each stratum.  EPA sent
a survey to all the facilities in strata 5 and 8, determining that it was necessary to capture the size,
complexity, or uniqueness of the steel operations present at these sites. EPA also sent surveys to
all the facilities in strata 1 though 4 (all cokemaking sites, integrated steel sites, and all sintering
and direct reduced iron sites) because the number of sites is relatively low and because of the size,
complexity, and uniqueness of raw material preparation and steel manufacturing operations
present. EPA statistically sampled the remaining sites in strata 6, 7, and 9 through 12. The
sample sizes were determined to detect a relative difference of 30 percent on a proportion of 0.25
with 90 percent confidence for a binary variable (e.g., a yes/no question).1 EPA used the
following formula to calculate the sample size for each stratum:
                                  n.  =
                                           Z2q/(d2p)
                                        1  +
                              [Z2q/(d2p)3
                                   N,
                                                                                    (A-l)
 1 While many questions are not binary, this is a common assumption used in survey methodology.
                                           A-2
-------
                                       Appendix. A- Survey Design and Calculation of National Estimates
 where:
              P
              q
              z
              Number of samples to be selected from stratum h, and h=l,2,...,12
              True proportion being estimated (assuming to be 0.25)
              1-p
              Value obtained from the standard normal (Z) distribution.  (For 90
              percent confidence, this value is 1.645, which is 95th percentile of
              standard normal distribution.)
              Relative difference (assuming to.be 0.3 or 30 percent)
              Total number of facilities in stratum h.
1.4
Out-of-Scope Sites and Response Rates
              EPA mailed industry surveys to all of the facilities in the sample. After receiving
the industry survey, EPA determined that some facilities were "out-of-scope" or "ineligible"
because the regulation would not apply to them.  After reviewing the survey responses, EPA
identified additional ineligible facilities. In all, EPA identified 203 of the 402 sample facilities as
ineligible. Over 75 percent of these facilities were ineligible because EPA is proposing that their
operations be regulated under the MP&M Category (see Section 1 of this document).

              Of the remaining 199 facilities, 188 were eligible respondents, and 11 were
nonrespondents (i.e., did not return a survey).  The overall unweighted response rate was 94
percent (188/199). Section 2 of this appendix provides detailed facility level response rates by
stratum.  EPA made a nonresponderit adjustment to the weights, as described in Section 2 of this
appendix.
2.0
CALCULATION OF SAMPLE WEIGHTS
              This section describes the methodology used to calculate the base weights, non-
response adjustments, and the final weights. The base weights and nonresponse adjustments
reflect the probability of selection for each facility and adjustments for facility level non-responses,
respectively. Weighting the data allows inferences to be made about all eligible facilities, not just
those included in the sample, but also those not included in the sample or those that did not
respond to the survey. Also, the weighted estimates have a smaller variance than unweighted
estimates (see Section 3 of this appendix for variance estimation.) In its analysis, EPA applied
sample weights to survey data.
2.1
Base Weights
              The base weight assigned to each facility is the reciprocal of the probability that
the facility was sampled for the particular stratum. EPA took a census for strata 1 through 5 and
stratum 8; thus, the probability of selection for facilities in these strata is one.  EPA selected-a
simple random sample from strata 6 and 7 and strata 9 through 12. The probability of selection
for facility i from stratum h can be written as:                                           -
                                           A-3
-------
                                       Appendix A - Survey Design and Calculation of National Estimates
where:
                                    PROBSEL. = -i
                                              hl   N,
                                                                      (A-2)
              i
              h
              Facility i
              Any of the h=l,2,..., 12 strata
              Total sample size for stratum h
              Total frame size for stratum h.
              The base weight is the inverse of this probability, and for facility i in stratum h can
be written as:                                                                   i
                          BASE WEIGHTh =
                                                   1
                                              PROBSELh     nh
                                                                      (A-3)
              Table A-2 provides the sample size and frame size by stratum.  Using stratum 6
from Table 3-1 as an example, the probability of selection for all sampled facilities in stritum 6
would be 40/69=.57971. Thus, the base weight for all facilities in stratum 6 would be  :
17.57971=1.725.                      '                                          i
2.2
Facility Level Nonresoonse Adjustment
              EPA made a facility-level nonresponse adjustment to account for those facilities
that did not complete the industry surveys.  Since the eligibility status of the nonrespondents was
unknown, EPA assumed that the eligibility status of the nonrespondents was proportional to the
known proportion of eligible respondents and ineligibles.
where:
follows:
              The facility-level nonresponse adjustment for stratum h was calculated as
                                                                                   (A-4)
              rh     =     Number of sample facilities (eligible and ineligible facilities) in
                           stratum h responding to the detailed survey and short survey.

              For example, the nonresponse adjustment for stratum 6 can be calculated as
                            NRA, =    40
                                6    30+9
                               = i2. =  1.02564
                                 39
(A-5)
                                          A-4
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                                       Appendix A - Survey Design and Calculation of National Estimates
              Table A-3 provides the response status of the sampled cases and the base weight
 and facility-level nonresponse adjustment by stratum.  There were no eligible respondents in
 stratum 12; therefore, EPA also assumed the nonrespondents to be ineligible.
 2.3
Final Weights
              The final facility weight is the product of the base weight and the facility-level
nonresponse adjustment. This can be written as:

                             FINALWTh = BASEWThxNRAh                        (A-6)

              Again, using the example from stratum 6, the final facility weight would be:

                                1.725'x 1.02564=1.76923

              Ineligible facilities also have a base weight and nonresponse adjustments, and thus
an associated final weight. However, they represent only other ineligible facilities in this sample
frame. Therefore, their contribution to the national estimates are not of interest, and thus their
final weights are zeros.

              Table A-4 provides the base weight, facility-level nonresponse adjustment factor,
and final weight for each facility by stratum.
3.0
ESTIMATION METHODOLOGY
              This section presents the general methodology and equations for calculating
estimates from the detailed survey and short form sampling efforts.
3.1
National Estimates
              For each characteristic of interest (e.g., number of a particular operation using dry
air pollution control or annual discharge flow from a particular operation), EPA estimated totals
for the entire U.S. iron and steel industry ('national estimates'). Each national estimate, Y^, was
calculated as:
where:
                                   12                 nh
                            Yst = E  [FINALWTh- £ yj
                                  h=l                i=l
             h            =     Stratum and h=l,2,... 12 since there are 12 strata
             FINALWTh   =     Final weight for the stratum h
             Vjh           =     ith value from the sample in stratum h.
                                                                      (A-7)
                                          A-5
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                                      Appendix A - Survey Design and Calculation of National Estimates
3.2
where:
Variance Estimation
«^———————                                            |;
                                                                i
The estimate of the variance for a national estimate can be calculated as follows:
              L

              FPCh
                     L

                    h=l

FINALWTh2 • FPCh • nh • sh2
                                                                                   (A-8)
             National estimate of number of facilities with the characteristic of
             interest                              .              \.
             Number of strata (Z>= 12)                            \

                    n                                     '      !  '
               1	1     (finite population correction for stratum h)
                    •^h                                          f
                                     n.
                2   =
                             nh -
                           (the estimate of the variance within stratum h where

                                   nh
                                  2-j yih  is the sample mean of stratum h).
                                    n.
              The variance estimates can be used to calculate confidence intervals for the survey
estimates. The confidence interval comprises a lower confidence limit and an upper confidence
limit The greater the variance, the wider the interval, and the lower the precision associated with
the estimate. A 95-percent confidence interval should be interpreted as follows: If many samples
were taken from the population of interest and a confidence interval were calculated from each
sample, 95 percent of the confidence intervals would contain the true value of what is being
estimated and 5 percent of the confidence intervals would not contain the true value.  Thus, a 95-
percent confidence interval is interpreted as saying that the true value of the population pan be
found by the random interval 95 percent of the time. The lower and upper 95-percent confidence
limits can be written as:                                                         !   '
              Lower 95-percent confidence limit =  Y^ -. (z •  ^var(Yst)|

              Upper 95-percent confidence limit =  Yst  + (z • ^var(Yst)j
                                                                     (A-9)

                                                                    (A-10)
                                          A-6
-------
                                        Appendix A - Survey Design and Calculation of National Estimates
 where:

