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leachates is advisable. Where appropriate, the location of
solid hazardous materials disposal sites should be
permanently recorded in the appropriate office of legal
jurisdiction.
Impact of Limitations on Energy Reguirements. The effect of
water pollution control measures on energy requirements has
also been determined. The additional energy required in the
form of electric power to achieve the effluent limitations
for BPCTCA and BATEA amounts to less than 3% of the 51.6
billion kwh of electrical energy used by the steel industry
in 1972. Energy requirements in the specialty steel
segments for various levels of treatment have been estimated
and generally do not exceed 2 percent of the 606 kw-hr per
kkg (550 kw-hr per ton) of electric power required in
electric furnaces producing stainless steel.
The enhancement to water quality management provided by
these effluent limitations substantially outweighs the
impact on air, solid waste, and energy requirements.
Consideration of the Engineering Aspects of the Application
of Various Types of Control Techniques
The level of technology selected as the basis for BPCTCA
limitations is considered to be practicable in that the
concepts are proven and are currently in place and in use by
the various steel mills as more fully described below. The
level of technology selected as the basis for BPCTCA
limitations is considered to be practicable in that the
concepts are proven and are currently available for
implementation and may be readily applied as "add-ons" to
existing treatment facilities.
Identification of the Best Practicable Control Technology
Currently Available - BPCTCA
Discussion By Subcategories;
The rationale used for developing the BPCTCA effluent
limitations guidelines is summarized below for each of the
Subcategories. All effluent limitations guidelines are
presented on a "gross" basis since for the most part,
removals are relatively independent of initial
concentrations of contaminants. The ELG^ are in kilograms
of pollutant per metric ton of product or in pounds of
pollutant per 1,000 pounds of product and in these terms
only. The ELG's are not a limitation on flow, type of
technology to be utilized, or concentrations to be achieved.
These items are listed only to show the basis for the ELG's
642
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and may be varied as the discharger desires so long as the
ELG loads per unit of production are met.
Basic Oxygen Furnace Operation
The only direct contact process water used in the EOF plant
is the water used for cooling and scrubbing the furnace off-
gases. One method used is the wet gas cleaning system which
uses a venturi scrubber and a gas quencher. The use of wet
air pollution control is rare in the alloy and stainless
steel industry. The water use at one plant producing alloy
steel in a EOF was 870 gals/ton. The water was used once-
through and the only treatment provided was clarification
where the EOF waste water was combined with blast furnace
gaswasher water.
The technology identified as used in the alloy and stainless
steel industry was judged to be inadequate. The water use
rate lies within the range found in the carbon steel
industry (130-1020 gal/ton) and there is no reason to
believe that the technology in use there is not directly
transferable, since the characteristics of the waste waters
and the nature of the processes are similar. The BPCTCA
limitations have thus been established on the basis of an
effluent suspended solids concentration of 50 mg/1 at an
effluent volume of 209 1/kkg (50 gals/ton). The blowdown
rate of 5.9 percent is being achieved in at least one carbon
steel plant and at least two such plants are achieving lower
effluent concentrations of suspended solids. The pH of the
scrubber water effluent from the alloy steel EOF averaged
7.4, so that no difficulty with a pH 6-9 limitation is
foreseen.
Vacuum Degassing Subcategory
The direct contact process water used in specialty steel
vacuum degassing is the cooling water used for the steam-jet
barometric condensers. Although most systems use steam
ejectors to draw the vacuum, dry mechanical pumps are also
used. The vacuum degassing systems surveyed in the alloy
and stainless steel industry used water once-through with
little effective treatment, completely recirculated -£he
water with no discharge, or use mechanical pumps.
It was judged to be unduly restrictive to impose a zero
effluent discharge limitation for BPT because all plants may
not be able to completely recirculate the water or convert
to mechanical pumps. The water use rate determined for the
once-through system (3021 1/kkg) lies in the range found in
the carbon steel industry plants surveys (813-3750 1/kkg)
643
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and there is no reason to believe that the technology in use
there is not directly transferable, since the
characteristics of the waste waters and the nature of the
processes are similar. The BPCTCA limitations have thus
been established on the basis of an effluent suspended
solids concentration at 50 mg/1 at an effluent volume of 101
1/kkg (25 gals/ton). The blowdown rate of 3.4 percent is
being achieved in at least one carbon steel plant and, of
course, in the completely recirculated system mentioned
above. At least one carbon steel plant is achieving lower
effluent suspended solids concentrations and the pH of the
once-through alloy steel systems averaged 6.5 (within the
specified 6-9 range) .
Continuous Casting and Pressure Slab Molding Subcategory
Continuous casting and pressure slab molding are processes
by which primary steel shapes are cast or molded from molten
steel instead of being rolled from ingots. The molds are
cooled by indirect water circulation. The continuous
casting spray cooling water system is direct contact cooling
of the cast product. As the cast product (slab, bloom, or
billet) emerges from the mold, the water sprays further
solidify and cool the cast product. The principal waste
contaminant in this contact cooling water is suspended
solids and, additionally, oil from machinery lubrication
finds its way into this water effluent. Pressure slab
molding results in the generation of wastewaters. containing
suspended solids and oil.
The current control and treatment technology in the alloy
and stainless steel industry consists of clarification of
the waste water with varying degrees of recirculation of the
water to the process use. One plant surveyed recirculated
the water completely with only periodic batch-type blowdown
of the system.
No system in current use in the alloy and stainless steel
industry was found to be adequate and/or necessarily usable
at all other plants; treatments were adequate, but complete
recirculation may not be always feasible. The water use
rates of 2379-4173 1/kkg are lower than the minimum of 6172
1/kkg found in the carbon steel industry plants surveyed.
The characteristics of the waste waters and the nature of
the processes are similar to those in the carbon steel
industry and hence there is no reason to believe that the
technology in use there is not directly transferable,
resulting in a very conservative estimate of achievable
limitations. The BPCTCA limitations have thus been
established on the basis of effluent suspended solids
644
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concentrations of 50 mg/1 and of 15 mg/1 oil and grease at
an effluent volume of 522 1/kkg (125 gal/ton). The
resultant blowdown rates are easily achievable as compared
to those in either of the carbon steel plants surveyed and
both carbon steel plants were achieving lower concentrations
of both suspended solids and oil and grease. All plants
surveyed easily achieved an effluent pH between 6 and 9.
Hot Forming-Primary
The carbon steel data base was examined and an average of
the best plants calculated. The calculated discharge rate
was based upon the average of the best loadings, which for
this subcategory was the average of the loads at the plants
surveyed. In some cases, where the suspended solids or oil
concentrations in the effluent were less than 5 or 10 mg/1
respectively, the concentration for the purposes of
calculating an average load were taken to be 5 or 10. This
variance from actual data was justified on the basis of
analytical accuracy, in that although we know that the
suspended solids level was very low, the analytical method
is not totally reliable at less than 5 or 10 mg/1. From the
calculated loading, a flow representing an achievable
concentration level such as 10 mg/1 for TSS and oil was
calculated. This flow was used for the cost of the
treatment technology, since costs are largely based on
hydraulic flows.
Plants E, H and D in the alloy and stainless steel industry
plant survey had water uses averaging 1912 gal/ton. Using
direct transfer of technology, the carbon steel guidelines
for this category were scaled up to reflect the higher water
use rate.
Hot Forming-Section
The carbon steel data base was examined and the
concentrations of pollutants were adjusted if they averaged
below the accepted minimum for that parameter. In some
plants, more than one section operation had been sampled, so
that although 7 plants were visited, information was
available from 11 operating lines. The loadings were
calculated for each line. One plant, H-2, which used
cyclones for settling (TSS was 71 ppm) was discarded from
consideration because the cyclones did not prove to be
exemplary for TSS or oil removal. The plant had originally
been sampled to ascertain as to the quality of the treatment
provided by cyclones. The average load from the 10 plants
which were determined to be exemplary was then calculated.
645
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Using achievable concentration levels, a discharge flow for
BPT of 2626 gpt was derived.
The section rolling mills in the alloy and stainless steel
industry plant survey in this subcategory had water use
rates which averaged to be slightly less than for carbon
steel. Directly transferring the technology results in a
conservative effluent limitation.
Hot Forming-Flat Plate
Only one exemplary carbon plate mill, K-2, was studied. No
other plate mills with good waste treatment could be
identified since other plate mills either discharged to
central treatment facilities or had even less treatment. It
had a 150 gpt discharge rate, and the pollutant
concentrations for oil loading calculations had to be
adjusted upward to allow for analytical methods. The BPT
loadings for TSS also had to be adjusted upwards to allow
for achievable concentrations in the treatment plant.
Because the technology for this operation was so much more
sophisticated than for the other hot forming operations, the
BPT technology was established at about the level of the
other hot forming operations and the limitations established
accordingly. The sole specialty steel plate mill surveyed
had a water usage rate twice the rate for the carbon steel
mill and was judged to be inadequate from a treatment
standpoint. Since the waste constituents are similar, the
technology in use in the carbon segment was transferred
directly, although an allowance was made for the higher flow
rate in the specialty steel segment.
Hot Forming-Flat-Sheet and Strip
The data base was examined and concentrations adjusted for
analytical methods. The average load of the four carbon
steel plants studied was derived from the loads, and this
average was used as the BPT limitation. The specialty steel
hot strip mills which were surveyed had water usage rates
which were slightly less than those in the carbon steel
segment. However, none of the specialty plants were
practicing recirculation. Therefore, the technology used in
the carbon steel segment was directly transferred and the
limitations were established as the same for both, resulting
in a conservative limitation for the specialty strip mills.
Pipe and Tube
Six plants were studied in the sutcategory, of which three
were electric resistance welding, two were butt weld and one
646
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a seamless plant. One of the ERW plants was excluded
because it used evaporation as part of the treatment
technology, which is not generally applicable to steel
plants. The average load from the five remaining plants was
then determined, and the technology for the cost model
selected. Two of the plants achieved zero discharge through
total recycle, and this was subsequently found to be the
limitation for BAT. The BPT model was subdivided on the
basis of pipe and tube operations integrated with other
steel forming operations, and those which were isolated
plants. The data base revealed that the isolated plants
generally used ponds for settling and cooling, rather than
clarifiers and cooling towers, since modeling all plants
based on use of clarifiers would tend to overstate the cost,
the subcategory was subdivided up for the purposes of
calculating limitations and costs.
Sulfuric Acid-Batch
Examination of the data base revealed that six plants were
treating the pickling concentrated acid. Five of these were
achieving zero discharge via sulfuric acid recovery for
three and waste acid hauling for two. The remaining plant
was neutralizing together with rinse water, settling and
discharging to the sewer. Sufficient data indicated that
BPT limitations could be established at zero discharge for
the sulfuric acid batch concentrated subcategory.
Six plants were studied that had sulfuric acid batch rinsing
operations. Three facilities were achieving zero discharge
by treating rinses via the concentrate recovery unit, and
using the rinsewater (after countercurrent use) as a diluent
in the concentrate makeup. One plant had essentially no
treatment, another treated along with the concentrated acid
via settling and a third treated rinse wastewater by
dilution with rod mill wastes. These latter three were
deemed to be inadequate treatment methods. Average of best
(three mills practicing zero discharge) dictated a BPT
limitation of zero discharge.
Sulfuric Acid-Continuous
The data base for sulfuric acid continuous pickling is
composed of six mills. Considering deep well disposal as a
mechanism for zero discharge of concentrates, then four out
of the six mills were capable of zero discharge (three out
of the four were practicing deep well disposal). Out of the
other two mills not attaining zero discharge, one was
discharging while the other was neutralizing. Noting the
fundmental differences between acid recovery and
647
-------
neutralization technologies, a provision was developed for
those facilities practicing acid neutralization of
concentrates.
