ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA-330/2-75-012
Characterization and Evaluation
of Wastewater Sources
United States Steel Corporation
Irvin Plant
Pittsburgh, Pennsylvania
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER. COLORADO
REGION
AND
PHILADELPHIA, PENNSYLVANIA
DECEMBER 1975
-------
Environmental Protection Aqency
Office of Enforcement
CHARACTERIZATION AND EVALUATION OF WASTEWATER SOURCES
UNITED STATES STEEL CORPORATION
1RVIN PLANT, PITTSBURGH, PENNSYLVANIA
August 18-28, 1975
December 1975
National Enforcement Investigations Center
Denver, Colorado
-------
CONTENTS
I. INTRODUCTION 1
II. SUMMARY 3
III. MONITORING PROCEDURES 7
IV. MONITORING RESULTS 11
OUTFALL 005 11
OUTFALL 006 14
OUTFALL 106 15
OUTFALL 306 AND 406 16
V. MONITORING REQUIREMENTS
OUTFALL 005 18
OILY WASTE TREATMENT FACILITY .... 19
OUTFALL 006 19
OUTFALL 106 19
OUTFALL 306 AND 406 20
RIVER WATER INTAKE AND
TREATMENT PLANT 20
TABLES 3-9 22
REFERENCES . 38
APPENDICES 39
A Chain of Custody Procedures
B Dye Dilution Technique
C Analytical Procedures and
Quality Control
D Utter: Reconnaissance Visit
to Irvin Works
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I. INTRODUCTION
The Irvin Plant, which commenced operation in 1938, is primarily a
steel finishing operation. Steel slabs, up to 8-inches thick and 235-inches
long, are received from other plants, primarily the Edgar Thomson Plant
and converted into finished steel for the automotive industry and tin
products for container manufacturers. The Irvin Plant has an 80-inch
hot strip mill; 36-inch, 56-inch, 80-inch and 84-inch pickling lines;
5-stand cold-roll ing mill; annealing lines; sheet steel finishing lines
(i.e., temper-rolled, side-trimmed, and/or split and recoiled); electro-
lytic tin lines; and galvanizing, aluminum and terne* coating lines.
Process water, estimated at a maximum of 265,000 m^/day (70 mgd), is
obtained from the Monongahela River. A portion receives treatment, con-
sisting of coagulation and sand filtration in the old and new (No. 1 and
No. 3) water treatment facilities. Daily water use rates of treated and
untreated water were unavailable from company officials.
Wastewater is discharged from two outfalls (005 and 006)** to the
Monongahela River [Figure 1]. An acid neutralization treatment facility,
a waste oil treatment facility and a domestic wastewater treatment facility
are located at the Irvin Plant. Waste oil treatment effluent is discharged
through outfall 005 and domestic effluent through outfall 006. Wastes from
the acid neutralization treatment facility are hauled by railroad tank car
to an approved dump for disposal.
The Environmental Protection Agency, Region III, requested the National
Enforcement Investigations Center (NEIC) to conduct an intensive "survey of
the U. S. Steel Uorks in the Pittsburgh area to characterize and evaluate
existing wastewater discharges. NEIC conducted a wastewater survey at the
Irvin Plant from August 18-28, 1975. Outfalls 005 and 006, intermediate
sampling points, and raw and treated water supplies were monitored for
six days between August 21 and 28. Effluent from the domestic wastewater
treatment plant was monitored August 21 and 22.
*Terne metal plating is a mixture of approximately 85 percent lead and
15 percent tin.
**These numbers refer to permit discharge points.
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SAMPLING
MR RAW RIVER"
WATRR
rnorosro TERMINAL
TRrATIICflT PUIHT
ROLL SHOP
GALVANIZING
A»0 TERNE
LINES
MOUSE
DISOIARCE 306
HO^TH
SCALE
PIT
80- HOT STRIP HILL
STORM
DRAINAGE
'1ISC.
COOL IN'
IIATFn
DISCHARGE
SCALF.
TO DISTRIBUTION
OUTFALL
COS
ri
OILY HASTE
TREATMENT
POINT
FOR OUTJA^I. —
CIJLD
Hi Al
ILttl'tDlYMC I
TINNiin iitirsl
Lines
SAtll'l tun POINT
Will I III AT III v
MAIIR X
ACID
NEUTRAL-
IZATION
.OFF SITE
DISPOSAL
VIA TANK CAR
MISC.
cnoLirr,
UHTfiEATEO UATEft
TO OISTR10UTION
* OLD AND NtU WATER
TREATMENT FACILITIES
STORM
FIGURE 1. KASTEVATER SCHEMATIC FLOW DIAGRAM - USSC IRVIN
(INFORMATION COURTESY USSC)
r\>
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II. SUMMARY
1. From August 18-28, 1975, wastewater discharges from outfalls 005, 006,
106, 306 and 406 were monitored. Raw and treated water from the
Monongahela River was sampled to determine net pollutant concentrations
discharged. In addition, influent and effluent from the oily waste
treatment system was sampled for three consecutive days from August 25-
27. Flow was measured and pollutant loads were calculated for each
outfall with the exception of the oily waste treatment system.
2. Outfall 005 contains oily waste treatment facility effluent, pickling
rinse waters, heat treating waters, non-contact cooling water, process
'and cooling wastes from electrolytic tinning, miscellaneous cooling
waters and area storm drainage. Company officials have reported on
self-monitoring data, flows ranging from 25,000 to 47,300 m3/day (6.6-
12.5 mgd). During NEIC monitoring, flows ranged from 51,200 to 71,400
m3/day (13.5-18.9 mgd). USSC has proposed effluent limitations for
total suspended solids, oil and grease and dissolved iron. The pro-
posed limitations and the NEIC monitoring data are as follows:
USSC Proposed Limitations Survey Data
Daily Average Daily Maximum Daily Average Daily Maximum
kg/day (lb/d"ayT kg/day(Ib/daTT kg/day(Ib/dayT kg/day(Ib/dayl
TSS 221,223 664,467 1770 3570
(487,276 (1.461,828) (3890) (7880)
Oil & Grease 21,015 5650
(46,236) (12,400)
Dissolved Iron 2640 3600
(5808) (7900)
The proposed limitation on TSS is a net limitation while oil and grease
and dissolved iron are gross limitations. Survey data is tabulated
accordingly. Suspended solids and oil and grease loads were less
than 1 and 33% respectively of proposed limitations. Dissolved iron
exceeded the proposed limitation on two of six days sampled. The pH
of wastewaters discharged from outfall 005 ranged from 2.6 to 9.6.
USSC has proposed that outfall 005 not be limited to a minimum pH
in order to more accurately describe the quality of the current
discharge.
Grab samples for organic analysis collected August 25 and 27, indicated
the presence of petroleum hydrocarbons, primarily normal paraffins.
These hydrocarbons ranged from Cg to C2Q and appeared in a uniform
pattern suggesting light refined oils. Triphenyl phosphate was also
Identified. Quantitative results are as follows:
-------
8/25/75 8/27/75
Compound yq/1 yg/1
€9 - Nonane Trace 4
- Decane 10 23
- Undecane 23 55
- Dodecane 20 42
- Tridecane 17 26
- Tetradecane 14 19
- Pentadecane 8 9
C-jg - Hexadecane 5 5
C]7 - Heptadecane 3 5
GIS - Octadecane 3 5
Cjg - Nonadecane 3 5
€20 - Eicosane Trace 4
Triphenyl Phosphate 220 240
3. The oily waste treatment system consists of an old and a new section
with a combined treatment capacity of 27,200 m3/day (7.2 mgd). The
company has not installed equipment to measure flow, however, oil and
grease and TSS concentrations were determined for influent to the oil
and new sections and for the combined effluent. Results are summarized
below:
Influent to Influent to Combined
Old Section New Section Effluent
Oil & Grease
Range (mg/1) 71-420 150-4800 < 1-34
Average (mg/1) 188 1727 9
TSS
Range (mg/1) 96-1600 120-5600 < 10-12
Average 428 1226 < 10
Based on average values of grab samples, treatment efficiency was
2 95 and £ 97 percent for oil and grease and TSS removal respectively.
Actual treatment efficiency could be determined only by knowing the
influent flow to each section of the system.
4. Outfall 006 contains wastewater from the north (306) and south (406)
scale pits, the domestic WWTP (106), miscellaneous cooling water,
heat treating water, cooling tower blowdown, boiler house effluents
and water treatment sludges. The company estimated the flow between
99,500 m3/day (26.3 mgd) and 193,000 m3/day (51 mgd). During the NEIC
survey, outfall 006 was sampled downsewer of all inputs except the
domestic WWTP effluent. Daily flows ranged from 146,000 m3/day (38.6
mgd) to 258,000 m3/day (68.2 mgd). USSC has proposed effluent limitations
-------
for TSS, oil and grease, phenols, dissolved iron and dissolved zinc.
The proposed limitations, compared below with NEIC results, are all
gross except TSS which is net.
USSC Proposed Limitations Survey Data
Pally Average Daily Maximum Daily Average Daily Maximum
kg/day(1b/dayT kg/day(Ib/dayT kg/day Ob/dayT kg/day(1b/day)
TSS
Oil & Grease
Phenols
Dissolved Iron
Dissolved Zinc
621,525
(1,368,998)
36
(80)
33
(73)
38
(83)
1,864,575
(4,106,994)
38,249
(84,147)
109
(240)
99
(217)
114
(249)
7500
(16,500)
3.3
(7.3)
53
(116)
12
(27)
11,700
(25,600)
8800
(19,400)
7.6
06.7)
190
(420)
67
(151)
Daily average and daily maximum values for TSS were less than 1.5%,
phenols less than 10%, oil and grease less than 30% and dissolved
zinc less than 70% of the proposed limitations. Dissolved iron
exceeded the proposed daily maximum limitation on one of the six
days sampled.
5. USSC has submitted plans to the State of Pennsylvania for a new
wastewater treatment facility which will discharge to outfall 006.
Company officials indicate the facility will treat a normal flow of
60,000 m3/day (11,000 gpm) composed of pickling rinse waters, oily
•wastewater effluent, basement sump drainage and miscellaneous waste
streams, and caustic and acid rinse waters from normalizing, terne
and galvanizing operations. All of these flows are now discharged
to outfall 005. The facility has not received State approval, but
company officials indicate that it should be operational approximately
30 months after it is approved. Additionally, USSC plans to construct
new wastewater treatment facilities to treat discharges from the 80-
inch hot strip mill. These facilities will include additional sedi-
mentation, partial filtration, cooling and 90% recycle. No completion
dates were provided by USSC.
-------
6. Outfall 106, the domestic WWTP was sampled for two consecutive days
for BOD and TSS. USSC proposed limitations for BOD and TSS are
compared below with NEIC monitoring results.
'USSC Proposed Limitations Survey Data
Daily Average Daily Maximum 8/21 8/22
BOD 30 mg/1 90 mg/1 15 mg/1 33 mg/1
TSS 43 mg/1 129 mg/1 45 mg/1 48 mg/1
During sampling, daily average flows as determined using an existing
Parshall flume were 821 m3/day (0.22 mgd) and 950 m3/day (0.25 mgd).
The company has reported this flow to range from 570 m3/day (0.15
ragd) to 760 m3/day (0.2 mgd).
7. Outfalls 306 (the north scale pit) and 406 (the south scale pit)
were found to contribute 61 to 92% of the daily flow discharged
through outfall 006. USSC proposed that limitations not be established
and monitoring not be conducted at the scale pits. During NEIC
monitoring, the north scale pit discharged from 54,800 to 70,400
m3/day (14.5 to 18.6 mgd) of wastewater containing from 12 to 46
mg/1 oil and grease. The south scale pit flow was 66,900 to 138,000
m^/day (17.7 to 36.5 mgd) and contained oil and grease concentrations
ranging from 15 to 61 mg/1. The net TSS concentrations discharged
were 0-6 mg/1 from the north scale pit and 1-66 mg/1 from the south
scale pit.
8. Flows should be continuously measured and recorded at each outfall
at the following frequencies: 005-3 days/week, 006-daily, 106-1 day/week,
306-3 days/week, 406-3 days/week. Wastewater discharqes should also be
sampled at these frequencies with the exception of outfall 106 which
need be sampled only 1 day/month. All composite sampling except the raw
and treated water supplies should be on a flow-weighted basis. The outfall
105 sampling point is not representative because wastewater inputs are
not completely mixed. A sampling point downsewer of the present location
should be selected.
Monitoring at outfalls 005, 006, 106, 306 and *06 should be increased
to include all critical parameters. This will result in the addition
of six parameters (total iron, total and hexavalent chromium, free and
total cyanide and tin) for outfall 005; five parameters (total iron,
total and hexavalent chromium, lead and tin) for outfall 006; two
parameters (chlorine residual and settleable solids) for outfall 106;
one parameter (pH) for outfall 306; and two parameters (pH and dissolved
Iron) for outfall 406. The oily waste treatment plant effluent currently
not monitored should be monitored once per week for flow, oil and grease,
suspended solids, total iron and pH.
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III. MONITORING PROCEDURES
During June 23-25, 1975, a reconnaissance inspection was conducted
at the Irvin Plant in order to evaluate waste treatment systems, sampling
locations and processing operations. A report describing this visit is
located in Appendix D. Sampling was conducted during the period August 18-28,
1975, at selected stations. The parameters monitored, sample type and
number of days sampled at each station are summarized in Table 1. Chain of
custody procedures were followed for the collection of all samples and field
data and for laboratory analyses [Appendix A]. Production figures1 for the
monitoring period were provided by USSC [Table 2].
The amount of intake water and wastewater discharged is not measured
but estimated by the company based on individual intake pump capacities
and operating times. During the survey, effluent flows, except station
106, were obtained using the dye dilution technigue [Appendix B]. Flow
from the domestic wastewater treatment plant (WWTP) (106) is measured by
a 3-Inch Parshall flume. The flume was checked for proper installation2
and the throat width was found to be only 8.82 cm (2.69 inch) rather than
9.8 cm (3 inch). The strip chart recorder is based on a 9.8 cm (3 inch)
throat* thereby inducing an error in the flow recorded. A rating curve
was developed by NEIC for the actual throat width and flows were calculated
using this curve.
