-------
Final Report
February 2000
Page 162
V. CAUSES OF NONCOMPLIANCE
The following summary of causes related to compliance problems is based on
whatever documentation was available in the files. In general, this information is
incomplete and reflects the fact that documentation of the reasons for violations is not
required for the agency to proceed with an enforcement response under the statutes and
regulations included in this study. Cause information is almost always incomplete for
hazardous waste violations and frequently incomplete for air program violations. Only
the surface water program files contained substantial documentation of the reasons for
violations, primarily because reporting regulations require that causes of violations be
reported, and most surface water violations are self-reported. Because of this overall
lack of information on causes, statistically valid, definitive conclusions as to why the
iron and steel industry frequently is not in compliance with certain environmental
requirements could not be drawn. 'However, supplementary interviews with inspectors
were conducted to gather anecdotal information on the underlying causes of
noncompliance.
To facilitate the presentation of cause explanations in a cohesive and readable
format, categories were established based on the types of reasons and the level of detail
provided in the files. A best effort was devoted to an objective categorization of these
reasons based on the information provided. However, there is potential overlap in
selected categories, and in a small number of cases, there may be some latitude for
interpreting the cause explanations differently. These issues are discussed briefly in
introductory sections to each program area.
In response to comments on a previous draft of this report, the categories used
to identify causes of compliance problems have been simplified and standardized across
all three media. The following categories are noted:
Equipment Failure. This category is used when a violation is caused by an
equipment malfunction. The equipment may be pollution control or process
related. The reasons for equipment failure may vary from unpredictable weather
events to design inadequacies, or they may be unexplained. Further explanation
of these failures, if available, usually is provided in the text of this report. If the
reason for equipment failure is clearly attributable to faulty operation or
maintenance, the cause is listed as O&M/Work Practice instead.
O&M/Work Practice. This category is used when a violation is clearly
attributable to faulty operation, maintenance or work practices. In cases when
the violated regulation is an O&M or Work Practice regulation, this is the
assumed cause.
Permit/Regulation Interpretation. In some instances the violation is a result of an
improper or disputed interpretation of permit or regulation conditions. These
violations are included in the report even if they are being challenged by the steel
mill. On several occasions we were able to determine that a challenge had been
successful, and the violations were removed.
Process Related. This category is used for a small number of violations where
the cause was a natural outgrowth of processes at the steel mill and not related
-------
Final Report
February 2000
Page 162
V. CAUSES OF NONCOMPLIANCE
The following summary of causes related to compliance problems is based on
whatever documentation was available in the files. In general, this information is
incomplete and reflects the fact that documentation of the reasons for violations is not
required for the agency to proceed with an enforcement response under the statutes and
regulations included in this study. Cause information is almost always incomplete for
hazardous waste violations and frequently incomplete for air program violations. Only
the surface water program files contained substantial documentation of the reasons for
violations, primarily because reporting regulations require that causes of violations be
reported, and most surface water violations are self-reported. Because of this overall
lack of information on causes, statistically valid, definitive conclusions as to why the
iron and steel industry frequently is not in compliance with certain environmental
requirements could not be drawn. However, supplementary interviews with inspectors
were conducted to gather anecdotal information on the underlying causes of
noncompliance.
To facilitate the presentation of cause explanations in a cohesive and readable
format, categories were established based on the types of reasons and the level of detail
provided in the files. A best effort was devoted to an objective categorization of these
reasons based on the information provided. However, there is potential overlap in
selected categories, and in a small number of cases, there may be some latitude for
interpreting the cause explanations differently. These issues are discussed briefly in
introductory sections to each program area.
In response to comments on a previous draft of this report, the categories used
to identify causes of compliance problems have been simplified and standardized across
all three media. The following categories are noted:
Equipment Failure. This category is used when a violation is caused by an
equipment malfunction. The equipment may be pollution control or process
related. The reasons for equipment failure may vary from unpredictable weather
events to design inadequacies, or they may be unexplained. Further explanation
of these failures, if available, usually is provided in the text of this report. If the
reason for equipment failure is clearly attributable to faulty operation or
maintenance, the cause is listed as O&M/Work Practice instead.
O&M/Work Practice. This category is used when a violation is clearly
attributable to faulty operation, maintenance or work practices. In cases when
the violated regulation is an O&M or Work Practice regulation, this is the
assumed cause.
Permit/Regulation[Interpretation. In some instances the violation is a result of an
improper or disputed interpretation of permit or regulation conditions. These
violations are included in the report even if they are being challenged by the steel
mill. On several occasions we were able to determine that.a challenge had been
successful, and the violations were removed.
Process Related. This category is used for a small number of violations where
the cause was a natural outgrowth of processes at the steel mill and not related
-------
Final Report
February 2000
Page 163
to poor O&M or equipment failures. Some examples of process-related causes
might include opacity at the secondary steelmaking (ladle} due to carbon
additions, excess opacity during normal slag flow conditions at a blast furnace,
water quality problems in the blast furnace recycle system due to unusual flow of
noncontact cooling water from the blast furnace, or inadequate treatment at a
central treatment plant not resulting from any equipment malfunction or work
practice inadequacy (central treatment plants are categorized as a water program
related steel mill process for the purpose of this study).
1 Unknown/Not Indicated. Most inspection reports (for all three programs) did not
indicate a cause for observed violations, and it is not known whether the
inspector may have known or suspected the cause. Also, many self-monitoring
and spill noncompliance reports (primarily occurring under the water program)
indicated that the cause of a violation could not be determined. We have
combined these two categories in this report.
Aside from these general cause categories, there are undoubtedly more basic,
underlying causes that might be considered. For example, differences in regulation
stringency, operating practices and even the types and age of equipment operating at
different mills account for variation in the frequency of violations at the different mills.
Specifically, underlying reasons for violations or concerns might include equipment
failures that are unforeseeable and unavoidable despite the reasonable monitoring and
control practices of industry staff (for example, as the result of a power loss caused by
lightning), marginal or inadequate control technology, old manufacturing equipment
needing repair or replacement, deficient O&M procedures, and resource constraints.
Violation patterns are also influenced in some instances by the relative stringency of site
specific regulations. Often these underlying causes are not documented in agency files
for specific violations or concerns. However, they are generally recognized by
experienced agency and industry staff.
A. Air Pollution Program
(1) Introduction
Documentation of causes existed for roughly 43% of the reported air program
violations and concerns. In many cases, a determination of the actual cause was not
required and frequently not possible. For example, roof monitor emissions during
steelmaking operations are caused by a variety of events that occur continually as a
normal part of the process, and documentation of these events is usually not required.
As a result, it is frequently not possible for agency staff to identify a specific event that
caused a roof monitor opacity violation.
The following discussion of compliance problem causes focuses on the
steelmaking processes experiencing the most air quality compliance problems: coke
ovens, blast furnaces, basic oxygen furnaces, and electric arc furnaces. The discussion
of each cause reflects additional information provided by agency inspectors. Where
causes have been documented they are summarized in an accompanying table.
-------
Final Report
February 2000
Page 164
(2) Coke Ovens
A coke oven battery is a structural operating system comprised of doors, pushing
machines, door machines, larry cars, coke cars, pushing emission control (PEC) systems
and operators. Oven elements require routine, repeated, and, at times, nearly constant
maintenance and adjustment if the battery is to perform properly. Operators must be
familiar with equipment and work practice standards with respect to their area of
responsibility if the battery is to operate in compliance with air quality opacity standards.
To permit the escape of volatile matter driven from the coal during coking, an
opening is provided at the top of the oven at either one or both ends of the coking
chamber. Each opening is fitted with an offtake pipe, which connects the oven with the
gas-collecting main for the battery. The gas passing from the offtakes to the collecting
main is shock-cooled with a flushing-liquor spray which causes tar to precipitate and
cools the gas to the desired temperature. At mills with by-product coke oven batteries,
specific compounds are recovered from the coke oven gas in a series of operations. At
one mill, recovered coke oven gas with a high sulfur content was used as fuel for a large
number of boilers, furnaces, and other fuel burning processes throughout the mill. This
resulted in a very high number of SO2 related violations for an extended period during
the study.
Excessive leveling of the charged coal tends to pack the coal at the top of the
charge, particularly under the charging holes, and may cause localized erosion of the
oven wall. Coke oven walls must be gas-tight to prevent gases or fine particles from
passing between the coking chambers and heating flues; fine particles may exit the
coking chambers and the battery .via the underfire stack if there are cracks — in some
cases, this may lead to opacity violations. To prevent escape of gases from the oven
during charging in most plants, a steam-jet aspirator is used to draw gases from the
space above the charged coal into the collecting main; this practice is called "charging
on the main."
There are alternative systems for controlling pushing emissions: coke-side sheds,
bench-mounted hoods (traveling hoods), enclosed quench cars with mobile scrubbing,
and wet spray pushing emission control systems. In contrast to bench-mounted hoods
and water-spray systems, both enclosed cars and sheds have demonstrated effective
capture of pushing emissions. Both enclosed cars and sheds are judged better for
capture of pushing emissions than the other control systems.
Training and proper operation have a considerable effect on oven performance,
coke quality, and emissions. A reference text explains that faulty heating, departing
from optimal setpoints, affects not only the quality and quantity of the coke and coal
chemicals produced, but also the ultimate life of the ovens. The text explains that the
most serious damage to coke ovens is caused by fluxing or slagging of exposed brick
surfaces due to local overheating beyond the critical temperature of the brick. Oven
heating is operator dependent to a degree. Important operation and maintenance tasks
include door and jamb cleaning prior to charging to insure proper seals during coking,
luting (sealing) lids to ensure gas-tight seals after charging, and repair of damaged
equipment, particularly doors and jambs.
-------
Final Report
February 2000
Page 165
Process-related constraints associated with coke oven batteries and cokemaking
are often very difficult to overcome. The operating pressure in a battery is selected to
be optimal, but this point may not correlate closely to the ideal pressure of individual
ovens at different stages in the coking cycle since at many batteries the system allows
operators to control pressure in the collector main but not the pressure in individual
ovens. If the pressure in the main does not permit the pressure in an early-stage oven to
decrease sufficiently, doors, lids and offtakes may leak.
All batteries operate at slightly positive pressure to prevent air from entering the
ovens. This in itself means door, lid and offtake seals must be gas-tight or the ovens
will leak. The seal and alignment between the larry car and the oven during charging is
important. Drop sleeves must come in close contact with the oven to prevent visible
emissions during charging and there is a limit to the speed at which coal can be
delivered through the lids of the oven. If charged too quickly, the likelihood of visible
emissions during charging increases.
During pushing, partially coked coal may lead to visible emissions. If the coal
charge is unevenly distributed (Le., if heating is uneven), if there is a problem with one
or more heating flues, or if the coal touching either door is incompletely coked, then the
uncoked coal or volatile compounds not completely driven from the coal may react
visibly with air as the coke falls into the coke car. All PEC systems require maintenance
with time to restore performance or to restore tolerances which will ensure proper
operation of system components. Many systems operate nearly continuously in a
physically extreme environment.
Cracks in the brickwork between the heating flues and the ovens provide a
means for particles of coal to reach the heating flues, then travel with flue gases to the
underfire stack where they exit as visible particles (opacity). The number of heating
flues in a single battery may exceed 2,000. Carbon deposition inside ovens helps to
seal these cracks and mills leave a layer of beneficial carbon on the walls of ovens when
cleaning the ovens.
Offtakes and lids must be inspected, cleaned and properly sealed to limit visible
emissions. Water seals for offtakes provide a flexible seal and are an improvement in
comparison with other methods for sealing offtakes. After an oven is charged, the
lidman lutes lids to seal them during coking. At times, the lidman will have to reapply
the luting material or the lids will leak.
Oven heights range from 3 meters to 6.5 meters. The difference is critical since
door seals must be maintained over a greater length (perimeter) on taller doors. A
relatively greater area must be cleaned and relatively longer edges .adjusted to close
tolerance on taller doors. Although it is reasonable to expect a 6.5 meter battery to
have more problems, and perhaps more violations, one mill which operates a 6.5 meter
battery has a program for repairing and closely monitoring door performance which has
led to a dramatic improvement in performance. Personnel are assigned (dedicated) to
this program and given responsibility for the performance and repair of doors; since
responsibility is not divided among several departments, management or institutional-
related obstacles have been reduced or eliminated. Several years ago, the worst
performing doors were repaired, then returned to service and monitored. Overall
performance improved quickly. An inspector related there was a time when as many as
-------
Final Report
February 2000
Page 166
30 doors would have visible emissions but that at present, perhaps only one door will
have visible emissions during an inspection.
The following table (Table 14A) summarizes the causes of violations documented
by the air program for coke ovens.
-------
5*V
g-cr£
(T § r-
5 -0 O)
.=
c
at
Quenching
"5
>
CO
CM
CO
CM
CO
CM
CO
CO
CM
CO
oo
CN
CD
CD
00
CN
CM
CO
IX
CO
scel
.s
4)
-------
Final Report
February 2000
Page 168
{3} Blast Furnaces
Flux, iron ore and coke are charged into refractory-lined blast furnaces to produce molten
iron. These materials combine and react in the furnace in the presence of a heated airstream
introduced near the base of the furnace to form slag and molten iron. The blast furnace operate:
continuously and is tapped periodically. A hole is drilled through the material sealing the taphole
to allow the molten iron to spill into a trough and flow through a series of runners to a transfer
station where it is poured into cars for transfer to the refining process. Slag, which is lighter
than the molten iron and contains impurities, begins to flow from the furnace toward the end of <
cast. As the slag is skimmed from the iron, it travels through a series of runners to pits where it
may be quenched. The blast furnace rises above shelters designed to enclose the casting
operation (casthouse). As a consequence, the blast furnace process category also includes iron
runners, slag runners, skimmers, a tilting spout or torpedo/pugh car station, kish and slag pot
cooling/wetting stations, slag pot desulfurization, slag pits, and casthouse roof monitors, in
addition to the blast furnace and blast furnace stoves.
Visible emissions occur primarily at times when hoods (if present) are withdrawn to allow
the drill to tap a furnace and at the end of a cast when tight-fitting hoods are again withdrawn.
Visible emissions may also occur from uncovered sections of iron or slag runners and at the iron
spout. Open sections may be controlled by steam suppression or gas lances which prevent air
from contacting the molten iron. If there is not a system to collect emissions which reach the
roof of the cast house during tapping, visible emissions will leave through the roof monitors.
Some mills employ roof evacuation systems, while others do not.
During drilling and at the beginning of a cast, opacity is somewhat dependent upon the
length of time the hood is withdrawn. At the end of a cast, visible emissions depend upon the
condition of the refractory at the face of the taphole; if this refractory is damaged, clays used to
seal the taphole may adhere less readily to the uneven face. It may take longer to seal the
taphole, and day sealing material may drop to the runner and contact hot iron still in the runner;
this may lead to visible emissions.
During casting at some mills, when the hood is in place, emissions are collected and
directed to a control device; these systems generally perform well. A system of runner covers
that suppress emissions by limiting the number of open sections on the iron and slag runners, hel
control emissions, but typically cannot perform as well as an active paniculate collection and
control system. Some mills employ systems for capturing and controlling iron and slag runner am
tilting spout emissions during casting.
One mill that voluntarily constructed a system to collect emissions from the iron spouts at
two blast furnaces and send them to a single baghouse had no violations during a five year
period. In another instance, a mill that was required to install controls as part of an EPA Consent
Decree was able to meet a 15% rolling 6-minute average casthouse opacity limit for 99.4% of
1169 rolling 6-minute average periods. The visible emission observations were performed on a
random basis during three consecutive daylight casts each calendar month in 1995.
Most blast furnace air quality violations documented in the study are opacity violations (4'
of 49), but documents often do not explain the reason violations occur. Faulty work practices
were listed as the cause for 7 violations; process related causes were responsible for 8 violations
and equipment failure was responsible for 3 violations. Examples of process related causes
include: excess opacity during normal slag flow conditions; excess opacity related to unusual
chemistry in the iron; and a failed cast due to "poor shutin." There were no reporting,
recordkeeping, permit-related, or monitoring violations.
-------
Final Report
February 2000
Page 169
A series of opacity violations at one mill related to "beach iron dumping." This is the
practice of pouring liquid iron on the ground when the iron is out of specification, cold, or there
are production delays at other plant facilities. At this mill, an indoor beaching facility was placed
in service. At first, the building was completely enclosed, but heat from the operation warped
portions of the structure. The mill removed panels along a wall and placed louvers in the building
roof which compromised the effectiveness of enclosing the process.
The following table (Table 14b) summarizes the causes of violations documented by the air
program for blast furnaces.
U.S. EPA Headquarters Library
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
-------
o
o
«- o
- §0
5 -Q TO
-.£ ,9 ro
u. u. CL
GO
<*
f"
Ul
CQ
0)
0)
u
10
10
J2
CQ
»
"35
"5
o
w
J
_o>
o
&.
0>
u
.S
"5.
o
o
>
^
iSsSSgrl'Sfe!!;®
'•••'IS'^?'- i !i^'"r-."!.-
i;l»!;^:ff
•ifr
f:"H
m?i
STiSS
4^¥
?*:s*
i-^",SS S-s
ii£f
;'g6ss
.•tS,";,.;-;
h«.*i?re«;jw t"»'i;*.:
5l;Sir
i^Jii
&&,*&*&
lijl
iliili
Sill
CD
•*
00
00
CO
CN
8
i
o
o
o
-------
Final Report
February 2000
Page 171
(4) Basic Oxygen Furnaces
This process utilizes refractory-lined vessels to convert molten iron and scrap into
steel. Scrap and molten iron are charged to the basic oxygen vessel, flux is added, and
oxygen is injected to drive the steelmaking process. Alloys may be added to the molten
steel in the vessel or added later. Other processes in the EOF shop (ladle treatment, for
example) are included in this description if agency documents describe a BOF shop
incident without identifying the source. As a result, BOF vessels may not be responsible
for all BOF incidents in this report (especially opacity violations). These related sources
may precede or follow the basic oxygen process and are often located in the BOF shop.
There are two principal sources of emissions in a BOF shop. The first is the
basic oxygen vessel which evolves dense emissions at different times during a refining
cycle which may last from 30 to 50 minutes. The second source comprises a variety of
operations (reladling, ladle metallurgy, slag skimming, charging, tapping, and
maintenance operations, for example) with their associated "secondary" emissions.
Typical BOF emissions include carbon monoxide and particles, or fumes,
consisting of metallic oxides and particles of slag. These emissions may occur during
the transfer of molten metal to and from the basic oxygen vessel or to other processes
within the BOF shop enclosure. The emissions from these processes may lead to
opacity violations at the roof monitor.
While opacity limits apply separately to many shop processes or to the controls
for these processes, the majority of BOF violations are roof monitor opacity violations
and are not linked to specific processes. Visible emissions occur primarily when the
refining vessel (EOF) is tilted away from the primary collection hood during charging and
at other times when the vessel is tilted. For example, if a mill processes scrap, the
vessel is tilted to allow charging of cold scrap. Hot metal (iron from the blast furnace) is
then poured over the scrap. Oil or other material in the scrap may flash off and escape
when it comes in contact with the iron. During turndown for sampling and alloy
addition, the vessel is again tilted and emissions may evade collection. Since the vessel
is tilted upright during oxygen refining, a period when oxygen is injected at supersonic
velocity, the primary control system located above the vessel is generally effective.
Although the causes of a majority of air quality violations are either unknown or
not indicated, agency representatives agree that violations can be reduced substantially
with the use of secondary control systems which capture and direct fugitive process
emissions escaping primary controls to a secondary control device. This was also
indicated in the compliance data at one mill with two BOF-shops, one with secondary
controls, and the other without. Although there were roof violations at both BOF shops,
there were roughly four times the number of violations at the shop without secondary
controls.
The design and construction of vessel hoods influence pollutant concentration,
particle size, and gas temperature which, in turn, affect control selection and design.
Closed hood vessels suppress full combustion (resulting in CO emissions) while open
hood vessels allow air to mix with the process airstream and burn CO to CO2. Wet
scrubbers are typically used to control particulates from closed hoods since electrostatic
precipitators (ESPs) present a risk of explosion if used with closed hoods. A wet
-------
Final Report
February 2000
Page 172
scrubber or ESP is used for particulate control of open hood vessels. There are several
advantages to closed hood systems, including increased control, thermal, and energy
efficiencies which relate to the smaller, cooler volume air stream and larger particle size
characteristic of closed hood vessel operation.
Furnace enclosures are an approach for controlling hot metal charging or other
"secondary" furnace emissions and "total" enclosures are capable of controlling other
furnace emissions, such as puffing, turndown, and skimming. Local hoods may be used
to control sources scattered throughout the shop but present design problems relating to
cross-drafts in the building and crane operations.
There are advantages and disadvantages to whole building evacuation systems
for the control of secondary shop emissions. Agencies may recommend or require
whole building evacuation if violations persist. If required to install such a system, a mill
is required to underwrite the expense of such a system and to find a way to enclose the
building while providing access to the shop and while meeting safety or operational
limits relating to visibility, heat, and exposure inside the shop.