Of the six mills, only one mill achieved zero discharge of
the rinse wastewater. The others were practicing either
joint treatment (4) or discharging to a sewer (1) .
Recognizing the difference in neutralization and acid
recovery, plants with neutralization facilities existing at
the time of promulgation will be permitted a discharge of 25
gpt for concentrates and 200 gpt for rinses and 25 gpt for
fume hoods for BPT. The BPT treatment model will be
neutralization followed by a 1 day settling lagoon.
Sulfuric Acid Pickling - Specialty Steel
There was only one operation identified in the alloy and
stainless steel industry plant survey that could be
separated from other pickling and cleaning operations for
the purposes of raw waste load and treatment level
specification. Since the characteristics and flows of the
wastes and nature of available treatments are similar
between the two industry segments, it was decided to base
the BPCTCA limitations on those adopted for this subcategory
for carbon steel operations. The specialty steel plant was
achieving no discharge of process wastewater pollutants both
for rinses and concentrations.
Pickling - Hydrochloric Acid - Batch and Continuous -
Concentrates
Batch Pickling Operations. A relatively small number of
pickling operations, predominantly rod and wire processors,
use hydrochloric acid in batch pickling systems. Production
rates on these units are about half of those for
corresponding sulfuric acid lines, so most batch operators
do not generate enough spent hydrochloric acid pickle liquor
to make acid recovery units practical. Instead, the general
practice has been contract hauling of batches of spent
pickle baths to treatment and ultimate disposal off-site,
where they may be blended with alkaline wastes from other
industrial sources. Two plants of this type were surveyed,
and these were either neutralizing to a level acceptable to
the municipal sanitary authority, or were using contract
hauling services to dispose of spent concentrates.
Technology for treatment of spent concentrates from batch
hydrochloric acid pickling does exist. In most instances,
it is more practical to treat spent concentrates jointly
with rinses in one unified treatment system.
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Continuous Pickling Operations. Plants utilizing
hydrochloric acid for continuous pickling, primarily sheet
and strip lines, are relatively new when contrasted with
continuous sulfuric acid pickling lines. As a result, they
practice more modern control and treatment technology than
their sulfuric acid counterparts. Emphasis is placed on
recovery of reusable hydrochloric acid from all spent
pickling concentrated solutions. Typical lines run at high
production rates, on the order of 1,270 to 5,440 kkg (1,400
to 6,000 tons) per day, with an average production near
2,720 kkg (3,000 tons) per day. Many plants operate more
than one line at a given location. Spent concentrates are
generated at a typical rate of 42 to 65 1/kkg (10 to 15
gal./ton).
The three continuous HCl regeneration systems surveyed are
using the same basic acid recovery process. Spent acid is
evaporated in a gas-fired roaster. Iron oxide is removed
from the bottom of the roaster while HCl vapors pass on to
an absorber where they are converted into reusable acid.
The inert combustion products pass through the absorber to a
final water scrubber for removal of any residual HCl vapor
and fine particulates prior to venting to atmosphere. The
vent scrubber discharge is the only liquid waste from the
acid recovery system, averaging approximately 830 1/kkg (200
gal./ton) in flow rate. For those hydrochloric acid
pickling operations not practicing acid regeneration,
treatment alternatives for spent concentrates ranged from
deep well disposal to carefully controlled lime
neutralization, jointly with the more dilute acidic rinse
waters. Of the seven continuous HCl pickling operations
surveyed, three were regenerating their spent acids, two
were practicing deep well disposal, one was using contract
hauling disposal services, and one was blending concentrates
and rinse waters prior - to treatment via aeration, lime
neutralization, polymer addition, clarification via a
thickener, with vacuum filtration of thickener underflows
and discharge of a clear, neutral, iron-free effluent.
Pickling - Hydrochloric Acid - Batch and Continuous - Rinses
A total of nine hydrochloric acid pickling plants were
examined for rinse water quality during the survey, and six
of these were large tonnage strip and sheet mills. Of the
nine operations, three were presently providing no rinse
water treatment; three attain some concentration reductions
through partial neutralization or dilution; two treat rinse
waters effectively using conventional lime treatment and
sedimentation/clarification; and the remaining plant
cascades dilute rinse waters toward the head end of the
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pickling line, thereby concentrating iron and acid levels
until the rinse waters resemble dilute (1-2%) spent acid
concentrated solutions. At present, this plant injects this
waste and the spent concentrate to a deep well, but this
mixture is amenable to acid recovery by systems described
previously in the sections on Pickling - Hydrochloric Acid -
Concentrates.
Cold Rolling Subcategories
Re ci r c ul a t io n Systems. Four of the five mills sampled had
recirculation systems. Spent rolling oils are pumped to a
separate storage tank and metered into an oil separator
along with oily wastewater (spillage, pump leakage, etc.)
from the oil cellar and machine shop, associated with the
cold mill operation. Discharges from these plants ranged
from 67 1/kkg to 760 1/kkg (16 to 182 gal./ton) of product
rolled. The volume of discharge per ton of product rolled
is highly dependent upon the width, thickness,, and type of a
product, the speed of the rolling mill, the condition of the
rolls and wipers, and will vary considerably on different
days for the same mill, depending on the product rolled. In
spite of the wide variation in flows shown above, three of
the four plants achieved average discharge rates between 67
and 75 1/kkg (16 and 18 gal./ton), and 4 to 6 mg/1 of oil
and grease was readily attained in the treatment plant
effluent, partly due to the dilution effect caused by
treating cold rolling mill wastewaters in a central
treatment plant along with wastewaters from other processes.
Two of the cold rolling mills at specialty plants achieved
no discharge of process waste water pollutants by completely
recirculating the oil or oil emulsion. The third plant
discharges at a rate of 57 gal/ton but with unacceptable
levels of suspended solids and oil and grease. No
generally applicable treatment technology was identified in
the alloy and stainless steel industry plant surveys and it
was thus decided that the limitations for this subcategory
would be based upon the BPCTCA adopted for similar
operations in the carbon steel industry.
Combination Systems. Although recent trends in cold rolling
practice have aimed at increased use of recirculatTion
systems wherever possibly, many plants must continue to run
one or more stands on a once-through basis. This need is
dictated by special customer requirements, control of
dissolved solids, or the need to remove a previously applied
oily coating which may be incompatible with the rolling
solutions used. Plants using such a combination of
recirculation and direct application stands generate
considerably more wastewater than recirculation alone. For
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example, the one combination plant visited on two different
occasions during this survey consisted of two different cold
rolling lines and a temper mill using various combinations
of recirculation and direct application, with wastewater
flows averaging 1551 1/kkg (372 gal/ton) at the time of the
visits. Data reported by this plant for a representative
period of operations confirmed the above average, indicating
a 28-day average flow of 1,530 1/kkg (367 gal./ton) to
treatment. For this reason, the BPCTCA ELGs for combination
cold rolling operations has been based on flow rates of
1,668 1/kkg (400 gal./ton) of steel produced.
Direct Application Systems. A few cold rolling
installations will continue to operate without recirculation
on any rolling stand, providing only once-through direct
application of rolling solutions. Although no plants of
this type were surveyed, a review of the application rates
utilized by the recirculation and combination types of
operation in the cold rolling subcategory indicate a typical
water reguirement of approximately 4,170 1/kkg (1,000
gal./ton) of product rolled. Thus this flow, together with
the treatment technology utilized on the other cold rolling
wastewaters (namely, equalization, chemical treatment,
flocculation, dissolved air flotation, surface skimming and
long-term settling) form a basis for BPCTCA ELGs for direct
application plants.
Hot Coatings - Galvanizing operations
Four plants in the hot coatings subcategory were visited.
Two of these were rod and wire mills producing galvanized
wire, but one had no process wastewaters in contact with the
coated product and, consequently, no raw waste load
attributable to the coating step. Waste loads from the rod
mill and the pickling operations associated with this
production line are covered under the hot forming section
and the pickling - hydrochloric acid subcategories.
The remaining three mills included two large continuous
strip galvanizing operations and (including one running
three coating lines side by side) one continuous wire
galvanizing operation. Wastewater flow rates for these
three lines ranged from 557 to 2,195 gal./ton for the strip
galvanizing lines, to 4,600 gal./ton for the wire mill. All
lines included varying portions of noncontact cooling water
from furnace cooling and from temperature control of the
molten metal baths.
Hot Coatings - Terne Operations
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Two plants operating terne plating lines were surveyed, and
both of these were practicing tight control to minimize
drag-out of solutions from process tanks. Process water
flow rates ranged from 2,150 to 4,115 1/kkg (516 to 987
gal./ton), and fume hood scrubber waters contributed an
equivalent load at one of the plants.
Miscellaneous Runoffs-Storage Piles - Coal, Stone, and Ore
These three miscellaneous runoffs are discussed together
since at a minimum, all three runoffs would require the same
general type of treatment; namely collection, sedimentation,
and pH adjustment. This is not meant to imply that these
runoffs should necessarily be collected and treated
together, although that possibility need not be specifically
excluded either. Nor should this analysis necessarily
preclude that the above treatment is all that is needed in
every case. For coal pile runoffs in particular, the
presence of other undesirable contaminants (as discussed in
Section V) due to their presence in the coal would be
heavily dependent on the area where the coal is mined and
the particular mineral makeup of the soil in that area.
Miscellaneous Runoff s - Casting and Slagging
Ingot Casting. Ingot casting operations employ minimal
amounts of water for mold spray cooling. Water usage is so
minimal that there is rarely any runoff from the area
proper. In addition, any excess spray water would generally
contain only suspended matter in the form of larger scale
particles which would settle in the immediate spray area. A
runoff that might exist at a specific site due to excessive
spray water usage could best be resolved by tightening up on
spray water usage.
Specialty Steel Pickling, Cleaning and Coating
Suspended Solids
The removal of suspended solids from the treated effluent
from pickling and cleaning wastes generally is accomplished
by clarification. The precipitated metal hydroxides act as
flocculating agents and the addition of polyelectrolytes
acts to agglomerate the flocculant particles into more
readily settlable form by increasing their bulk densities.
Properly designed and operated treatment facilities can
regularly achieve effluent suspended solids concentrations
of 25 mg/1. Such a value has been determined to be
attainable as a result of the carbon steel study. In the
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alloy and stainless steel industry plant survey, the
treatment facilities at Plants A and O attained effluent
suspended solids concentrations averaging 20 and 21 mg/1,
respectively. The limitation of 25 mg/1 thus appears to be
readily achievable.
Chromium
Chromium is optimally precipitated at pH 8.0. The 0.50 mg/1
limitation is based upon that effluent concentration which
is readily achievable at high flow rates. This limitation
is conservative in view of the fact that the treatment plant
effluents at Plants A and P never exceeded this value and
averaged 0.32 and 0.10 mg/lr respectively.
Ch romi urn, He xa va1ent
Hexavalent chromium compounds are highly soluble compared to
the trivalent form. Treatment for hexavalent chromium
consists of reduction to the trivalent form at low pH by
sulfur dioxide, ferrous sulfate, sodium metabisulfite, or
sodium hydrosulfite. The pH is then raised to pH 8 with an
alkaline reagent, precipitating the reduced chromium as the
hydroxide. Proper operation can reduce hexavalent chromium
to nearly zero. The 0.05 mg/1 limitation is based upon
analytically reproducible concentrations and is conservative
as judged from the less-than-detectatle concentrations found
in the treatment plant effluent at Plant P where hexavalent
chromium reduction is regularly practiced.
