THE USE AND IMPACT OF
IRON AND STEEL INDUSTRY
INTRA-PLANT TRADES
Prepared for:
Richard Kashmanian
Office of Policy, Planning and Evaluation
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Prepared by:
Industrial Economics, Incorporated
2067 Massachusetts Avenue
Cambridge, MA 02140
March 1994
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ACKNOWLEDGEMENTS
This report was funded under EPA Contract 68-W1-0009. The work could not have been
completed without the gracious assistance of environmental officials associated with the steel plants
contacted, as well as state and EPA Regional permitting officials. A draft version of the report was
reviewed by Richard Kashmanian of EPA's Office of Policy, Planning and Evaluation. In addition,
the report benefitted from the review of Mahesh Podar and Eric Strassler of EPA's Office of Water,
as well as Bruce Steiner, Vice President, Energy and Environment, American Iron and Steel
Institute.
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TABLE OF CONTENTS
EXECUTIVE SUMMARY ES-1
INTRODUCTION CHAPTER 1
BACKGROUND AND PURPOSE 1-1
SUMMARY OF FINDINGS 1-2
ORGANIZATION OF THE REPORT 1-4
IDENTIFICATION OF IRON AND STEEL PLANTS
MAKING USE OF INTRA-PLANT TRADING CHAPTER 2
INTRODUCTION 2-1
OVERVIEW OF THE REGULATION 2-1
PLANTS SUBJECT TO EPA
IRON AND STEEL EFFLUENT GUIDELINES 2-3
IDENTITY OF PERMITS
INCORPORATING INTRA-PLANT TRADING 2-5
FINDINGS CHAPTER 3
INTRODUCTION 3-1
PLANT PROCESSES AND POLLUTANTS
SUBJECT TO INTRA-PLANT TRADES 3-2
IMPACT OF INTRA-PLANT TRADES
ON POLLUTANT LOADS AND WATER QUALITY 3-2
Pollutant Loads 3-2
Water Quality 3-5
IMPACT OF INTRA-PLANT TRADES ON POLLUTION CONTROL COSTS ... 3-5
INTRA-PLANT TRADING AND INNOVATIVE TREATMENT 3-6
RESOURCE OR ADMINISTRATIVE IMPACTS ON
PERMIT AUTHORITIES AND DISCHARGERS 3-7
ATTITUDES TOWARD INTRA-PLANT TRADING 3-8
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TABLE OF CONTENTS
(continued)
PLANTS NOT MAKING USE OF INTRA-PLANT TRADING 3-8
National Steel Corporation 3-9
Armco Steel Company, Ashland, KY 3-9
Bethlehem Steel Corporation 3-9
LTV Steel Company, Cleveland, OH 3-10
Wheeling Pittsburgh Steel Corporation 3-10
Geneva Steel, Provo, UT 3-10
USE OF INTRA-PLANT TRADING IN OTHER INDUSTRIES CHAPTER 4
REFERENCES
APPENDICES
Appendix A: ACTIVE IRON AND STEEL INDUSTRY PERMITS IDENTIFIED USING THE
EPA'S PERMIT COMPLIANCE SYSTEM
Appendix B: IRON AND STEEL INDUSTRY PERMITS WITH TEN OR MORE OUTFALLS
IDENTIFIED USING THE EPA'S PERMIT COMPLIANCE SYSTEM
Appendix C: FEDERAL REGISTER NOTICES AW) OTHER DOCUMENTS RELATING TO
INTRA-PLANT TRADING IN THE IRON AND STEEL INDUSTRY
Appendix D: GLOSSARY OF IRON AND STEEL INDUSTRY TERMINOLOGY
Appendix E: PLANT BY PLANT SUMMARIES OF THE USE AND IMPACT OF INTRA-
PLANT TRADING
Appendix F: CALCULATION OF REDUCED TREATMENT COSTS DUE TO INTRA-
PLANT TRADING
Appendix G: CALCULATION OF PERMIT LIMITS IN INTRA-PLANT TRADING
Appendix H: FEDERAL REGISTER NOTICE ANNOUNCING EPA'S EFFLUENT
GUIDELINES PLAN
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EXECUTIVE SUMMARY
As part of its examination of innovative approaches to water pollution control, the U.S.
Environmental Protection Agency (EPA) is investigating the use and impact of iron and steel
industry intra-plant trades, first authorized by the Agency in 1982. Within certain regulatory
constraints, these trades offer direct dischargers in the iron and steel industry the option of crediting
pollutant reduction beyond discharge limits at one or more outfalls to discharges from other outfalls
at the same facility. It is expected that the insights and understanding gained from studying the
effect of this trading program will inform the design of future trading policies for reducing water
pollution.
The EPA's Permit Compliance System was used to identify steel plants subject to the
Agency's effluent guidelines and to obtain data on the production processes and pollutants
associated with those plants. To identify permits incorporating intra-plant trading, appropriate EPA
national and regional personnel, as well as some state personnel, were contacted. Detailed
information on each of the trades was gathered both from documentation related to permits and
from environmental managers associated with the different facilities.
The major findings of this study are as follows:
o The use of intra-plant trading is not common. Of 443 direct dischargers
currently identified by EPA as members of the iron and steel industry
category, six currently hold permits that incorporate intra-plant trading, and
another four facilities at one time held permits that incorporated trading. All
ten facilities that have traded are in EPA Regions 3 or 5.
o The information available on the ten trades to date suggests that trading is
likely to be feasible primarily at facilities with a large number of outfalls. In
general, the more outfalls a facility has, the greater the likelihood that
trading between two or more outfalls will be both feasible and economical.
o Water quality concerns — in particular, increasing reliance on water quality-
based rather than technology-based permit limits — limit the use of intra-
plant trading.
o Estimates of the reduction in pollution control costs enabled by trading are
available for seven of the ten facilities that have employed trades (five of the
permits incorporating these trades are still in effect). The present value of
these cost reductions is estimated at $122.7 million (1993 dollars).
o Over the next several years, the EPA's Office of Water is expected to
develop new or revised effluent guidelines for several industries. Office of
Water officials indicated that for some of these industries, intra-plant trading
may be feasible.
ES-1
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INTRODUCTION CHAPTER 1
BACKGROUND AND PURPOSE
The U.S. Environmental Protection Agency (EPA) is currently studying a variety of
innovative approaches for water pollution control. Among the policies under examination is
allowing industrial and municipal point sources to "trade" pollution discharge allowances, thereby
.taking advantage of economies of scale and other efficiencies in reducing pollutant loads. As
commonly used, the term "trading" may encompass a number of different approaches for developing
discharge limits. In general, however, these approaches hold in common the objective of allocating
further load reduction requirements among outfalls or groups of dischargers so that water quality
goals are achieved at the lowest total cost.
As part of its examination of innovative approaches to water pollution control, EPA is
investigating the use and impact of iron and steel industry intra-plant trades, first authorized by the
Agency in 1982.1 These trades offer direct dischargers in the iron and steel industry the option of
crediting pollutant reduction beyond discharge limits at one or more outfalls to discharges from
other outfalls at the same facility, within limitations noted below. This policy is known among
regulators as the "steel water bubble" policy. It is expected that the insights and understanding
gained from studying the effect of this trading program will inform the design of future trading
policies for reducing water pollution.
During the course of this investigation, the following information was obtained:
o the location and number of steel plants subject to EPA's effluent guidelines;
o the identity of steel plants that have incorporated approved intra-plant trades
in their permits;
o details of the trades, including plant processes and pollutants associated with
the outfalls involved in the trades, and the details of the effluent limits calculations;
140 CFR 420, Iron and Steel Manufacturing Point Source Category, 47 FR 23284 (May 27,1982),
47 FR 41739 (September 22,1982), 48 FR 46943 (October 14,1983), 49 FR 21028-21036 (May 17,
1984), 49 FR 24726 (June 15,1984). 40 CFR 420.03 authorizes intra-plant trading, and was made
final in 49 FR 21028-21036 (May 17,1984). This FR notice is included as Appendix C
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information on the impact of trading on pollutant loadings and water quality;
an appraisal of treatment technology that would have been used at each
facility in the absence of trading, including capital and operation and
maintenance costs;
an assessment from plant officials, Regional personnel, and steel industry
experts regarding the effectiveness of intra-plant trading and its impact on
administrative resources; and
a preliminary assessment of the potential for use of trading in other
industries.
The EPA's Permit Compliance System (PCS) was used to identify steel plants subject to the
Agency's effluent guidelines and to obtain data on the production processes and pollutants
associated with those plants. To identify permits incorporating intra-plant trading, appropriate EPA
national and regional personnel, as well as some state personnel, were contacted. Detailed
information on each of the trades was gathered both from documentation related to permits and
from environmental managers associated with the different facilities. In addition, the American Iron
and Steel Institute, the Steel Manufacturers Association, a former EPA employee intimately familiar
with the regulation, and personnel at EPA's Office of Water were contacted.
SUMMARY OF FINDINGS
The major findings of this study are as follows:
o The use of intra-plant trading is not common. Of 443 direct dischargers
currently identified by EPA as members of the iron and steel industry
category, six currently hold permits that incorporate intra-plant trading: five
in EPA Region 5 and one in EPA Region 3 (see Figure 1 for the location of
the ten EPA Regions). Another four facilities — one in Region 5 and three
in Region 3 — at one time held permits that incorporated trading. For
reasons ranging from plant shutdown to changes in ownership and plant
configuration, these four trades are no longer in effect.
o Industry environmental officials and state and Regional permit authorities are
familiar with the regulations allowing intra-plant trading, and are open to its
use. A variety of factors, however, limit broader application of trading. For
example, 208 of the 443 facilities identified above have only one outfall, and
thus are unable to engage in intra-plant trading. Indeed, the information
available on the ten trades to date suggests that trading is likely to be feasible
primarily at facilities with a large number of outfalls; the fewest outfalls
reported for a facility that has engaged in a trade is seven, and the number
for those currently engaged in trades ranges from 10 to 38. In general, the
more outfalls a facility has, the greater the likelihood that trading between
two or more outfalls will be both feasible and economical.
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Figu.
EPA Regions
Puerto Rico
C3?
Virgin Islands
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Water quality concerns — in particular, increasing reliance on water quality-
based rather than technology-based permit limits — also limit the use of the
effluent guidelines9 intra-plant trading provision. In addition, retooling and
modernization of iron and steel facilities may further constrain trading's use,
since trading is restricted to existing sources and does not apply to new
sources.
Despite its relatively infrequent use, the intra-plant trading policy has been
applied to a wide range of steel plant processes, and has allowed substantial
reductions in pollution control costs. Four pollutants have been subject to
trades: total suspended solids (TSS), oil and grease (O&G), lead, and zinc.
Estimates of the reduction in pollution control expenditures enabled by
trading are available for seven of the ten facilities that have employed trades
(five of the permits incorporating these trades are still in effect). The
present value of these cost reductions is estimated at $122.7 million (1993
dollars).2 For the other three plants that have had trades, one of which is
still in effect, no information was obtained.
Over the next several years, the U.S. EPA's Office of Water is expected to
develop new or revised effluent guidelines for several industries. The Office
is not explicitly evaluating the viability and merits of intra-plant trading for
each industry being considered. However, Office of Water officials expressed
a willingness to conduct such an evaluation, and indicated that for some of
the source categories, intra-plant trading may be feasible.
ORGANIZATION OF THE REPORT
The remaining chapters of this report discuss the analysis of intra-plant trading in greater
detail. Chapter 2 provides a brief overview of the regulations governing intra-plant trading and
identifies facilities whose permits make or previously made use of intra-plant trading. Chapter 3
discusses the impact of intra-plant trades on pollutant loads and water quality, the effect of trading
on poUution control costs, and other impacts of ultra-plant trading on permit authorities and
dischargers. Chapter 4 identifies industries for which EPA will soon develop or revise effluent
guidelines regulations, and discusses the potential application of intra-plant trading to these
industries.
The report also includes several appendices that provide additional information on the intra-
plant trading regulation, the iron and steel industry, and the application of intra-plant trading within
this industry. Specifically, Appendices A and B contain information on facilities subject to the iron
and steel industry effluent guidelines; Appendix C contains background information on the
development of the intra-plant trading regulation; Appendix D contains a detailed glossary of iron
and steel industry terms; Appendix E contains detailed writeups of the use and impact of trading
at each of the ten facilities identified; Appendix F contains an explanation of the methodology used
to estimate the reduction in treatment costs enabled by trading; Appendix G walks the reader
through the steps necessary to calculate effluent limits in a permit incorporating trading; and
Appendix H contains a copy of the September 9,1992 Federal Register notice announcing the EPA's
Effluent Guidelines Plan.
2 See Exhibit 3-3 for plant by plant details of cost reductions.
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IDENTIFICATION OF IRON AND STEEL PLANTS
MAKING USE OF INTRA-PLANT TRADING CHAPTER 2
INTRODUCTION
Intra-plant trading is available only to those plants permitted subject to the Iron and Steel
Effluent Guidelines (40 CFR 420). Research first focused on identifying these plants, and, from
among them, those plants where trading is most likely to be feasible. Following this, the
investigation identified ten permits incorporating intra-plant trading.
OVERVIEW OF THE REGULATION
Under the authority of the Gean Water Act, the EPA develops effluent guidelines for
categories of pollutant dischargers. The EPA's effluent guidelines for the iron and steel industry
point source category were made final in the early 1980s.1 The regulation divides the industry into
twelve subcategories, A through L, as shown in Exhibit 2-1. For each of these subcategories, the
guidelines specify effluent limitations for the best practicable technology (BPT), best available
technology (BAT), and new source performance standards (NSPS). In addition, one section of the
regulation allows affected facilities to develop alternative effluent limitations for existing point
sources.2 Under this section, commonly referred to as the steel bubble policy, a facility that
achieves beyond-BAT control at some outfalls is not required to provide BAT-level control at other
outfalls, provided that the total discharge of any pollutant(s) involved in such exchanges is less than
would be discharged under normal BAT requirements.3 This flexibility is designed to allow facilities
to reduce their total pollution control costs, provided that they can simultaneously achieve better
overall pollution control.
1 40 CFR 420.
2 40 CFR 420.03.
3 The alternative effluent limitations for each pollutant are determined for a combination of
outfalls by totaling the mass limitations of each pollutant allowed under subparts A through L and
subtracting from each total an appropriate net reduction amount." [40 CFR 420.03]. The regulation
originally did not require a net reduction in loading limits, but rather forbade a net increase.
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Exhibit 2-1
SUBPARTS OF 40 CFR 420:
IRON AND STEEL MANUFACTURING POINT SOURCE CATEGORY
EFFLUENT GUIDELINES
Steehnaking Subcategory
A: Cokemaking
B: Sintering
C: Ironmaking
D: Steelmaking
E: Vacuum Degassing
F: Continuous Casting
Subpartof
40 CFR 420
40 CFR 420.10
40 CFR 420.20
40 CFR 420.30
40 CFR 420.40
40 CFR 420.50
40 CFR 420.60
Steelmaking Subcategoiy
G: Hot Forming
H: Salt Bath Descaling
I: Acid Pickling
J: Cold Forming
K: Alkaline Cleaning
L: Hot Coating
Subpartof
40 CFR 420
40 CFR 420.70
40 CFR 420.80
40 CFR 420.90
40 CFR 420.100
40 CFR 420.110
40 CFR 420.120
The formulation of infra-plant trading changed several times during the rulemaking process
in the early 1980s. The final regulation was a result of compromise arrived at in negotiations
involving the Natural Resources Defense Council, the American Iron and Steel Institute, and EPA.
This regulation places four restrictions on the use of these exchanges:4
1) Resultant discharges cannot cause a violation of any applicable state water
quality standards.
2) For ease of administration, each outfall must be assigned specific, fixed
effluent limitations for the pollutants governed by the regulation.
3) Process wastewaters from cokemaking (subcategory A) and cold forming
(subcategory J) are not eligible for use in these exchanges.
4) The net discharge of traded pollutants must be less than the discharge
allowed without the trade. The magnitude of the reduction in net discharge
is a specified factor of the amount(s) by which any wastewater stream(s)
involved in the trade exceed otherwise allowable effluent limitations. The
reduction factor must be approximately 15 percent for total suspended solids
and oil and grease, and 10 percent for all other pollutants. Appendix G
walks the reader through the calculation of such a reduction.
These restrictions are designed to ensure that trading does not adversely affect water quality or pose
unacceptable difficulties in administrating and enforcing discharge permits. Documents charting the
evolution of the intra-plant trading regulation are included in Appendix C
4 40 CFR 420.03 (b). The reasoning behind the first three restrictions is detailed in 47 FR 23273
(May 27, 1982). The fourth restriction arises from the Settlement Agreement to a lawsuit
challenging the regulation (National Steel Corp. v. EPA). The Settlement Agreement is summarized
in 49 FR 21024-21025. These Federal Register notices are included in Appendix C.
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PLANTS SUBJECT TO EPA
IRON AND STEEL EFFLUENT GUIDELINES
As a first step in analyzing the extent of the use of trading, researchers identified all plants
potentially eligible to make use of the provision; that is, all plants permitted subject to the Iron and
Steel Effluent Guidelines. The EPA's Permit Compliance System (PCS) was used for this analysis.
The PCS contains information on all active National Pollutant Discharge Elimination System
(NPDES) permits. Using this system, 443 active permits issued under the authority of 40 CFR 420
were identified.5 A list of these permits is attached as Appendix A Each permit covers discharges
from a single facility. The PCS identifies the effluent guideline under which a particular permit was
issued by matching the Standard Industrial Classification (SIC) code associated with the entire
facility with the subsection of 40 CFR 420 that primarily governs discharges from that industry.
Because there is an inexact correspondence between the SIC codes and the subsections of 40 CFR
420, it is possible that discharges from some of these facilities are actually not governed by 40 CFR
420, or that some facilities with discharges regulated by 40 CFR 420 are not included.6 It is not
possible to precisely determine the regulation governing the issuance of a permit without actually
reading the permit.
Intra-plant trading is allowed among points of a single facility where the permit requires
effluent to be monitored. These points are generally referred to as "outfalls," although many of
them are internal monitoring points or internal outfalls into further conveyance rather than outfalls
directly into receiving waters. The PCS records information on each permitted outfall, allowing the
number of outfalls for each permitted facility to be calculated. A total of 1,775 outfalls are
regulated at the 443 facilities identified above. Exhibit 2-2 indicates the distribution of the 443 steel
facilities by the number of permitted outfalls recorded in the PCS. As noted in the exhibit, 208 of
the facilities have only one outfall. Because a trade requires a minimum of two outfalls, these
facilities are unable to engage in intra-plant trading.
Based on the presence of more than one outfall, the remaining 235 facilities are potentially
eligible to trade. An in-depth 1981 study of four steel plants, however, concludes that the technical
and economic feasibility of trading is likely to increase with the number of outfalls at a facility.7
To focus on those facilities most likely to be able to make use of trading, Appendix B lists the 46
tacilities with ten or more outfalls. As shown in Exhibits 2-3 and 2-4, 38 of these 46 plants are
located in EPA Regions 3 or 5; 26 of these 38 are located in Ohio or Pennsylvania. After actual
trades were identified, researchers contacted several of these plants that did not trade to determine
why trading was not utilized. These results are discussed in Chapter 3 of this report.
5 This information is current as of March 5,1993.
6 For example, 112 of the 443 permits are identified as having been issued under subsection L
of 40 CFR 420. Subsection L governs discharges associated with the hot coating of steel. However,
the SIC codes used to identify hot coating operations also cover coating operations not regulated
by 40 CFR 420 (e.g., jewelry enameling).
7 U.S. EPA, The Effect of the Water Bubble Policy on Individual Iron and Steel Facilities, prepared
by Temple, Barker and Sloane, April 1981, pp. 9-10.
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Exhibit 2-2
DISTRIBUTION OF FACILITIES PERMITTED
UNDER 40 CFR 420 BY NUMBER OF OUTFALLS
Number of OutftDs
1
2
3 to 5
5 to 9
10 to 19
Over 20
Number of Facilities
208
89
67
33
30
16
Exhibit 2-3
LOCATION OF FACILITIES WITH TEN OR MORE OUTFALLS
BY STATE
State
AL
IL
IN
KY
MD
MI
Number of Facilities
1
1
5
3
1
3
State
NJ
NY
OH
PA
TX
WV
Number of Facilities
1
2
12
14
1
2
Exhibit 2-4
LOCATION OF FAdLTIlES WITH TEN OR MORE OUTFALLS
BY EPA REGION
EPA Region
1
2
3
4
5
Number of
Facilities
0
3
17
4
21
EPA Region
6
7
8
9
10
Number of
Facilities
1
0
0
0
0
2-4
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IDENTITY OF PERMITS
INCORPORATING INTRA-PIANT TRADING
NPDES permits incorporating intra-plant trades are issued in the same form as permits not
incorporating trading: limits for specified parameters are stated for each outfall. Because the PCS
simply records information on the issued permit, it cannot be used to identify permits incorporating
intra-plant trading. Moreover, there is no other centralized system for recording the issuance of
such permits. According to EPA and industry sources, the only certain way to identify permits
incorporating intra-plant trades is to read the Fact Sheets/Briefing Memoranda for each permit
issued under 40 CFR 420. A research effort of this magnitude is beyond the scope of this study.
The same sources note, however, that because use of intra-plant trading is a relative rarity, those
approving or reviewing a permit incorporating it are likely to recall it. This institutional memory
has been relied on to identify active permits incorporating intra-plant trading.
As a first step in identifying active permits incorporating intra-plant trading, NPDES
personnel in EPA Regions 1 through 8 were contacted. EPA Regions 9 and 10 were not contacted
because the PCS lists no permits in these regions for steel industry facilities with more than one
•outfall. Regional personnel were able to identify four steel manufacturing facilities that use intra-
plant trading, all located in Region 5. Knowledgeable EPA personnel in other Regions indicated
no permits incorporating intra-plant trades, or directed researchers to state officials who reported
no such permits.8 However, subsequent contacts with representatives of the iron and steel industry
revealed two additional plants that use trading, one in Region 5 and one in Region 3. Thus, this
study identifies six currently valid NPDES permits issued under 40 CFR 420 that incorporate intra-
plant trading.
As a supplement to the main research effort, a June 1984 paper analyzing the use of intra-
plant trades in the steel industry was consulted.9 This paper listed seven permits incorporating such
trades. Three of these permits are among the six noted above. Of the remaining four permits, one
was issued to a facility now closed, and three no longer incorporate trading. Thus, this report
contains information on ten permits incorporating trading: six currently in effect and four no longer
in effect. Exhibit 2-3 lists these ten facilities, provides some background information, and describes
the current status of each permit.10
8 State officials were contacted in Connecticut, New Jersey, New York, and Utah. See the
sources section of this report for details.
9 John Palmisano and Debora Martin, "The Use of Nontraditional Control Strategies in the Iron
and Steel Industry: Air Bubbles, Water Bubbles, and Multimedia Based Control Strategies"
prepared for presentation at the 77th annual meeting of the Air Pollution Control Association, San
Francisco, CA, June 24-29,1984, p. 13.
10 The exhibit includes information on the total number of outfalls at each facility. In the case
of currently valid permits, this information \s from the PCS. In the case of expired permits, this
information was obtained from available permit documents.
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Exhibit 2-3
IRON AND STEEL INDUSTRY PLANT PERMITS INCORPORATING INTRA PLANT TRADING
Facility
Armoo Steel
Middletown, OH
Babcock and Wilcox
Beaver Falls, PA
Bethlehem Steel
Sparrows Point, MD
Inland Steel
East Chicago, IN
LTV Steel
Indiana Harbor, IN
Republic Steel
Massillon, OH
Rouge Steel
Dearborn, MI
U.S. Steel
Clairton, PA
U.S. Steel
Gary, IN
U.S. Steel
Homestead, PA
Pollutants
Traded
TSS, O&G,
Lead, Zinc
TSS, O&G,
Lead, Zinc
Zinc
Lead, Zinc
O&G, Lead,
Zinc
TSS, O&G
TSS, Lead,
Zinc
TSS
TSS, O&G
TSS, O&G
Total
Number
of
Outfalls
25
12
10
38
16
7
20
46
33
16
Number of
Outfalb
Involved in
Trade
5
2
2
3
4
2
2
2
3
3
Date
Issued
03/31/87
11/18/83
10/10/85
03/06/84
10/01/86
08/22/83
07/19/84
03/09/84
06/01/83
03/09/84
Status in February 1994
Current permit (12/01/92) incorporates trading.
Facility changed ownership in the late 1980s, and outfalls
involved in trade are no longer owned by a single entity. No
follow-on operations hold permits incorporating trading.
Still in administrative effect.
Still in administrative effect.
Still in administrative effect.
Facility changed ownership in the late 1980s, and some
Massillon operations have been sold or closed. No follow-on
operations hold permits incorporating trading.
Current permit (01/01/94) incorporates trading.
Current permit does not incorporate trading. One of the
outfalls involved in the trade is no longer in use.
Permit is still in administrative effect; some outfalls involved in
trade are no longer used. See Appendix E for details.
Facility was closed in the late 1980s.
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FINDINGS CHAPTER 3
INTRODUCTION
Following identification of the ten iron and steel plants known to have undertaken intra-plant
trades, research focused on characterizing the trades' impacts. The issues of greatest interest
included the types of effluents and pollutants subject to trades, the impact of trades on pollutant
loads and water quality, the effect of trades on pollution control costs, the effect of trading on the
use of innovative treatment technologies, the impact of trading on agencies administering the
NPDES permit program, and the attitudes toward trading held by industry and regulatory personnel.
To analyze the trades' impacts, researchers contacted state and Regional personnel to obtain
copies of permits, briefing memoranda, fact sheets, limit calculations, and any other relevant
documentation. If states or Regions were not able to provide this material, it was sought from
representatives of the iron and steel facilities involved in the trade. In some instances, a facility had
closed or changed ownership; in these cases, corporate officials or former employees of the facilities
were contacted. Based on the information these sources provided, brief case studies of each of the
ten intra-plant trades were developed. These case studies, which are presented in Appendix E, are
the primary basis of this report's discussion of trading's impacts.1
In addition to gathering relevant documents, researchers conducted informal, open-ended
interviews with industry and regulatory personnel, and also interviewed other knowledgeable experts.
These interviews provided information on trading's immediate impacts, and also addressed factors
that encourage or discourage trading. As part of this effort, researchers contacted representatives
of eight iron and steel facilities that do not engage in intra-plant trading; interviews of these officials
provide additional insight to the factors that have limited the application of intra-plant trading within
the iron and steel industry.2
1 Each of the case studies has been reviewed for accuracy either by a representative of the plant
that engaged in the trade, or, in the case of some expired trades, by individuals associated with the
plant while the trade was active. The case studies identify all information sources upon which they
rely, including permit documents and regulatory or industry officials. Copies of all relevant
documents are included as Attachment 1 to this report.
2 All individuals interviewed and documents employed are listed in the sources section of this
report except those included in Attachment 1 to this report.
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The following discussion summarizes the principal findings of this analysis of trading's
impacts.
PLANT PROCESSES AND POLLUTANTS SUBJECT TO INTRA-PLANT TRADES
Exhibit 3-1 identifies the pollutants involved in trading at each of the ten facilities analyzed.
The exhibit also indicates, on an outfall-by-outfall basis, whether the permit limits for a particular
pollutant were set above or below the effluent limitation guidelines. As the exhibit shows, all of the
trades involve one or more of only four pollutants: total suspended solids (TSS), oil and grease
(O&G), lead, and zinc. TSS is the pollutant most often traded (seven trades), followed by oil and
grease (six), zinc (six), and lead (five). It is interesting to note that all trades involving lead also
involve zinc. Although this is a limited number of trades upon which to base broad conclusions, the
likely explanation is a high degree of correlation between lead and zinc loadings at a given outfall;
these pollutants tend to be found together in untreated iron and steel wastewater, and can often be
controlled to a similar degree with the same technology.
The effluents associated with the outfalls involved in trades come from a wide range of
production processes, including sintering, steelmaking, vacuum degassing, continuous casting, hot
forming, and acid pickling operations (see Appendix D for a glossary of iron and steel terminology).
It is often the case that an outfall involved in a trade conveys wastewater from more than one
production process. In several instances, these mixed wastewaters included effluent from operations
not eligible for trading, e.g., effluent from cold forming operations or from operations governed by
the effluent guidelines for industries other than iron and steel. In these cases, the effluent
associated with ineligible processes is excluded from the trading calculation. In at least one case,
however — the trade at U.S. Steel's Qairton Works — a trade involved effluent from cokemaking
operations, which the current regulation specifically prohibits. No explanation for this apparent
discrepancy was provided, but as a result of a reconfiguration of outfalls, the trade is no longer in
effect.
IMPACT OF INTRA-PLANT TRADES ON POLLUTANT LOADS AND WATER QUALITY
Pollutant Loads
Trading requires that the sum of pollutant limits for outfalls involved in the trade be reduced
below effluent limitation guideline (ELG) limits. As noted previously, the minimum net reduction
must be approximately fifteen percent for TSS and O&G, and ten percent for all other traded
pollutants. The trading calculations performed by NPDES permit authorities and presented in
Appendix E incorporate these net reductions (see Appendix G for sample calculations). In all cases,
the resulting permit limits meet or exceed the net reduction requirements. Exhibit 3-2 summarizes,
for each of the ten facilities that have employed trades, the net reductions in permit limits provided
by trading. As the exhibit indicates, the net reduction in permitted loadings ranges from less than
a pound per day for most trades involving lead and zinc to several thousand pounds per day for
some trades involving TSS.3
3 As noted in Appendix E, the permit limits currently in effect for some facilities differ from the
draft permit limits suggested by the permit Fact Sheets/Briefing Memoranda. In most cases, the
differences are minor. In the case of the Armco Steel plant in Middletown, Ohio, however, current
permit limits for TSS, O&G, and lead are much more stringent than those suggested by the available
3-2
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Exhibit 3-1
OUTFALLS AND POLLUTANTS SUBJECT TO INTRA-PLANT TRADING
Facility
Armco Steel,
Middletown, OH
Babcock & Wilcox,
Beaver Falls, PA
Bethlehem Steel,
Sparrows Point, MD
Inland Steel,
East Chicago, IN
LTV Steel,
Indiana Harbor, IN
Republic Steel,
Massillon, OH
Rouge Steel,
Dearborn, MI
U.S. Steel,
Clairton, PA
U.S. Steel,
Gary, IN
U.S. Steel,
Homestead, PA
Outfall
005
613
614
631
641
113
115
101
014
601
614
618
Oil
101
111
211
004
603
04B1
001
102
120
028
030
605
008
010
115
Pollutant
TSS
—
+
+
+
+
+
—
*
*
*
*
*
*
*
*
*
+
—
+
—
+
—
+
+
—
—
+
—
O&G
—
*
*
*
+
+
—
*
*
*
*
*
—
—
+
*
+
—
*
*
*
*
+
+
—
—
+
—
Lead
—
+
+
+
—
+
—
*
*
+
+
—
+
—
*
—
*
*
+
—
*
*
*
«
*
*
*
*
Zinc
—
+
+
+
—
+
—
+
—
+
+
—
+
—
*
—
*
*
+
—
*
*
*
*
*
*
*
*
Key: + = limit above that set in Effluent Guidelines
- = limit below that set in Effleuent Guidelines
* = not involved in trade
documentation, while the limits for zinc are less stringent; no explanation for this discrepancy has
been provided. The discussion above reflects the permit limits as calculated in the Fact
Sheets/Briefing Memoranda.
3-3
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Exhibit 3-2
NET DECREASES BELOW ELG LIMITS
FOR TRADED POLLUTANTS (Ibs/day)
Facility
Armco Steel,
Middletown, OH
Babcock & Wilcox,
Beaver Falls, PA
Bethlehem Steel,
Sparrows Point, MD
Inland Steel,
East Chicago, IN
LTV Steel,
Indiana Haibor, IN
Republic Steel,
Massillon, OH
Rouge Steel,
Dearborn, MI
U.S. Steel,
Clairton, PA
U.S. Steel,
Gary, IN
U.S. Steel,
Homestead, PA
Type of
Limit
30-Day Average
Daily Maximum
30-Day Average
Daily Maximum
30-Day Average
Daily Maximum
30-Day Average
Daily Maximum
30-Day Average
Daily Maximum
30-Day Average
Daily Maximum
30-Day Average
Daily Maximum
30-Day Average
Daily Maximum
30-Day Average
Daily Maximum
30-Day Average
Daily Maximum
Pollutant
TSS
379
999
8.00
25.00
*
*
*
»
*
*
42
120
55
60
4,121
6,271
2,575
*
3,137
8,548
O&G
9
29
1.30
3.00
*
*
*
*
*
237.9
*
176
*
*
«
*
*
823
*
3,451
Lead
0.44
1.32
0.01
0.04
*
*
0.19
0.61
0.49
1.43
*
»
0.13
0.38
*
*
*
*
*
*
Zinc
0.57
1.54
*
0.03
1.4
4.0
0.14
0.40
0.49
1.48
*
*
0.19
0.22
*
*
*
*
*
*
* = not involved in trade
While it is clear that trading has reduced the sum of permitted discharges, its effect on actual
discharges in comparison to standard application of the effluent limitations guidelines is less clear.
In none of the ten cases analyzed did trading lead to the implementation of pollution controls
beyond those needed to control to BAT limits. Instead, in each case, trading was possible because
existing treatment or other circumstances at one or more outfalls had already reduced discharges
below the levels required by the effluent guidelines. This "excess control" was applied as an offset
to discharges from other outfalls, enabling facilities to forego installation of additional pollution
control systems that would otherwise have been needed. In the immediate term, therefore, standard
application of the effluent limitations guidelines would likely have resulted in a greater reduction
in actual discharges than that which occured under trading. In the longer term, however, it is
3-4
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possible that trading will prove to be a constraint on increases in pollutant loads, since plant
managers must operate existing treatment systems at peak performance, in order to maintain the
"excess control" used to offset the need for pollutant reductions elsewhere.
Waty.r Quality
Detailed assessments of the water quality impacts of trading were not conducted by
regulatory agencies as part of the permitting process for any of the permits incorporating trading.
The regulation governing intra-plant trading, however, specifically precludes its use when it would
result in any violation of state water quality guidelines. This requirement has been adhered to in
all cases. In fact, as noted later in this report, engineers at several steel plants not making use of
trading reported that they were prevented from doing so due to water quality constraints.
IMPACT OF INTRA-PLANT TRADES
ON POLLUTION CONTROL COSTS
Intra-plant trading is attractive to steel plants primarily because it reduces their pollution
control costs.4 For all ten plants, trading provided permit limits that could be met without installing
treatment beyond that necessary to achieve the effluent guideline limits. To determine how
treatment and related costs would have differed without the trade, personnel associated with each
of the facilities were contacted. In some cases, officials based their appraisal of reduced treatment
costs on analyses done at the time the trade originated. In most cases, however, appraisals were
developed post-hoc. These assessments are presented in detail in Appendix E.