Whereas high-performance wet scrubber and ESPs have traditionally been used
for primary furnace emissions, baghouses are typically used for secondary furnace
emissions. Secondary emissions may also be collected through the primary gas cleaning
system if total building enclosure is involved.
In this study, control equipment failure was the predominant cause of air quality
violations (49), followed by poor O&M (15), then process related problems (9). Again,
the underlying cause of the great majority of violations was either unknown or not
indicated (198).
The following table (Table 14C) summarizes the causes of violations documented
by the air program for basic oxygen furnaces.
-------
o
o
*- o
DC § r-
111
U- "- Q.
0)
0)
U
10
c
0)
X
o
o
"5
(D
CQ
• *
.2
"53
U
QQ
<
a i
(0
U
2
S
Q.
rt.'r
.
ii
m
ltifS7*5ifsSII»
eVSiB
SSKSiJWi:
.^.'-•^.^ :•!•«•».;
CO
tN
00
*
in
O)
CO
en
-------
Final Report
February 2000
Page 174
(5) Electric Arc Furnaces
EAFs are refractory lined vessels which melt and refine scrap or direct reduced
iron (DR!) using electric current and carbon electrodes which strike an arc in the furnace.
A roof swings away and a crane drops cold or preheated scrap in the bottom of the
furnace. Molten iron may also be charged to an EAF. The roof swings back into
position, electrodes are positioned above the charge, and immense current is applied.
Typically, at least three oxy-fuel burners are turned on during the first 5 to 10 minutes
of the heat in order to accelerate melting. Oxygen lances are used to make the scrap
collapse into the melt. Slag is poured from the bath and the furnace is tapped when
established goals for temperature and composition are reached. Alloys are added
directly to the furnace or to the tapping ladle, if needed. Although there are periods
during a melt cycle that are characteristically more emissive than others, documents
citing violations seldom establish a link between violations and a particular period of the
melt cycle.
Emissions are heaviest during charging, melting, and tapping. The process of
melting and refining scrap to produce liquid steel begins when the furnace roof swings
open. A crane drops a cold metal charge into the furnace and large volumes of hot
fume-laden air rise into the melt-shop roof trusses. The capacity of the EAF shop
control system needs to be designed either to collect this volume or to spill the volume
into an area scavenged by additional, smaller hoods. During melting, emissions consist
of volatilized metals and iron oxide. EAF steelmaking processes add alloying elements to
the ladle while tapping, which can increase emissions.
Air pollution control measures include direct evacuation of the furnace during
melting (through a "fourth" hole in the furnace roof). Secondary emission control
systems control charging and tapping emissions. Charging and tapping emissions are
generally captured by canopy hoods in the melt-shop roof trusses. Tapping emissions
are sometimes captured by low level tapping hoods if the ladle is not crane-held.
Canopy hood shapes and hood exhaust flow rates are determined by experience and
from plume rise formulas modified for obstructions such as cranes. Some EAFs are
equipped with enclosures that have movable doors to permit scrap bucket access,
tapping ladle access if necessary, access to the slag door, and access for maintenance.
However, many carbon steel producing furnaces are now too fast for this emission
capture concept to be practical. Most EAFs have fabric filters for fume cleaning and
collection.
This is the only section of the air program noncompliance cause analysis that
centers on compliance incidents at a process operating at integrated mills and at mini
mills. While all mini mills operate EAFs, in a few instances integrated mills do also. EAF
violations documented during the study include 19 at one integrated mill (all were roof
monitor opacity violations with no cause identified), and 40 at six mini mills.
There were 34 opacity violations in all (27 occurred at two mills -- 19 at one
integrated mill and 8 at one of the mini mills). In addition, there were 8 fugitive emission
violations, 7 O&M violations, and 4 mass emission violations relating to EAFs (all at mini
mills}. There were also 6 monitoring violations. The underlying cause of these violations
was indicated for only nine of the violations. These included 2 violations related to
equipment failures, 5 violations caused by faulty work practices, and two process
related violations.
The following table (Table 14D) summarizes the causes of violations documented
by the air program for electric arc furnaces.
-------
8
a > [^
CC | *-
— i-
"5
UJ
— '
OQ
_«
I
Q.
0)
U
Q.
O
o
iftfisfsm
llpfllf
£%:fa*S5'S
'^ -
JiiM
liittiHir^—^
•^i? ™ ^.r^s; ssa e-
4esiFio
-^'ift
.»-*o':~^;/?:<
^5^si!
in
tN
E
5
-------
Final Report
February 2000
Page 176
B. Surface Water Program
(1) introduction
Under the NPDES program, causes are provided for most reportsble effluent
violations, spills, upsets and other reportable self-monitored events. On numerous
occasions the cause cannot be determined, and this is also reported, usually with a
statement of possible causes and/or a statement that the cause is being investigated.
Situations where a facility routinely fails to respond to this requirement are rare. Aside
from self-monitoring violations, however, there are numerous agency inspection reports,
which frequently identify unacceptable outfall conditions but do not supply reasons.
Many pretreatment violations reported to POTWs are also not explained. As a result,
there are a substantial number of violations for which causes are not identified in agency
files.
As in the case of air quality violations, the types of causes that are reported tend
to relate to an immediate cause (e.g.. equipment malfunctions, operator error).
Underlying problems (e.g., the need to replace old treatment facilities with a more
advanced control system) either are not addressed, or are not addressed in a way that
links the problem to a specific violation as the reason -- more often, an underlying
problem is discussed in terms of a potential solution to continued violations, and not as
the definitive cause of a violation.
The cause categories reported in this analysis reflect a best effort to group the
reported causes into standard categories based on the reasons for violations that were,
for the most part, provided in reports submitted by the mills. Processes selected for this
analysis include those with the most violations. They include coke plants, blast furnaces,
basic oxygen furnaces, hot forming/hot mills, steel finishing (including cold
mill/annealing, pickling and coating) and central treatment plants.
(2) Coke Plants
(a) Process Discussion
Virtually all blast furnace coke produced in the U.S. is manufactured in by-product
coke plants comprising coke batteries (numerous, vertical slot-type ovens aligned side-
by-side) and by-product coke oven gas cleaning and chemical recovery facilities. There is
one, relatively small non-recovery coke plant operating in Virginia. A second non-
recovery coke plant is being constructed at an integrated steel mill located in
northwestern Indiana.
In the by-product process, coke is produced on a batch basis by distilling
metallurgical coals in the slot type ovens at temperatures of 1,650 to 2,000°F in the
absence of air. Blends of high, medium and low volatile coals are used to produce coke
of sufficient strength for use in ironmaking blast furnaces. Coke batteries comprise
numerous ovens constructed side-by-side equipped with ancillary coal charging, gas
collecting mains, and coke pushing and coke quenching facilities. Coal is charged into
the tops of the ovens with larry cars(there are no pipeline charged batteries in the U.S.).
The coking process typically lasts 16 hours. After the coking process is complete,
incandescent coke is pushed from the oven into a flat bed rail car and transported to a
coke quench station where the coke is quenched with water to near ambient
-------
Final Report
February 2000
Page 177
temperature. Coke breeze, essentially fine coke particles, is recovered from the quench
stations. Coke oven gas is the principal by-product of the coking process.
In the by-product coking process, distilled volatile components are collected as
unpurified "foul" gas containing water vapor, tar, light oils, solid particulate matter of
coal dust, heavy hydrocarbons, and complex carbon compounds. Condensable materials,
such as tar, light oils, ammonia, and naphthalene are removed, recovered, and processed
as gas and coal chemical by-products. Finally, sulfur is removed, leaving clean,
desulfurized oven gas.
This cleaning involves a number of steps. First, the "foul" gas is sprayed with
weak ammonia liquor, which condenses the tar and ammonia. The remaining gas is
cooled as it passes through a condenser and then compressed by an exhauster. Any
remaining tar is removed by a tar extractor, either by impingement against a metal
surface or collection by an electrostatic precipitator.
At this stage, the gas still contains approximately 75% of the original ammonia
and approximately 95% of the original light oils. The gas is passed through a saturator,
where the ammonia reacts with sulfuric acid to form ammonium sulfate, which is
crystallized and removed. The gas is further cooled to condense naphthalene. The light
oils are removed in an absorption tower and subsequently refined or used as fuel in the
coke heating process. The last cleaning step is removal of hydrogen sulfide in a
scrubbing tower. The cleaned, desulfurized gas is then used as fuel for heating the coke
ovens, as well as for other plant combustion processes, or sold to nearby facilities.
(b) Water Uses and Wastestreams
At the end of the coking period, the incandescent coke is pushed out of the
furnace into a coke car and taken directly to a quenching area. There are two methods
for quenching the hot coke: wet quenching and dry quenching. During wet quenching,
water is sprayed onto the hot coke and most of the water is carried up a stack over the
coke car as steam. Modern quenching stations are typically recirculating in nature.
Excess quench water is collected in a settling basin where the coke fines settle out. The
water is then reused for quenching (there is still one dirty quench process left in the
U.S.).
The gas produced during the coking of the coal contains valuable chemicals
which are recovered in the by-product recovery plant. The gas and vapors are shock-
cooled by spraying with flushing liquor at various points along the collecting main. The
cooling results from the evaporation of a portion of the water from the flushing liquor
which removes some of the sensible heat from the gas and condenses some of the
vapors, with the resultant condensation of heavy tar from the gas. The flushing liquor
also provides a carrying medium for the condensable tars and other compounds formed in
the operations.
The moisture and volatile components of the coal, typically 20 to 35% by weight,
are collected and processed to recover by-products, which include-crude coal tars, crude
light oil (aromatics, paraffins, cycloparaffins and naphthalenes, sulfur compounds,
nitrogen and oxygen compounds), anhydrous ammonia or ammonium sulfate,
naphthalene, and sodium phenolate. During this by-product recovery process.
-------
Final Report
February 2000
Page 178
wastewater is produced at the Ammonia Solution Spray, Tar Extractor, Condenser, and
the Scrubbing Tower.
The typical volume of process wastewaters generated at a well-controlled by-
product coke plant is approximately TOO gallons per ton (gpt) of coke produced. Waste
ammonia liquor made up of moisture contained in the coal charge accounts for about 25
to 35 gpt. The remainder results from steam addition for distilling ammonia from the
waste ammonia liquor, crude light oil recovery, and miscellaneous sources. Cokemaking
wastewaters typically contain high levels of oil and grease, ammonia-N, cyanides,
thiocyanates, phenolics, benzenes, toluene, xylene, other aromatic volatile components,
and polynuclear aromatic hydrocarbons
-------
Final Report
February 2000
Page 179
most significant cause for this category is equipment failure, with 14 violations and one
concern. Of these, 10 violations and one concern are related to problems with the
ammonia still, and 2 violations are related to failed pump bearings. Process related
causes are associated with 8 violations and one concern. Six violations are attributed to
the air pollution controls installed at one mill in response to the benzene NESHAP
regulations. The remaining process related incidents are attributed to an ammonia still, a
sewer collapse (the only concern), and a fundamental inadequacy of the pretreatment
system to remove cyanide from wastewater. There are 355 coke plant treatment system
violations and two concerns with no cause indicated. All but 11 involve one mill, and all
but one of the violations are effluent limit violations.
• Pretreatment Program: Coke Plant
Very few Pretreatment violations and concerns related to the coke plant are not
also linked to the Coke Plant Treatment System. There are only two concerns in this
category. Both involve potential unpermitted discharges. The cause for one is cited as
equipment failure related to a failed pump indicator, and the cause for the other is cited
as O&M/Work Practice related to operator error during maintenance.
• NPDES Program: Coke Plant Treatment System
There are 57 NPDES related violations and one concern involving the coke plant
treatment system. Of these, 26 cite equipment failure as the cause. Of the 26
equipment failure causes, nine were valve or equipment leaks, eight were stormwater or
other weather related equipment failures, and seven were attributed to a broken pH
probe. O&M\Work Practice causes are noted for 15 violations, 12 involving problems
with sediment basin operation. Process Related causes are associated with 11
violations, all of which are due to a fundamental inability of the treatment system to treat
the wastestream adequately. There are six violations for which the cause is not
indicated.
• NPDES..Program:_Coke Plant
There are 51 NPDES related violations and 27 concerns involving the coke plant.
Of these, 17 cite equipment failure, six of which are equipment leaks or pipe failures.
Other equipment failures include three level indicator malfunctions, a blown fuse, a pump
failure, and a pipe blockage. There are six violations and concerns categorized as
O&M/Work Practice. Three violations involve failure to conduct testing for the zebra
mussel treatment program, and two concerns relate to potential unauthorized discharges
during maintenance and repairs. There are 32 violations and 22 concerns with the cause
not indicated.
The following table (Table 15A) summarizes the causes of violations documented
by the water program for coke plants.
-------
Final Report
February 2000
Page 180
TABLE 15A
Water Quality Compliance Problem Cause Analysis: Coke Plant
|Unkffi)wAn^|i|
rSi»
mm
•jKOpt
|M||sf
3*ljE i-,*:*'"* **>*** Si:r ' j*wt O'flW^;- •'•?* • *•!•••'•. f-^'p" jK'<:"*''~a'-'* i:'*yt»*:?« " >• **'•**?" ?sJ>*A'^SS''V»p!*\^ '•iK.i'^iJ<''I'^'^fji-.---.' ""•! »^!i ="'
arasf^^iPfiwss
S^*,^.^l|gi«gfe««s
.
'
u< -
•Mills
.«,: •"•*'*•; su
','<& •'!•*? ,s
-------
Final Report
February 2000
Page 181
(3) Blast Furnaces
(a) Process Discussion
Blast furnaces are large cylindrical structures in which molten iron is produced
continuously by the reduction of iron bearing ores with coke and limestone. Reduction is
promoted by blowing heated air (hot blast) into the lower part of the furnace from
adjacent heating stoves. As the raw materials melt and decrease in volume, the volume
of the furnace charge decreases. Additional raw materials are added (charged) at the
top of the furnace to keep the raw material mass within the furnace at a constant level.
Blast furnace gas leaving the top of the furnace has heating value and is cleaned and
cooled prior to use for stove heating and boiler house and power house operations.
Iron oxides react with the hot carbon monoxide from the burning coke, and the
limestone reacts with impurities in the iron bearing material and the coke to form molten
slag. These reactions start at the top of the furnace and proceed to completion as the
charge passes to the bottom of the furnace. Molten slag floats on top of the molten iron
at the bottom of the furnace. Iron and slag are tapped separately from the bottom of
the furnace on a batch basis.
(b) Water Uses and Wastestreams
Non-contact cooling is the largest application of water for blast furnace
operations. For example, cooling water circulates constantly through the tuyeres, hearth
staves, bosh, and in-wall cooling plates, cinder notch, and stove valves. Process water
uses include blast furnace gas cleaning and cooling with direct contact water. Limited
amounts of water are used for slag cooling or slag granulation.
Ironmaking process wastewaters are generated from gas cleaning and cooling the
dirty exhaust (top) gases. The gas streams contain dust of raw materials and process
reaction products. Principal pollutants include total suspended solids, ammonia-N,
cyanides, phenolic compounds, and metals (Cu, Pb, and Zn).
(c) Typical Treatment and Potential Problem Areas
Standard treatment in the industry for the gas cleaning cooling waters includes
sedimentation in thickeners or clarifiers, cooling with mechanical draft cooling towers,
and high rate recycle. At present, all but one blast furnace plant (not included in the
current study) in the U.S. are equipped with high rate recycle and treatment systems.
Low-volume blowdowns from the recycle systems are either consumed in slag cooling at
furnaces with adjacent slag pits, or treated in conventional metals precipitation systems.
Alkaline chlorination is practiced at a few mills to treat for ammonia-N, cyanides, and
phenolic compounds.
Wastewater problems from blast furnace operations can result from overflows
from cooling tower hot or cold wells, hydraulic imbalances in the blast furnace recycle
system or slag quench system, cross-contamination of blast furnace process water and
non-contact cooling water, premature or excessively fast drainage of blast furnace gas
seals, and failure or upsets of recycle treatment systems.
-------
Final Report
February 2000
Page 182
in this analysis causes of violations and concerns attributed to the blast furnace
have been combined with those attributed to any related recycle system. A best effort
was made to isolate the blast furnace from other mill processes. However, there are
other violations that may be due to blast furnace wastestreams, but there was
insufficient information in the file to make that determination.
(d) Summary of Causes
There are 960 violations and concerns under the blast furnace category, making
this the process under the water program with the largest number of compliance
problems. However, a single mill represents 722 or 75% of all violations and concerns
for this process. There are two violation categories that account for the majority of
problems: effluent violations (811} and unauthorized discharges (102). There are 926
violations and concerns (96%) attributed to NPDES related requirements. The remaining
34 (4%) involve Pretreatment program related requirements. Of the 960 violations and
concerns, roughly two-thirds (610) cite cause information and no cause is indicated for
the remaining 350.
• Pretreatment Program: Blast Furnace Recycle System
There were 21 violations for this subcategory. All were effluent violations. Of
these, 16 cite pretreatment process related causes for noncompliance. As an example
of one type of process inadequacy encountered, an investigation determined that the
recycle system blowdown was high in carbonates and bicarbonates. This caused
"overburden" on the pretreatment system and resulted in exceedances. Equipment
failure is cited for two violations, one being a pump failure, and the other a check valve
malfunction. O&M/Work Practice is also cited as the cause for two violations, both of
which are due to an unusually high number of iron analyses requiring the use of mercuric
chloride in the analysis, and that resulted in mercury exceedances. One violation has no
cause indicated.
• Pretreatment Program: Blast Furnace
Only 13 violations are associated with this subcategory. O&M/Work Practice is
cited as the cause for 10 violations, nine of which are caused by the use of coal with a
higher than normal mercury content. No cause is indicated for three violations.
• NPDES Program: Blast Furnace Recycle System
There were 111 violations and 16 concerns for this subcategory. The most
commonly cited cause is equipment failure (56). Of these, 23 are due to various pump
failures, eight are due to weather related equipment failures, and the remainder are
related to leaks, ruptures or parts failure. O&M/Work Practice is cited as the cause for
24 violations and three concerns. Process related causes are cited for 13 violations and
one concern. Of these, eight are attributed to general operation of the recycle system
and six are due to problems with system capacity. Permit/regulation interpretation
issues are cited as the cause of two concerns, one for an unpermitted outfall, and one
for unpermitted construction. There are 16 violations and five concerns with no cause
indicated.
-------
Final Report
February 2000
Page 183
NPDES Program: Blast Furnaces
The majority of blast furnace violations and concerns, 775 violations and 24
concerns, are associated with this process subcategory. Of these, 334 violations and
six concerns cite O&M/Work Practice as the cause of noncompliance. There are 252
violations related to slag quench water management, and 51 violations related to sewer
cross-connections. Other violations or concerns relate to general operation and
maintenance, operating condition variations (high flows, sewer repairs, hydraulic
imbalances), or operator error. Equipment Failure is the second most frequently cited
cause (129 violations and five concerns). Of these, 92 are due to line and pipe leaks,
and 13 are weather-related equipment failures. Other equipment failures include power
failures, stuck and failed valves, level controller problems and pump malfunctions. There
are 309 violations and 11 concerns in this category with no cause indicated.
The following table {Table 15B) summarizes the causes of violations documented
by the water program for blast furnaces.
-------
o
o
*- o
-
DC §-
— E- CD
1
O
Q)
a
w
i " 'SK JAi -
.*
Wi
iO-JRiSi
a
["ini-SSi
.
IBI
jtasfra? *.?^'Bft. '
,3:-
-l
'' «• '••-• -
00
s
CD
co in
oo
00 £?
00 C
Bl
en
CM
CN
CD
CO
ss
CM ~
CM
CN
0)
co jr
5 =
m
encn
O) p
S?
CM
CO
O>
CN
CM
CN
CM
"5
25
25
CN
O>
CN
CM
CN
CM
81
SI
CM
*
CD
cop
-*
CD
en
CO
CN
CO
CM
«t
CM
CMS
Ss
CD
25
CM
CO C7
fBB *^
in —
coos
03
OJ ~
s
-------
Final Report
February 2000
Page 185
(4) Basic Oxygen Furnaces
(a) Process Discussion
The principal purpose of EOF steelmaking is to refine a metallic charge consisting
of approximately two-thirds to three-quarters molten iron and one third to one-quarter
steel scrap by oxidizing silicon, carbon, manganese, phosphorus and a portion of the
iron. Oxygen is injected into the molten bath either through the top of the furnace {top
blown), bottom of the furnace (bottom blown), or both (combination blown). Residual
sulfur is controlled by managing furnace slag processes.
(b) Water Uses and Wastestreams
Off-gases from furnaces in the U.S. are controlled by one of three methods:
semi-wet, wet-open combustion, and wet-suppressed combustion. In the semi-wet
method, furnace off-gases are conditioned with moisture prior to processing in
electrostatic precipitators or bag houses. In wet-open combustion, excess air is
admitted to the off-gas collection system allowing carbon monoxide to combust prior to
high-energy wet scrubbing for air pollution control. In wet-suppressed combustion,
excess air is not admitted to the off-gas collection system prior to high-energy wet
scrubbing for air pollution control. In addition to process water usage, large quantities of
non-contact cooling water are also used in BOF steelmaking operations.
