vvEPA
United States
Environmental Protection
Agency
Office of Water and
Waste Management
Washington, D.C. 20460
February 1981
Proposed Effluent
Guidelines
Rulemaking for the
Iron and Steel
Manufacturing
Point Source Category
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Background
The Clean Water Act
Under the Clean Water Act (the Federal
Water Pollution Control Act Amend-
ments of 1972, as amended by the Clean
Water Act of 1977), the Environmental
Protection Agency (EPA) is charged with
the responsibility to restore and main-
tain the chemical, physical, and
biological integrity of the Nation's
waters.
Direct Dischargers
The act requires that all industries
discharging wastes into navigable
waters achieve by July 1, 1977, the "best
practicable control technology currently
available" (BPT). This control technology
represents the average of the best exist-
ing waste treatment performance within
each industry category or subcategory.
By July 1, 1984, the Act requires the
achievement of effluent limitations
based on the very best control and treat-
ment measures that have been devel-
oped or that are capable of being
developed within the industry category
or subcategory. These effluent limita-
tions require the following controls:
• Toxic and Nonconventional
Pollutants—Application of the
"best available technology
economically achievable" (BAT)
• Conventional Pollutants—Applica-
tion of the "best conventional pollu-
tant control technology" (BCT)
New source performance standards
(NSPS) are also established for new in-
dustrial direct dischargers. NSPS, which
goes into effect at the commencement
of operation, is described as the "best
available demonstrated control
technology, processes, operating
methods, or other alternatives including,
where practicable, a standard permitting
no discharge of pollutants."
Indirect Dischargers
Indirect dischargers are industrial
facilities that discharge pollutants to
publicly owned treatment works (POTW).
The Clean Water Act directs EPA to
establish national pretreatment stand-
ards for pollutants that are incompatible
with or pass through municipal treat-
ment plants. The Act requires:
• Achievement, within 3 years of pro-
mulgation, of pretreatment stand-
ards for existing sources (PSES)
• Achievement, upon commencement
of operation, of pretreatment stand-
ards for new source$ (PSNS)
Purpose of Proposed
Regulation
The primary purpose of this proposed
regulation is to provide effluent limita-
tions guidelines for BPT, BAT, and BCT
and to establish NSPS, PSES, and
PSNS under Sections 301, 304, 306, 307,
and 501 of the Clean Water Act.
While the requirements for direct
dischargers are to be incorporated into
National Pollutant Discharge Elimination
System (NPDES) permits issued under
Section 402 of the Act by EPA and par-
ticipating States, pretreatment stand-
ards are enforceable directly by the
Agency against indirect dischargers.
The proposed regulation does not re-
quire the installation of any particular
treatment technology. Rather, it requires
the achievement of effluent limitations
representative of the proper operation of
treatment model technologies or
equivalent tecnologies.
Industry
Coverage
The Iron and Steel Manufacturing
Industry is included within the U.S.
Department of Commerce, Bureau of the
Census Standard Industrial Classifica-
tion (SIC) 3300. This proposed regulation
applies to subgroups SIC 3312 (except
forgings and cold coatings), 3315, 3316,
and 3317, which include all processes,
subprocesses, and alternative processes
involved in manufacturing intermediate
or finished products.
The Iron and Steel Manufacturing
Industry uses a variety of processes that
require large quantities of raw
materials. The industry can be divided
into raw steelmaking and forming and
finishing. Steel facilities range from
plants using few processes to extremely
large industrial complexes that may use
all production processes.