Cyanide
Cyanides are oxidized at elevated pH levels, usually by
chlorine, i.e., alkaline chlorination. The initial reaction
is very fast and produces cyanates. Maintenance of a
chlorine residual at a nearly neutral pH for an hour or more
oxidizes the cyanate to nitrogen and carbon dioxide and
essentially zero cyanide levels can be achieved. The
limitation was conservatively based on 0.25 mg/1, as judged
from the treatment plant effluents at Plants O and S which
did not exceed 0.10 and 0.04 mg/1, respectively.
Nickel, Iron, and Fluoride
The limitations here are based upon one-half the maximum
and/or the average concentrations found in the treatment
plant effluent at Plant A. This is a well-operated
conventional lime neutralization system using a solids
contact clarifier and polyelectrolyte addition. Nickel is
reduced here from about 15 mg/1 to an average of 0. 18 mg/1
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and a maximum of 0.22 mg/1. 0.25 mg/1 is used as the basis
for the limitation. Iron is reduced from 80-105 mg/1 to an
average of 0.13 mg/1 and a maximum of 1.4 mg/1. Fluorides
are reduced from 150-320 mg/1 to an average of 14 mg/1 and
15 mg/1 was used as the basis. The chosen limitations for
iron (1.0 mg/1) is also the limitation adopted as BPCTCA in
the carbon steel industry pickling subcategories.
Copper
The limitations for this metal at 0.25 mg/1 are based upon
the development document for the non-ferrous metals industry
as representing the concentrations readily achievable by
lime neutralization and clarification as demonstrated in
those industries. This transfer of technology approach is
judged to be the best method of establishing limitations
here because much more attention and study has been devoted
to treatment of these constituents in non-ferrous wastes
than has been the case in the steel industries.
BPCTCA for these subcategories has been based upon the
attainment of the above effluent concentrations by lime
neutralization, flocculation-clarification with
polyelectrolyte addition, and vacuum filtration of the
clarifier underflow to reduce sludge volumes for landfill.
Waste waters containing cyanides are pretreated to oxidize
the cyanide by alkaline chlorination as described above.
Waste waters containing hexavalent chromium are pretreated
to reduce the chromium to the trivalent form with the use of
sulfur dioxide or othejr reducing agent as described above.
Combination Acid Pickling (Continuous)
The flow volume for this subcategory are based upon the
plant survey data from Plants A, D, E and I to include
rinsewater, spent liquor, and fume scrubber effluents. The
rinsewater volumes at Plant A were from 3394-3721 1/kkg and
at Plant D from 3962-4237 l/kkgr averaging 3803 1/kkg. The
rinsewater volumes at Plant I equaled 7564 1/kkg of product,
but no data were provided as to the tonnage pickled vs. the
product tonnage. Assuming, for Plant I, that there are two
picklings per unit produced, the indicated average
rinsewater volume is 3803 1/kkg (912 gals/ton) of steel
pickled. The spent pickle liquor volume is based upon those
for Plants A, I, and E which were, respectively, 96, 98, and
112 1/kkg, averaging 102 1/kkg (24.5 gals/ton). Considering
all of the above data, an effluent volume of 4170 1/kkg
(1000 gals/ton) was selected as representing the best
estimate for this subcategory.
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Combination Acid Pickling (Batch Pipe and Tube)
The flow volumes for this subcategory are based upon the
plant survey data. The rinsewater volume at Plant U
provided the only basis for estimation of rinsewater volumes
in this subcategory and was equal to 677 gal/ton. The fume
scrubber effluent volume was based upon that at Plant F
which equaled 60 1/kkg (14.3 gals/ton). The spent pickle
liquor volume was based upon the average volume of 49 1/kkg,
the spent liquor volumes at Plants C, F, K and the remaining
plant were, respectively, 24, 60, 75 and 38 1/kkg. On the
basis of these data, the waste water volume for this
subcategory was determined to be 2919 1/kkg (700 gals/ton) .
Combination Acid Pickling (Other Batch)
The flow volumes here were based upon the plant survey data.
The fume scrubber and spent liquor volumes were determined
from the data as described above for the pipe and tube
subcategory. Rinsewater volumes for operations in this
subcategory at Plants Cr F and L were respectively, 91, 279
and 140 gal/ton, averaging 170 gal/ton. The waste water
volume for this subcategory was thus conservatively
estimated at 834 1/kkg (200 gals/ton).
Scale Removal
Kolene Scale Removal
The flow volumes for this subcategory were based upon the
plant survey data. The waste water volumes were, 398, 494
and 108 gal/ton, averaging 333 gal/ton. The waste water
volume here was thus established at 2085 1/kkg (500
gals/ton) .
Hydride
The flow volume for this subcategory was based upon the
plant survey data at Plant L at 5004 1/kkg (1200 gals/ton).
Wire Coating and Pickling
The flow was established on the basis of an observed 10-
minute rinsing of a 227 kkg (500 Ib) coil at Plant K at the
rate of 1.31/sec (20 gpm), i.e., 3378 1/kkg (800 gals/ton)
and the flows at plants K and O which were 222 and 1828
gal/ton, respectively, for an average of 950 gal/ton. The
limitations were established on the basis of 1000 gal/ton.
Continuous Alkaline Cleaning
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The flow volume here was based upon the plant survey data
from Plant I at 209 1/kkg (50 gals/ton).
Consideration of Process Changes
No in-process changes will be required to achieve the BPCTCA
limitations, although recycle water quality changes may
occur as a result of efforts to reduce effluent discharge
rates. Many plants are employing recycle, cascade uses, or
treatment and recycle as a means for minimizing water use
and the volume of effluents discharged. The limitations are
load limitations (unit weight of pollutant discharged per
unit weight of product) only, and not volume or
concentration limitations. The limitations can be achieved
by extensive treatment of large flows; however, an
evaluation of costs indicates that the limitations can
usually be achieved most economically by minimizing effluent
volumes.
Consideration of Costs Versus Effluent Reduction Benefits
In consideration of the costs of implementing the BPCTCA
limitations relative to the benefits to be derived, the
limitations were set at values which would not result in
excessive capital or operating costs to the industry.
To accomplish this economic evaluation, it was necessary to
establish the treatment technologies that could be applied
to each subcategory in an add-on fashion, the effluent
qualities attainable with each technology, and the costs.
In order to determine the added costs, it was necessary to
define what treatment processes were already in place and
currently being utilized by most of the plants within a
given subcategory. This was established as the reference
level of treatment.
Treatment systems were then envisioned which, as add-ons to
existing facilities, would achieve significant waste load
reductions. Capital and operating costs for these systems
were then developed for the average size carbon steel
facility. The average size was determined by dividing the
total industry production by the number of operating
facilities. The capital costs were developed from a quasi-
detailed engineering estimate of the cost of the components
of each of the systems. The annual operating cost for each
of the facilities was determined by summing the capital
recovery (basis ten year straight line depreciation) and
capital use (basis 7% interest) charges, operating and
maintenance costs, chemical costs, and utility costs.
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Costs for the alloy steel segment were generally scaled down
from those for carbon steel, using the "0.6" factor, as
explained in Section VIII. Average plant size for alloy
steel was determined by selecting a representative plant
from those studied. Where there was no comparable
subcategory in the carbon steel segment, a quasi-detailed
engineering estimate was determined.
Cost effectiveness diagrams were then prepared to show the
pollution reduction benefits derived relative to the costs
incurred. As expected, the diagrams show an increasing cost
for treatment per percent reduction obtained as the percent
of the initial pollutional load remaining decreased. The
BPCTCA limitations were set at the point where the costs per
percent pollutant reduction took a sharp break upward toward
higher costs per percent of pollutant removed. These cost
effectiveness diagrams are presented in Section X.
The initial capital investment and annual expenditures
required of the carbon steel industry to achieve BPCTCA were
developed by multiplying the costs (capital or annual) for
the average size facility by the number of facilities
operating for each subcategory. These costs are summarized
in Table 197 in Section X. Table 197 also shows the costs
for the specialty steel segment.
After selection was made of the treatment technology to be
designated as one means to achieve the BPCTCA limitations
for each subcategory, a sketch of each treatment model was
prepared. The sketch for each subcategory is presented
following the table presenting the BPCTCA limitations for
the subcategory.
Multi-community Economic Impact
Comments submitted in response to effluent limitations
proposed on February 19, 1974 (39 F.R. 6481) , contended that
the proposed regulations might result in large employment
reduction in the multi-community Mahoning River Valley
region of eastern Ohio. Upon the promulgation of those
regulations on June 28, 1974 (39 F.R. 24114), EPA concluded
that it lacked sufficient information to support different
requirements for point sources located in that region.
Following the promulgation of those regulations, and in
accordance with the preamble hereto, companies contending
that the effluent limitations guidelines contained therein
would cause curtailment of operations and heavy unemployment
in the Mahoning Valley region were afforded the opportunity
of presenting detailed technical, cost and financial
information to support that contention. Similar
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opportunities to present additional information were
afforded to officials of state, county and municipal
governments and regional planning and economic development
agencies. The data supplied by the companies and other
commenters, and the evaluation thereof by EPA, through its
consultants, have been utilized in the establishment of the
effluent limitations guidelines, as set forth in interim
final form, promulgated herein.
EPA retained a consulting firm to study the data in
order to determine whether conditions in the Mahoning River
Valley region warrant the establishment of region-specific
effluent limitations. The primary purpose of the study was
to assess the likelihood that major economic dislocations
would result in the region from plant closings if region-
specific factors were not considered in establishing
effluent limitations guidelines for facilities located
therein. In order to make this assessment, it was necessary
to determine whether: (1) the return on investment from
continued operation of these plants was sufficient to allow
the firms to make the sizeable investments required for
pollution controls, and, (2) the firms would be able to
raise sufficient capital to provide pollution control
equipment for these plants in the context of the total
capital requirements of the firms.
On August 1, 1974, EPA requested that companies
operating facilities in the region submit, by September 15,
1974, data concerning estimates of investment and annual
costs for pollution control equipment required for non-
region specific effluent limitations, analyses of the
effects of such costs upon profitability, and rationale for
concluding whether the necessary capital could be invested.
In order to facilitate the submission of the data, which was
not accomplished by the September 15, 1974 deadline, EPA
delivered a questionnaire to the companies in October, 1974.
The information solicited therein concerned plant physical
and operating characteristics, financial management systems
and policies, historical operating and financial data,
pollution abatement cost analyses, and methodologies and
assumptions for ROI (Return on Investment) projections. The
gathering and evaluation of the data required conferences
attended by EPA and its consultants and the companies,
visits by EPA and its consultants to the corporate offices
of the companies, and inspections by EPA and its consultants
of the companies' steelmaking facilities in the Mahoning
River Valley.
Tentative analysis of the available data leads to the
conclusion that conditions in the Mahoning River Valley
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region are unique with respect to the physical and
geographical characteristics of the facilities located
therein, and the importance of the facilities to the economy
of the region. Tentative analysis of the available data and
the consultant's evaluation thereof appears to support that
mandatory compliance with effluent limitations guidelines
which do not take into account these factors is likely to
result in severe economic dislocation within the Mahoning
River Valley region.
The discussion of categorization within the industry
contained in (i) supra, indicates that EPA has concluded
that subcategorizaticn of the industry is inappropriate on
the basis of size, per se, age, per se, or land availability
(location) , per se. The type of manufacturing process
employed was deemed to be the appropriate determinant of
subcategorization.
Data submitted by the companies operating in the
Mahoning Valley region reveal a unique combination of
economically disadvantageous size, age and land availability
(location) factors which appear to warrant consideration
pursuant to section 304 (b) (1) (B) of the Federal Water
Pollution Control Act, as amended, in determining the best
practicable control technologies available to facilities in
the region. The plants in the Mahoning River Valley region
include some of the oldest steelmaking facilities still in
use in the United States. The first steel plants in the
region were installed near the turn of the century. Four
blast furnaces and fourteen open hearth furnaces at one
facility are in the range of 60-75 years in age. In another
facility, the newest finishing mill is 40 years old with the
balance of finishing equipment more than 50 years old.