The paniculate matter carried by the gas stream is the principal source of
pollutants which contaminate the process wastewaters. The raw wastewaters from the
semi-wet and wet gas cleaning systems of each steelmaking subdivision are similar in
waste characterization in that toxic metals, fluoride, and significant quantities of
suspended solids are present. Pollutants include Zn, Cu, Pb, Hg, Cr, Ni, Ag, Cd, As, Se,
Tl. The levels of the various pollutants, however, vary between systems. Untreated
wastewaters are highly alkaline, particularly during the period of the furnace "blow."
(c) Typical Treatment and Potential Problem Areas
Standard treatment for wet gas cleaning systems consists of sedimentation in
clarifiers or thickeners and recycle of 90% or more of the applied water. Slowdown
treatment consists of metals precipitation. Operating problems can result in the recycle
systems from introduction of excess lime fines from furnace operations which can cause
fouling and scaling, loss of alkalinity control, and hydraulic imbalances within the
blowdown treatment systems.
Although the effluent limitations guidelines at 40 CFR Part 420 specify zero
discharge as the effluent limitation for BOF semi-wet air cleaning systems, most, if not
all of these systems are operated with waste water discharges. These discharges result
from use of water to flush deposits of dusts and sludges from the gas collection and
cleaning systems beyond that amount which can be evaporated. Discharges from BOF
semi-wet air cleaning systems are usually co-treated with wastewaters from other
processes in centralized wastewater treatment systems.
-------
Final Report
February 2000
Page 186
(d) Summary of Causes
For the purpose of this study, causes of violations and concerns associated with
the BOF include those attributed to the EOF, as well as those attributed to any related
recycle systems. A best effort was made to isolate the BOF part of the steelmaking
process from other processes. However, in some cases, there are other processes
where violations may be due to BOF wastestreams, but there was insufficient
information available to make that determination. The most common case is when BOF
wastestreams are directed to a central treatment plant and combined with wastestreams
from continuous casting and the ladle metallurgical facility. Therefore, the count of
violations and concerns for the BOF category in this summary should not be assumed to
represent all violations and concerns related to the BOF process.
There are 328 documented violations and concerns related to BOFs, ranking
BOFs fifth among the process categories selected for this study in the number of
documented compliance problems. A single mill represents 183 or 64% of all violations
and concerns. Two violation categories account for the majority of problems: effluent
violations (209) and unauthorized discharges (48). Of the 288 violations and concerns,
179 or 62% are related to the Pretreatment program, and the remaining 109 or 38% are
related to the NPDES program. A total of 184 (64%) of all violations and concerns for
the BOF have cause information, and 104 (36%) have no cause indicated.
• Pretreatment Program: BOF Recycle System
The least number of violations and concerns are related to this subcategory.
There are 33 violations, of which 19 cite equipment failure, all related to an antiquated
pH adjustment.system. O&M/Work Practice is cited for four violations involving
incorrect calibrations and operator error. There are 10 violations with no cause
indicated.
• Pretreatment Program: BOF
The majority of BOF related violations and concerns, 146 (all violations), are
associated with this subcategory. Of these, 91 violations are associated with
O&M/Work Practice problems, including 80 incidents related to the contamination of
cooling water from scrap. Other O&M/Work Practice problems include seven surcharge
conditions, two bypasses during maintenance, and two problems with acid meter
calibration. The remaining 55 violations have no cause indicated.
• NPDES Program: BOF Recycle System
The BOF Recycle System accounts for 30.NPDES related violations and 14
concerns. Of these, 19 violations and four concerns are due to equipment failure. Of
the 19 violations, 16 are weather related, including 10 pumping capacity related
exceedances due to stormwater flows. There are three effluent violations and seven
concerns involving potential unauthorized discharges with no cause indicated.
-------
Final Report
February 2000
Page 187
• NPDES Program: BOFs
Discharges in this subcategory account for 54 violations and 11 concerns. Of
these, 28 violations and three concerns are due to equipment failure, 17 of which are
weather related, and 15 of which involve stormwater infiltration into sewers. The
remaining equipment failures are primarily ruptures of pipes and pump failures.
O&M/Work Practice is cited as the cause for three violations and two concerns. There
are 23 violations and six concerns with no cause indicated.
The following summary table (Table 15C) provides information on the causes of
violations documented by the water program for basic oxygen furnaces.
-------
o N m
&=rS
cc § «-
1| o,
IT u. a!
O
U)
UJ
oa
<
U)
o
u
a
u.
a>
o>
>
x
O
w
a
ca
10
'35
0)
10
a
U
2
O.
0)
U
.2
"o.
o
O
IB
•^••JJS; %•*
F&.Z
ifes
ilas
S
'
i
.w^^^M-f-!!
llli
: '
in
00
CM
CM
CM
CO
CO
O
CM
CM
Basic Oxyge
CO
55
CO
ro —
2E
Basic Oxygen Furnace RS
°
n
CMp
CM
CM
(O «—
o>
Basic Oxygen Fu
CO
CO
CO
CO
0>
o>
X
O
O) —
Is* N
m
o>
in
-O)
o>
03 i
"8
O— .
u> CM
CM
(O
CA
CM
CN
CO
ss
ss
Oxyg
CO
ro
CO
O)
CM —
CO™
00PM
C0_
CO
ai
o
2
n
«
«
c
o
*
o
1
- s-
» a>
*- _oj
ia u
%•
a II
v
DC (A
II ^
O
a.
E «
-------
Final Report
February 2000
Page 189
(5) Hot Forming/Hot Mills
(a) Process Discussion
Hot forming mills can be divided into four categories by the purpose that the mill
serves in preparing the steel for finishing: primary rolling mills, section mills, flat-rolled
mills (plate mills and hot strip mills) and pipe and tube mills. Primary mills include
slabbing mills, blooming mills, and billet mills and perform the initial rolling step used in
the production of a semi-finished product from solid hot steel ingots. Primary mills
produce either blooms, slabs, or billets. Prior to hot rolling in primary mills, steel ingots
are heated to rolling temperature (2,000°F- 2,400°F) in soaking pit furnaces. In a
primary rolling mill, the hot ingot is passed between the mill rolls and reduced in cross-
section in either a reversing mill or a tandem mill. After the ingot is rolled to the desired
size, the end of the bloom, slab, or billet is cut off or "cropped." Also at the primary
rolling mill, the semi-finished steel is conditioned to remove defects, such as rolled
seams, light scabs, and checks, by hand chipping, machine chipping, scarfing, grinding,
milling, and hot steel scarfing. With the current high utilization of continuous casters at
steel mills in the United States, there are relatively few primary mills operating today.
They are most often used to produce slabs for selected grades of plate products where
ingot casting is desirable.
Most section mills, plate mills, and hot strip mills use continuously cast billets or
slabs to produce finished hot-rolled products, or to produce intermediate hot-rolled
products for cold finishing and coating. Continuous casting machines offer significant
yield and energy savings over the combination of ingot casting and primary hot rolling.
The section rolling mill takes the semi-finished product from the casting machine,
usually in the form of a rectangular cross-section billet or a round, and produces either
an intermediate finished product to be further reduced in other section mills or rolls the
billet directly to a finished product. Reheating is necessary for section operations
whenever the temperature of the metal being worked falls below the temperature
required to maintain plasticity. Automatic hot scarfing is used at some section mills to
remove defects, such as rolled seams, light scabs, and checks. Section mill types
include billet mills, bar mills, rail mills, rail-joint bars, and structural section mills.
The basic operation of a plate mill is the reduction of a heated slab from a
primary mill to the weight and dimensional limitations defining plates. Plates are
generally considered to be those flat, hot-rolled finished products that are more than 8
inches wide and generally 0.23 inches or more thick, or over 48 inches wide and at least
0.18 inches thick. The reduction of the plate is accomplished by heating slabs,
descaling and rolling them to plate dimensions, leveling, cooling and shearing the plate to
the desired size. Most plate mills use continuous heating furnaces. Descaling in modern
plate mills is accomplished by hydraulic sprays impinging on both top and bottom
surfaces of the plate at pressures up to 1,500 Ibs/in2.
The hot strip mill converts slabs that are reheated to rolling temperatures
{20000F-2400C1F) in continuous reheat furnaces into "hot bands," or coils of strip steel.
Slabs are provided either from a storage yard, or are delivered hot (or warm) directly
from slab casting machines. The hot strip mill rolling train consists of a roughing scale
-------
Final Report
February 2000
Page 190
breaker stand, several roughing mill stands, a finishing scale breaker stand, several
finishing mill stands, a run-out table, and coilers. Motor driven roll stands convey the
hot slabs along the strip mill from mill stand to mill stand. High pressure water sprays
used to remove scale from the hot slabs are located after the scale breaker and roughing
stands. Roll stand spray cooling water is provided for cooling of each roll in the stands.
(b) Water Uses and Wastestreams
In hot rolling mills, water in the form of high-pressure jets is used to remove
scale from the hot steel before rolling and to keep the surface clean between certain
passes. The scale removed from the hot steel by the high-pressure jets falls into a flume
or sluice beneath the mill, where a running stream of water carries the scale to a scale
pit. Hot-strip mills also use laminar cooling sprays at the runout table to cool the strip in
a controlled manner prior to coiling.
Water use and discharge rates from hot forming operations vary greatly
depending upon the type of hot forming mill and the shapes produced. Applied process
water rates typically range from 1,500 gpt for specialty plate mills to more than 6,000
gpt for hot strip mills. Discharge rates range from the applied water rates for hot
forming mills operated with once-through process water systems to near zero discharge
for mills equipped with high-rate recycle systems. At present, most hot forming mills in
the U.S. are equipped with recycle process water treatment systems.
The principal pollutants in wastestreams from hot mills are total suspended solids
(TSS) and oil and grease (O&G). Low levels of metals are also found in paniculate form.
(c) Typical Treatment and Potential Problem Areas
Wastewater treatment includes: processing in scale pits located adjacent to the
hot forming mill to recover mill scale and remove gross amounts of tramp oils; recycling
of a portion of the scale pit effluent for flume flushing; sedimentation in clarifiers for
TSS and O&G removal; filtration in mixed- or single-media filters; and discharge or
recycle. High rate recycle systems (e.g.. >95%) have been installed at many hot
forming mills in the United States.
Upsets and operating problems for hot forming process water treatment and
recycle systems are less common than for more complex steel mill process water
treatment and recycle systems involving pH control and chemical precipitation. The
most common operating problem in these systems is fouling of filter with oil resulting
from inadequate removal in upstream treatment units (scale pits, clarifiers).
(d) Summary of Causes
The steel mill processes in the hot forming/hot mill category include:
heating/soaking pits, primary slabbing or hot forming mills, and hot rolling mills. It was
possible to break this into two subcategories, hot forming/hot mill and the hot
forming/hot mill recycle system (when the available process information allowed).
-------
Final Report
February 2000
Page 191
There are 491 violations and concerns for the hot forming/hot mill process. One
facility is responsible for 156 or 32% of all violations and concerns. As is the case for
most processes, effluent violations and unauthorized discharges account for most
violations (209 and 233, respectively). Of all violations and concerns for this process,
476 or 97% are attributed to NPDES requirements. The remaining 15 or 3% relate to
Pretreatment program requirements. A total of 267 or 54% of all violations and
concerns have cause information, and 224 or 46% have no cause indicated.
• Pretreatment Program: Hot Forming/Hot Mill Recycle System
There are 14 violations, all at one mill, under this subcategory. The primary
cause is equipment failure, accounting for nine violations, eight of which are pump
related, seven resulting in overflows at the clearwell. The remaining equipment failure
violation is weather related. The second most common cause cited is O&M/Work
Practice (two violations). The only other cause cited is weather related (a single
violation involving an overflow caused by a frozen float). There are three violations with
no cause indicated.
• Pretreatment Program: Hot Forming/Hot Mill
This subcategory accounts for one violation. There is no cause indicated for this
one violation.
• MPDES Program: Hot Forming/Hot Mill Recycle System
The hot forming/hot mill recycle system accounts for 216 NPDES violations and
four concerns. Of these, equipment failure is the primary cause (96 violations). The
specific cause for 72 of the 96 violations is the percolation of groundwater at one mill
through a high calcium slag soil where it becomes excessively alkaline, enters a cracked
sewer line, and discharges. The next most significant cause cited is O&M/Work Practice
(37 violations and two concerns). Of these, 30 work practice related incidents are
operation related, 12 of which are attributed to the direct contact of clean water with
mill scale at one mill, which occurred frequently over a one year period. Another eight
work practice causes are maintenance related, and a single violation is related to startup.
Process related causes are cited for five violations and concerns. There are 75 violations
with no cause indicated.
• NPDES Program: Hot Forming/Hot Mill
The majority of violations, 227, and concerns, 29, are associated with this
subcategory. There are 47 violations and 11 concerns which cite equipment failure as
the cause. Of the 58 equipment failures, 21 are leaks, eight are weather related, six
involve pump failures and the remainder include a variety of equipment failures. There
are 45 violations and seven concerns which cite O&M/Work Practice as the cause. Of
these, 24 are operation related, 13 are maintenance related, and 5 are repair related. A
permit/regulation interpretation issue relating to unpermitted flow was cited as a cause
for one concern. There are 136 violations and nine concerns with no cause indicated.
The following summary tables provide information on the causes of violations
documented by the water program for hot forming/hot mills.
-------
O
O
*- O
O ^
S. >
a> _
ing
O)
CM
COM
(0
O)O
COM
00
r-.
O) (O
ing
n
CO
ro
ng
CM
ro
i
in co
CM —
0)
00 ~
S5
in
CO
00
10
O)
cn
to —
-------
Final Report
February 2000
Page 193
(6) Steel Finishing
Steel finishing categories selected for this analysis include acid pickling, cold
forming and annealing, and coating. These processes, their related wastestreams and
treatment issues, are discussed in two sections below: (a) Pickling, and {b} gold
Forming and Coating. The discussion of violation causes for three selected finishing
processes appears below in (c) Summary of Causes. Separate summary tables for all
three of the finishing processes are grouped together following the narrative discussion
of causes.
(a) Pickling
1 • Process Discussion
The most common acid pickling processes are hydrochloric, sulfuric, and
combination (nitric and hydrofluoric) acid pickling operations used to remove oxide scale
from the surfaces of semi-finished products prior to further processing by cold rolling,
cold drawing, and subsequent cleaning and coating operations. Acid pickling operations
may be either batch or continuous. For continuous pickling processes, flat rolled coils
are welded end-to-end at the start of the line, and are cut by torch at the end of the line.
Virtually all pickling operations in the steel industry involve immersion of the steel in acid
baths and subsequent rinse tanks. Continuous hydrochloric acid pickling is predominant
for flat-rolled carbon steels. Batch sulfuric acid pickling is often used for bar products.
A related process used to remove scale from certain grades of stainless steels is
salt bath descaling whereby the steel is immersed in an oxidizing (Kolene®) or reducing
(Hydride®) molten salt bath. Wastewaters result from rinsing the steel after processing
and from fume scrubbers.
2. Water Uses and Wastestreams
Process wastewaters include spent pickling acids, rinse waters, and discharges
from pickling line fume scrubbers. Process water and wastewater flows vary greatly
depending upon the product and process. Waste pickle liquor flows typically range
between 10 and 20 GPT for certain flat-rolled products.
The principal pollutants include total suspended solids (TSS), dissolved iron, and
metals. For carbon steel operations, the principal metals are lead and zinc, and for
specialty and stainless steel, chromium and nickel. Hexavalent chromium may be
formed in salt bath descaling processes, in addition to chromium and nickel dissolved
from the steel.
3. Typical Treatment and Potential Problem Areas
In-process controls for acid pickling include: counter-current rinsing; use of
indirect heating versus direct stream sparging for temperature control of acid solutions;
and recycle and reuse of fume scrubber blowdowns. Spent hydrochloric and sulfuric
acid solutions are rarely treated in conventional treatment systems on site; instead, they
are generally sold as treatment aids for municipal and centralized wastewater treatment
-------
Final Report
February 2000
Page 194
systems; injected into deep wells; or neutralized off site. Some steel mills are equipped
with acid recovery or regeneration systems for spent sulfuric and hydrochloric acids,
respectively. Waste nitric and hydrofluoric acids from combination acid pickling of
specialty steels are often neutralized separately on-site and further treated with pickling
and scale removal rinse waters and fume scrubber blowdowns.
At carbon steel mills, hydrochloric acid and sulfuric acid pickling rinse waters are
usually co-treated with wastewaters from cold rolling, alkaline cleaning, hot coating, and
electroplating operations, when present.
Operating problems for acid pickling and steel finishing wastewater treatment
systems can result from loss of pH control; hydraulic and waste loading imbalances
caused by spills and losses from the pickling lines; and, excessive loss of pickling acids
to rinse waters caused by inadequate maintenance or failure of wringer rolls at the exit
end of the pickling tanks.
(b) Cold Forming and Coating
1. Process Discussion
*
After acid pickling, the remaining Steel Finishing operations can be broken into
four subcategories by the purpose that each serves in the finishing process: cold
forming, alkaline cleaning, hot coating, and electroplating.
Cold forming operations transform steel of various configurations (Le., bar, slab,
sheet) to the final configuration desired. As the name implies, cold forming is done at
ambient temperature. The cold forming category maybe separated into two divisions:
cold rolling and cold working of pipe and tube. Cold rolling is the operation which
passes unheated metal through a pair or rolls for the purpose of reducing its thickness,
producing a smooth, dense surface and developing controlled mechanical properties in
the metal. The thickness reduction attained may be as much as ten per cent in some
tandem cold rolling applications to virtually nil in some temper rolling and skin pass mills.
An oil-water emulsion lubricant is sprayed on the material prior to its entering the rolls of
a tandem cold rolling mill, and the material is usually coated with oil prior to recoiling.
This oil prevents rust while the material is in transit or in storage. The oil must be
removed before the material can be further processed or formed. For temper and skin
pass mills, rolling solutions may or may not be used. In pipe and tube operations (cold
worked) unheated flat-rolled steel strip is formed into tubes, welded and cold rolled to
desired dimensions.
Alkaline cleaning baths are used to remove mineral and animal fats and oils from
cold rolled steel. Batch or continuous alkaline cleaning occurs after cold forming and
prior to hot coating or electroplating to provide a surface suitable to accept the coating.
The cleaning baths are solutions of carbonates, alkaline silicates, and phosphates in
water. Electrolytic cleaning may be used for high-production operations. Alkaline
cleaning may be conducted in separate cleaning lines or as integral parts of hot coating
or electroplating operations.
-------
Final Report
February 2000
Page 195
Hot dip coating processes involve the immersion of clean steel into baths of
molten metal for the purpose of depositing a thin layer of metal onto the steel surface.
Various fluxes are used in certain applications. Hot coating processes can be carried out
on either a continuous or batch basis. • The physical configuration of the product being
coated usually determines the method of coating to be used. The hot coating category
maybe divided into three subcategories based on the type of coating used: galvanizing,
terne coating, and other metal coatings. Galvanizing is basically a zinc coating
operation. Terne coating consists of a lead and tin application. Other metal coatings
can include aluminum, cadmium, hot dipped tin, or mixtures of metals.
Historically, electroplating at steel mills was limited to tin and chromium
electroplating for the food and beverage markets and relatively low tonnage production
of zinc-electroplated (electro-galvanized) steel for the automotive markets. During the
past ten to fifteen years, electro-galvanized steel production has increased substantially
in response to automobile manufacturers' demand. New coatings consisting of
combinations of iron, nickel, and other metals have been developed.
2. Water Uses and Wastestreams
In the cold forming subcategory, process wastewater results from using
synthetic or animal-fat based rolling solutions, many of which are proprietary. The
solutions may be treated and recycled at the mill, used on a once-through basis, or a
combination of the two. At mills with recirculated oil systems, batch dumps of spent
solutions occur when contaminants, particularly iron, reach undesirable levels. Process
wastewater discharge rates may range from less than 10 gpt for mills with recirculated
rolling solutions to more than 400 gpt for mills with direct application of rolling solutions.
In the alkaline cleaning subcategory, nearly all of the alkaline cleaning rinse
operations in the steel industry involve immersion in rinse tanks. Applied process water
flow rates may range from 250 gpt to 350 gpt.
Wastewaters from hot coating result principally from product rinses and fume
scrubbers. Applied process water rates may range from 600 gpt for flat rolled products
to 2,400 gpt for wire products.
Wastewater flows from electroplating are generated from precleaning operations,
electroplating, rinsing, and fume scrubbers. Wastewater flows at large continuous strip
electroplating lines are typically about 500 gpt.
Principal pollutants of cold forming operations are total suspended solids (TBS)
and oil and grease (O&G) (emulsified), and metals (lead and zinc for carbon steels, and
chromium and nickel for specialty and stainless steels). Chromium may also be a
contaminant from cold rolling of carbon steels resulting from wear on chromium-plated
work rolls. Toxic organic pollutants including naphthalene, other polynuclear aromatic
compounds, and chlorinated solvents have been found in cold rolling wastewaters.