• In 1978, revenues of the U.S. Steel
industry were $46 billion; it ranks
third in the Nation in value of total
shipments and accounts for about
15 percent of world production
• In 1978, approximately 87 percent of
the total U.S. steel ingot output was
produced by 15 corporations
• This industry is one of the highest
water users of all manufacturing
industries—water is essential in
almost all process operations, with
an average 40,000 gallons required
to produce 1 ton of finished steel
Pollutants
Pollutants discharged by the industry
include:
• Toxic Pollutants—Total and hex-
avalent chromium, cyanide,
phenols, copper, lead, tin, nickel,
zinc, cadmium, and approximately
40 toxic organics
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• Conventional Pollutants—TSS, pH,
and oil and grease
• Nonconventional Pollutants—
- Fluoride, ammonia-N, and iron
ERA'S
Development
Program
-To implement the Clean Water Act, EPA
conducted a complex development pro-
gram. This program included:
• Development of analytical methods
for detecting and measuring toxic
pollutants
• Sampling of intake water and raw
and treated wastewater at a
representative number of plants
• Use of the best state-of-the-art
methods for detection of toxics, i.e.,
atomic adsorption spectro-
metry (AAS), inductively coupled
argon plasma (ICAP) spectrometry,
and gas chromatography/mass
spectrometry (GC/MS)
Technical Data Gathering
The technical analysis was based on:
• Data Collection Portfolios (DCPs)
requesting information on pro-
cesses and production as they
relate to water usage and
wastewater generation. DCPs were
sent to all U.S. steelmaking and 85
percent of U.S. steel forming and
finishing operations, of which 393
steelmaking and 1,631 steel forming
and finishing operations responded
• Detailed DCPs (D-DCPs) requesting
detailed cost information and long-
term test data results were sent to
50 steelmaking and 128 forming and
finishing facilities
• A two-part sampling and analysis
program involving 31 steelmaking
and 83 forming and finishing
facilities
• Data from previous studies, NPDES
permit files, Discharge Monitoring
Reports, contacts with suppliers of
pollutant control equipment,
treatability studies, and literature
searches
Methodology
After developing analytical methods for
detecting and measuring toxic pollu-
tants, EPA studied the Iron and
Steel Manufacturing Industry to deter-
mine whether separate standards were
needed for different segments of the
industry.
Next, EPA identified the wastewater
constituents to be considered for
effluent limitations guidelines and
standards of performance and identified
in-plant and end-of-process treatment
technologies that were being used, or
that could be used, by the industry. EPA
analyzed data on the performance of
each technology and its associated non-
water-quality environmental impacts.
The cost of each control and treat-
ment technology was estimated for
model facilities for each subcategory or
subdivision. Baseline projections of
costs were computed for up to five alter-
native treatment models in each sub-
category or subdivision. Costs were also
calculated for the steel industry as a
whole for installing technologies
capable of achieving various levels of
regulation. The economic impacts of
these costs were then evaluated.
EPA then identified the various treat-
ment technology options for BPT, BCT,
BAT, NSPS, PSES, and PSNS. Finally,
EPA selected the preferred option by in-
dustry subcategory or subdivision for
each set of standards.
Subcategories
EPA found that the manufacturing pro-
cesses of the Iron and Steel Manufactur-
ing Industry provide the most significant
basis for determining subcategories.
Consequently, EPA has divided the
industry into the following 12 main pro-
cess subcategories:
• Cokemaking
• Sintering
• Ironmaking
• Steelmaking
• Vacuum Degassing
• Continuous Casting
• Hot Forming
• Scale Removal
• Acid Pickling
• Cold Forming
• Alkaline Cleaning
• Hot Coating
The Agency further segmented the
subcategories into 50 subdivisions
based on product type, composition,
shape, water use rates, control
technologies, and process variations.