Samples were collected every three hours and composited based on
Instantaneous flows measured at approximately the same time at stations
005, 006, 306 and 406. Hourly samples were collected for a period of
24-hours at the domestic WWTP (106) using SERCO automatic samplers and
then manually composited on a flow-weighted basis. Untreated and treated river
water was manually sampled every three hours and then time composited on
an equal volume basis for each 24-hour period. Grab samples for organic
analysis were collected August 25 and 27, 1975, from outfalls 005 and 006,
the river intake and the water treatment plant clearwell. Specific pro-
cedures used in organic sample collection and analysis are presented in
Appendix C. Samples for oil and grease, suspended solids and BOD were
analyzed at the NEIC mobile laboratory located at the McKeesport Wastewater
Treatment Plant. Other samples were air freighted to Denver for analysis
at the NEIC laboratories. All samples were preserved and analyzed in
accordance with EPA approved analytical guality control procedures [Appendix C].
EPA regulations require that net loadings be calculated based on con-
stituents present in intake water after treatment. That is, the intake
water concentration must be subtracted from the effluent concentration
and the result used to calculate pollutant loads. Because the company
could not supply figures indicating the amount of raw intake water used
or the percentage of intake water treated, net calculations were made
based on raw water concentrations and, therefore, are biased in favor of
USSC. (i.e., The net discharged waste load calculated will be less than
that using the treated water concentration.)
-------
TABLE 1
SAMPLING SCHEDULE FOR USSC IRVIN PLANT
Number
Days
Station Description Sampled
Discharge from waste 6
oil treatment & coolina
water (South Sewer 005)
Discharge from scale 6
pits, pickling lines, cooling
water (North Sewer 006)
Discharge from domestic 2
VMTP (106)
Discharge from M. 6
scale pit (306)
Discharge from S. 6
Scale pit (406)
Water Intake 6
Water Intake after 6
treatment (old plant)
Water Intake after 6
treatment (new plant)
Type of Sample
24 Hr. Comp.
Grab
24 Hr. Comp.
Grab
24 Hr. Comp.
24 Hr. Comp.
Grab
24 Hr. Comp.
Grab
24 Hr. Comp.
Grab
24 Hr. Comp.
Grab
24 Hr. Comp.
Grab
Parameter.!/
TSS; ammonia; total & dissolved Iron; total
hexayalent chromium; aluminum; lead; tin.
O&G!/; organicsl/.
TSS; total & dissolved Iron & zinc; total &
hexavalent chromium; aluminum; lead; tin.
O&Gi/; phenols!/; organics£/.
BOD; TSS.
TSS4/
O&Gi/.
TSS%,
O&Gi/.
TSS; total & dissolved Iron & zinc; total &
chromium; aluminum; lead; tin.
O&G!/; phenol!'; organlcs!/.
TSS; total & dissolved iron & zinc; total &
chromium; aluminum; lead; tin.
O&G!/; phenol!/; organic*!/.
TSS; total & dissolved iron & zinc; total &
chromium; aluminum; lead; tin.
O&Gi/; phenol!/; organics-'.
&
hexavalent
hexavalent
hexavalent
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TABLE 1 (cent.).
SAMPLING SCHEDULE FOR USSC IRVIN PLANT
Number
Days ..
Station Description Sampled Type of Sample Parameter.!/.
Influent to the 3 Grab TSSi'j O&G^.
old API separators
Influent to the 3 Grab TSSl/j
new API separators
Effluent from oil 3 Grab TSS^;
treatment system
J/ pH and temperature were measured periodically at all stations.
2f OS6 and phenol samples were collected 3 times each day.
~3/ Orgam'cs were sampled twice during the survey.
£/ Orgam'cs were sampled once during the survey.
5/ TSS samples were collected 3 times each day.
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TABLE 2
PRODUCTION DURING EPA SAMPLING PERIOD-METRIC TORS (TONS)
USSC - 1RVIN
80* Hot 56* 80* 84" No. 3 No. 4 No. T No. t • Contfnvev)
1975 Strip Pickle Pickle Plekl* Elee. Elec. No. I No. 2 No. 3 'No. 1 Ro. 2*- No. 3 Galv. Galv. Term Normal 1i.
Pate Turn Kill Line Line Hne_ Cleaner Cleaner 5 Stand 5 Stand 5 Stand 3 Stand ETL ETL ETL Una Line Line Line
8/20
8/21
8/22
8/23
8/25
8/26
8/27
8/28
8/29
2
1
2
3
1
2
3
1
1
2
3
1
2
3
1
2
3
1
2
3
1
a - 6
b • 4
c- 5
4 - 7
e - 7
161<
(1775)
2605
(2856)
2534
(2783)
2133
(2347)
26S9
(2325)
2674
(2942)
2410
<26S1)
2663
,(3153)
2535
(2789)
1957
(2164)
3228
(3551)
256Z
(2613)
1703
(1873)
2519
(2771)
2SE6
(2955)
2530
(2783)
2043
(2247)
2540
(2734)
2549
(2204)
Hours
Hour!
Hours
Hours
Hours
670
(737)
404
««)
678
(7<6)
455
(501)
475
(523)
710
(781)
534
(5£7)«
330
(363)
673
(740)
726
(799)
539
(659)
463
(509)
682
(750)
636
(755)
305 .
(336)"
544
(598)
636
(700)
637
(701)
646
(711)
644
(708)
656
(722)
635
(699)
7Z<
(797)
680
(748)
611
(672)
504
(554)
599
(659)
638
(702)
594
(654)
393
(«32)c
563
(619)
1042
(1146)e
1114
(1226)
1054
(1159)
1004
(1104)
1068
(1175)
1149
(1264)
1058 254
(1164) (279)
896
(986)
716
(788)
948 235
(1043) (259)
510
(561)
898
(983)
1337 295
(1471) (324)
1451
(1596)
783
(861)
334
(367)
358
(394)
424
(466)
321
(353)
369
(406)
325
(358)
387
(426)
429
(472)
400
(440)
252
(277)
458
(504)
608
(6G9)
479
(527)
504
(554)
511
(562)
179
(W)
•405
(445)
330
(363)
514
(S65)
562
(618)
484
(532)
483
(531)
496
(516)
4G9
(516)
508
(5W)
460
(506)
459
(516)
464
(510)
544
(596)
1566
(1723)
1223
(1345)
554
(610)
1265
(1392)
1054
(1160)
1004
(1104)
1323
(1461)
1114
(1226)
1491
(1640)
1603
(1852)
1285
(1414)
165G
(1822)
1678
(1846)
1668
(1857)
1424
(1567)
1430
(1573)
989
(1088)
1142
(1256)
1166
(1283)
1356
(1492)
1693
(1862)
^•••VMM
153
(168)
196
(216)
148
(163)
156
(172)
186
(205)
201
(221)
237
(261)
32
(35)
113
(124)
177
(195)
172
(189)
200
(220)
144
Oss)
196
(216)
218
(2«)
188
(207)
170
(187)
200
(220)
^BP«*^»
43
(47)
169
(186)
97
(107)
I?3
(135)
121
(133)
154
(169)
112
(123)
14S
(160)
183
(201)
200
(220)
93
(102)
159
(175)
105
(115)
125
(138)
116
(128)
81
(89)
85
(93)
79
(87)
100
(110)
84
(92)
76
(84)
89
(98)
93
(108)
94
(103)
104
(114)
104
(1U)
142
(156)
116
(128)
•••Mi^M •
171
(188)
164
(180)
153
(168)
128
(1«0>
171
(188)
172
(189)
164
(130)
17Z
(189)
170
(187)
177
(195)
173
(ISO)
95
(T04)
118
(130)
103
(113)
96
(105)
97
(106)
96
(105)
100
(no)
105
(115)
91
(100)
-------
11
IV. MONITORING RESULTS
Monitoring results are tabulated by individual sampling locations
[Tables 3, 4 and 5] and discussed by individual outfall. Organic com-
pounds were found only in wastewater from outfall 005 and are discussed
only in that section.
OUTFALL 005
This discharge contains oily waste treatment facility effluent,
pickling rinse (bath) waters, "heat treating" water, non-contact cooling
water (NCCW), process and cooling wastes from electrolytic tinning, mis-
cellaneous cooling waters and area storm drainage [Figure 1].
self-monitoring data* report a measured flow of from 25,000 ro-vday (6.6 mgd}
to 47,300 m3/day (12.5 mgd}. During the survey, flows ranged from 51,200
m3/day (13.5 mgd) to 71,400 m3/day (18.9 mgd).
USSC proposed effluent limitations for outfall 005 were compared
with survey data [Table 6]. The dissolved iron concentration exceeded
the USSC proposed daily maximum limitation of 2640 kg/day (5808 Ib/day)
on two of the six days sampled. Suspended solids and oil and grease
loads were less than one percent and 33 percent respectively of proposed
limitations. The odor of ammonia was detected coming from this discharge.
The data [Table 3] show that from 1.0 to 2.1 kg/day (2.2 to 4.5 Ib/day)
of ammonia was discharged. Company officials were not aware that any
source of ammonia existed on outfall 005 and have not proposed ammonia
limitations.
Total iron, total zinc, dissolved zinc, total chromium, total tin,
total aluminum and lead were also monitored. Results [Table 5] indicate
that during the survey, outfall 005 discharged from 13.7-39.4 kg/day
(30,0-86.6 Ib/day) total chromium, from 37-186 kg/day (82-410 Ib/day)
total tin and from 19-6? kg/day (41-134 Ib/day) total aluminum. Total
iron concentrations averaged 4.7 mg/1 greater than dissolved iron con-
centrations. Total zinc averaged 0.07 mg/1 and dissolved zinc averaged
0.07 mg/1. USSC has not proposed limitations on any metals other than
dissolved iron.
A grab sample collected on August 25, 1975, and another on August
27, 1975, were analyzed for organic compounds. Results indicated the
presence of petroleum hydrocarbons, primarily normal paraffins. These
hydrocarbons ranged from Cg to C20 and appeared in a uniform pattern
suggesting light refined oils. Triphenyl phosphate was also identified.
Quantitative results are as follows:
*Refers to USSC self-monitoring reports for the period January 1 -
March 31, 1975.
-------
12
8/25/75 8/27/75
Compound ug/1 yg/1
Cg - Nonane Trace 4
CIQ- Decane 10 23
J- Undecane 23 55
- Dodecane 20 42
- Tridecane 17 26
~ Tetradecane 14 19
Cl5- Pentadecane 8 9
C-J6- Hexadecane 5 5
C]7~ Heptadecane 3 5
Cl8~ Octadecane 3 5
C-|g- Nonadecane 3 5
CgQ- Eicosane Trace 4
Triphenyl Phosphate 220 240
USSC has proposed that outfall 005 not be limited to a minimum pH
in order to more accurately describe the quality of the current discharge.
The pH showed a wide variation ranging from 2.6-9.6 during monitoring.
Low pH values are probably caused by the discharge of pickling rinse
waters. The source of the high pH values is not known. The pH of the
intake water, which is downstream from this discharge, was 6.0 or greater
except on the second day of sampling when a pH of 5.6 was observed.
The self-monitoring data [Table 7] show that total suspended solids,
oil and grease concentrations, and pH values are similar to those obtained
during NEIC monitoring. Dissolved iron concentrations, however, were
more than 28 times higher during the survey (net values of 14.3 to 53.3
mg/1) than the values reported by USSC (0.02 to 0.51 mg/1). The cause
for the wide variation is not known.
The oily waste treatment system consists of an old and new section
with a combined treatment capacity of 27,200 m^/day (7.2 mgd). Oily
wastewater enters the system through API separators operating in parallel.
Wastewater then flows to equalization tanks to which 10-25 mg/1 of a
cationic polymer (emulsion breaker) is added. The flow passes to a
mixing tank where 30 mg/1 of FeCl3 ^s added and then to a flocculation
tank where 1 mg/1 of anionic polymer is added. The flocculation tank
effluent flows by gravity to two air flotation tanks where additional
oil is removed. Effluent from the flotation units is split with
approximately 50 percent recycled to the air flotation tanks and the
remainder discharged through outfall 005. The company has not installed
equipment to measure flow through the oily waste treatment system. A
schematic flow diagram and physical description1 of individual treatment
units is presented in Figure 2.
Influent and effluent grab samples were collected from the oily
waste treatment system and analyzed for total suspended solids and oil
and grease to evaluate the treatment efficiency of the system. Results
-------
SCHEMATIC FLOW DIAGRAM:
Influent to"*"
Old Plant
Influent to_^.
New Plant
API
Separators
(Old)
API
Separators
(New)
•*
Equalization
Tanks
(Old)
1
Equalization
Tanks
(New)
Catlonlc
Polymer FeClj
Ar
PC
Mixing
Tank
dor
T
>1c
ner
Flocculatlor
Tanks
rt50% Recycled
f
1
Air
Flotation
Tanks
i >
To
- j-Outfall
005
PHYSICAL DESCRIPTION OF TREATMENT UNITS;
UNIT
Old Plant:
API Separators
Equalization Tanks
New Plant:
API Separators
Equalization Tanks
Mixing Tank
Flocculatlon Tanks
Dissolve A1r
Flotation Tanks
DIMENSIONS
2 8 3.6x14x1.8m SWD
(12x46x6 ft. SWD)
2 0 1.8x6.7x2.7m SWD-
(6x22x9 ft. SWD)
4 @ 6.1x30.3x2.1m SWD
(20x100x7 ft. SWD)
2 0 8.6x9.1x2.4m SWD
(28.3x30x8 ft. SWD)
1 @ 3.8x3.8x3.Om SWO
(12.5x12.5x10 ft. SWD)
2 @ 3.9x7.9x3.Om SWD
(13x26x10 ft. SWD)
2 0 18m dia.x3.3m SWD
(60 ft. dia.xll ft. SWD)
CAPACITY
95,400 liters ea.
(24,800 gal. ea.)
34,180 liters ea.
(8,890 gal. ea.)
404,000 liters ea.
(105,000 gal. ea.)
195,600 liters ea.
(50,860 gal.ea.)
45,000 liters
(11,690 gal.)
97,230 liters ea.
(25,280 gal. ea.)
804,000 liters ea.
(209,000 gal. ea.)
FLOW
1900 1pm ea.
(500 gpm ea.}
1900 1pm ea.
(500 gpm ea.]
4600 1pm ea.
(1200 gpm ea.)
9600 1pm ea.
(2500 gpm ea.)
19.000 1pm
(5000 gpm)
9600 1pm ea.
(2500 gpm ea.)
9600 1pm ea.
(2500 gpm ea.)
DETENTION TIME
50 m1n.
18 m1n.
84 mln.
20 mln.
2 mln.
10 mln.
