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    United States
    Environmental Protection
    Agency
Office Of Water
(4303)
EPA821-R-95-037
September 1995
 EPA
 821
 R
'95
• 037
 c,l

V.	
    Preliminary Study of the
    Iron and Steel Category

    40 CFR Part 420
    Effluent Limitations Guidelines
    and Standards

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PRELIMINARY STUDY OF THE

  IRON & STEEL CATEGORY
   IEfA
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"                                40 CFR PART 420
•                       EFFLUENT LIMITATIONS GUIDELINES
                                 AND STANDARDS


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I                                 George M. Jett
                                  Project Officer

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                                 September 30,1995


-                        U.S. Environmental Protection Agency
|                                 Office of Water
                           Office of Science and Technology
•                        Engineering and Analysis Division (4303)
                                 401 M Street, S.W.
g                              Washington, D.C. 20460

                                 EPA-821-R-95-037

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                                Acknowledgements

The Environmental Protection Agency appreciates the dedicated effort, technical expertise and
many contributions to the Preliminary Study of the Iron and Steel Category effort by the
Radian Corporation personnel in Herndon, Virginia and Amendola Engineering, Inc. in
Lakewood, Ohio under Contract Number 68-CO-0005 and Contract Number 68-C4-0024.

The Agency acknowledges the plant managers, engineers and other Iron and Steel Industry
representatives whose cooperation and assistance in site visitations and information gathering
activities greatly contributed to the completion of the technical studies and assessments.  Also,
the American Iron and Steel Institute provided significant information that was useful in
understanding the current status of the industry.

A number of people within EPA made major contributions to this preliminary study.
Mr. George M. Jett (Project Officer, Metals Branch,  Engineering and Analysis Division) was
instrumental in the management of the contractor efforts, and coordination among many EPA
offices.  His deft guidance, technical expertise, and tireless efforts were essential to the
successful completion of this stage of the project  William Anderson and George Denning
(Economics and Statistical Analysis Branch, Engineering and Analysis Division) ably
contributed to the overall  efforts through dedicated performance related to the economics
analyses.

Ed Gardetto and Kevin Tingley (Exposure Assessment Branch, Standards and Applied
Science Division) provided Toxic Release Data summaries.  Additional Agency support was
ably provided by Lucy Reed and Maria Malava (Office of Enforcement Compliance
Assurance), Steve Hoffman (Office of Solid Waste and Emergency Response), Phil Mulrine
(Office of Air Quality Planning and Standards), and Ron Kovach (Region V Enforcements).
Legal support was provided by Carrie Wehling and Carol Ann Siciliano of the EPA's Office
of General Counsel.

Additional support was provided by Yousry Hamdy,  Ontario Ministry of the Environment, for
which the Agency is greatly appreciated.

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                              TABLE OF CONTENTS



                                                                                Page


             EXECUTIVE SUMMARY	   x


1.0          INTRODUCTION	1-1
             1.1    Purpose of This Review	1-1
             1.2    Structure of the Regulation	1-2
             1.3    Pollutants Limited by 40 CFR Part 420	1-3


2.0          INDUSTRY PROFILE	2-1
             2.1    Manufacturing Processes and Wastewater Treatment	2-2
                   2.1.1  Cokemaking	2-3
                   2.1.2  Sintering  	2-4
                   2.1.3  Ironmaking  	2-5
                   2.1.4  Steelmaking	2-6
                   2.1.5  Vacuum Degassing	2-8
                   2.1.6  Continuous Casting	2-8
                   2.1.7  Hot Forming  .  . .	2-9
                   2.1.8  Salt Bath Descaling	2-10
                   2.1.9  Acid Pickling	2-10
                   2:1.10 Cold Forming	 2-11
                   2.1.11 Alkaline Cleaning	2-12
                   2.1.12 Hot Coating	2-12
                   2.1.13 Electroplating	2-13
             2.2    Industry Segments	2-14
             2.3    Classification of Manufacturing Plants in the U.S. Iron
                 .  and Steel Industry	'...... 2-15
                   2.3.1  Stand-Alone By-Product Coke Plants  	'.	2-15
                   2.3.2  Integrated Steel  Mills  	2-16
                  . 2.3.3  Nonintegrated Steel Mills	 2-16
                   2.3.4  Stand-Alone Finishing Mills	2-17
                   2.3.5  Other Stand-Alone Operations 	2-17
             2.4    Changes in the U.S. Steel Industry - 1982 through 1993  	2-17
             2.5    Production Trends and  Capacity Utilization 	2-18
             2.6    Product Mix	2-20
             2.7    Imports and Exports, Employment, and Financial
                   Performance	2-21
             2.8    Capital Spending and Pollution Control Investments	2-22

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                        TABLE OF CONTENTS (Continued)
3.0
4.0
                                                                  Page

BACKGROUND OF CURRENT REGULATION	3-1
3.1    Prior Regulations  	3-1
3.2    Applicability	3-3
3.3    Subcategorization	3-4
3.4    Technology Bases for the Regulation	3-5
3.5    Regulated Pollutants  	3-10
3.6    General Provisions  	3-11
       3.6.1  Central Treatment	3-12
       3.6.2  Water Bubble	3-14

ASSESSMENT OF CURRENT REGULATION	4-1
4.1    Applicability	4-1
       4.1.1  §420.10 - Cokemaking  	1	4-1
       4.1.2  §420.20 - Sintering	4-1
       4.1.3  §420.30 - Ironmaking	4-2
       4.1.4  §420.40 - SteelmaMng	4-2
       4.1.5  §420.50 - Vacuum Degassing	 . 4-3
       4.1.6  §420.60 - Continuous Casting, §420.70 - Hot
             Forming, §420.80, Salt Bath Descaling	4-3
       4.1.7  Steel Finishing:  §420.90 - Acid Pickling,
             §420.100 - Cold Forming, §420.110 -Alkaline
             Cleaning, and §420.120 - Hot Coating	4-3
       4.1.8  §433 - Metal Finishing  	4-4
       4.1.9  New Steel Finishing Operations	4-5
4.2    Subcategorization 	4-5
4.3    Better Performing Mills	4-7
       4.3.1  Cokemaking - Figure 4-1	4-9
       4.3.2  Sintering - Figure 4-2	4-10
       4.3.3  Ironmaking - Figure 4-3  	4-11
       4.3.4  BOF Steelmaking - Figure 4-4	:	4-11
       4.3.5  Vacuum Degassing - Figure 4-5	4-12
       4.3.6  Continuous Casting - Figure 4-6	4-13
       4.3.7  Hot Forming:  Hot Strip  Mills - Figure 4-7	4-13
       4.3.8  Steel Finishing - Figures 4-8  and 4-9  	4-14
                                        11

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                        TABLE OF CONTENTS (Continued)
                                                                               Page

             4.4    General Provisions  	4-15
                   4.4.1   NPDES and Pretreatment Standards Production
                          Rate 	4-15
                 .  4.4.2   §420.01(b) -  Central Treatment	  4-17
                   4.4.3   §420.03 - Alternative Effluent Limitations (Water
                          Bubble Rule)	-..  4-20
             4.5    Pollutants Selected for Regulation	4-21
                   4.5.1   Conventional Pollutants	4-22
                   4.5.2   Nonconventional Pollutants 	4-23
                   4.5.3   Toxic Metal  Pollutants and Cyanide	4-25
                   4.5.4   Toxic Organic Pollutants	4-26
                          4.5.4.1       Chlorinated Dibenzo-p-dioxins and
                                      Chlorinated Dibenzofurans	4-27
                          4.5.4.2       Other Toxic Organic Pollutants	4-31
             4.6    Preliminary Estimates of Pollutant Loadings and Order-
                   of-Magnitude Costs	4-32
                   4.6.1   Modelled Estimates	4-33
                          4.6.1.1       Modelled Estimates of Pollutant
                                      Loadings at Current Regulation and
                                      at Level of Better Performing Mills	4-33
                          4.6.1.2       Modelled Estimates of Order-of-
                                      Magnitude Costs to Upgrade
                                      Industry Performance	4-38
                   4.6.2   Toxics Release Inventory (TRI) Database  	4-40
                   4.6.3   Permit Compliance System (PCS) Database	4-41

5.0          WATER QUALITY AND CROSS-MEDIA IMPACTS	5-1
             5.1    Impaired Water Bodies	5-1
             5.2    Receiving Water Sediments	5-2
             5.3    Groundwater	5-3
             5.4    Air  	5-4
             5.5    Solid and Hazardous Waste	5-5
             5.6    Opportunities for Multimedia Rulemaking	5-5
             5.7    Review of Recent Permit Violations and Enforcement
                   Actions  	5-6
                   5.7.1   Recent Permit Violations	5-6
                   5.7.2   Recent Federal and State Clean Water Act
                          Enforcement Cases	5-6
                                         111

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                    TABLE OF CONTENTS (Continued)
6.0
7.0

8.0
                                                        Page

NEW AND INNOVATIVE APPROACHES	6-1
6.1   Production Technologies	 6-1
6.2   Wastewater Flow Minimization and Improved Wastewater
     Treatment	6-4
     6.2.1  Wastewater Flow Minimization  	6-5
     6.2.2  Improved Treatment Methods and Treatment
           Operations	 6-5
6.3   Pollution Prevention  . .	6-6
6.4   Residuals Management  	6-9
6.5   Best Management Practices 	6-9
REFERENCES
7-1
GLOSSARY	8-1
           APPENDIX A:
           APPENDIX'B:
           APPENDIX C:
                SCHEMATIC DIAGRAMS OF TECHNOLOGIES
                CONSIDERED BY EPA

                MILL PERFORMANCE DATA VERSUS EFFLUENT
                LIMITATIONS GUIDELINES

                IRON AND STEEL MANUFACTURING FACILITIES
                INCLUDED ON STATE 304(L) SHORT LISTS
                                  IV

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                                                                                 Page

2-1          Steelmaking From Raw Materials to Finished Mill Products	2-25
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•   -        2-2           U.S. Iron and Steel Industry:  Steelmaking Capacity and
                           Production (1973 through 1993)  	2-26

•            2-3           U.S. Iron and Steel Industry:  Steelmaking Capacity Utilization
                           (1975 through 1993)  	2-27

™            2-4           U.S. Iron and Steel Industry:  Production as Percent of World
                           Steel Production (1973 through 1993) 	2-28

™            2-5           U.S. Iron and Steel Industry:  Blast Furnace Iron Production
                           (1973 through 1993)  	2-29

™            2-6           U.S. Iron and Steel Industry:  Ratio of Pig Iron to Raw Steel
                           Production (1973 through 1993)  	2-30

              2-7           U.S. Iron and Steel Industry:  Electric Arc Furnace Steel
_                         Production (1936 through 1993)	  2-31
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              2-8           U.S. Iron and Steel Industry:  Raw Steel Production by Type of
~                         Furnace (1973 through 1993)	2-32

              2-9           U.S. Iron and Steel Industry:  Raw Steel Continuously Cast
_                         (1978 through 1993)  	2-33

              2-10          U.S. Iron and Steel Industry:  Shipments by Type of Steel (1973
g                         through 1993)	2-34

              2-11          U.S. Iron and Steel Industry:  Steel Shipments, Major Products -
•                         All Grades (1973 through 1993)	2-35

              2-12          U.S. Iron' and Steel Industry:  Steel Shipments, Major Markets
•                         (1973 through 1993)	2-36

              2-13          U.S. Iron and Steel Industry:  Imports and  Import Penetration
•                         (1973 through 1993)  	2-37



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                           LIST OF FIGURES (Continued)
 2-14


 2-15

 2-16


 2-17


 2-18


 4-1


 4-2


 4-3


 4-4


4-5


4-6


4-7


4-8
                                                                   Page

U.S. Iron and Steel Industry: Value of Imports and Exports
(1973 through 1993)  	2-38

U.S. Iron and Steel Industry: Employment (1973 through 1993)  	2-39

U.S. Iron and Steel Industry: Net Income by Reporting
Companies (1973 through 1993)	;	2-40

U.S. Iron and Steel Industry: Capital Investments (1973 through
1993)	2-41

U.S. Iron and Steel Industry: Environmental Control
Investments (1951 through 1993)	  2-42

Mill Performance vs. Effluent Limitations Guidelines -
Cokemaking - Long-Term Average Data  	4-65

Mill Performance vs. Effluent Limitations Guidelines - Sintering
- Long-Term Average Data  	4-66

Mill Performance vs. Effluent Limitations Guidelines -
Ironmaking - Long-Term Average Data	4-67

Mill Performance vs. Effluent Limitations Guidelines -
Steelmaking - Long-Term Average Data   	4-68

Mill Performance vs. Effluent Limitations Guidelines - Vacuum
Degassing - Long-Term Average Data	4-69

Mill Performance vs. Effluent Limitations Guidelines -
Continuous Casting - Long-Term Average Data	4-70

Mill Performance vs. Effluent Limitations Guidelines - Hot Strip
Mill - Long-Term Average Data	4-71

Mill Performance vs. Effluent Limitations Guidelines - Steel
Finishing - Long-Term Average Data	  4-72
                                         VI

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                                     LIST OF FIGURES (Continued)
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                                                                                       Page
I          4-9         Metal Finishing vs. Steel Finishing Performance - Comparison of
                        LTA Treated Effluent Concentrations  	4-73
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                                  LIST OF TABLES
2-1


2-2


3-1


3-2


4-1


4-2



4-3

4-4

4-5

4-6

4-7

4-8

4-9


4-10

4-11
Iron and Steel Manufacturing Processes Identified Pollutants of
Concern	

Facilities Engaged in Basic Steelmaking Operations 1982 and
1993 	
                                                                                 Page
2-23
2-24
Iron and Steel Manufacturing Subcategories, Subdivisions, and
Segments	3-15

Iron and Steel Manufacturing Processes Pollutants Limited by 40
CFR Part 420	3-19

40 CFR 420.0 l(b) Central Treatment Facilities Temporarily
Excluded from Part 420	 4-42

Levels of CDDs and CDFs in Electric Arc Furnace Flue Gases
Before and After Bag House Filter During Continuous Charge
Through The Furnace Lid	'.	4-44

Pollutant Loadings for Total Iron and Steel Industry	4-45

Pollutant Loadings for Direct Discharging Coke Plants  	4-47

Pollutant Loadings for Indirect Discharging Coke Plants 	4-48

Pollutant Loadings for Other Coke Plants	4-49

Pollutant Loadings for Sintering  	4-50

Pollutant Loadings for Ironmaking  	4-51

Pollutant Loadings for BOF Steelmaking, Vacuum Degassing,
Continuous Casting	4-52

Pollutant Loadings for Hot Forming (Integrated Mills)	4-53

Pollutant Loadings for Finishing	4-54
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LIST OF TABLES (Continued)

4-12 Pollutant Loadings for Nonintegrated Mills 	 .....;....

4- 13 Pollutant Loadings for Hot Forming (Stand-alone) 	
4-14 Pollutant Loadings for Cold Forming 	 	 	

4-15 Comparison of Baseline and Projected Technologies 	

4-16 Costs to Upgrade to the Level of Better Performing Mills 	

4-17 Summary of 1992 TRI Data 	 	
4-18 Summary of 1992 PCS Database . 	 	

5-1 EPA Permit Compliance System Violations (1989) 	

5-2 EPA Permit Compliance System Violations (1990) 	

5.3 EPA Permit Compliance System Violations (1991) 	

5-4 EPA Permit Compliance System Violations (1992) 	

5-5 EPA Permit Compliance System Violations (1993) 	

5-6 EPA Permit Compliance System Violations (1994) 	

6-1 • Common Practices for Residuals Management 	





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Page
	 4-55

	 4-56
	 4-57

	 4-58

	 4-60

	 4-61
	 4-63

	 5-10

	 	 5-12

	 5-14

	 . 5-16

	 5-18

	 5-19

	 6-11








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             EXECUTIVE SUMMARY



             Purpose of This Review



             EPA is required by Section 304  of the Clean Water Act to  review effluent

limitations guidelines and standards periodically  to determine whether the current regulations

remain  appropriate in  light of  changes in the  industrial  category  caused by  advances in

manufacturing technologies, in-process pollution prevention, or end-of-pipe wastewater treatment.

EPA is also required by the terms of a consent decree with the Natural Resources Defense

Council (NRDC) to initiate preliminary reviews of a number of categorical effluent limitations

guidelines and standards on a set schedule.4  This review is  being conducted pursuant to those

legislative and judicial requirements.



             The approach taken includes:
                    A preliminary assessment of the status of the industry with respect
                    to the regulation promulgated in 1982 and as amended in 1984;


                    Identification of better performing mills that use conventional and
                    innovative   in-process   pollution  prevention   and  end-of-pipe
                    technologies;


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


                    Identification of regulatory and implementation issues with the
                    current regulation; and


                    Identification of possible solutions to those  issues.

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              Industry Profile

              There are 84 steel-producing companies located in the United States with more
than 300 separate manufacturing sites.  The U.S. domestic demand for finished and semi-finished
steel products was approximately 104 million tons in 1993. U.S. producers manufactured about
98 million tons of raw steel and shipped about 89 million tons to domestic and export markets..
Imports of semi-finished and finished steel accounted for about  19 million tons, or about 19%
of U.S. demand.  Exports from the U.S. totaled about 4.0 million tons.  The industry operated
at about 89% of capacity in  1993.6

              During the past fifteen years,  the U.S. steelmaking industry consolidated  and
modernized to become competitive in the U.S. and on world markets.  Annual raw steelmaking
capacity declined from over 150 million tons in 1978 to approximately 110 million tons in 1993.
Direct steel industry employment declined from 450,000 people  in 1978 to approximately
127,000 people in 1993.  Approximately 61% of the raw steel produced is currently manufactured
in basic oxygen furnaces and 39% in  electric arc furnaces; steel is  no longer manufactured in
open  hearth furnaces in the U.S.  During 1993,  approximately 86% of  the  raw steel was
continuously cast as opposed to approximately  15% in 1978. After a series of annual losses from
steelmaking operations (losses for eight of the eleven years during the period 1982 through 1992),
the industry returned to profitability during 1993, and is operating profitably during the economic
expansion continuing in 1994.  U.S. steel producers are now among the lowest cost steel
producers in the world.6

              Capital spending for new plants  and equipment, including environmental controls,
has ranged from less than one to more  than three billion dollars on an annual basis over the past
15 years.  Capital spending devoted to environmental controls ranged from less than 5 to nearly
21 percent. Total investment in environmental controls for the period 1951  through 1992 was
more than 7 billion dollars (water - $2.6 billion; air - $4.5 billion;  solid waste  - $0.1 billion).
                                           XI

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The industry is at or returning to the point where capital investments at the high end of its

investment cycle may be made.29



             For 1992, the industry reported the following Toxics Release Inventory (TRI) data

for direct and indirect wastewater discharges under Section 313 of the Emergency Planning and

Community Right-to-Know Act of 1986 (EPCRA):
,* ;v;-vV, \ v"."v- V* ;\\l'\y/'
V*",/ *. **** \'" •• f- "• ^ ^ .A
\- 'V!fSejDfet«*i*\ •'> - -[ '•- -; \
Ammonia-N
Cyanide Compounds
Phenol
Toxic Metal Compounds*
Other SARA Organic Compounds
>IL ' X> ' * f ff*~ f •% % *f C- '?Vf "• f f f *• ^ *
"-^ rJ&iiwt Wwdiprft.^'x -
:'< \,;>';vMlla^";^> ;'; %
1,830,000
65,500
65,000
447,000
671,000
'rijitos&t& «o ipoirws
v-;'/^;^l)S/yr>
679,000
14,400
618,000
55,400
63,100
*As defined in the Toxics Release Inventory.



             Forty iron and steel mills were included on state 304(1) short lists which identifies

facilities discharging  to  impaired waterbodies (see Appendix  C).  Receiving water sediment

contamination by polynuclear aromatic hydrocarbons has been documented at several iron and

steel mills where blast furnace coke has been manufactured as an intermediate product.  Three

companies have been required to conduct sediment characterization and remediation as a result

of consent decrees resulting from recent federal Clean Water Act enforcement actions.



             40 CFR Part 420: Effluent Limitations Guidelines and Standards for the

             Iron and  Steel Manufacturing Point Source Category



             Part 420 was promulgated in May 1982 (47 FR 23258) and was last amended in

May 1984 (49 FR 21024) as part of a Settlement Agreement among EPA, the iron and steel
                                         Xll

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industry, and the NRDC.  The regulation was the first promulgated under the 1977 Amendments
to the Clean Water Act  There are a number of regulatory issues identified by this study that
pertain to Part 420, as described below.


             Effluent Limitations Guidelines and Standards
                    Comparisons of long-term average effluent quality performance for
                    a number of better performing mills (data represent time periods
                    ranging from six months to more than one year) with the long-term
                    average bases  for Part 420 reveal that, in all subcategories, mills
                    are performing substantially better than is required by Part 420. In
                    a limited number of cases, zero discharge of pollutants is being
                    approached. This performance reflects increased high-rate process
                    water recycle, advances in application of treatment technologies,
                    and advances in treatment system operations.

                    A number of mills continue to discharge in excess of the effluent
                    limitations required by Part 420.

                    Several mills  are not achieving the  zero  discharge  limitations
                    applicable to semi-wet steelmaking operations.

                    In at  least  10  of  the  12 current  subcategories,  toxic  and
                    nonconventional pollutants not currently  regulated by Part 420 are
                    discharged.    The current effluent  limitations  guidelines  and
                    standards  for  toxic  organic pollutants for  the  cold  forming
                    subcategory are no longer applicable.

                    Scandinavian researchers have documented formation of chlorinated
                    dibenzo-p-dioxins (CDDs) and chlorinated dibenzofurans (CDFs)
                    in electric arc furnace steelmaking where steel is manufactured by
                    remelting steel scraps.53"55  There are no published studies for U.S.
                    mills that characterize the formation of CDDs and CDFs in electric
                    arc furnaces, other steelmaking furnaces, or other iron and steel
                    operations.  There are also no published data that characterize
                    process wastewater discharges from U.S. iron and steel  mills for
                    CDDs and CDFs.

                    At §420.03,  the  regulation provides  for  alternative  effluent
                    limitations (the water bubble) where dischargers can conduct intra-
                                          Xlll

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       plant "trades" of like pollutants from one outfall to another to save
       costs or  improve compliance  prospects.  Part 420 is the only
       effluent limitations guideline  regulation  that  contains  such a
       provision. Although not widely used, the present cost savings from
       §420.03 is more than $120 million, and there may be opportunities
       to increase its utilization.38
Potential Load Reductions
       Based on modelled estimates for the iron  and steel industry to
       upgrade  to  the  treatment  level of  better performing  mills, a
       pollutant  loading  reduction  of 1.9  million  pounds  of  toxic
       equivalents per year can be achieved with a total capital investment
       of $339 million.  Operating and maintenance costs are estimated at
       $32.2 million per year.  Assuming  an equipment life of 20 years
       and annual interest rates  of 7% and  10%, the cost effectiveness for
       the industry  as a whole  for these pollutant removals is  $34/lb-eq
       removed and $38/lb-eq removed, respectively.

       Other modelled estimates of pollutant removals not included in the
       toxic equivalent analysis are 29 million pounds per year of total
       suspended solids, 6.9 million pounds per year  of oil and grease,
       and 710,000 pounds per year of ammonia-N.
Multimedia Pollutant Transfers
       Because  most  process  wastewaters  from  basic  steelmaking
       operations are generated as a result of air emission control and gas
       cleaning, there are substantial pollutant transfers from the air media
       to the water and solid waste media.

       The most significant transfer of pollutants from the water to the air
       media results from quenching of coke with untreated cokemaking
       and by-product recovery process wastewaters.   This quenching
       practice is not widely used today; however, virtually none of the
       toxic pollutants found in cokemaking wastewaters are regulated by
       State Implementation Plans (SIPs) for coke quenching operations.
                             xiv

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       Cross-media transfers from leaking coke quench sumps, leaking by-
       product recovery wastewater sumps, leaking blast furnace slag pits,
       a limited number of unlined wastewater collection and treatment
       ponds, and leaking above-ground and below-ground storage tanks
       for fuel and various chemicals (including chlorinated solvents),
       have resulted in groundwater contamination at many steel mills.
Opportunities for Pollution Prevention
       The greatest long-term opportunities for pollution prevention will
       result from new cokemaking methods  that result  in  reduced
       emissions and discharges, and new iron and steelmakmg methods
       that reduce or  eliminate the need for coke.   Several research
       projects are underway; however, the  technologies have not been
       demonstrated to the point where they could serve as the basis for
       revised BAT or NSPS.

       A nonrecovery cokemaking technology (coke by-products such as
       coal tar, crude light oil, and ammonia are not recovered) has been
       fully demonstrated.  The process results  in virtually no process
       wastewater discharges and  air  emissions  that  can  be readily
       controlled.  This technology could serve as the basis for revised
       NSPS.

       There appear to be many pollution prevention opportunities in the
       areas of  increased process  water recycle and  reuse, cascade of
       process  wastewaters from  one  operation to another,  residuals
       management, and nondischarge disposal methods.
Applicability and Subcategorization
       The  regulation  promulgated  in  1982  provided  a  temporary
       exclusion (not to exceed one year) for 21 mills or parts of mills
       with central wastewater treatment facilities (§420.01(b)).  The
       exclusion  remains in the regulation  and continues  to present
       problems for state and EPA regional NPDES permit writers.

       The  1982 regulation does not specifically address small,  stand-
       alone steel finishing operations.   These facilities may not  be
                             xv

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characteristic of the larger facilities which were used to establish
the effluent limitations guidelines and standards.  These smaller
facilities may be more similar to the type of facilities that will be
regulated by the Metal Products and Machinery Category, currently
under development


It  may be  appropriate to evaluate regulating continuous strip
electroplating operations at steel mills under Part 420, instead of
under Part 433 - Metal Finishing.   Wastewater discharges from
continuous strip electroplating operations and wastewaters from
steel finishing operations are almost universally co-treated at steel
finishing mills.  Also, the database used by EPA to establish the
Part  420  effluent  limitations  and  standards included  both
electroplating and steel finishing wastewaters.


The current industry subcategorization in Part 420 may need to be
reevaluated with  regard to  regulating continuous  strip  steel
finishing lines  constructed  during the  past several  years.  These
mills are configured with both steel  finishing and metal finishing
operations  and are used to apply coatings  of metals and metal
combinations that were not commonly used in 1982.


The  current  subcategorization  does  not   adequately  address
nonintegrated  steel producers (so-called "mini-mills")  that are
equipped with  electric arc  furnaces, continuous casters, and hot
forming mills.


In some instances, Part 420 is obsolete because some segments of
the industry no longer exist in the U.S. (e.g., beehive cokemaking,
ferromanganese  blast   furnace  (ironmaking),   open   hearth
steelmaking).
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1.0          INTRODUCTION



             40 CFR Part 420, Effluent Limitations Guidelines and Standards for the Iron and

Steel Manufacturing Point Source Category, was promulgated in May 1982 (47 FR 23258), and

last amended in May 1984 (49 FR 21024) in response to challenges from the steel industry and

the Natural Resources Defense Council (NRDC).1A3 The regulation was the first promulgated

by the U.S. Environmental Protection Agency (EPA) under the 1977 Amendments to the Clean

Water Act, and thus was the first to distinguish between conventional, nonconventional, and toxic

pollutants in the regulatory scheme established by the  1977  Amendments. The regulation has

been implemented through the National Pollutant Discharge Elimination System (NPDES) permit

program and through state and local pretreatment programs, and has resulted in effluent reduction

and water quality  benefits.



1.1          Purpose of This Review



             EPA  is required by  Section  304  of the Clean  Water Act to review effluent

limitations guidelines  and standards periodically to determine whether the current regulation

remains appropriate in light of, among other things, changes in the industrial category caused by

advances  in manufacturing  technologies,  in-process  pollution prevention, and  end-of-pipe

wastewater treatment.  EPA is also required by the terms of a consent decree with the NRDC to

initiate  preliminary  reviews  of a number  of categorical effluent limitations  guidelines  and

standards on a set schedule.4 This review is being conducted pursuant to those legislative and

judicial  requirements.



             The approach taken includes a preliminary assessment of the status of the industry

with respect to the regulation promulgated in 1982 and amended in 1984; identification of better

performing mills using conventional and innovative in-process pollution prevention and end-of-

pipe technologies; estimation of possible effluent reduction benefits if the industry was upgraded
                                         1-1

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to the level of better performing mills; identification of regulatory and implementation issues with
the current regulation; and identification of possible solutions to those issues.


              This report was commissioned by the Agency to use as one of. many sources of
information to determine whether  revisions  to  the Iron  and Steel Manufacturing Effluent
Limitations Guidelines  and Standards at 40 CFR  Part 420 are warranted.   Consequently,
recommendations are not made within the body of this report as to whether any specific revisions
should be made.
1.2
Structure of the Regulation
             40 CFR Part 420 contains the following twelve  subparts for twelve distinct
manufacturing operations conducted in the manufacture of steel and finished and semi-finished
steel products:
             A.    Cokemaldng
             B.    Sintering
             C.    Ironmaking
             D.    Steelmaking
             E.    Vacuum Degassing
             F.     Continuous Casting
                                        G.    Hot Forming
                                        H.    Salt Bath Descaling
                                        I.     Acid Fielding
                                        J.     Cold Forming
                                        K.    Alkaline Cleaning
                                        L.    Hot Coating
             Electroplating operations conducted at steel mills are not regulated by 40 CFR Part
420, but are regulated by 40 CFR Part 433 - Metal Finishing.


             Part 420 contains production-based effluent limitations guidelines and standards.
Accordingly, steel mills with higher levels of production will receive higher permit discharge
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allowances.  The regulation was structured in a building-block manner to facilitate co-treatment

of compatible wastewaters from different operations as shown by the following groupings:5
Cokemaking
Sintering
Ironmaking
Steelmaking
Vacuum Degassing
Continuous Casting
Hot Forming
Salt Bath Descaling
Combination Acid Pickling
Cold Rolling
Acid Pickling
Cold Rolling
Alkaline Cleaning
Hot Coating
             The regulation contains effluent limitations for the same pollutants for each group

of manufacturing operations, such that discharge permits can reflect co-treatment of compatible

wastewaters from these processes. At the time 40 CFR Part 420 was promulgated, EPA sought

to discourage co-treatment of wastewaters across these groups to foster process-specific high-rate

recycle of process water where possible, and to minimize less effective treatment of toxic metal

and  toxic organic pollutants caused  by dilution of pollutant levels  by waste  streams  not

containing those pollutants.5
1.3
Pollutants Limited by 40 CFR Part 420
             Conventional Pollutants


             Total Suspended Solids
             Oil & Grease
             PH
             Nonconventional Pollutants


             Ammonia-N
             Phenols (4AAP)
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Priority or Toxic Pollutants

Total Cyanide
Total Chromium
Hexavalent Chromium
Total Lead
Total Nickel
Total Zinc
Benzene
Benzo(a)pyrene
Naphthalene
Tetrachloroethylene
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•           2.0          INDUSTRY PROFILE


•                        The American Iron and Steel Institute (AISI) reported the following statistics for
             the U.S. iron and steel industry for 1992 or 1993:6


                          •      Number of steel producing companies in the U.S. in
.                               1992:  84

                          •      Leading steel producing states in  1993:   Indiana,  Ohio,  and
•                               Pennsylvania

                          •      1993 Estimated direct employment:  127,000

|                        •      1992 Average hourly employee cost: $29.57

•                        •      1993 U.S. raw steel capacity:  109.9 million net tons

                          •      1993 U.S. raw steel production:  97.9 million net tons

m                        •      1993 U.S. capacity utilization:  89.1 percent
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1992 world steel production:  787.6 million net tons

1992 Steel productivity (man hours/ton):
•                                        United States  5.3
                                        Germany           5.6
                                        Japan               5.4

•                         •      1993 Steel production methods:     61% basic oxygen furnaces
                                                                  39% electric arc furnaces
                                                                  10% open hearth furnaces
                                                     .
                           •      1993 Continuous casting:  86% of raw steel produced

*                         •      1993 U.S. steel shipments of semi-finished and finished products (domestic
                                 and export):  89.0 million net tons

™                         •      1993 U.S. steel imports: 19.5 million net tons

•                         •      1993 U.S. steel exports: 4.0 million net tons



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                     1993 U.S. domestic demand:  104.5 million net tons
                     Environmental control investment:  >$7 billion (1951-1992)
                     Environmental control costs in 1992:  $10 to $20 per ton of steel
                     (typical costs to manufacture steel are in the range of $400 to $700
                     per ton)
                     1993 Selected product applications/markets (millions of net tons):
                           Service centers                   23.7
                           Construction and contractors       13.4
                           Automotive industry              12.7
                           Container industry                4.3
                           Appliance industry                1.6
              Detailed information about manufacturing processes and wastewater treatment;
production trends and capacity utilization; imports, exports and financial performance; and capital
spending and pollution control investments are presented in this section.
2.1
Manufacturing Processes and Wastewater Treatment
             40 CFR Part 420 includes twelve subparts for regulating steel manufacturing and
steel finishing  operations that generate and  discharge process wastewaters and  wastewater
pollutants; however, electroplating operations performed at steel mills are regulated by 40 CFR
Part 433  -  Metal Finishing.   The  major processes regulated  by 40 CFR  Part  420 and
electroplating operations conducted at steel mill sites are described briefly below in terms of
principal products and by-products, process water usage,  wastewater  pollutants, and typical
 »
treatment systems. More complete descriptions of these processes are found in The Making,
Shaping and Treating of Steel, 10th Edition.7 Figure 2-1 is a simplified schematic diagram of
the major ironmaking, steelmaking, and steel finishing processes. Table 2-1 presents a summary
of the wastewater pollutants associated with each process.8  Note that  tables and figures are
located at the end of each section of this report.
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2.1.1          Cokemaking



              Carbon in the form of metallurgical coke is used to reduce iron oxides to metallic

iron in blast furnaces. Virtually all coke in the U.S. is produced in by-product coke plants.  The

coke is produced on a batch basis by distilling metallurgical coals (blends of high, medium, and

low volatile coals designed to produce coke of sufficient strength for use in ironmaldng blast

furnaces) in slot type ovens at temperatures of 1,650  to 2,000°F in the absence of air. Coke

batteries comprise numerous ovens  constructed side-by-side  equipped with ancillary  coal

charging, gas  collecting mains, and coke pushing and coke quenching facilities.  The coking

process typically lasts 16 hours.  Coal is charged into the tops of the ovens with larry cars or by

pipeline. After the coking process is complete, the incandescent coke is pushed into a flat bed

rail car and transported to a coke quench station where the  coke  is quenched with water to near

ambient temperature.