               Z      =      Value obtained from the standard normal (Z) distribution.  (For 95-
                             percent confidence interval, this value is 1.96* which is 97.5th
                             percentile of standard normal distribution.)2

 When comparing estimates, if the confidence intervals overlap, there is no statistically significant
 difference between the two estimates.
 4.0

 A-l


,A-2
REFERENCES

Cochran, William G. Sampling Techniques. 3rd Ed. New York: John Wiley and
Sons, Inc., 1977.                       .                  '

SAS®, The SAS System, SAS Institute Inc.
2When the national estimate is based on a sample size of less than 30, the appropriate value from the t distribution is
used instead of Z0 02S for calculating the upper and lower confidence limits.
                                            A-7
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                                    Appendix A - Survey Design and Calculation of National Estimates
                                    Table A-l
               Sources Used For Development of Sample Frame
      Association of Iron and Steel Engineers' 1997 Directory: Iron and Steel Plants
      Volume 1, Plants and Facilities
      Iron and Steel Works of the World (12th edition) directory
      Iron and Steel Society's Steel Industry of Canada, Mexico, and the United States: Plant
4
5
6
i
American Coke and Coal Chemicals Institute (Membership List)
American Galvanizers Association (Membership List)
American Iron and Steel Institute (Membership List)

      Cold Finished Steel Bar Institute (Membership List)
      Specialty Steel Industry of North America (Membership List)
10
Steel Manufacturers Association (Membership List)
11
Steel Tube Industry of North America (Membership List)
12
Wire Association International (Membership List)
13
Dun & Bradstreet Facility Index database
14
EPA Permit Compliance System (PCS) database
15
EPA Toxic Release Inventory (TRI) database
16
17
18

Iron and Steelmaker Journal. "Roundup" editions
33 Metaloroducine Journal. "Census of the North American Steel Industry"
33 Metaloroducine Journal, "Roundup" editions





                                        A-8
-------
                             Appendix A - Survey Design and Calculation of National Estimates
                              Table A-2
Frame Sizes and Sample Sizes for the Iron and Steel Population Frame
Stratum
h
Stratum Description
Frame
Size
(Nfc)'
Sample
Size
(i»h)
Detailed Survey Strata
1
2
3
4
5 .
6
7
Integrated steel facilities with cokemaking
Integrated steel facilities without cokemaking
Stand-alone cokemaking facilities
Stand-alone direct reduced ironmaking or sintering
facilities '
Detailed survey certainty stratum
Non-integrated facilities (with and without finishing)
Stand-alone finishing and stand-alone hot forming
facilities
9
12
16
5
60
69
54
9
12
16
5
60
40
35
Short Survey Strata
8
9
10
11
12
Short survey certainty stratum
Stand-alone cold forming facilities
Stand-alone pipe and tube facilities
Stand-alone hot dip coating facilities
Stand-alone wire facilities
TOTAL:
13
62
164
106
252
822
13
37
59
49
67
402
                                 A-9
-------
                                Appendix A - Survey Design and Calculation of National Estimates
                                Table A-3
Response Status, Base Weight, and Facility-Level Nonresponse Adjustments
                               by Stratum
Stratum
(h)
1
2
3
4
5
6
7
8
9
10
11
12
Total
Frame
Size
(Nh)
9
12
16
5
60
69
54
13
62
164
106
252
822
Sample
Size
(nj
9
12
16
5
60
40
35
13
37
59
49
67
402
Response Status
Number of
Eligible
9
12
15
3
54
30
28
11
19
6
1
0
188
Number of
Ineligible
0
0
1
2
4
9
. 7
2 ,
18
50
48
62
203
Number of
Nonrespondents
0
0
0
0
2
1
0
0
0
3
0
5
11
Base
Weight
1.00000
.1.00000
1.00000
1.00000
1.00000
1.72500
1.54286
1.00000
1.67568
2.77966
2.16327
3.76119

Facility Level
Nonresponse
Adjustment
1.00000
1.00000
I'OOOOO
1.00000
1.03448
li.02564
l|.00000
1.00000
1.00000
1.05357
1.00000
OlOOOOO
1
                                   A-10
-------
                            Appendix A - Survey Design and Calculation of National Estimates
                             Table A-4

Base Weights, Facility-Level Nonresponse Adjustment Factors, and
                     Final Weights by Stratum
Stratum
1
2
3
4
5
6
7
8
9
10
11
12
Base Weight
1.00000
1.00000
1.00000
1.00000
1.00000
1.72500
1.54286
1.00000
1.67568
2.77966
2.16327
3.76119
Facility Level
Nonresponse
Adjustment
1.00000
1.00000
1.00000
1.00000
1.03448
1.02564
1.00000
1.00000
1.00000
1.05357
1.00000
0.00000
Final Weight
1.00000
1.00000
1.00000
1.00000
1.03448
1.76923
1.54286
1.00000
1.67568
2.92857
2.16327
0.00000
                               A-ll
-------
-------
                           Appendix B - Revised Editing Criteria for POTW Pass-Through Analysis
                               Appendix B




REVISED EDITING CRITERIA FOR POTW PASS-THROUGH ANALYSIS
-------
-------
                                  Appendix B - Revised Editing Criteria for POTW Pass-Through Analysis
                                      Appendix B

       REVISED EDITING CRITERIA FOR POTW PASS-THROUGH ANALYSIS
              For the proposed Iron and Steel rule, EPA used its traditional methodology to
 determine POTW performance (percent removal) for priority and nonconventional pollutants.
 POTW performance is a component of the pass-through methodology used to identify the
 pollutants to be regulated for PSES and PSNS. It is also a component of the analysis to
 determine net pollutant reductions (for both total pounds and toxic pound-equivalents) for various
 indirect discharge technology options (see Section 10). However, as discussed in more detail
 below, EPA is considering revisions to its traditional methodology for determining POTW
 performance (percent removals) for priority and nonconventional pollutants.  In the traditional
 methodology, the pertinent data selection editing criteria used to determine POTW percent
 removals were based on the editing criteria listed in Section 11 for each data source. However,
 since POTWs are designed to treat conventional pollutants, not toxic pollutants, the revised
 editing criteria would more accurately reflect the incidental removals of toxic pollutants in
 POTWs.

              See Section 11 for general information on the POTW pass-through analysis
 methodology and for data-editing criteria used for the proposed Iron and Steel rule.

              Review of the 50-POTW Study Analytical Laboratory Reporting Practices
              and Standardization of Minimum Level (ML) Values

              At the time of the 50-POTW sampling program that spanned approximately 2.5
 years (July 1978 to November 1980), EPA collected samples at selected POTWs across the
 United States. The samples were subsequently analyzed by either EPA or EPA contract
 laboratories using test procedures (analytical methods) specified by the Agency or in use at the
 laboratories. Laboratories typically reported the analytical method used along with the test
 results. However, for those cases in which the laboratory specified no analytical method, EPA
 was able to specify the method based on the nature of the results and knowledge of the methods
 available at the time.