Several antiquated units have been closed over the past
several years.
In addition to similar economic disadvantages resulting
from age and size characteristics, facilities in the region
appear to share economic disadvantages caused by locational
characteristics. These include the movement of markets away
from the region, constrained access to raw materials due to
the unavailability of waterborne transportation and required
transhipment by rail, and space limitations which prohibit
major expansion of existing facilities. All eight steel
plants operated by the companies submitting data are built
on land surrounded by either the river, main highways or
residential or industrial buildings.
As a result of this combination of age, size and land
availability (location) factors common to plants in the
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region, these facilities appear to be economically marginal
before the addition of pollution control costs. Tentative
analysis of available data and the consultant's evaluation
thereof indicates that the imposition of pollution control
costs is likely to substantially degrade the already
marginal profitability of these plants. Tentative analysis
of cash flows developed from company data submissions,
calculated on a "stand-alone" basis for average case and
best case conditions appear to substantiate this conclusion.
The cash .flows for all evaluated facilities are expected to
be negative on a stand alone basis under average conditions.
On this basis, the Mahoning Valley operations of one of the
companies submitting data is expected to realize a positive
cash flow only under infrequently occurring conditions of
maximum demand, while the operations of the two remaining
companies are expected to have negative cash flows even
under the best conditions.
The likelihood of a plant closing in a particular
community as a result of the unwillingness or inability of
its owners to invest the sums necessary to meet effluent
limitations does not justify the relaxation of those
limitations. On the contrary, the legislative history of
the Act indicates Congressional awareness that plant
closings may result. Similarly, the combination of
disadvantageous age, size, and land availability (location)
factors which apparently results in the marginal economic
status of the Mahoning Valley plants does not, in itself,
require the relaxation of standards which would otherwise be
applicable. What does justify a relaxation of otherwise
applicable standards is the requirement in section
304(b) (1) (B) of the Act that the assessment of best
practicable control technology currently available shall
include, inter alia, consideration of the total cost of
application of technology to the effluent reduction benefits
to be achieved from such application. The total cost of
application of technology includes external costs such as
potential unemployment, dislocation, and rural area economic
development sustained by the community, area, or region. It
is this consideration of external costs in relation to the
effluent reduction benefits to be achieved which established
the propriety of exempting point sources located within the
Mahoning Valley from required compliance with the nationwide
effluent limitations based on BPCTCA. As discussed
previously, the imposition of non-region specific effluent
limitations to facilities in the Mahoning Valley which share
region-specific economic disadvantages appears likely to
lead to plant closing, the effect of which would be heavy
unemployment and severe economic dislocation in this multi-
community region.
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Steel production is the largest single factor in the
economy of the Mahoning River Valley, a region with a
population of approximately 550 thousand. In terms of jobs
and payroll, the steel industry employs more people,
approximately 15% and provides more wages, approximately
20%, than any other industry in the region. Of more
significance than the percentages of employment and payroll,
however, is the absolute magnitude of the employment and
payroll statistics. Steel industry operations in the two-
county region account for 27,000 jobs and a taxable payroll
of $80 million. In addition, according to a study conducted
for a local economic development Agency in 1972, the
industry, in addition to its own payroll, purchased $90
million in goods and services from the local economy,
supporting an additional 3300 jobs with a total payroll of
about $31 million, and generated between 19% and 27% of the
region's 201,500 non-farm jobs and a similar proportion of
the $142 million in total tax revenues of local
jurisdications.
The relief granted from severe economic impact in the
Mahoning River Valley region, which impact is likely to
occur absent such relief, is the exemption of point sources
located within that region from the effluent limitations
based on best practicable control technology currently
available. Nevertheless, the Agency fully expects that
authorities granting permits, pursuant to section 402 of the
Federal Water Pollution Control Act, as amended, shall not
allow point sources in that region to discharge pollutants
in any greater amounts than are currently being discharged
by those sources.
As to reguirements which will be applicable in the
future, EPA is proposing limitations which establish the
degree of effluent reduction accomplished by BAT, under
section 301(b)(2) of the Act. The proposed BAT limitations
for plants in the Mahoning Valley are identical to those
reguired to be met by the balance of the industry. Section
301(c) authorizes modifications to be made in these
limitations under certain circumstances, based in part on
economic conditions applicable to individual owners and
operators.
Modifications under 301(c) may not, of course, reduce
the level of treatment below that required by BPT or
applicable state water quality standards. Since the Agency
is not establishing BPT limits for the Mahoning Valley
plants, a special provision is proposed which will confine
any such 301(c) modifications for Mahoning Valley plants to
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levels comparable to a region-specific BPT installed at an
economically feasible pace.
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SECTION X
EFFLUENT QUALITY ATTAINABLE THROUGH
THE APPLICATION OF THE BEST AVAILABLE TECHNOLOGY
ECONOMICALLY ACHIEVABLE
EFFLUENT LIMITATIONS GUIDELINES
The effluent limitations which must be achieved by July 1,
1983 are to specify the degree of effluent reduction
attainable through the application of the best available
technology economically achievable. Best available
technology is not based upon an average of the best
performance within an industrial category, but is to be
determined by identifying the very best control and
treatment technology employed by a specific point source
within the industrial category or subcategory, or where it
is readily transferable from one industry to another, such
technology may be identified as BATEA technology.
With the exception of the Hot Coating - Galvanizing and
Terne subcategories and the absorber vent scrubber on the
hydrochloric acid subcategory, there are plants in all other
categories who are presently achieving the BATEA effluent
limitation guidelines for carbon steel plants. This in
itself justifies the fact that technology is available and
demonstrates that the limitations can be achieved on a day
by day basis.
Consideration must also be given to:
1. The size and age of equipment and facilities involved.
2. The processes employed.
3. Non-water quality environmental impact (including energy
requirements).
4. The engineering aspects of the application of various
types of control techniques.
5. Process changes.
6. The cost of achieving the effluent reduction resulting
from application of BATEA technology.
Best available technology assess the availability in all
cases of in-process changes or controls which can be applied
to reduce waste loads, as well as additional treatment
663
-------
techniques which can be applied at the end of a production
process. Those plant processes and control technologies
which at the pilot plant, semi-works, or other level, have
demonstrated both technological performance and economic
viability at a level sufficient to reasonably justify
investing in such facilities may be considered in assessing
best available technology.
Best available technology is the highest degree of control
technology that has been achieved or has been demonstrated
to be capable of being designed for plant scale operation up
to and including "no discharge" of pollutants. Although
economic factors are considered in the development, the cost
for this level of control is intended to be the top-of-the-
line current technology subject to limitations imposed by
economic and engineering feasibility. However, this level
may be characterized by some technical risk with respect to
performance and with respect to certainty of costs.
Therefore, the BATEA limitations may necessitate some
industrially sponsored development work prior to its
application.
IDENTIFICATION OF THE BEST AVAILABLE TECHNOLOGY ECONOMICALLY
ACHIEVABLE - BATEA
Based on the information contained in Sections III through
VIII of this report, a determination has been made that the
quality of effluent- attainable through the application of
the Best Available Technology Economically Achievable is as
listed in Tables 174 through 196. These tables set forth
the ELGs for the following process subcategories of the
steel industry.
3. Basic Oxygen Furnace (Wet Air Pollution Control Methods)
- BPCTCA plus treatment of blowdown by lime precipitation of
fluorides, followed by sedimentation and neutralization.
K. Vacuum Degassing - BPCTCA plus additional lime
treatment, clarification and filtration, and biological
flenitrif ication, if necessary.
L. Continuous Casting and Pressure Slab Molding - BPCTCA
plus pressure filtration of the blowdown.
M. Hot Forming-Primary - BPCTCA plus recycle of clarifier
effluent to the sprays, discharge of 25 gpt (40 gpt for
alloy) .
664
-------
N. Hot Forming-Section - BPCTCA plus total recycle of
clarifier effluent through cooling tower to the sprays,
resulting in zero discharge to navigable waters.
O. Hot Forming-Flat-Plate - BPCTCA plus discharge of 150
gpt (350 gpt for alloy) and remainder recycled after cooling
tower.
Hot Strip and sheet - total recycle of clarifier effluent
through cooling tower to the sprays, resulting in zero
discharge to navigable waters.
P. Pipe and Tubes - for integrated mills; total recycle of
clarifier effluent through cooling tower resulting in zero
discharge to navigable waters.
For isolated mills; total recycle of clarifier effluent
through ponds resulting in zero discharge to navigable
waters.
Q. Pickling-Sulfuric Acid-Batch and Continuous - Batch and
Continuous Concentrates: identical to that for best
practicable control technology currently available.
Batch and Continuous Rinses: for those facilities practicing
neutralization as of December 1, 1975; countercurrent rinses
and cascade use in fume hoods to achieve 25 gpt of fume hood
scrubber and rinse discharges.
For those facilities without neutralization as of December
1, 1975 - countercurrent rinsing to achieve zero discharge
to navigable waters.
R. Pickling-Hydrochloric Acid-Batch and Continuous - For
batch concentrates: aeration, followed by a settling lagoon
with 2 to 5 day retention.
For batch rinses: countercurrent rinsing, aeration and
mixing followed by 2 to 5 day settling.
For batch fume hood scrubbers: aeration and mixing followed
by 2 to 5 day settling.
For continuous concentrates: settling for 2 to 5 days.
For continuous operations with absorber vent scrubbers:
recycle to the acid absorber vent scrubber, reuse, and a
settling lagoon with 2 to 5 day retention.
665
-------
For continuous rinses: countercurrent rinsing, aeration and
mixing followed by 2 to 5 day settling.
For continuous operations with a fume hood scrubber:
aeration and mixing followed by 2 to 5 day settling.
S. Cold Rolling-Recirculation, Combination, Direct
Application - identical to that for best practicable control
technology currently available.
T. Hot Coat Galvanizing - Rinses: countercurrent rinses,
neutralization by chemical addition, settling lagoon with 2
to 5 day retention.
Fume Hood Scrubber: recycle, settling lagoon with 2 to 5
day retention.
U. Hot Coat-Terne - Rinses: countercurrent rinses,
neutralization by chemical addition, settling lagoon with 2-
5 day retention.
Fume Hood Scrubber: recycle, neutralization by chemical
addition, settling lagoon with 2 to 5 day retention.
V. Miscellaneous Runoffs - Stock Piles - parameter
collection, egualization, neutralization by chemical
addition, chemical treatment and flocculation, polymer
addition, settling lagoon with 2 to 5 day retention.
Casting and Slagging - water conservation to prevent runoff
resulting in zero discharge to navigable waters.
W. Combination Acid-Batch and continous - identical to that
for best practicable control technology currently available.
X. Scale Removal - Kolene and Hydride - identical to that
for best practicable control technology currently available.
Y. Wire Pickling and Coating - identical to that for best
practicable control technology currently available.
Z. Alkaline Cleaning - identical to that for best
practicable control technology currently available.
In establishing the subject guidelines, it should be noted
that the resulting limitations or standards are applicable
to aqueous waste discharges only, exclusive of noncontact
cooling waters. In the section of this report which
discusses control and treatment technology for the iron and
steelmaking industry as a whole, a qualitative reference has
666
-------
been given regarding "the environmental impact other than
water" for the subcategories investigated.
