United States
Environmental Protection
Agency
Effluent Guidelines Division
WH-552
Washington, DC 20460
EPA 440/1-80/024-b
December 1980
Water and Waste Management
Development	Proposed
Document for
Effluent Limitations
Guidelines and
Standards for the
Iron and Steel
Manufacturing
Point Source Category
Vol. VI
Cold Forming Subcategory
Alkaline Cleaning Subcategory
Hot Coating Subcategory

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DEVELOPMENT DOCUMENT
for
PROPOSED EFFLUENT LIMITATIONS GUIDELINES,
NEW SOURCE PERFORMANCE STANDARDS,
and
PRETREATMENT STANDARDS
for the
IRON AND STEEL MANUFACTURING
POINT SOURCE CATEGORY
Douglas M. Costle
Administrator
Steven Schatzow
Deputy Assistant Administrator for
Water Regulations and Standards
Jeffery Denit, Acting Director
Effluent Guidelines Division
Ernst P. Hall, P.E.
Chief, Metals & Machinery Branch
Edward L. Dulaney, P.E.
Senior Project Officer
December, 1980
Effluent Guidelines Division
Office of Water and Waste Management
U.S. Environmental Protection Agency
Washington, DC 20460

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COLD FORMING SUBCATEGORY
COLD ROLLING
TABLE OF CONTENTS
SECTION	PAGE
I	PREFACE 		1
II	CONCLUSIONS 		3
III	INTRODUCTION	13
General Discussion	13
Data Collection Activities	13
Cold Rolling Limitations	14
Description of Cold Rolling Operations	15
IV	SUBCATEGORIZATION 		33
Introduction	33
Factors Considered in Subcategorization 		33
V	WATER USE AND WASTE CHARACTERIZATION	4 9
Introduction	49
Description of the Cold Rolling Operation and
Wastewater Sources	49
VI	WASTEWATER POLLUTANTS 		5 9
Introduction	59
Conventional and Nonconventional Pollutants 		59
Toxic Pollutants	60
VII	CONTROL AND TREATMENT TECHNOLOGY 		63
Introduction	63
Summary of Treatment Practices Currently Employed . .	6 3
Control and Treatment Technologies Considered for
Toxic Pollutant Removal			64
Summary of Sampling Visit Data	68
Summary of Long-Term Analytical Data	71

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COLD FORMING SUBCATEGORY
COLD ROLLING
TABLE OF CONTENTS (CONTINUED)
SECTION	PAGE
VIII	COST, ENERGY, AND NONWATER QUALITY IMPACTS 	103
Introduction	103
Actual Costs Incurred by Plants Sampled or
Solicited for this Study	103
Control and Treatment Technologies Recommended
for Use in the Cold Rolling Subdivision	103
Cost, Energy, and Nonwater Quality Impacts 	104
Estimated Costs for the Installation of Pollution
Control Equipment	104
Energy Impacts Due to the Installation of the
Requisite Technologies 	106
Nonwater Quality Impacts	107
Summary of Impacts	109
IX	EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICATION
OF THE BEST PRACTICABLE CONTROL TECHNOLOGY
CURRENTLY AVAILABLE	143
Introduction	143
Identification of BPT	143
Rationale for BPT	14 3
Justification of Proposed BPT Limitations	144
X	EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICATION
OF THE BEST AVAILABLE TECHNOLOGY ECONOMICALLY
ACHIEVABLE 	149
Introduction	14 9
Identification of BAT	149
Rationale for the Selection of the BAT Alternative . .150
Selection of a BAT Alternative	153
Removal of Organic Contamination by Oil Substitution .153
XI	BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY . . . .16 3
Introduction	163
Development of BCT	163
Development of BCT Limitations	164
ii

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COLD FORMING SUBCATEGORY
COLD ROLLING
TABLE OF CONTENTS (CONTINUED)
SECTION	PAGE
XII	EFFLUENT QUALITY ATTAINABLE THROUGH THE
APPLICATION OF NEW SOURCE PERFORMANCE STANDARDS . .	167
Introduction 		167
Identification of NSPS	167
Rationale for Selection of NSPS	168
Selection of an NSPS Alternative	168
XIII	PRETREATMENT STANDARDS FOR THE DISCHARGES TO
PUBLICLY OWNED TREATMENT WORKS 		171
Introduction 		171
General Pretreatment Standards 		171
Identification of Pretreatment 		172
Rationale for the Selection of Pretreatment
Technologies	
Selection of PSES and PSNS	I73
in

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COLD FORMING SUBCATEGORY
COLD ROLLING
TABLES
NUMBER	TITLE	PAGE
II-l	BPT TREATMENT MODEL FLOWS AND EFFLUENT QUALITY ....	6
II-2	PROPOSED BPT EFFLUENT LIMITATIONS 		7
II-3	TREATMENT MODEL FLOWS AND EFFLUENT QUALITY 		8
II-4	PROPOSED EFFLUENT LIMITATIONS AND STANDARDS	10
III-l	BASIC DESCRIPTION OF COLD ROLLING OPERATIONS SAMPLED .	17
III-2	DESCRIPTION OF U.S. COLD ROLLING OPERATIONS 		18
III-3	GENERAL SUMMARY TABLE - RECIRCULATION MILLS 		20
III-4	GENERAL SUMMARY TABLE - COMBINATION MILLS 		24
III-5	GENERAL SUMMARY TABLE - DIRECT APPLICATION MILLS ...	25
III-6	DATA BASE - RECIRCULATION MILLS	27
III-7	DATA BASE - COMBINATION MILLS	28
III-8	DATA BASE - DIRECT APPLICATION MILLS	29
IV-1	AFFECT OF MILL CONFIGURATION ON DISCHARGE
FLOW RATES	40
IV-2	PLANTS DEMONSTRATING RETROFITTED POLLUTION CONTROL
EQUIPMENT	41
IV-3	RELATIONSHIP BETWEEN FLOW AND OPERATION 	 42
V-l	to
V-5	SUMMARY OF NET RAW ANALYTICAL DATA - COLD ROLLING. • • ¦
VI-1	TOXIC POLLUTANTS KNOWN TO BE PRESENT 	 61
VI-2	SELECTED POLLUTANTS 	 62
VII-1	SUMMARY OF CONTROL AND TREATMENT TECHNOLOGY CODES. . . 72
VII-2 to
VII-7	SUMMARY OF ANALYTICAL DATA - COLD ROLLING	77
VII-8	SUMMARY OF LONG-TERM DATA	87
VIII-1	to
VIII-3	EFFLUENT TREATMENT COSTS 	 110
VIII-4	CONTROL AND TREATMENT TECHNOLOGY SUMMARY 	 113
VIII-5 to
VIII-7	BPT MODEL COST DATA	116
VIII-8 to
VIII-12	BPT CAPITAL COST TABULATIONS 	 122
VIII-13 to
VIII-15	BAT MODEL COST DATA	128
v

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COLD FORMING SUBCATEGORY
COLD ROLLING
TABLES (CONTINUED)
NUMBER	TITLE	PAGE
VIII-16	BCT COST TEST RESULTS	133
VIII-17	NSPS AND PSNS MODEL COST DATA	134
VIII-18 to
VIII-20	PSES MODEL COST DATA	136
IX-1	BPT EFFLUENT LIMITATIONS	145
IX-2	JUSTIFICATION OF BPT EFFLUENT LIMITATIONS	146
X-l	to
X-3	BAT EFFLUENT LIMITATIONS	155
X-4 to
X-6	BAT DISCHARGE FLOW DETERMINATION	158
XI-1	BCT LIMITATIONS	165
XII-1	ALTERNATIVE NEW SOURCE PERFORMANCE STANDARDS	16 9
XIII-1	ALTERNATIVE PRETREATMENT STANDARDS FOR NEW SOURCES. . 17 4
XIII-2	ALTERNATIVE PRETREATMENT STANDARDS FOR EXISTING
SOURCES	17 5
vi

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COLD FORMING SUBCATEGORY
COLD ROLLING
FIGURES
NUMBER	TITLE	PAGE
III-l	PROCESS FLOW DIAGRAM - RECIRCULATION MILL	3 0
II1-2	PROCESS FLOW DIAGRAM - COMBINATION MILL	31
III-3	PROCESS FLOW DIAGRAM - DIRECT APPLICATION MILL. ...	32
IV-1	to
IV-3	FLOW VERSUS SIZE ANALYSIS - COLD ROLLING	43
IV-4 to
IV-6	FLOW VERSUS AGE ANALYSIS - COLD ROLLING	46
VII-1 to
VII-15	SAMPLED PLANTS WATER FLOW DIAGRAMS	88
IX-1	BPT TREATMENT MODEL	147
X-l	BAT ALTERNATIVE TREATMENT SYSTEMS 		162
XI-1	BCT TREATMENT MODEL	166
XII-1	NSPS ALTERNATIVE TREATMENT SYSTEMS	170
XIII-2	PRETREATMENT ALTERNATIVE TREATMENT SYSTEMS	176
vii

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COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
TABLE OF CONTENTS
SECTION	PAGE
I	PREFACE	177
II	CONCLUSIONS	179
III	INTRODUCTION	183
General Discussion	183
Description of Pipe and Tube Mills	183
IV	SUBCATEGORIZATION 		201
Introduction	201
Factors Considered in Subdivision 		201
V	WATER USE AND WASTE CHARACTERIZATION 		207
Introduction	207
Water Use	207
Waste Characterization	208
VI	WASTEWATER POLLUTANTS 		211
VII	CONTROL AND TREATMENT TECHNOLOGY	213
Introduction	213
Summary of Treatment Practices Currently-
Employed at Cold Worked Pipe and Tube Plants	213
Plant Visit Analytical Data	214
VIII	COST, ENERGY, AND NONWATER QUALITY IMPACTS	22 3
Introduction	223
Actual Costs Incurred by the Plant Surveyed
for this Study	223
Control and Treatment Technology	223
Cost, Energy, and Nonwater Quality Impacts	223
Estimated Costs for the Installation of
Pollution Control Technologies 		224
Energy Impacts Due to the Installation of
the Model Technologies	226
Nonwater Quality Impacts	227
Summary of Impacts	228
ix

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COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
TABLE OF CONTENTS (CONTINUED)
SECTION	PAGE
IX	EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICA-
TION OF THE BEST PRACTICABLE CONTROL TECHNOLOGY
CURRENTLY AVAILABLE 		239
Introduction	239
Identification of BPT	239
Rationale for BPT Treatment Systems 		239
Justification of Proposed BPT Limitations 		24 0
X	EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICA-
TION OF THE BEST AVAILABLE TECHNOLOGY ECONOMICALLY
ACHIEVABLE	245
XI	BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY . . .	247
Introduction	247
XII	EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICA-
TION OF NEW SOURCE PERFORMANCE STANDARDS 		24 9
Introduction	24 9
Identification of NSPS	249
Rationale for Selection of NSPS	250
Selection of NSPS Alternative	250
XIII	PRETREATMENT STANDARDS FOR COLD WORKING PIPE AND
TUBE OPERATIONS DISCHARGINT TO PUBLICLY OWNED
TREATMENT WORKS 		253
Introduction	253
General Pretreatment Standards	253
Identification of Pretreatment Standards for
Existing and New Sources	254
x

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COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
TABLES
TABLE
TITLE
PAGE
II-l
III-l
III-2
III-3
III-4
IV-1
V-l
VII-1
VII-2
VIII-1
VIII-2
VIII-3
VIII-4
VIII-5
VIII-6
VIII-7
VIII-8
IX-1
PROPOSED EFFLUENT LIMITATIONS AND STANDARDS . ,
GENERAL SUMMARY TABLE - OPERATIONS USING WATER
GENERAL SUMMARY TABLE - OPERATIONS USING
SOLUBLE OIL SOLUTIONS 	
DATA BASE - OPERATIONS USING WATER 	
DATA BASE - OPERATIONS USING SOLUBLE OIL
SOLUTIONS 	
182
187
FLOW AVERAGES AND RANGES
SUMMARY OF ANALYTICAL DATA FROM THE SAMPLED
PLANT - NET CONCENTRATIONS 	
SUMMARY OF ANALYTICAL DATA FROM THE SAMPLED PLANT
OPERATING MODES, CONTROL AND TREATMENT TECHNOLO-
GIES AND DISPOSAL METHODS 	
EFFLUENT TREATMENT COSTS 	
CONTROL AND TREATMENT TECHNOLOGIES - OPERATIONS
USING WATER 	
CONTROL AND TREATMENT TECHNOLOGIES - OPERATIONS
USING SOLUBLE OIL SOLUTIONS 	
BPT MODEL COST DATA - OPERATIONS USING WATER ,
BPT MODEL COST DATA - OPERATIONS USING SOLUBLE
OIL SOLUTIONS 	
BPT CAPITAL COST TABULATION - OPERATIONS USING
WATER 	
BPT CAPITAL COST TABULATION - OPERATIONS USING
SOLUBLE OIL SOLUTIONS 	
NSPS ALTERNATIVE 2 COST DATA - OPERATIONS USING
SOLUBLE OIL SOLUTIONS 	
SUMMARY OF FLOWS AND BPT JUSTIFICATION - OPERA-
TIONS USING WATER 	
XI

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COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
FIGURES
NUMBER TITLE	PAGE
III-l	ELECTRIC RESISTANCE WELDED PROCESS FLOW DIAGRAM • •	199
IV-1	DISCHARGE FLOW VERSUS PRODUCTION CAPACITY -
OPERATIONS USING WATER 		205
IV-2 DISCHARGE FLOW VERSUS AGE - OPERATIONS USING WATER •	206
VII-1	PLANT HH-2 WASTEWATER TREATMENT SYSTEM, WATER
FLOW DIAGRAM		222
IX-1 BPT TREATMENT MODEL - OPERATIONS USING WATER ....	242
IX-2 BPT TREATMENT MODEL - OPERATIONS USING SOLUBLE
OIL SOLUTIONS	243
XII-1	NSPS TREATMENT ALTERNATIVE 2 - OPERATIONS USING
SOLUBLE OIL SOLUTIONS 		252
xiii

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ALKALINE CLEANING SUBCATEGORY
TABLE OF CONTENTS
SECTION	PAGE
I	PREFACE	255
II	CONCLUSIONS	257
III	INTRODUCTION	265
General Discussion 		265
Development of Limitations 		265
Description of Alkaline Cleaning Operations 		266
IV	SUBCATEGORIZATION 		281
Manufacturing Process and Equipment	28?-
Final Products	28^
Raw Materials	282
Wastewater Characteristics 		283
Wastewater Treatability 		2®3
Size and Age	2„
•	•	0 ft ^
Geographic Location 	
Process Water Usage	2"
V	WATER USE AND WASTE CHARACTERIZATION
291
Introduction	29^
Alkaline Cleaning Operations 		2^1
VI	WASTEWATER POLLUTANTS	295
VII	CONTROL AND TREATMENT TECHNOLOGY 		301
Introduction 		301
Summary of Treatment Practices Currently Employed . .	301
Advanced Treatment Systems Considered for the
Alkaline Cleaning Subcategory 		303
Summary of Sampling Visit Data	305
xv

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ALKALINE CLEANING SUBCATEGORY
TABLE OF CONTENTS (CONTINUED)
SECTION	PAGE
VIII	COST, ENERGY AND NON-WATER QUALITY IMPACTS 		317
Introduction 		317
Actual Costs Incurred by the Operations Sampled
for This Study		317
Cost, Energy, and Nonwater Quality Impacts 		318
Estimated Costs for the Installation of Pollution
Control Technologies 		318
Energy Impacts Due to the Installation of the
Requisite Technology 		319
Nonwater Quality Impacts 		320
Summary of Impacts		32 2
IX	EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICA-
TION OF THE BEST PRACTICABLE CONTROL TECHNOLOGY
CURRENTLY AVAILABLE	341
Introduction 		341
Identification of BPT		341
Rationale for BPT		342
Justification of BPT Limitations 		342
X	EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICA-
TION OF THE BEST AVAILABLE TECHNOLOGY ECONOMICALLY
ACHIEVABLE		345
Introduction 		345
Development of BAT	345
XI	BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
(BCT)	347
Introduction 		347
Development of BCT	347
XII	EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICATION
OF NEW SOURCE PERFORMANCE STANDARDS	349
Introduction 		349
Identification of NSPS	349
Rationale for the Selection of NSPS	349
XIII	PRETREATMENT FOR DISCHARGES TO PUBLICLY OWNED
TREATMENT WORKS 		355
^ R R
Introduction	
General Pretreatment Standards	
xv i

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ALKALINE CLEANING SUBCATEGORY
TABLES
NUMBER	TITLE	PAGE
II-l	BPT TREATMENT MODEL FLOWS AND EFFLUENT QUALITY ...	260
II-2	PROPOSED BPT EFFLUENT LIMITATIONS 		261
II-3	TREATMENT MODEL FLOWS AND EFFLUENT QUALITY 		262
H-4	PROPOSED EFFLUENT LIMITATIONS AND STANDARDS	263
III-l	SUMMARY TABLES, ALKALINE CLEANING - BATCH TYPE MILLS. 267
III-2 SUMMARY TABLES, ALKALINE CLEANING - CONTINUOUS TYPE
MILLS			269
IH-3	DESCRIPTION OF ALKALINE CLEANING MILLS SAMPLED FOR
THIS STUDY	275
III-4	DATA BASE: ALKALINE CLEANING - BATCH 	 27 6
III-5	DATA BASE: ALKALINE CLEANING - CONTINUOUS 	 277
IV-1	AFFECT OF FINISHING OPERATIONS AND PRODUCT TYPE ON
THE DISCHARGE FLOW RATES OF ALKALINE CLEANING
OPERATIONS	286
IV-2	EXAMPLES OF PLANTS THAT HAVE DEMONSTRATED THE ABILITY
TO RETROFIT POLLUTION CONTROL EQUIPMENT 	 287
IV-3	LOCATION OF ALKALINE CLEANING OPERATIONS	288
V-l	SUMMARY OF ANALYTICAL DATA OF SAMPLED PLANTS, NET
CONCENTRATIONS OF POLLUTANTS IN RAW WASTEWATERS . . .293
VI-1	TOXIC POLLUTANTS KNOWN TO BE PRESENT IN ALKALINE
CLEANING WASTEWATERS 	 298
VI-2	SELECTED POLLUTANT PARAMETERS 	 299
VII-1	OPERATING MODES, CONTROL AND TREATMENT TECHNOLOGIES
AND DISPOSAL METHODS 	 307
VII-2	SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS. . . . 312
VIII-1	EFFLUENT TREATMENT COSTS	323
VI11-2	CONTROL AND TREATMENT TECHNOLOGIES	324
VIII-3	BPT MODEL COST DATA - BATCH MILLS	32 6
VIII-4	BPT MODEL COST DATA - CONTINUOUS MILLS	327
VIII-5	BPT CAPITAL COST TABULATION - BATCH CARBON AND
SPECIALTY STEEL MILLS 		328
VIII-6	BPT CAPITAL COST TABULATION - CONTINUOUS CARBON AND
SPECIALTY STEEL MILLS			330
VI11-7	BAT MODEL COST DATA - BATCH MILLS	332
VIII-8	BAT MODEL COST DATA - CONTINUOUS MILLS	333
VIII-9	CONSIDERED BCT MODEL COST DATA - BATCH MILLS	334
xvii

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ALKALINE CLEANING SUBCATEGORY
TABLES (CONTINUED)
NUMBER	TITLE	PAGE
VIII-10	CONSIDERED BCT MODEL COST DATA - CONTINUOUS MILLS. .	335
VIII-11	RESULTS OF THE BCT COST TEST - BATCH MILLS 		336
VIII-12	RESULTS OF THE BCT COST TEST - CONTINUOUS MILLS. . .	337
VIII-13	NSPS MODEL COST DATA - BATCH MILLS	338
VIII-14	NSPS MODEL COST DATA - CONTINUOUS MILLS	339
IX-1	JUSTIFICATION OF BPT EFFLUENT LIMITATIONS	343
XII-1	NEW SOURCE PERFORMANCE STANDARDS 		352
xviii

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ALKALINE CLEANING SUBCATEGORY
FIGURES
NUMBER	TITLE	PAGE
III-l	PROCESS FLOW DIAGRAM - BATCH MILL 	278
III-3	PROCESS FLOW DIAGRAM - CONTINUOUS MILL	279
IV-1	ANALYSIS OF FLOW VERSUS SIZE - BATCH AND
CONTINUOUS	289
IV-2	ANALYSIS OF FLOW VERSUS AGE - BATCH AND
CONTINUOUS	290
VII-1	WATER FLOW DIAGRAM - PLANT 152	313
VII-2	WATER FLOW DIAGRAM - PLANT 152	314
VII-3	WATER FLOW DIAGRAM - PLANT 156	315
VII-4	WATER FLOW DIAGRAM - PLANT 157 and 1	316
IX-1	BPT MODEL	344
X-l	BAT MODEL	346
XI-1	BCT MODEL	348
XII-1	NSPS MODEL	353
xix

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HOT COATING SUBCATEGORY
TABLE OF CONTENTS
SECTION	PAGE
I	PREFACE	357
II	CONCLUSIONS	359
III	INTRODUCTION	369
Background	369
Description of Hot Coating Operations 	 370
IV	SUBCATEGORIZATION 	 391
Introduction	3 91
Factors Considered in Subcategorization 		3 91
Manufacturing Process and Equipment 		3 91
Raw Materials	392
Final Products	392
Wastewater Characteristics and Treatability 		393
Size and Age	393
Geographic Location 		395
Process Water Usage Rates 		395
V	WATER USE AND WASTE CHARACTERIZATION	401
Introduction	401
Water Use in Hot Coating Operations	401
Applied Flow Rates	403
Waste Characterization	403
VI	WASTEWATER POLLUTANTS	409
Introduction	409
Conventional Pollutants 	 409
Toxic Pollutants	409
VII	CONTROL AND TREATMENT TECHNOLOGY	417
Introduction	417
Summary of Treatment Practices Currently Employed . . 417
Plant Visits	420
xxi

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HOT COATING SUBCATEGORY
TABLE OF CONTENTS (CONTINUED)
SECTION	PAGE
VIII	COST, ENERGY, AND NONWATER QUALITY IMPACTS. ..... 445
Introduction	445
Costs for Facilities in Place	445
Control and Treatment Technology (C&TT) 	 447
Treatment Cost Estimates	447
Energy Impacts Due to Installation of
Recommended Technology 	 449
Nonwater Quality Impacts	450
Water Consumption	451
Summary of Impacts	451
IX	EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICA-
TION OF BPT TECHNOLOGY	517
Identification of BPT	517
Rationale for Selection of BPT		 . 517
BPT Flows 	518
Justification for Proposed BPT Limitations	519
X	EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICA-
TION OF BAT TECHNOLOGY	533
Introduction	533
Identification of BAT	533
Effluent Limitations 	 535
Selection of BAT Alternative	53 5
XI	BEST CONVENTIONAL POLLUTION CONTROL TECHNOLOGY. . . .553
Introduction	553
Analysis of BCT Control Costs	553
Selection of BCT Alternative	554
Development of BCT Limitations	555
XII	EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICA-
TION OF NEW SOURCE PERFORMANCE STANDARDS	561
Introduction	561
Identification of NSPS Technology			561
Selection of NSPS	562
xxii

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HOT COATING SUBCATEGORY
TABLE OF CONTENTS (CONTINUED)
SECTION	PAGE
XIII	PRETREATMENT STANDARDS FOR HOT COATING PLANTS
DISCHARGING TO PUBLICLY OWNED TREATMENT WORKS . . . .	569
Introduction	569
General Pretreatment Standards	569
Categorical Pretreatment Standards	569
New Sources	570
Rationale for Selection of Pretreatment
Technologies 		57 0
Selection of Pretreatment Standards 		571
xxiii

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HOT COATING SUBCATEGORY
TABLES
NUMBER	TITLE	PAGE
II-l	BPT TREATMENT MODEL FLOWS AND EFFLUENT QUALITY ...	363
II-2	PROPOSED BPT EFFLUENT LIMITATIONS 		364
II-3	TREATMENT MODEL FLOWS AND EFFLUENT QUALITY 		365
II-4	PROPOSED EFFLUENT LIMITATIONS AND STANDARDS	367
III-1	HOT COATING SUBCATEGORY - GALVANIZING SUMMARY. ... 375
II1-2 HOT COATING SUBCATEGORY - TERNE COATING SUMMARY. . . 382
III-3 HOT COATING SUBCATEGORY - OTHER METAL COATINGS
SUMMARY	383
III-4	HOT COATING DATA BASE	385
IV-1	PLANTS DEMONSTRATING THE ABILITY TO RETROFIT
POLLUTION CONTROL EQUIPMENT - HOT COATING
SUBCATEGORY	397
V-l	PROCESS WATER APPLIED RATES - HOT COATING
OPERATIONS			4 04
V-2 to	SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
V-4	(NET RAW WASTEWATER CONCENTRATIONS AND LOADS). . . . 405
VI-1	to
VI-3	TOXIC POLLUTANTS IN HOT COATING WASTEWATERS .... 412
VI-4	SELECTED POLLUTANT PARAMETERS - HOT COATING
OPERATIONS	415
VII-1	LIST OF CONTROL AND TREATMENT TECHNOLOGY
COMPONENTS AND ABBREVIATIONS 	 423
VII-2 to	SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
VII-4	(GROSS EFFLUENT CONCENTRATIONS AND LOADS)	 428
VIII-1	EFFLUENT TREATMENT COSTS REPORTED BY SAMPLED
PLANTS	452
VIII-2	ENERGY REQUIREMENTS TO ACHIEVE BPT LIMITATIONS -
HOT COATING OPERATIONS 	 453
VIII-3	ENERGY REQUIREMENTS TO ACHIEVE BAT LIMITATIONS -
HOT COATING OPERATIONS 	 454
VII1-4 to CONTROL AND TREATMENT TECHNOLOGY -
VIII-6	HOT COATING SUBCATEGORY	 455
VIII-7 to BPT TREATMENT MODEL COST DATA - HOT COATING
VI11-9	SUBCATEGORY	 464
XXV

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HOT COATING SUBCATEGORY
TABLES (CONTINUED)
NUMBER
TITLE
PAGE
VIII-10 to
VIII-12
VIII-13
VIII-14 to
VIII-16
VIII-17 to
VIII-19
VIII-20 to
VIII-24
VIII-25
BAT TREATMENT MODEL COST DATA - HOT COATING
SUBCATEGORY	474
RESULTS OF BCT COST TEST - HOT COATING SUBCATEGORY. . 484
NSPS AND PSNS TREATMENT MODEL COST DATA -
HOT COATING SUBCATEGORY 	 487
PSES TREATMENT MODEL COST DATA - HOT COATING
SUBCATEGORY	497
BPT CAPITAL COST TABULATION - FACILITIES IN-PLACE -
HOT COATING SUBCATEGORY 	 507
BPT COST REQUIREMENTS - HOT COATING SUBCATEGORY . . . 512
IX-1
IX-2
IX-3
BPT EFFLUENT LIMITATIONS
BPT EFFLUENT LIMITATIONS
BPT EFFLUENT LIMITATIONS
METALS		
HOT COATING
HOT COATING
HOT COATING
GALVANIZING.
TERNE METAL.
OTHER
526
527
528
X-l
X-2
X-3
X-4
X-5
X-6
BAT EFFLUENT LIMITATIONS - HOT COATING - GALVANIZING. 536
BAT EFFLUENT LIMITATIONS - HOT COATING - TERNE METAL. 537
BAT EFFLUENT LIMITATIONS - HOT COATING - OTHER
METALS	538
JUSTIFICATION OF BAT FLOW BASIS - FUME HOOD SCRUBBER
RECYCLE SYSTEMS 	 539
JUSTIFICATION OF BAT FLOW BASIS - RINSEWATER FLOW
REDUCTION	540
LONG-TERM DATA EVALUATION - HOT COATING -
GALVANIZING			542
XI-1
XI-2
XI-3
BCT EFFLUENT LIMITATIONS
BCT EFFLUENT LIMITATIONS
BCT EFFLUENT LIMITATIONS
OTHER METALS		
HOT COATING
HOT COATING
HOT COATING
GALVANIZING. 556
TERNE METAL. 557
558
XII-1
XII-2
XII-3
NSPS EFFLUENT LIMITATIONS
NSPS EFFLUENT LIMITATIONS
NSPS EFFLUENT LIMITATIONS
OTHER METALS 	
HOT COATING
HOT COATING
HOT COATING
-	GALVANIZING.563
-	TERNE METAL.564
565
XIII-1
XIII-2
XIII-3
PSES EFFLUENT LIMITATIONS
PSES EFFLUENT LIMITATIONS
PSES EFFLUENT LIMITATIONS
OTHER METALS 	
HOT COATING
HOT COATING
HOT COATING
-	GALVANIZING.572
-	TERNE METAL.573
574
xxv i

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HOT COATING SUBCATEGORY
FIGURES
NUMBER	TITLE	PAGE
III-l to	PROCESS FLOW DIAGRAM - HOT COATING -
III-3	GALVANIZING	386
III-4	PROCESS FLOW DIAGRAM - HOT COATING -
TERNE PLATE	389
III-5	PROCESS FLOW DIAGRAM - HOT COATING -
ALUMINIZING	390
IV-1	APPLIED FLOW VERSUS AGE ANALYSIS - HOT
COATING OPERATIONS	398
IV-2	APPLIED FLOW VERSUS SIZE ANALYSIS - HOT
COATING OPERATIONS	399
VII-1 to	WASTEWATER TREATMENT SYSTEM WATER FLOW
VII-13	DIAGRAMS - HOT COATING SUBCATEGORY	432
VIII-1	to	TREATMENT MODEL SUMMARIES - HOT COATING
VIII-3	SUBCATEGORY 	 513
IX-1	BPT TREATMENT MODEL DIAGRAM - HOT COATING
GALVANIZING	52 9
IX-2	BPT TREATMENT MODEL DIAGRAM - HOT COATING
TERNE	530
IX-3	BPT TREATMENT MODEL DIAGRAM - HOT COATING
OTHER METAL	531
X-l	to	ALTERNATIVE BAT TREATMENT MODEL DIAGRAMS -
X-3	HOT COATING - GALVANIZING	543
X-4 to	ALTERNATIVE BAT TREATMENT MODEL DIAGRAMS -
X-6	HOT COATING - TERNE 	54 6
X-7 to	ALTERNATIVE BAT TREATMENT MODEL DIAGRAMS -
X-9	HOT COATING - OTHER METALS	549
XI-1	ALTERNATIVE BCT TREATMENT MODEL SUMMARY -
HOT COATING SUBCATEGORY 	 559
XII-1	to	ALTERNATIVE NSPS TREATMENT MODEL SUMMARY -
XII-2	HOT COATING SUBCATEGORY 	566
XIII-1	to ALTERNATIVE PSES TREATMENT MODEL SUMMARY -
XIII-2	HOT COATING SUBCATEGORY 	 575
XXVii

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COLD FORMING SUBCATEGORY
COLD ROLLING
SECTION I
PREFACE
The USEPA is proposing effluent limitations and standards for the
steel industry. The proposed regulation contains effluent limitations
for best practicable control technology currently available (BPT),
best conventional pollutant control technology (BCT), and best
available technology economically achievable (BAT) as well as
pretreatment standards for new and existing sources (PSNS and PSES)
and new source performance standards (NSPS), under Sections 301, 304,
306, 307, and 501 of the Clean Water Act.
This part of the Development Document highlights the technical aspects
of EPA's study of the Cold Rolling Subdivision of the Cold Forming
Subcategory of the Iron and Steel Industry. Volume I of the
Development Document discusses issues pertaining to the industry in
general, while other volumes relate to the remaining subcategories of
the industry.
l

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COLD FORMING SUBCATEGORY
COLD ROLLING
SECTION II
CONCLUSIONS
This report highlights the technical aspects of EPA's study of the
cold rolling subdivision of the cold forming subcategory. Based upon
this current study and a review of previous studies, the Agency has
reached the following conclusions.
1.	Cold rolling and cold worked pipe and tube operations are
combined into one subcategory called "Cold Forming." Because of
differences in mill operation and effluent disposal practices,
the two operations are reviewed separately.
2.	The Agency is retaining the previous segmentation for cold
rolling operations. Proposed limitations and standards have been
developed separately for recirculation, combination, and direct
application mills because of differences in flow rates and
wastewater characteristics.
3.	The Agency is proposing BPT limitations for the cold rolling
subdivision which are identical to those previously promulgated
in 1976. Data obtained from the industry since the original
study demonstrates that the proposed limitations are achievable,
and in fact, less stringent than might be justified.
4.	Reanalysis of the cold rolling data base has shown that the BPT
model treatment system flows for combination and direct
application mills (400 gal/ton and 1000 gal/ton, respectively)
are less stringent than might be justified. Nonetheless, they
have been retained as the model flows for the proposed BPT
limitations. The Agency believes that a BPT model discharge flow
of 250 gal/ton for combination operations and 400 gal/ton for
direct application operations might be appropriate. These values
are used as the model flows for the proposed BAT limitations.
The Agency solicits comments on whether more stringent BPT
limitations based upon these lower flows are appropriate.
5.	Sampling and analysis of recirculation type cold rolling
operations demonstrated that toxic organic pollutants at levels
in excess of 5 mg/1 are present in their wastewaters. The Agency
concludes that toxic pollutant removal should be incorporated in
the various alternative treatment system for recirculation and
combination cold rolling operations.
6.	Sampling and analysis of direct application cold rolling mills
did not reveal the presence of significant levels of toxic
organic pollutants. For this reason, the Agency is not proposing
limitations for toxic organic pollutants for operations that use
3

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direct application oil systems on all rolling stands.
Wastewaters from these mills, however, contain significant levels
of toxic metal pollutants, so control measures for these
pollutants are incorporated in the alternative treatment systems
as was done for recirculation and combination mills.
7. EPA estimates that compliance with the proposed BPT and BAT
limitations will result in significant removals of toxic,
conventional and other pollutants. A summary of the discharges
at the proposed BPT and BAT levels of treatment are shown below.
Flow,
TSS
MGD
TSS
Oil and Grease
Toxic Metals
Toxic Organics
Raw Waste
39
16,290
112,500
185
280
Effluent Loadings (Tons/Year)
Proposed BPT
39.4
3, 130
1 ,250
38
265
Proposed BAT
39.4
860
285
34
33
EPA estimates that the industry will incur the following costs in
complying with the proposed limitations for cold rolling
operations.
Costs (Millions of July 1, 1978 Dollars)
	Investment Costs	 Total
Annual
Total In-Place Required
BPT
BAT
52.3
24. 0
TOTAL 76.3
22.0
_0	
22.0
30.3
24.0
54.3
9.7
4.5
14.2
NOTE: PSES costs are included in the BPT and BAT costs and BCT
costs are included in the BAT costs.
The presence of toxic organic pollutants in cold rolling
wastewaters was found to be highly variable. The Agency believes
this variability is attributable to the oil solutions used at the
operations. This conclusion is based upon sampling results
gathered at several mills which have shown site-specific organic
contamination. Some mills do not exhibit any problems with
organic contaminants while several discharge toxic organics in
the 10 ppm range.
The Agency is proposing limitations and standards for certain
toxic organic pollutants at recirculation and combination
operations. The Agency believes these limitations can be
achieved by the installation of demonstrated treatment
technology, or by substituting oil solutions. The Agency
solicits more data and information on this issue.
10. Although the Agency identified a significant number of the toxic
metal pollutants in the raw and treated wastewaters from cold
rolling operations, it believes that it is not necessary to
4

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propose limitations for every toxic metal detected. Adequate
limitation of the toxic metals can be attained by controlling the
three toxic metals currently proposed for limitation.
11. The Agency evaulated the "cost/reasonableness" of controlling
conventional pollutants and concludes that the control based upon
the proposed BCT model treatment systems are less than the costs
experienced by publicly owned treatment works for combination and
direct application operations. Therefore, it is proposing BCT
limitations for these mills based upon the application of the BCT
model treatment systems. The BCT alternative treatment system
for recirculation operations did not pass the BCT cost test.
Accordingly, the Agency is proposing BCT limitations for
recirculation mills which are the same as the proposed BPT
limitations.
12.	The Agency concluded that all new source cold rolling operations
can be of the recirculation type. The Agency considered two NSPS
alternative treatment systems for these operations. The NSPS
proposed standards and treatment systems are similar to those of
BAT alternative treatment systems 1 and 2. Based upon
demonstrated flows, a lower discharge flow rate is included in
the NSPS model treatment system.
13.	The Agency is proposing pretreatment standards for new and
existing sources (PSNS and PSES) discharging to POTWs. Those
standards limit the discharges of toxic metal and organic
pollutants as well as oil and grease to insure that the
emulsified oils present will be sufficiently treated prior to
discharge to POTWs. These standards are intended to minimize the
impact from cold rolling wastewater pollutants which would
interfere with, pass through or otherwise be incompatible with
POTW operations.
14.	With regard to the "remand issues," the Agency has concluded
that:
a.	Neither relaxed effluent limitations nor retrofit cost
allowances are appropriate for older cold rolling
operations. The age of a cold rolling mill has no
significant effect upon the ease or cost of retrofitting
pollution control equipment.
b.	The alternative treatment systems considered for cold
rolling operations do not include cooling or recycle
systems. Hence, there are no consumptive water use impacts.
15. Table II—1 presents the treatment model flow and effluent quality
data used to develop the proposed BPT effluent limitations for
cold rolling, and Table I1-2 presents these proposed limitations.
Table I1-3 presents the treatment model flow and effluent quality
data used to develop the proposed BAT and BCT effluent
limitations and the proposed NSPS, PSES, and PSNS for cold
rolling; Table I1-4 presents these proposed limitations and
standards.
5

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TABLE II-1
BPT TREATMENT MODEL FLOWS AND EFFLUENT QUALITY
COLD FORMING SUBCATEGORY - COLD ROLLING
	Monthly Average Concentrations	
Direct
Pollutant	Recirculation	Combinati on	Application
Flow, gal/ton	25	400	1000
TSS	25	25	25
O&G m	10	10	10
Iron, Dissolved	1.0	1.0	1.0
pH, Units	6.0 to 9.0	6.0 to 9.0	6.0 to 9.0
(1)	Daily maximum concentrations are three times the monthly average con-
centrations. All concentrations are expressed as mg/1 unless other-
wise noted.
(2)	Dissolved iron is limited only when cold rolling wastewaters are
treated with pickling wastewaters.
6

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TABLE II-2
PROPOSED BPT EFFLUENT LIMITATIONS
COLD FORMING SUBCATEGORY - COLD ROLLING
Pollutant
TSS
O&G
Iron, Dissolved
pH, Units
(2)
Effluent Limitations (kg/kkg of product)
DTrecT
Recirculation
0.00261
0.00104
0.000104
6.0 to 9.0
Combination
0.0417
0.0167
0.00167
6.0 to 9.0
(1)
ect
Application
0.104
0.0417
0.00417
6.0 to 9.0
(1)	Daily maximum effluent limitations are three times the monthly average
limitations.
(2)	Dissolved iron is limited only when cold rolling wastewaters are
treated with pickling wastewaters.
7

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TABLE II-3
TREATMENT MODEL FLOWS AND EFFLUENT QUALITY
COLD FORMING SUBCATEGORY - COLD ROLLING
Monthly Average Concentrations

Pollutant
BAT
BCT
NSPS
PSES
PSNS
A.
Recirculation






Flow, gal/ton
25
25
10
25
10

TSS
-
25
15
-
-

O&G
-
10
10*
-
-
119
Chromium, Total
0.1
-
0.1
0.1
0.1
122
Lead
0.1
-
0.1
0. 1
0.1
128
Zinc, Total
0.1
-
0.1
0.1
0.1
Oil
1,1,1-Trichloroethane
0.1
-
0.1
0.1
0.1
057
2-Nitrophenol
0.025
-
0.025
0.025
0.025
078
Anthracene
0. 01
-
0.01
0.01
0.01
085
Tetrachloroethylene
0.05
-
0.05
0.05
0.05

pH, Units
-
6-9
6-9
-
-
B.
Combinati on






Flow, gal/ton
250
250
(2)
250
(2)

TSS
-
15

-


O&G
-
10*

-

119
Chromium, Total
0. 1
-

0.1

122
Lead
0.1
-

0.1

128
Zinc, Total
0.1
-

0.1

Oil
1,1,1-Trichloroethane
0.1
-

0.1

057
2-Nitrophenol
0.025
-

0.025

078
Ant hr ace ne
0.01
-

0.01

085
Tet r ac h 1 or oe t hy 1 ene
0.05
-

0.05


pH, Units
-
6-9

-

8

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TABLE II-3
TREATMENT MODEL FLOWS AND EFFLUENI QUALITY
COLD FORMING SUBCATEGORY - COLD ROLLING
PAGE 2
Pollutant
Monthly Average Concentrations
(1)
BAT
BCT
NSPS
PSES
PSNS
C. Direct Application
Flow, gal/ton
TSS
O&G
119 Chromium, Total
122 Lead
128 Zinc, Total
pH, Units
400
0.1
0.1
0.1
400
15
10*
6-9
(2)
400
0.1
0.1
0.1
(2)
(1) Daily maximum concentrations are based upon the monthly average concentrations
multiplied by the following factors:
Pollutants	Factor
TSS (BCT for recirculation)	3.00
TSS (all others)	2.67
O&G (BCT for recirculation)	3.00
0&G (All other)	*
Chromium, Lead, Zinc	3.00
1,1,1-Trichloroethane, 2-Nitrophenol,
Anthracene, Tetrachloroethylene	3.00
Also, all concentrations are expressed as mg/1 unless otherwise noted.
(2) No NSPS or PSNS are being proposed for combination and direct application
mills. All new source plants shall incorporate recirculation systems.
* Daily maximum concentrations only, as shown.
9

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A.
119
122
128
Oil
057
078
085
B.
119
122
128
Oil
057
078
085
TABLE II-4
PROPOSED EFFLUENT LIMITATIONS AND STANDARDS
COLD FORMING SUBCATEGORY - COLD ROLLING
Effluent Limitations and Standards (kg/kkg of Product)^^
Pollutant
BAT
BCT
NSPS
PSES
PSNS
Recirculation





TSS
—
261
62.6
-
-
O&G
-
104
41.7
-
-
Chromium, Total
1.04
-
0.417
1.04
0.417
Lead
1.04
-
0.417
1.04
0.417
Zinc, Total
1.04
-
0.417
1.04
0.417
1,1, 1-Trichloroethane
1.04
-
0.417
1.04
0.417
2-Nitrophenol
0.261
-
0.104
0.261
0.104
Anthracene
0.104
-
0.0417
0.104
0.0417
Tetrachloroethylene
0.521
-
0.209
0.521
0.209
pH, Units
—
6-9
6-9
-
—
Combination





TSS
—
1560
(2)
-
(2)
O&G
-
1040*

-

Chromium, Total
10.4
-

10.4

Lead
10.4
-

10.4

Zinc, Total
10.4
-

10.4

1,1,1-Trichloroethane
10.4
-

10.4

2-Nitrophenol
2.61


2.61

Anthracene
1.04
-

1.04

Tetrachloroethylene
5.21
-

5.21

pH, Units
-
6-9

—

10

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TABLE II-4
PROPOSED EFFLUENT LIMITATIONS AND STANDARDS
COLD FORMING SUBCATEGORY - COLD ROLLING
PAGE 2
Pollutant
C. Direct Application
TSS
O&G
119 Chromium, Total
122 Lead
128 Zinc, Total
pH, Units
Effluent Limitations and Standards (kg/kkg of Product)
BAT
16.7
16.7
16.7
BCT
2502
1670*
6-9
NSPS
(2)
PSES
16.7
16.7
•16.7
PSNS
(2)
(1) The proposed limitations and standards have been multiplied by 10 to
obtain the values presented in this table. Also, daily maximum
limitations and standards are based upon the monthly average values
multiplied by the following factors:
Pollutant	Factor
TSS (BCT for recirculation)	3.00
TSS (all others)	2.67
O&G (BCT for recirculation)	3.00
O&G (All other)	*
Chromium, Lead, Zinc	3.00
1,1,1-Trichloroethane, 2-Nitrophenol,
Anthracene, Tetrachloroethylene	3.00
(2) No NSPS or PSNS are being proposed for combination and direct
application mills. All new source plants shall incorporate
recirculation systems.
* Daily maximum limitation only, as shown.
11

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COLD FORMING SUBCATEGORY
COLD ROLLING
SECTION III
INTRODUCTION
General Discussion
Cold rolling is the process in which flat steel products are reduced
in thickness by rolling operations without preheating the product.
The rolling operation works the steel to provide added strength,
better surface quality and other mechanical properties. Oil solutions
are applied directly to the rollng stands to dissipate the increase in
temperature of both the work rolls and the product as it is
mechanically processed, and to provide lubrication. Various oils and
oil application systems are used depending on the product being rolled
and the properties in the steel desired. There are primarily three
types of oil application systems used today: (1) Recirculation; (2)
Combination; and (3) Direct Application. The cold rolling subdivision
has been segmented to recognize differences in these systems.
Due mainly to the use of the oil solutions, various pollutants are
discharged in high levels from the cold rolling mills. The two most
common are oil and grease and total suspended solids. However, due to
the nature of some of the oils used in the process, toxic metals and
toxic organic pollutants are also present in cold rolling wastewaters.
The configuration of the mills and the pollutants generated is
discussed in greater detail in later sections.
The Agency promulgated BPT limitations for cold rolling (CR)
operations in 1976, and covered four pollutants: oil and grease, total
suspended solids, dissolved iron, and pH. For this study, the Agency
conducted additional sampling and gathered detailed information from
the steel industry to obtain an expanded data base.
Data Collection Activities
Valuable process information and wastewater quality data were obtained
through sampling visits at 52 cold rolling operations at 17 plant
locations. The Agency conducted eleven sampling visits during the
original guidelines study and visited seven plants during the recent
toxic pollutant survey (one plant was resampled). The plants which
were sampled during the course of this study are listed in Table
II1-1.
The Agency's primary source of new information is industry responses
to the DCPs that were sent to approximately 85% of the active cold
rolling operations in the United States. These questionnaires
requested information on process and discharge flow rates, treatment
systems in use, mill capacities and modes of operation. DCP responses
were received for two hundred and twenty nine cold rolling mills. The
13

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data for these mills have been tabulated and are summarized in Tables
II1-2 to II1-5. Table III-2 lists all the plants that have cold
rolling mills and describes the number and type of the cold rolling
mills at each site. Tables 111—3 to 111—5 provide more detailed
information for individual mills. These tables have been separated by
the type of oil application system because the mills are segmented on
this basis and also so that mills of similar configuration can be more
easily compared.
Detailed Data Collection Portfolios (D-DCPs) were sent to selected
mills to gather long-term effluent quality data, cost data for
treatment systems installed, and information on mill operations. The
Agency sent D-DCPs to thirty-one CR mills. The D-DCP responses
provided data to verify Agency cost estimates, establish retrofit
costs, and to provide additional effluent quality data. Tables III-6
through III—8 summarize the data base for cold rolling operations.
Cold Rollinq Limitations
In the originally promulgated regulation, the limitations for cold
rolling operations were established separately by mill type (oil
application system), and pertained to each mill as a whole regardless
of the number of rolling stands present at the mill. The Agency
reexamined this segmentation to determine if this was the most
appropriate way to develop cold rolling limitations.
First examined was whether three sets of limitations for the different
oil application systems was appropriate. The Agency analyzed
available data for all mills and contacted the mill operators and
designers. From this study, the Agency determined that not all cold
rolling mills can make the modification from either direct application
or combination systems to recirculation systems. Some direct
application and combination type mills can recirculate all oil
solutions, but some mills have oil sumps located beneath the mills.
To convert these mills to recirculation systems would require major
capital investments and production disruptions.. For this reason, the
Agency is again proposing BPT, BCT, BAT, and PSES limitations and
standards by mill type. However, the proposed NSPS are based upon
recirculation oil application systems since recirculation systems can
be incorporated into all new mills.
Another issue investigated during this study was the possibility of
proposing limitations on a "per stand" basis as opposed to a "per
mill" basis, to account for possible flow variations that can occur
between cold rolling mills with unequal numbers of stands. This would
involve developing allowable loads for one stand so if a mill had five
stands the allowable load for that mill would be five times the basic
allowance.
The Agency tabulated all available data and compared both methods
(limitations on a per mill basis vs. limitations on a per stand
basis). In neither case, were the limitations significantly different
than those proposed herein using the segmentation of cold rolling
operations by oil application system. Therefore, the Agency is
14

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proposing limitations on the same basis as was done in the original
regulation.
Description of Cold Rollinq Operations
Cold rolling is that operation where unheated metal is passed through
a pair of rolls to reduce its thickness, to produce a smooth dense
surface, and to develop controlled mechanical properties of the metal.
There are various types of cold rolling processes. Cold reduction is
a special form of cold rolling in which the thickness of the product
is reduced by relatively large amounts in each pass through the rolls.
In the production of most cold rolled materials, the cold reduction
process is used to reduce the thickness of the hot rolled breakdown
between 25% and 90%. After cleaning and annealing, a considerable
amount of product is tempered. In tempering, the thickness of the
material is reduced only a few percent to impart desired mechanical
properties and surface characteristics.
Cold rolled strip, cold rolled sheet, and cold rolled flat bar are the
principal cold reduced flat products. Carbon, alloy or stainless
steels are used depending on the end use of the produces. Most
products rolled are carbon steel in sheet form and are used as base
material for such coated products as long terne sheets, galvanized
sheets, aluminum coated sheets, tin- plate, or tin-free steel. Hot
rolled coils called "breakdowns" are the base material used in the
cold rolling operation. Prior to rolling, however, they must be
descaled and pickled, usually in a continuous pickling operation.
There are several types of cold reduction mills which vary in design
from single stand reversing mills to continuous mills with up to six
stands in tandem (in series). In the single stand reversing mill, the
product is rolled back and forth between the work rolls until the
desired thickness and mechanical and surface characteristics are
achieved. In the single stand nonreversing mill the material makes a
single pass through the rolls and is recoiled. If additional rolling
is required the coil is returned to the head of the mill and reworked.
The single stand nonreversing mill is generally used for tempering
operations.
Most cold reduced flat steel is rolled on continuous three, four, or
five stand tandem mills. In these mills the material continually
passes from roll to roll until the desired thickness is attained. The
continuous rolling mills represent modern technology and is the type
of equipment installed in new mills.
A typical modern cold rolling shop contains a continuous pickling
operation (sulfuric or hydrochloric acid) to remove scale and rust
from the hot rolled breakdown coil. As it leaves the pickler the
strip is oiled to prevent rusting and to act as a lubricant in the
cold rolling mill. The coil is then fed into a continuous cold
rolling reducing mill that can contain up to six rolling stands in
tandem. Each stand contributes to the reduction in thickness of the
material; the first contributes the greatest reduction while the last
stand acts as a straightening, finishing, and gauging roll. Unlike
15

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hot forming, no scale is formed during this operation. It should be
pointed out that the proposed limitations apply only to the
wastewaters generated in cold rolling operations, even though other
processes may be integrated into a complete "cold mill" complex. The
other process wastewaters are being regulated separately.
During cold rolling, the steel becomes quite hard and unsuitable for
most uses. As a result, the strip must usually undergo annealing to
return its ductility and to effect other changes in mechanical
properties. This is done in either a batch or continuous annealing
operation.
In batch or box annealing, a large stationary mass of steel is
subjected to a long heat treating cycle and allowed to cool slowly.
In continuous annealing, a single strip of cold reduced product passes
through a furnace in a relatively short period of time. The heat
treating and cooling cycle in the furnace is determined by the
temperature gradient within the furnace as well as the dimensions and
rate of travel of the steel. To prevent oxidation and the formation
of scale, inert atmospheres are maintained in these furnaces at all
times. Prior to annealing the material must be cleaned of all dirt
and oil from the pickling operation to prevent surface blemishes. In
the case of the continuous annealing furnaces the material is uncoiled
and passes through a continuous cleaning operation prior to entering
the furnace. Upon leaving the furnace the material is oiled,
recoiled, and is ready to be tempered.
The temper mill is a single stand cold rolling mill designed to
produce a slight reduction in thickness of the steel. This reduction
develops the proper stiffness or temper by cold working the steel at a
controlled rate. The end use of the material dictates the degree of
tempering to be performed.
An oil-water emulsion lubricant is sprayed on the material before it
enters the rolls of a cold rolling mill and the material is coated
with oil prior to recoiling. This oil prevents rust while the
material is in transit or in storage and must be removed before the
material can be further processed or formed.
As mentioned earlier, there are three types of oil application systems
used at cold rolling mills. The diagrams of these systems are shown
in Figures III—1 through III—3. Additional details on the cold
rolling operation and the three application systems are presented
later in this report.
16

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TABLE III-l
BASIC DESCRIPTION OF THE COLD ROLLING
OPERATIONS SAMPLED FOR THIS STUDY
c 1- <1>
Sampling
Plant
Type of
Type of Oil
Code
Code
Steel
Application System
D
248B
Specialty
Recirculation
I
432K
Specialty
Recirculation
P
Unk
Specialty
Recirculation
X-2
060B-03
Carbon
Recirculation
BB-2
060-03
Carbon
Recirculation
EE-2
112D-01
Carbon
Recirculation
FF-2
384A( 02 & 03)
Carbon
Recirculation
XX-2
6841-01
Carbon
Recirculation
101 A & B
020B & 020C
Specialty
Recirculation
102
384AC02 & 03)
Carbon
Recirculation
104
248B-03
Specialty
Recirculation
105
584F(02,03 & 05)
Carbon
Recirculation
107
176-08
Specialty
Recirculation
VV-2
584F-04
Carbon
Direct Application
105
584F-04
Carbon
Direct Application
106
112B (01 & 03-06)
Carbon
Direct Application
107
176-02
Specialty
Direct Application
DD-2
584E-01
Carbon
Combination
YY-2
432D-01
Carbon
Combination
103
856F-01
Carbon
Combination
(1) The sampling code is an alphabetic
or numeric code
assigned at the time of
sampling.



(2) The plant code is a reference code designated for
each mill responding to the
basic questionnaires. For example,
060B-03 represents the third cold rolling
mill at plant
06 0B.


17

-------
TABU III-2
DESCRIPTION Of U. S. COLD ROLLIHC HILLS
Plant
Code
MtaUier
of Mill*
4
ecir-
ulatioa
Type of Rolling Mill
Type of Steel
Rolled
Direct
Application
Coabi-
nation
Type of Product Rolled
(1)
24
1
1
1
Dry Unknown Carbon Specialty
12
6
2
11
6
2
1
24
5
4
C £
2 1
6
24

-------
TABLE III-2
DESCRIPTION OF U. S. COLO ROLLING MILLS
PACE 2		
Type of tolling Mill
Plant	Nuaber	Reci r-	Direct	Coabi-
Code	of Mills c illation Application oat ion Dry Unknown
21
2
3
TOTAL
253
Z of Total IOOZ
1
143
56.91
67
26.61
.51
18 6
6.71 2.3Z
(1) Product rolled ia identified aa foilova:
A: Strip	El	Strip, Sheet, Plate
B: Sheet	F:	Wire
C: Strip, Sheet	G:	Sheet, Tin Plate
D: Sheet, Plate	H:	Bar
1:	Other
Type of Steel
Rolled
Type of Product Eolled^^
Carbon Specialty A » C D £ £ G U 1
3
1
2
3
2
14
2
7
3
3
4
3
21
4
3
3
1
1
2
2
4
162
64Z
91
36Z
1
77 29 9 3 2 6
OZ 11.5Z
3.6Z
1.0Z
0.8X
2.4Z
24 2
0.4Z
9.5Z
0.8Z

-------
Nj
o
Plant
Code
020B-02
0200-03
020B-05
020C-03
020C-04
020C-05
020C-06
020C-07
020C-08
020C-09
020C-02
020C-01
0201.-01
060-01
060-02
060-01
060B-03
0600-02
060D-05
060D-06
0600-08
0600-04
0600-07
060E
0601-01
0601-02
112A-07
1120-01
176-05
176-06
176-07
176-08
176-09
176-10
176-11
248B-01
Age
(I)
.(2)
Nuaber
1954
1957
195!
1951
1951
1939
1941
1946
1950
1967
1941
1935
1966
1936
1941
1970
1967
1929(1961)
1947(1966)
1960
1960
1942(1960)
I960
1972
1942
1966
1970
1965
1946
1953
1962
1963
1968
1971
1976
NA
Capacity, tpd of Standa
969
60
306
75
81
45
39
576
129
843
96
93
186
2,658
1,974
4,803
2,679
402
153
282
984
204
471
0
10.8
6
816
4,107
63
102
126
132
39
4.5
60
NA
TABU III-3
GENERAL SUMMARY TABU
COLD ROLLING - RECIRCULATION
...	. ,	Discharge Mode With
Applied Process	Typical CPT for Each
Flow Vlaite Plow Central	Waatea
GPT
CPT
Treatment
Control A Treatment Technology
Direct
POTW
Ba tiled
Unk
(5)
Yea
Ultra filtration
0
(5)
0
Uak
Unk
Ho
n
0
0
Unk
Unk
(5)
Yea
Ultra filtration
0
(5)
0
Unk
(5)
Tea
Ultra filtration
0
(5)
0
Unk
(5)
Yea
Ultra filtration
0
(5)
.3
Yea
EB.FLP, CL,?,CY
0>.S
0
0
3,375
Unk
Yea
EB.FLP ,CL,T,CY
Unk
0
0
776
Unk
Yea
EB.FLP, CL,T,CY
Unk
0
0
2,970
Unk
Yea
EB.FLP ,CL,T,CY
Unk
0
0
Unk
Unk
Yea
Scr,EB,SS,CY
Unk
0
0

-------
TA1LE III-3
GENERAL SUWiAtY TABU
COLD BOLL INC - RECIRCULATION
flCt 2




Applied
Pre.."'