             To provide consistency for data analysis and establishment of removal efficiencies,
 EPA reviewed the 50-POTW Study and standardized the reported MLs for use in the Centralized
 Water Treatment (CWT) final rule and the proposed Iron and Steel rule. EPA standardized the
MLs based on information about the analytical methods used, laboratory capabilities at the time
the testing was conducted (1978 to 1980), MLs that had been achievable historically, and
 consultation with Agency experts in the field of analytical chemistry. The standardized MLs are
used in this reassessment.
                                          B-l
-------
                                     Appendix B - Revised Editing Criteria for POTW Pass-Through Analysis
               Reassessment of the Pass-Through Methodology and Revised Editing
               Criteria for the 50-POTW Study

               The Agency reevaluated several aspects of the 50-POTW Study databass editing
 process and is considering changes to the editing criteria.  Appendix C, "Revised Data
 Conventions for the 50-POTW Study Analytical Data," describes the minor editing criteria
 changes that EPA is considering for use in the final Iron and Steel pretreatment standards,
 including those related to the presence of analytical interferences, missing data, reported greater-
, than values, and reported less-than values higher than the minimum levels.            ,

               The principal editing criterion of the pass-through analysis used for the proposed
 Iron and Steel rule was to use available performance data representing average influent
 concentrations 10 times the analytical rninimum level.  This is also the primary editing criteria for
 ensuring that promulgated effluent limitations guidelines and standards are based only on the
 performance of BAT wastewater treatment systems with meaningful influent concentrations of
 pollutants.  This editing criterion ensures that BAT data would demonstrate at least 90 percent
 removal of priority pollutants.  EPA selected this criterion for the POTW data for similar reasons.
 However, after reconsidering the design differences between industrial BAT treatment and POTW
 treatment systems, as well as the differences in toxic pollutant influent concentrations, EPA
 believes that the "10 x ML" editing criterion is too restrictive- for the purpose of analyzing POTW
 data, especially where effluent values are above the minimum level.
                                                                                   i
               The majority of discharging POTWs (67 percent) have installed secondary
 biological treatment systems1 designed to treat conventional pollutants characteristic of [domestic
 sewage (primarily BOD and TSS).  Most POTWs with secondary treatment have installed a
 variation of the activated sludge biological process with typical wastewater hydraulic residence
 times ranging from 4 to 8 hours for the most prevalent process designs.2 Very few secondary
 POTWs install unit operations specifically designed to remove priority and nonconventipnal.
 pollutants.3                                                   •                     ;
 1 The 1996 Clean Water Needs Survey (Reference B-l) found that of the 13,992 discharging POTWs, 1.3 percent
 reported less than secondary treatment, 67.1 percent reported secondary treatment, and the remaining 31.6 percent
 reported better than secondary treatment fwww.epa.gov/owm/uc.htm at Reference B-1; Appendix C).    :

 2 Hydraulic residence times for the conventional and tapered aeration activated sludge processes range from 4 to 8
 hours; for the step aeration and contact stabilization processes, from 3 to 6 hours; for the modified and high-rate aeration
 processes, from 0.5 to 3 hours; and for the extended aeration process, from 18 to 36 hours (1992 WEF Manual of
 Practice No. 8. page 627. Vol. D (Reference B-2).                                           |

 3 Typical POTW unit operations include preliminary treatment (screening and grit removal), primary treatment
 (sedimentation, sludge collection, arid odor control), and secondary treatment (biological treatment with secondary
 clarification). POTW unit operations associated with advanced or tertiary treatment include nutrient controls
 (phosphorus and nitrogen [including ammonia] removal processes), multimedia filtration, and activated carbon (1992
 WEF Manual of Practice No. 8. pages 389,447, 517, and 675, Vol. I and pages 895 and  1013, Vol. II) (Reference B-2).
                                             B-2
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                                    Appendix B - Revised Editing Criteria for POTW Pass-Through Analysis
               In contrast, depending on raw waste characteristics, industrial treatment systems
 are often designed to remove toxic pollutants using a wide variety of in-plant wastewater
 treatment unit operations with or without end-of-pipe secondary biological treatment systems and
 sometimes followed by tertiary controls. For example, plants in the metal products and
 machinery, electroplating, iron and steel, OCPSF, inorganic chemicals, landfills, commercial
 hazardous waste combustor, CWT, and other industries may use in-process or end-of-pipe
 chemical precipitation for metals control, alkaline chlorination for cyanide control, steam or air
 stripping for volatile organic pollutant control, and activated carbon or biological treatment for
 control of a wide variety of organic pollutants. For plants in the OCPSF industry with end-of-
 pipe secondary biological treatment systems, the median and average wastewater hydraulic
 residence tunes are 48 and 118 hours, respectively.4 Most of the pollutant-specific treatment unit
 operations listed above are not used to treat POTW wastewater because of the relatively low
 influent toxic pollutant concentrations. POTW toxic pollutant influent concentrations are often
 orders of magnitude lower than industrial raw-waste concentrations. .

              Because of these design and toxic pollutant influent concentration differences, the
 POTW data-editing criteria should reflect typical incidental removals of toxic pollutants in
 secondary biological treatment systems designed and operated to control municipal sewerage. In
 general, due to dilution in municipal sewer collection systems, POTW influent concentrations of
 toxic pollutants are lower than the influent concentrations of industrial treatment systems. In
 those cases where both industrial and municipal treatment systems reduce the effluent pollutant
 concentration to the analytical minimum level, the relative performance (percent removal) is
 primarily a function of the influent concentrations. This was the principal reason for initially using
 the "10 x ML" influent editing'criterion for retaining POTW average performance data - to avoid
 the bias of calculating artificially low median percent removals (median of POTW average
 performance). However, this editing criterion, when applied to the 50-POTW Study data,
 overestimates POTW incidental'removals for many toxic pollutants. In the 50-POTW Study
 database, there are many cases where POTW average influent concentrations are less than the
 "10 x ML" edit and the average effluent data are  above the ML. These cases should be included
 in the calculation of national POTW performance (median of POTW average percent removals)
 because they accurately reflect the incidental removals of the toxic pollutants in treatment systems
 primarily designed to control conventional pollutants.  For example, for many POTWs in the
 study, average metal pollutant influent concentrations less than "10 times the ML" are paired with
 average effluent concentrations where each data point is measured above the analytical minimum
 level. Because of these pairings, EPA can accurately calculate the incidental removals of toxic
pollutants characteristic of POTW designs and the characteristically low POTW toxic pollutant
 influent concentrations. EPA believes it is reasonable to include these percent removal
 calculations in its pass-through analysis.
4 Based on 31 OCPSF biological treatment systems with residence times ranging from 4.5 to 1,008 hours (Development
Document for Effluent Limitations Guidelines and Standards for the Organic Chemicals. Plastics, and Synthetic Fibers
Point Source Category. EPA 440/1-87/009, October 1987, Vol. II, page VIH-45 and Supplement to the Development
Document for Effluent Limitations Guidelines and Standards for the Organic Chemicals. Plastics, and Synthetic Fibers
Point Source Category. EPA 821-R-93-007. May 1993; pages III-2Q to 111-23).
                                           B-3
-------
                                  Appendix B - Revised Editing Criteria for POTW Pass-Through Analysis
              Furthermore, one of the observations and conclusions in the 50-POTW Study was
that, for many pollutants, "as influent concentrations increased, effluent concentrations also  •
increased. This implies that the removal rates for the priority pollutants are relatively cpnstant
and a fixed percentage of incremental loadings of these pollutants will be removed by secondary
treatment." Therefore, except for highly biodegradable compounds, for typical POTW secondary
biological treatment designs without specific unit operations for toxic pollutant control, one
would not necessarily expect the percent removals of toxic pollutants to increase (above incidental
removal levels) as influent concentrations increased.

              Assessment of Editing Criteria for 50-POTW Study Performance by
              Treatment Technology                                           I
                                                                              t
              EPA is also considering incorporating POTW treatment system and BOD/TSS
performance editing criteria into the methodology for determining POTW performance (percent
removal) for priority and nonconventional pollutants.

              A major goal of the 50-POTW study was to obtain priority pollutant data from
representative types of secondary treatment facilities that would exist after completion of EPA's
Construction Grants program. The 50 POTWs selected for sampling are representative [of
biological treatment processes - 35 activated sludge, 8 trickling filter, 4 activated sludge with
parallel trickling filter, 1  rotating biological contactor, 1 aerated lagoon, and 1 lagoon system.
Eight of these POTWs include post-secondary or tertiary treatment (four filtration and four
lagoon systems).                                                   .
                                                                              I
              The 50-POTW Study and subsequent assessments of POTW performanc|e
(including the assessment for me proposed Iron and Steel rule) used combined end-of-pipe data
for all 50 POTWs.  The analyses did not assess potential differences in toxic pollutant reductions
among the various types  of secondary systems, between secondary and tertiary systems, and
among different levels of BOD5 and TSS control (the principal design basis for POTW treatment
systems).
             After publication of the 50-POTW Study, EPA promulgated its Secondary
Treatment Regulation (40 CFR Part 133) to provide information on the level of effluent
quality
attainable through the application of secondary or equivalent treatment.  Secondary treatment
generally refers to activated sludge biological processes, and treatment equivalent to secondary
treatment refers to trickling filters or waste stabilization ponds. The secondary treatment
performance criteria for both BOD5 and TSS are 30-day and 7-day averages not exceeding 30
mg/L and 45 mg/L, respectively. The BOD5 and TSS criteria for equivalent secondary treatment
are 30-day and 7-day averages not exceeding 45 mg/L and 65 mg/L, respectively. These
definitions and treatment levels provide the basis for the technology and BOD5 /TSS performance
edits being proposed for use in the proposed rule.                                  [