The effluent guidelines established herein take into account
only those aqueous constituents considered to be major
pollutants in each of the subcategories investigated. In
general, the critical parameters were selected for each
subcategory on the basis of those waste constituents known
to be generated in the specific manufacturing process and
also known to be present in sufficient quantities to be
inimical to the environment. Certain general parameters
such as suspended solids naturally include the oxides of
iron and silica. However, these latter specific
constituents were not included as critical parameters, since
adequate removal of the general parameters (suspended
solids) in turn provides for adequate removal of the more
specific parameters indicated. This does not hold true when
certain of the parameters are in the dissolved state;
however, in the case of iron oxides generated in the iron
and steelmaking processes, they are for the most part
insoluble in the relatively neutral effluents in which they
are contained. The absence of apparently less important
parameters from the guidelines in no way endorses
unrestricted discharge of the same.
The recommended BATEA effluent limitations guidelines
resulting from this study are summarized in Tables 174 to
196. These tables also list the control and treatment
technology applicable or normally utilized to reach the
constituent levels indicated. Figures 151 to 176 present
the BATEA treatment models. These effluent limitations set
herein are not necessarily the absolute lowest values
attainable (except where no discharge of process wastewater
pollutants to navigable waters is recommended) by the
indicated technology, but rather they represent values which
can be readily controlled around on a day by day basis.
It should be noted that these effluent limitations represent
values not to be exceeded by any 30 continuous day average.
The maximum daily effluent loads per unit of production
should not exceed these values by more than a factor of
three as discussed in Section IX.
RATIONALE FOR THE SELECTION OF BAT FA
The following paragraphs summarize the factors that were
considered in selecting the categorization, water use rates,
level of treatment technology, effluent concentrations
attainable by the technology, and hence the establishment of
the effluent limitations for BATEA.
667
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669
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Figure 151-2
MODEL COST EFFECTIVENESS DIAGRAM
BASIC OXYGEN FURNACE
(WET AIR POLLUTION CONTROL METHODS) SUBCATEGORY
"*ANNUAL COSTS = BASED ON TEN YEAR CAPITAL RECOVERY
+ INTEREST RATE 7%
+ OPERATING COSTS INCLUDE LABOR, CHEMICALS
& UTILITIES
•*• MAINTENANCE COSTS BASED ON 3.5% OF CAPITAL
COSTS
THIS GRAPH CANNOT BE USED FOR INTERMEDIATE VALUES
*C05T BASED ON 2847 KKG/DAY {2808 TON/DAY) BOF SHOP
473,830
429,059
376,878
318,189
244,094
D
(BATEA)
C
(BPCTCA)
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(BASE LEVEL)
PERCENT REMOVED
670
-------
Size and Age of Facilities and Land Availabili ty
Considerations
As discussed in Section IV, the age and size of steel
industry facilities has little direct bearing on the
quantity or quality of wastewater generated. Thus, the ELG
for a given sutcategory of waste source applies equally to
all plants regardless of size or age. Land availability for
installation of add-on treatment facilities can influence
the type of technology utilized to meet the ELGs. This is
one of the considerations which can account for a wide range
in the costs that might be incurred.
Cons ider at ion of Processes Employed
All plants in a given subcategory use the same or similar
production methods, giving similar discharges. There is no
evidence that operation of any current process or subprocess
will substantially affect capabilities to implement the best
available control technology economically achievable. At
such time that new processes appear imminent for broad
application, the ELGs should be amended to cover these new
sources. The treatment technologies to achieve BATEA assess
the availability of in-process controls as well as control
or additional treatment techniques employed at the end of a
production process.
Consideration of Non-Water Quality Environmental Impact
Impact of Limitations on Air Quality. The impact of BATEA
limitations upon the non-water elements of the environment
has been considered. The increased use of recycle systems
have the potential for increasing the loss of volatiles to
the atmosphere. Recycle systems are so effective in
reducing wastewater volumes, and hence waste loads to and
from treatment systems, and in reducing the size and cost of
treatment systems that a trade-off must be accepted.
Recycle systems requiring the use of cooling towers have
contributed significantly to reductions of effluent loads
while contributing only minimally to air pollution problems.
Careful operation of such a system can avoid or minimize air
pollution problems. The handling and storage of spent
nitric-hydrofluoric pickling solutions must be done with
care to avoid fumes of nitrogen oxides. One plant uses
floating plastic balls on the surface of open tanks to avoid
this problem.
Impact of Limitations on Solid Waste Problems.
Consideration has also been given to the solid waste aspects
of water pollution controls. The processes for treating the
671
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FIGURE 152-2
MODEL COST EFFECTIVENESS DIAGRAM
VACUUM DEGASSING SUBCATEGORY
* ANNUAL COST = BASED ON TEN YEAR CAPITAL RECOVERY
•f INTEREST RATE 7%
+ OPERATING COSTS INCLUDE LABOR, CHEMICALS &
UTILITIES
+ MAINTENANCE COSTS BASED ON 3.5% OF CAPITAL
COSTS
THIS GRAPH CANNOT BE USED FOR INTERMEDIATE VALUES
*COST BASED ON 472 KKG/DAY (520 TON/DAY) VACUUM DEGASSING
OPERATION
SUSPENDED SOLIDS
C
(BATEA)
B
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(BASE LEVEL)
100
PERCENT REMOVED
674
-------
wastewaters from this industry produce considerable volumes
of sludges. Much of this material is inert iron oxide which
can be reused profitably in melting operations. Other
sludges not suitable for reuse must be disposed of to
landfills, since most of them are chemical precipitates
which could be little reduced by incineration. Being
precipitates they are by nature relatively insoluble and
nonhazardous substances requiring minimal custodial care.
Impact of Limitations Due to Hazardous Materials. In order
to ensure long-term protection of the environment from
harmful constituents, special consideration of disposal
sites should be made. All landfill sites should be selected
so as to prevent horizontal and vertical migration of these
contaminants to ground or surface waters. In cases where
geologic conditions may not reasonably ensure this, adequate
mechanical precautions (e.g., impervious liners) should be
taken to ensure long-term protection to the environment. A
program of routine periodic sampling and analysis of
leachates is advisable. Where appropriate, the location of
solid hazardous materials disposal sites should be
permanently recorded in the appropriate office of legal
jurisdiction.
Impact of Limitations on Energy Requirements. The effect of
water pollution control measures on energy requirements has
also been determined. The additional energy required in the
form of electric power to achieve the effluent limitations
proposed for BPCTCA and BATEA amounts to less than 2% of the
electrical energy used by the carbon steel industry in 1972.
Limitations proposed for BPCTCA and BATEA amount to less
than 1.5 to 3.7 percent of the power required for alloy
production.
The enhancement to water quality management provided by
these effluent limitations substantially outweighs the
impact on air, solid waste, and energy requirements.
Consideration of the Engineering Aspects of the Application
of Various Types of Control Techniques
The BATEA level of technology is considered to be the best
available and economically achievable in that the concepts
are proven and available for implementation, and may be
readily applied through adaptation or as add-ons to proposed
BPCTCA treatment facilities.
Basic Oxygen Furnace Operation
675
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676
-------
Hjv
*
677
-------
FIGURE 153-2
MODEL COST EFFECTIVENESS DIAGRAM
CONTINUOUS CASTING AND PRESSURE SLAB MOLDING
*ANNUAL COSTS = BASED ON TEN YEAR CAPITAL RECOVERY
•f INTEREST RATE 7%
•f OPERATING COSTS INCLUDE LABOR, CHEMICAL & UTILITIES
+ MAINTENANCE COSTS BASED ON 3.5% OF CAPITAL COSTS
THIS GR^-PH CANNOT BE USED FOR INTERMEDIATE VALUES
*COSTS BASED ON 544KKG/DAY (6CO TON/DAY) CONTINUOUS CASTING OPERATION
B
(BATEA)
A
(BPCTCA)
60
Percent Removed
80
100
678
-------
The only direct contact process water used in the EOF plant
is the water used for cooling and scrubbing the off-gases
from the furnaces. One method used is the wet gas cleaning
system which uses a venturi scrubber and a gas quencher-
The use of wet air pollution controls is rare in the alloy
and stainless steel industry. The water use at one plant
producing alloy steel in a EOF was 870 gals/ton. The water
was used once-through and the only treatment provided was
clarification where the BOF waste-water was combined with
blast furnace gaswasher water.
The technology identified as used in the alloy and stainless
steel industry was judged to be inadequate. The water use
rate lies within the range found in the carbon steel
industry plant surveys (542-4250 1/kkg) and there is no
reason to believe that the technology in use there is not
directly transferable, since the characteristics of the
waste waters and the nature of the processes are similar.
The BATEA limitations have thus been'established on the
basis of an effluent suspended solids concentration of 25
mg/1 at an effluent volume of 208 1/kkg (50 gals/ton). The
blowdown rate of 5.9 percent is being achieved in at least
one carbon steel plant and at least two such plants are
achieving this effluent concentration of suspended solids.
The pH of the scrubber water effluent from the alloy steel
BOF averaged 7.4, so that no difficulty with a pH 6-9
limitation is foreseen. The BATEA limitations for carbon
steel operations also specify a limit for fluoride based
upon an effluent concentration of 20 mg/1 attainable by lime
precipitation and sedimentation. The alloy steel BOF
surveyed indicated fluoride present in the raw waste at a
concentration at 10 mg/1 vs. 14 mg/1 found in the carbon
steel survey. Similar treatment to reduce the expectedly
high concentrations in the blowdown are thus similarly
attainable in alloy steel operations.
Vacuum Degassing Subcategory
The direct contast process water used in vacuum degassing is
the cooling water used for the steam-jet barometric
condensers. Although most systems use steam ejectors to
draw the vacuum, dry mechanical pumps are also used. The
vacuum degassing systems surveyed used water once-through
with little effective treatment, completely recirculated the
water with no discharge, or used mechanical pumps.
It was judged to be unduly restrictive to impose a zero
effluent discharge limitation for BATEA, because all plants
may not be able to completely recirculate the water or
convert to mechanical pumps. The water use rate determined
679
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680
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681
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453^67
FIGURE 154-2.
MODEL COST EFFECTIVENESS
HOT FORMING)- PRIMARY 5UBCATEG|ORY
ANNUAL COST- BASED ON TEN YEAR CAPITAL RECOVERY
+ INTEREST RATE. 7 %
+ OPe.WATIN(a COSTS INCLUDE LABOR, CHEMICALS 4 UTILITIES
•(•OPERATING) AND MAINTENANCE. COSTS BASED OKI 3.9%
OF CAPITAL COSTS
COST BASED OM 3
-------
Figure 154-A
Hot Forming - Primary - Specialty
Annual Cost = Based on Ten Year Capital Recovery
+ Interest Rate 7%
+ Operating Costs Include Labor, Chemicals & Utilities
+ Operating & Maintenance Costs based on 3.5%
of Capital Costs
Cost based on 2,144 kkg/day (2,364 tons/day) of steel rolled.
This graph cannot be used for intermediate values.
SIB 62
3\,->&3
E faTc.TC.4j
teo
683
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684
-------
685
-------
F/GUGE ISS-'L
MODEL COST SFFECT/VEKESS O/AG&AM
HOT FQGMING- SECT/O/V SUBCATSGO/2Y
ANNUAL COSTS = BASED ON JEN VEA& CAP/TAL
•+/NTE/ZEST /S.ATS 7%
/ OP£i2A7(N<5 COSTS /NCLUDE LAQO&, CHEMICALS 4L/T/LITK
+OPEKAT/UG AMD MAINTENANCE COSTS BASED ON 3.5%
O^ CAP/TAL COSTS
COSTS BASED ON/l/79KKG/DAY0300TO^JS/DAY)of:-STEEL HOLt-ED
THIS GRAPH CANNOT BE USED POR IMTEKMED/ATE VALUES
774,039
673,010
50,741
36,539
CBATEA^
IOO
686
-------
Figure 155-A
Hot Forming - Section - Specialty
Annual Cost = Based on Ten Year Capital Recovery
+ Interest Rate 7%
+ Operating Costs Include Labor, Chemicals & Utilities
+ Operating & Maintenance Costs based on 3.5%
of Capital Costs
Cost based on 327 kkg/day (360 tons/day) of steel rolled.