Di.charge Mode With






Typical
CPT
for Eacl
Plant
-rDP(99.8)
0
0
1.9
384A-02
1958
3,354
4
3,86?
43
Ye.
EB,CL,SS,RUP(98.9)
43
0
0
384A-03
1970
5,757
5
3,761
10
Yea
EB,FL,FLP,CL,SS,RUP(99.7)
10
Dnk
0
3960-01
1938
69
1
Unk
Dnk
Yea
SSP.SS
Unk
Unk
0
396D-02
1940
246
4
Unk
Unk
Yea
SSP.SS
Unk
Unk
0
396D-03
1948
87
5
Unk
Unk
Ye.
SSP.SS
Unk
Uok
0
396D-04
1954
3
1
Unk
Uok
Yea
SSP.SS
Unk
Unk
0
396E
1954
240
4
Unk
Unk
Yea
No Treatment
Unk
0
0
432A-01
1947(1971)
1,911
5
Unk
Unk
Yea
CF,E,T,NC,SCB,CL,SS,VF,H,HL
Unk
0
0
432A-02
1963
906
3
Unk
Unk
Yea
GP,E,T,HC,HLaSCft,CL,8S,VF,H
Unk
0
0
432B-01
1937(1949)
1,827
4
Unk
Unk
Yea
E*,vr,ss
0
Unk
0
432C-01
1957
3,132
4
Unk
Unk
Yea
VP,FLL,FLP,HN,CL,PSP,88,0B,CT
Unk
0
0
44 8A-03
1967
780
I
Unk
Unk
Yea
CL
0
Unk
0
528-01
1955
153
1
Unk
0.03
Yea
El,CF,CWT,kUF
0
Unk
0.03
528-02
1955
243
1
Uok
0.02
Yea
E1,CF,RUP,BD,CNT
0
Unk
0.02
528-03
1947
51
1
Unk
0.09
Yea
EB,CF,KUP,BF,CNt
0
Unk
0.09
5288-01
1954
2,862
4
Unk
30.2
Yea
NC,SS,SL,RUP,BD,CHT (2>
30.2
0
0

-------
TABLE III-3
GENERAL SUMMARY TABLE
COLO ROLLING - RECIRCULATION
PACE 3		
.(3)
NJ
NJ
Proceaa
(4)
Discharge Mode With
Plant

(2) ","ber
Capacity, tpd of Standa
Flow
Uaatc Flow
Central



Waatee
Code
OPT
GPT
Treatment
Control & Treatment Technology
Direct
POTV
Hauled
58QC-01
1957
6 3
7,365
12.5
Mo
SS,RUP<99.9),BD(0.03)
0
0
12.5
580C-02
1975
6 3
1,733
12.5
No
SS,RUP(99.9),BD(0.08)
0
0
12.5
580C-03
1952
54 1
3,683
0.12
No
RUP(99.9),BD(0.003)
0.06
0.06
0
580C-04
1959
27 1
6,776
0
No
RUP(IOO)
0
0
0
580C-05
1964
67.5 1
1,067
0
No
RUP(100)
0
0
0
584E-03
1961(1972)
870 2
Unk
Unk
Ye*
BO,CQ ,CR,DW,EB ,F,P,FU.,FLP ,1Y,
NL,NW,CL,SL,SS
Uak
0
0
584F-02
1947(1966)
1,494 5
Unk
(6)
Yea
SS,SL,CNT
(6)
0
0
584F-03
1956(1966)
1,965 5
Unk
(6)
Yea
SS,SL,CNT
(6)
0
0
0584 F-05
1975
1,164 5
Unk
(6)
Yea
SS,SL,CNT
(6)
0
0
0584 F-07
1966
990 2
Unk
Unk
Yea
SS.SL.CNT
Unk
0
0
648-01
1969
45 1
Unk
Unk
No
PSP
0
Unk
0
648-02
1966
4.5 3
Unk
Uak
No
PSP
0
Gnk
0
648-03
1975
18 3
Unk
Unk
No
PSP
0
Unk
0
684B-01
1957(1961)
1,569 4
3,578
138
Ye*
SL,SS,CMT,RUP(96) ,BD(4)
138
0
0
684D-01
1939
129 1
Unk
(7)
Yea
EB,SS,SL,BD,CNT,RUP
(7)
0
0
684D-02
1939
63 1
Unk
(7)
Yea
EB,SS,SL,BD,CNT,RUP
(7)
0
0
6840-03
1939
24 1
Unk
(7)
Yea
EB,SS,CLIBDICNT,RUP
(7)
0
0
684D-04
1948
90 1
Unk
(7)
Yea
EB,SS,SL,BD,CNT,RUP
(7)
0
0
684D-05
1946
369 1
Unk
(7)
Yea
EB,SS,SL,BD,CNT,RUP
(7)
0
0
6840-06
1946
177 I
Unk
(7)
Yea
EB,SS,SL,BD,CNT,RUP
(7)
0
0
684D-07
1946
159 1
Unk
(7)
Yea
EB,SS,SL,BD,CNT,ftUP
(7)
0
0
684F-02
1953
1,740 4
12,006
8.7
Yea
C0,FLL,FLP,GF,F,NL,NU,8L9CNTI
RUP(99.9)
8.7
0
0
684F-03
1969
3,597 5
Unk
4.3
Yea
CL,F,FLL,FLP,GF,F01,NL,NU,8L,
CKT.RUP
4.3
0
0
6841-01
1958
1,149 4
3,595
751
Yea
NU,PSP,SSP,SS,CNT,RUP(75.1)t
BD.SL
751
0
0
700-C01-06) Uak
Unk L(each)
Unk
Unk
HA
No treataent
Unk
0
0
700-10
Unk
Unk 1
Unk
Unk
NA
No treataent
Unk
0
0
700-11
1974
Unk 1
Unk
Unk
NA
No treatment
Unk
0
0
724A-01
1964
510 1
Unk
Unk
Yea
No treataent
Unk
0
0
724A-02
1966
1,851 5
Unk
Unk
Yea
No treataent
Unk
0
0
760-01
1950
261 1
1,655
16.6
Unk
FF,RUP(93)
16.6
0
0
760-02
1957
165 1
2,618
26.3
Unk
FF,RUP
0
0
26.3
760-03
1954
156 1
0
0
NA
No rolling aolutioaa used
0
NA
HA

-------
TABLE 111-3
GENERAL SUM4AEY TABLE
COLD ROLLING - RECIRCULATION
PACE 4		 _
.	Discharge Mod* With
Applied Process	Typical CPT for Each
Plant	. .	Muaber	Flow Watte Flow Central	Wattes
Code
V
Capacity, tpd of Stands
GPT
CPT
Treatment
Control i Treatment Technology
Direct
POTW
Hauled
760-04
1926(1952)
42 1
0
0
MA
Mo roiling aolutiona uaed
0
HA
NA
760-05
1927(1963)
1.8 1
0
0
HA
Mo [oiling aolutiona uaed
0
HA
HA
760-06
1927(1953)
20.4 1
0
0
HA
Mo rolling aolutiona uaed
0
MA
HA
760-07
1944(1965)
12.3 1
0
0
MA
No rolling aolutiona uaed
0
MA
HA
7921-01
1952
369 1
Unk
Oak
Ho
H
0
0
Unk
7921-02
1945
132 1
Unk
Unk
No
H
0
0
Unk
7928-03
1961
165 1
(ink
(Ink
Ho
a
0
0
Unk
792C-01
1955
204 1
593
Unk
Tea
SS,r,CNT
link
0
0
792C-02
1970
120 1
1,080
Unk
Yea
SS,P,CNT
Unk
0
0
792C-03
1963
51 1
734
Unk
Yea
SS,r,CNT
Unk
0
0
856E-01
1946
249 1
1,439
Unk
Mo
H
0
0
Unk
B56P
1909(1918)
822(coab.) i(each)
4,390
0.8
Yea
K,RUP(99.9)
0
0
0.8
(01-21)


(coab)






8608-02
1967
2,244 6
Unk
1,283
Yea
E8,SS,PLL,PLP,MWtCL
1,283
0
0
8601-04
1964
4,194 5
Unk
687
Yea
EB,SS,FLL,Pl?,NWffCL
687
0
0
8648-01
1947
1,419 5
3,552
5.1
Yea
FLL, F LP, HL,NA,CL, *0^,88, CUT,
RUP(99.9)
5.1
0
0
8648-02
1965
813 3
3,542
354
Yea
NL,NA,CL,H01,SS,CMT,8UP(90)
354
0
0
8648-03
1974
1,986 5
3,625
7.3
Yea
ML,NA,CL,Nof,SS,CHT,RUP(99.9)
T,SS,FLP,FLL,CHT,RUP(62)
7.3
0
0
948C-03
1939(1966)
894 3
3,624
1369
Yea
1,369
0
0
(1)	The age liated represents the first year of production. Nusbsr in
parenthesea deaignate yeara of rebuilda or Major aodificationa.
(2)	the daily capacity liated waa deterained by Multiplying the 1976
average tonnage per turn by a factor of three.
O) The applied flow represents the total process water flow applied
to the cold roiling aill.
(4)	The proceaa water flow represents the water leaving the cold
rolling aill after any internal recycle systeas.
(5)	Flow value Measured during sampling visit for these 10 aills equals 11*0 gpt.
(6)	Flow value measured during aaapling visit for these 3 aills equala 1.0 gpt.
(7)	Coapany reports total flow for all seven aills. The flow rate ia
equivalent to 5.7 gpt.
*: Coofideutial
t Flow values in bracketa were received at plant viaits or in the response to D-DCF's.
NOTE: For a definition of the C4TT Codes, see Table VI1-1.

-------
TABLE II1-4
GENERAL SUKHARY TABLE
COLO KOLLINC - COMBINATION
Nj
45*
Plant
Code
Number
of
Age
(I)
(2)
Capacity ,tpd
Tot
of
Number
audi
Reci
S
culated
aadt
Appliei
Flow
O)
GPT
(4)
Proceia
Watte Flow Central
Treatment
CPT
Control fc
Treatment Technology
Discharge Node with
Typical GPT for Each
Waatea
Direct POTW Hauled
04320-01
1968
3,486 5
3 Unk
Qlj
Ye.
DU,F,P,FLL,T
bid
0
0
0448A-01
1952(65)
1,488 5
4 Unk
Unk
Yea
CL
Unk
Unk
0
0448A-02
1966
624 3
2 Unk
Unk
Ye.
CL
Unk
Unk
0
0584 A-02
1965
4.437 5
4 Unk
130
Ye.
M,A,E,EB,FU.,FLr,IIL,SCR,T,
130
0
0






SS.OT



0584 E-01
1961
2,004 5
4 Unk
[513
Ye.
BO,CU,CR,DW,EE,r,P,FLL,
0
0





FLP,Cr,IX,KL,HM,CL,SL,88



0584 E-04
1970
3,999 5
3 Unk
Unk
Ye.
»o,co,ce,dv,ei,r,p,fll,
FLP,CF,IX,NL,IM,CL,SL,8S
Unk
0
0
08560-01
1938(75)
1,092 5
4 Unk
Unk
Ye.
EI,PLP,FU>1,B5,CNT
Unk
0
0
08560-02
1940(55)
1,482 5
4 Unk
Unk
Ye.
EB,FLF,FU)1,SS,CNT
Unk
0
0
0856D-03
1971
4,620 5
3 Unk
Unk
Ye.
EB,FLP,FU)l,S8,Cirr
Unk
0
0
0856F-01
1951
3,132 4
3 552
[111
Ye.
CH,NW,FIX,T,CL,CNT,RUP(83)
[Hi
0
0
0856F-02
1953
1, 782 5
4 970
179
Ye.
CR, HU, FLL, T,CL,CNT, RUP( 82)
179
0
0
0860B-03
1948
3,105 4
2 14,2)5
325
Ye.
EB,FLL,FLP,NL,IN,CL,SL,
RUP(98),CNT(5)
325
0
0
0868A-01
1948
2,658 4
3 Unk
54
Ye.
F,FLP,FL01,NL,CL,SLvSS,Clrr
54
0
0
0868A-02
1963
1,674 6
5 Unk
481
Ye.
F,P,FLP,Fi01,CL,SL,SS,CMT
481
0
0
0868A-03
1964
570 2
1 Unk
25
Ye.
F, P, FLP,FL01 ,CL, SLVSS,CNT
25
0
0
0920001
1954
2,121 4
3 1,630
114
Ye.
EB,VF,SS,CKT,RUP(99)
114
0
0
0948C-01
1954
2, 730 2
4 1,477
870
Ye.
T,FLP,FLL,CNT,RUP(50)
870
0
0
0948C-02
1965
3,438 5
4 503
293
Ye.
F,S,FLA,FL01,CNT,RUP(42)
293
0
0
0948C-04
1961
2,082 5
4 8,127
1,245
Ye.
T,SS,RUP(85)
1,245
0
0
(1)	The age listed represents the first year of production. Nusibers in parentheses
designate years of rebuilds or major Modification*.
(2)	The daily capacity liated was determined by multiplying the 1976 average
tonnage per turn by a factor of three.
(3)	The applied flow represents the total process water flow applied to the
cold rolling mill.
(A) The process water waste flow represents the water leaving the cold roiling mill
after any internal recycle systems.
: Flow values in brackets were received at plant visits or in the responses to D-DCP's.
NOTE: For a definition of the C4TT Code®, aee Table VII-1.

-------
Plant
A,e
(2)
Capacity, tpd
Nunber
Code
of Stand*
020B-04
1957
30
1
060-04
1940
246
1
060-05
1938
1,308
1
060-06
1942
948
1
060-07
1956
2,529
1
060-08
1966
2,292
I
060B-01
1963
1,146
1
060D-01
1926(1929)
(1948)
HA
1
0600-03
1929(1958)
408
I
112A-01
1947(1951)
1,524
5
112A-02
1951
2,811
4
112A-03
1936
1,230
5
112A-04
1936
1,230
5
112A-05
1957
1,968
5
112A-06
1963
861
2
112B-01
1936(1950)
2,856
4
112B-02
1936(1963)
2,310
4
112B-03
1936
1,680
I
112B-04
1936
1,392
I
112B-05
1936
1,968
1
112B-06
1936
1,944
1
176-01
1921(1928)
630
1
176-02
1929
63
1
176-03
1933
NA
1
176-04
1934
3.0
1
256M-
1928
1.5(each)
1
(01-24)



284A-02
1957
186
1
TABLE III-5
GENERAL SUMMARY TAiLE
COLD ROLLING - DIRECT APPLICATION
...	...	Diacharg* Mode With
Applied	Procen	Typical CPT for Each
Flow	Uaate Plow	Central	UaaCea
CPT	CPT	Treafent	Control A Treatment Technology Direct POTW H*uled
Unk	Unk	No	B
Unk	Unk	Ye*	VF,FLP,NL,T,A,SS
Unk	Dnk	Yea	EB,FG,FLP,NL,CL,SS,A
Unk	Unk	Yea	EB.FG.FLP.Iil.CL.SS^
Unk	Unk	Yee	EB,FCIFLP1M.,CL,SS,A
Unk	Unk	Ye*	EB,FG,FLP,NL,CL,SS,A
Unk	Unk	Ye*	EB,GF,CL,SS
Unk	Unk	Ye*	NL,SL,A
Unk
0
Unk
Unk
0
0
Unk
0
0
Unk
0
0
Unk
0
0
Unk
0
0
Unk
0
0
Unk
0
0
Unk
Unk
Ye*
NL,SL,A
Unk
0
0
481
481
Ye*
SS,SCB,NL,A,SL,CY,FLP,GLA
481
0
0
246
246
Ye*
SS,SCR,NL,A,SL,CY,PLP,CLA
246
0
0
Unk
Unk
Ye*
SS,SCB,NL,A,SL,CY,PLP,CLA
Unk
0
0
Unk
Unk
Ye*
SS,SCg,NL,A,SL,CY,FLP,CLA
Unk
0
0
3,081
3,081
Ye*
SS,SCR,NL,A,SL,CY,FLP,CLA
3,081
0
0
607
607
Ye*
SS,SC8.NL,A,SL.CY.PLP.CLA
607
0
0
(S)
(5)
Ye*
F,S,NL,CL,SS,A
(5)
0
0
(5)
(5)
Ye*
F,S,NL,CL,SStA
(5)
0
0
(5)
(5)
Ye*
F,S,NL,CL,SS,A
(5)
0
0
(5)
(5)
Ye*
F,S,NL,CL,SS,A
(5)
0
0
(5)
(5)
Ye*
F,S,NL,CL,SS,A
(5)
0
0
(5)
(5)
Ye*
F,S,NL,CL,SS,A
(5)
0
0
Unk
Unk
Ye*
EB,FLP,CL,T,CY
Unk
0
0
[231
[231
Ye*
EB,FLP,CL,T,CY
chl
0
0
Unk
Unk
Ye*
EB,FLP,CL,T,CY
Unk
0
0
Unk
Unk
Ye*
EB,FLP,CL,T,CY
Unk
0
0
Unk
Unk
Yea
SS
Unk
0
0
0.5
0.5
Ye*
No treataenc(no oil aolution*
0.5
0
0



uted in procet*)




-------
TABLE III-5
GENERAL SUtMARY TABLE
COLD ROLLING - DIRECT APPLICATION HILLS
PAGE 2
to
ON
Plant
Nuaber
Applied
Flow
(3)
Procea*^^
Haste Flow
Central
Discharge Node With
Typical GPT for Each
tfaate*
Cade
, llj
Age
• ¦
Capacity, tpd
of Stands
GPT
CPT
Treatment
Control I Treatment Technology Direct
P0TW Hauled
320-01
1936(1961)
2,310
3
Unk
Unk
Unk
H
Unk
0
Unk
384A-01
1933(1948)
1,356
5
262
262
Yea
SL.SS
262
0
0
584A-01
1948
1,491
3
603
603
No
SS.OT
603
0
0
584C-01
1947
2,103
4
1,426
1,426
Yea
SS,Sl,CLB,FDS,CHT
1,426
0
0
584E-02
1961
2,256
1
Unk
Unk
Yea
B0,C0,CR,DM,EB,FU.,rLP,CF,DL,
Unk
0
0







NU,SL.SS



584F-04
1959
1,842
4
[424]
Erf
Yea
SS,SL,CKT,EB,CF,HL
m
0
0
584F-06
1972
1,107
2
Unk
Unk
Yea
SS,SL,CNT,EB,CP,NL
Unk
0
0
684C-01
1937
126
4
Unk
Unk
Yea
FSP,SS,0T,CNT,T
Unk
0
0
684C-02
1964
1,017
2
142
142
Yea
PSP,SS,OT,CNT,T
142
0
0
6841-02
1958
951
1
23
23
Yea
NU, PSP, SSP, SS, SL,0T,CHT
23
0
0
856F-03
1962
804
2
287
287
Yea
CR,NU,NL,FLL,T,CL,CIIT
287
0
0
8601-01
1963
855
2
168
168
Yea
EB,SS,FLL,FLP,NH,CL
168
0
0
920A-01
1930(1939)
1,953
4
273
273
Yea
C0,FLL,NL,CL,CNT
273
0
0
920G-01
1937(1964)
318
3
1,604
1,604
Yea
EB,CF,CL,SS,CNT
1,604
0
0
920G-02
1957
2,031
5
1,477
1,477
Yea
EB,CF,CL,SS,CNT
1,477
0
0
9A6A-01
1935
1,380
3
939
939
Yea
EB,VF,CF,SS,FLP,FLL,FL
939
0
0
948A-02
1937
1,500
4
864
864
Yes
EB,VF,GF,SS,FLP,FLL,FL
864
0
0
(1)	The age listed represents the first year of production. Nuabers in
parentheses designate years of rebuilda or aajor aodificatioos.
(2)	The daily capacity listed was detersiined by Multiplying the 1976 average
tonnage per turn by a factor of three.
(3)	The applied flow represents the total proceaa water flow applied to
the cold rolling sill.
(A) The process flow represent* the total process water flow leaving
the process and entering the treatment systea, if any.
(S) PUnt U2B reported a total flow for the six sails: 01-06.
The applied, process and discharge flows for these Mills waa
calculated by using a combined tonnage and equals 238 gal/ton.
: Flow values in brackets were received during plant visit* or in the response to D-DCP's.
NOTEt For a definition of C4TT Codes, see Table VIl-1.

-------
TABLE III-6
COLD ROLLING - RECIRCULATION
DATA BASE
No. of
Operationa
X of Total	Daily Capacity *	X of Total
No. of. Operations of Operations (Tons) Daily Capacity
Operations Sampled for
Original Guidelines Study
Operations Sampled For
Toxic Pollutant Study
Total No. of Operations
Sampled
Operations Solicited via
Detailed DCP
Operations Sampled and/or
Solicitated via Detailed DCP
Operations Responding to
DCP's
Estimated Total Number
of Recirculation Operations
19
25
20 incl.
13 above
32
143
168
3.6
11.3
14.9
11.9 incl.
7.7	above
19.0
^85.0
100.0
12,335
16,657
28,992
26,868 incl.
12,550 above
43,310
81,086
95,395
12.9
17.5
30.4
28.2 incl.
13.2 above
45.4
vT85.0
100.0
* Capacities for 1976 were used to determine the appropriate daily capacities.

-------
TABLE III-7
COLD ROLLING - COMBINATION
DATA BASE
No. of
Operations
% of Total	Daily Capacity *	X of Total
No. of Operations of Operations (Tons) Daily Capacity
Operations Sampled for
Original Guidelines Study
Operations Sampled For
Toxic Pollutant Study
Total No. of Operations
Sampled
Operations Solicited via
Detailed DCP
Operations Sampled and/or
Solicited via Detailed DCP
Operations Responding to
Basic DCP's
Estimated Total Number
of Combination Operations
19
22
9.1
4.5
13.6
13.6
^85.0
100.0
6,065
3,132
9,197
0
9,197
46,514
54,722
11.0
5.7
16.8
16.8
vT85.0
100.0
^Capacities for 1976 were used to determine the appropriate daily capacities.

-------
TABLE II1-8
COLD ROLLING - DIRECT APPLICATION
DATA BASE
Operations Sampled for
Original Guidelines Study
Operations Sampled For
Toxic Pollutant Study
Total No. of Operations
Sampled
Operations Solicited via
Detailed DCP
Operations Sampled and/or
Solicited via Detailed DCP
Operations responding to
DCP's
Estimated Total Number
No. of
Operations
0*
% of Total	Daily Capacity **	% of Total
No. of Operations of Operations (Tons) Daily Capacity
11 incl.
1 above
17
67
79
8.9
8.9
13.9 incl.
1.3 above
21.5
^85.0
100.0
of Direct Application Operations
0
11,220
11,220
16,023 incl.
1,380 above
25,863
55,000
64,700
0
17.3
17.3
24.7 incl,
2.1 above
40.0
S85.0
100.0
* One direct application operation was sampled for the original study. However, this mill was
resampled for this study and only the newer data was used for the updated data base.
~~Capacities for 1976 were used to determine the appropriate daily capacities.

-------
*2
*3
*4
*5
STAND




UNCOILER
SPRAYS
SPRAYS
SPRAYS
SPRAYS
SPRAYS
r
COIL ER
ROLLING
OIL
EMULSION
RECYCLE
TANK
ROLLING
OIL
EMULSION
RECYCLE
TANK
*3
PUMP LEAKAGE SPENT
ROLLING OIL EMULSION
MISC. OILY WASTEWASTE
FROM OIL BASEMENT
y X
j v.
"7"; / / / / 7 /// / /'V7/V7~7~7 77777 // / 7
TO TREATMENT-*
MISC. OILY WASTEWATER
ROLLING
OIL
EMULSION
RECYCLE
TANK
ROLLING
OIL
EMULSION
RECYCLE
TANK
•4
ROLLING
OIL
EMULSION
RECYCLE
TANK
MISC. OILY WASTEWATER
FROM OIL STORAGE AND
HANDLING PLUS MAINTENANCE
SHOP-ROLL FACING ETC.
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLING MILL
RECIRCULATION TYPE
PROCESS FLOW DIAGRAM
TEVt 2/19/76
MW.a/ll/74 REV. 2/26/76
FIGURE m-l

-------
*1
STAND
STAND
3
STAND
*4
STAND
STAND
UNCOILER	\J
ROLLING
OIL
EMULSION
RECYCLE
TANK
*1
Sprays
Sprays
ROLLING
OIL
EMULSION
RECYCLE
TANK
#2
Sprays


ROLLING
OIL
EMULSION
RECYCLE
TANK
#3



/
Sprays
F
ROLLING
OIL
EMULSION
RECYCLE
TANK
#4
COILER
Fresh Oil
Solutions
LI
To Treatment
Pump leakage,spent
rolling oil emulsion, misc
oily woste water from
oil basement.
Misc. oily waste water from
oil storage and handling,
plus maintenance shop-roll
facing, etc.
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLING MILL
COMBINATION TYPE
PROCESS FLOW DIAGRAM
Dwn. 6/5/79
FIGURE n-2

-------
LJ
K>
*i
STAND
*2
STAND
UNCOILER
*3
STAND
*4
STAND
STAND
Sprays
Sprays
Sprays
COILER
Fresh Oil
Solutions
Pump leakage, rolling oil
emulsions, misc oily
waste water from oil
basement.
To Treatment-
Misc. oily waste water
from oil storage and
handling plus maintenance
shop-roll facing etc.
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLING MILL
DIRECT APPLICATION TYPE
PROCESS FLOW DIAGRAM
Dwn.6/6/79
FIGURE 11-3

-------
COLD FORMING SUBCATEGORY
COLD ROLLING
SECTION IV
SUBCATEGORIZATION
Introduction
For cold rolling operations, the main element that affects
segmentation is the method of oil application. Flow rates were found
to differ deoending on the oil application system used. Hence,
proposed limitations were developed separately for recirculation,
combination, and direct application mills.
Basically, the difference in flow rates is the only factor affecting
segmentation of the cold rolling subdivision. Mill age and size,
product type, raw materials, wastewater characteristics, treatability,
and geographic location were considered but the analysis showed that
none of these factors would warrant further segmentation of the cold
rolling subdivision. Each of these elements is reviewed below.
Factors Considered in Subcateqorization
Manufacturing Process and Equipment
To determine if this factor had an affect on segmentation of cold
rolling operations, the Agency analyzed two elements. First, it was
thought that the type of cold rolling done (i.e., temper, tandem, or
reversing mill) might affect flow rates or discharge quality. The
second relationship examined was the configuration of the mill itself,
such as the number of stands present. These elements are discussed
below.
A.	Type of Cold Rolling
The Agency analyzed both the sampling data and the DCP responses
and found no relationship between the type of mill (e.g., temper
or tandem), and either the water flow rates or effluent quality.
Although most mills were identified only as "cold mills," data
for mills that were clearly identified showed no correlations
that indicated that further subcategorization would be
appropriate. For example, mills that perform large thickness
reductions discharge similar flows and achieve similar effluent
quality as those mills, such as skin mills, which perform small
thickness reductions.
B.	Mill Configuration
The Agency also examined the effect of the number of mill stands
on wastewater quality and quantity. All three types of mills
were examined. The mills analyzed varied from small one stand
33

-------
operations to large six stand complexes. To determine if the
number of stands affected flow rate, the flow data for all mills
were tabulated according to the number of stands present, and
then compared to the model flows considered for the three mill
types. These data are shown in Table IV-1 .
In all cases, the mills with the fewest number of stands achieve
the proposed flow rates. However, a large number of the
multi-stand mills achieve the same flow rates. While lower model
flows may be used to develop limitations for one stand cold
rolling mills, the Agency decided to use one model flow for mills
of all sizes. The model flow values used as the basis for the
proposed limitations are well demonstrated by all types of cold
rolling operations and by mills using multi-stand arrangements.
As a final note, it is quite possible for a one stand mill to use
as much water as a five stand mill if this mill is required to
pass the product through the one stand numerous times to achieve
the needed thickness reduction and surface quality. For these
reasons, the proposed limitations do not differentiate between
mills of different configurations.
The data were also analyzed to determine if mill configuration
has an effect on wastewater quality. Of the mills sampled, most
were five stand mills. However, there were a few mills with
fewer stands and some with more than five stands. The raw waste
data do not show any significant variations with mill
configuration. Similar types of oils are used regardless of the
number of mill stands, and notwithstanding equalization
facilities at some mills, concentrations of conventional
pollutants (i.e., TSS and oil & grease) are relatively consistent
among similar type mills (i.e., recirculation, DA). The sampling
data demonstrate that acceptable effluent quality is dependent on
treatment system design and operation and not on mill
configuration.
Final Product
Cold rolling operations yield a wide variety of final products (see
Table 111 — 2). An analysis was done to determine if the final product
rolled (e.g., sheet, strip) affected flow rates, wastewater
characteristics or other elements. The three main products analyzed
were sheet, strip, and flat wire. These three products account for
8 3% of the total tonnage reported by the industry. Others were not
addressed because of the multiple products rolled at these mills, or
because flow rates and other analytical data are not available. The
data show that the final product rolled does not have a significant
affect on either discharge flow or wastewater characteristics. Hence,
further segmentation on this basis is not warranted.
Strip and sheet mills were first analyzed because of their
similarities. The data indicate that more strip mills use
recirculation systems while more sheet mills are direct application
mills. This resulted in a slightly higher average applied flow rates
for the sheet mills. This difference, however, is not significant and
is covered by the basic segmentation by mill type. Aside from high
34

-------
levels of toxic organic pollutants found in recirculated mills for all
products, no differences were found in the wastewater characteristics
between the two mills. In addition, the ability to achieve the model
system flow rates is well demonstrated for both types of mills.
Wire mills are usually small operations with capacities in the range
of hundreds of tons per year as opposed to other operations which
produce many thousands of tons per year. Also, reported applied flow
rates are significantly higher at flat wire mills than at any other
type of cold mill operation. For example, an applied rate of 195,000
GPT was reported for one wire mill. This is approximately 40 times
the highest flow rate reported by either a strip or sheet mill. The
reason for these higher than normal flow rates is the small capacity
of these mills and not any special water requirements. Wire mills
only process products in small batches. Also, when the mill is
operated, it is run for only a small portion of a turn. When the flow
values were calculated on a gallon/ton basis it was assumed that the
mill operated for an entire eight hour turn. Since this is not the
case for wire mills, the calculated applied flow rates are
disproportionately higher than for any other types of mills types.
Despite these inordinately high calculated applied flows, the Agency
found that recirculating mills of all types achieve the model flow
used to develop the proposed limitations. Hence, it is not necessary
to differentiate between products rolled at cold mill operations.
Raw Materials
Carbon, stainless and other types of steel are used as raw material in
cold rolling mills. For this study, the Agency defined any mill
producing more than 50% carbon steel as a "carbon steel mill" and, any
mill producing less than 50% of its output as carbon steel as a
"specialty steel mill." It was found that while the type of steel
rolled sometimes affects mill operation, it does not affect the
eventual discharge quantity. Accordingly, the Agency concluded that
further segmentation based upon type of raw material used (i.e., the
type of steel rolled) is not appropriate.
Although the data from the sampling results and DCPs do not show any
significant differences based upon raw material, some interesting
trends were observed. Specialty steel cold rolling mills, on average,
are 10 times smaller than the average carbon steel mill. The average
yearly capacity for a specialty mill is 35,950 tons while carbon steel
mills have an average yearly capacity of 364,505 tons. This size
relationship results from the fact that at a given plant specialty
steel production is generally on a much smaller scale than carbon
steel production. Thus, the cold reduction operation is limited by
the initial raw steel production.
When the discharge flow rates for the carbon and specialty operations
were compared, no significant differences were found. In fact, both
types of mills have similar average flow rates and ranges of values.
It should be noted that this analysis was limited to recirculation
mills since there is only one specialty mill with available flow data
among the direct application and combination mills.
35

-------
The data for the two types of mills are summarized below:
Average Discharge Standard
Flow Rate (GPT)*	Deviation
Carbon Mills	8.9	11.1
Specialty Mills	9.2	15.8
* Average of the best flow values. See Section X for additional
details.
Wastewater Characteristics
Within the cold rolling subdivision, differences were found in
wastewater characteristics between operations that process specialty
steels and those that process carbon steels. The Agency found that
operations processing specialty steel products generate higher levels
of chromium, copper, lead, nickel, and zinc than do carbon mills.
However, as explained below, this neither affected the selection of
treatment components nor the development of appropriate effluent
limitations.
Specialty steels are produced by adding alloying agents to the steel
as it is being produced. These steels normally contain higher levels
of certain metallic elements such as chromium and nickel which give
the steel added properties. Because the specialty steels contain
these metals, there is a greater tendency for them to be released as
they progress through steel finishing operations, such as cold
rolling.
The data gathered during the sampling visits demonstrate that
wastewaters from specialty operations contain higher concentrations of
certain metals than do wastewaters from carbon steel operations. The
data presented below for recirculation mills illustrates this point.
Carbon Steel Specialty Steel
Operations	Operations

Ave.
Max.
Ave.
Max.

Cone.
Cone.
Cone.
Cone.

(mq/1)
(mq/1)
(ma/1)
(ma/1)
Chromium
0.01
0.03
5.3
10.4
Copper
1.4
2.0
11.7
28.4
Lead
1.3
2.3
3.1
10.4
Nickel
0.6
0.9
5.8
11.5
Zinc
0.5
0.5
5.7
9.5
As can be seen by these data, mills that process specialty steels
generate, on average, 2.4 (lead) to 530 (chromium) times as much
metals as do the carbon steel mills.
36

-------
The Agency is not proposing BPT limitations for the metals since the
Agency has decided to retain the original list of limited pollutants
at this level of treatment. However the Agency is proposing BAT,
NSPS, PSES, and PSNS limitations and standards for certain "indicator"
metals. Since the metals are principally in particulate form, the
treatment technology considered for metals removal at the above
mentioned treatment levels will result in similar treated effluent
quality for both carbon and specialty mills.
For the other pollutants found in the cold rolling wastes, no
differences were found based on product type. The previously limited
pollutants (i.e., total suspended solids, oil and grease) were found
at similar levels at most operations. Some waste streams are more
concentrated than others because of collection practices at some
mills. Depending on the product being rolled, different oils and
greases are used at different mills and within a given mill. The oils
and greases are proprietary in nature and are chosen mainly for their
lubricating and cooling properties. Subcategorization on the basis of
the various types of oils used is not practical due to the complex
nature of those oils and data availability concerning
characterization. It was found that acceptable levels of oil and
grease can be attained in the discharge provided adequate oil
separation and removal is practiced.
Various toxic organic pollutants found are believed to result from the
oils used in the mills. The characteristics of the wastewaters from
mills using different oil mixtures was quite varied. Different
organic pollutants were detected at the mills sampled. Since the
presence of these compounds is widespread among recirculation and
combination mills, and they were generally not found in direct
application mills, the basic segmentation of the cold rolling
subdivision noted above sufficiently accounts for this difference.
Wastewater Treatability
The Agency analyzed the treatability of the wastewater from different
cold rolling operations. It found that there is no significant
difference in treatability from the three segments, except as noted
above for toxic organic pollutants. If adequate treatment is
installed, the proposed levels of effluent quality can be attained.
Because of differences in flow rates, treatment systems must be sized
accordingly, but this does not affect treatability of the wastewater.
It was found, however, that some mills can use non-emulsifiable oils
on their rolling stands. For these mills some of the emulsion
breaking steps proposed in the treatment schemes are not needed.
Size and Age
The Agency considered whether size and age might affect segmentation
of cold rolling operations. It analyzed various relationships dealing
with possible correlations between the effect of age and size on
elements such as wastewater generation, the ability to install
treatment, and the ability to recycle wastes adequately to achieve
desired flow rates. However, the analysis does not show any
37

-------
relationships that affects the segmentation beyond that already
considered.
Size was considered as a possible factor for segmentation. The cold
rolling mills vary greatly in physical size, layout and product size.
However, these considerations revealed no significant relationships to
process water usage, discharge rates, effluent quality or any other
pertinent factors. Figures IV-1 through IV-3 show plots which analyze
the possible relationship between discharge flow and size. On the
plots, the model flow rates used as the basis for the proposed BAT
limitations are also shown. As can be seen, mills of all sizes
achieve the model flows.
There is a slight correlation between mill size and age. The 25
largest mills have an average age (not counting rebuilds) of 1-8.5
years while the 25 smallest mills have an average age of 27 years.
This shows that as technology and material resource requirements
increased over the years, the size of an average cold rolling mill
gradually increased to accommodate the higher demand for cold rolled
products and to take advantage of the economy associated with the
larger mills.
The relationship between flow and age was analyzed in the same way as
the flow vs. size relationship. The plots of flow vs. age for the
three types of cold rolling mills are shown in Figures IV-4 through
IV-6. No relationship between flow and age is evident. Hence, the
age of a mill has no significant impact on the discharge flow from
that mill.
The effect of age on the ability, ease, and cost of installing or
retrofitting treatment systems was also analyzed. Table IV-2 lists
those plants that retrofitted treatment systems onto older mills. The
numerous examples illustrate quite effectively the ability to retrofit
treatment systems onto older mills. Cost data received in the D-DCPs
for all iron and steel subcategories were tabulated. Those data show
that little or no cost is attributable to retrofitting pollution
control equipment. This analysis was detailed in Volume I of this
development document. Based upon this analysis, the Agency concludes
that there are no significant costs associated with retrofitting
pollution control technology and that technology can be retrofitted on
both newer and older mills with about the same degree of difficulty.
Further analysis of the data did not reveal any relationship between
age and wastewater characteristics or treatability. Older mills
discharge the same kinds and amounts of pollutants as newer mills and
the discharges from both older and newer mills can be treated equally.
This also holds true for the larger versus the smaller mills. Some of
the largest mills have installed the best recirculation systems and
achieve some of the lowest discharge flows on a gallon/ton basis.
Wastewaters from larger mills can be treated as effectively as those
from smaller mills.
Thus, based upon the analysis conducted above, the Agency concludes
that age and size do not affect the ability to achieve the proposed
limitations and standards and the ability to install appropriate
38

-------
pollution control technology and, thus, are not bases for
segmentation.
Geographic Location
Examination of the raw waste characteristics, process water
application rates, discharge rates, effluent quality and pertinent
factors associated with plant location reveals no general relationship
or pattern. Cold rolling mills are located in fourteen states, but
over half of the total number are situated in the major steel
producing areas of Pennsylvania and Ohio. Only seventeen are found
west of the Mississippi River (14 in Missouri and 3 in California).
No significant differences between geographic areas were noted when
the data for all plants were reviewed.
The Agency also examined in relation to geographic location, the
remand issue dealing with consumptive use of water in "arid" and
"semi-arid" regions of the country. However, since cooling towers are
not components of the model treatment systems for cold rolling
operations, there is no consumptive use of water which will result
from compliance with the proposed limitations and standards.
Therefore, the remand issue relating to water consumption is not
pertinent to this subdivision.
Process Water Usage
This factor, more than any other, affects the subcategorization of
cold rolling operations. The applied and discharge flow rates differ
significantly depending on the type of oil application system used at
the mills.
Flow rates for the different type mills are shown in Table IV-3. As
can be seen, both the applied and discharge flow rates differ
significantly. This relationship requires the cold rolling
subdivision of the cold forming subcategory to be segmented as
follows:
Recirculation Mills
Combination Mills
Direct Application Mills
Although the wastewater characteristics are fairly similar for all
mills, the Agency concluded that different effluent limitations are
appropriate due to the wide variance in flow rates. This relationship
is reviewed in more detail in later sections.
39

-------
TABLE IV-1
AFFECT OF MILL CONFIGURATION
ON THE DISCHARGE FLOW RATE
COLD ROLLING
Type of
Mill
Total No. of
Operations
Reporting Flows
No. of Operations
Achieving the ,..
Proposed Flow Rate
Percent
Recirculation
1 - Stand
3	- Stand
4	- Stand
5	- Stand
14
6
8
9
13
3
4
8
93
50
50
89
2. Combination
2 - Stand
4	- Stand
5	- Stand
6	- Stand
2
4
6
1
1
3
3
0
50
75
50
0
3. Direct Application
1	- Stand
2	- Stand
3	- Stand
4	- Stand
5	- Stand
3
2
1
4
3
3
1
0
3
1
100
50
0
75
33
(1) Proposed BAT flow basis
40

-------
TABLE IV-2
EXAMPLES OF PLANTS THAT HAVE DEMONSTRATED THE
ABILITY TO RETROFIT POLLUTION CONTROL EQUIPMENT
COLD ROLLING
Plant
Mill Age
Treatment Age
Code
(Year)
(Year)
020G
1951
1975
060
1936
1967
060B
1963
1968
060D
1926
1968
122A
1947
1971
112B
1936
1971
176
1921
1963
384 A
1938
1948
396D
1938
1959
432A
1947
1970
432B
1937
1966
432C
1957
1964
448A
1952
1969
528
1955
1975
584A
1965
1971
584C
1947
1947 & 1977
584F
1947
1965
684C
1937
1950
684D
1939
1970
684 F
1937
1969
760
1950
1971
856D
1938
1959 & 1967
856P
1909
1968
864B
1947
1972
868A
1948
1971
920A
1930
1978
94 8A
1935
1976
948C
1954
1970
41

-------
TABLE IV-3
RELATIONSHIP BETWEEN FLOW AND OPERATION TYPE
COLD ROLLING
Applied Process Flow	Discharge Flow*
(GPT)	(GPT)
Recirculation Mills	2715	9.0
Combination Mills	3930	268
Direct Application Mills	362*	362
* "Average of the Best" flow (see Section X).
42

-------
FIGURE 32-1
FLOW VS. SIZE ANALYSIS
COLD ROLLING - RECIRCULATION
150-
o
t-
CO
z
o
-J
glOO
9
o
Li
©
£T
<
O
CO
O 50-
	BAT FLOW BASIS = 25 GPT

1000
2000
3000
4000
5000
6000
SIZE (TONS/DAY)
43

-------
FIGURE rsr-2
FLOW vs SIZE ANALYSIS
COLD ROLLING-COMBINATION
1500
1250
1000
o
I-
<0
z
o
<
o
*
o
-J
u.
Ui
to

-------
FIGURE EZ-3
FLOW VS. SIZE ANALYSIS
COLD ROLLING -DIRECT APPLICATION
1500
1250
O
I-
>s
to
o 1000
Zj
<
©
£
o
750
UJ
O
tr
<
z
o
CO
500
• BAT FLOW BASIS*400 6PT
250
t	»	i 1	i	r
500	1000	1500	2000	2500
SIZE (TONS/DAY)
45

-------
FIGURE IZ-4
FLOW VS. AGE ANALYSIS
COLD ROLLING - RECIRCULATION
150-

100
50
BAT FLOW BASIS« 25 OPT
.
• •
• ••
* • -	' •
• •	•	f • , f	• • 0, " •	1	—	r
1930	1940	I960	I960	1970	198Q
AGE (FIRST YEAR OF PRODUCTION)
46

-------
FIGURE IE-5
isoo
1250-
FLOW VS.AGE ANALYSIS
COLD ROLLING-COMBINATION
P
CO
z
o
-I
-J
<

-------
FIGURE ET-6
1500-
1250 -
Z
o
I-
CO
z
o
_J
J
<
(D
*
o
-J
Ll_
UJ
O
OS
<
X
o
CO
1000 ¦
750
500-
FL0W VS. AGE ANALYSIS
COLD ROLLtNG - DIRECT APPLICATION
• BAT FLOW BASIS * 400 GPT
250
1930
1940
1950
I960
1970
AGE (FIRST YEAR OF PRODUCTION)
48

-------
SECTION V
COLD FORMING SUBCATEGORY
COLD ROLLING
WATER USE AND WASTE CHARACTERIZATION
Introduction
This section presents a characterization of the cold rolling waste
streams. The waste characterization is based upon data obtained
during field sampling programs at 17 cold rolling operations with two
surveys. During the first sampling survey, the Agency investigated
the levels of previously limited pollutants. During the second
survey, it performed additional monitoring for toxic pollutants. Some
mills were visited on more than one occasion during the two sampling
phases. In those instances, the more recent data were used to
characterize the wastes from that mill, with one exception. Plant 101
was visited twice and significantly different results were found at
each visit. For this plant, the results from both visits are included
in the data base.
The water use rates discussed below pertain only to process
wastewaters, and do not include noncontact cooling or nonprocess
waters. Process wastewater is that water which comes into contact
with the process, product, by-product, or raw materials, thus becoming
contaminated with various pollutants characteristic of the process.
Noncontact cooling water is defined as that water used for cooling
which does not directly contact processes, products, raw materials, or
by-products. Nonprocess water is defined as that water which is used
for nonprocess operations (i.e., utilities and maintenance).
Description of the Cold Rolling
Operation and Wastewater Sources
The major process water use in cold rolling mills is for cooling the
rolls and the material being rolled. This is accomplished by using a
flooded lubrication system for both lubrication and cooling. A
water-oil emulsion is sprayed directly on the material and rolls.
Each stand usually has separate sprays and, where recycle is used, a
separate recycle system. Past practice has been the direct sewering
of the emulsion. However, the high cost of rolling oils and the
implementation of pollution control regulations have modified this
practice. Recycle and recovery systems are currently in common use.
In fact, most of recently built cold rolling mills use recirculated
oil solution systems to minimize oil usage and pollutant loadings.
Considerable heat is generated during heavy reductions at high speed
on the various types of mills. Not only is the temperature of the
product raised but also the temperature of rolls. This heat is
removed from the mill by the flooded lubrication system, and by
noncontact water that is used in the internal roll cooling system.
49

-------
High quality rolling oils are added to form the emulsion sprayed on
the rolls. Oil and temperature are the basic pollutants in the
discharge. However, the oils become contaminated with solids as they
pass over the rolls and the product. Also, the oils themselves can
contain high levels of toxic organic pollutants.
Recirculation mills are more common throughout the industry and in the
aggregate, roll higher tonnages than do combination and direct
application mills. In this operation, the oil emulsion in the flooded
lubrication system is collected and recycled to the mill for
reapplication to the rolls. Generally, each stand has its own
collection tank or sump and pumps to return the emulsion to the
sprays. A five stand tandem mill has five recycle systems, one for
each stand. With this arrangement it is possible to renew one
emulsion tank at a time, or all at once. It is also possible to use
different oil emulsions in each tank if the product being rolled so
requires. These mills usually have periodic batch discharges of spent
rolling emulsions, although a small amount is continuously blown down
at some mills to maintain rolling solutions of acceptable quality.
The used emulsions in some mills are treated in filters and cooling
systems prior to reuse, thereby assuring that the rolling solutions
contain few impurities and remain at a fairly uniform temperature.
Because of the conservation practices in use and the high degree of
recycle, very low wastewater discharge volumes are achieved.
Flow data and net concentrations of pollutants (net over water supply)
found at the eleven recirculation operations surveyed for this study
are summarized in Tables V-l and V-2. Net concentrations are
presented to best describe the actual levels of pollutants contributed
from the cold rolling operation. Averages are' also presented to show
the typical level of pollutants that can be expected to be found in a
discharge from a recirculation cold rolling mill.
The second type of cold rolling mill is the Direct Application (DA)
mill. in these mills, fresh rolling solutions are continuously added
to the rolls. Treatment plants and palm oil recovery systems are
usually installed to reclaim oils for reprocessing and potential
reuse. The high cost of rolling oils has discouraged the use of
once-through systems. Once-through systems are used only when a high
quality product is desired which requires the application of a
solution that is free of contamination. These mills have the highest
discharge flow rates of any of the cold rolling operations. Flow data
and net concentration data for the three DA mills sampled for this
study are presented in Table V-5.
The third type of cold rolling mill is the combination mill, which is,
as the name implies, a combination of a recirculation and direct
application rolling stands. These cold mills are multi-stand with the
last stand usually being the direct application stand. Although the
applied flow rates are higher than for the other types of mills, the
discharge flow rate in gallons/ton for a combination mill is
substantially less than for a direct application mill because of the
recirculation system. Flow and net concentration data for the three
combination mills surveyed are summarized in Tables V-3 and V-4.
50

-------
Regardless of the type of oil application systems used, miscellaneous
oil leaks and spills can occur. Low volume, oil-bearing wastewaters
originating in maintenance and roll finishing shops can be significant
and should be directed to treatment facilities. Oil and water leaks
in oil basements can also contribute high oil loads. These sources of
wastewater were considered in developing the proposed limitations.
51

-------
TABLE V-l
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
ORIGINAL GUIDELINES STUDY
COLD ROLLING - RECIRCULATION

Net
Concentrations of
Pollutants
in Raw Wastewaters
(1)
Plant Code
D
I
X-2
BB-2
EE-2
XX-
Reference Code
0248B
0432K
060B-03
060-03
0112D-01
0684:
Sample Point(s)
3
3
4-7
5-4
1-3
2-:
Flow
(gal/ton)
58
Unk
17.7
16.0
17.5
138

Total Suspended
1, 170
NA
90
55
637
260

Solids







Oil & Grease
3,700
36,000
41,100
664
1,180
619

Dissolved Iron
NA
NA
NA
0.05
NA
NA

PH
6.8
NA
7.0
8.0
6.9
7.1
119
Chromium
0.1
NA
NA
NA
NA
NA
120
Copper
0.01
NA
NA
NA
NA
NA
121
Cyanide, Total
*
NA
NA
NA
NA
NA
122
Lead
*
NA
NA
NA
NA
NA
124
Nickel
0.6
NA
NA
NA
NA
NA
128
Zinc
0.03
NA
NA
NA
NA
NA
Average
49.4
442
13,877
0.05
6.8-8.0
0.1
0.01
*
*
0.6
0.03
(1) All values are in mg/1 unless otherwise noted.
* : Value is less than 0.010 mg/1.
NA: Not analyzed.
52

-------
TABLE V-2
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PUNTS
TOXIC POLLUTANT STUDY
COLD ROLLING - RECIRCULATION
Het Concentration of Pollutants in Raw Wastewaters
Plant Code
101A
101B
103
104
105
107


Reference Code
020B&020C
020B&020C
0384 A(02603)
0248B-03
584F(02,03,605)
176-08

Overall
Saaple Point(a)
B-A
B-A
E-A
B-A
E-A
B-A
Average
Average
Flow
(gal/ton)
4.5
11.0
49
3.5
1.1
0.9
14.7
28.9

Total Suspended
2,220
194
536
1,402
4,910
528
1,632
1,091

Solids









Oil & Grease
82,205
2,499
1,076
(3)
37,200
36,000
31,796
22,022

Dissolved Iron
33.6
HA
4.6
HA
5.6
HA
14.6
11.0

pH
6.5
2.4-4.9
6.7
6.8-7.9
5.8
7.5
2.4-7.9
2.4-8.0
004
Benzene
_
*
-
ND
0.03
ND
*
*
006
Carbon Tetra-
0.1
ND
ND
ND
ND
ND
0.02
0.02

chloride








Oil
It it1-Trichloro-
0.4
0.09
0.02
0.04
ND
ND
0.1
0.1

ethane








013
1i1-Dichloroethane
HD
0.03
10)
ND
ND
*
*
*
023
Chlorofora
0.07
*
0.01
-
0.5
ND
0.1
0.1
024
2-Chlorophetiol
35.5'
ND
0.02
HD
ND
ND
5.9
5.9
034
2,4-Diaethylphenol
25.0
ND
0.06
ND
ND
ND
4.2
4.2
038
Ethylbenzene
0.4
ND
*
*
ND
*
0.07
0.07
044
Methylene Chloride
-
ND
-
0.01
NR
*
*
*
055
Naphthalene
HD
0.5
-
ND
ND
ND
0.08
0.08
057
2-Uitrophenol
70.0
HD
0.06
ND
HD
ND
11.7
11.7
059
2,4-Dinitrophenol
ND
ND
0.02
ND
ND
ND
*
*
060
4, 6-Oinitro-o-
-
ND
0.9
ND
ND
ND
0.2
0.2

cresol








064
Pent achloro phenol
ND
ND
0.04
ND
ND
*
*
*
065
IKienol
HD
0.09
0.07
-
-
ND
0.03
0.03
066
Bis(2-ethylhexyl)
0.2
-
0.8
0.08
0
ND
0.2
0.2

phthalate








068
Di-n-butyl
0.04
-
0.05
-
-
ND
0.02
0.02

phthalate







0.03
069
Di-n-octyl
0.1
-
0.05
¦ -
HD
ND
0.03
phthalate
Data coatiaaad aa a*at. page

-------
TABLE V-2
SISMUtT OF ANALYTICAL DATA FROM SAMPLED PLANTS
TOXIC POLLUTANT STUDY
COLD ROLLING - RECIRCULATION
FACE 2		
Plant
: Code
101A
101B
103
104
Reference Code
020B&020C
020B&020C
0384A(02&03)
0248B-
Saaple Point(s)
B-A
B-A
E-A
B-A
Flow
(gal/ton)
4.5
11.0
49
3.5
070
Diethyl phthalate
*
ND
0.02
—
071
Diaethyl phthalate 0.1
ND
0.1
ND
078
Anthracene
H>
ND
ND
ND
080
Fluorene
0
0.2
0.02
ND
085
Tetrachloro-
ethylene
1.2
0.06
*
ND
086
Toluene
0.1
0.02
ND
0.04
087
Trichloro-
ethylene
0.02
0.1
""
0.03
114
Antimony
0.1
*
0
*
115
Arsenic
HA
0.4
NA
0
117
Beryl liusi
HA
*
NA
0
118
Cadaioa
0.03
0.3
0
0.04
119
Chroaiun
6.5
1.1
0.03
3.1
120
Copper
7.4
3.6
0.7
7.4
121
Cyanide, Total
0.01
0
0.03
0.03
122
Lead
1.5
*
0.2
10.4
124
Nickel
HA
1.5
0.2
4.5
126
Silver
0
0
0
0
128
Zinc
1.7
7.9
0.2
3.7
130
Xylene
4.3
NA
*
NA
(1)	All values are in ag/1 unless otherwise noted.
(2)	Average of all values on Tables V-l and V-2.
(3)	Saaple could not be analysed. Heavy oil emulsion formed.
* :	Value is less than 0.010 mg/1.
- :	Calculation yielded a negative value.
HA:	Not analyzed
IB:	Mot reported
105	107	(2)
584F(02,03,&05)	176-08	Overall^ '
E-A	B-A Average	Average
1.1	0.9 14.7 28.9
ND
ND
*
*
ND
ND
0.04
0.04
ND
14.0
2.3
2.3
ND
ND
0.03
0.03
ND
ND
0.3
0.3
0.06
ND
0.04
0.04
-
ND
0.03
0.03
0.1
0
0.04
0.04
0.6
0.03
0.3
0.3
0.01
0
*
*
0.4
0.02
0.1
0.1
-
10.4
3.5
3.0
2.0
28.4
8.3
7.1
-•
HA
0.01
*
2.3
0.6
2.6
2.6
0.9
11.5
3.7
3.2
0.2
0
*
*
0.5
9.5
3.9
3.4
ND
NA
1.4
1.4

-------
TABLE V-3
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
ORIGINAL GUIDELINES STUDY
	COLD ROLLING - COMBINATION	_
Net Concentration of Pollutants in Raw Wastewaters
(1)
Plant Code
Reference Code
Sample Point
Flow (gal/ton)
Total Suspended Solids
Oil & Grease
Dissolved Iron
pH
DD-2
584E-01
1
312
987
1,399
7.8
5.7
YY-2
432D-01
4
138
260
619
NA
7.1
Average
325
624
1,009
7.8
5.7-7.1
(1) All values are in mg/l unless otherwise noted.
NA: Not analyzed
55

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TABLE V-4
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
TOXIC POLLUTANT SURVEY
	COLD ROLLING - COMBINATION	
Net Concentrations of Pollutants in Raw Wastewaters
(1)
Plant Code
Reference Code
Sample Points
Flow (gal/ton)
Total Suspended Solids
Oil & Grease
Dissolved Iron
PH
66 Bis(2-ethylhexyl) phthalate
115 Arsenic
119	Chromium
120	Copper
124 Nickel
128 Zinc
103
856F-01
D-B
112
699
1,558
NA
6.6
0.03
0.16
0.03
0.89
0.21
0.15
Overall Average
	254
649
1,192
7.8
5.7-7.1
0.03
0.16
0.03
0.89
0.21
0.15
(2)
(1)	All values are in mg/1 unless otherwise noted.
(2)	Average of all values on Tables V-3 and V-4.
NA: Not analyzed
56

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TABLE V-5
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
TOXIC POLLUTANT STUDY
COLD ROLLING - DIRECT APPLICATION
Net Concentrations of Pollutants in Raw Wastewaters
Plant Code
Reference Code
Sample Points
Flow (gal/ton)
105
584F-04
D-A
424
106
112B-01&03-06
B-A
670
107
176-02
C-A
233
Average
442

Total Suspended Solids
160
73
14.3
82.4

Oil & Grease
1,861
1,600
173
1,21

Dissolved Iron
22.3
NA
NA
22.3

pH
7.2
6.5-9.0
6.8-7.7
6.5-'
004
Benzene
0.03
ND
ND
0.01
006
Carbon Tetrachloride
0.03
ND
ND
0.01
011
1,1,1-Trichloroethane
0.14
-
ND
0.05
044
Methylene Chloride
2.40
~
ND
0.80
066
Bis(2-ethylhexyl) phthalate
1.50
ND
ND
0.50
068
Di-n-butyl phthalate
1.00
ND
ND
0.33
069
Di-n-octyl phthalate
0.30
ND
ND
0.10
078
Anthracene
ND
ND
0.10
0.03
085
Tetrachloroethylene
0.08
ND
ND
0.03
115
Arsenic
0.03
0.02
ND
0.02
117
Beryllium
*
ND
0.02
0.01
119
Chromium
-
- ¦
0.10
0.03
120
Copper
ND
0.2
0.05
0.08
122
Lead
0.20
ND
0.8
0.33
124
Nickel
ND
ND
0.5
0.20
126
Silver
0.10
ND
ND
0.03
128
Zinc
ND
0.1
0.03
0.04
(1)
All values are in mg/1 unless
otherwise noted.



* :
Value less than 0.010 mg/1.




NA :
Not analyzed




ND :
Not detected




(-):
Negative value. Counted as
zero in average
calculations.