           '  The revised analyses under consideration include separating the data collected for
the four parallel activated sludge and trickling filter systems and, for two of the tertiary systems,
including the secondary activated sludge sampling data.  This expands the performance database
                                          B-4
-------
                                   Appendix B - Revised Editing Criteria for POTW Pass-Through Analysis
to 56 POTW treatment trains - 41 activated sludge, 12 trickling filter, 1 rotating biological
contactor, 1 aerated lagoon, and 1 lagoon system. Again, eight of these treatment trains include
post-secondary or tertiary treatment (four filtration and four lagoon systems). Based on the
definitions in 40 CFR Part 133, the POTW treatment trains consist of 47 secondary or equivalent
systems, 1 rotating biological contactor, and 8 post-secondary or tertiary systems. The Agency is
considering a variety of POTW treatment train and BOD/TSS performance editing criteria to
determine if these factors significantly affect the incidental removals of priority and
nonconventional pollutants in POTWs. For example, among other alternatives, EPA is
considering editing criteria that would retain only those secondary or equivalent treatment trains
and the rotating biological contactor treatment train that meet the BOD5 /TSS 7-day average
performance criteria. EPA is considering this alternative because it accounts for the fact that only
6 days of data were collected at each POTW.

              Revised Editing Criteria for Determining POTW Performance for the
              50-POTW Study

              Based on these concerns, EPA is considering revising the POTW priority and
nonconventional pollutant performance (percent removal) editing criteria.  Given the range of
analytical minimum levels5 and their influence on calculated percent removals, as well as the range
of in-place POTW treatment technology,  EPA is considering several editing alternatives including:

              •     Alternative A - For POTW treatment trains that meet the 7-day
                    conventional pollutant performance criteria for BOD5 (45 mg/L or lower)
                    and TSS (45 mg/L or lower) using secondary activated sludge biological
                    treatment or its equivalent:

                    1)  .   If all effluent values are equal to the ML and the ML is less than or
                           equal to 20 ug/1, retain the pollutant performance (percent removal)
                           if the pollutant influent average is at least 10 times the nominal
                           minimum level (10 x ML).

                    2)     If all effluent values are equal to the ML and the ML is greater than
                           20 ppb, retain the pollutant performance (percent removal) if the
                           pollutant influent average is at least 10 times one-half the nominal
                           minimum level (10 * yz ML or 5 x ML).

                    3)     If the effluent average is greater than the ML, retain the pollutant
                           performance (percent removal) regardless of the pollutant influent
                           average.
5 For mostorganic pollutants, the ML is 10 ug/1 (several have MLs of 20 and 50 ug/1). For mercury, silver, cadmium,
zinc, copper, nickel, lead, and barium, the respective MLs are 0.2,2,5,20,25,40, 50, and 200 ug/1.
                                          B-5
-------
              Appendix B - Revised Editing Criteria for POTW Pass-Through Analysis
4)     The national POTW/pollutant percent removal is the median of the
       retained values from 1, 2, and 3 above.                 |
                                                          i
Alternative B — The same as Alternative A for items 1, 2, and 4 with the
following modification to item 3:  If the effluent average is greater than the
ML, retain the pollutant performance (percent removal) if the pollutant
influent average is at least two times the nominal minimum level [2 x ML).
Based on the analyses conducted to date, this is the Agency's preferred
alternative.
                                                         atme
              •      Alternative C - Retain all priority pollutant data for POTW treatment
                     trams that meet the 7-day conventional pollutant performance criteria for
                     BODS (45 mg/L or lower) and TSS (45 mg/L or lower) using secondary
                     activated sludge biological treatment or its equivalent.           '\

              •      Alternative D — The same as Alternative B with the following
                     modifications: (a) retain POTW treatment trains with secondary biological
                     treatment (as designated by treatment flag "S"), only if both the effluent
                     BOD5 and TSS average concentrations are less than or equal to 45 mg/L,
                     and ,(b) retain POTW treatment trains with equivalent to secondary
                     biological treatment (as designated by treatment flag "E"), only if both the
                     effluent BOD5 and TSS average concentrations are less than or equal to 65
                     mg/L.                                    .                 I
                    . '    •   ';                    '                              t
              •      Alternative E — The same as Alternative D with the following
                     modification: substitute 1A x ML for all data points set equal to the
                     analytical ML.

              Table B-l lists the national POTW percent removals for several pollutants,
"determined by using the traditional methodology for the proposed rule, Alternative A, Alternative
B, Alternative C, Alternative D, and Alternative E.  For the proposed rule, EPA has used the
traditional methodology to estimate POTW percent removals, and, therefore, whether these
pollutants "pass through" for purposes of selecting pollutants for regulation by PSES and PSNS..

              Assessment of the Use of Analytical Minimum Levels for the 50-POTW
              Study

              Since some commenters on other effluent limitations guidelines and standards have
complained that EPA's use of the ML for reported effluent data of 
-------
                                   Appendix B - Revised Editing Criteria for POTW Pass-Through Analysis
              To help characterize the effect of substituting the analytical ML for not-detected
 data, the Agency assigned each POTW/pollutant dataset to one of three groups based on the
 proportion of not-detected effluent values, as follows:

              1)     All ND - when all of the effluent data points were not detected or assigned
                     the ML value for the pollutant;  .  .       .

              2)     All NC (noncensored) - when all of the effluent data points were measured
                     concentrations above the ML for the pollutant; and

              3)     Mix (NC and ND) - when the effluent data points were a mixture of not-
                     detect and measured values.

              For those cases where all of the effluent data were noncensored, the calculated
percent removal reflects POTW incidental removals with the most accuracy. For those cases
where all the effluent data were not detected, the calculated percent removal reflects POTW
incidental removals with the least accuracy.  In those cases where the effluent data is a mixture of
not detected and noncensored data, the calculated percent removals are probably more accurate
than "All ND" but less accurate than "All NC". Table A-2 provides pollutant-by-pollutant
tabulations for the number of POTWs retained by the Alternative D data conventions with counts
of the POTWs' effluent datasets that fall into each category.

              For the 21 metal pollutants retained by the Alternative D data conventions, about
97 percent of the 347 POTW/metal pollutant effluent datasets in the table comprise all NC (66
percent) and a mixture of NC and ND (31  percent) values. For ammonia and cyanide, 100
percent of the 65 data sets comprise all NC (99.5 percent) and a mixture of NC & ND (0.5
percent) values.

              The 28 organic pollutants retained by the Alternative D data conventions were
divided into low, medium, and high Henry's Law Constant groups.  For the six organics with low
Henry's Law Constants (10~3 to  10'8), about 81 percent of the 38 POTW/organic pollutant
effluent datasets in the table comprise all NC (18 percent) and a mixture of NC and ND (63
percent) values. For the nine organics with medium Henry's Law Constants (10"1 to  10"3), about
83 percent of the 36 POTW/organic pollutant effluent datasets in the table comprise all NC (25
percent) and a mixture of NC and ND (58  percent) values. For the 13 organics with high Henry's
Law Constants (2 x 102 to 10'1), about 83  percent of the 73 POTW/organic pollutant effluent
datasets in the table comprise all NC (19 percent) and a mixture of NC and ND (64 percent)
values.