56 mln. with SOX
recycle
FIGURE 2. SCHEMATIC FLOW DIAGRAM AND PHYSICAL DESCRIPTION OF TREATMENT UNITS
OILY WASTE TREATMENT SYSTEM - USSC IRVIN
-------
14
[Tables 3 and 4] are summarized below:
Influent to Influent to Combined
Old Section New Section Effluent
Oil & Grease
Range (mg/1) 71-420 150-4800 < 1-34
Average (mg/1) 188 1727 9
TSS
Range (mg/1) 96-1600 120-5600 <10-12
Average (mg/1) 428 1226 < 10
Based on average values of grab samples, treatment efficiency was
> 95 and >_ 97 percent for oil and grease and TSS removal respectively.
Actual, treatment efficiency could be determined only by knowing the
influent flow to each section of the system.
OUTFALL 006
Outfall 006 contains wastewaters originating from the north (306)
and south (406) scale pits; domestic v/astewater treatment facility (106);
miscellaneous cooling water (estimated at 8250 m3/day—2.18 mgd); heat
treating waters; cooling tower blowdown; boiler house effluents; and
water treatment sludges.
USSC has submitted plans and specifications to the State nf Pennsylvania for
a new Terminal Treatment facility which will discharge to outfall 0063. Accord-
ing to company officials, the facility will treat a normal flow of 60,000
m3/day (11,000 gpm) consisting of four principal waste streams now dis-
charged through outfall 005. These waste streams include:
a) Approximately 16,000 m3/day (2935 gpm) of acid rinse
waters resulting from nine pickling operations.
b) Approximately 16,360 m3/day (3000 gpm) of oily waste-
water effluent from two existing dissolved air flotation
units.
c) Approximately 16,720 m3/day (3065) gpm) of combined
cooling and miscellaneous water and drainage from
basement sumps.
d) Approximately 10,910 m3/day (2000 gpm) of typical acid
and caustic rinse waters from normalizing, terne and
galvanizing operations.
-------
15
Based on information provided by USSC3 none of the wastewater now dis-
charged to outfall 006 will be treated in the proposed Terminal Treatment
Facilities. Instead, the waste load discharged through outfall 006 will be
Increased due to the addition of effluent from the proposed facility. The
treatment system will include equalization, neutralization, aeration, clari-
fication, thickening and vacuum filtration. Waste pickle liquor will be
added to the raw wastewater at the equalization facilities. Following
equalization, lime will be added for neutralization. After aeration, polymer
will be added to assist in clarification. Waste oil and solids will be hauled
away by railroad car or truck. USSC officials indicated that the facility
should be operational approximately 30 months following State approval.
USSC also plans to construct new wastewater treatment facilities to
treat discharges from the 80-inch hot strip mill. These facilities will
Include additional sedimentation, partial filtration, cooling and 90% re-
cycle. No completion dates were provided by USSC1*.
.The company previously has estimated* the flow through outfall 006 to
range between 99,500 m3/day (26.3 mgd) and 193,000 m3/day (51 mgd). During
the survey, the flow ranged from about 146,000 m3/day (38.6 mgd) to 258,000
nr/day (68.2 mgd). The USSC proposed effluent limitations for suspended solids,
oil and grease, phenols, dissolved iron and dissolved zinc are compared with
the survey data [Table 8] indicating that only the dissolved iron limitation
was exceeded. Both daily average and daily maximum values for suspended solids
were less than 1.5%, phenols less than 10%, oil and grease less than 30% and
dissolved zinc less than 70% of the proposed limitations. Dissolved iron ex-
ceeded the proposed daily maximum limitation on one of the six days sampled.
Self-monitoring data [Table 7] were similar to values obtained during the
survey (i.e., total suspended solids, pH, phenol, oil and grease and dissolved
iron).
OUTFALL 106
The domestic WWTP consists of two Imhoff tanks in parallel, a trickling
filter with no recirculation and chlorine contact chamber/final clarifier.
Physical descriptions1 of the treatment units are as follows:
Detention
Size Capacity Flow Time
Imhoff Tanks 2 @ 10.6x7.6x5.2 m swd 423,000 1 ea. 385,000 Ipd ea. 24 hrs.
(35x25x17 ft swd) (110,000 gal ea.)(100,000 gpd ea.)
Trickling 22.7 m dia.xl.8 m depth N/A 769,000 Ipd
Filter (75 ft dia.x6 ft depth) (200,000 gpd)
Chlorine 3.3x3.3x1.4 m + a 1.5 m 21,200 1 769,000 Ipd 40 min.
Contact inverted pyramid bottom (5,500 gal) (200,000 gpd)
Chamber/Final (11x11x4.5 ft + a 5 ft
Clarifier inverted pyramid bottom)
*Refers to USSC self monitoring reports for the period January 1-March 31,
1975.
-------
16
Chlorine gas was being fed at the rate of about 2.9 mg/1, 2.7 kg/day (6 Ib/day).
Sludge from the Imhoff tanks is buried on company property. During the two
days of NEIC sampling, daily average flows as determined using an existing
Parshall flume were 821 m3/day (0.22 mgd) and 950 nvj/day (0.25 mgd). The
company has reported* this flow to range from 530 m3/day (0.14 mgd) to 760
m3/day (0.2 mgd).
USSC has proposed effluent limitations for coliform organisms, BOD and
total suspended solids. During the survey, effluent was monitored two con-
secutive days for BOD and total suspended solids. USSC proposed limitations
are as follows:
BOD daily average - 30 mg/1; daily maximum - 90 mg/1
TSS daily average - 43 mg/1; daily maximum - 129 mg/1
Sampling August 21 and 22, 1975, gave the following results:
.BOD TSS
8/21/75 15 mg/1 45 mg/1
12 kg/day 38 kg/day
(27 Ib/day) (83 Ib/day)
8/22/75 33 mg/1 48 mg/1
31 kg/day 45 kg/day
(69 Ib/day) (100 Ib/day)
The self-monitoring data [Table 6] show that the BOD and total suspended solids
concentrations both ranged from <5 to 55 mg/1, which is similar to values ob-
tained during the survey.
OUTFALLS 306 AND 406
Coarse scale settled in the north and south scale pits is removed by
clamshell and hauled to the Edgar Thomson Plant for recycling to the blast
furnaces. The company presently does not monitor the wastewater discharges
from the north (306) or south (406) scale pits. These pits consist of four
and three chamber settling basins respectively. The north scale pit measures
11.5 x 26.2 m (38 x 86.5 ft) with a 3 m (10 ft) swd and a capacity of 781,000 1
(203,000 gal). The south scale pit measures 10.6 x 12.4 m (35 x 41 ft) with a
2.1 m (7 ft) swd and a capacity of 260,000 1 (67,500 gal)1. USSC does not
measure flow through the scale pits.
The combined average daily flow from the north and south scale pits con-
stituted from 61 to 92% of the total flow discharged through outfall 006.
Flow measurements at points 306, 406 and outfall 006 were normally taken
within 30 minutes of each other. On several occasions, combined instantaneous
*Refers to USSC self-monitoring reports for the period January 1-March 31,
1975.
-------
17
flows at 306 and 406 exceeded the flow at outfall 006. In these cases,
flow through one or both of the scale pits apparently decreased between
the time fluorimetry samples were collected at the scale pits and outfall
006. Travel time from both scale pits to 006 was measured at less than
six minutes.
NEIC monitoring results [Tables 3 and 5] show that at the times sampled,
the north scale pit discharged from 54,800 to 70,400 m3/day (14.5 to 18.6
mgd) of wastewater containing from 12 to 46 mg/1 oil and grease. When the
south scale pit was sampled, it was discharging from 66,900 to 138,000 m3/day
(17.7 to 36.5 mgd) containing oil and grease concentrations ranging from
15 to 61 mg/1. The net total suspended solids concentrations discharged
were 0 to 6 mg/1 from the north scale pit and 1 to 66 mg/1 from the south
scale pit.
-------
18
V. MONITORING REQUIREMENTS
Monitoring requirements include both sampling and flow measurement
considerations. This section presents requirements concerning parameters
to be monitored, sampling frequency, sampling location and sample type.
Flow measurement aspects including the need for and duration of flow
measurement are addressed. Proposed treatment is not discussed in this
section, however, flow measurement and recording equipment must be included
in all future wastewater treatment facilities.
OUTFALL 005
The major inputs to outfall 005 include pickling, cold rolling and
tin plating wastes. The critical parameters for these operations are flow,
suspended solids, oil and grease, dissolved iron, total iron, hexavalent
chromium, total chromium, tin, free and total cyanide and pH [Table 9]5.
This is an increase of six parameters (total iron, total and hexavalent
chromium, free and total cyanide and tin) in addition to those now monitored.
Monitoring frequency for the above parameters shall be three times per week
rather than the current practice of twice per month . Sampling shall be
conducted on a 24-hour composite basis for all parameters except oil and
grease and pH. Representative oil and grease sampling requires the collection
of several individual grab samples during each 24-hour period. Field measure-
ments are taken for pH. Due to variability in flow rate, samples collected
at outfall 005 are representative only when composited on a flow-weighted
basis. Moreover, oil and grease loads can be determined only when instan-
taneous flows at the time of sample collection are known. At the present
time, flow is not measured but estimated and samples are composited on an
equal volume basis.
The sampling location must be selected to insure that samples are
representative of wastewater discharged. During the survey, NEIC determined
through dye studies that the sampling location used for outfall 005 is not
acceptable because wastewater from the oily waste treatment system is not
thoroughly mixed with other wastewaters in 005. An acceptable sampling
location downsewer of the existing sampling point must be used. The new
sampling location must be above high water in the river to preclude sur-
charged conditions.
Continuous flow measurement and recording capability must be provided.
The dye dilution flow measurement technique, used by NEIC during the survey,
is technically feasible for application by USSC. On a long-term basis,
however, this method may prove prohibitive economically. Dye costs* are
approximately $2.00/day per 3785 m3/day (1 mgd) of flow. Equipment costs
including a metering pump, sample pump, fluorometer and strip recorder are
estimated at $2700-$3000. In lieu of the dye dilution technique, USSC may
install any of several conventional flow measurement devices (i.e., flumes,
weirs, etc.) equipped with a continuous flow recorder. Should USSC choose
*Costs are for Rhodamine WT dye.
-------
19
the latter option, modifications will be necessary. Although the sewer
is an estimated 30 feet underground, sufficient elevation head is available
to allow gravity flow measurement between the plant site and the Monongahela
River.
OILY WASTE TREATMENT FACILITY
The oily waste treatment facility is not monitored by USSC. During
the NEIC survey, monitoring showed that influent process wastes ranged in
concentration from 71-4800 mg/1 oil and grease and 96-5600 mg/1 suspended
solids. Effluent monitoring indicated treatment efficiency of > 95% and
Oil and grease and suspended solids concentrations averaging 10 mg/1 or
less. Control of pollutants from this facility can most effectively be
maintained by placing limitations on effluent from the treatment system.
It is recommended that the oily waste treatment system effluent be
monitored for flow, oil and grease, suspended solids, total iron and pH
[Table 9]5. The recommended monitoring frequency for these parameters is
once per weeks. Flow must be measured on a continuous basis during self-
monitoring. With modifications a standard flow measurement device can be
installed on the treatment facility effluent.
OUTFALL 006
Outfall 006 receives process wastes from hot forming, pickling, cold
rolling, galvanizing and terne coating operations. Wastes from these pro-
cesses shall be monitored for flow, oil and grease, suspended solids, total
and dissolved iron, total and hexavalent chromium, zinc, lead, tin and pH
[Table 9]5. This is an increase of five parameters (total iron, total and
hexavalent chromium, lead and tin) in addition to those now monitored.
Monitoring frequency shall be daily, instead of the current practice of
twice per month5 and all parameters except oil and grease shall be sampled
on a 24-hour flow-weighted composite basis. Oil and grease will be grab
sampled at least three times per 24-hour sampling period and loads calculated
based on instantaneous flows at the time of sampling. Presently samples are
composited on an equal volume basis because flows are estimated rather than
measured.
The sampling location for outfall 006 was found to be adequate for
representative sampling. NEIC used dye to verify that all wastewater
inputs to this outfall were well mixed at the 006 sampling point. Con-
tinuous flow measurement and recording must be provided for self-monitoring.
USSC has the same flow measurement options for 006 as were previously pre-
sented for 005. The sewer depth below grade is estimated at 3.6-4.5 meters
(12-15 feet) at the 006 sampling point.
OUTFALL 106
Effluent from the domestic WWTP is discharged to outfall 006 downscwer
of the 006 sampling point. The WWTP serves USSC-Irvin personnel and discharges
-------
20
about 760 m^/day (0.2 mgd). Parameters for which self-monitoring is
required are flow, BOO, suspended solids, chlorine residual, total or
fecal coliform, settlcable solids and pH. Presently these parameters
are all monitored with the exception of chlorine residual and settleable
solids. Flow must be measured and recorded at least one day per week
and all other parameters a minimum of once per month6. USSC presently
monitors all parameters (flow, total coliform, BOD and suspended solids)
weekly.
Twenty-four hour composite samples shall be collected for BOD and
suspended solids. All other parameters shall be grab samples. At the
present time, USSC collects grab samples for BOD and 24-hour composite
samples for suspended solids. The existing sampling location and flow
measurement equipment are acceptable provided the flow recorder is re-
calibrated for the actual throat width of the Parshall flume (Re: Monitoring
Procedures).
OUTFALLS 306 AND 406
Wastewater from the roughing end of the 80-inch hot strip mill is
discharged to the north scale pit and then to outfall 006. Wastewater
from the finishing end of the 80-inch hot strip mill and from pickling
is discharged to the south scale pit and then to outfall 006. The com-
bined average daily flow from the north and south scale pits constituted
from 61 to 92% of the total flow discharged through outfall 006. Outfalls
306 and 406 discharging from the north and south scale pits respectively
will be monitored three days per week beginning January 1977 for flow,
suspended solids and oil and grease. Based upon the list of critical
parameters for hot forming and pickling operations5, 306 must also be
monitored for pH and 406 for pH and dissolved iron. Sampling for suspended
solids and dissolved iron shall be on a 24-hour flow-weighted composite
basis. In addition, continuous flow measurement and recording capability
must be installed and operational at 306 and 406 by January 1977. Flow
may be measured using the dye dilution technique or conventional flow
measurement devices. The dye dilution technique, as mentioned previously,
is costly. NEIC used dye and found the flow through both scale pits to
be highly variable. Instantaneous flows ranged from 24,000-143,000 m3/day
(6.4-37.9 mgd) at the north scale pit and 28,000-301,000 m3/day (7.5-79.4
mgd) at the south scale pit. Should USSC elect to install conventional flow
measurement equipment instead of using the dye dilution technique, some
modifications will be necessary. Each scale pit outlet is a suitable
location for sampling and for the installation of a standard flow measure-
ment device such as a rectangular weir.