57

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COLD FORMING SUBCATEGORY
COLD ROLLING
SECTION VI
WASTEWATER POLLUTANTS
Introduction
The final selection of pollutants to be limited for the cold rolling
subdivision depended upon an analysis of wastewater samples collected
in the field. The list of pollutants limited in the originally
promulgated limitations was confirmed and augmented with more
extensive field sampling data that included an analysis for toxic
pollutants. This section describes the pollutants chosen, and the
rationale for selecting those pollutants.
Conventional and Nonconventional Pollutants
In the previous regulation, four pollutants were limited: total
suspended solids, oil and grease, dissolved iron and pH. Suspended
solids, oil and grease and pH were limited at all cold rolling mills,
however; dissolved iron was limited only when the cold rolling
wastewaters were treated in combination with pickle rinse waters.
Two of these pollutants, oil and grease and suspended solids, are most
characteristic of the cold mill wastewaters. Both originate in the
oil solutions that are sprayed on the rolling stands. Oils in
significant level's (up to 40,000 mg/1) are contained in untreated
wastewaters. Suspended solids are also present in cold rolling
wastewaters in high levels with concentrations of 1000 mg/1 common for
many mills. The suspended solids also originate in the oil solutions
as the oils pass over the stands and product and pick up small scale
particles or soot from the product surface. In recirculation mills,
the solid levels are usually higher than for other mills because of
the buildup that can occur as the oil solutions are recirculated.
Dissolved iron can also be present in cold rolling wastewaters, but
effluent limitations for dissolved iron are proposed only for those
operations that co-treat pickling and cold rolling wastewaters.
In addition to the three pollutants discussed above, pH was included
in the original limitations and is again included in these proposed
limitations. Although the pH of raw cold mill wastes are often within
the proposed level of 6-9, a limitation is proposed to insure that the
pH remains in this range after treatment. Most cold mill treatment
systems use acid addition for treatment of the oily wastes, which
reduces the pH to the 4-5 range. The pH limit insures that proper
neutralization is carried out prior to discharge.
59

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Toxic Pollutants
Table VI-1 is a list of toxic pollutants found to be present in cold
mill wastes through EPA surveys or reported by the industry. The net
concentration of each pollutant was calculated and those that were
found at average concentrations greater than 0.010 mg/1 are considered
to be characteristic of cold mill wastes. Table VI-2 presents a list
of these toxic pollutants. It is important to note that net
concentrations were used only to characterize the pollutants generated
in the cold mill process. All proposed effluent limitations were
developed on a gross basis taking into account the treatability of
each pollutant.
Some pollutants were detected at concentrations greater than 0.010
mg/1 but are not listed in Table VI-2. The Agency believes the
presence of those compounds is not due to the cold rolling operation.
Methylene chloride was omitted because this compound is commonly used
as a cleaning agent in the laboratory and the Agency attributes its
detection to this practice and not to the cold mills sampled. Also,
the phthalate compounds are not believed to be characteristic of cold
mill wastes. Evidence developed during the sampling programs
indicates that their origin was probably related to plasticizers in
the tubing used with automatic samplers.
As noted in Table VI-2, many toxic organic and inorganic pollutants
were detected in the wastes from cold rolling operations. The major
source of these pollutants is the rolling oils used at the mills. The
exact nature of these oils are often proprietary in nature so it is
difficult to relate any of the pollutants to any one type of oil or
brand name. The Agency expected to find more toxic organic pollutants
at the recirculated and combination mills because these mills use more
synthetic types of oils. This was verified by the data gathered
during the sampling visits.
The Agency is proposing effluent limitations and standards for several
of the toxic pollutants on Table VI-2 at BAT, NSPS, PSES, and PSNS.
The Agency decided not to propose limitations for all toxic pollutants
as those which are limited will also serve as "indicator" pollutants.
These "indicator" toxic pollutants were selected on the basis that
control of these pollutants will result in similar control of those
not specifically limited and, to reduce monitoring costs to the
industry. The rationale for the selection of limited pollutants is
presented in Volume I of this document. Also, a discussion of the
selected pollutants is presented in Section X of this report.
60

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TABLE VI-1
TOXIC POLLUTANTS KNOWN TO BE PRESENT
COLD ROLLING
4.	Benzene
6.	Carbon Tetrachloride
11.	1,1,1-Trichloroethane
13.	1,1-Dichloroethane
23.	Chloroform
24.	Chlorophenol
34.	2,4-Dimethylphenol
38.	Ethylbenzene
44.	Methylene Chloride
57.	2-Nitrophenol
59.	2,4-Dinitrophenol
60.	4,6-Dinitro-o-cresol
64.	Pentachlorophenol
65.	Phenol
66.	Bis(2-ethylhexyl) phthalate
67.	Butyl benzyl phthalate
68.	Di-n-octyl phthalate
69.	Di-n-octyl phthalate
70.	Diethyl phthalate
71.	Dimethyl phthalate
78.	Anthracene
80.	Fluorene
85.	Tetrachloroethylene
86.	Toluene
87.	Trichloroethylene
114.	Antimony
115.	Arsenic
117.	Beryllium
118.	Cadmium
119.	Chromium
120.	Copper
121.	Cyanide
122.	Lead
124.	Nickel
126.	Silver
128.	Zinc
130.	Xylene
61

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TABLE VI-2
SELECTED POLLUTANTS
COLD ROLLING
006	Carbon Tetrachloride
Oil	1,1,1-Trichloroethane
023	Chloroform
024	2-Chlorophenol
034	2,4-Dimethylphenol
038	Ethylbenzene
055	Naphthalene
057	2-Nitrophenol
060	4,6-Dinitro-o-cre»ol
065	Phenol
078	Anthracene
080	Fluorene
085	Tetrachloroethylene
086	Toluene
087	Trichloroethylene
114	AntitaoAy
115	Arsenic
118	Cadmium
119	Chromium
120	Copper
121	Cyanide
122	Lead
124	Nickel
128	Zinc
130	Xylene
62

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COLD FORMING SUBCATEGORY
COLD ROLLING
SECTION VII
CONTROL AND TREATMENT TECHNOLOGY
Introduction
A review of the control and treatment technologies currently in use or
available for use in the cold rolling subdivision provided the basis
for the selection and development of BPT, BAT, NSPS, PSES, and PSNS
alternative treatment systems. The Agency reviewed the DCP responses
and plant visit data to identify those treatment components and
systems in use at cold rolling operations. Capabilities, either
demonstrated in this or in other operations (refer to Volume I), or
based upon engineering considerations, were used in evaluating the
various treatment technologies. This section presents a summary of
the treatment practices currently in use or available for use in the
treatment of cold rolling process yasfteviaters.
This section also presents the raw wastewater and treated effluent
analytical data for the plants sampled and the long-term effluent
analytical data provided in responses to the D-DCPs. Also included
are treatment system descriptions for each of the sampled plants.
Summary of Treatment Practices Currently Employed
Since the type of wastewaters generated in the three types of cold
rolling mills are fairly consistent, similar treatment is employed
regardless of the oil application system used. For example, one
treatment system may treat wastewaters only from recirculation mills
while another may treat a combined waste stream from direct
application and recirculation mills. Varying degrees of recovery and
reuse of oil emulsions is practiced at the different types of cold
rolling mills. While this may affect the concentration of pollutants
in the discharge, it does not have a significant affect on the
treatment components selected. Depending upon the extent of recycle
or reuse practiced, the treatment systems may be sized differently.
All treatment systems for cold rolling mills incorporate
physical/chemical controls. Also, wastewaters from over 95% of all
cold rolling mills are treated in central treatment systems (i.e.,
other wastewaters are combined with cold rolling wastewaters prior to
treatment). As with many other Phase II pperations, this often
complicates the analysis of the effluent data for the sampled mills
(all but two of the sampled mills had central treatment) because the
high strength cold mill wastewaters are often diluted in large central
treatment systems.
Because of the predominance of central treatment systems, the data for
this subcategory and others were analyzed to determine the effect of
63

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central treatment systems on the ability to achieve proposed
limitations. This analysis found that similar flow rates and effluent
levels are achievable with both types of treatment systems.
Therefore, the proposed limitations do not differentiate between
separate and central treatment. All treatment models shown in this
document reflect "stand-alone" systems, which can be integrated into
central treatment plants, provided adequate pretreatment is provided,
where necessary.
Betides direct discharge mills, there are ten mills that have only
United pretreatment and discharge to locally owned public treatment
works. Additionally, wastewaters from many plants are collected and
hauled off-site for disposal by contractor. Thirteen recirculation
mills have zero discharge of process wastewaters on this basis.
A »uiwnary of control and treatment technology currently practiced at
cold rolling mills follows:
The first level at control of pollutants for recirculation and
combination mills is oil solution reuse. While this practice
results in a great cost savings, it also results in a significant
reduction in the flow and pollutant loads leaving the operation.
The average recirculation rate of used rolling solutions for the
mills surveyed is 94.4% with the recirculation rates ranging from
58.4% to 100%.
2. A variety of options exist for treatment of the resultant
blowdowns, and all are physical/chemical in nature. The various
pollutants in the wastewaters from cold rolling operations are
usually treated in separate unit operations. These systems are
summarized below by pollutant removed.
a* Oils and Greases
Oils and greases present in cold rolling wastewaters can
either be emulsified or nonemulsified. The characteristics
of emulsified oils vary widely depending on the types of
oils used in the rolling solutions. Floating or free oils
resulting from mechanical lubrication systems are not found
in quantities as high as the emulsified oils.
If all the oils and greases are nonemulsified, as at some of
the direct application mills surveyed, simple oil skimming
is sufficient to reduce oil levels to an acceptable level.
All that is required is a pit or basin of sufficient size to
develop a quiescent zone so that the oil has the opportunity
to separate and rise to the surface. From there, it can be
either skimmed off by a trough or collected with a
mechanical skimmer.
However, if the wastewaters contain emulsified oils,
additional chemical treatment is required to separate the
oils from solution prior to other treatment steps. Either
acid pickling rinsewaters or purchased acid are added to the
oily cold rolling wastewaters in a mixing tank at a pH of
64

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4-5 to chemically break the oil emulsion. Once the emulsion
is "broken", coagulant or flotation aids such as alum and
polyelectrolytes may be added. The wastewaters are then
neutralized and passed through an air flotation or similar
oil removal system where oils are separated from the
wastewater. Another alternative used for oil removal is
sedimentation and skimming after emulsion breaking.
b.	Total Suspended Solids
Moderate levels of suspended solids are generated in cold
rolling operations. These solids are picked up on the rolls
and carried from the process in the oil-water emulsions.
Suspended solids removal, in most cases, is carried out in
clarifiers or in lagoons after the addition of lime and
polymer in mixing tanks. These chemicals promote settling
and neutralize the wastewaters. Also, suspended solids are
removed by the oil removal systems as some solids cling to
the oil particles and are removed by the skimmers and air
flotation devices.
An alternative method used at a small number of mills to
reduce solids and oil is ultra-high rate (UHR) filtration.
Primary settling and skimming is done prior to filtration to
reduce the levels of floating oils and heavy solids.
Polyelectrolyte addition prior to the filter is sometimes
used to improve filter effluent quality and also to
facilitate filter backwashing. Clogging of the filter is
eliminated by adding steam to the backwash cycle in addition
to air and water. The UHR filter is highly effective in
reducing solids and oils and can be installed in much
smaller areas than conventional settling basins.
c.	Dissolved Iron
For most operations that jointly treat acid pickling and
cold mill wastewaters, control of dissolved iron is
accomplished by the chemical addition, aeration, and
clarification described above. To achieve optimum removal,
the iron is converted to the ferric state by aeration and
neutralization.
3.	Plants which discharge to publicly owned treatment works usually
have an intermediate level of treatment. Most practice some
primary settling and oil skimming to reduce the load of solids
and oils entering the POTW. One plant has an ultrafiltration
system for pretreatment.
4.	Waste solutions are collected and hauled off-site for a large
number of plants with small waste volumes. Surface oil skimming
prior to disposal is practiced at some mills for recovery of a
portion of the used oil.
65

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Control and Treatment Technologies
Considered for Toxic Pollutant Removal
Because toxic inorganic and organic pollutants have been detected
above treatability levels in the discharges from cold rolling
operations, the Agency considered advanced levels of treatment for
BAT, NSPS, PSES, and PSNS.
Methods available to effectively reduce the levels of the toxic metal
pollutants in cold rolling wastewaters include filtration, chemical
precipitation., and others as noted in Volume I.
Twenty toxic organic pollutants were found in the wastewaters from
recirculation cold mills at levels up to 35 parts per million (ppm or
mg/1). Lesser amounts were found at the direct application mills
sampled because of the different oil solutions used at these mills.
Because combination mills employ at least one recirculated stand, high
levels of toxic organic pollutants are also expected to be found at
these operations. For these reasons, limitations for certain organic
pollutants are being been proposed for BAT, NSPS, PSES, and PSNS for
recirculation and combination mills. The proposed limitations are
based upon the application of advanced levels of treatment. However,
in most instances, the Agency believes that a change in oil solution
can achieve the same limitations.
The advanced treatment alternatives that were considered for cold
rolling are listed below. Although only one of these systems has been
demonstrated within the cold rolling subdivision, they all have been
demonstrated in other industrial applications on wastewaters with
characteristics similar to those of cold rolling. The treatment
systems actually selected as BAT, NSPS, PSES, and PSNS models are
discussed in greater detail in later sections with special emphasis on
the applicability to the cold rolling subdivision.
A. Processing of Wastewater With Activated Carbon
Activated carbon has long been used in a variety of applications
involving the removal of organic pollutants from wastewater
streams. It is also used to remove specific organic contaminants
in the wastewaters of various manufacturing operations of the
petroleum refining and organic chemical industries. Operational
guidelines for the use of activated carbon specify that where
treatment of combined wastewaters is involved, or where the water
to be processed has significant turbidity, chemical clarification
followed by filtration is required. Some industrial applications
use chemical precipitation followed by diatomaceous earth
filtration to achieve the clarity required for low level removal
of organic pollutants. The need for removal of particulates
increases where removal of toxic organic pollutants to low levels
is required.
Limited data available for carbon adsorption indicate that most
of the toxic organic pollutants found in the discharges from cold
rolling mills respond well to carbon adsorption. Most can be
treated to levels below 50 micrograms per liter. Reference is
66

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made to Volume I for additional information on activated carbon
adsorption.
B.	Removal of Orqanics With Reverse Osmosis
Reverse osmosis treatment of wastewater is effective for removal
of organic compounds that have molecular weights above 200.
Below a molecular weight of 200, retention characteristics are
variable, depending on steric size of the molecule, degree of
hydrogen bonding, and ionization of the molecule. One rough
approximation which can be made relative to reverse osmosis is
that retention of a compound decreases as molecular weight
decreases.
Molecular weights of organic compounds on the toxic pollutants
list range from 50 to over 400. Most compounds have molecular
weights below 200. Information presented in literature
concerning removal of specific compounds indicated poor retention
characteristics for low molecular weight compounds of the type
that are included on the toxic pollutant list. Based upon this
consideration, treatment with reverse osmosis may not be
effective for removal of toxic organic pollutants.
C.	Ultrafiltration
Ultrafiltration (UF) techniques are based upon a pressure-driven
filtration membrane to separate multicomponent solutes, or
solutes from solvents, according to molecular size and shape.
For this reason, ultrafiltration can be designed quite well to
separate the oil emulsion present in many of the discharges from
cold rolling operations. At the same time, organic compounds of
the correct molecular size that may be found in these emulsions
will also be removed. Hence, ultrafiltration could prove to be
an effective means to achieve organic toxic pollutant removal of
cold rolling wastewaters.
One of the sampled plants, Plant 101, has an ultrafiltration
system installed to treat wastewaters from twelve cold mills.
The data for this plant (see Table VII-3), show that the
ultrafiltration unit is quite effective in reducing the levels of
oil and grease and organic matter. However, one potential
disadvantage of this system is that the membrane is selective in
the types of pollutants it will act on and can clog easily if
free oils or similar pollutants are present. This problem was
experienced at Plant 101. Wastes from one of the cold mills is
now hauled off-site because the ultrafiltration system is unable
to effectively treat the wastes from this mill.
Although UF has been demonstrated at Plant 101, this technology
has not been used as the basis for the effluent limitations
developed for this subcategory. The Agency does not believe that
the data available, at this time, on the performance and
operation of this system is sufficient to generalize the
application of UF for the entire cold rolling subcategory.
67

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D. Processing of Wastewater with Vapor Compression Distillation
Vapor compression brine concentrators are typically used to
concentrate high TDS (3,000-10,000 mg/1) to a slurry consistency
(approximately 100,000 mg/1). The slurry discharge can be dried
in a mechanical drier or allowed to crystallize in a small solar
or steam-heated pond prior to final disposal. The distillate
quality water generated by this system can be recycled back to
the process, thereby eliminating the aqueous discharge from the
cold rolling mill. One desirable feature of this system is its
relative freedom from scaling. Because of the unique design of
the system, calcium sulfate and silicate crystals grow in
solution as opposed to depositing on heat transfer surfaces.
Economic operation of the system requires a high calcium to
sodium ratio (hard water).
Due to cost considerations, only limited application is made of
vapor compression distillation in processing wastewater. The
need for recovery and reuse of water as may exist in "arid" or
"semi-arid" areas is a major consideration in the installation of
distillation processing equipment.
Summary of Sampling Visit Data
Recirculation Mills
Thirteen recirculation operations were visited during this study, with
one operation sampled twice. The raw and effluent data gathered for
the original guidelines study are summarized in Table VII-2. Table
VI1-3 presents the raw and effluent data from the toxic pollutant
survey. Table VII-1 provides a legend for the various control and
treatment technology abbreviations used on the above tables and in
other tables throughout this report. A brief description of each
wastewater treatment system follows. More details are available on
the respective wastewater flow diagram.
Plant D - Figure VII-1
Oil skimming is used to remove the insoluble surface oil and chemical
addition is used to break the oil emulsion found in the blowdown
coolant from the cold rolling operation.
Plant I - Figure VII-2
Oil skimming is used to remove the insoluble surface oil and a paper
filter is used to remove particulate matter before recirculating the
coolant to the cold rolling operation. The skimmed oil is reprocessed
by an outside firm. There is no other discharge from this system.
Plant BB-2 - Figure VII-3
Cold rolling wastes are treated in combination with pickling wastes.
Treatment consists of neutralization, aeration, clarification, and
lagooning prior to discharge to the receiving stream.
68

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Plant EE-2 - Figure VII-4
Oil skimming, chemical treatment, lagooning, are provided prior to
discharge.
Plant X-2 z Figure VII-5
Treatment at this mill consists of air flotation, chemical treatment,
clarification, and plant reuse. The cold mill wastes are treated in a
central treatment unit together with pickling wastes.
Plant XX-2 - Figure VII-6
Treatment at this mill consists of primary settling, oil skimming, and
secondary settling in a lagoon. The cold mill wastes are treated in
conjunction with wastes from other operations.
Plant 101 - Figure VII-7
Wastewaters at this plant originate at twelve different cold mill
operations. All wastewaters are collected in a holding tank and are
treated in an ultrafiltration unit on a batch basis. The effluent
from this system is discharged to a POTW. There is no other discharge
from this plant.
Plant 102 and FF-2 - Figure VII-8
Plants 102 and FF-2 are the same. Treatment consists of primary
sedimentation, mixing, clarification, and sewer discharge. The cold
mill wastes are combined with wastes from a hot strip mill prior to
the mixing and clarification. Flow and production data shown on
Figure VII-8 are from the second visit (102).
Plant 104 = Figure VII-9
This plant has a central wastewater treatment system for several cold
rolling mills and other miscellaneous wastes. Treatment consists of
addition of an emulsion breaking aid, oil skimming and sedimentation
in a settling tank. Wastes from the recirculation mill sampled were
not flowing to the treatment system when effluent samples were taken.
However, data for the treated effluent are shown and have been used to
characterize treatment capabilities of the emulsion breaking and
skimming technologies.
Plant 105 - Figure VII-10
This plant has a treatment/oil reclamation system that treats cold
mill wastewaters from three recirculated and one direct application
mill. Treatment at this mill consists of oil holding tanks, oil
skimming and discharge to large lagoons where additional oil and
solids removal is provided. The effluent sample at this mill was
taken prior to the lagoons.
69

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Plant 107 - Figure VI1-11
Only raw waste samples were taken at this operation. A large central
treatment system is used at this plant to treat wastes from more than
20 sources.
Combination Mills
Tables VII-4 and 5 present the raw and effluent wasteload data for
combination mills. Sampling results are available for three
combination mills. Mill DD-2 was sampled twice in 1976; however, only
one set of data is provided to avoid duplication. One combination
mill was sampled for the toxic pollutant study; the levels found at
this visit are listed in Table VII-6.
Plant DD-2 Figure VII-12
Oil skimming, chemical treatment, final settling in a lagoon, are
provided prior to discharge.
Plant YY-2 - Figure VII-13
Primary settling, oil skimming, chemical treatment, and final settling
in a clarifier are provided. Other wastewaters are combined with the
cold mill wastes before central treatment.
Plant 103 z Figure VII-14
Only representative samples of the raw wastewaters at this mill could
be obtained at the time of sampling. A large central treatment system
is used to treat several waste sources.
Direct Application Mills
Three direct application operations were visited. One operation was
sampled twice, once during the original guidelines study and once
during the toxic pollutant study. Only the data from the second visit
at this operation are used in the data base tables. The raw and
treated effluent data for the three operations are presented in Tables
VII-6 and 7.
Plant 105 and W-2 - Figure VII-10
The treatment system and diagram for this mill is the same as
described previously for Plant 105 (under recirculation mills).
Plant 106 - Figure VII-15
At this plant, wastewaters from six direct application mills are
collected in a sump where floating oils are collected; filtered with
twelve upflow sand filters; combined with neutralized pickling and
galvanizing wastes; and, settled in a thickener. The discharge from
the thickener is then discharged.
70

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Plant 107 - Figure VII-11
See prior discussion on Plant 107.
Summary of Long-Term Analytical Data
Long-term effluent data were obtained for two cold rolling plants.
These data are summarized in Table VII-8. Data for the wastewater at
Plant 0684F were obtained before it entered final clarification and
neutralization. Data for Plant 0920G were provided for the wastewater
after chemical treatment and sedimentation.
71

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TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
Symbols
Operating Modes
1.	OT	Once-Through
2.	Rt,s,n	Recycle, where t » type waste
s * stream recycled
n ¦ % recycled
t: U " Untreated
T » Treated
		s		n	
P	Process Wastewater	1 of raw waste flow
F	Flume Only	% of raw waste flow
S	Flume and Sprays	% of raw waste flow
FC	Final Cooler	% of FC flow
BC	Barometric Cond.	% of BC flow
VS	Abs. Vent Scrub.	Z of VS flow
FH	Fume Hood Scrub.	% of FH flow
3.	REt,n	Reuse, where t » type
n ¦ % of raw waste flow
t: U ¦ before treatment
T ¦ after treatment
4.	BDn	Blowdown, where n ¦ discharge as % of
raw waste flow
Control Technology
10. DI
Deionization
11. SR
Spray/Fog Rinse
12. CC
Countercurrent Rinse
13. DR
Drag-out Recovery
Disposal
Methods
20. H
Haul Off-Site
21. DW
Deep Well Injection
72

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TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 2
C.	Disposal Methods (cont.)
22.	Qt,d	Coke Quenching, where t ® type
d ¦ discharge as %
of makeup
t: DW ¦ Dirty Water
CW * Clean Water
23.	EME	Evaporation, Multiple Effect
24.	ES	Evaporation on Slag
25.	EVC	Evaporation, Vapor Compression Distillation
D.	Treatment Technology
30.
SC
Segregated Collection
31.
E
Equalization/Blending
32.
Scr
Screening
33.
OB
Oil Collecting Baffle
34.
SS
Surface Skimming (oil,
35.
PSP
Primary Scale Pit
36.
SSP
Secondary Scale Pit
37.
EB
Emulsion Breaking
38.
A
Acidification
39.
AO
Air Oxidation
40.
GF
Gas Flotation
41.
M
Mixing
42.
Nt
Neutralization, where
t: L ¦ Lime
C ¦ Caustic
A ¦ Acid
W • Wastes
0 • Other, footnote

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TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 3
D.	Treatment Technology (cont.)
43.	FLt	Flocculation, where t ¦ type
t: L ¦ Lime
A ¦ Alum
P " Polymer
M ¦ Magnetic
0 ¦ Other, footnote
44.	CY	Cyclone/Centrifuge/Classifier
44a. DT Drag Tank
45.	CL	Clarifier
46.	T	Thickener
47.	TP	Tube/Plate Settler
48.	SLn	Settling Lagoon, where n * days of retention
time
49.	BL	Bottom Liner
50.	VF	Vacuum Filtration (of e.g., CL, T, or TP
underflows)
51.	Ft,m,h	Filtration, where t ¦ type
m ™ media
h " head
	t		m 	h
D " Deep Bed	S ¦ Sand	G - Gravity
F - Flat Bed	0 - Other, P - Pressure
footnote
52.	CLt	Chlorination, where t » type
ts A ¦ Alkaline
B ¦ Breakpoint
53.	CO	Chemical Oxidation (other than CLA or CLB)
74

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TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 4		
D.	Treatment Technology (cont.)
54. BOt	Biological Oxidation, where t
t ¦ type

t: An ¦
Activated Sludge
n ¦
No. of Stages
T -
Trickling Filter
B -
Biodisc
0 -
Other, footnote
55.	CR	Chemical Reduction (e.g., chromium)
56.	DP	Dephenoiizer
57.	ASt	Amnonia Stripping, where t ¦ type
t: F ¦ Free
L ¦ Lime
C ¦ Caustic
58.	APt	Ammonia Product, where t ¦ type
t: S ¦ Sulfate
N ¦ Nitric Acid
A " Anhydrous
P ¦ Phosphate
H ¦ Hydroxide
0 ¦ Other, footnote
59.	DSt	Desulfurization, where t " type
ti Q ¦ Qualifying
N ¦ Nonqualifying
60.	CT	Cooling Tower
61.	AR	Acid Regeneration
62.	AU	Acid Recovery and Reuse
63.	ACt	Activated Carbon, where t ¦ type
t: P ¦ Powdered
G " Granular
64.	IX	Ion Exchange
65.	RO	Reverse Osmosis
66.	D	Distillation
75

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TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 5
D.	Treatment Technology (cont.)
67.	AA1	Activated Alumina
68.	OZ	Ozonation
69.	UV	Ultraviolet Radiation
70.	CNTt,n	Central Treatment, where t * type
n = process flow as
Z of total flow
t: 1	¦ Same Subcats.
2	¦ Similar Subcats.
3	¦ Synergistic Subcats.
4	¦ Cooling Water
5	¦ Incompatible Subcats.
71.	On	Other, where n ¦ Footnote number
72.	SB	Settling Basin
73.	AE	Aeration
74.	PS	Precipitation with Sulfide
76

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TABLE VI1-2
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
ORIGINAL GUIDELINES STUDY
COLD ROLLING - RECIRCULATION 	
Saw Wastewaters
Plant Code
Reference Code
Sanple Point
Plow, GPT


¦g/1

Total Suspended Solids
1,740

Oil & Grease
3,700

Dissolved Iron
NA

pH (Units)

119
Chrooiiufa
0.10
120
Copper
0.010
124
Nickel
0.62
128
Zinc
0.030
D
24 SB
II
57
6.8
lb/1000 lbT
0.41
0.88
NA
0.000024
0.0000024
0.00015
0.0000071
¦g/1
NA
36,000
HA
NA
NA
NA
HA
I
432K
3
0.8
HA
lb/1000 lbs
NA
0.12
NA
NA
NA
NA
NA
X-2
060B-03
4
17.7
mg/l
lb/1000 lbs
mg/l
90
0.0066
55
41,100
3.03
664
1.2
0.000089
0.05

7.0

NA
JiA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
BB-2
060-03
5
16.0
8.0
lb/1000 lbs
0.0037
0.044
0.0000033
NA
NA
NA
NA
Treated Effluents
Plant Code
Reference Code
Saaple Point
FloVf.CPT
C&TT
Total Suspended Solids
Oil & Grease
Dissolved Iron
pH (Units)
119	Chroaiua
120	Copper
124 Nickel
128 Zinc
D
248B
5
57
Scr,EB,SS,CV
¦j7T	ib/loop tb7
961	0.23
1,049	0.25
NA	NA
12.0
NA	NA
0.33	0.000078
0.050	0.000012
0.33	0.000078
I
43 2K
3
0.8
(2)
¦g7T	lb/1000 lbs
X-2
060B-03
5
17.7
EB,GF,CL,SS
^I7T	lb/1000 lb7
20	0.0015
4	0.00030
0.10	0.0000073
7.8
NA	NA
NA	NA
NA	NA
NA	NA
BB-2
060-03
7
16.0
DN,EB,T,FLP,
FP,NL,CL,SL,SS,VF
mg/l	lb/1000 lbs"
2.0	0.00013
6.0	0.00040
0.04	0.0000026
7.7
NA	NA
NA	NA
NA	NA
NA	NA

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TABLE VII-2
SUWW.KY OF ANALYTICAL DATA FKOH SAMPLED PLANTS
ORIGINAL GUIDELINES STUDY
COLD ROLLING - RECIRCULATION
PAGE 2
Raw Wastewaters
Plant Code
Reference Code
Sample Point
Flow, CPT

EE-2
112D-01
1
17.4

FF-2
384A(02&03)
1
1S2

XX- 2
6841-01
2
138

Average
61.3

mg/1

lb/1000 lbs
mg/1

lb/1000 lbs
mg/1

lb/1000 lbs


lb/1000 lbs
Total Suspended Solids
637

0.046
194

0.15
260

0.15
495

0.13
Oil & Grease
1,180

0.086
354

0.27
619

0.36
11,930

0.68
Dissolved Iron
1.00

0.000073
0.60

0.00046
NA

NA
0.71

0.00016
pH (Units)

6.8


8.1


7.1


7.3

119 Chromium
NA

NA
NA

NA
NA

NA
0.10

0.000024
120 Copper
NA

NA
NA

NA
NA

NA
0.010

0.0000024
124 Nickel
NA

NA
NA

NA
NA

NA
0.62

0.00015
128 Zinc
NA

NA
NA

NA
NA

NA
0.030

0.000071
Treated Effluents
Plant Code
Reference Code
Sample Point
Flow..GPT
C&TT
EE-2
112D-01
2
17.4
CR,FLP,NL,NW,CL,SI,SS

FF-2
384A( 02&03)
2
182
EB,FLP,CL,SS
XX-2
6841-01
5
138
NW,PSP,SSP,SS,CNT,BD,SL

¦g/1
lbs/1000 lbs
mg/1
lb/1000 lbs
mg/1
lb/1000 lbs
Total Suspended Solids
2.0
0.00015
10
0.0076
30
0.017
Oil & Grease
4.0
0.00029
5
0.0038
7
0.0040
Dissolved Iron
0.020
0.0000014
0.030
0.000024
NA
NA
pH (Units)

7.8

8.3
7.3

119 Chromium
MA
HA
NA
NA
NA
NA
120 Copper
NA
NA
NA
NA
NA
NA
124 Nickel
NA
NA
NA
NA
NA
NA
126 Zinc
NA
NA
NA
NA
NA
NA
(1)	For C&TT abbreviations, see Table VII-1.
(2)	Recirculated oil emulsions treated in a filter. Hie only discharge from this system is waste oil solutions.
(5)	Discharge consists of waste oil solutions.
NA: Not analyzed

-------
TABLE VII-3
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
TOXIC POLLUTANT STUDY
COLD ROLLING - RECIRCULATION HILLS
Raw Wastewaters
<0
Plant Code
Reference No.
Sample Point
Plow, GPT
101A
20B+20C
B
4.5
(1)
lbs/
lou
20B+20C
B
11.0
lbs/
102
384A-(02+03)
E
49
lbs/
104
248B-03
B
3.5
lbs/
105
584F-(02,03,*05)
E
1.1
Tbs7
107
176-08
B
0.9
lbs/
(3)
Average
11.7
lbs7~
Overall
Average
36.5
(A)
lbsT


¦g/1
1000 lbs
¦g/1
1000 lbs
mg/1
1000 lbs
¦g/1
1000 lbs
»g/l
1000 lbs
»g/l
1000 lbs
Mg/1
1000 lbs
¦g/1
1000 lbs

Total Suspended
2,220
0.042
170
0.0078
556
0.11
1403
0.020
5,040
0.023
530
0.0020
1653
0.034
1,074
0.081

Solids
Oil and Grease
82,210
1.54
2,506
0.11
1,076
0.22
na<2)
na(2)
37,200
0.17
36,000 0.14
31,798
0.44
21,864
0.56

Dissolved Iron
6.5
0.00012
NA
NA
4.8
0.00098
NA
NA
516.5
0.0023
NA
NA
176
0.0011
88.4
0.00063

pH (Doits)
6.
5
2-3-4
.5
6.
7
6.8-7
.9
5.8

7.5

2.3-
-7.9
2.3
-7.9
006
Carbon Tetra-
chloride
0.11
0.0000020
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.018
**
0.018
**
Oil
1,1,1-Trichloro-
ethane
0.42
0.0000077
0.10
0.000046
0.019
0.0000040
0.03a
**
ND
ND
*
**
0.097
0.0000031
0.097
0.000031
023
Cblorofora
0.08
0.0000014
A
**
0.011
0.0000022
ND
ND
0.54
0.0000024
ND
ND
0.11
0.0000012
0.11
0.0000012
024
2-Chlorophenol
35.5
0.00066
ND
ND
0.021
0.0000042
ND
ND
ND
ND
ND
ND
5.92
0.00011
5.92
O.OOOU
034
2,4-Di.et hy 1 -
phenol
25.0
0.00047
ND
ND
0.060
0.000012
ND
ND
ND
ND
ND
ND
4.18
0.000080
4.18
0.000080
038
Ethylbenzene
0.39
0.0000072
ND
ND
*
0.0000020
*
4rk
ND
ND
*
**
0.070
0.0000019
0.070
0.0000019
055
Naphthalene
ND
ND
0.54
0.000025
ND
ND
ND
ND
ND
ND
ND
ND
0.090
0.0000042
0.090
0.0000042
057
2-Nitrophenol
70.0
0.0013
ND
ND
0.060
0.000012
ND
ND
ND
ND
ND
ND
11.68
0.00022
11.68
0.00022
060
4,6-Dinitro-
o-cresol
ND
NE
ND
ND
0.94
0.00019
ND
ND
ND
ND
ND
ND
0.16
0.000032
0.16
0.00032
065
Phenol
ND
ND
0.090
0.0000041
0.068
0.000014
ND
ND
ND
ND
ND
ND
0.026
0.0000030
0.026
0.0000030
078
Anthracene
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
16.0
0.000060
2.67
0.000010
2.67
0.000010
080
Fluorene
*
**
0.16
0.0000073
0.015
0.0000031
ND
ND
ND
ND
ND
ND
0.031
0.0000019
0.031
0.0000019
085
Tetrach loro-
ethylene
1.15
0.000022
0.062
0.0000028
*
0.0000020
ND
ND
0.48
0.0000021
ND
ND
0.29
0.0000048
0.29
0.0000048
086
Toluene
0.11
0.0000020
0.019
**
ND
ND
0.035
**
0.064
**
*
**
0.040
0.0000010
0.040
0.0000010
087
Trichloro-
ethylene
0.018
**
0.14
0.0000064
ND
ND
0.025
**
ND
ND
ND
ND
0,031
0.0000014
0.031
0.0000014
114
Antimony
0.15
0.0000028
*
**
0.10
0.000020
0.014
**
0.13
**
0.012
**
0.069
0.0000045
0.069
0.0000045
115
Arsenic
HA
NA
0.41
0.000019
NA
NA
*
**
0.58
0.0000026
0.06
**
0.27
0.0000059
0.27
0.0000059
118
Cadaiua
0.045
**
0.031
0.000014
*
0.0000020
0.040
**
0.45
0.0000020
0.02
**
0.099
0.0000035
0.099
0.0000035
119
ChrcwiiMi
6.5
0.00012
1.08
0.000050
0.06
0.000012
3.13
0.000046
0.38
0.000017
10.4
0.000039
3.59
0.000045
1.85
0.000034
120
Copper
7.5
0.00014
3. 65
0.00017
0.70
0.00014
7.44
0.00011
2.26
0.000010
28.4
0.00011
8.32
0.00011
4.17
0.000056
Raw wastewater data continued on next page.

-------
TABLE VII-3
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
TOXIC POLLUTANT STUDY
COLD ROLLING - RECIRCULATION MILLS
PAGE 2		
Raw Wastewaters
Plant Code
Reference No.
Sample Point
101 A,
20B+20C
(1)
101B
20B+20C
B
(I)
102
384A~(02+03)
E
104
248B-03
B
105
584F-(02,03,*05)
E
107
176-08
B
Average
(3)
Overall
Average
(4)
Flow
, GPT

4.5

11.0

49

3.5

l.l

0.9

11.7

36.5



lbs/

lbs/

lbs/

lbs/

lbs/

lbs/

lbs/

lbs/


¦g/1
1000 lbs
mg/1
1000 lbs
mg/1
1000 lbs
mg/1
1000 lbs
¦g/1
1000 lbs
¦g/1
1000 lbs
lag/1
1000 lbs
mg/1
1000 lbs
122
Lead
1.55
0.000029
0.53
0.000024
0.21
0.000043
10.48
0.00015
2.5
0.000011
0.6
0.0000022
2.65
0.000038
2.65
0.000038
124
Nickel
NA
NA
1.58
0.000072
0.23
0.000047
4.71
0.000069
1.25
0.0000056
11.5
0.000043
3.85
0.000047
2.24
0.000097
128
Zinc
1.75
0.000033
7.95
0.00036
0.18
0.000037
3.74
0.000055
0.68
0.0000030
9.5
0.000036
3.97
0.000087
2.00
0.000079
130
Xylene
4.30
0.000080
NA
NA
*
0.0000020
ND
ND
NA
NA
NA
NA
1.44
0.000027
1.44
0.000027
CO
O
Treated Effluents
Plant Code
Keference No.
Sample Points
Flow.-GPT
C&TT
101 A,
20B+20C
C
4.5
(1)
101B
20B+20C
B
11.0
(1)
Ultrafiltration Ultrafiltration
102
384A-(02+03)
I
49
PSP,EB,CL
104(6>
248B-03
D
3.5
Surge Tank,EB,
OB, SB
105
584F-(02,03,+05)
NA
l.l
EB,SS
107
176-08
NA
0.9
006
011
023
024
034
038
055
057
060
065
078
080


lbs /

lbs/

lbs/

lbs/
lbs/
lbs/

¦g/l
1000 lbs
mg/1
1000 lbs
mg/1
1000 lbs
mg/1
1000 lbs
mg/1 1000 lbs
mg/1 1000 lbs
Total Suspended
198.5
0.0037
76.5
0.0035
20
0.027
52
0.00076
Samples of the
The cold mill at
Solids








effluent at this
Plant 107 dis-
Oil and Grease
140
0.0026
13.1
0.00060
3.0
0.0075
133
0.0019
plant were not
charges into a
Dissolved Iron
805
0.015
NA
NA
15.7
0.027
NA
NA
available. There-
large central
pH (Units)
4.
1
2.4-4
.9
8.2

5.8-6
.8
fore , no
treatment system.









effluent data
No effluent samples
Carbon Tetra-
ND
ND
ND
ND
ND
ND
ND
ND
will be pre-
were taken of this
1,1,1-Trichloro-
*
**
0.056
0.0000026
ND
ND
*
¦**
sented .
treatment system.
ethane










Chloroform
0.043
**
~
**
0.024
0.0000049
*
**


2-Chlorophenol
ND
ND
ND
ND
ND
ND
ND
ND


2,4-Dimethyl-
ND
ND
*
**
*
0.0000020
0.021
**


plienol










Ethyfbenzene
0.010
**
ND
ND
ND
ND
0.015
**


Naphthalene
0.034
**
0.10
0.0000046
ND
ND
0.010
**


2-Nitrophenol
0.021
**
ND
ND
ND
ND
ND
ND


4,6-Dinitro-o-
ND
ND
ND
ND
*
0.0000020
ND
ND


cresol










Rienol
0.055
0.0000010
0.50
0.000023
*
0.0000020
0.14
0.0000020


Anthracene
ND
ND
~
**
0.010
0.0000020
ND
ND


Fluorene
*
**
0.033
0.0000015
*
0.0000020
ND
ND


Treated effluent data continued on next page.

-------
TABLE VII-3
SUMIARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
TOXIC POLLUTANT STUDY
COLD ROLLING - RECIRCULATION MILLS
PAGE 3 		
Treated Effluents
CD
Plant Code
101A
101B
102
104
105
107
C&TT

Ultrafiltration
Ultrafiltration
PSP
,EB,CL
OB, SB

EB,SS Not Applicable



lbs /

lbs/

lbs/

lbs/

lbs/ lbs/


¦g/1
1000 lbs
¦g/1
1000 lbs
Mg/l
1000 lbs
¦g/1
1000 lbs
¦g/1
1000 lbs ag/1 1000 lbs
085
Tetrachloro-
0.016
**
0.033
0.0000015
ND
ND
ND
ND
See
note above See note above

ethylene










086
Toluene
0.060
0.0000011
0.10
0.0000046
ND
ND
*
**


087
Trichloro-
ND
NO
0.064
0.0000029
*
0.0000020
0.013
**



ethylene










114
Ant inony
0.30
0.0000056
*
**
0.10
0.000020
*
**


11J
Arsenic
NA
NA
0.36
0.000017
NA
NA
*
*4


118
Cadaiua
0.020
**
0.029
0.0000013
NA
NA
*
**


119
Chraaiua
1.17
0.000022
0.81
0.000037
0.010
0.0000020
0.19
0.0000028


120
Copper
0.063
0.0000012
1.85
0.000085
0.030
0.0000061
0.41
0.0000060


122
Lead
0.09
0.0000017
0.50
0.000023
0.020
0.0000041
0.11
0.0000016


124
Nickel
HA
NA
1.41
0.000065
0.050
0.000010
0.31
0.0000045


128
Zinc
5.25
0.000099
7.46
0.00034
0.025
0.0000051
0.32
0.0000047


130
Xylene
*
**
NA
NA
ND
ND
NA
HA


(1)	Twelve cold rolling mills discharge to a joint treatment system. The designation of these aills
is as follows: 20B-OI, 20B-02, 20B-04, 208-05, 20C-(01-08).
(2)	Sample could not be analyzed, heavy oil emulsion formed.
(3)	Values reported as ND are included in the average value as zero. Values reported as NA are not
included.
(4)	Average of all values on Tables VII-2 and VII-3.
(5)	For C&TT abbreviations, see Table VII-I.
(6)	Treated effluent samples were taken when no wastes from the recirculation mill of concern were entering the treatment
system. Therefore, this data will not be used for limitation justification.
* : Detected at a value Less than 0.010 mg/l.
**i value less than 0.000001 lbs/1000 lbs. •
NA: Not analyzed#
ND: Not detected.

-------
TABLE VI1-4
Raw Wastewater
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
ORIGINAL GUIDELINES SURVEY
COLD ROLLING - COMBINATION
Plant Code
Reference Code
Sample Point
Flow, gal/ton
Total Suspended Solids
Oil & Grease
Dissolved Iron
pH
m:
g/1
DD-2
584E-01
1
512
987
1,399
7.8
5.7
lbs/1000 lbs mg/1
2.11
2.99
0.017
260
619
NA
YY-2
432D-01
4
138
7.1
Average
325
lbs/1000 lbs mg/1 lbs/1000 lbs
0.15
0.36
NA
624 1.13
1,009 1.67
7.8 0.017
5.7-7.1
Treated Effluents
Plant Code
Reference Code
Sample Points
Flow, gal/ton
C&TT
Total Suspended Solids
Oil & Grease
Dissolved Iron
pH
mg/1
6
4
0.04
DD-2
584E-01
2
512
Chem. Treat.
Lagoons
lbs/1000 lbs mg/1
YY-2
432D-01
5
138
Chem. Treat. &
Lagoons
0.013
0.085
0.000085
16
6
NA
lbs/1000 lbs
0.0092
0.0035
NA
7.7
8.2
NA: Not analyzed
82

-------
TABLE VI1-5
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
TOXIC POLLUTANT STUDY
COLD ROLLING - COMBINATION
Raw Wastewater
Plant Code
Reference Code
Sample Point
Flow, gal/ton
Total Suspended Solids
Oil & Grease
Dissolved Iron
pH
115 Arsenic
119	Chromium
120	Copper
124 Nickel
128 Zinc
Treated Effluent
103
0856F-01
D
112
mg/1
lbs/1000 lbs
NA
NA
1563
0.73
NA
NA

6.6
0.16
0.000075
0.03
0.000014
0.89
0.00042
0.21
0.000098
0.15
0.000070
Overall, v
Average
254
mg/1
lbs/1000 lbs
624
1.13
1194
1.36
7.8
0.0167

5.7-7.8
0.16
0.000075
0.03
0.000014
0.89
0.00042
0.21
0.000098
0.15
0.000070
Because of the difficulty in obtaining treated effluent samples at the central treatment
system at this plant, no samples were taken during the plant visit.
(1) Average of all values on Tables VII-5 and VII-6.
NA: Not analyzed
83

-------
TABLE VI1-6
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
ORIGINAL GUIDELINES SURVEY
COLD ROLLING - DIRECT APPLICATION
Raw Wastewater
Plant Code
Reference Code
Sample Point
Flow, gal/ton
Total Suspended Solids
Oil & Grease
Dissolved Iron
pH
Treated Effluents
Plant Code
Reference No.
Sample Point
Flow, gal/ton
C&TT Codes
Total Suspended Solids
Oil & Grease
Dissolved Iron
pH
VV-2
584F-04
1
1,200
mg/1	lbs/1000 lbs
43	0.22
468	2.34
NA	NA
6.0
VV-2
584F-04
3
1,200
SS.SL
mg/1	lbs/1000 lbs
36	0.18
9	0.045
NA	NA
7.1
NA: Not applicable
84

-------
TABLE VI1-7
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
TOXIC POLLUTANT STUDY
	COLD ROLLING - DIRECT APPLICATION	
Raw Wastewater
Plant Code	105	106	107
Reference Code
Sample Point
Flow, gal/ton
584F-04
D
424
112B-
-01S03-06
B
670
176-02
C
233
Average
442
Overall, .
Average
632



iba/

lbs/

lbs/

lba/

lbs/


¦k/i
1000 lbs
¦8/1
1000 lbs
¦g/1
1000 lbs
¦g/1
1000 lbs
¦fi/1
1000 lbs

Total Suspended
290
0.51
99
0.28
15
0.015
135
0.27
112
0.26

Solid*











Oil 4 Greaae
1.861
3.29
1605
4.48
178
0.17
1215
2.65
1028
2.57

Dissolved Iron
23.3
0.041
NA
NA
NA
NA
23.3
0.041
23.3
0.041

pH
7
.2
6.5-9.0
6.7-7
.7
6.5
-9.0
6.0
-9.0
4
Benzene
*
**
MS
ND
ND
ND
*
**
*
**
6
Carbon Tetrachloride
0.03
0.000058
ND
ND
ND
ND
0.01
0.000019
0.01
0.000019
11
1,1,1-Trichloro-
0.14
0.00025
*
0.000028
ND
ND
0.05
0.000093
0.05
0.000093

ethane










78
Anthracene
ND
ND
*
0.000028
0.10
0.000098
0.03
0.000042
0.03
0.000042
85
Tetrachloroethylene
0.08
0.00015
ND
ND
ND
ND
0.03
0.000050
0.03
0.000050
115
Arsenic
0.03
0.000053
0.02
0.000056
ND
ND
0.02
0.000036
0.02
0.000036
117
Berylliua
*
**
*
0.000028
0.02
0.000019
0.01
0.000019
0.01
0.000019
119
Chroaiiai
0.17
0.00030
*
0.000028
0.10
0.000098
0.10
0.00014
0.10
0.00014
120
Copper
0.24
0.00042
0.2
0.00056
0.05
0.000049
0.16
0.00034
0.16
0.00034
122
Lead
0.42
0.00074
*
0.000028
0.80
0.00078
0.41
0.00052
*
0.000028
124
Nickel
0.35
0.00062
0.05
0.00014
0.50
0.00049
0.30
0.00042
0.30
0.00042
128
Zinc
0.20
0.00035
0.2
0.00056
0.03
0.000029
0.14
0.00031
0.14
0.00031

-------
TABLE VII-7
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
TOXIC POLLUTANT STUDY
COLD ROLLING - DIRECT APPLICATION
PAGE 2	
Treated Effluent
00
CT\
Plant Code
Refererence Code
Saaple Point
Flow, gal/ton
CtTT Codes
105
584F-04
F
424
NA,EB,SS
(2)
lbs/
106
112B-01S03-06
(C/C+D)E
670
E,SS,FSP,NW,T
lbs/
(3)
107
176-02
NA
233
Central
Treafent
lba/


28l±
1000 lbs
ng/1
1000 lbs
mg/1 1000 lbs

Total Suspended
295
0.52
28
0.00039
Ho treated

Solids




effluent samples

Oil & Grease
1,351
2.39
15
0.0027
taken at this

Dissolved Iron
167
0.30
NA
NA
plant.

pa
3.
.3
Onk

4
Benzene
*
**
*
**

6
Carbon Te trachloride
0.04
0.000076
ND
ND

11
1,1,1-Trichloro-
0.2
0.00034
*
0.000029


e thane





78
Anthracene
ND
ND
*
0.000016

85
Tetrachloroe thylene
0.07
0.00013
*
0.000049

115
Arsenic
0.03
0.000055
*
**

117
Berylliua
0.02
0.000035
*
0.000029

119
Chroaiua
0.24
0.00042
*
**

120
Copper
0.45
0.00080
0.018
**

122
Lead
0.60
0.0011
0.05
**

124
Rickel
0.50
0.00088
0.05
**

128
Zinc
0.68
0.0012
1.6
**

* s Value leaa than 0.010 ag/1
**: lbs/1000 lba values less than 0.000010
(1)	Average of all values on Tables VII-8 and VI1-9.
(2)	Discharge goes to lagoons for further treatment.
(3)	lbs/1000 lba vales calculated. The values shown can not be derived front
concentrations and flow value shown.