             The Agency concludes that POTW performance for metals, ammonia,  cyanide, and
organic pollutants is not significantly affected by the bias of effluent data being less than the
minimum levels.
                                           B-7
-------
                    Appendix B-Revised Editing Criteria for POTW Pass-Through Analysis
References

U.S. Environmental Protection Agency.  1996 Clean Water Needs Survey.  1996.
B-l

B-2
U.S. Environmental Protection Agency.  1992 WEF Manual of Practice-No. 8
(Volume I and II).  1992.
                            B-8
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-------
                      Appendix B - Revised Editing Criteria for POTW Pass-Through Analysis
                           Table B-2
Number of POTWs Retained by Alternative D Data Conventions







Analyte
CAS No.
Total
Number of
POTWs
Effluent All
(NC)
Effluent
Mix
(NC and
ND)
Effluent
(ND)
Class=M, Tech Group=E or S [
Aluminum
Antimony
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Silver
Sodium
Tin
Titanium
Vanadium
Yttrium
Total
7429905
7440360
7440428
7440439
7440702
7440473
7440484
7440508
7439896
7439921
7439954
7439965
7439976
7439987
7440020
7440224
7440235
7440315
7440326
7440622
7440655

31
1
6
6
36
34
1
34
43
7
22
40
15
2
14
.17
21
3
10
2
2
73
11
1
4
2
35
23
0
13
34
2
22
38
4
1
9
5
21
1
1
2
0
14
16
0
2
4
1 '
11
1
17
9
4
0
2
11
1
5
12
0
2
9
0
2
47
4
0
P
b
o •
0
P
4
0
1
• '9
0
p
6
p
• p
0
p
0
i>
p
12
1
1

B-10
I
['
-------
  Appendix B - Revised Editing Criteria for POTW Pass-Through Analysis
Table B-2 (Continued)
Analyte
CAS No.
Total
Number of
POTWs
Effluent All
(NQ
Effluent
Mix
(NC and
ND)
Effluent
(ND)
Class=N, Tech Group=E or S
Ammonia as N
Total Cyanide
Total
7664417 '
57125

35
30
65
35
27
62
0
3
3
0
0
0
Class=O_LOW, Tech Group=E or S '
Bis(2-ethylhexyl)phthalate
Butyl benzyl phthalate
Di-n-butyl phthalate
Di-n-octyl phthalate
Fluoranthene
Phenol
Total
117817
85687
84742
117840
206440
108952

25
1
2'
2
1
7
38
6
0
0
0
0
1
7
19
0
2
2
1
0
24
0
1
0
0,
0
6
7
Class=O_MED, Tech Group=E or S
Acenaphthene
Anthracene
Methylene chloride
Naphthalene
Phenanthrene
1 ,2-Dichlorobenzene
1 ,2-Dichloroethane
1 ,2-Dichloropropane
1 ,2,4-Trichlorobenzene
Total
83329
120127
75092
91203
. 85018
95501
107062
78875
120821

2
' 2
22
-1
2
2
2
1
2
36
.0
0
7
0
0
0
2
0
0
9
1
1
15
0
1
1
0
0
2
21
1
i
0
i
i
i
0
1
0
6
         B-ll
-------
  Appendix B - Revised Editing Criteria for POTW Pass-Through Analysis
Table B-2 (Continued)
Analyte
CAS No.
Total
Number of
POTWs
Effluent All
(NC)
Effluent
Mix
(NC and
ND)
Effluent
(ND)
Class=OJHIGH, Tech Group=E or S
Benzene
Chlorobenzene
CMoroform
Chloromethane
Dichlorodifluoromethane
Ethylbenzene
Tetrachloroethene
Tetrachloromethane
Toluene
Trans- 1 ,2-Dichloroethene
TricMorethene
Vinyl chloride
1,1,1-Trichloroethane
Total
71432
108907
67663
74873
75718
100414
127184
56235
108883
156605
79016
75014
71556

5
1
5
2 •
1
5'
15
1
11
2
10
1
14
347
0
0
2
0
1
0
4
1
0
0
4'
0
2
229
2
0
3
2
0
5
9
0
9
2
4
1
10
109
3 .
1
6
0
0
0
2
0
2
0
2
0
2
9
Source: U.S. EPA, 50-POTW Study, 1982. ,
NC - Noncensored (when all effluent data points were measured concentrations above the ML for the pollutant).
ND - When all effluent data points were not detected or assigned the ML value for the pollutants.
          B-12
-------
                               Appendix C - Revised Data Conventions
           Appendix C




REVISED DATA CONVENTIONS
-------
-------
                                                        Appendix C - Revised Data Conventions
                                     Appendix C

 REVISED DATA CONVENTIONS FOR THE 50-POTW STUDY ANALYTICAL DATA
   (UNDER CONSIDERATION FOR USE IN THE FINAL IRON AND STEEL RULE)

             This appendix describes the minor editing criteria changes that EPA is considering
for use in the final Iron and Steel pretreatment standards, including those related to the presence
of analytical interferences, missing data, reported greater-man values, and reported less-than
•values higher than minimum levels. To compare the proposed changes to the traditional editing
criteria used for the proposed Iron and Steel rule (outlined in Section 11), additions to the criteria
are highlighted as "(New)" and revisions to existing criteria are highlighted as "(Revised)".

             1.      (New) Applied an alpha-numeric naming convention to identify parallel
                    treatment trains within a POTW. The naming convention is composed of
                    the POTW's number and a suffix. For example, POTW 10 has two parallel
                    treatment trains, which the new naming convention designated as 10A and
                    10B. Records associated with treatment train "A" in POTW 10 all carry
                    the designation 10A. If a POTW has only one treatment train, all records
                    for the POTW are identified by the POTW number only.  The one
                    exception is POTW 56, in which case a"sampling point is designated after
                    primary clarification (56A) and after tertiary filtration (56B). EPA did not
                    collect samples after the secondary activated sludge treatment unit. The
                    traditional data conventions - used for the proposed Iron and Steel rule -
                    averaged all of the respective influent and effluent values for parallel
                    treatment systems. '    '    ;.

             2.      (New) Added treatment technology codes and technology flags. Treatment
                    technology codes include "AS" for activated sludge, "TF" for trickling
                    filter, and "RBC" for rotating biological contactor, lagoon, and primary
                    clarifier. Some POTWs use a combination of treatment technologies, such
                    as AS + tertiary oxidation ponds. In these cases, EPA identifies the
                    combination. Technology flags are "P" for primary treatment, "S" for
                    secondary biological treatment, "E" for equivalent to secondary biological
                    treatment, and "T" for secondary biological or equivalent treatment
               .     systems with tertiary treatment unit operations.

             3.      This placeholder ensures consistency between the computer output
                    headings and these data conventions. (The numbered  statements
                    correspond to preliminary drafts of the revised data conventions.  Some
                    data conventions contained in earlier drafts were mistaken or misplaced in
                    sequence and EPA removed these conventions from subsequent drafts.
                    However, EPA retained the assigned number sequence because of
                    reference to these numbers in the computer listings. Thus, this number is
                    effectively blank.)
                                         C-l
-------
                                             Appendix C - Revised Data Conventions
4.     Converted the units of measure for each pollutant to a common rhetric.
                                                                  s,
5.     (Revised) Deleted individual data points for a pollutant if supporting
       records indicated that one of the following conditions was met     .
       (corresponding to key codes 4, 5, 6, and 8 in Table C-l in this appendix):
                                                                  i
       a.     Analytical interference prevented the determination of the presence
              or; quantification of the pollutant (key code = 4),

       b.     Analytical interference was present, but the pollutant concentration
              was not detected above the concentration reported (key code = 5),

       c.     No chemical analysis was conducted or the result of the c lemical
              analysis was not reported (key code = 6), and

       d.     The pollutant was detected but not quantified or confirmed (key
              code = 8).                                           I
                                                                  i
       e.     (Revised) Deleted the record results from a "right censored"
              qualitative method. These records are identified as "greater-than (>)
              X" where "X" is a method-specific value.  This indicator signifies
              that the recorded measure is the lower bound of the amount of the
              pollutant in the sample. The traditional data conventions j- used for
              the iron and Steel and Metal Products and Machinery (MP&M)
              proposed rules - reported ">values" as the value. (If calculations
              are based on influent ">values," then the percent removals would
              be lower than they should be. If calculations are based on|effluent
              ">values," then the percent removals would be higher than they
              should be.)

              The revised data conventions delete pollutant concentration data
              points on an individual basis, not hi pairs. For example, if [the
              influent data point meets one of the previously identified conditions,
              it is deleted. Its paired effluent data point is not deleted unless  it
              too meets one of the conditions. The traditional data conventions
              deleted data in daily pairs.                             J.