              The moisture and volatile components of the coal,  typically 20 to 35% by weight,

are collected and processed to recover by-products, including crude coal tars, crude light oil

(aromatics, paraffins, cycloparaffins and naphthenes,  sulfur compounds, nitrogen  and  oxygen

compounds), anhydrous ammonia or ammonium sulfate,  naphthalene, and sodium phenolate.



              The typical volume  of process  wastewaters generated at a well-controlled by-

product coke plant is approximately 100 gallons per ton  (gpt) of coke produced.9 About 25 to

35 gpt is generated from water contained in the coal charge in the form of waste ammonia liquor.

The balance results from steam addition for distilling ammonia from the waste ammonia liquor,

crude light oil recovery, and miscellaneous sources. Cokemaking wastewaters contain high levels

of oil  & grease (O&G), ammonia-N, cyanides, thiocyanates, phenolics, benzenes, toluene, xylene,

other  aromatic volatile components, and polynuclear aromatic compounds (see Table 2-1).9



              The conventional  wastewater treatment approach consists of physical/chemical

treatments,  including oil separation, dissolved gas flotation, and ammonia distillation followed
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 by biological treatment with nitrification. An innovative biological treatment approach without
 ammonia distillation pretreatment has been installed at one plant.10

              During the past ten years, the number of active coke plants in the United States
 has declined as a result of the consolidation of the industry, more stringent air pollution control
 regulations, and because coke requirements for blast furnace operations has decreased with the
 trend toward alternate carbon sources (e.g., direct injection of oil and pulverized coal).11 Many
 blast furnace operators are using these techniques.
2.1.2
Sintering
              Sinter plants are used to beneficiate (upgrade the iron content) iron ores and to
recover iron values from wastewater treatment sludges and mill scale generated at integrated steel
mills (see Section 2.3.2 for definition of "integrated").  Sinter plants consist of numerous raw
material storage  bins; a mixing  drum for each sinter strand; sinter  strands (travelling  grate
combustion devices); a windbox (device for drawing air through the travelling gate); a discharge
end; a cooling bed for sintered product; and wet or dry air pollution control devices.  Coke
breeze (fine coke particles), iron ores, sludges, mill scales, and limestone are mixed in sinter
machines and charged to a travelling grate at a depth of approximately one foot.  The mixture
is ignited and air is drawn through the bed as it travels toward the exit end. Clinkers (i.e., sinter
of suitable size and weight) are formed for charging to the blast furnace.

              Wastewaters are generated from wet air pollution control devices on the wind box
and discharge ends of the sinter machines.  Applied flows for wet air pollution control  devices
are typically 1,500 gpt of sinter, with discharge rates of 120 gpt for the better controlled plants.12
Wastewater treatment comprises sedimentation for removal of heavy solids, recycle of clarifier
or thickener overflows, and metals precipitation treatment for blowdowns.  Some sinter plants
are operated with once-through treatment. The principal pollutants include total suspended solids
(TSS), O&G, ammonia-N, cyanide, phenolic compounds, and metals (principally lead and zinc).12
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2.1.3         Iron making



             Blast furnaces are used to produce molten iron which makes up about two-thirds

of the charge to basic oxygen steelmaking furnaces, the balance being cold steel scrap.  The raw

materials charged to. the top of the blast furnace include coke, limestone, beneficiated iron ores,

and sinter. Hot blast (preheated air) is blown into the bottom of the furnace through a bustle pipe.

and tuyeres (orifices) located around the circumference of the furnace. The iron-bearing furnace

burden (material charged to the furnace) is supported by coke and is reduced to molten iron and

slag as it descends through the furnace.  The molten iron, at approximately 2,800 to 3,000°F, is

tapped at regular intervals into refractory-lined cars for transport to the steelmaking furnaces.

Molten slag, which  floats on top of the molten iron, is also tapped and processed for sale as a

by-product.  Blast furnace slag may be used as railroad ballast, as an  aggregate in cement

manufacturing, and  for other construction uses.



             A simplified summary of the chemical reactions that occur in the blast furnace is

presented below:
                    + H2 --> 2Fe3O4 + H2O
             3Fe2O3 + CO --> 2Fe3O4 + CO2


             Fe3O4 + H2 --> 3FeO + H2O
             Fe3O4 + CO --> 3FeO + CO2


             FeO + H2 --> Fe + H2O
             FeO + CO --> Fe + CO2


             3Fe +  CO + H2 --> Fe3C + H2O
             3Fe +  2CO --> Fe3C + CO2


             C02 + C --> 2CO
             H2O + C --> CO + H2
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              FeO + C --> Fe + CO
              3Fe + C --> Fe3C

              The hot blast exits the furnace top as blast furnace gas in enclosed piping and is
cleaned and cooled in a combination of dry dust catchers and high-energy venturi scrubbers.  The
cleaned gas is combusted in stoves to preheat the incoming air and used as fuel elsewhere in
integrated mills.  Direct  contact water used  in the gas  coolers and  high-energy  scrubbers
comprises nearly all of the wastewater from blast furnace operations. About 6,000 gpt of iron
is applied at the furnace.13  The principal pollutants include TSS, ammonia-N, cyanides, phenolic
compounds, and metals (copper, lead, and zinc).  Standard treatment in the industry includes
sedimentation in thickeners or clarifiers, cooling with mechanical draft cooling towers, and high-
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rate recycle.  Low-volume blowdowns (<70 gpt of iron) are either consumed in slag cooling at
furnaces with adjacent slag pits, or treated in conventional metals precipitation systems.  A few
mills practice alkaline chlorirtation to treat ammonia-N, cyanides, and phenolic compounds.
2.1.4
Steelmaking
             All steelmaking in the U.S. is conducted in basic oxygen furnaces or electric arc
furnaces; open hearth furnaces are no longer operated. Basic oxygen furnace (BOF) and electric
arc furnace (EAF) processes are batch processes with tap-to-tap (batch cycle) times of about 45
minutes and two to three hours, respectively.  Up to 360 tons per heat may be produced in a
BOF, while capacities in EAFs range from less than 10 tons to more than 300 tons per heat.14
BOFs are typically used for high tonnage production of carbon steels, while EAFs are used to
produce carbon steels and low tonnage alloy and specialty steels.

             The principal purpose of BOF steelmaking is to refine a metallic charge consisting
of approximately two-thirds molten iron and one-third steel scrap by oxidizing silicon, carbon,
manganese, phosphorus and a portion of the iron. Oxygen is injected into the molten bath either
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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. Off-

gases from furnaces in the U.S. are controlled by one of three methods:
                    Semi-Wet Furnace off-gases are conditioned with moisture prior
                    to processing in electrostatic precipitators or bag houses;


                    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; and


                    Wet - Suppressed Combustion. Excess air is not admitted to the
                    off-gas collection system prior to high-energy wet scrubbing for air
                    pollution control.
             About 1,100 gpt and 1,000 gpt of steel are applied in the open combustion and

suppressed combustion systems, respectively.15  The principal pollutants are TSS and metals

(lead, zinc). Standard treatment consists of sedimentation in clarifiers or thickeners and recycle

of 90% or more of the applied water. Blowdown treatment consists of metals precipitation.  It

may be possible to operate semi-wet off-gas systems at zero discharge by balancing the applied

water with evaporative losses, but none are operated in this fashion. One suppressed combustion

EOF installation located in Germany has been operated with dry emission controls.



             Most EAFs are operated with dry air cleaning systems with no process wastewater

discharges.  A small number of  wet and semi-wet systems also exist.  The water flows and

pollutants of concern for those systems with wet and semi-wet air cleaning systems are similar

to those for the wet basic oxygen furnaces, but the levels of metals are higher because of the

100% scrap charge.  Wastewater treatment operations are similar to  those  for the wet basic

oxygen furnaces.
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2.1.5
Vacuum Degassing
             In  this batch process, molten steel is subjected to a vacuum for composition
control, temperature control, deoxidation (O2 removal), degassing (H2 removal), decarburization,
and to otherwise remove impurities from the steel. Oxygen and hydrogen are the. principal gases
removed from  the  steel.   In most degassing systems,  vacuum is  provided  by  barometric
condensers;  thus, direct contact between the gasses and the barometric water occurs.   The
principal pollutants are low levels of TSS and metals (lead and zinc), which volatilize from the
steel. Applied water rates are typically around 1,250 gpt of steel.16 Discharge rates of 25 gpt
      •
are achieved through  high-rate recycle.   Standard treatment includes processing the total
recirculating flow or a portion of the flow in clariflers for TSS removal, cooling with mechanical
draft cooling towers, and high-rate recycle.  Blowdowns are usually co-treated with steelmaking
and/or continuous casting wastewaters for metals removal. Vacuum degassing plants are often
operated as part of ladle metallurgy stations where additional steel refining is conducted. These
additional refining operations do not use process water.
2.1.6
Continuous Casting
             Molten steel is tapped from the BOF or EAF into ladles of sufficient capacity to
hold an entire heat.  The ladles are then processed in ladle metallurgy stations and/or vacuum
degassers prior to teeming (pouring) into ingot molds or direct casting into semi-finished shapes
using continuous casters.  Steel cast into ingot molds must undergo cooling, mold stripping,
reheating, and hot rolling  to produce the same semi-finished shape that can be produced with
continuous casting. The casting machine includes a tundish (receiving vessel for molten steel),
a water-cooled mold (or  molds on multi-strand machines), secondary cooling water sprays,
containment rolls, oxygen-acetylene torches for cutoff,  and a runout table.  Molten steel is
transferred from the ladle  to the tundish and then to the  water-cooled mold at controlled rates.
The steel solidifies as it passes through the mold and is cut to length on the runout table.
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The four main types of continuous casters are billet, bloom, round, and slab. The
names derive from the shape of the cast product. Casting machines are either single-strand or
multi-strand. Modern slab casters used to manufacture flat-rolled products are universally of a
curved-mold design, while those used to produce bar products may be of a straight vertical mold
design with vertical cutoff or bending with horizontal cutoff.
Continuous casters usually include two separate closed-loop cooling water systems:
one for the copper mold (mold cooling water system), and one for all other mechanical
equipment (machine cooling water system). Direct contact water systems are used for spray
cooling and for flume flushing to transport scale from the caster runout table. Applied water
rates for the contact systems are typically about 3,600 gpt of cast product.17 Discharge rates for
the better controlled casters are less than 25 gpt. The principal pollutants are TSS, O&G, and
low levels of paniculate metals. Wastewater treatment includes scale pits for mill scale recovery
and oil removal, mixed- or single-media filtration, and high-rate recycle.

2.1.7 Hot Forming

In hot forming operations, ingots, blooms, billets, slabs, or rounds are heated to
rolling temperatures (about 1,800°F) in gas-fired or oil-fired reheat furnaces, and formed under
mechanical pressure with work rolls to produce semi-finished shapes for further hot or cold
rolling, or finished shapes for shipment Water use and discharge rates from hot forming
operations vary greatly depending upon the type of hot forming mill and the shapes produced.18
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. The principal pollutants are TSS and O&G. Low levels of
metals are found in particulate form.

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              Process water is used for scale braking, flume flushing, and direct contact cooling.
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; recycle of a large 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.
2.1.8
Salt Bath Descaling
              Salt bath descaling uses the aggressive physical and chemical properties of molten
salt baths to remove heavy scale from selected specialty and high-alloy steels.  Two processes,
oxidizing and reducing, are commonly referred to by the names of the proprietary molten salt
descaling baths, Kolene® and Hydride®, respectively.   These processes may be  batch or
continuous and are conducted prior to combination acid pickling (hydrofluoric and nitric acids).
Wastewaters originate from quenching and rinsing operations conducted after processing in the
molten salt baths. Principal pollutants are TSS, cyanides, dissolved iron, hexavalent and trivalent
chromium, and nickel. Wastewater flows normally range from 300 to 1,800 gpt, depending upon
the product and process.19 Descaling wastewaters are usually co-treated with wastewaters from
other finishing operations (e.g., combination acid pickling, cold rolling).
2.1.9
Acid Pickling
             The  most common  acid  pickling  processes  are sulfuric,  hydrochloric, and
combination 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. Nearly all pickling operations in the steel industry
involve immersion  of the steel in  acid and rinse tanks.  Process wastewaters include spent
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pickling acids, rinse waters, and pickling line fume scrubbers.  Process water and wastewater

flows vary greatly depending upon product and process.20 Waste pickle liquor flows typically

range between 10 and 20 gpt of pickled product.  Rinse water flows may range from less than

70 gpt for bar products to more than 1,000 gpt for certain flat-rolled products.  The principal

pollutants include 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.



             In-process controls include: countercurrent rinsing; use of indirect heating versus

direct steam sparging for acid solutions; and recycle and reuse of fume scrubber blowdowns.

Spent 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 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.  Rinse waters are

usually co-treated with wastewaters from  cold  rolling, alkaline cleaning, hot  coating, and

electroplating operations.



2.1.10       Cold Forming



             Cold forming involves cold rolling of hot rolled and pickled  steels at ambient

temperatures to impart desired mechanical and surface properties in  the steel, and cold working

of pipe and tube. In most cold rolling operations, the reduction in thickness is small compared

to that resulting from hot forming.  Cold rolling imparts hardness to the steel.  Annealing (heat

treating) and temper rolling are usually performed after the initial cold rolling to  obtain desired

mechanical properties.



             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.M  The principal pollutants are TSS,

O&G (emulsified), and metals (lead and zinc for carbon steels and chromium and nickel for
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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.  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.

              Conventional treatment of cold rolling wastewaters includes chemical emulsion
breaking,  dissolved gas flotation for gross oil removal, and co-treatment with other finishing
wastewaters for removal of toxic metals.
2.1.11
Alkaline Cleaning
              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. These finishing
operations may be conducted  in  separate cleaning  lines or as integral  parts of coating or
electroplating operations.  The cleaning baths are solutions of carbonates, alkaline silicates, and
phosphates in water.  Electrolytic cleaning may be used for high-production  operations. Because
the 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. Nearly all alkaline cleaning rinse operations in the steel industry involve immersion
in rinse tanks.  Alkaline cleaning wastewaters are usually co-treated with wastewaters from other
steel finishing operations.  Applied process water flow rates may range from 250 gpt to 350 gpt.
2.1.12
Hot Coating
              Hot coating operations comprise immersing precleaned steel into molten baths of
tin, zinc (hot dip galvanizing), combinations of lead and tin (terne coating), or combinations of
aluminum  and zinc (galvalume coating); any associated cleaning or fluxing steps  prior to
                                          2-12

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immersion; and any post-immersion steps (e.g., chromium passivation).  Cadmium hot coating

operations in the U.S. steel industry are limited to certain wire coating operations. The principal

purposes of hot coating are to improve resistance to corrosion, and for some products, improve

appearance.



             Wastewaters result principally from product rinses and fume scrubbers. In-process

controls include countercurrent rinses for lines with multiple rinses and recycle of fume scrubber

water.  The principal pollutants are usually  those associated with the coating  metal or metal

combinations and hexavalent chromium for lines with chromium brightening or passivation

operations. 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.  Applied process water rates may range from 600 gpt

for flat rolled products to 2,400 gpt for wire  products.



2.1.13        Electroplating



             Electroplating operations conducted at steel mills are  currently regulated by 40

CFR Part 433 - Metal Finishing, and not by 40 CFR Part 420. 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.   In  recent 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.



             Wastewater flows at large continuous strip electroplating lines are typically about

500 gpt.  The principal pollutants are TSS and O&G generated from the precleaning operations

and the plated metals from electroplating, rinsing, and fume scrubbers. Conventional wastewater

treatment includes metals precipitation. At some finishing mills, wastewaters from electroplating
                                          2-13

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lines are pretreated or treated separately to minimize the volume of listed hazardous waste sludge
generated due to heavy metal concentrations.
2.2
IndustrySegments
              The three principal types of steels produced in the United States are plain carbon.
steels, alloy steels, and stainless steels.  These are defined as follows:7
              Plain Carbon Steels.  Steels containing up to 1.65% manganese,
              0.60% silicon, 0.60%  copper,  and  smaller  quantities of other
              alloying elements.

              Alloy Steels.  Steels containing greater quantities of manganese,
              silicon, or copper than plain carbon steels, and/or steels containing
              specified minimum quantities of other alloying elements such as
              aluminum, chromium (less than 4%), cobalt, niobium (columbium),
              molybdenum, nickel, titanium, tungsten, vanadium, zirconium, or
              any other alloying element added  to obtain  a desired  alloying
              effect

              Stainless  Steels.   Steels  containing  at least  10% chromium in
              combination with other alloying elements.
              Carbon steels represent the most important group of engineered materials.  They

are produced in much greater quantities than alloy and stainless steels (see Section 2.4) and have

the most diverse applications of any engineered material.7  Common uses include castings,

forgings, tubular products, plates, sheet and strip, wire and wire products, structural shapes, bars,

and railway items (rails, wheels and axles).


              Alloy steels have enhanced properties due to the presence of the various elements

listed above.  They include construction alloy steels, high-strength low-alloy steels, alloy tool

steels, heat-resistant steels, and electrical steels (high-silicon steels).  Alloy steels are used where
                                          2-14

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enhanced properties of strength, foimability, hardness, weldability, corrosion resistance, or notch
toughness are desired for specific applications.

             Most stainless steels are produced as plates, sheets, strips, bars, tubes, and wires.
These  steels are specifically designed for corrosion-resistant applications or.where surface
staining is not desired.

             Each type of steel may be produced in BOFs or EAFs; however, many alloy and
stainless steels are produced in smaller EAFs to facilitate sequential production of low-tonnage
steels with varying composition.

             The three major segments of the U.S. iron and  steel  industry are: integrated
producers that operate coke  plants, blast  furnaces, and BOFs for high-tonnage production of
nearly all grades of carbon steels; nonintegrated producers that use EAF furnaces to produce
carbon steel bar products  and lower grades of  flat rolled products (i.e., the "mini-mills"); and
specialty  steel  producers  that produce  alloy  and  stainless steels, principally with  EAFs.
Manufacturing facilities within the U.S. industry vary hi terms of operations performed, but can
be classified into the five  major groups described below.

2.3          Classification of Manufacturing Plants in the U.S. Iron and  Steel Industry

             For purpose of this review,  manufacturing sites of the U.S. iron and steel industry
currently regulated by 40  CFR Part 420 are classified as follows.

2.3.1        Stand-Atone By-Product Coke  Plants

             Stand-alone by-product coke plants are facilities that produce metallurgical  coke
and are not located at integrated steel mills.  Typically, the coke produced is  sold under long-
term contracts to steel makers and on the spot market.  These facilities  may be owned by major
                                          2-15

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steel producers (e.g., U.S. Steel - Clairton Works; LTV Steel - Aliquippa, Chicago, and Warren
Plants), or may be smaller, independently owned and operated facilities (e.g., New Boston Coke,
Tonawanda Coke). This group of facilities includes the largest U.S. coke plant (U.S. Steel -
Clairton, 13,000 tons/day) and smaller facilities with typical production rates of 1,000 tons per
day.
2.3.2
Integrated Steel Mills
              Traditionally, integrated steel mills conducted all basic steelmaking operations (i.e.,
cokemaking, sintering, ironmaking, open hearth and/or EOF steelmaking, continuous casting);
hot forming; and steel finishing operations (e.g., acid pickling, cold rolling, alkaline cleaning, hot
coating,  and electroplating)  to  produce finished  steel products.   Today,  however, the term
"integrated mill" generally refers to facilities where steel is manufactured in BOFs from molten
iron produced in blast furnaces and scrap, as opposed to  nonintegrated mills where steel  is
manufactured in EAFs by melting various grades of steel scrap.  Due to consolidation of the
industry, cokemaking  and sintering  operations have been permanently shut down at many
integrated mills.   For the  most  part,  flat-rolled carbon steel products  for the automotive,
appliance,  construction,  and  food and  beverage markets  are produced  at  integrated mills.
Integrated mills may also have EAFs for producing steel from scrap steel.
2.3.3
Nonintegrated Steel Mills
              As noted above, nonintegrated mills (also known as "mini-mills") are those where
steel is manufactured from melting steel scrap in EAFs.  Nonintegrated mills generally produce
carbon, specialty, stainless, and high-alloy steels. These mills typically include a two- or three-
furnace EAF shop, a continuous caster, and hot rolling mills. Specialty, stainless, and high-alloy
steel mills include ladle metallurgy and vacuum degassing operations. Although nonintegrated
steel producers  are  making  inroads into carbon  steel flat-rolled markets, most  carbon steel
                                           2-16

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produced at nonintegrated mills is currently in the form of bar, rod, or wire. Both flat-rolled and

bar products are produced at specialty and high-alloy nonintegrated mills.



2.3.4         Stand-Alone Finishing Mills



              Stand-alone finishing mills process semi-finished steel into finished steel products..

Molten steel is not manufactured or processed at these sites. At most stand-alone finishing mills,

hot rolled steel is processed by a combination of acid pickling, cold rolling, alkaline cleaning,

hot coating, and electroplating operations.



2.3.5         Other Stand-Alone Operations



              In addition to stand-alone coke plants and finishing mills,  a limited number of

other stand-alone operations in the U.S. industry also exist These include a coke plant-sinter

plant-blast furnace combination; stand-alone blast furnaces; stand-alone hot forming  mills; and

stand-alone cold forming and wire mills. Many of these facilities are located near integrated steel

mills and  finishing mills to allow  for relatively inexpensive transportation of intermediate

products,  but  typically have separate  water and wastewater  treatment systems  and separate

discharge permits.



2.4           Changes in the U.S. Steel Industry - 1982 through 1993



              Table 2-2 presents a preliminary comparison of the number of facilities engaged

in basic steelmaldng operations in 1982 when the regulation was promulgated, and in 1993.8'14'22'23

The estimates presented in  Table 2-2  are preliminary because they were not derived from  a

comprehensive census of the industry. These results show the dramatic decrease in cokemaking,

sintering,  ironmaking, and steelmaldng facilities at integrated mills, and increases in continuous

casting.
                                          2-17

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2.5
Production Trends and Capacity Utilization
             Figures 2-2 through 2-9 present data regarding production trends and capacity
utilization for the U.S. iron and steel industry. These data were reported by AISI for. the period
1973 through  1993.24'29  AISI defines raw steel as steel in the first solid state after melting
suitable for further processing or sale, including ingots, steel for foundry castings and strand or
pressure cast blooms, billets, slabs or other product forms. Raw steel production capacity is
defined as the tonnage capability to produce raw steel for a sustained back-log of steel orders.
Steel production and steel shipments data reported by AISI are based upon reports by AISI
member and non-member companies.  Financial data do not represent data for all steel producing
companies. Financial data for 1992 and 1993 represent data for companies producing about 66%
of total raw steel produced.

             The U.S. iron and steel industry has undergone the following major consolidation
and changes during the period  1973 through 1993:  mergers and bankruptcies among the major
integrated steel producing companies; shutdown of smaller integrated companies and shutdown
of all or parts of several integrated mills; modernization of basic steelmaking operations; and
continued expansion of the  nonintegrated segment of the industry.  Figure 2-2 illustrates the
results of some of these changes.  Raw steelmaking capacity declined from a range of 150 to 160
million tons/year from 1973  to 1983,  to a range of 110 to 117 million tons/year during the early
                                                     •
1990s. Actual production peaked at approximately 150 million tons during 1973, reached a low
of approximately 75 million tons during the 1982 recession, and recovered  to about 98 million
tons during 1993.

             The industry is highly  capital-intensive, is cyclical with major economic trends,
and historically has required high-capacity utilization to generate  operating profits.  Figure 2-3
shows that capacity utilization during the period 1975 through 1993 was highly variable, reaching
the range of 85 to 88% during the  1977-1978 expansion, falling to less than 50% during  1982,
recovering  to nearly 90% during 1988, falling to  approximately 75% during the  1990-1991
                                          2-18

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              equipment, appliance, and construction industries, capacity utilization exceeded 91% for the first
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quarter of 1994.30

             During the period 1973 through 1993, estimated world  steel production fell to
approximately 710 million tons in 1982 and rose to 865 million tons in 1989.  Figure 2-4 shows
that U.S. raw steel production declined from nearly 20% of world supply in 1973 to a relatively
constant  range  of 10 to  12% during the late  1980s and  early  1990s.  There currently is
overcapacity in  world steel markets for many semi-finished and finished steel products.

             Figures  2-5 through  2-9  illustrate  important  trends  and changes  in  steel
manufacturing methods and  modernization  of the industry.  Prior to the advent of  EAF
steelmaking during the late  1930s,  virtually  all steel  produced in the United  States was
manufactured from molten iron (hot metal) produced in  blast furnaces.  Open hearth furnaces
were  the principal steelmaking  furnaces at integrated mills prior to the 1960s  when  BOF
steelmaking became widespread commercially. Figure 2-5 illustrates the decline in blast furnace
iron production from approximately 100 million tons/year in 1973 to a range of 48 to 56 million
tons/year from  1987 through 1992, and about 40% in  1993.  This dramatic decline is also
reflected in Figure 2-6, in the ratio of pig iron produced to raw steel manufactured.  These data
highlight the increasing trend of EAF steel production shown in Figure 2-7. Raw steel produced
in EAFs increased from approximately 10% in 1965 to a range of 35 to 38% during the period
1985 through 1992. Most of the  new EAF capacity was installed at nonintegrated mills ("mini-
mills") located to serve regional  areas principally in the bar, rod, wire, and structural markets.
More recently, nonintegrated mills have been constructed to produce flat-rolled steel products.

             Figure 2-8 shows U.S. raw steel production by type of steelmaking furnace for the
period 1973 through  1993. Open hearth furnace steelmaking declined from nearly 40 million
tons in 1973  to zero  in  1992, while EAF production increased from approximately 28 million
tons to a maximum of 38 million tons in 1993.  BOF steelmaking declined from approximately
                                         2-19

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 83 million tons in 1973 to a range of 53 to 59 million tons/year during the 1988-1993 period.
 While the industry has been consolidating and shifting toward a higher proportion of raw steel
 produced at nonintegrated mills, most mills have been modernized extensively to produce higher
 quality products and to compete  with imports to the U.S. market.  This trend is illustrated in
 Figure 2-9 by the significant increase in the percentage of raw steel continuously .cast as opposed
 to traditional ingot casting.  These data show the percentage of steel continuously cast increased
 from approximately 15% in 1978 to nearly 86% in 1993.  Installation  of continuous casters
 accounted for a large portion of the industry's investment in new plant and equipment during this
 period.
2.6
Product Mix
              Figure 2-10 presents steel shipments by type of steel (carbon, alloy, and stainless)
for the period 1973 through 1993. Carbon steels currently account for more than 90% of steel
mill shipments, alloy steels for less than 10%, and stainless steels for less than two percent.
During  the past six  years, there has been a trend of decreasing alloy steel shipments with a
corresponding increase in carbon steel shipments.  Stainless steel shipments have remained fairly
constant as a percentage of total steel shipments.
              Historical steel shipments for the period 1973 through 1993 by major grades and
markets are presented in Figures 2-11 and 2-12, respectively. The product data in Figure 2-11
show steady, slow declines in shipments of tin mill and wire and wire products, a significant
decline in pipe and tubing shipments in the early 1980s that has not since recovered, and variable
shipments of other products. Total shipments of all products were lower in the early 1990s than
during the early 1970s.  The results presented in Figure 2-11 are reflected in the data presented
in Figure 2-12.  A general trend of increasing shipments to steel service centers (processing
plants that perform various sizing and shaping operations on steel prior to resale) has occurred
in recent years, as end  users  have required more customized processing that can more
economically be provided at service centers than at producing mills.
                                          2-20

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2.7          Imports and Exports. Employment, and Financial Performance

             Figure 2-13 shows the import penetration to the U.S. steel markets of semi-finished
and finished steel products for the period 1973 through  1993 in millions of tons/year and as a
percentage of the apparent U.S. steel supply.  These data do not include steel imported as
manufactured goods  (e.g., foreign-made automobiles).  From  the late 1970s through the late
1980s, import penetration to the U.S. market has been a major factor limiting the ability of U.S.
manufacturers to raise prices and operate profitably. Import penetration peaked at approximately
26% of the U.S. supply  during 1984 and declined to a range of 16 to  19%  in recent years
because of a combination of voluntary import agreements with major importing countries, anti-
dumping actions against foreign  countries and  foreign steel-producing companies by U.S.
manufacturers, and the consolidation and modernization of much of the U.S. industry.

             Figure 2-14 presents plots of the value of steel imports and exports for the period
1973 through 1993.  The difference represents the net balance  of trade deficit in steel markets.
The deficit was approximately $2  billion in  1973, peaked at approximately  $9 billion in 1984,
and fell to less than $6 billion in recent years.  Factors contributing to the improvement in the
balance of trade include improved productivity by U.S. steel producers, the value of the U.S.
dollar compared  to foreign currencies, and economic performance of selected foreign economies.

             The consolidation and  modernization of the U.S. steel industry has resulted in a
major reduction  in direct employment by U.S. producers from over 500,000 people in 1973 to
approximately 127,000 in 1993, as shown annually in Figure 2-15. Part of the decline resulted
from direct jobs that were lost because many companies now contract for services provided
formerly by direct employees.

             Figure 2-16 shows the financial performance of companies  reporting financial
results to AISI for  the period  1973  through 1993.  These results generally reflect the large
integrated producers  and do not represent performance across the entire industry. Collectively,
                                         2-21

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the reporting companies showed operating profits during the period 1973 through 1981, and
substantial operating losses for many of the subsequent years.   Financial performance has
improved considerably during 1993 and 1994 as a result of the economic recovery in this
country, the weakness of the dollar compared to selected foreign currencies, and the improved
position of the U.S. industry in terms of overall productivity and the trend toward production of
higher grade products.
2.8
Capital Spending and Pollution Control Investments
             Figure 2-17 shows capital investment for new plants and equipment for the period
1973 through 1993 and for environmental controls by reporting companies for the period 1973
through 1992 (the 1993 environmental control expenditures were not available at this writing).
Also shown for each year is the percentage of the  total  capital invested for  environmental
controls. During this period, capital spending by reporting companies ranged from more than 3
billion dollars in 1976  to slightly  more than one billion dollars in  1986.  Environmental
expenditures ranged from 15 to more than 20% of total-capital investments during the period
1976 through 1981 when compliance programs associated with the amendments to the Clean Air
Act and Clean Water Act passed during the early and  mid-1970s were implemented.  The peak
was in 1979 at 20.9 percent. From 1982 to 1992, environmental expenditures ranged  from 4,4
to 12.9% of total capital investment.

             Figure 2-18 presents capital investment for environmental controls by reporting
companies  for the period 1951  through  1992,  broken out by investments in  air and water
pollution control facilities and solid  waste disposal faculties. AISI reports that, through 1992,
total capital investments for environmental controls exceeded $7.2 billion. Approximately $2.6
billion was invested in water pollution control facilities, $4.5  billion in air pollution control
facilities, and about $100 million in  solid waste disposal facilities.
                                         2-22

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Cokemaking
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Number of Blast Furnaces
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3.0          BACKGROUND OF CURRENT REGULATION



3.1          Prior Regulations



             EPA promulgated two regulations applicable to the iron and steel industry prior

to the current effluent limitations guidelines and standards at 40 CFR Part 420. The first was

promulgated on June 28, 1974 (Phase  1), and included Best Practicable Control Technology

Currently Available (BPT) and Best Available Technology Economically Achievable (BAT)

effluent limitations guidelines, and New Source Performance Standards (NSPS) and Pretreatment

Standards for New Sources (PSNS) for the following basic steelmaking operations:31
             By-product Cokemaking                  Beehive Cokemaking
             Sintering                               Blast Furnace (Iron)
             Blast Furnace (Ferromanganese)           BOF (Semi-wet)
             EOF (Wet)                             Open Hearth Furnace (Semi-wet)
             Open Hearth Furnace (Wet)              Vacuum Degassing
             Continuous Casting
             The terms "Semi-wet" and "Wet" refer to semi-wet and wet air pollution control

systems for the different types of steelmaking furnaces.