-------
TABLE VI1-8
SUMMARY OF LONG-TERM DATA
COLD ROLLING
Plant Code
C&TT Codes
0684F-03
EBiGF tSS
(1)
0920G-(01&02)
EB,GF,CL,SS tCNT


No. of


Stand.
No. of

Parameters
Samples
Hi8h
Mean
Deviation
Samples
High Mean

Total Suspended
80
1,363
113
188
195
81.0 25.0

Solids







Oil & Grease
79
147
17.7
22.0
268
66.0 19.2

pH
1,206
13.6
10.0
0.9
58
2.7 to

Phenols
7
1.4
0.4
0.5
0
-
118
Cadmium
11
0.012
0.0069
0.0039
0
-
119
Chromium
11
0.13
0.044
0.037
0
-
120
Copper
11
0.13
0.071
0.037
0
_
121
Cyanide
7
0.063
0.029
0.020
0
-
122
Lead
11
1.16
0.059
0.039
0
-
124
Nickel
11
0.08
0.054
0.022
0
_
128
Zinc
78
80.0
4.6
10.6
0
-
Stand.
13.3
9.6
(1) The discharge receives additional treatment prior to discharge to a receiving stream.
87

-------
PROCESS- COLD ROLLING-RECIRCULATION
PLANT:	0
PRODUCTION:
SERVICE
WATER
COLD
MILL
241 l/kkg
(58 GAL/TON)
CAUSTIC SODA
ALUM
SURFACE
OIL
X
OO CP
WASTE OIL HAULED AWAY
BY PRIVATE CONTRACTOR
-&r
TO STREAM
237 l/kkg
(57 GAL/TON)
/\ SAMPLING POINTS
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLING-RECIRCULATION
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
DWN. 2/2/79
FIGURE 1HI-I

-------
COLD
ROLLING
MILL
28.4 l/SEC
(450 GAL/MIN)
FILTER
SOLIDS DISPOSAL
SAMPLING POINTS
PROCESS:
COLD ROLLING-RECIRCULATION
PLANT".	X
PRODUCTION: 106 METRIC TONS STEEL/TURN
017 TONS STEEL/TURN)
0.01 l/SEC
(.2 GPM)
WASTE OIL
10,000 GAL
WASTE OIL
10,000 GAL
WASTE
TO BE
REPROCESSED
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLING"RECIRCULATION
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
DWN. 2/3/79
FIGURE 3ZII-2

-------
WELL WATER
3.8 l/SEC
(60 6PM)
48 l/SEC (760 GPM)
5 STD. TANDEM
COLO MILL
I
1
20 l/SEC
(320 GPM)
CLARIFIED WATER
(FROM HOT STRIP MILL)
TREATED
RIVER WATER
r-TRE
CONTINUOUS STRIP
PICKLERS (2 LINES)
SPENT
EMULSION
TANKS (2)
COLD MILL
RINSE WTR.
SURGE TANW2)
I
ACID RINSE
WTR. SURGE
TANKS (2)
72 l/SEC—
(t 140 GPM)

AGITATION
FLASH
TANK
AGITATION
AERATION
TANK
AERATION
TANK
J
PROCESS-" COLD ROLLING RECIRCULATION-,
PICKLING-HCI-CONTINUOUS RINSE
PLANT: BB-2
PRODUCTION: (COLD ROLLING):
1633 METRIC TONS OF STEEL/TURN
(1800 TONS OF STEEL/TURN)
(PICKLING):
6676 METRIC TONS OF STEEL/DAY
(7360 TONS OF STEEL/DAY)	
SPENT PICKLE
—71
LIQUOR
1 4
STORAGE
TO HCI RECOVERY AT AN OFF-SITE LOCATION
OR DISPOSAL AT AN ON-SITE DEEP WELL
113,500,000 1(30,000,000 GAL.) LAGOON
r*
COAGULANT AID
72 l/SEC —
(1140 GPM)
LIME
FLOCCULATION
TANK
NEUTRAL
IZATION
TANK
RECIRCULATED
^-SLUDGE
16.8 M
	I 55')0IA _
Q.27 l/SEC/M2
(0L4 GPM/FT2)
r^r
COAGULANT AID
FLOCCULATION
TANK
RECIRCULATED
y-SLUDGE
I6.8M(55')DIA
0.27 l/SEC/M
(0.4 GPM/M*)'
69 l/SEC
(1100 GPM)
TO RECIEVING
STREAM
VACUUM FILTERS(2)
T0«
DUMP
VACUUM FILTERS (2)
SAMPLING POINT
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLING 8 HCI PICKLING
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
Dwn.4/19/79
FIGURE 2H-3

-------
PROCESS: COLD ROLLING-RECIRCULATION
PLANT:EE-2
PRODUCT ION =935 METRIC TONS STEEL/TURN
U030 TONS STEEL/TURN)
WASTEWATERS FROM ALL
OTHER PLANT FACILITIES
2500-2600 l/SEC
(39,600-44,400 GPM)
LAGOON * I
CENTRAL
PLANT WASTE
TREATMENT
FACILITIES
COLO MILL \
OIL 1
wcentrationJ
TANK /
SERVICE
WATER
COLD
MILL
2.33 l/SEC
(37 GPM)
LAGOON *2
SEC A
GPM) / 2
2650 l/SEC
(42,000 <
TO
OUTFALL
OIL
RECOVERY
PLANT
SAMPLING POINT
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLING
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
FIGURE 2H-4

-------
U3
fo
PROCESS:
COLO ROLLING-RECIRCULATION
H CI "CONTINUOUS CONCENTRATED
PICKLING-HCI-ACID REGENERATION
X-2
(COLD ROLLED)
685 METRIC TONS OF STEEL/TURN
(755 TONS OF STEEL/TURN)
(PICKLING)
1380 METRIC TONS OF STEEL/DAY
PLANT
PRODUCTION:
CLARIFIER
(4 UNITS)
1521 TONS OF STEEL/DAY)
TO VACUUM
RESERVOIR
(MILL WATER
SUPPLY)
FILTERS 8LANDFILL
NC COOLING
9.5 l/SEC
(150 GPM)
CITY
RINSE 31.5 l/SEC
(500 GPM
HEATING STEAM
l/SEC(50 GPM)
'CONTINUOUS
iPICKLING
f yMILL WATER
FILTERED WATER
TANDEM
COLD
Ml LL
S.N. A. P.
PICKLER
PICKLER
N ON-CONTACT
COOLING
a RINSE
WATERS
467 l/SEC
(7,400 GPM
TO OTHER MILL AREAS
4421	;
l/SEC
Ai /R700GPM)
2.52 l/SEC
(40 GPM1
CLARIFIER
SETTLER
EFFLUENT
n\
WASTEWATER
DISCHARGE
r
0,63 l/SEC
(10 GPM)
ANTHRAFILT
FILTER
WASTE OIL
(FLOTATION
TANK)
TREATMENT
ACID
ENERATION
PLANT
0.63 l/SEC
(10 GPM)
58 l/SEC
(25 GPM)
47.3
I (750 GPM)
COLDJJOUJNG WL^.
HCI
REGENERATIONj
ENVIRONMENTAL
PROTECTION
AGENCY
STEEL INDUSTRY STUDY
COLD FORMING AND HCI PICKLING
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
TO SEWER
A SAMPLING POINT
FIGURE

-------
ALL OTHER PLANT
WASTEWATER
COLD
ROLLING
MILL

7.38 l/SEC
(117 GPM)
ROLLING SOLUTION
MAKE-UP
INDUSTRY SUPPLY WATER
SAMPLING POINT
PROCESS: COLD ROLLING-RECIRCULATION
PLANT- XX-2
PRODUCTION'- 363 METRIC TONS/TURN
1400 TONS/TURN)
OIL
I
18 ACRES
DISCHARGE
TO RIVER
3680 l/SEC
(58.333 GPM)
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLING
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
DWN.2/2/7S
FIGURE 3ZE-6

-------
SOLUBLE
OIL
WASTES
HOLDING
TANK
ACID
STEAM
HEATING
SKIM A
TTLIN6
TANK
KIM AND
SETTLING
TANK
RECLAIMED
SKIMMED OIL
TANK
PROCESS: COLD ROLLING-RECIRCULATION
plant: ioia a ioib
PRODUCTION1 IOlA:83t Metric Tons/Turn
1913 Tons/Turn)
!OIB: 512 Metric Tons/Turn
(563 Tons/Turn)
BREAK
TANK

RECLAIMED
.OIL IS
HAULED
AND BURNEO
IN BOILERS
STEAM
HEATING
WASTES AT FINISH OF
FILTRATION CYCLE
ULTRAFIL-
TRATION
UNIT
CLEANING
TANK

AC D
BREAK
STEAM
HEATING
DISCHARGE
(PERMEATE)
TO POTW
IOIA: |2,350 gpd
IOIB: 14,705 gpd
A
SAMPLING POINT
STEAM
HEATING/A
CITY WATER
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLINS
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
FIGURE 3ZE-7

-------
10
cn
6.62 I/sec
(IOH gpm) PICKLE ACIO
HAW WATEH 20% HCl
0.375 iJiec
(5.94 gpm)
\
7^
RAW WATER
(23.8 gpm)
1.5 l/£ec
PROCESS: S-COLD ROLLING - RECIRCULATION
PLANT".	102
PRODUCTIONS3201 METRIC TONS OF STEEL/TURN
(3530 TONS/TURN)
WET
LOOPING
PIT !
*4 PICKLING LINE
HCl CASCADE RINSE
CASCADE
RINSE
£
.(215 gpm
136
lAec
FUME
SCRUBBER
8CT HSM
o
£
ftlui
	ft
56"
TANDEM
MILL
1.87 t/sec
(29.7 gpm)
A
Ul
. ^ CD
^ 9 CD
<0 & ic
K> O
— CM CO
UJ
3
:	*
OUTFALL
TO LAKE
ACIO
SUMP
*5 PICKLE
LINE
	1	
J \_
BCr TANDEM
r*
£
1
#3

*2
COLDMILL

COLDMILL
SPENT ACID

SPENT ACID
(ONLY 				,
»3 C0LDMILl4/^t82.6 qpm)j
ACIO WASTES) ~~"5.2I l/sec
SPENT ACID STORAGE TANKS

3 COLD ROLLED STRIP MILL
( 2±jl
I 56* R
*5 PICKLING LINES
80 TANDEM MILLS J
^ NORMALIZING
LINE
ACID RINSE
I 1


(2U29 gpm)
1333 |/4ec
(4)FLOCCULATING CLARIFIERS
CLARIFIER
DISTRIBUTION
A
80 HOT
STRIP
MILL
BOX	^
1.310 l/sec (DISTRIBUTION
20.767gpm)
D.I.W.
WET WELL ^ ,
[362 gpm)
2234 (tec
*3 COLO
STRIP MILL
PRETREATMENT
FACILITIES
(SCALPING PITS)
BOX
8 MIXING
CHAMBER
—f£y»
(362 gpm)
22.84 l/sec
HOUSE
/\ SAMPLING POINT
	PRODUCT FLOW
DEEP WELL
ACID INJECTION
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLING - ACID PICKLING
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
CWN.6/27/78
FIGURE m- 8

-------
tD
INTAKE a
WATER ZLT
¦ OIL
PROCESS:
COLO ROLLHXC
RECIRCULATION
PLANT: 104
PRODUCTION! 496 metric tons/turn
(545 tons/turn)
CLEAN WATER
SUMP
-47.4 lAec
(750 gpm)
COLD
A
MILL
HYDROMATION
FILTERS
BATCH DUMP-
of 40,000 gallons
once/week
DIRTY
WATER
SUMP
-$ 54" COLD MILL
-{ MISC. COLD MILL WASTES
-f 44" COLD MILL
EMULSION
BREAKING
AIDS
OTHER
WASTES
OIL
J
A
\ * ¦
—— ——¦






	/dV
~TO OUTFALL
SURGE
TANK
4.8 I/sec
"(76.5 gpm)
(Continuous)
(6' * 15')
(6* * 15')
SETTLING TANK
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLING-RECIRCULATION
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
Own. 11/1/79
FIGURE 3Zn-9

-------
r~
DECANT
TANKS
FUEL OILS
DECANT
TANKS
PALM OILS
OILS FROM
LAGOON
y\
FILTER
CAKE
RECIRCULATION \
MILL WASTES ^
""WET
SLUDGE
PROCESS: COLD ROLLING-DIRECT APPLICATION
AND RECIRCULATION
PLANT1105
PRODUCTION- RECIRCULATING MILLS
1060 Metric Tons Steel/Turn
(1169 Tons Steel/Turn)
DIRECT APPLICATION MILL
418 Metric Tons Steel/Turn
(461 Tons Steel/ Turn j
VACUUM
FlLTER
TO SKIMMERS
SLUDGE
WASTE OIL
STORAGE
TANKS
FUEL OILS
SULFURIC ACID ,,
H2S04
STEAM
FILTRATE
6300 GAL.
COOKER
BATCH
PROCESS
WATER
TO
SKIMMERS

2CX000 GAL. BATCH
(1.000 6PM*4flwHEN (2)
63.1 l/SEC. JRUNNING 1
HOLDING
SKIMMER
SKIMMER
NOTES-(I) SAMPLE POINTsAaNdA
REPRESENT RAW WASTES AND TREATED
EFFLUENT, RESPECTIVELY, FROM THE
DIRECT APPLICATION MILLS.
(2)	SAMPLE POINT A REPRESENTS THE
RAW WASTES FROM THE RECIRCULATION
MILL. A SEPARATE TREATED EFFLUENT
SAMPLE WAS NOT AVAILABLE SINCE
THESE WASTES ARE ADMIXED WITH
DIRECT APPLICATION MILL WASTES
DURING TREATMENT.
(3)	MEASURED FLOW VALVE
(4)	FLOW ESTIMATED FROM COMPANY
DATA.
WASTE OIL
STORAGE
TANKS
PALM OILS
DIRECT
APPLICATION
MILL WASTES
25.7 l/SEC. AVG.
(407 GPM) AVG.®
25.7 l/SEC
(407 6PM)
TO LAGOONS
RECOVEREO PALM
OR FUEL OILS
FROM TANDEM
MILLS
SAMPLING POINT
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLING-DIRECT APPLICATION 8 RECIRCULATION
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
Dwg£/I0/71
FIGURE 301-10

-------
10
00
RECIRCULATED
Oily Sludge
to Disposal
City Water
Make-up
-4.7 l/sec
(75 gpm)
(Design)
HEAT
EXCHANGER
^txh
PROCESS"- Cold Rolling-Recirculation ond
Direct Application
PLANT: 107
PRODUCTION1 Recirculation Mill"36.4metric tons/turn
(40 tons/turn)
Direct Application Mill" 12.2 metric tons/turn
(13.4 tons/turn)
FILTER
	
__
CLEAN
DIRTY
TANK
TANK.
Rolling oil
manually
applied-
-City water for
roll colling


DIRECT
APPLICATION
MILL
-0.4 l/sec. (6.5 gpm) ~Avg.
Ronge'-0"0.9 l/sec(0~I4.6 gpm)
COOLING
TOWER
Batch discharge of
970 gallons every
four weeks.	
(Heat Exchanger was
not used during
sampling survey)
• Once- through discharge
to central treatment
Slowdown to
Central
Treatment
NOTE
Coils processed at the recirculating
mill on the first day of sampling were passed
through the mill at least four times. Tonnage for
this day was calculated by multiplying the
processed tonnage by four.
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLING-RECIRCULATION a DIRECT APPLICATION
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
Own. S/27/80
FIGURE 3ZE-II

-------
PROCESS: COLD ROLLING- COMBINATION
PLANT:DO-2
PRODUCTION- 630 Metric Tons Steel/Turn
(695 Tons Steel/Turn)
WASTE
INFLUENT
-46.7 l/SEC
(740 6PM)
INTERCEPTOR
TANKS
CHEMICAL ADDITION
a MIXING
INTERCEPTOR
TANKS
j v
TO RECEIVING
STREAM
SLUDGE TO
OIL INCINERATION
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLING
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
OIL SKIMMINGS
TO
OIL RECOVERY
A SERVICE WATER
A SAMPLING POINT
D«qj6*/7g W*t2-2/23/76
FIGURE 5H-I2
FLOCCULATION a
SEDIMENTATION
FLOCCULATION a
SEDIMENTATION

-------
PROCESS: COLD ROLLING-COMBINATION
PLANT:	YY-2
PRODUCTION: 1202 METRIC TONS/TURN
(1325 TONS/TURN)
OTHER PLANT
WASTEWATER
29.7 l/SEC
(470 GPM)
1262 l/SEC
(20,000 GPM)
TERMINAL
TREATMENT
PLANT
COLO ROLLING
MILL
DISCHARGE TO
RECEIVING STREAM
A'
SAMPLING POINT
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLING
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
DWN. 2/2/79
figXjrehe-13

-------
4 STAND MILL
PROCESS1 Cold Rolling-Combination
Oil Solutions
PRODUCTION- 797 Metric Tons/Turn
(876 Tons/Turn)
Water
52.4 l/sec
(830 gpml
e >
Pickling
Wastes-
2.5 l/sec—
(40 gpm)
7.9 l/sec
(125 gpm)
Clean
Oil
Other
Waste
Sources
Misc. Waste
Sources from
4 Stand Mill
Galvanizing
Wastes-
1.9 1/sec-
(30 gpm)
Make-up
Water—
12.6 l/sec-
(200 gpm)
< >
OIL
>To Storage
—77.7 l/sec
i (1230 gpm)
To Other Treatment
Componants
OIL
RECIRCULATION
SUMP
Dump once every
two weeks
(16,000 gal)
COLLECTION
SUMP
/^SAMPLING POINT
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLO ROLLING-COMBINATION
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
FIGURE 3ZH-I4

-------
Service
Water-
COLO
MILLS
151.6 l/sec (2400 gpm!
(Continuous)
TANDEM MILL
A SAMPLING POINT
PROCESS: Cold Rolling-Direct Application
PLANT 106
PRODUCTION1 1564 metric tons/turn
11718 tons/turn)
Galvanizing
Scrubber
Water
LIME
Pickling
Rinse Water
100.4 l/sec
(1590 gpm)
SAND
FILTERS
<12 each)
-15.8 l/sec
(250 gpm)
Recycled Stodge
267.8 l/sec
(4240 gpm)
Sludge to
Storage
(~ 55,000 gal/wk)
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD ROLLING-DIRECT APPLICATION
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
Dwn.6/27/60
FIGURE 3ZH-I5

-------
COLD FORMING SUBCATEGORY
COLD ROLLING
SECTION VIII
COST, ENERGY, AND NONWATER QUALITY IMPACTS
Introduction
This section presents the incremental costs incurred in the
application of the different levels of pollution control technology to
the cold rolling subdivision based upon the development of treatment-
system models. Also included are energy requirements, the nonwater
quality impacts, and techniques, magnitude, and costs associated with
the application of the BPT, BAT, NSPS, PSES, and PSNS levels of
treatment. In addition, solid waste generation rates, the BCT cost
comparison, and the consumptive use of water are discussed.
Actual Costs Incurred by the Plants
Sampled or Solicited for this Study
The effluent treatment costs supplied by the industry for the cold
rolling subdivision during sampling visits and in response to the
D-DCPs are presented in Tables VII1-1 through VII1-3. These costs
have been updated to July 1, 1978 dollars. Many of the industry
responses included total costs for central treatment systems. Where
possible, these costs were analyzed and allocated to cold rolling
wastewaters.
Because of the extensive use of central treatment for cold rolling
wastewaters,, the Agency could not directly verify its model-based cost
estimates for separate treatment of cold rolling wastes with cost data
reported by the industry for central treatment systems. However, the
Agency did compare its model-based treatment costs with industry costs
for several central treatment systems by summing the model-based
treatment costs for each subcategory included in the existing central
treatment systems. The results of this comparison, which are
presented in Volume I, demonstrate that the Agency's costing
methodology accurately reflects industry costs for central treatment
facilities in general, and for those systems including cold rolling
wastewaters in particular. In fact, as shown by the data presented in
Volume I, the Agency's cost estimates for separate treatment for
finishing operation wastewaters are likely to be significantly higher
than industry costs for central treatment.
Control and Treatment Technologies (C&TT)
Recommended for Use in the Cold Rolling Subdivision
A review of the treatment components included in the BPT and BAT
alternative treatment systems is presented in Table VIII-4. The
following items are described for each treatment method in the C&TT
table.
103

-------
1.	Status and reliability
2.	Problems and limitations
3.	Implementation time
4.	Land requirements
5.	Environmental impacts other than water
6.	Solid waste generation
Cost, Energy, and Nonwater Quality Impacts
General Discussion
This section addresses the additional funding that will be required to
install and operate the various BPT, BAT, NSPS, PSES and PSNS
alternative treatment systems. In addition, it contains a discussion
of the air pollution, water consumption, energy requirements, and
solid waste disposal impacts associated with each level of treatment.
Costs and energy requirements are estimated from alternative treatment
systems developed in Sections IX through XIII of this report and are
presented in the tables and text of this section.
Estimated Costs for the
Installation of Pollution Control Technologies
A. Costs Required to Achieve the Proposed BPT Limitations
The Agency estimates that the industry will need to spend $30.3
million (capital cost) to bring present water pollution control
facilities at cold rolling operations into compliance with the
proposed BPT limitations. This $30.3 million is out of a total
estimated capital cost of $52.3 million for BPT systems. In
addition, the Agency estimates that these systems will require
$9.7 million of annual costs to operate. This annual cost
estimate takes into account $7.1 million for the recovery and
sale of the waste oil solutions. BPT model cost data are
provided in Tables VII1-5 through VII1-7.
To estimate the above costs, the Agency developed model plants
based upon average plant sizes at the model flow rates (see
Section X for a development of these flow rates). Plant by plant
capital cost estimates were then made by factoring the production
of each plant to the model plant size by the "six-tenth" rule.
This method yields cost estimates for the subcategory which are
representative of the actual costs spent in the industry. Cost
comparisons presented in Volume I verified the accuracy of this
costing methodology. Because the DCP responses listed the
installed treatment components, costs for "in-place" components
were separated from the total estimated cost. These capital cost
tabulations are shown in Tables VIII-8 through VIII-12.
The cost estimates were developed based upon the assumption that
all plants would install separate wastewater treatment systems.
However, as pointed out earlier, wastewaters from most cold
rolling operations are treated in central treatment systems.
Treatment in central systems reduces costs because of economies
of scale and because duplicate equipment components are
104

-------
eliminated. Hence, the Agency expects that the actual cost
requirements for cold rolling operations will be less than shown
above.
B. Costs Required to Install BAT Treatment Systems
The Agency considered three BAT alternative treatment systems for
cold rolling. The details and descriptions of, and rationale for
selecting these alternatives are outlined in Section X. The
model costs involved in applying each of the BAT alternative
treatment system to the BPT model treatment system are presented
in Tables VIII-13 through VIII-15. The estimated investment and
annual costs for each BAT Alternative follows. These costs were
determined by multiplying the unit model costs by the number of
cold rolling operations requiring each component.
C.	BCT Cost Comparison
The BCT treatment system passed the BCT cost test for both direct
application and combination cold rolling operations. Refer to
Section XI for a complete review of the BCT cost test analysis.
However, the BCT treatment system for recirculation mills did not
pass the BCT cost test. The cost test analysis for cold rolling
is presented in Table VI11-16. This cost test was completed by
dividing the annual cost to achieve the BCT system by the annual
loading of conventional pollutants removed from BPT to BCT.
D.	Costs Required to Achieve NSPS
The Agency developed two NSPS alternative treatment systems for
those cold rolling facilities. The NSPS treatment systems are
similar to the BPT and BAT treatment systems. Their costs are
presented in Table VIIl-17.
E.	Costs Required to Achieve the Pretreatment Standards
Pretreatment standards apply to those new and existing plants
that discharge to POTW systems. The Agency developed two
pretreatment alternative treatment systems for cold rolling
operations. The model costs for the Pretreatment Alternatives
for Existing Sources (PSES) are presented in Table VIII-18
through VIII-20. Model costs for the Pretreatment Alternatives
for New Sources (PSNS) are identical to NSPS costs and are
presented in Table VIII-17.
Total
Capital ($ x 10~«)	Annual
Alternative In-Place Required ($ x 1Q-*)
BAT-1
BAT-2
BAT-3
0
0
0
6.07
47.1 5
63.89
1.10
85.38
12.94
105

-------
Energy Impacts Due to the
Installation of the Requisite Technologies
Moderate amounts of energy are required for the BPT and BAT-1
treatment systems. BAT Alternatives 2 and 3 are very energy
intensive, as compared to BPT and BAT-1 treatment systems. The energy
requirements for the various levels of treatment are presented below:
A.	Energy Impacts at BPT
The estimated energy .requirement of 30.5 million kilowatt hours
per year for BPT is based upon the installation of the model
treatment system for all cold rolling operations with flows
similar to that of the treatment model. This estimate represents
0.053% of the 57 billion kilowatt hours of electricity used by
the steel industry in 1978. These energy requirements are not
excessive compared to the pollution control benefits derived from
compliance with the proposed BPT limitations.
B.	Energy Impacts at BAT
Additional energy will be required at BAT due to the installation
of additional energy consuming equipment. The additional energy
needs for the three BAT alternative treatment systems, along with
the percentage of total energy consumption for each BAT
alternative, are summarized below.
BAT	kwh per	% of Industry
Alternative	year	Usage
No. 1	11.61 million	0.020
No. 2	68.66 million	0.12
No. 3	1.25 billion	2.19
C. Energy Impacts at NSPS and Pretreatment
The Agency did not estimate the total impacts for NSPS and PSNS
since an estimate of the number of new source cold rolling
operations were not made as part of this study. Energy impacts
for PSES are included in those considered for BPT and BAT above.
The energy requirements and annual costs for the model sized
plants are listed below:
106

-------
Energy (kw) Annual Cost ($)
NSPS & PSNS-1
14.8
3,100
NSPS & PSNS-2
22.5
4,700
Recirculation


PSES-1
20.6
4,300
PSES-2
35.4
7,400
Combination


PSES-1
150.9
31,500
PSES-2
339.6
70,900
D. Application


PSES-1
134.6
28,100
PSES-2
320.9
67,000
Nonwater Quality Impacts
In this analysis, the Agency investigated three impacts: air
pollution, solid waste disposal, and water consumption. A discussion
of these impacts is presented below.
A. Air Pollution
Only if the waste oils are incinerated could there be a potential
air pollution problem. Disposal by incineration is not a
requirement established by this regulation. However, the Agency
concludes that such impacts would not be significant provided
proper combustion and air emission controls were practiced.
B. Solid Waste Disposal*
The treatment components incorporated in both BPT and BAT
treatment systems generate large amounts of solid waste in the
form of sludges. These sludges result from the removal of
suspended solids and oil and grease. The following table
presents a summary of the quantity of solid waste produced with
both the BPT and BAT treatment systems for the cold rolling
subdivision.
Solid Waste Generation
	For Cold Rolling
Dewatered	Oil and
Treatment	Solids	Grease
Level	(Tons/Year) (Gal/Year)
BPT	127,550	44,500,000
BAT-1	3/450	76,700
BAT-2	3/450	76,700
BAT-3	8/628	153,394
As shown above, a large amount of solid waste is generated at the
BPT level of treatment, while the BAT treatment systems generate
lesser amounts. In addition, solid waste is generated at the
NSPS, and Pretreatment levels as noted below for the model
plants.
107

-------
Solid Waste Generation
For Cold Rolling
Treatment
Level
Dewatered
Sol ids
(Tons/Year)
Oil and
Grease
(Gal/Year)
NSPS-1
NSPS-2
696
696
0.49 million
0.49 million
PSES-1
PSES-2
696
696
0.49 million
0.49 million
PSNS-1
PSNS-2
696
696
0.49 million
0.49 million
The NSPS and Pretreatment models are similar to BPT/BAT treatment
systems. The solid waste generation, shown in the above table,
is based upon the sum of the BPT and BAT generation rates
previously established.
Some of the solid wastes result from the use of lime in the
treatment systems. Lime is used to raise pH levels after the
emulsion breaking step and can produce up to 8-10 tons of sludge
per day in the form of untreated calcium hydroxide, along with
precipitated calcium carbonates. Disposal of these sludges adds
significantly to costs, and care must be taken to prevent sludges
from redissolving and entering streams as runoff from landfill
sites.
Additional solids may be generated depending upon the BAT
alternative. If the filter system proposed in Alternative 1 is
installed, additional solid wastes will be produced when the
filters are backwashed. If the systems including activated
carbon are installed additional solid wastes will also be
generated as carbon that cannot be reactivated in the carbon
column system is disposed. However, the volume of sludges
generated at BAT is small compared to the amount generated at the
BPT level.
Notwithstanding the above, the Agency believes that the effluent
reduction benefits associated with compliance with the proposed
limitations and standards justify any adverse environmental
impacts associated with solid waste disposal.
C. Water Consumption
No significant water consumption is expected to occur at cold
rolling mills as a result of the installation of the alternative
treatment systems. Recycle systems are installed at
recirculation mills, but these are usually closed systems with no
inherent water consumption. There are no other opportunities for
water consumption in cold rolling operations.
108

-------
Summary of Impacts
The Agency concludes that the pollution control benefits described
below for the cold rolling subdivision justify any adverse
environmental impacts associated with energy consumption, air
pollution, solid waste disposal, and water consumption.
Effluent Loadings (Tons/Year)
Raw Waste Proposed BPT BAT
Proposed
BAT and BCT
Flow, MGD
Suspended Solids
Oil and Grease
Toxic Metals
Toxic Organics
39.4
39.4
39. 4
16,290
112,500
185
280
3,130
1 ,250
38
265
860
285
34
33
109

-------
TABLE VIII-1
EFFLUENT TREATMENT COSTS
GOLD ROLLING - RECIRCULATION
(All costs are expressed in July, 1978 Dollars.)
Plant Code
BB-2*
EE-2*
X-2Kl}
XX-2*
101
102*

Reference Code
060-03
1120-01
060B-03
6841-01
020B&020C
384A(02&03)
684F-03
Initial Investment Cost
1,361,231
436,693
2,469,600
430,091
712,200
1,782,070
863,564
Annual Cost







Cost of Capital
57,171
18,341
106,200
18,064
30,625
82,781
37,100
Depreciation
136,125
43,669
246,960
43,009
71,220
197,097
86,360
Operation and Maintenance
81,096
180,521
194,500
2,489
170,900
49,657
11,000
Energy, Power,
10,569
116,484
-
-
-
-
-
Chemicals, etc.







Other
-
-
-
-
-
36,583
56,800
TOTAL
284 , 959
359,015
594,860
70,563
272,745
366,118
181,360
$/Ton
0.17
0.26
0.93
0.22
0.57
0.39
0.19
(1)	Reported costs are for a treatment system which treats two cold rolling mills. Costs to treat the
individual operation sampled were unable to be broken out.
(2)	The costs for this operation were supplied in the response to the D-DCP.
*: Portion of costs attributable to this subcategory.

-------
TABLE VIII-2
EFFLUENT TREATMENT COSTS
COLD ROLLING - COMBINATION
Plant Code	DD-2*
Reference Code	584E-01
Initial Investment Cost	3,913,654
Annual Cost
Cost of Capital	164,373
Depreciation	391,366
Operation and Maintenance	250,105
Energy & Power	191,552
TOTAL	997,402
$/Ton	0.65
* Portion attributed to this subcategory only.
Ill

-------
TABLE VIII-3
EFFLUENT TREATMENT COSTS
COLD ROLLING - DIRECT APPLICATION
Plant Code
Reference No.
Initial Investment Cost
Annual Costs
Cost of Capital
Depreciation
Operation and Maintenance
Energy and Power
TOTAL
$/Ton
105*
584F-04
2,804,245
Annual costs
not available
since company
accounting pro-
cedures do not
segregate production
and pollution
operating costs.
Unk
* Portion attributed to this subcategory only.
112

-------
TABLE VIII-4
COKTROL AMD TREATMENT TECHNOLOGIES
	COLD BOLLIHC		
TrMtaenC and/or
Control Methods E^loyed
A. Oil separator - used to
treat wastewaters froa the cold
rolling sill to reaove any
floating oils that may be present*
B. Equalisaiton tank - to
protect treatment syste* fro
shock or high toxic loads.
C. Alua addition - used in
coo junction with Step D to
break eon la ion.
D. Acid addition - used to loner
the pR to 4-5, in conjunction with
Step Cf to break esilsion.
Status and
Reliability
Md8t Bills have oil separatora
of soae type with aost being
either surface skiaaing or
gravity separation types*
Practiced at amy aills in
cold rolling to equalise
oily wastes prior to further
treatment.
Widely practiced in cold
rolling "ill treataeitt
systeas.
Widely practiced in this
subcategory.
Probleas
and Liaitations
Primarily reaovea only
floating oils.
lapleaen
tation
Tiae
Land
Requiren
ilktS
Included Contained
in Step within an
B Iaple- equalisation
aentation tank, Step B.
tiae
Environaental
lap act Other
Than Water
None
Generally| no probleaa. 9 aontha 50'*50'
Sire is aost iapor-
tant paraaeter.
Increased cheaical	6 aonths
costs and aoae in-
crease in solids load.
Increased cost unless 6 aonths
source^ of acid exists
at plant.
No addi-
tional
space
required.
No addi-
tional
apace
required.
None
None
None
Solid Waate
Generation and
Priaary
Const ituenta
Recovered oils can
be reused in the
rolling aills, sold
to contractors who
reprocess used oils
or can be burned aa
a fuel.
Slight buildup of
solids in systea
which aust be
properly disposed.
Slight addition to
solid waste
generated.
None
E. Liae neutralisation - to
raise pV to 6-9 in a aixing
tank, following Step D.
Widely practiced at cold
rolling aills.
Increased cheaical
costs. Also, this
step generates a
significant solids
loading that requires
additional treatment,
before discharge.
onths 25 *3(25'
None
Can produce 6-10
tons of sludge per
day. This sludge
can be difficult
to dispose of
due to its
consistency.

-------
TABLE VIII-4
CONTROL AND TREATMENT TECHNOLOGIES
COLD ROLLING
PACK 2		
Treatment and/or
Control Method* Employed
F. Polymer addition - add
polymer or polyelectrolyte
to promote settling.
Status and
Reliability
Widely practiced in cold
rolling Hills throughout
the steel industry.
G. Air flotation * effluent	Deed by nunerous cold
from Step 7 treated vith air	rolling plants,
flotation, for solids
separation.
H. Settling lagoon - effluent	Widley practiced at many
fro* Step G settled in a settling mills in this subcategory
pond or lagoon (last step in BPT). and in ohter areas of the
steel industry.
I. Filtration - effluent from
Step H is treated by passage
through a mixed-media filter
unit (last step in BAT-l).
Used at several aills and
nunerous steel plants.
J. Activated carbon columns -
effluent from Step I is passed
through activated carbon columns
(last step in BAT-2).
Practiced at two plants in
the ateel industry, and also
in the organic chemicals and
petroleum industries.
Problems
and Limitations
Implemen-
tation	Land
Time Requirements
Environmental
Impact Other
Ulan Uater
Solid Waste
Generation and
Primary
Constituents
Increased chemical
costs.
6 months
No addi-
tional
space
required.
None
No significant
amount of sludge
generated.
Requires car not to 12
disturb flotants prior months
to removal.
25'*25'
(for all
rolling
operations).
Possibility of
obnoxious gases
in immediate area
surrounding the
unit.
Oils recovered from
flotation unit may
be reused, sold to
an oil reprocessing
contractor or used
as fuel.
Requires considerable
9-12
40'x40f
Possibility of
Sludges accumulate
space to intall.
months
(recircula-
producing ob-
in lagoons, must


tion)
jectional odors;
be periodically


210,x210l
aesthetically
removed and


(combination)
unattractive.
properly disposed


260'x260'

of.


(direct




application)


Will primarily remove
15-18
25,x251
None
Some additional
solids and oils. In-
months
(recircula-

sludge will be
creased capital and

te*40'

geaerated when the
operating costs.

(combination)

filters are


SO'xSO'

backwashed.


(direct




application)


Significant increase
18
SO'xSO"
Consumes energy
Spent carbon that
in capital and
months

to reactivate
cannot be reacti-
operating costs,


carbon.
vated must be
especially if on-site



disposed of.
carbon regeneration is




required.





-------
TABLE VIII-4
CONTROL AND TREATMENT TECHNOLOGIES
COLD ROLLING
PACE 3
Treatment and/or
Control Methods Employed
K. Evaporation - effluent from
Step J is passed through a
vapor decompression evaporation
system to achieve sero discharge.
L. Recycle - distillate quality
water from Step K is recycled
through the plant for reuse
(last Step in RAT-3).
Status and
Reliability
Not demonstrated in the
steel industry. However,
used at a few plants in the
power industry.
Widely practiced throughout
the iron and steel industry.
Problems
and Limitations
Requires maintenance
economics• Dependent
oa the integration of
this system into the
water cycle*
Essentially no
problems involved.
Implement
tation
Time
18
months
18
moaths
Land
Requires!
60,x60l
25**25'
Environmental
Impact Other
Ihan Water
Uses approxi-
mately 90 kuh/
1000 gallons
of feedwater.
None
Solid Waste
Generation and
Primary
Constituents
Slurry generated
in this process
must be dewatered.
Sludge generation
is increased.
None

-------
TABLE VII1-5
BPT MODEL COST DATA; BASIS 7/1/78 DOLLARS
Subcategory
Cold Forming
Cold Rolling
Recirculation
Carbon-Specialty
Model Size-TPD : 1700
Oper. Days/Year: 348
Turns/Day	: 	3
C&TT Step
A
B
c(2)
d(2)
E^
F
G
H
Total
-3
Investment $ x 10
43
49
81
76
83
78
72
27
509
Annual Cost $ x 10









Capital
1.8
2.1
-3.5
3.3
3.6
3.3
2.1
1.1
20.8
Depreciation
4.3
4.9
8.1
7.6
8.3
7.8
7.2
2.7
50.9
Operation & Maintenance
1.5
1.7
2.8
2.6
2.9
2.7
2.5
0.9
17.6
Sludge Disposal.
Energy & Power
-
-
—
-
-
-
-
0.2
0.2
—
—
0.3
0.2
0.5
0.5
1.2
—
2.7
Chemical Costs
-
-
0.9
0.4
0.5
1.3
-
-
3.1
Oil Disposal
0.8
—
—
—

—
—
—
0.8
TOTAL
8.4
8.7
15.6
14.1
15.8
15.6
13.0
4.9
BPT
96.1
Effluent 0uality(3)
Raw Waste





Effluent


Level





Level

Flow, gal/ton

25





25

Suspended Solids

1000





25

Oil & Grease

20000





10

Dissolved Iron

100





1.0

pH (Units)

6-9





6-9

6 Carbon Tetrachloride

0.02





0.02

11 1,1,1-Trichloroethane

0.10





0.10

23 Chloroform

0.10





0.10

24 2-Chlorophenol

6.00





6.00

34 2,4-Dimethylphenol

4.20





4.20

38 Ethylbenzene

0.07





0.05

55 Naphthalene

0.09





0.05

57 2-Nitrophenol

12.00





12.00

60 4,6-Dinitro-o-cresol

0.20





0.20

116

-------
TABLE VIII-5
BPT MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE 2
. (3)
Effluent Quality
Raw Waste
Level
65
Phenol
0.02
78
Anthracene
3.00
80
Fluorene
0.03
85
Tetrachloroethylene
0.30
86
Toluene
0.04
87
Tri chloroethylene
0.03
114
Antimony
0.03
115
Ars eni c
0.30
118
Cadmium
0.10
119
Chromium
2.00
120
Copper
4.20
122
Lead
2.70
124
Nickel
2.20
128
Zinc
2.00
130
Xylene
1.50
BPT
Effluent
Level
0.02
0.01
0.01
0.30
0.04
0.03
0.03
0.30
0.10
0.50
0.50
0.50
0.50
0.50
1.50
(1)	Costs are all power unless otherwise noted.
(2)	Treatment components are used in tandem.
(3)	All values are in rag/1 unless otherwise noted.
KEY TO C&TT STEPS
A:
Oil Separator
E
B:
Equilization
F
C:
Alum Addition
6
D:
Acid Addition to
H

break oil emulsion

Lime Neutralization
Polymer Addition
Air Flotation
Settling Lagoon
117

-------
TABLE VII1-6
BPT MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory
Cold Forming
Cold Rolling
Combination
Carbon-Specialty
Model Size-TPD
Oper. Days/Year
Turn8/Day
4400
348
C&TT Step
A
B
C(2)
D(2)
e(2)
F
G
H
Total
_3
Investment $ x 10
136
315
223
161
296
201
259
229
1820
Annual Cost $ x 10









Capital
5.8
13.6
9.6
6.9
12.7
8.7
11.1
9.8
78.2
Depreciation
13.6
31.5
22.3
16.1
29.6
20.1
25.9
22.9
182.0
Operation & Maintenance
4.7
11.0
7.8
5.6
10.4
7.0
9.0
8.0
63.5
Sludge Disposal^
-
-
-
-
-
-
-
7.4
7.4
Energy & Power
-
-
3.9
3.6
4.4
4.4
10.9
-
27.2
Chemical Costs
-
-
35.8
13.5
17.9
45.7
-
-
112.9
Oil Disposal
30.2
-
-
-
—
—
-
-
30.2
TOTAL
54.3
56.1
79.4
45.7
75.0
85.9
56.9
48.1
501.4
BPT
Raw Waste	Effluent
Effluent Quality	Level	Level
Flow, gal/ton	400	400
Susp. Solids	600	25
Oil & Grease	1000	10
Diss. Iron	10	1.0
pH, Units	6-9	6-9
6 Carbon Tetrachloride	0.02	0.02
11 1,1,1-Trichloroethane	0.10	0.08
23	Chloroform	0.15	0.10
24	2-Chlorophenol	3.00	3.00
34 2,4-Dimethylphenol	2.00	2.00
38 Ethylbenzene	0.03	0.03
55 Naphthalene	0.02	0.02
57 2-Nitrophenol	6.00	6.00
60 4,6-Dinitro-o-cresol	0.10	0.10
118

-------
TABLE VII1-6
BPT MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE TWO		
BPT
Raw Waste	Effluent
Effluent Quality
Level
Level
65
Phenol
0.10
0.10
78
Anthracene
0.20
0.01
80
Fluorene
0.01
0.01
85
Tetrachloroethylene
0.15
0.15
86
Toluene
0.02
0.02
87
Trichloroethylene
0.02
0.02
114
Antimony
0.02
0.02
115
Arsenic
0.10
0.10
118
Cadmium
0.08
0.08
119
Chromium
1.00
0.50
120
Copper
2.00
0.50
122
Lead
1.50
0.50
124
Nickel
0.90
0.50
128
Zinc
0.90
0.50
130
Xylene
0.35
0.35
(1)	Costs are all power unless otherwise noted.
(2)	Treatment components are used in tandem.
(3)	All values are in mg/1 unless otherwise noted.
KEY TO C&TT STEPS
Oil Separator
Equalization
Alum Addition
Acid Addition to break
oil emulsion
E:	Lime Neutralization
F:	Polymer Addition
G:	Air Flotation
H:	Settling Lagoon
119

-------
TABLE VIII-7
BPT MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory:	Cold Forming
:	Cold Rolling	Model Size-TPD :	2900
:	Direct Application	Oper. Days/Year:	348
:	Carbon-Specialty	Turns/Day	: 	3
C&TT Step
A
B
_s(2)
_D(2)
_e(2)
F
G
H
Total
_3
Investment $ x 10
194
407
289
208
392
284
371
342
2487
Annual Cost $ x 10









Capital
8.3
17.5
12.4
9.0
16.9
12.2
16.0
14.7
107.0
Depreciation
19.4
40.7
28.9
20.8
39.2
28.4
37.1
34.7
249.2
Operation & Maintenance
6.8
14.2
10.1
7.3
13.7
9.9
13.0
12.0
87.0
Sludge Disposal
-
-
-
-
-
-
-
12.2
12.2
Energy & Power
-
-
6.1
5.6
7.8
7.9
16.3
-
43.7
Chemical Costs
-
-
59.0
22.3
29.5
75.8
-
-
186.6
Oil Disposal
49.7
—
-
—
—
—
-
—
49.7
TOTAL
84.2
72.4
116.5
65.0
107.1
134.2
82.4
73.6
734.9
BPT
Raw Waste	Effluent
Effluent Quality	Level	Level
Flow, gal/ton	1000	1000
Suspended Solids	100	25
Oil & Grease	1025	10
Dissolved Iron	25	1.0
pH (Units)	6-9	6-9
4 Benzene	0.01	0.01
6 Carbon Tetrachloride	0.01	0.01
11 1,1,1-Trichloroethane	0.05	0.05
78 Anthracene	0.03	0.03
85 Tetrachloroethylene	0.03	0.03
120

-------
TABLE VIII-7
BPT MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE 2

BPT
Raw Waste
Effluent
Level
Level
0.02
0.02
0.01
0.01
0.10
0.10
0.16
0.15
0.40
0.40
0.30
0.30
0.15
0.15
. (3)
Effluent Quality
115 Arsenic
117 Beryllium
119	Chromium
120	Copper
122 Lead
124 Nickel
128 Zinc
(1)	Costs are all power unless otherwise noted.
(2)	Treatment components are used	in tandem.
(3)	All values are in mg/1 unless	otherwise noted.
KEY TO C&TT STEPS
A: Oil Separator	E: Lime Neutralization
B: Equilization	F: Polymer Addition
C: Alum Addition	G: Air Flotation
D: Acid Addition to	H: Settling Lagoon
break oil emulsion
121

-------
Plant
Code	TPD
0060	9435
0060B	2679
0112A	816
0112D	4107
0256A	276
0256B	180
0284A	219
0320	3295
£	0384A	9110
to	0396D	405
0396E	240
0432A	2817
0432B	1827
0432C	3132
0448A	780
0528B	2862
0580C	161
0584E	870
0584F	5613
0648	68
0684B	1569
0684F	5337
06841	2100
0760	659
0792B	666
0792C	375
TABLE VII1-8
BPT CAPITAL COST TABULATION
BASIS: 7/1/78 DOLLARS X 10
: FACILITIES IN PLACE AS OF 1/1/78
Subcategory: Cold Forming
: Cold Rolling - Recirculation
: Carbon
	C&TT STEP	
A
B
C
D
E
F
G
120
136
227
211
233
217
201
56
64
107
99
110
102
94
28
31
52
49
54
50
46
73
83
138
128
142
132
122
14
16
27
25
28
26
24
11
13
21
20
22
20
19
13
14
24
22
24
23
21
64
72
121
112
124
115
107
117
133
223
207
228
212
197
18
21
34
32
35
33
30
6
7
11
U
12
11
10
58
66
110
102
113
105
97
45
51
85
79
87
81
75
62
70
117
109
120
112
104
27
31
51
47
52
49
45
59
67
111
103
114
106
98
10
12
20
18
20
19
17
29
33
54
51
56
52
48
88
100
166
155
171
159
147
6
7
12
11
12
11
10
41
46
77
72
79
74
69
85
97
162
150
166
154
143
49
55
92
86
95
88
82
24
28
46
43
47
44
41
24
28
46
43
48
44
41
17
20
33
31
34
31
19
H
In
Place
Required
Total
74
845
574
1419
35
185
482
667
17
247
80
327
45
597
266
863
9
14
155
169
7
0
133
133
8
0
149
149
40
0
755
755
73
827
563
1390
11
29
185
214
4
0
72
72
36
417
270
687
28
73
458
531
38
506
226
732
17
45
274
319
36
209
485
694
6
0
122
122
18
95
246
341
54
560
480
1040
4
6
67
73
25
66
417
483
53
860
150
1010
30
216
361
577
15
15
273
288
15
0
289
289
11
46
160
206

-------
TABLE VII1-8
BPT CAPITAL COST TABULATION
PAGE 2		
C&TT STEP
Plant









In


Code
TPD
A
B
C
P
E
F
G
H
Place
Required
Total
0856P
822
28
31
53
49
54
50
46
17
28
300
328
0860B
6438
95
108
181
168
185
173
160
59
861
268
1129
0864B
4218
74
84
140
130
144
134
124
46
606
270
876
0948C
894
29
33
55
51
57
53
49
18
255
90
345










7608
8620
16228
Hote: Underlined costs represent facilities in place; where two figures appear in the same column, the underlined
portion is in place; the non-underlined portion remains to be installed.

-------
TABLE VII1-9
BPT CAPITAL COST TABULATION
BASIS: 7/1/78 DOLLARS X 10
i FACILITIES IS PLACE AS OF 1/1/78
Subcategory: Cold Fonaiitg
: Cold Rolling - Recirculation
: Specialty
C&TT STEP
Plant
Code
TPD
A
B
C
D
E
F
G
H
In
Place
Required
Total
0020B
1365
38
43
71
66
73
68
63
23
0
445
445
0020C
1975
62
70
117
109
120
112
56-47
21-17
77
654
731
0060D
2496
54
61
102
95
105
98
91
33
0
639
639
0060E
339
16
19
31
29
32
29
27
10
98
95
193
00601
16
3
4
5
5
5
5
4
2
0
32
32
0528
447
19
22
36
34
37
35
32
12
51
176
227
0684D
1011
31
36
60
55
61
57
53
19
50
322
372
0856E
249
14
15
26
24
26
25
23
8
0
161
161










*276
2524
2800
~Total does not include confidential plants.
Note: Underlined costs represent facilities in place, where two figures appear in the same column, the underlined
portion is in place; the non-underlined portion reaaina to be installed.

-------
TABLE VIII-10
BPT CAPITAL COST TABULATION
BASIS*. 7/1/78 DOLLARS X 10 3
; FACILITIES IB PLACE AS OF 1/1/78
Subcategory: Cold Forming
: Cold Rolling - Direct Application
: Carbon
C&TT STEP
Plant









In


Code
TPD
A
B
C
P
E
F
6
a
Place
Required
Total
0060
7323
151
416
296
212
396
269
269
297
0
2306
2306
0060B
1146
50
137
97
70
130
88
88
98
236
522
758
0112A
9624
177
490
349
250
466
317
317
350
1976
740
2716
0112B
12150
204
563
401
287
536
364
364
403
1507
1615
3122
0320
2310
75
208
148
106
198
135
135
149
0
1154
1154
0384A
13S6
55
151
108
77
144
98
98
108
163
676
839
0584A
1491
58
160
114
82
152
104
104
114
172
716
888
0584C
2102
71
197
140
100
187
127
127
141
339
751
1090
0584F
2949
87
241
172
123
229
156
156
172
783
553
1336
0684C
1143
49
136
97
70
130
88
88
98
147
609
756
0856P
804
40
110
79
56
105
71
71
79
255
356
611
0860S
855
42
115
82
58
109
74
74
82
447
189
636
0920A
1953
68
188
134
96
179
122
122
135
0
1044
1044
0920G
2348
76
210
150
107
200
136
136
150
362
803
1165
0948A
2880
86
237
169
121
226
154
154
170
959
358
1317










7346
12392
19738
Mote: Onderlined coats represent facilities in place, where two figures appear in the same column, the underlined
portion ia in place; the non-underlined portion reaains to be installed.

-------
TABLE VIII-11
BPT CAPITAL COST TABULATION
BASIS: 7/1/78 DOLLARS X 10
; FACILITIES XH PLACE AS OF 1/1/78
Subcategory: Cold Forming
: Cold Rolling - Direct Application
: Specialty
C&TT STEP
Plant
Code
TPD
ABC
D
E
F G
H
In
Place
Required
Total
0060D
408
27 74 52
37
70
48 48
53
123
286
409
0176
696
37 101 72
52
96
66 66
72
262
300
562
02568
1.5
13 2
1
2
2 2
2
1
14
15







386
600
986
Mote:
Onderlined
costs represent facilities in place.
Where
two figures appear
in the
same column,
the underlined

portion is
in place; the non-underlined portion reaains
to be installed.





-------
TABLE VIII-12
BPT CAPITAL COST TABULATION
BASIS: 7/1/78 DOLLARS X 10
: FACILITIES IN PLACE AS OF 1/1/78
Subcategory: Cold Forming
: Cold Rolling - Combination
: Carbon
C&TT STEP
Plant
Code
TPD
A
B
C
D
E
F
G
H
In
Place
Required
Total
0432D
3486
72
197
148
105
196
134
134
135
331
790
1121
0448A
2112
53
146
109
78
155"
99
99
TW
100
729
829
Q548A
4437
83
228
171
122
227
155
155
135
776
521
1279
0584E
6003
W
274
204
146
275"
TBS
115
TB7
472
1082
1554
0856D
7194
TTl
305
228
163
303
207
1157
IBS
546
1186
1732
0856F
4914
ST
92
135
143
158
157
136
50
517
444
961
0860B
3105
57
ra
138
98
TBI
125
T75
176
670
376
1046
0868A
4902
88
242
TIT
179
1ST
155
165
155
1067
310
1377
092OC
2120
IT
157
110
78
146
TW
TTO
TOff
399
435
834
0948C
8250
no
331
247
177

125
225
125
1549
331
1880










6427
6204
12631
Rote:
Underlined costs represent facilities in place.
Where two figures
appear
in the
sane colwn,
the underlined


portion is in
place} the
bob-underlined
portion
reaains
to be installed.





-------
TABLE VIII-13
ALTERNATIVE BAT MODEL COSTS; BASIS 7/1/78 DOLLARS
Subcategory: Cold Foming
: Cold Rolling-Recirculation Model Size-TPD :	1700
: Carbon-Specialty Oper. Days/Year:	348
Turns/Day	: 	3
Alternative
H
to
00
C4TT Steps

I
Total
I
J
Total
K
L
Total
_3
Investment $ x 10 ^

132
132
132
893
1025
1309
80
1389
Annual Costs $ x 10









Capital

5.7
5.7
5.7
38.4
44.1
56.2
3.4
59.6
Depreciation

13.2
13.2
13.2
89.3
102.5
130.9
8.0
138.9
Operation 6 Maintenance

4.6
4.6
4.6
31.2
35.8
45.8
2.8
48.6
Energy & Power

0.5
0.5
0.5
3.1
3.6
33.8
0.3
34.1
Carbon Regeneration

-
-
-
1670.0
1670.0
-
-
-
TOTAL

24.0
24.0
24.0
1832.0
1856.0
266.7
14.5
281.2



BAT No. 1


BAT No. 2


BAT No. :
/n\
BAT Feed

Effluent


Effluent


Effluent
Effluent Quality
Level

Level*


Level


Level
Flow, gal/ton
25

25


25


0
Suspended Solids
25

15


15


-
Oil & Grease
10

5


5


-
Dissolved Iron
1.0

1.0


1.0


-
pH, Units
6-9

6-9


6-9


-
6 Carbon Tetrachloride
0.02

0.02


0.02


-
11 1,1,1,-Trichloroethane
0.10

0.10


0.10


-
23 Chlorofom
0.10

0.10


0.02


-
24 2-Chlorophenol
6.0

6.0


0.05


-
34 2,4-Di»e thylpheno1
4.2

4.2


0.05


-
38 Ethylbenzene
0.05

0.05


0.05


-
53 Naphthalene
0.05

0.05


0.025


-
57 2-Nitrophenol
12.0

12.0


0.05


-
60 4,6-Dinitro-o-cresol
0.20

0.025


0.025


-

-------
TABUS VIII-13
ALTEBMATIVE BAT MODEL COSTS: BASIS 7/1/78 DOLLARS
COLD KOLLIRG - RECIRCULATIOH
PAGE 2
BAT Mo. 1
BAT Ho. 2
BAT No. 3
NJ
ID
Effluent Quality*2*
BAT Feed
Effluent
Effluent
Effluent
Level
Level*
Level
Level
65 Phenol
0.02
0.02
0.02
_
78 Anthracene
0.01
0.01
0.01
-
80 Fluorene
0.01
0.01
0.01
-
85 Tetrachloroethylene
0.30
0.05
0.05
-
86 Toluene
0.04
0.04
0.02
-
87 Trichloroetbylene
0.03
0.03
0.03
-
114 Antiawy
0.03
0.03
0.03
—
115 Arsenic
0.30
0.10
0.10
-
118 Cadaioa
0.10
0.10
0.10
-
119 Chroain
0.50
0.10
0.10
-
120 Copper
0.50
0.10
0.10
-
122 Lead
0.50
0.20
0.20
-
124 Bickel
0.50
0.10
0.10
-
128 Ziac
0.50
0.25
0.25
-
130 Xylene
1.5
1.5
0.05
-
(1)	Costa are all power unless otherwise noted.
(2)	Values are all in ag/1 unlesa otherwise noted.
*: Lower levels of organics can be achieved at BAT-1 by oil solution substitution (see Section X).
KEY TO CWT STEPS
I: Filtration
J: Granular Carbon Colwn
K: Evaporation
Li Recycle

-------
TABLE VIII-14
ALTERNATIVE BAT MODEL COSTS: BASIS 7/1/78 DOLLARS
Subcategory: Cold Forming
: Cold Rolling-Combination Model Size-TPD :	4400
: Carbon-Specialty Oper. Days/Year:	348
Turns/Day	: 	3
U)
o
C6TT Steps

I
Total
I
J
Total
K
L
Total
Inreitaeot $ x 10*\

539
539
539
2,918
3,457
10,183
267
10,450
Ammal Cost $ * 10









Capital

23.2
23.2
23.2
125.5
148.7
437.9
11.5
449.4
Depreciation

53.9
53.9
53.9
291.8
345.7
1018.3
26.7
1045.0
Operation 6 Maintenance

18.9
18.9
18.9
102.1
121.0
356.4
9.3
365.7
Energy & Power

8.1
8.1
8.1
38.9
47.0
861.5
6.2
867.7
Carbon Regeneration

-
-
—
717.4
717.4
"¦

""
TOTAL

104.1
104.1
104.1
1275.7
1379.8
2674.1
53.7
2727.8



BAT NO. 1


BAT No. 2


BAT No. :
/M\
BAT Feed

Effluent


Effluent


Effluent
Effluent Quality
Level

Level*


Level


Level
Flow, gal/ton
250

250


250


0
Suspended Solids
25

15


15


-
Oil 6 Grease
10

5


5


-
Dissolved Iron
1.0

1.0


1.0


-
pH, Units
6-9

6-9


6-9


-
6 Carbon Tetrachloride
0.02

0.02


0.02


-
11 1,1,1-Trichloroethane
0.08

0.08


0.08


-
23 Chloroform
0.10

0.10


0.02


-
24 2-Chlorophenol
3.00

3.00


0.05


-
34 2,4-Dimethylphenol
2.00

2.00


0.05


-
38 Ethylbenzene
0.03

0.03


0.03


-
55 Naphthalene
0.02

0.02


0.02


-
57 2-Hitrophenol
6.0

6.0


0.05


-
60 4,6-Dinitro-o-cresol
0.10

0.025


0.025


—

-------
TABL2 VIII-14
ALTERNATIVE BAT M3DEL OOSTS: BASIS 7/1/78 DOLLARS
COLO ROLLING - COMBINATION
PAGE 2
65
Phenol
0.10
0.10
0.05
78
Anthracene
0.01
0.01
0.01
80
Fluorene
0.01
0.01
0.01
85
Tetrachloroethylene
0.15
0.05
0.05
86
Toluene
0.02
0.02
0.02
87
Trichloroethylene
0.02
0.02
0.02
114
Antimony
0.02
0.02
0.02
115
Arsenic
0.10
0.10
0.10
118
Cadaion
0.08
0.08
0.08
119
Chroaius
0.50
0.10
0.10
120
Copper
0.50
0.10
0.10
122
Lead
0.50
0.20
0.20
124
Hickel
0.50
0.10
0.10
128
Zinc
0.50
0.25
0.25
130
Xylene
0.35
0.35
0.05
U>
H*
(1)	Costs are all power unless otherwise noted.
(2)	All values are in ag/1 unless otherwise noted.
*: Lover levels of organic* can be achieved at itt-1 by oil solution substitution (see Section X).
KEY TO C6TT STEPS
IS
J:
Filtration
Granular Carbon Colusins
X: Evaporation
L: Recycle

-------
TABLE VIII-15
ALTERNATIVE BAT MODEL COSTS; BASIS 7/1/78 DOLLARS
Subcategory: Cold Forming
: Cold Rolling-Direct Application Model Size-TPD :	2900
: Carbon-Specialty Oper. Days/Tear:	348
Turns/Day	: 	3
Alternative
1


2


3

C&TT Steps
1
Total
I
J
Total
K
L
Total
.1
Investment $ x 10 _j
540
540
540
3011
3551
10183
267
10450
Annual Cost $ x 10








Capital
23.2
23.2
23.2
129.5
152.7
437.9
11.5
449.4
Depreciation
54.0
54.0
54.0
301.1
355.1
1018.3
26.7
1045.0
Operation 6 Maintenance
18.9
18.9
18.9
105.4
124.3
356.4
9.3
365.7
Energy & Power
8.1
8.1
8.1
38.9
47.0
908.7
6.2
914.9
Carbon Regeneration
-
-
-
740.0
740.0
-
-
-
TOTAL
104.2
104.2
104.2
1314.9
1419.1
2721.3
53.7
2775.0


BAT Ho. 1


BAT Ho. 2


BAT No. !
/«\
BAT Feed
Effluent


Effluent


Effluent
Effluent Quality
Level
Level


Level


Level
Flow, gal/ton
400
400


400


0
Suspended Solids
25
15


15


-
Oil & Grease
10
5


5


-
Dissolved Iron
1.0
1.0


1.0


-
pH, Units
6-9
6-9


6-9


-
4 Beasene
0.01
0.01


0.01


-
6 Carbon Tetrachloride
0.01
0.01


0.01


-
11 1,1,1-Trichloroethane
0.05
0.05


0.05


-
78 Anthracene
0.03
0.03


0.03


-
85 Tetrachloroethylene
0.03
0.03


0.03


-
US Arsenic
0.02
0.02


0.02


-
117 Beryllina
0.01
0.01


0.01


-
119 Chromoa
0.10
0.10


0.10


-
120 Copper
0.15
0.10


0.10


-
122 Lead
0.40
0.20


0.20


-
124 Mickel
0.30
0.10


0.10


-
128 Zinc
0.15
0.15


0.15


-
(1)	Costa are all power unless otherwise noted.
(2)	All values are in ag/1 unless otherwise noted.
KEY TO C&TT STEPS
J: Filtration	K: Evaporation
J: Granular Carbon Columns L: Recycle

-------
TABLE VIII-16
RESULTS OF BCT COST TEST
COLD ROLLING
A.	Recirculation Type
BCT: lbs/year removed » 1872
Cost of BCT = $24,000	$/lb «* 12.82 FAIL
B.	Combination Type
BCT: lbs/year removed = 114,932
Cost of BCT - $104,100	$/lb - 0,91 PASS
C.	Direct Application Type
BCT: lbs/year removed = 227,251
Cost of BCT = $104,200	$/lb - 0.46 PASS
133

-------
TABLE VIII-17
USPS and PSHS MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory:
Cold Forming
Cold Rolling
Recirculation
Carbon-Specialty
Model Size-TPD : 1700
Oper. Daya/Year: 348
Turns/Day	: 	3
Alternative 1
2-Alt. Ho.l plus:
C&TT Step
Investment $ i 10
-3
.-3
u>
¦Is.
Annual Coat $ x 10
Capital
Depreciation
Operation and Maintenance
Sludge Disposal . .
Energy and Power
Cheaical Costs
Oil Disposal
Carbon Regeneration
TOTAL
A
B
C<2>
Hi

F
C
H<3)

J
Total
K
Total (Im
25
27
65
60
66
61
59
15
47
107
532
515
1047
1.1
1.1
2.8
2.6
2.8
2.6
2.6
0.6
2.0
4.6
22.8
22.1
44.9
2.5
2.7
6.5
6.0
6.6
6.1
5.9
1.5
4.7
10.7
53.2
51.5
104.7
0.9
0.9
2.3
2.1
2.3
2.1
2.1
0.5
1.7
3.8
18.7
18.0
36.7
-
-
-
-
-
-
-
-
0.1
-
0.1
-
0.1
-
-
0.3
0.2
0.5
0.3
0.6
— *
0.9
0.3
3.1
1.6
4.7
-
-
0.3
0.1
0.2
0.4
-
-
-
-
1.0
-
1.0
5.0
-
-
-
-
-
-
-
-
-
5.0
-
5.0
-
-
-
-
-
-
-
-
-
-
-
96.0
96.0
9.4
4.7
12.2
11.0
12.4
11.5
11.2
2.6
9.4
19.4
103.9
189.2
293.1


Raw
HSFS and PSHS Mo.l
HSPS and PSHS


Waste
Effluent
Effluent
Effluent Quality
Level
Level
Level

Flow, gal/ton
10
10
10

Suspended Solids
2,500
15
15

Oil and Grease
50,000
5
5

Dissolved Iron
250
1
1

pH (Units)
6-9
6-9
6-9
6
Carbon Tetrachloride
0.05
0.05
0.05
11
1,1,1-Tricbloroethane
0.25
0.25
0.10
23
Chlorofora
0.25
0.25
0.02
24
Cblorophenol
15.00
15.00
0.05
34
2,4-Di«ethylphenol
10.50
10.50
0.05
38
Ethylbenzene
0.20
0.20
0.05

-------
TABLE VIII-17
USPS and PSNS MDDEL COST DATA: BASIS 7/1/78 DOLLARS
COLD ROLLING
PACK 2
Effluent Quality***
Rav
Haste
Level
55
Naphthalene
0.25
57
2 -M i trophenol
30.00
60
4,6-Oinitro-o-creaol
0.50
65
Ctwnol
0.08
78
Anthracene
7.50
80
Fluorene
0.08
85
Tetrachloroethylene
0.80
86
Toluene
0.10
87
Tri chloroethylene
0.08
114
Antimony
0.20
115
Arsenic
0.80
118
Ctdaioi
0.25
119
Ghroaiwn
5.0
120
Copper
10.5
122
Lead
6.8
124
Nickel
5.5
128
Ziac
5.0
130
Xylene
3.8
(1)	Cost* are all power unless otherwise noted.
(2)(	3) Treatment ccapooeats are used ia tandea
(4) All values are in ag/1 mleaa otherwise noted
KEY TO CUT STEPS
A: Oil Separator
Bi Bqualiration tank
C: Altia addition
D: lentralitatioa w/acid
E: Floe eolation w/liae
NSPS and PSNS No.l
Effluent
Level
0.05
30.00
0.025
0.08
0.01
0.01
0.05
0.10
0.08
0.10
0.10
0.10
0.10
0.10
0.20
0.10
0.25
3.8
NSPS and PSNS No.2
Effluent
Level
0.025
0.05
0.025
0.05
0.01
0.01
0.05
0.02
0.08
0.10
0.10
0.10
0.10
0.10
0.20
0.10
0.25
0.05
F:	Polyaer addition
G:	Air flotation
H:	Settling basin
I:	Vacuus f ilter
J:	Mixed-aedia preaure filter
R:	Granular carbon col van unit