Because alkaline cleaning baths are not aggressive chemical solutions, the principal
pollutants generated are oils and greases removed from the steel, and low levels of toxic
organic pollutants found in cold rolling solutions. Principal pollutants of hot coating
operations are usually those associated with the coating metal or metal combinations
-------
Final Report
February 2000
Page 196
and hexavalent chromium for lines with chromium brightening or passivation operations.
Principal pollutants of electroplating operations are TSS and O&G and the metals plated.
3. Typical Treatment and Potential Problem Areas
Conventional treatment of cold rolling wastewaters includes chemical emulsion
breaking, dissolved gas flotation for gross oil removal, and co-treatment with other steel
finishing wastewaters for removal of toxic metals. Alkaline cleaning wastewaters are
usually co-treated with wastewaters from other steel finishing operations. In-process
controls of wastewater in hot dip coating include countercurrent rinses for lines with
multiple rinses and recycle of fume scrubber water. Wastewaters from hot coating lines
located at integrated steel mills or at stand-alone steel finishing plants are almost
universally co-treated with wastewaters from other steel finishing operations in metals
precipitation systems. Conventional wastewater treatment in electroplating includes
metals precipitation. At some finishing mills, wastewaters from electroplating lines are
pretreated or treated separately to minimize the volume of fisted hazardous waste sludge
generated due to heavy metal concentrations.
As noted for acid pickling, the primary operating problems for steel finishing
wastewater treatment systems are those associated with loss of pH control for metals
precipitation; hydraulic and waste loading imbalances caused by spills and losses from
the finishing lines; and inadequate performance of cold rolling oil removal systems.
(c} Summary of Causes
The Steel Finishing general category is subdivided into five subcategories based
upon the level of information provided in the documents that were reviewed. As much
as possible, different steel finishing processes were separated. Processes that have
been identified include: Cold Mill/Annealing and Cold Mill/Annealing Treatment Systems,
Pickling and Pickling Treatment Systems, and Finishing/Coating. For the Cold
Mill/Annealing Treatment System subcategory it should be noted that in a small number
of cases, pickling wastewater may be involved. However, the documentation was not
specific enough to allow attribution to Pickling. As noted in the process description, a
central treatment plant may be used to combine and treat steel finishing wastewaters.
However, violations and concerns were only attributed to the central treatment plant
category if it was not possible to trace the compliance problem back to a specific
process, or if the violations and concerns were specifically linked to the central
treatment plant.
There are 604 documented violations and concerns for the Steel Finishing
category. A single mill represents 310 or 51 % of all violations and concerns. Of the
604 violations and concerns, 379 are effluent violations, and 182 are unauthorized
discharges. The great majority (536 or 89%) of all violations and concerns are NPDES
related. The remaining 68 or 11 % are Pretreatment program related. A total of 332 or
55% of all violations and concerns for the Steel Finishing category have cause
information, and 272 or 45% have no cause indicated.
-------
Final Report
February 2000
Page 197
1. Pickling and Pickling Treatment Systems
The subcategory of steel finishing with the greatest number of violations and
concerns (249) is pickling and pickling treatment systems. Of these, there are 172
effluent violations, and 66 unauthorized discharges. Of all violations and concerns, 193
or 78% are NPDES related. The remaining 56 or 22% are Pretreatment program related.
A total of 148 or 59% of all violations and concerns have cause information cited, and
the remaining 101 or 41 % do not have cause information.
• Pretreatment Program: Pickling Treatment Systems
This pickling subcategory accounts for 50 violations and two concerns. Thirteen
violations and one concern are due to O&M/Work Practice problems. Of these, five
violations are due to discharges during the repair of a waste acid storage tank, two are
due to operational problems with pH control resulting in reduced metals removal
efficiency, two are related to the startup of a new mill and the startup of a new
wastewater treatment plant, and another two are related to maintenance oversights. Of
the three equipment failure related incidents, problems with the chemical feed system
are cited in one instance, failure of a pH meter is cited in another, and the third is a
concern regarding frozen tubing in a composite sampler. There are 35 violations with no
cause indicated.
• Pretreatment Program: Pickling
This pickling subcategory accounts for three violations and one concern. There
are two violations related to O&M/Work Practice problems, and there is a single concern
related to an equipment failure. One O&M/Work Practice violation is due to improper
maintenance, the other is due to a slug discharge of acid. The equipment failure
concern involves a flow meter reading falsely elevated values. There is one violation
with no cause indicated.
• NPDES Program: Pickling Treatment Systems
This pickling treatment system subcategory is cited the most frequently <113
violations and three concerns). A majority are accounted for by 44 equipment failures
and 37 O&M/Work Practice problems. Of the 44 equipment failures, 13 are due to
malfunctions of the lime feed system, eight are due to problems with a clarifier, and six
are due to pump malfunctions. Of the 37 O&M/Work Practice causes, 17 are attributed
to poor pH adjustment or capacity related exceedances, nine violations are related to
operator error associated with the pH adjustment system, and six violations are related
to improper maintenance. There are 33 violations and two concerns with no cause
indicated.
• NPPES Program: Pickling
This subcategory accounts for 73 violations and four concerns. O&M Work
Practice and equipment failure account for the majority (28 and 19, respectively).
O&M/Work Practice causes include 10 violations related to an acidic condition causing a
clarifier upset, four violations citing general operation, and three violations related to
-------
Final Report
February 2000
Page 198
maintenance problems. Equipment failures are due to leaking pipes, hoses or flanges in
12 instances. There are 28 violations and two concerns with no cause indicated.
2. Cold Mill/Annealing and Cold Mill/Annealing Treatment System
The cold mill/annealing and cold mill/annealing treatment system steel finishing
subcategory is ranked third in the number of steel finishing violations and concerns
(197). Of these, 196 are NPDES related, and one violation is Pretreatment program
related. Effluent violations account for 110 violations, and unauthorized discharges
account for 74 violations. There are 87 (44%) violations and concerns that have cause
information. The remaining 110 (56%), have no cause information.
• Pretreatment Program: Cold Mill/Annealinq/PicklinQ Treatment System
The one violation for this subcategory had no cause indicated.
• Pretreatment Program: Cold Mill/Annealing
There are no violations or concerns for this subcategory.
• NPDES Program: Cold Mill/Annealinq/Pickling Treatment System
There are 75 violations and two concerns for the cold mill/annealing treatment
system steel finishing subcategory. Of these, 32 violations and one concern are related
to equipment failures. Of the 32 violations, nine are freezing weather related, eight are
due to stormwater (with no additional information), three are due to a lime slurry feed
problem, and two are due to a pH meter probe clog. Ten violations are attributed to
O&M/Work Practice causes. Of these, six are due to a slug of FeCI2 solution released
from the pickle line, and one is due to a slug of Zn released when a cell was left open at
startup. One other O&M/Work Practice violation involved a general operation issue.
Only one process related cause was cited, and it was related to a treatment system
interruption. There are 33 violations with no cause indicated.
• NPDES Program: Cold Mill/Annealing
There are 113 violations and six concerns for the cold mill/annealing steel
finishing subcategory. Of these, 22 violations and five concerns are related to
equipment failures, 15 violations are related to O&M/Work Practice problems, and one
violation is related to process related causes. Of the 27 equipment failures, nine are due
to various leaks of pipes, trenches, flanges and lines, eight are due to a leak at a heat
exchanger, and five are due to pump failures or blockages. Of the 15 O&M/Work
Practice violations, 11 are due to operator error, failure to take necessary preventive or
corrective action involving spills and overflows, and similar deficiencies, three are due to
maintenance or repair work, and one is due to personnel absence during a holiday
shutdown. There are 76 violations with no cause information.
-------
Final Report
February 2000
Page 199
3. Finishing/Coating
This subcategory has the second largest number of the steel finishing violations
and concerns (158). Of these, 97 are effluent violations, and 42 are unauthorized
discharges. Unlike other process categories, there is no treatment system exclusively
noted for finishing/coating. Of the total violations and concerns, 147 are NPDES related,
and 11 are Pretreatment program related. Cause information is cited for 97 {61 %) of
these violations and concerns and there is no cause information for 61 (39%).
• Pretreatment Program: Finishing/Coating
There are 11 violations associated with this steel finishing subcategory. There
are only two cause explanations, and both cite O&M/Work Practice problems related to
retention basin overflows.
• NPDES Program: Finishing/Coating
NPDES related violations and concerns occur most often in this steel finishing
subcategory (130 violations and 17 concerns). Of these, 43 violations and 11 concerns
are related to equipment failures. Various leaks associated with oil lines, process lines
and sewers account for 21 violations. Failed pipes and valves account for 13 violations.
Most of the concerns (nine) involve inadequate outfalls -- in eight instances the outfall
and sampling point is subject to submersion. Five violations involve stormwater flows
that exceeded the capacity of pumping stations or sumps. There are 32 O&M/Work
Practice related violations and five concerns. Of the 32 violations, 12 are related to
overfilling a zinc tank, eight are related to maintenance and repair work, and 11 are
related to miscellaneous operating problems. In addition, there are four process related
violations and concerns, all of which were attributed to suspended materials being
discharged from clarifiers. There are 51 violations and one concern with no cause
information.
The following summary tables (Tables 15E through 15G) provide information on
the causes of noncompliance documented by the water program for pickling and
finishing operations.
-------
O
o
o
§ «N
w 03
-D O)
UJ
U)
111
OQ
O)
c
1
D)
_c
w
'E
w
"w
"5
(0
(0
O
E
o>
2
I
o>
u
.1
*E
o
O
o>
+*
ra
w
i
'V •=";'<
SSI
Bil
irt
(0
00
CM
0)
Finishing-Pickling
m
JI CM
n
Ss
Finishing-Pickling TS
§§
CD
2s
55
ng
Finishing-Pic
CMUJ
CVtf)
1OT-
CO
co
in
m ?
f
>
CM
OlD
cv
to
CM
8
<0
nishing-Pickling
co
CO
•CM
U)
00
Ss
CO
-------
8
Its
IT I
(0
CO
U
0)
o
I
Q.
O
O
CO
O
i
II
Hi
-"--'
CO
S3
O> —
»- CM
1
00
CM
S3
S3
ng
Finishing-Cold
r-. o
*"*
£5
O)
BE
Annealing/
Finishing-Cold
Pickling TS
S3
(O
in S3
CMVi
25
S5
(O
OCO
TOTAL
Annealing
ishing-Cold
Annealing
Finishing-Cold
Pickling TS
CO
§3
00
P-.
CM
53
Annealing
Finishing-Cold Mi
85
O)
ing
Finishing-Cold Mi
Pickling TS
§3
o>
25
85
£0
S3
TOTAL
not possible to attribute these violations or concerns specifically
Section ill relating to how daily and monthly averages are treated
ll
li
o w
I-o
0)
I-
O CO
i.i
*1
£>
eg,
ss
a >
g i
£ >•
» £
il
o> £
;= d>
-^ m
Q TO
1!
c *
rll
-------
O
o
o
a
O
o
O)
IE
(0
"35
>
13
<
O o
U) «
*~ (0
UJ O
JJ
S
2
a.
%
/.a''
m
ili|
ifo8;p
mm
mr
If:
•&3<|
&f*
»;f*4|k
?X:f< '
*|
*-\2-jS& — --^-_ -
Ti-$£H"' .^nstii'S.ssA
toi* "-"sftS^
ap :J e^ss?-
*lss i?-c»:S;;
j^F^Trr! .::I:!«M
^^K^k^s^K
• ..,-ifr««af:5i
.; jfr.W-^' 'if;
;r;^ri;H >
^l:'!
o>
O>
>
>.
I
2
O)
.£
*-
jo
a>
o
*;
o
a>
CO
.1
in
w
w
c
o
I
o
a>
i-
g
£
|
c
I
CO
c
I
V
- fe
a.
s
CO
-------
Final Report
February 2000
Page 203
(7) Central Treatment of Steel Industry Process Wastewater
(a) Process Discussion
Centralized wastewater treatment is the mixing of process wastewaters from
two or more distinct process operations prior to or as part of an end-of-pipe wastewater
treatment system. Use of centralized wastewater treatment is common in the U.S. iron
and steel industry today. Such systems are generally configured as follows:
• treatment and recycle of process waters on a process-specific basis, followed by
mixing and co-treatment of low-volume blowdown streams from each process;
• cascading of low-volume blowdowns from process-specific recycle systems to
other process water treatment and recycle systems;
• combinations of blowdowns from process-specific recycle systems with once-
through flows from other processes where recycling is not feasible because of
product quality considerations;
• mill-wide recycle systems whereby major process water flows are discharged
from the processes on a once-through basis and then combined, treated and
subsequently recycled for selected process applications; and,
• terminal, or end-of-pipe, wastewater treatment systems where compatible
wastewaters from steel finishing operations are combined and treated and then
discharged on a once-through basis.
Those processes where high-rate recycle of process waters ([.e.. greater than 90
to 95 percent) is feasible include sintering, ironmaking in blast furnaces, steelmaking in
open-combustion and suppressed-combustion basic oxygen furnaces, vacuum
degassing, continuous casting, and hot forming. Much of the reduction in mass
discharges of conventional and toxic pollutants from these processes is attributable to
high rate recycling. For certain steel finishing operations (e.g.. acid pickling, alkaline
cleaning, hot coating and electroplating), cascade rinsing and other techniques may be
used for wastewater flow reduction; however, in many instances high rate recycling as
defined above is not practical because of product quality considerations. In these cases,
most of the conventional and toxic pollutant discharge reduction is attributable to end-
of-pipe wastewater treatment systems.
Mixing of incompatible wastewaters prior to wastewater treatment is an issue
that EPA considered when it promulgated 40 CFR Part 420 in 1982 and 1984.
Incompatible wastewaters were defined as those wastewaters that contained toxic
pollutants that were not present in wastewaters from other processes that were mixed
prior to treatment (e.g.. mixing of ironmaking wastewaters containing ammonia-N,
cyanide and phenolic compounds with wastewaters from steelmaking operations that do
not contain those pollutants). EPA's principal concern was that when mixing
incompatible wastewaters, certain toxic pollutants would not be treated effectively, but
would be diluted and discharged at higher quantities than would occur if the
wastewaters were treated separately. Consequently, EPA structured the effluent
-------
Final Report
February 2000
Page 204
limitations guidelines in Part 420 to foster co-treatment of compatible wastewaters from
the following processes: Group 1: cokemaking; Group 2: sintering, ironmaking; Group
3: steelmaking, vacuum degassing, continuous casting, acid pickling (H2S04, HCI), cold
rolling, alkaline cleaning, hot coatings; and Group 4: specialty steel finishing operations,
combination acid pickling, salt bath descaling, and cold rolling. EPA also stated that co-
treatment of hot forming wastewaters with wastewaters from processes in Groups 2
and 3 above would be appropriate where the hot forming wastewaters were recycled to
a high degree and a low-volume blowdown was discharged to the central treatment
system (see 47 Fed. Reg. 23265-66, May 27, 1982).
For integrated steel mills, cokemaking wastewaters are almost universally treated
on a process-specific basis. The most common types of centralized wastewater
treatment systems include the following combinations: sintering and ironmaking;
steelmaking, vacuum degassing, and continuous casting; hot forming from multiple hot
forming mills; carbon steel finishing - acid pickling, cold rolling, alkaline cleaning, hot
coating, and electroplating; and specialty steel finishing — combination acid pickling, salt
bath descaling, and cold rolling.
For mini mills, centralized wastewater treatment most often involves co-
treatment of process waters from continuous casting and hot forming mills. Stand-alone
steel finishing mills typically have centralized wastewater treatment systems for the
steel finishing mills listed above.
(b) Potential Problem Areas
Wastewater treatment systems require a balance of flows through the plant and
chemical loadings within design limits to ensure effective treatment. Physical or
chemical shock loadings to the treatment system can reduce or destroy treatment
efficiencies. As a result, maintaining an appropriate hydraulic balance through the
system is critical for treatment performance. Stormwater flows, sudden hydraulic
increases or drops may adversely affect treatment and in some cases require bypass of
treatment altogether. Likewise, chemical loadings can fluctuate within a range, but
excessive loadings of chemical waste can lead to a number of different treatment upsets
including, disruption of pH balance, reduction in metals removal, or flocculating
problems. In treatment systems using biological methods, shock chemical loadings can
destroy microbial populations resulting in severe treatment deficiencies. Proper
maintenance of treatment systems ensure that treatment components are working and
performing at expected levels. Slug discharges of oil or sediment can cause a number of
maintenance problems that can affect adequate treatment including clogged filters or
rapid filling of settling basins or clarifiers.
(c) Summary of Causes
For the purpose of this study the central treatment plant process category
includes all violations and concerns that occur at the central treatment facility and that
are caused by a problem at the plant. It may also include violations and concerns
caused by an upstream process if the upstream process is not identified. When
possible, central treatment plant violations and concerns have been traced back and
assigned to the iron and steelmaking process responsible for the problem.
-------
Final Report
February 2000
Page 205
There are 247 documented violations and concerns for the centra! treatment
plant process. A single mill is responsible for 95 or 38% of all violations and concerns.
Approximately 84% of the violations and concerns involve pollutant discharges: effluent
exceedances account for 168 violations, and unauthorized discharges account for 39
violations. Of the 247 total violations and concerns, 229 or 93% are NPDES related,
and 18 or 7% are Pretreatment program related. Cause information was available for
102 (41 %} of the violations and concerns and not available for 145 (59%).
• Pretreatment Program: Central Treatment Plant
The Pretreatment program accounts for 18 violations. Of these, 13 cite
equipment failure, six of which relate to pH probe failures. The additional equipment
failures include: two plugged bubbler tubes, two valve failures, a motor failure, a pipe
flange rupture, and a blown fuse. Process related causes are cited for three violations,
all of which relate to problems with the gravimetric neutralization system. There are two
violations where no cause is indicated.
• NPDES Program: Central Treatment Plant
The majority of central treatment plant violations and concerns are associated
with the NPDES program. Of the 192 violations and 37 concerns in this category, the
principal cause of noncompliance is related to O&M/Work Practices (34 violations and
nine concerns). Of these, nine violations relate to tank or clarifier overflows, four
violations relate to operator error, two violations relate to startups, and 24 violations and
concerns involve discharges resulting from miscellaneous maintenance activities at or
affecting the central treatment plant (e.g., clarifier upset resulting from acid cleaning of a
wastewater transfer line, pH slug resulting from lime neutralization of an acid tank during
maintenance, accidental power interruption during pump maintenance, accidental
activation of pump during maintenance, etc.).
The second most common central treatment plant related, cause is equipment
failure with 26 violations and six concerns, comprised of eight line/pipe/valve leaks or
failures, five freezing weather related failures, five incidents of broken grit chamber
equipment or scrapers, three power failures, and three pump failures. There are also
various incidents of control circuit failures, level controller failures, lime feed system
problems, or tank leaks. There are also nine concerns and one violation citing process
inadequacies (eight involved defective oil separators at one mill). There is one violation
citing a permit/regulation interpretation issue regarding an unpermitted discharge pipe.
There are 132 violations and 11 concerns with no cause indicated.
The following summary table (Table 15H) provides information on the causes of
noncompliance documented by the water program for central treatment plants.
L
-------
O
*!
a ><°
0) h. O
DC £3 CM
«" b. Q)
in
t—
in
m
(Q
£
*^
Q)
O
o>
CO
IB
U
p
.
O
O
a
§
(0
.-.*::ii;.
.11
;»..«:
ill!
os —
^vi ^^
03
00
n
o>
o>
c
c
O
CO
.1
<4
C
O
S
_
">
e>
o>
R)
CD
%
£
!
CO
jo
O
'
a)
.a
c
CD
C
0]
03
«
Q.
-I
— . 0>
e «
ra
O m
>• ^
T- 0}
-------
Final Report
February 2000
Page 207
C. Hazardous Waste Program
{1} Introduction
The Resource Conservation and Recovery Act (RCRA) establishes standards and
procedures for the handling, storage, treatment, and disposal of hazardous waste.
Generators of hazardous waste are subject to waste accumulation, manifesting, and
recordkeeping standards in order to achieve "cradle-to-grave" management of hazardous
waste. Facilities that treat, store, or dispose of hazardous waste (TSD facilities) must
obtain a RCRA Part B permit. The permit contains general facility standards such as
contingency plans, emergency procedures, recordkeeping and reporting requirements,
financial assurance mechanisms, and unit-specific standards. RCRA also contains
provisions for conducting corrective actions that govern the cleanup of releases of
hazardous waste or constituents from solid waste management units (SWMUs) at RCRA-
regulated facilities. Typically, the contamination addressed by RCRA corrective action
can be attributed to historical work practices and the historical mismanagement of
wastes, rather than present day operations.
Several RCRA listed wastes are generated during steel mill operations. The
majority of these wastes are related to coke production, steel manufacturing at an
electric arc furnace (EAF), and pickling/finishing. At the coke plant, tar residues {K087,
K141, and K142), oil (K143 and K144), naphthalene residues (K145), lime sludge
(K060), wastewater sump residues containing benzene and polynuclear aromatic
hydrocarbons (K144), and coke oven gas condensate from transfer and distribution lines
are generated. EAF emission control dust and sludge (K061) are generated during the
steelmaking operation at mini mills. Finishing/Pickling operations at steel mills generate
wastewater sludge from cooling, descaling, and rinsing (D006, D007, D008, D009,
D010, and D011) and spent pickle liquor (K062). In addition, smaller amounts of waste
solvents, used oil and waste paint are also generated.