Exhibit 3-3 presents summary information on the present value of reductions in pollution
control costs due to trading. Cost estimates are provided for both capital and operation and
maintenance (O&M) expenses, and are available for seven of the ten facilities that have engaged
in trades.5 Five of the permits incorporating these trades are still in effect. For the seven cases, the
present value of reduced costs attributable to trading ranges from $3.2 million to $69.8 million. The
present value of total reduced costs for the seven plants is $122.7 million. For the other three plants
that have had trades, one of which is still in effect, no information was obtained. Explanation of the
methodology and assumptions used to calculate the present value of the reduced costs is provided
in Appendix F.
4 In addition, one plant reported that trading provided a "buffer" at one outfall, making permit
violations less likely.
5 The cost data do not take tax considerations into account.
3-5
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Exhibit 3-3
REDUCTION IN TREATMENT COSTS DUE TO TRADING
nut
Annco Steel
Middletown. OH
Babcock and Wilcox
Beaver Falls, PA
Bethlehem Steel
Sparrows Point, MD
Inland Steel
East Chicago, IN
LTV Steel
Indiana Harbor, IN
Republic Steel
MassiDon, OH
Rouge Steel
Dearborn, MI
US. Steel
Clairton,PA
U.S. Steel
Gary, IN
U.S. Steel
Homestead, PA
Totals
Reduced
Capital
(1993doDan)
$2,000,000
NA
11,374,676
$1,125,000
NA
$5,238,534
$3,000,000
$4,832,007
$29.313.285
NA
Present Value of
Reduced Capital
En^vrftum
Through 1993
$3,934^03
NA
$2361,949
$2,068467
NA
$10304,990
$5,515378
$8383,448
$57,663,668
NA
$90,732,002
Annual Reduced
OAM
Elpenditure
(1993 dollars)
$150,000
NA
$206,201
$84375
NA
$392,890
$225,000
$724,801
$2,198,496
NA
Praent Value of
RcducedO&M
BapeadUurcs
Through 1993
$2367.340
NA
$2,469,878
$1,165,763
NA
$3,941,811
$3,108,701
$6,796,101
$12,144,047
NA
$31,993,841
Praent Value of
Tool Reduced
Eapenditiirei
Through 1993
$6,301,843
NA
$4,831,827
$3,234,029
NA
$14,246,801
$8,624,078
$15,679,549
$69,807,715
NA
$122,725,843
INTRA-PLANT TRADING AND INNOVATIVE TREATMENT
None of the environmental engineers at the plants making use of trading indicated that
trading had spurred the use of innovative pollution control technologies. A recent report on waivers
issued for the use of innovative treatment technology under section 301 (k) of the Clean Water Act
indicates that one of the plants making use of trading, Inland Steel, also made use of the innovative
treatment waiver.6 According to the fact sheet for Inland Steel's permit, however, none of the
outfalls involved in trading were associated with this waiver.
According to a former EPA employee who was intimately involved in intra-plant trading
issues in the mid-1980s, and who currently works as a consultant to the steel industry, no innovative
6 U.S. Environmental Protection Agency, Office of Water, The 301(k) Innovation Waiver and
Pollution Prevention," prepared by Ken and Associates, 1994.
3-6
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treatment techniques have been developed as a result of the application of intra-plant trading.7
There is no indication that any treatment technologies other than those considered BAT in the
effluent guideline development documents have been used on traded outfalls.
RESOURCE OR ADMINISTRATIVE IMPACTS ON
PERMIT AUTHORITIES AND DISCHARGERS
Like all NPDES permits, those incorporating trading have explicit limits set for each outfall;
the actual permit document looks the same as a permit not incorporating trading. In the regulation,
the Agency explicitly requires that "specific, fixed effluent limitations" be set for each outfall involved
in trading.8 According to a 1982 Federal Register notice, this requirement was necessary to avoid
increasing the administrative burden on permit authorities.' The requirement appears to have been
successful in achieving this goal. None of the state or EPA personnel contacted indicated that
administering or enforcing a permit that incorporates trading differs in any respect from
administering or enforcing a standard permit.
The only administrative change imposed by a permit that incorporates trading is in the
permit development stage. State permit authorities, EPA Regional personnel, and industry sources
noted that the initial formulation and subsequent checking of the calculations required to include
trading in a permit has a small impact on the time needed to issue a permit. According to an
individual involved in the negotiation of several of the permits incorporating intra-plant trading, the
development of a permit for a large integrated steel plant typically takes two to four weeks of a
permit writer's time. Trading adds about one day to this time. This individual indicated that when
trading is under consideration, the permit writer's involvement is generally limited to checking
trading calculations provided by the facility.10 Although not trivial, the calculations are not
especially complicated, and are relatively easy to follow, especially compared to other calculations
required for a permit (e.g., the calculations relating production to maximum loadings permitted
under ELGs). Moreover, materials related to trading typically constitute only a small portion of the
background documentation compiled in issuing a permit. For example, the State of Pennsylvania
provided copies of all calculations associated with the Babcock and Wilcox permit. These
calculations filled 32 pages. Calculations associated with the trade took up part of one page.
Available calculations for other permits incorporating trading show a similar portion associated with
trades. Although purely anecdotal, the limited documentation required for review of trades provides
further evidence that intra-plant trading does not result in a significant burden on permit authorities.
7 Gary Amendola, Amendola Engineering, Incorporated, telephone conversations, May through
.November 1993. Mr. Amendola worked as a Senior Iron and Steel Industry Specialist for EPA until
1989, and was the information contact noted in the Federal Register notice of the final regulation.
He has been involved in negotiations for several of the permits incorporating trading.
8 40 CFR 420.03(b)(2).
9 47 FR 23272, included as part of Appendix C.
10 Gary Amendola, telephone conversation, 8 November 1993.
3-7
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ATTITUDES TOWARD INTRA-PLANT TRADING
The state and Regional regulatory personnel contacted were generally familiar with the intra-
plant trading provision for iron and steel facilities, voiced no objections to its use, and appeared
willing to consider its application. Staff turnover in the years since most intra-plant trades were first
developed, however, limited the ability of many of those contacted to comment on the details of the
process. In addition, the high degree of turnover made it impossible to determine the extent to
which regulators' attitudes toward trading may have evolved over time. Like their government
counterparts, the steel facility environmental managers contacted were also quite familiar with the
regulations governing intra-plant trading; these individuals often had been instrumental in suggesting
its use.
While state and Regional permit writers voiced no objections to the intra-plant trading
policy, they, along with industry officials, noted a number of factors that limit its use. One industry
source noted that the exclusion of effluent from the cold forming and cokemaking subcategories had
in some cases prevented an intra-plant trade.11 In addition, because intra-plant trading provisions
do not apply to new sources, and because many older iron and steel mills have closed in recent
years, the number of facilities eligible to trade has declined over time. This trend is likely to
continue, particularly as the steel industry brings new equipment, such as continuous casting
machinery and electric arc furnaces, on line. Finally, several state officials and industry sources
noted a trend toward increased reliance on water quality-based permitting, particularly in Ohio. As
water quality-based permitting becomes increasingly prevalent, the flexibility that the intra-plant
trading regulation allows in writing technology-based permits becomes less relevant.12
PLANTS NOT MAKING USE OF INTRA-PLANT TRADING
To develop a better understanding of factors that have limited broader use of intra-plant
trading, environmental managers at several large iron and steel plants whose permits do not
incorporate trading were interviewed. The plants contacted were selected either because they are
among the largest in the nation, or because the PCS indicated that they maintain multiple outfalls,
and thus might be candidates for trading.
The interviews indicate that there is no single reason why the plants contacted have not used
trading; however, lack of familiarity with trading provisions does not appear to have been a factor.
All managers contacted were aware of the intra-plant trading rule, and indicated that in negotiating
permit limits with regulatory authorities they would not hesitate to call for its use. While they were
reluctant to generalize about factors limiting trading, they were able to describe the specific
circumstances that prohibited its use at their facility. These factors are summarized below.
11 J. David Moniot, General Manager, Environmental Affairs, USX—U.S. Steel Group.
Telephone conversation, 16 November 1993.
12 It is important to note that the principles of intra-plant trading can be applied to a facility that
is subject to a water quality-based permit. This report, however, confines itself to the consideration
of intra-plant trading under technology-based permits.
3-8
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National Steel Corporation0
Great Lakes Division, River Rouge, MI
National Steel Corporation's Great Lakes Division, located io River Rouge, Michigan, is not
able to make use of the intra-plant trading provision because state water quality requirements
constrain the discharge of lead and cadmium to levels below federal BAT-based limits. It is
interesting to note, however, that Michigan provides the plant with a total lead limit that it can
allocate among its outfalls. In this case, the implementation of the water quality-based limit for lead
in effect permits intra-plant trading, albeit not as defined by the intra-plant trading regulation.
Granite Gty Division, Granite dry, EL
National Steel Corporation's Granite City Division is located in Granite City, Illinois. All
wastewater from the plant's operations is treated in an on-site central treatment plant with a single
outfall. Thus, there is no opportunity for trading at this facility.
Annco Steel Company. Ashland. KY14
Armco Steel Company's Ashland Works is located in Ashland, Kentucky. The company has
an on-site central treatment plant for all process wastewater. Effluent from the central treatment
plant flows to a central reservoir from which cooling water is drawn and returned. Flow from this
reservoir is monitored at a single point prior to entering the Ohio River through several outfalls.
Due to the presence of a central treatment plant and a single monitoring point, there is no
opportunity for trading at this facility.
Bethlehem Steel Corporation15
Bums Harbor Division, Burns Harbor, IN
Bethlehem Steel Corporation's Burns Harbor Division is located in Burns Harbor, Indiana
The facility has two outfalls, one for treated process water and one for treated cooling water. It is
not able to make use of trading in its permit because the pollutants controlled at these outfalls do
not match in a way that allows a trade to occur.
0 John Olashuk, Environmental Engineer, National Steel Corporation. Telephone conversation,
2 December 1993.
14 Steve Custer, Manager, and Bill Cody, Senior Environmental Engineer, Environmental Affairs
Department, Armco Steel Ashland Works. Telephone conversations, 26 January 1994 and 28
January 1994.
u Barbara E. Bachman, Senior Environmental Engineer, Bethlehem Steel Corporation.
Telephone conversations, 2 December 1993 and 18 February 1994.
3-9
-------
Bethlehem Division, Bethlehem, PA
Bethlehem Steel Corporation's Bethlehem Division is located in Bethlehem, Pennsylvania.
Trading was considered in writing the facility's permit. However, Bethlehem was unable to identify
any combination of outfalls that could successfully engage in a trade.
LTV Steel Company. Cleveland. OH1*
According to information in the PCS, LTV Steel Company's Cleveland Works has 32 outfalls.
The corporate environmental manager for water is aware of the trading provision and was involved
in negotiating the trading permit now in effect for LTV's Indiana Harbor Works. Due to water
quality constraints, however, he has been unable to find an opportunity to use trading in the
Cleveland Works' permit.
Wheeling Pittsburgh Steel Corporation"
Wheeling Pittsburgh's main steelmaking facility is its Steubenville Complex, made up of two
separately permitted facilities: the North Works, in Steubenville, Ohio, and the South Works, in
Mingo Junction, Ohio. The North Works has 20 outfalls (11 process and 9 stormwater), and the
.South Works has 23 outfalls (16 process and 7 stormwater). Environmental officials at the plant are
familiar with the trading provision; however, they were not able to make use of it at either facility.
Permit limits at all process outfalls are water quality constrained for all parameters except total
suspended solids and oil and grease. Controlling the water quality constrained parameters to permit
limits has reduced TSS and O&G discharges to levels below ELG limits. Thus, there is no
opportunity at this facility to make use of trading.
Geneva SteeL Provo. UT18
Geneva Steel, a large independent steel manufacturer, has an on-site central treatment plant
with a single outfall, and thus cannot make use of trading.
16 John Etchison, Manager, Water, Corporate Environmental Control. Telephone conversation,
8 September 1993.
17 Dr. William Samples, Manager, Engineering and Environmental Control, and Tom Waligura,
Assistant Manager of Environmental Control. Telephone conversations, 2 December 1993 and 22
February 1994.
18 Steve McNiel, Utah Department of Environmental Quality, Department of Water Quality.
Telephone conversation, 17 May 1993.
3-10
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USE OF INTRA-PLANT TRADING IN OTHER INDUSTRIES CHAPTER 4
A preliminary assessment of the feasibility of using intra-plant trading in effluent categories
other than Iron and Steel was conducted through informal interviews with officials of EPA's Office
of Water who are involved with issuing effluent guidelines.1 Over the next several years, the EPA
is expected to develop new or revised effluent guidelines for several industries. According to an
official of the Engineering and Analysis Division of EPA's Office of Water, rulemaking is currently
.in progress for the Industrial Laundries and Metal Products and Machinery categories. The
Industrial Laundries category is made up almost exclusively of small indirect dischargers (i.e.,
facilities that discharge to POTWs), which are not likely candidates for intra-plant trading. The
same generally holds true for the Metals Products and Machinery category; although there are a few
large dischargers with multiple outfalls, most dischargers in this category are small indirect
dischargers, and thus not likely candidates for intra-plant trading.2 Note, however, that these
facilities may be candidates for inter-plant pretreatment trading.3
In addition to the industries cited above, the Office of Water is in the initial stages of
considering revision of effluent guidelines for five categories of dischargers: Iron and Steel
Manufacturing, Steam Electric Power Generation Facilities, Textile Manufacturing, Inorganic
Chemical Manufacturing, and Petroleum Refining. Like the Iron and Steel Manufacturing category,
the remaining four categories are made up largely of direct dischargers, many with multiple outfalls.
Thus, intra-plant trading may be feasible for facilities in these categories. Although the Office of
Water is not currently planning to explicitly evaluate the viability and merits of intra-plant trading
for any of these industries, officials expressed a willingness to conduct such an evaluation. In
1 The Agency's plan for developing new and revised effluent guidelines was announced in the
Federal Register September 8,1992. Appendix H contains a copy of this notice.
2 Eric Strassler, Engineering and Analysis Division, Office of Science and Technology, Office of
Water, U.S. Environmental Protection Agency. Telephone conversation, 2 February 1994.
3 For a discussion of pretreatment trading, see Use of Market-Based Allocations to Meet Local
Limits for Pretreatment: A Report in Support of Clean Water Act Reauthorization, prepared for
Richard Kashmanian, U.S. EPA, Office of Policy, Planning and Evaluation, by Industrial Economics,
Incorporated and Science Applications International Corporation, March 1994.
4-1
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addition, several officials at the Office of Water familiar with these industries discussed their initial
impressions of the potential for intra-plant trading.4
According to these sources, most of the water from the steam power generation industry is
likely to be non-contact cooling water, blowdown water from steam recycling operations, runoff
water, or water from air pollution control devices. It is unclear to what extent this effluent is likely
to be a viable candidate for trading. The Chief of the Energy Branch of the Engineering and
Analysis Division of the Office of Water suggested that the feasibility of trading would be "small to
medium" for the Petroleum Refining, Textile, and Inorganic Chemical categories; he based this
assessment both on the number of facilities in each industry with multiple outfalls and on his initial
impression of the likelihood that these outfalls discharge similar pollutants.5 The Office of Water's
studies regarding these categories are scheduled to be completed over the next year.6 In addition,
he noted a "medium to large" feasibility for intra-plant trading in the Organic Chemicals category,
although the current guidelines, promulgated in November 1987, do not permit intra-plant trading.
These guidelines are not among those currently scheduled for revision.
* Strassler; Marvin Rubin, Chief, Energy Branch, Engineering and Analysis Division, Office of
Science and Technology, Office of Water, U.S. Environmental Protection Agency, telephone
conversation, 4 February 1994; Elwood Forscht, Chief (acting), Metals Branch, Engineering and
Analysis Division, Office of Science and Technology, Office of Water, U.S. Environmental
Protection Agency, telephone conversations, 24 and 25 February 1994.
5 Telephone conversation, 4 February 1994.
* A schedule of expected completion dates should be published in the Federal Register in late
Spring.
4-2
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Mote: In addition to the sources cited below, the documents included in
the appendices and in Attachment 1 to this report were consulted.
33 Metal Producing, 1991 Guide to North American Steel Industry, vol. 29, no. 5 (May 1991).
Amendola, Gary, Amendola Engineering Incorporated, telephone conversations, 17 May 1993,13
September 1993, and 8 November 1993.
American Iron and Steel Institute, Steel Processing Flowlines, undated.
American Iron and Steel Institute, Steelmaking Flowlines, undated.
Bachman, Barbara E., Senior Environmental Engineer, Bethlehem Steel Corporation, telephone
conversations and correspondence, December through February 1994.
Bell, Brian, U.S. Environmental Protection Agency, Industrial Permitting Section, Water Quality and
Industrial Permits Branch, Permits Division, Office of Wastewater Enforcement and
Compliance, telephone conversation, 10 May 1993.
Boehle, William, Section Chief, Surface Water Section, Bureau of Standard Permits, New Jersey
Department of Environmental Protection and Energy, telephone conversation, 24 May 1993.
Cason, Gary, Environmental Affairs, USX—US Steel Group, telephone conversation, 19 January
1994; miscellaneous correspondence, January and February 1994.
Catania, Victor, Babcock and Wilcox Special Metals Plant, telephone conversations, September 1993
through January 1994.
Cody, Bill, Senior Environmental Engineer, Environmental Affairs Department, Armco Steel
Company, Ashland (Kentucky) Works, telephone conversation, 28 January 1994.
Dahlgren, Allan, former Environmental Manager, Babcock and Wilcox, Beaver Falls, PA, telephone
conversation, 24 January 1994.
Dzikowski, Irvin, U.S. Environmental Protection Agency, Region 5, Chief, Unit #1, Permits Section.
Personal communications, May through December 1993.
Engineering News-Record, "First Quarterly Cost Report," vol. 230, no. 13 (29 March 1993), pp. 27-41.
Etchison, John W., Manager, Water, Corporate Environment Control, LTV Steel Company,
telephone conversations, September 1993 through February 1994
-------
Forsht, Elwood H. (Woody), U.S. Environmental Protection Agency, Chief (acting), Metals Branch,
Engineering and Analysis Division, Office of Science and Technology, Office of Water,
telephone conversations, 24 and 25 February 1994.
Harder, Mike, Director, Bureau of Water Management, Connecticut Department of Environmental
Protection, telephone conversation, 20 May 1993.
Humke, Fred, U.S. Environmental Protection Agency, Region 6, Industrial Permits Section, Water
Division, telephone conversation, 19 May 1993.
Indiana Department of Environmental Management, telephone conversations with various personnel
(Virgil Bradford, C. P. Cheng, Joe Krieger, George Meyers, Mark Stanifer, Rod Thompson,
John Winters), September through December 1993.
Jarrett, Matt, U.S. Environmental Protection Agency, Metals Branch, Engineering and Analysis
Division, Office of Science and Technology, Office of Water, telephone conversations, 17
May 1993 and 24 February 1994.
Johnston, Robert D., Staff Engineer, Environmental, Health, and Safety, Inland Steel, East Chicago,
IL, personal communications, November 1993 through February 1994.
Kelleher, Joe, Chief, Chemical Systems Section, Bureau of Wastewater Facih'ties Design, Division
of Water, New York Department of Environmental Conservation, telephone conversation,
11 May 1993.
Krueger, Thomas J., The Iron and Steel Industry Consent Decree: Implementing the Bubble Policy
Under the Clean Water Act," Virginia Journal of Natural Resources Law, vol. 4,1984, pp. 155-
183.
Landry, Ted, U.S. Environmental Protection Agency, Region 1, Wastewater Management Branch,
Water Management Division, telephone conversation, 11 May 1993.
Liu, Larry, U.S. Environmental Protection Agency, Region 3, Permits Enforcement Branch, Water
Management Division, telephone conversations, May and September through December
1993; letters 3 November 1993 and 24 November 1993.
McCormick, Kurt, U.S. Environmental Protection Agency, Region 8, Pretreatment Coordinator,
NPDES Branch, Water Management Division, telephone conversation, 11 May 1993.
McNiel, Steve, Environmental Scientist, Division of Water Quality, Utah Department of
Environmental Quality, telephone conversation, 17 May 1993.
Moniot, J. David, General Manager, Environmental Affairs, USX—US Steel Group, telephone
conversations, 31 August 1993 and 16 November 1993.
Moore, Tammy, U.S. Environmental Protection Agency, Region 4, Chief, South Area Permits Unit,
NPDES Branch, Water Management Division, telephone conversations, May 1993.
-------
Nordlund, Victor V., U.S. Steel, Gary, Indiana, personal communications, November 1993 through
February 1994.
Ohio Environmental Protection Agency, telephone conversations with various personnel (Jenny
Leshnock, Mark Mann, John Owen, Bob Phelps), September through November, 1993.
Olashuk, John, Environmental Engineer, National Steel Corporation, telephone conversation, 2
December 1993.
Palmisano, John, AER * X, Washington, DC, telephone conversation, 3 September 1993.
Palmisano, John and Debora Martin. "The Use of Nontraditional Control Strategies in the Iron and
Steel Industry: Air Bubbles, Water Bubbles, and Multimedia Based Control Strategies,"
prepared for presentation at the 77th annual meeting of the Air Pollution Control
Association, San Francisco, CA, June 24-29,1984, p. 13.
Pennsylvania Department of Environmental Resources, telephone conversations with various
personnel (Cliff Dashti, Carol Mensing, Lisa Spano), August through November 1993.
Perander, Donald R., Senior Staff Engineer, Armco Steel Company, personal communications,
November 1993 through February 1994.
Potvin, Lowell, Environmental Engineering, Rouge Steel, personal communications, December 1993
through February 1994.
Ried, Lucy, U.S. Environmental Protection Agency, Enforcement Division, Office of Wastewater
Enforcement and Compliance, computer diskettes containing information from Permit
Compliance System; telephone conversations, April through November 1993
Rubin, Marvin B., U.S. Environmental Protection Agency, Chief, Energy Branch, Engineering and
Analysis Division, Office of Science and Technology, Office of Water, telephone
conversation, 4 February 1994.
Samples, Dr. William, Manager, Engineering and Environmental Control, Wheeling Pittsburgh Steel
Corporation, telephone conversation, 2 December 1994.
Serjeantson, Richard, editor, Iron and Steel Works of the World, 10th Edition, 1991, Meal Bulletin
Books, Ltd., Surrey, United Kingdom.
Steel Manufacturers Association, telephone conversation, 21 May 1993.
Steiner, Bruce, American Iron and Steel Institute, telephone conversations, 29 April 1993,21 May
1993.
Strassler, Eric, U.S. Environmental Protection Agency, Engineering and Analysis Division, Office
of Science and Technology, Office of Water, telephone conversation, 2 February 1994.
-------
Summers, Ralph, U.S. Environmental Protection Agency, Region 7, Permits and Compliance
Section, Water Compliance Branch, Water Division, telephone conversation, 24 May 1993.
Sweeney, Philip, U.S. Environmental Protection Agency, Region 2, Section Chief, Permits
Management Section, Water Permits and Compliance Branch, Water Management Division,
telephone conversation, 11 May 1993.
Temple, Barker & Sloane, Inc. The Effect of the Water Bubble Policy on Individual Iron and Steel
Facilities," prepared for U.S. EPA, Office of Planning and Evaluation, April 1981.
U.S. Environmental Protection Agency, Permit Compliance System Data Element Dictionary, 1
December 1992, (PCS-DD92-2.02).
Waligura, Tom, Assistant Manager, Environmental Control, Wheeling Pittsburgh Steel Corporation,
telephone conversations, 2 December 1994 and 22 February 1994.
Wisniewski, Leonard D., formerly of Republic Steel, personal communications, November 1993
through February 1994.
Zacarchuk, Leonard, PMAC, personal communications, September 1993 through February 1994.
-------
Appendix A
ACTIVE IRON AND STEEL INDUSTRY PERMITS
IDENTIFIED USING THE ETA'S PERMIT COMPLIANCE SYSTEM
-------
Z2
AL0000027
AL0000485
AL0000680
AL0001155
AL0001554
AL0001767
AL0003247
AL0003417
AL0003646
AL0003735
AL0025216
AL002S321
AL0050164
AL0050776
AL0054941
AL0055239
AL0056499
AR0034550
AR0036552
AR0038181
AR0039730
AR0046523
CA0005002
CA0005690
CA0027928
CA0028282
CA0029513
CA0082511
CA010S899
C00000621
CT0000132
CT0000159
Facility Name
SOU RECLAMATION, COLBERT CO
APPLIED INDUSTRIAL MAT CORP
KOPPERS D4D INC, WOODWARD FAC
NATL STANDARD, COLUMBIANA
SMI STEEL INC, BIRMINGHAM
EMPIRE COKE CO, TUSCALOOSA
SLOSS INDUSTRIES CORPORATION
ABC COKE DFWDRUMMOND CO INC
USX CORPAISS FAIRHELD WORKS
BIRMINGHAM STEEL CORPORATION
GLOBE METALLURGICAL, SELMA
HART & COOLEY, HUNTSVILLE
REYNOLDS METALS CO
POLYMER COIL COATER, FAIRFIELD
TUSCALOOSA STEEL CORP.
GULF STATES STEEL INC. GADSDEN
HANNA STEEL CORPORATION
ARKANSAS STEEL ASSOCIATES
BEKAERT STEEL WIRE CORP-VAN BU
DAIWA STEEL TUBE INDUSTRIES CO
QUANEX CORP-FT SMITH
MAVERICK TUBE CORP.
uss-posco/prrrsBURG WORKS
CONTL-WHTTE CAP
KAISER STEEL CORP.
U.S. NAVY
PASS METAL COMPANY
STANLEY-BOSTITCH, INC
MORTON INTERNATIONAL
CF&I STEEL, L.P.
BARNES GROUP INC-STEEL DIVISION
ATLANTIC WIRE CO.
City Name
SHEFFIELD
BRIDGEPORT
DOLOMITE
COLUMBIANA
BIRMINGHAM
TUSCALOOSA
BIRMINGHAM
BIRMINGHAM
FAIRFIELD
BIRMINGHAM
SELMA
HUNTSVILLE
SHEFFIELD
FAIRFIELD
TUSCALOOSA
GADSDEN
FAIRFIELD
NEWPORT
VAN BUREN
PINE BLUFF
FORT SMITH
BLYTHEVILLE
PITTSBURG
PUEBLO
BRISTOL
BRANFORD
State
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AR
AR
AR
AR
AR
CA
CA
CA
CA
CA
CA
CA
CO
CT
CT
Region
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
6
6
6
6
6
9
9
9
9
9
9
9
8
1
1
Number
ofOudalb
1
2
2
1
3
1
3
5
IS
2
1
1
1
2
2
1
1
2
3
3
3
3
1
1
1
1
1
1
1
2
1
1
A-l
-------
Pcraut
Number
CT0000612
CTO001601
CT0001694
CT0002399
CT0002623
CT0003042
CT0003573
CT0003701
CT0021822
CT0022331
CT0022926
CT0022969
CT0022977
CT0023191
CT0024848
CT0024970
CT0024996
CT0025046
DE0000264
DEOOS1021
FL0001139
FL0002771
FL0030121
FL0041840
GA0000230
IA0003352
IA0003841
IA0061972
IA0072818
ILD000329
IL0000612
IL0001309
Faculty Name
HOLO-KROME CO
DRAWN METAL TUBE COMPANY
CONSOLIDATED INDUSTRIES
ADVANCED PRODUCTS CO.
RISDON MFG. COMPANY
CARPENTER TECH CORP-STEEL DIV
UNION CARBIDE CORP-MATLS-SYS
ALLEGHENY LUDLUM STEEL
NEWMET PRODUCTS
LOOS & CO
SMITH GATES CORP
ARISTOL INC
J&S METALS INC
HOUSATONIC WIRE CO INC
IJ. RYAN CORPORATION
PLASMA COATINGS, INC
PLASTON1CS, INC.
MORIN COIL COATING CO., INC.
PHOENIX STEEL CORP CLAYMONT PT
CmSTEEL USA INCORPORATED
FL WIRE & CABLE JAX
CLEANERS HANGER CO.- JAX
ADCOM WIRE-IAX
WELLSTREAM CORPORATION
GEORGIA TUBING CORP.
KEOKUK FERRO-SIL, INC.
NORTHERN ENGRAVING CO
NORTH STAR STEEL COMPANY
KEOKUK FERRO-SILJNC.-LEACHATE
NATIONAL STEEL-GRANITE CITY
LACLEDE STEEL-ALTON
TSC ENTERPRISES, INC.
City Name
WEST HARTFORD
THOMASTON
CHESHIRE
NORTH HAVEN
D ANBURY
READING
NORTH HAVEN
IVORYTOWN
FARMINGTON
FAIRFIELD
FORESTVILLE
SEYMOUR
PLANTS VILLE
WATERBURY
HARTFORD
BRISTOL
CLAYMONT
JACKSONVILLE
JACKSONVILLE
JACKSONVILLE
PANAMA CITY
CEDAR SPRINGS
KEOKUK
KEOKUK
GRANITE CITY
ALTON
LEMONT
State
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
CT
DE
DE
FL
FL
FL
FL
GA
IA
LA
LA
IA
IL
IL
IL
Region
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
3
3
4
4
4
4
4
7
7
7
7
5
5
5
Number
ofOutfaBs
4
2
5
2
3
5
1
I
1
1
1
1
1
1
1
1
1
1
1
1
6
4
2
1
2
8
1
1
1
5
1
5
A-2
-------
Number
IL0001678
IL0002101
IL0002I19
ILOQ02S26
IL0002593
IL0002631
IL0002674
IL0002691
IL0003751
IL0003794
IL00048S5
IL0035297
ILOOS9234
IL0060968
IL0061816
IL0061891
IL0062S11
IL0069779
IN0000094
IN000017S
IN0000205
IN0000281
IN0000337
IN0000639
IN00006SS
IN0001074
IN000129S
IN0001481
IN0002445
D40002909
IN0003107
IN0004278
Facility Name
CHS ACQUISITION CORP
ACME STEEL CO.-CHICAGO
ACME STEEL CO.-RIVERDALE
KEYSTONE STEEL AND WIRE
LTV STEEL-CHICAGO
LTV STEEL-HENNEPIN
AMERICAN STEEL AND WIRE-JOLIET
USX-USS SOUTH WORKS
ATWOOD VACUUM MACHINE CO
NORTHWESTERN STEEL AND WIRE
CO
ST. CHARLES ACQUISITION LMTD
BIRMINGHAM BOLT COMPANY, INC
PnrSBURG TUBE-INTL DIV
AMEROCKCORP
ROCK PLASTIC PRODUCTS
ROCKFORD BOLT & STEEL CO
RAYNOR MANUFACTORING CO.
RYERSON STEEL COIL-ELK GROVE
INLAND STEEL COMPANY
BETHLEHEM STEEL CORPORATION
LTV STEEL COMPANY
USX CORP, USS GARY WORKS
NATIONAL STEEL, MIDWEST DIV.
UNIVERSAL TOOL AND STAMPING
ITT AEROSPACE/OPTICAL DIVISION
LANDIS A OYR METERING, INC.
INDIANA STEEL & WIRE DIVISION
FAIRFIELD MANUFACTURING
MIDSTATES WIRE
CONTINENTAL STEEL CORPORATION
UNITED TECH. AUTOMOTIVE, BSD
WARSAW BLACK OXIDE
City Name
CHICAGO HEIGHTS
CHICAGO
RIVERDALE
PEOR1A
CHICAGO
HENNEPIN
JOUET
CHICAGO
STOCKTON
STERLING
ST. CHARLES
BOURBONNAIS
FAIRBURY
ROCKFORD
ROCKFORD
ROCKFORD
DIXON
ELK GROVE VILLAGE
EAST CHICAGO
CHESTERTON
EAST CHICAGO
PITTSBURGH
PORTAGE
BUTLER
FORT WAYNE
LAFAYETTE
MUNCIE
LAFAYETTE
CRAWFORDSVILLE
INDIANAPOLIS,
UNION CITY
BURKET
State
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IL
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
Region
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
S
5
S
S
S
5
S
S
Number
ofOutfalb
I
6
S
V
4
3
2
10
2
4
2
2
1
I
1
1
1
1
38
10
16
33
11
3
1
4
2
2
4
4
4
'1
A-3
-------
BtMMB**
• uum
Number
IN0004847
IN0032352
IN0038172
IN0045284
IN0046248
INOOS0415
INOOS1136
INOOS2302
IN0053732
IN0054488
IN0054682
IN0109541
KY0000485
KY0000507
KY0000558
KY0001S71
KY0002712
KY0003531
KY0028720
KY0033979
KY0035394
KY0043168
KY00492SS
KY0058301
KY0060399
KY0072231
KY0092118
KY0094293
KY0095877
KY0096482
KY0097781
KY0098221
Facility Name
PLYMOUTH TUBE CO.
DELTA FAUCET
ROLL COATER, INC.
ALLEGHENY LUDLUM STEEL
NUCOR FASTENER PLANT
SOMMER METALCRAFT CORP
VULCRAFT DIV. .NUCOR CORP.
B & B CUSTOM PLATING
FEENY MANUFACTURING COMPANY
U.S. ARMY RESERVE TRAINING CTR
NUCOR STEEL
RANDALL DIV. OF TEXTRON, INC.
ARMCO STEEL CO LP
CONTECH CONST PROD INC
ARMCO INC COKE PLT
GREEN RIVER STEEL
NEWPORT STEEL CORP WILDER PLT
SKW METALS & ALLOYS INC
SKILCRAFT MFC CO
KY ELECTRIC STEEL CO
FLORIDA STEEL CORP
LLOYDS MECHANICAL ERECTION
ROLL FORMING CORP SHELBYVILLE
PLYMOUTH CO
ARMCO STEEL NORTON FOUNDRY
NORTH STAR STEEL KY
WORLDSOURCE COIL COATINGS INC
STEEL TECHNOLOGIES INC
NORTH AMERICAN STAINLESS
BUNDY CORP
INDUSTRIAL POWDER COATING
DOFASCO INC GALLATOJ CO STEEL
City Name
WINAMAC
GREENSBURG
KINGSBURY
NEWCASTLE
ST. JOE
CRAWFORDSVILLE
ST. JOE
HOAGLAND
MUNCIE
KINGSBURY
CRAWFORDSVILLE
MORRISTOWN
ASHLAND
ASHLAND
ASHLAND
OWENSBORO
NEWPORT
CALVERT CITY
BURLINGTON
ASHLAND
LOUISVILLE
OWENSBORO
SHELBYVILLE
HOPKINSVILLE
ASHLAND
CALVERT CITY
HAWESVILLE
EMINENCE
CARROLLTON
CYNTHIANA
NORWALK
HAMILTON ONT L8N
3JS
State
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
IN
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
KY
Region
5
5
5
5
5
5
5
5
5
5
5
5
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
Number
of Outfalls
2
2
2
3
1
1
2
1
1
1
4
3
30
2
5
8
17
4
1
5
1
1
2
5
4
4
6
1
12
2
1
1
-------
FfcffOUt
— • —
•••••m
LA0006777
LA0026638
LAOOS5859
LA0061867
LA0063924
LA0065862
LA0084123
LA0092878
LA0094129
MA0000647
MA0002411
MA0002721
MA0003336
MA0005801
MA0022471
MA0026743
MA0027375
MD0000981
MD0001201
MD0001694
MD0001970
MD0024848
NQ0001571
MI0001902
MI0002313
MI0002399
MI0002755
MI0003361
MI0004219
MI0004227
Faculty Nwnc
STUPP CORP-E BATON ROUGE
US STEEL SUPPLY HOUSTON DISTRI
LAFAYETTE WELL TESTING-LAFAYET
AMF TUBOSCOPE INC-AMELIA
BAKER HUGHES VETCO SERVICES
CAMERON IRON WORKS- VILLE
PLATT
HOBSON GALVENIZING/POWER
STRUC
WESTSIDE COATING SERVICES INC-
ENEROY COATINGS CO. INC.-HARVE
EASTERN ETCHING & MFC CO
SIMPLEX TIME RECORDER COMPANY
INDUSTRIAL CHROMIUM CORP.
