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

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           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

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                       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:

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                                   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

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    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.

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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.)

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             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)

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                                                                       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

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                                                                         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.

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                                                                          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.

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                                                                         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.

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                                                                        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

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                                                                         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.

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                                                                         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.

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                    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).

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                                                    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: 
-------
                               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.

-------
                             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.

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 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.

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 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

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 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

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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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