-------
TABLE VII1-18
PSES MODEL COST DATA; BASIS 7/1/78 DOLLARS
Subcategory:	Cold Forming
;	Cold Rolling	Model Size-TPD :
:	Recirculation	Oper. Days/Tear:
:	Carbon/Specialty	Turns/Day	:
Alternative
Carbon Regeneration
TOTAL
Alternative 1
C&TT Step
A
B
C^
D^
e<2>
F
C
h(3)
^(3)
J
Total
K
_3
Investment $ * 10,
43
49
81
76
83
78
72
18
46
132
678
893
Annual Cost $ z lo" -












Capital
1.8
2.1
3.5
3.3
3.5
3.3
3.1
0.8
2.0
5.7
29.2
38.4
Depreciation
4.3
4.9
8.1
7.6
8.3
7.8
7.2
1.8
4.6
13.2
67.8
89.3
Operation and Haintenance
1.5
1.7
2.8
2.6
2.9
2.7
2.5
0.6
1.6
4.6
23.7
31.2
Sludge Disposal , .
-
-
-
-
-
-
-
-
0.3
-
0.3
-
Energy and Power
-
-
0.3
0.2
0.5
0.5
1.2
-
1.1
0.5
4.3
3.1
Cheaical Costs
-
-
0.4
0.4
0.5
1.3
-
-
-
-
3.1
-
Oil Disposal
0.8
-
-
-
-
-
-
-
-
-
0.8
-
&.4 8.7
15.6 14.1
15.8
15.6 14.0
3.2
9.6
24.0 129
Alternative 2
Total (Includes A-J)
1571
67.6
157.1
54.7
0.3
7.4
3.1
0.8
167.0
167.0
329.0
458.0


PSES
PSES No.1
PSES No.2


Feed
Effluent
Effluent
Effluent Quality
Level
Level
Level

Flow, gal/ton
25
25
25

Suspended Solids
1000
15
15

Oil i Grease
20,000
5
5

Dissolved Iron
100
1.0
1.0

pH (Units)
6-9
6-9
6-9
6
Carbon Tetrachloride
0.02
0.02
0.02
11
1,1,1-Trichloroethane
0.10
0.10
0.10
23
Ch lor o font
0.10
0.10
0.02
24
2-Chlorophenol
6.00
6.00
0.05
34
2,4-Di>ethylpheno1
4.20
4.20
0.05
38
Ethylbenzene
0.07
0.05
0.05
55
Naphthalene
0.09
0.05
0.025
57
2-Hi trophenol
12.00
12.00
0.05
60
4,6-Dini tro-o-cresol
0.20
0.025
0.025
65
Phenol
0.02
0.02
0.02
78
Anthracene
3.0
0.01
0.01
80
Fluorene
0.03
0.01
0.01
85
Tetrachloroethylene
0.30
0.05
0.05
86
Toluene
0.04
0.04
0.02
87
Trichioroe thylene
0.03
0.03
0.03

-------
TABLE VIII-18
PBETKATWR MODEL COST DATA: BASIS 7/1/78 DOLLARS
SUBCATEGORY: COLD ROLLING - RECIRCULATION
PAGE 2

PSBS
PSES No.l
PSES Ho.:
Effluent Quality^
Feed
Effluent
Effluent
Level
Level
Level
114 Antiaony
0.03
0.03
0.03
115 Arsenic
0.30
0.10
0.10
118 Cadaius
0.10
0.10
0.10
119 Chroaiw
2.0
0.10
0.10
120 Copper
4.2
0.10
0.10
122 Lead
2.7
0.20
0.20
124 Hickel
2.2
0.10
0.10
128 Zinc
2.0
0.25
0.25
130 Xylene
1.50
1.5
0.05
cu
«J 	
(1) Goat* are all power unleaa otherwise noted.
(Z),(3) Treataeat coaponenta are naed ia taoden.
(4) All nlwt are in ag/1 unleaa otberaiae noted.
KKT TO Ci.TT STEPS
A:	Oil Separation
B:	Equalization
C:	Alua Addition
D:	leattilitttiM w/aeid
E:	Flocculation w/liae
F:	Polyaer Addition
6:	Air Flotation
H:	Settling Baain
It	Vacuta* Filter
J:	Filtration
K:	Granular Carbon Colunn Unit

-------
TABLE VIII—19
PSES MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory: Cold Foraing
Cold Rolling	Model Size-TPD :	4400
: Combination	Oper. Days/Tear:	348
: Carbon/Specialty	Turns/Day	: 	3
Alternative		Alternative 1 	 	Alternative 2
C&TT Step
A
B
C<2)
d<2>
E
F
g<3)
H(3)
I
J
Total
K
Total
(Includes A-.
_3
Investment 5 i 10
82
227
170
121
226
154
154
155
98
539
1926
2918
4844
Annual Cost $ x 10













Capital
3.4
9.8
7.3
5.2
9.7
6.6
6.6
6.7
4.2
23.2
82.8
125.5
208.3
Depreciation
8.2
22.7
17.0
12.1
22.6
15.4
15.4
15.5
9.8
53.9
192.6
291.8
484.4
Operation 4 Maintenance
2.9
7.9
5.9
4.2
7.9
5.4
5.4
5.4
3.4
18.9
67.3
102.1
169.4
Sludge Disposal
Energy and Power
-
-
-
-
-
-
-
7.8
0.8
-
8.6
-
8.6
-
-
4.5
3.6
4.2
3.9
5.5
-
1.7
8.1
31.5
38.9
70.4
Chemical Costa
-
-
22.4
8.5
11.2
28.8
-
-
-
-
70.9
-
70.9
Oil Disposal
31.6
-
-
-
-
-
-
-
-
-
31.6
-
31.6
Carbon Regeneration
-
—
—
-
—
-
—
""
""
—

717.4
717.4
TOTAL
46.2
40.4
57.1
33.6
55.6
60.1
32.9
35.4
19.9
104.1
485.3
1275.7
1761.0


PSES
PSES-1
PSES-2


Feed
Effluent
Effluent
Effluent Quality
Level
Level
Level

Flow, gal/ton
250
250
250

Suspended Solids
600
15
15

Oil & Grease
1000
5
5

Dissolved Iron
10
1.0
1.0

pH, Units
6-9
6-9
6-9
6
Carbon Tetra-
0.02
0.02
0.02

chloride



11
1,1,1-Trichloro-
0.10
0.08
0.08

e thane



23
Chlorofom
0.15
0.10
0.02
24
2-Chlorophenol
3.00
3.00
0.05
34
2,4-Di»ethyl-
2.00
2.00
0.05

phenol


0.03
38
Ethylbenxene
0.03
0.03

-------
TABU VIII-19
PSES MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE 2



PSES
PSES—1
PSES-2


(4)
uent Quality
Feed
Effluent
Effluent

Effl<
Level
Level
Level

55
Naphthalene
0.02
0.02
0.02

57
2-Hitrophenol
6.00
6.00
0.05

60
4,6-Dini tro-o-
cresol
0.10
0.025
0.025

65
Ihenol
0.10
0.10
0.05

78
Anthracene
0.20
0.01
0.01

80
Fluoreoe
0.01
0.01
0.01

85
Tetrachloroethy1en
s 0.15
0.05
0.05

86
Toluene
0.02
0.02
0.02

87
Trichloroethylene
0.02
0.02
0.02

114
Antiaony
0.02
0.02
0.02

115
Arsenic
0.10
0.10
0.10

118
Cadaiua
0.08
0.08
0.08

119
Cktoaia
1.00
0.10
0.10
139
120
Copper
2.00
0.10
0.10
122
bead
1.50
0.20
0.20
124
Hickel
0.90
0.10
0.10

128
Zinc
0.90
0.25
0.25

130
Xylene
0.35
0.35
0.35
(1)	Cost* are all power unless otherwise noted.
(2)(	3) Treatment components are used in tioda.
(4) All values are in wg/1 unless otherwise noted.
KEY TO C&TT STEPS
Polymer Addition
Air Flotation
Settling Basin
Vacuus Filter
Filtration
Granular Carbon Coluan Unit
A: Oil Separation	F:
B: Equalization	G:
C: Alum Addition	B:
D: Neutralisation w/Acid	I:
E: Flocculation w/Liae	j.
K:

-------
TABLE VIII-20
FSES MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory: Cold Foraing
Cold Rolling	Model SUe-TPD :	2900
: Direct Application	Oper. Days/Tear:	348
: Carbon/Specialty	Turns/Day	: 	3
Alternative
C&TT Step
Investment $ x 10
Alternative 1
Alternative 2
-3
-3
Annual Cost $ x 10
Capital
Depreciation
Operation ( Maintenance
Sludge Disposal
Energy and Power
Cheaical Costs
Oil Disposal
Carbon Regeneration
A
86
3.7
8.6
3.0
50.2
B
238
10.3
23.8
8.3
-(2)
170
7.3
17.0
5.9
2.6
23.6
,C2)
122
5.2
12.2
4.3
2.3
8.9
E
227
9.8
22.7
7.9
4.0
11.8
F
154
6.6
15.4
5.4
3.9
30.1
„(3>
154
6.6
15.4
5.4
5.5
H<3)
171
7.3
17.1
6.0
4.9
I
101
4.4
10.1
3.6
0.8
1.7
J
540
23.2
54.0
18.9
8.1
Total
1963
84.4
196.3
68.7
5.7
28.1
74.4
50.2
3011
129.5
301.1
105.4
38.9
740.0
Total
(Includes A-J)
4974
213.9
497.4
174.1
5.7
67.0
74.4
50.2
740.0
TOTAL
65.5
42.4
56.4
32.9
56.2
61.4
32.9
35.3
20.6
104.2
507.8
1314.9
1822.7


PSES
PSES—1
PSES-2


Feed
Effluent
Effluent
Iffluent Quality
Level
Level
Level

Flow, gal/ton
400
400
400

Suspended Solids
100
15
15

Oil & Grease
1025
5
5

Dissolved Iron
25
1.0
1.0

pH, Units
6-9
6-9
6-9
4
Beniene
0.01
0.01
0.01
6
Carbon Tetra-
0.01
0.01
0.01

chloride


0.05
11
1,1,l-Trichloro-
0.05
0.05

ethane


0.03
78
Anthracene
0.03
0.03
85
Tetracbloro-
0.03
0.03
0.03

ethylene




-------
TABLE VIII-20
PSKS MWKL COST CAT A: BASIS 7/1/78 DOLLARS
PAGE 2
(A)
Effluent Quality
PSES
Feed
Level
115
Arsenic
0.02
117
Beryl li»
0.01
119
Chroaius
0.10
120
Copper
0.16
122
Lead
0.40
124
Mickel
0.30
128
Zinc
0.15
H"
(1)	Costs are all potter unless otherwise noted.
(2)(	3) Treatment components are used in tanda.
(4) All values are in ag/1 ml ess otherwise noted.
KEY TO CATT STEPS
A: Oil Separation	F:
B: Equalization	G:
C: Alas Addition	H:
D: Neutralisation v/Acid	Is
E: Flocculatioo w/Liae	J:
K:
Polymer Addition
Air Flotation
Settling Basin
Vacuus Filter
Filtration
Granular Carbon Coluan Dnit
PSES-1
Effluent
Level
PSES-2
Effluent
Level
0.02
0.01
0.10
0.10
0.20
0.10
0.15
0.02
0.01
0.10
0.10
0.20
0.10
0.15

-------
142

-------
COLD FORMING SUBCATEGORY
COLD ROLLING
SECTION IX
EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICATION
OF THE BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE
Introduction
The Agency is proposing Best Practicable Control Technology Currently
Available (BPT) limitations which are the same as those originally
promulgated in March, 1976. As previous documents explain the methods
used to develop the originally promulgated guidelines, the intent of
this section is to further subtantiate these limitations. Some of the
proposed limitations are justified only by one of the plants visited
during the sampling trips because either some of the mills sampled had
inadequate treatment or representative samples of the treatment plant
effluents could not be taken. In these instances, additional
justification of the limitations is provided by demonstrating that the
flow and concentrations used to develop the proposed BPT limitations
are justified. A review of the treatment processes and effluent
limitations associated with the cold rolling subdivision follows.
Identification of BPT
The BPT model treatment system is identical to the model used in the
previous regulation. This system involves the treatment of either
once-through (DA mills) or recirculated (recirculation and combination
mills) wastewater by oil separation and equalization; chemical
addition (alum and acid) to break any oil emulsions; flocculatlon with
polymer and neutralization; air flotation; and, settling.
Figure IX-1 depicts the BPT model treatment described above for cold
rolling operations. Few plants in the subcategory employ the exact
treatment configuration outlined above. The system was developed
based upon general practices within the category and is an efficient
way to treat cold rolling wastewaters. The proposed BPT effluent
limitations for the three types of cold rolling operations, which
represent 30-day average values, are presented in Table IX-1. Maximum
values are three times the average values.
Rationale for BPT
Treatment- System
As noted in Sections III and VII, each of the treatment system
components incorporated in the BPT model treatment system is in use at
a number of cold rolling operations. On the basis of widespread use,
the use of each model treatment system component is demonstrated.
143

-------
Justification of Proposed BPT Limitations
Table IX-2 presents sampled plant effluent data which support the
proposed limitations for the three types of cold rolling operations.
The only limitation not justified by the data is the dissolved iron
limit for direct application mills. The ability to achieve the
dissolved iron limit is well substantiated by other cold rolling
plants which practice adequate neutralization and sedimentation.
The Agency believes that other plants which do not achieve the
proposed limitations have inadequate treatment. This conclusion is
based upon the fact that many cold rolling plants have reported flows
less than the model flow and because several treatment technologies,
including the model treatment system, can achieve the model
concentrations. The plants achieving the BPT flows are shown in
Tables X-4 through X-6. Data presented in Volume I detail the
capabilities of the treatment components used in the model treatment
system.
As noted earlier, the Agency believes that more stringent BPT
limitations may be appropriate for the combination and direct
application segment of the cold rolling subdivisions. Those more
stringent limitations are based upon lower model flow rates of 250
gal/ton and 400 gal/ton, respectively, and the same model technology
noted above. These more stringent limitations are as follows.
Combination
TSS
Oil and Grease
Direct Application
TSS
Oil and Grease
Monthly
Average
(kq/kkg)
0.0261
0.0104
0.104
0.0417
Daily
Maximum
(ka/kkq)
0.0783
0.0312
0.312
0.125
The costs (in millions of
limitations are as follows.
July 1, 1978 dollars) to achieve these
Model
Plant
Capital Annual
Segment
Total
Capital Annual
Combination
Direct Application
1.29
1.32
0.36
0.38
12.89
30.41
3.61
8.81
The above costs include all facilities in-place as of January 1, 1978
and are the same as those required to achieve the proposed BPT
limitations.
144

-------
TABLE IX-1
BPT EFFLUENT LIMITATION GUIDELINES
COLD ROLLING	
	Effluent Limitation Guidelines (lbs/1000 lbs)^^
Recirculation
(2)
Dissolved Iron
PH
Mills
Discharge Flow Basis (gal/ton)* 25
Total Suspended Solids	0.0026
Oil & Grease	0.00104
0.00011
6-9
Combination
Mills
400
0.0417
0.0167
0.00167
6-9
Direct Application
Mill 8
1000
0.104
0.0417
0.0042
6-9
(1)	Average limitations. Maximum limits are three times the values shown.
(2)	Dissolved iron load is allowed only when the cold rolling wastewaters are treated with
pickle rinse wastewaters.
Flow is not limited but has been used as a basis for the proposed limitations.
145

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TABLE IX-2
JUSTIFICATION OF BPT EFFLUENT LIMITATIONS
COLD ROLLING
Actual Loads
BB-2 (060B)
EE-2 (0112D)
X-2 (060)
B. Combination Mills
TSS
Effluent Limitations in kg/kkg (lbs/1000 lbs)
(1)
A. Recirculation Mills
Proposed BPT Effluent 0.00261
Limitations
0.00013
0.00015
0.0015
Proposed BPT Effluent 0.0417
Limitations
DD-2 (584E-01)	0.0128
YY-2 (432D-01)	0.00921
C. Direct Application Mills
Proposed BPT Effluent 0.104
Limitations
106 (0112B)
0.00039
0 & G
0.00104
0.00040
0.00029
0.00030
0.0167
*
0.00345
0.0417
0.0027
D. Iron
0.000104
0.0000026
0.0000014
0.0000073
0.00167
0.000085
NA
0.00417
NA
C&TT
E,SS,NA,FLP,EB,SL
EB,T,FLP,NL,CL,SS,VF
FLP,NL,NW,CL,SL,SS
EB,GF,CL,SS
E, SS, NA, FLP,EB, SL
NA,FLP,SL
NA,FLP,SL
E, SS, NA, FLP, EB, SL
E, SS, FSP, NW, T
* : Load not justified
NA: Not analyzed
146

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-J
WASTES FROM
COLO ROLLING
OPERATION
ALUM
FLOTATOR
REACTOR
FLOCCULATOR
AIR
SETTLIN6
BASIN
Susp. Solid* 25 mg/li
Oil a Qtmm 10 mg/l
pH	6-9 I
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD FORMING SUBCATEGORY
COLD ROLLING
	BPT MODEL 	
FIGURE EC-
acid
LIME
POLY
SLUDGE

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COLD FORMING SUBCATEGORY
COLD ROLLING
SECTION X
EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICATION
OF THE BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
Introduction
This section identifies three BAT alternative treatment systems, and
the resulting effluent levels considered for the cold rolling
subdivision. In addition, the rationale for the selection of
treatment technologies, their discharge flow rates, and the proposed
limitations are presented. Previously, the three types of cold
rolling mills (recirculation, combination, and direct application)
were discussed individually. Here, the BAT alternative treatment
technologies apply to all three types. Finally, there is a discussion
of the selection of a BAT model treatment system which serves as the
basis for the proposed BAT limitations.
Identification of BAT
Based upon the information contained in Sections III through VIII, the
Agency developed the following treatment technologies (as add-ons to
the BPT treatment system model) as BAT alternative treatment systems
in the cold rolling subdivison.
1.	BAT Alternative No. 1
The first BAT Alternative employs a mixed-media filter following
BPT treatment. Filtration of the BPT discharge removes toxic
metal pollutants in the particulate form, solids, and oils that
may entrain toxic organic pollutants.
2.	BAT Alternative No. 2
This alternative employs carbon columns following the filtration
step outlined above to reduce toxic organic pollutants present in
the filtered discharge.
3.	BAT Alternative No. 3
Alternative No. 3 is a zero discharge system which treats the BPT
discharge in a vapor compression evaporation system.
Figure X-l illustrates the three BAT alternative treatment systems
described above for the cold rolling subdivision. The treatment
technologies shown represent those technologies in use at one or more
plants, or demonstrated in other wastewater treatment applications.
These systems are capable of attaining the respective BAT effluent
149

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levels. The applicability of each treatment method is reviewed below.
Tables X-l through X-3 contain effluent limitations associated with
the three BAT Alternatives. Section VI presents the general rationale
for the selection of the toxic pollutants for which BAT limitations
are proposed. More details on why the Agency is proposing limitations
for specific pollutants at BAT are provided below.
Xnvestr^nt and annual costs for the BAT alternative treatment systems
are presented in Tables VIII-13 through VIII-15.
Rationale for the Selection of the BAT Alternatives
This discussion presents the rationale for selecting the BAT model
treatment system, for determining the effluent flow rates, selecting
the list of pollutants to be limited, and determining the
concentration levels of the limited pollutants.
Treatment Technologies
To reduce the levels of particulate toxic metal and toxic organic
pollutants entrained in the oils, a mixed-media filtration system is
included in Alternative No. 1. Although this alternative does not
significantly remove the toxic organic pollutants present, it
significantly reduces the pollutant load of conventional and toxic
inorganic pollutants being discharged from the cold rolling
operations.
Four plants have filtration systems which treat cold rolling mill
wastewaters, one of which has been sampled. At this plant, the
filtration step was used as an intermediate treatment step with the
filter discharge receiving additional treatment in a thickener. The
oil and solids concentrations entering the filter were extremely high,
which greatly affected the efficiency of the filter. Therefore, the
effluent data from this mill are not comparable to other well operated
filter systems sampled for this study, and have not been used in
support of the proposed limitations. The levels achieved with
filtration are based upon the performance of filter systems in other
subcategories. Refer to Volume I for more details.
Alternative No. 2 uses granular activated carbon following the
mixed-media filtration system described above. The carbon system was
selected for removal of toxic organic pollutants based upon
performance of activated carbon systems on similar wastewaters.
Although fifteen organic pollutants have been found in raw cold mill
wastes (some at levels above 10 mg/1), at present, no carbon systems
are installed at any cold rolling mills. However, because activated
carbon is used to treat wastes in the cokemaking subcategory and in
other industrial categories with similar organic contamination,
activated carbon is expected to work effectively for cold rolling
wastes.
Alternative No. 3 makes use of a vapor compression evaporation system,
as it is one of the less costly of the evaporation systems available.
However, it is energy intensive and expensive to operate. This system
150

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was considered since it may be the only technically feasible way to
achieve zero discharge at all cold rolling operations..
Flows
The Agency developed the alternative treatment system flows
recognizing the three types of cold rolling mills (recirculation,
combination, and direct application). These flows were based upon
data gathered from cold rolling mills in response to DCPs or during
sampling visits. Tables X-4 through X-6 list the mills in operation
and their respective discharge flows. The treatment system discharge
flows are based upon the average of the best flows. For recirculation
mills, the proposed flow rate is the same as for BPT - 25 GPT, even
though the flow analysis demonstrates that a lower flow value for BAT
limitations might be justified. Flow rates of 250 GPT and 400 GPT are
being used for combination and direct application mills, respectively.
These flows are less than BPT model system flows and can be achieved
as demonstrated in Tables X-4 to X-6. Based upon available
information, the Agency believes that product quality considerations
do not restrict the ability of the industry to achieve these flows.
Wastewater Quality
Following are the average effluent concentrations incorporated in each
BAT alternative. The maximum values appear below enclosed in
parentheses.
1,1,1-Trichloroethane
2-Nitrophenol
Anthracene
Tetrachloroethylene
Chromium
Lead
Zinc
BAT Concentration Bases (mq/1)
BAT-1	BAT-2	BAf^3
0.10(0.30)*
0.025(0.075)*
0.01(0.03)*
0.05(0.15)*
0.1(0.3) 0.1(0.3)
0.1(0.3) 0.1(0.3)
0.1(0.3) 0.1(0.3)
*Not limited for direct application operations.
No effluent concentrations are presented for BAT-3, since this
alternative results in zero discharge.
Listed below is the rationale for the selection of the pollutants
limited at BAT and their respective treatment levels.
Toxic Organic and Inorganic Pollutants
Fifteen toxic organic pollutants and nine toxic inorganic pollutants
were detected in the raw and treated wastewater from cold rolling
operations at treatable levels. For this reason, the Agency developed
BAT alternative treatment systems which were designed primarily to
reduce the levels of these pollutants.
151

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Alternative No. 1 is designed to remove particulate metals and
organics that may be entrained in oils. However, when highly
contaminated oils (oils with high levels of toxic organics) are used
in cold rolling mills, filtration will most likely not be effective in
achieving the toxic organic effluent limitations proposed for those
cases. The Agency believes the least costly method of complying with
the proposed limitations is to change the rolling oil solutions to
those that do not contain toxic organic pollutants. Based upon data
obtained during this study (Plant 0248B), the Agency believes that
such solutions are available and in use in the steel industry. Little
or no capital costs are associated with an oil solution change. In
the event a change in oil solutions is not the selection means of
compliance, other technologies, such as those outlined in Alternative
2, can be employed to achieve the proposed limitations. Reference is
made to Section VI of Volume I for a review of the performance of
activated carbon for removing toxic organic pollutants.
Although nine inorganic toxic pollutants were found in the wastewaters
from cold rolling operations, the Agency is proposing limitations for
only three: chromium, lead, and zinc. The Agency is proposing
limitations for these pollutants for three reasons. First, these
pollutants were found in the highest levels. Second, these pollutants
serve as "indicators" for the other metals that can be present in the
wastewaters. The data show that removal of these metals to low levels
also insures that all other metals will be reduced to low levels. And
finally, limitations for these metals are also being proposed in the
pickling subcategory. Since, as noted previously, cold rolling wastes
can be co-treated with pickling wastes, the Agency has decided to
develop a common list of limited pollutants so that those operations
that chose to co-treat compatible wastes can do so without incurring
extra costs.
Alternative No. 2 consists of filtration and carbon adsorption. This
system is also effective at reducing metals, oils, and solids.
However, it is designed primarily to reduce organic contamination in
the wastewaters. Because cold rolling wastes contain a number of
organic pollutants that are unaffected by the BPT model treatment
system, activated carbon was considered as an alternative.
As shown above, limitations for four specific organics are being
considered for proposal at cold rolling operations. These four
pollutants were selected because they were: (1) found at high levels
at the sampled plants, (2) found at more than one plant, and (3)
limiting these four pollutants will insure removal of the other
organics that may be discharged due to the nature of the oil solutions
used.
The Agency attempted to find one or two general indicator pollutants
which would properly serve as representative limited pollutants for
the organics in this subdivision. Oil and grease will serve as an
indicator for some of the insoluble organics, but not all of the
pollutants of concern. Phenolic compounds, an indicator used in other
subcategories, could not be used here, since it would serve as an
indicator for only a few of the pollutants detected and because it was
not found at high enough levels consistently to correlate its removals
152

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to removals of other pollutants. For these reasons, limits for four
specific toxic organics are being proposed.
Lastly, Alternative No. 3 includes a zero discharge system.
Effluent Limitations for Alternative Treatment Systems
The effluent limitations associated with BAT alternative treatment
systems were calculated by multiplying the effluent flows incorporated
in the alternative treatment systems by the concentration of each
pollutant and an appropriate conversion factor. Tables X-l through
X-3 present the effluent limitations developed for each BAT
alternative treatment system.
Selection of a BAT Alternative
The Agency selected BAT Alternative No. 1 as the BAT model treatment
system upon which the proposed BAT effluent limitations are based.
All of the treatment alternatives achieve significant reductions in
toxic pollutant loads. The Agency selected Alternative No. 1 since
the components of this alternative are demonstrated within the
subdivision and because it reduces pollutant loads at a relatively low
cost. However, the Agency does not believe that Alternative No. 1 is
sufficient to insure that the organic contamination present in cold
rolling wastewaters will be reduced. Therefore, in addition to
proposing limitations at BAT-1 for solids, oils, and metals, EPA is
also proposing BAT-2 limitations for the four toxic organics described
above for recirculation and combination mills. Since toxic organic
pollutants were found below treatable levels in direct application
wastewaters, no limitations for toxic organic pollutants are being
proposed for this segment.
The Agency believes the proposed limitations can be met by any of
three methods:
1.	If a clean oil is used at a cold rolling mill (free from organic
contamination), no additional treatment is required to achieve
the proposed limitations.
2.	if a "dirty" oil is used, a carbon adsorption system can be
installed to reduce organic contamination.
3.	If a "dirty" oil is used, change to a clean oil to remove the
organic problem can be accomplished at virtually no capital
expense. This issue is described in greater detail below.
Removal of Organic Contamination bv Oil Substitution
As pointed out above, significant levels of numerous organic
pollutants were detected in cold .rolling wastewaters during the
sampling visits. These organics result in the wastewater because of
the oil solutions used at the rolling stands. These rolling oils are
specially formulated oils that provide high degrees of lubricating and
cooling. The data gathered during the sampling visits demonstrate
that this organic contamination is not widespread throughout the
153

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category. Some mills, because of the oil solutions used, do not have
any organic contamination. Furthermore, the sampling visits have
shown that oil solutions may be substituted, sometimes using "clean"
oils and other times using "dirty" or contaminated solutions. For
these reasons, the Agency has considered as an alternative to
installing treatment to meet organic limits, a simple substitution of
oil solutions where necessary. There are evidently several oils used
in the subdivision that do not contain toxic organic pollutants.
To summarize, the Agency is proposing BAT-2 effluent limitations for
recirculation and combination cold rolling operations. This
alternative includes limitations for toxic metals and four toxic
organic pollutants. The EPA estimates that the least costly method of
achieving these limitations is to install BAT-1 technology and use oil
solutions which are free from organic contamination. The cost impacts
for this subdivision are based on the assumption that all operations
will install BAT-1 technology.
Obviously, monitoring for at least the four toxic organics will be
recommended for all cold rolling operations. This monitoring will
show whether or not organic contamination is a problem. If organics
are detected at levels above the proposed limitations, then the oil
solution should be changed or treatment installed to reduce the
contamination to below the proposed limits.
154

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TABLE X-l
BAT EFFLUENT LIMITATION GUIDELINES
COLD ROLLING - RECIRCULATION
BAT Effluent Limitations in kg/kkg (lbs/1000 lbs)
(1)
Alternative 1
Alternative 2*
l,l,l-Tri-(2)
chloroethane
(Oil)
NL
0.000010
2-Nitrophenol
(057)
NL
0.0000026
(2)
Anthracene
(078)
(2)
NL
0.0000010
Tetrachloro-
ethylene
(085)
NL
0.0000052
(2)
Chromium	Lead	Zinc
(119)	(122)	(128)
0.000010	0.000021	0.000026
0.000010	0.000021	0.000026
Alternative 3 No discharge of process wastewater pollutants to navigable streams.
(1)	30-day average limitations. Daily maximum values are twice the limitations stated.
(2)	If a plant can demonstrate by sampling and analysis that its oil solutions do not contain these or other toxic
organics at levels above their treatability level (see Volume I), then monitoring for these parameters can be
suspended.
NL: No limitations
* : Limitations for Alternative No. 2 selected for BAT

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TABLE X-2
BAT EFFLUENT LIMITATION GUIDELINES
COLD ROLLING - COMBINATION
BAT Effluent Limitations in kg/kkg (lbs/1000 lbs)
(1)
Alternative 1
Alternative 2*
l,l,l-Tri-(2)
chloroethane
(Oil)
NL
0.00010
2-Nitrophenol
(057)
NL
0.000026
(2)
Anthracene
(078)
NL
0.000010
(2)
Tetrachloro-
ethylene
(085)
NL
0.000052
(2)
Chromium
(119)
0.00010
0.00010
Lead
(122)
0.00021
0.00021
Zinc
(128)
0.00026
0.00026
Alternative 3 No discharge of process wastewater pollutants to navigable streams.
(1)	30-day average limitations. Daily maximum values are twice the limitations stated (except for 0 & G).
(2)	If a plant can demonstrate by sampling and analysis that its oil solutions do not contain these or other
toxic organics at levels above their treatability level (see Volume I), then monitoring for these parameters can
be suspended.
(3)	Limitation for oil & grease is on a maximum basis only.
NL: No limitations
* : Limitations for Alternative No. 2 selected for BAT

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TABLE X-3
BAT EFFLUENT LIMITATION GUIDELINES
COLD ROLLING - DIRECT APPLICATION
BAT Effluent Limitations in kg/kkg (lbs/1000 lbs)^^
Alternative 1*
Alternative 2
Alternative 3
Chromium
(119)
0.00017
0.00017
Lead
(122)
0.00033
0.00033
Zinc
(128)
0.00042
0.00042
No discharges of process wastewater
pollutants to navigable streams.
(1) 30-day average limitations. Daily maximum values are twice the limitations stated
(except for 0 & G).
* : Selected BAT alternative
157

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TABLE X-4
BAT DISCHARGE FLOW DETERMINATION
COLD ROLLING - RECIRCULATION
Plant
Code
580C-04
580C-05
528-02
528-01
528-03
284A-01
580C-03
060-01
256A( 01&02)
060-03
256B-01
856P(01-21)
060-02
176-08
584F( 02, 03&05)
320-02
112A-07
248B-03
684F-03
864B-01
684D(01-07)
864B-03
684F-02
384A-03
020B&020C
580C-01
580C-02
760-01
112D-01
60B-03
Discharge Flow
(GPT)
0
0
0.02
0.03
0.09
0.1
0.1
0.4
0.5
0.8
0.8
0.8
0.9
0.9
1.1
I.9
3.5
3.5
4.3
5.1
5.7
7.3
8.7
10.0
II.0
12.5
12.5
16.6
17.5
17.7
Basis
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
Sampling Visit
Sampling Visit
DCP
DCP
Sampling Visit
DCP
DCP
DCP
DCP
DCP
DCP
Sampling Visit
DCP
DCP
DCP
Sampling Visit
Sampling Visit
158

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TABLE X-4
BAT DISCHARGE FLOW DETERMINATION
COLD ROLLING - RECIRCULATION
PAGE 2
Plant
Code
760-02
528B-01
384A-02
248B
684B-01
864B-02
860B-04
6841-01
860B-02
948C-03
Discharge Flow
(GPT)
26.3
30.2
43.0
57.0
138.0*
354.0*
687.0*
• 751.0*
1,283.0*
1,369.0*
Average of all discharge flow values
"Average of the Best" flow value
Use
114 gal/ton,.s
9.0 gal/ton
25.0 gal/ton
Basis
DCP
DCP
DCP
Sampling Visit
DCP
DCP
DCP
DCP
DCP
DCP
(1) Includes flow data from three confidential operations.
*: Flow values marked with an asterisk were omitted from
the "Average of the Best" flow calculation.
159

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TABLE X-5
BAT DISCHARGE FLOW DETERMINATION
COLD ROLLING - COMBINATION
Plant
Code
Discharge Flow
(GPT)
Basis
868A-03
868A-01
856F-01
920C-01
584A-02
432D-01
856F-02
948C-02
860B-03
868A-02
584E-01
948C-01
948C-04
25
54
112
114
130
138
179
293
325
481
512
870
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
Sampling Visit
Sampling Visit
Sampling Visit
1,245*
Average of all flow values : 345 GPT
"Average of the Best" value: 268 GPT
use: 250 GPT
* Flow value marked with an aserisk were omitted from the "Average of the Best"
flow calculation.
160

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TABLE X-6
BAT DISCHARGE FLOW DETERMINATION
COLD ROLLING - DIRECT APPLICATION
Plant
Code
284A-02
6841-02
684C-02
860B-01
176-02
112B(01-06)
112A-02
384A-01
920A-01
856F-03
584F-04
112A-01
584A-01
112A-06
948A-02
948A-01
584C-01
920G-02
920G-01
112A-05
Discharge Flow
(GPT)
0.5
23
142
168
233
238
246
262
273
287
424
481
603
607
864
939
1426*
1477*
1604*
3081*
Basis
DCP
DCP
DCP
DCP
Sampling Visit
DCP
DCP
DCP
DCP
DCP
Sampling Visit
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
DCP
Average Discharge Flow Value " 669 GPT
"Average of the Best" Flow Value " 362 GPT
Use 400 GPT
* Flow values marked with an asterisk were omitted from the "Average of
the Best" flow calculation.
161

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WASTES FROM
COLO ROLLING
OPERATION
ACIO
BAT-I
FILTERS
BAT -2
CARBON TO
REGENERATION
CARBON
COLUMNS
FILTERS
BAT "3
EVAPORATION
100% RECYCLE
TO PROCESS
CENTRIFUGE
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD FORMING SUBCATEGORY
COLD ROLLING
BAT ALTERNATIVES
Dwn.7/9/80
FIGURE x-

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COLD FORMING SUBCATEGORY
COLD ROLLING
SECTION XI
BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
Introduction
The 1977 Amendments added Section 301(b)(4)(E) to the Act,
establishing "best conventional pollutant control technology" (BCT)
for discharges of conventional pollutants from existing industrial
point sources. Conventional pollutants are those defined in Section
304(g)(4) - BOD, TSS, fecal coliform and pH - and any additional
pollutants defined by the Administrator as "conventional." On July
28, 1978, EPA proposed that COD, oil and grease, and phosphorus be
added to the conventional pollutant list (43, Fed. Reg. 32857). Only
oil and grease was added.
BCT is not an additional limitation, but replaces BAT for the control
of conventional pollutants. BCT requires that limitations for
conventinal pollutants be assessed in light of a new
"cost-reasonbleness" test, which involves a comparison of the cost and
level of reduction of conventional pollutants from the discharge of
POTWs to the cost and level of reduction of such pollutants from a
class or category of industrial sources. As part of its review of BAT
for certain "secondary" industries, EPA proposed methodology for this
cost test. (See 43 Fed. Reg. 37570. August 23, 1978).
Development of BCT
The reference POTW treatment cost for the conventional pollutants is
$1.34/lb. The detailed results of the BCT Cost Test are presented in
Section VIII, Table VIII-16. The Agency considered one alternative,
filtration, as a BCT technology for the cold rolling segments. Figure
XI—1 depicts this system. The model flows used for BCT are the same
as those used for BAT. A summary of the results from the BCT cost
test is presented below.
Mill Type	BCT Cost Test Results
Recirculation	12.82
Combination	0.91*
Direct Application	0.46*
* BCT limitations are proposed based on the application
of this treatment.
As can be seen above, the treatment costs for combination and direct
application type mills are less than $1.34/lb for the BCT system. The
cost of removal for recirculation mills, on the other hand, exceeds
the $1.34/1b treatment cost and thus fails the BCT Cost Test. Based
163

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on these results, the Agency is proposing BCT limitations for
combination and direct application mills which are based upon the
respective BCT treatment systems. The proposed BCT limitations for
recirculation mills are the same as the proposed BPT limitations. The
BCT limitations proposed for cold rolling are presented in Table XI-1.
Development of BCT Limitations
The Agency promulgated BPT limitations for suspended solids, oil and
grease, and pH in 1976. The Agency is proposing BCT limitations for
the same pollutants. Since the BCT alternative passed the BCT Cost
Test for combination and direct application mills, the Agency is
proposing BCT limitations for these operations based upon the
application of BCT filtration technology. Following are the
concentrations incorporated in the BCT limitations.
Concentration Values (ma/1)
Ave	Max
Total Suspended Solids 15	40
Oil & Grease	-	10
pH, Units	6-9
The effluent concentrations presented above are based on an analysis
of long-term data available on numerous filtration applications in the
steel industry. A detailed discussion of the derivation of these
concentration values is presented in Volume I. BCT limitations for
the combination and direct application mills were developed by
multiplying these concentrations by the BCT flow values and the
appropriate conversion factors. As noted above, BCT limitations for
recirculation mills are identical to the proposed BPT limitations.
164

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Recirculation Mills
Combination Mills
Direct Application Mills
TABLE XI-1
BCT EFFLUENT LIMITATIONS
COLD ROLLING
Effluent Limitations in kg/kkg (lbs/1000 lbs)
Suspended Solids	Oil & Grease
Ave	Max	Ave	Max	pH (Units)
0.00260 0.00780	0.00104 0.00312	6-9
0.0156	0.0312	-	0.0104	6-9
0.0250	0.0500	-	0.0167	6-9
165

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WASTES FROM
COLO ROLLING
OPERATION
M

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COLD FORMING SUBCATEGORY
COLD ROLLING
SECTION XII
EFFLUENT QUALITY ATTAINABLE THROUGH
THE APPLICATION OF NEW SOURCE PERFORMANCE STANDARDS
Introduction
The effluent limitations which must be acheived by new sources, i.e.,
any sources, the construction of which is started after proposal of
new source performance standards are to specify the degree of effluent
reduction achievable through the application of the best available
demonstrated control technology (BADCT) processes, or other
alternatives, including, where practicable, a standard permitting no
discharge of pollutants. This section identifies the NSPS alternative
treatment systems developed by the Agency and the resulting effluent
levels for cold rolling operations. In addition, this section
presents the rationale for selecting the NSPS model treatment system
and the flow values and effluent standards.
The NSPS alternative treatment systems described below were developed
for recirculation oil systems only. Discussions with industry
representatives, mill manufacturers, and an analysis of the DCP
responses indicate only recirculation type cold rolling mills are
likely to be constructed as new sources. Recirculation systems are
used on all types of steels and at mills that process all types of
products and thicknesses. Although clean water can be required on the
entry stand of some mills, the Agency believes that for new sources
this water can be treated and reused, thus achieving the NSPS model
flow.
Identification of NSPS
NSPS Alternative No. J_
Alternative No. 1 consists of an equalization basin equipped with an
oil separator, chemical addition steps to break the oil emulsions, a
flocculation tank and an air flotation system. These components are
followed by a concrete settling basin and a mixed media filtration
system. The effluent standards proposed for this alternative are
listed in Table XII-1 and the system is diagrammed in Figure XII-1,
The costs for this alternative were shown in Table VIII-17.
NSPS Alternative No. 2
Alternative No. 2 includes the components of Alternative No. 1 plus a
granular carbon column system to reduce organic contamination, (Figure
XII-1). The standards achieved with this alternative are also
presented in Table XII-1.
167

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The components employed in Alternative No. 2 were developed so as to
achieve significant reductions in the toxic organic, toxic inorganic,
and conventional pollutants. Although not all components are
presently used in the cold rolling subdivision, their applicability to
this subdivision was detailed earlier in Section X.
Rationale for Selection of NSPS
The NSPS alternative treatment systems for cold rolling operations are
similar to the combined BPT, BAT-1, and BAT-2 treatment systems
described in Sections IX and X, respectively. Hence, the detailed
rationale presented in these sections is applicable to NSPS and is not
repeated. A short discussion on the NSPS tretment systems and flow
rates is presert®d below.
Treatment Scheme
As noted in Section X, the use of filtration is documented not only
within the steel industry, but also within the cold rolling
subdivision. With the exception of carbon adsorption, the other
treatment components are also well demonstrated at cold rolling
operations. As discussed in Section X, carbon adsorption has been
successfully applied to the treatment of wastewaters containing
similar organic contamination as cold rolling wastes. The
technologies are reliable, demonstrated methods of treatment and thus
are appropriate for incorporation in NSPS.
Flow Rates
Since recirculation systems should be incorporated at all new cold
rolling operations regardless of the product type or mill
configuration, the flow rate for NSPS is based upon the best
demonstrated flow rates for recirculation mills. The best
demonstrated recirculation mills attain flows of 10 gal/ton of steel
rolled. Twenty-three cold rolling mills producing all types of
products have demonstrated the ability to achieve this level.
Therefore, NSPS has been developed using 10 gal/ton as the model flow.
Selection of an NSPS Alternative
The Agency selected NSPS Alternative No. 1 as the NSPS model treatment
system upon which the proposed NSPS standards are based. This
treatment system includes well demonstrated technologies and provides
for removal of the solids, oils, organics, and metals found in cold
rolling wastewaters. As with BAT (Section X), the Agency is proposing
NSPS standards for four organic pollutants. The standards for these
pollutants can be met by installing carbon adsorption systems.
However, they can also be achieved by using oil solutions that do not
contain these, or other toxic organic pollutants.
168
/

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TABLE XII-1
HSFS EFFUKKI LIMITATIOB GUIDELINES
	COLD gOLLIWG		
¦SFS
Alternative 1
Ave.
Max.
USPS Effluent Limitation* in fcg/kkg (Iba/lOOO lbe)^^
1,1,1-Iri-	Tetrachloro-
cbloroethane 2-Hitrophenol Anthracene ethylene Chroaiua Lead	Zinc	pi
MS 0 t G	(Oil)	(057)	(078)	(085)	(119) (122) (128) Haiti
0.00063 -	-	0.0000042 0.0000083 0.000010 6-9
0.0013 0.00042 -	-	0.0000083 0.000017 0.000021
USPS
Alternative 2*
Ave. 0.00063 -	0.0000042 0.0000010	0.00000042 0.0000021	0.0000042 0.0000083 0.000010 6-9
Max. 0.0013 0.00042 0.0000083 0.0000021	0.00000083 0.0000042	0.0000083 0.000017 0.000021
H	* limitation* for Alternative Ho. 2 selected for BSFS.
0V
V0

-------
WASTES FROM
RECIRCULATION
SYSTEM
ACID
ALUM

LIME
~
POLY
H-H
AIR-
I
VACUUM
FILTER
I
SOLIDS TO
DISPOSAL
NSPS-I
NSPS-2
CARBON TO
REGENERATION
CARBON
COLUMNS
FILTERS
FILTERS
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD FORMING SUBCATEGORY
COLD ROLLING
NSPS ALTERNATIVES
Dwn.7/9/80
FIGURE xn-l

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COLD FORMING SUBCATEGORY
COLD ROLLING
SECTION XIII
PRETREATMENT STANDARDS FOR THE
DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS
Introduction
This section discusses the alternative control and treatment systems
available for the cold rolling operations that discharge wastewaters
to publicly owned treatment works (POTWs). The Agency has given
separate consideration to the pretreatment of cold rolling wastewaters
from new sources (PSNS) and from existing sources (PSES). The main
factors considered in the development of pretreatment systems were the
need to insure that the cold rolling wastewaters are treated
sufficiently to avoid overloading the POTW treatment system and to
insure that pollutants are not introduced into POTWs that will
interfere with, pass through, or are otherwise incompatible with POTW
operations. The general pretreatment and categorical standards
applying to cold rolling operations are discussed below.
General Pretreatment Standards
For detailed information on Pretreatment Standards refer to 43 FR
27736-27773, "General Pretreatment Regulations for Existing and New
Sources of Pollution," (June 26, 1978). In particular, 40 CFR Part
403 describes national standards (prohibited discharges and
categorical standards), revision of categorical standards and POTW
pretreatment programs.
In establishing pretreatment standards for cold rolling operations,
the Agency gave primary consideration to the objectives and
requirements of the General Pretreatment Regulations. In addition,
the Agency considered additional factors which are specifically
applicable to cold rolling operations which are discussed below.
The General Pretreatment Regulations set forth general discharge
prohibitions that apply to all nondomestic users of a POTW to prevent
pass-through of pollutants, interference with the operation of a POTW,
and municipal sludge contamination. The regulations also establish
administrative mechanisms to ensure application and enforcement of
prohibited discharge limits and categorical pretreatment standards.
In addition, the Regulations contain provisions relating directly to
the determination of and reporting on pretreatment standards.
Although wastewaters from many cold rolling operations are discharged
to POTWs, POTWs are usually not designed to treat the toxic pollutants
such as 1,1,1-trichloroethane, nitrophenol, anthracene,
tetrachloroethylene, chromium, lead, and zinc which are present in
cold rolling wastewaters. Instead, POTWs are designed to treat
171

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biochemical oxygen demand (BOD), suspended solids (TSS), fecal
coliform bacteria, and pH. Whatever removal obtained by POTWs for
toxic pollutants is incidental to the POTWs main function of treating
conventional pollutants. POTWs have historically accepted extremely
large amounts of many pollutants well above their capacity to treat
them adequately. As the issue of municipal sludge use has become more
important, pretreatment standards must address toxic pollutant
removal, rather than transfer of these pollutants to POTWs where many
pollutants concentrate in the sludges.
Due to the presence of many toxic pollutants in wastewaters from cold
rolling operations, extensive pretreatment must be provided to ensure
that these pollutants do not interfere with, pass through, or are
otherwise incompatible with POTW operations or cause harm to the
treatment plant. Additionally, oil and grease must be controlled by
pretreatment standards to adequately control emulsified oils that may
be present in cold rolling wastewaters. The Agency is not proposing
pretreatment standards for suspended solids because this pollutant, in
the amounts present in cold rolling wastewaters, is compatible with
POTW operations and can be effectively treated at POTWs.
Identification of Pretreatment
New Sources (PSNS)
Pretreatment standards for new sources will be the same as New Source
Performance Standards for direct dischargers (Section XII), with the
exception that there are no PSNS standards proposed for two
conventional pollutants, total suspended solids and pH. These two
pollutants are effectively controlled in POTW systems.
Existing Sources (PSES)
The Agency considered two PSES alternative treatment systems. The
first alternative includes the BPT and BAT-1 treatment system
components. This system reduces solids, emulsified and floating oils,
and the toxic metal pollutants that may be present in the wastewater.
PSES Alternative No. 2 includes all the components of Alternative No.
1, plus a carbon adsorption system. This alternative removes
essentially all toxic pollutants which could adversely affect the
operation of the POTW, pass through the POTW and also reduces the
possibility of contamination of the sludges in the POTW system.
Rationale for the Selection of Pretreatment Technologies
The intent of pretreatment is to provide sufficient treatment of the
toxic pollutants or any conventional pollutants that could upset, pass
through, or otherwise interfere with the operation of the POTW. Both
of the alternative treatment systems achieve significant reductions of
those pollutants (toxic metals and organics, emulsified oils) which
could be detrimental to the operations of the POTW system.
As discussed in Volume I, metals present in industrial discharges may
pass through a POTW system without being treated to any great extent.
Since domestic wastes do not typically contain objectionable
172

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concentrations or quantities of toxic metals, POTW systems are not
usually designed for removal of the metals. The toxic metal
pollutants which do not pass through a POTW are concentrated in the
POTW sludges. Generally, land application is the most advantageous,
and least expensive method of the POTW sludge disposal as the sludge
can be used to replace soil nutrients. However, excessive amounts of
toxic metals in the sludges would inhibit plant growth thus rendering
the sludge unfit for use as a soil nutrient supplement.
The organics in the wastes can also be detrimental to POTW operation
in excessive levels, thus control measures for toxic organics have
been included in the pretreatment alternatives. Reference is made to
Volume I for additional information regarding the fate of those
specific toxic organic pollutants found in cold rolling wastewaters in
POTWs.
Treatment Scheme
The two pretreatment alternatives considered are identical to the NSPS
alternatives discussed in Section XII. Refer to Section XII for
justification of the equipment suggested.
Flow Rates
The flow rate used to develop the preatreatment standards for new
sources (PSNS) is identical to the model flow for NSPS - 10 gal/ton.
See Section XII for the rationale for the selection of this model
flow.
The flow rates used in the PSES alternatives are equal to the model
BAT flow rates. Based upon widespread demonstration, the Agency
believes this is an achievable model flow for existing sources.
Selection of PSNS and PSES
The Agency relied upon the same rationale used in Sections X and XII
to select appropriate treatment systems and effluent standards as
pretreatment standards. Based upon the considerations presented in
those sections, the Agency selected Alternative No.l as the PSNS and
PSES model treatment systems upon which the proposed pretreatment
standards are based.
The proposed PSNS standards for cold rolling operations are presented
in Table XII1-1. The proposed PSES standards are presented in Table
XII1-2. No effluent standards are proposed for suspended solids and
pH as these conventional pollutants receive sufficient treatment in
POTWs. Because the oils present will most likely be of the emulsified
type, standards for oil are proposed since these oils contain the
toxic organic pollutants and since POTW systems are not equipped to
treat high levels of emulsified oils. These oils tend to interfere
with the biological treatment process by affecting oxygen transfer,
coating the biological floe, and hindering floe settling.
173

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TABLE XIII-1
PSNS EFFLUENT LIMITATION GUIDELINES
COLD ROLLING
1,I,1-Tri-
chloroethane
(Oil)
PSNS Effluent Limitations in kg/kkg (lbg/lOOO Iba)
(1)
0 & G
2-Nitrophenol
(057)
Anthracene
(076)
Tetrachloro-
ethylene
(085)
Chroaiua
(119)
Lead
(122)
Zinc
(128)
P«
Units
PSNS
Alternative 1
Ave.
Max.
0.00042
0.0000042 0.0000083 0.000010 6-9
0.0000083 0.000017 0.000021
PSNS
Alternative 2*
Ave.
Max.
0.00042
0.0000042
0.0000083
0.0000010
0.0000021
0.00000042
0.00000083
0.0000021
0.0000042
0.0000042 0.0000083 0.000010 6-9
0.0000083 0.000017 0.000021
* Limitations for Alternative No. 2 selected for PSNS.
-J
4*

-------
TABLE XIII-2
PSES EFFLUENT LIMITATION GUIDELINES
COLD ROLLING
Recirculation
PSES
Alternative 1
Ave.
Has.
PSES
Alternative 2*
Ave.
Max.
Coabination
PSES Effluent Limitations in kg/fckg (lb«/1000 lb»)
1,1,1-Tri-	"	Tetrachloro-
ch lor oe thane
(1)
0 « G
(Oil)
2-Nitrofhenol
(057)
Anthracene
(078)
ethylene
(085)
0.0010
0.0010
0.000010
0.000020
0.0000026
0.0000052
0.0000010
0.0000021
0.0000052
0.000010
Chroaiun
(119)
Lead
(122)
0.000010
0.000021
0.000010
0.000021
0.000021
0.000042
0.000021
0.000042
Zinc
(128)
0.000026
0.000052
0.000026
0.000052
PSES
Alternative 1
Ave.
Max.
0.010
0.00010
0.00021
0.00021
0.00042
0.00026
0.00052
PSES
Alternative 2*
Ave.	-
Max.	0.010
Direct Application
PSES
Alternative 1*
Ave.
Max.	0.017
0.00010
0.00020
0.000026
0.000052
0.000010
0.00021
0.000052
0.00010
0.00010
0.00021
0.00017
0.00034
0.00021
0.00042
0.00033
0.00066
0.00026
0.00052
0.00042
0.00084
PSES
Alternative 2
Ave.
Max.
0.017
0.00017
0.00034
0.00033
0.00066
0.00042
0.00084
* Limitation* for this alternative selected for PSES.