TELEDYNE-RODNEY METALS
TREMONTNAILCO
FALL RIVER PLATING CO.
COATINGS ENGINEERING CORP
RATHBONE CORPORATION
EASTERN STAINLESS CORP.
BETHLEHEM STEEL CORP SPARROW
P
MARYLAND SPECIALTY WIRE. INC
ARMCO STAINLESS: ALLOY PRODUCT
PITTSBURG-DES MOINES STEEL COM
BESSERCO
QUANEX CORP-MICH SEAMLESS
TUBE
NAT STEEL CORP-GLS-ECORSE
MCLOUTH STEEL-TRENTON
HASTINGS BUILDING PRODUCTS
FORD-ROUGE MFG COMPLEX
"HOFMANN IND-MICH TUBE DIV
MCLOUTH STEEL-GIBRALTAR
City Name
BATON ROUGE
CHICOPEE
GARDNER
HOLYOKE
NEW BEDFORD
WAREHAM
SUDBURY
PALMER
BALTIMORE
SPARROWS POINT
COCKEYSVILLE
BALTIMORE
BALTIMORE
ALPENA
SOUTH LYONS
ECORSE
TRENTON
HASTINGS
DEARBORN
EAU CLAIRE
GIBRALTAR
State
LA
LA
LA
LA
LA
LA
LA
LA
LA
MA
MA
MA
MA
MA
MA
MA
MA
MD
MD
MD
MD
MD
MI
MI
MI
MI
MI
MI
MI
MI
Region
6
6
6
6
6
6
6
6
6
1
1
1
1
1
1
1
1
3
3
3
3
3
5
5
5
5
5
5
5
5
Number
of Outfalls
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
2
10
2
5
1
2
1
14
13
1
7
1
f
A-5
-------
PfefDlt
Number
MI0026778
MI0026794
MHW27596
MKM27812
MI0028461
MI0039179
MI0042269
MI0043S24
MI0043991
MI0044415
KQ0044539
MI0047S71
MI0048747
MN0001325
MO0001627
MO0101231
MO01 11635
MO01 11643
MO01 12101
MO0112119
MS003N21
NC0065064
NE0111287
NE01 14626
NE0123846
NE0128082
NJ0000035
NJ0002613
NJ0003719
NJ0023523
NJ0031178
NJ0031186
Vtdtoy Name
NAT STEEL CORP-GLS-80" MILL
NAT STEEL CORP-GLS-MICH PLT
NAT STANDARD-LAKE ST
HITACHI MAGNETICS CORP
QUANEX CORP-MAC STEEL DIV
NAT STANDARD-CITY COMPLEX
SUMTTEC INC
ROUGE STEEL CO
ROOD INDUSTRIES INC
ROUGE-USX CORP-DOUBLE EAGLE
JACK-POST CORP
SPECTRUM IND INC
GOLD STAR COATINGS INC
PEERLESS CHAIN CO
BOHN AND DAWSON INC.
BULL MOOSE TUBE CO.
STEEL PROCESSORS DIVISION
HUTCHENS INDUSTRIES
TALBOT INDUS INC PLANT II
TALBOT INDUS INC PLANT I
COPIAH COUNTY INDUSTRIAL PARK
RICHTER PRECISION, INC.
NUCOR STEEL NORFOLK
VULCRAFT DIVISION, NUCOR CORP.
GREAT PLAINS POLYMERS, INC.
INDUSTRIAL MACHINE SPECIALTIES
NATIONAL-STANDARD COMPANY
OKONTTE COMPANY
METAL IMPROVEMENT CO INC
OKONITE COMPANY THE
RARITAN RIVER STEEL COMPANY
ECD1NC
City Name
ECORSE
ECORSE
MILES
EDMORE
JACKSON
NILES
BENTON HARBOR
DEARBORN
STURGIS
DEARBORN
BUCHANAN
GRAND RAPIDS
WEST BRANCH
WINONA
ST. LOUIS
GERALD
SPRINGFIELD
SPRINGFIELD
NEOSHO
NEOSHO
HAZLEHURST
GREENSBORO
NORFOLK
NORFOLK
OMAHA
LINCOLN
NILES
RAMSEY
CARLSTADT
RAMSEY
PERTH AMBOY
HILLSIDE
Slate
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MI
MN
MO
MO
MO
MO
MO
MO
MS
NC
NE
NE
NE
NE
NJ
NJ
NJ
NJ
NJ
NJ
Region
5
5
5
5
S
5
5
5
5
5
5
5
5
5
7
7
7
7
7
7
4
4
7
7
7
7
2
2
2
2
2
2
Number
of Outfalls
2
4
4
3
3
5
1
20
1
2
1
1
1
1
1
3
2
2
2
2
2
1
8
1
3
2
2
17
3
1
2
2
A-6
-------
Ftcnut
Hunter
NJ0032611
NJ0035807
NJOOS2931
NJ0062464
NM00204«0
NY0000787
NY0000825
NY0001368
NY0002399
NY0003034
NY0003395
NY0003719
NY0004073
NY0007081
NY0007129
NY0025453
NY0030210
NY0072231
NY0075833
NY0075884
NY0078221
NY0083623
NY0084689
NY0084841
NY0086495
NY009784S
NY0108090
NY0108189
NY0108359
NY0108626
NY0108979
FacffilyNuie
NATIONAL METALLIZING
APLHA CHEMICAL & PLASTICS CO
CARPENTER TECHNOLOGY-TUBE
DIV.
EAST COAST SPRAYING INC
AMERICAN SMELT & REF CO-PORT N
JORDAN ROAD INDUSTRIAL DIV
SPECIALTY METALS DIV
LACKAWANNA FACILITIES
TONA WANDA COKE CORP
ENARC-O MACHINE PRODUCTS INC
VALEO ENGINE COOLING SYSTEMS
ELLICOTT (T) SD#6
AIR FORCE PLANT #59
AL TECH SPECIALTY STEEL CORP
SPECIAL METALS CORP
NAVAL WEAPONS INDUST DOD 446
DOWCRAFT CORPORATION
HADCO CORP
STANDARD MICROSYSTEMS CORP.
E.B. STIMPSON CO., INC.
R S M ELECTRON POWER INC.
SIVACO NEW YORK
MARKIN TUBING INC
AUTH ELECTRIC CO INC
EG&G ROTRON INC
OAK-MTTSUI, INC
DOVER FINDINGS INC.
JOINING MATERIALS &. ANALYSIS
AMERICAN TECH. CERAMICS-STEPAR
. PCK TECHNOLOGY
MERCURY AIRCRAFT INC
City Name
CRANBURY
NEWARK
READING
NORTH BERGEN
VANADIUM
SKANEATELES FALLS
SYRACUSE
LACKAWANNA
TONAWANDA
HONEOYE FALLS
JAMESTOWN
CELORON
JOHNSON CITY
WATER VUET
NEW HARTFORD
CALVERTON
FALCONER
OWEGO
HAUPPAUGE
BAYPORT
DEER PARK
TONAWANDA
WYOMING
DEER PARK
WOODSTOCK
HOOSICK FALLS
SAINT JAMES
DEER PARK
HUNTINGTON
STATION
MELVILLE
HAMMONDSPORT
Stale
NJ
NJ
NJ
NJ
NM
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
Region
2
2
2
2
6
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Numbcf
of OutfaDs
1
1
2
1
1
2
1
54
7
1
3
3
4
20
8
4
8
1
2
2
3
5
1
1
3
5
2
3
2
2
3
A-7
-------
VhMWMt
1 U 11111
NY01 10701
NY0171638
NY0191809
NY0191868
NY0199401
NY0204374
NY021885S
OH0000426
OH0000850
OH00009S7
OH0001295
OH0001562
OH0002160
OH0004006
OH0004171
OH0004219
OH0004260
OH0004910
OH0004995
OH0005312
OH0005606
OHOOOS622
OH0006068
OH0006840
OH0006858
OH0006912
OH0006921
OH0006939
OH0007188
OH0008338
OH0009989
OH0009997
Fatitity Name
API ELECTRONICS, INC
MENNEN MEDICAL INC
SPIELMAN, MICHAEL
CERAMASEAL INC O.P.D. BLDG.
NUMAX ELECTRONICS
HERITAGE CUTLERY. INC
THE VIRTIS CO INC
MOEN INCORPORATED
LTV STEEL COMPANY, INC.
LTV STEEL COMPANY, INC.
LTV STEEL COMPANY, INC.
USS/KOBE STEEL CO
AMERICAN STEEL AND WIRE CORP.
ELKEM METALS COMPANY
THE TIMKEN COMPANY
TIMKEN COMPANY
ARMCO INC.
ARMCOINC.
THE ROBERTSON FENCE COMPANY
EATON CORPORATION
GREER STEEL COMPANY
NCR CORPORATION
NEW BOSTON COKE CORPORATION
ARMCOINC.
ARMCO INCORPORATED
REPUBLIC ENGINEERED STEELS
REPUBLIC ENGINEERED STEEL
REPUBLIC ENGINEERED STEEL
J&L SPECIALTY PRODUCTS CORP
COPPERWELD CORP
ARMCO STEEL COMPANY L. P.
ARMCO STEEL COMPANY L. P.
OtyNune
HAUPPAUGE
CLARENCE
HUDSON
NEW LEBANON
HAUPPAUGE
BOLIVAR
GARDINER
ELYRIA
CLEVELAND
CLEVELAND
ELYRIA
LORAIN
CUYAHOGA HTS
MARIETTA
WOOSTER
CANTON
COSHOCTON
DOVER
MT.STERLING
MASSILLON
DOVER
NEW BOSTON
MANSFIELD
ZANESVILLE
CANTON
CANTON
MASSILLON
LOUISVILLE
SHELBY
MIDDLETON
MIDDLETOWN
State
NY
NY
NY
NY
NY
NY
NY
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
Region
2
2
2
2
2
2
2
S
5
5
S
5
S
S
5
S
5
5
5
5
5
S
5
5
5
5
S
5
5
5
5
5
Number
of Outfalls
2
4
4
5
1
2
2
4
7
32
2
22
3
10
6
11
3
6
2
2
6
4
8
13
4
20
3
5
6
15
5
25
A-8
-------
UB««B£*
rCTDU
Nunfter
OH00104S1
OH0011207
OH0011266
OH0011274
OH0011312
OH0011321
OH0011339
OH0011347
OH0011355
OH0011363
OH0011371
OH0011878
OH0012122
OH0012572
OH0031437
OHOOS1802
OHOOS1853
OH0052329
OH0052701
OH0054003
OH0057991
OH0079898
OH00838S2
OH0092444
OH0101079
OK0034193
OK0041912
OR0000451
OR0000469
OR0027260
OR0027693
OR0030180
Facility None
ARMCO INC.
CSC INDUSTRIES, INC.
WARREN CONSOLIDATED IND
LTV STEEL COMPANY
LTV STEEL COMPANY, INC.
LTV STEEL COMPANY
WHEELING PTTTSBURO STEEL
WHEELING-PITTSBURGH STEEL
WHEELING PITTSBURG STEEL
THOMAS STEEL STRIP CORP.
WHEELING PITTSBURG STEEL
BABCOX AND WILCOX
OHIO FERRO-ALLOYS CORP.
OHIO FERRO ALLOYS - BRILLIANT
SPS TECHNOLOGIES
KALT MANUFACTURING CO
THE HOOVER COMPANY
SPENCER MANUFACTURING CO.
NATIONAL STEEL SERVICE CEN.
MARION STEEL COMPANY
SIMS BROTHERS INC.
ZIMNOX COAL CO
BRAINARD ACQUISITION CORP
MERCURY STAINLESS INC
WARREN CONSOLIDATED INDUSTRY
SOUTHWEST TUBE MFC CO-SAND SPR
PARAGON INDUSTRIES, INC.-SAPUL
OREGON STEEL MILLS INC
OREGON STEEL MILLS INC
CASCADE STEEL ROLLING MILLS
> SCHNTTZER STEEL PRODUCTS CO
PACIFIC FABRICATORS INC
CJtyNunc
PIQUA
WARREN
NILES
WARREN
YOUNGSTOWN
CAMPBELL
STEUBENVILLE
MINGO JUNCTION
WARREN
YORKVILLE
ALLIANCE
CANTON
CLEVELAND
N.RIDGEVILLE
NORTH CANTON
SPENCER
TOLEDO
MARION
MARION
WARREN
MASSILLON
WARREN
SAND SPRINGS
PORTLAND
PORTLAND
MCMINNVTLLE
PORTLAND
PORTLAND
Sute
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OK
OK
OR
OR
OR
OR
OR
Region
5
S
5
5
5
5
5
5
5
5
5
5
5
5
S
5
5
5
5
5
S
5
S
5
S
6
6
10
10
10
10
10
Number
ofOutfaDa
3
1
3
21
3
7
2
10
20
7
7
3
2
I
I
1
1
1
1
3
1
1
6
5
21
2
1
|
1
1
1
1
-------
Pctmt
Number
PA0000264
PA0000868
PA0001406
PA0001481
PA0001554
PA0001562
PA0001660
PA0001902
PA0002046
PA0002160
PA0002429
PA0002437
PA0002585
PA0002593
PA0002607
PA0002721
PA0002739
PA0002879
PA0002887
PAOOQ2992
PA0003000
PA0003239
PA000325S
PAOOQ3603
PA0003620
PA0003697
PA0003S75
PA0003S91
PA0004073
PA00041S4
Facility Name
WESTERN PA WATER CO-NEW
CASTLE
WHEATLAND TUBE-CO
BRAEBURN ALLOY STEEL DIV PLANT
SHARON STEEL CORPORATION
MONESSEN, INC.
WHEELJNG-PGH STEEL CORP-ALLEN
EDGEWATER CORP
JESSOP STEEL CO WASH PLANT
TELEDYNE PITTS TOOL STEEL
PITTSBURGH TUBE CO-MONACA
SHARON STEEL-FARELL
SHENANGO INC-NEVILLE
COKE&IRON
TELEDYNE VASCO COLONIAL PLANT
TELEDYNE SCOTTDALE PLANT
TELEDYNE CARNEGIE PLANT
WASHINGTON STEEL CORP
WASHINGTON STEEL CORP
UNION ELEC STEEL CORP-HARMON
UNION ELEC STEEL CORP-CARNEGIE
BETHLEHEM STEEL
CORP-JOHNSTOWN
UNITED DOMINION INDUSTRIES INC
BABCOCK & WILCOX CO TUB PROD
LATROBE STEEL COMPANY
ARMCO STANILESS & ALLOY
PRODUC
PITTSBURGH FLATROLL CO.
CYTEMP SPECIALITY STEEL DIVISI
US STEEL CORP - JOHNSTOWN
US STEEL-IMPERIAL WORKS
USS IRVTN PLANT
BLAIR STRIP STEEL CO NEWCASTLE
City Name
NEW CASTLE
WHEATLAND
PITTS.
GREENVILLE
FARRELL
WHEELING
OAXMONT
WASHINGTON
MONACA
MONACA
SHARON
PITTSBURGH
MONACA
PITTSBURGH
PITTSBURGH
WASHINGTON
WASHINGTON
CARNEGIE
CARNEGIE
JOHNSTOWN
CHARLOTTE
KOPPEL
LATROBE
BRIDGEVILLE
PITTSBURGH
TTTUSVILLE
PITTSBURGH
PITTS
DRAVOSBURG
NEWCASTLE
State
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
Region
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
Number
of Outfalls
1
I
1
6
6
12
1
3
1
1
13
9
2
1
1
1
1
1
1
16
1
3
1
6
4
1
1
1
<)
1
A-10
-------
Permit
Nimter
PA0004278
PA0004464
PA0004472
PA0004766
PA0005240
PA00057S4
PA0005762
PA0006114
PA0006131
PA0006238
PA0006327
PA0006335
PA0006351
PA0006378
PA0007889
PA0008095
PA0008184
PA0008303
PA0008575
PA0009164
PA0009S98
PA0009725
PA0011011
PA0011177
PA0011436
PA0011568
PA00118S1
PA0012441
PA0013056
PA0013129
PA0013463
Faculty Nine
STANDARD LAFARGE
USX CORP-NATIONAL WORKS
USSJMV. OF USX CORPORATION
NATIONAL FORGE CO-IRVINE DIV
TELEDYNE VASCO LATROBE
J&L SPECIALTY PRODUCTS CORP
ELECTRALLOY CORP
LTV STEEL (ALJQUIPPA)
LTV STEEL COMPANY
NAPCO INC VALENCIA
ALLEGHENY LUDLUM STEEL CORP
KOPPEL STEEL CORP
CYCLOPS CORPS SAWMILL TUBULAR
CYCLOPS CORP
ALUMINUM COMPANY OF
AMERICA-LE
MILTON MFG CO DIV OF CECO CORP
WHARTON, TAYLOR
BETHLEHEM STEEL-STEELTON
WILLIAMSPORT WIREROPE WORKS,
STANDARD STEEL DIV OF FREEDOM
SANDVIK STEEL INC SCRANTON WKS
JERSEY SHORE STEEL CO PLANT
PLYMOUTH TUBE COMPANY
BETHLEHEM STEEL CORP
BETHLEHEM
HANDY HARMAN TUBE CO
LUKENS STEEL CORP COATESVILLE
SUPERIOR TUBE CO NORRISTOWN
DAILY CORP A RUSSEL ENTERPRISE
PHOENDC PIPE & TUBE
. CARPENTER TECHNOLOGY
USX, INC - FAIRLESS HILLS
City Name
CANFIELD
LORAIN
CLAIRTON
IRVINE
LATROBE
MIDLAND,
OIL CITY
ALJQUIPPA
PITTSBURGH
VALENCIA
PITTSBURGH
BEAVER FALLS
SHARON
SHARON
LEBANON
MILTON
DAUPHIN COUNTY
WILLIAMSPORT
MIFFLIN COUNTY
SCRANTON
SEY SHORE
HORSHAM
BETHELEM
NORRISTOWN
COATESVILLE
MONTGOMERYVIL
PHOENIX VILLE
BERKS COUNTY
FAIRLESS
Slate
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
Region
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
Number
ofputfelb
2
12
14
1
1
5
1
8
17
1
37
1
1
3
1
1
1
3
3
33
1
1
1
46
1
12
1
1
I
15
12
A-ll
-------
FBI nut
Number
PA0013641
PA0013820
PA0014311
PA0028037
PA003466S
PA0040274
PA0040312
PA0041378
PA0042617
PA0042781
PA0045021
PAOQ50326
PA0050440
PA0054372
PA0060364
PA0084620
PA0094S10
PA0094811
PAOW5737
PA0095796
PA0096792
PA0097870
PA0100382
FA01Q2709
PA0103411
PA0204313
PA0205109
PA0205222
PA0206121
PA0598T71
RI0001139
Facility Name
BISHOP TUBE CO-DIVISION
ALLEGHENY LUDLUM STEEL
REPUBLIC STEEL UNION DRAWN DIV
NATIONAL - STANDARD COMPANY
STANDARD STEEL SPECIALTY CO-SU
UNITED STATES STEEL CORP., VAN
MOLYCORP INC
STAR MANUFACTURING CO
UNIFORM TUBES4NC
MOUNT JOY WIRE CORPORATION
PRE FINISH METALS, INC
LUKENS STEEL COMPANY
SPRA-CO., INC.
NATIONAL ROLLING MILLS, INC.
DRESSER MANUFACTURING DIV
ORES
RICHTER PRECISION, INC.
USS STEEL EDGAR THOMPSON
USSJDIV. OF USX CORPORATION
PITTSBURGH TUBE COMPANY
PITTSBURGH TUBE COMPANY
METALTECH
LTV STEEL COMPANY
ERIE COKE CORP
SHARON STEEL CORPORATION
ELLWOOD UDDEHOLM STEEL
COMPANY
J & L STRUCTUAL INC
JOHNSTOWN CORPORATION
KOPPLE STEEL CORP
DOVERSPIKE BROTHERS COAL CO.
M. B. ENERGY, INC.
STANLEY - BOSTTTCH
City Name
FRAZER
BRACKENBRIDGE
BEAVER FALLS
MTJOY
MONACA
PITTSBURGH
WASHINGTON
HOMER CITY
COLLEGEVnJLE
MOUNT JOY
MORRISVILLE
COATESVILLE
IVYLAND
PAOLI
WELLSBORO
EAST PETERSBURG
DRAVOSBURG
CLAIRTON
MONACA
MONACA
PITTSBURGH
BEAVER
PITTSBURGH
GREENVILLE
NEW CASTLE
ALJQUIPPA
KOPPEL
PUNXSUTAWNEY
INDIANA
EAST GREENWICH
State
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
RI
Region
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
1
Number
ofOutfalb
1
12
I
1
1
1
4
1
1
1
2
1
1
1
1
1
12
9
1
1
1
1
1
1
1
1
1
1
1
1
1
A-12
-------
•». - ._ p~
irnut
ftlODDCT
RI0001449
RI0021393
RI0021423
SCOOOH31
SC0004014
SC0034029
SC0034304
SC0035238
TN0001686
TN0027715
TN0027804
TN0064661
TN00647S1
TN0067628
1X0000027
TX0003026
TX0004898
TX0007307
TX0007706
TX0008S24
TX0030031
TX0033758
TX0057371
TX006769S
TX0075370
TX007694S
TX0083178
TX008«177
TX0086576
1X0088404
TX0091227
Ratify Nine
OCEAN STATE STEEL INC
ACS INDUSTRIES INC
TECHNICAL MATERIALS, INC.
GEORGETOWN STEEL CORP
MACALLOY CORP-CHARLESTON
HUDSON INTERNATIONAL
CONDUCTOR
WISCONSIN WIRES
NUCOR STEEL
CHEMETALS
RAYOVAC MATERIALS DIVISION
FLORIDA STEEL COMPANY
MILL BUSINESS FURNITURE
TAC ALLOYS-KIMBALL PLANT
LTV STEEL COMPANY-COUNCE
LONE STAR STEEL COMPANY
QUANEX CORP-GULF STATES TUBE D
CAMERON IRON WORKS USA. INC.
TEK-RAP, INCORPORATED
US STEEL CORP-BAYTOWN
ARMCO STEEL CORP-HOUSTON
ROMAN WIRE CO-SOUTHMAYD
SULLIVAN LAND AND CATTLE CO
JONES & LAUOHLIN STEEL CORP-GA
N STAR STEEL TEXAS INC
BAKER TUBULAR SERVICES, INC
SEQUA CORPORATION-HOUSTON
STRUCTURAL METALS, INC-SEGUIN
VETO) SERVICES, INC.
GORE, W L & ASS INC
ARMCO INC GREEN BAYOU
LANDFILL
LUBRIZOL CORP- PASADENA
City Name
EAST PROVIDENCE
WOONSOCKET
LINCOLN
GEORGETOWN
CHARLESTON
INMAN
GREENVILLE
DARLINGTON
HUMPHREYS COUNTY
TIPTON COUNTY
KNOX COUNTY
PUTNAM COUNTY
KIMBALL
HARDIN COUNTY
LONE STAR
ROSENBERG
HOUSTON
HOUSTON
BAYTOWN
HOUSTON
SHERMAN
GALVESTON
GAINESVILLE
VIDOR
HOUSTON
HOUSTON
SEGUIN
AUSTIN
Slate
RI
RI
RI
SC
SC
SC
SC
SC
TN
TN
TN
TN
TN
TN
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
TX
Region
1
1
1
4
4
4
4
4
4
4
4
4
4
4
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
Number
ofOutbfo
1
1
1
1
3
1
1
1
2
4
3
3
1
4
13
4
5
2
4
8
1
1
1
8
I
2
3
1
I
1
1
A-13
-------
Pctinit
MumlHif
TX0093S13
TX0093769
1X0095427
TX0097012
TX0101729
TX0107191
UT0000361
VA0001341
VA0001589
VA0051047
WA0000744
WA0002046
WA0002861
WA0022250
WA0031305
WI0002771
WI0026417
WI0038938
WI0043877
WI0054500
WV0000167
WV0000426
WV0002330
WV0003336
WV0003425
WV0004499
WV0004502
WV0004511
WV0004634
WV0005746
WV0023281
Facility Name
CDC COATING CO-CHANNELVIEW
B & D COATING, INC.
HAWKINS INC-HOUSTON
TEX-TRACJNC DBA OLD RIVER BUL
CARGILL INC-STEEL & WIRE DIV
NORTHWESTERN STEEL & WIRE CO
GENEVA STEEL
ROANOKE ELECTRIC STEEL SALEM
ROANOKE ELECTRIC STEEL
CORPORA
C-K COMPANY
SALMON BAY STEEL CORP
SALMON BAY STEEL CORP
SILICON METALTECH, INC.
ACE GALVANIZING INC
SALMON BAY STEEL CORPORATION
NORTHERN ENGRAVING CORP
SPARTA
AMRON CORPORATION
TRENT TUBE DIVISION PLANTS 2 A
ROLLEX CORPORATION
METALLICSINC
ELKEM METALS COMPANY
AMERICAN ALLOYS, INC.
ACME FISHING TOOL CO
WEIRTON STEEL CORPORATION
SIGNODE SUPPLY CORPORATION
WHEELING-PITTSBURGH STEEL CORP
WHEELING NISSHIN STEEL CORP
WHEELING-PITTSBURGH STEEL CORP
SHARON STEEL CORPORATION
NATL STEEL CORPBROWNS ISLAND 3
WHEELING-PITTSBURGH STEEL CORP
City Name
PROVO
ROANOKE
ROANOKE
SOUTH BOSTON
BELLE VUE
SEATTLE
SEATTLE
SPARTA
WAUKESHA
EAST TROY
ELK GROVE VILLAGE
ONALASKA
ALLOY
NEW HAVEN
PARKERSBURG
WEIRTON
WEIRTON
WHEELING
FOLLANSBEE
WHEELING
SHARON
WEIRTON
WHEELING
State
TX
TX
TX
TX
TX
TX
UT
VA
VA
VA
WA
WA
WA
WA
WA
WI
WI
WI
WI
WI
WV
WV
WV
WV
WV
WV
WV
WV
WV
WV
WV
Region
6
6
6
6
6
6
8
3
3
3
10
10
10
10
10
5
5
5
5
5
3
3
3
3
3
3
3
3
3
3
3
Number
of Outfalls
1
1
1
1
1
1
8
1
1
1
1
1
1
1
1
2
2
2
2
4
10
1
1
12
2
6
5
8
3
1
2
A-14
-------
Pniuil
»-• — «- —
nuinpcr
WV0043176
WV0046744
WV0076198
WV01 11961
Fttafty Name
PITTSBURGH TUBE CO JANE LEWS
ARMCO STEEL CORP
AMERICAN ALLOYS, INCORPORATED
WHEELING PITTSBURGH STEEL CORP
City Name
JANE LEW
MIDDLETON
NEW HAVEN
WHEELING
State
WV
WV
WV
WV
Region
3
3
3
3
Number
ofOudalb
1
1
1
1
A-15
-------
Appendix B
IRON AND STEEL INDUSTRY PERMITS WITH TEN OR MORE OUTFALLS
IDENTIFIED USING THE SPA'S PERMIT COMPLIANCE SYSTEM
-------
Permit
Number
AL0003646
IL0002691
IN0000094
IN0000175
IN0000205
IN0000281
IN0000337
KY0000485
KY0002712
KY0095877
MD0001201
MI0002313
MI0002399
MI0043524
NJ0002615
NY0001368
NY0007081
OH0000957
OH0001562
OH0004006
OH0004219
OH0006840
OH0006912
OH0008338
OH0009997
OH0011274
OH0011347
OH0011355
OH0101079
PA0001562
Facility
USX CORPAJSS FAIRFIELD WORKS
USX-USS SOUTH WORKS
INLAND STEEL COMPANY
BETHLEHEM STEEL CORPORATION
LTV STEEL COMPANY
USX CORP., USS GARY WORKS
NATIONAL STEEL, MIDWEST DIV.
ARMCO STEEL CO LP
NEWPORT STEEL CORP WILDER PLT
NORTH AMERICAN STAINLESS
BETHLEHEM STEEL CORP
NAT STEEL CORP-GLS-ECORSE
MCLOUTH STEEL-TRENTON
ROUGE STEEL CO
OKONITE COMPANY
LACKAWANNA FACILITIES
AL TECH SPECIALTY STEEL CORP
LTV STEEL COMPANY, INC.
USS/KOBE STEEL CO
ELKEM METALS COMPANY
TIMKEN COMPANY
ARMCO INC.
REPUBLIC ENGINEERED STEELS
COPPERWELD CORP
ARMCO STEEL COMPANY L. P.
LTV STEEL COMPANY
WHEELING-PITTSBURGH STEEL
WHEELING PITTSBURG STEEL
WARREN CONSOLIDATED INDUSTRY
WHEELING- PGH STEEL CORP-ALLEN
City
FAIRFIELD
CHICAGO
EAST CHICAGO
CHESTERTON
EAST CHICAGO
PITTSBURGH
PORTAGE
ASHLAND
NEWPORT
CARROLLTON
SPARROWS POINT
ECORSE
TRENTON
DEARBORN
RAMSEY
LACKAWANNA
WATER VLIET
CLEVELAND
LORAIN
MARIETTA
CANTON
MANSFIELD
CANTON
SHELBY
MIDDLETOWN
WARREN
STEUBENVILLE
MINGO JUNCTION
WARREN
WHEELING
State
AL
IL
IN
IN
IN
IN
IN
KY
KY
KY
MD
MI
MI
MI
NJ
NY
NY
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
PA
EPA
Region
4
5
5
5
5
5
5
4
4
4
3
5
5
5
2
2
2
5
5
5
5
5
5
5
5
5
5
5
5
3
Number of
Outfalls
15
10
38
10
16
33
11
30
17
12
10
14
13
20
17
54
20
32
22
10
11
13
20
15
25
21
10
20
21
12
B-l
-------
Permit
Number
PA0002429
PA0002992
PA0004464
PA0004472
PA0006131
PA0006327
PA0009164
PA0011177
PA0011568
PA0013129
PA0013463
PA0013820
PA0094510
TX0000027
WV0000167
WV0003336
Facility
SHARON STEEL-FARELL
BETHLEHEM STEEL CORP
USX CORP-NATIONAL WORKS
USS.DIV. OF USX CORPORATION
LTV STEEL COMPANY
ALLEGHENY LUDLUM STEEL CORP
STANDARD STEEL DIV OF FREEDOM
BETHLEHEM STEEL CORP
LUKENS STEEL CORP COATESVILLE
CARPENTER TECHNOLOGY
USX, INC - FAIRLESS HILLS
ALLEGHENY LUDLUM STEEL
USS STEEL EDGAR THOMPSON
LONE STAR STEEL COMPANY
ELKEM METALS COMPANY
WEIRTON STEEL CORPORATION
Qty
SHARON
JOHNSTOWN
LORAIN
CLAIRTON
PITTSBURGH
PITTSBURGH
MIFFUN COUNTY
BETHELEM
COATESVILLE
BERKS COUNTY
FAIRLESS
BRACKENBRIDGE
DRAVOSBURG
LONE STAR
ALLOY
WEIRTON
State
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
TX
WV
WV
EPA
Region
3
3
3
3
3
3
3
3
3
3
3
3
3
6
3
3
il
Number of
Outfalls
13
16
12
14
17
37
33
46
12
15
12
12
12
13
10
12 „
B-2
-------
Appendix C
FEDERAL REGISTER NOTICES AND
OTHER DOCUMENTS RELATING TO
LNTRA-PLANT TRADING IN THE IRON AND STEEL INDUSTRY
-------
Thursday
May 27, 1982
Part II
Environmental
Protection Agency
Iron met 8M Manufacturing Point
Sourco Category Effluant Umtttottoiw.
Quldatima, Pretrtatmant Standard* and
Maw Souroa Paf (orinanc*. Standards
-------
23272 FoaoMl Rogbtor / Vol 47. No. 108 / ThuncUy. May P. 1M2 / Rulea and Regulation.
oftr
Some eucanente/B opposed the
condition which requires that each
outfall hew a scedflc discharge limit
because they believed that il would
preclude opportunities to implement
efficient control strategies. They
suggested lhat the Agency adopt a
bubble policy which allows effluent
limitations to be established on a
plantwide basis: Ihe so-called, -floating
bubbtc". Under Ihe suggested "floating
bubble-, dischargers would be allowed
to vary the eiix of controls at the various
outfall* within a pint an a dally.
weekly, or monthly basis, as long as the
\amwide limitation l« not exceeded
.te Agency has carefully evaluated the
Advantages and disadvantages of the
-floating bubble- and has concluded
that fixed bouts on each outfall are
necessary to ensue optimum operation
canfonsRBwalof
permit limitations: •ndJ to mlr*"*1" Ihe
administrative burdaa el the water
bubble. The ^oaang bubble would nakt
it difficult for permit authorities to
determine compliance usivg normal
aamyUng techniques. To confirm
compliance with m floating bubble
permit, the control authority would need
tlfflultueoos saamlM froa each outfall
for which limitation an established
under the policy. Reporting requirements
and mapactlon procedures would have
to be significantly modified and would
require significant additional resources.
EPA recogniies that to theory, the
flexibility to vary Ihe mix of treatment
within a plant al different times cooM
reduce (be cost of compliance ».itb this
regulation. However, despite requests to
do so. Industry representatives have not
provided any data in support of their
contention lhat the floating bubble
would allow steel Industry dischargers
to use control strategies lhat are not
feasible under a policy requiring fixed
limits oa each outfalL EPA believes Ihe
nuforMvinga associated with too
bubble policy will result boa changes in
fixed c&atrol costs. Dischargers can lake
advantage of these savings under the
policy adopted by the Age-tcy.
The Agency solicited comments on
the resource and administrative burden
that tin bubble policy Bight pUet on
permit authorities. Several i
,»r. that the policy would
present an additional burden that permit
euthoritfea would bo unable to bear. The
Agency baa Wed to design ths bubble
policy 10 minimise «• administrative
burden, r.tit the Agency hat specified
that dischargers &sat Initiate bubble
proposals at their own expense. In
addition, aa discussed above EPA has
sought to mmimixe the resource burden
by requiring that bubble permits have
Axed enforceable limits on each outfalL
Once these limitations are determined.
the cost of reviewing inspection and
•elf-monitoring reports will be
comparable to toe administrative costs
associated with traditional permit
practices.