6.     Incorporated the standardized analytical "minimum level" (ML) values for
       each record: EPA assigned these values based on the precision and
       accuracy of the 1978 to 1980 analytical methods used to measure the
       pollutant.

7.     (Revised) Deleted records reported as "< values" that are greater than the
       ML. This may occur when samples are diluted to reduce analytical matrix
       interference. If a pollutant is not detected in the diluted sample, the
                             C-2
-------
                                             Appendix C - Revised Data Conventions
       resulting ML is multiplied by the dilution factor. (For data reported as "<
       values," this rule initially set the value to the ML for calculation purposes
       without considering if the value is greater than the ML.  The traditional
       editing rule decreases calculated performance for influent value
       substitutions, and increases it for effluent value substitutions.)

8.     Set equal to the pollutant analytical ML any remaining pollutant values
       reported as not detected (key codes 1, 3, and 7):

       a.      Less than the concentration listed (key code =1),

       b.      Detected, but not quantified at lower than the concentration listed
              (key code = 3), and

       c      "Not detected" (key code = 7).

9.     For detected or noncensored (NC) values reported as less than the ML, set
       the value equal to the ML and report the value as a nondetect.

10.    (New)  If the pollutant ML is GREATER THAN 20, substituted 0.5 x ML
       for influent and effluent samples if all effluent values are equal to the ML
      , and the value was a nondetect. The following pollutants are excluded from
       this convention: BOD5, COD, O&G, TDS, TOC, total solids, and TSS.

11,    Retained pollutant data for a POTW if there are at least three (3) influent
       concentration values reported and at least one of these values is measured
       above the ML for the pollutant.

12.    This placeholder ensures consistency between the computer output
       headings and these data conventions. (The numbered statements
       correspond to preliminary drafts of the revised data conventions. Some
       data conventions contained in earlier drafts were mistaken or misplaced in
       sequence and EPA removed these conventions from subsequent  drafts.
       However, EPA retained the assigned number sequence because of
    •   reference to these numbers in the computer listings.  Thus, this number is
       effectively blank.)

13.    (New)  Retained POTW treatment trains with secondary biological
       treatment or equivalent (as designated by treatment flags "S" or "E") only
       if both the effluent BOD5  and TSS average concentrations are less than or
       equal to 45 mg/L.

14.    (Revised)  Retained non-negative percent removals that are greater than
       zero for a given pollutant where the percent removal = (100)(average
       influent - average effluent)/average influent. The traditional data
                            C-3
-------
                                             Appendix. C - Revised Data Conventions
 15.
16.
17.
18.
19.
 conventions retained zero percent removals. (The medians of these
 intermediate values are referred to as Alternative C.)          !
 _
 Identified three (overlapping) subsets of POTWs based on the average
 influent concentration:                                      I
       a.     (i.) If all effluent values are equal to the ML and the ML
                                                           is greater
20.
              than 20 ppb, retain the pollutant performance (percent removal) if
              the pollutant influent average is at least 10 times one-half [the
              nominal ML (10 x y2 ML = 5 x ML).                   \
                                                                  \
              (ii) If all effluent values are equal to the ML and the ML is less
              than or equal to 20 ppb, retain the pollutant performance (percent
              removal) if the pollutant influent average is at least 10 tunes the
              nominal ML (10 x ML).
b.     If the effluent average is greater than the ML, retain the pollutant
       performance (percent removal) regardless of the pollutantj influent
       average.
                                                           !•
The national POTW/pollutant percent removal is the median of the retained
values from 15a and 15b above. (This is referred to as Alternative A.)

Modify I5b: If the effluent average is greater than the ML, retain the
pollutant performance (percent removal) if the pollutant influent average is
at least two times the nominal minimum level (2 x ML).

Modify 16: The national POTW/pollutant percent removal is the [median of
the retained values from 15a and 17 above. (This is referred to as
Alternative B.)

Modify 13: (a) Retain POTW treatment trains with secondary bioWical
treatment (as designated by treatment flag "S"), only if both the effluent
BOD5 and TSS average concentrations are less than or equal to 45 mg/L.
(b) Retain POTW .treatment trains with equivalent to secondary biological
treatment (as designated by treatment flag "E"), only if both the effluent
BOD5 and TSS average concentrations are less than or equal to 65 mg/L.
(c) The national POTW/pollutant percent removal is the median of the
retained values from 15a and 17 above.  (This is referred to as
Alternative D.)

Modify, 19: Substitute 1A x ML for all data points set equal to the [analytical
ML. (This is referred to as Alternative E.)
                             C-4
-------
                                                    Appendix C - Revised Data Conventions
                                   Table C-l

                 Description off the Key Codes Used to Qualify
                  Analytical Results in the 50-POTW Dataset*
Code
0
1
2
3
\
4
4
5
6
7
'8
8
Concentration
. . any
. .any
• • snY
. . any
. . 0
. . any value >0
. . any
..0
. .0 or blank
..0
. . any value >0
Meaning of code
Detected at this concentration
Less than this concentration
Detected at greater than (>) this concentration
Detected, but not quantified at lower than this
concentration
Analytical interference prevented determination of
the presence or quantification of the analyte
Analytical interference was present, but
concentration was estimated as this concentration
Analytical interference was present, but the
analyte was not detected above this concentration
No chemical analysis conducted or the result of
the chemical analysis was not reported
Reported as "not detected"
Analyte was detected, but not quantified or
confirmed
A pesticide was detected by GC-ECD at this
concentration, but GC-MS did not confirm the
presence of the analyte
aU.S. EPA, 50-POTW Study, 1982, pp. 29 and 30.
                                      C-5
-------
-------
                                Appendix D - Aggregated Data Listing
           Appendix D




AGGREGATED DATA LISTING
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-------
-------
                              Appendix E - Modified Delta-Lognormal Distribution
                     Appendix E




MODIFIED DELTA-LOGNORMAL DISTRIBUTION
-------
-------
                                                  Appendix E - Modified Delta-Lognormal Distribution
                                        Appendix E

                  MODIFIED DELTA-LOGNORMAL DISTRIBUTION

               This appendix describes the modified delta-lognormal distribution and the
 estimation of the episode-specific long-term averages and variability factors used to calculate the
 proposed limitations and standards.1 This appendix provides the statistical methodology that was
 used to obtain the results presented in Section 12.                                      .   .
 E.I
Basic Overview of the Modified Delta-Lognormal Distribution
       • •      EPA selected the modified delta-lognormal distribution to model pollutant effluent
 concentrations from the iron and steel industry in developing the long-term averages and
 variability factors. A typical effluent data set from a sampling episode or self-monitoring episode
 (see Section 12 for a discussion of the data associated with these episodes) consists of a mixture
 of measured (detected) and non-detected values.  The modified delta-lognormal distribution is
 appropriate for such data sets because it models the data as a mixture of measurements  that
 follow a lognormal distribution and non-detect measurements that occur with a certain
 probability. The model also allows  for the possibility that non-detect measurements occur at
 multiple sample-specific detection limits. Because the data appeared to fit the modified delta-
 lognormal model reasonably well, EPA has determined that this model is appropriate for these
 data.
              The modified delta-lognormal distribution is a modification of the 'delta
distribution' originally developed by Aitchison and Brown.2 While this distribution was originally
developed to model economic data, other researchers have shown the application to
environmental data.3 The resulting mixed distributional model, which combines a continuous
density portion with a discrete-valued spike at zero, is also known as the delta-lognormal
distribution.  The delta in the name refers to the proportion of the overall distribution contained in
the discrete distributional spike at zero; that is, the proportion of zero amounts.  The remaining
non-zero, non-censored (NC) amounts are grouped together and fit to a lognormal distribution.

              EPA modified this delta-lognormal distribution to incorporate multiple detection
limits. In the modification of the delta portion, the single spike located at zero is replaced by a
discrete distribution made up of multiple spikes. Each spike in this modification is associated with
a distinct sample-specific detection limit associated with non-detected (ND) measurements in the
'In the remainder of this appendix, references to 'limitations' includes 'standards.'

2Aitchison, J. and Brown, J.A.C. (1963) "the Lognormal Distribution. Cambridge University Press, pages 87-99.