Generally, RCRA violations are determined during a State/Local or Federal
inspection of the facility. During an inspection, the inspector examines the areas of the
facility where hazardous wastes are generated and stored to determine compliance with
the applicable storage, labeling, and handling requirements. In addition, the inspector
will review the required records, including: manifests. Land Disposal Restriction (LDR)
forms, appropriate plans and reports, training and certification records, and other
relevant documentation. The record review provides the inspector with insight into the
hazardous waste handling practices over the past few years, or since the last RCRA
inspection. Record deficiencies are frequently identified during this review and cited in
violation notices.
. Most of the RCRA violations at steel mills are not related to a specific
steelmaking process. When steelmaking processes are involved, the violations occur
most frequently in relation to coke plants, electric arc furnaces, and steel finishing
operations (cold rolling, pickling and coating). There is very little information available in
the RCRA compliance files regarding the specific causes of violations. Generally, this is
because documentation of a specific reason for a violation is not required to support an
enforcement response, and agencies have not found that documentation of this
information is needed or useful for other purposes in their compliance programs.
-------
Final Report
February 2000
Page 208
The tables included in this report contain data from the same mills over the same
time period as the water and air programs. Included in the five year review are four
integrated mills and three mini mills, all of which were inspected during the five year
period. Ten integrated mills and seventeen mini mills were included in the one year
review. Of these, six integrated mills and four mini mills were inspected in 1995.
Because only 17 (or one-half) of the steel mills included in the study were actually
inspected during the stated timeframe, the RCHA file review was expanded to cover five
years for every mill. During this period, every mill was inspected at least once. The
following violation cause analysis is based on documented violations over a five year
period at all mills and therefore provides a more comprehensive representation of
compliance problems and their relative frequency than represented in the preceding
tables.
(2) Non-Process Specific Violations
By reviewing incidents of noncompliance and enforcement in State and EPA
Regional files it was a goal of this project to relate specific violations back to individual
steelmaking operations. Although this could be done for some of the RCRA violations, it
could not be done for most of them. These non-process specific related violations are
summarized in this section. Violations that could be linked to a specific steelmaking
process are discussed below in the context of the specific process. For the purpose of
this study, RCRA violations were grouped into thirteen subcategories. These include:
closure, financial assurance, self-inspection, labeling, manifest, monitoring, notification,
permit, corrective action or contingency plan, recordkeeping, reporting, training, and
waste analysis.
The greatest number of these violations relate to recordkeeping, manifesting,
required plans, and financial assurance. For the most part, recordkeeping violations
include: failure to maintain records for the appropriate amount of time, failure to
maintain the operating record or inspection log, failure to update the appropriate training
records, failure to have inspection records, and failure to maintain emergency equipment
logs. Manifesting violations generally include: failure to complete manifests correctly,
failure to use appropriate waste codes or measuring units on a manifest, failure to
receive the return-to-generator copy of manifest within the required time, and failure to
initial corrections on a manifest. Examples of violations pertaining to required plans
include: failure to update or amend required plans, failure to distribute appropriate plans
to emergency agencies, and failure to revise a waste analysis plan when required to do
so. The financial assurance related violations include: failure to update closure cost
estimates, failure to use proper inflation rates, and failure to use the correct financial
worksheet/form.
Non-process specific "RCRA related concerns" identified in this report are
generally conditions documented by an inspector at the time of the inspection, that
appear to be violations, but are not cited as such by the inspector, or they appear to be
a condition that may lead to a violation in the future if not addressed by the facility.
Examples include: failure to report a change in operating status, deviations from the
facility's Ground Water Sampling and Analysis Plan, and debris interfering with the
ability to conduct a secondary containment inspection.
-------
Final Report
February 2000
Page 209
The causes of these violations, if known, were rarely included in the
documentation reviewed. In most cases, the obvious cause is likely to be related to
some type of oversight. Discussions with State and Federal inspectors indicate, in their
opinion, that an underlying cause may often be attributed to limited and overextended
environmental staffs. However, these conditions were not mentioned in the compliance
files. It should be noted that very few of the non-process specific violations identified in
this study actually caused a release to the environment (e.g., mislabeled hazardous
waste resulted in improper disposal).
Of the violations and concerns discussed above, the majority of them were
associated with integrated mills. The large number of non-process specific violations at
integrated mills may be attributed to more frequent inspections of the integrated mills
and the fact that integrated mills are usually larger (more employees, more processes,
greater facility area, etc.) than mini mills. In addition, integrated mills are generally older
and have a more complicated physical layout with recycling, storage and disposal areas
and procedures that have changed and evolved over time.
(3> Coke Plant Violations
The violations associated with the coke plant relate to coke plant operations and
coke plant generated wastes. The greatest number of coke plant violations relate to spill
prevention, storage, secondary containment, and labeling. In addition, there were
violations relating to permitting, self-inspection, spill response, closure, improper
disposal, monitoring, and waste determination. Since coking operations are performed
at integrated mills, all of the violations listed above are associated with the integrated
mills included in this study. Also, most violations at the coke plant tend to involve the
mismanagement of coke by-products in containers or tanks — over half of the coke plant •
violations have had the potential to cause a release to the environment; and the number
of violations that have actually resulted in a release to the environment is greater at the
coke plant than at other steel mill processes.
The spill prevention violations at the coke plant primarily involve the management
of aboveground and underground storage tanks -- for example, tanks that are not
provided with leak detection devices, tanks not provided with spill/overfill prevention
controls, incomplete or nonexistent integrity assessments and tank certifications.
The storage violations primarily involve the management of containers or tanks.
These violations include containers that are not stored closed at all times except when
waste is being added. When this issue was discussed with inspectors, they indicated
their belief that the problem may often be related to understaffing - the size of the
integrated mills, some covering thousands of acres, and the number of employees, in the
thousands, make it difficult for an understaffed environmental team to manage
adequately all aspects of the RCRA program.
The secondary containment violations include tanks that do. not have secondary
containment or tanks with inadequate or damaged secondary containment. The facility's
self-inspection program should include the aboveground tanks. Problems with secondary
-------
Final Report
February 2000
Page 210
containment should be noted during these inspections, and, subsequently, the proper
maintenance should be performed. The labeling violations involve the failure to label
containers and tanks with the words "Hazardous Waste" and the absence of
accumulation start dates on containers and drums.
The hazardous wastes produced at the coke plant are primarily associated with
cokemaking by-products and their treatment. In the by-product coking process, distilled
volatile components are collected as unpurified "foul" gas containing water vapor, tar,
light oils, solid paniculate matter of coal dust, heavy hydrocarbons, and complex carbon
compounds. Condensable materials, such as tar, light oils, ammonia, and naphthalene
are removed, recovered, and processed as gas and coal chemical by-products. Finally,
sulfur is removed, leaving clean, desulfurized oven gas.
This cleaning involves a number of steps. First, the "foul" gas is sprayed with
weak ammonia liquor, which condenses the tar and ammonia. The remaining gas is
cooled as it passes through a condenser and then compressed by an exhauster. Any
remaining tar is removed by a tar extractor, either by impingement against a metal
surface or collection by an electrostatic precipitator.
At this stage, the gas still contains 75% of the original ammonia and 95% of the
original light oils. The gas is passed through a saturator, where the ammonia reacts
with sulfuric acid to form ammonium sulfate, which is crystallized and removed. The
gas is further cooled to condense naphthalene. The light oils are removed in an
absorption tower and subsequently refined or used as fuel in the coke heating process.
The last cleaning step is removal of hydrogen sulfide in a scrubbing tower. The cleaned,
desulfurized gas is then used as fuel for heating the coke ovens, as well as other plant
combustion processes, or sold to nearby facilities.
There are seven listed hazardous wastes associated with cokemaking under
RCRA: K060, K087, K141, K142, K143, K144, and K145. Process residues from coal
tar recovery (K141) are generated when the uncondensed gas enters the primary cooler.
Condensate from the primary cooler flows into the tar collecting sump and is discharged
to the flushing liquor decanter. The tars at the bottom of a tar collecting sump are
discharged to the flushing liquor decanter. Tar collection sump residue (sludge)
accumulates at the bottom of the collecting sump and must be recycled periodically.
The tar residue is recycled either as an individual stream, by recycling it through the
flushing liquor decanter, or by recycling it back to the coke oven.
Tar storage tank residues (K142) are produced when residuals settle out of the
crude coal tar collected as a coking by-product. The residues are periodically removed
from the storage tanks and are recycled to the coke oven or are landfilled.
Residues from light oil processing units (K143) collect in a light-oil scrubber and
light oil stripping still. Resin is a related waste that accumulates from cleaning wash oil
used in the light-oil recovery process. Wash-oil muck, residue from either a wash-oil
purifier or a wash oil decanter is periodically removed and recycled to the coke oven,
reclaimed off-site, or used as blast furnace or boiler fuel.
-------
Final Report
February 2000
Page 211
Wastewater sump residues (K144) accumulate in the bottom of a sump used to
provide sufficient quiescent residence time for oil and water to separate during light oil
recovery. The settled solids are removed periodically and either recycled to the coke
oven or landfilled off-site.
Residues from naphthalene collection and recovery (K145) accumulate at the
bottom of a skimmer sump where naphthalene is mechanically skimmed off the surface.
Residues also accumulate in the hot and cold sumps used as collection or surge vessels,
and on cooling tower surfaces. K145 is recycled to the decanter or sometimes to the
oven.
EPA has excluded a number of the hazardous wastes generated at the coke plant
from substantive regulation under RCRA. Coke by-product residues (K087, K141, K142,
and K147), considered hazardous because they exhibit the Toxicity Characteristic (TC)
specified in 40 CFR § 261.24, have been excluded from the definition of solid waste if
they are recycled either by returning the residues to the coke ovens as feedstock to
produce coke or to the recovery process as feedstock to produce coal tar, or by mixing
the residues with coal tar prior to coal tar refining or sale. This exclusion is conditioned
on there being no land disposal of the wastes from the point they are generated to the
point they are recycled to coke ovens or to tar recovery or to refining processes, or to
the point they are mixed with coal tar.
EPA concluded that the exclusion for coke by-product residues rests on three
factors. First, the recycling of the material in coke ovens causes no statistically
discernable increase in concentration of toxic constituents in the coke ultimately
produced. Second, if by-product residues are generated from the coking process and are
inserted on-site back into the process, this can be viewed as continuing activity (a
continuous process), rather than waste management activity. Third, by conditioning the
exclusion on no land disposal, the traditional RCRA objectives of avoiding land placement
of material and the general safe-handling and management of the material will be
assured. The exclusion is intended to encourage waste minimization, while maintaining
RCRA control over the wastes prior to the recycling step. The EPA noted that an
abandoned spill of these materials (a spill not cleaned-up expeditiously and used
beneficially) would constitute land disposal of a hazardous waste.
Inspectors indicate that these exclusions create a "grey area" with respect to
what is considered a recyclable material and what is hazardous waste when enforcing
the storage and handling requirements of these materials. A facility may recycle coke
by-products to their coke ovens or sinter plant; however, the storage of these materials
prior to recycling is often inadequate. For example, although the material must not be
stored in waste piles or in a similar manner that qualifies as land disposal prior to
recycling, inspectors noted that facilities have done so, arguing that the recycling
exclusion applies. This improper storage has resulted in findings of violation and
subsequent enforcement.
(4) Electric Arc Furnace Violations
The violations and concerns associated with the EAF relate to EAF operations
and the management of EAF dust and sludge. The greatest number of EAF related
-------
Final Report
February 2000
Page 212
violations relate to spill prevention, labeling, spill response, closure, and storage. In
addition, there were violations relating to recordkeeping, secondary containment, self-
inspections, and training and certifications. Like violations occurring at the coke plant,
violations associated with EAF operations, when they occur, involve primarily the
mismanagement of hazardous waste (EAF dust). As a result, a large number
(approximately one-third) have the potential to cause a release to the environment,
although few of the EAF violations that were identified actually resulted in a release.
The spill prevention and spill response violations at the EAF involve the
management of storage tanks, waste piles and containers. For example, EAF dust
containers (roll-offs) that have not been provided with sufficient containment to prevent
wind dispersal or contact with stormwater runoff would be considered a spill prevention
violation, and if the spill is not cleaned-up properly, it would also be considered a spill
response violation. The closure violations relate to closure activities associated with EAF
dust landfills and former EAF storage areas. In addition, infractions involving the aisle
space between storage containers requirements are included in the storage violation
category. The labeling violations involve the labeling of containers and tanks with the
words "Hazardous Waste," the absence of "No Smoking" signs, and the absence of
accumulation start dates on containers and drums. The violation relating to secondary
containment involved the containment of EAF sludge stored in a roll-off trailer.
The majority of violations relating to EAFs are associated with mini mills. The
larger number of violations at mini mills are likely because there are only two integrated
mills in this study with EAFs, and all the mini mills had one or more EAFs.
EAF dust is particulate matter produced during the EAF process and subsequently
conveyed into a gas cleaning system. The particulate matter that is removed from
emissions in a dry system is called EAF dust, and the particulate matter removed from a
wet system is EAF sludge. The dust (or sludge) has been designated by EPA as a listed
hazardous waste, K061. The primary hazardous constituents of EAF emissions control
dust/sludge are lead, cadmium, and chromium. EAF dust/sludge may vary greatly in
composition depending on the composition of the scrap charge and on the furnace
additives used.
Mini mills typically transport K061 off-site for disposal or reclamation. However,
some facilities are treating the dust or sludge in a high temperature metals recovery
{HTMR) unit to recover valuable metals. The treatment of EAF dust in the HTMR is
considered reclamation. The EAF dust is pumped pneumatically from the baghouse at
the EAF to the HTMR. Therefore, prior to being fed into the HTMR the EAF dust and
sludge are considered hazardous waste and must be handled and stored according to
RCRA requirements. The HTMR reduces the zinc and lead concentrations to acceptable
levels for land disposal of the dust, and the resulting slag is sampled and analyzed. If it
is found to be below exclusion limits it is sold offsite to integrated mills for introduction
into their blast furnaces. If the slag is analyzed and found to be above exclusion limits,
it is shipped off-site as special waste. The files reviewed indicate that only one of the
facilities included in the study is equipped with a HTMR.
Inspectors indicate that the management of EAF dust is difficult because of its
physical properties. The dust is very fine, much like talc, and reddish-brown in color.
-------
Final Report
February 2000
Page 213
Any small hole in a baghouse bag or storage bin cover results in a very noticeable, and
often times significant release. The dust is easily spread via wind and water dispersion
because it is fine and light. Inspectors add that the management of the dust requires
constant attention, but adequate management of the material is possible.
(5) Cold Rolling/Picklinq/Finishinq (Steel Finishing) Violations
The greatest number of violations and concerns associated with steel finishing
operations (cold rolling, pickling and finishing) relate to spill prevention, labeling,
secondary containment, and records. In addition, there were spill response violations,
self-inspection violations, permit violations, storage violations, training and certification
violations, waste determination violations, and an improper disposal violation.
The spill prevention violations at the steel finishing processes primarily involve
the management of aboveground storage tanks, for example, tanks that are not provided
with leak detection devices, tanks not provided with spill/overfill prevention controls,
and incomplete or nonexistent integrity assessments and tank certifications. The
labeling violations involve the labeling of containers and tanks with the words
"Hazardous Waste," the absence of "No Smoking" signs, and the absence of
accumulation start dates on containers and drums. The record violations relate to
inspection logs not being completed properly, records not maintained for the appropriate
length of time, and operating logs not being maintained.
The secondary containment violations include tanks that have not been provided
with secondary containment or tanks with inadequate or damaged secondary
containment. The number of secondary containment violations for the steel finishing
operations is likely to be high because of the large number of aboveground tanks
typically used for the storage of spent pickle liquor. Since many violations associated
with the finishing operations involve secondary containment and spill prevention, they
tend to have a greater potential to cause a release to the environment. Also, the large
volume of acids and other finishing solutions are caustic and tend to degrade containers,
tank systems and other containment systems, thereby increasing the potential for
release. However, the actual releases at steel finishing operations identified in this study
were not significantly greater as a percentage of the total violations identified.
In contrast to the coke plant and EAF related violations, which are linked
primarily to one specific mill type (integrated mills in the case of coke ovens, and mini
mills in the case of EAFs), steel finishing violations would be expected to occur at both
types of mills. In this study, however, the majority were associated with integrated mills.
This may be attributed to the fact that integrated mills are inspected more often and that
they are usually larger with more extensive finishing operations. The overall operations
are also more extensive at integrated mills, requiring a significantly larger commitment of
environmental staff.
Inspectors indicate that iron and steel facilities handle the spent pickle liquor in
three ways. They either sell it to a company that will resell it as a chemical additive to
neutralize pH in waste water, sell it to a firm for the production of iron oxides, or
dispose of it by deep well injection. There are instances where a mill has sold the spent
pickle liquor to a firm as hazardous waste, and then bought the same material back as
-------
Final Report
February 2000
Page 214
product to be used in the waste water treatment plant to facilitate the. precipitation of
metals from the waste water by neutralizing pH.
The mills have requested that EPA exclude spent pickle liquor from RCRA
regulation if it is used as a product in their waste water treatment plants on-site.
However, EPA has denied such requests because of its concern that the mills would use
amounts of spent pickle liquor in excess of what is necessary to neutralize pH in their
waste water as a way to dispose of the excess spent pickle liquor. The mills argue that
the use of excess amounts of spent pickle liquor in their waste water treatment plant
would result in pH exceedances in violation of their NPDES permits.
-------
Final Report
February 2000
Page 215
VI. ENFORCEMENT SUMMARY
The following is a summary of the enforcement response against the iron and
steel mills that were included in the study. The same study period used for the
compliance review was used in the enforcement review — enforcement documents were
reviewed over a five year period (January 1, 1991 - December 31, 1995) for four
integrated mills and three mini mills, and over a one year period (January 1, 1995 -
December 31, 1995) for ten integrated mills and 17 mini mills. Consistent with the
approach taken in the compliance section of this report, all 34 mills are grouped together
without distinguishing between mills with different review periods.
Only enforcement responses that were completed during the applicable study
period are included in this analysis. Because civil administrative and judicial actions
often involve lengthy negotiations, the number of these cases actually completed during
the study period and included in this report does not fully represent the level of ongoing
enforcement that occurred during the period. Also, in several instances major
enforcement cases that were completed prior to the study period {and therefore are not
reflected in this summary) resulted in compliance plans and guidelines that governed
plant activities during the review period, reducing the number of violations and, as a
result, the number of warnings and notices of violations that were issued.
It should be noted that the enforcement summaries cannot be linked directly with
the compliance summaries in this report, even though they cover the same timeframe.
Enforcement responses that occurred early in the review period may have pertained to
violations that were identified by the agency before the January 1, 1991 or January 1,
1995 file review starting point. Likewise, violations that were identified towards the end
of the review period may have been subject to enforcement initiated (or not completed
until) after the December 31, 1995 file review end point.
The enforcement responses reported below are classified as a Warning (a
potential violation is cited, but no actual determination of a violation is made; or an
actual violation is cited, but the agency has chosen not to issue an official Notice of
Violation); a Notice of Violation (NOV) (a formal, written notice of a violation is given,
representing an agency's determination that a violation exists — the terminology may
vary from one agency to another); Civil Administrative Action (an administrative
enforcement action which results in an administrative order or agreement); and Civil
Judicial Action {a judicial action in a State or Federal court resulting in a final judgment,
court order, or consent decree).
If a document indicated that a civil penalty was issued, this is also indicated in
the report. In some cases it was clear that a penalty was not issued. However, in other
cases whether a penalty was issued could not be determined. To avoid any
misinterpretation, all three options are tabulated. In most cases the civil penalty was
imposed as part of a civil administrative or judicial action. However, in a small number
of cases, a State or local agency imposed the penalty in conjunction with the issuance
of an NOV, and the tables below reflect this.
-------
Final Report
February 2000
Page 216
A. Overall Summary for All Media
Twenty-five of the 34 mills included in this study were subject to an enforcement
response finalized during the study period. Roughly half of the mills subject to
enforcement were integrated mills and half, mini mills. However, all but one of the
integrated mills included in the study were subject to some type of enforcement
response, while only 60% of the mini mills were.
During the study period, 172 enforcement responses were completed under the
air program, 149 under the water program, and 56 under the RCRA program. State or
local agencies accounted for the great majority of the NOVs and warnings (over 98%).
However, EPA accounted for a larger share {over 25%) of the civil administrative and
judicial enforcement actions.
• Types of Enforcement Responses
As would be expected, the vast majority of enforcement responses were NOVs.
The number of NOVs issued under the air and water programs (156 and 131
respectively) greatly exceeded the number of NOVs issued under the RCRA program
(29). This difference among programs mirrors both the relative inspection frequencies of
the programs, as well as the manner in which violations are typically identified within
each program. It should further be noted that, for all three media programs, a
predominance of the NOVs involving mini mills were associated with a single mill.