-------
Federal Register / VoL 47. No. 103 / Thursday. May 27. 1982 / Rules and Regulations
c. Trades involving certain
suhcategory waste stxeams will be
limited.
EPA has identified certain process
subcategories with wastewaten that are
significantly different than those from
other steel industry jubcategones.
Unrestr.c:«d trades with these
subcaiegones could result m a net
increase in toxic pollutant! discharged
To ensure thai permit! issued under the
bubble policy do not result la u
increase in pollutants discharged, tha
Agency has imposed the following
subcategory limitations:
(I) Cokanaking. Pennits issued under
the bubble policy which involve trades
with cokemaJdng waatawaters will not
be allowed. The Agency believes that
the; number and amounts of toxic
organic pollutants found in cokemaJdng
wastewaten cannot be effectively
controlled under the bubble policy.
(U) Cold Fanning. Permits issued
under the bubble policy which involve
trades with cold forming wastewaten
will not be allowed. The Agency
believes that the variability and
amounts of toxic organic pollutants
associated with cold forming
wastewatars an such that it ij not
possible to ensure effective control of
toxic organic pollutants under the water
bubble policy.
2. Dischargers matt meet inter
^aaJitytlandards. A chang 1 ta the
distribution of pollutant loadings may
adversely affect water qc Jity even if
total loadings discharged do not
increase. Permit authorities may not
approve- a bubble application if it would
result in a violation, of water quality
standards.
3. Each outfaJI auat have a specific
discharge liaut Water bubble permits
may not allow limitations to be set on a
plant-wide "floating" basis. For the
reasons discussed in Section XVI of this
preamble, the Agency has decided not to
allow the policy to be applied on a
"Boating" basis.
-------
Thursday
May 17, 1984
Part VII
Environmental
Protection Agency
40 CFR Parts 403 and 420
Iron and Start Manufacturing Point
Source Category Effluent Limitations
GuldaHnast Pretreaunent Standard^ and
New Source Performance
General Pretrealment Regulations; Final
Rule
S-034W
00!l
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21024 Federal Register / Vol. 43. No. 97 / Thursday. May 17. 1934 / Rules ana Regulations
ENVIRONMENTAL PROTECTION
AGENCY
40 CF* Parts 403 and 420
[Fm. 2550-11
iron and Sttol Manufacturing Point
Source Category Effluent UmrUttona
GuMtHiiM. Pretreatment Standard*
and Now Source Performance
SlendBfdK and General Pretreetinent
Regulations
AOIMCY: Environmental Protection
Agency (EPA).
ACTION: Final regulation.
SUMMMr EPA is promulgating
modifications to the regulation which
Hauls effluent discharges to waters of
the United States and the introduction of
pollutants into publicly owned treatment
works from facilities engaged in
manufacturing iron and steel. EPA
agreed to propose these modifications in
a Settlement Agreement which resolved
the venous lawsuits brought against
EPA by the steel industry and the
Natural Resources Defense Council. Inc..
challenging the final iron and steel
industry regulation promulgated by EPA
on May 27, 1982. 47 PR 23258. This
promulgation satisfies EPA's obligations
under that Settlement Agreement.
The modifications include: (1) An
amendment to the "water babble" rule;
(2) certain modifications of the effluent
limitations guidelines for "best
practicable control technology currently
available: (BPT): "best available
technology economically achievable"
(BAT): "best conventional pollutant
control technology" (BCT): and. "new
source performance standards" (NSPS)
for direct dischargers; and (3) certain
modifications to the pretreaunent
standards for new and existing indirect
dischargers (PSES and PSNS). In
addition. EPA agreed to publish
additional preamble language regarding
the steel industry regulation. The
Agency is also promulgating an
amendment to the General Pretreatment
Regulations (40 CFR Part 403) which
permits reclassificatton of non-contact
cooling water flows contaminated with
significant quantities of pollutants from
"dilute i 'unregulated" for purposes of
the cor. u >ed waste stream formula
contained in 40 CFR { 403.6(e)
OATH: This regulation shall become
effective on fuly 2.1984.
The compliance date for the BAT
regulations is as soon as possible, bul in
any event, no later than July 1.1984. The
compliance date for new source
performance standards (NSPSI and
pretreatment standards for new sources
(PSNS) is the date inn new source
begins operations. The compliance oatc
for pretreatment stanoards tor existing
sources (PSES1 is |ulv 10.1SG5.
Under Section 509(b!UI of the Clean
Water Act. judicial review of this
regulation can be maae only by filing a
petition for review in the United Stares
Court of Appeals within W oays atter
the regulation IB considered issued for
purposes of judicial review. Under
Section 509|b)(2) of the Clean Water
Act. the requirements in this regulation
may not be challenged later in cml or
criminal proceedings brought by EPA to
enforce these requirements. In
accordance with 40 CFR 100.01 (45 FR
28048). this regulation shall be
considered issued for purposes of
judicial review «t 1:09 p.m. eastern time
on May 31.1984.
AOOnmtl; Mr. Ernst P. Hail. Effluent
Guidelines Division (WH-S52I.
Environmental Protection Agency, 401 Kn
Street SW.. Washington. D.C. 20480.
Attention EGD Docket Clerk. Proposed
Iron and Steel Rules (WH-552).
The supporting information and all
comments on this regulation are
available for inspection and copying at
the EPA Public Information Reference
Unit Room 2922 (EPA Library). The EPA
information reguletion provides that a
reasonable fee may be charged for
copying.
ro* roirmat MMPMUTION CONTACT:
Mr. Gary Amendola. Senior Iron and
Steel Industry Specialist. (218) 835-E200.
Organization of this document:
I. Legal Authority
II. Background
A. Prior Regulation
B. Challenge* to the Prior Regulation
C. Settlement Agreement
III. Response to Public Comments
IV. Modifications to the Iron «nd Steel
Manufacturing Point Source Category
Regulation
A. Alternative Effluent Limitations (Water
Bubble) {J 420-031
B. Calculation of Mass-Based Pretnauneni
Standards
C. Removal Credits for Phenols (4AAP)
(! 420.081
0. Subparu B and C—Sintering and
Ironmaking Subcaiegories
E 301 Ig) Water Quality V a nance lor
Ammonia-N and Phenols (4AAP)
K Blast Furnace Flow: Related Safety Issue
C Subpan 1—Acia Pickling Subcaiegary.
Sulfunc and Hydrochloric Acid Pickling
Segments
H Subpart |—Cold Forming Subcategory.
Cold Worked Pipe and Tube Segments
I Subpart L—Hot Coaling Subcmegory
V Amendments 10 the Preamble to Ihe
Regulation
A. Pretreatmem Issuea
B Central Treatment
\ 1 ModifiCblion to me General Prelreatmeni
Regulation, j 403.8fel
VII. Environmental Impact 01 the
Modifications to the Steei Industry
Regulation
VIII. Executive Order 12291
IX. Regulatorv Flexibility Analyst*
\ OMB Review
VJ. List of Subiecis-
A 40 CFR Part 403
B. 40 CFR Part \za
1. Legal Authority
The regulation Described in this notice
is promulgated unaer authority of
sections 301. 304. 306.307. and 501 of the
Clean Water Act (the Federal Water
Pollution Control Act Amendments of
1972. 33 USC1251 et seq., as amended
by Ihe Clean Water Act of 1977. P.L 92-
517].
II. Background
A. Prior Regulation
On January 7.1981. EPA proposed a
regulation to establish Best Practicable
Control Technology Currently Available
(BPT), Beat Available Technology
Economically Achievable (BAT), and
Beat Conventional Pollutant Control
Technology (BCT] effluent limitations
guidelines and New Source Performance
Standards (NSPS). Pretreatment
Standards for Existing Sources (PSES).
and Pretreatment Standards for New
Sources (PSNS) for the iron and steel
manufacturing point source category
[steel industry). 46 FR 1858. EPA
promulgated that steel industry
regulation on May 27.1982.47 FR 23258.
The preamble lo the final steel industry
regulation describes the history of the
ruiemaking action.
B, Challenges to the Prior Regulation
After publication of theeteel industry
regulation, certain members of the steel
industry, the American, Iron and Steel
Institute, and the Natural Resources
Defense Council. lac.. Tiled petitions to
review the regulation. Those challenges
were consolidated into one lawsuit by
the Third Circuit Court of Appeals.
(National Steel Corp. v. EPA. No. 82-
3223 and Consolidated Cases).
C. Settlement Agreement
(1) Agreement to Modifications and
Changes. On February 24,1983. the
parties in the consolidated lawsuits
entered into a comprehensive
Settlement Agreement which resolved
all issues related lo the steel industry
regulation raised by the petitioners. A£*^
result of that Settlement Agreement, the*
United States Court of Appeal issued an
order on March 9.1963 which stayed
briefing in the law suits. In Ihe
Settlement Agreement. EPA agreed lo
5-034000 OOI2rOOKI6-MAY-&*-l* S3 »0>
-------
Federal Register / Vol. 49. No. 97 / Thursday. Mav 17 19B4 / Rules and Regulations
21025
puohsri a notice 01 proposea nuemeKine
•« to SOUGH comments regarding
in modifications 10 (he final ateei
.sin- regulation. In addition. EPA
agreea 10 publish an amendment as an
interim final rule. EPA also agreed to
publish proposed additions to the
preamoifc 10 the regulation The
petitioners agreeo that. if. after EPA has
-------
21026 Federal Register / Vol. 49. No. 9: ,' Thursday. Mav 17. 1984 / Rules and Regulations
pretreatmont standards for existing anc
new sources established in 40 CFR Part
420 (iron and steei manufaclunng point
source category) are "mass-baaed"
limitations and standards. These mass-
based limitations ana standards
establish the maximum amount of a
poiiutani which may be discharged per
1.000 pounds of product. The Agency s
NPDES permit regulations. 40 CFR
I22.45(b)(2). establish a method for
denying the applicable product basis for
applying the effluent limitations and
standards for direct dischargers.
However, neither the General
Pre treat me it Regulations (40 CFR Part
403) nor the steel industry pretreatment
standards (40 CFR Part 420) presently
contain a comparable method for
deriving the production basis for those
who discharge wastewatere to publicly
owned treatment works (POTVYs).
In accordance with the Settler-ent
Agreement, the Agency is promulgating
d regulation which establishes the
method for calculating the applicable
mass-based pretreatment standard. This
regulation, in large measure, mirrors the
existing regulation by whn;r. mass-base a
effluent limitations for direct
dischargers are calculated.
C Removal Credits far Phenols (4AAP)
(§ 430.06)
EPA is promulgating ft 42046 which
specifies that pretreatment removal
credits for phenols (4AAPJ may be
granted when phenols (4AAP) is used as
an indicator or surrogate pollutant.
Under the general pretreatment
regulations, a categorical pretreatment
standard may be revised to reflect
removal of indicator or surrogate
pollutants if the standard specifies that
sucn revisions are permissible (40 CFR
403.7(a)|. The final regulation published
on May 27.1982. did not specify that
removal credits could be granted for
phenols (4AAP). The Agency believes
that the jiological treatment systems
employed at publicly owned treatment
works will, in large measure, remove
those pollutants for which phenols
(4AAP) is used as an indicator pollutant
lo the same degree as they remove
phenols (4AAP). Accordingly. EPA is
revising the steel industry regulation to
provide (hat removal credits may be
granted for phenols (4AAP).
The following preamble language is
substantially the same as the language
m the Settlement Agreement.
Removal allowance* pursuant to 40 CFR
403.7(a|(l| may be granted for phenols
(4AAP) limited in 40 CFR Part 420 when used
as an indicator or surrogate pollutant. Of
course, when phenols I4AAP) are not used as
an indicator or surrogate pollutant, removal
allowances may also be granted
D Subverts B ana C—Smtenn? cna
Irontnakine Subcategories
The modified BAT. NSPS. PSES. ana
PSNS iranmaking and sintering
limitations and standards (or lead and
zinc are slightly higher than those
contained in the final steel industry
regulation published on May 27.1982.
After promulgating the final regulation.
EPA learned that the final limitations lor
ironmaking operations (blast furnaces)
were based in part upon data obtained
at a plant with treatment operations
more extensive than the EPA model
treatment system. Therefore, these data
may not be an appropriate basis for the
limitations and standards. The
limitations and standards promulgated
today are based upon data obtained
from steelmaking operations using the
applicable BAT model treatment system.
The model treatment systems used to
develop the limitations and standards
for steelmaking operations are the same
as those considered for sintering and
ironmaking operations. Because
wastewaten from steelmaking
operations are similar in character and
treatability to wastewaie-u from
sintering and ircnmaking operations
with respect to toxic metal pollutants.
the Agency believes that it »*
appropriate to rely upon thai data in
promulgating modified lead and zinc
limitations end standards for sintering
and ironmaking operations. Volume I of
Development Document (EPA 440/1-82/
024. May 1982. pages 13.18.19. 27. 31.34.
35.40.41.46.51.55,59.63.64.66-68. and
409-427) contain* the relevant data
relating lo steelmaking operations.
EPA is modiTying the BAT limitations
and PSES for total cyanide and
establishing a new segment for existing
indirect blast furnace dischargers that
contain standards which an the same
as the generally applicable PSES except
that the promulgated ammorua-N and
phenols (4AAP) standards are less
stringent. These standards are only
applicable to the two exiating iron blast
furnace operations which discharge
their wastewater into POTWs. These
operations are located in Chicago.
Illinois and discharge their wastewater
into the Metropolitan Sanitary District
system. Compliance with the cyanide
BAT limitations and PSES could be
accomplished through the use of
waatewater treatment technologies
other than the model BAT and PSES
alkaline chlonnation technology. The
changes would, accordingly, give the
industry added flexibility. EPA is not.
however, promulgating any changes to
the BAT limitations and pretreatment
standards (except as noted above for
existing indirect dischargers) for
iimnonia-N ana ohenois (4AAP1
containeo m the final regulation.
£. 301(g) Woter Quality Variance fcr
Ammonia-N and Phenois (4AAPI
Thr avaiiabililv of vanances from th(
BAT limitations tor non-toxic
nonconventional pollutants as allowed
under section 301 (g) of the Clean Water
Act can significantly affect the cost of
compliance for a discharger. Section
301(g) variances can. however, only be
granted in cases where the granting of
the variance will not interfere with
attainment of existing water quality
standards. Certain parties lo the
Settlement Agreement have sought a
clarification regarding the availability o
section 301|g) vanances for steel
industry discharges. The following
preamble language ic substanually the
same as the language in the Settlement
Agreement.
The BIT referred to in section 301(g) o( UK
Clean Water Acl ia either la) the requiremen
applicable to the facility aa a result of the
BPT limitation contained in the steel industr
regulation, or (b) the requirement applicable
to a facility as a mull of the BPT limitation
contained in the steel industry regulation
which is or may be modified after February
24.1983 by a fundamentally different factors
("FDF") variance. (40 CFR 1Z5J1). or the net
grass provisions of the NPDES pencrt
regulations (40 CFR 12Z83(h)). Section 301fg)
variance* may be granted for ammonia-N
discharge* from Mast furnaces and from
sinter plants when ainier plant waatewaten
an treated with blast furnace westwaters.
Section 301(g) variances may alao be grantee
for phenol* (4AAP) discharges from blast
furnaces and from sinter plants when sinter
plant wastewater* are treated with blast
'furnace waatewaten if the applicant
discharging phenols performs appropriate
analyses o those contemplated by the
EPA model. Such a safety related flow
problem may result in difficulty in meeting
olast furnace mass limitations at the facility.
Safety related issues were not raised prior to
promulgation of the effluent limitations
guidelines ana were therefore, not
consiaered by the Agency m the niiemakuuj.
S-034W OOI4(OOM 16-MAV-84-14 5.» 35)
-------
Federal Register ; Vol. 49. No 9T • Thursday. May 17. 1984 / Rules and Regulations 21027
Int Ajen:.' nas nui 'i>i.r.u a en\ in r.rnaiiir
ir.s: thif ma\ re s procieni b1 a:>\ O:I.K
(aciiiK if IL apocsri mat iherr is « seir<.
•oblem ai ir.tu psrticu'sr site relate m flov,
lucdon lor the total cos! of compliance
iih the BA1 requirement including the cost
c1 remedying lite safeti prouttin is
. applicanor. fur &ucr a \ariancr
mall he in accordance wnr. ana Sdlisix Ihi
requirement ot *OCFK Pan IL'S Subpart C
C SuLpcfl I—^cidPicklinf
Subcategor, Si/If urn and Hydrochloric
Acid Pickling Segments
In accordance with me settlement
agreement the BP1 and BAT limitations
pnd NSPS. PSES and PSNS for zinc
promulgated in this regulation are
slightly higher than those contained in
the regulation promulgatec on May 27.
1982
H Subpart /—C*jid Forming
Subcategory. Ccld Worked Pwe and
Tube Segments
The regulation promulgated on May
27.1982. limned all cold worked pipe
and tube operations to cer** discharge at
each level of treatment (BFT. BAT.
NSPS. PSES. PSNS. and BCT). The
idel treatment system relied upon by
t Agency as the basis for those
limitations and standards includes
recycle of the oil or water solution and.
when appropriate, contract hauling of a
small oil solution blowdown. This
regulation permits nominal discharges of
the spent oil or water solution (rather
than contract hauling), and also
specifies that appropriate limitations
and standards for process waaiewaturs
which are nol regulated by the prior
regulation are to be developed on a
case-by-caae baais. The effluent
limitations and standards for cold
worked pipe and tube operations are
based upon the cold rolling model
treatment systems and a model flow
rate of S gallons per ton.
/. Subpan L—Hot Coating Subcategory
This regulation contains modified
effluent limitations and standards far
zinc. These limitations and standards
are based upon the same effluen:
concentration as are the zinc limitations
and standards for acid pickling
operations (0.20 mg/1) This regulation
contains a provision requiring that hot
coaling treatment facilities presently
•hievmg zinc discharge levels more
iiuwnt than the limitations and
..andards contmvc to do so. This
regulation also provides that the
limitations may be ustd as a basis for
determining alternative limitations
usioer 40 O'F. «0.03 Iweier c-uboif rule
even ror inose facilities presents
achievmp discharge levels morf
stringent men the limitations am:
standards
V. Amendment? to the Preamble to tbc
Reguiaaor
'i Freireatmeit issue:
\1) Flow Monitoring for Combine?
\Vastestrecrr. Formuic The follow-in?
preamble language is substantially the
same as tne language in the Seltlemen1
Affreernen
Unaer \ 40312'b||4J o! the Genera
P"etreaimenl Regulations, a facility mud
monitor ihp flow of regulated process »tream<.
and other streams' as necessart lo allots
use of the Combined Wa«iestream Formula
A facilily must monitor tlie flow* of us
regulated streams However, a facility can
avoid monitoring 119 othei streams
(unregulated and dilute) under this section b\
agreeing 10 oieet a mass limitetion ai least as
stringent a> the one which would be
calculated under the Contained Wastestream
Formula if these other streams were taken
into consideration. An integrated iron and
steel facility combining legulated process
streams with either unregulated or dilute
streams, or both, can avoid monitoring the
flows of those streams if it agrees to meet the
mass limit ca'eulated solely through UM of
the limits applicable to (he regulated streams
Such a limit would be as stnngenl as any
which could possibly be derived under the
formula if either the unregulated or dilute
streams, or both, wen taken into
consideration. If. however, the facility desires
lo take into account potential pollutants
contained in these unregulated or dilute
streams, monitoring of these streams will be
required to enable calculation of the
alternative limit under the formula
It should be noted that it is an entirely
different matter where concentration-baaed
rather than mass-baaed limits are involved. A
facility cannot, for example, avoid monitoring
unregulated or dilute streams by agreeing to
meet the concentration limit applicable to its
regulated ctreams. This it because
application if the formula could result in a
more stringent concentration-based limit if
the unregulated or dilute streams were taken
into ronsideration.
(2) Monitoring Data far Temporarily
Closed Plants The following preamble
language in substantially the same as
the language in the Settlement
Agreement.
The preireatntent regulations should be
construed to establish that temporarily closed
plants are required lo submit a baseline
monitoring report if recommencement o!
discharge is expected, but need nol include
the monitoring tiformatior*. -.-'r»i tnc plant
wants to submit historical uata and this it
acceptable lo the Control Aulhoru;,
Monitoring data should be submitted within a
reasonable time a'ter reopening Ine plant For
mow ciems thai are ooeraiir.fi at a recuceu
rate o: uroduclior. « corr.oleie tiaselint
"loniionng report is required Tne report
•hoUd include monuonnp data based upor.
the present average rate of production. If the
plant calculates Us limns through use of the
Combined Wastestream Formula it will be
necrssan to in lorn tne Control Authoniv of
an> significant change in the values used tc
calculate this limit See 40 CFR 403 6{ei
11981)
13] f/on Estimates fof Comomed
Wastestream Formula The fallowing
preamole language is substantially the
same as the language in the Settlement
Agreement
Flows from integrated facilities can be
estimated when it is difficult or nearl.v
impoiaiDie to monitor 'he Rows to achieve an
actual reading 40 CFR -W3.12(b|(4) (1882) lists
the Flow measurement requirements, and
stales in part that "Ihe Control Authority may
allow for verifiable estimates of these flows
| regulated streams «nd other streams
necessary to allow use of the Combined
Wastestream Formula! where luslifled b>
cost or feasibility considerations "
(4) Mass-Based and Concentration-
Based Pretreatment Standards. The
following preamble language is
substantially the same aa the language
in the Settlement Agreement.
If an integrated plant is required lo comply
with a categorical preireatment standard
expressed only in mass-based limits and with
another categorical pretreatmenl standard
expressed only in concentration-baaed limits.
a mass-based limit should be applied lo the
combined flow. To accomplish tins under the
formula, the concentration limit may be
converted to a mass limit by multiplying the
concentration limit by Ihe average or other
appropriate flow of the regulated stream to
which that limit applies
B. Central Treatment
The following preamble language is
substantially the same as the language
in Ihe Settlement Agreement.
Industry petitioners believe that they are
entitled to obtain a PDF variance under 40
CFR Part 125 subparl D for an individual
process (a) where the removal costs are
wholly out of proportion to the removal costs
considered during development of the
national limits, or (bj where other (actors
solely related to that individual process
would result in a non-water quality
environmental impact (including energy
requirements) fundamentally more adverse
than the impact considered during
development of the national limits, even
though EPA may have considered such costs
or such other factors in making its
determination pursuant to 40 CFR 42O01(b).
EPA does nol concede that petitioners
contention is a correct interpretation 01
S-OMW 001X00* I6-MA\ -64-U <3 K
-------
21028 Federal Register / Vol. 49. No. g? / Thursday. Mav 17. 1984 / Rules and Regulations
aoplicabie law. oui aces agree Ihet the
discussion in U» preamoie 14' FR 23267
(Column II (May 27.1932!) wai not intended
to preclude thia coniennon
VI. Modification to the General
Pretraatment Regulation. * 403.6(e)
In thp combmca wastestresm formula.
the term "dilution stream ' is defined In
include boiler blowaown and non-
contact cooling water streams, among
others. However, in certain
circumstances le.g . wnere recycled
cooling water ts treated with algaecides)
non-contact cooling water or boiler
blowdown could contain significant
concentrations of regulated pollutants.
The Agency today is refining the
meaning of dilution stream to address
thia situation. Where non-contact
cooling water or a boiler blowdown
stream contains a significant amount of
a pollutant, and an industrial user
combines this wastewater with its
regulated proceaa wastestreain(s) prior
la treatment, resulting in a substantial
reduction of that particular pollutant.
the Control Authority is authorized to
exercise its discretion to classify this
stream as either a dilution or an
unregulated stream. The tern "Control
Authority" refers either to the POTW if
il has an approved pretraatment
program, or to the Approval Authority
(EPA or the NPDES State) if the POTW
has no approved program
Before the Control Authority can
exercise its discretion to classify such a
stream, the industrial user must provide
engineering, production, and sampling
and analysis information sufficient to
allow a determination by the Control
Authority on how the stream should be
classified.
VTI. Environmental Impact of the
Modifications to the Steel Industry
Regulation
ETA's estimates of the industry-wide
direct discharges of toxic metals and
total cyanide under the steel industry
regulation promulgated on May 27.1982
and this regulation are presented below.
Volume i of the Development Document
contains a compilation of estimated
industry-wide discharges on a
subcaleaory specific basis. The
estimated discharges of other pollutants
limited by ine steel industry regulation
promulgates on May I". 1982 are the
«ame under this regulation. These
estimates do not take into account the
change in the water bubble rule which
would result in a decrease in the amount
of pollutants discharged at those
facilities using the rule
P*ic* REGULATION (M*v 27 I962t
B»T
Tone Mcun
i*< WO
"BOC
«U
1-1
THIS REGULATION
ppt
RAT
ToMCWMt
'II MO
iTOO
280
'00
VIII. Executive Order 12291
Under Executive Order 12291. EPA
must fudge whether a regulation is
"major' and therefore subject to the
requirement of a Regulatory Impact
Analysis. The Agency previously
prepared such an analysis regarding the
May 27.1962 final sleel industry
regulation. Today's regulation IB not
major because it does not fall within the
criteria for major regulations established
in Executive Order 12291.
IX. Regulatory Flexibility Analysis
Under the Regulatory Flexibility Act. 5
U.S.C. 801 et seq. EPA must prepare a
Regulatory Flexibility Analysis for all
proposed regulations that have a
significant impact on a substantial
number of small entities. In the
preamble to the May 27.1982 final steel
industry regulation, the Agency
concluded that there would not be a
significant impact on any segment of the
regulated population, large or small. For
that reason, the Agency determined tha
a formal regulatory flexibility analysis
was not required. That conclusion is
equally applicable to this regulation.
The Agency has not. therefore prepared
a formal analysts for thia regulation.
X. OMB Review
This regulation was submitted to the
Office of Management and Budget for
review as required by Executive Order
12291. Any comments from OMB to EPA
and any EPA response to ihoie
comments are available for public
inspection at Room M2404. U.S. EPA.
401 M Street SW.. Washington. D.C.
20460 from £00 a.m. to 4:00 p.m. Monday
through Friday, excluding Federal
holidays.
XI. List of Subjects:
A. 40 CFR Pan 4O3: Confidential
business information, reporting and
recordkeeping requirements, waste
treatment and disposal, water pollution
control
B. 40 CFR Pa*: 470 Iron, steel, water
pollution control, wastewater treatment
and disposal
D«ted April 27 1904
William D. Ruckelihwi.
•\dminisi ra:or
For the reasons set out in the
preamble. EP.A is amending 40 CFR Part
420 as follows:
P ART 420—£ AMENDED)
1 The authority citation for Parl 420
reads as follows:
Authority: Sections 301.304 (b|, (cj. (el. and
(g): 306 lb| and (c|. 307. 306 and SOt of the
Clean Water Act (the Federal Water
Pollution Control Act Amendments of 1972.
ai amended by the Clean Water Act of 19771
(the "Act"): 33 U.S.C. 1311:1314 (b). |c). (e).
and lg|: 1316 (b) and (e|: 1317.131& and 1361:
86 Slat. 816 Pub L 92-500. 91 Slat. 1567: Pub.
L 95-217
2. By revising { 420.03 to read as
, follows:
$42043
(a) Except as provided in paragraphs
(b)(l) through (b)(3) of this section, any
existing point source subject to this part
may qualify for alternative effluent
limitations to those specified in Part 420.
Subparts A through L for a number of its
processes representing the degree of
effluent reduction attainable by the
application of best practicable control
technology currently available, best
^available technology economically
achievable, and best conventional
technology. The alternative effluent
limitations for each pollutant are
determined for a combination of outfalls
by totaling the mass limitations of each
pollutant allowed under subparta A
through L and subtracting from each
total an appropriate net reduction
amount. The permit authority shall
determine an appropriate net reduction
amount (or each pollutant traded based
upon consideration of additional
available control measures which would
result in non-trival (substantial) effluent
reductions and which can be achieved
without requiring significant additional
expenditures at any outfall(s) in the
combination for which the discharge is
projected to be better than required by
this regulation.
(b) In the case of Total Suspendec
Solids (TSS) and Oil and Grease (OfrG).
the minimum net reduction amount shall
be approximately 15 percent of the
amount)s] by wnich anv waste stream(s)
QOIMOOyi»-MAY-*4-U!j4l)
-------
Federal Register / Vol. 49. No. 97 / Thuredoy. May 17. 1964 / Rules and Regulations
m the combination will exceed
otherwise allowable effluent limitations.
For all other traded pollutants, the
minimum net reduction amount shall be
appoximately 10 percent of the
amount(s) by which the discharges from
any '.waste stream!*) in the combination
will exceed otherwise allowable effluent
limitations for each pollutant under this
regulation
(1) A discharger cannot qualify for
alternative effluent limitations if the
application of such alternative effluent
limitdhons would result in violation of
any applicable State water quality
standards.
(2) Each outfall from which process
waste waters are discharged must have
specific, fixed effluent limitations for
each pollutant limited by the applicable
Subparts A through L
(3) Subcategory-Speafic Restrictions:
(i) There shall be no alternate effluent
limitations for cokemaking process
wastewaters:
(ii| There shall be no alternate effluent
limitations for cold forming process
wastewaters.
3. By adding a new 1420.04 as
follows:
(a) Pretreatment standards shall be
calculated for each operation using the
applicable avenge rate of production
reported by the owner or operator of the
facility to the Control Authority in
accordance with 40 CFR 403.12(b)(3).
(b) The average rate of production
reported by the owner or operator in
accordance with 40 CFR 403.12(b)(3)
shall be based not upon the design
production capacity but rother upon a
reasonable measure of actual
production of the facility, such as the
production during the high month of the
previous year, or the monthly average
for the highest of the previous 5 years.
For new sources of new dischargers.
actual production shall be estimated
using projected production.
(c) If. due to a change of
circumstance*, the average rate of
production for an operation reported by
the owner or operator of the facility to
the Control Authority in accordance
with 40 CFR 403.12(b)(3) does not
represent a reasonable measure of
actual production of that operation, the
owner or operator muat submit to the
Control Authority a modified average
rate production.
4. By adding a new 142008 to reed as
follows:
J4MJN
Removal allowances pursuant to 40
CFR 403.7f.aMl) may be granted for
phenols (4AAP) limited in 40 CFR Part
420 when used as an indicator or
surrogate pollutant.
S. The table in i 42X23 is amended by
revising the entries for cyanide, lead.
and nnc as follows:
BffW
Of Ml
Zne
K9/UQ SmMiMr '-000
ooom OOOIH
• •
0000*51 08081 SO
The table in 1420J6 is amended by
revising the entries for lead and line as
follows:
SUSJMNTB
Mol
OOB1SO
00001SO
oe
a The table in 142O24 is amended by
revising the entries for lead and fine aa
follows:
S.4JOOM MSWI
SuePARTB
«V 1.000
Zinc
O.OOOM1 OCOB1SB
9. By adding a new paragraph (c) to
1420J1 as followa:
{410J1
pM 1.000
(c) The term "existing indirect
dischargers" means only those two iron
blast furnace operations with discharges
to publicly owned treatment works prior
to May 27.1982.
10. The table in paragraph (a) of
ft 42033 ia amended by revising the
entries for cyanide, lead and sine as
follows:
Zinc
7. The table in 1420.25 is amended by
revising the entries for cyanide, lead and
zinc as follows:
I4MJS
by«w
(a) * ' '
S-034999 0017(01«I6-MAY-84-I4 36-27)
-------
ARGONNE NATIONAL LABORATORY
9700 South CAM Avtnut
Argonne. Illinois 60439
ANL/EES-TM-2T2
EVALUATION OF OPPORTUNITIES FOR EFFLUENT TRADING
EN THE STEAM-ELECTRIC. PETROLEUM-REFINING.
AND COAL MINING INDUSTRIES
MlctiMl J. Davis
Energy and Environmental Systems Division
Integrated Assessments and PoUoy Evaluation Group
October 1983
work sponsored by
U.S. DEPARTMENT OP ENERGY
Assistant Secretary for Environmental Protection,
Safety and Emertfenpv Preparedness
Of!;ce or' Environmental Annysis
-------
WATER BUBBLE FOR THE IRON AND STEEL INDUSTRY
This appendix contains the following; EPA's comments on the use of the water
bubble concept in the iron and steel industry.1 the original regulation,1 EPA's comments
on the modified rule,2 and the amended rule.
A.1 EPA'S COMMENTS
of tbo
it
to adopt aa dtanata offlooat ttaaita
prilcy r votar tobUO. Tba Aaoac?
ooiabUabadbytboAtBBcyam
to oaoa« than win aot bo a oot
ta tbo diacbaiBB of
tg tta uopetorf fr^toflc
U&dor tho mttff bobbb DoHey.
EPA davdop a notbod to
watar quality Inpoet of dtthroat
oooBbnatfoaa rrf inrilT'Tiitt aad aflow
rM tradoo oadar tbo wator
docroiMia
ootfalb ot tbt
!• lotO
boobtttoodatloM
Bd>bio policy wbaa tba watar quality
IflBBOJuAtfat MB? ftlA tftiawJoAflBBBM BBlWVHV C^iA
bobblo poiiey would bo tba MM ao
without ita aao. Tbo Afoacy baa daddad
aot to adopt dut apptooeb for tba
fbOowtaf roaaoaa. Tba adadaiattatfTO
•dooiod o wotor bibbJo potter far tbo
ttooi tadaotnr. Ȥ pottqr 1* mtrwoa IB
douil la Socttea XXVI of ttda pma^lo.
Followtef on tbo Aaoaqr'* tvpoaooo to
tbti
bidv IPA'a wator bubbU pdiej
atod tDdoatry la aa ahanattro
jo
dtacbaraodlba!ta,ata
ttOtOQ BOt thO
ld bo i
acbiovodbytrodltleaal
. Tba
byduooi
> wooid bmtvt a
•ad iMMpottbiovtib tbo OM of
tbo babMo poiky. dtoebtiicn would bo
•aount of tbooo
•poafie UmJUttaat bovo oot
MUbii-bod. Tbs Accasy ttxrwi
ooaccra ud tiaiirirnd tba looao
eartfully ta dtvoioplBf it* Baal poUqr.