RIVER WATER INTAKE AND TREATMENT PLANT
Raw and treated water must be monitored on the same days outfalls are
sampled to determine net pollutant loads inasmuch as raw and treated water
is used at various points within the plant. USSC estimates for the period
January-June 1975 indicate that 13% of the total intake water is treated1.
-------
21
EPA regulations require that whenever water is treated prior to use, treated
water quality be used in determining net pollutants discharged7. This cannot
be accomplished until the quantity of treated water discharged through each
outfall is known. USSC does not meter treated water to the mill on a daily
basis and therefore is unable to accurately compute net pollutants discharged.
To correct this situation the flow of treated water from storage to the mill
areas served by each outfall must be measured.
Daily grab samples of raw water are analyzed and used in computing net
pollutants discharged. Because river water quality can change markedly in
24 hours, raw water must be sampled on a composite basis. Treated water
quality can also change as raw water quality changed. Composite sampling
of both raw and treated v/ater is required. Composite sampling may be on
an equal volume basis.
The raw water sampling site, located at the river pumphouse adjacent
to the intake screens, is acceptable for the collection of representative
"Samples. During the NEIC survey, treated water was sampled at the water
treatment-plant clearwell upstream of storage facilities. For self-monitoring,
it is recommended that treated water be sampled after storage.
-------
TABLE 3
SUWARY OF FIELD MEASUREMENTS AND ANALYTICAL DATA
ussc iRviN PLANT
AUGUST 21-29. 1975
Station Description
Discharge fron waste
oil treatment; cooling
water: pickling rinse
water (035)
Discharge from scale
pits, pickling rinse
waters and cooling
water (006)
Gate
8/22
8/23
8/26
8/27
8/28
8/29
8/22
8/23
8/26
8/27
8/28
8/29.
8/22
8/23
8/26
8/27
8/28
8/29
8/22
8/23
8/26
8/27
8/28
8/29
Flow
m-Ydav
X 10 3 KGD
67.5
61.6
58.7
71.4
51.3
59.3
17.8
16.3
15.5
18.9
13.5
15.7
Ranee
2.6-8.6
3.6-7.5
2.8-6.5
4.5-9.6
3.6-6.8
3.8-7.2
242.0
233.5
146.0
258.2
188.8
254.0
63.9
61.7
38.6
68.2!
49.91
3.3-7.7
6.7-7.6
5.9-8.1
6.7-9.4
6.4-7.4
67.1) 6.2-7.3
Temp.
Range °C
29-34
30-36
30-33
33-39
32-39
30-35
31-35
32-40
26-34
28-36
32-35
34-40
Gross
Net '
G
G
G
G
G
G
N
N
N
N
N
N
G
G
G
G
G
G
N
N
N
N
N
N
TSS
A.-pon1a N
im>/1 ko/day fib/day) ma/1 ko/cav (Ib/tfav)
73
42
18
14
66
45
53
29
0
4
56
35
68
28
36
49
62
39
48
15
17
39
52
29
4920 (10.900) 0.03 2.1 (4.5
2590 (57
1050 (23
1000 (22
3380 (75
2670 (58
10) 0.02 1.2 2.7
30) 0.02 1.2 2.6
00) 0.02 1.5 3.2
00 0.02 1.0 2.2
90) 0.02 1.2 2.7
3570 (7880)
1780 (3900)
0 (0)
280 (630)
2870 (6330)
2070 (4S80)
16,500 (37.100)
6500 (14.400)
5200 (11.600)
12,700 (27,900)
11.700 (25,800)
9940 (21,900)
11.700 (25.600)
3510 (7720)
2480 (5470)
10,000 (22,200)
9770 (21.600)
7400 (16.200)
IM
ro
-------
TABLE 3 (cent.)
SUKMWY OF FIELD MEASUREXEN7S AND ANALYTICAL DATA
USSC IRVIN PLAHT
AUGUST 21-29. 1975
Station Description
Discharge from N.
scale pit (306)
Discharge from S.
scale pit (406)
Vater Intake
Date
8/22
8/23
8/26
8/27
8/28
8/29
8/22
8/23
8/26
8/27
8/28
8/29
8/22
8/23
8/26
8/27
8/28
8/29
8/22
8/23
8/26
8/27
8/28
8/29
8/22
8/23
8/26
8/27
8/28
8/29
Flow
n->/dav pH
X 10*3 KGD Ranae
70.4 (1C
62.3 (U
68.5 (1C
5«.8 (14
55.1 (14
57.4 (15
138.2 (36
125.6 133
66.9 (17
112.9 (29
86.9 (23
97.6 (25
.6) 6.1-8.6
.5 6.9-8.3
.0 5.9-8.3
.5 6.9-8.3
.6 7.1-8.3
.2) 6.8-8.1
.5) 6.3-6.9
.2) 6.7-7.5
.7) 3.2-8.2
.81 7.6-8.1
.0) 7.0-7.6
.8) 6.6-7.4
6.0-6.8
5.6-7.5
6.1-8.0
6.6-7.9
6.4-7.5
6.5-7.3
Temp.
Range *C
28-38
30-31
26-32
31-32
31-32
29-32
36-41
32-40
26-39
38-39
37-39
36-40
24-26
24-26
25-27
25-27
25-28
26-28
Gross
Net
G
G
G
G
G
G
H
N
N
N
N
N
G
G
G
G
G
G
N
N
N
M
N
N
G
G
G
G
G
G
mo/1
26
11
TSS
Atnonla-N
Ice/day (lb/day) ro/1 ko/day Mb/day)
1830 («040
700 (1510
<10 <700 (1530
< 10
15
11
6
0
0
0
5
1
86
27
20
17
38
20
66
14
1
7
28
10
20
13
19
< 10
< 10
< 10
-------
TABLE 3 (eont.)
SUHXARY OF FIELD MEASUREMENTS AND ANALYTICAL DATA
USSC IRVIII PLANT
AUGUST 21-29. 1975
Station Description
Hater Intake After
Treatment (old
plant)
Water Intake After
Treatment (new
plant)
Influent to the Old
API Separator
Influent to the flew
API Separator
lAverage of last 4 days
Date
8/22
8/23
8/26
8/27
8/28
8/29
8/22
8/23
8/26
8/27
8/28
8/29
8/25 1
2
3
8/26 1
2
3
8/27 1
2
3
8/25 1
2
3
8/26 1
2
3
8/27 1
2
3
n^/der pH
X 10 3 KGD Ranoe
19.7 (5
19.7 5
17.8 4
21.2 5
20.8 (5
18.5 (4
19.7 5
19.7 5
17.8 (4
21.2 (5
20.8 (5
18.5 (4
.21) 8.2-9.1
.21) 8.9-9.6
.7 7.5-9.0
.6 8.1-8.7
.5 7.6-9.2
.9 8.8-9.0
.2) 7.6-9.1
.2) 6.0-9.2
.7 7.3-8.6
.6 7.0-8.2
.5 6.8-8.2
.9 7.7-8.2
7.6-10.4
9.0-10.1
6.3-10.4
6.8-7.9
7.6-9.5
6.6-8.1
of sampling as data for this date was not
TSS Amonla N
Temp. Gross
Range °C Net ma/1 ko/day Ob/day) mo/1 ke/day db/dav}
24-26 G < 10 434'
25-26 G i 10 434
25-28 G < 10 392
26-28 G < 10 467;
26-28 G < 10 459|
26-28 G < 10 409)
24-26 G 13 260 (560)
25-26 G 13 260 (560)
25-27 G < 10
25-28 G < 10
25-28 G < 10
25-28 G < 10
28-29 G 96
110
400
50-60 G 240
250
610
49-50 G 340
210
1600
32-34 G 120
490
650
30-34 G 2000
780
180
31-34 G 1030
180
5600
recorded.
-------
TABLE 3 (cent.)
StWWWY OP FIELD MEASUREMENTS AND ANALTTICAL DATA
USSC IRVJfl PLANT
AUGUST 21-29. 1975
Statton Description Oate X 10
PH
Range
Tc-np.
Range "C
Gross
-
T3T
ArrionU ft"
ing/1
(1b/(fay3 rrq/1 kc/
-------
TABLE 4
S1WWRY OF OIL AND GREASE AND PHENOL'DATA*
USSC IRVIN PLANT
AUGUST 22*29. 1975
Instantaneous Flow*
la^/dav
Steile-i :eser1=t<0!! Oste Tlise X 10 3 (KGO)
nc/1 ka/dav Ib/day uq/1 kq/day Ib/dav uo/1 ko/fty Ib/tfay
Discharge fron waste 8/211 1505 59.6 {15.8) 31 1850
Oil treatment plant 2 2230 83.0 121.9) 23 1910
cooling water pickling 3 - ' - - -
rinse water (005) 5 8/221 0405 44.4 (11.7
2 1515 67.4 (17.8
3 2125 60.0 (15.8
8/25 1 1520 59.0 15.6
2 1805 63.2 (16.7
60 2660
52 3500
47 2820
24 1410
21 1330
3 - -
8/26 1 0005 68.1
2 1500 146.0
3 1615 69.4
8/27 1 0035 59.6
2 1500 41.8
3 1825 53.6
8/28 1 0015 65.1
2 1510 59.4
3 1830 61.0
8/29 1 0005 63.6
18.0
38.6
1&.3
15.8
11.0
14.1
17.2
15.7
16.1
16.8
Discharge from scale 8/211 1545 227 (60.1
pits, pickling rinse 2 2010 425 (112.0
water end cooling 3 2330 47.4 (12.5
water (006) 8/22 1 0440 266
2 1540 242
3 2215 236
8/25 1 1615 166
2 1950 231
3
8/26 1 0045 251 {
2 1615 408 (
3 1920 249
8/27 1 0045 224
2 1605 154
3 1925 241 i
70.1
G4.1
62.4
43.9
61.2
66.2
08 0
66.0
59.5
40.7
26 1770
(4080)
(4210)
-
(5000
(7730
(6210
3120
(2930
-
(3900)
66 9600 (21.300)
79 5480 (12.100)
31 1850
86 3600
46 2460
58 3780
75 4450
22 1340
44 2790
15 3410
10 4250
23 1090
30 7950 (1
34 8240 < 1
27 ' 6370 1
31 5140 (1
18 4160
14110
(7930
(5420
(S330
(9770
12960)
(G160)
(7520
9340
(2400
7.600
8.200
} S 1.1 (2.
5 2.1 14.
11 0.52 11.
10 2.7 IS.
2 0.4 1.
4.100) 83 19.6 (43.
1.300
(9170
15 3760 (8290
39 15.900 (35.100
27 6740 (14. BOO
20 4500 (9940
19 2920
9 1.5 (3.
9 2.1 (4.
5> 0 0 fO)
7 1 0.43 (0.9)
1; 4 0.19 0.4)
8 8 2.1 (4.7)
0) 0 0 (0)
2) 79 18.7 (41.1)
3i B 1.3 (2.9
6) 5 1.2 (2.6)
7 1~7 (3~9) 2 0.5 (1.1)
7 2.8 (6.3) 5 2.1 (4.5)
5 1.3 (2.7 4 1.0 (2.2)
6 1.4 (3.0) 2 0.4 (1.4)
(6450) 5 0.8 (1.
63.8) 29 7030 (15.400) 7 1.7 (3.
7) 3 0.4 (1.0)
7) 4 0.9 (2.1)
ro
-------
TABLE 4 (cunt.)
SUMMARY OF OIL AND GREASE AND PHENOL'DATA*
USSC IRVIN PLANT
AUGUST 22-29. 1975
S— <
,, ^ie.is.i..
Discharge fron scale
pits, pickling rinse
water and cooling
water (036) (cont'd)
Discharge fron N.
scale
pu (306)
Discharge from S.
scale pit (406)
Cets
8/28
8/29
8/21
8/22
8/25
8/26
8/27
8/28
8/29
8/21
8/22
8/25
1
2
3
1
1
2
3
1
2
3
1
Z •
3
1
Z
3
1
2
3
1
2
3
1
1
2
3
1
2
3
Z
Hre
0040
1535
1855
0040
1530
1935
2300
0415
1530
2155
1605
1910
.
0020
1540
1900
0020
1545
1900
0020
1525
1840
0320
1515
1950
2310
0430
1520
2200
1950
Instantaneous Flow*
X 1C » fKGD)
212 (55.9
390 (103.0
204 (54.0
206 (54.6
59.6 (15.8
144
49.9
55.1
60.0
45.4
95
47.6
,37.9
Oil
mq/1
' 24
23
20
17
18
21
13.2) 12
14.6) 46
15.8) 38
12.0) 27
25.1) 24
12.6) 17
*
52.5
40.9
46.4
47.6
56.5
53.6
49.0 i
86.6 i
55.1 i
43.1 1
34.4
300
160
143
112
132
83
13.9) 22
10.8 30
12.3) 24
12.6) 38
14.9) *
14.1) 35
12.9) 32
22.8) 20
14.6) 26
11.4) 34
(9.1
79.4
42.3
38.2
29.6
'35.0
!21.9
32
19
18
44
45
43
31
i Grease
kq/day
5070
8910
4090
3510
1070
3020
600
2540
2280
1230
2280
810
.
1160
1230
1110
1810
.
1870
1570
1720
1430
1460
1097
5710
2883
6360
5030
5690
2570
(Gross)* Phenol (Gross) Pnenol (Net)"
Ib/day uo/1 kcAJay Ib/day ufl/1 ko/tfey lb/e*ay
(11.230
(19.700
(9000
(7740
5 1.4 (3.0) 0 0 (01
' 3.7 (8.1) 4 2.1 f«.6)
•« 1.6 (3.51 4 i.O Jz.3)
43 12.7 (27.9 39 11. 5 (25.3)
2360)
6650)
1320)
5!»90)
5020
2700
5020
1780
_
2540)
2700)
2450)
3990)
.
4130)
3450)
3800
3160
3230
(2420
(12.600
(6360
(14.100
(11.100)
(12.500)
(5670)
PO
-------
TABLE 4 (cent.)
SUMMARY OF OIL AND GREASE AND PHENOL DATA*
USSC IRVIN PLANT
AUGUST 22-29. 1975
Station Description
Date Tine X 10
Instantaneous Flow2
?H3
(TOD)
Oil & Grease (Gross}*_
mg/1 kg/day Ib/day
Phenol (Gross)
Phenol (Net)1*
ug/1 kg/day Ib/day uq/1 kg/day IbAiay
Discharge from
S. scale pit (406)
(cont'd)
Xater Intake
8/26 1
2
3
8/27 1
2
3
8/28 1
2
3
8/29 1
8/21 1
2
3
8/22 1
2
3
8/25 1
2
3
8/26 1
2
3
8/27 1
2
3
8/28 1
2
3
8/29 1
0030
1530
1910
0035
1555
1910
0030
1520
1845
0030
1600
2020
2345
0450
1555
2235
1625
2005
-
0100
1635
1935
0100
1615
1945
0055
1545
1905
0055
132 35
133 35
126 33
107 28
61.9 116
105 ',27
92 124
104 (27
110 (28
94 (24
.0 15
.0 28
.3 61
.4 39
.4) 31
.8 44
.3) 28
.4) 37
.9,1 22
.9} 27
< 1
3
8
6
< 1
2
< 1
< 1
.