In contrast to NOVs, the number of civil administrative enforcement actions
completed under each program were roughly equivalent. The air, water, and RCRA
programs each accounted for five civil administrative actions involving integrated mills.
For mini mills, the air program accounted for four civil administrative actions, the water
program for six, and the RCRA program for ten (all ten of these actions addressed a
single mill).
Of the three documented civil judicial enforcement actions, the water program
accounted for two and the RCRA program accounted for one. All involved integrated
mills. While the air program did not account for any completed civil judicial actions,
there was one action pending at the close of the study period. This pending action also
involved an integrated mill. No criminal actions were identified during the study.
• Violation Categories
Pollutant emissions/discharges constituted the most frequently cited category of
violations in both the air and water program enforcement responses. While O&M/Work
Practice violations were cited frequently in both the air and RCRA program enforcement
responses, no O&M violation was cited in a water program response. Manifest, labeling
and recordkeeping were, in the aggregate, the most frequently cited RCRA violations.
• Process Cateo. ories
The major steelmaking processes cited most frequently among all three programs
were coke ovens and steel finishing operations. In the air program, the most frequently
-------
Final Report
February 2000
Page 217
cited processes were (in order of frequency) basic oxygen furnaces, coke ovens, blast
furnaces, steel finishing operations, and electric arc furnaces. Most frequently cited in
the water program were {in order of frequency} steel finishing operations, blast furnaces,
central treatment plants, hot forming mills, and coke ovens. Finally, most frequently
cited steelmaking processes under RCRA (in order of frequency) were coke ovens, steel
finishing operations, waste treatment plants and electric arc furnaces. However, most
RCRA enforcement responses addressed violations that were not limited to specific
processes.
Processes addressed in civil administrative and judicial actions by all three of the
programs include: coke ovens (7 in all), pickling operations (5 in all), and cold
mill/annealing operations (5 in all). At least two programs addressed blast furnaces (air
and water), basic oxygen furnaces (water and RCRA), electric arc furnaces (air and
RCRA}, and hot forming mills (water and RCRA). Multiple civil administrative and judicial
actions during the study period also include three air program actions involving emissions
from boilers, two water program actions involving non-process specific wastewater
treatment plants, and six RCRA related actions involving violations related to landfills,
waste piles and other storage or disposal conditions involving unspecified wastes.
The following summary tables (Tables 16-18} sort enforcement responses by
type of mill; the agency initiating the enforcement action; and the type of enforcement
response.
-------
Q.
O
a
V
s
LU
O
Iff
w
(0
Q>
5
03
•O
a
a
(A
.
fexgSs^g
flit
(O
00
00
10
CM
CD
00
00
CO
Bl
O
•
2
'o
'•5
G
111
c
.
£
s>
w
O
I
'c
I
tt>
•3
-------
o
o
~ o
fl) w. *—
CC 2j CM
LU
CO
o
0>
OJ
.a
01 •
cu
(A
O
a
to
0)
E
4)
O
UJ
(5
CO
t
fc
sis
^sH
fl«
f ^
ilpi
«i»?i
IbfS
'4#!Vi&g(X
H,,
*%£fip?
iifp«S|
iSi-2*
CM
O
CM
CM
(D
ro
CM
eo
n
CO
I
<0
'o
5
s
«
-
o
w
O
c
I
"o
c
-------
o
o
t o
o ^
D. >O
0) ^CM
DC § tN
II s
' .= ID to
U. U. Q|
00
m
-------
Final Report
February 2000
Page 221
B. Air Program Enforcement
(1) Overview
During the study period, air program enforcement focused most heavily on
integrated mills. There were enforcement responses against 12 of the 14 integrated
mills included in the study, and five of the 20 mini mills. Most (95%) of the
enforcement responses involving integrated mills and all of the enforcement responses
involving mini mills were State or local responses. All seven of the Federal enforcement
responses involving integrated mills addressed coke oven violations, four of which
occurred at a single facility. Roughly 75% of the State or local responses involving
integrated mills occurred at one mill, as did slightly more than 75% of the enforcement
responses involving mini mills.
(2) Types of Actions
There were 156 NOVs issued for air program violations. Of these, 137 were
issued to integrated mills, and the great majority (roughly 75 %} were issued to one
facility, primarily for either BOF or coke oven-related violations. The same facility was
also subject to three civil administrative actions during the study period, all of which
cited coke oven-related violations.
One of the NOVs issued to integrated mills included a stipulated penalty
assessment, and three were followed by penalty settlement offers. Also, ten of the
NOVs issued to mini mills were accompanied by penalty settlement offers. Of the four
NOVs with penalties issued to integrated mills, three addressed coke oven violations at a
single facility, and of the ten NOVs with penalties issued to mini mills, all addressed
electric arc furnace (EAF) and pickling emission control violations at a single mini mill
with operations at several sites.
Nine civil administrative actions were completed during the study period. Five
involved integrated mills, and four involved mini mills. In addition, three civil
administrative actions were pending at the end of the study period. All three pending
actions involved a single integrated mill and were initiated by a State agency. Four of
the five civil administrative actions involving integrated mills cited coke oven-related
violations, and three occurred at a single mill. Eight of the nine civil administrative
actions included penalty assessments.
No civil judicial actions against either integrated or mini mills were completed
during the study period. There were, however, civil judicial actions completed prior to
the study period at several of the mills, and one Federal civil judicial action against an
integrated mill was pending at the end of the study period.
(3) Types of Violations
Of the 146 enforcement responses taken against integrated mills, the vast
majority cited violations of either opacity or fugitive emission limits. (See Section III for
an explanation of how the overlap between these two types of limits has been
addressed in this report.) Roughly 75% of the NOVs addressing opacity violations were
-------
Final Report
February 2000
Page 222
issued to a single facility, as were slightly less than 75% of the NOVs addressing
fugitive emission violations. Of the 26 enforcement responses taken against mini mills,
most addressed opacity violations at a single integrated mill. Operation and maintenance
(O&M) violations were also addressed in a significant number of enforcement responses
(roughly 20% of the total enforcement responses). More than half of the NOVs citing
O&M deficiencies were also issued to a single facility.
(4) Types of Processes
More than half of the NOVs issued to mini mills addressed pickling emission
control violations (all of which involved one mini mill with finishing operation occurring at
several sites), and roughly a quarter addressed EAF related violations (all of which
involved a single site at the same mini mill).
Civil administrative enforcement actions focused primarily on coke oven
violations at the integrated mills. This was the case in four of the five civil
administrative actions, three of which involved a single facility. Basic oxygen furnace
(BOF) related violations were addressed in over a third (35%), and coke oven related
violations in slightly less than a third (29%), of all enforcement responses involving
integrated mills. The majority of enforcement responses citing BOF related violations
involved a single facility. Similarly, the majority of enforcement responses citing coke
oven related violations involved the same facility. Blast furnaces and secondary
steelmaking operations/controls are the only other processes that were frequently cited
in the enforcement responses taken against integrated mills. Again, the majority of
enforcement responses citing these processes involved a single facility.
The following summary tables (Tables 19-23) sort air-related enforcement
responses by type of mill; the agency initiating the enforcement action; the type of
enforcement response; the type of violation; and the type of process.
-------
o
o
«- o
o N
°- >-s
ni i_ CN
tr g w
II &
re
*
(0
«
(0
c
o
a
(A
0>
cc
111
_J
CO
<
UJ
cc
I
k.
»WM
<
O
.£.
w
V)
•a
as
E
3
(0
?scl«^
Stsge
f£:SS«
ftsssi
^8
'
CN
Cvj
«
E
D5
a>
c
in
tn
'c
I
CO
"5
4^
O
u
<
~m
'o
=5
>
O
•o
o
<
I
TO
O
CD
"5
S
U.S. EPA Headquarters Ubrary
Mail code 3201
1200 Pennsylvania Avenue NW
Washington DC 20460
-------
o
o
t: °
a >^;
a} »- CM
DC
CM
T= 1- 0)
W Q} (TJ
u_ u_ Q.
o
OJ
CO
4)
Q.
C
Q>
D)
*
CO
Q)
(A
O
Q.
CO
o
a>
E
v
S
O)
I
CO
£
3
,
I
^9:
§ga!
,i?'?< ' ;
ft> fr"*^
g
II
|3S
g
?«
Jt'-te
v^'sN
lip
.?3v*
lip
'
JfP<>^!t«
~!W
CM
to
CM
8
2
|
CD
b.
O>
10
(0
CM
'S
i
CM
CO
(D
"S
S
<
"S
'5
O
1
c
o
•§
§
C
'c
-------
o
o
*- o
ec -CM
H &
LL U_ |£
CD
W
O
Q.
8
DC
H-
O
CO
5:
*-
JD
«
V
0)
(0 C
«- o
CO W*
S* *
a tt
! i
"" E
4)
S H
m £
< c
P UJ
ro
&
2
a.
ry of
CM
Summa
- :r,', I'-W
was
ill!
^i
iS
;#|
iv--:i •
H
"
ill
^M
.,.
1*-
1P1
lil
•
CO
CM
CM
oo
(0
o
CM
n
.
ies
-------
O
O
tr § CN
c
c
I
u
c
-------
O
o
o
CM
.
U.
*
0)
Q.
O
CO
a>
U)
a
a.
CM
CM
UJ
_l
03
<
8
CO
c
o
Q.
(A
0)
cc
Q>
O
UJ
2
2
Q.
5
"S
a
«»
©fir
W|
'*
m
-
^SlCiaSaaa
••'. ::Ki*i;S
7VT'Tif>fi?S^
»'-O. *-l^.
J?Z*P?SS
ion
111
II)
III
ID
00
m
IN.
N
O
CM
CS
m
S
£
U
(0
CO
(*)
ro
(N
S
o
UJ
a>
>
O)
(O
CN
CM
CM
CM
CM
CM
o
c
o
CM
CN
W
o
o
CM
CM
CN
CN
CO
I
c
T:
«
I
E
c
3
o
-8
•g
« o
Q> Q.
cl
O O
•p o
II
il
nses in whic
of violation
c »
!l
« *"
U *-
is
O 3
5 _
.a ra
Is
= o
o S
o o
_JB Q.
£ 1
S c
J |
5 5
• 5
s £
-------
o
o
CM
[I u. oi
CM
CM
CQ
f
0)
a
JS
o
.0
10
0)
CO
Q.
8
0)
0)
o
2
D)
O
CD
E
CO
111
ill
sr;, -'•«
Ifti
ioi
ISZf'
1^*5
^^Pi'-
•slip.
UK
m
ii
fl:
Kit!.
ff^g'r'
r0i*ili
Ml*
•'
^•1
' •*>'
o>
I
^-«
'£
o
D)
C
'c
m
c
o
D.
O
CO
c-
o
c
4)
CC
O
a
01
CL
CM
I
I
I
£
€
I
tfl O
as a.
II
<0 g
« i
c E
o o
'& o
II
> i
s •*
§L£
S •-
g «
1-2
.
5*5
° M
S £
a c
1- w
-------
o
o
*- o
j £T CM
OC § CM
? •?, §>
C Q) m
*
0)
Q.
_ra
o
nses
£ &
O
O)
CO
CM
UJ
Res
LU
S
O>
o
<
>*-
o
to
CO
||S
9,
''^fc^^J^fSp
;-:;;*}*sEiS;!^isfffiia»
CM
.2
»
w
UJ
(0
o>
00
tM
CM
00
CO
CO
o
a
o
CO
r-
CM
CO
CO
CO
0)
v>
C
_o
CO
UJ
0)
00
O)
CM
CO
CO
CO
CO
CO
D)
O)
c
'E
3
m
c
0)
a
O
CO
CM
CM
OJ
c •
'a
a>
m
S **
s in which eac
violation is cit
gi
il
I!
O 3
.a "io
IS
O CO
^ c
U O
_« o.
'g g
3 »
> O
-------
•M O
a >
cc
<0 _Q
COO
BJ Csl
to
w
CO
4)
W
I
(0
en
co
oj
uj
UJ
O)
(0
PP
^
if
i
Sis
KS^l
S:*fi
lisi:
«S
ll
- *.
S
il
CN
c
0)
O
o
CJ
O)
CO
u
o
c
10
JO
CD
ID
£
c
05
CD
CO
o
in
o
u
CD
3
a>
2
_c
. C
o _
•o «
is
C q,
0 1
o o
5 8"
-------
o
o
*- o
C « CM
_ ^
ro -5 OJ
E a> TO
u_ u- Q.
O
O)
CO
CM
111
CO
<
*
a
a
H
(0
to
s
I
XI
I
o
a
(0
V
1
I
D)
I
t_
<
i*.
O
0
l
'
Hi
(O
(O •
CD
(O
ca
o
O
ta
'c
CO
•O
C
V)
01
.
TJ
1
ca
10
O
ID
-Q
5
M
CO
CM
O
8
to
|
I
£
o
13
~
i!
Sc
£ *
U CD
ID £
tB **
f. e
c «
I!
O 3
i. C
(U _
A 10
E S
3 *-
C „,
a D.
C? LC
S E
S c
I |
to c
* g
ll
-------
o
o
o
CC TO
CM
to
«M
3,
s.
CM
UJ
CO
*
0)
Q.
£
10
w
8
o
>.
J3
w
«
(A
O
a
W
a>
oc
+*
a>
I
UJ
2
O>
I
<
>*-
o
>.
o
E
CO
i
ill
jS5r?*;>*S
p;.iS!rii.1JS'.L"&'
«S^:»^
.rfS^SgS
';?~J
>
O
o
«
O
c
5
LL.
CO
2
CD
c
ID
Q_
c
(A
O
CQ
0)
CO
c
TJ
C
o
o
0)
CO
O)
c
1
o
LL.
S
CO
CM
O
c
u
-<£
\
O)
^
o>
"c
CN
m
CN
ing
Ann
•o
o
u
if
i
75
s
-§
s .
.i2 o
>
e c
<"
, g
a
c
- w
C m
O u
o o
_03 Q.
*S p
(C C
3P
." c
-------
o
o
to
§• £" co
DC § CM
CM
0>
!
CM
uu
*
0>
Q.
w
(0
0)
o
2
Q.
>
CO
0)
(ft
o
Q.
(0
o>
w#
I
§
H—
O
(
(A
ill
gsag*f,»;
% TE^SSK1
Tt*^5
ssir.
'
;:"o'-:oJSj:!
*.»¥??•
:.
i4ff^./i..'"&s-.ii r.
SiS";>?s? ;•*•«»;•
'fostii—s
Sl/^E:* rt r!S •
liMllS SlT)ffi3 ^5
:ix>a-«';
lUJSi*
^i^ei
%f»
i'S-'Si^
ID
O
U
OI
C
(0
'£
o
eo
CN
C
O
to j=
a> *•
Jl C
2?
c M
l!
01 *-
o »-
°i
0? _
.a to
I s
C *n
^5
>s
II
f f=
o o
11
-------
0>
D)
m
CM
«
m
«
o
o
CO
0)
(0
c
o
a
to
|
iij «2
09
2
a.
k.
<
M-
o
CO
CO
i
If
l!
•.Yiii-s»s;«;,
mm
.:
l
O'^k
S!»>
ofOpi
CM
CO
in
O)
Ifl
CO
m
(O
co
CM
CO
o>
0
CM
ID
o
J3
m
CM
CM
CN
£ S
Oi
CN
(O
M
O)
CO
0
\t>
CD
CM
CO
O
O
O
Furnace
at
m
£
c
O
m
a>
u
ro
3
U.
O
<
o
*-<
u
.32
LU
O>
_C
-------
o
o
SN
Q> I- CO
CC § CM
— C o
2 -9 o>
D>
(0
a
CO
OJ
Ul
Jo
I
w
(0
a>
o
o
0)
0)
CO
o
a
1
£
*c
iy
S
o
nl
to
I
tte
sW|
^«S&
SS
ll?|
«|
as
ill
iKf4
IP
im
fcj»C»
ft5
iv!S?
"1
ij
i.Qs;
it
. ._as
§.55
5^
ll
^;-T
jS?W
»
:>^JB-
^•v
ffeaj:
m
J^sa;
:i?*'I;
'fi^i
11
»:..s >''
iiii
HI
pis-ssp
l*?5>^
iiS'SS
rdjiS^SS
S"s^i=|
>•
C «)
2 -a
._ «o
ro
CM
n
v>
o
•s
o
5
in
01
c
2
'5
m
(O
c
(0
o
5
1
c
s
CD
o
T3
s-
•o
•a
a
.2 o
«
a
•^
o
•
Q)
.
;
Q. g
S ^
•- (0
c «
ll
o *•
C 0)
0] .Q
ol
3
II
2 £
-------
Final Report
February 2000
Page 236
C. Surface Water Program Enforcement
(1) Overview
Less than one-half of the 34 mills included in this study were subject to water
program enforcement during the study period. Enforcement responses were
documented for eight of the 14 integrated mills, and eight of the 20 mini mills. The
great majority of the NOVs were issued to integrated mills, compared to mini mills, and
most NOVs in both cases were issued by State or local agencies. In contrast, a nearly
equal number of civil administrative and judicial actions were brought against integrated
mills (seven) and mini mills (six), and there was a nearly equal number brought by EPA
(six) and State agencies (seven).
NOVs were fairly evenly distributed between the NPDES program (68) and the
Pretreatment program (63). However, all of the civil administrative and judicial actions
were NPDES related.
(2) Types of Actions
Of the 131 NOVs documented during the study period, 52% were associated
with NPDES permits and the remaining 48% with Pretreatment permits. Roughly three-
quarters of the NOVs associated with NPOES permits were issued to a single integrated
mill. Similarly, about two-thirds of the NOVs associated with Pretreatment permits were
issued to a single integrated mill. One NOV had a penalty associated with it (a $700
penalty was imposed by a POTW on a mini mill).
There were 11 civil administrative actions documented during the study period.
AH were NPDES-related and were fairly evenly distributed between integrated and mini
mills. Nine included civil penalties (three were taken against a single mini mill). The
penalties associated with civil administrative actions often involved stipulated penalty
payments for subsequent violations or for failure to meet the terms of an order. The
highest penalty documented was approximately 50,000 dollars.
There were only two civil judicial actions during the study period. Both actions
were brought by State agencies and involved integrated mills and NPDES permits. The
penalty in one case was less than 200,000 dollars, and the violations included
unauthorized discharges associated with the miscellaneous steelmaking and finishing
processes at one mill. This action required extensive corrective action at the mill.
The other civil judicial case had a penalty approximately 8 times higher than the
other civil judicial action, and addressed effluent violations, unauthorized discharges, and
reporting and permitting violations. These violations involved the blast furnace recycle
system, the central treatment plant, and miscellaneous steelmaking processes. This
action, occurring at the end of the study period, also required extensive corrective action
by the facility.
Several mills were operating under civil consent decrees during the study period.
In one case (involving an integrated mill) the consent decree resulted from a multi-media
-------
Final Report
February 2000
Page 237
enforcement case involving all three programs. This consent decree was finalized in
1993, before the review period for that mill.
(3) Types of Violations
Effluent violations were the most frequently cited type of violation in
enforcement responses for all mills. This is consistent with violation patterns in the
compliance section of this study. Over a third (37%) of the NOVs citing effluent
violations involved a single integrated mill. Unauthorized discharges were the second
most frequently cited violation category for all mills. As with effluent violations, over a
third (36%) of the enforcement responses citing unauthorized discharges involved a
single integrated mill.
The fact that most NOVs cite effluent violations is consistent with the use of
monthly discharge monitoring reports (OMRs) (a major mechanism for monitoring
compliance under the water program). In most cases DMR exceedances are effluent
violations, and most are cited in NOVs by the responsible enforcement agency.
Similarly, unauthorized discharges are most frequently identified through spill reports,
which typically result in NOVs, depending on the nature of the spill and applicable permit
requirements.
Civil administrative and judicial actions documented in this study also focus
largely on effluent violations and unauthorized discharges (NOVs have usually already
been issued for these violations}. However, these less frequent actions usually include
any other violations that may have occurred, and because the summary tables in this
report reflect the number of actions and not the number of violations, the predominance
of effluent violations and unauthorized discharges does not stand out as strongly.
(4) Types of Processes
The central treatment plant and the blast furnace related processes stand out as
the most frequently cited process categories in the water program NOVs. However,
over 80% of the NOVs citing blast furnace related violations involved a single integrated
mill, and over 70% of the NOVs citing central treatment plant related violations involved
another integrated mill.
The hot forming processes are the next most frequently cited category for NOVs,
followed by coke plant processes and finishing processes. Roughly 75% of the NOVs
addressing hot forming/hot mill related violations involved a single integrated mill. Over
80% of the NOVs citing coke plant related violations and all of the NOVs citing coke
plant treatment system related violations involved another integrated mill. Also, all of
the NOVs citing pickling treatment system related violations involved a single mini mill.
At integrated mills, the processes most commonly cited (in order of frequency)
are blast furnace related processes, the central treatment plant, hot mill processes, and
coke plant processes. In alt cases, a single mill was responsible for the majority of the
NOVs. Among mini mills, the processes most frequently cited (in order of frequency)
are the finishing processes and miscellaneous steelmaking processes (e.g.. ladle
-------
Final Report
February 2000
Page 238
metallurgy, desulfurization, or casting). Eighty percent of the enforcement responses in
which miscellaneous steelmaking was cited involved a single mill.