Tbt flaai policy oaataiaa eeaditioaa oa
tfct uao of tbo wotar bobblo. Tbo AfOBCf
found that imlata oaadtttoaa waro
Unpetod opoa tbo oao of tba pottey
tavohrtaf oafcaaaaktas. bot fomiat, oad
eold reilLaf epantfaea. tbartww o
probability that than wold bo a aot
taertaao la tnde peOvtaat dtaebaifoa
ondtr tba policy.
eaflod Cor by tba Oaaa Watat Act
rActTbia
baaod Btraiatj wttb aa aitanathro.
water qoattty baaod attataoj. Tbo
Afoacfa totoat ta drrdopiaf a i
bubble policy la to allow diaebaifan to
eava aoaoy iABOottof tba todiaoloey
baaod Umitafloaa lapotod by tbo doaa
Watar Act aatto pfovtdo aa altaraattvo
rtfulatocy pre^na. •
i tbt
dltic
licbraqotrattbataocb
oatfall hart a ipodfle diaeBaift Iteit
baeaoao tboy boUovod tbat it would
prtdndt oppoftuaittM to inpltmant
tiBdaat control •nttftaa. Tboy
nunttad tbat tba Afoaey adopt a
bobbla policy wbieb ailowa offluoat
UaiUttoai to bo totabiiabod oo •
plaatwida buta tbo ao-callod. "fbattof
babbit'*. Uadof tbo tuBjtttod "floattag
babUo". diacbaifan would bt ailowad
to traiy tbo ate of ooattda it tbo vortouo
oadallawttbB*ada&taBadailir.
woddy. or aootfUy baaia. aa loaf w tht
daatwida Ibai «tioa to oot ouoodod
Tbo Ainer BM emAdly ovoJutod tbo
te 11ootto«bobbloMadbM
1ho.t fhttd Uniti OB oocb **?**iH on
odmiBiotnOn
babblo. TIM fiooa^-babMo woald OMko
B^UB^^tfl a^M ^^^^M^A ^^^a^^^M^^ (adnatty fopfaaaatattvoa bavo aot
providad aay data la aoptoct of tboir
ooataadoo that tba flpattaf bobblo
would allow i
to oao eoatrel tttitaftao tbat an oot .
faaaibla cadar a odic* nqoitiaf ftxad
timita oa aoeb oaoUL EPA baliovao uo
aafor Mvtap aaaodatad wttb tba
bobbla policy will rttdt from dtaaftt to
flud eoaaol eosta. Otabarfm eaa taka
advaataaa of tbato »avtBft undtt tba
policy adoptad by dw Afoaey.
Tba Afoaey toUdtad ooauBaata oo
tba totouteo aad •daUaiatnttvt burdao
tbat tba bobbla policy oifbt placa oa
ptfmkt autbortdta. Savtial coamtatan
i dwt tbo policy would
-------
pmer; IB additional Surde: ±at cens:t
*„ junuaa wou«a M uaaaia :o Dear. Hie
Atoncy hu Mod to deafen the bubble
policy 10 alaimiae tu adauatomttve
burden. Pint the Afoncy hu ipodnad
that diacharten moat laiaata bubble
propoMli at their own expenaa. la
addition. •• dtocuaaad •bow. EPA hu
•ought to aiattn the mow burden
by roquiriaf that bubble pemitt aavt
fixed enforceable ttmita oa each outfall
Once iheee limitation* are determined.
the ooet of rerlewtaf iaepeedoa tad
Mif.Banitartaf reparte will be
comparable to the admiauaaoTe eotti
aaeociatod with tedWaaal permit
crandertd dunot oermlt '»roarr»
wiu penut ;aaae Oiiuir^vn *iuca ~a
not hive the eppoituatty to aaea e
ptmit beeed upon the bubble poUey ID
do M u MOB u poeable without
weittBf for niMueAee. However. It
evoids the loaf ten edmlaiitnave
burdeBe eieodeted with ellowlaf
dleeheifen to apply for perBlbTbeeed
on the bubble policy whoa they hid w
i pei
illftbtfity
i were oppeeefl to
the eeodiaoa in the Aeeney'i propoeed
policy which reonired til waatMtmae
beeeueo U would reatrtct IB« uflllty aad
coat eavtai poteattal of the bubbU. VA
•ad eufjMted that each e Umiueaa wee
iaappnprUte. 1U« laterpretettea ie
correct u d» Afiecy does aotUUeve
that it would be eppropriete to pemtt a
tthaafereauifedbyNSPt
because of the rabble policy. Under the
dean Water Act BOW euutoei arete
uia of *ha babbit, and'?' h« ••emtiva to
p.xpc«*u ^om Murcca ^41 alaccaa be
> bet aot ton
One
belaai
latne
m
lUaiUOoaiuldeUaMi
lalTlaMeereU
IteetteereUOBf
to a water babbie policy be reeohad
during the pemit (aauaaeo proceee> 9A
baUoveo that thtortiulatloa to en
appropriate vahlda for impiemeai
poucy.Tte
meeti
adequate to protect water quallt*.
EPA hu decided IB not mdade a
oondlBoa mat an oatfaOa at piaaa
i mat
the uaaef the bubble will
plant to pleat However, the
bellavee that the bubble policy'
Boaallowa
with wutewetan that are
ToeaawothatMmlte
babble pobcy do aot
laaa
Tbel
yaalt
(l)Coci
^ —
will aot
pottey, a
beUevee ihie approach U
ardor to keep the aottalatrativo
auocUtad with thifpolky toe
nunianam, *a Aaeecy baUovea that
appUeadaafataaaafi
beralaedaad
wlDjavt the bebbloi Howeveti wtta tbo
poUey. the dlaehaipr weald aava the
flexibility ta allocate the aiacfaarae
I Ita oatfalla la the laaat ooady
avaaeetod that dtochaifen be allowed to
aubal t propoaala to awdlfy odatlaf
peroita to tadade a water bubUa. Tbe
Aaeacy hae oaoaldafad that tatfeaBoa
and haa dedded ta accept bobble
application* at aay one duriai BM
parted of currently effectrre pemtie
where a bubble waa aot apedaeaUy
wattewatars euBai be eflectrraly
coatroUad ander the babble policy.
(II) Cold Format. Permit! leaned
BBdaV the bubble polky which toveta
tradaawlDaaldformiBi'
EPA
euthorlBae (1) iaform aouraea that the
bobble approach la arailaWa. (I) esplala
the edveaiaaee aad eoadtttoaa of the
will aot be allowed The Aaoacf
baUevu aat the vaUabUltf and
A^^^^t^^ta^ ^^ a^eaadA ^^UMkea/
amomna at UBBB orna
aaaodated with cold formln«
wutewetera an mch that it to not
paeaibla to auui • afficttv* w&ffol of
toxic arnak pouotaata under the weti
bubble polky.
t Ditenarttn mut mtft water
quality ttaodardt. A chann m the
dtoMbuBoa of paUatant loadtnai may
-------
•dvcmly alba wturqulitr matt babbit pomittMt out iathwnialtttoa mtb
Wliiii i illm hupi
Ptmlttto
raMiU««lMtittoMMbiMtai« dmiop
plttt.trtdt-flaMmrbuta.ta to
DM to faftai
topattcytoboHvllMlaBi DOB*
•if proowt • dlBtrat art of«
ttahatfaDj far hi ottftfla Mtofl to
Ttgsigga.'to Apnrr tmmmnwl tot It babbit COM*. Tbapcramtt rat _
wueaMidcriMiBpouftQoadtttoaoa toBOHtnto.totoMttalMtfaaofto iMBlifloItoAttMMaeaBatdtottt
tU policy wl3wo«ldijindji»B pntUiMoiacntfaarttT.totlti ^Sidrt.fiwScSlww^
wutmtmtonMtippfeabltBT JBUPUMJ i^ritHH t totol dtodaiy ooiH^tojttSmifroai^atto
l!!!!!!!^.^1^*?!,^^ «-!«^J"!» "?*"*«• SKSSTrffA^iSd:^
- ^_ L j. ^ "*""*..,. teailownnn noaplytM dtochantrt tt
• ItrtMtat.WbatotodMpriHkM pnvoHtoWoftolaMnKtf
joUdritvificuiljri'MMct oodbidtaoaMnttcBtoto
toaavtapaModaiffdwlthtowttor oftopomltlMaiDaaatbart
babokaadttaatBooMatiyttacbit** . junoparalt •ay'bt baaod w •• nsman \mUnm ^- *^ lu^hti^ te
oqulvaits^toi^ 'oiteBatt«*d(aGftaffiita8tttlfoM>' ^ dMtltpopBpilaaotmtopMtot
-_^» ,ii _ ^, , —n—^— ^^«^^^^* ^v • _i .«. «*^_* w»^^^^«^^^p» -»«^ W^MWW^. ^^^^^^^M vi^v
thiipoteymayaUo* •eUcyMmrtocdrtaytoUiofft •chira to «BM total onnll owtmtnt
•tmtottMwi MnBit«Br««iek«i
.baeeutboi*tm;M7a
oaifalliaadtootor
A.2 ORIGIKAL RULE
I^4lA ^M A^^^^^^^B^^K ^•^b^^^rit ^^^^^_^^^_^ f *P^^ ^^^^kO; ^^^B^^^ ^^•^••J ^^^L.4^^^^ Al^A fttl flb«lMi*k4^^^^>^A__^A^^^^Jt^ B * m^^*^ m • •
4W1 WMWtWVVMMMHHn !• TM pOIBt NOrDf BBH aCBWO ON [flf aUDCMOJOfJ^^VOGUte JtMtflCOOBf
j«to«nnooioi»y< total maaatattaflas far Mctapolbjtut (DnmabillbaMaltamtttfflaaBt
*~< ^ •! w oBfHiHN M lor tb* oaabiaatlaa of pfoetiaoa> UaiitttieBaCaveokaaaklaipioeMa
— ^^^^** (a) A dtacbar|ar eaaooi QBattfy Cv waattwtiara.
•ItaraatrvaaffiaaBttattadootifto (t)TtetabiflbtaoaltarMtfa.Bti«i
appUcadoaofncbaltanattvaaflbMBt ttoitatiou for cold forniai pmtn
|»pt»F.*idtdtapM|npbi(.) ^2rBMltwteta*111
•BbtBMtoBOf
».. _ rf.,-
•!!•&••*•
Aflfl
toappJieibltSabBtttiAlhoafb
-------
A-J EPA'S COMMENTS ON THE MODIFIED RULE
.4. Section 420JB Aitmatn-f Effluent
L.mitatioiu (Water Subtle/
The proposed amendments to the
*«ier bubble rule for the iroo tad steel
manufacturing pomi source category
regulation provide that the •Iterative
effluent limitabou established under
the weier bubble must mult in •
decrease in the discharge of traded
pulluianta from (he amount Allowed by
the generally applicable limiatlona. The
water bubble rule establiahftd b> the
final regulation published on M«y 27,
1982. provided that there could be no
increase in the discharge of pollutant*
beyond thai allowed by ihe generally
applicable limitations. Too preamble
amendments presented in Section V of
ihis notice describes the propoeed
revisions to the wmer bubble rule.
In the settlement agreement, tbe
Agency agreed to propose to amend the
preamble to the regulation aa follows:
AJ pan of ihe Miilemeni. EPA is proposing
10 amend >u> bubble rule for the Meet
industry As engiaslly promulgated the rale
provided thai a dischsiqer could qualify tar
•Itemattve effluent limitation as lone; aa Ms
discharge ire* a combination el outfalls awt
cerum requnmema (water qualify
•laadardsl and lestrtcuoM and would aot
exceed the total nasa of each petulant
unarms* allowed under dw nrnuaito*
Under the nviaod rale bemg proposed today.
• discharger would have te meet the same
nquiremefite aad resmctiona. bui would
qualify tor sltomattve effluent liautauem
only if a achieves a net redaction from die
total mass af each traded pollutant
The amended refutation prondae that the
eutnoniy enet determine an
reduction amount un
case, m making that dstarmmsiine. it to
intended that the parmii writer will <
hietonca^diacaaifsievetsandseafcto
at a facility through good snajnsirtng
practices, impreved tpiretlens and
tupemsMO of existing treatment eyeteme or
other fesMble awdiflcationo. a*, aan-prooasa
flow Mgregattoa or chemical addition, if they
can be achieved without requiring significant
additional expenditurea, It ta intended that M
nes far aperopnaat
i (M poWUt wnlkW Wai IQufUeW Qflly
those measures which result m nan trivial
Ituhetantial) effluent raducriena and<
will aot require significant
exponi
The
each pollutant nded fa to bo
t ef pereantagaa el the
amount by which a discharger prapsisa te
exceed the atharwise applicabto <
UmitaiionssatabUahadi
isppmimaielytlj
far TetatauapsHdadSoUda fT8il and OU and
Crease (OnC| and tppniumawty tf |
(or all «tt*i >radi-d poRulanUk
In dw i.melesi <»«. ta example, a
disGhareer mifhi prrpwo to exceed the
jllow»b* bmiuiitm far TSS oe Outfall A b;
109 pounds and tbea make «p the •mount or
Outfall • by reducing its allowable dischaig
by UB pounds. The net reduction provision
would require that, at a minimum, the
allowable discharge from Outfall B (or any
other eutfell which me discharger bee
included in the bubble ndet be reduced by
approximately 111 pounds, to mahing a
deiermuiauon of the •soprepnata net
reduction amount," the permit wnter will
require hirt' if. aan^nvlal (subsunnall
rwJuffiiens enly tf he determmae taat ihey t»
Us schievad wiihout iignificani addiimnel
expimdituns.
Din am mdmeai reaulte from setdemenr w
Imgauan imong several parnn wiu
ereniflcar tly divergent vtews af ttw water
bubble r Je. Hue pravuMn does net
ruprsss" t the Agency mow on whether 11 te
•tthor •eiaUyreqiund condition of a bubbl
rule under the Cleeo Water Act or any other
rnvtimmeaial statute or required as a matte
of policy, nor shall it be takes aa an indicetoi
of whet the Agency may or may net require
m any other mgalettans eeiaUahmg effluent
limitattons guieshnes ander the dean Water
Act
imply any changes m their Daemons. In the
interest of sveuiing protracted Utttjetton end
of expediting the mstaUaMon of pollution
eoante for this mdusey. the ponies have
reeehed aa overall settlement of raaay sHuae
mat they view aa beneficial, to t
the aortas have agreed to reach
dtffsiences with this settlement.
A.4 AMENDED BOLE
(a| Except as pravidad in pnregrapna
IblU) threufh (b«3) of this eectton. any
existing poini source subject in thla pert
may qualify for alternative effluent
limitations to those specified in Pert 42ft
Suoparts A though L far s number of ile
processes representing the degree of
effluent reduction attainable by the
application of bail practicable control
technology currently available, beat
ivailable. technology economically.
schieveble end best conventional
technology The alternative effluent
limiietions for eech pollutant are
determined for a combination of outfalls
by totaling the mass limitations of each
pollutant allowed under Subpens A
though L and lubtrscting from each total
an appropriate net reduction amount.
The permit authority shall determine en
appropriate net reduction amount lor
each pollutant traded based upon
consideration of additional itailabto
control meaeurea which would result in
nootrivnl (substantial) effluent
reducoone and which can be achieved
without reqoinng etgnifleant addition!
expenditurea at any outfaUM by which
the dischargee bom any waste steam|a|
in the combine tion for which the
discharge is projected to bo better dun
required by this regulation.
(b| In the eaae of Total Suspended
Sdida (TSSI and OU aad donee (O*CJ.
iho minimum net reduction amount shell
be approximately is percent of the
emountts) by which any weete aoonmla)
m the combination will exceed
otherwise allowable effluent limltarlona.
For all other traded poUuiente. ihe
minimum net reduction exceeds
otherwise allowable effluent Ibaitntione.
For all other traded poUutanta. the
minimum net reduction amount shall be
approximately to percent of the
amountlsl by which the diachnresa from
any waste streanf si in the combinatton
will exceed otherwise allowable effluent
llmitattOM for eech pollutant under ibis
(1) A dtochargar cannot qualify for
alternative effluent Umiunooa if the
•ppiicatfoo of each almnutive effluent
bmiuttoee wwtd •*-:'• T •- tiatiaa of
any epplknbie Stele water quality
standard?
(2| Eech outfall from which process
waetewaters are discharged must have
speaflc. Axed effluent Uautaoona for
each poUutani limited by the applicable
Suoparts A though L
(3) Subeategory-Soedflc restrictions.
(0 There ihell be no alternate effluent
limitations fortoaemaking process
wmteweters.
(ti| There shall be no alternatv*
effluent limitations for cold forming
process wsstewaten.
-------
ENVIRONMENT REPORTER
Current
Developments
A weekly review of pollution control and related environmental management problems
June 5. 1981
THE BUREAU OF NATIONAL AFFAIRS INC
Volume 12. Number 6
198
ENVIRONMENT REPORTER
Water Pollution
BUBBLE POLICY FOR IRON. STEEL SOURCES
OPPOSED BY NROC. SUPPORTED BY INDUSTRY
The Natural Resources Defense Council opposes use of the
water bubble concept in the iron and steel industry, while the
American Iron and Steel Institute supports its
"unrestricted" use. according to comments submitted to the
Environmental Protection Agency.
NROC told the agency the bubble is impenmsnbie under
the Clean Water Act. but AISI supported the concept as being
environmentally and economically sound.
In early January, EPA announced that it was evaluating
the use of the babble concept for iron and steel. Proposed
effluent guidelines for the industry under the Act were
published Jan. 7 (Current Developments. Jan. 9. p. 1393).
The agency invited public comments on the concept, which
would allow facilities to relax expensive compliance controls
at some outfalls, while tightening controls at outfalls where
the measures cost less, as long as the plant's total discharge
does not exceed pollution standards.
Two studies conducted for EPA concluded that the concept
has only limited applicability for the iron and steel industry.
A study by Temple. Barter, and Stoane. Inc.. of Islington,
Mass.. at four steel mills concluded that use of the bubble
concept could save between 3.3 and 6.2 percent in capital
costs, and between 2.1 and 3.6 percent in annual best
available technology (BAT) operating and maintenance
costs.
Dollar savings were projected to range from $200.000 tor
capital costt at Kepchiic Steel in Warren. Ohio, to $L1 million
for U.S. Steel at Gary, Ind.. and from $10.000 in annual
operating and maintenance costs at the Wamn facility to
155.000 at the Gar? plant. Other plants studied were
Republic Steel in Cleveland, Ohio, and the Wheeling-
Pittsburgh Steel Co.. Steubenville. Ohio.
United Saving*
The study cautioned that "cost savings of this magnitude
are probably not generally applicable to most ated facilities
because steel plants often do not possess the multiple outfall
and similar pollutant stream characteristics usually
necessary to benefit from the water bubble policy."
In its public comments. NROC maintained that the bubble
policy is not permitted under the Act because it "requires
mat BPT [best practical tecfawtogyj and BAT limitations
are applied to each point source."
TteeDvironmental group stated. "If a discharger can
remove -cheap pounds' at any given point source, it.should do
so in order to make progress toward the elimination of dis-
"The very fact that such cheap pounds are available may
mean that EPA has not properly established the ap-
propriate effluent limitation, or (B) a more stringent fun-
damentally different factors' variance B warranted, the
council said.
Bubble Approach Lauded
AISI said it is "heartened by the present consideration" of
the water bubble which, the institute said, "permits a prac-
tical and reasonable approach" to controlling pollutant dis-
charges that is "both economically and environmentally
sound "
But'the institute cautioned that the bubble-'wiUI servea
useful purpose" only if it is not subject to what AISI called
ie "unnecessary restrictions and conditions" that EPA
suggested be applied to the concept if it is adopted.
These conditions. EPA said in the proposal, stipulate that
dischargers must meet water quality standards. Trades could
-------
CURRENT DEVELOPMENTS
199
involve only the same pollutant, and each outfaJI would be
restricted to a specific discharge limit.
Also, dischargers would initiate, at their own expense.
water bubble proposals during the normal permit
re-issuance process. Non-complying dischargers would not
be allowed to use the bubble concept, and all wastestreams
would be required to meet applicable BPT requirements un-
der the EPA proposals.
Finally, trading between some wastestreams from
different suhcategones of streams would be prohibited.
'Greatest" UM Urged
AISI said the water bubble "should be structured in such a
manner to allow the greatest degree of application by in-
dustry so long as (its) use does not result in significant
adverse environmental impacts affecting water quality or
water use."
In its comment letter to EPA. the institute expressed
reservations or opposition to each of the seven conditions
suggested by the agency.
A "rigid imposition" of the condition that dischargers
meet water quality standards. AIS! said, "may limit the
utility of the water bubble." Hie institute also argued that
the bubble concept "should be sufficiently flexible to permit
trades among pollutants which have similar characteris-
tics."
Imposing specific discharge limits on each outfall, AISI
said, "precludes opportunities to allocate effluent limitation
loadings flexibly among outfalls in order tc reduce costs and
promote efficiency."
The institute stated that plants should be allowed to seek a
bubble when applying for a new source or new discharger
permit, for modification of an existing permit, "or at any
time during permit review or negotiations." AISI also said it
•sees no reason" to make non-compliance a bar to bubble
eligibility
Requiring all wastestreams to meet applicable BPT re-
quirements "would unnecessarily restrict the utility and
economic benefit" of the bubble policy. AISI maintained.
The institute added that a wastestream trading ban would
"greatly restrict and lessen the utility" of the water bubble.
AISI recommended that EPA allow water bubbles on a
plant-wide basis, "unencumbered by the non-cost effective
conditions" proposed by EPA.
Resource Increases Seen Necessary
NRDC predicted that a policy allowing bubbles would
spawn "a significant increase in the demand for permitting
and enforcement resources." * ,
The council noted that EPA's budget and staff are being
reduced and commented that "without additional manpower
to review the permit application and monitor the operating
facilities to assure minimal violations, the bubble policy will
be a failure."
Regarding the seven conditions suggested by EPA. the
council predicted that water quality standards would be
jeopardized near outfalls where more pollutants were dis-
charged than otherwise would be allowed.
The legislative history of the Act. NRDC argued, "clearly
prohibits, for BAT. the types of economic tradeoffs that are
necessary with a bubble policy."
Setting specific discharge limits for each outfall, the coun-
cil continued, "is a legal and necessary requirement, with or
without a bubble."
NRDC said if the bubble concept is approved, "a detailed
survey of the wastewaters from all point sources must be re-
quired prior to the issuance of a permit so that tighter
limitations can be applied to point sources that can remove
the most tonnage of toxics."
The council said it supports banning water bubbles for dis-
chargers in violation of their permits. It said limitations
••more stringent than BPT" should be required "in cases
where a specific BPT waste stream is known to be highly
toxic."
NRDC also recommended that EPA prohibit waste stream
"trading" between "any point sources that would discharge
significantly more tonnage of toxic pollutants."
Study of General Concept
The second study, conducted for EPA by Putnam. Hayes.
and Bartlett, Inc.. of Cambridge, Mass., involved the use of
the water bubble concept in industry generally and did not
focus on iron and steel.
The study concluded that the water bubble saves money
only if'the concept is applicable to the facility, if tradeoffs
between outfalls are feasible, and if current regulatory re-
quirements do not already permit the facility to make these
tradeoffs.
According to the study, most industrial facilities do not
meet one or more of these conditions because:
» Many facilities have only a single process wastewater
outfall "and hence rib opportunities for trading across out-
falls exists";
» Tradeoffs of control between outfalls may not be feasible
for water quality reasons or may be "technologically in-
feasible," and
» Some facilities currently have permits that allow all
feasible tradeoffs to be made, and thus "no cost savings will
be realized by the application of the water bubble concept"
The Temple. Barker, and Sloane study found that no
degradation of the water quality of the receiving waters at
any of the four steel plants would occur if the water bubble
policy were adopted.
BAT Seen Conrtraining Policy
The study said that the most important factor limiting
"effectiveness" of the policy at steel facilities considered
prune candidates for bubbles is "the stringency of the
proposed BAT guidelines."
BAT limitations, the study noted, "typically result in 97
percent to 99 percent cleanup of total pollutant discharge
relative to uncontrolled process wastewaters. This leaves a
relatively small amount of pollutants that can be removed
beyond BAT standards in order to generate pollutant credits
for use of offsets under the water bubble policy," the study
stated.
The small amounts of pollutant credits and the relatively
significant differential between BPT and BAT levels of con-
trol "make it difficult to eliminate BAT equipment as part of
'the water bubble tradeoff process," the study said. It added.
"Moreover, because BPT treatment typically removes sub-
stantial quantities of pollutant loadings, it is improbable that
the relatively small amount of pollutant credits available for
the tradeoff process would facilitate elimination of BPT
equipment," the study said.
It noted that plants with single treatment facilities and
single outfalls "usually cannot benefit" from bubbles.
"Because of the importance of each step in the treatment
train to the quality of the entire effluent stream with central
treatment, it becomes difficult to eliminate equipment as
part of the bubble tradeoff process." the study concluded.
Richard Raines, chief of the Water Economics Branch in
EPA's Office of Planning and Management, told BNA June 1
that the agency hopes to establish final effluent guidelines
for the iron and steel industry by November.
A decision on whether to include a bubble policy in the
guidelines will be made sometime before that time, he said.
6-5-81
Coov"9-( '981 by The Bureau of National Affairs me
0013-K11/8I/SOOM
-------
13 ELR 10094
ENVIRONMENTAL LAW REPORTER
NEWS&ANA^SB
4-83
DIALOGUE
ELR Dialogue is a vehicle for the easy sharing of ideas with our subscribers.
ELR invites submission of materials analyzing or commenting on develop-
ments in the law, and in particular solicits responses to Articles. Comments,
and Dialogue we have published. Submissions should be 500-1,000 words in
length, typed double-spaced. We hope you will communicate with us and the
diverse, nationwide readership of the Reporter through ELR Dialogue.
The views presented in ELR Dialogue are those of the author, not the
Environmental Law Reporter or the Environmental Law Institute.
—The Editors
Steel Industry Effluent Limitations: Success At the Negotiating Table
by Alan S. Miller
In the midst of the chaos prevailing at the Environ-
mental Protection Agency (EPA), one major envi-
ronmental accomplishment received too little notice. On
March 3. 1983, the Natural Resources Defense Council
(NRDC), the American Iron and Steel Institute, and EPA
filed a settlement agreement' with the U.S. Court of Ap-
peals for the Third Circuit resolving all legal challenges to
water pollution effluent guidelines for the steel industry.
As a result, protracted, resource-intensive litigation was
avoided, and Federal Water Pollution Control Act
(FWPCA or the Act) permits for iron and steel discharg-
ers wiil be written without the uncertainty created by
pending judicial review. The settlement assures signifi-
cant progress toward curtailing toxic discharges and im-
proving water quality, but it is less clear whether the
agreement furnishes hope for greater reliance on negotia-
tion or represents an aberration from the usual tug of war
between industry and environmentalists.
Background
The regulations modified by the settlement were issued by
EPA on May 27, 1982. They provided requirements for
the use of "best available technology economically
achievable" (BAT) by direct dischargers and pretreat-
ment standards for discharges into municipal treatment
works. The steel industry was the first important industri-
al category for which BAT regulations were issued under
the 1977 FWPCA amendments.
Mr. Miller, an iiiomey in the Natural Resources Defense Council'!
Washington. O.C. office, was the lead NRCD lawyer in the steel negoti-
ation.
I. 13 ELR 20366.
The Settlement
The settlement is a major accomplishment for several rea-
sons. First, industry's promise to comply with the re-
quirements of the regulations without further challenges
assures that significant reductions will be made in the dis-
charge of toxic and other pollutants from iron and steel
facilities. Iron and sieel production is a very large source
of water pollution; an average of 40,000 gallons of water
is used in the production of a ton of steel, and the resul-
tant effluent includes more than forty different toxic pol-
lutants. The technology required by the regulations will
remove more than 99 percent of the raw waste load dis-
charged directly from steel plants into water bodies, more
than 53,000 tons of pollution.
The industry argued that several portions of the origi-
nal regulations were not supported by adequate data.
EPA agreed to revisions for five categories in the interest
of achieving a settlement and finality in permit terms.
However, none of the changes will significantly increase
the total amount of effluents being discharged.
The settlement .also includes important changes in the
so-called "bubble" policy. As promulgated last May, the
regulations would have allowed dischargers to trade a re-
duction in the discharge permitted from one outfall for
an increase in the limits on the same pollutant discharged
from another outfall. For example, a discharger could in-
crease the limits on discharging lead from a sintering op-
eration by reducing discharges of lead from ironmaking
or steelmaking by the same amount.
All three panics entered negotiations with strongly
held views concerning the bubble policy. NRDC argued
that the bubble is inconsistent with the Act because the
economic savings that result are not considered when
-------
4-43
NEWS & ANALYSIS
13 ELR 10095
EPA selects the best technologies that are economically
achievable. Industry, on the other hand, very much
wanted the bubble because the flexibility it provided
made the prospect of compliance with significant effluent
reduction requirements far more tolerable. Similarly,
EPA viewed the bubble provision as an essential regula-
tory reform designed to reduce the costs of environment-
al regulation.
After several months of meetings, the panics agreed to
a compromise which requires that ail trades must include
a net reduction if it can be achieved without significant
additional expenditures. The settlement also requires a
minimum net reduction of approximately 15 percent in
the case of total suspended solids and oil and grease, and
approximately 10 percent in the case of all other pollu-
tants. The difference in these minimum requirements re-
flects the much larger quantities generally involved in dis-
charges of conventional pollutants, and the correspond-
ingly greater opportunity for further reductions. The
compromise was accepted by all sides in order to obtain a
settlement, and while EPA has not included a bubble
policy in regulations for any other industry, the debate
undoubtedly will recur if the policy surfaces again.
Settlements often leave the parties with a feeling of sa-
tisfaction and accomplishment, anc\ this one was no ex-
ception. Protracted litigation is never anyone's first
choice for resolving differences; efforts to promote nego-
tiation always merit applause. In the afterglow, it is
tempting to ask—as the Washington Post did in a March
7th editorial—"How did they do it?" and "Why must
[such settlements] be so unusual?"
The answers to the questions asked by the Post are im-
portant and, unfortunately, sobering, for they sugge?
that negotiation can be successful only in special circum
stances. The first requirement is arms length negotiation
with all sides legally and technically well represented. In
this case, each party had something to lose through leng-
thy court proceedings, and a compromise was possible
that enabled each party to obtain much of what it most
wanted.
More frequently, either the bargaining process is one-
sided or one party has nothing to gain from negotiation.
When former EPA Administrator Anne Burford negoti-
ated modifications to lead standards for the benefit of an
oil refinery, no environmentalists were involved and an
adversarial response was assured. In the dance of envi-
ronmental negotiation, it takes three to tango.
Equally important, there has to be something over
which to negotiate. For the most part. EPA's steel regula-
tions were basically sound and well supported; modifica-
tions were in order, not a major overhaul. Unfortunately,
EPA actions under this Administration have too often
been so one-sided that there is little room for comprom-
ise. For example, NRDC also sued EPA over BAT regu-
lations for petroleum refineries. These rules require noth-
ing beyond treatment systems already in place, despite
the availability of better technology, already used by a
third of the industry, that would remove up to a third of
remaining toxic pollutants, and that can be utilized with-
out causing any measurable economic impact. This kinc
of regulation leaves little room for negotiation.
-------
Appendix D
GLOSSARY OF IRON AND STEEL INDUSTRY TERMINOLOGY
From:
Development Document for
Proposed Effluent Limitations Guidelines and Standards
for the Iron and Steel Manufacturing Point Source Category,
Draft, October 1979, Volume 1, Section XVI.
-------
Acid Furnace. 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.
Acid Steel. 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 is
lined with a kind of sandstone called "firestone". Raw materials for
acid steel must be low in phosphorus and sulfur.
Additions. 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.
Air Cooled Slag. 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.
Allov. 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, copper.
Allov Scrap. Scrap steel which contains one or more alloying metals
such as nickel, chromium, tungsten, molybdenum. Such scrap must be
very carefully classified according to composition and kept separate
from other kinds of scrap.
Allov Steel. "Steel is classified as alloy when the maximum of the
range given for the content of alloying elements exceeds one or more
of the following: manganese, 1.65 pet; silicon, 0.60 pet; copper,
0.60 pet; or in which a definite range or a definite minimum quantity
of any of the following elements is specified or required within the
limits of the recognized field of constructional alloy steels:
aluminum, boron, chromium up to 3.99 pet, cobalt, columbium,
molybdenum, nickel, titanium, tungsten, vanadium, zirconium, or any
other alloying element added to obtain a desired alloying effect."
Aluminum. A metallic chemical element. (1) In either the bessemer,
openhearth or electric furnace processes, it is 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 contro
of grain size, and occasionally as an alloying element. (2) A .' v
weight metal. It weighs 2B pet as much as carbon steel.
Ammonia Liquor. Primarily water condensed from the coke oven gas, ai
aqueous solution of ammonium salts of which there are two kinds; fre<
and fixed. The free salts are those which are decomposed on boilim
to liberate ammonia. The fixed salts are those which require boillnc
with an alkali such as lime to liberate the ammonia.
Ammonia Still. The free ammonia still is simply a steam stripping
operation where ammonia gas is removed from ammonia liquor. The fixec
still is similar except lime is added to the liquor to force the
combined ammonia out of its compounds so it can be steam strippec
also.
Ammonia Still Waste. Treated effluent from an ammonia still.
Angle. A very common structural or bar shape with two legs of equal
or unequal length intersecting at 907.
Annealing. A process involving heating and cooling, usually applied
to induce softening. The term also refers to treatment intended to
alter mechanical or physical properties, produce a definite
microstructure, or remove gases.
Apron Rolls. Rolls used in the casting strand for keeping < ".
products aligned.
Bar, Hot Rolled. 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.
Base Box. 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.
Basic Bottom and Lining. In a melting furnace, the inner lining and
bottom are composed of either crushed burned dolomite, magnesite,
mangnesite bricks or basic slag. These materials have a basic
reaction in the melting process.
Basic Brick. A brick made of a material which is a basic anhydride
such as MgO or mixed MgO plus CaO. See acid furnace.
Basic Furnace. A furnace in which the refractory material is
of dolomite or magnesite.
200
-------
Basic Material. 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*iime, CaO),
magnesite (MgO), dolomite (containing both CaO and MgO). Examples of
acid materials; quartzite or silica (Si02) and the various clays,
oxides of sulfur, etc. In metallurgy, the terms, "bases" and "acids,"
are applied to refractories, fluxes, and slags. Slags are 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.
Basic Steel. Steel melted in a furnace that has a basic bottom and
lining, and under a slag that is dominantly basic.
Basic Oxygen Steelmakino. 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.
Battery. A group of coke ovens arranged side by side.
Beam. 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.
Billet. A semi-finished piece of steel which has resulted from
rolling in 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.
Blackplate. Cold reduced sheet over 12 in. wide to less than 32 in.,
in gases 29 and lighter, in cut length or coils and within the uniform
Classification of Flat Rolled Carbon Steel Products.
Blast Furnace. A large, tall conical shaped furnace used to reduce
iron ore to iron.
Bloom. 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.
Box Annealing. 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."
Bosh. The bottom section of a blast furnace. The section between the
hearth and the stack.
Briquette. An agglomeration of steel plant waste material of
sufficient strength to be a satisfactory blast furnace charge.
-------
By-Product Coke Process. Process in which coal Is carbonized ii t
absence of air to , permit recovery of the volatile compounds -,tc
produce coke.
Burden. Solid feed 'stack to a blast furnace.
Carbon Steel. Steel which owes its properties chiefly to various
percentages of carbon without substantial amounts of other alloying
elements. Steel is classified as carbon steel when no minimum content
of elements other than carbon is specified or required to obtain a
desired alloying effect; when the specified minimum for copper does
not exceed 0.40 pet; or the maximum content for the following does not
exceed the percentage noted: Manganese, 1.65; silicon, 0.60; copper,
0,60
Cast Iron. The metallic product obtained by reducing iron ore with
carbon at a temperature sufficiently high to render the metal fluid
and casting it in a mold.