This graph cannot be used for intermediate values.
too
687
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688
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689
-------
FIGURE IS6-Z
MODEL COST EFFECTIVENESS
HOT FORM INS- FLAT- HOT STRIP AND SHEET
SUBCATESORY
ANMUAL COSTS * BASED ON TEN YEAR CAPITAL RECOVERY
+ INTEREST RATE 1%
+ OPERATING COSTS INCLUDE LABOR,CHEMICALS 4 UTILITIES
+ OPERATING AND MAINTENANCE COSTS BASED ON 3.s1> OF CAPITAL COSTS
COST BASED ON 344-7 KKft/DAY (38OOTONS/DAY) OF STEEL ROLLED
THIS GRAPH CANNOT BE USED FOR INTERMEDIATE VALUES
1,970, 103-
1,310,214-
789,817
440,169 •
<3 (BATEAU
IOO
690
-------
FIGURE 156-A
MODEL COST EFFECTIVENESS DIAGRAM
HOT FORMING - FLAT - HS & SHEET
ANNUAL COSTS « BASED ON TEN YEAR CAPITAL RECOVERY
+ INTEREST RATE 7 %
+ OPERATING COSTS INCLUDE LABOR, CHEMICALS & UTILITIES
+ MAINTENANCE COSTS INCLUDE LABOR & MATERIALS
COSTS BASED ON 1851 KKG/DAY (2041 TONS/DAY) PRODUCTION
THIS GRAPH CANNOT BE USED FOR INTERMEDIATE VALUES
1,404,120
1,254,809
SUSPENDED SOLIDS
274,487
54,249
32,011
G
(BATEA)
E
(BPCTCA)
D
B
A
(BASE
LEVEL)
100
PERCENT REMOVED
691
-------
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692
-------
693
-------
FIQURE 157-2
MODEL COST EFFECTIVENESS DIAGRAM
HOT FORMIWG,-FLAT-PLATE SUBCATEQORV
ANNUAL COSTS-BASED ON TEN VEAR CAPITAL RECOVERV
t INTEREST RATE 7%
+ OPE*«TIM^ COSTS INCLUDES LAEK5R ,CWftM4CAA.* t UTILITIES
•t-OPERATING, AMD MAIMTCMAKJCE COSTS BASED OM
3.5?, OP CAPITAL COSTS
COSTS BASED OM 1814 KKQ/DAV (3OOO TONS/DAV^ OP STEEL ROLLED
THIS GRAPH CAM MOT BE USED FOR INTERMEDIATE VALUES
(3 (BATEA')
fo4,07O
47,573
B
AfREFERENCE
2O
too
PERCENT REMOVED
694
-------
Figure 157-A
Hot Forming - Flat - Plate - Specialty
Annual Cost = Based on Ten Year Capital Recovery
+ Interest Rate 7%
+ Operating Costs Include Labor, Chemicals & Utilities
+ Operating & Maintenance Costs based on 3.5%
of Capital Costs
Cost based on 479 kkg/day (528 tons/day) of steel rolled.
This graph cannot be used for intermediate values.
C
6,
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695
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697
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FIGURE I5S-2.
MODEL COSTS EFFECTIVENESS DIAGRAM
PIPE AND TUBES SUBCATE.QORY
INTEGRATED PLANTS (THOSE WITH NO LAND AVAILABLE.)
ANN UAL COSTS = BASED ON TEN YEAR CAPITAL RECOVERY
+ INTEREST RATE 7%
•t-OPERATING. COSTS INCLUDE LABOR, CHEMICALS £ UTILITIES
+ OPERATING AND MAINTENANCE- COSTS B466D
ON 3.5 7. OF CA^I TAl_ COSTS>
COSTS BA5&O ON 3fe3 KKfi/DAY (400 TONS/DAY) PRODUCTION
TWI5 GRAPH CANNOT BE-USfrD FOe INTB2.MEDIATE- VAl_u&<=>.
24937O
235,760
q (BATEA
FOR. SEAMLESS)
F (SEAMLESS
ONLV)
169,728
155,516
E'(BPCTCA FOR
120,798
98.B34
37.Z35
33,730
ALL EXCEPT
SEAMLESS)
A (RErERENCE.
LEVEL)
i r i
4O 6O
PERCENT REMOVED
80
IOO
698
-------
for the once-through system (3022 1/kkg) lies in the range
found in the carbon steel industry plant surveys (813-3750
1/kkg) and there is no reason to believe that the technology
in use there is not directly transferable, since the
characteristics of the waste waters and the nature of the
processes are similar. The BATEA limitations have thus been
established on the basis of an effluent suspended solids
concentration of 25 mg/1 at an effluent volume of 1014 1/kkg
(25 gals/ton). The blowdown rate of 3.H percent is being
achieved in at least one carbon steel plant and, of course,
in the completely recirculated system mentioned above. The
pH of the once-through alloy steel system averaged 6.5
(within the specified 6-9 range) . Limits for zinc,
manganese, lead, and nitrate were also established for this
subcategory of the carbon steel industry. The raw waste
concentrations of zinc, lead, and nitrate were not found to
be significant in the vacuum degassing effluents at Plants E
and G in the alloy and stainless steel industry plant
survey; maximum concentrations found were 0.37, Zero, and
17.6 mg/1, respectively. Fluoride and manganese
concentrations were found at 35 mg/1 each at Plant E, but
were negligible at Plant G. Accordingly the BATEA
limitations for this subcategory of the alloy and stainless
steel industry include a limitation for manganese on the
basis of an effluent concentration of 5 mg/1 and for
fluoride on the basis of 20 mg/1. Manganese and suspended
solids removals are based upon the use of sand filtration as
in the carbon steel industry guidelines. Fluoride removal
is based upon the use of lime precipitation and
sedimentation as for the BOF subcategory above.
Continuous Casting and Pressure Slab Molding Subcategory
Continuous casting and pressure slab molding are processes
by which primary steel shapes are cast or molded from molten
steel instead of being rolled from ingots. The molds are
cooled by indirect water circulation. The spray cooling
water system is a direct contact cooling of the cast
product. As the cast product (slabs, blooms, or billets)
emerge from the molds, the water sprays further cool and
harden a thicker skin on the cast product. The principle
waste contaminant in this contact water is suspended solids
and, additionally, oil from machinery lubrication finds its
way into this water effluent. Pressure slab molding, in a
manner analogous to that found in the case of continuous
casting, results in the generation of wastewaters containing
suspended solids and oil.
The current control and treatment technology in the alloy
and stainless steel industry consists of clarification of
699
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701
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F/GUB.E /5<=>-2
MODEL COST EFFECTIVENESS D/AGQAM
P/PE $ TUBE'S SUBCATEGO/QY
/SOLATED PLANTS (THOSE W/W LAND AVAILABLE FOR LARGE
ANNUAL COSTS */3A5EO ON TEN VEA/2 CAP/TAL
+ INTEREST GATE 7%
+ OPERAT/NG COSTS /NCLUDE LABOG ^CHEMICALS $ UTILITIES
+ OPERATING. A>NC>tA\WTE.NfrvNCE COSTS BAiSEta
ON 3. 5^0 C>FCAP|TO\_C.C»5TS
COSTS BASED O^ 3C.-5 KX.Q/DKY (4OOTON3/D^Y) PRODUCTION
USEO'
81,17* -| 1-£
(3AT£A)
66,966
PREFERENCE
LEVEL)
/OO
-------
the waste water with varying degrees of recirculation of the
water to the process use. One plant surveyed recirculates
the water completely with only periodic batch-type blowdown
of the systems.
No system in current use in the alloy and stainless steel
industry was found to be adequate and/or necessarily usable
at all other plants; treatments were adequate, but complete
recirculation may not always be feasible. The water use
rates of 2379-4173 1/kkg are lower than the minimum of 6172
1/kkg found in the carbon steel industry plants surveyed.
The characteristics of the waste waters and the nature of
the processes are similar to those in the carbon steel
industry and hence there is no reason to believe that the
technology in use there is not directly transferable,
resulting in a conservative estimate of achievable
limitations. The BATEA limitations have thus been
established on the basis of effluent suspended solids
concentrations of 10 mg/1 and of 10 mg/1 oil and grease at
an effluent volume of 522 1/kkg (125 gal/ton) . The
resultant blowdown rates are easily achievable as compared
to those in either carbon steel plant surveyed and one
carbon steel plant surveyed was achieving lower
concentrations of both suspended solids and oil and grease.
The suspended solids and oil and grease removals were
established on the basis of using a flat bed filter system
as in use at this one carbon steel plant. All plants
surveyed easily achieved an effluent pH between 6 and 9.
Hot Forming-Primary •
The best plant in the subcategory was used in calculating
the best available technology limitations. In this case, it
was plant L-2. However, because the water usage rate for
this plant was smaller than the average of the other plants,
an increase in the loading was made, based on water usage
ratios. Using direct transfer of technology, the guidelines
for this category were scaled up to reflect the higher water
use rate for alloy operations to arrive at the guidelines
for specialty steel operations.
Hot Forming-Section
Of the ten process lines surveyed for this subcategory, four
were practicing either tight or total recycle. Two of these
plants had effluent flows of 584 1/kkg (140 gal/ton) and
1,555 1/kkg (373 gal/ton) of product. The third plant
containing two process lines had zero aqueous discharge,
with the only "blowdown" being the water content of the wet
sludges generated by the treatment processes.
703
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705
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FIGURE ieO-Z
MODEL COST ££TECr/VEAfESS D/AGBAM
PtCKL W<5 - 5ULFUAIC A C/D - GA TCH
ANNUAL COSTS = BASSD ON JEN YEAR CAWTAL
+ INTEREST SATE 7%
y- OPERATING COSTS INCLUOE LA8QRtCHEMKAI-S
+ OPERATING AND MAINTENANCE COSTS*BASED ON 3.5%
OF CAPITAL COSTS
COSTS BASED ON Z27 KKG/DAY (ZSO TONS/DAY) OF STEEL PICKLED
THIS GRAPH CAUNOT BE USED FOR INTERMEDIATE VALUES
*TOTAL COSTS POR LEVEL B' INCLUDE CREDITS POR
ACIO RECOVERY AND AL&O REFLECT SAVIMQS DUE
TO E.LIMINATIOM OF OFF-SITE. DISPOSAL COSTS
WHICH WERE INCLUDED IN LEVEL A. COSTS SHOWN
FOR LEVEL B ARE ^ROSS COSTS, WITH MO CREDITS
I55.46Z
DOLLARS SPENT FOR "COLLECTION SYSTEM AND
HAULINQ WASTES FOR OFF-SITE DISPOSAL IN
LEVEL A. THIS MEANS OF DISPOSAL IS ABANDONED
AND REPLACED BY A SYSTEM UTILIZING, COUNTER
CURRENT RIK1SIN& TO REDUCE RINSE WATER
FLOWS TO A VOLUME SUITABLE FOR USE AS
MAKE-UP TO PICKLE TANKS. SPENT PICKLE
LIQUORS ARE REGENERATED IN A EVAPORATIVE
RECOVERY UNIT, PRODUCING, H25O4 AND
I
20
I I I I I
PERCENT REMOVED
706
I
ffO
(BPCTCA i
LEVEL)
(BPCTCA 4
/oo
-------
One plant operating two bar mills was recycling so
effectively that no aqueous discharges were required. From
the data base, the best available technoloyg indicates that
the water discharged for BPT should he passed over a cooling
tower and then recycled totally to the sprays resulting in
zero discharge to navigable waters.