             In response to several petitions for review, the U.S. Court of Appeals for the Third

Circuit remanded the regulation to the Agency on November 7, 1975.32  The Court rejected all

technical challenges to the BPT effluent limitations guidelines, but ruled that the BAT effluent

limitations guidelines and NSPS for certain subcategories were not demonstrated. The Court also

ruled that EPA had not adequately considered the impact of plant age on the cost or feasibility

of retrofitting pollution control equipment, did not assess the impact of the regulation  on water

scarcity in arid and semi-arid regions, and failed to make adequate "net/gross" provisions for

pollutants found in intake waters.
                                         3-1

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             On March 26, 1976, EPA promulgated BPT effluent limitations guidelines and
proposed BAT  effluent limitations guidelines and NSPS  and PSNS for the following steel
forming and finishing operations:33
             Hot Forming - Primary
             Hot Forming - Flat
             Pickling - Sulfuric Acid
             Cold Rolling
             Hot Coatings - Teme
             Scale Removal
             Continuous Alkaline Cleaning
Hot Forming - Section
Hot Forming - Pipe and Tube
Pickling - Hydrochloric Acid
Hot Coatings - Galvanizing
Combination Acid Pickling
Wire Pickling and Coating
Miscellaneous Runoffs - Storage
Piles, Casting and Slagging
             In response to several petitions for review, the U.S. Court of Appeals for the Third

Circuit also remanded this regulation to the Agency on September 14, 1977.34  The Court again

rejected all technical challenges to the BPT effluent limitations guidelines; however, it again

questioned the regulation on the age/retrofit and water scarcity issues.  It also invalidated the

regulation as it applied to the specialty steel industry for lack of proper notice.  The Court
directed EPA to reevaluate its estimates of compliance costs with regard to certain "site-specific"
factors and to reexamine its economic impact analysis.  Finally, the Court also ruled that EPA

had no authority to exempt certain steel mills located in the Mahoning Valley of Ohio from the

regulation.


             The current regulation at 40 CFR Part 420 was proposed on January 7,1981, and

was promulgated on May 22,  1982.1'35  The regulation was last amended in May 1984 through

a negotiated Settlement Agreement with the iron arid steel industry and the NRDC in response

to challenges to the May 27, 1982 promulgation.1-2-3
                                         3-2

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3.2           Applicability



              Section 420.01 (a) presents the following general statement of applicability for Part
420:
              "(a) The provisions of this part apply to discharges and to the
              introduction of pollutants into a publicly owned treatment works
              resulting from production operations in the Iron and Steel Point
              Source Category."
              Section 420.0 l(b) provided a temporary exclusion from Part 420 for 21 steel mills

or parts of steel mills that were identified as having central treatment facilities at the time Part

420 was promulgated.  Section 420.0 l(b) is reviewed in detail in Section 3.6.1 below.



              In promulgating Part 420 in 1982, EPA addressed three court-remanded issues

from EPA's initial attempts to promulgate effluent limitations guidelines in 1974 and 1976:



              •     Inclusion of site-specific costs;


              •     Impact of plant age on the costs or feasibility of retrofitting control
                    facilities; and

              •     Impact of the regulation on the consumptive loss of water.



              In response to these issues, EPA modified its costing methodology to include site-

specific costs to the extent they could be reasonably estimated, evaluated whether costs to retrofit

control facilities at "older" mills would be disproportionately higher than similar costs for the

industry as a whole, and evaluated the potential consumption of water that might occur as a result

of compliance with  the  regulation.   Aside from the  temporary central treatment  exclusion

provided for selected mills at §420.0 l(b), which were promulgated independently of the remand
                                          3-3

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issues, no exclusions from Part 420 were provided for mills on the basis of age, size, complexity,
or geographic location as a result of the remand issues.

             The applicability statement presented in §420.01(a), and many of the applicability
statements for specific  subparts of the regulation,  are broad and include virtually all facilities
which manufacture or process coke, iron, steel, or semi-finished steel products.  As described in
Section 4.1, some changes may need to be considered for small, stand-alone facilities that may
perform operations on finished or  semi-finished  steel that are subject to Part 420.
3.3
Subcategorization
             When promulgating Part 420 in 1982, EPA revised the Subcategorization scheme
of the iron and steel industry from that specified in the  1974 and 1976 regulations to more
accurately reflect major types of production operations and to attempt to simplify implementation
of the regulation by permit writers and the industry. The following factors were considered in
revising the Subcategorization scheme:
                    Manufacturing processes and equipment;
                    Raw materials;
                    Final products;
                    Wastewater characteristics;
                    Wastewater treatment methods;
                    Size and age of facilities;
                    Geographic location;
                    Process water usage and discharge rates; and
                    Costs and economic impacts.
                                          3-4

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A.
B.
C.
D.
I.
J.
. Cokemaking
Sintering
Ironmaking
Steelmaking
Acid Pickling
Cold Forming
E.
F.
G.
H.
K.
L.
              EPA found that the type of manufacturing process was the most significant factor,

and subsequently divided the industry into the twelve process subcategories (subparts) listed

below:
                                                             Vacuum Degassing
                                                             Continuous Casting
                                                             Hot Forming
                                                             Salt Bath Descaling
                                                             Alkaline Cleaning
                                                             Hot Coating
These subcategories were further divided into subdivisions and segments as shown in Table 3-1.
              These processes and electroplating operations conducted at steel mills are briefly

described in Sections 2.1.1 through 2.1.13.  As described in Section 4.2,  the current industry

subcategorization as reflected in Part 420 could  be reorganized to more effectively regulate

nonintegrated steel producers; to include operations currently regulated under Part 433 - Metal

Finishing; to address new continuous strip steel finishing mills that include new metal coatings

and combinations of operations that currently fall under Pahs 420 and 433; and to delete obsolete

manufacturing processes.
3.4
Technology Bases for the Regulation
              The technologies considered by EPA for establishing the effluent limitations

guidelines and standards contained in Part 420 are, for the most part, based upon a combination

of process water flow reduction and conventional end-of-pipe wastewater treatment technologies.

Because of the capital-intensive nature of the industry and the lack of commercially available

new cokemaking, ironmaking, steelmaking, forming, or steel finishing technologies that could be

applied on an industry-wide basis,  EPA did not consider process change as a basis for the BAT
                                          3-5

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effluent limitations guidelines and NSPS  and PSNS contained in the current Part 420.  As
described in Section 6, there may now be opportunities to establish revised BAT and NSPS for
certain operations based upon process changes.

             When promulgating Part 420, EPA established Best Conventional Pollutant Control
Technology (BCT) effluent limitations guidelines only for the hot forming subcategory at a level
equivalent to BPT. BCT was not promulgated for any other subcategories.  For all subcategories
except cokemaking, PSES for nonconventional and toxic pollutants were set equal to BAT, and
PSNS  were set equal to NSPS.  PSES for cokemaking were based upon physical/chemical
treatment as opposed to a combination of physical/chemical treatment and biological treatment
for BAT.

             Appendix A contains a series of schematic diagrams showing the technologies
considered by EPA in developing the effluent limitations guidelines and standards for each
subcategory.8 Following are brief summaries of the selected major model technologies for BPT
and BAT/NSPS for each subcategory:

             Cokemaking
                    BPT. Recycle of final cooler water, dissolved gas floatation for
                    benzol plant  wastewaters, free and  fixed  ammonia stripping,
                    equalization, and single-stage activated sludge.
                    BAT.  BPT plus recycle  of ammonium crystallizer water and
                    modify single-stage activated sludge to two-stage activated sludge
                    with nitrification.
                                         3-6

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Sintering
      BPT.  Clarification and recycle (92%) of air emission control
      scrubber water and sludge dewatering.


      BAT/NSPS.   Recycle system blowdown treatment  comprising
      metals  precipitation,  two-stage  alkaline  chlorination,  and
      dechlorination.
Ironmaking
      BPT.  Clarification, cooling, and recycle (96%) for blast furnace
      gas cleaning and gas cooling waters, and sludge dewatering.


      BAT/NSPS.   Increased  recycle  (98%)  and recycle system
      blowdown treatment comprising metals precipitation, two-stage
      alkaline chlorination, and dechlorination.
Steelmaking
      BPT.   Clarification  and recycle  (95% EOF  -  Suppressed
      Combustion; 90% EOF - Open Combustion; 94% Open Hearth
      Furnace; 95% EAF) of Steelmaking  wet air emission control
      scrubber water, and sludge dewatering. Recycle to extinction of
      gas conditioning water for BOFs and EAFs equipped with semi-wet
      air emission control systems.


      BAT/NSPS.   Recycle system blowdown treatment  comprising
      metals precipitation and pH control for Steelmaking furnaces with
      wet air emission control systems.
                           3-7

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Vacuum Degassing
      BPT.  Sedimentation  and recycle (98%) for condenser contact
      cooling waters.

      BAT/NSPS.  Recycle  system  blowdown  treatment comprising
      metals precipitation and pH control.
Continuous Casting
      BPT. Closed loop cooling for casting machine and mold cooling
      water systems; sedimentation, filtration, cooling,  and recycle
      (96.3%) for spray  water.

      BAT/NSPS.   Increased  recycle (99.3%) and  recycle  system
      blowdown  treatment  for   spray  water  comprising  metals
      precipitation and pH control.
Hot Forming
      BPT/BCT.  Sedimentation and oil skimming, partial recycle of
      scale pit effluents (Primary Mills - 61%; Section Mills - 58%; Hat
      Mills - 60%;  Pipe and Tube Mills  -  77%), clarification and
      filtration, and sludge dewatering.

      BAT.  Not promulgated because of low toxic metals loadings and
      high cost of high-rate recycle.

      NSPS. Sedimentation, partial recycle of primary scale pit effluents,
      clarification, cooling, additional recycle (to 96%), recycle system
      blowdown filtration, and sludge dewatering.
                           3-8

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I


I

I                        Salt Bath Descaling


I                        •     BPT.   Oxidizing:   Reduction  of hexavalent  chromium,  oil
™                              skimming, metals precipitation, and sludge dewatering,

I                              BPT.    Reducing:    Two-stage  chlorination,  metals
™                              precipitation, and sludge dewatering.

I                        •     BAT/NSPS.  Effluent limitations guidelines and standards based
™                              upon BPT technologies.


"                        Acid Pickling


                          •     BPT.   Recycle of fume  scrubber waters, equalization,  oil
_                              skimming, metals precipitation, and sludge dewatering.

                          •     BAT/NSPS.   Acid regeneration plant  absorber  vent  scrubber
_                              recycle, and countercurrent cascade pickling rinses.


_                        Cold Forming - Cold Rolling


                          I*     BPT.   Primary  oil removal, emulsion  breaking, dissolved gas
                                flotation, and sludge dewatering. Contract hauling of waste rolling
                                solutions for limited applications.

|                        •     BAT/NSPS.  Effluent limitations guidelines and standards based
                                upon BPT technologies.

I
                          Alkaline Cleaning

I
                          •     BPT.  Oil skimming, pH control, and clarification.

I
BAT. Not promulgated because of low toxic pollutant loadings.


NSPS.  Standai
flow reduction.
 8                        •      NSPS.  Standards based upon BPT technologies with additional


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                     3-9

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             Hot Coating
                    BPT.  Reduction of hexavalent chromium, equalization and oil
                    removal, metals precipitation, and pH control.
                                                       i
                    BAT/NSPS.  Recycle of fume scrubber waters.
3.5
Regulated Pollutants
             Table 3-2 presents, by subcategory, the conventional, nonconventional, and priority
(or toxic) pollutants regulated by Part 420.  The regulated pollutants were selected based upon
process wastewater characteristics in each subcategory in terms  of pollutant  loadings and
concentrations,  whether controlling certain pollutants  would result in comparable control  of
similar pollutants (e.g., limitations for lead and zinc based upon metals precipitation technology
would control  other metals not  directly  limited), and  whether co-treatment of compatible
wastewaters would be encouraged by limiting the same pollutants in different subcategories.  A
principal concern expressed by the Agency was the potential for dilution of toxic metal and toxic
organic pollutants from co-mingling and co-treatment of incompatible wastewaters.36

             EPA regulated the pollutants in Table 3-2 and grouped the following subcategories
to attempt to restrict indiscriminate mixing of incompatible wastewaters and dilution of toxic
pollutants:
                                         3-10

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             Group        Subcategories


             1             Cokemaking


             2             Sintering, Ironmaking


             3             Steelmaking,  Vacuum Degassing,  Continuous  Casting,  Acid
                           Pickling (B^SO4,  HC1), Cold  RoUing, Alkaline Cleaning, Hot
                           Coating


             4             Specialty Steel  Operations:  Salt Bath  Descaling, Acid Pickling
                           (Combination), Cold Rolling



             This aspect of the regulation is reviewed in more detail in Sections 3.6 and 4.4

with the Central Treatment provisions set out at §420.01(b).



3.6          General Provisions



             The General  Provisions  of the regulation contain the  applicability statement

described above at §420.01(a); the temporary central treatment exclusion for selected facilities

and parts  of facilities at  §420.01(5); general  definitions at §420.02;  an alternative effluent

limitations  provision for BPT,  BCT, and BAT, otherwise  known as  the  "water bubble", at

§420.03; a statement of basis for determining the appropriate production level for calculating

mass-based pretreatment standards at §420.04; a pretreatment  standards compliance date at

§420.05; and a provision  that would allow pretreatment removal credits for phenols (4AAP)

under certain circumstances, at §420.06.



             Because of their actual and potential significance in the regulatory framework for

iron and steel mills, the temporary central treatment exemption at §420.0 l(b) and the "water

bubble" rule at §420.03  are reviewed  separately below and in Section  4.4.  The general

applicability statement at §420.01 (a) and the  applicability  statements  for selected subcategories

are reviewed in Section 4.1.
                                         3-11

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             The General Provision regarding the appropriate production rate for establishing
mass categorical pretreatment standards is a more refined statement of the production basis used
to determine mass NPDES permit effluent limitations set  out at §122.45(b).  For the iron and
steel industry, most NPDES  permits and pretreatment standards have been computed based on
the daily average production for the month with the highest production that occurred over the
prior five years at the time of permit issuance.  Because of the cyclical nature of operations at
most steel mills, this approach results in what may be inflated effluent limitations or pretreatment
standards in some cases.  This  issue is reviewed in Section 4.4.

             Because the recently promulgated removal credits provisions of the pretreatment
regulations at §403.7 specifically list the priority pollutant phenol as being eligible for removal
credits, and do not list the nonconventional pollutant phenols (4AAP), General Provision §420.06
regarding possible removal credits for phenols (4AAP) does not appear to be applicable at this
time.
3.6.1
Central Treatment
             During development of the current Part 420, the industry requested that EPA
develop a subcategory for "central treatment" facilities (i.e., facilities that provide treatment for
wastewaters from multiple subcategories). In the promulgation of Part 420, EPA did not include
a central  treatment subcategory.   Upon examination of this issue, the Agency found that
numerous combinations of centralized treatment systems were used by the industry.37  Many
treated wastewaters were compatible (i.e., the mix  of  pollutants present was such  that the
treatment provided would be essentially the same as that provided if the wastewaters were treated
separately, or that certain wastewaters could be effectively pretreated for selected pollutants and
then mixed and co-treated with similar wastewaters). EPA also found other types of centralized
treatment  facilities where incompatible  wastewaters were  mixed and  co-treated  without
pretreatment. In  many of these systems, mass discharges of pollutants were much higher than
could be achieved if only compatible wastewaters were co-treated and incompatible wastewaters
                                          3-12

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were treated separately. The principal issue raised by the industry was that the cost to retrofit

separate treatment facilities at mills with certain types of centralized treatment facilities would

be excessive when compared to the Agency's estimated costs of compliance.



             Because EPA could not resolve cost  issues at mills with centralized treatment

facilities during development of Part 420, it established a scheme in the proposed regulation

whereby alternative, less stringent limitations  could be obtained for mills or parts of mills

provided the  owners or operators made certain demonstrations regarding the costs to retrofit

pollution control facilities.  Seven mills or parts of mills were identified by EPA from a list of

35 mills provided by the industry as possibly qualifying for such alternative effluent limitations.

Based upon comments received in response to the proposed regulation,  EPA  expanded the list

to 21 mills in the final regulation.



             Section 420.0 l(b) provided that these facilities were temporarily excluded from

Part 420 provided that the owner or operator made the required demonstrations set out in the

regulation. These included an estimate of the cost to fully comply with Part 420 and estimates

of the effluent limitations that could be achieved if the owner or operator were to spend  an

amount equal to the Agency's model treatment system cost estimate to comply with Part 420.

The regulation also required supplemental wastewater quality,  production,  and other data.

Although §420.0 l(b) does not address the extent of the temporary exclusion, the preamble to the

regulation at 47 FR 23267 stated that the Agency's intent was that the temporary exclusion was

not to exceed one year from date of promulgation.



             As described more fully in Section 4.4,  none of the  21 facilities  listed  in

§420.0 l(b) received alternative, less stringent effluent limitations or pretreatment standards

through the mechanism established by the  regulation. Because the central treatment provision

remains in the regulation, the owners or operators of two listed facilities are currently attempting

to use §420.0 l(b) as a vehicle to obtain less stringent NPDES permit effluent limitations than

would otherwise be required under Part 420.
                                       .  3-13

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3.6.2
Water Bubble
              Section  420.03 (commonly known  as  the "water bubble"  role)  provides  a
mechanism whereby dischargers with multiple outfalls  may  discharge  greater quantities of
pollutants from outfalls where treatment costs  are high in exchange for a larger  decrease in
discharges from outfalls at the same plant where treatment costs are less. The regulation provides
that there can be only intraplant trades and no interplant trades; that only like pollutants can be
traded (e.g., zinc for zinc, not zinc for lead or ammonia-N); that minimum net reductions of 10%
for toxic and nonconventional pollutants and 15% for conventional pollutants must be achieved;
and, that trades within certain subcategories are restricted (cokemaking and cold rolling). These
restrictions were included to ensure there would be no inadvertent excess discharge of toxic
organic pollutants from these operations in implementing the water bubble rule.

              Although the water bubble rule has not been used by many mills, the present value
of the cost reductions of intraplant trading at seven mills was recently estimated at $122.7 million
(1993 dollars).38 Possible modifications to the water bubble rule are reviewed in Section 4.4.

              At the time the current Part 420 was under review for promulgation, U.S.  EPA
evaluated whether to develop a water  bubble type rule for other industrial categories including
petroleum refining, organic chemicals, pulp and paper, and metal finishing. The Agency found
that a water  bubble rule would  not be effective for these and other categories  because  most
manufacturing facilities in these categories do not have multiple process  wastewater treatment
facilities and multiple outfalls that are characteristic of integrated steel mills.
                                          3-14

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                                                       3-18

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Table 3-2
Iron and Steel Manufacturing Processes
Pollutants Limited by 40 CFR Part 420

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S S

Total Metats
Chromium
Chromium +6
Lead
Nickel
Zinc


S S








S N S
Toxic Organlcs
Benzene
Benzo-a-pyrene
Naphthalene
Tetrachloroethylene
3-19

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4.0          ASSESSMENT OF CURRENT REGULATION



4.1          Applicability



             The combination of the general applicability statement at §420.01 (a) and the

subcategory-specific applicability statements make Part 420 applicable to virtually all facilities

that manufacture steel or process semi-finished and finished steel products.  As described below,

there are relatively few issues associated with applicability statements for the basic steelmaking

operations; however, applying Part 420 to small, stand-alone facilities which perform some steel

finishing and metal finishing operations has resulted in a number of NPDES and pretreatment

issues.  Following are brief reviews of the subcategory-specific applicability statements and

preliminary assessments of possible modifications.



4.1.1         §420.10 - Cokemaking



             The current applicability statement applies the current regulation  to by-product

recovery coke plants and beehive coke plants; however, operating  beehive coke plants in the

United  States no  longer  exist.   In addition, .the applicability statement  does not address

nonrecovery coke batteries (discussed on pages 6-1 and 6-2).  Although nonrecovery cokemaking

has not been installed at any major integrated mills, this technology allows for cokemaking with

comparatively few air emissions and wastewater discharges.



4.1.2         §420.20 - Sintering



             The sintering applicability statement is written such that the regulation applies only

to sintering plants.  Currently, there are tenoperating sinter plants in the United States, compared

to 33 when the regulation was promulgated. Because of the potential difficulties in permitting

new sinter plants from an air emissions standpoint, it is not likely that very  many will be

constructed in the near term.  Some steel makers have been evaluating and installing hot and cold
                                          4-1

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briquetting plants to recover iron values from both blast  furnace and steelmaking  sludges.
Briquetting plants are also used at Direct-Reduced Iron (DRI) plants for agglomerating DRI into
a form that can be charged to steelmaking furnaces.  Although  most  briquetting plants use
minimal process water compared to sinter plants with wet air emission control systems, they are
not regulated by Part 420.  Also, because sinter plants can  be operated with dry air emission
control systems, zero discharge could be considered for NSPS and PSNS on the basis of dry air
controls.  The current NSPS and PSNS are based upon wet air emission control systems. Dry
air emission controls are currently used in the U.S. by three sinter plant operators to comply with
current air emission regulations
4.1.3
§420.30 - Ironmaking
             The  ironmaking  subcategory  includes  iron-producing  blast furnaces  and
ferromanganese-producing blast furnaces.  Ferromanganese is no longer produced in blast
furnaces in the United States. The ironmaking subpart does not apply to DRI plants which can
have process wastewater discharges.
4.1.4
§420.40 - Steelmaking
             The applicability statement for steelmaking operations appears adequate to cover
existing conventional BOF and EAF steelmaking operations. It also encompasses open hearth
furnaces which are no longer used for steelmaking in the United States. Ferroalloy products are
also manufactured in EAFs; however, the applicability statement for the steelmaking subcategory
does not need to be amended to specifically exclude manufacture of ferroalloys in EAFs because
the applicability statements in Part 424 are specific to ferroalloys.
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4.1.5         §420.50 - Vacuum Degassing



              The applicability statement appears adequate for existing  vacuum degassing

operations. Most new vacuum degassing plants are installed as part of ladle metallurgy stations

that typically have dry air cleaning systems for the nondegassing operations.  NSPS could be

developed based upon dry air emission controls to ensure that no wet systems are installed for

nondegassing ladle metallurgy operations.



4.1.6         §420.60 -  Continuous Casting, §420.70 - Hot Forming, §420.80, Salt Bath

              Descaling



              Currently, there are no known or suspected issues associated with the applicability

statements for the continuous casting, hot forming, or salt bath descaling subcategories.



4.1.7         Steel Finishing:  §420.90 - Acid Pickling, §420.100 - Cold Forming, §420.110 -

              Alkaline Cleaning, and §420.120 - Hot Coating



              As noted  in  Section 3.0, there are a number  of  issues associated with the

applicability of Part 420 to small, stand-alone facilities that process semi-finished steel products.

The current applicability statements for the steel finishing operations (acid pickling, cold forming,

alkaline cleaning, and hot coating) apply Part 420 to virtually all facilities that perform any of

the above operations on steel that are not regulated under Part 433 - Metal Finishing, This raises

the following issues:
                    The effluent limitations guidelines and standards in Part 420 were
                    based upon the flow rates and treated effluent quality attained at
                    large steel finishing mills with co-treatment of compatible steel
                    finishing and metal finishing wastewaters.


                    Exceptionally low treated effluent concentrations of toxic metals
                    are attained in these systems with conventional lime precipitation
                                          4-3

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                     as a result of coprecipitation of toxic metals with ferrous and ferric
                     iron present from acid pickling operations.

                     Many of the small, stand-alone facilities do not have the benefit of
                     co-treating  significant volumes of pickling rinse waters and thus
                     have difficulty readily achieving the same effluent quality with the
                     model technologies. This is particularly true of stand-alone hot dip
                     galvanizers.

                     Small, stand-alone facilities not affiliated with major steel finishing
                     operations tend to have higher flow rates per unit of production
                     than do  the  large flat-rolled, continuous  strip  steel finishing
                     facilities used as  the basis for the effluent limitations guidelines
                     and standards.
              It may be appropriate to consider revision to Part 420 to address these issues.
Because of their similarity to metal products and machinery facilities, small stand-alone steel

finishing plants may be more appropriately regulated under  the  new Metal Products  and

Machinery Category.


              The applicability statement for the alkaline cleaning subcategory  should be made
clearer as to how alkaline cleaning operations integral to hot coating and electroplating lines are

regulated.  Some permit writers have double-counted these operations within a  facility.
4.1.8
§433 - Metal Finishing
              Electroplating of chromium, tin, zinc, and other metals onto steel at steel finishing
plants is regulated by Part 433 - Metal Finishing.  As described in Section 4.3, it may be more

appropriate for these operations to be regulated by Part 420 as a new subcategory.
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4.1.9         New Steel Finishing Operations



             During the past five to seven years, several (approximately ten) new continuous

strip steel finishing facilities have been constructed to respond to demands  from automobile

manufacturers for higher quality electro-galvanized steels, steels coated with other metals, and

new combinations of metals.   At some of these plants, steel  finishing and metal finishing

operations are conducted on the same extended processing lines without the shearing and re-

welding of coils that is typical for these types of process lines.  These operations complicate the

discharge permitting process because the effluent limitations guidelines and standards contained

in Parts 420  and  433 are  different in  terms  of method of application  (mass-based vs.

concentration-based) and level of final effluent quality (see Section 4.3).  Sufficient numbers of

these  facilities  exist to  consider a separate subcategory on the basis of the mix of process

operations and wastewater characteristics.



4.2          Subcategorization



             Based upon the issues presented above, the following modifications to the existing

Subcategorization of Part 420 are presented for consideration:
             Cokemaking.  Delete beehive coke plants and add nonrecovery
             coke plants.


             Sintering. Add a segment for briquetting operations.


             Ironmaking.   Delete ferromanganese  blast furnaces, and add a
             segment for Direct-Reduced Iron plants.


             Steelmaking. Delete open hearth furnaces.


             Vacuum Degassing.  Add a segment for nondegassing operations
             at ladle metallurgy stations.  .
                                          4-5

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              Acid Pickling, Cold Forming, Alkaline Cleaning, Hot Coating.
              Develop  a size cut-off  or otherwise modify the applicability
              statements to exclude  small, stand-alone facilities  that perform
              some or all of the steel finishing operations.  The facilities could
              be covered by the new Metal Products and Machinery Category.
              Deletion of existing obsolete subcategories is presented because it may not be

appropriate to leave effluent limitations guidelines and standards for obsolete processes with

inherent high-pollution generation rates  and high process water use.


              In addition to changes to existing subcategories suggested above for review, it may

be appropriate to create new subcategories to better reflect the current iron and steel industry and

to more effectively regulate steel and metal finishing operations conducted at steel mill sites:
              Nonintegrated Steel Mills.  Nearly all nonintegrated steel mills
              (mini-mills) are configured  with  EAFs with  dry primary  and
              secondary air emission controls; continuous billet, round, or slab
              casters; and section, flat, or pipe and tube hot forming mills.  A
              small number are also equipped with steel finishing facilities (e.g.,
              acid pickling, cold rolling, hot coating). It is common practice at
              nonintegrated mills to co-treat compatible continuous caster spray
              water and hot forming process water in high-rate process water
              recycle systems, and to co-treat blowdowns from these systems.
              This is not the case at nearly all integrated mills where hot forming
              and continuous caster process waters are independently treated and
              recycled.  The current regulation includes limitations for total lead
              and total zinc for continuous casters, but no limitations for these
              metals for hot forming  mills.  This  has  created a  number of
              permitting  issues for these  facilities.   A  new subcategory for
              nonintegrated  steel mills could be created to more effectively
              regulate these facilities.

              New  Continuous Strip Finishing  Mills.    As  described in
              Section 4.1.11, a subcategory to specifically regulate this new type
              of finishing mill could be developed.  The mills are characterized
              by continuous in-line acid pickling, cold rolling, annealing, temper
              rolling, and/or hot coating and electroplating operations. Some of
              these mills cannot be effectively regulated by  either the current
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             Part 420 or Part 433, or by a combination of the two regulations.
             In some cases, new metal coatings and  combinations of metal
             coatings are applied that were not in use at the time Parts 420 and
             Part 433 were promulgated.


             Electroplating Conducted at Steel Mills. Because of the factors
             described in Section 4.3, a new subcategory for electroplating of
             chromium, tin, zinc, other metals, and combinations of metals may
             be appropriate.  The effluent limitations guidelines and standards
             for steel finishing operations were based upon performance of
             treatment systems that co-treat steel finishing and metal finishing
             process wastewaters; and the effluent limitations guidelines and
             standards in Part 433 are much less restrictive than the comparable
             effluent  limitations  guidelines  and  standards  in  Part  420.
             Accordingly, NPDES permit effluent limitations  and categorical
             pretreatment limitations based upon a combination of the two
             regulations are much less restrictive than would be allowed under
             Part 420 alone.  Some owners and operators of steel mills have
             sought to take advantage of this circumstance through application
             of the "water bubble" rule (§420.03).
4.3          Better Performing Mills



             In order to  assess on a preliminary basis possible advances in process water

management, process wastewater treatment technologies, wastewater treatment performance, and

effluent disposal practices, EPA obtained treated effluent data and production data from a number

of mills believed to be among the better performing mills located in North America.  Some of

the data were gathered by the Ontario Ministry of the Environment as part of that agency's study

of its  Iron  and  Steel Sector  for  its  Municipal/Industrial Strategy  for  Abatement  (MISA)

program.39'40 Additional data were assembled during this preliminary assessment. Although the

limited number of mills selected for review are believed to be among the better performing mills

in North America, the selection process was based upon personal knowledge of the project team

and not upon a comprehensive survey of the industry.  Any technology, whether or not used on

a permanent basis in the U.S. or  any other country, is a candidate technology for BAT and/or
                                         4-7

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NSPS, There may be other mills with equal or better performance and there are many mills that
do not perform as well as the mills included in this review.

             The approach taken was to obtain  daily effluent performance  data and total
monthly production during a period of relatively high production. For purposes of this report the
"long term average" is the arithmetic mean of the effluent data collected over a period of time
ranging from six months to more than one year, depending upon the specific treatment system
being evaluated.  These data were  used to compute long-term average concentrations, mass
discharges of monitored pollutants, and long-term average effluent flows.  The mass discharge
data were divided by the long-term average production data to establish  a long-term average
production-normalized discharge rate for each monitored pollutant in terms of mass of pollutant
discharged per mass  of production (kg/kkg or lbs/1,000 Ibs). These results were compared on
a mill-by-mill basis to the long-term average production-normalized discharge rates in kg/kkg for
the currently applicable BPT, BCT, and BAT effluent limitations guidelines and NSPS from Part
420. Where process wastewaters from manufacturing operations in different subcategories were
co-treated, the long-term average discharge for each manufacturing  operation was estimated in
proportion to discharge flow for each operation.

             A modified approach was used for steel finishing mills that are currently regulated
by  a combination of Parts 420  and 433.  For these mills, the long-term average effluent mass
discharges were divided by the long-term average hydrochloric acid (HC1) pickling production
data to obtain production-normalized discharge loads for each monitored pollutant in kg/kkg of
HC1 pickled product. To develop a comparable long-term  average discharge load that would
result from application of Parts 420 and 433, the long-term average mass discharge rate in kg/day
was determined for both Parts  420  and 433.  These discharge rates were added together and
divided by the HC1 pickling production rate to obtain a production-normalized discharge load in
kg/kkg (lbs/1,000 Ibs) of HC1 pickled product that could be directly compared against the actual
long-term average production-normalized discharge loads.
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              The results of these comparisons are presented in tabular form in Appendix B and
 in Figures 4-1 through 4-8.  The data in Figures 4-1 through 4-8 are presented as percentages
 below and above the long-term average production-normalized discharge rates derived from the
 effluent limitations guidelines and standards (ELG LTA). The ELG LTAs are thus shown at the-
 zero  line on each  figure.   Performance better than the  ELG LTAs  is shown by negative
 percentages above the zero line, with negative 100% representing zero discharge.  Performance
•less than the ELG LTAs is designated by positive percentages below the zero line. A default
 value of positive 100% was selected for mills with long-term average production-normalized
 discharges two or more times the ELG LTAs to maintain a reasonable scale for these plots.  The
 results for each subcategory are reviewed below.

 4.3.1         Cokemaking • Figure 4-1

              The comparisons show performance substantially better than the ELG LTAs for
 most monitored pollutants for the three coke plants selected for review, the exceptions being total
 cyanide and phenols (4AAP). Performance of nearly 80% better than BAT is indicated.  At the
 time of data collection, Mills A and B  had  coke plant biological treatment systems in place
 comparable to the model technologies used by EPA to establish the effluent limitations guidelines
 and standards. Mill C has a conventional coke plant biological treatment system that is followed
 by co-treatment of the coke plant effluent with blast furnace blowdown  by equalization, metals
 precipitation,  alkaline chlorination  and filtration.   This  level  of  treatment is beyond  that
 considered BAT by EPA in 1982.

              There is also one U.S. coke plant equipped with a BAT type physical/chemical and
 biological  treatment system followed  by  sand filtration  and granular  activated  carbon.
 Performance data were not available at this writing to develop production-normalized wastewater
 loadings for this facility.
                                          4-9

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4.3.2
Sintering - Figure 4-2
             Results for two sintering plants are presented in Figure 4-2.  At Mill D, the
process waters are commingled in one treatment and recycle system. A large portion of the sinter
plant/blast furnace .blowdown at Mill D is disposed of by slag quenching (evaporation on blast
furnace slag in  slag pits located at the blast furnaces).  The portion of the blowdown that is
discharged is not treated. At Mill E, sintering and blast furnace process waters are separately
treated and recycled. The blowdowns from the recycle systems at this mill  are mixed and co-
treated in a blowdown treatment system consisting of metals precipitation.

             The comparisons show better performance for all pollutants at Mill D and better
performance for most pollutants at Mill E, the principal exceptions being ammonia-N and phenols
(4AAP).  Mill  E has an application pending for a Section 301(g) variance from BAT for
ammonia-N and phenols (4AAP).  These results suggest that near zero discharge levels can be
attained at mills where  slag quenching is an  available option and  that effluent performance
substantially better than  BPT/BAT can be obtained for TSS, total cyanide, and total lead with
metals precipitation of sinter plant recycle system blowdowns.