2
1
< 1
6
2
2
3
1
< 1
< 1
1990 (437
3710 (818
7700 (17,00
4180 (926
1920 (423
4620 (10.20
2580 568
3840 846
2400 530
2540 560
0
0
0,
o;
0,
0,
0
0
o;
0
5
4
7
2
21
4
1
4
.
5
2
1
4
2
3
5
3
2
5
1X9
00
-------
TABLE 4 (cont.)
SUMMARY OF OIL AND GREASE AND PHENOL DATA*
USSC IRVIN PLANT
AUGUST 22-29. 1975
Instantaneous Flow2 Oil & Grease (Gross)4
Station Description
Water Intake after
Treatment
Hater Intake after
Treatment
Date
8/21 1
2
3
Avg
8/22 1
2
3
Avg
8/25 1
2
3
Avg
8/26 1
2
3
Avg
8/27 1
2
3
Avg
8/28 1
2
3
Avg
8/29 1
8/21 1
2
3
Avg
8/22 1
2
3
Avg
mJ/tizv
Tlire X 10'3
1625
2055
2355
18.2
0505
1610
2250
18.2
1645
2020
.
17.7
0120
1655
1950
20.9
0120
1630
1955
21.0
0115
1600
1920
18.4
0115
1630
2055
2355
18.2*
0505
1620
2250
18.2'
(KGD) mo/1 kq/day Ib/day
< 1
< 1
2
(4.81 7) 1.3 23.7 (52.1)
2
2
4
(4.81 7) 2.7 49.2 (108)
13
< 1
m
(4^68)
<
(5.52)
<
<
(5.56)
<
<
<
(4.87) 1
<
<
<
(4.81 )
124 (273)
63 (140)
20 (45)
8s 33 (73)
18 (40)
9
2
3
(4.81) 4.7 85 (190)
Phenol (Grass) Phenol (Net)*
ug/1 kq/day
< 1
< 1
< 1
1 0.018
< 1
7
1
3 0.055
3
5
—
4 0.071
4
1
3
2.7 0.056
1
1
1
1 0.021
4
3
3
3.3* 0.061
3
<
<
<
0.018
<
<
0.018
Ib/day vg/1 kg/day Ib/day
(0.040)
(0.120)
(0.156)
(0.124)
(0.046)
(0.134)
(0.04)
(0.04)
r\»
to
-------
TABLE 4 (cont.)
SWWARY OF on AND GREASE AKO PHEKOI OATA>
USSC IRVIH PLAHT
AUGUST 22-29, 1975
Instantaneous Flow* 011 & Grease (Gross)1 Phenol (Gross) Phenol (Net)"
SUtfon CesertDtfon
Water Intake after
Treatment (cont'd)
Influent to the
Old API Separators
Date
8/25 1
2
3
Avg
8/26 1
2
3
Avg
8/27 1
2
3
Avg
8/28 1
2
3
Avg
8/29 1
8/25 1
2
3
8/26 1
2
3
8/27 1
2
3
Tln-e X 10"*
1650
2020
.
17.7
0120
1700
1920
20.9
0120
1640
1955
21.0
0115
1610
1910
18.4
0115
1210
1535
1840
0910
1SG5
1845
0910
1520
1840
fKGD) mq/1 kq/day
10
< 1
•
(4.68) 5.5 100
< 1
7
< 1
(S.S2) 3 63
< 1
1
5
(S.56) 2.3 48
2
< 1
< 1
(4.87) 1.3* 24
< 1
71
92
320
130
170
250
102
133
420
Ib/day u
-------
TABLE 4 (cent.)
SUWWRY OF OIL AND GREASE AND PHENOL DATA*
USSC WIN PLANT
AUGUST 22-29. 1975
Station Description
Influent to the
New API Separators
Effluent from
Oil Treatment
Systea
Date
8/25 1
2
3
8/26 1
2
3
6/27 1
2
3
8/25 1
2
3
8/25 1
2
3
8/27 1
2
3
Instantaneous Flow*
T1re X 10'* (KSD)
1220
1545
1825
0920
1515
1840
0915
1525
1845
1225
1555
1820
0925
1525
1630
0920
1530
1830
011 & Grease (Gross)1 Phenol (Gross) Phenol (Net}"
nq/1 kg/day Ib/day jig/1 kg/day Ib/day uq/1 kg/day Ib/day
150
4800
1760
790
1900
3500
220
1700
720
34
1
33
< 1
3
< 1
6
5
3
>A11 data based on grab samples.
*Lo£ds are calculated using Instantaneous flows.
'Freon extractable material.
*Cred1t 1s given for Intake concentration where specified 1n permit or adjudicator? hearing request.
s.'i't/-&ers in parenthesis are permit designations.
7Aver«?e dally flows for 8/21 and 8/22 obtained by averaging the average dally flows of 8/23-8/29.
'Average Includes 8/29-Sequence fl concentrations.
-------
Table S
SUmARY OF KETAIS DATA
USSC IKIW PLANT
August 21-29. 1975
flow Gross Total iron Dissolved iron
Tot&l Zinc Dissolved zinc
Description Date X 10 ' (md) Net no/1 kq/dzy ' (Ib/day) mg/1 kq/day (Ib/day] mq/1 kg/day Mb/day) irq/1 kq/
-------
TABU 5 (cent.)
SUWARY OF HETALS DATA
USSC IRVIN PLANT
AUGUST 21-29. 1975
Station
Description
Discharge
f ro^ waste
oil treat-
ment plant.
celling
xa'.er and
pickling
rinse
water (005)
Discharge
from scale
pits pick-
ling rinse
water and
cooling
water (006)
Water
Intake
Water
Intake
after
treatment
(Old Plant}
Water
Intake
after
treatnent
(.Sew Plant)
Date
8/22
8/23
8/26
8/27
8/28
8/29
8/22
8/23
8/26
8/27
8/28
8/29
8/22
8/23
8/26
8/27
B/28
8/29
8/22
8/23
8/2S
8/27
8/28
B/29
8/22
8/23
8/26
8/27
8/28
8/29
8/22
8/23
8/26
8/27
8/28
8/29
8/22
8/23
8/26
8/27
8/28
8/29
MOW cross
nVday
X 10 ' (nqd) Net
67.4 1
61.6
58.7
71.4
51.2
59.4
17.8
16.3
15.5
18.9
13.5
15.7
i G
G
G
G
G
G
N
N
H
N
N
N
242.0 '
233.5
145.9
258.2
1B8.7
254.0
63.9
61.7
38.8
68.2
49.9
67.1
G
G
G
G
G
' G
N
N
N
N
N
N
G
G
G
G
G
G
16.9 (4.5
16.9
15.3
18.2
17.8
15.9
16.9
16.9
15.3
18.2
.5
.0
o
.7
.2
1 G
G
G
G
G
G
( .5) G
( .5) G
K'.l
G
G
17.8 (4.7) G
15.9 (4.2) G
Total Chrornum
ffg/1
0.50
0.30
0.23
0.54
0.40
0.39
0.03
0.03
0.10
0.04
0.03
-
<0.01
0.01
<0.01
0.03
0.02
0.02
0.02
<0.01
<0.01
<0.01
<0.01
-
<0.01
<0.01
0.01
0.01
<0.01
<0.01
Total Tin •
Total Aluminum
kg/day (Ib/day) ng/1 kg/day (Ib/day) ng/1 ko/day
33.4 74
18.8 41
13.7 30
38.6 84
39.4 86
23.1 SI
6.9 (16
6.9 <15
14.6 132
10.3 23
6.0 (12
-
.6) <0
.11 0
.0) 0
.8) 2
.61 1
• 4) 1
.31 <0
.4;
-------
TABLE 6
COMPARISON OF USSC PROPOSED EFFLUENT LIMITATIONS
AND SURVEY DATA - DISCHARGE 005
USSC IRVIN PLANT
USSC PROPOSED LIMITATIONS SURVEY
Daily AverageDai1y Maximum Daily Average Dally Maximum No. of Days
Parameter kg/day (Ib/dayJ kg/day (Ib/day) kg/day lib/day) kg/day (Ib/dayl Limitations Exceeded
Total Suspended 221,2231 (487,276) 664,4671 (1,461,828) 1770 (3890) 3570 (7880) 0/6
Solids
Oil and Grease 21,015* (46,236) 5650 (12,400) 0/6
Dissolved Iron 2640* (5808) 3850 (8490) 2/6
U
is a net limitation.
2This is a gross limitation.
3USSC has proposed that flow be estimated rather than measured.
c*>
-------
TABLE 7
SUMMARY OF SELF MONITORING DATA*
USSC IRVIN PLANT
Station Description
Discharge from waste oil
treatrent plant pickling
rinse water, cooling
water (COS)
Discharge from scale pits.
pickling rinse water.
cooling water (OC6)
Discharge from domestic
WWTF (106)3
Water Intake"
Date*
1/15-6/19
1/10-6/19
1/17-4/25
1/17-6/19
Range
Avg
No. of Samples
Range
Avg
No. of Samples
Range
Avg
No. of Samples
Range
Avg
No. of Samples
Temp
•c
16-26
12
13-27
11
4-24
9
pH
2.3-12.6
25
6.2-11.9
23
2.3-8.0
19
TSS
nq/1
37-1392
499
13
22-610
174
12
< 5-50
25
16
3-583
115
11
CN-T
mq/1
0.003-0.050
0.020
10
0.004-0.021
0.012
10
0-0.043
0.013
9
CN-A
nq/1
0-0.010
0.002
10
0-0.002
0.0005
10
0-0.020
0.002
9
Phenol
nq/1
0.21-1.70
0.623
10
0-0.120
0.049
15
0.009-0.106
0.040
13
045
nq/1
0.2-212.1
28
44
3.6-69.4
20
40
0.09-15
4.3
38
TOC
mq/1
7.0-103.4
54
8
0-16.5
4.7
8
1.0-16.0
9
16
0-80.3
IS
7
fe
mq/1
0.02-0.51
0.13
14
0.01-11.8
1.17
13
0.01-0.44'
0.14
12
JOata provided by USSC in August 29, 1975 transmlttal to Enforcement Director. EPA. Region III from James L. Hamilton. III.
*Dates sanp.es collected were not provided for all data. Therefore dates are those that were reported.
3ln addition to these parameters, company monitors for fecal collform and BCD. Based on 16 samples, fecal coll form ranged from < 30 to 24,000/100 nl
,and the 303 ranged fron < 5 to 55 ng/1 (< 10 mg/1 average).
The company monitors the Intake water for zinc. Based on 15 samples the zinc concentrations averaged 0.10 mg/1 (range of 0-0.80 mg/1).
-------
TABLE 8
COMPARISON OF USSC PROPOSED EFFLUENT LIMITATIONS
AND SURVEY DATA - DISCHARGE 006
USSC IRVIN PLANT
USSC PROPOSED
Parameter
Total Suspended
Solids
Oil and Grease
Phenols
Dissolved Iron
Dissolved Zinc
11
Daily
kg/day
621,525
36
33
38
Averaae
(Ib/day)
(1,368,998}
(80)
(73)
(83)
LIMITATIONS1
Daily
kg/day
1,864,575
38,249
109
99
114
Maximum
(Ib/day)
(4.106.994)
(84,147)
(240)
(217)
(249)
Daily
kg/day
7500
3.3
53'
12
SURVEY DATA
Average
(Ib/day)
(16,500)
(7.3)
(116)
(27)
Daily
kg/day
11.700
'8800
7.6
190
67
Maximum
(Ib/day)
(25,600)
(19,400)
(16.7)
(420)
(151)
No. of
Limitations
0/6
0/6
0/6
1/6
0/6
Days
Exceeded
1A11 limitations are gross except suspended solids which are net.
2USSC has proposed that flow be estimated rather than measured.
-------
TABLE 9
CRITICAL PARAMETERS AND REQUIRED MONITORING FREQUENCY
USSC IRVIN1
Outfall
005
1052
006
106
306
406
Intake
Flow
X
X
X
X
X
X
X
O&G
X
X
X
X
X
X
TSS
X
X
X
X
X
X
X
Parameters
PH Fe-D Fe-T CrTt> Cr-T Zn Pb SN CN-F
X X X X X XX
X X
XXX X X XXX
X
X
X
XXX X X XXXX
CN-T BOD Cl?-r Fec.C. Sds. Frequency
X 3 days/week
1 day/week
Dally
X X X X 1 day/month8
3 days/week
3 days/week
X Dally
Permit Program Guidance for Self-Monitoring and Resorting Requirements, April 30, 1973, Office of Permit Programs, EPA.
2This outfall is effluent from the oily waste treatment system which Is currently not monitored by USSC.
3Except flow which shall be monitored one day per week.
COL
-------
38
REFERENCES
1. Letter dated September 30, 1975, with attachments from Mr. James L.
Hamilton III, Manager Environmental Control-Water, United States
Steel Corporation to Mr. Stephen R. Wassersug, Director, Enforcement
Division, U. S. Environmental Protection Agency, Region III,
Philadelphia, Pennsylvania.
2. Water Measurement Manual, United States Department of the Interior,
Bureau of Reclamation, Second Edition 1967, p. 48-52.
3. Letter dated September 21, 1973, with plans and specifications from
Mr. H. J. Dunsmore, Director-Environmental Control, United States
Steel Corporation to Mr. Howard Luley, Regional Sanitary Engineer,
Department of Environmental Resources, Pittsburgh, Pennsylvania.
4. Letter dated August 1, 1975, with attachments from Mr. James L.
Hamilton III, Manager Environmental Control-Water, United States
Steel Corporation to Mr. Stephen R. Wassersug, Director, Enforcement
Division, U. S. Environmental Protection Agency, Region III,
Philadelphia, Pennsylvania.
5. Development Document for the Hot Forming and Cold Finishing Segment
of the Iron and Steel Manufacturing Point Source Category, USEPA,
Effluent Guidelines Division, p. 174-179.
6. Permit Program Guidance for Self-Monitoring and Reporting Requirements,
April 30, 1975, USEPA, Office of Permit Programs, p. 12.