3Owen, W.J. and T.A. DeRouen. 1980. "Estimation of the Mean for Lognormal Data Containing Zeroes and Left-
Censored Values, with Applications to the Measurement of Worker Exposure to Air Contaminants." Biometrics,
36:707-719.
                                           E-l
-------
                                                  Appendix E - Modified Delta-Lognormal Distribution
database.4  A lognormal density is used to represent the set of measured values.  This modification
of the delta-lognormal distribution is illustrated in Figure E-l.

              The following two subsections describe the delta and lognormal portion's of the
modified delta-lognormal distribution in further detail.
E.2
Continuous and Discrete Portions of the Modified Delta-Lognormal
Distribution
              The discrete portion of the modified delta-lognormal distribution model'p the non-
detected values corresponding to the k reported sample-specific detection limits. In the model, 8
represents the proportion of non-detected values in the dataset and is the sum of smaller fractions,
8;, each representing the proportion of non-detected values associated with each distinct detection
limit value.  By letting D; equal the value of the 1th smallest distinct detection limit in the data set
and the random variable XD represents a randomly chosen non-detected ineasurement, jfhe
cumulative distribution function of the discrete portion of the modified delta-lognormal model can
be mathematically expressed as:
                                                        0
-------
                           Appendix E - Modified Delta-Lognormal Distribution
                   Figure E-l
Modified Delta-Lognormal Distribution
        Censoring Type
NC
          ND
                      E-3
-------
                                                Appendix E - Modified Delta-Lognormul Distribution
                                                                                   (E-4)
where the random variable Xc represents a randomly chosen detected measurement, 
-------
                                                 Appendix E - Modified Delta-Lognormal Distribution
               The expected value of the random variable U can be derived as a weighted sum of
 the expected values of the discrete and continuous portions of the distribution (equations 2 and 5,
 respectively) as follows
                                                                                    (E-9)
              In a similar manner, the expected value of the random variable squared can be
 written as a weighted sum of the expected values of the squares of the discrete and continuous
 portions of the distribution as follows
                                                                                   (E-10)
 Although written in terms of U, the following relationship holds for all random variables, U, XD,
                                       = Var(U)+[E(U)]
                                                                     (E-ll)
 So using equation 1 1 to solve for Var(U), and applying the relationships in equations 9 and 10,
 the variance of U can be obtained as

E.4
Episode-specific Estimates Under the Modified Delta-Lognormal
Distribution                                 '
              In order to use the modified delta-lognormal model to calculate the proposed
limitations, the parameters of the distribution are estimated from the data. These estimates are
then used to calculate the proposed limitations.
                             $      U
              The parameters  l and ° are estimated from the data using the following formulas:
                                                                                  (E-13)
                                             n
where nd is the number of non-detected measurements, dpj = -\ to nd, are the detection limits for
the non-detected measurements, n is the number of measurements (both detected and non-
detected) and I(...) is an indicator function equal to one if the phrase within the parentheses is
                                          E-5
-------
                                                Appendix E - Modified Delta-Lognortnal Distribution
true and zero otherwise. The "hat" over the parameters indicates that they are estimated from the
data.
                                                                             ii
              The expected value and the variance of the lognormal portion of the modified
delta-lognormal distribution can be calculated from the data as:
      •k


      7=1
 k

' X  '
 /^
 7=1
                                                                                  (E-14)
                                                                                  (E-15)
              The parameters of the continuous portion of the modified delta-lognormal
distribution, " and ^  , are estimated by
                                                                                  (E-16)
                                                                             I
where xt is the i* detected measurement value and nc is the number of detected measurements.
Note that n = nd + nc.                                                          i

             The expected value and the variance of the lognormal portion of the modified
delta-lognormal distribution can be calculated from the data as:                     [
                                                                                  (E-17)
                                                                                  (E-18)
              Finally, the expected value and variance of the modified delta-lognormal
distribution can be estimated using tihie following formulas:
                                                                                  (E-19)
                                           E-6
-------
                                                  Appendix E -Modified Delta-Lognormal Distribution
Var(U] =
                                                                                     (E-20)
               Equations 17 through 20 are particularly important in the estimation of episode-
 specific long-term averages and variability factors as described in the following sections. These
 sections are preceded by a section that identifies the episode data set requirements.
 E.4.1
             Episode Data Set Requirements
               Estimates of the necessary parameters for the lognormal portion of the distribution
 can be calculated with as few as two distinct detected values in a data set.  (In order to calculate
 the variance of the modified delta-lognormal distribution, two distinct detected values are the
 minimum number that can be used and still obtain an estimate of the variance for the distribution.)


               If an episode data set for a pollutant contained three or more observations with
 two or more distinct detected concentration values, then EPA used the modified delta-lognormal
 distribution to calculate long-term averages and variability factors.  If the episode data set for a
 pollutant did not meet these requirements, EPA used an arithmetic average to calculate the
 episode-specific long-term average and excluded the dataset from the  variability factor
 calculations (because the variability could not be calculated).

              In statistical terms, each measurement was assumed to  be independently and
 identically distributed from the .other measurements of that pollutant in the episode data set.

              The next two  sections apply the modified delta-lognormal distribution to the data
 for estimating episode-specific long-term averages and variability factors for the iron and steel
 industry.                    ,         .                 .
E.4.2
            Estimation of Episode-specific Long-Term Averages
              If an episode dataset for a pollutant mets the requirements described in the last
section, then EPA calculated the long-term average using equation 19.  Otherwise, EPA
calculated the long-term average as the arithmetic average5 of the daily values where the sample-
specific detection limit was used for each non-detected measurement.
E.4.3
            Estimation of Episode-Specific Variability Factors
              For each episode, EPA estimated the daily variability factors by fitting a modified
delta-lognormal distribution to the daily measurements for each pollutant.  In contrast, EPA
estimated monthly variability factors by fitting a modified delta-lognormal distribution to the
5EPA also used the arithmetic average of daily values in costing the technology options. See Section 12.7.1.
                                           E-7
-------
                                                 Appendix E - Modified Delta-Lo'gnormhl Distribution
monthly averages for the pollutant at the episode. EPA developed these averages using the same
number of measurements as the assumed monitoring frequency for the pollutant. EPA is
assuming that all pollutants will be monitored weekly (approximately four times a month).6
E.4.3.1
Estimation of Episode-specific Daily Variability Factors
              The episode-specific daily variability factor is a function of the expected value, and
the 99th percentile of the modified delta-lognoimal distribution fit to the daily concentration
values of the pollutant in the wastewater from the episode. The expected.value, was estimated
using equation 19 (the expected value is the same as the episode-specific long-term ayerage).

              The 99th percentile of the modified delta-lognormal distribution fit to each data set
was estimated by using an iterative approach. First, the pollutant-specific detection limits were
ordered from smallest to largest. Next, the cumulative distribution function, p, for each detection
limit was computed.  The general form, for a given value c, was:
                            P=
                                                                                   (E-21)
where <& is the standard normal cumulative distribution function. Next, the interval containing the
99* percentile was identified. Finally, the 99th percentile of the modified delta-lognormal
distribution was calculated.  The following steps were completed to compute the estimated 99th
percentile of each data subset:                                                  [

Step 1        Using equation 21, k values of p at c=Dm, m=l,...,k were computed an|l labeled
Step 2
StepS
The smallest value of m (m=l,...,k), such that pm > 0.99, was determined and
labeled as PJ. If no such m existed, steps 3 and 4 were slapped and step 5 was
computed instead.
Computed p* = PJ -
                                 8,.
 "Compliance with the monthly average limitations will be required in the final rulemaking regardless of the number of
 samples analyzed and averaged.
                                            E-8
-------
                                                 Appendix E - Modified Delta-Lognormal Distribution
 Step 4
 Ifp*<0.99,then^)99 = Dj
       else if p*_> 0.99, then
                          P99 = exp
f

" *• -at. — 1
LL H-cry?

V
. -i\
0.99 -£$
z=l
y\
1-5
-')
                                                                     (E-22)
 Step 5
where <&"' is the inverse normal distribution function.