             Figure 4-2 presents effluent quality data for Mill C transferred to the EPA model
BAT sinter plant wastewater treatment system flow of 120 gallons  per ton. As described in
Section 4.3.1, Mill  C is  equipped with a blowdown treatment system comprising metals
precipitation, alkaline chlorination, and filtration for treatment of combined coke plant and blast
furnace process wastewaters.   Except for  final  effluent filtration, this  treatment system is
equivalent to EPA's selected model BAT treatment system for  sintering and ironmaking
operations. The transferred data show production-normalized loadings  substantially  better than
the  BAT ELG LTAs  for all pollutants  except  for ammonia-N,  where  performance is
approximately 20% better than BAT.
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4.3.3         Ironmaking - Figure 4-3"

             The blast furnace systems selected for review include those that are equipped to
dispose of a portion of the gas wash water and gas cooling water recycle system blowdowns by
slag quenching (Mills F and G), and those that are not equipped for slag quenching (Mills C, E,
H, and I). Many blast furnace operators have applied for or obtained Section 301(g) variances
from BAT for ammonia-N and phenols (4AAP). This accounts for performance less than the
ELG LTAs for these pollutants. In addition to the blast furnace systems included in this review,
other blast furnace systems are operated at or near zero discharge through slag quenching.

             Mills  H and I are equipped with metals precipitation systems for  blast furnace
recycle system blowdowns.  Mill C (described above in Section 4.3.1 - Cokemaking) has a blast
furnace blowdown treatment  system equivalent to EPA's model BAT and NSPS treatment
systems.  This mill demonstrates better performance  then the ELG LTAs for most pollutants
despite a higher blowdown flow than the EPA model  treatment system blowdown flow rate.

             The results presented in Figure 4-3 show that performance substantially better than
the ELG LTAs is  being achieved for most pollutants for which treatment is provided.

4.3.4         BOF Steelmaking - Figure 4-4

             Performance data for three wet - suppressed combustion BOF Steelmaking shops
and two  wet - open combustion BOF  shops are presented in Figure 4-4.  Each  BOF shop is
equipped with a treatment and recycle system comprising partial recycle at the furnaces, external
clarification facilities, and additional recycle of clarified gas cleaning water.

             For the suppressed combustion systems,  Mill F achieves zero discharge for
extended periods  of time  by using  carbon dioxide injection for  water softening of the
recirculating water to prevent fouling and scaling.  Blowdowns are intermittent and average about
                                        4-11

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5 gpt. The treatment systems at Mills C and G are similar to the EPA model treatment systems.
Although  the  treated  effluent concentrations  at Mill  C are lower than  the ELG  LTAs,
performance at Mill C in terms of kg/kkg (lbs/1,000 Ibs) is adversely affected by blowdown
flows that are much higher than those from the EPA model treatment systems.

             Performance at Mill B (open combustion) is substantially better man the ELG
LTAs for all monitored pollutants. Recycle system blowdown treatment consists of filtration.
Performance at Mill H is better than the ELG LTAs for TSS and total lead, but not as good for
total zinc.  Blowdown treatment at the  time  these data were obtained  consisted of  metals
precipitation using sulfide. The performance at this mill is primarily a function of blowdown
flows higher than the EPA model treatment system flow rates.

             Collectively, these results demonstrate that performance approaching zero discharge
for suppressed combustion BOFs and performance substantially better than the ELG LTAs for
open combustion BOFs can be achieved with conventional treatment technologies.
4.3.5
Vacuum Degassing - Figure 4-5
             Performance data were obtained from Mills C and F for their vacuum degassers.
The vacuum degasser at Mill C is equipped with a dedicated recycle system for condenser
cooling water.  The recycle system blowdown is combined with recycle system blowdowns from
BOF  steelmaking,  continuous casting,  and a hot strip mill before  treatment in a  metals
precipitation system.  This level of treatment is equivalent to the EPA model BAT and NSPS
treatment systems.

             The Mill F treatment system is essentially the same as for Mill C's except that,
in Mill  F, the blowdown from the dedicated vacuum degassing recycle  system is treated
separately for zinc in a dedicated metals precipitation system prior to discharge to a combined
treatment system for a suppressed-combustion BOF and a continuous slab caster.
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4.3.6         Continuous Casting - Figure 4-6

             Performance results for four continuous slab casters are presented in Figure 4-6.
Each caster is equipped with closed-loop cooling systems for mold and machine cooling water
and spray water recycle systems consisting of scale pits with oil removal, filtration, and recycle.
Mill J, which is a nonintegrated mill, operates two thin-slab casters. The blowdowns from these
casters are cascaded to other process  water recycle systems and ultimately disposed of through
evaporation  by direct contact  cooling of EAF electrodes, resulting in zero discharge.  This
method of effluent disposal may not be applicable to all continuous casters.

             Performance at the other casters demonstrates that effluent quality substantially
better than the ELG LTAs can be achieved with conventional treatment.

4.3.7         Hot Forming: Hot Strip Mills - Figure 4-7

             Performance data for four hot strip mills were obtained for this review. Three are
located at large integrated mills and one is located at the nonintegrated mill described in Section
4.3.6.  All of these mills are equipped with high-rate recycle and treatment systems consisting
of scale pits, clarification and/or filtration, and cooling. Process water recycle rates at these mills
exceed  95%, while the BPT/BCT model treatment system process water recycle  rate for the
effluent limitations guidelines and standards was 60 percent

             Process wastewater blowdown discharged from the Mill J hot strip mill is disposed
of through evaporation on EAF electrodes.  Discharges from the other mills are substantially
below the ELG LTAs for TSS and O&G, which are the only regulated pollutants in Part 420 for
hot forming  operations.  The ELG LTAs for total lead and total zinc shown on Figure 4-7 were
derived from BAT and NSPS model  treatment system effluent quality considered by EPA, but
not promulgated.  As shown in Figure 4-7, performance at Mill C is substantially better for total
zinc and nearly 40% lower than the estimated ELG LTA for total lead.
                                         4-13

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             Collectively, these results demonstrate that performance substantially better than
the ELG LTAs for BPT/BCT can be achieved at hot strip mills with conventional treatment and
recycle technologies. Hot strip mill performance with respect to TSS and O&G is transferable
to other hot forming operations (primary, section, flat-plate, pipe and tube) because the quality
of the process waters across all hot forming operations is relatively uniform. There are, however,
differences in concentrations and mass loadings of selected metals (e.g.,  lead, chromium and
nickel) among process  waters for hot forming operations processing alloy and specialty steels
(e.g., leaded steels, stainless steels).
4.3.8
Steel Finishing - Figures 4-8 and 4-9
             Performance data were obtained from two continuous strip finishing mills that
contain acid pickling, cold rolling, alkaline cleaning, hot coating, and electroplating operations.
The electroplating operations are currently regulated by Part 433 - Metal Finishing.  Performance
data were obtained for two periods for Mill L, designated as Mill L-l and Mill L-2 on Figure
4-8.  Each mill is equipped with treatment systems consisting of gross oil removal, mixing of
compatible waste-waters, and final treatment in metals precipitation systems. Mill L has dedicated
pretreatment systems for fluoride from tin electroplating operations and for hexavalent chromium.

             The results demonstrate substantially better performance for all regulated pollutants
at both mills. The performance with respect to the regulated metals is noteworthy because the
ELG LTAs are based upon a combination of the long-term average values from Parts 420 and
433.  The difference in actual mill performance versus  the LTAs used to develop the effluent
limitations guidelines and standards in Part 433 is highlighted in Figure 4-9, where long-term
average treated effluent concentrations from three steel finishing mills are presented. Data are
presented from  Mills K and L-l, as well as from Mill D, which has similar production facilities
plus an electrogalvanizing  line.  These comparisons show the actual performance from steel
finishing lines is substantially better than the ELG LTAs from Part 433.
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4.4          General Provisions              '

4.4.1         NPDES and Pretreatment Standards Production Rate
'•                        Section 122.45(b) of the NPDES permit regulations provides that production rates
             used  to compute mass NPDES permit effluent limitations  from production-based  effluent
M           limitations guidelines and standards "...shall be based not upon the design production capacity
             but rather upon a reasonable measure ofactual productionof'the facility". For existing iron and
I           steel industry manufacturing operations, this regulation has most often been interpreted to mean
             the daily  average production, assuming three turns of operation  per day (three eight-hour
•           operating  shifts), for the month with the highest production that occurred over the five-year
             period prior to permit issuance. This convention was established during the mid-1970s when the
•           first effluent limitations guidelines were being developed and has continued to the present  An
             example of the  calculation to determine the  NPDES production  rate is shown below for a
•*>+.
•           hypothetical hot strip mill:
                             ^
fx
I                        High Production Month:     March 1994
                          Total Monthly Tonnage:     225,624 net tons
^                        Operating Turns:           84
|                        Tons Per Turn:             2,686 net tons
                          NPDES Tons Per Day:      8,058 net tons
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                          An operating schedule of 84 turns in one month is a relatively high operating rate
•           that may occur as a result of full production with one maintenance day per month and one
             maintenance turn per week.  The high level of operation noted in the  above example may be
I           sustained for long periods during economic expansion; however, as discussed in Section 2.5, iron
             and steel  manufacturing operations  are highly cyclic.   NPDES permits and pretreatment
 8—
             limitations for iron and steel mills are typically not modified to account for changes in production
             resulting from  the business cycle.   Consequently, NPDES  permit effluent limitations and
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             In response to the requirements set out at §420.01 (b), the owners or operators of
the following mills elected not to provide.the required information and thus became subject to
Part 420 on July 26, 1982:41
             Laclede Steel - Alton, JJL
             Republic Steel -  Chicago, IL (LTV Steel Company)
             U.S. Steel - Provo, UT (Geneva Steel)
             U.S. Steel - Fairless Hills, PA         .
             U.S. Steel - Chicago, IL
             During  the period 1982 through 1984 when EPA was evaluating §420.01(b),

NPDES permits were issued for the mills listed below. EPA considered these permits consistent

with Part 420.  Mill-specific circumstances were instrumental for issuance of many of these

permits:  Section 301(g) variances were granted to one facility; a water bubble was used to

resolve issues at another facility; and the owners or operators of other facilities conditionally

withdrew their applications for alternative effluent limitations pending promulgation of proposed

revisions to Part 420 resulting  from the  Settlement Agreement.2-3'41   Consequently, EGD

concluded that alternative, less stringent effluent limitations developed under §420.01 (b) were not
appropriate for these mills.  The owners or operators notified EPA of their intent to withdraw

their requests for alternative effluent limitations on the dates shown below:
             Facility

             Interlake, Inc. - Riverdale, IL (Acme Metals, Inc.)
             J&L Steel - Hennepin, IL (LTV Steel Company)
             J&L Steel - Louisville, OH (J&L Specialty Steel)
             J&L Steel - Aliquippa, PA (LTV Steel Company)
             J&L Steel - Cleveland, OH (LTV Steel Company)
             National Steel - Granite City, IL
             National Steel - Portage, IN
             Ford Motor - Dearborn, MI (Rouge Steel Company).
Date of Notification

February 3, 1984
April 10, 1984
April 10, 1984
May 17,  1984
July 2, 1984
May 3, 1984
April 24, 1984    .
July 19, 1984
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             U.S. Steel - Lorain, OH                               October 25, 1982
             U.S. Steel - Gary, IN                                 October 25, 1982
             Weirton Steel Company - Weirton, WV                 May 29, 1984
             (formerly National  Steel)
             EGD conducted detailed assessments of the remaining five central treatment

facilities listed below to determine whether alternative effluent limitations would be appropriate.

EGD determined that the total investment cost to comply with Part 420 would need to be at least

twice the  total investment cost estimated by EPA for the facilities to qualify for alternative

effluent limitations.  Because estimated investment costs for none of the facilities were that high,

EGD concluded that alternative, less stringent limitations would not be appropriate and that all

facilities listed at 420.01 (b) should be subject to Part 420:41
             Armco, Inc. - Ashland, KY (AK Steel Corporation)
             Bethlehem Steel, Burns Harbor - Chesterton, IN
             Bethlehem Steel - Sparrows Point, MD
             J&L Steel - East Chicago, IN (LTV Steel Company)
             Republic Steel - Gadsden, AL (Gulf States Steel, Inc.)
             As noted above, the draft proposed rulemaking developed by EGD in 1984 has not

been subjected to formal agency review or set out for public notice as a proposed modification

to Part 420.



             The owners or operators of two mills (National Steel - Granite City, IL and Gulf

States Steel, Inc. - Gadsden, AL) are currently attempting to obtain favorable treatment under

§420.01(b) for their respective mills, more than twelve years after promulgation of the temporary

exclusion at §420.01(b).42-43  Because EPA has  not modified §420.01(b), it  remains in the

regulation  and has resulted in permitting and compliance issues  for EPA and state agency

personnel.44'45
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4.4.3
§420.03 - Alternative Effluent Limitations (Water Bubble Rule)
             As described in Section 3.6.2, §420.03 is a regulatory flexibility mechanism that
allows for intraplant  exchanges or "trades" of mass pollutant discharges  among outfalls  to
minimize  overall compliance costs. Section 420.03 is commonly known as the "water bubble
rule". The rule allows trading like pollutants (e.g., lead for lead, not lead for zinc or ammonia-
N), and requires "appropriate minimum net reduction  amounts" in pollutant mass discharges
resulting from trades.46'47  The rule includes restrictions on trades involving cokemaking and cold
rolling operations to avoid inadvertent excess discharges of toxic organic pollutants  found  in
cokemaking and cold rolling wastewaters.46  At the time Part 420 was promulgated, there was
concern that transfers of regulated conventional or nonconventional pollutants to cokemaking and
cold rolling operations might allow for less treatment of certain toxic organic pollutants which
were regulated through direct limitations for other similar toxic pollutants.

             The water bubble rule has not been used extensively in NPDES permitting of iron
and steel plants.  As part of a recent survey of the industry, ten trades under this rule
were identified.38 The present value of the cost reductions of intraplant trading for seven of the
ten trades was  estimated at  $122.7 million (1993  dollars).38  Based upon this survey, there
appeared  to be no  administrative  impediments to  industry or permit writers using the  water
bubble rule.38

             Many smaller mills  are precluded from using the water bubble rule because they
have only one  treatment system  and one outfall; others  have water quality-based effluent
limitations more stringent than technology-based effluent limitations and thus are also precluded
from using the rule.
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              The following are issues regarding §420.03 that could be considered to expand its

use:
                    The requirement that trades be completed on an intraplant basis
                    limits   possible   opportunities   to  complete   interplant  and
                    intercompany trades for mills discharging to the same receiving
                    water segment


                    Restrictions  on  all  trades for  cokemaking  and  cold rolling
                    operations limits possible opportunities to affect trades where more
                    stringent  effluent limitations for  cokemaking or  cold rolling
                    operations result, thereby ensuring that  there would  be no excess
                    discharges of unregulated toxic organic  pollutants.


                    The trading  of "like" pollutants  limits possible opportunities  to
                    trade "similar" pollutants (e.g., one toxic metal for another toxic
                    metal).


                    Discharges at steel mill sites that are limited by 40 CFR Part 433 -
                     Metal  Finishing are  not eligible  for  intraplant  trades with
                    discharges from operations limited by Part 420. If electroplating
                    operations conducted at steel mill sites were regulated by Part 420,
                    expanded use of the water bubble rule could result.
4.5           Pollutants Selected for Regulation



              The Clean Water Act (CWA) establishes three classes of pollutants: conventional,

nonconventional, and priority or toxic pollutants. Conventional pollutants are those defined at

Section 304(a)(4) of the CWA, namely TSS, biochemical oxygen demand (BOD5), O&G, fecal

coliform, and pH.  Analytical  measures of TSS, BOD5, and  O&G are not chemical-specific

determinations but aggregate measures of suspended particulates, oxygen-demanding substances,

and hexane-extractable (formerly freon-extractable) substances in water, respectively.  Specific

compounds contributing to these measures may or may not exhibit toxic effects and may or not

be among the 126 designated priority or toxic pollutants defined by the CWA. The priority or

toxic pollutants are specifically designated elements or compounds that exhibit toxic effects in
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aquatic  systems and, if determined to be present at significant levels, must be regulated by
categorical technology-based effluent limitations guidelines and standards pursuant to Section
301(b)(2)(A) of the CWA.  Nonconventional pollutants are all other pollutants that are neither
the  five   listed  conventional  pollutants  nor  the designated  126  priority  pollutants.
Nonconventional pollutants may be aggregate measures such as chemical oxygen demand (COD)
or adsorbable organic halides (AOX) or specific elements or compounds such as chlorine (C12),.
ammonia-N (NH3-N), and 2,3,7,8-tetrachloro-dibenzofuran (2,3,7,8-TCDF).  Nonconventional
pollutants can be nontoxic (e.g., iron at low levels) or highly toxic (e.g., 2,3,7,8-TCDF), EPA
has the authority and  discretion  to limit nonconventional. pollutants in categorical effluent
limitations guidelines and standards as appropriate based upon the presence of these pollutants
and findings that the removal or treatment of the pollutants is technically  and economically
achievable.

             Note that the database used by EPA to support the current Part 420 effluent
limitations guidelines and standards was collected principally during the late 1970s and was
limited  to  the original list of 126 priority or toxic pollutants, as well as conventional and
nonconventional pollutants common to the industry. EPA has not conducted broader pollutant
scans of industry process wastewaters.
4.5.1
Conventional Pollutants
             Conventional pollutants regulated by Part 420 are TSS, O&G, and pH.  BOD5 and
fecal coliform are not regulated.  TSS  and pH  are regulated in all  subcategories.  O&G is
regulated in the cokemaking, sintering, continuous casting, hot forming, cold  rolling, alkaline
cleaning, and hot coating subcategories.

             There do not appear to be  any compelling reasons to regulate BOD5 or  fecal
coliform at kon  and steel mills.  Discharges from most iron  and steel process wastewater
treatment systems are relatively low in organic content, the exceptions being  discharges  from
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cokemaking operations and steel finishing operations that contain oxidizable organic material

from oils and rolling solutions.  There are a few instances where states have proposed water

quality-based effluent limitations for BOD5 for steel finishing discharges to  achieve in-stream

dissolved oxygen standards; however, there may not be sufficient need to establish categorical

effluent limitations for BOD5.



             Fecal coliform or E. Coli. is limited under state regulations in a number of iron

and steel mill NPDES permits in discharges from on-site sanitary wastewater treatment systems.

Regulation at the federal level for these nonprocess wastewaters would be duplicative.



4.5.2         Nonconventional Pollutants



             The nonconventional pollutants regulated by Part 420 include ammonia-N and

phenols (4AAP) in the cokemaking, sintering, and ironmaking subcategories.  Phenols (4AAP)

means the value obtained by the method specified in 40 CFR Part 136.3.  Phenols (4AAP) is a

non-specific measure of phenolic compounds present in steel industry wastewaters that respond

to the analytical test conditions.   Based upon findings from the field  studies  conducted for

development of the existing regulation, following is a list of nonconventional pollutants that could

be considered in a revised regulation:


             Cokemaking


             Thiocyanate
             Nitrate
             Total Nitrogen (Total Kjeldahl N, Ammonia-N, NO2-N, NO3-N)
             Sulfide



             Sintering, Ironmaking. Steelmaking


             Fluoride
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             Steel Finishing
             Dissolved Iron

             Hot Coating (Hot Dip Galvanizing with Zinc Ammonium Chloride Flux)
             Ammonia-N

             Each of these pollutants was found at significant concentrations in wastewaters
from the respective process operations based upon data collected during  the late  1970s and
published in 19828. EPA did not establish effluent limitations guidelines and standards for these
pollutants when Part 420 was promulgated because they would be controlled incidentally through
direct limitations on conventional and toxic pollutants, and  because setting limitations for
different pollutants in subcategories with compatible wastewaters would complicate NPDES
permitting.

             Nitrate-N or total nitrogen could be regulated in cokemaking operations if BAT
or NSPS were  redefined to include control  of total nitrogen.  Under the current  regulation,
cokemaking treatment systems can be operated to nitrify ammonia-N to nitrate-N, without control
of nitrate-N discharges.  Denitrification of coke plant wastewaters is apparently demonstrated in
Europe. Denitrification of coke plant wastewaters was attempted at one coke plant located in the
United States in a novel nitrification-denitrification mode.  That method of treatment  was
operated successfully for a period of time but later abandoned because of increased process
wastewater flow resulting from efforts to comply with coke plant NESHAPs requirements.  The
increased process wastewater flow exceeded the hydraulic design of the system for operation in
the nitrification-denitrification mode.10
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4.5.3         Toxic Metal Pollutants and Cyanide



             Total lead and total zinc are regulated for most subcategories, the exceptions being

cokemaking, hot forming, salt bath descaling, and combination acid pickling. Total chromium

and total nickel are limited for salt bath descaling, combination acid pickling, and cold forming

when cold forming wastewaters are co-treated with combination acid pickling wastewaters. EPA

selected these metals for limitation because they were generally present at the highest levels and,

based on limited analytical data and published solubility data, control of these  metals was

expected to result in comparable control of other toxic metals. Total cyanide is limited in the

cokemaking, sintering, ironmaking, and salt bath descaling subcategories.



             Many other toxic  metals are present in iron and steel wastewaters.8 Below are

potential additional candidate metals for regulation:



             Cokemaking


             Total Antimony
             Total Arsenic
             Total Selenium
             Total Zinc



             Sintering, Ironmaking. Steelmaking


             Total Arsenic
             Total Cadmium
             Total Copper
             Total Chromium
             Total Selenium



             Vacuum Degassing. Continuous Casting


             Total Chromium
             Total Copper
             Total Selenium
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             Hot Forming

             Total Chromium
             Total Copper
             Total Lead
             Total Nickel
             Total Zinc
             Steel Finishing

             Total Antimony
             Total Arsenic
             Total Cadmium
             Total Copper
             EPA has recently issued  guidance regarding dissolved metals for purposes of

establishing ambient water quality standards and implementing those standards through water

quality-based effluent limitations in NPDES permits. The effluent limitations guidelines program

has historically regulated total metals because the ELGs are to reflect the capabilities of process
and treatment technologies to remove pollutants from process wastewater streams.  Issuance of

dissolved  metal  ELGs could allow for  conversion of  dissolved metals  into particulate form

without attendant solids removal.  This, in turn, could result in metals deposition in receiving

water sediments.
4.5.4
Toxic Organic Pollutants
              Part 420 regulates four toxic organic pollutants in two subcategories as follows:
              Cokemaking

              Benzene
              Benzo-a-pyrene
              Naphthalene
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              Cold Forming


              Naphthalene
              Tetrachloroethylene
              Benzene was regulated as an indicator pollutant for other volatile toxic organic

pollutants found in cokemaking wastewaters (e.g.,  ethylbenzene, toluene, xylene).  Benzo-a-

pyrene and naphthalene were regulated as indicator pollutants for other semi-volatile toxic

organic pollutants, specifically the polynuclear aromatic compounds (PAHs) (e.g., acenaphthylene,

benzo-a-anthracene, chrysene, fluorene, fluoranthene, and pyrene). It appears that the limitations

for these compounds are effective for regulating the volatile toxic organic compounds and the

semi-volatile PAHs.  Comprehensive  GC/MS  screens  of untreated and treated cokemaking

wastewaters using current,  more sensitive analytical methods would be necessary to determine

whether other toxic organic pollutants are present at levels where categorical effluent limitations

guidelines may be appropriate.



              The field investigations conducted in  developing the existing regulation revealed

the presence of a wide variety of toxic organic compounds present in cold rolling wastewaters.

These include several  PAHs,  a few chlorinated phenols, and  two chlorinated  solvents:

trichloroethylene and tetrachloroethylene.   These compounds originated as components of the

rolling solutions and cleaning solvents used in mill operations.   Naphthalene was selected for

limitation as an indicator pollutant for other PAHs  and tetrachloroethylene was selected as an

indicator pollutant for chlorinated solvents. Because of the potential for operators to change

rolling solutions and  cleaning solvents, there can be no assurance that the current regulation

effectively limits discharges of toxic organic pollutants from cold rolling operations.



4.5.4.1        Chlorinated Dibenzo-/?-dioxins and Chlorinated Dibenzofurans



              Chlorinated dibenzo-p-dioxins and chlorinated dibenzofurans (CDDs and CDFs,

respectively) are closely related families of highly toxic and persistent organic chemicals which
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are formed as unwanted by-products in some commercially significant chemical reactions, during
high-temperature decomposition and combustion of certain chlorinated organic chemicals, and
through other reactions involving chlorine and organic materials.48"55 There are 210 CDD and
CDF chemical compounds (or congeners) with varying chemical, physical, and toxicologic
properties.  The congener that appears to be the most toxic and has generally raised the greatest
public health concerns is 2,3,7,8-tetrachlorodibenzo-p-dioxin, (2,3,7,8-TCDD).

             EPA's National Dioxin Study highlighted findings of CDDs and CDFs at wire
reclamation facilities and  municipal  waste  combustors where  incomplete combustion  of
substantial quantities of plastics containing chlorine and chlorine compounds occur. The National
Dioxin Study did not examine all potential sources of combustion of plastics containing chlorine
or chlorine compounds.  Swedish researchers have documented formation of CDDs and CDFs
in EAF steelmaking operations where steel scraps are remelted to produce and refine molten steel
for subsequent casting and hot forming.53'55  There have been no publicly reported studies of
formation or emissions of CDDs and CDFs from North American EAF steelmaking operations.

             EAF steelmaking and advances in continuous casting of molten steels directly into
semi-finished shapes fostered development of "mini-mills", which, as the name implies, are small
steel mills that generally serve local markets.  Mini-mills exclusively use EAFs to produce raw
steel which is men continuously cast into billets, rounds, or  slabs.   By  the nature  of their
operations, mini-mills consume mostly "purchased" scrap as opposed to "home" scrap.   Home
scrap comprises the yield loss from processing liquid  steel to the final products at  a given mill,
and results from processing blooms, slabs, billets, and rounds into semi-finished and finished steel
products. Home scrap is usually more desirable, principally because it is of known metallurgical
composition and free from unwanted alloying elements that may be present in purchased scrap.

             Purchased  scrap  is usually classified as either "dormant" scrap or "prompt
industrial" scrap. Dormant scrap comprises obsolete, worn out, or broken products of consuming
industries (e.g., used steel furniture, structural members, automobiles, used ships, and appliances).
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Because  of the variable quality of dormant  scrap, careful  sorting is  required to prevent
contamination of the steel in the furnace with unwanted alloying elements.  There are over 70
different  classifications  for dormant scrap.7  Prompt industrial scrap is generated by steel
consumers making  their products  (e.g., unused portions of sheet steel  used for stampings,
trimmings from pressing operations, machine turnings, and rejected products). The source and
composition of prompt industrial scrap can usually be readily identified.

              There are ten major grades of carbon steel scrap and one nonspecific category.25'26
No. 1 heavy melting steel (sections of beams, crop ends from ingots, billets, etc.) accounted for
about 32% of carbon steel scrap consumption in 1988; No. 1 and No. 2 bundles (baled scrap)
together accounted for nearly 15%; and, shredded or fragmentized scrap accounted for nearly 11
percent.  No.  1  and electric furnace bundles are made from prompt industrial scrap.   No. 2
bundles comprise junked automobiles and appliances, usually painted goods.  Shredded scrap is
manufactured from the same items.
                                     •
              Shredded  scrap is prepared from junked automobiles and appliances by passing
partially stripped automobile and appliance bodies through rotary shredders.  Ferrous metal in
chip form is then separated magnetically.  Plastics, which  may comprise up to  30%  of the
stripped automobile  by weight, consists of the residual "fluff1 which is difficult to dispose of or
recycle due to combinations of various thermosets and thermoplastics in the mix. Separation of
the ferrous metal from the fluff is not 100% efficient.  Thus, shredded scrap used in EAFs often
contains plastic residues.

              In EAF steelmaldng, a mix  of scrap is selected  to make up the furnace charge.
Various types are used to obtain the smallest number of bucket  charges, the most rapid melting,
lowest power utilization, and the lowest electrode consumption, consistent with the price of the
scrap mix charged.7  For efficient operations, common practice is to charge the furnace with two
buckets, with 60% of the charge contained in the first bucket.  If the charge  comprises mostly
lighter scrap, a three-bucket charge of 40%, 30%, and 30% may  be used.7 Depending upon scrap
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availability, buckets are prepared with a layer of light scrap on the bottom followed by heavier
scrap.  The light scrap provides protection for  the  bottom of the  furnace during charging.
Shredded scrap is used for this purpose.  It is also desirable to place any large pieces of scrap
low in the furnace to prevent damage to  electrodes from falling steel during the melting cycle.
Medium weight scrap is charged next. Light scrap (shredded scrap) is usually also charged on
top to ensure quick boredown of the electrode tips such that furnace roof wear will be minimized
and high voltages can be applied more quickly.7

             Consumption of shredded  scrap in the  United States has steadily increased as a
percentage of total scrap used for steelmaking. Consumption has increased from approximately
1.7 million tons in 1973 to approximately 3.5 million tons in 1981, then dropped precipitously
with overall steel production in 1982 and 1983.25-26 Since that time, consumption of shredded
scrap has  steadily increased with increases in EAF steelmaking to about 6.1  million tons in
1992.26 The amount of shredded scrap used in EAF shops is variable and dependent upon
operating practice, price, quality, and availability of other light scrap.

             At the start of the melting process, electrodes are lowered to the scrap charge in
the furnace. The initial melting is characterized by violent reactions and uncontrolled combustion
and melting of the  scrap charge.  It is  likely that CDDs  and CDFs form at that  time from
incomplete combustion of residual plastics and other chlorine-containing materials in the scrap
charge. Table 4-2 shows experimental levels of CDDs and  CDFs formed from EAF  melting of
scrap with the indicated contaminants.54   Of interest is indicated formation of 0.8 ug/ton of
TCDD equivalents  (Nordic  - a 2,3,7,8-TCDD  toxicity equivalence scheme very similar to,
although not identical to, the I-TEF/89 2,3,7,8-TCDD toxicity equivalence  scheme adopted by
EPA and environmental agencies in many other countries) with "no chlorine" in feedstocks, 1.5
pg/ton with  feedstocks  contaminated  with cutting oils, and  30 pg/ton  with  feedstocks
contaminated with PVC.
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             Most EAF shops in the U.S. are equipped with dry primary air emission controls

and many are equipped with dry secondary emission  controls.  At  the time Part 420 was

promulgated in  1982, there were nine EAF shops with wet scrubbers for air emission controls

and three semi-wet EAFs.15 There are no publicly available data or studies showing actual or

potential wastewater discharges of CDDs and CDFs from EAF steelmaking operations.



             Formation of CDDs and CDFs in EOF steelmaking has not been reported in the

literature. The potential for such formation would appear to be lower than with EAF steelmaking

because comparatively less scrap is used per ton of raw steel produced, and the scrap is charged

to the furnace prior to adding hot metal; consequently, there is less opportunity for uncontrolled

combustion as in EAFs.  Also, in open-combustion BOFs, any CDDs and CDFs formed would

likely be combusted in the zone above the furnace. Performance at suppressed combustion BOFs

might be different because furnace off-gases are not combusted  until after wet scrubbing.  In

these  systems, there would appear to be  a greater potential for any CDDs and CDFs formed to

reach  the wastewater treatment systems.  There are also no publicly available data regarding the

potential or actual discharge of CDDs and CDFs from BOF steelmaking operations.



             Because of the nature of the combustion operations and  the feed materials used,

formation of CDDs and CDFs may also  occur at sintering plants.



4.5.4.2       Other Toxic Organic Pollutants



             There has been growing concern about whether low level, chronic exposure to

estrogenic substances might account for the increasing  frequency of infertility and associated

disorders of the  male reproductive systems in humans.56  Alkylphenol polyethoxylates (APEOs),

which were introduced in the 1940s, are the second largest group of nonionic surfactants in

commercial production.57  They are widely used in detergents, paints, herbicides, pesticides, and

many  other  formulated  products  including  water and  wastewater  treatment  chemicals.

Nonylphenol polyethoxylates account for about 80% of APEOs  (>300,000  tons are produced
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annually worldwide) and octylphenol  polyethoxylates make up most of the remaining 20
percent.57  It has been estimated that 60% of the APEOs produced are released to the aquatic
environment,58 most entering via sewage treatment works, where they are readily degraded to
form  relatively stable  metabolites.59'60   Some  of these  metabolites are hydrophobic (e.g.,
alkylphenols, nonylphenol, and octylphenol) and tend to accumulate in sewage sludges and river
sediments.   Recently,  British  researchers demonstrated  that  4-nonylphenol,  4-octylphenol,
4-nonylphenoldiethoxylate  and  4-octylphenoxycarboxylic  acid,  all  compounds  found  in
groundwater and tap water in the U.S.59'61-62, are estrogenic in fish, avian and mammalian cells,
and they mimic the effects of ITfi-estradiol (a natural estrogen) by binding  to  the estrogen
receptor.
        57
             Possible sources of nonylphenol and octylphenol in the steel industry include water
and wastewater treatment chemicals, cleaning solutions used in steel finishing operations, and
cleaning solutions used  in maintenance operations.63  A review of the composition of water
treatment chemicals and  the cleaning solutions used in the steel industry and the possible fate of
alkylphenol compounds  in steel industry wastewater treatment  systems could be conducted to
determine whether and to what extent the industry contributes to the mass loadings of these
anthropogenic compounds to the environment.
4.6
Preliminary Estimates of Pollutant Loadings and Order-of-Magnltude Costs
             Estimates for current industry pollutant loadings were made using the Toxics
Release Inventory Database, the Permit Compliance System Database, and by using a modelling
approach for the industry.  The modelling approach was then used to estimate pollutant loadings
if the industry were to upgrade to the level of better performing mills presented in Section 4.3,
and the order-of-magnitude costs for this upgrade.  The pollutant loading and cost estimates are
presented in the following sections.
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•            4.6.1         Modelled Estimates

•            4.6.1.1       Modelled Estimates of Pollutant Loadings at Current Regulation and at Level
                           of Better Performing Mills

                           As described in Section 2.3, U.S.  iron and steel manufacturing sites  can be
fl            classified into the following five groups:

I                                Stand-alone by-product coke plants;
™                                Integrated steel mills;

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                                  Nonintegrated steel mills;
                                  Stand-alone finishing mills; and
                                  Other stand-alone operations.
                           Because of the configuration of wastewater control and treatment technologies used

             in the industry and the data available to characterize the performance of those technologies, a

             modified industry classification  was used  to  develop estimated baseline  (current)  pollutant

•           loadings and projected loadings that may be achieved if the industry was upgraded to the level

             of the better performing mills identified in Section 4.3. The modified industry classification is

•           as follows:                                                               '


                           I»      Cokemaking (all plants);
                                         Direct dischargers;
                                         Indirect dischargers;
fl                         —      Other coke plants;

                           •      Sintering (all plants);

™                         •      Ironmaking (all blast furnaces);

                           >•      EOF steelmaking, vacuum degassing, continuous casting (integrated
                                  mills);

                           I*      Hot forming (integrated mills);
         u


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              •     Finishing (integrated and stand-alone finishing mills);
              •     Nonintegrated mills (all operations combined);
              •     Hot forming (stand-alone hot forming mills);
              •   .  Cold forming (stand-alone cold forming mills); and
              •     Wire (stand-alone wire mills).