Casting. (DA term applied to the act of pouring molten metal into a
mold.T2) The metal object produced by such pouring.
Caustic Dip. Immersion in a metal in a solution of sodium hydroxide
to clean the surface, or, when working with aluminum alloys, to reveal
the macrostructure.
Channels. A common steel shape consisting of two parallel flanges -*.
right angles to the web. It is produced both in bar sizes (less than
3 in.) and in structural sizes (3 in. and over).
Charge. The minimum combination of skip or bucket loads of material
which together provide the balanced complement necessary to produce
hot metal of the desired specification.
Checker. A regenerator brick chamber which'is used to absorb heat and
cool the waste gases to 6SO-7507C.
Cinder. Another name foe slag.
Chromium. An alloying element added to alloy steel (in amounts up to
around 1.50 pet) to increase hardenability. Chromium content of 4 pet
or more confers special ability to resist corrosion, so that steel
containing more than 4 pet chromium are called "Stainless Steel."
Clarification. The process of removing undissolved materials from a
liquid, specifically either by settling or filtration.
Closed Hood. A system in which the hot gases from the basic oxygen
furnaceare not allowed to burn in the hood with outside air
infiltration. These hoods cap the furnace mouth.
Coating. The process of covering steel with another material.
primarily for corrosion resistance.
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Cobble. (DA jamming of the line of steel sheet while being rolled.
(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 arei Steel too cold, a bad end
which can not enter a pass, sticking to the roll and wrapping around
It, etc.
Coke. The carbon residue left when the volatile matter is driven off
of coal by high temperature distillation.
Coke Breeze. Small particles of coke/ these are usually used in the
coke plants as boiler feed or screened for domestic trade.
Coke Wharf. The place where coke is discharged from quench cars prior
to screening.
Cold Metal Furnace. A furnace that is usually charged with two
batches of solid material.
Cold Pig. Blast furnace metal which has been cast into solid pieces,
usually weighing from 60 to 80 Ib.
Ctfld Rolled Products. Flat-rolled products which have been finished
byrollingEKepiece without heating
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(FeO), which is dissolved in the steel, and is removed by adding
deoiidizing agent such as manganese, silicon, or aluminum.
Descaling. 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. Common methods of descaling are: (1) crack the scale by use of
roughened rolls and remove by a forceful water spray, (2) throw salt
or wet sand or wet burlap on the steel just previous to its passage
through the rolls.
Double Slagging. Process in which the first oxidizing slag is removed
and replaced with a white, lime finishing slag.
Drags. Flat bed railroad cars. A drag will generally consist of
five-six coupled cars.
Duplexing. An operation in which a lower grade of steel is produced
in the basic oxygen furnace or open hearth and is then alloyed in the
electric furnace.
Dustcatcher. A part of the blast furnace through which the major
portion of the dust is removed by mechanical separation.
Electric Furnace. 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 electric furnace.
Electrostatic Precipitator. 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.
Evaporation Chamber. A method used for cooling gases to the
precipitators in which an exact heat balance is maintained between
water required and gas cooling; no effluent is discharged in this case
as all of the water is evaporated.
Extrusion. Shaping metal into a continuous form by forcing it through
a die of appropriate shape.
Ferroalloy. A 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,
chromium. Some of the more common ones are ferrochromium,
ferromanganese, ferrophosphorus, ferrosilicon, ferrovanadium. The
chief use of these alloys is for making additions of their respective
alloying elements to molten steel.
Ferrochrome. A finishing material which contains about 70 pet
chromium. It is used when it is desired to add chromium to steel.
Ferromanganese. A product of the blast furnace, containing, besidfg
iron, 78 to 82 pet of manganese and some silicon, phosphorus, sulphur
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and carbon. It is used »• * 4«oxldU®r and for the introduction of
manganese into steel.
Ferrophosphorus . A *lintahiiui material (see "finishing") which
contains about 18 pet nhft.Hi«^,i« It is used when it is necessary to
add phosphorus to •
Ferrosilicon. A product of the blast furnace which contains 8 to 15
pet silicon. It is used as a deoxidizer and for adding silicon to
steel .
rt
Ferrous Metallurgy, that section of general metallurgy which embraces
d knowlede aling to iron an
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Flux. Material added to a fusion process for the purpose of removing
impurities from the hot metal.
Forging. (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.
Forming. To shape or fashion with the hand, tools 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. A strand which has four rolls, one above the other.
This kind of mill has two work rolls, each of which is stiffened by a
larger back-roll. Four-high rolls are used only on mills which roll
flat products: Slabs, plates, sheets and strips.
Fourth Hole. A fourth recovery lined hole in the roof of the electric
furnace which serves as an exhaust port.
Free Leg. A portion of the ammonia still from which ammonia, hydrogen
sulfide, 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.
Gages. A measurement of thickness. There are various standard gases
such as United States Standard Gage (USS), Galvanized Sheet Gage
(GSG), Birmingham Wire Gage (BWG).
Galvanizing. 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.
Galvannealed. An extra tight coat of galvanizing metal (zinc) applied
to a soft steel sheet, after which the sheet is passed through an oven
at about 12007F. The resulting coat is dull gray, without spangle, and
especially suited for subsequent painting.
Grade. The term grade designates divisions within different types
based on carbon content or mechanical properties.
Granulated Slag. 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 looks like light tan sand.
H-Steels. Alloy steels that can be used in applications requiring
different degrees of hardenability.
Hammer Forging. A forging process in which the work is deformed by
repeated blows. Compare with press forging.
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Hammer Lao. A defect on the surface of steel, being a foldedover
portion produced by bad practice in forging.
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.
Hammerino. 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.
Hardness. Defined in terms of the method of measurement. (1)
Usually, the resistance to identation. (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. <1) A form of energy which raises the temperature of bodies
into which it is absorbed. (2) An individual bath of metal as it is
tr'eated in a furnace.
Hexagons. A product of hot rolled carbon steel bars hexagonal in
cross section. Commercial size range of hexagons, 1/4 to 51/2 in.
inclusive.
High Strength Steel. Low alloy steels forming a specific class in
whichenhancedmechanical properties and, in most cases, good
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 now "high-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. It is furnished in black or galvanized, in cut
lengths or coils as specified.
Hot Bed. A large area containing closely spaced rolls or rails for
holding hot, partially rolled metal.
Hot Blast. The heated air stream blown into the bottom of a blast
furnace. Temperatures are in the range of 5507C to 10007C, and
pressures are in the range of 2 to 4.5 atmospheres.
Hot Forming. Working operations such as bending and drawing sheet and
plate,forging, pressing, and heading, performed on metal heated to
temperatures above room temperature.
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Hot Metal. Melted, liquid iron or steel. Generally refers to tlr
liquid metal discharge from blast furnaces.
Hot Metal Furnace. A furnace that is initially charged with solid
materials followed by a second charge of melted liquid.
Hot Quenching. A process of quenching in a medium at a temperature
substantially higher than ambient temperature.
Hot Rolled. Hot rolled products are those products that are rolled to
finish at temperatures above the recrystallization temperature.
Hot Top. 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".
Hot Working. 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. Coating a metal with a second metal by immersing
the first in a solution containing ions of the second.
Impact Extrusion. A cold forming process in which the metal is force-*
by impact to flow around the punch, forming a tube with a soli
bottom.
In Tandem. 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.
Indirect Extruction (Inverted). An extrusion process in which the
metal is forced back inside a hollow ram that pushes the die.
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. A large block shaped steel casting. Ingots are intermediates
from which other steel products are made. An ingot is usually the
first solid form the steel takes after it is made in a furnace.
Ingot Iron. 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.
Ingot Mold. A mold in which ingots are cast. Molds may be circular,
square, or rectangular in shape, with walls of various thickness.
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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 pet iron, the product made by the reduction of
iron ore. Iron in the steel mill sense is impure and contains up to
4% dissolved carbon along with other impurities.
Iron Ore. The raw material from which iron is made. It is primarily
iron oxide with impurities such as silica.
Iron Scrap. Blast furnace metal or other iron which may be salvaged
by r erne It ing in a blast furnace or in a steelmaking furnace.
Killed Steel. 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.
KIP. A load of 1000 Ib, or 453.59 kg.
Kish. A graphite formed on hot metal following tapping.
Ladle. A large vessel into which molten metal or molten slag is
received and handled. Molten metal may be transported short distances
by carrying it in a ladle.
Lap. A surface defect appearing as a seam caused from folding over,
during hot rolling, fins or sharp corners and then rolling or forging,
but not welding them into the surface.
Lap Weld. 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 the skelp are beveled or scarfed so that when they
are over-lapped they can be welded together.
Light Oil. 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 2007C and from which benzene, toluene,
fcylene and solvent napthas are recovered.
Lime Boil. 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 the gas stream.
Liming. Application of lime to pickled rod produced in the wire
industry for protection against corrosion and as a lubricant for cold
drawing.
Machlnin
no. In general, the cutting away of the surface of a metal by
of power driven machinery. Specifically, a method of
conditioning steel by machining away from the surface;
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Malleability. The property that determines the ease of defermine
metal when the metal is subjected to rolling or hammering. The m
malleable metals can be hammered or rolled into thin sheet more east.
than others.
Mandrel. (1) A rod used to relation the cavity in hollow metal
products during working. (2) A metal bar around which other metal may
be cast, bent, formed or shaped.
Manganese-Nickel-Cooper. An obsolete high-strength low alloy steel,
intendedprimarilytor weight reduction by means of high strength,
greater toughness and improved welding characteristics in applications
requiring cold forming and moderately severe impacts in low
temperature service.
Meltdown. The melting of the scrap and other solid metallic elements
of the charge.
Mill Edge. Normal rounded edge produced in hot rolling. Does not
conform to any standard radius. This replaces the old term, band
edge.
Mill Finish. A surface finish produced on sheet and plate,
characteristic of the ground finish on the rolls used in fabrication.
Mill Length. Those lengths which can be most economically handled h*
the mill.Upper and lower limits are set by equipment limitations
the mill.
Mill Scale. 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.
Mold. A form or cavity into which molten metal is poured to produce a
desired shape.
Molten Metal Period. The period of time during the electric furnace
steelmaking cycle when fluxes are added to furnace molten bath for the
purpose of slag formation.
Molybdenum. A special alloying element commonly used to increase
hardenability of steel. Molybdenum is sometimes added to Stainless
Steel to enhance its corrosion resistance to certain chemicals.
Molybdenum is commonly called "moly".
Molybdenum Oxide. A commercial compound of molybdenum (Mo03.) which is
used as a finishing agent in making molybdenum steels.
Nickel. A metallic element used in some metals.
Non-Standard Steel. A steel is classed as non-standard when th
chemicalcomposition or mechanical properties specified do nov
coincide with or encompass the ranges or limits of a standard steel
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(AISI or ASTM), or when restricted ranges or limits are outside the
ranges or limits of a standard steel.
Normalize. The normalizing process which is commonly applied to steel
articles of heavy section consists oft heating to a temperature about
1007F above the critical range and cooling in still air.
Off Size. Rolled steel, too light or too heavy to meet requirements.
Oiled. Application of a suitable oil to final product to retard
rusting. Where surface 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.
Open Hearth Furnace. A furnace for melting metal, in which the bath
is heated by the convection of hot gases-over the surface of the metal
and by radiation from the roof.
Open Plate Panel Hood. A 4.5 meter to 6 meter square, rectangular or
circular cross sectional shaped conduit, open at both ends, which is
used in the BOF steelmaking process for the combustion and conveyance
of hot gases, fume, etc., generated in the basic oxygen furnace,' to
bhe waste gas collection system.
Ore. A mineral from which the metal can be extracted profitably.
Ore Boil. The generation of carbon monoxide by the oxidation of
carbon.
Ovals. A hot rolled carbon steel bar product which is oval in cross
section.
Overfill. A defect in a rolled bar or other section which is an
overfull ness on some part of the surface. Among the causes are worn
rolls and extrusion into the clearance of the rolls, lt+1 Oxide.
Usually refers in the steel industry to the oxides of iron, of which
there are three principal onest FeO, Fe304, Fe203. In addition,
there are many mixtures of these oxides 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 the surface of steel objects which are to be
coated with tin, zinc, or other metals.
Oxidize. 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 002, Si to Si02, Mn to MnO.
Oxidizing Agent. A substance added to a mixture for the purpose of
oxidizing some constituents. For example, iron ore
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Oxidizing Slaos. Fluxing agents that are used to remove certah
oxidessuch as silicon dioxide, manganese oxide, phosphorus pentoxide
and iron oxide from the hot metal.
Pass, (l) Movement of a piece of steel through a stand of rolls. (2)
The open space between grooved rolls through which is rolled the steel
which is being processed.
Patenting. In wire making, a heat treatment applied to mediumcarbon
orhigh-carbon steel before the drawing of wire or between drafts.
This process consists of heating the 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.
Palletizing. The processing of dust from the steel furnaces into a
pellet of uniform size and weight for recycle.
Pickle. Chemical or electrochemical removal of surface oxides.
Pig. An ingot of virgin or secondary metal to be remelted for use.
Pig Iron. Inpure iron cast into the form of small blocks that weigh
about 30 kg. each. The blocks are called pigs.
Piling. A form of rolled structural shape of two typesi sheet piling,
arid bearing piling. The three forms of sheet pile - straight, arch
type and zee - are used for such types of construction as docks,
breakwaters, coffer dams, etc. Bearing piles, which range from 14 in.
to 8 in. in depth, are heavy, wide flange sections for foundation
work, etc.
Pinch Pass. A pass of sheet through rolls that are set to give a very
light reduction.
Pinch Rolls. Rolls used to regulate the speed of discharge of cast
product from the molds.
Distillate from tar.
Plain Carbon Scrap. Scrap steel with less than: 1.65 pet manganese,
0.60 pet silicon, 0.60 pet copper, or any other alloying element added
for a special alloying effect.
Plate. 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
Pouring. The transfer of molten metal from the ladle into ingot molds
or other types of molds; for example, in castings.
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Preheating. (DA 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.
Press Forging. The forging process in which metal stock is formed
between dies, usually by hydraulic pressure. Press forging is an
operation that employs a single, slow stroke. Compare with hammer
forging.
Primary Scale. Oxide of iron (Fe3pi) which is formed while the steel
is being heated.
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. The station at which the Incandescent coke in the coke
car is sprayed with water to prevent combustion. ,/ Quenching of coke
requires about 500 gallons of water per ton of coke.
Quenching. A process of rapid cooling from an elevated temperature by
contact with liquids, gases or solids.
s
di
uenching Crack. A fracture resulting from thermal stresses induced
uring rapid cooling or quenching. Frequently encountered in alloys
that have been overheated and liquated and are thus "hot short."
Recuperator. A piece of equipment for recovering heat from hot, spent
gases and using it for the preheating of incoming fuel or air. This
is a continuous operation, in which the incoming materials pass
through pipes surrounded by a chamber through which the outgoing gases
pass.
Reducing Slag. Used in the electric furnace following the slagging
off ol an oxidizing slag to minimize the loss of alloys by oxidation.
Refining. Oxidation cycle for transforming hot metal (iron) and other
metallies into steel by removing elements present, such as silicon,
phosphorus, manganese and carbon.
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Refractory. Ideally, any substance which Is infusible at the highes
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) it would not react
chemically with substances in contact with it.
Rod Mill. (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.
Roll Forming. (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 varioius contours,
sometimes called "molded sections." (2) A process of coiling sheet
into open cylinders.
Roll Scale. 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.
Roll Table. A conveyor-type table surface that contains a series oi
small rolls over which metal products pass during processing.
Roughing Stand. The rolls used for breaking down the ingot or billet
in the preliminary rolling of metal products.
Round Cornered Squares. A bar product square in cross sections with
rounded corners with size ranges 3/8 in. to 8 in., inclusive.
Runner. 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.
Runout. Escape of molten metal from a furnace, mold or melting
crucible.
Scale. An oxide of iron which forms on the surface of hot steel.
Sometimes it forms in large sheets which fall off when the steel is
rolled.
Scarfing. Cutting surface areas of metal objects, ordinarily by using
a gas torch. The operation permits surface defects to be cut from
ingots, billets, or the edges of plate that are to be beveled for butt
welding.
Scrap. Iron or steel discard, or cuttings, or junk metal, which can
be reprocessed.
Secondary Scale. Oxide of iron which is formed on hot steel while it
is being rolled or forged.
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Self-Hardening Steel A steel containing sufficient carbon or
alloying element orboth, 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.
Semi-Finished Steel^ steel in the form of ingots, blooms, billets, or
slabs for forging or rolling into a finished product.
Semi-Killed Steel, steel incompletely deoxidized, to permit evolution
of sufficient carbon monoxide to offset solidification shrinkage.
Shake-Out. The operation of removing castings from their molds.
Shear. In a steel mill, a machine for cutting steel products. There
are many kinds of shears, but the general principle is the same as
that used for shearing cloth or paper; the work is held upon a lower
blade and an upper blade is thrust down, severing the piece. Steel
shears may be classified: as to kind of "drive - hydraulic and
electric; as to the work done - cropping, squaring, slab, bloom,
bilelt, bar shears; as to type of mechanism - rotary, rocking, gate,
guillotine, alligator shears; as to movement of work while shearing -
flying shears.
Silico Manganese. An alloy containing silicon and manganese. In the
open hearth process, it is used as a deoxidizer in the furnace and for
the introduction of manganese and silicon into steel.
Sinter. In blast furnace usage, lumpy material which has been
prepared from flue dust. The dust is agglomerated by heating it to -a
high temperature. Sinter contains valuable amounts of combined iron.'
Skelp. 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.
Skin. A thin surface layer that is different from the main mass of a
metal object, in composition, structure or other characteristics.
Slab. A semifinished block of steel cut from a rolled ingot, with its
width at least twice its thickness. It differs from a bloom which is
square or nearly so. Slabs are the product of a slabbing mill, or a
blooming mill.
Slab Shear. A shear for cutting a rolled ingot into slab lengths.
This shear also cuts off the discard or crop.
Slabbing Mill. A mill which rolls ingots into slab shapes.
Slag. A product resulting from the action of a flux on the
nonmetallic constituents of a processed ore, or on the oxidized
metallic constituents that are undesirable. Usually slags consist of
combinations of acid oxides with basic oxides, and neutral oxides are
added to aid fusibility.
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Slag TOD. A variation of the Hot Top.
Soak. 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.
Soaking Pit. A furnace or pit for the heating of ingots of steel to
make their temperature uniform throughout.
Spark Box. A solids and water collection zone in a basic oxygen
furnace hood.
Spieaeleisen (Also Spiegel). A pig iron containing 15 to 30 pet Mn
and 4.5 to 6.5 pet C.
Sponge Iron. The material produced by the reduction of iron oxide
with carbon, without melting.
Stainless. (1) A trade name given to alloy steel that is corrosion
and heat resistant. The chief alloying elements are chromium, nickel
and silicon in various combinations with a possible small percentage
of titanium, vanadium, etc. (2) by AISI definition, a steel is call
"Stainless" when it contains 4 pet or more chromium.
Stainless Steel. Any steel containing four or more pet chromium is
classified asTtainless. However, there are many grades for specific
purposes. These grades may contain nickel or molybdenum or both, but
always chromium.
Steel. 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
pocess (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%.
Steel Ladle. A vessel for receiving and handling liquid steel. It is
made with a steel shell, lined with refractories.
Stools. Flat cast iron plates upon which the ingot molds are seated.
Stoves. Large refractory filled vessels in which the air to be blown
into the bottom of a blast furnace is preheated.
Strand. A term applied to each continuous casting mold and its
associated mechanical equipment.
Stretcher Flattening. 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.
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Strip. Hot Rolled r«rtv»i steel. Flat hot rolled carbon steel produced
Incoilsorin cut lengths is classified as hot rolled carbon steel
strip when the product is within the following sire limitations:
Width Thickness
up to 3-1/2 in. incl. .0255 to.2030 in. incl.
over 3-1/2 to 6 in. incl. .0344 to .2030 in. incl.
over 6 to 12 in. incl. .0568 to .2299 in. incl.
Support Rolls. Rolls used in the casting strand for keeping cast
products aligned.
Tandem Mill. A mill with a number of stands in succession.
Tap Hole. 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.
Tap to Tap. Period of tine after a heat is poured and the other
necessary cycles are performed to produce another heat for pouring.
Tapping. Transfer of hot metal from a furnace to a steel ladle.
Tar. The organic matter separating by condensation from the 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.
Teeming. Casting of steel into ingots.
Temper. 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.
Tempering. A process of reheating quench-hardened or normalized steel
to a temperature below the transformation range, and then cooling at
any rate desired.
Tensile Strength. 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."
-------
Terneplate. Steel sheet, hot dip coated with terne metal (10-15
tin; 85-90 pet lead).
Three-High Mill. A stand which has three rolls, one above the other.
The steel which is being rolled passes one way between the bottom and
middle rolls, and the other way between the middle and top mills.
Tinplate. A mild steel of low carbon content bearing a coating of
commercially pure tin. Two manufacturing processes are in use at the
present time, hot dipped and electrolytic tinning lines.
Titanium. 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.
Train of Stands. 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.
Tundish. A preheated covered steel refractory lined rectangular
container with several nozzles in the bottom which is used to regulate
the flow of hot steel from the teeming ladles.
Tungsten. A metal which is sometimes added to steel to make tool
steel.
Two-High Mill. A stand having only two rolls. Some two-high mills
are reversing with screw-downs to adjust the rolls; other 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.
Universal Plate Mill. A mill for rolling steel plates, which has
verticalaswell as horizontal rolls, so that its product has rolled
edges.
Upsetting. (1) A metal working operation similar to forging. (2) The
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. A wet type collector that uses the throat for
intermixing of the dust and water particles. The intermixing is
accomplished by rapid contraction and expansion of the air stream and
a high degree of turbulence.
Wash Oil. A petroleum solvent used as an extractant in the co
plant.
Waste Heat Boiler. Boiler system which utilizes the hot gases from
the checkers as a source of heat.
-------
Water Tube Hood. 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 steelmaking process for the combustion and
conveyance of hot gases to the waste gas collection system.
Wet Scrubbers. 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.
Wire Rod. A semifinished product from which wire is made. It is
generally of circular cross section approximately 1/4 in. in diameter.
Work Rolls. 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 with the work
rolls.
-------
Appendix E
PLANT BY PLANT SUMMARIES
OF THE USE AND IMPACT
OF INTRA-PLANT TRADING
-------
ARMCO STEEL, MIDDLETOWN, OH
The NPDES permit issued to Armco Steel's Middletown Ohio Works effective March 31,
1987 contained a trade involving five outfalls: 613, 614, 631, 641, and 005. This trade is also
included in the facility's December 1,1992 permit, with slightly different limits, and is still in effect.
The use of the outfalls involved in the trade at the time the permit was issued is described below.1
Descriptions of Qutfally Involved in Trad'"g
Outfall 613
This internal outfall conveys treated effluent from the blast furnace and sinter plant. This
treated effluent mixes with other wastewaters, including those from outfall 614, prior to discharge.
The permit specifies limits for the combined effluent from outfalls 613 and 614.
Outfall 614
This internal outfall conveys treated effluent from the cold mill coating and acid pickling
lines, and boiler house/water softener operations. The treated effluent mixes with other wastewaters,
including those from outfall 613, prior to discharge. The permit specifies limits for the combined
effluent from outfalls 613 and 614.
Outfall 631
This internal outfall conveys treated effluent from the basic oxygen furnace.
Outfall 641
This internal outfall conveys treated effluent from cold mill and pickling operations.
Outfall 005
This outfall conveys treated wastewater from the hot forming operations, continuous caster,
vacuum degasser (at the basic oxygen shop), and blowdown water from the non-contact cooling
water recycle system associated with slab reheat furnaces. This effluent combines with cooling and
storm waters prior to discharge.
1 These descriptions are based on descriptions in the 1992 permit. The relevant portions of the
1992 permit are reproduced in Attachment 1 to this report.
E-l
-------
The Trade
The use of trading at this facility involves the five outfalls described above, and four
parameters: total suspended solids (TSS), oil and grease, lead, and zinc. As indicated in the
descriptions above, several of the outfalls contain wastewater either from cold forming operations
(which are not eligible for trading) or from operations whose effluent is governed by effluent
guidelines other than the iron and steel guidelines (i.e., metal finishing). The trade involves only
that portion of the effluent eligible for trading. The details of the trade are presented in Exhibit
E-l.2 Appendix G walks the reader through a sample trading calculation.
Effluent Limits Differences
In the permit, total suspended solids (TSS) and oil and grease limits for outfall 005 are more
stringent than required by the effluent limitation guidelines (ELGs). A portion of the reduction
below the ELG limits is applied to allow effluent from outfalls 613/614, 631, and 641 to exceed the
ELG limits for these parameters. In addition, lead and zinc limits for outfalls 641 and 005 are more
stringent than required by the ELG limits. A portion of the reduction below the ELG limits is
applied to allow effluent from outfalls 613/614 and 631 to exceed the ELG limits for these
parameters.
For example, the draft permit calculations show combined monthly average TSS limits for
these five outfalls of 7,213 pounds per day, 379 pounds below ELG limits of 7,593 pounds per day
(6,821 pounds from iron and steel wastewater and 772 pounds from non-steel wastewater).3 This
reduction is achieved because the limit at outfall 005 is below the ELG limit by a greater amount
than the amount by which the combined effluent limit for outfalls 613/614, 631, and 641 exceeds
ELG limits. As the exhibit shows, the sum of the limits in the draft 1992 permit for these five
outfalls are also below the maximum allowed under the ELG for oil and grease, lead, and zinc.
Compliance Cost Differences
If the option to trade had not been available, the plant would have had to meet ELG limits
at all the outfalls. According to a plant official, Armco Steel would most likely have installed sand
filters at outfall 631 and either outfall 613 or 614 (probably outfall 613) to control TSS and lead.4
The official estimated the capital cost of these filters at $1 million each, a total capital cost of $2
million (1993 dollars).5
2 The information presented here is based on calculations prepared for the 1992 permit. These
calculations are the only readily available information on the trade. The limits they arrive at differ
slightly from the limits in the final permits. In addition, the 1987 and 1992 permit limits are slightly
different from each other. Nonetheless, the trade as described here appears to be the basis for the
current permit limits.
3 The final 1992 permit shows combined limits 951 kilograms below ELG limits.
4 This assumes that controlling suspended lead would allow the effluent to meet the ELG limits
(i.e., dissolved lead is below ELG limit).
5 Donald R. Perander, Senior Staff Engineer, Environmental Affairs.
E-2
-------
Control of zinc at outfall 631 would have been achieved by the sand filters discussed above.
The final permit limits for zinc at outfalls 613/614 reflect the resolution of issues in addition to
trading, such as waste load assimilation and water quality standards. Because these other issues had
priority over trading, Armco officials were not able to estimate the additional capital costs that
would have been associated with zinc control at these outfalls had trading not been available.
Readily available information on plant operations at the time of the permit is insufficient to allow
an engineering estimate to be made.6
Thus, had trading not been allowed, at least $2 million (1993 dollars) in additional pollution
control capital costs would have been incurred. The annual operation and maintenance costs that
would have been associated with this additional treatment capita] were estimated at five to ten
percent of installed capital costs, or $100,000 to $200,000 (1993 dollars). The trade was in place
under a draft permit from 1983, prior to final permit approval in 1987. Thus, estimated compliance
cost differences are calculated from 1983 onward.
Under the assumptions outlined in Appendix F, the present value through the end of 1993
of the estimated capital cost of additional treatment that would have been required in the absence
of trading is $3.9 million (1993 dollars). In addition, the present value of the operation and
maintenance expenses associated with this additional treatment is estimated at $2.4 million (1993
dollars). Thus, the present value of the additional costs that Armco Steel, Middletown, would have
incurred without the trade is estimated at $6.3 million (1993 dollars).
6 Mr. Perander did not feel that additional treatment equipment would have made a substantial
reduction in effluent loadings at outfall 641.
E-4
-------
Eiftibit E-1
EFFLUENT LIMITS (Iblrt.y)
AflMCO STEEL COMPANY
MIOOLETOWN OHIO
ToW Sutp*nd«4 SoHdm
30-OiyAwio*
OulWIi «1V»M
CUIMI931
Outfall 041
OuftllOOS
ToM
ELG Umlu Eld IMa
LaatCeMFaiiring For CoM Forming
«nd Non-SM and Non-SMI
Modlnad
EKum
1:301
4,714
9921
2M
772
(iMSOnfl)
1.CC7
7K
1.97
2.Z18
7.113
Minimum
Raqulrad
Actual Reduction
IncfMM in Umt
in Uml (115 pticonO
IM
Z.4M
Aenul fteduolon In
Uml Pinmmd
Rtducun Duchiigf
2.500
MOO
Daily Mutmum
OutfallaOIMM
Ouiutoai
Outfall 041
OUIMI009
Tool
3.300
990
1.407
18092
7.S1S
123B
27M
C.122
ta.asr
3.S5J
1M
«.H7
(.U7
and Nan-SMI and
For CeU Fofnlng
Aetul
MFnlmum
Htqulfld
(Wuctton
in Uml
Actual Reduction In
LbnH
OutWIMI
duMiooe
Tettl
OaVyMuImm
OuMIOH
lamt
201
1.2S7
1.457
3.375
3.077
1.110
J.1M
IJ47
SI
1SB
1*3
M
82
197
187
Teullwd
ELOUnlH ELOLMK
LMCoMFormlttg For CeM Fanning Effwnl
wid Nan-SlMl and Non-SMI LMMoni
(1M20ran)
Mini mm
ItoqulnMl
InUnM
Amd
Umi
DlBftOTJI
30>0iy Awmgt
OUMI641
OuKillOOS
•J7
117
300
100
1243
157
140
147
1107
IM
!40
091
311
0*2
434
300
130
43*
044
Dally M*jlmun>
CXIIM031
Ou«WI041
1736
3 S3
• 00
T«wU
719
124*
32.10
901
781
190
1674
»SO
240
1110
004
4»
11 a
iia
Teal Sue
ELOUmttt
LMtCaMFanriiig For Cold FomUng
Minimum
ft****
EMuant *CMI
UtrtgBataflB IflCfBiWB
0992 OraM In Lin*
Ulrtl
Roduoaenln
Pw
Qla
OMMt«1M14
CUU041
OMMOOS
TOM
40)
2.02
1049
351
199
94?
1920
MD
190
009
2130
42)
06*
909
990
409
199
997
097
OtllyMuimum
OwMi 911/914
OU1M041
OUMIOOI
TOM
24.21
».»
iaoe
789
4947
479
1U1
4181 to 39
999 329
994
191
9074 1397
1904
1021
499
1921
-------
Exhibit E-2
EFFLUENT UMfTS (Ibl/dty)
BABCOCK AND WtLCOX
BEAVER FALLS. PENNSYLVANIA
Minimum
ftequtad
Toiil Suip«id*d Solldt ELGUmm ELGUmlBlor Modifed Aciuil Rodurton Acnul Roducdonm
L*n Non-SMI Non-SMI EttliMM Incnui In Urn I Urn! P«milM
WIMWIM WnMtnmn Limit. InUim (IISewewQ Reduction Duchmj.
30-Oiy Average
OMM113 1597 446 H 43 4800
Outfall 119 80*00 SSiOO MOO
ToM tan 446 62043 4600 969 MOO 800
Only Mufcnum
37 a »w 73 «o ZBOO
t.«1500 1M200 HOO
TOM i.Mia (64 feaiw aoo 3220 saoo 2900
Minimum
ELGLMa ELG Unto tor Modltad Actual Rtdurtpn ACBMI Ftadueflon In
ImNon-SMl NonSMI Eflwnt Inenra toUmlt Umn P«mnM
WMMmM Umrt* InUmlt (HSpweintl Itodueaofi OhKlunj.
«ia 3T4 1179 270
(XOM119 10*00 1MOO 400
TOM loan >T4 aoon 2.70 310 400
OuBWI 11J 11*7 74* 4146 1«00
wn so* n 2100
•mat n»
-------
BABCOCK AND WILCOX, BEAVER FALLS, PA
The NPDES permit issued to Babcock and Wilcox's Beaver Falls Works effective November
18,1983 contains a trade involving two outfalls: 113 and 115. The company was reorganized in the
mid-1980s, and portions of the facility, including these two outfalls, came under different ownership.
The trade was discontinued in 1986 when the plant associated with outfall 115 was closed. The use
of these outfalls at the time the permit was issued is described below.7
Description^ €ff QutfalUf Involved in
Outfall 113
This outfall conveyed treated wastewater associated with Babcock and Wilcox's Special
Metals Works, which produces stainless steel with a very high chromium and nickel content. As
noted below, a portion of the effluent from this outfall was classified as "non-steel wastewater," and
thus not governed by the iron and steel effluent limitation guidelines.
Outfall 115
This outfall conveyed treated effluent from the Koppel Steel Mill, located near the Special
Metals Works. This was primarily cooling water and water from scaling pits.
The Trade
In the 1983 permit, limits for total suspended solids (TSS), oil and grease, lead, and zinc at
outfall 115 are more stringent than required by the effluent limitation guidelines (ELGs). A portion
of the reduction below the ELG limits is applied to outfall 113, allowing its effluent to exceed the
ELG limits for these same parameters. A portion of the effluent from outfall 113 is from non-steel
sources, and thus not eligible for trading. The trade involves only that portion of the effluent
regulated by the iron and steel ELGs. The details of the trade are presented in Exhibit E-2.'
Appendix G walks the reader through a sample trading calculation.
7 These descriptions are based on information from the 1983 permit and from conversations with
Len Zacarchuk and Victor Catania, both of whom worked for Babcock and Wilcox during the time
the trade was in effect. The relevant portions of the permit are reproduced in Attachment 1 to this
report.
8 Because of the reorganization of Babcock and Wilcox in the mid-1980s, complete information
on the trade is difficult to obtain. The information presented here is drawn primarily from the fact
sheet for the November 18,1983 permit and the associated calculations. As noted below, the limits
in the permit itself differ somewhat from-the limits laid out in the fact sheet. Neither the
Pennsylvania Department of Environmental Resources nor the former employees of Babcock and
Wilcox who provided information on the trade could explain this difference.
E-5
-------
Effluent Limits Differences
In the permit, monthly average TSS loadings for outfall 115 are 56 pounds per day below
ELG limits (552 pounds vs. 608 pounds). At the same time, the corresponding TSS limit for outfall
113 is 48 pounds above the ELG limit of 20.43 pounds per day (15.97 pounds from iron and steel
wastewater, and 4.46 pounds from non-steel wastewater). The combined monthly average TSS
loading limit for these two outfalls is thus 8 pounds below ELG limits. Similar limit reductions are
shown for the daily maximum loading limit for TSS, and for monthly average and daily maximum
limits for oil and grease, lead, and zinc.4
Compliance Cost Differences
If the option to trade had not been available, the plant would have had to meet ELG limits
at outfall 113. No official currently associated with the facilities that once made up Babcock and
Wilcox's Beaver Falls Works was able to provide detailed information on the additional treatment
that would have been required in the absence of trading to assure that effluent from outfall 113 met
ELG limits. A former Babcock and Wilcox official, who was in charge of environmental affairs at
the time of the trade, explained two factors that made the trade attractive to Babcock and Wilcox.L0
• The existing treatment plant associated with outfall 113 would have required
expansion in order to treat the effluent to ELG limits. This was not possible
on the land available — a new plant would have been required.