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Summary of Control
Technologies Considered
The following pollution control tech-
niques and technologies were con-
sidered by EPA in developing standards
for the Iron and Steel Manufacturing In-
dustry:
• In-plant control
—Cascade rinse systems in pickling
and hot coating operations to
reduce rinse flow discharges by
up to 95 percent
—Process modifications and reduc-
tion of wastewater generation by
recycle and reuse
• End-of-pipe treatment
• Add-on technology to BPT for BAT,
BCT, NSPS, PSES, and PSNS treat-
ment levels
—Extended biological treatment
(cokemaking)
—Granular activated carbon
—Powdered carbon addition
—Pressure filtration with and
without sulfide addition
—Multistage evaporation/condensa-
tion systems
reports in the Development Document
for Effluent Limitations Guidelines and
Standards for the Iron and Steel
Manufacturing Point Source Category
(EPA 440/1-80/024b, December 1980). The
pertinent sections are as follows:
• BPT—Section IX
• BAT—Section X
• BCT—Section XI
• NSPS—Section XII
• PSES, PSNS—Section XIII
Regulated Pollutants
Proposed BPT
• Same as those for prior BPT with
some deletions in various sub-
categories
Proposed BCT
• TSS, pH, and oil and grease
Proposed BAT, NSPS, PSES, and PSNS
• Phenols (4AAP), cyanide, cadmium,
chromium, copper, lead, nickel, zinc,
ammonia-N, fluoride, benzene,
naphthalene, benzo(a)pyrene,
1,1,1-trichloroethane,
2-nitrophenol, anthracene, and
tetrachloroethylene
Non-Water-Quality
Aspects of Pollution
Control
Air Pollution
• Aeration of cokemaking
wastewaters may release minimal
amounts of volatile organic com-
pounds
• Small emissions may result as iron-
making wastewaters quench hot
slag
• Water vapor having some par-
ticulates will be released from cool-
ing tower systems
Solid Waste
• No significant change in solid
waste generation is anticipated
Consumptive Water Loss
• None of the requirements will cause
significant evaporative water loss
Energy Requirements
• A net increase of 2.07 billion
kilowatt hours will be incurred at
the BPT, BAT, and BCT levels of
treatment, 3.6 percent of the elec-
trical (0.6 percent of the total)
energy consumed by the industry
in 1978
The Proposed
Regulation
The regulation for BPT, BAT, BCT,
NSPS, PSES, and PSNS was developed
for specific subcategories. Detailed
discussions of the regulation, tech-
nologies, and rationales are contained in
sections of each of 12 subcategory
Effluent Reduction
Benefits
• Proposed BAT and BCT limitations
will result in removal per year (from
BPT effluents) of:
—1,900 tons of toxic organic
pollutants
—2,500 tons of toxic metals
—130,000 tons of other pollutants
Best Management
Practices
Although EPA is not proposing them at
this time, the Agency is considering
development of BMP specific to the Iron
and Steel Manufacturing Industry. These
will be applicable to all industrial sites
and will offer guidance to permit
authorities in establishing the BMP
required by unique circumstances at a
given plant.
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Economic Impact
Analysis
The economic analysis was based on:
• A policy-testing model that com-
bined a methodology for calculating
economic effects with the cost-
impact methodology used by the
American Iron and Steel Institute
(AISI)
• An assessment of the economic im-
pact of the proposed regulation
under three scenarios
The impacts of the three scenarios
are summarized in Tables 1 and 2.
—Scenario 1:
A continuation, from 1981 to 1990,
of the economic environment and
governmental policy faced over the
last 10 years with two sub-
scenarios: zero passthrough of an-
nual costs and full passthrough of
annual costs
—Scenario 2:
A 3-percent growth in steel
shipments; higher profitability; and
policy changes, including quicker
recovery of capital investments,
return to "fair value" import prices,
and latitude to increase prices
—Scenario 3:
Changed economic environment as
a result of governmental policies,
such as increased real economic
growth, reinstatement of trigger
prices, and a 40-percent increase in
depreciation cash flows
TABLE 1
SHORT-RUN ECONOMIC IMPACT OF PROPOSED
WATER POLLUTION CONTROL REGULATION—1984
Industry Status in 1979
Scenario 1: Baseline
Additional Water Pollution Control Costs
Zero Passthrough
Full Passthrough
Scenario 2: Baseline
Additional Water Pollution Control Costs
Scenario 3: Baseline
Additional Water Pollution Control Costs
Domestic Shipments
(millions of net tons)
100.3
101.3
101.3
101.3
106.7
106.7
106.6
106.6
Number of Employees
(thousands)
342.0
334.5
335.8
335.8
356.0
357.3
354.8
356.1
Market Share
(percent)
84.8
82.0
82.0
82.0
82.0
82.0
85.0*
85.0
* Reflects new surge provisions of recently reinstituted Trigger Price Mechanism.