              Cokemaking.  Cokemaking  is performed at either stand-alone by-product coke
plants or at integrated steel mills.  This was the only industry classification where distinctions
were made between direct and indirect discharges (although there are many  stand-alone steel
finishing operations with discharges to POTWs, most of these are smaller facilities and were not
included in these estimates).

              The  "other  coke plants"  subclassification  represents  two coke plants  where
untreated wastewaters are disposed of by dirty-water coke quenching and underground injection
in deep wells, respectively. Because these sites do not currently discharge to a surface water or
POTW, and are subsequently not subject to the current regulation, they are not included in the
total industry summary table  (Table 4-3). Data for these two sites are presented in Table 4-6,
representing potential cross-media benefits to air quality and reductions in subsurface discharges.

              Sintering.  This classification includes all sintering plants in the industry with wet
air pollution controls, including those designated as "other stand-alone operations" in Section 2.3.

              Ironmaking. This classification includes all ironmaking blast furnaces, including
those designated as "other stand-alone operations" in Section 2.3.

              BOF steelmaking, vacuum  degassing, continuous casting. This classification
includes the combination of these operations performed at integrated mills.
                                          4-34

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•                         Hot forming (integrated).  This classification includes hot forming operations
              performed at integrated mills.

                           Finishing.  This  classification includes  acid pickling, cold rolling, alkaline
I            cleaning, hot dip coating, and electroplating performed at either integrated mills or stand-alone
              finishing mills. Electroplating operations are currently regulated under 40 CFR Part 433, but are
I            included in this review for the reasons cited in Section 4.3.
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              Nonintegrated mills. This classification includes the principal operations typically
performed at nonintegrated mills:   EAF steelmaking with dry  air emission controls, vacuum
degassing,  continuous casting,  and  hot forming.   Because  there are  a limited number
(approximately 5%) of nonintegrated mills with cold forming, acid pickling, alkaline cleaning,
and hot dip coating operations, loadings were not developed for these finishing operations.
I                         Hot forming (stand-alone).  This classification includes hot forming operations
              performed at stand-alone hot forming mills.
I
                           Cold forming. This classification includes cold forming operations performed at
|            stand-alone cold forming mills, including stand-alone mills manufacturing pipes and tubes.

|                         Wire mills.  This classification includes wire manufacturing operations performed
              at stand-alone wire mills. Pollutant loading estimates were not prepared for mills in this group
|            because they produced less than 1% of industry shipments in 1993 and because data to generate
              baseline and projected production-normalized pollutant loading estimates are not readily available.

                           The classifications  presented  above include all  of the  current  Part  420
I            subcategories except salt bath descaling.  Only a few salt bath descaling operations remain in the
_            U.S., and the production rates for these lines are relatively low. Therefore, pollutant loading
•            estimates were not prepared for this subcategory.

*-                                                    4-35

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             The following data sources were used to estimate the number of facilities, the

facility classifications, and industry production rates:
                    1994 Association of Iron and Steel Engineers' Directory of Iron
                    and Steel Plants;

                    1993 American Iron and Steel Institute Annual Statistical Summary
                    (preliminary);

                    1994 International Trade Commission Report on Cokemaking;

                    1982  EPA  Development Document  for  Effluent  Limitations
                    Guidelines and  Standards for the Iron and  Steel Manufacturing
                    Point Source Category; and

                    1991 Industry Round-up Article from 33 Metal Producing.
loadings:
             The following data sources were used to estimate current and projected pollutant
                    1982  EPA Development  Document  for  Effluent Limitations
                    Guidelines and Standards for the Iron and Steel  Manufacturing
                    Point Source Category;

                    1994 EPA mill visits;

                    1991 Municipal-Industrial Strategy for Abatement (MISA) program
                    - Ontario Ministry of the Environment; and

                    1980 SATS Coke Plant Verification Study (EPA Study).
             To the extent possible, industry and mill production data were based directly upon

published  references.   Recent mill performance data were  used to determine  production-

normalized loadings of the better performing mills. Data from the 1982 Development Document

were used to fill data gaps for pollutants present but not routinely monitored by the identified
better performing mills.
                                        4-36

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             The loadings and reductions estimates are presented in Tables 4-3 through 4-14.

Table 4-15 summarizes the baseline technologies assumed to be in place for estimating current

pollutant loadings, and presents those technologies used to estimate the projected loadings and

pollutant loading reductions presented in Tables 4-3 through 4-14.  The major assumptions used

for this effort are as follows:
                    For the purposes of estimating baseline pollutant loadings, the 1982
                    Development Document long-term average production-normalized
                    pollutant loadings were used at BPT for regulated and nonregulated
                    conventional  pollutants and  at BAT/PSES  for  regulated  and
                    nonregulated nonconventional and priority pollutants.

                    Projected pollutant loadings were calculated using performance data from
                    the better performing mills presented in Section 4.3, and the number of
                    currently operating production facilities  listed below. Projected pollutant
                    loading reductions were computed as the difference between the baseline
                    loadings and the projected pollutant loadings.

                    The following are the number of mills within each classification as
                    estimated using the above references sources:
                           Cokemaking
                                 Direct dischargers              12
                                 Indirect dischargers             13
                                 Other coke plants                2
                           Sintering plants                       10
                          Ironmaking                           22
                          EOF steelmaking, vacuum degassing,
                            continuous casting                   22
                          Hot Forming (integrated)               22
                          Finishing                             53
                          Nonintegrated mills                  100
                          Hot forming (stand-alone)              26
                          Cold forming                         76
                          Wire mills                            43

                    Based upon an assessment of the current industry status, it was
                    estimated that 50% of the hot forming mills (integrated and stand-
                    alone) have high-rate treatment and recycle systems approximating
                    those described  as BAT - Option  1 or NSPS,  and 50% have
                                         4-37

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                     treatment systems with partial recycle approximating the EPA BPT
                     model treatment technology.

                     Nonintegrated  mills were  assumed to be equipped  with electric
                     furnaces with dry air emission controls, continuous casters and hot
                     forming operations.  The continuous casters, and hot forming mills
                     were assumed to be  equipped with high-rate treatment and recycle
                     systems.

                     Specialty steel mills are more likely to discharge higher  levels  of
                     chromium and nickel than carbon steel  or  low alloy steel mills.
                     Because specialty steel production accounts  for approximately 2%
                     of total  steel  production in  the U.S., these mills were not
                     differentiated in the  pollutant loading estimates.

                     The pollutants  presented in Tables 4-3 through 4-14 represent the
                     pollutants of concern identified during the 1982 rulemaking effort,
                     and are not necessarily those currently regulated by  40 CFR Part
                     420.  The list of pollutants limited by 40 CFR Part 420 is presented
                     in Table 3-2.

                     Table 4-5 presents  estimated mass  loading  data for discharges  from
                     indirect discharge steel mills to POTWs.   These  data do not  represent
                     discharges to receiving waters.
              Other specific assumptions made to develop the pollutant loading estimates are
included in the record for this project


4.6.1.2        Modelled Estimates of  Order-of-Magnitude  Costs to  Upgrade  Industry

              Performance


              Table 4-16 summarizes preliminary estimates of total capital investment and annual

operating and maintenance costs to upgrade the industry to the level of the better performing

mills for each industry  classification listed in Section 4.6.1.1. In all cases, assumptions were

made about the baseline level of process wastewater treatment and recycle technologies currently

installed in the industry.  Technologies  necessary to upgrade mills  to the level of the better
                                          4-38

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performing mills, including increased recycling, were then identified.  Cost estimates were

developed based upon model plant cost data presented in the 1982 Development Document that

were scaled to wastewater flow rate and/or production rate for actual mill production capacities

for cokemaking and sintering operations and typical mill sizes for the other classifications.



             The 1978 cost data presented in the 1982 Development Document were upgraded

to 1994 costs using the Chemical Engineering Plant Cost Index. Because of the number and

nature of the assumptions that were made in this analysis and the  use of a cost index  over a

relatively long period of time, these estimates must be considered preliminary and subject to wide

variation.  The assumptions made  to develop the cost estimates and the bases for the  cost

estimates for each classification are  included in the record for this project.



             Using an equipment life of 20  years and annual interest rates of 7% and 10% for

1994, the iron and steel industry totals presented in Table 4-16 for total capital investment and

annual operating and maintenance costs were converted to total annualized costs of $64.3 million

per year  and $72.1 million per year, respectively.



             To determine cost effectiveness, the  differences in toxicity among the various

pollutants is accounted for by using toxic weighting factors (TWFs).  TWFs are calculated such

that relatively more toxic pollutants have higher TWFs.  In the majority of cases, TWFs are

derived from both chronic freshwater aquatic criteria and human health criteria established for

the consumption of fish.  These factors are then standardized by relating them to copper.  When

TWFs are multiplied by pollutant mass loadings in units such  as pounds per year, the resulting

values are in units of toxic pound-equivalents. Mass loadings from different pollutants can be

summed  together after they are converted to toxic pound-equivalents.  TWFs are presented in the

last column of Table 4-3.



             Using the data presented in Table 4-3, the toxic pounds-equivalents removed by

upgrading to the level of better performing mills was estimated at 1.9 million Ibs-eq/yr. The total
                                         4-39

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annualized cost and the toxic pounds-equivalents removed can be divided to determine the cost-

effectiveness of upgrading to the level of better performing mills.  For the industry as a whole,

the cost-effectiveness based on these modelled estimates is $34/lbs-eq removed and $38/lbs-eq
removed for annual interest rates of 7% and 10%, respectively.
4.6.2
Toxics Release Inventory (TRI) Database
             Table  4-17  summarizes EPCRA Section 313  Toxics  Release  Inventory (TRI)

wastewater discharge data reported by the iron and  steel  industry for  1992.  The summary

includes data from manufacturing facilities within SIC Codes 3312, 3315, 3316, and 3317.  For

the purpose of estimating baseline pollutant loadings and pollutant loading reductions, the TRI
database has the following limitations:
                    Most integrated mills have large-volume noncontact cooling water
                    discharges  from  cokemaking  and  ironmaking  operations and
                    associated  steam-  and power-producing  units.   It is  common
                    practice to discharge treated,  low-volume  process  wastewaters
                    through high-volume noncontact cooling water discharges. In some
                    cases, direct discharged TRI pollutant loadings may have been
                    estimated based upon the  gross amount of pollutants discharged
                    from the combined noncontact cooling water flows.  For  large-
                    volume noncontact cooling water discharges in river systems where
                    upstream or background concentrations for selected pollutants are
                    measurable (e.g., ammonia-N), discharge loadings calculated in this
                    manner would not be representative and would overstate the  actual
                    pollutant loadings contributed by the steel mill  from the treated
                    process wastewaters.

                    At many mills, TRI estimates for direct and indirect discharges are
                    not based upon actual discharge measurements of all TRI pollutants
                    used or processed above TRI threshold levels.  The TRI estimates
                    may not account for  relatively low-concentration discharges  of
                    toxic pollutants that can amount to significant annual mass loadings
                   ; when considering the industry as a whole.
                                         4-40

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Because these concerns could not be investigated within the scope of this project, baseline and

projected pollutant loading estimates and estimated pollutant loading reductions were developed

as described in Section 4.6.1.1.



4.63          Permit Compliance System (PCS) Database



              Table 4-18 summarizes pollutant loading data from the EPA Permit Compliance

System (PCS) Database for 1992.  The summary includes wastewater discharge data from

manufacturing facilities within SIC Codes 3312, 3315, 3316, and 3317.  Many steel mills have

multiple treatment systems in which NPDES  permit  effluent limitations and  monitoring

requirements are applied  at  the discharge of  the treatment systems  prior to mixing  with

noncontact cooling waters  and other nonregulated flows (e.g., stormwater).  In many cases, the

pollutants limited and monitored at the internal monitoring stations are not limited or monitored

at the final discharge point. From examination of the PCS database, there are several examples

at integrated steel mills, nonintegrated steel mills, and stand-alone finishing mills where NPDES

monitoring data for internal monitoring stations have not been included in the database.  Several

pollutants that are limited and monitored are missing from the database for selected mills. Based

on this review, the PCS database was judged to be deficient for estimating baseline pollutant

loadings and pollutant loading reductions for this project.
                                         4-41

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                          Table 4-1
                      40 CFR 420.01(b)
Central Treatment Facilities Temporarily Excluded from Part 420
.-..., ,- ',,| -,. ..^; ,'-'..i.^-'-x=X-'\>\ , v-
,„ , ;,|Nattt ;/ - r ;
Annco Steel, Ashland, KY (AK Steel
Corporation)
Bethlehem Steel, Sparrows Point, MD
Bethlehem Steel, Bums Harbor, IN
Ford Motor Co., Dearborn, MI (Rouge Steel
Company)
Interlake, Inc., Riverdale, IL
(Acme Metals, Inc.)
J&L Steel, Aliquippa, PA
(LTV Steel Company)
J&L Steel, Cleveland, OH
(LTV Steel Company)
J&L Steel, Hennepin, IL
(LTV Steel Company)
J&L Steel, Louisville, OH
(J&L Specialty Steel)
J&L Steel, East Chicago, IN
(LTV Steel Company)
Laclede Steel, Alton, IL
National Steel, Granite City, IL
National Steel, Portage, IN
National Steel, Weirton, WV
(Weirton Steel Company)
Republic Steel, Gadsden, AL
(Gulf States Steel, Inc.)
Republic Steel, Chicago, IL
(LTV Steel Company)
U.S. Steel, Lorain, OH
(USX/Kobe Steel)
4"J4PB&$' $&&&*"*
* * °'l98fc
KY 0000485
MD 0001201
IN 0000175
MI 0003361
IL 0002119.
PA 0006131
OH 0000850
IL 0002631
OH 0007188
IN 0000205
IL 0000612
IL 0000329
IN 0000337
. WV 0003336
AL 0003522
IL 0002593
OH 0001562
_..,„,„,. „ „ f ,. , ^
< .r'V * <> * f f^ f"> * "" ^ :s '
i'.\.' r j.^.' j. %.'v, -* -• -• -••"•£• s* f ^ rt •'•'•••••• .v / -• v .-
11 "* 
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                         Table 4-1 (Continued)


                            40 CFR 420(b)
     Central Treatment Facilities Temporarily Excluded from Part 420
^ ^ ^ '"" "" V " * ' ' ' ,''''<. ' S' •> "l \
\- - ; % 'i ••'•*?'", - ,v%»<*^^?,- -,' ./*''•=• '
•\*v < .;•-.•••••- .; -•, -••if, ,•*<«_,' v , •.^\'^v-Kk'\x--f4\-'yfy-
* - , ; ; jPla»« \- •,« - «,> ' ,:v v> -
U.S. Steel, Provo, UT
(Geneva Steel)
U.S. Steel, Fairless ffills, PA
U.S. Steel, Gary, IN
U.S. Steel, Chicago, IL
>•!> ";-sJy ' '3* •• ' * •. '*•'
"fr '
UT 0000361
PA 0013463
IN 0000281
IL 0002691
^ •. * ' ; j '' , ' - - >
;" "'':'s€eti^»! YfeeflMMtlMnfr'' *
Total Plant
Terminal Treatment Plant
Terminal Lagoons
Discharge to POTW
() a Current Mill Owner.
                                  4-43

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                                      Table 4-2
               Levels of CDDs and CDFs in Electric Arc Furnace
             Flue Gases Before and After Bag House Filter During
                 Continuous Charge Through The Furnace Lid
                    (Results in TCDD Equivalents - Nordic (Eadon))

                                                                       -,.--.. * "
                                                                     ' 'J V*L.r •. ^
      "No Chlorine"
                                 0.2 (0.2) ng/Nm3
                                  0.8(l.l)pg/ton
                      0.1 (0.1) ng/Nm3
                      0.5 (0.7) fig/ton
                                0.3
                                 0.5 (0.5) ng/Nm3
                                  2.8 (2.7) pg/ton
                     0.04 (0.04) ng/Nm3
                       0.2(0.2) jig/ton
      Cutting Oils
                   0.4
0.3 (0.4) ng/Nm3
 1.5 (2.1) pg/ton
0.1(0.2) ng/Nm3
 0.6(1.0) pg/ton
          PVC
                   1.3
5.9 (6.4) ng/Nm3
 30 (33) ug/ton
1.5(3.9) ng/Nm3
 7.7(20) jig/ton
Source: Tysklind, 1989 (Reference 54)
Notes:
(1)     The first number presented in columns three and four represents 2,3,7,8-TCDD Toxicity
       Equivalents (TEQs) using the Nordic convention. The number in parentheses represents
       23,7,8-TCDD TEQs using the Eadon convention.

(2)     Mixtures of CDDs and CDFs are reported as 2,3,7,8-TCDD TEQs to simplify reporting
       and to commonly express the potential toxicity of mixtures of CDDs and CDFs in terms
       of  the toxicity of 2,3,7,8-TCDD.  The International Toxicity Equivalents Factors
       convention (I-TEF/89) was adopted in 1989 by the U.S. and most foreign countries. The
       Nordic convention is similar to the I-TEF/89 convention.
                                          4-44

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                                   Table 4-3
           Pollutant Loadings for Total Iron and Steel Industry
•.-.•.•> f
•. ., T. 1. v
[ •. - V ^
Pollutant ;
*"•*-,
Total suspended solids
Oil and grease
Ammonia - N
Total cyanide
Phenols (4AAP)
Acrylonitrile
Parachlorometacresol
2,4-Dimethylphenol
Ethlybenzene
Fltioranthene
Isophorone
Phenol
Benzo-a-anthracene
Benzo-a-pyrene
Chrysene
Acenaphthalene
Fluorcne
Naphthalene
Pyrene
Benzene
Toluene
Xylenes
Total arsenic
Total cadmium
>S>'' -,*i'^%* •• ^ s
rs/XJeiyeiirt^,:
: , ^fifi$r) :
34,000,000
8^00,000
900.000
180,000
300,000
2,000
uoo
13,000
6,100
5,600
2,400
310,000
1,600
700
1.800
7,900
1,600
490
1,800
490
4,000
2,400
7,900
3,500
^ *• > ^ O •»> *'I'T,'T, ;
•* $^jBKtK& * ^\.
	 tMtflh"!
,;.WW.'-J
5,000,000
UOO.OOO
190,000
34,000
UOO
160
40
660
240
2,800
80
510
79
340
240
160
160
340
400
340
400
160
3.200
750
'/]$*«•**£* ?;
^JfeS^ -•
29.000,000
6,900,000
710,000
150.000
300,000
1,800
1,200
12,000
5,900
2,800
2.300
310,000
1,500
360
1,600
7,700
1,400
150
1.400
150
3.600
2,200
4,700
2,800
^^,>«'^i
''^\ l^ftttait: ' " 1
Redfldion 'I
j-t - c- ;
85
84
79
83
99.6
90
97
92
97
50
96
99.8
94
51
89
97
88
31
78
31
90
92
59
80
, ^'TEtalfe^r^
n**r* -v
*
*
*
i.i
*
0.85
0.0043
0.0053
0.0014
0.92
0.00073
0.028
24
4,300
18
0.0084
0.70
0.015
0.98
0.018
0.0056
0.0015
4.0
5.2
Toxic Weighing Factors are not applicable for these parameters.
                                      4-45

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                                    Table 4-3 (Continued)



                Pollutant Loadings  for Total Iron and Steel Industry
                                                                                         Tosste
 Total chromium
 90,000
61,000
29,000
32
0.027
  Total copper
 12,000
 2400
 9,500
79
                                                               0.47
  Total lead
 39,000
 7,300
32,000
82
1.8
 Total nickel
                             14,000
                 3,400
                11,000
               79
                0.036
 Total selenium
  1,600
                                               790
                  810
               51
                                              1.1
 Total zinc
200,000
                                            21,000
               180,000
               90
                               0.051
"Toxic Weighing Factors are not applicable for these parameters.
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                     Table 4-4
Pollutant Loadings for Direct Discharging Coke Plants
' I? \ \ vj, , ;
\ itanttttT^ -
., ^ " •• •" £
Total suspended solids
Oil and grease
Ammonia - N
Total cyanide
Phenols (4AAP)
Benzo-a-pyrene
Naphthalene
Benzene
' €urj*'»t-Ix«Kl&igv
;^;3*fc#v>;N
2,600,000
180,000
110,000
38,000
300
300
300
300
^jPisBjIeetwl Jteff&itoig.
Vl7<^&$r}y^,
.."I 	 » 	 T 	 ^.^.x^'....'•_.__^l:x.
73,000
33,000
11,000
8.200
190
150
150
150
^ ? •• """ o v ^
-l^*a, i< ^tetytl -,* >'
.- .* .-;jvo ffi, T-^ >^ '
2400,000
150,000
99.000
30,000
110
150
150
150
Percent - - :;
H«dac&Mi
96
83
90
79
37
50
50
50
                        4-47

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                      Table 4-5
Pollutant Loadings for Indirect Discharging Coke Plants
' ^ V <
0, ^>^laai;^C
Total suspended solids
Oil and grease
Ammonia - N
Total cyanide
Phenols (4AAP)
Aciylonitrile
Parachlorometacresol
2,4-Dimethylphenol
Ethlybenzene
Fluoranthene
Isophorone
Phenol
Benzo-a-anthracene
Benzo-a-pyrene
Chtysene
Acenaphthalene
Fluorene
Naphthalene
Pyrene
Benzene
Toluene
Xylenes
Total arsenic
Total selenium
Total zinc
;^iwwtt^a j*. *viB&fy&f' w',// *
630,000
48,000
96,000
24.000
960
160
40
40
240
160
79
40
79
190
79
160
160
190
240
190
400
160
3,200
790
790
loading Reduction %
>v-v,:<|ii^\ ,.,-•-
160,000
72,000
380,000
110,000
290,000
1,800
uoo
7,900
6,200
1,400
2^00
240,000
1400
210
1,500
7,700
1,400
0
1,400
0
3,600
2,200
4,700
810
810
,• , Pereeot
H«dactuUi ;
20
60
79
85
99.7
90
97
99.5
97
88
96
99.98
94
53
94
97
88
0
88
0
90
92
60
51
51
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               Table 4-6
Pollutant Loadings for Other Coke Plants
1 -u -!\\ ^ ' ' •" ' f *• ""
** ><&utjtttr • '
' * •• C * •• •>
Total suspended solids
Oil and grease
Ammonia - N
Total cyanide
Phenols (4AAP)
Acrylonitrile
Parachlorometacrcsol
2,4-Diaiethylphenol
Ethlybenzene
Fluoranlhene .
Isophorone
Phenol
Benzo-a-anthracene
Benzo-a-pyrene
Chrysene
Acenaphthalene
Fluorene
Naphthalene
Pyrene
Benzene
Toluene
Xylenes
Total arsenic
Total selenium
Total zinc
CiiTFefttlioatfiitg
1 - IllWWl^'vi
"..* 	 iv.>. 	 5....J
260,000
390,000
3,100,000
260,000
1,600,000
4,000
2.000
16,000
9,900
2,600
1.600
910,000
990
520
1,300
12,000
2,000
160,000
2,000
180,000
82.000
40,000
6,600
660
660
•>Fro|ectoi'ii^diiBgVC
>*\ :$*&£*$'*<
24,000
11,000
3,400
2,700
61
98
24
24
150
98
49
24
49
49
49
98
98
49
150
49
250
98
2,000
490
490
XJoadftag KcdttctiteR -
;x;^wrv.
240,000
380.000
3,100,000
260,000
1.600,000
3,900
2.000
16,000
9,800
2300
1,600
910,000
940
470
1,300
12,000
1,900
160,000
1,900
180,000
82,000
40,000
4.600
170
170
' Pereoat ^
•j' m&etiatto ^
92
97
99.9
99
99.99
98
99
99.9
99
96
97
99.99
95
90
96
99
95
99,97
95
99.97
99.7
99.8
70
26
26
                  4-49

-------
           Table 4-7
Pollutant Loadings for Sintering
•;*':-•':"" %/
, l%ttii*fflBt >
Total suspended solids
Oil and grease
Ammonia - N
Total cyanide
Phenols (4AAP)
Fluoranthene
Phenol
Chrysene
Pyrene
Total cadmium
Total chromium
. Total copper
Total lead
Total nickel
Total zinc
•» •••> c1 ff' ; , - »,;„•>,:
' nrliffjfffftf 'Iri'ftJfflTTT fftij!*
•• . . Jf ^ N ^
600,000
110,000
93,000
3,100
230
1.500
770
160
l
160
160
3,100
310
1,900
160
2,300
Pr^ect^d toA«ng
N -L •• V ^^ > X Ji C
80,000
17,000
80,000
1,800
40
160
160
160
160
160
2,300
310
730
160
970
Loading Rettacflwi
^'V/,,^*^"' - "\
520,000
93,000
13,000
1,300
190
1,300
610
0
0
0
800
0
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0
1.300
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87
85
14
42
83
87
79
0
0
0
26
0
63
0
57
              4-50

-------
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            Table 4-8
Pollutant Loadings for Ironmaking
"tv ^v-V/'V *' A-i
- | ;»«««*«" v?;.
Total suspended solids
Ammonia - N
Total cyanide
Phenols (4AAP)
2,4-Dimethylphenol
Fluonnthene
Phenol
Total cadmium
Total chromium
Total copper
Total lead
Total nickel
Total zinc


2,300,000
190,000
7,700
460
4,600
2400
65,000
3,100
6.200
930
3,400
3,100
4,600
"«L «H* aai ff "'^diut "
& V ';|^S/yrp „<'-' -'
1,900
1,900
41
1
620
2,500
310
310
4,600
620
17
460
22
0 f**'} fff •• f S / f
*vv:-*H*to ^- ;
2,300,000
190,000
7,700
460
4.000
0
65.000
2,800
1,600
310
3,400
2,600
4,600
''"" 'P^ctet' ^'"
•' Berfnctiolr
99.9
99
99
99.8
87
0
99.5
90
26
33
99.5
84
99.5
              4-51

-------
               Table 4-9
Pollutant Loadings for BOF Steelmaking,
 Vacuum Degassing, Continuous Casting
- •• .. ' '•> " ^
Pollutant , ,:.
Total suspended solids
Oil and grease
Total cadmium
Total chromium
Total copper
Total lead
Total nickel
Total zinc
£imW i^ing
^NyrK,;
3.900,000
680,000
280
2,800
2.800
7,500
6,900
120,000
,^3^LfiaSdi,ig !
', ::;$&&j*y\ ,,;
26.000
76.000
280
770
770
370
2,300
5,800
i
-------
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                     Table 4-10
Pollutant Loadings for Hot Forming (Integrated Mills)
^ •{• -, •£ v ^ 1 •""•*• ^
% % > V \ f
, •. ^^\$*j&uti!t8!t ,•• , ',
^
Total suspended solids
Oil and grease
Total chromium
Total copper
Total lead
Total nickel
Total zinc
•'"€ttor«Btioadiog",
^*$£iti$$::*j
8,700,000
1,800,000
640
7,000
4^00
3,800
31,000
Stfc>u»3<*«te^l IT j^JBWfc"
-jKrojectwp ixiatpttg,
^V.^OttWixV'1
740.000
340,000
71
780
450
430
3.500
:\Ts;o6$ir>;'^.
8,000,000
1,500,000
570
6^00
4100
3.400
28,000
"*', Pwc^itt ,,
> ; Rerfwcti«)t ,, ,
92
83
89
89
91
89
90
                        4-53

-------
                                            Table 4-11
                             Pollutant Loadings  for  Finishing
Total suspended solids
10.000,000
3,200,000
6,800,000
68
Oil and grease
 4,400,000
 760,000
3,600,000
                                                                82
Total chromium
Total lead
Total zinc
   77,000




   10,000
                                21.000
  53,000




   4,800
                         8,300
  24,000




   5,200
                        13.000
                                                                                              31
52
                    62
                                                4-54

-------
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                                         Table 4-12
                    Pollutant Loadings for Nonintegrated Mills
Total suspended solids


Oil and grease
Total lead
Total zinc
3,900,000


 790,000
11,000
16,000
                                                  83.000
                                                   18,000
                                                    760
                                                   1.000
3300,000


 770,000


-   10,000


   15,000
                                                         97
                                                         97
                                                           91
                                                           94
                                             4-55

-------
                                        Table 4-13
               Pollutant Loadings for Hot Forming (Stand-alone)
Total suspended solids
570.000
49,000
520,000
91
Oil and grease
118,000
22,000
 96,000
                                     81
Total chromium
    42
                                                                        37
                                     88
Total copper
   460
   52
   410
                                                          89
Total lead
   290
   33
   260
                                                                                      90
Total nickel
Total zinc
   250
  2,000
   28
                                                   230
   220
                     1.800
                  90
                                             4-56

-------
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                                     Table 444
                      Pollutant Loadings for Cold Forming
Total suspended solids
Oil and grease
Total lead
Total zinc
47,000
21,000
  290
                              180
47,000
21,000
  no
                    180
ISO
62
                                         4-57

-------
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-------
                     Table 446
Costs to Upgrade to the Level of Better Performing Mills
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Indirect discharging coke plants •
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t
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continuous casting ' ;
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Finishing ; , 1
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5.0
5.1
WATER QUALITY AND CROSS-MEDIA IMPACTS
Impaired Water Bodies
             Prior, to  the early 1970s,  the following U.S. rivers were among those highly

polluted by discharges from major iron and steel mills:
                    Cuyahoga River at Cleveland, Ohio;
                    Grand Calumet River at Gary, Indiana;
                    Indiana Harbor Ship Canal at East Chicago, Indiana;
                    Mahoning River at Warren and Youngstown, Ohio;
                    Monongahela River in Western Pennsylvania;
                    Black River at Lorain, Ohio;
                    Rouge River at Dearborn, Michigan;  and
                    Ohio River at Weirton, WV and Steubenville, Ohio.
             At that time, many of these streams were polluted with heavy floating oils from

untreated and partially treated discharges from rolling mills; low pH and high iron levels from

dumping of spent pickling acids and untreated pickling rinse waters; and high concentrations of

ammonia-N, cyanide and phenols (4AAP) discharged from coke plants and blast furnaces.  These

conditions greatly improved during the 1970s and early 1980s through implementation of the first

technology-based NPDES permits  and federal and state enforcement actions.



             Despite major improvements in these  and other steel mill streams, state agencies

have identified 40 iron and steel mills with discharges to impaired water bodies.  (See Appendix

C, Iron and Steel Manufacturing Facilities Included on State 304(1) Short Lists).  Most facilities

were listed because of toxic metal discharges. Other pollutants listed include cyanide, phenols

(4AAP), selected toxic organic pollutants, and whole  effluent  toxicity (WET).64  This is an

indication that the current Part 420 is not wholly adequate to protect receiving water quality.
                                         5-1

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             Current NPDES permits for most integrated steel mills contain a combination of
technology-based effluent limitations and water quality-based effluent limitations (WQBELs).
Mills such as the U.S. Steel - Gary Works, Inland Steel - Indiana  Harbor Works and the
Bethlehem Steel - Burns Harbor Division have internal monitoring stations where technology-
based effluent limitations apply and outfalls where combinations of technology-based effluent
limitations and WQBELS apply.  Since the current Part 420 was promulgated, many state water
quality standards have been upgraded to include more stringent chemical-specific criteria for toxic
metals, ammonia-N and cyanide to conform to U.S. EPA water quality criteria. This has resulted
in application of WQBELs  more stringent than corresponding technology-based effluent
limitations. It is more likely that mills located on large receiving streams will be limited more
so by the  current Part 420 than WQBELs, while mills located on small receiving streams will
principally be limited by WQBELs.
5.2
Receiving Water Sediments
             There are several documented cases of receiving water sediment contamination
caused by historical discharges from iron and steel mills:
             Receiving Water
             Black River at Lorain, OH
             Grand Calumet River at Gary, IN
             Indiana Harbor Ship Canal
             Mahoning River
             Black Creek at Gadsden, AL
                                       Iron and Steel Mill
                                       USX/Kobe Steel
                                       U.S. Steel - Gary Works
                                       Inland Steel, LTV Steel
                                       LTV Steel
                                       Gulf States Steel
             Sediments in the Black River at Lorain, Ohio were contaminated by discharges of
PAHs from cokemaking operations.  These sediments have been partially remediated under the
terms of a consent agreement between U.S. Steel and EPA.65  As required by a federal consent
order, U.S. Steel has characterized contaminated sediments in the Grand Calumet River,66 and
is currently negotiating the terms and extent of a major sediment remediation program with
                                         5-2

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EPA.67  Also as part of a federal consent order, Inland Steel has committed to a sediment

characterization and remediation program for part of the Indiana Harbor Ship Canal and Indiana

Harbor.68



             During the mid-1980s, EPA Region 5 conducted sediment screening studies in

receiving streams for a number of current (at the time) and former coke manufacturing sites and

documented sediment contamination by PAHs.69 The results  of these studies suggest a high

probability that sediments contaminated by PAHs can be found at and immediately downstream

of most active and inactive coke plants located in the U.S.