7. 40 CFR Part 125.28(c).
-------
39
APPENDICES
A Chain of Custody Procedures
B Dye Dilution Technique
C Analytical Procedures and Quality Control
D Letter: Reconnaissance Visit to Irvin Works
-------
VPLNUIX A
ENVIRONMENTAL PROTECTION AGENCY
Office Of Enforcement
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Building 53, Box 25227, Denver Federal Center
Denver, Colorado • 80225
July 24, 1974
CHAIN OF CUSTODY PROCEDURES
General:
The evidence gathering portion of a survey should be characterized by the
minimum number of samples required to give a fair representation of the
effluent or v/ater body from which taken. To the extent possible, the quan-
tity of samples and sample locations will be determined prior to the survey.
Chain of Custody procedures must be followed to maintain the documentation
necessary to trace sample possession from the time taken until the evidence
is introduced into court. A sample is in your "custody" if:
1. It is in your actual physical possession, or
2. It is in your view, after being in your physical possession, or
3. It was in your physical possession and then you locked it up in
a manner so that no one could tamper with it.
All survey participants will receive a copy of the survey study plan and will
be knowledgeable of its contents prior to the survey. A pre-survey briefing
will be held to re-appraise all participants of the survey objectives, sample
locations and Chain of Custody procedures. After all Chain of Custody samples
are collected, a de-briefing will be held in the field to determine adherence
to Chain of Custody procedures and whether additional evidence type samples
are required.
Sample Collection:
1. To the maximum extent achievable, as few people as possible should
handle the sample.
2. Stream and effluent samples shall be obtained, using standard field
sampling techniques.
3. Sample tags (Exhibit I) shall be securely attached to the sample
container at the time the complete sample is collected and shall
contain, at a minimum, the following information: station number,
Station location, date taken, time taken, type of sample, sequence
number (first sample of the day - sequence No. 1, second sample -
sequence No. 2, etc.), analyses required and samplers. The tags
must be legibly filled out in ballpoint (waterproof ink).
-------
Chain of Custody Procedures (Continued)
Sample Collection (Continued)
4. Blank samples shall also be taken with preservatives which will
be analyzed by the laboratory to exclude the possibility of
container or preservative contamination.
5. A pre-printed, bound Field Data Record logbook shall be main-
tained to record field measurements and other pertinent infor-
mation necessary to refresh the sampler's memory in the event
fie later takes the stand to testify regarding his action's
during the evidence gathering activity. A separate set of field
notebooks shall be maintained for each survey and stored in a
safe place where they could be protected and accounted for at
all times. Standard formats (Exhibits II and III) have been
•established to minimize field entries and include the date, time,
survey, type of samples taken, volume of each sample, type of
analysis, sample numbers, preservatives, sample location and
field measurements such as temperature, conductivity, DO, pH,
flow and any other pertinent information or observations. The
entries shall be signed by the field sampler. The preparation
and conservation of the field logbooks during the survey will
be the responsibility of the survey coordinator. Once the
survey is complete, field logs will be retained by the survey
coordinator, or his designated representative, as a part of the
permanent record.
6^'. The field sampler is responsible for the care and custody of the
samples collected until properly dispatched to the receiving lab-
oratory or turned over to an assigned custodian. He must assure
that each container is in his physical possession or in his view
at all times, or locked in such a place and manner that no one can
tamper with it.
7. Colored slides or photographs should be taken which would visually
show the outfall sample location and any water pollution to sub-
stantiate any conclusions of the investigation. Written documenta-
tion on the back of the photo should include the signature of the
photographer, time, date and site location. Photographs of this
nature, which may be used as evidence, shall also be handled
recognizing Chain of Custody procedures to prevent alteration.
Transfer of Custody and Shipment:
1. Samples will be accompanied by a Chain of Custody Record which
Includes the name of the survey, samplers signatures, station
number, station location, date, time, type of sample, sequence
number, number of containers and analyses required (Fig. IV).
When turning over the possession of samples, the transferor and
transferee will sign, date and time the sheet. This record sheet
-------
'Chain of Custody Procedures (Continued)
allows transfer of custody of a group of samples in the field,
to the mobile laboratory or when samples are dispatched to the
KFIC - Denver laboratory. When transferring a portion of the
samples identified on the sheet to the field mobile laboratory,
the individual samples must be noted in the column with the
signature of the person relinquishing the samples. The field
laboratory person receiving the samples will acknowledge receipt
by signing in the appropriate column.
2. The field custodian or field sampler, if a custodian has not
been assigned, will have the responsibility of properly pack-
aging and dispatching samples to the proper laboratory for
analysis. The "Dispatch" portion of the Chain of Custody Record
.shall be properly filled out, dated, and signed.
3'. Samples will be properly packed in shipment containers such as
1ce chests, to avoid breakage. The shipping containers will be
padlocked for shipment to the receiving laboratory.
4. All packages will be accompanied by the Chain of Custody Record
showing identification of the contents. The original will accom-
pany the shipment, and a copy will be retained by the survey
coordinator.
5. If sent by mail, register the package with return receipt request-
ed. If sent by common carrier, a Government Bill of Lading should
be obtained. Receipts from post offices and bills of lading will
be retained as part of the permanent Chain of Custody documentation,
6. If samples are delivered to the laboratory when appropriate person-
nel are not there to receive them, the samples must be locked in
a designated area within the laboratory in a manner so that no
one can tamper with them. The same person must then return to the
laboratory and unlock the samples and deliver custody to the
appropriate custodian.
Laboratory Custody Procedures:
1. The laboratory shall designate a "sample custodian." An alternate
will be designated in his absence. In addition, the laboratory
shall set aside a "sample storage security area." This should be
a clean, dry, isolated room which can be securely locked from the
outside.
2\ All samples should be handled by the minimum possible number of
persons.
3. All incoming samples shall be received only by the custodian, who
will indicate receipt by signing the Chain of Custody Record Sheet
-------
.Chain of Custody Procedures (Continued)
accompanying the samples and retaining the sheet as permanent
records. Couriers picking up samples at the airport, post
-office* etc. shall sign jointly with the laboratory custodian.
4. Immediately upon receipt, the custodian will place the sample
In the sample room, which will be locked at all times except
when samples are removed or replaced by the custodian. To the
maximum extent possible, only the custodian should be permitted
In the sample room.
5. The custodian shall ensure that heat-sensitive or light-sensitive
samples, or other sample materials having unusual physical
characteristics, or requiring special handling, are properly
Stored and maintained.
6. Only the custodian will distribute samples to personnel who are
to perform tests.
7. The analyst will record in his laboratory notebook or analytical
worksheet, identifying information describing the sample, the
procedures performed and the results of the testing. The notes
shall be dated and indicate who performed the tests. The notes
shall be retained as a permanent record in the laboratory and
should note any abnormalities which occurred during the testing
procedure. In the event that the person who performed the tests
Is not available as a witness at time of trial, the government
may be able to introduce the notes in evidence under the Federal
Business Records Act.
8. Standard methods of laboratory analyses shall be used as described
in the "Guidelines Establishing Test Procedures for Analysis of
Pollutants," 38 F.R. 28758, October 16, 1973. If laboratory
personnel deviate from standard procedures, they should be prepared
to justify their decision during cross-examination.
9. Laboratory personnel are responsible for the care and custody of
the sample once it is handed over to them and should be prepared
to testify that the sample was in their possession and view or
secured in the laboratory at all times from the moment it was
received from the custodian until the tests were run.
10. Once the sample testing is completed, the unused portion of the
sample together with all identifying tags and laboratory records,
should be returned to the custodian. The returned tagged sample
will be retained in the sample room until it is required for trial.
Strip charts and other documentation of work will also be turned
over to the custodian.
-------
Chain of Custody Procedures (Continued)
11. Samples, tags and laboratory records of tests may be destroyed
only upon the order of the laboratory director, who will first
confer with the Chief, Enforcement Specialist Office, to make
certain that the information is no longer required or the samples
have deteriorated.
-------
EXHIBIT I
/
1
c
\,
EPA, NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Sfalion No. Dale Time Scquonco No.
Station Location
BOD MelaU
Solids _._ ,O;f atwl Grnacn
rnn nn
Nnlrionft Barf.
. Oldnr
Samplers:
_____Grab
Comp.
Remarb / Prosorvalive:
Front
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
BUILDING 53, BOX 25227, DENVER FEDERAL CENTER
DENVER, COLORADO 80225
\
•z?
Back
-------
EXHIBIT II
OR
SURVEY; PHASE.
., DATE
VPE OF SAMPLE.
ANALYSES. REQUIRED
STATION
NUMBER
STATION DESCRIPTION
•
.
,
TOTAL VOLUME ' |
TYPE CONTAINER
; 1
1
1 |
PRESERVATIVE j
! •
,
'
i
NUTRIENTS I
O
03
n
o
u
o
o
TOTAL SOLIDS |
SUSPENDED SOLIDS |
ALKALINITY |
O
Q
2C
o.
CONDUCTIVITY" |
UJ
oc
5
IU
o.
TOTAL COIIFORM |
•
| FLCA1 COLIFORM |
rj
C.1
c,
UJ
UJ
Uf
0
Q
Z
o
| METAIS |
U
CO
•
PCS1ICIDES |
OL"
I
I
1PACE ORGANICS |
10N9HJ j
1 CYANIDE
REMARKS
-------
Samplers:.
FIELD DATA RECORD
STATION
•
•
NUMBER
-
"
DATE
TIME
TEMPERATURE
•c
•
CONDUCTIVITY
ft. mhos/cm
•
PH
S.U.
D.O.
mg/l
Gage Hi.
or Flow
Pi. or CFS
.
-------
EXHIBIT IV
ENVIRONMENTAL PROTECTION AGENCY
Office Of Enforcement
KATIONAl ENFORCEMENT INVESTIGATIONS CENTER
building 53. Box 25227, D-jrwer Federal Center
Denver, Colorado 80225
CHAIN OF CUSTODY RECORD
SURVEY
SUTION
NUMBER
STATION IOCATION
.
DATE
Relinquished by: (Signature)
Relinquished by: /Signature/
Relinquished by: (s,gn0iur»)
Relinquished by: (Signomrej
Dispatched by:
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APPENDIX B
DYE DILUTION TECHNIQUE FOR FLOW MEASUREMENT - IRVIN WORKS
Flow determinations were made using dye dilution with fluorometric
detection technique. In this procedure a dye of known concentration is
injected at constant rate upstream of the sample site, an adequate distance
to insure mixing. Samples are collected and the dye concentration determined
by a fluorometer. Knowing the dye injection rate, initial dye concentration
and concentration after the dye has mixed with the wastewater flow, the flow
can be calculated.
The G. K. Turner Model III fluorometer was used. Calibration of the
fluorometer was accomplished daily using dye standards prepared in the
NEIC laboratory. Rhodamine WT dye was used due to its low sorptive tendency
and stability under varying pH conditions.
Background investigation of all stations were conducted to determine
if any substances in the waste stream would fluoresce in the range that
could induce errors in flow determinations. Background samples were taken
each time samples for flow determination were collected. The fluorescence
measured on background samples was subtracted from the fluorescence measured
on the flow samples.
Special precautions taken to insure against interference in flow
measurements consisted of: (1) cuvettes triple rinsed with distilled
water between each sample; (2) cuvettes cleaned daily with solvent; (3)
cuvettes filled with distilled water and fluorescence measured twice daily
to insure against contamination from operator handling; (4) fluorometer
checked for "0" reference between each reading and after use, using "0"
reference blank; (5) all readings were taken on upward movement of indicator
to eliminate any error due to gear "slop"; and (6) rubber gloves were worn
when handling raw dye to avoid contamination during fluorometer operation.
-------
APPENDIX C
ANALYTICAL PROCEDURES AND QUALITY CONTROL
Samples collected during this survey were analyzed, where appropriate,
according to procedures approved by EPA for the monitoring of industrial
effluents.!' The analytical procedures for characterizing trace or-
ganic chemical pollutants are described below. The remaining procedures
are listed in the following table.
Parameter
A1, Cr, Fe, Pb,
Sn, Zn, Cu
TSS
Cyanide
Phenol
Ammonia
Oil & Grease
BOD
Method
Atomic Absorption
Gravimetric
Distillation,
Colorimetrie
Automated Colcri-
me trie
Automated Phenate
Freon Extraction
Serial Dilution
(Winkler-Azide)
Hexavalent Chromium Colorimetric
Reference
EPA Methods for Chemical
Analyses of Water and Waste-
water, 1971, page 83
Ibid., page 278
Ibid., page 41
EPA Methods for Chemical
Analyses of Water & Wastes,
1974, page 243
ibid., page 168
Standard Methods 13th Ed.,
page 254
Ibid., page 489
Ibid., page 429
Samples for organic chemical pollutant analysis were collected in clean,
solvent rinsed one-gallon glass containers. These samples were air
freighted to Denver and extracted with methylene chloride. The extract
was dried with anhyd. sodium sulfate, concentrated, exchanged into acetone,
and analyzed by hydrogen flame ionization gas chromatography. Those sam-
ples that showed adequate response were set aside for characterization by
-------
combined gas chromatography-mass spectrometry (GC/MS). The GC/MS analyses
were carried out with a Finnigan Model 1015 Quadrapole Mass Spectrometer
and a Systems Industries Model 150 computerized data system. Mass spectra
were compared to data files' in the NIH Computer System and also to listings
In the Eight Peak Index of Mass Spectra, Second Edition, 1974, compiled
by the Mass Spectrometry Data Center. All identifications are considered
preliminary until authentic standards of the suspected chemical compounds
can be obtained and analyzed under similar conditions to match the mass
spectrum and gas chromatographic retention time. This procedure does not
detect highly volatile organic chemical pollutants since their presence
ts masked by the extraction solvent.
Reliability of the analytical results was documented through an active
Analytical Quality Control Program. As part of this program, replicate
analyses were normally performed with every tenth sample to ascertain the
reproducibility of the results. In addition, where appropriate, every
tenth sample was spiked with a known amount of the constituents to be
measured and reanalyzed to determine the percent recovery. These results
were evaluated in regard to past AQC data on the precision, accuracy, and
detection limits of each test. On the basis of these findings, all ana-
lytical results reported for the survey were found to be acceptable with
respect to the precision and accuracy control of this laboratory.
I/ Federal Register, Vol. 40, No. Ill, June 9, 1975.