The section rolling mills in the alloy and stainless steel
industry plant survey in this sutcategory had water uses
which averaged to be slightly less than for carbon steel.
Directly transferring the technology results in a
conservative effluent limitation.
Hot Forming-Flat Plate
Limitations here are based on the present performance of the
best plant. The limitations for alloy steel are based on
those for carbon steel, with allowance made for higher water
usage.
Hot Forming-Flat, Hot Strip and Sheet
The best plant in the subcategory was used for the basis of
BAT determinations. This plant was achieving zero
discharge. The specialty steel hot strip mills which were
surveyed had water usage rates which were slightly less than
those in the carbon steel segment. However, none of the
specialty plants were practicing recirculation. Therefore,
the technology used in the carbon steel segment was directly
transferred and the limitations were established as the same
for both, resulting in a conservative limitation for the
specialty strip mills.
Pipe and Tube
As indicated for BPT, one of the electric resistance welding
plants was eliminated from the discharge flow determination
because it used evaporation to achieve zero discharge and
this treatment technology is not generally applicable to all
steel plants. Two of the six plants sampled achieved zero
discharge through total recycle, thus indicating the best
plants in the subcategory. The BAT technology and
limitations are based, therefore, on total recycle resulting
in zero discharge to navigable waters. The BAT effluent
limitations guidelines are for both isolated and integrated
mills.
Sulfuric Acid-Batch
707
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709
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FIGURE IG-li-Z
MODEL COST EFFECTIVENESS DIAGRAM
PICKLINQ SULPURIC ACID- CONTINUOUS SUBCATEQORV
TREATMENT VIA NEUTRALIZATION
ANNUAL COSTS = BASED ON TEKl VEAR CAPITAL RECOVERS
-*• INTEREST RATE. 7%
+ OPERATING COSTS INCLUDE LABOR, CHEMICALS i UTILITIES
••• OPERATING ^ MAIKITENANCE COSTS B.ASED OKJ -3.5% OP
CAPITAL COSTS
COSTS BASED OMIO88K KG/ DAY f 1100 TOKJS/DAY) OF STEEL PICKLED
THIS GRAPH CAMNOT BE USED FOR INTER MEDIATE. VALUES
c (BATEA)
A (REFERENCE
B. L
(BATEA)
* TOTAL COSTS FOR LEVELS B' AND C1 REFLECT
SAVINGS DUE TO ELIMINATION OF «4fe6,,OOO
OP CONTRACT HAULINQ COSTS WHICH
WERE IMCLUDED IN LEVEL A. COSTS
SWOWN FOR LEVELS B AND C ARE
COSTS WITH NO CRtDITS.
60
60
IOO
710
-------
Examination of the data base indicated that the BAT
technology and limitations are identical to those of BPT.
SuIfuric Acid-Continuous
For plants with neutralization facilities existing at the
time of promulgation, the BAT limitations are based on the
use of countercurrent rinses and cascade use in fume hoods
to achieve flows of 25 gpt of concentrate and 25 gpt of fume
hood scrubber and rinse discharges.
For those plants presently without neutralization, BAT
limitations are set at zero discharge for both concentrate
and rinses.
Pickling-Hydrochloric Acid-Batch and Continuous-Concentrates
Concentrates
The most modern pickling installations in use today utilize
hydrochloric acid continuous pickling, with continuous
regeneration of spent pickle liquor to produce reusable
hydrochloric acid and sinterable ferric oxides. Such
systems are discussed in Section IX, where the BPCTCA
limitations were set using such a system to recover spent
concentrated acid, discharging only the wastewaters from the
absorber vent scrubber.
A significant reduction in discharge flows from this system
can be obtained by adding a recycle loop on the absorber
vent scrubbers, and treating the blowdown from this system
via aeration, lime neutralization and sedimentation. A
system such as this has not been tested; however, the key to
the system is keeping the water flows in balance. Systems
similar to this are in use in the sulfuric acid
subcategories with considerable success.
Based on the above, the BATEA limits for pickling operations
utilizing HC1 regeneration have been established for each
critical parameter as discussed below.
For those hydrochloric acid pickling operations not
practicing acid regeneration, joint treatment of spent
concentrates and rinse waters was recommended to achieve the
BPCTCA limitations. This technology is further advanced
through use of countercurrent rinsing to reduce flows from
that source to less than 209 1/kkg (50 gal./ton), which when
taken together with the wastewater flow from spent
concentrates gives a total flow to the treatment plant of
333 1/kkg (80 gal./ton of product) . Although the only plant
surveyed which was discharging flows approximately twice as
711
-------
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712
-------
4»
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713
-------
MODEL COST EFFGCT/VE/VESS O/AGRAM
SULFURIC AC/D - CONT/NUOU5-
T&EATMEMT V/A AC/D RECOVERY
519,961
513,409
ANNUAL COSTS*BASED ON TEN YEAR. CAPITAL &ECOVE&Y
V- INTEGERST GATE 7%
i-OPE/SATING COSTS /NCLVOE LA&O*, CHEMICALS ^ C/T/L/T/ES
+ OPERATING AND MAINTENANCE- COSTS BA56D
ON 3.5% OF CAPITAL COSTS
COST* BAftB.0 ON lOftft HfcG /DAY ( I7OO TONS/DAY) OF- STEEL.
TWI5 GRAPH CANNOT BE U5K) FOR INTERMEDIATE- VALUES.
* TOTAL COSTS FOR l_£YEL B1 INCLUDE CREDITS FOR
ACID RECOVERY AMD ALSO REFLECT SAVINGS DOE
TO ELIMINATION OP OFF-SITE DISPOSAL COSTS
WHICH WERE INCLUDED IN LEVEL A. COSTS S.HOWKI
FOR LEVEL B ARE 5ROSS COSTS WITH NO CREDITS
B (BPCTCA
BATEAU
IT
3
I
2,739
-DOLLARS SPENT FOR COLLECTION SYSTEM
A.ND HAULIN^ \WASTRS FOR OFF-SITE
DISPOSAL IN LEVEL A TMIS MEANS OF
DISPOSAL is ABANDONED AND REPLACED
BY A SYSTEM UTILIZING, COUNTER-CURRENT
RlNSINCj TO REDUCE RINSE WATER FLOWS
TO A VOLUME SUITABLE FOR USE AS A
MAKE-UP TO PICKUN^ TANKS. SPENT PICKLE
LIQUORS ARE REGENERATED IN AN
EVAPORATIVE RECOVERY USIVT, PRODUCING
AND
SUSPENDED SOUDS AND DISSOLVED IRON
20 4O 6O
PERCENT REMOVED
80
[A ('REFERENCE
LEVELS
/do
714
-------
large as the recommended flows, two of the other plants, one
using regeneration and the other deep well disposal, were
successfully concentrating rinse water flows to 50 gal./ton
or less. In fact, the plant using deep well disposal
methods achieves flow rates of only 3.3 gal./ton of spent
pickle liquor, plus 5.9 gal./ton of rinse water using a
cascade system, indicating how efficiently such rinse water
conservation practice may be.
Pickling-Hydrochloric Acid-Rinse Waters
One of the two plants providing more or less complete
treatment of rinse waters in this subcategory has been used
as the basis for establishing all BATEA Effluent Limitations
Guidelines. This plant provides equalization, blending,
lime addition to pH 8.0, mixing, aeration in dual chambers,
polymer addition, clarification in either of two identical
thickeners used in parallel with vacuum filtration of
underflows, and final settling in a large lagoon with
discharge of overflow to a receiving stream. An effluent of
extremely high quality results. All parameters listed below
are effectively removed using the above equipment and
treatment technology.
Cold Rolling
The degree of effluent load reductions achieved via the
treatment and control technology required to attain the
BPCTCA limitations for recirculation, combination and direct
application cold rolling operations as described in Section
IX is equivalent to the best available technology
economically achievable at this time. To achieve additional
reductions would require expenditures of capital and
operating costs out of line with the benefits derived. For
this reason, the BATEA limitations for the cold rolling
operations are identical with the BPCTCA limitations in all
cases.
Hot Coatings-Galvanizing Operations
Flow information relative to the four plants visited is
discussed in Section IX, along with the BPCTCA limitations.
Hot Coatings-Terne Operation
Since both of the terne-plating lines surveyed were
discharging wastewaters after once-through use without
treatment, but rather with control to minimize dragout,
BATEA limitations for all parameters were set at levels in
715
-------
38
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-------
FIGURE
COST
MODEL COST EFFECTIVENESS P/AG,KAM
PICKLING HYDROCHLORIC /9C//D -
CONCENTRATED 5U&CflrEGOF?y - ALTERNATE _T
COST-&ASED OH TEN Y&A& C.APITA.L
+ IN T&K.&S T «A T£- 7 %
+ OPERATING COSTS INCLUDE LA&OK, Cf-/EM/CALS $ UTILITIES
+ OPERATTINCSi ANt> tAA.\NTE.N KNCE COSTS
a .5% OF C-A^rroL. c.o«»-rs
TUX'S
/,//9,322-•
-A
TOTAL
5PSMT f=-OR.
A. 7W/S MEANS- '
DISPOSAL IS
AND REPLACED WITH
AND IRON OX/Di
WITH
I
LEVEL &,
INCLUDE t=K.£DlTS FOK,
I
tOO 75
h PERCENT ADDED
\
SO
I
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I
SO
PERCENT REMOVED
/OO
718
-------
719
-------
F/6URE /G4-2
PICKLIMG-HYDROCHLORIC ACID-RINSE SUBCATEGORY ALTERNATE /
ANNUAL COSTS = BASSO OM TBM YBAR CAP/TAl- ff£COVeBY
3/3,288
TBM YBAR
7%
+ opea AT/MS COSTS
+ OPERATING, AND MAINTENANCE COSTS BASED ON 3.5%
OF CAPITAL COSTS
COST BASED OH Z7ZI KKG/DW(3OOOTOHSI DAY) OF STEEL PICKLED
THIS GRAPH CAN NO T BE USED FOR INTERMEDIATE VALUES
/OO
PEI3CEMT ADOSD
720
-------
effluents from systems similar to those used in the Hot
Coatings - Galvanizing subcategory.
Miscellaneous Runoffs-Storage Piles
Coal, Stone and Ore
These three miscellaneous runoffs were discussed in general
terms in Section IX, but no BPCTCA limitations were
specified, indicating instead that such limitations will be
deferred until such time as BATEA limits apply. The best
available technology economically achievable is considered
to be perimeter collection, storage, chemical flocculation,
neutralization and sedimentation. The use of impervious
liners or other means to preclude subsurface drainage has
not been included in the BATEA technology due to the absence
of demonstrated cost effectiveness.
Concentration limits on specific pollutants present in the
wastewater which are due to leaching from the stockpile must
be set on an individual basis wherever appropriate.
The .stockpile size and surface area is calculated from the
raw material usage, storage capacity, bulk density, and
stockpile height parameters. The rainfall value chosen
represents the greatest mean maximum 2U hour rainfall
generally experienced in the western, north central, and
northeastern part of the United States. (Source: The 1970
National Atlas of the United States.) The runoff
coefficient of 0.90 was assumed since the proposed
subsurface and surface runoff collection systems should
collect all rainfall except that accounted for by
evaporation.
It should be particularly obvious that the system costs
based upon the above set of criteria and assumptions
represent only one specific case of the probable cost of
such a system. A great variety of alternatives in size and
cost exist for this basic treatment concept and must be
determined and applied on a site-by-site basis. The
particular system described above, although not rigorous for
all applications, does provide a reasonable cost estimate
for the particular set of criteria and assumptions used.
The basic concept of collection and storage is justifiable
in every application. Even though logistics and economics
may preclude the application of provisions for impervious
sealing of the stockpile base for existing piles, there
should generally be no restriction to prevent perimeter
collection of a large part of the runoff. Once collected.