5.3          Groundwater



             Groundwater pollution at integrated iron and steel mills has resulted from: leaking

wastewater collection sumps, leaking coke quench towers, and leaking blast furnace slag pits;

leaking wastewater treatment lagoons and ponds; historical direct disposal of spent pickling acids

in earthen pits; and leaking underground storage tanks and pipelines used to store  and transport

fuel oils and various chemicals including chlorinated solvents.



             It is  likely that  many  active and  former  by-product cokemaking  sites have

groundwater contamination.'  Disposal of  untreated  waste ammonia liquor and by-product

recovery wastewaters by coke quenching was. a common practice at many coke plants prior to

and during the 1960s and 1970s. This method of wastewater disposal is still practiced at a few

active coke plants. Groundwater contamination resulted  from leaking coke quench pits used to

collect and recycle excess quench water.   These pits are usually constructed of  concrete and

remain in service as long as the coke batteries are operated, generally from 20 to more than 40

years. Other coke plant groundwater contamination sources include leaking by-product recovery

wastewater collection sumps, disposal  of tank drag-outs  and process wastes in unlined surface

impoundments, and leaking storage tanks.  Principal pollutants include benzene, toluene, xylene,

ammonia, cyanide, phenolics, and PAHs.
                                          5-3

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             Similarly, disposal of blast furnace gas  wash recycle system blowdown by
evaporation on blast furnace slag has caused groundwater contamination at a number of mills
from  leaking slag pits and  inadequate containment of  excess quench water.   Groundwater
contamination from this source is a relatively recent phenomena compared to contamination from
leaking coke quench pits.  Most blast furnaces were equipped with treatment and recycle systems
during the 1970s, and disposal of recycle system blowdown did not become widespread until the
early and mid-1980s when compliance with Part 420 became an issue for blast furnace operators.
Disposal of recycle system blowdowns by slag quenching offered a relatively low-cost means to
comply with Part 420. Groundwater contamination from blast furnace operations is characterized
by ammonia, cyanide, and phenolics.

             Many other sources of  groundwater contamination at  steel  mills are similar to
those found at other industrial manufacturing sites: leaking above-ground and below-ground fuel
storage  tanks  and  leaking  underground  storage   tanks  of  chlorinated solvents  (e.g.,
trichloroethylene, tetrachloroethylene).
5.4
Air
             Most of the cross-media impacts in the iron and steel industry involve pollutant
transfers from air to water and solid waste media from wet and semi-wet air pollution control
systems and from blast furnace and coke oven gas cleaning systems. Disposal of untreated coke
plant waste ammonia liquor arid by-product recovery wastewaters by coke quenching probably
causes the greatest transfer of pollutants from water to air; however, this practice is currently
limited to a relatively small number of plants.  Other water-to-air transfers result from loss of
volatile pollutants from:  open coke plant wastewater equalization and  storage  tanks and
wastewater treatment systems; open process wastewater sumps; emissions from blast furnace slag
pits where blast furnace blowdown is used for slag quenching; and volatilization of oil-based
compounds from hot forming and cold rolling wastewater treatment systems. When Part 420 was
                                          5-4

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promulgated, EPA found that the effluent reduction benefits associated with disposal of blast

furnace blowdown by slag quenching outweighed the air pollution impacts.13



5.5           Solid and Hazardous Waste



              As noted above,  most of the cross-media impacts in the iron and steel industry

involve transfers of air emissions to water through wet and semi-wet air pollution control systems

and subsequent transfers from wastewater to solid waste in the form of wastewater treatment

sludge.  There are also direct transfers from air to solid waste from dry air pollution control

systems, the most prominent of which are dry air controls on EAFs.



              There are also opportunities for transfers from solid waste to water from handling

and disposal of wastewater sludges and air pollution control dust. At some mills, runoff from

dewatered wastewater sludge collection and storage areas reaches noncontact cooling water and

stormwater discharges without treatment.  At other mills, air pollution control dust falls  to the

ground  to  be absorbed in  subsequent runoff  in  stormwater and noncontact cooling  water

discharges.



5.6           Opportunities for Multimedia Rulemaking



              Because many of the  wastewaters generated from basic steelmaking operations

result from air emission control or gas cleaning operations, there are obvious opportunities for

multimedia rulemaking. To the extent that dry air controls can be the basis for either the air or

water  technology-based  emission or  discharge  limitations,  wastewater discharges can  be

eliminated.  This can be done within the water media  alone by setting NSPS at zero discharge

for those operations where dry air controls are a viable technology (e.g., sinter plants, EAFs, ladle

metallurgy stations, scarfers on hot forming mills, all of which are demonstrated in the industry).

A coordinated review of all iron and steel industry operations may yield additional opportunities.
                                          5-5

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             Coke quenching operations are limited by State Implementation Plans (SIPs) for
paniculate emissions  only.  Many of these limitations are in the form of maximum allowable
total dissolved solids (IDS) concentrations in quench water.  Pollutants characteristic of coke
plant and by-product recovery wastewaters (ammonia-N, cyanide, phenols (4AAP), benzene,
toluene, xylene and PAHs) are not regulated.  Because  of the benzene NESHAP regulations
currently applicable to coke plants and additional pending regulations for HAPs (hazardous air
pollutants) under the  Clean Air Act, a coordinated air/water review of coke plant regulations
would ensure that the resulting regulations would not be contradictory.

             Other opportunities for multimedia rulemaking include consideration of regulations
that would limit disposal of iron and steel industry wastewaters by non-discharge methods such
as slag quenching and incineration  in  steelmaking furnace air emission control systems.
Coordinated rulemaking could also be considered to control groundwater contamination resulting
from wastewater treatment and disposal.
5.7
Review of Recent Permit Violations and Enforcement Actions
5.7.1
Recent Permit Violations
             Tables 5-1 through 5-6 summarize data from EPA's Permit Compliance System
'(PCS) Database regarding documented NPDES permit violations.  The data for 1994 are only
complete through August 31,1994. For each parameter, the number of violations and the number
of companies representing the violations are presented.
5.7.2
Recent Federal and State Clean Water Act Enforcement Cases
             During the past six years, at least four major federal enforcement cases and one
major state enforcement case have been brought against iron and steel manufacturers for NPDES
permit violations under the Clean Water Act.  The  four federal enforcement actions  were
                                         5-6

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eventually settled through negotiations resulting in Consent Agreements or Consent Orders,

whereby the affected companies agreed to technical remedies, and cash penalties and stipulated

penalties for continuing violations.  The one state action has not been completed at this writing.

Following is a brief summary of each case describing the types of NPDES permit violations

alleged, the technical remedies and the cash penalties.



              U.S.A. v. USX Corporation (Civil Action No. 88-558, N.D. Indiana)



              In 1988, the U.S. Government alleged that U.S. Steel's integrated mill at Gary,

Indiana made  unauthorized discharges of blast furnace process wastewater from  noncontact

cooling water  outfalls, exceeded NPDES permit effluent limitations for ironmaking and steel

finishing operations, made unauthorized discharges  of  intake  screen backwash,  and made

unauthorized discharges from unpermitted outfalls.



              The Consent Order issued in  1990 required U.S. Steel to pay a  cash penalty of

$1.6 million; spend at least $7.5 million for receiving stream sediment characterization and

remediation; and make  several process wastewater sewer rehabilitation and treatment system

upgrades, which were reported to cost about $26 million. These upgrades included:  installation

of a recycle system for basic oxygen process contact gas cooling water; development and

implementation of a coke plant wastewater management plan; rehabilitation of coke plant cooling

water sewers;  corrections for discharges of blast furnace gas seal overflows and blast furnace

process water  cross-connections to noncontact cooling water outfalls; routing of finishing mill

basement  sump  discharges to the finishing  mills treatment system; and development and

implementation of a visible oil monitoring and correction action program for process and cooling

water outfalls discharging to the Grand Calumet River.
                                          5-7

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             U.S.A. v. Wheeling-Pittsburgh Steel Corporation (Civil Action No. C-2-88-598,
             S.D., Ohio)

             In 1988, the U.S. Government brought a civil action against Wheeling-Pittsburgh
Steel for its plants located at Steubenville, Mingo Junction and Yorkville, Ohio (the Steubenville-
North, Steubenville-South and Yorkville Plants) for exceedances of NPDES permit effluent
limitations and untimely installation of wastewater treatment facilities necessary to comply with
the technology-based BPT and BAT effluent limitations applicable to those facilities.

              The Consent  Order for this case was issued in  1991 and required Wheeling-
Pittsburgh to pay a cash penalty of $6.1 million, complete construction of process wastewater
treatment facilities that was underway at the time of the lawsuit, and  conduct a series  of
investigative and corrective action programs at each facility, many of which were similar to those
required by the U.S. Steel Consent Decree noted above.

             U.S.A. v. Wheeling-Pittsburgh Steel Corporation (Civil Action No. 89-2375,
             W.D.,  PA)

             The  U.S. Government  also brought suit against Wheeling-Pittsburgh Steel for
NPDES permit violations at its Allenport, Pennsylvania steel finishing plant in 1989.  The
Consent Order in that case was issued in 1992 and required Wheeling-Pittsburgh Steel to pay a
cash penalty of about $2 million and upgrade the process water and process wastewater treatment
systems at the mill.

             U.S.A. v. Inland Steel  Corporation (Civil Action No. H90-038, N.D. Indiana)

             The  U.S. Government's case against Inland Steel involved Resource Conservation
and Recovery Act,  Clean Air Act, and NPDES permit effluent violations.  The Consent Decree
                                          5-8

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in that case required Inland Steel to pay a cash penalty of $3.5 million for all media violations.

The case was filed in October 1990 and the Consent Decree was issued in March 1993.



             The required wastewater remedial actions included:  upgrading sampling and

analytical quality assurance/quality control programs; a heavy metal corrosion inhibitor control

program; investigations and corrective actions at a number of process and cooling water outfalls;

rehabilitation of  a  sanitary wastewater  treatment  plant;  development  of a  plant-wide

environmental communications program directed at spill prevention, control and response; and

a plant-wide visible oil monitoring and corrective action program. Inland Steel also agreed to

conduct sediment characterization and remediation in Indiana Harbor and the Indiana Harbor Ship

Canal as a supplemental environmental project.



             IDEM v. LTV Steel Company, Inc. (Indiana Cause No. 37C01-9104-CP-54)



             The Indiana Department of Environmental Management filed a civil enforcement

case against LTV Steel in 1991 for NPDES permit effluent violations from sintering, ironmaking,

steelmaking, vacuum degassing, and continuous casting operations at  the LTV  Steel Indiana

Harbor Works located in East Chicago,  Indiana. The complaint also  alleged that LTV Steel

caused an oil spill to the Indiana Harbor Ship Canal.  The case is pending at this writing.
                                         5-9

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                  Table 5-1
EPA Permit Compliance System Violations (1989)
' •>'-'' '*,"« *"''<>'"1 '+•.?&.'•? ^,*t".**S1^'
< , j* V- /, fMnoweter - '- - ,v .^x^ i
•• ••.', - -.\-- *- ,"-5 , ;- "'->*-? «r,t *' J
Dissolved oxygen (DO)
BOD, 5-day (20 deg. C)
Chemical oxygen demand (COD)
PH
Total suspended solids
Oil and grease
Nitrogen, Ammonia Total (as N)
Total phosphorous (as P)
Total organic carbon
Total cyanide
Free cyanide (amen, to chlorination)
Total arsenic
Total cadmium
Hexavalent chromium
Total chromium
Total cobalt
Total copper
Total iron
Dissolved iron
Total lead
Total manganese
Total nickel
Total silver
Total zinc
»• *>*•«*«*"! -';&'* ' '.-. ^;w>i: , ••„ !
• ;;s ytmiitf* VjUM|M»,v,c
16
30
6
282
266
157
68
7
3
28
10
3
4
17
24
1
7
98
5
52
9
24
1
130
; Nw»lierof€wapai*t
V ? ^ f f 5 f %.
7
15
3
61
60
39
16
2
1
12
3
1
1
7
13
1
6
14
1
20
3
6
1
32
                     5-10

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            Table 5-1 (Continued)

EPA Permit Compliance System Violations (1989)
' viV.-i^ * '' <* "'\$^- - "JLji^'-H ^/^fV"* V" ,*<
Total aluminum
Total recoverable phenolics
Toluene
Benzene
Benzo(a)pyrene
1,1,1 -trichloroethane
Phenol, single compound •
Naphthalene
Phenols
Vi^^l&toi^x!;
•• j- s. ; o <>*• rt *-^, , •». f * % f',,'*
4
49
2
6
11
9
15
25
1
c" NamWr &-£w»jNmfejr
'„ s.,— ., - >-»^ :... ,
1
11
i
3
2
1
2
5
1
                     5-11

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                  Table 5-2
EPA Permit Compliance System Violations (1990)
'- * '-r \f&sw^.7^^-^:T*
Dissolved oxygen (DO)
BOD, 5-day (20 deg. C)
Chemical oxygen demand (COD)
pH
Total suspended solids
Oil and grease
Nitrogen, Ammonia Total (as N)
Total phosphorous (as P)
Total organic carbon
Total cyanide
Free cyanide (amen, to chlorination)
Total cadmium
Hexavalent chromium
Total chromium
Total copper
Total iron
Total lead
Total manganese
Total thallium
Total nickel
Total silver
Total zinc
Total antimony
Total aluminum
'. "< ..:•.'» V *"* < •. '' "..
10
13
6
313
323
166
89
7
10
39
9
1
19
23
28
97
64
7
6
29
1
171
. 1
2
•,::w.:^' A •„> vy. •". ^ ^-.;. '. _, -.
N«n»b«r (^ Ctmipanjes
5
10
2
60
73
47
20
3
2
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7
1
7
10
7
15
17
3
1
9
1
46
1
1
                     5-12

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            Table 5-2 (Continued)

EPA Permit Compliance System Violations (1990)
, , •••• •- 1 :-•" * {• "Bw-awfctjr/- -" " "' ;\' « ' ?> "- -i
•• •• - s f ^ J' *- •* o ^ ^ *- •• "• -. t '5 ^ S •"
Total recoverable phenolics
Toluene
Benzene
Benzo(a)pyrene
Fluorene
1,1,1-trichloroethane
Phenol, single compound
Naphthalene
Phenols
:\v;Ki»»b«R «T -flWte^m' , ^
52
1
4
3
1
3
2
29
2
V^wmlwr of Companies :
12
1
. 2
2
1
1
2
9
2
                     5-13

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                  Table 5-3
EPA Permit Compliance System Violations (1991)
-" •• ~» " > *~ s-^''\ ' ;.. •> « C >» " '
:, .. s >,f..,,, --. - rN $>arai8«ter ? t . - ;- ^/, V i -.s
^ •« XC- «. ^^ .. v v^ j-"'-' f V« v f f* •* ,s.
Dissolved oxygen (DO)
BOD, 5-day (20 deg. 'Q
Chemical oxygen demand (COD)
pH
Total suspended solids
Oil and grease
Nitrogen, Ammonia Total (as N)
Total organic carbon
Total cyanide
Free cyanide (amen, to chlorination)
Hexavalem chromium
Total chromium
Total copper
Total iron
Dissolved iron
Total lead
Total manganese
Total thallium
Total nickel
Total silver
Total zinc
Total antimony
Total aluminum
Total recoverable phenolics
;4$^^lto^
19
19
3
309
258
185
68
2
46
11
23
19
17
73
4
47
2
12
22
5
138
1
2
55
iKuiBlwT ef Cwttpaiwes -/
9
10
• 2
75
70
46
23
2
12
2
8
10
7
12
2
15
2
1
9
2
36
1
1
9
                     5-14

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            Table 5-3 (Continued)

EPA Permit Compliance System Violations (1991)
&>;-v '^:^mm^f^^^^^
•• •.. v •• .. 0\ . ^ ^ x>^ *\?^ ^ ^ "• <: •=
Benzene
Benzo(a)pyrene
Ruoran there
1,1,1 -trichloroethane
Phenol, single compound
Naphthalene
Phenols
:: "^I^Wf^^V^rtfeBS f "
: ' , , , v-'s ' ' , '»'-. '.
1
1
1
3
1
w>
9
N«»|>«rofC«i»|)aw»es -
1
i
l
l
1
4
3
                    5-15

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                  Table 5-4
EPA Permit Compliance System Violations (1992)
^ y ^ \ v > v^M&^£^v^>'W!A^&??
r ^r^^^^W^^-^^^^^
Dissolved oxygen (DO)
BOD, 5-day (20 deg. C)
Chemical oxygen demand (COD)
pH
Total suspended solids
Oil and grease
Nitrogen, Ammonia Total (as N)
Total phosphorous (as P)
Total organic carbon
Total cyanide
Free cyanide (amen, to chlorination)
Total cadmium
Hexavalent chromium
Total chromium
Total copper
Total iron
Dissolved iron
Total lead
Total manganese
Total nickel
Total silver
Total zinc
Total antimony
Total aluminum
w* smjjfrjj£j^*ffiji0faA£,\?
•j;^l«Pl^r^ ^fl^sr^ *«..>
14
33
3
237
211
174
50
1
2
36
6
1
23
14
12
29
1
72
2
10
1
113
2
3
'" ^itmtM^nf f*flmtkai&*it '"

6
13
3
53
58
46
20
1
1
10
4
1
6
9
5
8
1
19
1
6
1
26
1
1
                     5-16

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                           Table 5-4 (Continued)

             EPA Permit Compliance System Violations (1992)
Total recoverable phenolics
Benzene
Benzo(a)pyrene
14,1 -trichloioethane
Naphthalene

Phenols
48
13

14
                                      5-17
11

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                  Table 5-5
EPA Permit Compliance System Violations (1993)
s *'<*
	 *...,.......<:. 	 ?..£At^.^..X..+ art^"A.-:*r £*-'•«''.'»<.
Dissolved oxygen (DO)
BOD, 5-day (20 deg. C)
pH
Total suspended solids
Oil and grease
Nitrogen, Ammonia Total (as N)
Total organic carbon
Total cyanide
Free cyanide (amen, to chlorination)
Total cadmium
Hexavalent chromium
Total chromium
Total copper
Total iron
Total lead
Total nickel
Total silver
Total zinc
Total recoverable phenolics
Benzo(a)pyrene
1,1,1-trichloroethane
Naphthalene
Phenols
$? >f^^^i^f^^^l^'<°-'''^
^tfWFj^^^^^P-; -t<
5
7
232
150
119
33
1
27
1
2
11
12
10
17
53
16
14
99
29
1
2
4
2
^^jaf^^-
3
4
59
54
43
15
1
11
1
1
4
4
3
8
13
9
2
29
11
1
1
2
2
                     5-18

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                  Table 5-6
EPA Permit Compliance System Violations (1994)
;<" 0% ^">"** """"^ Optk^M&rf' >V ^ *'" '"V'^ 'tO V"
"" ^ ** v" Iv. ^ •> -u ^v-v* ... ' •«' s *• -ft f S *r -.jy, ^N v WN*? 1?
Dissolved oxygen (DO)
BOD, 5-day (20 deg.'C)
pH
Total suspended solids
Oil and grease
Nitrogen, Ammonia Total (as N)
Total organic carbon
Total cyanide
Free cyanide (amen, to chlorination)
Total cadmium
Hexavalent chromium
Total chromium
Total copper
Total iron
Dissolved iron
Total lead
Total manganese
Total nickel
Total silver
Total zinc
Total tin
Total aluminum
Total selenium
Total recoverable phenolics
i . .'. . - *. O. - - '- - 1. >' "".'. *). - . t^jA. ?..?*'?..?... '.'. >* "?
6
22
133
100
67
32
1
23
10
1
19
12
9
19
2
26
1
5
7
59
1
1
1
28
•f^^^milk^
4
8
47
44
36
14
1
9
3
1
9
6
5
7
1
9
1
5
2
27
1
1
1
9
                     5-19

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                        Table 5-6 (Continued)



            EPA Permit Compliance System Violations (1994)
&?£^Hn? fis»f|p^4 Wf %P8
 Benzo(a)pyrene
 Naphthalene



 Phenols
                                 5-20

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6.0          NEW AND INNOVATIVE APPROACHES



6.1          Production Technologies



             (a)    A considerable amount of research is currently underway into new iron and

                    steelmaking processes that would eliminate or substantially minimize the

                    need for coke.  Among these is a $55 million Direct Steelmaking research

                    project funded primarily by the Department of Energy.27 The purpose of

                    this project is to determine whether direct steelmaking without production

                    of coke and molten iron in separate processes can be a commercially

                    viable technology. Processes to produce molten iron directly from coal

                    and  iron-bearing  materials are also being evaluated.   Because these

                    processes have not yet been demonstrated on a commercial scale at this

                    tune, they are judged not to be suitable to form the basis for revised BAT

                    effluent limitations guidelines and NSPS.   Furthermore,  the capital

                    investment required to implement such processes across the industry for

                    existing mills within the compliance schedule required by the CWA would

                    most likely be prohibitive.  In the long term, these projects may provide

                    substantial benefits for the integrated segment of the industry in the form

                    of lower capital investments for upgrades and modernization;  improved

                    production scheduling and productivity through use of multiple parallel

                    production units instead of a smaller number of large units that must be

                    periodically taken out of service; and substantially lower air emissions and

                    wastewater discharges than current operations.



             (b)    In the United States, nearly all of the blast furnace coke is produced in by-

                    product coke plants with their costly and difficult air and water pollution

                    control problems.  There is one commercial-scale nonrecovery coke battery

                    operated for production  of blast furnace coke by Sun Coal Company in
                                          6-1

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       Vansant, Virginia.  The coke battery comprises adjacent horizontal, dome-
       shaped ovens constructed to allow combustion of the gasses evolved from
       the coal during coking, thus consuming the by-products that are recovered
       in  by-product recovery coke  plants.   The process allows for energy
       recovery and results in substantially lower air emissions and virtually no
       cokemakmg process wastewater discharges compared to by-product coke
       plants.  Inland Steel  announced  plans to replace its coke plants with
       nonrecovery coke batteries but later abandoned those plans for financial
       reasons.
              70
(c)     A patent application is pending for a continuous; closed process to pyrolize
       coal in circular tubes (ovens) which are indirectly heated with a portion of
       the gas produced.  The process is being developed by Calderon Energy
       Company of Bowling Green, Ohio. Calderon reports the following major
       components of the process:

       •     Positive displacement of coal feed and coke discharge;
       •     Horizontal pyrolysis of coal for consolidation;
       •     Integrated dry steam quenching of coke;
       •     Hot cleanup of raw gas yielding cracked desulfurized gas;
       •     Regeneration of sorbent yielding elemental sulfur; and
       •     Provision of lockhoppers for charging coal,  discharging
             coke, and sorbent handling.

       Calderon reports that the  process will generate no fugitive or process
       emissions and that wastewater treatment will not be required because the
       process cracks all coal distillation products (tars, ammonia, light oils).
                             6-2

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       Calderon reports that the process will result in three products: coke of

       high stability, desulfurized syngas rich in hydrogen, and elemental sulfur.

       The process has not been demonstrated on a commercial scale as of this

       writing.



(d)    Pulverized coal injection for blast furnace operations is a technology that

       uses.raw material substitution. In this process, pulverized coal is injected

       into the blast furnace through the tuyeres, thus supplying part of the carbon

       required to reduce the iron-bearing materials to molten iron. This reduces

       the coke demand for furnace operations and eliminates the air emissions

       and wastewater discharges that would have occurred from production of

       the displaced coke. The project team is not aware of any studies that fully

       characterize blast furnace recycle system discharges from furnaces operated

       with pulverized coal injection.  Injection of oil and pulverized coal into

       blast furnaces is demonstrated in the U.S. iron and steel industry.



(e)    Although continuous  casting  is not a  new  process, it has only  been

       implemented on a large scale in the United States during the last fifteen

       years (see Figure 2-9).  This  process results in substantial productivity

       improvements,  energy and  manpower  savings, and effluent  reduction

       benefits.   The  effluent reduction benefits accrue because  virtually all

       continuous casters are installed with high-rate  recycle systems for cooling

       and process waters. These systems replace blooming and slab mills that

       typically have considerably higher water usage and effluent discharges.



       Most continuous  casters installed  to produce flat rolled products are

       configured  to produce slabs ranging from 8  to 10 inches in  thickness.

       Breakdown of these slabs into strips requires a complete hot strip mill

       equipped with  reheat furnaces, several roughing  stands, and a set of
                             6-3

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                    finishing stands.  There is one nonintegrated mill that is equipped with
                    two, thin-slab casters to produce two-inch thick slabs. These slabs are hot-
                    charged into a normalizing furnace, processed in one descaling stand, and
                    then processed in a set of finishing stands.  Recently, Acme Metals, Inc.,
                    one of the smallest integrated steel makers, announced plans to install a
                    thin slab caster to produce flat-rolled carbon steels for selected markets.71
                    The  use  of thin  slab  casting  allows for lower capital  investment
                    requirements for entry into some of the flat rolled steel markets, and
                    results in  effluent reduction  benefits  from reduced  water usage  and
                    discharge from hot strip mills.

              (f)    A number of new continuous strip finishing mills have been constructed
                    during the last five to seven years.  As noted earlier, several steel finishing
                    and metal  finishing operations  are often combined  in one or  two
                    continuous production lines compared  to  many separate mills.  These
                    newer mills offer the potential for effluent reduction benefits over separate
                    processes.   The  project team is  not aware of any studies that  fully
                    characterize effluent discharges from these mills.
6.2
Wastewater Flow Minimization and Improved Wastewater Treatment
              Aside from process modifications that would result in changes in the volume and
character of process wastewaters, there are three principal methods to reduce mass discharges of
pollutants to the environment from iron and steel manufacturing operations:
                    Wastewater flow minimization through process water conservation,
                    process water reuse, and process water recycle;
                    Improved end-of-pipe wastewater treatment to lower concentrations
                    of discharged pollutants; and,
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                    Effluent disposal by nondischarge methods including evaporation
                    on slags, incineration in furnaces, and deep well disposal.
             When considering the CWA goal of zero discharge of pollutants for iron and steel

manufacturing operations, wastewater flow minimization must be a first priority.  For many of

the basic steelmaking  operations,  opportunities to  minimize or eliminate the  discharge of

pollutants become feasible only if process wastewater flows are minimized through high-rate

recycle.



6.2.1         Wastewater Flow Minimization



             Since Part 420 was promulgated in 1982, better performing mills in the U.S. iron

and steel industry have significantly improved wastewater flow minimization through increased

high-rate recycle, cascading process water from one operation to another, and alternate effluent

disposal methods. Process water  discharge rates at many of the mills highlighted in Section 4.3

as better  performing  mills are  substantially below  those  used  by EPA as model process

wastewater flows to establish the  effluent limitations guidelines and standards.  Except for

cokernaking and steel finishing operations, performance better than the ELG  LTAs shown on

Figures 4-1 through 4-8 is principally attributable to reductions in process wastewater discharges.



6.1.2         Improved Treatment Methods and Treatment Operations



             Also  demonstrated by the better performing mills are improved wastewater

treatment methods and  enhanced  treatment system  operations. These include:
                    Operation of coke plant wastewater treatment  systems without
                    ammonia stripping as a pretreatment;


                    Improved operation of coke plant biological treatment systems by
                    adding enhanced biocultures;
                                          6-5

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                    Combined metals precipitation and alkaline chlorination treatment
                    of pretreated coke plant wastewaters  and blast furnace recycle
                    system blowdown;

                    Combined treatment of sinter plant and blast furnace blowdowns in
                    an advanced metals precipitation system;

                    Innovative treatment of wastewaters resulting from BOF suppressed
                    combustion emission controls that permits operation with zero
                    discharge for extended periods;

                    Cascading of recycle system blowdowns from basic steelmaking
                    operations  (BOF,  vacuum degassing,  continuous  casting)  to
                    minimize process wastewater discharges;

                    Combined treatment of a blowdown from a hot strip mill high-rate
                    recycle  system with blowdowns from  other high-rate  recycle
                    systems in a metals precipitation and filtration system; and

                    Operation  of  a  combination of pretreatment and end-of-pipe
                    wastewater treatment systems to achieve minimal discharges from
                    steel finishing operations.
6.3
Pollution Prevention
             For purposes of this report, "pollution prevention" is used in the context of EPA's

definition of the term:  "... the use of processes, practices or products that reduce or eliminate

the generation of pollutants."  EPA advocates a hierarchial approach to pollution prevention

which focuses first upon "source reduction" as a means to reduce or eliminate waste, and second

upon "recycling" to reuse or reclaim used materials and waste. Historically, the iron and steel

industry used pollution prevention as an integral part of its operations.  However, most of the

following pollution prevention techniques are  examples of recycling, rather than examples of

source reduction:
                    Recovery of by-products from cokemaking operations (crude coal
                    tars, crude light oils, anhydrous ammonia or ammonium sulfate,
                                          6-6

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                    sodium phenolate) for use  or  processing  into  final products
                    elsewhere;


                    Reprocessing of coke plant tar decanter sludges and wastewater
                    treatment sludges in coke ovens;


                    Recovery of iron values from blast furnace flue dusts, blast furnace
                    wastewater sludges and mill scale, and consumption of coke breeze
                    in sinter plants;


                    Processing and reuse of blast furnace and steelmaking slags for use
                    in the road building, construction, and railroad industries;


                    Remelting and processing of home scraps, prompt industrial steel
                    scraps, and dormant steel scraps in BOFs  and EAFs to make new
                    steel;


                    Collection and recovery of EAF flue dusts for recovery of lead and
                    zinc values;


                    Recovery and processing of recovered waste lubricating oils and
                    rolling solutions for use as fuel supplements;


                    Regeneration of spent  acid pickling liquors for reuse and use of
                    spent pickling liquors as treatment aids for POTWs; and


                    Collection of dross from hot coating operations for recovery of
                    metal values at off-site processors.
             Examples of source reduction in the iron and steel industry include the alternative

ironmaking and steelmaking processes briefly reviewed in Section 6.1: nonrecovery cokemaking

instead of by-product cokemaking and continuous casting instead of the combination of ingot

casting  and primary  rolling.   Nonintegrated  steelmaking  with  EAFs instead  of integrated

steelmaking with intermediate production  of coke, sinter, and molten iron could also  be

considered source reduction.  Because EAF steelmaking cannot currently be used to produce all

grades of steel products, and cannot be used to produce all steel products at current demand rates,

it would not be practical to base a revised single media  or multimedia regulation on this

technology.
                                          6-7

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              A primary pollution prevention technique to eliminate wastewater discharges is use
of dry air emission and gas cleaning controls instead of wet or semi-wet controls where possible
(see Section 5.6).  Other available pollution prevention techniques regarding wastewater treatment
include high-rate process water and  process  wastewater recycle for sintering,  ironmaking,
steelmaking, vacuum degassing, continuous casting, and hot forming operations, flow reduction
through other means for steel finishing operations (e.g., cascade rinsing and fume scrubber
recycle for acid pickling lines), and cascading of recycle system blowdowns from one operation
to another. These technologies are well demonstrated in the U.S. iron and steel industry, but not
universally applied.

              One example of an innovative process wastewater treatment and recycle system
is that operated by LTV Steel for the suppressed combustion BOF shop at its Cleveland Works.
The process water treatment system for the furnace air emission control wet scrubbers is operated
in a water softening mode such that LTV Steel  operates with no discharge for extended periods
of time.  Relatively low-volume, intermittent discharges are made to a nearby continuous caster
recycle system. The total discharge of toxic metals from the BOF system is substantially lower
than the effluent limitations derived from the applicable effluent limitations guidelines.72

              A potential innovative approach  for disposing of a blowdown from a combined
blast furnace/sinter plant recycle system is being explored by U.S.  Steel at its Gary Works.67
U.S. Steel has applied for a permit from the Indiana Department of Environmental Management
to pilot test incineration of the blast furnace/sinter plant blowdown in BOF steelmaking  gas
cleaning systems.  This project is designed to eliminate a wastewater source by evaporating the
blowdown and incinerating the nonmetal pollutants.  The metals present would be transferred to
the BOF gas cleaning water and treated with metals normally found in BOF wastewaters.  It is
expected that the pilot testing will occur during the next year.
                                          6-8

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6.4           Residuals Management



              The iron and steel industry generates large quantities of residuals from the primary

ironmaking  and steelmaking processes and wastewater  treatment sludges from all industry

operations.  Table 6-1  summarizes  the  more common practices for beneficially reusing or

disposing of residuals.



              Virtually all residuals from by-product cokemaking operations are either recovered

as crude by-products (e.g., crude coal tar, crude light oil, ammonium sulfate),  collected  and

reused or sold (e,g., coke breeze), or recycled to the coke ovens for recovery of carbon values

(e.g., coal tar decanter  sludge, coke plant wastewater  treatment sludge).   Ironmaking  and

steelmaking slags generated at most integrated steel mills are processed and beneficially reused

in a variety of construction and road building uses. Blast furnace flue dusts and blast furnace

gas wash water wastewater treatment sludges are recovered through sinter plants at less than half

the blast furnace plants.  These materials are recovered through cold briquetting at one known

mill.  Other wastewater treatment sludges are landfilled at nearly all mills.