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APPENDIX D
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OP ENFORCEMENT
NATIONAL FIELD INVESTIGATIONS CENTER-DENVER
BUILDING 53, DOX 25227, DENVER FEDERAL CENTER
DENVER, COLORADO 80225
T. P. Gallagher, Director OATE. July 2, 1975
NEIC-Denver
E. J. Struzeski, Jr.,
Industrial Haste Constant, NEIC-Denver
Visit to Irvin Works of United States Steel Corporation, Pittsburgh,
Pennsylvania Area, June 24-25, 1975.
In Attendence
Fred Thomas, E. T. Irvin
Bob Dunham, Corporate, Pittsburgh
George Pitcairn, E. T. Irvin
B. A. Procyk, Honroeville
S. 'A. (Jeff) Davis, Corporate, Pittsburgh
EPA;
Oim Vincent, NEIC-D
Oim Hatheway, NEIC-D
E. J. Struzeski, NEIC-D
M. G. Miller, Region III
Background
The Edgar Thomson Plant and the Irvin Plant comprise two separate iron
and steel-making plants situated about 8 miles apart but are, however,
included under a single management and described by U. S. Steel Corpor-
ation as the Edgar Thompson-Innn Works. Both plants are included in
a single NPDES permit. The ET and Irvin plants are located on the
Monongahela River respectively 11 miles and 18 miles upstream from the
confluence of the Allegheny and Monongahela Rivers which join to form
the Ohio River at Pittsburgh. The Irvin Plant is on the left side of
the River facing downstream. The ET Plant is on the right side. This
trip report focuses upon the Irvin Steel Plant visited by the EPA on
Tuesday, July 24, 1975. The Irvin Plant commenced production in 1938.
The Irvin plant is primarily a finishing steel operation receiving
slab steel from other plants, particularly Edgar Thomson. Maximum
production capacity for the Irvin Plant has been specified in the NPDES
permit as 7900 tons/day of hot-formed steel products, 7800/tons cold-
formed products, 1650 tons/day of galvanized (zinc) ternc-coated (85%
lead - 15% tin) steel; and 1600 tons of clcctrolytically - tin coated
.steel/day. Additionally, it is reported that 8100 tons steel arc
acid-pickled daily. Matt Miller of Region III, the permit writer, in-
dicates that the permit production figures were taken as the highest
sipgle.'month production over the past five- years experienced by U. S.
Steel at each mill and for each major process sector.
-------
Both during the general meeting between EPA and Steel on Friday, July
20 and the Irvin plant visit of July 24th, the Company was extremely
cautious and pleaded ignorance on many of the questions presented be-
fore them by EPA personnel. Jim Hamilton, the Team Leader for USSC
at the meeting of June 20th pledged a spirit of cooperation with the
EPA. This cooperation demonstrated by U. S. Steel during our field
Visits of June 23-25 to the Edgar Thomson and Irvin Plants, was how-
ever, severely constrained by Steel personnel, especially as to their
completely'inadequate responses to many of our questions. Likewise,
attitudes were extremely subdued. Dunham and Thomas implied certain
"data could only be obtained via an official 308 request, and perhaps
even then, legal complications could preclude any sort of speedy re-
sponse.
Process Description
The Irvin Plant primarily produces much of its finished steel for the
automotive industry. Partly because of a currently-depressed demand
for steel by the auto industry, the Irvin Plant is slated to be
completely shut down the week of June 30th and stay closed for an in-
definite period thereafter.
Processing at the Irvin steel-finishing mill is described below. Primary
production takes place in the 80-inch hot strip mill. Steel slabs are
received into the Irvin mill varying in approximate width from 36 to 80
Inches. Although Irvin receives much of its primary (slab) steel from
the neighboring Edgar Thomson mill, the largest slab coming from the
latter mill runs only about 44 inches in width. The large slabs at
80-84 inches are shipped from from the Homestead Plant into Irvin.
In the 80 inch Hot Stripmill, the red hot slabs are hot rolled into
steel coils of varying dimensions. Slabs up to eight inches thick and
19.5 feet long (or less) are inserted into slab reheating furnaces (five
in number) and subsequently passed through a scalebreaker, and then four
roughing stands followed by six finishing stands. The steel slab is
rolled down to thickness of .047 to .375 inches. Traveling at speeds
up to 2,000 feet per minute, the strip steel is rolled into large coils.
The original slab of 235 inches in length may be rolled out to a total
length of nearly 3,000 feet. A single coil or roll of steel may weigh
up to 47 tons (generally no more than 30 tons.) This mill utilizes no
steel scarfing but the sheet steel is sheared before being rolled to the
desired gage on the six finishirrg stands. The six finishing stands have
a total of 26,500 IIP under remote control. As the hot strip leaves the
finishing stands, it is water cooled, coiled, inspected, banded and for-
warded by conveyor to a storage area to await final shipment or further
processing.
-------
Products at this stage of processing are directed into pipeline, i.e.
Alaskan pipe, auto bumpers, etc. Three coilers are deployed at the
end of the 80 inch hot strip mill to enable continuous operation.
Steel must be adequately coded via water sprays to permit coiling of
the strip metal. The hot strip mill also has facilities for cutting
the strips down into narrower widths.
Pickling
After hot rolling, the steel coils slated for cold reduction and sub-
sequent finishing are delivered according to width to one of four con-
tinuous pickling lines, i.e. an 84 inch pickle line, and/or 36", 56"
and 80" pickle lines. At the pickling lines, the rolls are uncoiled
and immersed into a sulfuric acid (or other unspecified acid) baths
to remove surface oxides. The pickling lines comprise uncoilers,
a butt welder (in order to maintain a continuous strip down the pickle
line), pickle tanks, rinsing tanks, dryers and recoilers. Overall
length of the 84 inch pickle line is about 1,000 feet. After pickling.,
the strip steel is delivered to the cold reduction and temper mills
sectors of the overall works. Pickled steel is generally conveyed to
one of two major product areas: A - Tin or Black Plate Products; or
B - The Cold Rolled/Coated/Terne Products Sectors. Fumes coming off
the pickle lines are collected and conveyed into packed tower air scrub-
bers. There are a total of 5 such scrubbers on the 80 inch line, and
one each on the 84, 36 and 56 inch pickle lines. These fumes are wet
scrubbed and disposed of into the pickle rinse lines.
'Cold'Roll ing Mills
For Tin or Black Plate Product, pickled steel is sent through a 5-stand
cold rolling mill, through cleaning followed by annealing, then a 2-stand
temper mill; the line then splits into two possible products. The
"tempered steel may be sheared and converted into black plate (backyard
sheds, etc.) or otherwise is subjected to electrolytic tinning yielding
tin (can) plate products.
Other pickled products after passing a 5-stand cold-rolling mill
(similar to above) may proceed in one of three general directions:
1. The cold rolled product is subjected to annealing,, a four-high
temper mill, then sheared, recoiled and shipped;
2. Cold-rolled strip is passed through continuous galvanizing and
aluminum coating lines giving galvanized or aluminum-coated sheet steel;
3. Cold-rolled strip is exposed to annealing and lead coating
giving terne plate product.
There are actually four cold reduction mills at the Irvin site. Steel
to be converted into tin or blackplnte mill products are passed through
one of two 43-inch wide five stand cold reduction mills. This steel
can be rolled at speeds up to 3900 fpm yielding final product thickness
of .006 to .040 inches. An 84-inch five stand cold reduction mill pro-
duces final product having thickness of .012 to .165 inches with steel
-------
width up to 76 inches. The 84-inch cold reduction mill is served by a
total of 39,000 HP and can achieve maximum rolling speeds up to 5,000
fpm. The 84-inch mill generates coils 75 inches in diameter weighing
up to 42 tons. Lastly, a three-stand tandem cold reduction mill is
employed to produce sheet product. The tandem mill has a line speed
of approximately 900 fpm and handles coils up to 72 inches in width and
up to 30 tons.
Annealing
Annealing is a process whereby cold-reduced strip steel is specially
"heat-treated to provide ductibility and softness in the steel product
necessary to meet drawing and forming requirements of the customer. The
strip steel may be handled either in box annealing furnaces or by con-
.tinuous annealing techniques. In box annealing, the coils are heated
to between 1,200 and 1,300°F in separate furnaces for many hours. The
coils once removed from the furnaces are cooled to approximately 225°F
in unique containers or covers. During both heating and cooling, a
deoxidizing atmosphere is maintained to protect the steel surfaces.
Open coil annealing is a variation of the above in which coils are loosely
wound on the recoiler with a wire inserted between concentric wraps,
thereby giving greater exposure to heat and accelerating the annealing
cycle. An alternate to box annealing is continuous annealing whereby
the strip steel is moved through a furnace in a series of vertical passes
and the steel is heated to a prescribed temperature and held at that
level. The metal is subsequently cooled at a controlled rate. At Irwin,
on the continuous annealing line, cold reduced rolls are welded into a
continuous strip, cleaned in an alkaline detergent solution, heat-
treated by passing through a furnace and cooled in rapidly cooling chambers.
The total length of sheet steel on the continuous annealing line at Irvin
is about one mile. A controlled deoxidizing atmosphere is also maintained
in this heating operation. The continuous annealing line at the Irvin
works is deployed for Tin or Black Plate Product. All other annealing
is conducted via the box annealing process.
Sheet Steel Finishing
Finishing operations at Irvin are divided into hot-rolled steel operations
and cold-rolled steel operations. Off the 80-inch hot strip mill, the
products are temper-rolled, side-trimmed and/or slit, or sheared and
recoiled. Sheets or coils hot-rolled and finished out on the Nos. 10 and
11 lines at Irvin include railroad cars, automobile and truck frames,
agricultural equipment and building components.
In the Cold Strip Finishing Department, products that have been hot-
rolled, pickled, cold reduced and annealed receive final treatments.
Final products include the steel parts in automotive bodies, refrigera-
tors, wall partitions, etc. Cold-rolled products are rolled in one of
four temper mills which include an 84-inch temper mill. Temper rolling
.imparts desired flatness, hardness and specific surface finish or tex-
tures to the final finished products. Following temper rolling, coils
may be sheared, side-trimmed, slit and recoiled. The 84-inch cold steel
line is further equipped with a welder that enables joining two coils
-------
together to form a very large single coil weighing as much as 50 tons.
The Coated Product lines at Irvin include application of zinc (galvanized),
aluminum, and lead (ternc) coatings onto cold-rolled steel. Three
different process lines are involved. On lines Nos. 1 and 2, coils are
cleaned, annealed, coated with molten zinc, cooled, chemically treated,
leveled, and sheared or recoiled. This galvanizing process imparts
corrosion resistance to the steel. This galvanized product is used
1n roofing, siding, road culverts, heating ducts, rocker panels on
cars, and air conditioner parts. Line No. 2 may be used to produce
galvanized steel or to produce aluminum coated steel. The aluminum
coated material is deployed in parts where protection from higher
temperatures is necessary, such as in auto mufflers and exhaust systems.
Line No. 3 at Irvin is the terne-coat line. Terne metal is a mixture of
approximately 85% lead and 15°/, tin. In this production sector, the cole!
reduced steel is annealed, tempered, cleaned, pickled, fluxed, coated
with lead and tin, cooled, leveled, and sheared or recoiled. Terne-
coated product provides good corrosion resistance and is specially used
in forming auto gas tanks, TV and radio chassis, etc.
Tin Finishing
In the tin-coated sheet steel production sector, the strip steel is
first annealed, then passed through a temper mill. Sheet steel in the
non-coated form after tempering is side trimmed or sheared in producing
the black plate product used in the manufacture of pie pans, trays, and
other uses wherein a light but durable metal is required. Irvin has
three continuous tinning lines employing electrolytic plating for making
"tin" cans, which are actually 99% steel. The thin, temper rolled black
plate is pickled or cleaned and then passed through on electrolyte solu-
tion in which are immersed pure tin anodes. An electric current super-
imposed on the solution deposits a thin layer of tin on both sides of
the steel. The coated sheet is heated to fuse the tin coating, cooled,
chemically treated and either sheared into desired lengths or coiled.
Four different temper mills are used in the tin finishing department.
The tin recoil line can accept steel speeds up to 4,000 feet per minute.
The Irvin mill has only two permitted outfalls to the Monongahela River,
i.e. outfalls 005 and 006. However, these sev;er systems serve to collect
many factory wastewater sources. Both outfalls are large.
General Mill Operations
The Irvin mill is aligned in a general north-south direction with out-
fall 006 serving the northern'or downstream sector of the plant and
outfall 005 serving the southern half of the plant. USSC has recently
submitted plans to the State of Pennsylvania for proposed wastcwatcr
treatment facilities at the Irvin plant intended to treat "sonic" of the
present wastes on the 006 outfall lino. These wastes, however, exclude
scale pit effluents from the CO inch hot strip mill, up to 1.3 MGD
"process" waste flow from heat treating operations customarily going
to outfall 006, and boiler house effluents. Maximum water intake to
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the Irvin Plant was reported by USSC people as around 70 MGD. At
current decreased steel production, Irvin should be below the 70 MGD
intake figure. Previous data accompanying the NPDES permit application
from USSC to EPA, Region III gives 70 MGD as a total for both outfalls
005 and 006. All these figures appear significantly biased on the
high side.
He were told the 80-inch hot strip mill in June was only operating 5
days a week, 3 shifts per day. However, upon walking through the 80-
inch strip mill, the production board indicated this particular mill
was only operating 12 shifts or "turns" per week equalling 57% capacity.
Fred Thomas also cited normal operations on the galvanizing lines may
.be one week up and perhaps 1 to 2 weeks dov/n. The Terne-Coating line
may typically operate 1 week and be down the subsequent 3-4 weeks.
In the various cold steel reduction operations, lubricating oils are
extensively used throughout processing. Irvin personnel consider their
oil treatment facilities to be more than adequate for USEPA needs. Air
compressors generate (uncontaminated) coolant waters. Oil cooling is
involved In hot rolling and/or cold rolling steel processing. Pump
gland leakages, etc. are "supposedly" directed into pits underlying
critical operations and collected into the oil treatment sewer. Fred
Thomas initially described the Irvin waste treatment sub-system as con-
sisting of API separators followed by FeCl2 addition followed by air
flotation, with sludges being removed from the system. None of the
pickling lines incorporate "drag-out" recovery procedures. Spent
or discard pickle baths go in the direction of the acid neutralization
WW treatment sub-system. Sprays off the 34 inch pickle line, immediately
following the pickling solution baths plus pickling rinse (bath) waters
are discharged untreated to both the 005 and 006 outfalls. Irvin does
not utilize pickling rinse waters as makeup although they supposedly
will do so in the future.
Plating metals utilized at Irvin are tin, zinc, aluminum and lead. Other
waste constituents include chromium, detergents, wetting agents, etc.