Civil administrative actions cited the same processes, with a more significant
focus on finishing processes (pickling and coating) but with no other major focal point.
The two civil judicial actions (involving two integrated mills) focused on blast furnace
recycling systems, miscellaneous steelmaking processes, and central treatment plants.
The following summary tables (Tables 24-28) sort water-related enforcement
responses by type of mill; the agency initiating the enforcement action, the type of
enforcement response; the type of violation; and the type of process.
-------
§"CM
-------
ego
O ° -fr
0>
+*
i
3
(O
tel
il
Hi!
' 'fer-^^^Vi.'.-l^iO
j&iHj*-«-8 *^
Iffesrt?
.«=!
.'•i*s l;iti;.t:^j^^*:!*J
ill?
(O
(O
m
•o
':«^
r
^
%
;aii
rJig*
^BSt^-y
>"-•;}
3g'£"
iiSO-l
fif«>i
Sslcfi
P
So
90.:
1P^
iSlrf
SK'
5-Wl'i!
.'.'5=r-
|SM
ii;
-J!>S.CC
"v^r.
||ft;||
::£W;'
09
CM
I
to
00
09
CM
O)
00
(D
03
CM
(O
§
"5
'5
1
">
O
g
I
'c
I
U
to
O
ui
O>
I
m
-------
(0
a
to
CM
HI
CQ
<
9
0)
O
Q.
10
O
0
5
0)
0)
»
O
a
(0
4)
5
D)
O
£
0)
o
CO
E
3
(0
«Mtelii
am
»-
I
J
Au&&>':-';' •'
#*?'»"-
Sjft
^SS^JTi
ss=(
ti5
ji-iai^**'
«%I
iS
'SfSR'4
^}"i
• "~.*>"-_-^S1L» •S*?i!x'.i
SB»rre—;i»*, •" ijf-t
liH
-•rnW^
ill
jjftKP^w',
^oifSiS;
^zjSSasE
£:'iili»
*.<
ll!
'
CM
CN
(D
O>
CO
in
CN
I
B
o
o
Dl
•o
0)
TJ
III
•o
1
-------
C 2
a
a>
(0
O
a
(0
Q)
H
O
M—
UJ
£
£
o>
I
s
I
CO
3
(0
.'.kssjssi^r^j'fi. •
lEsSyit: TtViFHi
i^^rSt."
;53Sr|^HS^
-------
co
* 2r£
g §2
IT ^
v
0)
(A
O
a
CO
0>
Q.
a
w
I
_. Q
CM ^
(A
Q) Q)
O) CC
CM
LU
CO
i
o
0>
a
E
tfi
11
«M
g3MI
S^s
*i?,.s
l£PSs-. '
lSi;
1T^
JSsfi
i:s •"?>[;
Isi
fp
»i?
r.:H2
98BI;'
1S|«:i,
i'fciE '•« :*" «53
5!1$tp,
asj^vf
ips3»:ir»« (
:«isp!p
A-fc-f v-.. i£ J» <•
feM&ik
>!*.1-
gSfr
i*wA»
(^W
J.V'TTV'., -rs^^S
•Sfsfcffias-"
e-L¥»
fesssa
7r «!«!<»>»*
*ftS?g«s«
^«sS(jcf
feifc'^-;;-;i:-!«u
fiiii
M^&sbiyj
JilPtOl
' ?=.:#< .«C
M»%&*i§|i
^i$ip
" .iSiW*!
sBJKifaas
^^
•?Zfef|g;
g^^^;.
S2^S:!l'
j^iSss
'!1^1^
^g^Q-/2£
ijp&gv^:
o>
ro
O)
n
o
ID
.c
o
10
CM
(O
o
o
CN
a
ID
n
w
o
a. •
E
IB
C
0)
T3
3
0 <0 rr
I 5.S
22
-------
eg*
o
TO TO
.£ E
u. .Q
a
*
CO
CM
<
cc
0)
ss
O)
p
9
s
»^
O
>
CO
E
3
*£
m
m
'• • a) s. •
jj£&c3
Is3!
i»p3%i
ii
U!mi:-3«-«iJ'!f
in
1111
^jv>-« -;*£) sr ;ifc*-.i
iii^
~^
*> '«y,» '«<«^s*^;< j
ills
^•0>iiXi»i
a^Sr-Ii
a>
ro
CM
o>
o>
to
C
"c
I
_g
8
-------
qj
in
*
CM
u.
(D
CO
V
O)
(0
a
W
Ul
00
(0
o
o.
0)
a
(A
4)
(A
O
a.
0)
H
o
•£
UJ
2
O>
O
0
^
5
to
aS-
I*
<.ji
.-.:>•!•}.-•-
J".^?
ft.*'*—'--
«*&
%£•• '*
S*\|Sf.
"!r^
•t- -
Iflpl
IN^SJ
•KiSS
igij
SsSil
P3;C
sf^.
il«L,
ifil^
i-j-'Sj
f^rsSl
.;.
'WOi.JLi^E?
Iftftpsig;
%£?&&]
tfR&'&ii
^•N;Sf
^^?Kri.'-i'L^-.!'iti
>X^**.-'WK^t2!
ilit
J
«JSEJ«£tMM»S
ffl*SS-i«5
itioiSftst
$z^Si
l
iliiSsi
S.^i.TT^.Ai.Sl;
-SiNs^i^h-Vi,.!.-.
•E
-------
§»
75 5 *
c 3 Q.
D>
CO
a
C
o
Q.
0
0)
DC
a>
§:
<0
Q)
W
O
a
03
0
O
£
£
o
£
<0
I
(0
II
ill
IS
«?f
fi;
*.zt3-\*i?7'zr-
*&n
'•••giO9
Ǥi*
J-rtp&ai: J,
ffa^Sl
Sffi
tSi'SajgWH'
S^S^-^f
s«'*H ,sT7jT. S*<
lii
SZlPlSi
i-lJfgii^
S«S
'^.'tfe^^NlR
•••^ir-*iii'-&iB¥
fctaj^tt-iSa
1??i2r;Sii=
J*^liPf
O'S^E-
.re-sia^.
?:Ss5i«
'jna8a~"
till
»sw
'^fi^iic^^f^i
^^^-•.WSfa.yr^ii:
"> ^s£2-S* £.:•'.!£•
"is*iii'
jfJ^^jPJ^'i^j-
00
9
00
oo
CO
m
*
8
en
*t
CM
*T
N
«J-
IA
CM
r-
co
CO
CM
•D
V
%
1=
2
'E
I
(C
o
at
c
c
^
<0
to
I
"5
c
-------
O <-* ^j-
CJ) CM
- frj
{Q (Q ^Q
ill
0>
c>
(0
a
CM
UJ
_1
m
I
c
o
.a
(0
Q>
(0
C
o
Q.
«
0)
cc
E
CD
E
CD
111
<0
O)
I
a
CO
SB'S
•»%&>•
"ijS*
IS
Hill
CD
C
"E
'
ication
0)
U
.CB
3
T3
0)
J=
U
CO
n
C m
O in
«- C
en *;
0) C
= ?
ro e
> g
0) "
S o
,
-------
03
t
TO CO
c 2
u- a
0)
li.
*
0)
Q.
.0
S
o
CO
0)
(0
0
O)
(0
Q.
CM
UJ
_1
CO
4)
8
2
O)
o
0>
I
CO
E
3
%,
wsifi
•«*•
>
ed
Unautho
0)
o
u
£
O&M
s
o
4-
I
o
c
o
•o
I ...
C C
•o o
•O Q.
« £
If
<-• C
ID o
1 |
> £
O v
c
o
c ™
'^ O
in
c
o
i |
U H-
I £
o 3
||
|l
£ i
I §
-5 _0
-------
0
Q.
a>
g
0)
Q.
I-
O
1
O
.a
CO
to en
Q) »
^^ fl
CM ^^
(0 4-
a c
i °
r> «gr^"
i|||fsi
li!
ftiSlsisr
-•iisfe
("TT^BSS
--
' " "" ""
^yssfcsls
fi^Sp
00
00
<0
a
CM
tM
a>
c
"5
2
§
i
u
^
T3
^:
u
10
u
c
(0
I
(3
_3
>^
LU
I
o
+•»
1
S.
O)
e
1
u
13
CC
D)
C
. O
Q.
Ol
(5
I
o
I
10
c
O
U
.*
I
o<5
O
c
"5
s
a
o
•a
-------
03 ra
C 3
4)
a
I-
0)
(0
8
O)
(0
Q.
00
CM
UJ
OQ
<
V
(0
O
a.
w
a>
UJ
S
o>
I
(0
1
•*&"-*£'• "«:3:
SS«*?w*'-t»*i.'
iSSi
fill
CM
CO
o
CM
c
to
O
u
J
CL
O
n
o.
c
W
in
CM
0
n
in
CM
0)
CM
nace
Bla
^
Blast Fu
CM
CM
CM
fO
0>
u
ID
C
c
0)
O)
>.
X
O
u
'w
0>
i
o
s
CO
CM
CM
01
c
ZK
01
iscellaneous 'S
D)
C
S
Miscellane
RS/TS
CO
to
CM
n
m
CM
CM
ming/Ho
Ho
3
c
"5
4»f
o
c
09
•a
.2 i
-------
0)
CN
TO
JD
V
o>
CO
D.
00
CM
UJ
*
V
a
(A
(0
§
o
(ft
CO
o
a.
0)
0)
cc
(D
O)
8
a.
IB
iisfe
II
1
'-«
m
mm
?*i"
ll
*SNc^2l
ftia?«^f
•.. «.?,*S>c:.a: " •!>.••>*••> .?*«J!;
o
E
o
CN
CM
O)
c
c
•o
o
o
ID
c
2
o
u
?
1
'£
E
I
CD
C
C
•D
C
i
0)
o>
c
Coating
Finishing
.§
al
T3
0)
•E
o
a>
I
D
O tf>
S
o
o
1
o
eg <0
.<« O
S *
8 £
a
o
£
CJ
m Cfl
?•? M
c
o
«
w .a
»- E
O 3
>. c
^2 ~a
£ €
3 «-
c ?
f?
««— U
£ S
» t!
i
11
I- 0)
-------
ro
.£
u.
if
0
O>
CO
Q.
!
00
IU
CO
*
9
a.
CO
10
0>
u
o
.0
(0
CD
CO
CO
OC
I
0
o
c
u
2
o>
o
Q>
15
CO
3
SatiSi
l
1
•AKT.f*f'J,
P- aS '• r™' ssr<
liiii
2
a
CD
i
o
(3
CM
CM
ro
CM
Conveyance
co
1
O
CO
ds
V>
<#
in
a>
c
is
CD
•3
i
V
O
andfi
0)
O
0>
O5
s
CA
•o
O H
CM
CO
D>
1
a
c
CD
C
CM
(D
CM
CO
CO
'a
I
o
cc
a>
ll
49 o
Q) 0}
O oc
"S
I
I
I
JS
-w
u
c
o
I
ra
o
u
o
-------
co
Q.
CM
0)
D)
a
i
oo
CM
LU
CQ
0)
o
o
(A
V
W
O
a
(0
Ul
s
o
I
(5
3
(A
.CM
fcf &>|s
i§!
^21
fei
IS
ss-
iiaSI
/l?
.^•'idissm
-J^^-S4f:;li^|A||;
c
ID
CL
0>
^
o
o
C
(0
O
0
C
10
c
(A
nace
Blas
CO
DC
O
O
(D
«
CO
c
0)
X
O
n
CD
tn
K.
£•
c
0
2
X
O
ro
CD
«N
00
CO
oo
10
"5
*4
y>
(A
3
O
0)
C
CO
king
0)
0>
S
Miscellane
RS/TS
cs
ng
Fo
Ho
.£>
3
C
75
o
o
Q)
O
O
•o
:§
Q.
« 2
us S
If
"5 «
S^
-------
o 2 i"
Q.O CM
to CM
_ J^ O>
C 3 °-
il £
.0
CM
*
0)
D.
>
CO
»
0)
o
o
CO
o
to
o
Q.
n
§> ;
CD
Q.
i
00
CM
LLJ
DO
0)
U
UJ
S
O)
o
H-
o
E
Siff
iasffeySI'-
if *PIL.
01.--J fl",jSsj.^"*
v-'iiW--
CO
DC
O
f
E
o
u.
S
X
(O
to
(O
D)
c
S
•O
•5
O
O)
c
'
o>
c
<
T3
O
U
O)
C
c
LZ
2
o
s
c o
CM
CM
I
if
a>
_c
_o
!
c
CM
n>
c
'S3 '
ID
O
u
D>
C
C
il
O
.o
•D
09
U
0}
c
CO
c
V
U
o
IE
s s
.c «
*; >
O
3
C
"5
4-*
O
U
JO
"5
o
c
o
•D
ai
v
•2a
it
21
Q.
ro
o
5 'i
» s
le
Si
2 i
o _
.Q 0
E o
3 •»
C j,
Ir
7= vt
§ S
*- c
U O
^ Q.
7 HI
w k.
8 c
•2 8
ID C
-------
r
~ o
o 2
-
05
U_
CO
1
CM
tN
Buildings & Grounds
c
V
a
•D
j
0)
c
0)
2
CO
1
I
I
"5
a>
^
•E •
8
0)
oc
a>
— c
to *^
s b
0> o
O QC
Miscellan
o>
1
icated
ocess
XI
3
C
"55
+•»
o
I
o
•c
1
•a
o
10
t
H
II
o i-
i; o
•sl
JD CO
£ S
D *-
only
lect
- S-
«*-, 0}
g> «
if
!i
00 v-
3£
« c
K CB
-------
C
U. .Q
4)
a
(0
(0
0)
o
o
J3
(0
0)
CO
O
Q.
0)
0)
O)
00
CD
<
O
O
"c
LLI
(Q
cb
I
I
,5
5&C*
ii
usdjy^
S3
HI
"m
!*fSsiP>
Pi
.IjiiBy-.'i -«siS
.^mapi-iifii
(D
O
O
CO
c
-
o
O
C
ID
Q.
C
cn
U)
IN
8
LO
CM
cn
CM
Blast Furnace
IT)
(A
EC
o
u
(0
I
LL
to
10
ffi
CM
CN
CM
CM
CO
O
CM
nace
Basic Oxyge
urnace RS
Basic Oxy
oo
CM
CM
CO
Steelmaking
lane
Steelmaking
Miscellaneo
RS/TS
to
CO
CM
in
CO
CO
to
CM
CM
CO
orming
Ho
U
0)
V
v>
in
.52 O
S *
I!
S =
51
a. o
>*!=
~ S
w
S a>
c •>
Is
§ a
>- (B
-
O 3
w C
§ s
+* c
U O
^Z (Q
01 O
^ w
a »r
-------
g
if
00
CM
ID
ffi
<
•ocess
o
a
m
0)
cc
«
a>
o
£
I'
O>
O
«2
I
*o
|
W
SiSi:
te=
|1
•3pCiO>iS
IPii
o
X
t
1
o
o
OJ
CM
CM
CM
Annealing
o
o
o
CM
CM
m
O)
c
a>
'£
'c
£
o>
O)
c
o>
c
i
c
CO
CM
CM
TO
C
O
en
c
!c
CO
c
CM
CO
m
O
-1
ct
»
t^
"3
o.
|
S S
5 §.
O co
3
C
o
V
O
O
0
o
T3
-5
•a
S »
|£
II
fe *3
.E£
CO '~
CD w
s s
Is
8*
CD *"*
•s £
O 3
w C
5 "S
E S
3 «-
C »
o •£
"? <"
ig
t- C
u o
|§
* S
s £
H §
-------
C
O
00
ID
U.
U
CO
*
0)
w
(0
0)
u
(A
V
(0
i
w
O) +<
00
0
O)
(0
a
J)
:,"fi!J;'^.i
m
£=i
jSWi
IfSl
#a*
|s|
I
«f
§P
ill
l
. .>;, w*i
iii
•£,.
iiii
agbejigEj
^OfEM'w':
psfdtSwes
izSi
^^lig
f
c
o
(3
(N
CN
CSJ
CM
u
I
c
o
o
I
o>
u>
n
10
•o
2
o
05
'5
m
(3
TJ
C
<0
01
c
o
O
ound S
de
-
S S
O 1-
(0
(O
«J
I
ct
o>
c
Moni
Q>
C
V
(S
IA
CT>
dkeeping/
O)
^: c
§
Q.
49
0 OC
cel
i
J3
° I
^2 15
!!
u o
O Q.
^ »
O V
t» *;
* £
-2 ?
>l
O w
S £
^ c
1— «3
-------
Final Report
February 2000
Page 259
D. RCRA Program Enforcement
(1) Overview
Less than one-half (13) of the 34 mills included in this study were subject to
RCRA enforcement during the study period. This is primarily related to the fact that only
17 of the mills were inspected during the applicable review period (all seven of the five
year review mills, but only ten of the 27 one year review mills). An enforcement
response was documented for nine (64%) of the 14 integrated mills, and four (20%) of
the 20 mini mills. This includes three of the four integrated miils included in the five
year review and all three of the mini mills included in the five year review. Also, an
enforcement response was documented at six of the ten integrated mills included in the
one year review, but at only one of the 16 mini mills included in the one-year review.
The greater number of integrated mills subject to an enforcement response may
partially be attributed to more frequent inspections of the integrated mills (ten of the 14
integrated mills were inspected during the review period). Although there were more
integrated mills than mini mills subject to an enforcement response, 35 (62%) of the 56
responses involved mini mills. This is greatly influenced by one mill that was subject to
24 enforcement responses during the five year period. The large number of enforcement
responses attributed to this one facility may be due in part to the fact that the facility is
comprised of four non-contiguous sites, and each site was inspected and cited
independently.
All but two of the RCRA enforcement responses were initiated by a State
agency. This is probably due to the fact that all the States included in the study have
been delegated RCRA authority, and, therefore, the vast majority of inspections are
conducted by State officials.
(2) Tvoes of Actions
Of the 56 enforcement responses documented under the RCRA program, ten
(18%) were warnings, 29 (52%) were NOVs, 16 (29%) were civil administrative
enforcement actions, and one was a civil judicial enforcement action. In addition, two
State civil administrative actions and one Federal civil judicial action were pending at the
end of the study period. Civil penalties resulted in 15 of the 16 civil administrative
actions as well as in the one civil judicial action. Six of the 16 administrative actions
with penalties involved integrated mills and ten involved mini mills. All ten of the latter
actions involved a single mini mill.
The one civil enforcement action finalized within the study period involved an
integrated mill and the failure to perform corrective action plan requirements regarding
the disposal of waste ammonia liquor (and possibly other wastes) in violation of both the
Safe Drinking Water Act and RCRA. It concluded in a stipulated penalty settlement of
$3,375,000.
-------
Final Report
February 2000
Page 260
(3) Types of Violations
Manifest, labeling, and recordkeeping were, in the aggregate, the most frequently
cited types of violation in enforcement actions for all mills. This is consistent with the
compliance analysis included in this report. More than half (55%) of the 22 enforcement
responses citing manifest violations were associated with a single mini mill, as were
more than a third (36%} of the 14 responses citing recordkeeping violations.
The next most frequently cited violations were permitting violations (42% of
which involved a single mini mill), followed by spill prevention and storage violations.
This finding is also consistent with the compliance analysis portion of this report.
{4} Types of Processes
Steelmaking processes most frequently cited in enforcement responses under
RCRA include (in order of frequency} coke plants, steel finishing operations and electric
arc furnaces. However, the majority of the RCRA enforcement response violations could
not be linked to a specific Steelmaking process. Most of these violations involved
general program deficiencies that would be applicable to the handling of any regulated
waste at a steel mill. However, in some cases cited violations pertain to waste piles,
landfills, underground storage and similar site related conditions, where specific
Steelmaking process wastes have been combined and often can't be identified because
they involve historical land disposal practices for which there are no records. There are
14 enforcement responses in this combined category (five waste pile and landfill related,
and nine general buildings and grounds related).
The following summary tables (Tables 29-33) sort RCRA-related enforcement
responses by type of mill; the agency initiating the enforcement action; the type of
enforcement response; the type of violation; and the type of process.
-------
o
o
*- o
•
CM
0)
0)
c
o
Q.
w
0)
fiC
0)
o
£
"c
UJ
S
ra
o
g
O
cc
15*
3
CO
$
**
(/}
•o
a
i
a
E
3
l
O
CM
CO
in
to
CN
O
TJ
O
T>
C
to
(0
C
O
a>
CO
o
o
z
'£
<5
w
o
"S
2
05
O
-------
o
o
*- o
o N
OC §
O)
(0
d>
0)
o
Q.
W
0)
oc
E
4)
O
c
IU
o
OC
"S
(5
3
(O
IK
m*f^
t«E St «!;>.••
>•- ^S^(0>!^:
S^SS"
"
"91*0 •:»'•
o>
CO
in
O)
in
O
CJ
.