              Continuous caster and hot forming mill scales are recovered on site at mills with

sinter plants, recovered off site in cement manufacturing, or are landfilled at a number of mills.

Wastewater treatment sludges from hot forming operations are generally  not  recovered or

recycled because of high oil content.  Similarly,  wastewater  treatment sludges from finishing

operations are generally not recovered because of high  oil and metals content.  Although these

sludges are relatively high in iron content, it is not currently economical to process and recover

the iron from the sludges.



6.5           Best Management Practices



              Part 420  does  not contain best management practices (BMPs).  Because of the

extensive raw material handling and the nature of cokemaking,  sintering,  ironmaking,  and
                                          6-9

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steelmaking operations, a considerable number of discharges are not currently regulated by Part
420  or  by most  NPDES permits.  These unregulated discharges have been the subject of
remediation actions sought by EPA in steel industry enforcement actions.66'68'73 A more effective
and uniform means to control such discharges would be to require BMPs as part of 40 CFR Part
420. Following is a partial list of potential BMPs:
                    Control  of spillage and losses  from  raw  material unloading
                    operations  (ore docks);

                    Control of runoff from raw material storage piles: coal, coke, iron
                    ore, limestone, scrap steel;

                    Control  of  fugitive discharges  of  process  waters,  process
                    wastewaters, and process materials to coke plant, blast furnace, and
                    sinter plant noncontact cooling water (NCCW);

                    Control of  coke oven and blast furnace gas condensates;

                    Control of runoff/leachate and  groundwater contamination from
                    coke batteries, coke quench tower sumps, and by-product recovery
                    areas;

                    Control of runoff/leachate and  groundwater contamination from
                    blast furnace slag pits located at the furnaces;

                    Control  of runoff from blast furnace  and  steelmaking  slag
                    processing  located  at the furnaces and in remote areas (almost
                    always operated by contractors);

                    Control of  runoff from EAF dust collection areas;

                    Control of spillage and runoff  from loading stations for rolling
                    solutions and pickling acids; and

                    Surveillance and corrective action programs for oil discharges from
                    large NCCW flows.
                                          6-10

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                Table 6-1
Common Practices for Residuals Management
Proc^Opera^i
Cokemaking
Ironmaking
Steebnaking
Continuous Casting
Hot Forming
Finishing operations
•-.'!-'^>'.^r^./^'.-'r.'1-. *' ? ,>*> v- s.'.rf A'V^'^V'V
Crude coal tar
Crude light oil
Ammonium sulfate
Ammonia
Coke breeze
Tar decanter sludge
Wastewater treatment sludge
Blast furnace slag
Hue dust
Wastewater sludge
BOFslag
EAFslag
Wastewater sludge
MiU scale
Mill scale
Waste oils
Wastewater sludge
Waste pickling acids
Waste oils
Wastewater sludges

Recovered and sold as by-product
Returned to coke ovens
Processed and sold as by-product
Recovered in sinter plants; cold briquetted;
landfUled
Processed and sold as by-product
Processed for recovery of metals
LandfUled; cold briquetted and reused
LandfUled; recovered in sinter plants
Recovered in sinter plants; recovered in
cement manufacturing; landfUled
Recovered and used as fuel supplement
LandfUled

Regenerated and reused; reused as municipal
wastewater treatment aide; neutralized and
discharged
Recovered and used as fuel supplement
LandfUled
                   6-11

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           7.0          REFERENCES


_         1.     47 FR 232S8. Part II; Environmental Protection Agency; Iron and Steel Manufacturing
J                Point Source Category Effluent Limitations Guidelines and Standards; May 27, 1982.

           12.     Settlement Agreement for Case No. 82-3225 and Consolidated Cases; National Steel
                  Corporation, etal., Petitioners v. U.S. Environmental Protection Agency, Respondent and
                  Natural Resources Defense Council, Inc., Ihtervenor-Respondent; U.S. Court of Appeals
•                for the Third Circuit; February 24, 1993.

           3.     49 FR 21036. Part H Environmental Protection Agency; Iron and Steel Manufacturing
•                Point Source Category Effluent Limitations Guidelines and Standards; May 17, 1984.

           4.     Consent Decree for Civil No. 89-2980; Natural Resources Defense Council, Inc.; Public
I                  Citizen, Inc., Plaintiffs v. William K. Reilly, Administrator, U.S. Environmental Protection
                  Agency, Defendant, and American Paper Institute; National Forest Products Association;
                  et ah, Intervenor-Defendants; United States District Court for the District of Columbia;
•                January 31, 1992.

           5.     47 FR 23266. May 27, 1982.

•         6.     American  Iron and  Steel Institute; Steel Works, U.S. Steel Industry  at a Glance;
                  Washington, D.C, 1992.
•
•         7.     Association of Iron and Steel  Engineers; The Making, Shaping and Treating of Steel',
                  ISBN 0-930767-00-4; Pittsburgh, PA; 1985.

'         8.     U.S. EPA; Development Document for Effluent Limitations Guidelines and Standards
m                for the Iron and Steel Manufacturing Point Source Category, VoL I; EPA 440/1-82/024;
I                Washington, D.C; May 1982.

_         9.     U.S. EPA; Development Document for Effluent Limitations Guidelines and Standards
I                for the Inn and Steel Manufacturing Point Source Category, VoL H (Cokemaking);
                  EPA 440/1-82/024; Washington, D.C; May 1982.

|         10.    Personal communication between Gary A.  Amendola, P.E., Amendola Engineering, Inc.,
                  Lakewood, OH and K.C Shaw, P.E., Chief Engineer - Environment, Geneva Steel, Provo,
•                UT; June 16, 1994.

           11.    U.S. International Trade Commission; Metallurgical Coke: Baseline Analysis of the 17,5.
•                Industry and Imports',  Publication 2745; Washington, D.C;  March 1994.



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12.   U.S. EPA; Development Document for Effluent Limitations Guidelines and Standard*
      for the In* and Steel Manufacturing Point Source Category, VoL n (Sintering); EPA
      440/1-82/024; Washington, D.C; May 1982.

13.   U.S. EPA; Development Document for Effluent Limitations Guideline* and Standard*
      for the Iron and Steel Manufacturing Point Source Category, VoL n (Ironmalring); EPA
      440/1-82/024; Washington, D.C; May 198Z

14.   BOF Roundup; 33 Metal Products; May 1991; p-35.

15.   U.S. EPA; Development Document for Effluent Limitation* Guideline* and Standards
      for the Iron and Steel Manufacturing Point Source Category, VoL in (Steelmaking);
      EPA 440/1-82/024; Washington, D.C; May 1982.   ,a

16.   U.S. EPA; Development Document for Effluent Limitation* Guidelines and Standards
      for the Iron  and Steel Manufacturing Point Source Category, VoL ffl (Vacuum
      Degassing); EPA 440/1-82/024; Washington, D.C; May 1981

17.   U.S. EPA; Development Document for Effluent Limitations Guidelines and Standard*
      for the Iron and Steel Manufacturing Point Source Category, VoL in (Continuous
      Casting); EPA 440/1-82/024; Washington, D.C;  May 1982.

18.   U.S. EPA; Development Document for Effluent Limitations Guidelines and Standards
      for the Iron and Steel Manufacturing Point Source Category, VoL IV (Hot Forming);
      EPA 440/1-82/024; Washington, D.C; May 1982.

19.   U.S. EPA; Development Document for Effluent Limitations Guidelines and Standards
      for the  Iron  and Steel Manufacturing Point  Source Category, VoL V (Salt Bath
      Descaling); EPA 440/1-82/024; Washington, D.C; May 1982.-

20.   U.S. EPA; Development Document for Effluent Limitations Guidelines and Standards
      for the Iron and Steel Manufacturing Point Source Category, VoL V (Acid Pickling);
      EPA 440/1-82/024; Washington, D.C; May 1982.

21.   U.S. EPA; Development Document for Effluent Limitations Guidelines and Standards
      for the iron and Steel Manufacturing Point Source Category, VoL VI (Cold Forming);
      EPA 440/1-82/024; Washington, D.C; May 1982.

22.   American Iron and Steel Institute; Directory  of Iron and Steel Works of the United
      States and Canada; Washington, D.C.; 1977.
                                       7-2

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           23.    Association of Iron and Steel Engineers; Directory of Iron and Steel Plants; Pittsburgh,
                 PA; 1994
           124.   American Iron and Steel Institute; Statistical Highlights, U.S. Inn and Steel Industry,
                 Washington, D.C.; 1983.
           25.   American Iron and Steel Institute; Annual Statistical Report, 1988', Washington, D.C.;
                 1989.
           26.   American Iron and Steel Institute; Annual Statistical Report, 1992; Washington, D.C.;
                 1993.
           27.   American Iron and Steel Institute; Statistical Highlight* KS. Iron and Steel Industry;
                 Washington, D.C; 1993.
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           128.    Personal communication between Gary A. Amendola, P.E., Amendola Engineering, Inc.,
                  Lakewood, OH  and Mary Johnson, Statistics Department, American Iron and Steel
                  Institute, Washington, D.C, August 9, 1994.
•         29.    American Iron and  Steel Institute; Capital Expenditures by Reporting Companies for
                  Domestic Environmental Control and Solid Waste Disposal Faculties; AIS  17EC;
•                Washington, D.C, 1993.
           30.    American Iron and Steel Institute; AISI News; Washington, D.C.; June 1994.
"         31.    39 FR 24114-24133. 40 CFR Part 420, Subparts A - L.
I         32.    American Iron and Steel Institute, et. al, v EPA, 526 F.2d 1027 (3rd Circuit, 1975)
g         33.    39 FR 12990-13030. 40 CFR Part 420, Subparts M - Z.
 •          34.    American Iron and Steel Institute, et. al., v EPA, 568 F.2d 284 (3rd Circuit, 1977)
I         35.    40 FR  1858  -  1907.   Part II; Environmental Protection Agency; Iron and Steel
                  Manufacturing Point Source Category  Effluent Limitations Guidelines and Standards;
•                January 7, 1981.
           36.    47 FR 23266. May  27, 1982.
I
•         38.    Industrial Economics, Incorporated; The Use and Impact of Iron and Steel Industry

I.
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           37.    47 FR 23265. May 27, 1982.
                  Industrial Economics, Incorpc
                  Intra-Plant Trades; Cambridge, MA; March 1994.

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39.    Ontario Ministry of the Environment Status Report on the Effluent Monitoring Data
      for the Inn and Steel Sector for the Period from November 1,1989 to October 31,
       1990; Water Resources Branch; Toronto, Ontario; September 1991.

40.    Hatch  Associates Ltd.  Inventory and Costing of Best Available Pollution Control
       Technologies for the Iron and Steel Sector in Ontario', (Final Draft Report); Mississanga,
       Ontario; September 1991.

41.    U.S. EPA File Information. Central Treatment Rulemaking Record. September 27,1984.
       Washington, D.C  (Draft Proposed Modification to 40 CFR Part 420).

42.    Mr.  Joseph  S. Kocot (Director - Plant Maintenance and Engineering, National Steel
       Corporation, Granite City Division, Granite City, Illinois) to Mr. Timothy R. Kluge P.E.
       (Manager, Industrial Unit, Permit Section, Illinois Environmental Protection Agency,
       Springfield,  Illinois); June 25, 1992; 3 pp w/attachments.

43.    Mr.  James  H.  Scarbrough (Chief,  Water Permits and Enforcement Branch, Water
       Management Division)  to Mr. John Poole (Chief,  Industrial Branch; Water Division,
       Alabama Department of Environmental Management, Montgomery, Alabama); June 29,
       1993; 3 pp w/attachments.

44.    Personal communication between Gary A. Amendola, P.E., Amendola Engineering,  Inc.,
       Lakewood,  OH  and  Irvin  DzikowsM,  Chief,  Permits Section,  Water Management
       Division, U.S. EPA Region V, Chicago, IL; August 2,  1994.

45.    Personal communication between Gary A. Amendola, P.E., Amendola Engineering,  Inc.,
       Lakewood, OH and Karen Buerki, Enforcement Section, Water Management Division,
       U.S. EPA Region 4, Atlanta, GA; June 1993.

46.   47 FR 23273.  May 27, 1982.

47.   49 FR 21025.  May 24, 1984.

48.    Espositot MJ., Tieman, T.O.  and Dryden, F.E., Dioxins,  Office of Research and
       Development; U.S. Environmental Protection Agency, Cincinnati, Ohio, EPA-600/2-80-
       197, November 1980.

49.   U.S. Environmental Protection  Agency, National Dioxin Study Report to Congress,
      Office of Solid  Waste and Emergency Response, Washington, D.C., August 1987,
      EPA/530-SW-87-025.
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—          50.    U.S. Environmental Protection Agency, The National Dioxin Study • Tien 3J,6, and 7,
•                Office of Water Regulations and Standards, Washington, D.C., February 1987, EPA-
*                440/4-87-003.

I          51.    Amendola, G.A., Barna, D., Blosser, R., LaFleur, L., McBride, A., Thomas, E, Tieman,
                  T., and Whittcmorc, EL, The Occurrence and Fate ofPCDDs and PCDFs in Bleached
m                Kraft Pulp and Paper Mills, Chemosphere, Volume 18, Nos. 1  - 6, 1989.
            52.    U.S.  Environmental Protection Agency, U.S. EPA/Paper Industry Cooperative Dioxin
                  Screening Study, Office of Water Regulations and Standards, Washington, D.C., March
                  1988, EPA 440/1-88-025.
•


            153.    Oberg, T. and Allhammar, G. Chlorinated Aromatics from Metallurgical Industries -
                  Process Factors Influencing Production and Emissions, Chemosphere, Volume 19, Nos.
                  1 - 6, pp 711 - 716, 1989.

I          54.    Tysklind, M., Soderstrom, G., Rappe, C, Hagerstdet, L.E., and Burstrom, E. PCDD and
                  PCDF Emissions from Scrap Metal Melting Processes at a Steel Mill, Chemosphere,
•                Volume  19, Nos. 1 - 6, pp 705 - 710, 1989.

            55.    Antonsson, A.B., Rumark, S., and Mowrer, J.  Dioxins in the Work Environment in Steel
•                Mills, Chemosphere, Volume 19, Nos. 1 - 6, pp 699 - 704, 1989.

            56.    Colburn, C. and Clement, C., Chemically-Induced Alterations in Sexual and Functional
I                Development: the Wildlife/Human Connection. In: (ed) Princeton Scientific, Princeton,
•                pp 1-403, 1992.

I          57.    White, R., Jobling, S., Hoare, S.A., Sumpter, J.P., and Parker, M.G., Environmentally
                  Persistent Alkylphenolic Compounds are Estrogenic, Endocrinology:  135:175-182,
-                1994.

            58.    Nayior, G.C., Mierure, J,P., Weeks, J.A., Castaldi, F.J., and Romano, R.R., Alkylphenol
                  IEthoxylates in the Environment.  Journal of the Society of American Oil Chemists:
                  69:695-703, 1992.


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59.
60.
61.
62.
       Ahei, Mw Conrad, J. and Giger, W., Persistent Organic Chemicals in Sewage Effluents.
       III.   Determination of nonylphenoxy carboxyUc  acids  by high  resolution gas
       chromatography/mass spectroscopy and high performance liquid chromatography.
       Environmental Science and Technology: 21:697-703,1987.

       Giger, W., Ahel, M., Koch, M., Uubscher, H.U., Schaffner, J. and Schneider, J.,
       Behavior of AUcylphenol-polyethoxylate Surfactants and of NitrOoacetate in Sewage
       Treatment. Water Science and Technology:  19:449-460, 1987.

       Zoller,  U., Groundwater Contamination  by Detergents and Potycyctic Aromatic
       Hydrocarbons • A Global Problem of Organic Contaminants: Is the Solution Locally
       Specific? Water Science and Technology:  27:187-194, 1993.

       Clark, L.B., Rosen; R.T., Hartman, T.G., Louis, J.B., Stuffet, LH., Uppincott, RX., and
       Rosen, J.D., Determination of AlkylphenolEthoxylates and their Acetic Acid Derivatives
       in  Drinking  Water  by Particle  Beam Liquid Chromatography/Mass Spectroscopy.
       International JournaLof Environmental Analytical Chemistry: 47:167-180,1992.

63.    Personal communications between Gary A. Amendola, P.E., Amendola Engineering, Ins,
       Lakewood, OH, and Peter Howe, Permits Section, Water Management Division, U.S. EPA
       Region 5, Chicago, IL; September 1, 9, and 26, 1994.

64.    304(1) lists.

65.    USX/Kobe Dredging Consent Decree.

66.    Consent Decree for Civil Action No. 88-558; United States of America, Plaintiff v. USX
       Corporation, Defendant; United States District Court for the Northern District of Indiana;
       1990:			-              	-	-

67.    Personal communication between Gary A. Amendola, P.E., Amendola Engineering, Inc.,
       Lakewood, OH and J. David Moniot,  General Manager - Environmental Affairs and
       Water Manager, U.S. Steel, Pittsburgh,  PA; September 1,1994.

68.    Consent Decree for Civil Action No. H88-0328; United States of America, Plaintiff v.
       Inland Steel Company, Defendant; United States district Court for the Northern District
       of Indiana, Hammond Division; March  8, 1993.
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            169.    Personal communication between Gary A. Amendola, P.E., Amendola Engineering, Inc.,
                  Lakewood, OH and Mark O. Moloney, Environmental Engineer, U.S. Environmental
                  Protection Agency, Region 5, Environmental Sciences Division, Eastern District Office,
•                Westlake, OH; May 27, 1994.

            70.    Personal communication between Gary A. Amendola, P.E., Amendola Engineering, Inc.,
I                  Lakewood, OH and Robert D. Johnston, Staff Engineer,  Environmental, Health and
                  Safety, Inland Steel Company, East Chicago, IN, September 7, 1994.

            171.    Newspaper Article:  Steel Producer Plans 'Hybrid? Afiff; Chicago Tribune; Thursday,
                  August  16, 1994.

            172.    Amendola, G.A. and Safavi, B.; LTV Steel Company  -  Cleveland Works Pollution
                  Prevention Case Study; 1992 (Draft Report).

            173.    Consent Decree for Case No. C2 88-216; United States of America, Plaintiff v. Wheeling-
                  Pittsburgh Steel Corporation, Defendant; United States District Court for the Southern
                  District of Ohio Eastern Division; 1991.




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8.0
GLOSSARY
Acid Furnace
Acid Steel
Additions
Air Cooled Slag
Alloy
       A furnace lined with acid brick as contrasted to one lined with basic brick.
       In this instance the terms acid and basic are in the same relationship as the
       acid anhydride and basic anhydride that are found in aqueous chemistry.
       The most common acid brick is silica brick or chrome brick.


       Steel made in a furnace or converter lined with siliceous (acid) refractory
       material.   In the open hearth and electric furnaces employing the  acid
       process, the hearth or bottom consists of fritted ("burned in") silica sand.
       The acid  bessemer converter usually was lined with a kind of sandstone
       called "firestone". Raw materials for acid steel must be low in phosphorus
       and sulfur.


       Materials which  are added to the molten bath of steel or to  the molten
       steel in the ladle to produce the chemical composition required for the
       specific steel order.

       Slag which is cooled slowly  in  large pits in the ground.  Light water
       sprays are generally used to accelerate the cooling over that which would
       occur in air alone.  The finished slag is generally gray in color and looks
       like a sponge.

       A substance that has metallic properties and is composed of two or more
       chemical elements of which at least one is a metal.  .
Alloying Materials  Additives to steelmaking processes for improving the properties of the
                    finished products.  Chief alloying elements in medium alloy steels are:
                    nickel,  chromium, manganese, molybdenum,  vanadium,  silicon, and
                    copper.
Alloy Scrap
       Scrap steel which contains one or more alloying metals such as nickel,
       chromium, manganese,  molybdenum,  tungsten, vanadium,  silicon,  or
       copper.   Such scrap must be very  carefully classified  according  to
       composition and kept separate from other kinds of scrap.
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Alloy Steel
Aluminum
Ammonia Liquor
Ammonia Still
Ammonia Still
 Bottoms

Angle


Annealing



Apron Rolls
Steel is classified as alloy when the maximum of the range given for the
content of alloying elements exceeds  one or more  of the  following:
manganese, 1.65%; silicon, 0.60%; copper, 0.60%; or in which a definite
range or a definite minimum quantity of any of die following elements is
specified  or  required  within  the  limits  of the  recognized field  of
constructional alloy steels:  aluminum, boron, chromium up to  3.99%,
cobalt, niobium (columbium), molybdenum, nickel, titanium, tungsten,
vanadium, zirconium, or any other alloying  element added to obtain a
desired alloying effect,

A metallic chemical element  (1) In either the bessemer, open hearth or
electric furnace processes, it is  (or was) used as a deoxidizer, by adding
it to the molten steel either in the ladle or in the mold to remove oxygen,
and thereby  control, or entirely eliminate,  the escape  of gas  (called
"killing"). Aluminum may also be added for the control of grain m/c, and
occasionally as an alloying element  (2) A light weight metaL It weighs
28% as much as carbon steel.

Primarily water condensed from the coke oven gas, an aqueous solution of
ammonium salts of which there are two kinds; free  and fixed. The free
salts are those which are decomposed on boiling to liberate ammonia. The
fixed salts are those which require boiling with an alkali such as lime or
sodium hydroxide to liberate die ammonia.

The free ammonia still is simply a steam stripping column where ammonia
gas is  removed from ammonia liquor.  The fixed still is similar except
lime or, more commonly,  sodium hydroxide, is added to the liquor to
liberate .ammonia from  its compounds so it can be steam stripped.

Treated effluent from an ammonia stilL
A very common structural or bar shape with two legs of equal or unequal
length intersecting at 90°.

Either batch or continuous heat treatment applied to cold rolled or cold
formed steel to soften the steel and modify other mechanical and physical
properties, or to produce a definite microstructure.

Rolls used in the casting strand for keeping cast products aligned.
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Bar, Hot Rolled
Base Box
Basic Bottom
 and Lining
Basic Brick


Basic Furnace


Basic Material
Basic Steel
Basic Oxygen
 Steelmaking
Battery
Produced from ingots, blooms, or billets covering the following range:
Rounds,  3/8 to 8-1/4 in. incl.;  Squares, 3/8 to 5-1/2 in.; Round cornered
squares, 3/8 to 8 in. incl.; Hexagons, 1/4 to 4-1/16 in. incl.; Flats, 13/64
(0.2031)  in. and over in specified thicknesses and not over 6 in. specified
width.

Standard and special shapes: Angles, channels, tees, and zees, when their
greatest cross-sectional dimension is under 3 in.  Ovals, half ovals, and
half rounds.  Special shapes.

A unit of measure peculiar to the tin plate industry. It corresponds to an
area equivalent to 112 sheets of tin plate, 14 x 20 in. each; or, 31,360 sq.
in.; or, 217.78 sq. ft.

In a melting furnace, the  inner lining and bottom are composed of
either crushed burned dolomite, magnesite, magnesite bricks, or basic slag.
These materials have a basic reaction in the melting process.

A brick made of a material which is a basic anhydride such as MgO or
mixed MgO plus CaO. See acid furnace.

A furnace  in which the refractory material is  composed of dolomite or
magnesite.

A chemical expression meaning the opposite  of acid.  Basic and acid
materials, when brought  together  so that they  can react, neutralize each
other,  forming salts or slags.  In such reactions, the  base becomes the
positive  part of the salt  and  the acid the negative.  Examples of basic
materials;  limestone   (or  lime,  CaO), magnesite   (MgO),  dolomite
(containing both CaO and MgO). Examples of acid materials; quartzite or
silica (SiOj) and the various clays, oxides of sulfur, etc. In metallurgy, the
terms, "bases" and "acids," are applied to refractories, fluxes, and slags.
Slags aze said to be basic when the bases in  them are greater than the
acids;  or to be acid when the acids in them are greater than the bases.

Steel melted in a furnace that has a basic bottom and lining, and under a
slag that is dominantly basic.

The basic oxygen process is carried out in a basic lined furnace
which is shaped like  a pear.  High pressure oxygen is blown vertically
downward  on the surface of the molten iron through a water cooled lance.

A group of coke ovens arranged side by side.
                                           8-3

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  Beam
  Billet
  Blackplate
 Blast Furnace
 Bloom
 Slowdown
 Box Annealing
Bosb


Briquette
  An important member of the  structural steel family.   There are three
  varieties; the standard H, I, and the side flange used for weight supporting
  purposes.

  A semi-finished piece of steel which has resulted from rolling an ingot or
  a bloom.  It may be square, but is never more than twice as wide as thick.
  Its cross-sectional area is usually not more than 36 sq. in.

  Cold reduced sheet over 12 in. wide to less than 32 in.,  in cut length or
  coils, and within the uniform classification of Flat Rolled Carbon Steel
  Products.

  A large, tall conical-shaped furnace used to reduce iron ore to molten iron
  or "hot metal".

 A semi-finished piece of steel, resulting from the rolling or forging of an
 ingot  A bloom is square or  not more than twice as wide as thick, and
 usually not less than 36 sq. in. in cross-sectional area.

 Volume of water discharged  from  process water or noncontact cooling
 water recycle system.  For high-rate recycle systems, the  blowdown may
 be less than 2% of recirculating water flow.

 A process of annealing a ferrous alloy in a suitable closed  metal container
 with or without packing material in order  to minimize oxidation.   The
 charge is usually  heated slowly to a temperature below the transformation
 range, but sometimes above or within it, and is then cooled slowly.  This
 process is also called "close annealing" or "pot annealing."

 The bottom section of a blast furnace. The section between the hearth and
 the stack, where melting of iron  starts.

 An agglomeration of steel plant waste material of sufficient strength to be
 charged to a blast furnace.
By-product Coir  Process in which coal is carbonized in the absence of air to permit
 Processes          recovery of the volatile compounds and produce coke.
Burden
Solid feed to a blast furnace.
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Bustle Pipe
Carbon Steel
Cast Iron




Casting



Caustic Dip




Channels




Charge




Chromium
Clarification
Large-diameter, refractory-lined pipe surrounding the bottom of a blast
furnace near the bosh (inverted conical section of blast furnace where
melting of iron starts). The bustle pipe is used to distribute the hot blast
from the blast furnace stoves to the furnace through tuyeres located below
the bosh.

Steel which owes its properties chiefly to various percentages of carbon
without substantial amounts of other alloying elements. Steel is classified
as carbon steel when no minimum content of elements other than carbon
is specified or required  to  obtain a desired  alloying effect; when the
specified minimum for copper does not exceed 0.40%; or the maximum
content for  the  following  does not  exceed  the  percentage  noted:
manganese,  1.65; silicon, 0.60; copper, 0.60.

The metallic product obtained by reducing iron ore with carbon at a
temperature sufficiently high to render the metal fluid and casting it in a
mold.

(1) A  term applied  to the act of pouring molten metal into  a moM.
(2) The metal object produced by such pouring.

Immersion of a metal in a solution of sodium hydroxide to clean the
surface,  or, when  working with  aluminum  alloys,   to  reveal the
macrostructure.

A common steel shape consisting of two parallel flanges at right angles to
the web. It  is produced both in bar sizes (less than 3 in.)  and in structural
sizes (3 in. and over).

The minimum combination of skip or bucket loads "of material which
together provide the balanced complement necessary to produce hot metal
in the blast  furnace of the desired specification.

An alloying element added to alloy steel (in amounts up to about 1.50%)
to increase  hardenability.   Chromium content of 4% or more confers
special ability to resist corrosion, so that steel containing more than 4%
chromium is called "stainless steeL"

The process of removing undissolved materials from a liquid, specifically
either by settling or filtration.
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Clinkers
Closed Hood



Coating


Cobble
Coke


Coke Battery
Coke Breeze



Coke Wharf

Cold Pig
Cold Rolled
 Products
Another name for sinter, the product of burning a fuel (coke fines, coke
breeze) with limestone fines and a variety of fine iron-bearing materials
including iron ore  screenings, blast furnace gas cleaning wastewater
sludges,  and mill scale to form an agglomerated product suitable  for
charging to a blast furnace.

A system in which the hot gases from the BOF are not allowed to bum in
the hood with outside air infiltration. These hoods cap the furnace mouth.
Suppressed combustion.

The process of covering steel with another material, primarily-for corrosion
resistance.
                                                     -.ce-
(1) A jamming of the tine of steel sheet while being rolled in a hot strip
milL  (2) A piece of steel which for any reason has become so bent or
twisted that it must be withdrawn from the rolling operation and scrapped.
Some reasons  for cobbling are: Steel too cold,  a bad end which cannot
enter a pass, sticking to the roll and wrapping around it, etc.

The carbon residue left when the volatile matter is driven off of coal by
high temperature distillation.

A coke producing unit comprising numerous, adjoining, refractory-lined,
slot-type top coke ovens; coal charging  and coke pushing facilities; coke
quench stations; coke oven gas collecting mains; and other appurtenant
equipment

Undersize coke particles recovered from coke screening operations and
coke  quenching stations.   Coke breeze  is used as  fuel  in  sintering
operations or sold as a by-product

The place where coke is discharged from quench cars prior to screening.

Blast furnace metal which has been cast into solid pieces, usually weighing
from 60 to 80 Ibs.

Flat-rolled products  which have been finished by rolling the
piece  without heating (at approximately ambient temperature).
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Conditioning
The removal of surface defects (seams, laps, pits, etc.) from semi-finished
steel in the form of blooms, billets, slabs.  It may be accomplished by
chipping, scarfing, grinding, or machining. In special cases, the steel may
be pickled first so as to reveal more of the defects.
Continuous Casting A process for solidifying liquid steel in place of pouring it into ingot
                    molds. In this process, the solidified steel is in the form of cast blooms,
                    billets, or slabs.  This eliminates the need for soaking pits and primary
                    rolling.
Continuous Mill
Creosote

Crop End



Dephenolizer



Deoxidize
 Descaling
Double Slagging



Duplexing



Dustcatcher
A mill composed of several stands of rolls arranged "in tandem", usually
so close together that the  steel being  rolled is passing through several
stands simultaneously.  Examples: bar mills, hot strip mills,  and some
recently constructed plate mills.


Distillate from tar.

The end or ends of an ingot or rolled product that contain the pipe or other
defects to be cut off and discarded; also termed "discard."


A facility  in which  phenol is removed from ammonia liquor  and is
recovered as sodium phenolate by liquid extraction and vapor recirculation.


in the limited sense used in metallurgy,  the removing of oxygen  from a
heat of molten steel. Oxygen is present as iron oxide  (FeO), which is
dissolved in the steel, and is removed by  adding a deoxidizing agent such
as manganese, silicon, or aluminum.

The process of removing scale from the surface of steel. Scale forms most
readily when the steel is hot by union of oxygen with iron.  The most
common method of descaling is to crack the scale by use of  roughened
rolls and a forceful water spray.

Process in which the  first oxidizing slag  is removed and replaced with a
white, lime finishing  slag.

An operation in which a lower grade of steel is produced in a basic oxygen
furnace and then an alloyed in  the electric arc furnace.

A part of the blast furnace  through which the major portion of the dust is
removed by mechanical separation.
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Electric Arc
 Furnace
Electrostatic
 Precipitate*
Evaporation
 Chamber
Extrusion


Ferroalloy
Ferrochrome


Ferromanganese



Ferrophosphorus


Ferrosilicon
A furnace in which scrap iron, scrap steel, and other solid ferrous
materials are melted and converted to finished steel. Liquid iron is rarely
used in an EAF.

A gas cleaning .device using the principle of placing an electrical charge
on a solid  particle which is then attracted  to an oppositely charged
collector plate. The collector plates are intermittently rapped to discharge
the collected dust to a hopper below.

A method used for cooling gases to the precipitators in which an exact
heat balance is maintained between water required and gas cooling; the
design is to discharge no  effluent as all of the water  is supposed to be
evaporated.                .,

Shaping metal into a continuous form by forcing it  through  a die of
appropriate shape.

An iron-bearing product, not within the range of those called steels, which
contains a considerable amount of one or more alloying elements, such as
manganese,  silicon, phosphorus, vanadium, and chromium.  Some of the
more common ones are ferrochromium, ferromanganese, ferrophosphorus,
ferrosilicon, and ferrovanadium.  The  chief use of these alloys is for
making additions of their respective alloying dements to molten steel.

A finishing  material which contains about 70% chromium.  It is used as
a chromium alloying material.

A product  of  the blast furnace, containing, besides iron, 78% to  82%
manganese and some silicon, phosphorus, sulphur, and  carbon..  It is used
as a deoxidizer and for alloying manganese.

A  finishing material  (see  "finishing")  which contains  about  18%
phosphorus. It is used as a phosphorus alloying material.

A product of the blast furnace which contains 8 to 15% silicon,  it is used
as a deoxidizer and for alloying silicon.
Ferrous Metallurgy That  section of general metallurgy which embraces  the science  and
                    knowledge applied to iron and steel  products, their  preparation,  and
                    adaptation to their uses.
Ferrovanadium
A product which contains iron and about 38%  vanadium.  Used for
alloying vanadium.
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Fettling
Final Cooler

Finish
Finishing Materu

Flat Sheet

Flats
Flattening
Flume Flushing

Flying Shear
Flushing Liquor
Flux
Forging



                    The period of time between tap and start

                    An open packed tower for cooling coke oven gas by direct contact  The
                    gas must be cooled to 30°C (86°F) for recovery of light oil  Open final
                    coolers have been replaced  with closed final coolers to control benzene
                    emissions.