-------
WASTES FROM
COLD ROLLING
OPERATION
ACID
ALUM
[*~

LIME

POLY




AIR-
VACUUM
FILTER
f
SOLIDS TO
DISPOSAL
PTS- I
FILTERS
PTS-2
CARBON TO
REGENERATION
CARBON
COLUMNS
FILTERS
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD FORMING SUBCATEGORY
COLD ROLLING
PRETREATMENT ALTERNATES
Dwn.7/9/80
FIGURE XE" I

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COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
SECTION I
PREFACE
The USEPA is proposing effluent limitations guidelines and standards
for the iron and steel industry. The proposed regulation will contain
effluent limitations guidelines for best practicable control
technology currently available (BPT), best conventional pollutant
control technology (BCT), and best available technology economically
achievable (BAT) as well as pretreatment standards for new and
existing sources (PSNS and PSES) and new source performance standards
(NSPS), under Section 301, 304, 306, 307 and 501 of the Clean Water
Act.
This part of the Development Document highlights the technical aspects
of EPA's study of the Cold Worked Pipe and Tube Subdivision of the
Cold Forming Subcategory of the Iron and Steel Industry. Volume I of
the Development Document discusses issues pertaining to the industry
in general, while other volumes relate to the remaining subcategories
of the industry.
177

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COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
SECTION II
CONCLUSIONS
This report highlights the technical aspects of EPA's study of the
cold worked pipe and tube subdivision of the cold forming subcategory
of the Iron and Steel Manufacturing Category.
Based on this current study and a review of previous studies, the
Agency has reached the following conclusions:
1.	In the previous study,1 cold worked pipe and tube operations were
part of the pipe and tube subcategory. However, additional data
obtained since that time indicate that the limitations
promulgated in 1976 for all pipe and tube operations are not
appropriate for cold worked pipe and tube operations.
2.	The cold worked pipe and tube subdivision is further segmented
into those operations using water and those using soluble oil
solutions. Differences in wastewater characteristics, wastewater
treatability, and process water usage are the basis for this
division.
3.	As the Agency has determined that the BPT limitations originally
promulgated for pipe and tube operations are not representative
of cold worked pipe and tube operations, new BPT limitations are
being proposed. For those operations using water, the Agency
proposes a zero discharge limitation. EPA proposes that those
plants using soluble oil solutions recycle most of the solutions
with a small amount, 0.5 gal/ton, disposed of by a contract
hauler. There is no discharge to navigable waters. Incineration
is an alternate method of disposal.
4.	EPA estimates that industry will incur the following costs in
complying with the proposed cold worked pipe and tube
limitations.
*EPA-440/I-76/084-b, Development Document for Interim Final	Effluent
Limitation Guidelines and Proposed New Source Performance	Standards
for the Forming, Finishing and Speciality Steel Segment of	the Iron
and Steel Manufacturing Point Source Category.
179

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Costs (Millions of July 1. 1978 Dollars)
Investment
5.
6.
7.
8.
9.
Using Water
BPT
Total In-place
7.1	3.9
	 Total
Required Annual
3.2	1.8
Using Soluble Oil Solutions
BPT	1.1	1.1
TOTAL
8.2
5.0
3.2
1.1
2.9
EPA estimates that compliance with the proposed BPT limitations
in the cold forming-cold worked pipe and tube subdivision will
result in significant removals of conventional and toxic
pollutants. A summary of the removals occurring as a result of
the proposed BPT limitations follows:
Process
Flow
(MGD)
Effluent Loadings (Tons/Year)
Toxic Conventional
Organics Pollutants
Using Water
Raw Waste
Proposed BPT
Using Soluble Oil
Raw Waste
Proposed BPT
29.6
0
Solutions
18.0
0
0
0
541 .5
0
2,888
0
1,974,000
0
Based upon the data available, the Agency has been unable to
determine whether or not toxic pollutants are present in
wastewaters from cold worked pipe and tube operations using
water. The Agency is continuing its investigation of these
wastewaters. If toxic pollutants are found, the Agency will
promulgate a BAT limitation of zero discharge for cold worked
pipe and tube operations using water.
The Agency determined that the proposed BPT limitations for cold
worked pipe and tube operations using soluble oil solutions
provide sufficient pollution control. Therefore, the proposed
BAT limitations are identical to the proposed BPT limitations for
these operations. Additional investment or energy expenditures
are not required at BAT.
The BCT model treatment systems are identical to the
corresponding BPT model treatment systems for all cold worked
pipe and tube operations. Therefore, the proposed BCT
limitations are identical to the corresponding BPT limitations.
The proposed NSPS for pipe and tube plants using water
identical to the corresponding proposed BPT limitation.
is
180	'

-------
10.	Two NSPS alternative treatment systems were considered for plants
using soluble oil solutions. The selected alternative is
identical to the corresponding BPT model treatment system. The
other alternative, which includes a treatment system prior to
discharge "to navigable waters, is not recommended because it is
impractical and very costly.
11.	At this time, EPA is not proposing specific PSES or PSNS for pipe
and tube operations using water. Instead, General Pretreatment
Regulations (43 FR 27736-27773, "General Pretreatment Regulations
for Existing and New Sources of Pollution," (Monday, June 26,
1978)) only apply for these operations. However, should toxic
pollutants be found as a result of the Agency's continuing
investigation, the Agency will promulgate PSES and PSNS based
upon zero discharge for cold worked pipe and tube operations
using water.
12.	The Agency is proposing zero discharge at PSES and PSNS for those
cold worked pipe and tube operations using soluble oil solutions.
13.	With regard to the "remand issues," the Agency has concluded
that;
a.	It need not provide a special retrofit cost allowance for
older cold worked pipe and tube plants. Analysis indicates
that the age of a plant has no effect upon the ease or cost
of retrofitting pollution control equipment.
b.	No significant water consumption is expected to occur in
cold worked pipe and tube operations as a result of
compliance with the proposed limitations and standards.
14.	Table II—1 presents the proposed limitations and standards
corresponding to the BPT, BAT, BCT, NSPS, PSES/ and PSNS
treatment levels for cold worked pipe and tube operations using
water and soluble oil solutions.
15.	The Agency has only limited data available for cold worked pipe
. and tube operations. In order to better identify and
characterize the quality of wastewaters from these operations,
the Agency is continuing its investigation. The Agency solicits
comments and any available data or information which may be
helpful in this regard.
181

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TABLE II-l
PROPOSED EFFLUENT LIMITATIONS AND STANDARDS
COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
Treatment Level
Operations Using Water
BPT
BAT
BCT
NSPS
PSES
PSNS
Effluent Limitations and Standards
No discharge of process wastewater pollutants
to navigable waters.
No limitations presently proposed.
No discharge of process wastewater pollutants
to navigable waters.
No discharge of process wastewater pollutants
to navigable waters.
"General Pretreatment Regulations" are referenced.
"General Pretreatment Regulations" are referenced.
Operations Using Soluble Oil Solutions
BPT
BAT
BCT
NSPS
PSES
PSNS
No discharge of process
to navigable waters.
No discharge of process
to navigable waters.
No discharge of process
to navigable waters.
No discharge of process
to navigable waters.
No discharge of process
to navigable waters.
No discharge of process
to navigable waters.
wastewater
wastewater
wastewater
wastewater
wastewater
wastewater
pollutants
pollutants
pollutants
pollutants
pollutants
pollutants
182

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COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
SECTION III
INTRODUCTION
General Discussion
In cold worked pipe and tube operations, cold flat steel strip (skelp)
is formed into hollow cylindrical products followed by electrical
resistance welding of the seam. During this operation, wastewaters
are generated because contact cooling water or soluble oil solutions
are continuously flushed over the cold pipe and tube products for
cooling and lubrication purposes. Those wastewaters require treatment
prior to discharge to a receiving stream.
In 1976, the Agency sent basic questionnaires (DCPs) to approximately
85% of the cold worked pipe and tube mills in the United States. The
responses to the DCPs for one hundered twenty-six cold worked pipe and
tube mills provided information regarding applied and discharge flow
rates, wastewater treatment systems installed, mill capacities, and
modes of operation. The data contained in the DCPs have been
tabulated and summarized in Tables III-l and II1-2.
Detailed data collection portfolios (D-DCPs) were sent to selected
pipe and tube mills to gather information on treatment costs, and on
the pipe and tube mill process. Responses were received for two water
and three oil pipe and tube mills. Tables II1-3 and II1-4 summarize
the data base for this report as derived from the above mentioned
sources of information.
Pipe and tube operations are no longer treated as a separate
subcategory. Hot worked pipe and tube plants are incorporated in the
hot forming subcategory, while cold worked pipe and tube plants are
included in the cold forming subcategory. Cold worked pipe and tube
operations are further segmented based upon the lubricant used: water
or oil.
Description of Pipe and Tube Mills
Cold Expanded Pipe
The properties of hot rolled seamless pipe can be improved by cold
working the product. Cold working the pipe increases its yield
strength and generally improves the product. One method of cold
working is the seamless pipe method, in which the hotrolled pipe
(after cooling) is conveyed to a cold expander mill. The hot rolled
pipe is dropped into an expander trough and clamped with one end held
firmly against a backstop. A long ram is positioned at the opposite
end of the pipe, and an expander plug is forced through the pipe by
extreme pressure. The plug is lubricated through the ram head with a
183

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water soluble oil. After cold expansion, the seamless pipe enters a
rotary straightener and then is hydrostatically tested.
Cold Drawn Tube
While most quality requirements for seamless pipe and tubing products
can be met by the hot rolling processes, some pipe and tube
specifications require closer tolerance, enhanced physical and surface
properties, thinner walls, and smaller diameters than can be produced
by hot worked methods. These specifications can be met by cold
drawing the hot rolled tubes in a finishing operation.
The process consists of pulling a cold tube through a die, the hole of
which is smaller than the outside diameter of the tube being drawn.
At the same time, the inside surface of the tube is supported by a
mandrel anchored on the end of a rod, so that the mandrel remains in
the plane of the die during the drawing operation. Another method
involves using an internal bar rather than a stationary mandrel. This
bar travels along with the tube, as it is drawn through the die. The
hot rolled tubes are crimped and pointed on one end, so that the pipe
section can pass through the die and permit the jaws of the puller
mechanism to grip the end of the. tube. Some tubes of certain steel
grades are annealed prior to the cold drawing operation. All tubes
are pickled to remove scale and oxides, rinsed, and then dipped into a
lubricant tub (flour, tallow and water, or a special oil emulsion for
a bright finish) prior to the cold drawing operation.
Other cold tube reducing methods, such as the "Rockrite" process, are
also, used for cold drawing. The "Rockrite" process accomplishes
simultaneous reduction of tube diameter and wall thickness by a cold
swaging action, which uses compressive forces rather than tensile
forces, as used in conventional cold drawing. In the "Rockrite"
process, two semi-circular dies have matched, tapered, semi-circular
grooves machined into their curved faces. In operation, one die is
placed on top of the other, so that the matched semi-circular grooves
make a circular pass. The dies are geared to each other in such a
manner that they rotate in opposite directions when they are moved
laterally, and a converging circular pass is traced by the die
grooves. When a tube is held stationary on the centerline of this
pass, the converging path of the die grooves reduces its diameter. If
a stationary mandrel of the proper taper is also positioned in the
center line of the pass, the inside of the tube is supported between
the die and mandrel. When in operation, the dies are in constant
lateral and rotary reciprocal motion. Coolant solutions are
constantly poured onto the dies.
Electric Resistance Welded Tubing
Electric resistance welded tubing is referred to as ERW tubing.
Strip, sheet, or plate in coil form is used as a starting material for
the ERW process. The steps used in the manufacture of ERW tubing are:
forming, welding, sizing, cutting, and finishing.
The width of the tubing produced from strip equals the circumference
of the tubing to be welded. If extra wide strip is used, it is passed
184

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through a slitting-line for cutting to proper width and then recoiled.
The proper width strip is fed into forming rolls. The forming rolls
consist of an edge trimmer (to smooth and clean the edge of the strip
for welding and forming), closing, and fin pass rolls. After the fin
rolls, the strip enters the welding section where the tube is held in
pressurized squeeze rolls, as the edges are heated to welding
temperature. The heat for welding is provided by low-frequency power
through electrode wheels, by radio-frequency power through sliding
contacts, or by coil induction. Typical power for welding is supplied
at 450,000 cycles per second. The welded tube then passes under a
cutting tool, which removes the flash resulting from the pressure
during welding. The welded seam or entire tube is then annealed or
normalized, depending on the required metallurgy. After cooling, the
tube is sized on horizontal and vertical sizing rolls, to obtain a
round finished product of the desired diameter. After sizing, the
tube is cut to length and straightened, and end-finished if required.
The tubes are then inspected and packed for shipment.
Electric Welded Pipe
The electric weld process or fusion weld is used to produce pipe in
unlimited diameters. If the desired pipe circumference exceeds the
plate width, two or more plates may be welded together to provide the
necessary width. The steps required to make plates into pipe by the
electric weld process are shearing, planing, crimping, bending,
welding, expanding, and finishing.
Plate is transferred to the edge-planing machine, where it is aligned
so that the two edges will be parallel and square with the ends after
planing. Forming plate into circular pipe is usually performed in
three operations called crimping, "U"-ing, and "0"-ing. The first
operation, crimping, consists of bending the edges in a press, so as
to avoid a flat surface near the longitudinal seam of the pipe. The
crimped plate is then conveyed to a "U"-ing machine. In this
operation, the plate is centered over a series of parallel rocker-type
dies, which lie along the axis of the plate. A large "UM-shaped die
operated by a press# as long as the longest length of plate, is moved
down on the plate, forcing it between the dies which automatically
conform themselves to the operations and assist in forming the plate
into the "U"-shape. The plate is then transferred to what is called
the H0"-ing machine. The machine consists of two semi-circular dies,
which are as long as the plate. Rollers mounted on vertical spindles
prevent the plate from falling and keep it in correct alignment as it
enters the "0"-ing machine. The "U"-shaped plate rests in the bottom
die, and the top die is forced down by a press, deforming the plate
until it is the shape of an almost closed circle, which is then ready
for welding. The pipe is held in position for welding by a
longitudinal rod, which maintains the proper gap for welding. A
specially designed welding head deposits flux along the joint, feeds
the metal electrode, and transmits welding current to the joint and
electrode. Molten filler metal is deposited from the metal electrode
to the work and replaces the fluid flux and forms the weld. After the
pipe is welded on the outside, it is then welded on the inside by an
automatic welding machine mounted on the end of a long cantilever arm.
The pipe is drawn over this arm by a carriage. After welding, the
185

-------
scaly deposit left from the flux is removed by a cantilevered tube
device.
The final pipe diameter is obtained by either hydraulically expanding
the shell against a retaining jacket or mechanically expanding it over
an inside mandrel. In hydraulic expansion, the ends az;e expanded to
the proper diameter by mandrels. Retainer rings encircle the body of
the pipe, which is filled with water and hydraulically expanded to the
limits of the bands. This also serves as a hydraulic test. The
expansion, by either method, sizes, rounds, and straightens the pipe
and provides a good test of the weld. Attention is given to
nondestructive inspection of the weld by X-ray examination. The pipe
is then placed in special machines which face the ends, to ensure that
they are smooth and at right angles. If the joints are to be welded,the
ends are beveled in this operation prior to shipment.
More specific details of a typical ERW operation are presented in
Figure III—1.
186
/

-------
TABLE Ill-t
GENERAL SUMMARY TABLE
COLD FORMIHG SUBCATEGORY
COLO WORKED - PIPE AND TUBE (USING HATER)
t-»
00
-J
Plant
Code
0060
0060N
0060P
01
OO60P
02
0060P
03
0060P
04
0060P
OS
0060P
06
0060P
07
oo«or
08
Product
Welded
Tube
(01-08
¦ilia)
Welded
Tube
Welded
Pipe
Welded
Tube and
Pipe
Welded
Tube and
Pipe
Welded
Pipe
Welded
Tube
Welded
Tube and
Pipe
Welded
Tube
Welded
Tube
type of
Steel
CS 100
SS.98
RSLA 2
SS 100
SS 100
SS 100
SS 100
SS 100
SS 100
SS 100
SS 100
H«w (ttHow/toa) Treatment Components
Mill Mill Size Applied Discharge Process	Central	Operating
Age (Tona/Day) Flow	Flow
Treatment Treataent
01-07	1%
1963	Total
08 -	for 8
1974	Hills
1970	9.6
1968	0.3
1968	0.6
1968	0.9
1968	0.3
1968	1.8
1968	0.6
1969	0.9
1976	1.5
3673
Hone
Dry Operation
1920	Unk	None
960
640
Unk
Unk
1920	Unk
320	Unk
960	Unk
640	Unk
384	Unk
Hone
None
Horn
Hone
None
None
Hone
CHT1 100 RTP 100
PSP,SSP,
FFOP
CHT2(0nk), OT
SLCUnk)
CHT2(Unk), OT
SL(Unk)
CNT2(Unk), OT
SLCUnk)
CNT2(0nk), OT
SLCUnk)
CNT2(Unk), OT
SLCUnk)
CNT2(Unk), OT
SUOnk)
C(»T2(Unk), OT
SLCUnk)
CHT2(Unk), 01
SLCUnk)
Discharge
Mode
Zero Diacharge
Evaporation
and Percola-
tion Pond
Evaporation
and Percola-
tion Pond
Evaporation
and Percola-
tion Pond
Evaporation
and Percola-
tion Fond
Evaporation
and Percola-
tion Pond
Evaporation
and Percola-
tion Pond
Evaporation
and Percola-
tion Pond
Evaporation
and Percola-
tion Pond

-------
TABUS III-l
GENERAL 80MIAR TABLE
COLO F0UUHC SUBCATEGORY
GOLD HOIKED - PIPE AND TUBE (DSIBG WATER)
PAGE 2	
Plant
Cod*
0060P
09
Product
Welded
Pipe
Type of	Milt Mill Size
Steel	Age (Ton*/Day)
SS 100	1976 0.3
0112 A
03
Welded
Pipe
CS 100
1957 858
0112K
0176C
0176D
0256F
0432A
OS
0492 A
01
0492 A
02
04 92 A
03
Welded
Pipe
Welded
Tube
(01-19
¦ills)
Welded
Tube
(01-04
¦ills)
Welded
Tube
(04-O6
¦ill*)
Welded
Tube
Welded
Tube
Welded
Tube
Welded
Pipe
CS 45
HSLA 55
SS 100
SS 100
SS 100
CS 80
HSLA 20
CS 100
CS 100
CS 100
1962 1134
1947 22.8
Total for
19 ailla
1972 9
Total for
4 ailli
1968 4.5
Total for
3 aills
1957	444
1953	1011.4
1953	669.2
1962	246
Flows (gallons/ton)
Applied Discharge
Flow	Flow 	
Treatment Coaponents
Process	Central	Operating
Treatment Treataent Mode
Discharge
Mode
1920	Onk	Rone	CHT2(0nk), OT
SL(Unk)
Onk	Onk	Rone	CST2(Dnk), OT
SS, Ser,
HL,AE,FLA,
FLP,SL(0nk),
CY,T
Onk	Unk	PSP	Rone	RET 100
1990	Onk	-	CHTl(Onk), RTP(Unk)
CT	RET(Unk)
BD(Unk)
2880	Onk	-	CHTl(Unk), RTP(Unk)
CT	RET(Unk)
BD(Unk)
Unk	0	Hone	-	KOP 100
Unk	0	-	Hone	R(Unk)P 100
22,211 17,731 PSP.SS	CHT2 20.2,	RIP 20.2
SL(Onk)	RET 79.8
33,784 26,926 PSP,SS	CHT2 20.3,	RTF 20.3
SL(Unk)	RET 79.7
2049	2039	Hone	CNT2 0.5,	RTF 0.5
SL(Unk)	RET 99.5
Evaporation
and Percola-
tion Pond
Direct
Indirect
POTW
POTW
Zero Discharge
Zero Discharge
Recirc.
Reservoir
Recirc.
Reservoir
Recirc*
Reservoir

-------
TABLE HI-1
GENERAL SOWURT TABLE
COLD FORMING SUBCATEGORY
COLD WORKED - PIPE AMD TUBE (USING HATER)
PAGE 3






Flows (gallons/ton)
Treatment
Components


Plant
Code
Product
Type of
Steel
Hill
Age
Hilt Size
(Ton#/Day)
Applied
Flow
Discharge
Flow
Process
Treatment
Central
Treatment
Operating
Mode
Discharge
Mode
0492A
04
Cold Drawn
Tube
CS
100
1970
339
1920
1910
Hone
CHT2 0.5,
SL(Unk)
RIP 0.5
RET 99.5
Recirc.
Reservoir
0548C
01
Helded
Tube
cs
100
1966
Unk
Unk
Unk
None
None
OT
Direct
0548C
02
Helded
Tube
CS
ss
50
50
1966
Unk
Unk
Unk
None
None
OT
Direct
0548C
03
Helded
Tube
CS
ss
50
50
1975
Unk
Unk
Onk
None
None
OT
Direct
0584 B
Helded
Tube and
Pipe
CS
100
1976
246
51,483
3512

CNT2 92.3
PSP, SS,
SSP.CT,
NH
Losses 1.2
BD 6.4
RTP 92.4
POTW - 0.1
Direct-6.4
0684 A
01
Helded
Tube
CS 80
HSLA 20
1963
1050
1824
453
-
-
RUP 75,2
BD 24.0
Direct
0684K
01
Helded
Tube
*

1957
*
*
0
-
CNTl(Unk),
PSP,SS
RTP 100
Zero Discharge
0684K
03
Helded
Tube
•

1941
*
*
0
-
CNTl(Unk),
PSP.SS
RTP 100
Zero Discharge
0684K
05
Helded
Tube
*

1930
*
*
0
-
CNTUtink),
PSP,SS
RTP 100
Zero
Discharge
0684K
06
Helded
Tube
*

1938
*
*
0
-
am (unk)
PSP, SS
RTP 100
Zero
Discharge
0684K
07
Helded
Tube
*

1938
*
*
0
-
CNTl(Unk)
PSP.SS
RTP 100
Zero
Discharge
0684K
04
Helded
Tube
*

1937
*
*
0
psp,ss
None
RTP 100
Zero
Discharge

-------
TABLE III-l
GENERAL SfflMAKY TABLE
COLD FORMING SUBCATEGORY
COLD WORKED - FIFE AHD TUBE (OS IMG HATER)
PAGE 4		
Plant
Code
OS56N
OS
Product
Welded
Pipe
Type of
Steel
CS 100
Fiona (gallons/ton) Treatment Components
Mill Mill siae	Applied Discharge Process	Central
Age (Tons/Day) Flan	Flow
1965 435
2979
Treatment Treatment
i979
PSP
CNT2 2.5,
SL(Unk),
SS
Operating Discharge
Node	Hode
0856Q
03
Welded
Tube
CS 70
HSLA 30
1950 1155
Onk
Unk
PSP
CHT2(Unk), OT
SL(Unk),
SS
\D
O
0864 A
08681
0884C
Welded	CS 68
Tube,	HSLA 32
Submerged
Arc Welded
Pipe, Elec.
Resiatance
Welded
Pipe
Double	CS 25
Submerged HSLA 75
Arc - Welded
Pipe
Seaaleaa
Pipe and
Tube Cold
Dram and
Welded
Tube
CS 90
HSLA 10
1955 489
589
589
FSP
1978 (lot Yet In Operation
1961 21
720	720
CNT2 1.2,
SL(Unk),
OT
CNT2 0.7,
F(Unk)
(Unk)P,
SS, SL(t)nk)
None
Direct
Q884S
Cold
Drawn
and Welded
Tube
SS 100
1968 1 3.5
Onk
CNT2 (Unk), OT
HI
POTW
08841
Cold
Drawn
Tube
SS 100
1976 4.5
Dry Operation
0908
0908A
01
Welded
Tube
Welded
Tube
CS 100
CS 100
1976 156
1971 327
Unk
Unk
CT
CT
Hone
Hone
RTP 100
RTP 100
Zero
Discharge
Zero
Discharge

-------
TABLE III-l
ckmml mmua tabu
COLO mRR flKOian
cold hooxd - rm urn tobe (toik hated
PACE 5	
Plant

Code
Product
090AA
Raided
02
Tube
09Z0D
tfelded

Tubs
09*88
Welded

Tube
Type of
Steel
CS 100
CS 100
CS 100
Hill
1971
1973
1930
Hill aise
( Tons/Dsy)
285
40. Z
Idle
Flews (gallons/top)
Applied Discharge
Flan	Flaw
Onk
Dry
M
Imtwit Copponents
Process	Central	Operating
Treatment Treataeat	Mode	
CT	Hone	RTF 100
0 p
HA
PSP
Rone
Discharge
Hode
Zero
Diacharge
-1 There is insufficient data to determine if such ayaton exist.
*: Confidential information.
Hone: The available data imply that no tack aystens esist.
Onk > The ugmtnde of the itna was not calculable froa the available data.
HA I Hot applicable.
Ctf i Z Carbon Steel
UUfl Z U# Strength Lev Alloy Steel
88# t Z Stainless Steel
BOTE: lefer to Table III-I for MindiM of the abbreviations naod in thia table.

-------
COLD WORKED
Plant
Code
0080A
01
0080A
02
0080A
03
0240B
01
Product
Velded
Tube
Welded
Tube
Welded
Tube
Welded
Tube
Type of
Steel
CS 100
CS 100
CS 100
CS 100
H
VD
to
0240B
02
Welded
Tube
CS 100
0240B
03
Welded
Tube
CS 100
0240B
04
0240C
01
0240C
02
0240C
03
0240C
04
Welded
Tube
Welded
Tube
Welded
Tube
Welded
Tube
Cold
Drawn
Tube
CS 100
CS 100
CS 97
HSLA 3
CS 95
HSLA 5
CS 100
Mill	Hill Size
Age	(Tons/Day)
1954	21.8
1954	21.6
1954	21.8
1937	20.7
1946	12
1961	99
1961	141
1955	39.3
1963	122.7
1969	217.8
1974	102
TABLE III-2
GENERAL SUMMARY TABLE
COLD FORMING SUBCATEGORY
PIPE AND TUBE (USING SOLUBLE OIL SOLUTIONS)
Flows (gallons/ton) Treatment Components
Applied Discharge Process - Central
Flow	Flow	Treatment Treatment
Unk
Unk
Unk
3478
Unk
Unk
Unk
1.13
CNTl(Unk),
CT
CNTl(Unk),
CT
CNTl(Unk),
CT
Operating
Mode
RUP(Unk)
RUP(Unk)
RUP(Unk)
RTP 99
Discharge
Mode
Oil solutions
are hauled
Oil solutions
are hauled
Oil solutions
are hauled
Oil solutions
are hauled
6000
Unk
FF0P
RTP(Unk)
Oil solutions
are hauled
Unk
Unk
FFOP
RTP(Unk)
Oil solutions
are hauled
Unk
Unk
Unk
Unk
Unk
Unk
Unk
Unk
FFOP
None
None
RTP(Unk)
RUP(Unk)
RUP(Unk)
RUP(Unk)
RUP(Unk)
Oil solutions
are hauled
Oil solutions
are hauled
Oil solutions
are hauled
Oil solutions
are hauled
Oil solutions
are hauled

-------
TABLE XII-l
cukml swtuwar tabu
COLO raUOK 8BCUB00KT
GOLD MOWED - FIFE AH) TOM (US IK SOLUBLE OIL SOLOTinS)
PACE 2		
Flan (liHm/tw) Treataent Component*
Plant
Coda
Product
Type of
Steel
Mill
Age
Mill Size
(Tooa/Day)
Applied
Flow
Discharge
Flow
Proceaa
Treatment
Central
Treatment
Operating
Node
Diacbarge
Mode
0236*
(folded
Mc
(01-03
¦ilia)
CS 99.5
HSU 0.S
1953
189
Total
for 3
¦ilia
1143
0
cr
-
RTF 100
Zero
diacharge
0548A
03
Welded
Tube
CS 100
1970
•
*
•
*
*
*
*

0636
01
Welded
Tube
CS 100
1963
Onk
Unk
Onk
-
-
RUP(Unk)
Oil
are
aolutiona
hauled
0636
02
Melded
Tube
CS 100
1963
Dnk
Onk
Onk
-
-
RUF(Octk)
Oil
are
aolutiona
hauled
0636
03
Melded
Tube
SS 100
1960
Onk
Onk
Onk
-
-
RUP(Onk)
Oil
are
aolutiona
hauled
0636
M
Melded
Tube
SS 100
1975
Onk
Onk
Dnk
-
-
RUF(Onk)
Oil
are
aolutiona
hauled
06MK
02
Melded
Tube
*
I960
*
*
*
PSP
Hone
¦TP *
Oil
are
aolutiona
hauled
Q6MK
OB
Melded
Tube
*
1968
•
•
•
FSP
Rone
RTF *
Oil
are
aolutiona
hauled
06MK
09
Melded
Tube
*
Oak
*
*
•
PSP
Hone
RTF *
Oil
are
aolutiona
hauled
0684K
to
Melded
Tube
*
1960

•
*
PSP
None
RTF *
Oil
are
aolutiona
hauled
0684K
11
Melded
Tbbe
*
1944
•
*
*
PSP
Hone
RTF •
Oil
aTe
aolutiona
hauled
0684K
12
Melded
M*
•
1947
*
*
*
PSP
Mone
RTF *
Oil
are
aolutiona
hauled

-------
TABU III-2
GENERAL SUMMAKT TABUS
COLD FORMIHG SUBCATEGORY
COLD WORKED - PIPE AMD TUBE (OS OK SOLUBLE OIL SOLOTIONS)
PAGE 3		
Iowa (galloni/ton) Treatment Component*
Plant
Code
Product
Type of Mill
Steel Age
Hill Sixe
(Tons/Day)
Applied
Flow
Discharge
Flow
Process
Treatsent
Central
Treatment
Operating
Mode
Discharge
Mode
0684K
13
Welded
Tube
» 1952
*
*
*
PSP
None
RTP
*
Oil solutions
are hauled
0684*
14
Welded
Tube
* 1966
•
*
•
PSP
None
RTP
*
Oil solutions
are hauled
0684K
15
0684K
16
Welded
Tube
Welded
Tube
* 1972
Mo Inforaa
*
t i o n
*
*
PSP
None
RTP
*
Oil solutions
are hauled
0684 L
01
Welded
Tube
* 1967
•
*
*
PSP
None
RTP
*
Oil solutions
are hauled
0684L
02
Welded
Tube
* 1975
*
*
*
PSP
None
RTP
*
Oil solutions
are hauled
0684L
03
Welded
Tube
* 1975
*
*
*
PSP
None
RTP
*
Oil solutions
are hauled
0684i.
04
Welded
Tube
* 1976
*
*
*
PSP
Heme
RTP
*
Oil solutions
are hauled
0664M
01
Welded
Tube
* 1934
*
*
*
None
CNT1 *
PSP, Cooler
RTP
RET
*
*
Oil solutions
are hauled
0684K
02
Welded
Tube
* 1929
*
~
*
Hone
CNT1 *
PSP, Cooler
RTP
RET
*
*
Oil solutions
are hauled
0684M
03
Welded
Tube
* 1959
*
*
*
None
CNT1 *
PSP, Cooler
RTP
RET
*
*
Oil solutions
are hauled
0684K
04
Welded
tube
* 1959
*
*
*
None
CNTl *
PSP, Cooler
RTP
RET
*
*
Oil solutions
are hauled

-------
TABLE III-2
CEieRAL SOMURT TABU
COLD FORMING SUBCATEGORY
COLD HORKED - PIPE ADD TUBE (DStKG SOLUBLE OIL SOLUTIONS)
PAGE 4
Plant
Code
0684M
05
0684M
06
06«4*
01
0684H
02
0684H
03
0684 R
04
0M4H
05
0664II
06
060411
07
068411
08
06840
0684V
01
Product
Welded
Me
Maided
Tube
Welded
Me
Welded
Tube
Welded
Tube
Welded
Tube
Welded
Tube
Welded
Tobe
Welded
Tube
Welded
Tube
Welded
Pipe
Welded
Tube
Type of
Steel
Kill
Age
1959
1965
I9Z5
1915
19Z5
1965
1942
1946
1959
1943
1968
1969
Flow* (gallons/ton) Treatment Component8
Mill Size Applied Discharge Process	Central
(Tone/Day) Flow	Flov	 Treafent Treafent
Operating
Mode
Hone
Hone
Hone
PSP
¦one
Hone
Cooler
Done
PSP,SS
CHT1 *	RTP
PSP, Cooler	RET
CKT1 *	RTP
PSP, Cooler	RET
cirri
PSP
cirri
PSP
cirri
PSP
CHTl
PSP
CRTl
PSP
CRTl
PSP
cm
PSP
Hone
PSP,Cooler Hone
RTP
RET
RTP
RET
RTP
RET
RTP
RTP
RET
RTP
RET
RIP *
RET *
RIP *
RET *
RTP *
RTP *
Discharge
Mode	
Oil solutions
are hauled
Oil solutions
are hauled
Oil solutions
are hauled
Oil solutions
are hauled
Oil solutions
are hauled
Oil solutions
are hauled
Oil solutions
are hauled
Oil solutions
are hauled
Oil solutions
are hauled
Oil solutions
are hauled
Direct
(Ground
Evaporation)
Oil solutions
are hauled

-------
TABU IIl-Z
GEKML SUMMIT TABU
cou> nunc sdbcaibocmt
GOLD WUXD - PIPE MD TUBE (OS IMC SOLOBU OIL SOLUTIONS)
PACE 5 		
KM
Code
Prtxfcict
Raided
02
OK«Q
0*
0916A
02
MM
TOte
Maided
Ma
VO
C\
Typa of
Steel
GS 30
BSLA 70
CS 100
Mill
1969
Mill Size
(Tone /Day?
How (gallona/ton)
Applied titdutfi
Flow	Flow
1963 I.
195* 72
Oak
Oak
Oak
Treaf ent Coaponente
Peaces* Central
Treatacat Treatment
PSP,Cooler Hone
rsr
Operating
Mode	
OTP *
OT
¦OP Oak
I Bracketed data aas derived frea D-OGP.
- i Thare ia iaaofficieat data to determine if aach ajritc
* i Cflafidaatial iafocaatioa.
edit.
Discharge
Mode
Oil aolutiona
are hauled
Oil aolutioaa
are healed
Oil aolatiooa
are hauled
CSf t X Carboa Steal
asu#l Z li^i Strength Low Alloy Steel
89# i Z Stainlasa Steel
¦ouei The available data iaply that ao aach aystcM eziit.
Oak I TW aagaitade of the streea »ae aot calculable frea the available data,
mi Kefer to Table T1I-1 for defiaittoaa of the abbreviatioua oaad ia thie table.

-------
TABLE III-3
DATA BASE
COLD FORMING SUBCATEGORY
COLD WORKED - PIPE AND TUBE (USING WATER)

Number
Percent of
Daily
Percent of

of
Total Nunber
Capacity of
Total Daily

Mills
of Mills
Mills (Tons)
Capacity
Mills sampled for D/D 3/76
1
1.4
300
3.2
Mills sampled for this study
0
0
0
0
Mills which responded frith D-DCP data
1
1.4
24.5
0.26
Mills 8ampled and/or surveyed via D-DCP
2
2.8
324.5
3.46
Mills responding to DCP
71<1>
85
9358.9
85
Cl) This total includes three mills with unknown tonnages and two mills which are not operating.

-------
TABLE III-4
DATA BASE
COLD FORMING SUBCATEGORY
COLD WORKED - PIPE AND TUBE (USING SOLUBLE OIL SOLUTIONS)
Mills sampled for D/D 3/76
Mills sampled for this study
Mills which responded with D-DCP data
Mills sampled and/or surveyed via D-DCP
Mills responding to DCP
Number
of
Mills
0
0
3
3
51
(1)
Percent of
Total Number
of Mills
0
0
5.9
5.9
85
Daily
Capacity of
Mills (Tons)
0
0
110.7
110.7
3507.75
Percent of
Total Daily
Capacity
0
0
3.2
3.2
85
(1) This total includes five mills which did not provide production data.

-------
EE	=~.
X
TUBE COOLING SPRAY HEADER
SOLUBLE OIL-WATER SOLUTION
i\ * «
COLD FORMING ROLLS
STRIP IS FORMED
INTO A TUBE
COILED NARROW
STRIP UNCOILERS
Q1
UJ
?
o
x
h-
WELDING
ELECTRODES
TUBE SEAM
IS WELDED
SOLUBLE OIL-WATER
SOLUTION
RECYCLE TANK
WELDED FLASH
REMOVAL TOOL
I x
o
t-
<
s
SIZING MILL
TO OBTAIN PROPER
SIZED TUBING
ANNEALING OR
NORMALIZING
FURNACE
52
EE
(s>©(s
-------
COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
SECTION IV
SUBCATEGORIZATION
Introduction
Originally, cold worked pipe and tube operations were included in the
pipe and tube subcategory. Based upon data obtained since the
promulgation of the previous regulation, the Agency has found
significant differences between the hot worked and cold worked pipe
and tube subdivisions. Accordingly, cold worked pipe and tube
operations now constitute a subdivision of the cold forming
subcategory. The cold forming subcategory also includes cold rolling
operations. As the Agency found variations in the final products and
manufacturing processes between these two types of cold forming
operations, it subdivided the subcategory into the cold rolling and
cold worked pipe and tube subdivisions.
The Agency also believes that within the cold worked pipe and tube
subdivision, further segmentation is appropriate based upon the type
of process solution used (see discussion below). The Agency examined
other factors, including raw materials, size and age, and geographic
location, but found that they have no significant effect on further
segmentation. Each of these factors is discussed in greater detail
below.
Factors Considered in Subdivision
Manufacturing Process and Equipment
The cold working processes manufacture cold drawn or welded pipe and
tube from cold semi-finished products, strip, or skelp. Several
processes are employed to manufacture these products. Electric
resistance welding, fusion welding, and cold drawing are all cold
working operations which encompass similar equipment and processes.
Therefore, the Agency believes that no further division or
segmentation is necessary on this basis.
Final Products
Products of various dimensions can be manufactured in cold working
pipe and tube mills. Different types of equipment are employed in the
manufacture of these products. While some processes use water
solutions for lubrication and cooling purposes, others use soluble oil
solutions. Although the quality and quantity of waste solutions may
vary, the Agency did not find any correlation between the products
manufactured and the waste solutions generated.
201

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Raw Materials
The raw materials used in cold worked pipe and tube operations include
steels of various material specifications. For purposes of this
discussion, any mill producing less than 50% of its output as carbon
steel is termed a "specialty mill." The raw materials used in the
manufacture of a finished product have little bearing upon the
subdivision or segmentation of cold worked pipe and tube operations.
Wastewater Characteristics
A review of the DCP data indicates the need for further segmentation
based upon the process wastewaters generated in the cold worked
subdivision. The plant survey data indicates that soluble oil
solutions are used in some cold working mills for process
requirements, while only water is used at the remaining cold working
mills. On this basis, the segmentation of the cold working process
was made.
Wastewater Treatability
As indicated above, the treatability of cold worked pipe and tube
wastewaters differs betw.een mills using water and mills using soluble
oil solutions. The various model treatment systems recognize this
difference and provide separate treatment for the two types of waste
solutions.
Size and Age
The Agency considered the impact of size and age on the segmentation
of cold worked pipe and tube mills. Size has no apparent effect upon
segmentation. Analysis failed to reveal any correlation between the
size of a pipe and tube mill and process water usage. Figure IV-1 is
a plot of discharge flow (in gallons/ton)versus size (expressed as
capacity in tons/day) for cold worked pipe and tube mills using water.
(No figure is provided for cold working mills using soluble oil
solutions, as more than 90% of these mills currently achieve the
proposed BPT limitations of zero discharge.) Also shown on this plot
is the BPT effluent discharge rate. As can be seen by the plot, the
size of a pipe and tube mill has no bearing upon the ability to
recycle and subsequently attain the BPT discharge flow rate. Thus,
the Agency concluded that further segmentation based upon the size of
cold worked pipe and tube mills is not appropriate.
The Agency next examined age as a possible basis for further
segmentation. According to DCP data, the oldest mill now in operation
was built in 1925, and the newest was built in 1978. The Agency
compared discharge flow versus age in a manner similar to the
discharge flow versus size comparison noted above, and this comparison
is illustrated in Figure IV-2. As with the flow versus size plot, no
relationship between age and process flow is evident. (A figure is
not provided for the cold worked mills using soluble oil solutions, as
more than 90% of these mills currently achieve the proposed BPT
limitations of zero discharge.) Hence, the Agency concludes that the
age of a mill has no effect on the ability to treat and recycle
202

-------
process wastewaters. Further analysis also indicated that mill age
does not affect wastewater quantity.
The Agency also addressed the issue of retrofitting pollution control
equipment as part of its plant age analysis. The ability to retrofit,
pollution control equipment has been demonstrated at several plants.
These plants serve to illustrate that pollution control equipment can
be retrofitted on existing production facilities without unreasonable
difficulty or expense. In addition, the Agency analyzed the cost of
retrofit, to determine whether older plants require additional capital
expenditures for the installation of pollution control equipment over
that required for new plants. The D-DCPs solicited this retrofit cost
information. Since the industry indicated that no retrofit costs were
incurred for the survey mills, the Agency concludes that the cost of
retrofitting pollution control equipment on older mills is either
minimal or not significant.
Based upon the preceding discussion, the Agency believes that neither
the size nor age of a cold worked pipe and tube mill has any
significant effect upon the nature or treatment of its wastewaters.
Accordingly, the Agency concludes that further subdivision or
segmentation based upon size or age is not appropriate.
Geographic Location
The location of cold worked pipe and tube plants has no apparent
effect upon segmentation.. The Agency analyzed the relationship
between mill location and process water use. No discernible pattern
was.revealed. Most pipe and tube mills are located in twelve states
east of the Mississippi River and in Texas, California, Colorado,
Utah, and Louisiana. It should be noted that cold worked mills using
water achieve zero discharge, and cold worked mills using soluble oil
solutions have a minimal blowdown which is disposed of by hauling at
the BPT level. Thus, both readily attain minimal water use
conditions.
Process Water Usage
DCP and D-DCP data, as well as sampled plant data, were used in
determining the applied and discharge flow rates (gal/ton) for each
mill. Flow averages and ranges in each of the two cold worked mill
subdivisions are presented in Table IV-1. The flow differences among
the types of cold worked pipe and tube mills can be readily noted on
this table. Processs water usage, therefore, is a consideration in
cold worked pipe and tube mill segmentation.
203

-------
TABLE IV-1
FLOW AVERAGES AND RANGES
COLD FORMING SUBCATEGORY
COLD WORKED - PIPE AND TUBE
(All flows expressed in gal/ton)
Discharge Flow	
Average ^	Range^
1,895	0-26,926
0.54	0-1.13
(1)	Confidential information was included in average calculations.
(2)	Ranges do not include confidential values.
Applied Flow
Average^	Range ^ ^
Cold Worked (Using Water)	2,960	320-51,483
Cold Worked
(Using Soluble Oil Solutions)	4,769	1,143-6,000
204

-------
FIGURE EL-I
DISCHARGE FLOW VS PRODUCTION CAPACITY
COLD FORMING SUBCATEGORY
COLD WORKING: PIPE AND TUBE
(USING WATER)
32,000 -i
28,000 -
24,000
CO
20,000 -
<

-------
FIGURE BT-2
DISCHARGE FLOW VS AGE
COLD FORMING SUBCATEGORY
COLD WORKING: PIPE AND TUBE
(USING WATER)
32£00l
26,000
P 24000
s
<0
Z
o
H 20,000
o 16000
_J
IL.
12,000
8,000
4,000-
-**¦
1930 1956
„ BPT LEVEL
W«	i	
1942 1948
4-
1954 I960
AGE
T
X X
a
**-
X
X
-ft-
1966 1972
—i
1978
206

-------
COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
SECTION V
WATER USE AND WASTE CHARACTERIZATION
Introduction
Process water use and characterization of the wastewaters generated by
the pipe and tube mills are the principal considerations used in
determining pollutant loads, developing treatment alternatives, and
estimating the cost of compliance with the proposed limitations. This
section describes the wastewater systems in use in the cold worked
pipe and tube subdivision and the types of wastewaters originating
from the processes. The description of the wastewater systems is
limited to those which come into contact with pollutants contributed
by the process. This excludes the various noncontact cooling and
nonprocess water systems. The limited waste characterization is based
upon analytical data obtained during field sampling surveys.
Water Use
Wastewaters are generated in cold worked operations as a result of the
continuous flushing of the product, welders, or rolls, either with
water or soluble oil solutions. Also, wastewaters are discharged from
hydrostatic testing operations.
The cold worked pipe and tube mills generally employ three main water
systems.
1.	Noncontact cooling water for annealing or normalizing furnaces.
2.	Water or soluble oil solution cooling or lubrication systems for
welders, rollers, etc.
3.	Hydrostatic testing waters.
The noncontact cooling waters are handled in once-through, tight
recycle, or closed loop systems, depending upon mill water
availability. As noted above, the waters are noncontact and, as such,
exhibit only a temperature increase and are not considered herein.
The various contact wastewaters originating in cold worked operations
using water are usually discharged to trenches beneath the pipe and
tube mill stands and subsequently flushed into scale pits. Scale
settles out in these pits, while an oil skimming device is used to
remove insoluble oils. The treated wastewater from the scale pit is
recycled back to the process at most operations.
Hydrostatic test waters are typically reused in the testing of large
tonnages of steels. Those wastes are small in volume, variable, and
207

-------
are not included in the limitations set forth herein. Limitations for
those wastes should be established on a case-by-case basis.
The soluble oil solutions are continuously recycled through settling
and storage tanks. In some instances, these solutions are filtered or
cooled as they are recycled from the settling tank. The solids which
accumulate in settling tanks are periodically removed either
mechanically or by a vacuum. The solutions are recycled until they
are removed for disposal by contractors.
Wastewater recycle is practiced in the two cold worked pipe and tube
mill segments. Many of the mills using water and almost all of the
mills using soluble oil solutions include recycle to some extent. The
use of recycle is considered a good water conservation practice and,
being widely demonstrated in both types of cold worked pipe and tube
mill operations, has been included in the BPT and BAT model treatment
systems.
In summary, the water and oil solutions used in cold worked pipe and
tube mills are recycled to a high degree with only minimal blowdown
from oil solution mills. This blowdown is hauled offsite for disposal
for virtually all oil solution mills. Eight of seventeen water
solution mills have no discharge. Based on the above, the Agency
believes that zero discharge is attainable for all cold worked pipe
and tube mills, and is, in fact, proposing such limitations at the BPT
level. Hence, those wastes have not been studied in great detail.
Waste Characterization
The cold worked process using water and cold worked process using
soluble oil solutions both generate a fine scale as well as insoluble
and water soluble oils and greases. Free oils and greases are present
in both types of mill wastes as a result of oil spills, line breaks,
excessive dripping of lubricants, and equipment washdown. In
addition, water soluble and emulsified oils are found in the mill
soluble oil solutions. The pH of cold worked pipe and tube
wastewaters may be slightly acidic due to prior pickling operations.
Table V-l presents the available raw waste data for cold worked pipe
and tube mills using water. These concentrations have served as the
bases for pollutant load reduction calculations summarized in Section
VIII. Based upon the data available, the Agency has been unable to
determine whether or not toxic pollutants are present in wastewaters
from cold worked pipe and tube operations using water. At this time,
the Agency is continuing its investigation of these wastewaters.
Since similar oil solutions are used in both cold rolling and cold
worked pipe and tube operations, similar pollutants are expected in
all cold worked wastewaters. Reference is made to the cold rolling
report for a description of cold rolling waste solutions. Data from
cold rolling plants have served as the bases for pollutant load
reduction calculations for pipe and tube operations which use soluble
oil solutions. These calculations are summarized in Section VIII.
208

-------
TABLE V-l
SUMMARY OF ANALYTICAL DATA FROM THE SAMPLED PLANT
ORIGINAL GUIDELINES SURVEY
COLD FORMING SUBCATEGORY
COLD WORKED - PIPE AND TUBE (USING WATER)
(Net Concentrations (tng/1) of Pollutants in Raw Wastewaters)
Reference Code	0492A
Plant Code	HH-2
Sample Points	1-2
Applied Flow (gal/ton)	1920
Suspended Solids	19
Oil and Grease	61.3
209

-------
COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
SECTION VI
WASTEWATER POLLUTANTS
As noted in Section V, the Agency believes that zero discharge of
process wastes can be achieved at all cold worked pipe and tube
operations. As this level of treatment is being proposed at the BPT
level, the Agency has not selected specific pollutants for limitation.
However, in order to provide estimates of the pollutant loads removed,
suspended solids and oil and grease concentrations have been used for
those plants using water solutions. For those plants using soluble
oil solutions, concentrations of toxic organics have been used in
addition to the TSS and oil and grease concentrations to calculate
pollutant loads. The sources of these concentration data are
referenced in Section V of this report.
211

-------
212

-------
COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
SECTION VII
CONTROL AND TREATMENT TECHNOLOGY
Introduction
This section presents the treatment practices currently used within
the cold worked pipe and tube subdivision. Data from DCPs and a plant
visit provide the basis for the summary of treatment technologies used
for cold worked mills. Available information shows the level of
effluents achievable through the various treatment systems.
To develop the technology, propose limitations, and estimate
incremental costs associated with the application of the technologies
designated as possible treatment approaches, it was necessary to
determine the levels of treatment in existence within this
subdivision. The alternative treatment systems developed and the
corresponding effluent characteristics are summarized in Sections IX
through XIII. The costs are summarized in Section VIII.
Control and Treatment Technology
Summary of Treatment Practices Currently
Employed at Cold Worked Pipe and Tube Plants
The treatment provided by most pipe and tube plants consists of
sedimentation (primarily by scale pits), oil removal (by skimming),
and recycle. Following is a description of the various treatment
technologies employed by cold worked pipe and tube operations (see
Tables 111 — 1 and II1-2 for treatment technologies used by the
individual mills).
A. Cold Worked Pipe and Tube Plants Using Water
1.	Sedimentation-Primary Scale Pit
The primary scale pit serves to collect the heavier
suspended particulate matter and allows tramp oils to float
to the surface. Approximately 45% of the pipe and tube
plants using water have a primary scale pit.
2.	Oil Skimmer
Oil skimmers are used to remove the tramp oils which
accumulate in the scale pits. Approximately 35% of the pipe
and tube plants using water have some type of oil skimming
equipment.
213

-------
3. Recycle
Recycling all or part of the process waters conserves water
use. Approximately 45% of these plants recycle all or part
of their process water.
B. Cold Worked Pipe and Tube Plants Using Soluble Oil Solutions
1.	Sedimentation-Primary Scale Pit
Approximately 57% of these plants use primary scale pits to
provide for the collection of particulate matter and
insoluble oil.
2.	Oil Skimming
Approximately 7% of these plants use some type of oil
skimming device to remove insoluble oils.
3.	Recycle
Approximately 93% of these plants recycle a large percentage
of process solutions.
4.	Contractor Removal
A small fraction of the oil solution is not recycled but is
hauled off-site by a contractor. About 86% of the plants
dispose of spent oil solutions in this manner. The spent
oil solution from one plant is disposed of by ground
application.
Plant Visit Analytical Data
One cold worked pipe and tube mill using water was visited during the
original guidelines survey. Table VII-1 presents a summary of the raw
and effluent analytical data from that sampled cold worked mill.
Table VI1-2 provides a legend for the various control and treatment
technology abbreviations used in the above tables and in other tables
throughout this report.
Cold worked pipe and tube mills using soluble oil solutions were not
visited during either survey.
Plant Visit
Plant HH-2 - Figure VII-1
Plant HH-2 is a cold worked mechanical tubing mill. The tubing mill
wastewaters discharge to a settling and cooling basin which receives
wastes from other mill operations such as open hearths and rolling
mills. The settling basin overflow is directed into another similar
basin and then to oil skimming facilities. The effluent is then
pumped to a large reservoir from which all of the water is reused.
214

-------
However, if the reservoir is full, treated effluent, after oil
skimming, is discharged to a receiving stream.
215

-------
TABLE VII-1
SUMMARY OF ANALYTICAL DATA FROM THE SAMPLED PLANT
ORIGINAL GUIDELINES SURVEY
COLD FORMING SUBCATEGORY
COLD WORKED - PIPE AND TUBE (USING WATER)
Raw Wastewater
Reference Code
Plant Code
Sample Point
Flow (gal/ton)
04 92 A
HH-2
1
1920
ng/ 1
lbs/1000 lbs
Suspended Solids
Oil and Grease
pH
23
63.3
5.8
0.184
0.507
Effluent
Sample Point
Flow (gal/ton)
C&TT
2
1910
Settling Lagoon, Skimmer
mg/1
lbs/1000 lbs
Suspended Solids
Oil and Grease
PH
4
2
0.032
0.016
6.2
216

-------
TABLE VII-2
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
Symbol8
A.	Operating Modes
1.	OT	Once-Through
2.	Rt,s,n	Recycle, where t ¦ type waste
s " stream recycled
n ¦ Z recycled
t: U ¦ Untreated
T » Treated
	8	n	
Process Wastewater Z of raw waste flow
Flume Only	Z of raw waste flow
Flume and Sprays Z of raw waste flow
Final Cooler	Z of FC flow
Barometric Cond. Z of BC flow
Aba. Vent Scrub. Z of VS flow
Fume Hood Scrub. X of FH flow
Reuse, where t " type
n ¦ Z of raw waste flow
t: U ¦ before treatment
T " after treatment
Blowdown, where n ¦ discharge as Z of
raw waste flow
B.	Control Technology
10. DI
Deionization
11. SR
Spray/Fog Rinse
12. CC
Countercurrent Rinse
13. DR
Drag-out Recovery
Disposal Methods

20. H
Haul Off-Site
21. DW
Deep Well Injection
P
F
S
FC
BC
VS
FH
REt,n
BDn
217

-------
TABLE VII-2
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 2
Disposal Methods (cont.)
D,
22.
Qt,d
Coke Quenching, where t = type
d = discharge as %
of makeup
t; DW ¦ Dirty Water
CW ¦ Clean Water
23.
EME
Evaporation, Multiple Effect
24.
ES
Evaporation on Slag
25.
EVC
Evaporation, Vapor Compression Distillation
Treatment
Technology
30.
SC
Segregated Collection
31.
E
Equalizati on/Blending
32.
Scr
Screening
33.
OB
Oil Collecting Baffle
34.
SS
Surface Skimming (oil, etc.)
35.
PSP
Primary Scale Pit
36.
SSP
Secondary Scale Pit
37.
EB
Emulsion Breaking
38.
A
Acidification
39.
AO
Air Oxidation
40.
GP
Gas Flotation
41.
M
Mixing
42.
Nt
Neutralization, where t ¦ type
t: L ¦ Lime
C ¦ Caustic
A ¦ Acid
W ¦ Wastes
0 ¦ Other, footnote
218

-------
TABLE VII-2
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 3
Treatment Technology (cont.)
43.	FLt	Flocculation, where t = type
t: L = Lime
A = Alum
P = Polymer
M = Magnetic
0 = Other, footnote
44.	CY	Cyclone/Centrifuge/Classifier
44a. DT Drag Tank
45.	CL	Clarifier
46.	T	Thickener
47.	TP	Tube/Plate Settler
48.	SLn	Settling Lagoon, where n = days of retention
time
49.	BL	Bottom Liner
50.	VF	Vacuum Filtration (of e.g., CL, T> or TP
underflows)
51.	Ft,m,h	Filtration, where t » type
m = media
h " head
	t		m 	h
D ¦ Deep Bed	S " Sand	G ¦ Gravity
F ¦ Flat Bed	0 « Other,	P ¦ Pressure
footnote
52.	CLt	Chiorination, where t * type
t: A ¦ Alkaline
B ¦ Breakpoint
53.	CO	Chemical Oxidation (other than CLA or CLB)
219

-------
TABLE VII-2
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 4		
D.	Treatment Technology (cont.)
54.	BOt	Biological Oxidation, where t • type
t: An - Activated Sludge
n ¦ No. of Stages
T ¦ Trickling Filter
B ¦ Biodisc
0 ¦ Other, footnote
55.	CR	Chemical Reduction (e.g., chromium)
56.	DP	Dephenolizer
57.	ASt	Amnonia Stripping, where t ¦ type
t: F ¦ Free
L " Lime
C ¦ Caustic
58.	APt	Amnonia Product, where t ¦ type
t: S ¦ Sulfate
N ¦ Nitric Acid
A ¦ Anhydrous
P ¦ Phosphate
H ¦ Hydroxide
0 ¦ Other, footnote
59.	DSt	Desulfurization, where t ¦ type
t: Q ¦ Qualifying
N • Nonqualifying
60.	CT	Cooling Tower
61.	AR	Acid Regeneration
62.	AU	Acid Recovery and Reuse
63.	ACt	Activated Carbon, where t » type
t: P ¦ Powdered
G ¦ Granular
64.	IX	Ion Exchange
65.	R0	Reverse Osmosis
66.	D	Distillation
220

-------
TABLE VII-2
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 5
D.	Treatment Technology (cont.)
67.	AA1	Activated Alumina
68.	OZ	Ozonation
69.	UV	Ultraviolet Radiation
70.	CNTt,n	Central Treatment, where t ¦ type
n = process flow as
X of total flow
t: 1 = Same Subcats.
2	¦ Similar Subcats.
3	= Synergistic Subcats.
4	* Cooling Water
5	* Incompatible Subcats.
71.	On	Other, where n * Footnote number
72.	SB	Settling Basin
73.	AE	Aeration
74.	PS	Precipitation with Sulfide
221

-------
PROC&SS : PIPES* TUB&S - COUP
WORU.&D
TO BLASTFURNACE,
COttE. PLANT, $ 2 OTHER
RESEBVOlB, INCLUDING QPfcM
t-lfcABTHS, ROLLING MILLS , ROD MILL 4 PIPE Ml LL
I&32 - 2013 SL/itC
(30,000- 31,000 GPM)
SETTLING
tCOOLIKIG
BASI N
¦2S.2C/5 £C.
(400 SPM)
CAUSTIC
SOLUTJOM
t*&»OfelN6l
A
HOT
RINSE
Water.
M2.SO4
PlCldLE
batu
COLD
RINSE.
WATER.
I
MOT
RINSE.
WAT EC.
Mt-NT
TANK
NEUTRA-
LIZ.EB
TA.NK.
OIL
SLIMMING.
BASIN
-4.731 i/stc-	MECHANICAL TU&INS MILL.
(75,000 GPM)	PRODUCTION SEQUENCE (TVPICaQ : 1,2,5, £,S,G»,4,7
25.1 t/sec.
(&OOGPM)
SETTLING
4 COOLING
EbkSl N
LABGfc MAIN
gfcSER.VQlR
STORAGE CAPACITY
- ao^&o.ooo
CUBIC MET&KS
(-M.SSO ACP&
PEET)
(S.ooo, OOP, OOP
GALLONS)
PUMP
station
1693 i/SEC.
(30,000 6
OIL SU.I MM&R
SETTLING
$ COO LI NG
BASI IS
DI5CMAa
-------
COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
SECTION VIII
COST, ENERGY, AND NONWATER QUALITY IMPACTS
Introduction
This section addresses the cost, energy, and nonwater quality impacts
of applying different levels of pollution control technology to cold
worked pipe and tube operations. The following topics are discussed:
actual treatment costs incurred by plants surveyed; the treatment
technologies and systems recommended for use in the cold worked pipe
and tube subdivision; and the cost, energy, and other nonwater
quality impacts associated with the application of BPT, BAT, BCT,
NSPS, PSES, and PSNS. In addition, air pollution, solid waste
disposal, and consumptive use of water impacts are addressed.
Actual Costs Incurred
BZ the Plant Surveyed for This Study
The water pollution control costs for the plant surveyed during this
study are presented in Table VIII-1. These costs were derived from
data presented in response to the D-DCPs. The costs have been
adjusted to July 1978 dollars.
Control and Treatment Technology
The treatment components and systems recommended for use are presented
in Tables VII1-2 and VII1-3. These tables provide a basic summary of
the treatment technologies which comprise the treatment models for the
cold worked pipe and tube subdivision of the cold forming subcategory.
On these C&TT summary tables, the following items are described for
each step:
1.	Treatment and/or control methods employed
2.	Status and reliability
3.	Problems and limitations
4.	Implementation time
5.	Land requirements
6.	Environmental impacts other than water
7.	Solid waste generation and primary constituents
Cost, Energy, and Nonwater Quality Impacts
General Information
The installation of BPT, BCT, BAT, NSPS, PSES, and PSNS systems may
require additional expenditures in terms of costs and energy and may
affect solid waste disposal and water consumption. The Agency
223

-------
estimated	costs and energy requirements on the bases of alternative
treatment	systems developed in Sections IX through XIII of this
report.	These costs and energy requirements are presented in this
section.
Estimated	Costs for the
Installation of Pollution Control Technologies
A.	Cost	Required to Achieve the Proposed BPT Limitations
In order to develop BPT compliance costs, the Agency developed
BPT model treatment systems sized to represent the average cold
worked pipe and tube plants found in the United States. Separate
models were necessary for the water and soluble oil mill
processes. The model sizes (tons/day) were developed on the
basis of the average production capacities of water and soluble
oil plants. The treatment model applied flows were also
developed using industry average flow values. The components and
effluent flows discussed in Section IX were then incorporated to
complete the development of the treatment models.
Some plants will have to incur additional capital and operating
costs to attain the proposed BPT limitations. The BPT model
costs are presented in Tables VIII-4 and VIII-5. However, not
all plants will incur all of these cost outlays, as many are
already operating at or near BPT. To obtain a more accurate
accounting of costs required for BPT, a capital cost tabulation
was performed for all pipe and tube mills. The tabulations,
presented in Tables VIII-6 and VIII-7, involve the application of
the model costs to each mill in both process subdivisions. These
tabulations summarize the treatment installed at each mill and
estimate the amount of money already expended and the costs yet
required to attain BPT.
The Agency estimates the capital costs of the BPT model treatment
system for all cold worked pipe and tube plants using water to be
$7.1 million. Of this total, $3.9 million is currently in place
and $3.2 million is associated with technology which remains to
be installed. The estimated industry annual operating cost of
the proposed BPT limitations for cold working pipe and tube
(using water) wastewaters is $1.8 million.
The Agency estimates the capital costs of the BPT model treatment
system for all of the cold worked pipe and tube plants using
soluble oil solutions to be $1.1 million. All of the necessary
technology is currently in place. The estimated industry wide
annual operating cost of the BPT limitations for cold worked pipe
and tube (using soluble oil solutions) wastewaters is $1.1
million.
B.	Costs Required to Achieve the BAT Limitations
The Agency is currently investigating the quality of wastewaters
from cold worked pipe and tube operations using water. If this
investigation reveals the presence of toxic pollutants in these
224