• The Special Metals Plant (the source of wastewater for outfall 113) was
dedicated to production of tubing for use in nuclear reactors for U.S. Navy
ships on a "cost plus" basis. Babcock and Wilcox was concerned that a new
treatment plant would not meet the Navy's cost standard.
This individual was not able to estimate the increase in treatment costs that might have been
associated with controlling effluent at this outfall had trading not been possible. Readily available
information on plant operations at the time of permit issuance is insufficient to allow an engineering
estimate to be made.
9 Note that in the final 1983 permit the limits for TSS and oil and grease for outfall 115 do not
appear to have been decreased as the calculations indicate they should have been. No explanation
for this discrepancy has been provided, but it may be a clerical error corrected in a subsequent
permit modification. Officials of the State of Pennsylvania noted that any documents modifying this
permit would have been sent to the state archives, and therefore are not readily retrievable.
Regional EPA officials discard or archive all documents over five years old. Babcock and Wilcox
has also archived all documents relating to this permit.
10 Telephone conversation with Allan Dahlgren, manager of environmental affairs at Babcock
and Wilcox at the time of the trade. 24 January 1994.
E-7
-------
BETHLEHEM STEEL, SPARROWS POINT, MD
The NPDES permit issued to Bethlehem Steel's Sparrows Point Division effective October
10, 1985 contains a trade involving two points: outfall 014 and monitor point 101. The permit
containing this trade is still in administrative effect. The operations associated with these points at
the time the permit was issued are described below.11
Descriptions of Points Involved in Trading
Outfall 014
This outfall conveys effluent from a large central treatment plant that manages wastewater
from a basic oxygen furnace, hot and cold forming operations, and finishing operations. Some of
the wastewaters associated with this outfall are not eligible for trading, as they originate from cold
forming operations (excluded from trading) or operations regulated under metal finishing guidelines.
Monitor Point 101
This internal monitor point conveys treated wastewater from blast furnace and sintering
operations.
The Trade
The use of trading at this facility is relatively complicated. As indicated in the description
above, outfall 014 contains wastewater from cold forming operations (which are not eligible for
trading) and from operations whose effluent is governed by effluent guidelines other than the iron
and steel guidelines (i.e., metal finishing). The trade involves only that portion of the effluent from
outfall 014 that is eligible for trading under the iron and steel ELGs.
In the 198S permit, limits for zinc at outfall 014 are more stringent than required by the
effluent limitation guidelines. A portion of the reduction below the ELG limits is applied to
monitor point 101, allowing its effluent limits for zinc to be set above the ELG limits. The details
of the trade are shown in Exhibit E-3.u Appendix G walks the reader through a sample trading
calculation.
11 These descriptions are based on correspondence and telephone conversations with Barbara
E. Bachman, Senior Environmental Engineer, Bethlehem Steel Corporation. The relevant portions
of documents related to trading at this facility are reproduced in Appendix 1 to this report.
12 This exhibit is based on correspondence and documentation provided by Barbara E. Bachman,
Senior Environmental Engineer. Relevant documents are reproduced in Attachment 1 to this
report.
E-8
-------
Effluent Limits Differences
As the exhibit shows, for monitor point 101, the permit allows monthly average zinc loadings
12.6 pounds per day above ELG limits (21.8 pounds vs. 9.2 pounds). At the same time, the monthly
average zinc limit for outfall 014 is 73.1 pounds per day, 14.0 pounds below ELG limits of 87.1
pounds per day (14.0 pounds from wastewater eligible for trading and 73.1 pounds not eligible for
trading). Thus, the combined monthly average loading limit for zinc from these two points is 1.4
pounds (94.9 pounds vs. 96.3 [87.1 plus 9.2] pounds) below ELG limits. Similarly, the trade results
in daily maximum zinc loading limits from these two points 4.0 pounds below ELG limits.
Compliance Cost Differences
If the option to trade had not been available, the plant would have had to meet ELG limits
for zinc at monitoring point 101. According to a Senior Engineer in Bethlehem Steel's
Environmental Regulatory Affairs Department, in the absence of the trade Bethlehem Steel would
have controlled zinc by adding filtration to the existing treatment train prior to monitoring at point
In 1983, Bethlehem estimated the capital cost of meeting "strict BAT' limits to be $2.1
million (1983 dollars) greater than the capital cost of meeting limits arrived at using the trading
provision, as well as other limit modifications not related to trading. The portion of the difference
in capital cost expenditures attributable to trading is not readily discernible. However, Bethlehem's
engineer stated that it was reasonable to assume it accounted for more than half and perhaps as
much as three-fourths of the cost difference. Thus, $1.05 million (1983 dollars) provides a
conservative estimate of the treatment capital costs that would have been incurred had trading not
been allowed.
No definitive estimate of associated operation and maintenance costs is available. However,
the company's engineer stated that as a rule of thumb, Bethlehem estimates that annual operation
and maintenance costs are fifteen percent of installed capital costs. This implies a conservative
estimate of additional annual operation and maintenance costs of $157,500 (1983 dollars) had
trading not been possible.
Under the assumptions outlined in the Appendix F, the present value through the end of
1993 of capital costs that would have been incurred in the absence of trading is $2.36 million (1993
dollars). In addition, the present value through 1993 of associated operation and maintenance
expenses is estimated at $2.47 million (1993 dollars). Thus, the present value of the costs that
Bethlehem Steel would have incurred without the trade is estimated at $4.83 million (1993 dollars).
13 Barbara E. Bachman, telephone conversations and correspondence, December 1993 through
February 1994.
E-10
-------
Exhibit E-3
EFFLUENT LIMITS (IDs/day)
BETHLEHEM STEEL
SPARROWS POINT, MARYLAND
Zinc
ELGUmrto
LOM CoM Forming
and Non-Steel
Wattewater*
ELG Limits
For Cold Forming
and Non-Steel
Waitewaten
Modified
Effluent
Limitation*
Actual
Increaia
hiUmtt
Minimum
Roquirad
Reduction
in Limit
(110 percent)
Actual
Limit
Reduction
Reduction n
Permitted
Owcharoe
3OXXay Aver«0*
OuttaUIOI
Outfall 014
Total
Daily Maximum
Outfall 101
Outfall 014
Total
92
14.0
23.2
277
400
67.7
731
73.1
171 4
171 4
21 0
73.1
948
637
171 4
235 1
>26
126
360
360
306
140
140
400
400
40
-------
Exhibit E-4
EFFLUENT LIMITS (Ibs/day)
INLAND STEEL COMPANY
EAST CHICAGO. INDIANA
Lead
ELG Limits
Modified
Effluent
Limitations
Actual
Increase
in Limit
Minimum
Required
Reduction
in Limit
(110 percent)
Actual Reduction in
Limit Permitted
Reduction Discharge
30-Day Average
Outfall 601
Outfall 61 4
Outfall 616
Total
Daily Maximum
Outfall 601
Outfall 614
Outfall 61 8
Total
0.11
1.13
4.20
5.44
0.34
3.38
12.59
16.31
020
289
216
525
0.60
8.62
6.48
1570
009
1 76
1.85
0.26
5.24
5.50
2.04
2.04
2.04
019
6.05
6.11
611
061
Zinc
ELG Limits
Modified
Effluent
Limitations
Actual
Increase
in Limit
Minimum
Required
Reduction
in Limit
(110 percent)
Actual Reduction in
Limit Permitted
Reduction Discharge
30-Day Average
Outfall 601
Outfall 61 4
Outfall 61 8
Total
Daily Maximum
Outfall 601
Outfall 61 4
Outfall 61 8
Total
0.17
1.69
6.32
8.18
0.51
5.08
18.91
24.50
0.20
2.89
4.95
8.04
0.60
8.62
14.88
24.10
0.03
1.20
1.23
0.09
3.54
3.63
1.35
1.37
1.37
014
3.99
4.03
4.03
040
-------
INLAND STEEL, EAST CHICAGO, IN
The NPDES permit issued to Inland Steel's East Chicago Works effective March 6, 1984
contains a trade involving three outfalls: 601, 614, and 618. The permit is still in administrative
effect. The use of these outfalls at the time the permit was issued is described below.14
Descriptions Of Outfall*} Involved in Trading
Outfall 601
This internal outfall conveys treated effluent from the billet caster. After this point the
effluent mixes with other treated waste water and non-contact cooling water, and discharges through
outfall 001.
Outfall 614
This internal outfall conveys treated effluent from the facility's number two basic oxygefc
furnace. This effluent is discharged through outfall 014 along with treated wastewaters from other
production operations.
Outfall 618
This internal outfall conveys filtered blowdown from the wastewater recycle systems
associated with the facility's number four basic oxygen furnace and number one slab caster. Effluent
from this monitoring point is mixed with a large quantity of noncontact cooling water prior to
discharge through outfall 018.
The Trade
The trade involves two pollutants, lead and zinc, and three outfalls, 601,614, and 618. The
1984 permit sets monthly average and daily maximum lead and zinc limits for outfall 618 more
stringently than required by the ELGs. The maximum allowable portion of the difference between
this limit and the ELG limits is applied to the corresponding limits for outfalls 601 and 614, allowing
them to be set above the ELG limits. The details of the trade are shown in Exhibit E-4.u
Appendix G walks the reader through a sample trading calculation.
14 These descriptions are based on the 1984 permit fact sheet. The relevant portions of the fact
sheet are contained in Attachment I to this.report.
13 This exhibit is based on 1984 permit fact sheet.
E-ll
-------
Effluent limits Differences
For outfalls 601 and 614, the permit allows monthly average lead loadings above ELG limits
(0.20 pounds vs. 0.11 pounds, and 2.89 pounds vs. 1.13 pounds, respectively). The corresponding
limit for outfall 613 is 2.04 pounds per day below ELG limits (2.16 pounds vs. 4.20 pounds). Thus,
the trade results in a net reduction of 0.19 pounds per day (5.25 pounds vs. 5.44 pounds) in the
monthly average loading limit for lead. As the exhibit shows, the trade results in similar decreases
in the daily maximum loading limit for lead, the monthly average loading limit for zinc, and the daily
maximum loading limit for zinc.
Compliance Cost Differences
According to an official at Inland Steel's East Chicago Works, if the opportunity to trade had
not been available, Inland Steel would have installed a small filtration plant at outfall 614.'* The
official estimated the cost of such a system as between $750,000 and Si.5 million (1993 dollars).
Inland Steel estimates annual operation and maintenance costs as approximately 7.5 percent of
capital costs, or $56,250 to $112,500 (1993 dollars). The treatment capital would have been installed
in 1984, the year the permit was issued. Inland officials note that the increased limit trading allowed
at outfall 601 did not prevent an increase in treatment cost, but simply provided a buffer for emir.
Under the assumptions outlined in Appendix F, the present value through the end of 1993
of the additional treatment capital that might have been required at Inland Steel's Indiana Harbor
Works in the absence of trading is $2.07 million (1993 dollars). In addition, the present value of
the associated increase in operation and maintenance expenses through 1993 is estimated at $1.17
million (1993 dollars). Thus, the present value of all costs that Inland Steel would have incurred
without the trade is estimated at $3.2 million (1993 dollars).
16 Robert Johnston, Staff Engineer, Environmental, Health, and Safety.
E-13
-------
LTV STEEL, INDIANA HARBOR, IN
The NPDES permit issued to LTV Steel's Indiana Harbor Works effective October 1,1986
contains trades involving four outfalls: 101, Oil, 111, and 211. This permit is still in administrative
effect. The use of these outfalls at the time the permit was issued is described below."
Descriptions of Outfalls Involved in Trading
Outfall 101
This internal outfall conveys treated effluent from cold rolling, pickling, hot-dip galvanizing,
alkaline cleaning, tinning, and chromium electroplating operations. These wastewaters originate
from two tin mills and one cold sheet mill.
Outfall Oil
This outfall conveys treated effluent from the basic oxygen furnace (BOF), a blooming mill,
a seamless mill, continuous casting operations, sintering and blast furnaces, miscellaneous shop add
water treatment plant backwash, non-contact cooling water from the BOF, and stormwater.
Outfall 111
This internal outfall conveys effluent from the filtration plant associated with a hot strip mill.
Outfall 211
This internal outfall conveys effluent from the oily waste treatment plant associated with a
cold sheet reduction mill.
The Trade
The use of trading at this facility is relatively complicated. As indicated in the descriptions
above, several of the outfalls contain wastewater from either cold forming operations (which are not
eligible for trading) or from operations whose effluent is governed by effluent guidelines other than
the iron and steel guidelines (i.e., metal finishing). The trade involves only that portion of the
effluent from each outfall that is eligible for trading under the iron and steel ELGs. Trading
involves oil and grease at outfalls 101, Oil, and 111, as well as lead and zinc at outfalls 101,011, and
211. The details of the trade are shown in Exhibit E-5.18 Appendix G walks the reader through
a sample trading calculation.
17 These descriptions are based on information contained in the fact sheet prepared for the 1986
permit. A copy of the permit itself was not readily available. The relevant portions of the permit
fact sheet are reproduced in Attachment 1 to this report.
18 The exhibit is based on information in the fact sheet for the 1986 permit.
E-14
-------
Effluent Limits Differences
As shown in the exhibit, daily maximum oil and grease limits for outfalls 101 and Oil are
more stringent than required by the ELGs. A portion of the effluent reduction below the ELG
limits is applied to allow effluent from outfall 111 to exceed the ELG limits for this parameter. In
addition, monthly average and daily maximum lead and zinc limits for outfalls 101 and 211 are more
stringent than required by the ELG limits. A portion of the reduction below the ELG limits is
applied to allow effluent from outfall Oil to exceed the ELG limits for these parameters.
For example, the draft permit calculations show that daily maximum oil and grease limits for
outfalls 101, Oil, and 111 total 8,093 pounds per day, 237.9 pounds below total ELG limits of 8,330.9
pounds per day (7,081.9 pounds from wastewater eligible for trading and 1,249 pounds from
ineligible wastewater). This trade is achieved because the combined effluent limits at outfalls 101
and Oil are below ELG limits by a greater amount than effluent limits at outfall 111 exceed ELG
limits. As the exhibit shows, the combined 1986 permit limits for lead and zinc are also below the
maximum allowed under the ELGs.
Compliance Cost Differences
If the option to trade had not been available, the plant would have had to meet ELG limits
at all the outfalls. According to a company official, without the trade, LTV would need to install
additional treatment facilities.19 LTV was not able to provide an estimate of the capital and
operation and maintenance costs that would have been associated with such facilities, and readily
available information on plant operations at the time of permit issuance are insufficient to allow an
engineering estimate to be made.
14 John Etchison, Manager, Water, Corporate Environmental Control.
E-16
-------
EFFLUENT LIMITS (Itn/diy)
LTV STEEL
INDIANA HAflBOR WORKS. INDIANA
Minimum
Raaulrad
ELO Limit* ELQUmMfof Modified Actual ftcducgon Actual
km Non-SMI Non-StMl Eflhnffl tncrau* in Omit Lint
WMHwaM Wunwatwi Unuuiloni in Umt (IISpamnQ RaducMn
l»OiyA*moi
OuHad 101 KA NA
OuttlOII MA NA
Outtllll MA NA
ToM NA NA
OuMMOl g«al 1.3MO 1.249 B BUI
OUIMOII tstat i.mo saaa
Outltl111 1WQO 534*0 1MSO
7 Ml B 1 2*9 0 S 093 0 1 MS 0 1348 7 I 582 9 237 9
Mnknum
aaumhi ELG Limit* fcx ModllM Aetul fhdueden Acnul FtadueMn In
U4*Hon-te44 NeiKStMl EDhMfit Incnm taUmtl UmJi
WMwnM Lmtrteni In Limit (HO pram) toductofi
OuiMIOI 4<1 1012 1032 4*1
QUIM011 t» 101) 491
OMM211 429 373 04*
ToM 1441 10M Z4Z» 491 »40 340
OtllyMudmum
OUMII01 1470 1857 1637 1* »
OMM011 1383 MSB 1473
OUIMI211 1287 Hit '«•
Teal 4320 1*97 «34 1473 1BZ) 18 IB
TottXnc EUSUmHi ELG Uirtti tor Uodlftid Acaul FWdueden AeBul R»duedo« In
Nen^lHl EHIiMM Inenu* InUmft Llntt PwmOM
wmmnn Umtufcrni inUmH (11«pn«Yfl ftadurton OlKhug*
1101 4J9 MM MM ««•
1011 7QB 127B 489
1911 470 «21 040
Toal 1740 3333 3239 439 318 S»
Ddlyl
1101 1470 ea» 32.89 1470
1011 2379 1*43 1470
OutM211 140* 12.00 1M
324) (2.89 11374 1470 1017 1010
-------
ExtubttE-6
EFFLUENT LIMITS (Ibe/day)
REPUBUC STEEL COMPANY
MASSILLON. OHIO
Minimum
Reqund
ToM Suspended SdMs Lnme Actual Reduction Actual Reduction m
n 1883 Increase m Unw Lnul Permuted
ELQ Units Permrl inUrml (llSparcmt) Reductan Discharge
30-Day Awaga
Outtall004 1.036 1.318 282
Outfall 603 604 280 324
Total 1.640 1,586 282 324 324 42
Dody Maximum
Outfall OO4 2.760 3.482 702
Ouuaueoa 1.372 sso 822
Total 4.132 4.012 702 807 822 120
Mnimuin
Required
Oiand&aase Limits Actual Reduction Actual Reduction in
in 1883 Increase in Limit Limit Permitted
ELG Units Permit in Urn* (115 percent) Reduction Dncnarge
30-Day Average
Outfall 004 NA NA
Outfall 603 NA NA
TOW NA NA
Daily Maximum
Outfall 004 681 882 191
Outfall 603 580 213 367
Total 1.271 1,095 161 2IB 367 178
-------
REPUBLIC STEEL, MASSILLON, OH
The NPDES permit issued to Republic Steel's Massillon Ohio Works on August 22, 1983
contains a trade involving two outfalls: 004 and 603. This permit expired in 1988, and the follow-on
permit did not contain the trade, apparently because the company had been reorganized and
portions of the plant, including these two outfalls, had come under different ownership. The use
of these outfalls at the time the permit was issued is described below.9
Descriptions of Outfall!} Involved in Trading
Outfall 004
This outfall conveyed treated effluent from billet and bar mills, and a quenching unit.
Discharge also included non-contact cooling water, surface water runoff, and ground water.
Outfall 603
This internal outfall conveyed treated effluent from several operations, including stainless
steel cold rolling and pickling operations.
The Trade
The trade involved two pollutants, total suspended solids (TSS) and oil and grease, and two
outfalls, 004 and 603. In the 1983 permit, monthly average and daily maximum TSS limits and daily
maximum oil and grease limits for outfall 603 were more stringent than required by the effluent
limitation guidelines (ELGs). A portion of the effluent reduction below the ELG limits was applied
to outfall 004, allowing its effluent to exceed the ELG limits for these same parameters. Details of
the trade are shown in Exhibit E-6.21 Appendix G walks the reader through a sample trading
calculation.
Effluent Limits Differences
As the exhibit shows, for outfall 004, the permit allowed monthly average TSS loadings 282
pounds per day above ELG limits (1,318 pounds vs. 1,036 pounds). At the same time, the TSS limit
for outfall 603 was 324 pounds per day below ELG limits (280 pounds vs. 604 pounds). Thus the
trade resulted in a net reduction of 42 pounds (1,598 pounds vs. 1,640 pounds) in the monthly
average loading limit for TSS. The trade also resulted in a daily maximum loading limit for TSS 120
pounds below ELG limits, and a 176 pound decrease in the oil and grease maximum daily loading
limit.
20 These-descriptions are based on information in the August 22, 1983 permit. The relevant
portion of the permit is reproduced in Attachment 1 to this report
21 Details of the trade axe based on a letter prepared in 1982 laying out proposed final limits,
in combination with the actual limits in the August 1983 permit. The relevant portion of these
documents are reproduced in Attachment 1 to this report.
E-17
-------
Compliance Cost Differences
If the option to trade had not been available, the plant would have had to meet ELG limits
at outfall 004. According to a wastewater management engineer formerly with Republic Steel
Corporation, in the absence of the trade the plant would have required a recycle system with deep
bed filters for the hot mill operations.22 He estimated the capital cost of such a system as between
$3 million and $6 million dollars (1983 dollars). This official was not able to provide an estimate
of operation and maintenance costs.
Under the assumptions outlined in Appendix F, the present value through the end of 1993
of the estimated capital cost for additional treatment that might have been required in the absence
of trading is $10.3 million (1993 dollars). In addition, operation and maintenance expenses
associated with this additional treatment would have been required for the years 1983 through 1988,
when the permit allowing the trade was made void due to corporate reorganization. If operation
and maintenance costs are estimated at 7.5 percent of capital costs, the present value of these
increased operation and maintenance costs is S3.9 million (1993 dollars). Thus, the present value
of the costs that Republic Steel would have incurred without the trade is estimated at $14.2 million
(1993 dollars).
2 Leonard Wisniewski, formerly of Republic Steel. Telephone conversation 3 December 1993.
E-19
-------
ROUGE STEEL COMPANY, DEARBORN, MI
The NPDES permit issued to the Rouge Steel Company effective July 19, 1984 contained
a trade involving two outfalls: 04B1 and 001. The trade is still in effect, and is included in the most
recent permit, issued January 1, 1994. The use of these outfalls at the time the permit was issued
is described below.0
Descriptions of Qutfally Involved in
Outfall 04B1
This outfall conveys treated wastewater from Rouge Steel's blast furnace operations.
Outfall 001
This outfall conveys treated wastewater from hot mill, cold mill, and slab mill operations
The trade involves three pollutants, total suspended solids (TSS), lead, and zinc, and two
outfalls, 04B1 and 001. In the 1994 permit, limits for TSS, lead, and zinc for outfall 001 are more
stringent than required by the effluent limitation guidelines. A portion of the effluent reduction
below the ELGs is applied to outfall 04B1, allowing limits for these three parameters to exceed the
ELG limits. The details of the trade are shown in Exhibit E-7.M Appendix G walks the reader
through a sample trading calculation.
Effluent Limits Differences
As the exhibit shows, for outfall 04B1, the permit allows monthly average TSS loadings 367
pounds per day above ELG limits (700 pounds vs. 333 pounds). At the same time, the
corresponding TSS limit for outfall 001 is 422 pounds per day below ELG limits (5,419 pounds vs.
5,841 pounds). Thus, the combined monthly average limit for TSS at the two outfalls is 55 pounds
(6,119 pounds vs. 6,174 pounds) below ELG limits. Similarly, the combined daily maximum limit
for TSS at these outfalls is 60 pounds below ELG limits. In addition, combined monthly average
and daily maximum loading limits for lead and for zinc for these two outfalls are below the ELG
limits.
23
These descriptions are based on conversations with Lowell Potvin of Rouge Steel's
Environmental Engineering Department, and on documents related to the trade provided by his
office.
24 This information is based on information contained in the January 1, 1994 permit and fact
sheet. The relevant portions of these documents are included in Attachment 1 to this report.
E-20
-------
Compliance Cost Differences
If the option to trade had not been available, the plant would have had to meet ELG limits
at outfall 04B1. According to an official of Rouge Steel's Engineering and Environment
Department, in the absence of the trade, Rouge Steel would most likely have added additional
clarification and filtration to the existing treatment train associated with outfall 04Bl.a
This official estimated the capital costs associated with such a system at $2 to $4 million
(1993 dollars), and annual operation and maintenance costs for such a system at 7.5 percent of
installed capital costs, or $150,000 to $300,000 (1993 dollars).
Under the assumptions outlined in Appendix F, the present value through the end of 1993
of the estimated cost of treatment capital that would have been required in the absence of trading
is $5.5 million (1993 dollars). In addition, the present value of the operation and maintenance
expenses through 1993 is estimated at $3.1 million (1993 dollars). Thus, the present value of the
costs that Rouge Steel would have incurred without the trade is estimated at $8.6 million (1993
dollars).
25 Lowell Potvin, Rouge Steel, Environmental Engineering Department.
E-22
-------
Exhibit £-7
EFFLUENT LIMITS (Ibs/day)
ROUGE STEEL
DEARBORN. MICHIGAN
Total Suspended Solidt
30-Oay Average
Outfall 04B1
Outfall 001
Total
Daily Maximum
Outtall 04B1
Outfall 001
Total
ELG Limits
333
5,941
6.174
1.001
13,301
16,302
Modified
Effluent
Limitations
Actual
Increase
in Limit
Minimum
Required
Reduction
in Limit
(11 5 percent)
Actual
Limit
Reduction
Reduction in
Permitted
Discharge
700
9.418
6,119
1,400
14,842
16,242
367
367
399
399
422
459
422
422
438
459
55
60
Lead
30-Oay Average
Outfall 0481
Outfall 001
Total
Dally Maximum
Outfall 0481
Outfall 001
Total
ELG Umrts
1 12
761
6.73
337
22.67
26.24
Modified
Effluent
Limitations
240
620
860
720
1866
2586
Actual
Increase
in Limit
128
1 28
383
363
Minimum
Required
Reduction
in Limit
(110 percent)
1 41
422
Actual Reduction in
Limit Permitted
Reduction Discharge
1 41
1 41
422
422
013
038
Zinc
30-Oay Average
Outfall 04B1
Outfall 001
Total
ELG Limits
1.66
10.76
12.43
Modified
Effluvnt
Limitations
Actual
Increase
in Limit
M inifn uffl
Required
Reduction
In Limit
(110 percent)
Actual
Limit
Reduction
Reduction in
Permitted
Discharge
360
684
1224
1 92
1 92
2.12
2.12
2 12
019
Daily Maximum
Outfall 04B1
Outfall 001
Total
9.04
32.23
3727
720
2986
37.06
216
2.16
2.37
2.37
2.37
0.22
-------
Exhibit E-8
EFFLUENT LIMITS (Ibs/day)
US STEEL COMPANY
CLAIRTON, PENNSYLVANIA
Total Suspended Solids
30-Day Average
Outfall 102
Outfall 120
Total
Daily Maximum
Outfall 102
Outfall 120
Total
ELG Limits
Modified
Effluent
Limitations
Actual
Increase
in Limit
Minimum
Required
Reduction
in Limit
(11 5 percent)
Actual
Limit
Reduction
Reduction in
Permitted
Discharge
352
6,245
6,597
600
1,876
2,476
248
248
938
12,061
12,999
1,100
5,628
6,728
285
162
162
186
4,369
4,369
6,433
6,433
4,121
6,271
-------
UNITED STATES STEEL, CLAIRTON, PA
The NPDES permit issued to U.S. Steel's Clairton Works effective March 9,1984 contained
a trade involving two outfalls: 102 and 120. The trade was not included in the foltow-on September
29, 1989 permit because one of the outfalls (outfall 102) was no longer in use. The use of these
outfalls at the time the permit was issued is described below.26
Descriptions of Outfalls Involved in Trading
Outfall 102
This internal outfall conveyed treated wastewater from rolling mills.
Outfall 120
This internal outfall conveyed treated wastewater from coking operations, and other
miscellaneous wastes.27
The Trade
The trade involved one pollutant, total suspended solids (TSS), and two outfalls, 102 and
120. In the 1984 permit, limits for TSS at outfall 120 were more stringent than required by the
effluent limitation guidelines (ELGs). A portion of the effluent reduction below the ELG limits was
applied to outfall 102, allowing its effluent to exceed the ELG limits for TSS. The details of the
trade are shown in Exhibit E-8.a Appendix G walks the reader through a sample trading
calculation.
Effluent Limits Differences
As the exhibit shows, for outfall 102 the permit allowed monthly average TSS loadings 248
pounds per day above ELG limits (600 pounds vs. 352 pounds). At the same time, the TSS limit
for outfall 120 was 4,369 pounds per day below ELG limits (1,876 pounds vs. 6,245 pounds). Thus
the combined monthly average TSS loading limit for the two outfalls was 4,121 pounds (2,476
pounds vs. 6,597 pounds) below ELG limits. Similarly, the combined daily maximum loading limit
for TSS at these two outfalls was 6,271 pounds below the maximum allowed under the ELG.
26 These descriptions are based on information from the 1984 permit and fact sheet, and from
calculations provided with the fact sheet. The relevant portions of the permit and fact sheet are
contained in Attachment 1 to this report.
27 Note -that this outfall is included in the trade despite the explicit exclusion from trading of
outfalls associated with coking operations. No explanation is provided in available documentation.
28 This exhibit is based on information from the fact sheet and calculations associated with the
1984 permit.
E-23
-------
Compliance Cost Differences
If the option to trade had not been available, the Clairton plant would have had to meet
ELG limits at outfall 102. According to an official of U.S. Steel's Environmental Affairs
Department, in the absence of the trade U.S. Steel would have had to expand the existing treatment
for the rolling mill wastewaters associated with outfall 102.s This would have included additional
cooling, clarification, and recycle facilities, as well as chemical treatment, clarification, and filtration
on the recycle system blowdown stream. In 1981, the capital cost of such a system was estimated
at $3.5 million (1981 dollars). No definitive estimate of operation and maintenance costs is
available. However, the official noted that U.S. Steel generally estimates operation and maintenance
costs at fifteen percent of installed capita] costs, or $525,000 (1981 dollars).
Under the assumptions outlined in the Appendix F, the present value through the end of
1993 of the additional treatment capital that would have been required at U.S. Steel's Qairton
Works in the absence of trading is $8.9 million (1993 dollars). In addition, increased operation and
maintenance expenses would have been required for the years 1984 through 1989, when the permit
allowing the trade expired. The present value of these operation and maintenance costs is $6.8
million (1993 dollars). Thus, the present value of all costs that U.S. Steel would have incurred
without the trade is estimated at $15.7 million (1993 dollars).
Gary Cason, U.S. Steel, Environmental Affairs Department.
E-25
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UNITED STATES STEEL, GARY, IN
The NPDES permit issued to U.S. Steel's Gary Works effective June 1,1983 contains a trade
involving three outfalls: 028, 030, and 605. This permit is still in administrative effect. The use of
these outfalls at the time the permit was issued is described below.30
ff Outfalls Involved in Trading
Outfalls 028 and 030
These outfalls convey the effluent from three terminal lagoons to the Grand Calumet River.
At the time of permit issuance, roughly 36 percent of the treated lagoon wastewater discharged from
outfall 028; the remainder discharged from outfall 030. The influent to the lagoons is contact
cooling water from hot forming mills, treated gas cleaning process wastewater from two basic oxygen
process shops, and non-contact cooling water from foundry open hearth furnaces. In addition, the
lagoons were scheduled to receive treated slab cooling water from a continuous caster recycle system
once the permit took effect. The terminal lagoons allow settling of these wastewaters prior tp
discharge from outfalls 028 and 030. The permit specifies limits for the combined effluent from
these two outfalls. Shortly after the permit was issued, the flow from outfalls 028 and 030 was
substantially reduced due to the permanent closure of many of the hot forming mills and the
foundry.
Outfall 605
This internal outfall conveys treated wastewater associated with the coolant water recycle
system for an 84-inch hot strip mill.
The Trade
The trade involves two pottutants, total suspended solids (TSS) and oil and grease, and three
outfalls, 028 and 030 (combined) and 605. la the permit, monthly average TSS limits and daily
maximum oil and grease limits for outfall 605 are more stringent than required by the effluent
limitation guidelines (ELGs). A portion of the effluent reduction below the ELG limits is applied
to the corresponding limits for outfalls 028 and 030, allowing their combined effluent to exceed the
ELG limits for these parameters. The calculations of effluent limits for the outfalls involved in the
trade are shown in Exhibit E-9.31 Appendix G walks the reader through a sample trading
calculation.
30 These descriptions are based on the fact sheet for the 1983 permit. The relevant portions of
the fact sheet are reproduced in Attachment 1 to this report
31 Details of the trade are based on the fact sheet for the 1983 permit. The relevant portions
are reproduced in Attachment 1 to this report.
E-26
-------
Effluent Limits Differences
As the exhibit shows, for the combined effluent from outfalls 028 and 030, the permit allows
monthly average TSS loadings 1,766 pounds per day above ELG limits (10,842 pounds vs. 9,076
pounds). At the same time, the daily maximum TSS limit for outfall 605 is 4,341 pounds per day
below ELG limits (725 pounds vs. 5,066 pounds). Thus, there is a net reduction of 2,575 pounds
(11467 pounds vs. 14,142 pounds) in the monthly average limit for total suspended solids. As the
exhibit shows, trading also enables an 823 pound decrease in the oil and grease maximum daily
limit.32
Compliance Cost Differences
If the option to trade had not been available, the plant would have had to meet ELG limits
at outfalls 028 and 030. In the absence of the trade, U.S. Steel would most likely have installed a
process water recycle system, and a treatment system for the blowdown water from that system."
In 1982, the cost of this equipment was estimated by U.S. Steel as approximately $22 million (1982
dollars). In addition, annual operation and maintenance costs associated with such a treatment
system were estimated by U.S. Steel as five to ten percent of capital costs, or $1.1 to $2.2 million
(1982 dollars).
Under the assumptions outlined in Appendix F, the present value through the end of 1993
of the additional treatment capital that would have been required at U.S. Steel's Gary Works in the
absence of trading is $57.7 million (1993 dollars). In addition, associated operation and maintenance
expenses would also have been required. As indicated previously, many of the facilities associated
with these outfalls shut down over the period 1983-1985. Therefore, operation and maintenance
costs associated with the treatment system would have been incurred only for those three years, 1983
through 1985. The present value of this expense is estimated at $12.1 million (1993 dollars). Thus,
the present value of the costs that U.S. Steel would have incurred without the trade allowed in the
1983 permit is estimated at $69.8 million (1993 dollars).
32 The daily maximum TSS limits were reduced below ELGs for all three outfalls. Thus these
reductions are not considered attributable to trading.