                    In the steel industry, refers to the type of surface condition desired or
                    existing in the finished product

Finishing Materials Any material  which may be added to purified molten  steel in the latter
                    stages of producing  a  heat of steel (Le., for  modifying its chemical
                    composition).

                    Sheet rolled as pieces of convenient size and then flattened or leveled,
                    usually by stretching.  This operation may produce properties  slightly
                    different from those of coiled sheet

                    Flat bars. They include all rectangular bars, except squares 13/64 in.  and.
                    over in specified thickness, not over 6 in. in specified width.

                    Standard commercial flatness is obtained by roller leveling. This consists
                    in passing  sheets individually or in packs through a machine having a
                    series of small diameter rolls.

                    Process by which mill scale collected under hot forming mills and runout
                    tables  of continuous  casters is transported with water to scale  pits for
                    recovery.

                    A shear which severs steel as the piece continues to move. In continuous
                    mills, the piece being rolled cannot be stopped for the shearing operation,
                    so the shear knives must move with it until it is  severed.

                    Water recycled in the coke battery gas collecting main  for the purpose of
                    cooling the gas as it leaves the coke ovens.

                    Material added to a fusion process for the purpose of removing impurities
                    from the hot metal

                    (1) As a noun; a metal product which has been formed by hammering or
                    pressing, (2) As a verb; forming hot metal into the desired shape by means
                    of hammering or pressing.
                                          8-9

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Forming
To shape or fashion with the hand, tools, mechanical equipment, or by a
shape or mold.
Forming Properties Those physical and mechanical properties that allow a steel to be formed
                    without injury to the steel in the finished product
Four-High Mill
Fourth Hole
Free Leg
A stand which has four rolls, one above die other. This kind of mill has
two working rolls, each of which is stiffened by a larger back-roll Four
high rolls are used only on mills which roll fiat products:  slabs, plates,
sheets, and strips.

A fourth recovery lined hole in the roof of die electric arc furnace which
serves as an exhaust port for furnace gases.

A portion of old-design free  and fixed ammonia  stills from which
ammonia, hydrogen sulfidc, carbon dioxide, and hydrogen cyanide are
steam distilled and returned to the gas stream.
Fugitive Emissions  Emissions that are expelled to the atmosphere in an uncontrolled manner.
Furnace Burden


Gages



Galvanizing



Galvannealed
Grade


Granulated Slag
The solid materials charged to a blast furnace comprising coke, iron ore
and pellets, sinter, and limestone.

Measurements of  thickness.  Examples of various standard  gages are
United  States Standard Gage (USS), Galvanized Sheet Gage  (GSG),
Birmingham Wire Gage (BWG).

The process of applying a coating of zinc to the finished cold-reduced
sheet  or to fabricated parts made from strip products.  The  coating is
applied by hot dipping or electrolytic deposition.

An extra tight coat of galvanizing metal (zinc) applied to a soft steel sheet,
after  which the sheet is  passed through an annealing oven at about
1,200°F. The resulting coat is dull gray, without spangle, and especially
suited for subsequent painting.

The term grade designates divisions within different  types based  upon
carbon content or mechanical properties.

A product made by dumping liquid blast furnace slag past a high pressure
water jet and allowing it to fall into a pit of water. The material has the
appearance of light tan sand.
                                         8-10

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            H-Steel             Alloy steels that can be used in applications requiring different degrees of
 I                              hardenability.

 _          Hammer Forging   A  forging process in  which the work is deformed by repeated blows.
 £                              Compare with press forging.

I            Hammer Lap       A defect on the surface of steel, being a folded over portion produced by
                                bad practice in forging.

I            Hammer Welding   Welding effected by heating close to their melting point the two surfaces
                                to  be joined, and hammering them until a firm union is made.

I            Hammering        Beating metal sheet into a desired shape either over a form or on a high-
                                speed mechanical hammer, in which the sheet is moved between a small
                                curved hammer and a similar anvil to  produce the required dishing or
 •                              thinning.

            Hard Drawn        A temper produced in wire, rod, or tube by cold drawing.

 I          Hardness           Defined in terms  of  the method  of  measurement  (1)  Usually, the
                                resistance to dentation. (2)  Stiffness or temper of wrought products. (3)
 •                              Machinability characteristics.

            Hearth             In a reverberatory furnace, the portion that holds the molten metal or bath.

 "          Heat               Quantity of steel manufactured in a BOF or an EAF on a batch basis; the
                                capacity of the furnace.

 ~          Hexagons-          A  product  of hot rolled carbon steel  bars hexagonal in  cross  section.
                                Commercial size range of hexagons, 1/4 to 5-1/2 in. inclusive.

            High Strength Steel Low alloy steels forming a specific class in which enhanced mechanical
 —                              properties and, in most cases, resistance to atmospheric corrosion are
 •                              obtained by the incorporation of moderate proportions of one or more
                                alloying elements other than carbon. The preferred terminology is "high-
 g                              strength, low-alloy steels."

            Holding Furnace   A  small furnace  for  maintaining molten metal from a larger melting
 •.                              furnace at the right casting temperature.

            Hoop               Special quality flat rolled steel product developed to meet the requirements
•                              of the cooperage industry in the manufacture of barrels, pails, and kegs.
I

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Hot Bed


Hot Blast
Hot Metal
   f.

Hot Metal Furnace


Hot Quenching


Hot Rolled


Hot Top



Hot Working
It  is furnished in  black or galvanized, and in cut lengths or coils, as
specified.

A  large  area  containing closely spaced rolls or rails for holding hot,
partially rolled metaL

Preheated air  blown into the blast furnace through a bustle pipe and
numerous tuyeres located around  the circumference of the furnace.
Temperatures are in the range of 550°C to 1,000°C, and pressures are in
the range of 2 to 45 atmospheres.

The molten iron product of a  blast furnace; pig iron.

A  furnace that is  initially charged  with solid materials  followed by a
second charge of melted liquid.

A process of quenching in a medium at a temperature substantially higher
than ambient temperature.

Hot  rolled products are  those  products that  are rolled to  finish at
temperatures above the recrystallization temperature.

A reservoir insulated to retain  heat and to hold excess molten metal on top
of an ingot mold in order to feed the shrinkage of the ingot Also called
"shrink head," or "feeder head".

Plastic deformation of metal  at such  a temperature and rate that strain
hardening does not occur.  The lower limit of temperature for this process
is the recrystallization temperature.
Hydraulic Shear    A shear driven by water or oil pressure.

Immersion Coating
Impact Extrusion?
In Tandem
Indirect Extinction
 (Inverted)
Coating a metal with a second metal by immersing the first in a solution
containing ions of the second.

A cold forming process in which the metal is forced  by impact to flow
around the punch, forming a tube with a solid bottom.

An arrangement of stands in a rolling mill, one after another, so that the
piece being rolled can travel in one direction through a number of stands.

An extrusion process in which the metal is forced back inside a hollow
ram that pushes the die.
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Induction
 Hardening
A process of hardening a ferrous alloy by heating it above the
transformation range by means of electrical induction, and then cooling as
required.
Induction Heating  A process of heating by electrical induction.
Ingot
bigot Iron
Ingot Moid
Iron
Iron Ore


Iron Scrap


Killed Steel



Kish

Ladle
A large block-shaped steel casting.  Ingots are intermediates from which
other steel products are made.  When continuous casters are not used, an
ingot is usually the first solid form the steel takes after it is  made in a
furnace.

Steel so low in carbon, silicon, manganese, phosphorus, sulphur and other
metalloid content that it is commonly called "pure iron".  Ingot iron is
sometimes used for making enameling sheets. Also, silicon is  sometimes
added to "pure iron" to make high grade electrical sheets.

Cast iron molds into which molten steel is  teemed.  After cooling, the
mold is  stripped from  the  solidified steel  which is then  re-heated in
soaking pits (gas or oil-fired furnaces) prior  to primary rolling into slabs
or billets. Molds may be circular, square, or rectangular in shape, with
walls of various thickness.  Some molds are  of larger cross section at the
bottom, other are larger at the top.

Primarily the name of a metallic element In  the steel  industry, iron is the
name of the product of a blast furnace containing 92  to 94% iron, the
product made by the reduction of iron ore. Iron in the steel mill sense is
impure  and contains  up to  4% dissolved carbon along with other
impurities.

The raw material from which iron is made. It is primarily iron oxide with
impurities such as silica.

Blast furnace metal or other iron which may be salvaged before remelting
in a blast furnace or in a steelmaking furnace.

Steel deoxidized with a  strong  deoxidizing agent  such  as  silicon or
aluminum in order to reduce the oxygen content to a minimum so that no
reaction occurs between carbon and oxygen during solidification.

A graphite formed on hot metal following tapping.

A large vessel into which molten metal or  molten slag is received and
handled. Molten metal may be transported short distances in a ladle.
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Ladle Metallurgy
Lap
Lap Weld
Larry Car
Light Oil
Lime
Lime Boil



Liming


Machining
A secondary step in the steelmaking process often performed in a ladle
after the initial refining process in a primary furnace (BOP, EAF) is
complete. Ladle metallurgy is conducted for one or more of the following
purposes:  control  of gasses in the steel; remove  sulfur beyond that
removed in  primary  steelmaking;  remove  undesirable non-metallics;
inclusion morphology; and, to change mechanical properties.

A surface defect appearing as a seam caused from folding over fins or
sharp corners during hot  rolling and then rolling or forging, but not
welding, them into the surface.

A term applied to a weld formed by lapping two pieces of metal and then
pressing or hammering, and applied particularly to the longitudinal joint
produced by a welding process for tubes or pipe, in which the edges of die
skelp are beveled or scarfed so that when they are over-lapped they can be
welded together.

Movable device located  on top of a coke battery  for receiving and
charging predetermined amounts of screened  coal to coke ovens through
charging holes.

A clear yellow-brown oil with a specific gravity of about 0.889.  It
contains varying amounts of coal-gas products with boiling points from
about 40°C to 200°C and from which benzene, toluene, xylene, and solvent
naphthas are recovered.

Calcium oxide  (CaO),  produced   by burning  limestone, principally
comprising calcium carbonate (CaCO3), in a lime kiln. Lime is used as a
flux (slagging agent) in basic oxygen  furnace steelmaking; limestone is
used as a flux in blast furnaces for production of molten iron (hot metal).

The fixed leg of the ammonia still to which milk of lime is added to
decompose ammonium salts; the liberated ammonia is steam distilled and
returned to die gas stream.

Application  of lime to pickled rod produced  in die wire industry for
protection against corrosion and as a lubricant for cold drawing.

In general, the cutting away of the surface of a metal by means of power
driven  machinery.  Specifically,  a method of  conditioning steel  by
machining the surface.
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Malleability
Mandrel
Meltdown
Mill Edge
Mill Finish
Mill Length
Mill Scale
Mold
Molten Metal
Period

Molybdenum
Molybdenum
Nickel


'„

                    The property that determines the ease of deforming a metal when the metal
                    is subjected to rolling or hammering.  The more malleable metals can be
                    hammered or rolled into thin sheet more easily than others.

                    A  metal  bar  around  which other metal may be cast, bent, formed, or
                    shaped.

                    The melting of the scrap and other solid metallic elements of the charge.

                    Normal rounded edge produced in hot rolling.  Does not conform to any
                    standard radius. This replaces the old term, band edge.

                    A surface finish produced on sheet and plate, characteristic of the ground
                    finish on the rolls used in fabrication.

                    Those lengths which can be most economically handled  by  the  mill
                    Upper and lower limits are set by equipment limitations in the mill

                    The iron oxide scale which breaks off of heated steel as it passes through
                    a rolling  mill. The outside of the piece of steel is generally completely
                    coated with scale as a result of being heated in an oxidizing atmosphere.

                    A form or cavity into which molten metal is poured to produce a desired
                    shape.  See ingot molds.

                    The period of .time during the electric arc furnace steelmaking cycle
                    when fluxes are added to furnace molten bath for the purpose of slag
                    formation.

                    A special alloying element commonly used to increase hardenability of
                    steel. Molybdenum  is sometimes added  to stainless steels to enhance
                    corrosion resistance to certain chemicals.

Molybdenum Oxide A commercial compound of molybdenum (MoO3) which is used as a
                    finishing  agent in making molybdenum steels.

                    A metallic element used in some alloy steels.
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Nonrecovery        Production of coke from coal with no recovery of coal by-products and
 Cokemaking       by-product chemicals that are recovered with by-product cokemaking (e.g.,
                    coal tars,  crude  light oil,  ammonia  and/or  ammonia  compounds,
                    naphthalene, sodium phenolate). In the nonrecovery cokemaking process,
                    coking occurs in horizontal, refractory-lined ovens. Volatile components
                    of the coal are consumed in the process,

Non-Standard Steel A steel is classified as non-standard when the chemical composition or
                    mechanical properties  specified do not coincide with or encompass the
                    ranges of limits of a standard steel (AISI or ASTM), or when restricted
                    ranges or limits are outside the ranges or limits of a standard steel
Normalize



Off Size

Oiled
Open Hearth
 Furnace
Open Plate
 Panel Hood
Ore

Ore Boil

Ovals

Overfill
The normalizing process which is commonly applied to steel articles of
heavy section consists of:  heating to a temperature about 100°F above die
critical range and cooling in still air.

Rolled steel, too light or too heavy to meet requirements.

Application of a suitable oil to final product to resist corrosion.  Where
surface quality is a consideration, it is also desirable in reducing friction
scratches that may develop in transit The oil coating is not intended to
serve as a lubricant for subsequent fabrication.

A furnace for melting metal, in which the bath is heated by the
convection of hot gases over  the surface of the metal and by radiation
from the roof.

A 4.5 meter to 6 meter square, rectangular, or circular cross
sectional shaped conduit, open at  both ends, which is used in the EOF
steelmaking  process  for the combustion and conveyance of hot  gases,
fumes, etc., generated in the BOF, to the waste gas collection system.

A mineral from which the metal can be extracted.

The generation of carbon monoxide by the oxidation of carbon.

A hot rolled carbon steel bar product which is oval in cross section.

A defect in a rolled bar or other section which is an overfullness on some
part of the surface.  Among the causes are worn rolls and extrusion into
the clearance of the rolls.
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Oxide
Oxidize
Oxidizing Agent
Oxidizing Slags
Pass
Passivation
Patenting
Pe!letizing


Phenols (4AAB>



Pickle

Pig
Oxides of iron, chiefly:  FeO, Fe,O4, Fe-p,.  Many mixtures of these
oxides exist which form on the surface of steel at different temperatures
and give the steel different colors, such as yellow, brown, purple, blue, and
red.  Oxides must be thoroughly removed from steels to be coated with tin,
zinc, or other metals.

A chemical treatment which increases the positive valences of a substance.
In a  limited sense, adding oxygen to a substance, as in oxidizing C to CO,
CO to COj,  Si to SiO2, Mn to MnO.

A substance added to a mixture for  the  purpose of oxidizing some
constituents.  For example, iron ore (Fe4O3) was used in an open hearth
furnace  to  furnish oxygen for the removal of Si, Mn, P,  and C, by
converting them to SiO2,  MnO, P2O5 and CO.

Fluxing agents that are used to remove  certain oxides such as silicon
dioxide, manganese oxide, phosphorus pentoxide, and iron oxide from die
hot metal.

(1) Movement of a piece of steel through a stand of rolls.  (2) The open
space between grooved rolls through which the steel is processed.

Chemical treatment of hot dip galvanized sheet with hexavalent chromium
compounds to prevent humid- or wet-storage staining.

In wire making, a heat treatment applied to medium carbon or high-carbon
steel before the drawing of wire or between drafts.  This process consists
of heating die product in air or in a bath of molten  lead or salt maintained
at a  temperature appropriate to the carbon content  of the steel and to the
properties required of the finished product

The processing of dust from the steel furnaces into a pellet of uniform size
and weight for recycle.

The  value  obtained  by  the method specified in 40  CFR Part 136.3.
Phenols (4AAP) is a non-specific measure of phenolic compounds present
in steel industry wastewaters that respond to the analytical test conditions.

Chemical or electrochemical removal of surface oxides.

An ingot of virgin or secondary metal to be remelted for use.
                                         8-17

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Pig Iron


Piling
Pinch Pass

Pinch Rolls


Pitch

Plain Carbon
 Scrap


Plate
Pouring


Preheating
Press Forging
Primary Scale
Impure iron cast into the form of small blocks that weigh about 30 kg.
each. The blocks are called pigs.

A form of rolled structural shape  of two types:  sheet piling and bearing
piling. The three forms of sheet pile - straight, arch type, and zee - are
used for  construction of docks, breakwaters, coffer dams, etc.  Bearing
piles, which range from 14 in. to 8 in. in depth, are heavy, wide flange
sections used for foundation and similar applications.

A pass of sheet through rolls that  are set to give a very light reduction.

Rolls used to regulate the  speed  of discharge of cast product from the
molds of continuous casting machines.

Distillate from tar.

Scrap steel with less than:  1.65% manganese, 0.60%
silicon, 0.60% copper, or any other alloying element added for a special
alloying effect

Carbon steel  plates comprise that group  of  flat rolled  finished steel
products  within the following size limitation:

0.180 in. or thicker, over 48 in. wide;
0.230 in. or thicker, over 6 in. wide;
7.53 Ib/sq ft or heavier, over 48 in. wide;
9.62 Ib/sq ft or heavier, over 6 in. wide

The transfer of molten metal from  the ladle into ingot molds or other types
of molds; for example, in castings.

(1) A  general term used to describe heating applied as a preliminary to
some  further  thermal or mechanical  treatment.   (2) A term applied
specifically  to steel to describe a process in  which the  steel is heated
slowly and uniformly to a  temperature below the hardening temperature
and is then  transferred  to a furnace  in which  the  temperature  is
substantially above the preheating temperature.

The forging process in which metal stock is formed between dies, usually
by hydraulic pressure.  Press forging is an operation that employs a single,
slow stroke.  Compare with hammer forging.
Oxide of iron
                                         which is formed while the steel is being heated.
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Primes
Metal products such as sheet and plate, of the highest quality and free
from visible surface defects.
Process Annealing  In the sheet and wire industries, a process by which ferrous alloy is heated
                    to a temperature* close to, but below, the lower limit of the transformation
                    range and  is subsequently cooled.  This process is applied in order to
                    soften the alloy for further cold working.
Quality
Refers to the suitability of the steel for the purpose or purposes for which
it is intended.
Quench Hardening A process of hardening a ferrous alloy of suitable composition by heating
                    within or above the transformation range and cooling at a rate sufficient
                    to increase the hardness substantially.  The process usually involves the
                    formation of martensite.
Quench Tower




Quenching



Quenching Crack




Recuperator
Reducing Slag



Refining
A station at which the incandescent coke in the cokecar is sprayed with
water to prevent further combustion.  Quenching of coke requires about
500 gallons of water per ton of coke.


A process of rapid cooling from an elevated temperature by contact with
liquids, gases, or solids.

A fracture resulting from thermal stresses induced during rapid cooling or
quenching  of steels.  Frequently encountered in  alloys that  have been
overheated and liquidated and are thus "hot short."


A piece of equipment for recovering heat from hot, spent gases and using
it for the  preheating.of incoming fuel or air,- Incomingjnatraials pass-
through pipes surrounded by a chamber through which the outgoing gases
pass.

Used in the EAF following the slagging off of an oxidizing  slag to
minimize the loss of alloys by oxidation.


Oxidation cycle for transforming hot metal (iron) and other metallics into
steel  by  removing  elements present,  such as  silicon,  phosphorus,
manganese, and carbon.
                                          8-19

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Refractory
Rod Mill
Roll Forming
Roll Scale
Roll Table


Roughing Stand
Round Cornered
 Squares

Runner
Runout

Runout Table
Ideally, any substance which is infusible at the highest temperature it may
be required to withstand in service.  A perfect refractory, which does not
exist at present, would be one which:  (1) would not fuse or soften, (2)
would not crumble or crack, (3) its contraction and expansion would be the
minimum, (4) would not conduct heat, (5) would be impermeable to high
temperature gases and liquids, (6) would resist mechanical abrasion, and
(7) would not react chemically with substances in contact with it

(1) A mill for fine grinding,  somewhat  similar to the ball  mill, but
employing long steel rods instead of balls as the grinding medium. (2) A
mill for rolling metal rod.

(1) An operation used in forming sheet  Strips of sheet are passed between
rolls of definite settings that bend the sheet progressively into  structural
members of various contours, sometimes called "molded sections." (2) A
process of coiling sheet into open cylinders.

Oxide of iron which forms on the surface of steel while it is being heated
and rolled. Much of the  scale is cracked and loosened during the rolling
operation and may fall off the piece naturally or be blown off by high-
pressure water sprays or by other means.

A conveyor-type table surface that contains a series of small rolls over
which metal products pass during processing.

The  rolls  used for  breaking down the  ingot, billet,  or slab in the
preliminary rolling of metal products.

A bar product square  in cross sections with rounded corners with size
ranges 3/8 in. to 8 in., inclusive.

A channel through  which molten  metal or  slag is passed from one
receptacle to  another; in a casting mold, the portion of the gate assembly
that connects the downgate or sprue with the casting.

Escape of molten metal from a furnace, mold, or melting crucible.

Area of a hot strip mill located after the finishing  stands and before the
coilers where laminar-flow cooling  is applied to the strip; generally, for
any hot forming mill, the area of the mill downstream of the last stand of
work rolls; for continuous casters, the area downstream of the  torch cut-
off.
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Scale

Scarfing


Scrap
Secondary Scale

Self-Hardening
Steel


Semi-Finished Steel

Semi-Killed Steel

Shake-Out

Shear


_ . . .

Shot Blasting

Silico-Mangaan»-


Sinter


•





An oxide of iron which forms on the surface of hot steel. Sometimes
forms in large sheets which fail off when the steel is rolled.
Catting surface areas of metal objects, ordinarily by using a gas torch.
The operation permits surface defects to be cut from ingots, billets, slabs,
or the edges of plate that are to be beveled for butt welding.
Iron or steel discard, or cuttings, or junk metal, which can be reprocessed.
Oxide of iron which is formed on hot steel while it is being rolled or
forged.
A steel containing sufficient carbon or alloying element or both.
to form martensite either through air hardening or, as in welding and
induction hardening, through rapid removal of heat from a locally heated
portion by conduction into the surrounding cold metal
Steel in the form of ingots, blooms, billets, or slabs for forging or rolling
into a finished product
Steel incompletely deoxidized, to permit evolution of sufficient carbon
monoxide to offset solidification shrinkage.
The operation of removing castings from their molds.

In a steel mill, a machine for cutting steel products. Steel shears may be
classified: as to kind of drive - hydraulic and electric; as to the work done
- cropping, squaring, slab, bloom, billet, bar shears; as to type of
mechanisms-rotary, rocking,- gate,, guillotine, alligator shears;, as, to
movement of work while shearing - flying shears.
Abrasive grit blasting of steel to remove scale; used in place of or in
combination with acid pickling.
An alloy containing silicon and manganese. lit the open hearth process, it
was used as a deoxidizer in the furnace and for the introduction of
manganese and silicon into steel.
In blast furnace usage, lumpy material which has been prepared from flue
dust, other iron-bearing materials, lime, and coke breeze. The dust is
agglomerated by heating it to a high temperature. Sinter contains valuable
amounts of combined iron.

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Skelp



Skin


Slab
Slab Shear


Slabbing Mill

Slag
Slag Top

Soak
Soaking Pit
Spark Box

Spiegeleisen
 (Also Spiegel)
A plate of steel or wrought iron from which pipe or tubing is made by
rolling the skelp into shape  longitudinally and welding or riveting the
edges together.

A thin surface layer that is different from the main mass of a metal object,
in composition, structure, or other characteristics.

A semifinished block of steel cut from a rolled ingot or manufactured on
a continuous slab caster, with its  width at least twice its thickness.  It
differs from a bloom which is square or nearly so. Currently, most slabs
are produced with continuous casters as opposed to slabbing on blooming
mills. Slabs are the product of a slabbing mill or a blooming milL

A shear for cutting a cast slab to desired lengths.  This shear also cuts off
the discard or crop.

A mill which rolls ingots into slab shapes.

Vitrified mineral waste removed in the reduction of metals from their ores.
The principal components of blast furnace slag are oxides of silica and
alumina originating chiefly with the iron-bearing  materials and lime and
magnesia originating with the flux.  The major components of steelmaking
slags are calcium silicates, lime-iron compounds and lesser amounts of free
lime and magnesia. Usually, slags consist of combinations of acid oxides
with basic oxides, and neutral oxides are added to aid fusibility.

A variation of the hot top.

To hold an ingot, slab, bloom, billet, or other  piece of steel in a hot
chamber or pit to secure uniform temperature throughout Freshly stripped
ingots are hottest in the interior, whereas a cold object which is being
heated is hottest at the surface.   The term is used in connection with
heating of steel whether for  forging or rolling or for heat treatment

A furnace  or pit for  the  heating of ingots of steel to make  their
temperature uniform throughout

A solids and water collection zone in a EOF hood.

A pig iron containing IS to  30% manganese and 4.5 to
6.5% carbon.
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Sponge Iron



Stainless Steel
Steel
Steel Ladle



Stools

Stoves



Strand
Stretcher
 Flattening^
Strip, Hot Rolled
 Carbon Steel
Support Rolls
The material produced by the reduction of iron oxide with carbon, without
melting.

(1) A tradename given to alloy steel that is corrosion and heat resistant
The chief alloying elements ate chromium, nickel, and silicon in various
combinations with a possible small percentage of titanium, vanadium, etc.
(2) by AISI definition, a steel is called "stainless" when it contains 10%
or more chromium.

Refined iron.  Typical blast furnace iron has the following composition:
Carbon, 3 to 4.5%, Silicon, 1 to 3%; Sulfur, 0.04 to 0.2%; Phosphorus, 0.1
to 1.0%; Manganese, 0.2 to 2.0%.  The refining process (steelmaking)
reduces the concentration of these elements in the metal A common steel,
1020, has the following composition: Carbon, 0.18 to 0.23%; Manganese,
0.3 to 0.6%; Phosphorus, less than 0.04%; Sulfur, less than 0.05%.

A vessel for receiving  and handling liquid steeL  It is made with a steel
shell and lined with refractories.

Flat cast iron plates upon which the ingot molds are seated.

Large refractory filled vessels in which the air to be blown into the bottom
of a blast furnace is preheated.

A term  applied  to  each continuous  casting  mold and its  associated
mechanical equipment

A process for removing bow and warpage from sheet by applying a
uniform-tension at the ends- so^that the- piece-is-elongated-to-a-definite
amount of permanent set

Bat, hot rolled carbon steel produced in coils or in cut lengths is
classified as hot rolled carbon steel strip when the product is within the
following size limitations:
                    Width

                    up to 3-1/2 in. incL
                    over 3-1/2 to 6 in. incL
                    over 6 to 12 in. incL
                                  Thickness

                                  0.0255 to 0.2030 in. incL
                                  0.0344 to 0.2030 in. incL
                                  0.0568 to 0.2299 in. incL
Rolls used in the continuous casting machine casting strand for keeping
cast products aligned.
                                          8-23

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Tandem Milt

Tap Hole



Tap to Tap Time


Tapping
Tar
Teeming


Temper
Temper Rolling
. A mill with a number of stands in succession.

 A hole approximately fifteen (15) centimeters in diameter located in the
 hearth brickwork of the furnace that permits flow of the molten steel to the
 ladle.

 Period of time after a heat is poured and the other necessary cycles are
 performed to produce another heat for pouring.

 Process of opening a taphole in a blast furnace to remove hot metal and
 slag; process of pouring molten steel from a steelmaking furnace into a
 receiving ladle for transfer to a  ladle metallurgy station  or  continuous
 caster, or into a teeming ladle for pouring into ingot molds.

 The organic matter separated by condensation from coke oven gas in the
 collector mains.  It is a black, viscous liquid, a little heavier than water.
 From it the following general classes of compounds may be recovered:
 pyrites, tar acids, naphthalene, creosote oil, and pitch.

 Pouring or casting of molten steel from a ladle into cast iron ingot molds
 of various dimensions for cooling and solidification of the steeL

 A condition produced  in a metal or alloy  by mechanical or thermal
 treatment, and having characteristic structure and mechanical properties.
 A given alloy may be in the fully softened or annealed  temper, or it may
 be  cold  worked  to the hard  temper,  or  further to spring temper.
 Intermediate tempers produced by cold working (rolling or drawing) are
 called "quarter-hard", "half-hard" and,  "three-quarters hard",  and are
 determined by the amount  of cold  reduction- and  the resulting tensile
 properties.  In addition to the annealed temper, conditions produced by
 thermal treatment are the solution heat treated temper and the heat treated
 and artificially aged temper.  Other  tempers involve  a combination of
 mechanical and thermal treatments and include that temper produced by
 cold  working  after heat treating, and that produced by  artificial aging of
 alloys that are as-cast, as-extruded, as-forged and heat treated, and worked.

 Relatively light  cold rolling process (1  to 4%  thickness reduction)
 performed to improve flatness, alter the mechanical properties of the steel,
 and to minimize  surface disturbances. Temper mills are usually single-
 stand mills.
                                          8-24

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Tempering


Tensile Strength



Ternepiate
Three-High Mill


Tinplate


Titanium



Train of Stands



Tramp Oils

Tundish




Tungsten
Tuyeres






A process of reheating quench-hardened or normalized steel to a
temperature below the, transformation range, and then cooling at any rate
desired.
The value obtained by dividing the maximum load observed during tensile
straining until breakage occurs by the specimen cross-sectional area before
straining. Also called "ultimate strength".

Steel sheet, hot dip coated with teme metal (10-15% tin; 85-90% lead).
A stand which has three rolls, one above the other. The steel which is
being rolled passes one way between the bottom and middle rolls, and the
other way between die middle and top rolls.
A mild steel of low carbon content bearing a coating of commercially pure
tin. Two manufacturing processes are currently used, hot dipped and
electrolytic tinning lines.
A metal which is commonly added to chrome-nickel stainless steel to
improve its welding properties. So used, it is called a "stabilizer" or is
said to prevent "carbide precipitation." The amount of titanium commonly
used for this purpose is 5 to 7 times the carbon content
In rolling mill construction, those stands of rolls which are placed side by
side (i.e., so that the rolls of the different stands come end to end so that
one engine or motor can drive them). Contrast this with strands in
tandem.
Waste oils and greases from lubricating and other oilr or grease-containing^
systems.
A refractory-lined vessel located between the ladle and the continuous
caster. Molten steel is tapped from the ladle to the tundish for the purpose

of providing a stable flow of metal into the caster by providing a constant
ferrostatic head.
A metal which is sometimes added to steel to make tool steeL
Water cooled openings located around the circumference of a blast furnace
at the top of the hearth through which the hot blast enters die furnace.

*
8-25


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Two-High Milt
Universal
 Plate Mill

Upsetting
A stand having only two rolls.  Some two-high mills ate reversing with
screw-downs to adjust the rolls; others are one way only and may or may
not have screw-downs for roll adjustment and may or may not be a part
of a continuous mill.

A mill for rolling steel plates which has vertical as well as horizontal
rolls so that its product has rolled edges.

(1) A metal working operation similar to forging. (2) Hie process of axial
flow under axial compression of metal, as in forming heads on rivets by
flattening the end of wire.
Vacuum Degassing  A process for removing dissolved gases from liquid steel by subjecting it
                    to a vacuum.
Venturi Scrubber
Wash Oil
Water Tube Hood
Wet Scrubbers


Windbox


Wire Rod


Work Rolls
A wet type collector that uses the throat for intermixing of die dust and
water particles. The intermixing is accomplished by rapid contraction and
expansion of the air stream and a high degree of turbulence.

A petroleum solvent used as an extractant for by-product recovery in the
coke plant

Consists of steel tubes, four (4) centimeters to five (5) centimeters, laid
parallel to  each  other  and  joined  together  by means  of  steel ribs
continuously welded.  This type of hood is used in the  basic oxygen
steeimaking process for die combustion and conveyance of hot gases to the
waste gas collection system.

Venturi or orifice plate units used to bring water into intimate contact with
dirty gas for the purpose of its removal from the gas stream.

Device for drawing air through the  sinter strand to enhance combustion
and fusing of the iron-containing materials into a sintered product

A semi-finished product from which wire is made.   It is generally of
circular cross section approximately 1/4 in. in diameter.

Nongrooved rolls which come into contact with the piece  of steel  (slab,
plates, strip, or sheet) being rolled.  In four-high mills, the rolls which
stiffen or strengthen the work rolls are called back-up rolls.  The  drive
spindles are connected with the work rolls.
                                          8-26

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                              HOT COATING / GALVANIZING
                            TREATMENT  MODELS  SUMMARY
BPT/BCT/PSES-I/
NSPS-I/PSNS-I
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                                   EQUALIZATION
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                                                                        Selidi
BAT-l/PSES-2

CHROMATE
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FUME
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REDUCTION

FUME
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ALL OTHER
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REDUCTION

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       HOT COATING RINSE WATER FLOW RATES (GPT)
PRODUCT
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 (2)Fum« tcrubbar flow at all other model§: 15 gpm/icrubber
                                          A-24

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HOT COATING/TERNE 8 OTHER METALS
TREATMENT MODELS SUMMARY
[POLYMER]
T| L i ME]
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TANK

L^CLARIFIER^J
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- A-25
1

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                                      Appendix B
™           MILL PERFORMANCE DATA VERSUS EFFLUENT LIMITATIONS GUIDELINES
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                                      Appendix C
I                     IRON AND STEEL MANUFACTURING FACILITIES
                          INCLUDED ON STATE 304(L) SHORT LISTS
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