-------
wastewaters, a BAT limitation of zero discharge will be
promulgated for these operations. Since zero discharge is
proposed at BPT for pipe and tube operations using water, no
additional expense would be incurred at BAT. Refer to Table
VII1-4 for BPT model cost information.
The proposed BAT limitations for cold worked pipe and tube
operations using soluble oil solutions are identical to the
corresponding proposed BPT limitations. Therefore, no additional
expense is incurred at BAT. Refer to Table VII1-5 for BPT model
cost information.
C.	Cost Required to Achieve the BCT Limitations
The proposed BCT limitations for both types of cold worked pipe
and tube plants are equal to the corresponding proposed BPT
limitations. Therefore, no additional costs beyond BPT will be
incurred. Pipe and tube plants using water have been limited to
zero discharge at BPT. Similarly, it has been proposed that
those plants using soluble oil solutions discharge waste
solutions by contract hauling. Refer to Tables VI11-4 and VI11-5
for BPT model cost information.
D.	Costs Required to Achieve NSPS
New source performance standards apply to those facilities which
are constructed after the proposal of these standards. NSPS for
pipe and tube operations using water are proposed at zero
discharge. On a model plant basis, the estimated capital cost of
NSPS technology is $0.5 million. The corresponding annual cost
is about $0.09 million.
The Agency considered two alternative treatment systems for
plants using soluble oil solutions. The first alternative is
identical to the corresponding BPT model treatment system. On a
plant basis, the estimated capital cost of NSPS technology is
$0.42 million, while the annual cost is approximately $0.08
million. The second alternative is discussed in Section XII.
The corresponding costs for this alternative are presented in
Table VII1-8.
E.	Costs Required to Achieve the Pretreatment Standards
At this time, no specific pretreatment standards are being
proposed for cold worked pipe and tube plants using water.
Instead, the Agency is referencing "General Pretreatment
Regulations" for these operations. However, if the Agency's
current investigation reveals the presence of toxic pollutants in
these wastewaters, PSES/PSNS will be set equal to zero discharge.
Should a zero discharge standard be set at PSES/PSNS, the
pretreatment costs will be the same as the corresponding BPT
costs. Refer to Table VII1-4.
The proposed standard for new and existing pipe and tube plants
using soluble oil solutions is equal to the proposed BPT zero
225

-------
discharge limitation for plants using oil. Therefore, the
pretreatment costs will be the same as the corresponding BPT
costs. Refer to Table VII1-5.
Energy Impacts Due to the
Installation of the Model Technologies
Moderate amounts of energy are required by the various levels of
treatment in the cold worked pipe and tube subdivision of the cold
forming subcategory. All of the energy expenditures occur at the BPT
treatment level for those plants using water and for those plants
using soluble oil solutions which haul wastes. For new plants using
oil, which treat wastewaters rather than haul off-site, the major
energy expenditures will occur at the NSPS and PSNS levels of
treatment.
A.	Energy Impacts at BPT
The estimated energy requirements are based upon the assumption
that treatment systems similar to the treatment models presented
in this report are installed. On this basis, the energy use for
the BPT model treatment systems for all pipe and tube plants
using water is estimated at 160,000 kilowatt-hours of electricity
per annum. Similarly, the energy use for the BPT model treatment
system for all pipe and tube plants using soluble oil solutions
is estimated at 112,000 kilowatt-hours of electricity per annum.
Both estimates represent insignificant percentages of the 57
billion kilowatt-hours used by the steel industry in 1978.
B.	Energy Impacts at BAT
If the Agency's current investigation reveals the presence of
toxic pollutants in wastewaters from cold worked pipe and tube
mills using water, BAT for these operations will be promulgated
at zero discharge. Since zero discharge is also proposed at BPT
for pipe and tube operations using water, no energy expenditures
in excess of those incurred at BPT would be required.
As the BAT alternative treatment system for pipe and tube plants
using soluble oil solutions is identical to the corresponding BPT
model, no energy expenditures in excess of those incurred at BPT
are required.
C.	Energy Impacts at BCT
As the two BCT alternative treatment systems are identical to the
two corresponding BPT models, no energy expenditures in excess of
those incurred at BPT are required.
D.	Energy Impacts at NSPS
The energy requirements for the NSPS models follow. The Agency
did not estimate the energy impacts for NSPS since a
determination of the nujnber of new pipe and tube plants which
will open was not made as part of this study.
226

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For those pipe and tube plants using water, NSPS is proposed to
be zero discharge. The treatment system presented is identical
to the BPT model treatment system for water plants. On a per
plant basis, this treatment model will use 8,000 kilowatt-hours
of electricity per year.
For those pipe and tube plants using soluble oil solutions, the
energy requirements follow for the two NSPS alternatives.
Model	kw-hr per year
NSPS-1	8,000
NSPS-2	44,000
E. Energy	Impacts at Pretreatment
The energy impacts for the pretreatment models follow. The
Agency did not estimate the energy impacts for PSNS since a
determination of the number of new pipe and tube plants which
will discharge to POTWs was not made as part of this study.
At this time, no specific pretreatment standards are being
proposed for cold worked pipe and tube plants using water.
Instead, the Agency is referencing the "General Pretreatment
Regulations" for these operations. However, if the Agency's
current investigation reveals the presence of toxic pollutants in
these wastewaters, PSES/PSNS will be equal to zero discharge. A
zero discharge pretreatment model would use 8,000 kilowatt-hours
of electricity per year.
For those pipe and tube plants using soluble oil solutions, the
PSES and PSNS energy requirements (on a per plant basis) would be
8000 kilowatt-hours per year.
Nonwater Quality Impacts
In general, the Agency expects that the nonwater quality impacts
associated with the proposed treatment technologies will be minimal.
The three impacts evaluated are air pollution, solid waste disposal,
and water consumption.
A.	Air Pollution
No air pollution impacts are expected to occur for cold worked
pipe and tube mills as a result of the installation of the
treatment models.
B.	Solid Waste Disposal
The treatment steps incorporated in the BPT model treatment
systems will generate quantities of solids and oils and greases.
A summary of the solid waste generation for all pipe and tube
operations at the proposed BPT level of treatment follows.
227

-------
Treatment Level
Solid Waste Generation
Cold Worked Pipe and Tube Plants
	(Tons/Year)	
BPT Using Water
1,443
BPT Using Soluble Oils
17,800
If the Agency's current investigation of pipe and tube operations
using water reveals the presence of toxic pollutants in these
wastewaters, BAT will be promulgated at zero discharge. A zero
discharge BAT model would not generate additional solid waste
beyond the quantity generated at BPT.
The BAT level of treatment for cold worked pipe and tube plants
using soluble oils will not generate additional solid waste
beyond the quantity generated at BPT.
Following are the estimated amounts of solid wastes generated by
the NSPS and Pretreatment models.
NSPS for cold worked pipe and tube plants using water has been
set at zero discharge. This NSPS model will generate 72
tons/year of solid waste. At this time, no specific pretreatment
standards are being proposed for cold worked pipe and tube plants
using water. Instead the Agency is referencing the "General
Pretreatment Regulations" for these operations. However, if the
Agency's current investigation reveals the presence of.toxic
pollutants in these wastewaters, PSES/PSNS will be equal to zero
discharge. A zero discharge pretreatment model would also
generate 72 tons/year of solid waste.
The estimated amounts of solid wastes generated by the NSPS and
Pretreatment models for cold worked pipe and tube mills using
soluble oil solutions follow.
C. Water Consumption
No significant water consumption is expected to occur for c6ld
working pipe and tube mills as a result of the installation of
the proposed treatment systems.
Summary of Impacts
The Agency concludes that the effluent reduction benefits described
below for the cold worked pipe and tube subdivision justify any
Treatment Level
Solid Waste Generation
Treatment Model
	(Tons/Year)	
NSPS-1
NSPS-2
PSES/PSNS
91
91
91
228

-------
adverse impacts associated with energy consumption, air pollution,
solid waste disposal, or water consumption.
	Effluent Discharge (Tons/Year)	
Raw Waste1 Proposed BPT Proposed BAT
Using Water
Flow, MGD	29.6	0	0*
TSS	802	0	02
Oil & Grease	2,086	0	02
Using Soluble Oil Solutions
Flow, MGD	18.0	0	0
TSS	19,550	0	0
Oil & Grease	1,955,000	0	0
Total Organics	541.5	0	0
1	Raw waste loadings are based upon estimated concentrations from
cold rolling (oil) and analytical data (water).
2	If the Agency's current investigation reveals the presence of
toxic pollutants in these wastewaters, BAT will be promulgated at
zero discharge.
229

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TABLE VIII-1
EFFLUENT TREATMENT COSTS
COLD FORMING SUBCATEGORY
COLD WORKED - PIPE AND TUBE (USING SOLUBLE OIL SOLUTIONS)
(All costs are expressed in July, 1978 dollars)
Reference Code	0240B
Initial Investment Cost	13,390
Annual Costs
Cost of Capital	1,340
Depreciation	670
Operation and Maintenance	235
Energy, Power, Chemicals, etc.	35
Other	210
TOTAL	2,490
$/Ton	1.93
NOTE: All cost values were taken from the D-DCP.
230

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TABLE VIII-2
COimtOL AKD TREATMENT TECOIOLOC1ES
COLD FOUOHG SUBCATEGORY
GOLD WORKED - PIPE AMD TOE (OSIMC WATER)
IO
U)
Treatment and/or
Cootrol Methods Employed
A.	Scale pit with cla shell -
Provide! for primary settling of
the majority of solid waste.
Solids ere moved by cl« shell*
B.	Surface ikiver - Removes oils
and greases fros the surface of
the wastewater.
C. Recycle * The total flow fr
the filter la returned to the
process.
Status and
Reliability
Very reliable, widely used
in this and other relsted
subcategories.
Widely used in this subcate-
gory and throughout the
steel industry.
Widely osed in this and other
related subcategories.
Problens
and Limitations
Accumulated solids
must be periodically
removed.
Hydraulic overload
or surface turbulence
will reduce effective-
ness.
Potential for scaling,
plugging or fouling
due to increasing
concentrations of
diaaolved solida in
the recycled water.
The pomps require
maintenance.
Implemen-
tation
Time
6-8
months
3 months
12-14
months
Land
Requirements
15 'x201
Environmental
Impact Other
Than Water
Accumulsted
solids must be
disposed of
properly.
Ho sddi-	The skimswd oils
tional	and greases must
land required, be disposed of
properly.
25*x25'
Rone
Solid Waste
Generation and
Primary
Constituents
Generates rela-
tively dry sludge.
Generates oils
and greases.

-------
TABLE VIII-3
CONTROL AND TREATMENT TECHNOLOGIES
COLD FORMING SUBCATEGORY
COLD WORKED - PIPE AND TUBE (USING SOLUBLE OILS)
fO
u>
to
Treatment and/or
Control Methods Employed
A.	Scale pit with clan shell -
Provides for primary settling
of the majority of solid wastes.
Solids are removed by clam shell.
B.	Surface skimmer - Removes
tramp oils and greases from
surface of solutions.
C.	Recycle - Virtually all
process flow is recycled.
D.	Storage tank and contractor
removal * spent oil solution
is stored and hauled off-site
as required.
E.	Equalisation tank - Collects
and stores the wasteload for
future batch treatment.
Status and
Reliability
Very reliable, widely used
in this and other related
subcategories.
Widely used in this subcate-
gory and throughout the
steel industry.
Most plants recycle
their solutions.
This method is used by more
than 90Z of the mills in this
subcategory.
Practiced throughout the
steel industry.
Problems
and Limitations
Accumulated solids
must be periodically
removed.
Hydraulic overload
or surface turbulence
will reduce effective-
ness.
Much maintenance is
requi red.
None
None
Implemen-
tation	Land
Time Requirements
6-8
months
16'x22f
3 months No addi-
tional
land
required.
12-14
months
25'x25'
Environmental
Impact Other
Than Water
Accumulated
solids must be
disposed of
properly.
The skimmed oils
and greases
must receive
proper disposal.
None
None
Solid Waste
Generation and
Primary
Constituents
Generates rela-
tively dry sludge.
Generates oils
and greases.
None
None
F.	Acid addition - Acid is added
in a reactor vessel to break the
oil emulsion.
G.	Alum addition - Aim is used
in conjunction with Step E to
aid in breaking the oils.
Practiced in related
subcategories.
Practiced in related
subcategories.
Increased cost unless
source of acid exists
at plant.
Increased chemical
cos t s.
None
None
None
None

-------
TABLE V1II-3
CDHTBOL AMD TREAT**! TECHNOLOGIES
gold forming SUBCATEGORY
COLD WORKED * PIPE AJQ> TOTE (USING SOLUBLE OILS)
FACE 2 		
Treatment and/or
Coot rot Method Eapl eyed
H. LiM addition - List
neutralise* the wastes in the
flocculator aixing tank.
Status and
Reliability
Practiced in related
subcategories•
Problems
and Limitations
Increased cheaical
costs. This step
generates a significant
solids loading that
cannot be discharged
without further treat-
aent •
Iaplmn-	Envi ronaent al
tat ion	Land	lapact Other
Ti»e Eequireaents	Than Water
*	*	Hone
Sol id Waste
Generation and
Priaary
Constituents
Produces significant
quantities of
sludge that is of
a consistency
which is
difficult to
dispose of.
K>
OJ
u>
I. Poly addition - Poly is added
to waste solution in conjunction
with Step G to proaote settling.
J. Air flotation - Suspended or
oily aateriala rise to the
surface attached to air bubbles.
Practiced throughout the
steel industry. Reliable
coagulation Bethod.
Practiced in related
subcategories.
Increased cheaical
costs.
Requires care not to
disturb flotants prior
to reaoval.
Hone
Possibility of
obnoxious gases
in ianediate area
surrounding the
URL t .
Wo significant
aaount of sludge
is generated.
Oils recovered
froa flotation
unit may be able to
be reused. If not,
they aay be in-
cinerated or
disposed of in a
landfill.
K. Settling basin - Additional
solid waste reduction is
accoaplished.
L. Filtration - Treat effluent
froa Step J via passage through
a filtration unit.
Practiced throughout the
steel industry.
Practiced throughout
the steel industry.
Accuaulated solids
aust be periodically
reaoved.
Increased capital
and operating costs.
Possibility of
producing ob-
jectionable
odors.
Sludges accuaulated
in basins aust be
periodically re-
aoved and disposed
of properly.
Seme additional
sludge will be
generated when the
filters are back-
washed.
*: Since the wasteload is so saall, iapleaentatioo tiae and land requireaents for
Steps F through L have been coabicted. They total approxiaately
one year and 50*x50'.

-------
TABLE VIII-4
BPT MODEL POST; BASIS 7/1/78 DOLLARS
Subcategory: Cold Forming	Model Size - TPD:	500
: Cold Worked	Oper. Days/Year :	260
Pipe and Tube	Turns/Day :	3
: (Using Water)
C&TT Step	A	B	C	Total
-3
Treatment $ x 10~3 ,	106	20	372	498
Annual cost $ x 10
Capital	4.6	0.8	16.0	21.4
Depreciation	10.6	2.0	37.2	49.8
Operation and Maintenance	3.7	0.7	13.0,17.4
Energy and Power	-	0.2	5.8	0.2
Oil Disposal	-	1.4	-	1.4
TOTAL	18.9	5.1	66.2*2)	90.2
Raw	BPT
Waste	Effluent
Effluent Quality	Level	Level
Flow, gal/ton	2960	0
Total Suspended Solids	25
Oil and Grease	65
pH, Units	6-9
(1)	Costs are all power unless otherwise noted.
(2)	Total cost does not include power, because a credit is supplied for existing
process water requirements.
(3)	All values are in mg/1 unless otherwise noted.
KEY TO C&TT STEPS
A: Scale Pit
B: Oil Skimmer
C: Recycle
234

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TABLE VIII-5
BPT MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory:
Cold Forming
Cold Worked
Pipe and Tube
(Using Soluble
Oil Solutions)
Model Size - TPD
Oper. Days/Year
Turns/Day
270
26U
C&TT Step
Investment $ x 10
-3
10
-3
Annual Cost $ x
Capital
Depreciation
Operation and Maintenance
Sludge Disposal
Energy and Power
Oil Disposal
TOTAL
87
3.8
8.7
3.1
2.1
17.7
B
17
0.8
1.8
0.6
0.2
3.4
309
13.3
30.9
10.8
4.7
(2)
55.0
(2)
11
0.5
1.1
0.4
0.3
2.3
Total
424
18.4
42.5
14.9
2.1
0.2
0.3
78.4
(3)
Effluent Quality
Flow, gal/ton
Total Suspended Solids
Oil and Grease
pH, Units
Raw
Waste
Level
4770
1000
10%
6-9
BPT
Effluent
Level
(1)	Costs are all power unless otherwise noted.
(2)	Total cost does not include power, because a credit is supplied for existing
process water requirements.
(3)	All values are in mg/1 unless otherwise notqd.
KEY TO C&TT STEPS
A: Primary Scale Pit
B: Surface Skimming
C: Recycle
D: Storage and
Contract Hauling
235

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TABLE VIII-6
BPT CAPITAL OOST TABULATION
BASIS: 7/1/78 DOLLARS X 10
: FACILITIES IN PUCE AS OF 1/1/78
Subcategory: Cold Forming
: Cold Worked Pipe & Tube
: (Using Water) Carbon & Specialty
Plant




In


Code
TPD
A
B
C
Place
Required
Total
0060
196
60

212
272
0
272
0060 P
7
572
1.5
2*77
0
38.4
38.4
0112 A
858
147
28
514
28
661
689
0112 E
1134
173
31
608
781
33
814
0176 C
23
17
3
39~
59
20
79
0176 D
9
9.5
1.8
3T.4
33.4
11.3
44.7
0256 F
5
-
-
7377
23.5
0
23.5
0432 A
444
-
-
346
346
0
346
0492 A
2266
262
50
m-801
432
801
1233
0584 H
246
W
n
I37-19
306
19
325
0684 A
1050
165
31
555-145
600
176
776
0856 N
435
W
18
342
116
342
458
0856 Q
1155
175
u
615
208
615
823
0864 A
489
m
Iff
367
125
367
492
0884 C
21
IS"
T"
56
0
75
75
0884 E
14
12.4
2.3
43.5
0
58.2
58.2
0908
156
-
-
185
185
0
185
0908 A
612
-
-

420
0
420





3
-------
Subcategory
TABLE VIII-7
BPT CAPITAL COST TABULATION
BASIS: 7/1/78 DOLLARS X 10
; FACILITIES IN PLACE AS OF 1/1/78
Cold Forming
Cold Worked Pipe & Tube
(Using Soluble Oil Solutions) Carbon & Specialty
Plant
In
Code

TPD
A
B
C
D
Place
Required
Total
0080
A
65
—
—
—
4.7
4. 7
0
4. 7
0240
B
273
-
-
311
11
322
0
322
0240
C
482
-
-
wr
16
453
0
453
0256
F
189
-
-
249
-
249
0
249
0856
Q
1107
-
-
-
26
26
0
26
0916
A
72
-
-
-
3"
5
0
5
1059.7*
0*
1059.7*
* Totals do not include confidential plants.
Note: Underlined costs represent facilities in place.
KEY TO C&TT STEPS
A: Primary Scale Pit
B. Surface Skimming
C: Recycle
D: Storage and
Contract Hauling
237

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TABLE VIII-8
USPS ALTERNATIVE 2 COST DATA! BASIS 7/1/78 DOLLARS
Subcategory! Cold Fonint
I Cold Worked Pip* and Tube
I (tiling Soluble Oil Solutions)
Model Sits - TPDl 270
Op«r. Days/Year i ijQ
Turns/Day	j ~~y
C6TT Stop*
„-3
Investment } j lo"
Annual Cost $ x 10
Capital
Depreciation
Operation and Maintenance
Sludge Disposal..
Energy i Power11'
Chaaical Costs
Oil Disposal
TOTAL
A
B
C
E
r
0
H
1




——>
-
" -

87
17
309
29
33
32
34
36
3.8
0.8
13.3
1.2
1.4
1.4
1.3
1.8
8* 7
1.8
30.9
2.9
3.3
3.2
3.4
3.6
3.1
0.6
10.8
1.0
1.1
1.1
1.2
1.3
2.1
0.2
;.7<»
0.1
0.1
0.1
0.1
0.2
-
-


nil
Nil
Ril
Nil
17.7
3.4
55.0(2)
5.2
5.9
5.8
6.2
6.7
J
33
1.4
3.3
1.2
0.2
0.2
0.3
6.6
K
11
0.5
1.1
0.4
L
44
1.9
4.4
1.3
0.1
2.0 7.9
Total
666
28.8
66.6
23.3
2.3
1.1
0.3
122.4
Effluent Quality
'low, gal/ton
Suspended Solids
Oil and Grease
pa
<3)
USPS
Paad
Level
4770
1000
10Z
6-9
USPS
Effluent
Level
0.5
15
5
6-9
(1)	Coats are all power unless otherwise noted.	...	_ .
(2)	Totsl does not include power, as a credit is supplied for exieting process water requirements.
(3)	All values are in mg/l unless otherwise noted.
EKT TO C6TT STEPS
At
Cl
r>
Hi
Ji
Li
Scale Pie with Cls
Recycle
Acid Addition
Lisa Addition
Air Flotation
Filtration
Shall
Bl
Ei
C>
Ii
Ii
Surface Skinner
Equalization Tank
Alia Addition
Poly Addition
Settling Basin
238

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COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
SECTION IX
EFFLUENT QUALITY ATTAINABLE THROUGH
THE APPLICATION OF THE BEST PRACTICABLE CONTROL
TECHNOLOGY CURRENTLY AVAILABLE
Introduction
The Best Practicable Control Technology Currently Available (BPT)
limitations originally promulgated for the pipe and tube subcategory
are not applicable to cold worked pipe and tube operations. As
explained previously, the original limitations were developed based
primarily upon hot working pipe and tube operations. The proposed BPT
limitations for cold worked pipe and tube operations are reviewed
below.
Identification of BPT
Based upon the information contained in Sections III through VIII of
this report, the BPT model treatment systems for the cold worked pipe
and tube subdivision are as follows.
A.	Cold Worked Pipe and Tube Plants Using Water
The BPT model treatment system involves settling of the raw
wastewater in a primary scale pit equipped with oil skimming
equipment. All of the treated wastewater is then recycled back
to the process. This system achieves zero wastewater discharge.
B.	Cold Worked Pipe and Tube Plants Using Soluble Oil Solutions
The BPT model treatment system involves settling of the raw waste
solution in a primary scale pit equipped with oil skimming
equipment which removes tramp oils. A large percentage of the
solution is then recycled back to the process. The spent
solution is periodically removed by a contract hauler so that
there is no discharge to navigable waters.
Figures IX-1 and IX-2 depict the treatment systems described
above. The proposed BPT limitations do not require the
installation of the model treatment systems; any treatment which
achieves the proposed limitations is acceptable.
Rationale for BPT Treatment Systems
As noted in Section VII, each of the components in the BPT model
treatment systems is demonstrated at a large number of cold worked
operations.
239

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Justification of Proposed BPT Limitations
The proposed BPT limitation for cold worked pipe and tube plants using
water is zero discharge. Justification of this limitation is
presented in Table ix-1.
It is proposed that the discharge flow of 0.5 gal/ton, from cold
worked pipe and tube plants using soluble oils, be periodically hauled
off-site for disposal, so there will be no discharge from cold worked
operations to navigable waters. Approximately 86% of the cold worked
pipe and tube plants using soluble oils presently have spent oil
solutions hauled off-site for disposal. Incineration is another
method of disposal of spent oil solutions which achieves the zero
discharge limitation.
240

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TABLE IX-1
SUMMARY OF FLOWS AND BPT JUSTIFICATION
COLD FORMING SUBCATEGORY
COLD WORKED - PIPE AND TUBE (USING WATER)
Plant Reference	Discharge Flow
Code		(gal/ ton)	Basis
0060 (01-08)	0*	DCP
0256F( 04-06 )	0*	DCP
0432A(05)	0*	DCP
0684K(01)	0*	DCP
0684K(03-07)	0*	DCP
0908	0*	DCP
0908A( 01)	0*	DCP
0 90 8A( 02)	0*	DCP
0684 A( 01)	453	DCP
0864A	589	DCP
0884C	720	DCP
0492A(04)	1910	Visit
0492A(03)	2039	DCP
0856N(05)	2979	DCP
0584H	3512	DCP
0492 A( 01)	17731	DCP
0492A(02)	26926	DCP
*: Flow values used in the "Average of the Best" calculation.
Average Discharge Flow: 1895
"Average of the Best" Discharge Flow: 0 gal/ton
Proposed Flow Basis: 0 gal/ton.
241

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100% RECYCLE
2960 gal/ton
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD FORMING SUBCATEGORY
COLD WORKING: PIPE AND TUBE
USING WATER
BPT TREATMENT MODEL
Dwa7/KV80


FIGURE IX" 1




-------
4770 gal/ton
$1
SCALE PIT
STORAGE
0.5 gal/ton
CONTRACTOR
REMOVAL
AS REQUIRED
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY 9TUDY
COLD FORMING SUBCATEGORY
COLD WORKING: PIPE AND TUBE
SOLUBLE OIL SOLUTIONS
BPT TREATMENT MODEL
Dwn.7/10/80
FIGURE IX-2

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COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
SECTION X
EFFLUENT QUALITY ATTAINABLE THROUGH
THE APPLICATION OF THE BEST AVAILABLE TECHNOLOGY
ECONOMICALLY ACHIEVABLE
The Best Available Technology Economically Achievable (BAT) effluent
limitations are to be attained by July 1, 1984. BAT is determined by
reviewing subcategory practices and identifying the best economically
achievable control and treatment technologies employed within the
subcategory. In addition, a technology that is readily transferable
from another subcategory or industry may be identified as BAT.
Based upon the data available, the Agency has been unable to determine
whether or not toxic pollutants are present in wastewaters from cold
working pipe and tube operations using water. At this time the Agency
is continuing its investigation of these wastewaters. If toxic
pollutants are found, the Agency will promulgate a BAT limitation of
zero discharge for cold worked pipe and tube mills using water. This
technology is illustrated in Figure IX—1 and is identical to the model
BPT technology.
In the BPT model treatment system, for the cold worked pipe and tube
plants using soluble oil solutions, (illustrated in Figure IX-2), most
of the waste solution is recycled, with a small amount collected by
contract haulers for off-site disposal. This disposal could also be
accomplished through incineration. The Agency is proposing a BAT
limitation of zero discharge for these operations based upon the
likely presence of toxic organic pollutants as described in Section V.
245

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COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
SECTION XI
BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
Introduction
The 1977 Amendments added section 301(b)(4)(E) to the Act,
establishing "best conventional pollutant control technology" (BCT)
for discharges of conventional pollutants from existing industrial
point sources. Conventional pollutants are those defined in section
304(b) (4) - BOD, TSS, fecal coliform, and pH - and any additional
pollutants defined by the Administrator as "conventional." On July
28, 1978, EPA proposed that COD, oil and grease, and phosphorus be
added to the conventional pollutant list (43 Fed. Reg. 32857). Only
oil and grease was added.
BCT is not an additional limitation, but replaces BAT for the control
of conventional pollutants. BCT requires that limitations for
conventional pollutants be assessed in light of a new
"cost-reasonableness" test, which involves a comparison of the cost
and level of reduction of conventional pollutants from the discharge
of POTWs to the cost and level of reduction of such pollutants from a
class or category of industrial sources. As part of its review of BAT
for certain "secondary" industries, EPA proposed methodology for this
cost test. (See 43 Fed. Reg. 37570, August 23, 1978).
The BCT model treatment system for cold worked pipe and tube plants
using water, (illustrated in Figure IX-1), achieves zero discharge by
recycling 100% of the process water. In the BCT model treatment
system, for cold worked pipe and tube plants using soluble oil
solutions, (illustrated in Figure IX-2) the spent oil solutions are
hauled off-site. Contractor removal is a means of achieving zero
discharge from those plants. Incineration in industrial boilers or
furnaces is another method of achieving zero discharge of these
wastes.
No BCT tests were carried out for the operations in this subdivision,
because proposed BCT limitations do not incorporate further load
reductions than the proposed BPT limitations. Accordingly, the Agency
is proposing BCT limitations which are the same as the proposed BPT
limitations.
247

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COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
SECTION XII
EFFLUENT QUALITY ATTAINABLE THROUGH THE
APPLICATION OF NEW SOURCE PERFORMANCE STANDARDS
Introduction
A new source is defined as any source constructed after the proposal
of New Source Performance Standards (NSPS). The effluent standards
which must be achieved by new sources specify the degree of effluent
reduction achievable through the application of the Best Available
Demonstrated Control Technology (BADCT), including, where applicable,
a standard permitting no discharge of pollutants. This section
identifies the alternatives considered for NSPS and the resulting
effluent levels for cold worked pipe and tube operations. In
addition, the rationale for selection of the NSPS treatment systems,
flow values, and proposed effluent standards are presented.
Identification of NSPS
Pipe and Tube Plants Using Water
The NSPS model treatment system for plants using water is identical to
the BPT model treatment system corresponding to those same plants.
This system, which is illustrated in Figure IX-1, consists of a scale
pit, oil skimmer, and recycle mechanism. As this is a total recycle
system, there is no discharge.
Pipe and Tube Plants Using Soluble Oil Solutions
A.	NSPS Alternative 1
The first NSPS alternative treatment system considered for plants
using oil solutions is identical to the BPT model treatment
system corresponding to those same plants. This system, which is
illustrated in Figure IX-2, consists of a scale pit, oil skimmer,
and recycle mechanism. The entire process flow, except for 0.5
gal/ton, is returned to the process for recycle. The 0.5 gal/ton
of spent oil solution is sent to a storage tank. The solutions
are removed from the tank by contract hauler as required. Thus
there is no discharge from cold worked operations at the plant.
B.	NSPS Alternative 2
In response to industry comments, an NSPS alternative
incorporating treatment and discharge of the oil solution
blowdown was considered by the Agency (Figure XII-1). In this
alternative, the oil solutions pass through a scale pit with an
oil skimmer. Most of the oil is recycled to the process with 0.5
249

-------
gal/ton directed to an equalization and storage tank, with a one
week detention time, prior to further treatment. It is necessary
to accumulate the waste solutions in order to provide a
reasonably sized flow for the rest of the treatment cycle.
However, for an eight hour treatment cycle, the flow rate remains
small, only 2.0 gal/min. The first component in this cycle is a
reactor into which acid and alum are added. These chemicals help
break the soluble oils which are present. Lime and
polymer/polyelectrolyte are then introduced in the flocculator.
The lime neutralizes the solution, while the
polymer/polyelectrolyte helps to coagulate the oils. An air
flotation device follows which helps to raise the pollutant
particles to the surface of the vessel for separation. Sludge is
removed at this point. A settling basin and filter complete the
treatment system by removing solids and oils which have not been
separated out by the preceding treatment steps. The treated
effluent is then batch discharged to a receiving stream. Because
the Agency does not believe NSPS Alternative No. 2 is
practicable, no effluent standards were developed based on this
alternative.
Rationale for Selection of NSPS
Treatment Systems
The NSPS alternative treatment systems presented for consideration for
cold worked pipe and tube plants are either similar to treatment
schemes presently in use in this subdivision or have been transferred
from similar operations in other cold worked metals manufacturing
processes.
Flows
The applied and discharge flows developed for these NSPS models are
representative of actual flows found in cold worked pipe and tube
plants. Process information provided for these plants was used in
developing the average values.
Selection of NSPS Alternative
Pipe and Tube Plants Using Mater
There is only one NSPS treatment system considered, which is a zero
discharge system. That system is illustrated in Figure IX-1.
Pipe and Tube Plants Using Oil
Alternative No. 1, the system illustrated in Figure IX-2, is the
selected NSPS alternative for plants using soluble oil solutions.
This selection was based primarily on practicality. With the second
alternative, the amount of waste oil solution discharged from the
recycle system for further treatment is very small. Over an eight
hour period, the resulting flow rate is only 2.0 gal/min. The
components used to treat this flow would be extremely small, yet they
would still be costly. For these reasons, Alternative 1, in which the
250

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minimal wastes are removed by contract haulers, was chosen. As an
alternative, incineration of these wastes could be accomplished in
industrial boilers or furnaces. Both methods would accomplish zero
discharge, the NSPS treatment level proposed for these operations.
251

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ACID
2.0 gal/min—\
(BASED ON AN
8 HR. TREAT-
MENT CYCLE)
ALUM
I
SCALE PIT
EQUALIZATION
TANK
(OIL SOLUTIONS
ACCUMULATED
REACTOR
4770 gal/tan
0.5 gal/ton
FOR A ONE WEEK
PERIOD.)
SETTLING
BASIN
FLOCCULATOR FLOTATOR
AIR
BATCH
DISCHARGE
LIME
POLY
SLUDGE
FILTERS
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
COLD FORMING SUBCATEGORY
COLD WORKING: PIPE AND TUBE
SOLUBLE OIL SOLUTIONS
NSPS TREATMENT ALTERNATIVE 2
Dwn.7AV80
FIGURE 3H-

-------
COLD FORMING SUBCATEGORY
COLD WORKED PIPE AND TUBE
SECTION XIII
PRETREATMENT STANDARDS FOR COLD WORKED
PIPE AND TUBE OPERATIONS DISCHARGING TO PUBLICLY
OWNED TREATMENT WORKS
Introduction
This section discusses the control and treatment systems available for
cold worked pipe and tube operations which discharge waste solutions
to publicly owned treatment works (POTWs). Consideration has been
given to the pretreatment of cold worked process waste solutions from
new sources (PSNS) and from existing sources (PSES).
General Pretreatment Standards
General Pretreatment Regulations 40 CFR Part 403, are applicable to
all sources. For detailed information on Pretreatment Standards refer
to 43 FR 27736-27773, "General Pretreatment Regulations for Existing
and New Sources of Pollution," (June 26, 1978). In particular, 40 CFR
Part 403 describes national standards (prohibited discharges and
categorical standards), revision of categorical standards, and POTW
pretreatment programs.
In establishing pretreatment standards for cold worked pipe and tube
operations, the Agency gave primary consideration to the objectives
and requirements of the General Pretreatment Regulations. The Agency
also considered additional factors which are specifically applicable
to cold worked pipe and tube operations.
The General Pretreatment Regulations set forth general discharge
prohibitions that apply to all nondomestic users of a POTW to prevent
pass through of pollutants, interference with the operation of a POTW,
and municipal sludge contamination. The regulations also establish
administrative mechanisms to ensure application and enforcement of
prohibited discharge limits and categorical pretreatment standards.
In addition, the Regulations contain provisions relating directly to
the determination of and reporting on pretreatment standards.
POTWs are usually not designed to treat the toxic organic pollutants
and emulsified oils which might be present in cold worked pipe and
tube operations using soluble oil solutions. Instead, POTWs are
designed to treat biochemical oxygen demand (BOD), total suspended
solids (TSS), fecal coliform bacteria, and pH. Any removal of the
toxic organic pollutants which a POTW might obtain is incidental to
its main function of treating conventional pollutants.
In the past, POTWs have accepted pollutants in quantities much greater
than their capacity for adequate treatment. As the issue of municipal
253

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sludge use has become more important, pretreatment standards must
address toxic pollutant removal. The transfer of toxic pollutants to
POTWs only concentrates the pollutants in sludges.
Identification of Pretreatment
Standards for Existing and New Sources
A.	Using Water
Available data demonstrate that many cold worked operations using
water employ total recycle systems, while very few discharge to
POTWs. As no toxic pollutants have yet been detected in cold
worked pipe and tube operations using water, no specific
pretreatment standards are proposed for these operations at this
time. Instead, the Agency references 43 FR 27736-27773, "General
Pretreatment Regulations for Existing and New Sources of
Pollution," (Monday, June 26, 1978) for these operations. Should
toxic pollutants be found in these wastewaters, as a result of
the Agency's continuing investigation, the Agency will promulgate
PSES and PSNS based upon zero discharge. This technology is
described in Section IX.
B.	Using Soluble Oil Solutions
Waste oil solutions from most plants are currently hauled
off-site for disposal by contractors. None of these plants
discharge spent oil solutions to a POTW. To insure that these
solutions, which may contain large quantities of toxic organics
and emulsified oils not treatable by municipal systems, do not
pass through POTWs or interfere with their operation, a zero
discharge standard is being proposed for these operations.
254

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ALKALINE CLEANING SUBCATEGORY
SECTION I
PREFACE
The USEPA is proposing effluent limitations guidelines and standards
for the steel industry. The proposed regulation contains effluent
limitations guidelines for best practicable control technology
currently available (BPT), best conventional pollutant control
technology (BCT), and best available technology economically
achievable (BAT) as well as pretreatment standards for new and
existing sources (PSNS and PSES) and new source performance standards
(NSPS), under Sections 301, 304, 306, 307 and 501 of the Clean Water
Act.
This part of the Development Document highlights the technical aspects
of EPA's study of the Alkaline Cleaning Subcategory of the Iron and
Steel Industry. Volume I of the Development Document discusses issues
pertaining to the industry in general, while other volumes relate to
the remaining subcategories of the industry.
255

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ALKALINE CLEANING SUBCATEGORY
SECTION II
CONCLUSIONS
This report highlights the Agency's evaluation of the Alkaline
Cleaning subcategory. Based upon additional data obtained through
field sampling, analyses, and questionnaires the Agency has reached
the following conclusions.
1.	Although alkaline cleaning operations are conducted on both a
batch and continuous basis, the Agency has not subdivided the
alkaline cleaning subcategory on that basis since similar
effluent flow rates and effluent quality can be achieved for both
operations.
2.	The model treatment system used as a basis for the BPT
limitations promulgated in 1976 for alkaline cleaning operations
remains applicable for all operations in this subcategory. The
model treatment system consists of equalization and oil
separation, polymer and acid addition followed by sedimentation
in a flocculation-clarifier. Sludges are dewatered in a vacuum
filtration system.
3.	The Agency is not proposing limitations for dissolved chromium,
nickel, and iron as were contained in the originally promulgated
BPT regulation. Data gathered for this study demonstrate that
these pollutants are found only in low concentrations in raw
alkaline cleaning wastewaters. The discharge of pollutants in
the alkaline cleaning subcategory at the proposed BPT level of
treatment is characterized as follows.
Effluent Loadings (Tons/Yr)
RawProposed
Waste	BPT
Flow, MGD	2.9	2.9
TSS	1,521	76
Oil and Grease	61	30
Dissolved Iron	1.5 1.5
Toxic Metals	0.8	0.8
Toxic Organics	0.2	0.2
4. Based upon facilities in place as of January 1, 1978, the Agency
estimates the following costs will be incurred by the industry to
bring alkaline cleaning operations into compliance with the
proposed BPT limitations.
257

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Costs (Millions of July 1, 1978 Dollars)
Investment Costs
Annual
Costs
Total Required In-Place
BPT $13.6
$7.1
$6.5
$4.2
5.	Sampling and analyses of alkaline cleaning wastewaters revealed
that low concentrations of toxic pollutants are found in the raw
wastewaters. Aside from flow reduction, the Agency is not aware
of any economically achievable method to further reduce the
discharge of low levels of toxic pollutants. The Agency also
lacks sufficient information to determine whether reduction of
alkaline cleaning wastewaters is feasible. Hence, the Agency is
not proposing BAT limitations for this subcategory.
6.	The Agency evaluated the "cost/reasonableness" of controlling the
discharge of conventional pollutants in this subcategory by a
variety of treatment methods. However, the cost to control these
pollutants is far in excess of the comparable POTW costs.
Therefore, EPA is proposing BCT limitations for the alkaline
cleaning subcategory that are the same as the proposed BPT
1 imitations.
7.	The Agency is not proposing specific pretreatment standards for
the alkaline cleaning subcategory since the pollutants present in
these wastewaters are compatible with POTW systems. The general
pretreatment standards apply to the alkaline cleaning *
subcategory.
8.	With respect to the "remand issues," the Agency has reached the
following conclusions.
a.	The age of an alkaline cleaning line has no significant
effect upon the ease or cost of retrofitting pollution
control equipment. Therefore, neither relaxed limitations
for "older" lines nor retrofit cost allowances are included
for alkaline cleaning operations.
b.	The remand also required examination of the consumptive use
of water that would result from compliance with the proposed
effluent limitations. Since no cooling systems are included
in any of the model treatment systems, little or no
consumption of water due to wastewater treatment is
expected. Hence, there is no impact on the consumptive use
of water.
9.	The Agency believes that cascade rinsing and direct recycle of
treated alkaline cleaning rinsewaters may be feasible. However,
the Agency has limited information or data about recycle as
practiced in this subcategory. Hence, the Agency solicits
comments and information on whether flow reduction of the BPT
effluent by recycle or other means should be considered as BAT
and BCT alternative treatment systems. The Agency estimates the
cost to recycle ninety percent of the BPT effluent would be $5.5
million for this subcategory. The resultant effluent quality
258

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would be as follows for a model plant in comparison to the
proposed BPT effluent limitations.
Proposed
Proposed
BCT
BPT
mq/1
kq/kkq mq/1
kq/kkq
Flow, GPT
TSS
25 0.0052 25
50
5
0.00052
0.00021
0.000010
0.000005
0.000001
Oil and Grease
Dissolved Iron
Toxic Metals
0.50 0.00010 0.50
0.25 0.00005 0.25
0.055 0.00001 0.055
10 0.0021 10
Toxic Organics
Table 11-1 presents the treatment model flow and effluent quality
data used to develop the proposed BPT effluent limitations for
the alkaline cleaning subcategory, and Table I1-2 presents these
proposed limitations. Table I1-3 presents the treatment model
flow and effluent quality data used to develop the proposed BAT
and BCT effluent limitations and the proposed NSPS, PSES, and
PSNS for the alkaline cleaning subcategory; Table I1-4 presents
these proposed limitations and standards.
259

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TABLE II-l
BPT TREATMENT MODEL FLOWS AND EFFLUENT QUALITY
ALKALINE CLEANING SUBCATEGORY
Pollutant
Flow, gal/ton
TSS
pH, units
Cl) The daily maximum concentration is
presented above.
Monthly Average ,
Concentration (mg/1)
50
25
6.0 to 9.0
times the monthly average concentration
260

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TABLE II-2
PROPOSED BPT EFFLUENT LIMITATIONS
ALKALINE CLEANING SUBCATEGORY
Effluent Limitations .
Pollutant	(kg/kkg of Product)
TSS	0.0052
pH, units	Within range of 6.0 to 9.0
(l) The daily maximum effluent limitation is three times the monthly average effluent
limitation presented above.
261

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TABLE II-3
TREATMENT MODEL FLOWS AND EFFLUENT QUALITY
ALKALINE CLEANING SUBCATEGORY
Pollutant	Monthly Average Concentration (mg/1)^^
BAT	BCT	NSPS	PSES	PSNS
Flow, gal/ton	(2) 50	50 (3)	(3)
TSS	25	15
O&G	-	10*
pH, units	6.0 to	9.0 6.0 to 9.0
* : As shown, daily maximum concentration only.
(1):	Daily maximum concentrations are the above monthly average concentrations
multiplied by the following factors:
Pollutant	Factor
TSS for BCT	3.0
TSS for NSPS	2.67
(2):	No limitations are currently proposed for BAT.
(3):	No pretreatment standards are currently proposed. Only the general
pretreatment regulation applies.
262

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TABLE I1-4
PROPOSED EFFLUENT LIMITATIONS AND STANDARDS
ALKALINE CLEANING SUBCATEGORY
Pollutant		Effluent Limitations (kg/kkg of Product)^^	
BAT	BCT	NSPS	PSES	PSNS
TSS	(2)	520	310
O&G	-	210*	(3)	(3)
pH, units	6.0 to 9.0 6.0 to 9.0
*: As shown, daily maximum standard only.
(1)	The proposed limitations and standards have been multiplied by 10^ to
obtain the values presented in this table.
Daily maximum effluent limitations and standards are the above monthly
average limitations and standards multiplied by the following factors:
Pollutant	Factor
TSS for BCT	3.0
TSS for NSPS	2.67
(2)	No limitations are currently proposed for BAT.
(3)	No pretreatment standards are currently proposed. Only the general
pretreatment regulation applies.
263

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ALKALINE CLEANING SUBCATEGORY
SECTION III
INTRODUCTION
General Discussion
Alkaline cleaning is that process in which steel products are cleaned
prior to entering other finishing operations such as coating or
pickling. Several solutions are used in the cleaning baths but since
alkaline cleaning lines have the same purpose, most operations have
similar characteristics.
Since the baths used in alkaline cleaning are not aggressive, large
amounts of pollutants are not generated. The pollutants generated are
generally found at relatively low concentrations. The most
significant pollutants contributed by this process are suspended
solids, oil and grease, and some metals. These pollutants originate
in the alkaline cleaning bath and in the rinse step which usually
follows the cleaning bath.
Almost all alkaline cleaning operations are included in larger steel
finishing mills. For example, an alkaline cleaning bath and rinse
step may precede a pickling operation which may in turn precede a
coating operation. While this entire steel finishing operation may be
operated in an integrated manner, finishing operations have been
subcategorized such that appropriate effluent limitations could be
established for each discrete operation. This allows for
consideration of plant-specific process configurations during the
preparation of NPDES permits.
As with many other finishing operations, there are two types of
alkaline cleaning operations: batch and continuous. These are
illustrated in Figures 111—1 and 111—2 which detail complete finishing
operations (i.e., cleaning, pickling). The information developed and
presented in this report applies only to the alkaline cleaning portion
of the steel finishing operation.
Development of Limitations
Effluent limitations applicable to alkaline cleaning operations were
last promulgated on March 29, 1976 and included five pollutants: total
suspended solids, dissolved iron, dissolved chromium, dissolved
nickel, and pH. For this study, the Agency conducted additional
sampling and gathered detailed information from the steel industry to
provide an expanded data base. The primary source of new information
is the industry's response to the basic data collection portfolios
(DCPs) that were sent to approximately 85% of the active alkaline
cleaning operations in the United States. Information was provided
for 175 alkaline cleaning operations through the DCPs. The data for
batch and continuous mills have been tabulated and summarized in
Tables III-l and III-2, respectively.
265

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Detailed data collection portfolios (D-DCPs) were sent to selected
mills to gather information on long-term effluent quality, cost
information on the wastewater treatment systems installed, and the
cleaning operation. Detailed data for twenty alkaline cleaning
operations at three plant sites were solicited through these D-DCPs.
The responses provided data to verify cost estimates, and to establish
retrofit costs.
The previous limitations for the alkaline cleaning subcategory were
based solely upon data obtained through field sampling at one plant.
During this study, two additional lines were sampled and the one line
originally sampled was revisited. This sampling increased the
existing data base for the limited pollutants and provided data for
toxic pollutants. A complete list of all alkaline cleaning operations
sampled, with a basic description of each, is provided in Table III-3.
As shown in Table II1-3, Mill 0432K was sampled twice and designated
as Mill I on the first visit and Mill 157 on the second visit. The
updated data base for this subcategory is presented in Tables II1-4
and II1-5.
Description of Alkaline Cleaning Operations
Alkaline cleaners are used where vegetable, mineral and animal fats
and oils must be removed from the steel surface prior to further
processing. Immersion in solutions of various compositions,
concentrations, and temperatures is often satisfactory. Electrolytic
cleaning may be used for large scale production or where a cleaner
product is required. The alkaline cleaning bath is a solution or
dispersion of various chemicals in water. These chemicals can include
carbonates, alkaline silicates and phosphates. Wetting agents are
often added to the cleaning bath to facilitate cleaning.
266

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TABLE III-l
SUMMARY TABUS
ALKALIME CLEANIHC - BATCH TYPE HILLS
Plant

Steel
Hill
Hill Site
Proceaa Flow
Discharge Flow

Treatment
Hill Diac
Code
Produc ta
Type
Age
(TPD)
(GPT)
(GPT)
Control and Treatment Technologiea
Ana
To POTW
060N-01
Pipe
SS
1970
5
42
42
CNT(UMC),1;NL; NU; SS;0(#1);
1970
No







Rinaea ~ Cleaner


060S-02
Pipe
SS
1970
5
42
42
CNT(UMC), 1| NL| NU; SS| 0(#1);
1970
No







Rinaea ~ Cleaner


068-01
Bar, Strip
CS
1934
39
1829
1829
Untreated to POTW;
NA
Tea







Rinaea * Cleaner


068-03
Rod
CS
1937
1
236
236
Untreated to POTW;
NA
Tea







Rinaea ~ Cleaner| REU, 85


112C
Bar, Hire,Rod
MA
1972
MA
KA
NA
Untreated Rinaea * Cleaner
NA
No
112?
Hire
CS
1948
2
UMC
UMC
Rinae ~ Cleaner are hauled
NA
No
1121-02
Faatenera
CS
1951
38
UNK
UMC
an 3,5 HU| ML; SL(UMC)) BS| T|
Pre 1950
No







FDS(UMC)| E| Rinaea ~ Cleaner


1121-03
Faatenera
CS
1922
65
UMC
UMC
CUT 3(UNC> NW] ML, SL(UNK); SB)
Pre 1950
No






[67]
T; FDS(UMC); E; Rinaea * Cleaner


1121-04
Plate Washers,
CS
1970
146
(®7D
CNT 3, 10 WW; NL| SL(UMC)| SS;
Pre 1950
No

Slug*



l_ J
T; FOS(UNK); E) Rinaea,~ Cleaner


1121-05
Faatenera
CS
1970
4
UMC
UMC
CNT 3, 1; NU; NL; SL(UMC)i SS;
Pre 1950
No







T; FDS(UMC)| E; Rinaea » Cleaner


1121-06
Faatenera
CS
1970
44
UMC
UIK
CRT 3(UIK) NU{ NL! SL(UIK){ SS;
Pre 1950
Ho







T; FDS(UMC); E; Rinaea t Cleaner


1121-07
Faatenera
CS
1956
12
UMC
UNK
CUT 3(UNK) NW; NL; SL(UNK); SS;
Pre 1950
No







T; FDS(UMC); E; Rinaea * Cleaner


1121-08
Faatenera
CS
1962
16
UNK
UMC
CNT 3(UMt) NU; NL; SL(UtK); SS;
Pre 1950
No







T; FDS(UMC); E; Rinaea • Cleaner


1121-09
Faatenera
CS
1950
17
UMC
UMC
CNT 3, <1; NW; NL; SL(UNK); SS;
Pre 1950
No







T; FDS(UMC); Rinaea + Cleaner


1121-15
Forginga,
CS
1968
12
UMC
UMC
CNT 3, 1; NW; NL; SL(UMC); SS;
Pre 1950
No

Set Screws





T; FDS(UNK); E; Rinaea ~ Cleaner


240B-01
Tube*
CS
1965
240
24
24
RET, 75, CNT 3, 9.3 NWj NL; AO;









SS; T; VF; SL(UMC);
1968
No







Rinaea * Cleaners


240B-02
Tubes
CS
1974
102
28
28
RET, 100 CNT 3, 4.6 NW; NL; AO;









SS; T; VF; SL(UNK);
1968
No







Rinaea ~ Cleanera


240B-03
Tubea
CS
1938
54
53
53
RET,too,CNT 3, 4.6 NU; NA; AO;
1968
No







SS; T; VF; SL(UMC)


240B-04
Tube*
CS
1954
3
UMC
UMC
CNT 3, 0.3 NW; NL; AO; SS: T; VF;
1968
No







SL(UNK); Rinaea * Cleanera


240C
Tubea
CS
1973
102
8
7
Rinaea * Cleaner Hauled
NA
No
248C
Bar, Rod, Wire
SS
1973
13
UMC
UMC
CNT; NL; A| CL) T; VF|
1975
No







FL0(1), FLP


256N-01
Bar
**
1965
**
**
**
NA, Then to POTW;
1973
Yea







Treated 95X, Untreated 5Z


256N-02
Sbapea
**
1976
**
**
**
NA, Then to POTV;
1973
Yea






Treated 95X, Untreated St



-------
TABLE 1II-1
SUMMARY TABLES
ALKALINE CLEANING - BATCH TYPE MILLS
PACE 2
Plant

Steel
Hill
Mill Size
Proce*. Flow
Code
Produc ta
Type
Age
(TPD)
(CPT)
384A
Sheet, Strip
CS
1968
858
168
A60D
Uire
CS
1959
55
266
460G
Wire
CS
1969
19
270
460H
Ui re
CS
1957
42
170
476A
Rod, Wire
CS
1960
UMC
UMC
492A-01
Pipe
CS
1962
186
UMC(3>
548
Tube
CS
1927
23
961
548A
Pipe, Tube
CS
1957
15
UMC
548B-01
Tube
CS
1947
54
216
548B-02
Tube
SS
1947
2
1290
580A-03
Uire
CS
1962
4
1931
580C-01
Uire
CS
1971
2
600
580G-02
Uire
CS
1971
5
2000
580G-04
Uire
CS
1971
2
5000
580C-10
Ui re
CS
1971
1
8000
580G-11
Uire
CS
1971
2
400
636-01
Tube
SS
UMC
NA
NA
636-02
Tube
CS
1943
HA
NA
636-03
Tube
SS
UMC
NA
NA
684Y-01
Sheet
a*
**
**
**
728
Pipe
CS
1952
7S
5
776C
Pipe, TUbe
SS
1957
* *
a*
776D
Pipe, Tube
CS
1948
**
**
776C-01
Uire
SS
1950
NA
NA
856N-01
Couplinga
CS
19J5
3
HA
856Q-01
Couplings
CS
1947
35
UNK
9I6A-01
Tube
CS
1931

UNK
NOTE: For a definition of the abbreviation* used, refer to Table VII
** : Confidential Information
~ : n«t« liated in brackets was received during a ae^>ling viait.
(1)	Ferric chloride
(2)	Ammant a
(3)	Cleaning tank waatea duaped; volume unknown.
Diacharge Flow
(CPT)
Control and Treatment Technologies
Treatment
	
Milt Diae
To POTW
168 CNT(UW) 0.45 SS; CL, FLLj	FLA; 1970	Ho
FLP, FLO(6) Spent Cleaner hauled
266 CKT, T, VF, NL, FLP, CL	1970	No
270 CNT(UMt), HO(2) SL	1968	No
170 Untreated to POTW,	HA	Yea
Cleaner ia hauled
UMC CNT(UMC) (UMC) A, SCR; SS;	NL; 1977	No
FLP; CL; SL(UMC);
Cleaner duaped 4/6 Mo.
UNK No Rinaea(rinae with pickling	NA	No
line) Cleaner to acid pit
961 CNT, FLL, NL, MA, SL	1969	No
UMC CKT 3(UNR) NC; NU;	1967	No
SL(UMC); Cleaner
216 Ho Treatment	NA	Yea
1290 No Treatment	NA	Yea
1931 CNT 3( 2.6 F(UNK) (DMC) P;	NL; 1967	No
NU; Cleaner - CR then vlth	rinae,
RET, 100
600 No Treatment	UMC	Yea
2000 No Treatment	UNK	Yea
5000 No Treataent	UNK	Yea
8000 None	UMC	Yea
400 None	UNK	Yea
NA NU, CNT(0.5) Cleaner	1974	Yea
HA NU, CHT(0.5) Cleaner	1974	Yea
NA NU, CMT(O.S) Cleaner	1974	Yea
** NL, FLP, CL, F(UNK), I, CUT;	1977	No
Rinae only
5 Cleaner* hauled, no rinaea	1971	No
** CNT(40) NA, Rinaea,	1957	Yea
Cleanera Hauled
** CNT(40) MA, Rinaea,	1973	Yea
Cleanera Hauled
NA FDS(UMC), FLP, NC CNT(l),	NA	No
Rinaea ~ Cleaner
NA H; Rinae ~ Cleaner	NA	No
UMC SL(UMC), SS, orr(l);	1963	No
UNK Hi Rinaea ~ Cleaner	NA	No

-------
TABLE III-2
SUMMARY TABLES
ALKALINE CLEANING - CONTINUOUS TYPE MILLS
Plant

Steel
Mill
Hill Site
Proceaa Flow
Diacbarge Flow

Treatment
Mill Diac
Code
Producta
Type
Age
(TPD)
(GPT)
(GPT)
Control and Treatment Technologiea
Age
To POTV
060D-01
Strip
ss
1967
213
4056
IIMC
CNT(UMC) (UNK) PSPl FLL| FLP; CL|
SL(UNK) Spent Cleaner t Rinaea
1958
No
060D-02
Str ip
ss
1966
132
6545
6545
Not Treated| Rinaea ~ Cleaner
NA
No
068-02
Chain Link
cs
1934
104
693
693
Untreated to POTVf
NA
Yea

Fence



U*<5)
0«(5>
Rinsea ~ Cleaner


088C-01
Tube
cs
1930
NA
Untreated to POTWi
NA
Yea





UNK*5'
UN**5*
Kinaea ~ Cleaner


088C-02
Tube
CS
1930
NA
Untreated to POTW;
NA
Yea





unk(5)
UWt5>
Kinaea ~ Cleaner


088C-03
Tube
cs
1930
NA
Untreated to POTU
NA
Tea





uwc<5>
UW<5)
Kinaea ~ Cleaner


088C-04
Tube
CS
1930
NA
Untreated to P01U|
KA
Yea





unic<5)
U«<5)
Kinaea * Cleaner


088C-05
Tube
cs
1930
NA
Untreated to POTWj
Kinaea • Cleaner
NA
Yea
112A-01
Strip
cs
1936
NA
NA
NA
CNT(UHt) 1.8 to 5.3| Sl| SCK| NL;
1977
No