•o
o
•D
C
n
CO
I
s
.E
i
c
'c
I
10
Tl
0>
£
c
(0
o
-------
o
o
O
"
CC jo
0)
w
I
0)
Q.
H
«
£ I
g> tt
8. £
J. §
CO o
uj S
03
<
ua
D)
O
QC
O
CC
5
(O
V-ft
15*^11!
i siCiSsS'
•35c*>i!.l«=»i?:*?
ill
.
,«O "ttSf;
'ifcaa
S^SSWiSJ
III!
-j*'Trf.
., O E .»
•*•• -!..• ff.f -i-VMSS•'.-..
.:-V'"-i>-.K^?N^^
o
oo
CO
£
o
c
o
o
n
o
1
a
IB
•o
a
o
a
o>
5
a
c
0)
a.
o
-------
o
o
~ o
5 N *
dj i-
-------
O
O
*- O
OC § CM
1 -I §>
•= ,? «0
U_ U- flL
a
i
•
CM
to
*
V
a
o
1
"o
w
(0
o
Q.
<0
0)
oc
C
Q)
O
O
n—
LU
2
OJ
o
DC
o
cc
CO
E
3
CO
M"S
Si?S..'^
?i&[
"iF-:
A*
WV'S.-i
If^6
s^J^sd
SffliiE^
'£?.', ».'&%
8*5
I
.?*:*• ;.«a»v!!l!S.
Si
ii%
IS^JS-Ti^Rfi .^
CM
O>
C
<0
O
•E
o
O
o
CM
ra
c
JQ
ID
tN
CN
ID
CN
O)
C
I
CO
CO
O>
C
0)
£
a.
•O
O
s
oc
CO
|
o
o
I
o
to
o
T3
1s
II
o a)
'^ P
i o
Is
•1.1
"c »
1 1
Q) ••
1°
O 3
i. C
Q _.-
J2 a
Is
C (B
<-> C
o o
» a
-------
•M O
ItS
rr as CM
-Jo
LL U- (l!
o
>»
(0
0>
(0
o
t- »
0>
CD flP
o> *
°- «
: E
0)
o
1
Ul
s
O)
o
DC
O
CC
5
CO
at
to
ii
SJi>
~"
.._.
^g»f:
l«iS»
j
10
c
o
v>
c
Q.
CO
I
a
CO
(O
O>
10
O
*J
CO
CM
|
<0
O
5
>-
il
~ s
•c .2
CD <-
s S
^1
« >•
i"!
o 5
S _
a to
Is
^ w
C Q>
O en
JO
^
s I
Is
-------
o
O
*^ O
OC ra CN
«i »
•- .? °3
U. U- Q.
CM
O)
ro
Q.
i
CM
CO
UJ
CO
H
0)
Q.
>
I
"o
(A
0)
(A
C
O
a
v
I
o
"H
tii
I
<
cc
o
DC
<5
E
=j
li
mm
S«!Sa
<-KOBf-!H-:
'3!.«^-:'^
SSglfvg:
*-SSiSrS'
o>
10
.9
O
i
o
1
o
Q.
O>
c
5
**
'c
o
E
CL.
CD
g
tr
c
01
c
'S
*-»
§
O
>-
CD
C
o
I
o
•o
IB
SI
.
§1
*: o
o »
o »-
.2 c
•£ .2
c •§
»>
l|
i;
£ »>
Li
O 3
v- C
E S
3 e
H
«v C
o o
IV Q.
C 09
2 S
C6 •£
O C
= I
S
.55
-------
o
o
~ o
o N
°- >•%
fl) b. 3S-=S
%*«Ssi
ifliWJSSWS
l-ZjCi'lg,.
c
o
c
o
c
0)
'a
cn
c
o
Q.
IA
Q)
oc
Q.
CO
CM
O)
(0
CM
(0
o
4)
4^
en
I
8
10
E
c
"3
c>
o
0)
o
I
£
o>
S
S
c £
•2 S
II
> £
•85
0) *-
co '5
« »
•^ £
jc .9
S S
e "5
'
I
0) **
I!
C £
ll
E €
3 *
II
§ 8
II
0> V
3 S
-------
o
o
o
jo CM
2 -° o
E ® ra
. u. Q_
2
.E
u.
(0
0)
TO
(0
Q.
M
W
UJ
_J
OD
<
0)
Q.
15
"•P
(0
(0
0)
OT
C
o
Q.
»
0)
cc
+*
o
2
Q.
<
DC
U
CC
(0
E
3
W
'»sf
i
•>•, -suj(
ife
is:
saag-sa
ll!
ispi
Mil
'*' M'-'v^'sr-J-^^-'^c^
CO
CM
CN
m
?
c
'
en
c
CM
CM
CO
(O
a>
(O
ani
CM
ing
oni
CD
CO
CO
CN
co
CO
ing
Pe
CO
(0
Recordkee
CO
CO
Con
da
Sec
fe
J3
<5
3
5
0
o
u
c
55
10 ^
.2 g
H
> g>
s *•
§:.£
£ ffl
U *—
11
- s
•S -2
li
n
I?
•si
i-l
o %
S §
£ &
£ £
S c
ll
Ss
3£
10 C
I- w
-------
o
o
o
DC Sj CM
.0
CO
§>
(0
a
CM
CO
111
00
*
fl>
a
.0
+3
jo
.o
o>
01
10
o
a.
w
at
a>
U
£
D)
O
O
GC
c5
1
''S'
fSS...
IS
151
&
"^,^51^7
l»
1
li1
^SP'
fiiti
,
i&M^&i
a
II
'SJ-
yS
35^ *mss*
«fe^jL*T-~™J
10:
'Hoi
f
CM
-------
o
o
o
DC « CM
•5 £ g,
Q? to
IT U- Q.
HI
_l
<
*
0)
Q.
J-
10
10
8
o
£
CO
0
0)
c
W
l_
o
2
Q.
cc
u
cc
I
I
CO
? »*<
:S.f.VSifC5
CM
tv
_w
0.
o
o
o
nace
m
_ra
CO
O
CO
ra
cc.
o
O)
_e
"5
2
I
0
O
f
cs
o>
c
u
£
CO
"c
CJ
«
if
CM
CM
CO
•
r «J
0 T5
•
N
i X
o
£
f
3
C
1
o
•o
•o
£ .
_ c
2 o
|!
li
O 0)
« s
15
0)
"5 3
L. C
If
•& r
f2
S g
s i
0) Q.
^ 01
o £
8
15
£§
-------
o
o
o
-
CC. § CM
«J 5 oj
C (0 m
0>
O)
I
m
CO
111
CQ
<
(ft
(A
V
I
o.
0)
«
CO
O
a
in
0
V
o
ail
fasi
P§i
"VJ5SSSS
c
CD
(X
1
m
•o
I
+*
c
13
C
2
O
_^ Q.
« e
= •
eg o
11
oo
m
(N
|
1
O
=3
to
O)
c
CD
ro
o
JD
3
o
CN
tN
surance
o
I
pecting
D>
_C
15
'
s
ID
U>
0
M
CM
CM
est
§
o
c
B
2
a
.c
w
•fc"
o
JD
£
i-
•d
CO
•c «
13 0)
• c
4= «
SCO
f
fl) •*
I!
o *«-
IS
i!
E
3
7 IO
ll
u o
O Q.
^: co
-------
o
o
O
DC S> CM
"P -S &
.- ,P «
LL. "- Q.
I
w
in
2
Q.
0)
o>
(0
o
Q.
10
O) *-
co e
Q. «p
: E
(*>
CO
IU
CO
o
01
2
ra
p
cc
O
cc
(0
I
.«aM*\i&*l°^S!£
mm.
111
&»fr
*:a»>.-*!^
foftgicJ
1Z^|S
4)
O
C8
C
1
g
a
c
CD
C
o
'I.
o
u
0>
DC
tt)
ft)
D>
C
'£
o
0)
c
a>
(3
£
c
'5
CN
(N
ID
I
CD
ts
CO
V
ft)
O
'o
Q)
I
C
03
x:
o
o
•a
.2 5
I!
2 H
-1
o . C
0) _
n £
O (Q
O O
w a.
=: »
£ £
•i E
> g
.2 S
S £
CO C
I- 9)
-------
O
O
*- o
0)
CC
CN
CO
I
V)
s
Q.
>
(0
V
tl>
o
o.
o tt
D) +4
« c
Q.
c
~a
9
c
c
•o
o
o
f
at
CM
CM
(S
CM
Finishing - Pickling
Coating
Finishing
S
Hazardous Was
(< 90 days)
o
k.
0)
s
0)
-§
1
•u «)
•o a
« g
.2 o
a
"5
x: =
V a>
I I
I!
£ £
« *i
-------
o
o
*- o
1» f%J
O ^
O. >
5 |
(0 o
C 133
IT u-
CO
*
0
a
w
0)
a>
u
o
IT
(A
V
10
- I
CM $
O CC
O> +j
UJ
_J
CO
<
0)
o
o
H-
Ul
s
O)
o
cc
u
cc
I
CO
"5fe»!l
<;K?
m
Si
S&jf
§©=!
BgESSw;
i&gjssili
•*: "ip "*' ' ^"-^fei'M'S"-
c
a
2
H=
I
«>
Waste P
Surface
Grounds
M
D>
m
aborato
Closure
CO
CO
ance
inancial
ing
General
CM
CO
Ol
c
1
Gene
CO
£
o
c
o
T3
•o
g
IB
.S2 o
i!
se
a|
«t- fc
o g
«
qj
1 5
c °>
.
-------
o
o
*- o
rl CM
0}
DC
Cf*-
2 CM
ro
a .Q
C o
iE u. Q;
U
n
m
UJ
OQ
at
a.
to
w
v
o
o
w
O
a
(0
a>
cc
**
5
a>
o
s
O)
o
cc
o
DC
(0
E
3
(A
«
IB
t«
?:**•
A
tSI
H
"S&>l'»
,
llj*cAli
ppSdS=l
ftsissisa
i~2"0)
B'-^^???'CS"«»ftSi'i
&:M»^i^i'»iiJit;
fotiHi
^Z)>iSSj;':
E
o
O
m
o>
'&
.tr
I
<0
^
c
c
_ra
a.
I
cn
'I.
O
O
CD
DC
c
9
O)
O
a
03
CC
a>
C
a
a>
c
'£
"5
1
o
^>.
2
<
ID-
-
I
c
1
o
o
o
TJ
0)
•o
09
a
v 5
a> 2
11
-------
o
o
+- o
_
rn
CM
5 -g 03
•— .? «
U_ U- Q.
a
m
fl»
o>
a
Q.
i
i
co
w
ui
ea
<
a
f
v>
w
0)
(0
o
a
w
a>
0)
o
UJ
2
TO
o
QC
O
cc
(5
E
(0
II
' ";"«Lrt*^ij1
' .•i'u.7;;iljJ.''?!-
i2?^ill
vil-
^^^'i^tWv'9
JSFp «t;f>!
SiZ-iO.O
flSysrtS^
p'r—*'^.n-> J»S
*«»
CM
e
ro
_
O
u
V
u
(O
to
_(D
OQ
O
CO
CM
<
UJ
CN
TO
_C
o
c
CN
ro
c
u
t£
TO
!£
CO
'c
(D
O
U
CN
CN
CN
to
I
C
g"
O -O
"So
« v
JL — •
o
I
c
"5
o
T3
s
•S
"a
ID
Sf
*- c
£ °
o ffi
•*
g-s
e g
o ii
3
= ffi
O %
~ e
o o
a> a.
II
§^
47
o E
> S
n c
I- «>
-------
o
o
*- o
o^
a >
CN
§
£ CD
il U.
0)
Q.
(0
0)
0)
»
«
c
o
-o 8-
m a
o OC
o> +*
(0 C
d> (U
• i
s g
CO
<
Ul
2
TO
O
2
O
QC
a
3
w
I?
'•
!fplp
l^iisaiE
en
CN
CO
CN
O>
co
|
c
"»
s
CM
eg
CO
CN
CO
CO
CM
10
m
es
en
CM
CO
CM
C
n
eatment
0)
ra
«
to
10
;=
T3
5
ce Impound
to
1
o
=
w
m
O
J3
(0
0
ance
5
ID
'5
c
CO
nspecting
£
3
en
"5
JD
JS
CO
V
O
Mani
Q>
C
»
0
-------
O
o
O
OC § CM
- §>
0)
O)
03
a
CO
CO
LLJ
a
w
i
e
CO
0)
w
C
0)
V
o
111
I
tm
2
Q.
s
o
cc
10
w
,
m
•»
At"»S»*S
•AS'.W'.i
«w,vtsr«f»i!ij«£K1*
nil
.
jf=-fsi
flli
:k~,:.E-(3is.*st
O>
_c
o
.t:
o
C?
CN
a:
D.
ID
a>
C
0)
0)
c
CN
CO
'a.
o
u
01
oc
a)
O
CO
CN
O
D.
0>
OC
v
O
CO
CO
c
'E
a>
c
a>
O
CO
CN
I
1
0
I
a.
en
o
l_
01
I
c
1
**
o
O
o
T3
1
•o
a>
£ •
•o *°
•o ®
IB g
~ g.
W (D
S £
8E
51
o o>
u
f»
ll
J =
i?
i"
C an
(0
W
II
g a
E a
E S
II
S "
1°
!l
5!
II
>l
I
> »
> o
i o
II
-------
Final Report
February 2000
Page 280
[This page intentionally left blank]
-------
February 2000
Appendix A: Glossary
I. Air Program Terms
Air pollution source means any specific emission point where pollutants regulated under
the Clean Air Act are emitted.
Continuous Emissions Monitoring System (CAMS) means a monitoring system for
continuously measuring the emissions of a pollutant from an affected facility.
Continuous Opacity Monitoring System (COME) means a monitoring system for
continuously measuring opacity emissions from an affected facility.
Fugitive emissions means air pollutants entering into the atmosphere from other than a
stack chimney, vent, or other functionally equivalent opening (e.g.. vapors, dust, fumes).
Mass emission standard means a regulatory standard limiting the emission of pollutants
into the atmosphere that is related to pollutant weight (e.g., Ibs/hour, up/m3, Ibs of
product, Ibs/mmBtu, etc.)
Opacity standard means a regulatory emission limit that is based on the degree to which
emissions reduce the transmission of light and obscure the view of an object in the
background.
Visible emissions means visible paniculate or condensable particulate matter emitted
from an air pollution source.
Visible emissions observation means any observation of emissions that meets the
requirement of reference method 9 or an approved equivalent method under 40 CFR part
60, Appendix A.
II. Water Program Terms
Best Management Practice (BMP) means a permit condition used in place of or in
conjunction with effluent limitations to prevent or control the discharge of pollutants.
BMPs may include a schedule of activities, the prohibition of practices, maintenance
procedures, or other management practices. BMPs may include, but are not limited to,
treatment requirements, operating procedures, or practices to control plant site runoff,
spillage, leaks, sludge or waste disposal, or drainage from raw material storage.
Bypass means the intentional diversion of wastestreams from any portion of a treatment
(or pretreatment) facility.
Composite sample means a sample composed of two or more discrete samples. The
aggregate sample will reflect the average water quality covering the compositing or
sample period.
-------
Appendix A
February 2000
Page A-2
Contact cooling water means the water discharged from any cooling use to which any
pollutant other than heat is added. The water must come into contact with the process.
«
Discharge Monitoring Report
-------
Appendix A
February 2000
Page A-3
POTW (publicly owned treatment works) means any device or system, owned by the
State or municipality, which is used in the treatment (including recycling and
reclamation) of municipal sewage or industrial wastes of a liquid nature.
Pretreatment means the reduction of the amount of pollutants, the elimination of
pollutants, or the alteration of the nature of pollutant properties in wastewater prior to or
in lieu of discharging or otherwise introducing such pollutants into a POTW.
Slug means any discharge or a non-routine, episodic nature, including but not limited to
an accidental discharge or a non-routine batch discharge.
Spill Prevention Control and Countermeasure Plan (SPCC) means a plan prepared by a
facility to minimize the likelihood of a spill and to expedite control and cleanup activities
should a spill occur.
Stormwater means storm water runoff, snow melt runoff, and surface runoff and
drainage.
Unauthorized discharge means the discharge of a pollutant that is not authorized in an
NPDES permit.
Unset means an exceptional incident in which there is unintentional and temporary
noncompliance with technology based permit effluent limitations because of factors
beyond the reasonable control of the permittee. An upset does not include
noncompliance to the extent caused by operational error, improperly designed treatment
facilities, inadequate treatment facilities, lack of preventative maintenance, or careless or
improper operation.
III. RCRA Program Terms
Closure refers to either a closed portion of a facility which an owner or operator has
closed in accordance with the approved facility closure plan and all applicable RCRA
closure requirements or the closure of all hazardous waste management units at the
facility in accordance with all applicable final closure requirements so that hazardous
waste management activities are not longer conducted at the facility. The owner or
operator must close the facility in a manner that minimizes the need for further
maintenance and that controls, minimizes or eliminates the future threat to human health
and environment.
Corrective action is required when a specific ground water standard set forth in the
facility permit is exceeded or the facility's permit may simply include the requirement to
establish a corrective action program. Corrective action requires the monitoring of
ground water, removal or treatment of any hazardous constituents that exceed permit
limits.
Container means any portable device in which a material is poured, transported, treated,
disposed of, or otherwise handled.
-------
Appendix A
February 2000
Page A-4
Contingency plan means a document setting out an organized, planned, and coordinated
course of action to be followed in case of a fire, explosion, or release of hazardous
waste or hazardous waste constituents which could threaten human health or the
environment.
Generator means any person, by site, whose act or process produces hazardous waste
identified or listed in 40 CFR part 261 or whose act first causes a hazardous waste to
become subject to regulation.
Hazardous waste means a solid waste identified as a characteristic or listed hazardous
waste in 40 CFR § 261.3.
Hazardous waste accumulation area is a designated location to place wastes from
several generation points in containers and/or tanks for a length of time not to exceed
90 days.
Land Disposal Restriction (LDRj is intended to restrict the land disposal of specific
hazardous wastes prior to treatment and requires that the manifests of these wastes be
accompanied by an LDR notice.
Landfill means an area of land or an excavation in which wastes are placed for
permanent disposal, and that is not a land application unit, surface impoundment,
injection well, or waste pile.
Manifest means the shipping document originated and signed containing the information
required by 40 CFR part 262, subpart B.
Part B permit is the permit issued to facility that treats, stores or disposes of hazardous
wastes. The permits include the administrative and technical standards that are applied
to a specific facility. Existing facilities that have applied for a permit, but have yet to be
issued a RCRA permit are considered to be in interim status if they applied for a Part A
and Part B Permit and may continue to operate if they comply with the RCRA mandated
Interim Status Standards.
Run-off means any rainwater, leachate, or other liquid that drains over land from any
part of a facility.
Run-on means any rainwater, leachate, or other liquid that drains over land onto any part
of a facility.
Satellite accumulation area means an area where no more than 55 gallons of a
hazardous waste or no more than one quart of acute hazardous waste is accumulated at
or near the point of generation. When the 55 gallon limit is reached, the operator has
three days in which to move the waste to a 90-day storage area or to a permitted TSD
facility.
Secondary containment includes structures, usually dikes or berms, surrounding tanks or
other containers that are designed to contain spilled material from the storage
containers.
-------
Appendix A
February 2000
Page A-5
Sludge means any solid, semi-solid, or liquid waste generated from a municipal,
commercial, or industrial waste water treatment plant, water supply treatment plant, or
air pollution control facility, exclusive of the treated effluent from a wastewater
treatment plant.
Solid waste means garbage, refuse, sludge, and other discarded solid material resulting
from industrial and commercial operations from community activities. It does not include
solids or dissolved materials in domestic sewage or other significant pollutants in water
resources.
Solid waste management unit (SWMU) means a site where waste disposal or
contamination of soil and terrain may have occurred from industrial activities or
operations.
Spill prevention includes those measures taken to avoid the accidental or intentional
spilling, leaking, pumping, pouring, emitting, emptying, or dumping of hazardous waste
into or on any land or water.
Spill response includes the measures required to respond to the accidental or intentional
spilling, leaking, pumping, pouring, emitting, emptying, or dumping of hazardous waste
into or on any land or water. This includes the containment, management and
remediation of any spill or release.
Tank means a stationary device designed to contain an accumulation of hazardous
waste which is constructed primarily of non-earthen materials (e.^.. wood, concrete,
steel, plastic) which provide structural support.
Toxicitv characteristic is one of four characteristics {ignitability, corrosivity, reactivity, or
toxicity) used to determine if a waste is hazardous. A solid waste exhibits the
characteristic of toxicity if, by using the test methods described in 40 CFR part 261,
Appendix II or an equivalent method approved by the Administrator, the extract from a
representative sample of the waste contains any of the contaminates listed in 40 CFR
§ 261.24, Table 1 at a concentration greater than or equal to that in the table.
TSP facility is a facility permitted to treat, store or dispose of hazardous waste on-site.
Used oil means any oil that has been refined from crude oil, or any synthetic oil that has
been used and, as a result of such use, is contaminated by physical or chemical
impurities.
-------
-------
-------
-------