Of the plating'metals, only zinc is required to be measured in the NPDES
permit. The Company could provide us with no data on the other consti-
tuents. Plating is generally conducted via the hot dip and rinse technique,
For lead plating, the steel is dipped in the metallic solution, then
cooled; lead presents absolutely no problems in the effluents according
to Steel. Chromium could present difficulties. Steel personnel had no
idea what acid solutions were utilized in the pickling baths. Further-
more, they could not give us any data on composition of chemicals used
in steel finishing.
Questions on storm sewers contributing to outfalls 005 and 006 indicated
there would be little or no upstream contribution during dry weather.
During- wet weather, practically all storm flow would originate from
Company grounds rather than from external areas. Some spring water was
thought to be possible in outfall 005 and/or outfall 006. Possible
sampling points were selected on the open storm culverts immediately
Dbove plant production areas in the event that NET determinations are
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necessary. One such point Is close to the main gate at Irvin (on the
head end of outfall 005), and the other is close to the north (truck)
gate (on the head end of outfall 006) near the blue shack.
Two sets of scale pits exist on the wastes off the 80-inch hot strip
mill. The first of these is a (south side) 3-compartment scale basin,
the compartments thought to be arranged in series. Two larger cells
are followed by a smaller third cell. The second of these consists
of four compartments arrayed in series located adjacent to and just
•north of the boiler house. Both scale pits are on the east side of
the 80-inch hot strip mill. Scale pit effluents find their way into
outfall 006. The south side scale pit complex also receives up to 0.84
MGD spent concentrated pickling liquors off the 84-inch continuous
pickling line. Effluents from the respective scale pits are represented
by sampling points "306" and "406" as specified in the NPDES Permit.
However, no sampling is required at these two latter points until after
1/1/77 and the Company has not yet selected these stations. The stations
If sampled today, will need to be taken off the last compartment of each
scale pit just as the effluent leaves the tank and flows underground
to sewer 006. The presence and function of aluminum sulphate phenol ate
in marked barrels around the scale pits was not determined. Scale
originating from the 80-inch hot strip mill is collected and customarily
shipped to the E. Thomson sinter plant. However, this sinter plant has
been shut down since January 1975 due to air pollution problems. Current
disposition and disposal of the Irvin hot strip mill scale solids is not
known. The boiler house contributes primarily boiler blowdown to the
006 sewer. Close to the boiler house was located a set of cooling
towers (double fan type) primarily for treatment and reuse of waters
from the annealing operations generally located in the cold reduction-
temper rolling process sectors of the plant. USSC characterizes the hot
annealing waters as "plain cooling waters." This cooling tower is situated
on the north side of the Irvin works. As shown in the available materials
given EPA by Steel, "Miscellaneous Cooling Water" amounting to 2.18 MGD
is directed to the 006 sewer whereas "Heat Treating" waters are split with
approximately one-half going to the 006 sewer and the remaining to the
005 sewer.
On the fuel sides, the boilers are powered by coal and coke oven gas.
The annealing furnaces are served by natural gas. The No. 7 boiler
has collection of fly ash and subsequent reuse of fly ash. The "shot"
plant is equipped with small sized baghouses.
In the coating section, we viewed the two galvanizing lines and the
terne-coated line. The coating lines are equipped with large furnaces
for drying the sheet steel after dipping or coating. Before terne-
coating, the metal steel receives caustic-detergent cleaning. Pure
metal bars of zinc, aluminum and lead seem to be largely bought from
St.'Joe Metals. The galvanized and aluminum coat lines can handle a
maximum width of steel of 54-inchcs. Steel plate prior to terne
coating is subjected to annealing and acid cleaning and rinsing.
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The metal for tin coating employs caustic-detergent cleaning, looping
of the metal, heat treating or annealing of the metal, followed by
rapid cooling. The annealed metal may then be temper rolled prior to
coating. Tin sheet is largely used for tin cans. In the electrolylical
tinning sector, the operations generally comprise uncoiling, acid
cleaning, rinsing, immersion in the electrolytic bath, rinsing, pro-
bable drying, and coiling. The tinning operations were completely shut
down during our visit of June 24 which, according to Pitcairn, was the
first time he had witnessed this occurrence. The tinning operations
which consist of 3 separate lines, handle steel plate of approximate-
ly 150 fpm requiring less than 60 seconds for complete coating and
drying. The anodes are made of pure tin and the steel introduced into
solution becomes the cathode. Thomas reported that practically all tin
coating in the industry today is accomplished by electrolytic means and
there is practically no more tin "dipping."
Haste Oil Treatment and Acid Neutralization Systems at Irvin Plant
Waste streams into the waste oil treatment system originate almost en-
tirely from various cold rolling steel operations. Waste oils enter
either-into the "old" plant consisting of a dual chamber API separator
or into a four-compartment (in parallel) API separator, the latter part
of the new plant. The wastes next enter one of two equalization basins
and are pumped across into a rectangular mixing basin. Chemicals,
principally FeCl2 plus polyelectrolytes, are added to this tank. The
Waste next enters two flocculation basins in parallel followed by two
circular air flotation tanks in parallel. The effluents from the waste
oil treatment system enter into outfall 005. Oils skircmed off the
various sets of API separators are separately stored and taken to Clair-
ton where the oils are added to the coal in the coking works. Thomas
reports this system has been down to less than 5 mg/1 oils. Irvin
samples the waste oil treatment plant effluent on what is believed to be
a daily basis and ,reports analytical results to PENDCR on a monthly
basis. Analyses include Fe, TSS, and oils. The plant operator indi-
cated to us that the influent oil level of around 300 mg/1 is consistent-
ly lowered to less than 10 mg/1. They had been previously dosing the
system with about 58 mg/1 FeCl2 but have since entered into an experi-
mental testing phase. Current dosage is down to 22 mg/1 Fed? or less.
Sludges are removed to the acid neutralization plant. The effluent pll
of the waste oil treatment system is around 10.0, compared to highly
acidic condition of the other wastes entering the 005 discharge line.
The composite 005 waste stream continues to be highly acidic.
The'acid neutralization treatment system essentially receives concen-
trated spent pickling solutions. This system includes two waste pick-
ling liquor storage tanks, three reaction tanks wherein lime is added
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to the pickling liquors and the end-point pH is brought up to about 5.0,
followed by three detention tanks. Chemical sludges from the waste oil
treatment system are mixed with sludge contents of the final detention
tanks and piped into adjoining railroad cars. These sludges are taken
to landfill. Waste oils from the waste oil treatment plant are piped
Into a tank truck at the rear of the neutralization plant and as re-
ported previously, are transported to the USSC Clairton site. There
is no reported discharge from the neutralization system to either outfall
005 or 006 or any other In/in outfall, although Thomas admits there is
still access of a sludge line to the 005 sewer: Irvin reports this dis-
charge to be "zero" in the NPDES permit information. Neutralized sludges
amount to between 10,000 to 20,000 gallons per shift per day;
this material is disposed of to Brown's Dump. Irvin personnel cite the
005 outfall as carrying 15 to 20 MGD wastewater to the Monongahela River.
Besides waste sources previously described, the 005 sewer receives NCCW,
process and cooling wastes from electrolytic tinning, considerable pick-
ling rinse waters, miscellaneous non-process waters from cold rolling
and heat-treating operations, miscellaneous cooling waters, and area.
storm drainage. A large sub-flow of 10.34 MGD was shown by previous
Company transmittals as a separate discharge into the 005 sewer but
-according to Pitcairn, this is not true; the 10.34 MGD actually enters
the 005 line at many diverse points. Plant personnel characterize the
composite 005 discharge as generally acidic with a pH between 2.3 and
"11.0 and typified as a generally white foaming scum on the surface of
the Monongahela River.
Effluent from the waste oil treatment system is accessible via a
Central collection box before disappearing into the 005 sev/er.
^Measurement of this flow will be exceedingly difficult. The 005 sewer
is sampled by the Company immediately below the waste oil treatment and
-acid neutralization systems just before the sev/er starts its radical
vertical descent down the hillside into the Monongahela River. Access
to the 005 sampling point is through an impossibly small 6-inch diameter
"hole" on plant property. Flow measurement is impossible at this loca-
tion.
The 005 outfall at the River is difficult to reach because of a steep
incline from the road down the river bank and no parking on the road-
way within a quarter mile or more of the outfall. On June 24th, the 005
discharge into the river was observed as being very murky and oily.
Down at the river bottoms, the circular cross section of outfall 005
was measured as approximately 66-inches across. The discharge was ob-
served moving down a 40 foot apron before intercepting the River with
an approximate velocity around 18 fps. The discharge was noted as
being very hot and extremely oily. There was a preponderance of sludge
banks in proximity to the outfall although these deposits were heavy
black in contrast to the milky-white emulsion contained in the direct
discharge. A sketch of the waste oil treatment plant is shown on the
following page/ (Exhibit A).
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EXHIBIT A
>
West
Old
Sep
«»»-f
N
^
f
East
Old
Sep
"**r
N
'
API
Sep
FEED
API
Sep
Equalization
Basin
BOX
API
Sep
V
API
Sep
Equalization
Basin
Final Collection Box
To 005
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« I.
Domestic Sewage Treatment
Returning to the 006 sewer line, we proceeded down to the domestic sewage
treatment facility of the Irvin works located on the last scries of bluffs
overlooking the River. We viewed the plant from outside a chained fence
sfnce nobody had a key to enter inside. The treatment plant consisted of
two small imhoff tanks in series followed by a non-recirculating trickling
filter and chlorination, with chlorine contact presumably obtained in the
discharge line down to the 006 sewer. During our visit, the trickling
filter was non-operational. Fred Thomas stated the filter had been down
only a couple of days but judging by the condition of the filter rocks,
the down time was more like many weeks or months. We were told chlorina-
tion was followed by a parshall flume but we could neither see nor get
access to this side of the plant. As usual, Steel personnel could provide
no technical detail on treatment. Even chlorine dosage v/as unknown.
A double set of manholes is available a few feet upstream of the domestic
sewage treatment plant. One manhole provides access to the domestic
sewage flow down to the separate treatment facility. The other manhole
provides access to the 006 sewer upstream of the domestic sewage treat-
went plant. Both manholes are deep and the 006 pipeline in particular/
has extremely high velocity as it drops down the hillside to the
Monongahela River. The 006 outfall at its terminus with the Monongahela
River cascades in almost a waterfall effect down a concrete apron and
then into the River. Maximum reported flow for "006" has been given in the
NPDES permit as 54 MGD. This very large flow was hot and estimated to have
a velocity in the range of 25 fps. From the River, this outfall is ex-
tremely well-hidden, being situated behind a long series of empty-standing
barges. On the North side of the Irvin plant boundaries are located
Westinghouse, Continental Can, and General Motors, indicating a highly
Industrialized area.
River Water Intake and Hater Treatment
Lastly, we visited the Irvin water intake pumping station on the
Monongahela River and the water treatment facilities situated on a
hill overlooking both the production plant and the River approximately
300 feet higher in elevation than the River. We received conflicting
data on volumes of water withdrawn. Initially, plant personnel were
guessing about 18,000 gpm per pump x 5 available pumps = 130 MGD, but
With only 2 or 3 pumps generally being used, the estimated intake was
then 51.9 to 77.8 MGD. Thomas and Pitcairn indicated the pump station
has a maximum intake of 80 MGD but they were currently utilizing only
about 40-45 MGD, or roughly 50% of capacity. After talking with the
plant operator and inspecting the nameplates and gages on the pumps,
we found there are 5 large pumps and one small pump. The capacity on
each of the 5 large pumps was 12,000 gpm but they were currently
running at only 8,800 gpm. During our visit, volume being pumped was
close to 8,800 gpm x 5 pumps = 63.4 MGD.
The Company for purposes of NET loads in the NPDES permit, is sampling
water intake from the pumps at the intake station on the pump discharge
side. Sampling is conducted at the lower level in the pump station. A
pipe discharge extends from the intake station on the north side running
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'down the hill to the water. This intermittent discharge was described
as screen or strainer backwash from pumps on the intake station. A
second unreported discharge was observed boiling up in the River (backed
With high pressure) apparently coming from the direction of the intake
station and finally described by USSC as sump discharge from the intake
station-, This is a relatively sizeable discharge flowing almost con-
stantly. This discharge will be most difficult to sample and nearly
impossible to gage. A third unreported discharge was found coming down
the hillside, crossing the road, and intercepting the Monongahela River
a short distance downstream of the Irvin water intake station. Flow
was appreciable and whereas the discharge appeared clear, large deposits
of oil were present where this stream intercepted the River. The Company
thought this to be acid mine drainage from abandoned operations.
The water treatment plant consists of an old and a new section. The old
facility seems to comprise a circular settling basin and sand filters,
the latter no longer in use. The new plant more or less includes a new
settler and a new sand filtration station. They also have available, a
large storage tank or reservoir for finished water together with an 9
emergency elevated water tank. Steel could not provide us with any
figures on sizes and dimensions of the various water treatment units
nor with volumes of raw or finished water. Steel divides Irvin v/ater
use into three categories: Filtered water (thru water treatment plant);
Plant water (thru water treatment plant); and plant v/ater used in pro-
duction but not treated. Large quantities of Calgon BC-4 Industrial
Cleaner were stored in the main filter plant building but Steel did not
know its use. Aluminum sulfate also stored on the premises is un-
doubtedly used as a coagulant. The new v/ater treatment facility was
equipped with three high-rate sand filters. Water treatment sludges
were reported as primarily discharged to the 006 sewer. Irvin obtains
its drinking v/ater from Allegheny Company, not from its own treatment
system.
Proposed sampling and gaging points for the Irvin works are tabbed as
follows:
Total
005, at terminus
006, at terminus
Water intake at River 3
306, 80-inch hot strip scale pit effluent
106, sanitary treatment plant effluent 6
Waste oil treatment plant influent
Vlaste oil treatment plant effluent 8
Storm drainage (1 or 2 locations) but
only if found necessary 10
Additional Items
During a closing meeting of June 25 with USSC, we asked as to the avail-
ability of water metering records since we had been previously told
Irvin routinely meters the raw water into its tin v/orks. We thereby
suspected records were available for the water usage on all throe electro-
lytic tinning lines. We were told whatever records are available are
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maintained by the Accounting Department and in order to satisfy our
data needs, the whole accounting department would need to become in-
volved. They would also have to tell us where the meters may be
located if any others existed. We asked for the same information on
the water treatment plant and v/ere told "nobody knows", the meters,
if they exist, probably need calibration, they will try to find out,
etc. Water not treated at the water plant is that which primarily is
utilized within the 80-inch hot strip mill.
cc: Hathaway
Vincent
Blackman
Pennington
Benson
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