If no such m exists such that pm > 0.99 (m=l,...,k), then


                                     0.99-5
                                                     1-d
The episode-specific daily variability factor, VF1, was then calculated as:
                                                                                  (E-23)
                                      VF1 =
                               P99
                               E(U)
(E-24)
E.4.3.2
Estimation of Episode-Specific Monthly Variability Factors
              EPA estimated the monthly variability factors by fitting a modified delta-lognormal
distribution to the monthly averages. These equations use the same basic parameters, \i and a,
calculated for the daily variability factors. Episode-specific monthly variability factors were based
on 4-day monthly averages because the monitoring frequency was assumed to be weekly
(approximately four times a month).

              In order to calculate the 4-day variability factors (VF4), the assumption was made
that the approximating distribution of jj  , the sample mean for a random sample of four
independent concentrations, was also derived from the modified delta-lognormal distribution.7 To
obtain the expected value of the 4-day averages, equation 19 is modified for the mean of the
distribution of 4-day averages in equation 25:
                         E(U4)=84E(X4)D+(1-84)E(X4)(
                                                                      (25)
7As described in section 12.4, when non-detected measurements are aggregated with non-censored measurements', EPA
determined that the result should be considered non-censored.
                                          E-9
-------
                                               'Appendix E - Modified Delta-Lognormdl Distribution
where  *  *'D denotes the mean of the discrete portion of the distribution of the average of four
independent concentrations, (i.e., when all observations are non-detected values) and
(X }
\  A'c denotes the mean of the continuous lognormal portion (i.e., when any observations are
detected).

             First, it was assumed that the probability of detection (5) on each of theifour days
was independent of the measurements on the other three days (as explained in Section E.4.1, daily
measurements were also assumed to be independent) and therefore, 64 = S4. Because the
measurements are assumed to be independent, the following relationships hold:
                                                                                 (E-26)
                                Var
_Var(XD)
      4
             Substituting into equation 26 and solving for the expected value of the continuous
portion of the distribution gives:                                                ;
                                                                                 (E-27)
                                              1-8'
Using the relationship in equation 19 for the averages of 4 daily measurements and substituting
terms from equation 25 and solving for the variance of the continuous portion of jj gives:
                                        1-5'
Using equations 17 and 18 and solving for the parameters of the lognormal distribution describing
the distribution of  ;f    gives:
                                          E-10
                                                                                 (E-28)
-------
                                                  Appendix E - Modified Delta-Losnormal Distribi
                                           Var(X4]
  and
                                                       + 1
                                                                                     (E-29)
               In finding the estimated 95th percentile of the average of four observations/four
 non-detects, not all at the same sample-specific detection limit, can gerierate an average that is not
 necessarily equal to D,, D2,..., or Dk.  Consequently, more than k discrete points exist in the  '
 distribution of the 4-day averages. .For example, the average of four non-detects at k=2 detection
 limits, are at the following discrete points with the associated probabilities:
                             z

                             1

                            2

                            3

                            4

                            5

 (3Dl+D2)/4

(2D1+2D2)/4
                     48,81
                       8*
              When all four observations are non-detected values, and when k distinct non-
detected values exist, the multinomial distribution can be used to determine associated
probabilities. That is,                                .
                       Pr
u*=-£L
                                                  41
                                             u^L.^l*-.!
                                                 (E-30)
where u; is the number of non-detected measurements in the data set with the D; detection limit.
The number of possible discrete points, k*, for k=l, 2,3,4, and 5 are as follows:
                                          E-ll
-------
k
1
2
3
4
5
kl
1
5
15
35
70
I1
;.
i,
E



              To find the estimated 95th percentile of the distribution of the average o|f four
observations, the same basic steps (described in Section 4.3.1) as for the 99th percentile of the
distribution of daily observations, were used with the following changes:
Step 1
Step 2
StepS
Step 4
StepS
Then, using
was calculated as:
Change P99 to P95, and 0.99 to 0.95.                                       .
Change Dm to Dm*, the weighted averages of the sample-specific detection limits.
Change 8; to 8;*.
Change k to k*, the number -of possible discrete points based on k detection limits.
Change the estimates of 8, ^ ,and G to estimates of 84, ™ and   4 respectively.
            , the estimate of the episode-specific 4-day variability fadjor, VF4,
E.4.3.3
                               :E(U)


Evaluation of Episode-Specific Variability Factors
              Estimates of the necessary parameters for the lognormal portion of the ^distribution
can be calculated with as few as two distinct measured values in a data set (in order to. calculate
the variance); however, these estimates can be unstable (as can estimates from larger data sets).
As stated in Section E.4.1, EPA used the modified delta-lognormal distribution to develop
episode-specific variability factors for data sets that had a three or more observations with two or
more distinct measured concentration values.                                     \

              To identify situations producing unexpected results, EPA reviewed all pf the
variability factors and compared daily to monthly variability factors.  EPA used several criteria to
determine if the episode-specific daily and monthly variability factors should be included in
calculating the option variability factors. One criteria that EPA used was that the daily and
monthly variability factors should be greater than 1.0. A variability factor less than 1.0 would
result in a unexpected result where the estimated 99th percentile would be less than the long-term
average. This would be an indication that the estimate of ° (the log standard deviation) was
unstable. A second criteria was that the daily variability factor had to be greater than the monthly
variability factor. A third criteria was that not all of the  sample-specific detection limits could
exceed the values of the non-censored values. All the episode-specific variability factbrs used for
the proposed limitations and standards met these criteria.                          j
                                           E-12
-------
                                               Appendix E - Modified Delta-Li
                                                             llDiitrihi
 E.5
References
 Aitchison,J. and J.A.C. Brown.  1963.  The Lognormal Distribution.  Cambridge University
 Press, New York.                       '


 Barakat,R. 1976. "Sums of Independent Lognormally Distributed Random Variables." Journal
 of the Optical Society of America, 66:211-216.

 Cohen, A. Clifford. 1976. Progressively Censored Sampling in the Three Parameter Log-Normal
 Distribution.  Technometrics, 18:99-103.


 Crow,E.L,andK.Shimizu. 1988.  Lognormal Distributions: Theory and Applications  Marcel
 Dekker, Inc., New York.


 Kahn, H.D., and M.B. Rubin. 1989. "Use of Statistical Methods in Industrial Water Pollution
 Control Regulations in the United States." Environmental Monitoring and Assessment
 Vol. 12:129-148.


 Owen, W.J. and T.A. DeRouen. 1980. Estimation of the Mean for Lognormal Data Containing
 Zeroes and Left-Censored Values, with Applications to the Measurement of Worker Exposure to
 Air Contaminants. Biometrics, 36:1'01'-719.                                        .

U.S. Environmental Protection Agency.  2000.  Development Document for Effluent Limitations
Guidelines and Standards for the Centralized Waste Treatment Point Sniifr.p Tat^gn^  Volume T
Volume II.  EPA 440/1 -87/009.                  ~              	    •
                                       E-13
-------
-------
                               Appendix F - Attachments for Section 12
            Appendix F




ATTACHMENTS FOR SECTION 12
-------
-------
                                                     Appendix F - Attachments for Section 12
                                    Appendix F

                        ATTACHMENTS FOR SECTION 12

 Subcategory Abbreviations:

 Abbreviation              Subcategorv
 COKE_BYPROD
 FINISHING
 INT_HOTFORM
 INT_STEEL
 IRON
 NONINT_STEEL_HOTFORM
 OTHER
 Option Abbreviations:

 Abbreviation

 CARBON_BAT1
 SPECIALTY_BAT1
 DRI BPT
       Cokemaking, By-Product Segment
       Steel Finishing
       Integrated and Stand-Alone Hot Forming
       Integrated Steelmaking
       Lronmaking
       Non-Integrated Steelmaking and Hot Forming
       Other Operations
Option
      Carbon and Alloy Segment, Option BAT1
      Stainless Steel Segment, Option BAT1
      Direct Iron Reduction, Option BPT
Other Abbreviations:

Abbreviation

CAS_NO
Est.    ,
LTA
ND
Obs
STD
V.F.
Definition
      Chemical Abstract Service Number
      Estimated
      Long-Term Average
      Non-Detect  .
      Number of Daily Values; OR Observed (e.g., Qbs Mean)
      Standard Deviation
      Variability Factor
                                      F-l
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