TABLE 2
LONG-RUN ECONOMIC IMPACT OF PROPOSED
WATER POLLUTION CONTROL REGULATION—1990
Industry Status in 1979
Scenario 1: Baseline
Additional Water Pollution Control Costs
Zero Passthrough
Full Passthrough
Scenario 2: Baseline
Additional Water Pollution Control Costs
Scenario 3: Baseline
Additional Water Pollution Control Costs
Domestic Shipments
(millions of net tons)
100.3
92.4
86.1
89.1
126.0
126.0
117.8
115.3
Number of Employees
(thousands)
342.0
271.1
254.6
262.9
366.4
368.3
341.5
336.0
Market Share
(percent)
84.8
71.5
66.6
68.9
82.0
82.0
85,0"
83w2*
•Represents recovery from baseline market share of 77.8 percent in 1988 and from market share after additional water pollu-
tion control costs of 73.4 percent, also In 1988.
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Total additional investment costs
are estimated at $1.02 billion
—BPT: $418 million
—BAT: $444 million
—NSPS: $159 million
Incremental annual costs are
estimated at $264 million in 1984,
decreasing to $226 million in 1990
—BPT: $97 million decreasing to
$93 million
—BAT: $150 million decreasing to
$93 million
—NSPS: $17 million increasing to
$40 million
Industry's ability both to finance
baseline production and to satisfy
capital requirements for water pollu-
tion control from 1981 to 1990
depends heavily on governmental
policy changes
EPA believes that Scenario 3
represents the operating environ-
ment the Iron and Steel Manufactur-
ing Industry probably will face in
the i980's. In this event, these
regulations will have the following
impact:
—Temporary job loss of 14,540
below projected baseline for late
1980's, but rising to only 5,500
below baseline in 1990
—Decreased market share of 4.4 per-
centage points below baseline
for late 1980's, but rising to only
1.8 percent below baseline in
1990
Glossary
AAS Atomic adsorption
spectrophotometry
AISI American Iron and Steel
Institute
BAT "Best available technology
economically achievable," to
be achieved by July 1,1984
BCT "Best conventional pollutant
control technology," to be
achieved by July 1,1984
BMP Best management practices
BPT "Best practicable control
technology currently available,"
to be achieved by July 1,
1977
DCP Data Collection Portfolio
D-DCP Detailed Data Collection
Portfolio
EPA U.S. Environmental Protection
Agency
GC/MS Gas chromatography/mass
spectrometry
ICAP Inductively coupled argon
plasma
NPDES National Pollutant Discharge
Elimination System
NSPS New source performance
standards, to be achieved upon
commencement of operation of
a new plant
POTW Publicly owned treatment
works
PSES Pretreatment standards for
existing sources, to be achiev-
ed within 3 years of promulga-
tion of a regulation
PSNS Pretreatment standards for
new sources, to be achieved
upon commencement of opera-
tion of a new plant
SIC Standard Industrial Classifica-
tion (Department of Commerce,
Bureau of the Census)
TSS Total suspended solids
For further information, contact:
Technical information may be obtained
from:
Mr. Ernst P. Hall
Effluent Guidelines Division (WH-552)
U.S. Environmental Protection Agency
Washington, D.C. 20460
(202) 426-2726
Copies of technical documents may be
obtained from:
Distribution Officer
Effluent Guidelines Division (WH-552)
U.S. Environmental Protection Agency
Washington, D.C. 20460
(202) 426-2724
Copies of the economic impact analysis
may be obtained from:
Mr. Robert Greene
Industrial Analysis Branch (PM-220)
U.S. Environmental Protection Agency
Washington, D.C. 20460
(202) 287-0713
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