33 Victor Nordlund, U.S. Steel Gary Works.
E-28
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Exhibit E-fl
EFFLUENT LIMITS (Ibs/day)
US STEEL COMPANY
GARY, INDIANA
Total Suspended Solids
30-Day Average
Outfalls 026.030
Outfall 609
Total
Dady Maximum
Outfalls 028.030
Outfall 60S
Total
ELG Units
0.076
5,066
14.142
24.655
13.520
38.175
Modified
Effluent
Limitations
Actual
Increase
in Limit
Minimum
Required
Reduction
in Limit
(11 5 percent)
Actual
Limit
Reduction
Reduction in
Permitted
Discharge
10.642
725
11.567
22.600
2.175
24.975
1.766
1.766
2.031
4.341
4.341
1.8S5
11.345
13.200
2.575
13,200
Oil and Grease
30-Day Average
Outfalls 026.030
Outfall 605
Total
Dally Maximum
Outfalls 028.030
Outfall 605
Total
ELG Limits
NA
NA
NA
5.345
3.366
8.733
Modified
Effluent
Limitations
NA
NA
NA
6.460
1.450
7,910
Actual
Increase
in Limit
Minimum
Required
Reduction
in Limit
(115 percent)
Actual Reduction in
Limit Permitted
Reduction One huge
1.115
1.115
1,262
1.936
1,938
823
-------
Exhibit E-10
EFFLUENT LIMITS (Ibs/day)
US STEEL COMPANY
HOMESTEAD. PENNSYLVANIA
Total Suspended Solids
30-Day Average
Outfalls OB8(+115)
Outfall 010
Total
Dally Maximum
Outfalls 088(+115)
Outfall 010
Total
ELG Limits
5.747
1.800
7.547
11.703
4.795
16.498
Modified
Effluent
Limitations
Actual
Increase
in Limit
Minimum
Required
Reduction
in Limit
(11 5 percent)
200
4.210
4.410
500
7.450
7.950
2.410
2.410
2.655
2.655
2,772
3.053
Actual Reduction in
Limit Permitted
Reduction Discharge
5.547
5.547
11.203
11.203
3,137
8.548
Oil and Grease
30-Day Average
Outfalls OB8(+115)
Outfall 010
Total
Daily Maximum
Outfalls 088(+115)
Outfall 010
Total
ELG Limits
NA
NA
NA
4.386
1.200
5.586
Modified
Effluent
Limitations
NA
NA
NA
75
2.060
2.135
Minimum
Required
Actual Reduction
Increase in Limit
In Limit (115 percent)
Actual Reduction in
Limit Permitted
Reduction Discharge
860
860
989
4.311
4.311
3.451
-------
UNITED STATES STEEL, HOMESTEAD, PA
The NPDES permit issued to U.S. Steel's Homestead Works effective March 9, 1984
contained a trade involving three outfalls: 008, 010, and 115. The trade was in place until the
facility closed in the mid-1980s. The use of these outfalls at the time the permit was issued is
described below.34
Descriptions of Outfalls fnvnh/ed iii Trading
Outfall 008
This outfall conveyed treated wastewater from slab and plate mills, and a plate heat
treatment line. In the permit, limits are set for the combined effluent from outfall 008 and outfall
115.
Outfall 010
This outfall conveyed treated wastewater from structural and slab mills.
Outfall 115
This internal outfall conveyed treated wastewater from a plate heat treatment line. In the
permit, limits are set for the combined effluent from outfall 008 and outfall 115.
The Trade
The trade involved two pollutants, total suspended solids (TSS) and oil and grease, and three
outfalls, 008 and 115 (combined) and 010. In the 1984 permit, the limits for TSS and oil and grease
set for the combined effluent from outfalls 008 and 115 were more stringent than required by the
effluent limitation guidelines (ELGs). A portion of the effluent reduction below the ELGs was
applied to outfall 010, allowing its effluent to exceed the ELG limits for TSS and oil and grease.
The details of the trade are shown in Exhibit 10* Appendix G walks the reader through a sample
trading calculation.
14 These descriptions are based on information from the 1984 permit and fact sheet, and from
calculations provided with the fact sheet. The relevant portions of the permit and fact sheet are
contained in Attachment 1 to this report
35 The exhibit is based on information from the 1984 permit, fact sheet, and calculations.
E-29
-------
Effluent Limits Differences
As the exhibit shows, for outfall 010, the permit allows monthly average TSS loadings 2,410
pounds per day above ELG limits (4,210 pounds vs. 1,800 pounds). At the same time, the monthly
average TSS limit for the combined effluent from outfalls 008 and 1 IS is 5,547 pounds per day below
ELG limits (200 pounds vs. 5,747 pounds). Thus, the 30-day average loading limit for total
suspended solids is 3,137 pounds (4,410 pounds vs. 7,547 pounds) below ELG limits. In addition,
the daily maximum loading limit for total suspended solids is 8,548 pounds below the maximum
allowed under the ELG, and the daily maximum loading limit for oil and grease is 3,451 pounds
below the ELG maximum.
Compliance Cost Differences
If the option to trade had not been available, the plant would have had to meet ELG limits
at outfall 010. According to officials in U.S. Steel's Environmental Affairs Department, in the
absence of the trade, U.S. Steel would most likely have expanded the existing treatment system in
a manner similar to that envisioned at U.S. Steel's Clairton Works.36 This would have included
additional cooling, clarification, and recycle facilities. Due to the unavailability of documentation
related to this long-closed facility, officials were not able to provide an estimate of the capital and
operation and maintenance costs that would have been associated with such a system. Readily
available information on plant operations at the time of permit issuance is insufficient to allow an
engineering estimate to be made.
* Gary Cason, U.S. Steel, Environmental Affairs Department.
E-31
-------
pp
ndi
CALCULATION OF REDUCED TREATMENT COSTS
DUE TO INTRA-PLANT TRADING
-------
INTRODUCTION
As noted in the main body of the report, the present value of the reduction in treatment
costs associated with intra-plant trading is estimated at $122.7 million for the seven facilities for
which cost information was obtained. Permits incorporating trading are still in place at five of these
facilities.1 This appendix presents an explanation of how these costs are calculated.
IDENTDFICATION OF TREATMENT TECHNOLOGY
USED IN ABSENCE OF INTRA-PLANT TRADING
The treatment technology that would have been used in the absence of trading was identified
by interviewing facility environmental managers or other officials associated with the plants at the
time permits containing trades were issued. These officials were also asked to provide estimates of
the capital costs and operation and maintenance costs associated with the treatment technology.
As described in the detailed writeups in Appendix E, treatment technologies were identified for most
of the facilities, and cost estimates were provided for seven facilities. Three of the seven cost
estimates were based on analysis carried out at the time of the trade (Bethlehem Sparrows Point,
U.S. Steel Gairton and U.S. Steel Gary). The remaining costs were estimated by managers based
on their knowledge of plant operations and understanding of treatment costs. Some of the cost
estimates were provided as ranges of costs. Operation and maintenance (O&M) costs wf re
estimated as a percentage (or percentage range) of capital costs. Exhibit F-l presents the capital
and O&M cost estimates provided by the plant officials, as well as the base year for these cost
estimates.2
To provide a single point estimate of cost for each facility, the midpoint of each capital cost
range was employed. Similarly, the midpoint of each O&M percent range was applied to estimate
annual O&M costs. These values are used in the calculation of present value, presented in Exhibit
F-2. The other calculations in this table are discussed below.
UPDATING COSTS TO 1993
The Engineering News-Record Construction Cost Index (ENR CCI) was used to update
treatment capital costs to 1993 dollars.3 This standard construction index is available for twenty
cities. The calculations employ the index for the city nearest each facility; these cities are identified
in Exhibit F-2. For all cost estimates given in pre-1993 dollars, the index for December of the base
year was used. For 1993, the March index was used (the most recent available). Annual O&M costs
were derived using 1993 treatment capital costs as the base.
1 For the other three plants that have had trades, one of which is still in effect, no cost
information was obtained.
2 The base year of the cost estimate does not necessarily correspond to the year in which the
trade first took effect. The base year simply indicates whether the initial cost estimate is expressed
in 1993 dollars or in values for some prior year. If the latter is the case, the initial cost estimate
must be adjusted to account for inflation. This adjustment is described below.
3 Engineering News-Record, March 29,1993, pp. 34-39.
F-l
-------
CALCULATING'PRESENT VALUE THROUGH 1993
To calculate the present value of cost reductions through the end of 1993, the following
assumptions were made:
° treatment capital is assigned no salvage value; and
o a seven percent real discount rate is used to calculate present values."
The present value of capital costs is calculated from the year trading was implemented.5
The present value of O&M costs is calculated by adding together the present value of each year's
O&M expenditures.4 These two figures are added together to arrive at the present value of total
averted expenditures through the end of 1993.
* This is consistent with guidance from the U.S. Office of Management and Budget. See: U.S.
Office of Management and Budget, "Guidelines and Discount Rates for Benefit-Cost Analysis of
Federal Programs,* Circular A-94, October 29,1992.
5 This method — as opposed to calculating present values from the date each permit was issued
— is a simplification that reflects the uncertain timing of any additional investment in treatment
capital that would have been needed in the absence of trading. If it would have been necessary to
make such an investment prior to the year in which the trade first took effect, this assumption will
understate the present value of reductions in treatment costs due to trading. Conversely, if such an
investment would have been delayed until a subsequent year, this assumption will overstate the
present value of reductions in treatment costs. In light of these considerable uncertainties, a more
precise characterization of each trade's "start date" is unwarranted.
* An entire year of O&M costs is assessed for each year the trade was in effect, as detailed at
the bottom of Exhibit F-2. This approach is consistent with the treatment of capital costs explained
above.
F-2
-------
Exhibit F-l
ESTIMATES OF REDUCTION IN TREATMENT COSTS
DUE TO TRADING
Plant
Armco Steel
Middletown, OH
Babcock and Wilcox
Beaver Falls, PA
Bethlehem Steel
Sparrows Point, MD
Inland Steel
East Chicago, IN
LTV Steel
Indiana Harbor, IN
Republic Steel
Massillon, OH
Rouge Steel
Dearborn, MI
U.S. Steel
dairton, PA
U.S. Steel
Gary, IN
U.S. Steel
Homestead, PA
Reduced Capital
cS^DCOduUFCS
$2,000,000
NA
more than V4 but less
than 3/4 of $2.1 million
$750,000 to
$1.5 million
NA
S3 million to
$6 million
$2 million to
$4 million
$3.5 million
$22 million
NA
Base Year for
Cost Fstimatg
1993
NA
1983
1993
NA
1983
1984
1981
1982
NA
Annual O&M
Expenditure
5 to 10 percent
of capital cost
NA
15 percent
of capital cost
5 to 10 percent
of capital cost
NA
7V4 percent
of capital cost
lYi. percent
of capital cost
15 percent
of capital cost
5 to 10 percent
of capital cost
NA
F-3
-------
Exhibit F-2
CALCULATION OF PRESENT VALUE OF REDUCTION IN TREATMENT COSTS
DUE TO INTRA-PLANT TRADING
Pi««MV4lvw Pimm Value
ollUducMl AmuaJOUl ofAnntuUOlM ollolll
C«plM Eipmfllum E«pmllKmi Ej|»ndUu»
HMYMI BM.V.M Cftytof ENHCQ ENHCCI Mductan E^mftim. ftoducfen lUducDon fteducfen
PtantUnlan DiMtoTndi alTmd* torOdUn EHRCO BM.VMI 1M3 ki IM3S Thmgh IOM In 1003* Through ion Thnmgh I Ml
MMdHBMI.ON R.OOOJMO 1U3 IM3 ClndnMl tjn *.m S2.000.000 ta.M4.301 IISO.OOO 13.367940 M 301.843
mnd IMIIeo. BwM(F«ll«.PA NA '
IMS IMI Mum. 1.107 4loaa ti.m«n t2.Mi.Mt 1208.201
**** *"" •'•"*«• ta.OM.2B7
5.441 HMO.OOO K.SI3.3M t2Z9,OOO
••OM M-aM-8B7 """^ •"-•
IMI 10e> CMag. 4.Z3I S.M4 *20J11.2H H7.M3.M. t2.IM.4W .I2..44.O47
ttO.732,002
AmooSlMl BrtiWMm MindSMl Bipufalfc Roug* SMI US 8ml US SMI
MMdtokmn SpmamPl bid Hwboi Mirtltpn OMibam Ctalnan. PA Guy. M
t2»9.073 10 ID *772£74 10 10 $4.324.775
tZ7».7W 10 t19».12» 03*313 1413,691 tl.3M.517 t4.04l.64«
(384,zn SI44J72 tns.ost naewa ILMJU ta.r77.42t
taat.114 t13».4M M10JM 1361401 (I.IMM3 tO
IBS? tza.iio tml4sa tia.«24 tutjm cur AM ti.oe7.7ii to
IMt KtOja3 t2M.205 1111.340 SHI^MS t315.5 74 tlJttlJUl SO
IMS »IO».«1» S00JM S1IOJM H (2S4.S30 SHOMS SO
isso tisa.rsa tau.ao* tiouM to tm.sa to to
IMI (I7I.73S 13MMO SM.M1 M 1257,003 S> SO
IM3 tIMAOO t22>.«35 Sn.3B1 M S240.7W M SO
IM3 tlSO.OOO S2M.20I «M47S SO t225.0M 10 SB
F-4
-------
Appendix G
CALCULATION OF PERMIT LIMITS IN INTRA-PLANT TRADING
-------
[jura-plant trading requires that the net discharge of traded pollutants be less than the
discharge allowed without the trade. For trades involving total suspended solids or oil and grease,
the reduction in net discharge must be approximately 15 percent; for trades involving any other
pollutants, the reduction must be approximately 10 percent. This appendix walks the reader through
the calculation of such a reduction.
As a simple example, assume a plant has two outfalls, outfall A and outfall B. Furthermore,
assume that the effluent limitation guidelines (ELG) daily maximum limit for total suspended solids
(TSS) on outfall A is 1,000 pounds, and the corresponding limit on outfall B is 2,000 pounds. Using
intra-plant trading, the discharger might propose to increase the limit on Outfall A to 1,100 pounds,
exceeding the ELG limit by 100 pounds. In order to do so, the discharger must reduce TSS at
outfall B by IS percent more than the limit at outfall A is increased, or by 115 pounds. Thus, the
new limit at outfall B would be 1,885 pounds (2,000 pounds -115 pounds). Without trading, the
maximum TSS loading permitted from these two outfalls would have been 3,000 pounds. Using
trading, the maximum loading would be 2,985 pounds (1,100 pounds + 1,885 pounds), a net Limit
reduction of 15 pounds (3,000 pounds - 2,985 pounds). This is illustrated in Exhibit G-l.
Exhibit G-l
SAMPLE CALCULATION OF PERMIT LIMITS USING INTRA-PLANT TRADING
INVOLVING TWO OUTFALLS
(Pounds per Day)
Outfall
Outfall A
Outfall B
Total
ELG
Limits
1,000
2,000
3,000
Limits Using
Intra-Plant
Trading
1,100
1,885
2,985
Actual
rn_nmo-jLJi_n_ *•»
Limit
100
100
Minimum
Required
Reduction
in TJmit
115
Actual
Reduction
in Limit
115
115
Reduction
in Permitted
Discharge
15
A more complicated trade, involving five outfalls, is illustrated in Exhibit G-2. This trade
is more typical of the actual trades described in Appendix E. In this example, the limits at three
of the outfalls (C, D, and G) are increased above the ELG limits by a total of 1,000 pounds. In
order to meet the act reduction requirement, the minimum reduction in other limits must total 15
percent more than this, or 1,150 pounds (1,000 * 1.15=1,150). Limits at outfalls E and F are
reduced below ELG limits by a total of 2,000 pounds, more than the minimum 1,150 required. The
final column in the exhibit records the total reduction in permitted discharge from these outfalls -
1,000 pounds (19,000 -18,000). The exhibits in Appendix E follow this general format, although
some are complicated by the removal of wastewaters not eligible for trading.
G-l
-------
Exhibit G-2
SAMPLE CALCULATION OF PERMIT LIMITS USING INTRA-PLANT TRADING
INVOLVING FIVE OUTFALLS
(Pounds per Day)
Outfall
Outfall C
Outfall D
Outfall E
Outfall F
Outfall G
Total
ELG
Limits
5,000
3,000
2,000
8,000
1,000
19,000
Limits Using
Intra-Plant
Trading
5,300
3,400
1,500
6,500
1,300
18,000
Actual
Limit
300
400
300
1,000
Minimum
Required
Reduction
in limit
1,150
Actual
Reduction
in Limit
500
1,500
2,000
Reduction
in Permitted
Discharge
1,000-
G-2
-------
Appendix H
FEDERAL REGISTER NOTICE
ANNOUNCING ETA'S EFFLUENT GUIDELINES PLAN
-------
41000 Federal Register / Vol. 57. No. 174 / Tuesday. September 8. 1992 / Notices
ENVIRONMENTAL PROTECTION
AGENCY
IFW.-419W]
RINM40-AA90
EffiUMItQll
AOINCY: Environmental Protection
Agency (EPA).
ACTION: Notice of affluent guidelines
plan.
BUMMAirc-Thu notice announce! the
Agency's plan for developing new and
revised effluent guidelines, which
regulate industrial discharges to surface
waters and publicly owned treatment
works (POTWtl- Section 30*(m) of the
Clean Water Act requires EPA to
publish a biennial Effluent Guidelines
Plan.
UHUltfl DATE October a, 1992.
anoMMMr The public record for this
notice is available for review in EPA's
Headquarters Library, room M24M. 401
M Street SW., Washington. DC The
EPA publk information regulation (40
CFR part 2) provides that a reasonable
fee nay be charged for copying.
FOB nunrnn usFomuTton COHTACT
Eric Strauler. Engineering and Analysis
Division (WH-4S2). U.S. Ennonunental
Protection Agency. 401M Street SW.
Washington. DC 20*60, telephone 202-
r*mr
I. Legal Authority
II. Introduction
A. Purpose of Today's Notice
B. Overview of Today's Notice
UL1802 Proposed Efflusat Ctddattus Han
IV. 1982 Effluent Guidelines Plan
^Regulations
i. Ongoing Rulemakugs
i New Rulatnskings
B. Preliminary Studies
C. Summary of Changes Fran Proposed
PUn
V. Public Comments
A. Metal Products and Machinery Category
a Basis for Conducting Pfelinunary Stadias
C Overall Effluent Guidelines PUn
0. H>A DtsennoB Not To Regaiate
Following a PwUmmary Study
B. dean Water AcUUejaiwaients
Retarding Toxic and rtoncoavauanal
Pouutsnu
F. Relationship of CUan Water Act and
Pollution Prevention Act
C. Relative Utility of POTW Local Limit*
Compared to National Categorical
Pretnatmant Standards
VL Future Effluent CuidaUan PMBS
va
I. Legal Authority
Thii nonce it publithed under the authority
of tecoon 304(m) of the Clean Water Act 33
U.SC 1314(81].
0. Introduction
A. Purpose of Today's Notice
Today's notice announces the
Agency's second biennial Effluent
Guidelines Plan for developing new and
revised effluent guidelines pursuant to
section 304(m) of the Clean Water Act
(CWAJ.
EPA proposed this plan on May 7,
1992 (57 PR i9748)(uProposed Plan").
The Agency invited comment on the
notice until June & 1902. Today's notice
summarizes and addresses the major
comments the Agency received.
B. Overview of Today's Notice
The Agency intends to develop
effluent limitation guidelines and
standards ("effluent guidelines") as
follows:
1. Continue development of the nine
ongoing rules: Pulp. Paper and
Paperboard: Pesticide Chemicals
(Manufacturing); Pesticide Chemicals
(Formulating F*** Packaging); Offshore
Oil and Gas Extraction: Coaatal Oil and
Gee Extraction: Organic Chemicals.
nasties and Synthetic Fibers (Remand):
Waste Treatment Pharmaceutical
Manufacturing; and Metal Products and
Machinery. Phase 1.
2. Develop effluent guidelines far each
of the following point source categories:
Waste Treatment. Phase 2: Industrial -
Laundries: Transportation Equipment
Cleaning; and Metal Products and
Machinery. Phase Z
iBegm approximately two
DsTBliBUlsKi^i^ fltDfllflfl OI DAfudUBf DOIOt
source categories each year. Each
preliminary study will generally take
approximately two yean to complete.
4. Start development of additional
guidelines (either new or revised). Point
source categories will be identified in
future biennial Effluent Guidelines
Plans. Eight rules would be begun on e
staggered bajisdurmgtheyears 1996 to
Appendix A-Psragraph • of Consent Decree
Under Deveb L New Categories To
Be Regulated. «ad PnUmmarr f
2DO&*
These actions are identical to those
described in the Proposed Phut
ULlMB
Pita
In the Proposed Plan. EPA described
Ite intent to continue development of 9
ongoing ralemakmgs. develop U new
rules over en U year period and
conduct 11 preliminary studiM over a a .
yew period The Proposed Pun set Corn
EPA's rationale for the selection of
new or revised effluent guidelines The
Proposed Pisn alto described the
relevant statutory framework, the
components and process for
development of an effluent guidelines
regulation, and other background
information. The principal elements of
the Proposed Plan were designed to
implement sec 304(m) and a consent
decree in Natural Resources Defense
Council et el. \. Reilly (D.D.C. 89-2980.
January 31.1992)(the "Consent Decree").
See 57 FR19750-19755.
IV. 1992 Effluent Guidelines Plan
EPA's 1992 Effluent Guidelines Plan is
eel forth below. Today's Plan is
substannvely identical to the Proposed
Plan. As noted above, the basis for
selection of the industries identified in
today's Plan is described in the
Proposed Plan. This plan is based on
funding levels proposed by the
President's Budget for fiscal yew 1983. If
these levels cannot be achieved EPA
will have to evaluate the impact on tf
Plan's schedules.
A. Regulations
1. Ongoing Rulemakings
EPA is currently in the process of
developing new or revised effluent
guidelines for nine categories. These
rulemakings will proceed as previously
described in the Proposed Plan. The
currant schedules for these rules are eet
forth in Table l.
TABLE i.—EFFLUENT GUIDELINES
01 art Gee
11/26YSO
&9/13/
et
ia/a/91
4/io/az
10/tt
i/e*
44*
•at
11/94
1/08
1/98
5/W
7/9*
S/SS
S/M
f/se
2/9*
s
T/.
-------
Tuesday
September 8, 1992
Part V
Environmental
Protection Agency
Effluent Guideline* Plan; Notice
-------
Federal Register / Vol. 57. No. 174 / Tuesday. September 8. 1992 / Notices 41001
2. New Rulemakmgs
EPA intends to develop 12 new
effluent guidelines over an 11 year
period. Four of the rules are specified:
the remaining eight rules will be
specified in future Effluent Guidelines
Plans. This schedule for developing the
guidelines is set forth in Table 2. and is
identical to the schedule in the Proposed
Plan.
TABLE 2.—NEW CATEGORIES TO BE
REGULATED
BflW
1907
Rf*
tesr
1MB
iOHO-3003
EPA will Include any updates to these
schedules in the semi-annual Regulatory
Agenda published in the Federal
Register.
B. Preliminary Studiet
In the Proposed Plan EPA announced
that it intended to conduct ll
preliminary studies, which will assist
the Agency in selecting industries for
the eight remaining rules discussed in
Section FV.A.2 above (see 57 FR19752.
19755).
The Agency is proceeding as proposed
with studies for the Metal Finishing
Category (40 CFR part 433) and the
Petroleum Refining Category (40 CFR
part 419). These studies an underway
and are scheduled to be completed by
the end of 1993. The findings will be
published in Preliminary Data
Summaries, and will be considered in
preparation of the 1994 Effluent pollutants, they believed that attention
Guidelines Plan. should be focused on the larger faculties
EPA intends to conduct nine in the category.
additional studies. Six industries (all of EPA's Proposed Plan included a brief
which are currently subject to effluent working description of the MPftM
guidelines) were tentatively identified in category. This working description is
the Proposed Plan as the subject of subject to change, pending collection
future studies, with two studies labegin ••"* "t'y*1' ~f •.Mni~ri
-------
41002
Federal Register / Vol. 57. No. 174 / Tueaday. September B. 1992 / Notices
estimates are large because of the large
number of mines (estimated in the
thousands).
The Agency estimated that the other
two categones also continue to
discharge high levels of pollutants on a
nationwide basis, after application of
BAT-level limitations. The Iron and
Steel Manufacturing Category
discharges include antimony, arsenic.
copper, selenium, benzene, phenol.
sulfide. and fluoride. The Leather
Tanning and Finishing Category
discharges lead zinc, and toxic organic
pollutants.
EPA's studies of the existing
regulations will likely include a review
of existing wastewater characteristics
and technologies (including source
reduction, recycling and treatment
techniques). A decision to study an
industry does not mean that EPA has
decided to proceed with a rulemaking
for that industry.
C. Overall Effluwt Guidelines Plan
One commenter recommended that
any further work on effluent guidelines
be postponed and that EPA's water
quality efforts should be directed
primarily at nonpomt source pollution.
The commenter cited reports that
nonpoint sources are responsible for 55
percent of the water quality problems in
the nation's streams, and that directing
additional work toward point sources
would be a waste of resources.
The Agency agrees that nonpoint
source pollution is a major cause of
water quality problems nationwide.
However, industrial point sources
continue to causa water quality
impairment in some anas, and the
Agency 11 mandated by the Clean Water
Act and the Consent Decree to develop
new or revised effluent guidelines.
D. EPA Discretion Not to Regulate
Following a Preliminary Study
The Natural Resources Defense
Council (NRDC) objected to several
phrases in the Proposed Plan relating to
EPA'a discretion to elect not to issue
effluent guidelines for a particular
industry following study of that
industry. NRDC ^-p.*~. »u-«kTT £pA
necessarily has such discretion.
EPA acknowledges that NRDC and
EPA have different views concerning the
Agency's discretion to decide not to
proceed with an effluent guideline. At
NRDCs suggestion. EPA is including as
Appendix A to today's plan a copy of
paragraph o of the Consent Decree.
which states EPA'a position concerning
ItS QlaKTBQOn not tQ pVOCeMQ With
lelines and establishes a procedure
which NRDC may challenge any
attempt by EPA to exercise such
discretion.
£. Clean Water Act Requirements
Regarding Toxic and NonconventionoJ
Pollutants
NRDC also objected to the statement
in the Proposed Plan that effluent
guidelines "may include limitations on
any toxic or nonconventional pollutants
in addition to the 128 priority pollutants"
(57 FR18701). hi NRDCs view, the
Clean Water Act requires, rather than
allows, effluent limitations for all toxic
and nonconventional pollutants present
in more than trivial amounts.
EPA does not share NRDCs view on
this issue. In addition. EPA believes the
quoted statement which appeared in a
parenthetical explaining the Agency's
methodology in "'"-'"""j "toxic
pound-equivalent factors", is accurate
even under NRDCs view of the law.
F. Relationship of dean Water Act and
Pollution Prevention Act
ided that the Eff>"««*
NRDCrt
Guidelines Plan should focus explicitly
on the Pollution Prevention Act of 1980
(Pub. L101-608) (PPA) and explain the
Agency's efforts to identify source
reduction opportunities in connection
with the development of effluent
guidelines.
The PPA declares that pollution
should be prevented or reduced
whenever feasible: pollution that cannot
be prevented should be recycled or
reused in an environmentally safe
iMim» wherever feasible; pollution that
cannot be recycled should be treated:
and disposal or release into the
environment should be chosen only as a
last resort Source reduction, as defined
by the PPA. means any practice which
reduces the amount of any hazardous
substance, pollutant or «««*••«''"«'«
entering any waste stream or otherwise
released into the environment prior to
recycling, treatment or disposal and
reduces the hazards to public health and
the environment associated with the
release of such substances. The term
includes equipment or technology
process or procedure
of products, substitution of raw
intftT*slt,
-------
Federal Register / Vol. 57. No. 174 / Tuesday. September 8. 1992 / Notices
41003
assessments for effluent guidelines have
traditionally focused on manufacturing
processes. As a result, source reduction
strategies for service industries have not
been fully explored. Such strategies, if
adapted, would meet the requirements
for "best available technology
economically achievable" or "best
available demonstrated control
technology." In the case of the industrial
laundries example. EPA may evaluate
the appropriateness of source reduction
methods such as substitute cleaners and
changing of materials handling
practices, in addition to the Industrial
Laundries Category, two other
categories in today's Effluent Guidelines
Plan are service industries: Waste
Treatment and Transportation
Equipment Cleaning.
C. Relctwf Utility of POTW Local
LJmts Compared to National
Categorical Pretnatment Standards
One POTW contended that local
pretreatment limits established by a
POTW are a more effective way of
controlling specific industrial discharges
to that POTW than national categorical
pretreatment standards. This POTW
argued that due to the wide level of
discharge variability in some of the
categories listed in EPA's Proposed Plan,
development of national standards
would be difficult and control by means
of local limits would be men effective..
This is especially true for certain
categories such as Waste Treatment
Industrial Laundries, and Metal
Products and Machinery, according to
the commenter.
EPA required POTWs to develop local
limits as part of their pretreatment
programs pursuant lo the General
Pretreatment Regulations (40 CFR part
403) and has provided assistance to
POTWs in developing local limits.
However, the Agency considers local
limits-10 be complementary to. rather
than a replacement for. categorical
standards, aa part of an overall
pretreatment program. Many POTWs
have informed EPA that they need
categorical standards because they lack
the resources and/or technicaldxpertise
to develop local limitrfoi suiiie
pollutants, particularly toxic organica.
The Agency's National Pretreatment
Program Report to Congress (July 1991)
listed enhancement of national
categorical pretreatment standard* as
its first recommendation. (Improvement
of local prematmenl standards wee the
second recommendation.) While EPA
may indeed encounter more difficulty in
setting national standards for some
categories such as those mentioned by
the commenter. other POTWs have m
fact urged EPA to develop standards for
these categories.
VI. Future Effluenl Guidelines Plans
EPA will continue to publish Effluent
Guidelines Plans biennially. In future
notices, the Agency will provide
updated information on these
rulemakings and preliminary studies.
and will notice other information
received, if any. that may be considered
in the designation of additional
industries to be regulated by new or
revised effluent guidelines. Industries
tisted in today's notice for further study
may be designated for rulemaking in the
future 304[m) notices. In those notices.
the Agency may also schedule
rulemaking actions for other industries
not listed in todey's nonce, based on
public comments received and new data
made available to tha Agency.
The public ii invited to submit
information on industrial discharges that
may be useful to EPA in planning for
future effluent guidelines development
SUCD iflfOa^BiluQQ sDlflflt lO^LLDdfi
description* of specific industrial
effluent water quality effects of
industrial discharges, impacts on
POTWs (interference, pass-through.
etc.). and developments la westewater
technology (including source reductioa
recycling and treatment techniques). In
particular, the Agency is ialerested in
data that would facilitate category-wide
comparisons of industries with regard to
discharge characteristics, treatment
practices and effects on water quality.
EPA will include any information
submitted in the record for the 1994
plan.
Comments on proposed guidelines for
specific categories of dischargers will be
accepted, as usual according to the time
periods specified hi notices published es
part of rulemaking proceedings to
establish affluent guidelbes tor Ihe
categories.
VO.
This notice contains a plan for the
review and revision of mrisHng effluent
guidelines and for the selection of
priority industries for new regulations.
This-notice is not a rui "
therefore, no economic impact
assessment has been prepared. EPA will
provide economic impact analyses or
regulatory impact analyses, as
appropriate, for all of the future affluent
guideline rulemakinge developed by the
Agency.
Today's notice has been reviewed by
the Office of Management and Budget
under Executive Order 12391.
Dated: August 28.1992.
F. Henry Habxhl II.
A cttng Administrator
Appendix A—Paragraph 6 of Consent
Decree in NRDC et al v. Railly
1D.D.C. ae-aao. January 31.1BB2)
>.(•] The partm duagrae with nspect ID
what discretion, if any EPA has under
applicable law to dead* not to proceed with
an effluent guideline. Accordingly, the Court
has determined that ths following promsioiu
ihall govern in the event that EPA decides
net to proceed vritfe an effluent guideline for a
particular point source category. For luch
purpose*, "decide not to proceed with an
ffflngfit guideline" *^lt nieen 10 nuke •
final, affirmative decision prior lo proposal
that an effluent guideline is not appropriate
for the point source category under
consideration, and shall noi include nuking a
dadejoa to defer dmlnpmm at ruefa
(1) Notwithstanding IB* provuioa of
Paragraphs 4 and 5, EPA naarves ihe
dlscrsttoB to dsode not to proceed with any
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41004
Federal Register / Vol. 57. No. 174 / Tuesday. September 8. 1992 / Notices
above, or (11) the Court holds that, m making
such decision. EPA properly exercised its
discretion under applicable law. then such
decision shall sansry any and all obligations
of EPA under this Decree with respect to such
point source category.
(b) Any decision by the Administrator not
to proceed with an effluent guideline
pursuant to Paragraph 8(a)(l) above shall be
included in the first 304(m) Plan proposed
following such determination.
(c) (1) Notwithstanding the provisions of
Paragraph 6(a). EPA will take final action
with respect to twelve (12) effluent guideline*
(in addition to those listed in Paragraph 2)
before December 31.2008 unless, after
analysis of the eleven (11) studies undertaken
pursuant to Paragraph 3 and the seven (7)
studies already completed, the Administrator
determines, pursuant to any discretion the
Administrator has under the Clean Water
Act 33 US.C 1291-1387. or any other legal
authority, that fewer than twelve (12) of the
eighteen (18) total point source categories
studied ment proposal of effluent guidelines
pursuant to the standards set forth in
Paragraph e(a)(l). In such case. EPA will
undertake studies of additional categories of
point sources to determine whether the
promulgation of additional effluent guidelines
is appropriate. EPA will state its intention to
conduct any such additional studies in 30t(m)
Plena.
(2) EPA will notify plaintiffs within thirty
(30) days after any decision pursuant to
Paragraph 8(cKl) not to take final action with
respect to twelve (12) effluent guidelines (in
addition to those effluent guidelines listed in
Paragraph 2) before December 31.2003.
Plaintiffs may challenge such decision by
following the procedures set forth in
Paragraph 8(a)(3) above In the event the
Court holds that EPA lacks the authority to
make such a decision, the Court will establish
a new schedule for taking final action on the
remaining effluent guidelines.
Appendix B—Effluent Guidelines
Currently Under Development New
Categories to be Regulated, and
Preliminary Studies
EFFLUENT GUIDELINES CURRENTLY
UNDER DEVELOPMENT
NEW CATEGORIES To BE REGULATED
Category
CFR
Pen
Final
ICOOn
wa
Phase 2
Eoupmem Cleanng ..)
Mete) Products and j
Macrmry, Phase 2
Eight addRjonai
«37 I
«38l
1889 | 1887
18881 1
1888
1987
2001 BOOO-03
Category
Offshore 01 and Gas
(Re
08 and Gas
40
CFR
438
414
498
430
486
437
438
438
438
PRELIMINARY STUDIES
3/13/82
12/8/81
4/10/82
10/83
1/84
4/84
8/84
11/84
1/88
1/83
Category
CompMM
8:49 am)
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For a copy of this attachment, please contact
Richard Kashmanian at the address below
THE USE AND IMPACT OF
IRON AND STEEL INDUSTRY
INTRA-PLANT TRADES
ATTACHMENT 1
DOCUMENTS RELATED TO PERMITS INCORPORATING
INTRA-PLANT TRADING
Prepared for:
Richard Kashmanian
Office of Policy, Planning and Evaluation
U.S. Environmental Protection Agency
401 M Street
Washington, DC 20460
Prepared by:
Industrial Economics, Incorporated
2067 Massachusetts Avenue
Cambridge, MA 02140
March 1994
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