721
-------
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722
-------
723
-------
F/GURE ICoS-2.
MODEL COST EFFECT/VENESS DIAGRAM
P/CKLING - HYD&OCHLOR 1C AC/D-
CONCENTRATED/WDRINSE- £UBCATEGOGY-ALTERNATE!!
ANNUAL COST -BASED ON T&N VEAE CAPITAL. QeCOVEEV
+ j/vreffe-ST RATS T7.
+ OPERATING COST INCLUDE LABOR,CHEMICAL* * UT/L/r/C-5
i- OPERATING AND MA/MTBNANCE COSTS B45E-O
O/V/v3.57. OP- C4P3/TAL. COSTS
COSTS BASED ON 2.7Z KKG/&AV C3OOO 7-QM5/OAY)
OF 5TE£L ^/CKLED
THIS GRAPH CANNOT SE USED r<3& //VTE/SMED/ATE VALUES
_l_ X?
SPENT PICKLE LIQUOf? A(OD RINSE WATER TREATMENT COSTS ^BA5£
INCLUDES DOLUfcBS •JENIT FOe COtLeCTlOKJ SY^TfeM A^>5P HAULIVJ&
OF
l"5 ^BAWOMfcCJ AMD CtPLACtO BY KJ&UTEAUWTIOW 5Y5TEM
Bfr(JIKJIs)|ioG \yfrM LfeVEL eTMUS ELIMINATING '(,044,000 OF LEVEL A COSTS
_ . ft (COSTS
CARRt
FORWARD)
PERCENT ADDED
I
o 50 /oo
•(* PERCENT REMOVED
724
-------
at least minimal treatment for suspended solids and pH
should be applied under BATEA wherever site or area specific
pollutants appear in excessive concentrations in the runoff.
The treatment of these specific pollutants where they are
identical to critical parameters identified in this study,
should follow the treatment and control technology and
effluent guidelines established for these parameters in
other subcategories. In other cases, treatment and control
technology and limits will have to be formulated and applied
on a case-by-case basis.
Since it is not possible to present a uniform set of
parameters on which to design, size, and cost these systems,
some discussion of the variables involved and their impact
on the completed system is in order. They can be described
as follows:
Stockpile Surface Area. This, of course, depends heavily
upon the capacity of the ironmaking facility, its production
rate, the number of days stockpiled inventory, the height of
the pile, and the amount of sinter charge employed.
Although coal is converted to coke before charging to the
blast furnace, the coal supply will generally keep pace with
blast furnace production since coke produced is generally
used immediately in the blast furnace.
Rainfall. Rainfall intensity, frequency, and duration can
vary significantly from area to area in this country. In
certain areas, the use of mean maximum 24 hour rainfall to
estimate the load on the system may be sufficient. However,
in other areas, the use of figures for the 2 year, 5 year,
10 year, etc., 24 hour storms may be more appropriate. In
other areas, where definite wet seasons occur, the system
design may have to be based upon maximum consecutive days of
rainfall in the area. Each case will depend on weather
conditions specific to the area and will have to be
determined on that basis.
Runoff Coefficients. Again, case-by-case estimates may be
needed. Runoff coefficients are generally average numbers
reflecting runoff throughout the storm cycle. During the
peak of an intensive, long duration rainfall, the
coefficient may approach 100%. However, during brief rains,
at the start of rainfall, and after rainfall has ended,
these coefficients may be considerably lower. The
coefficient in all cases will require conservative
estimation to avoid underdesign of the system.
Treatment Alternatives. As mentioned previously, the basic
treatment system for will require sedimentation and pH
725
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1
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adjustment, with more specific treatment processes employed
under BATEA where additional constituents appear. However,
this does not preclude the possibility of using treatment
facilities associated with other subcategory facilities in
the mill. With the right combination of rainfall load and
storage capacity, flow may be effectively metered to allow
such a possibility.
In addition, in some areas of the country where evaporation
exceeds rainfall, it may be possible to collect and store
the runoff during wet periods, and later spray evaporate
runoff during dry periods and thus achieve zero discharge.
Another factor that may affect the size of treatment
facilities will be land area available for storage of
runoff. Where land is at a premium, pond area will have to
be minimized and treatment capacity maximized. Where land
availability is not restrictive, the opposite may be true.
The 2.5 inch 24 hour rainfall used as the basis for runoff
collection and treatment facilities for storage piles is
based upon mean annual maximum 24 hours rainfall data in the
USGS National Atlas, This data map indicates that the vast
majority of steel industry production is centered in areas
of the country having a mean annual maximum 24 hour rainfall
equal to 2.5 inches or less.
Although it is realized that maximum rainfall data is highly
site specific, and in many cases should be based upon 10,
25, etc. years storms, no other source of data was available
that could provide a general estimate covering most of the
areas of the country where steel production is located.
Specialty Steel Pickling and Coating Operations
It has been determined on the basis of a review of the
available technology, the engineering aspects of the
application of various control techniques, energy
requirements, and the costs of application in relation to
the effluent reduction benefits to be achieved that the
BATEA limitations for the specialty steel pickling, cleaning
and coating subcategories should be the same as the same as
the BPCTCA limitations:
Cons ideration of Process! Changes
No process changes are envisioned for implementation of this
technology for plants in any subcategory. The treatment
technologies to achieve BATEA assess the availability of in-
729
-------
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731
-------
FIGURE
MOD&L COST tFFfcCTlVEKJfcSS
COLD eOLLIUG-COMBIVJATlOM
AKJKJUA.L CO«5TS » BAStD OU TEKJ Yfc\e CAPITAL
+ IMT6B65T RATE: T/u
•»• OPEPATlUG COST^ WCLUDE L*vt>OR>
* OPERATIKIG ^MAlMTEWAKJC-E. COSTS BASED OK) 3,5%
CAPITAU COSTS
COSTS BASED OW »3
-------
process controls as well as control or additional treatment
techniques employed at the end of a production process.
Consideration of Costs of Achieving the Effluent Reduction
Resulting from the Application of BATEA Technology
The costs of implementing the BATEA limitations relative to
the benefits to be derived is pertinent, but is expected to
be higher per unit reduction in waste load achieved as
higher guality effluents are produced. The overall impact
of capital and operating costs relative to the value of the
products produced and gross revenues generated was
considered in establishing the BATEA limitations.
The technology evaluation, treatment facility, costing, and
calculation of overall capital and operating costs to the
industry as described in Section IX and which provided the
basis for the development of the BPCTCA limitations was also
used to provide the basis for determining the BATEA
limitations, the costs, and the acceptability of those
costs.
The initial capital investment and total annual expenditures
required of the industry to achieve BATEA limitations are
summarized in Table 197.
After the treatment technology to be designated as one means
to achieve the BATEA limitations for each subcategory was
selected, a sketch of each treatment model was prepared.
The sketch for each subcategory is presented following the
tables presenting the BATEA limitations for the subcategory.
Cost Versus Effluent Reduction Benefits
Estimated total costs on a dollars per ton basis have been
included for each sufccategory as a whole. These costs have
been based on the wastewaters emanating from a typical
average size production facility for each of the
subcategories investigated. In arriving at these effluent
limitations guidelines, due consideration was given to
keeping the costs of implementing the new technology to a
minimum. Specifically, the effluent limitations guidelines
were kept at values which would not result in excessive
capital or operating costs to the industry. The capital and
annual operating costs that would be required of the
industry to achieve BATEA was determined by a six-step
process for each of the subcategories. It was first
determined what treatment processes were already in place
and currently being utilized by most of the plants.
Secondly, a hypothetical treatment system was envisioned
733
-------
>S e
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734
-------
735
-------
MODEL CO«5T fcFFtCTlVfcKJfc^*, DIAGRAM
COLD EOLLIKX5-DIBECT APPLICAJIOK)
AUUU/U- COSTS • fcASfcO OU Tfc»0
•t- IkJTfcBfc'ST BATE
+ OP6BATIIOG
dOSTS
CAPITAL
IWCLUDfc
* UT\HTIES
OF
RO t5OCT\ON
e>
(BPCTCAi
Av
CKEf/TRENCE
LEVEL)
IOO
736
-------
which, as an add-on to existing facilities would treat the
effluent sufficiently to meet BATEA ELGs. Thirdly, the
average plant size was determined by dividing the total
industry production by the number of operation facilities.
Fourth, a quasi-detailed engineering estimate was prepared
on the cost of the components and the total capital cost of
the add-on facilities for the average plant. Fifth, the
annual operating, maintenance, capital recovery (basis 10
years straight line depreciation) and capital use (basis 1%
interest) charges were determined. And sixth, the costs
developed for the average facility were multiplied by the
total number of facilities to arrive at the total capital
and annual costs to the industry for each subcategory. The
results are summarized in Table 197 which also shows total
costs for the specialty steel segment.
Mahoning Valley
For steel plants wihtin the Mahoning Valley which apply for
a Section 310(c) exemption, the modified limitations shall
not be less stringent than the industry-wide BPCTCA
limitations for the following subcategories:
Cold Rolling
Hot Coating - Galvanizing
Hot Coating - Terne
Miscellaneous Runoffs - Storage Piles, Casting and •
Slagging
Combination Acid Pickling
Seale Remova1
Wire Pickling and Coating
Continuous Alkaline Cleaning
For steel plants within the Mahoning Valley which apply for
a Section 301(c) exemption, the modified limitations shall
not be less stringent than those set forth below.
Hot Forming-Primary-Mahoning Valley:
Effluent Effluent
Characteri st ic Limitations
Maximum for Average of daily
any one day values for thirty
consecutive days
shall not exceed
(Metric units) kg/kkg of product
(English units) lb/1000 Ib of product
737
-------
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738
-------
739
-------
MODEL COST EFFECTIVENESS
HOT COATING - GALVANIZING-5UBCATEGORY
ANNUAL COSTS = BASED ON TEN YEAR CAP/TAL RECOVERY
+ INTEREST RATE 7%
i-OPERATING COSTS INCLUDE LABOR,CUEMICAL5 f'UTILITIES
^OPERATING AND MAINTENANCE COSTS BASED OA/3.5%
OF CAPITAL COSTS
COSTS BASED ON 635MG/DAY(7OOTONS/DAY) HOT COATING OPERATION
THIS GRAPH CANNOT BE USED FOR INTERMEDIATE VALUES
VI
8
NO INCREASED COST'S.
ARE A
OF SETTS'R.
A
(REFERENCE
LEVEL}
o
I I I I I
PERCENT REMOVED
/OO
740
-------
Oil and Grease
TSS
PH
0.5391 0.1797
0.8238 0.2746
Within the range 6.0 to 9.0.
Hot Forming Section-Mahoning Valley:
Effluent
Characteristic
Maximum for
any one day
Effluent
Limitations
Average of daily
values for thirty
consecutive days
shall not exceed
(Metric units)
(English units)
Oil and Grease
TSS
PH
kg/kkg of product
lb/1000 Ib of product
0.7062 0.235U
2.2560 0.7520
Within the range 6.0 to 9.0.
Hot Forming-Flat-Sheet & Strip-Mahoning Valley:
Effluent
Characteristic
Maximum for
any one day
Effluent
Limitations
Average of daily
values for thirty
consecutive days
shall not exceed
(Metric units)
(English units)
Oil and Grease
TSS
PH
kg/kkg of product
lb/1000 Ib of product
0.7758 0.2856
1.7661 0.5887
Within the range 6.0 to 9.0.
Pipe and Tube-Ma honing Valley:
Effluent
Characteristic
Maximum for
any one day
Effluent
Limitations
Average of daily
values for thirty
consecutive days
shall not exceed
741
-------
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