A} FLA; FLP| SL(UMC)| CY| To 0(3)
Cleaner * Kinaea


112A-02
Strip
cs
1936
NA
NA
HA
CNT(UNK) l.S to 5.3| SS) SCR; HL|
1977
No






Ai FLA; FLP; SL(U1K)| CT; To 0(3)
Cleaner * Kinaea


112A-03
Str ip
cs
1936
NA
NA
NA
CNT(UMC) l.S to 5.3| U) SCBt ML I
A; FLA| FLP; SL(UNC); CT| To 0(3)
Cleaner • Kinaea
1977
No
U2A-04
Str ip
cs
1936
NA
NA
NA
«
CNT(UIK) 1.8 to 5.3; SS; SCR; ML;
A; FLA; FLP; SL(UW); CT; To 0(3)
Cleaner ~ Kinaea
1977
Mo
1124-05
Strip
cs
1936
NA
NA
NA
CNT(ONK) 1.8 SS| SCR; NL; A; FLA;
FLP; SL(IINK); CT; to 0(3)
Kinaea * Cleaner
1977
No
112A-06
Strip
cs
1957
NA
NA
NA
CNT(UNC) 1.8 SS; SCR; NL; A; FLA;
FLP; SL(UW); CT;
to Rinaea * Cleaner
1977
No
112A-07
Strip
cs
1957
NA
NA
NA
CNT(UHC) 1.8 SS; SCR; ML; A; FLA;
1977
No






FLP; SL(OMC); CT;
to Rinaea ~ Cleaner


112A-08
Strip
cs
1962
1152
SOS
508
RET, 98.5, CNr(CIIK) 0.6 to 2.0;
1977
No






SS; SCR; ML; A; FU; FLP; SL(DNK) 1
CY| to 0(3) Kinaea * Cleaner; FUS


112A-09
Strip
cs
1963
1032
421
421
CNT(UIK) 0.5 to 1.5; SS) SCR; NL;
A; FLA; FLP; SL(UW); CY; to 0(3)
Kinaea * Cleaner; FHS
1977
No
112A-10
Str ip
cs
1966
960
906
906
CNT(l)NK) 1.0 to 3.0; SS; SCR; NL;
A; FLA; FLP; SL(UIK); CT; to 0(3)
Rinaea t Cleaner; FHS
1977
No
112A-11
Strip
cs
1956
492
12
12
CNT(UIK) 0.005 to 0.02; SS{ SCR;
HL; A; FLA; FLP| SL(OIK); CT;
to 0(3) Rinaea ~ Cleaner
1977
No
U2A-12
Strip
cs
1956
441
13
13
CMT(OIK) 0.005 to 0.02; SS) SCR;
197J
No
NL{ At FLA; FLP; SL(UNK); CY(
to 0(3) liniei ~ Cleaner

-------
TABU IIt-2
SQMIAKX TIIUI
AUALW CLBAHIHC - aMTMOOOS ITPI MIX!
rni
Pint
Cod*
Product•
Steal
Tyy
Mill
Hill Sis*
(WD)
Proce
(C
U2A-13
•trip
CS
1970
S64
221
112 A-14
Strip
cs
19S7
369
IS
mt-u
Strip
CS
IKS
480
12
1120-01
Sheet
cs
IMS
1614
urn
112D-02
Tin * Ckrou
Plat*
cs
1966
1136
WK
1121-01
Feettnera
cs
1927
29
DM
1121-10
luttMt
cs
19SS
10
OR
1121-11
Paataaar
cs
1952
10
OKK
1121-12
Paataaar
cs
1958
IS
OIK
1121-13
Paetener
cs
1971
10
URK
1121-14
Fastener
cs
1971
0
DDK
176-01
Strip
MA
1962
31
QisI
174-02
Strip
M
1963
10
710
176-01
Strip
M4
1963
4
1108
176-04
Strip
¦4
1964
12
828
176-0 J
Strip
MA
1966
5
SS8
176-06
Strip
¦4
196S
11
1763
176-07
Strip
H4
1976
HA
MA
2560-01
2560-02
Strip
Strip
•*
**
1963
1966
61
21
S9
372
4324-01
Sheet
CS
1960
777
UNK
Discharge Plov

Treats ent
Mill
(CPT)
Control aad Tr*ata*at Technologies

To
Ml
bt, ioo, cirr(oMK) 0.2 to 0.7;
1977
No

SS| SCR; HL| A| FLA; FLP; SUUMK);



CT| T| 0(3) Kinase * Cleaner; FHS


IS
arrdJNK) 0.005 to 0.021 ss, sat;
1977
No

ML 1 A; PLA| FLP; SLdWK)| CTJ



T| 0(3) Bineea ~ Cleaner


12
CMT(OHK) 0.00S to 0.02) 88; SCSI
1977
Ho

ML) A| FLA| FLP| SUUHK); CT|



Tj 0(3) Rineee ~ Cleaner


on
cirrO), 
-------
TABLE III-2
SUMMARY TABLES
ALKALINE CLEANING - CONTINUOUS TYPE HILLS
PACE 3		
Plant
Code
Produce*
Steel
Type
Hill
Age
Mill Sixe
(TPD)
Procei
(CI
432A~02
Sheet
CS
1940
645
UNr
432A-03
Sheet
cs
1951
768
UMC
432K
Coll
SS
1962
95
§54j
448A-01
Sheet
cs
1970
987
UNK
448-02
Sheet
cs
1959
650
UNK
448A-03
Sheet
CS
1954
928
UMC
528
Sheet
SS
1961
93
387
580-01
Hire
CS
1960
1
4000
580-02
Hire
cs
1965
2
1875
380-03
Wire
cs
1965
5
1333
580-04
Wire
cs
NA
3
1500
580-05
Wire
cs
1965
15
300
580-06
Wire
cs
1965
30
150
580-0?
Wire
cs
1965
5
1333
58 OA-01
Wire Cloth
cs
1962
2
21264
580A-01
Wire Cloth
cs
1962
2
23833
5808-01
Wire
cs
1965
15
300
580B-02
Wire
cs
1965
30
150
5800-01
Wire
cs
1965
15
300
580D-02
Wire
cs
1965
30
150
580E-01
Wire
cs
1950
30
150
580G-03
Wire
cs
1971
2
3750
580G-05
Wire
cs
1971
2
3750
580C-06
Wire
cs
1971
2
6000
580G-07
Wire
cs
1960
2
6000
580G-08
Wire
cs
1960
2
6000
580C-09
Wire
cs
I960
2
6000
Discharge Plow
	(CPT)	Control and Tmttnt Technologies
Ttutaent Mill In..
A«c	To POTW
UK
CUT 3(UMC) P| E| 88} NL| NC) PLPj
1970
No

CL| T; VP J litM * Cleaners


UK
CUT 3(UNK) Pi El S8| H.J MC| PLPj
1970
No
&54J
CLJ T( VP J Kinae ~ Cleaners


CKT(UNK) 0.8, NLt SLlOm)
UMC
No
Kinae ~ Cleaner


UMC
CNT(UMC) (UMC) CL to POTW
1969
Yes

Kiaae ~ Cleaners} PHS


OIK
CMT(UNC) (UMC) CL to POTW
1969
Yes

Kinae ~ Cleaners


UMK
CNT(UMC) (UK) CL to POTW
1969
Yes

Kinae ~ Cleanera


387
CMT(UMC) (UMC) U) SS then to POTW
UMC
Yea

Kinaea * Cleaner) PBS


4000
Rinse Untreated to POTW Cleaner
NA
Yes

N(UNK)j SL(UW)


1875
Kinae Untreated to POTW Cleaner
MA
Yes

N(UMC)j SL(UMK)


1333
Kinae Untreated to POTW Cleaner
NA
Yes

M(UMC) } SL(UNK)


1500
Kinae Untreated to POTW Cleaner
NA
Yes

N(UMC); SL(UMC)


300
Kinae Untreated to POTW Cleaner
NA
Yes

H(UNK); SL(UMC)


ISO
Kinae Untreated to POTW Cleaner
NA
Yea

N(UMC)} SL(UMC)


1333
Kinae Untreated to POTW Cleaner
MA
Yes

M(UMC) } SL(UMC)


21264
CUT 3, 8 F(UMC) (UMC) P} ML) NU|
1966
Mo

Rinses * Cleaner


23833
CUT 3, 11 P(OMC) (UMC) P} RL} NW}
1967
No

Kinses ~ Cleaner, RET, 70


300
No Treataent *¦ Contract Keaoval
NA
Yes
150
No Treataent - Contract Keaoval
MA
Yes
300
Rinse * Cleaner PLP, Ml, CL,
1965
No

SL(UMC), CNT(UMC) 3


150
Rinse ~ Cleaner FLP, Mf, CL,
1965
No

SL(UMC) ) CNT(UNK) (UNK)


150
Rinse ~ Cleaner NU, CMT(UMK) 20
1970
Yes
3750
No Treataent
UNK
Yes
3750
No Treataent
NA
Yes
6000
No Treataent
MA
Yea
6000
None
HA
Yes
6000
None
HA
Yes
6000
None
MA
Yes

-------
TABLE III-2
SUMMARY TABLES
ALKALINE CLEANING - CONTINUOUS TYPE MILLS
PAGE 4
Plane

Steel
Mill
Mill Size
Process Flow
Discharge Flow

Treataent
Mill
Code
Produc ti
Type
Age
(TPD)
(GPT)
(CPT)
Control and Treatment Technologies
*«e
To
584E-01
Sheet
CS
1965
1005
488
488
DU,IX,BO(UIK), CI, El, fcuwQ
(UNK) P, CO, FIX, FLP, CF, ML, Ml,
CL, SL(UNC),SS,CHT;
1960
No





UW(2)
UWC(2)
Rinse ~ Cleaner


584F-01
Sheet
cs
1941
714
H
1960
No
584F-02
Strip
CS
1957
621
2
2
H
1970
Mo
584F-03
Str ip
cs
1958
237
6
6
H
1970
Mo
584F-04
Strip
Ca
1966
561
3
3
H
1970
Ho
584F-05
Str ip
CS
1940
1077
NA
HA
UNK
UNK
UHK
584F-06
Sheet
CS
1950
1077
HA
NA
None
NA
UHK
584F-07
Sheet
CS
1960
477
503
503
Hone
MA
DNK
684*-01
Sheet
*
**
••
**
**
None
NA
No
684*-02
Fabricated
and Formed
*
**
**
*+
**
None
HA
Ho

Steel Iteas


o(i>





684C
Sheet
CS
1964
UNK
UNK
NU
1937
No
684X-01
Sheet
*
**
**
**
**
Nona
NA
No
684X-02
Sheet
4
**
**
**
M
None
HA
No
684X-03
Sheet
*
**
**
**
**
None
HA
No
684Z-01
Sheet
*
* *
**
**
**
None
HA
Yes
6842-02
Tube
*
**
**
**
**
None
HA
Yea
760-01
Coil
CS
1920
65
88
88
Nona
NA
Yea
BS60-01
Sheet
CS
1938
786
NA
MA
FLP, EB, SS, fUKS), CHT(3)|
Biases ~ Cleaner
1960
Ho
856D-02
Sheet
CS
1941
1245
NA
HA
FLP, U, SS, FUKS), C¥T(4)|
Rinses * Cleaner
1960
No
856D-03
Sheet
CS
1962
870
NA
HA
FLP, EB, SS, FUX8), CHT(4)j
Rinses ~ Cleaner
1960
Ho
856E-01
Strip
ss
1969
282
894
894
None, FHS
HA
Ho
856E-02
Strip
ss
1957
NA
NA
HA
None
HA
Ho
856E-03
Strip
ss
1956
NA
NA
HA
None
NA
Mo
856E-04
Strip
ss
1956
296
487
487
None
HA
Ho
856F-01
Sheet
CS
1952
882
204
204
CR, NU, HL, FLL, SS, CL, CKI(t)|
Rinse ~ Cleaner
1952
No
856Q-02
Couplings
CS
1960
38
UNK
UME
SL(U)K), SS, CMT(1)| Rinse « Cleaner
1963
Ho
860B-01
Strip, Coil
CS
1950
564
766
766
EB, FLL, FLF, FLO(3), XL, Ml,
CL, SS, 0(4), CUT
IBS
Ho
860B-02
Strip
CS
1951
681
1692
1692
EB, FLL, FLF, FLO(3), ML, Ml,
cl, ss, 0(4), an
UNK
Ho
8608-03
Strip
CS
1960
1029
1120
1120
EB, FLL, FLF, FL0(3), ML, HI,
CL, SS, 0(4), CUT
DNK
No
860B-04
Sheet
CS
1943
357
1210
1210
EB, FLL, FLF, FL0(3), NL, Ml,
CL, SS, 0(4), CUT
DUE
Ho
860B-05
Strip, Coil
CS
1937
462
649
649
EB, FLL, FLP, FL0(3), HL, NW,
CL, SS, 0(4), CUT
DNK
Ho
8608-06
Strip
CS
1957
762
567
S67
EB, FLL, FLF, FL0(3), NL, Ml,
CL, SS, 0(4), CUT
UNK
No
860B-07
Sheet, Strip
CS
1962
963
935
935
EB, FLL, FLP, FL0(3), HL, NW,
cl, ss, 0(4), art
DNK
Ho

-------
TABU 111-2
SUMMIT TABLES
ALKALINE CLEANING - CONTINUOUS TYPE MILLS
PACE 5	
Plant

Steel
Mill
Mill Sise
Procesa Plow
Discharge Plow

Treataent
Mill Mac
Code
Products
Type
**«-
1967
(TPD)
(err)
(CPT)
Control aad Treatment Technoloeiea
A*e
To POIW
860B-08
Serif
CS
900
480
480
EB, PLL, PLP PUX3), ML, H,
1MB
No






cl, ss, 0(4), an


8601-09
Sheet, Strip
CS
1954
Line has been shutdown



8601-10
Strip, Coil
CS
1967
1247
231
231
EB, PLL, PLP, PLO<3), ML, Ml,
CL, SS, 0(4), CUT
UK
No
860B-11
Sheet, Strip
CS
1950
327
1835
1835
DB, PLL, PLP, PLOO), NL, Ml,
CL, SS, 0(4), on
UNE
No
864B-01
Sheet, Coil
CS
1948
810
267
267
SS, NL, PLL, PLP, CL, NA, PBS,
CNT(1)| Binaea * Claaaer, BET, 100
1972
Bo
864B02
Sheet, Coil
CS
19)3
363
595
595
SS, NL, PLL, PLP, CL, NA, IBS,
CMT| Binaea ~ Cleaner
1972
Bo
064B-O3
Sheet
CS
1958
561
385
385
SS, NL, PLL, PLP, CL, NA, PBS,
CMT| Bieaea ~ Cleaner
1972
Bo
8641-04
Sheet
CS
1960
882
245
245
BET, 100, SS, ML, PLL, PLP, CL,
NA, PBS, CNT) Bieaea ~ Claaeer
1972
Bo
0641-05
Sheet
CS
1963
•64
250
250
SS, NL, PLL, PLP, a, NA, PUS,
CNT; Bieaea ~ Cleaner
1972
No
064B-06
Sheet, Coil
CS
1965
759
285
285
SS, NL, PLL, PLP, CL, NA, PUS,
CNT{ Binaea * Cleaner
1972
No
868A-01
Sheet
CS
1938
633
946
944
P(UNE) (OIK) P, PLP, NL, CL,
sL(nac), plo(6), c*r(7);
Binaea ~ Cleaner
1971
No
868A-02
Sheet
CS
1938
855
701
701
P(OMC) (DMO P. PLP, NL, CL
SL(DMC), FUX6), PBS, CBT|
Binaea ~ Cleaner
1971
Bo
068A-03
Strip
CS
1944
450
96
96
P(OMK) (DNK) P, PLP, NL, CL,
SL(MK), PL0(6), PBS, CR|
Binaea ~ Cleaner
1971
No
8&5A-04
Strip
CS
1955
543
133
133
P(UNK) (UNO P, PLP, NL, CL,
SL(ONK), SS, PUX6), CNT, PBS|
Binaea ~ Cleaner
1971
Bo
868A-05
Sheet
CS
1960
825
243
243
P(UNK) (UNO P, PLP, NL, a,
SL(UMC), SS, PUX6), CNT, PBS|
Binaea * Cleener
1971
No
868A-06
Strip
CS
1943
444
162
162
P(UNK) (DM) P, PLP, NL, CL
SL(IMC), SS, FUX6), PBS, CKT,
Binaea ~ Cleener
1971
No
868A-07
Strip
CS
1965
312
762
762
P(UKK) (ONE) P, PLP, NL, CL,
SL(UIK), SS, PL0(6), CNT)
Binaea * Cleaner
1971
No
920C-0I
Sheet
CS
1959
676
776
7)6
CB, NL, PLL, PLP, CL, an-j
Binaea ~ Cleaner
Pkiture
1977
No
920G-02
Sheet
CS
1937
391
538
538
CB, NL, PLL, PLP, CL, CHT|
Binaea ~ Cleaner
Puture
1977
No

-------
TABLE III-2
SUMMARY TABLES
ALKALINE CLEANING - CONTINUOUS TYPE HILLS
PAGE 6	
Plant	Steel Hill	Hill Size	Frocen Flow
Code	Product*	Type	Age	(TPD)	(CPT)
920C-03	Sheet	CS	1937	1058	354
9200-01	Sheet	CS	UNK	240	I
920L-01	Coil	CS	1961	243	509
948F-01	Pipe, Tube	CS	1939	82	176
NOTE: For t definition of Abbreviation# used, eee Table Vll-l-
**	: Confidential information
[3	: Data in bracketa waa received during a aaapling viait.
(1)	- Cleaning tank waate duaped once every 8 weeks, voluan unknown.
(2)	~ Cleaner ban no operated aince 1974.
(3)	- Waate Pickle Liquor.
(4)	- Gravity Oil Separation
(5)	- About 1/$ a tank per week
Diacharge Flow

Treatment
Hill Disc
(GPT)
Control and Treatment Technologic*
Age
To POTW
354
CR, ML, FLL, FLP, CL, CirTj
Future
No

Rinaea ~ Cleaner
1977

1
NC, HA, NU, SS, CNT(l)}
1967
No

Rinaea ~ Cleaner


509
CR, NL, FLP, CL, CNTj
1973
No

Rinaea ~ Cleaner


176
Cleanera hauled)
NA
No
No Treatment for the Rinses

-------
TABLE III-3
DESCRIPTION OF THE ALKALINE CLEANING
MILLS SAMPLED FOR THIS STUDY
Sampling
Code
I
152
156
157
(1)
Plant
Code
(2)
432K
0176-01
1121-04
432K
Type of
Steel
Specialty
Unknown
Carbon
Specialty
Type of
Operation
Continuous
Continuous
Batch
Continuous
Principle Product
	Processed
Strip
Strip
Plate Washers
Strip
(1)	The sampling code is an alphabetic or numeric code assigned at the
time of sampling.
(2)	The plant code is a reference code designated for each company and plant
For example, 0176-01 represents the first alkaline cleaning operation
ro	at plant 0176.
*-4
U1

-------
TABLE II1-4
ALKALINE CLEANING SUBCATEGORY
DATA BASE - BATCH
1 of Total	Daily Capacity
No. of Operations No. of Operations of Operations (TPD)
Operations Sampled For
Original Guidelines Study
Operations Sampled For
Toxic Pollutant Survey
Total Operations Sampled
Total Operations To Receive
D-DCPs
Operations Sampled And/Or
Solicited Via D-DCPs
Operations Responding To DCPs	51	J*85	2601
Estimated No.	60	100	3060
Of Operations
0	0	0
1	1.7	146
1	1.7	146
12	20	607
13	21.7	753
Z of Total
Daily Capacity
0
4.7
4.7
19.8
24.6
^85
100

-------
Operations Sampled For
Original Guidelines Study
Operations Sampled For
Toxic Pollutant Study
Total Operations Sampled
Total Operations To Receive
D-DCPs
Operations Sampled And/Or
Solicited Via D-DCPs
Operations Responding To DCPs
Estimated No.
Of Operations
TABLE II1-5
ALKALINE CLEANING SUBCATEGORY
DATA BASE - CONTINUOUS
of Operations
% of Total
No. of Operations
0.7
Daily Capacity
of Operations(TPD)
95
% of Total
Daily Capacity
0.19
2 incl.
1	above
2
7
1.4
0.68
1.4
0.7
126 incl,
95 above
126
170
0.25
0.19
0.25
0.34
6.2
296
0.59
124
146
^85
100
42,914
50,487
^85
100

-------
FUME
SCRUBBER
Water ,
Supply
FUME EXHAUST SYSTEM
Rack Conveyor
Water
Supply
ALKALINE CLEANING
BATH
RINSE
TANK
DIP RINSE TANK
PICKLING TANK
Acid rinse water
continuous discharge
cleaning solution
Rinse water
discharge
Spent acid discharge
discharge
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
ALKALINE CLEANING*
BATCH TYPE OPERATION
Alkaline cleaning
i wastewater discharge
(500 gat/ton)
* The regulations developed in this document
apply only to the olkoline cleaning bath
and rinse «tep(s).
FIGURE HI-

-------
ro
-J
ID
WATER
SUPPLY
CONTINUOUS DISCHARGE
ACIDIFIED WATER
4 WATER SUPPLY
—4.STEAM SUPPLY
1	111 W*™" jf WATER f WAT ER
PICKLING TANKS
(/'
SPRAY RINSE DIP RINSE PLATING OR
DIP RINSE
ALKALINE
SPRAY RINSE
COATING
TANK
CLEANING
BATH
CONSTANT OVERFLOW
SPENT PICKLING LlbuOR
SPENT ALKALINE
CLEANING
SOLUTIONS
ACID
RINSE WATER
DISCHARGE
ALKALINE CLEANING
WASTEWATER DISCHARGE
(300 gal/ton)
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
ALKALINE CLEANING *
CONTINUOUS TYPE OPERATION
~ The regulations developed in this
document apply only to the alkaline
cleaning bath and rinse step(s).
FIGURE IH-2

-------
ALKALINE CLEANING SUBCATEGORY
SECTION IV
SUBCATEGORIZATION
None of the factors examined by the Agency were found to affect the
subdivision of the alkaline cleaning subcategory. Both types of
operations (batch and continuous) demonstrated similar discharge flows
and their discharges contain the same pollutants at similar levels.
The Agency also analyzed other elements to determine if further
subdivision was appropriate, but none were found to have a significant
effect. The Agency analyzed the impact of line age, type of product,
raw materials, wastewater characteristics, treatability of wastewater
pollutants and the geographic location of the plants. However, none
of these factors were found to warrant further subdivision of the
alkaline cleaning subcategory. Each of these factors is reviewed in
greater detail below.
Manufacturing Process and Equipment
The Agency examined differences in the alkaline cleaning operations
which might possibly affect subdivision. For example, there are two
different ways in which the alkaline cleaning process is carried out.
The cleaning can be done in either batch fashion where the product is
moved manually in and out of cleaning and rinse tanks, or it can be
done in a continuous fashion on sheet, strip or wire products.
Alkaline cleaning operations can also be integrated into different
types of larger production lines. Industry responses to the DCPs show
that alkaline cleaning lines are used in conjunction with coating,
annealing, galvanizing, plating and pickling lines. The Agency
considered whether these different types of operations may affect the
flow (applied or discharge) or wastewater characteristics and thus
warrant further subdivision. However, the Agency found that these
variations have no significant affect on either the effluent flow or
the pollutants contained in the process wastewaters. Both batch and
continuous operations can achieve similar flow rates and both
discharge similar amounts of pollutants. In addition, no significant
differences were found among alkaline cleaning operations that are
part of larger complexes (Table IV-1). For these reasons, the Agency
concluded that no further subdivision of the alkaline cleaning
subcategory, based upon manufacturing process differences, is
appropriate.
Final Products
The products processed in alkaline cleaning operations vary from sheet
and strip to chain link fence. Based upon its analysis, the Agency
concluded that the product being cleaned does not significantly affect
the quality or quantity of the wastewaters generated. Thus, further
subdivision based upon this factor is not appropriate.
281

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Three mills were sampled for this study. While the Agency found the
wastewater quality to vary between these mills, the Agency believes
that these variations were not the result of the different types of
products being processed. Data for mills in most other subcategories
have shown that the type of final product processed does not have a
significant effect on wastewater quality. Accordingly, the Agency
expects a similar relationship in the alkaline cleaning subcategory as
similar types and quantities of pollutants should originate in the
cleaning tank and rinsing steps regardless of the type of product
being processed.
The Agency also analyzed the potential for variations in wastewater
flow depending on the final product being processed. The Agency
originally thought that some of the processed product shapes (such as
sheet and strip) might be easier to rinse than other products (such as
tubes and wire). However, when the discharge flow data were analyzed
no significant flow variations were found. Many mills producing
different products achieve the proposed flow values. These data are
also summarized in Table IV-1. For continuous mills, strip, sheet,
and wire are the primary products processed. Low discharge flow rates
are demonstrated for each. The Agency found that batch mills are able
to achieve the model BPT flow of 50 gal/ton for four different product
types.
At first, wire products appeared to have much higher applied and
discharge flow rates than any other product type. The Agency found
that the smaller wire lines have flow rates that were often in the
range of thousands of gallons per ton. Because the Agency found these
large variations for this one product type, it examined the data for
these lines in great detail. It found that these lines have, on the
average, similar applied flow rates to the process on a gallon per
minute basis as all the other lines, but due to the extremely low
tonnage processed (less than 1 ton/turn) the flow on a gallon per ton
basis is extremely high. The cleaning process in these lines is only
carried out for a fraction of a turn and, as a result, pollutants from
the process are generated during a small portion of the eight hour
turn. Flow calculations are based upon constant production over the
eight hour period. Thus, the result of the calculations are high.
These flow values could not be adjusted due to the unavailability of
the length of time the alkaline cleaning operation is in use.
The Agency believes that changes in the current practice at the
smaller wire mills could be implemented, which would enable these
lines to achieve flow rates comparable with those from other lines.
The cleaning baths and rinse tanks should be equipped with product
activated flow or spray rinse valves so that flows occur only when the
tanks are being used. Because the lines affected are extremely small,
this practice should not cause any problems to the alkaline cleaning
process and should not cause any disruptions in other parts of the
finishing line.
Raw Materials
Carbon, stainless, and other types of steel are processed in alkaline
cleaning operations. For purposes of this discussion, any line
282

-------
processing more than 50% carbon steel is considered to be a "carbon"
steel line. The Agency found that the type of steel being processed
does not significantly affect the quality or quantity of wastewater
which is generated. For this reason, the Agency concluded that
further subdivision based upon the type of raw material used (i.e.,
the type of steel processed) is not appropriate.
During its study, the Agency sampled one specialty line, one carbon
steel line, and one operation which was not clearly designated. No
significant differences were noted in the wastewater characteristics
of these lines. All types of lines use similar cleaning solutions and
operating practices and achieve similar flow rates regardless of the
type of steel used. Based upon the limited data obtained, the Agency
does not believe that there will be any significant variations in
wastewater quality between carbon and specialty lines.
The Agency also analyzed wastewater flow variations which result from
processing carbon and specialty steels. The Agency found that there
are no significant differences between flow rates for carbon and
specialty lines. There is a difference between carbon and specialty
average flow rates for batch operations; however, this difference is
attributable to the extremely small data base for the specialty mills
(3 mills) and not to any particular variation in the operation of the
mills.
Carbon and specialty alkaline cleaning lines do vary in size. It was
found that the continuous operations were, on the average, ten times
as large as the batch operations. This difference does not affect
further subdivision since similar effluent levels can be achieved at
any operation regardless of size. Separate cost estimates were made
for batch and continuous operations to develop more representative
costs to the industry.
Wastewater Characteristics
Wastewater from alkaline cleaning operations originates from two
sources; the cleaning solutions and the rinse step or steps that
follow the cleaning operation. The characteristics of the wastewaters
leaving the process depend primarily upon three elements; (1) the
solutions used in the cleaning baths; (2) the degree of carry-over of
the pollutants from the cleaning tanks to the rinse step; and (3) the
frequency of dumping the cleaning solution tanks.
Based upon the analysis of data for this subcategory, the Agency
believes that there are no significant variations in the wastewater
characteristics from alkaline cleaning operations. Similar pollutants
originate in all alkaline cleaning operations and the levels at which
they are discharged are not highly variable.
Wastewater Treatability
The Agency analyzed the treatability of wastewaters from the different
types of alkaline cleaning operations. Based upon the data developed
during the plant visits, and the data supplied in the DCPs,the Agency
found that there are no significant differences in wastewater
283

-------
treatability between the different types of cleaning operations. As
noted above, pollutants found in various alkaline cleaning wastewaters
are similar and are subject to similar treatment. For this reason,
the Agency has concluded that further subdivision of this subcategory
based upon wastewater treatability is not appropriate.
Size and Age
Consideration was also given to the impact of size and age on the
subdivision of the alkaline cleaning subcategory. The analysis does
not show any need for subdivision.
Size was considered a possible factor for subdivision, but from the
analysis of the compiled data, the Agency found that further
subdivision based upon size is not appropriate. While alkaline
cleaning operations vary greatly in physical size, layout and product
size, the Agency found that these factors do not significantly affect
process water usage, discharge flow rates, or effluent quality.
Figure IV-1 is a plot which analyzes the relationship between the
discharge flow and size. The flow rate which forms the basis of the
proposed limitations is also shown. As shown, lines of any size have
achieved the proposed flow rate. Additionally, the Agency found that
the size of the operation does not affect wastewater characteristics,
as all lines are operated in similar manners and the wastewater
characteristics remain relatively constant regardless of size.
The relationship between flow and age was analyzed in a similar
fashion. The plot of discharge flow vs. age for the two types of
alkaline cleaning operations is shown in Figure IV-2. Again, the plot
demonstrates that the proposed flow has been achieved at lines of all
ages. Therefore, the age of a line has no significant impact on the
discharge flow from that line.
The Agency investigated the effect of age on the feasibility and cost
of retrofitting pollution control equipment at alkaline cleaning
lines. Comparison of the age of a cleaning line with the year in
which pollution control facilities were installed (see Table IV-2),
demonstrate that pollution control equipment can be retrofitted. The
discussion in the preceding paragraphs show that similar rates of
pollutant discharge are achievable at alkaline cleaning lines of all
ages. As a result, the Agency has concluded that retrofitting
pollution control to alkaline cleaning lines is feasible.
Most alkaline cleaning wastewaters are treated in central treatment
plants. As a result, the industry was either unable to provide
retrofit costs or reported that costs were not significant. In
addition, as discussed in Section VIII, a comparison of actual costs
incurred by the industry with the Agency's estimated costs show that
the Agency's estimates sufficiently account for any retrofit and other
site-specific costs. The Agency thus concludes that the cost of
retrofitting pollution control equipment at alkaline cleaning lines is
minimal.
Thus, from the analysis conducted above, the Agency concludes that age
and size do not affect the ability to achieve the flow rates and
284

-------
effluent levels which form the basis of the proposed limitations.
Additionally, age and size do not affect the ability to install the
appropriate pollution control technology for alkaline cleaning
operations. Accordingly, the Agency concluded that further
subdivision based upon size or age is not appropriate.
Geographic Location
An examination of the raw waste characteristics, process water
application rates, discharge rates, effluent quality and other
pertinent factors relative to plant location revealed no general
relationship or pattern. Alkaline cleaning lines are located in
sixteen states across the country. Most of these mills are located in
the major steel producing areas of Pennsylvania and Ohio. Table IV-3
summarizes the location of all alkaline cleaning operations responding
to the DCPs.
A small number of lines are located in what could be considered "arid"
or "semi-arid" regions. For this reason, the Agency gave special
attention to the consumptive use of water in these regions. However,
because no cooling systems are required to attain the proposed
limitations, no additional water consumption (or only a very minimal
amount) will result from compliance with the proposed limitations.
Process Water Usage
The Agency found that although water use varies in this subcategory,
water conservation practices are available to achieve fairly uniform
discharge flow rates for all lines. Hence, further subdivision on the
basis of water use is not warranted.
285

-------
TABLE IV-1

EFFECT OF
FINISHING OPERATIONS AND
PRODUCT TYPE


ON THE DISCHARGE
FLOW RATES OF ALKALINE
CLEANING OPERATIONS



Type of


Plant
Discharge
Finishing
Product
Type of
Code
Flow(GPT)
Operation
Type
Operation
0920-01
1
w/Electroplating
Sheet
Continuous
0584F-02
2
w/Hot Coating
Strip
Continuous
0584F-04
3
w/Hot Coating
Strip
Continuous
0728
5
Stand Alone
Pipe
Batch
0584F-03
6
w/Hot Coating
Strip
Continuous
0240C
7
w/Hot Coating
Tubes
Batch
0112A-11
12
w/Cleaning Line
Strip
Continuous
Oil2A-15
12
w/Cold Coating
Strip
Continuous
0112A-12
13
w/Cold Coating
Strip
Continuous
0112A-14
16
w/Cold Coating
Strip
Continuous
0240B-01
24
Stand Alone
Tubes
Batch
0240B-02
28
Stand Alone
Tubes
Batch
060N-02
42
Stand Alone
Pipe
Batch
060N-01
53
Stand Alone
Tubes
Batch
0240B-03
53
Stand Alone
Tubes
Batch
02560-01
59
w/Bright Anneal
Strip
Continuous
01121-01
67
w/Hot Coating
Plate Washers
Batch
0760-01
88
w/Copper Coating
Coil
Continuous
0868A-03
96
w/Cold Coating
Strip
Continuous
0868A-04
133
w/Cold Coating
Strip
Continuous
0580E-01
150
w/Cold Coating
Wire
Continuous
0580D-02
150
w/Cold Coating
Wire
Continuous
0580B-02
150
w/Cold Coating
Wire
Continuous
0580-06
150
w/Brass Plating
Wire
Continuous
0868A-06
162
w/Cold Coating
Strip
Continuous
0384A
168
w/Hot Coating
Strip & Sheet
Batch
046 OH
170
w/Cold Coating
Wire
Batch
0948F-Q1
176
w/Cold Coating
Pipe & Tube
Continuous
0856F-01
204
Stand Alone
Sheet
Continuous
0548B-01
216
w/Acid Pickling
Tubes
Batch
0112A-13
221
w/Cold Coating
Strip
Continuous
0860B-10
231
Stand Alone
Sheet
Continuous
068-03
236
w/Acid Pickling
Rod
Batch
0868A-05
243
w/Galv. Line
Sheet
Continuous
0868B-04
245
w/Annealing Line
Sheet
Continuous
0864B-05
250
w/Degreasing Line
Strip
Continuous
286

-------
TABLE IV-2
EXAMPLES OF PLANTS THAT HAVE DEMONSTRATED
THE-ABILITY TO RETROFIT POLLUTION CONTROL EQUIPMENT
ALKALINE CLEANING SUBCATEGORY
Plant
Code
1121
240B
24 8C
256N
384A
476A
548
548A
580A
636
728
776D
85 6Q
And ten others.
Plant
Age (Year)
1922
1965
1973
1965
1968
196*0
1927
1957
1962
1943
1952
1948
1947
Treatment Plant
Age (Year)
1950
1968
1975
1973
1970
1977
1969
1967
1967
1974
1971
1973
1963
287

-------
TABLE IV-3
LOCATION OF ALKALINE CLEANING OPERATIONS
Location	Total Number	% of Total
Pennsylvania	55	31.4
Ohio	22	12.6
Indiana	18	10.3
Maryland	15	8.6
Massachusetts	11	6.3
Michigan	10	5.7
West Virginia	8	4.6
Alabama	8	4.6
California	7	4.0
Texas	5	2.9
Wisconsin	5	2.9
Georgia	3	1.7
Illinois	3	1.7
Kentucky	3	1.7
Connecticut	1	0.5
Mississippi	1	0.5
# of States - 16	175	1002
288

-------
FIGURE IV" I
FLOW vs SIZE ANALYSIS
ALKALINE CLEANING SUBCATEGORY
1400-
1200 ¦
1000
<
<*>
800
Ui
g 600
c
X
o
CO
400
200 «
• • O
• BATCH OPERATIONS
O CONTINUOUS OPERATIONS
O
o
s
o
o
o °o
00
_			BPT FLOW 8ASIS 3 50 QPT	
»
"200
o	o
00 o o
400	600	800	1000
PRODUCTION CAPACITY (TONS/DAY)
1200
289

-------
1400
1200
FIGURE IV-2
FLOW vs AGE ANALYSIS
ALKALINE CLEANING SUBCATEGORY
• BATCH OPERATIONS
O CONTINUOUS OPERATIONS
§1000
t—
•V
<
o
•m*
§ 800
_J
u.
LU
CD

-------
ALKALINE CLEANING SUBCATEGORY
SECTION V
WATER USE AND WASTE CHARACTERIZATION
Introduction
Process water usage within the alkaline cleaning subcategory is a
major factor in determining pollutant loads and estimating the cost
for removal of pollutants. The Agency analyzed the data from the
sampling inspections and the DCP responses to evaluate process water
usage within this subcategory and to obtain total wastewater volumes.
Alkaline Cleaning Operations
As shown in Figures III-l and III-2, alkaline cleaning is accomplished
in batch and continuous operations. In both operations, the product
is cleaned in alkaline solutions prior to entering other finishing
operations. As explained in the preceding sections, because these
operations are carried out in a similar manner, the flow rates and
wastewater characteristics do not vary significantly from operation to
operation. Where flows do vary, water conservation methods can be
applied to reduce water usage.
Wastewaters are discharged from two sources at alkaline cleaning
lines? the cleaning solution tank, and in the subsequent rinsing
steps. The cleaning solution tank contains a caustic solution which
generally has high levels of sodium compounds and other constituents
depending on the type of solution used. Some lines reuse the cleaning
solution continuously, adding fresh solution only to make up for
dragout and evaporative losses. However, due to the buildup of
contaminants (dissolved solids and oils) in the baths, the contents of
the bath are discharged periodically or as soon as the cleaning
ability of the solution is impaired by the build-up of contaminants.
A process is being developed that employs an ultrafiltration system
which continuously treats the alkaline cleaning solutions and enables
them to be reused with a minimal loss. The solutions in the alkaline
cleaning tanks are sometimes heated to increase the chemical action of
the degreasing agents. As a result, the temperatures of the wastes
discharged from the bath are as high as 93.3°C (200°F). Wastewaters
from all alkaline cleaning lines are treated in large central
treatment systems. For this reason, the high temperature does not
present a problem to the environment.
Because most alkaline cleaning baths are used to process a large
amount of product, pollutants can build up in the tank to extremely
high levels. Typical levels of pollutants found in alkaline cleaning
baths are shown below:
291

-------
Pollutant or
Wastewater Characteristic
Typical Values (mq/1)
Alkalinity
Iron, total
Oil & Grease
pH (units)
1,000
100
1, 500
12-13
Total Dissolved Solids
Total Suspended Solids
Temperature
25,000
1,000
70°-200°F
The other source of wastewaters from the alkaline cleaning process is
the rinse steps following the cleaning operation. After immersion of
the product into the cleaning bath, rinsing is required to remove
residual cleaning solution from the product and to cool the product if
the cleaning bath was heated. . The rinsing is usually done in dip
tanks or spray chambers, and there can be either one or several tanks
depending upon the degree of rinsing required. Although some mills
use standing rinse tanks (no continuous flow through the tanks) many
mills use rinse tanks that have continuous water feed and overflows.
This is done to keep the rinsewater relatively free of contaminants
and to cool the product, if necessary.
The Agency obtained sampling data for the three mills visited during
this study. The rinsewater was sampled at each mill. Because the
discharges from batch and continuous operations are similar, the data
for these operations have been combined. It should be noted that
Plant 0432K was visited twice, but only the data gathered during the
most recent visit are included. The data gathered at the three
sampled plants are presented in Table V-l. Net concentrations are
listed in this table because the Agency believes that net values best
describe pollutants contributed by the alkaline cleaning operation as
opposed to comtamination in makeup waters. Averages are also listed,
where appropriate, to show a typical level of pollutants that can be
expected in the rinsewater from the alkaline cleaning process.
292

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TABLE V-l
SUMMARY OF ANALYTICAL DATA OF SAMPLED PLANTS
ALKALINE CLEANING SUBCATEGORY	, .
NET CONCENTRATIONS OF POLLUTANTS IN RAW WASTEWATERS
Reference Code
0176-01
01121-04
0432K

Plant Code
152
156
157
Averagi
Sample Points
(V-W)
(C-A)
(C-A)

Flow
(gal/ton)
815
67
254
379
Type
of Mill
Continuous
Batch
Continuous
-
Dissolved Iron
0.08
0.3
0.03
0.14
Oil
& Grease
4.0
6.5
18.3
9.6
Suspended Solids
-
10.0
15.7
8.6
PH,
units
8.9-9.1
7.2-8.1
10.3-11.7
7.2-11
23
Chloroform
0.020
ND
ND
*
36
2,6-Dinitrotoluene
ND
ND
0.047
0.016
39
Fluoranthene
-
ND
0.051
0.017
64
Pentachlorophenol
ND
0.029
ND
*
65
Phenol
ND
ND
0.024
*
66
Bis(2-ethylhexyl)phthalate
ND
0.015
0.48
0.17
68
Di-n-butyl phthalate
ND
ND
0.086
0.029
69
Di-n-octyl phthalate
ND
ND
0.031
0.010
71
Dimethyl phthalate
ND
ND
0.12
0.040
73
Benzo(a)pyrene
ND
ND
0.01
*
84
Pyrene
ND
ND
0.032
0.010
85
Tetrachloroethylene
0.027
ND
-
*
114
Ant imony
NR
NR
0.030
0.010
119
Chromium
ND
0.025
—
*
121
Cyanide, Total
0.034
*
ND
0.010
122
Lead
0.015
0.025
-
0.013
124
Nickel
0.015
*
-
*
125
Selenium
NR
NR
0.068
0.023
128
Zinc
-
0.23
-
0.077
* :	Less than 0.010 mg/1
NR:	Not reported
ND:	Not detected
(1)	All values are in mg/1 unless otherwise noted.
(-)	Calculation yielded a negative value.
293

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ALKALINE CLEANING SUBCATEGORY
SECTION VI
WASTEWATER POLLUTANTS
This section describes the wastewater pollutants characteristic of
alkaline cleaning operations and the basis for the Agency's selection
of those pollutants for which limitations are proposed. The first
step in this process involved the development of a list of pollutants
considered to be representative or characteristic of the alkaline
cleaning process. This list is based upon data gathered during the
original study and through DCP responses.
This initial list of pollutants was confirmed by data collected from
field sampling conducted during this study. A r®Y**w .?f f
analytical data for the wastewater samples collected during all of the
field sampling programs formed the basis for the f®eleetion of
pollutants for which limitations are being proposed for alkaline
cleaning operations.
In the originally promulgated limitations, five pollutants *er®
limited including total suspended solids, dissolved iron, dissolved
chromium dissolved nickel and pH. In these proposed limitations, the
Agency has selected different pollutants for limitation. The Agency
is not proposing limitations for dissolved chromium, iron or nickel.
Additional information on these proposed changes are provided below.
The Aaencv is Drooosing to eliminate limitations for dissolved nickel,
chromium^ In/lTn In the originally promulgated limitations, these
pollutants were limited because high levels were detected at the one
mill which was sampled (Plant I). However, the wastewater monitored
at this mill was a combination of wastewaters from pickling and
alkaline cleanina operations. The Agency now believes that the levels
of thesl three pollutants are most likely attributable to the pickling
wastes and not to the alkaline cleaning wastewaters. This conclusion
is based upon the additional data collected at the three other Plants
for this studv Those data show that the concentrations of these
three pollutants in the wastewaters from the alkaline cleaning
operations are very low, with averaqe levels of about 0.01 mg/1.
The wastewater from the alkaline cleaning process is relatively clean
in comDarison to wastewaters from other steelmaking operations.
However there is the potential for high concentrations of various
pollutants in the discharge from the mills. Suspend®^ solids, oil and
grease, toxic metals (antimony, lead, selenium, and zinc) and nigh pH
are characteristic of the alkaline cleaning	a1.h* e
pollutants are generated in the rinse tanks and the cleaning baths.
The suspended solids and toxic metal pollutants originate when the
dirt, soot and scale are removed from the steel product in the
cleaning bath. Because the solution is not as aggressive as some of
the other cleaning steps (i.e., pickling and scale removal), the
295

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solutions do not contain high concentrations of most toxic metal
pollutants. Solids, both total and dissolved, are the principal
pollutants washed off the surface of the metal. In addition, the
cleaning baths are used to remove oil coatings that may have been
applied to the steel product to prevent rust formation during storage.
This oil is washed off during the process and enters the wastewaters.
The discharges from the cleaning mills also have a high pH. This
results from the alkaline solutions that are used in the process. pH
levels of 9-12 are commonly found in alkaline cleaning wastewaters.
Sampling of toxic pollutants was performed. The Agency did not expect
to find these pollutants to be present at significant levels.
However, the possibility existed that some toxic pollutants may be
present in some of the substances or solutions used in the cleaning
process. A list was developed which summarizes the toxic pollutants
known to be present in alkaline cleaning wastewaters (Table VI—1).
This list is based upon data gathered from the sampling visits and
responses by the industry.
Using the sampling data, the Agency calculated a net concentration
value for each pollutant found in the raw wastewaters. A net raw
value was used because this value best describes the contribution of
pollutants from the alkaline cleaning process. If one of the
pollutants was found to be in the raw wastewater at an average
concentration (net) of 0.010 mg/1 or greater, the Agency considered it
to be characteristic of alkaline cleaning wastewaters and is addressed
accordingly throughout this report. The list of the toxic pollutants
determined to be characteristic of the alkaline cleaning subcategory
is presented in Table VI-2. Also included in this table are the
nontoxic pollutants determined to be characteristic of the process.
Five additional pollutants were detected at an average concentration
greater than 0.010 mg/1 but are not listed in Table VI-1 or VI-2. The
Agency believes that their presence is not attributable to alkaline
cleaning operations. Methylene chloride was detected at high
concentrations but was omitted because the Agency believes that this
pollutant is not present in alkaline cleaning wastewaters. This
compound is commonly used as a cleaning agent in the laboratory and
its presence is ascribed to this practice; not to the alkaline
cleaning operation. Also, four phthalate compounds were detected at
levels greater than 0.010 mg/1. Evidence developed during the
sampling inspections indicates that their origin was probably related
to plasticizers in the tubing used in collecting the samples
automatically.
Based upon the analysis conducted above and in Section V, it appears
that none of the toxic pollutants are present in the wastewaters from
alkaline cleaning mills at concentrations at levels sufficient to
warrant limitation at the BAT level. All the pollutants are present
in concentrations that are below practical treatability levels. Aside
from reducing the BPT effluent through recycle or water conservation
practices, there are no economically achievable treatment technologies
that EPA is aware of to reduce the loading of those pollutants by a
significant amount. Recycle is being practiced at only one plant in
this subcategory. However, the alkaline cleaning wastewaters at this
296

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plant are mixed with other wastewaters, and the combined waste stream
is reused at different processes. The Agency has no other information
regarding recycling of alkaline cleaning wastewaters or water conserva-
tion practices (such as cascade rinsing) which can be applied at
these operations; As a result, the Agency has been unable to assess
the feasibility of reducing discharge flow rates of alkaline cleaning
operations. The Agency is, therefore, soliciting comments and
information on the feasibility of flow reduction for the alkaline
cleaning subcategory.
297

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TABLE VI-1
TOXIC POLLUTANTS KNOWN TO BE PRESENT IN
ALKALINE CLEANING WASTEWATERS
Toxic Pollutant	
23. Chloroform
36.	2,6-Dinitrotoluene
39.	Fluoranthene
64.	Pentachlorophenol
65.	Phenol
73.	Benzo(a)pyrene
84.	Pyrene
85.	Tetrachloroethylene
114.	Antimony
119.	Chromium
121.	Cyanide, Total
122.	Lead
123.	Nickel
125.	Selenium
128.	Zinc
298

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TABLE 71-2
SELECTED POLLUTANT PARAMETERS
ALKALINE CLEANING SUBCATEGORY
Dissolved Iron
Oil & Grease
Total Suspended Solids
PH
36 2,6-Dinitrotoluene
39 Fluoranthene
84 Pyrene
114 Antimony
121	Cyanide, Total
122	Lead
125 Selenium
128 Zinc
299

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ALKALINE CLEANING SUBCATEGORY
SECTION VII
CONTROL AND TREATMENT TECHNOLOGY
Introduction
A review of the control and treatment technologies currently in use or
available for use in the alkaline cleaning subcategory provided the
basis for selecting and establishing the BPT, BCT, and NSPS
alternative treatment systems. This review involved summarizing
questionnaire and plant visit data in order to identify those
treatment components and systems in use at alkaline cleaning
operations. The Agency analyzed which treatment components and
systems were most appropriate for the various levels of treatment.
This section also presents the raw wastewater and treated effluent
analytical data for the plants sampled, and a short description of the
treatment at each of the sampled plants.
Summary of Treatment Practices Currently Employed
As explained previously, wastewater in the alkaline cleaning
operations is generated in the cleaning tanks and the the rinse steps
following the cleaning operation. The wastewater and treatment
techniques practiced by the operating alkaline cleaning mills vary
considerably, but most tend to have similar components to reduce
levels of the pollutants present. The Agency used the data from the
DCPs and the plant visits to determine the treatment methods practiced
at alkaline cleaning operations. Based upon these data, the Agency
developed the following summary of disposal and treatment techniques:
No. of Operations
Choosing This Treatment	% of
and/or Disposal Practice Total
No. of mills providing
treatment of any kind	106	60.6
No. of mills discharging
to a POTW system	44	25.1
No. of mills having
wastes hauled	12	6.9
No. of mills that do not
provide any treatment	13	7.4
TOTAL 175	100%
As explained earlier, all alkaline cleaning lines that provide
treatment do so in central treatment systems. These treatment systems
usually include wastewaters from operations that have similar or
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compatible wastewater characteristics and thus are designed primarily
to reduce the levels of suspended solids, oils, greases, and dissolved
metals as well as to neutralize the pH of the discharge. The type of
treatment operations at the mills surveyed are outlined below.
The first treatment step that is carried out at many of the alkaline
cleaning operations is equalization. Because of the potential for
batch discharges to originate in the process and for other waste
sources to be combined with the alkaline cleaning wastes, wastewaters
are collected in a sump or pit at many lines with sufficient retention
time to equalize the wastewater prior to subsequent treatment.
Because of the presence of oils and greases in the wastewaters, oil
separation is usually practiced. Several methods are used in this
subcategory (i.e., API separation, trough type, belt type skimmer),
but surface skimming in the equalization basin is often practiced.
After equalization and oil separation, the wastewaters are
neutralized. The DCP responses indicate that this is done in two
ways. If the other wastewaters entering the central treatment system
are acidic, then the alkalinity of the wastewaters from the alkaline
cleaning operations are neutralized to the required pH range by
comingling with those other wastewaters. This practice is common at
many mills, as it reduces chemical costs. If acidic wastewaters are
not present in the central treatment systems, then acid must be added
to the alkaline cleaning wastewaters for neutralization. The cost of
this system is higher than other types of neutralization systems
because of the amount of acid required to neutralize the alkalinity of
the wastewater. Only 17% of the alkaline cleaning lines have
auxiliary acid addition systems installed in the event that the other
wastewaters entering the central treatment system do not neutralize
the wastewaters sufficiently.
After neutralization and oil skimming, polymers are usually added in a
mixing tank to promote flocculation. These agents are useful in
promoting settling in clarification systems. Various chemical agents
are used to achieve optimum settling, depending on the exact nature of
the wastes.
After equalization, oil skimming and chemical.addition, removal of the
suspended solids and metals is commonly practiced in central treatment
systems that include alkaline cleaning wastewaters. This is done in a
variety of ways within this subcategory. Seven alkaline cleaning
operations use settling lagoons as a sedimentation device. Eighteen
use flocculation-clarifiers alone, or in conjunction with settling
lagoons, and two use thickeners to achieve solids and metals removal.
Additionally, there are four operations that employ filtration to
reduce pollutant loads. The choice of clarification or filtration
devices depends upon the amount of land available for installation of
the treatment system and the other types of wastewaters that are
treated in the central treatment systems.
In the clarification or filtration step, sludges are generated as
solids, oils, and precipitated metals are removed from the
wastewaters. Large volumes of sludge can be generated depending upon
302

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the wastewaters being treated and the type of neutralization carried
out. Three types of solid waste dewatering devices - centrifuges,
thickeners and vacuum filters - are used in this subcategory to reduce
the volumes of solid waste generated.
Advanced Treatment Systems Considered
for the Alkaline Cleaning Subcategory
As shown in Section V, none of the toxic organic or inorganic
pollutants were detected above treatability levels in alkaline
cleaning wastewaters. For this reason, the Agency did not consider
additional wastewater treatment components that would achieve further
concentration reductions of the toxic pollutants. Instead, the Agency
considered advanced treatment systems which would reduce or eliminate
the wastewater flow from the alkaline cleaning operation and thus
reduce the pollutant load being discharged.
A description of the advanced treatment alternatives considered by the
Agency for alkaline cleaning operations, is set out below. These
systems have been demonstrated, to varying degrees, in the alkaline
cleaning subcategory or in other industrial applications on
wastewaters with characteristics similar to those generated in the
alkaline cleaning operation.
1. Ultrafiltration
Ultrafiltration (UF) is a pressure driven process for separating
high molecular weight solutes or colloids from water solutions by
means of a permeable membrane. The wastewater is filtered by
passing it through the membrane under low pressure.
This process is now being developed for use on alkaline cleaning
baths. These baths are quite amenable to ultrafiltration,
resulting in the concentration of the dilute oily waste and the
recycle of the alkaline cleaning chemicals. Since UF membranes
allow only the low molecular weight solutes and water to pass
through, the emulsified oil and particulates are held back and
concentrated. The concentrate is not returned to the cleaner
bath and serves to remove the soil and oily waste from the
cleaning system. The main components of the cleaning solutions,
the alkali and builders, are generally low molecular weight
solutes. These materials pass through the membrane freely and
are returned to the cleaner bath.
By using this system, the amount of pollutants discharged from
the cleaning bath is reduced significantly. This reduces
chemical costs needed to make up the solutions, improves the
cleaning characteristics of the bath and reduces the pollutant
load generated by the alkaline cleaning process.
While no data are presently available regarding the application
of this technology to alkaline cleaning solutions, it is expected
that this system will work quite effectively. Although the
technology can be costly, a payback period of less than 3 years
is predicted because of the saving achieved due to the reuse of
303

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the cleaning solutions. While the installation of this treatment
system would reduce the pollutants in the cleaning baths, the
rinsewater would still require treatment.
Vapor Compression Distillation (Evaporation)
Vapor compression distillation is typically used to concentrate a
high dissolved solids wastestream (3,000-10,000 mg/1) to a slurry
consistency (approximately 100,000 mg/1). The slurry discharge
can be dried in a mechanical drier or allowed to crystallize in a
small solar or steam-heated pond prior to final disposal. The
distillate quality water generated by this system can be recycled
to the alkaline cleaning operation thereby eliminating all
discharges to navigable waters. One desirable feature of this
unit is its relative freedom from scaling. Because of the unique
design of the system, calcium sulfate and silicate crystals grow
in solution as opposed to depositing on heat transfer surfaces.
Economic operation of this system requires a high calcium to
sodium ratio (hard water).
Due to economic considerations, only limited application is made
of vapor compression distillation in processing wastewater.
Vapor compression distillation may be the only possible means to
achieve zero discharge of process water for alkaline cleaning
operations.
3.	Cascade or Counter-Current Rinse System
The installation of a cascade rinse system can drastically reduce
the rinsewater flows discharged from the alkaline cleaning
process. This system replaces or modifies the existing rinsing
system to achieve a multiple tank arrangement in series. The
water flow to the tanks is reduced and cascades from one tank to
the next. The product being cleaned travels in the opposite
direction to the water flow and thus encounters progressively
cleaner water. This type of arrangement reduces the wastewater
flow (i.e., the waste volume), concentrates the pollutants in the
first rinsing chamber and achieves a more thorough rinsing
because of the multiple rinsing achieved in the series of tanks.
Although this type of rinsing is ideally suited for continuous
operations it can also be implemented at batch type operations.
The rinsing operation carried out in the alkaline cleaning
process is similar to the rinsing operations in pickling and hot
coating which include cascade rinse systems. Therefore, there is
a great potential for the use of this system at alkaline cleaning
operations.
4.	Reuse Systems
As the wastewaters from alkaline cleaning operations are
relatively clean after treatment, there is a great potential for
reuse. While reuse rates up to 100% were demonstrated, these
high rates where achieved mainly because the alkaline cleaning
wastewaters were diluted with other wastes in large central
treatment systems. A reuse rate of 50% to other processes has
304

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been demonstrated at numerous lines. This rate was also achieved
at a line with a separate treatment system.
5. Recycle Systems
The low pollutant concentrations associated with alkaline
cleaning wastewaters provide a great potential for recycle of the
treated effluent. A recycle system could significantly decrease
the discharge from alkaline cleaning operations. With a recycle
rate of 90%, the proposed BPT flow of 50 gal/ton could be reduced
to 5 gal/ton. Limited use of this technology (one plant, Oil 2D)
has been demonstrated throughout the alkaline cleaning
subcategory. The one plant using recycle has two lines in
operation. Fifty and ninety percent of the process water
required by these two lines is central treatment effluent
supplied using recycle systems. In addition to flow reduction,
recycle systems also decrease the pollutant load being
discharged.
Summary of Samplinq Visit Data
Three alkaline cleaning lines were visited for this study: two
continuous operations and one batch operation. Table VI1-2 presents
the raw wastewater and effluent analytical data for these lines.
Table VIl-i provides a legend for the various control and treatment
technology abbreviations used on the above table and in other tables
throughout this report. The concentration values presented in Table
VI1-2 represent, except where footnoted, gross average values. In
some cases these data were obtained from central treatment systems. A
brief discussion of each wastewater treatment system follows.
Additional detail is presented for each wastewater system in the
respective flow diagrams.
Plant 152 - Figures VII-1 and VI1-2
Wastewaters from alkaline cleaning operations are discharged to a
complex central treatment system. The sources of wastewaters to the
central treatment system are shown in Figure VII-1 and the schematic
for the treatment system is shown in Figure VI1-2. The alkaline
cleaning wastewaters, which comprise approximately 1% of the total
flow to the central treatment system, are discharged directly to the
central treatment system without pretreatment.
The wastewaters combine with wastewaters from approximately twenty
other sources and undergo equalization and neutralization,
flocculation with polymers, and clarification with oil skimming.
Sludge formed in the treatment process is dewatered in mechanical
centrifuges. The effluent from this system is discharged to a
receiving stream.
PlanT 156 - Figure VII-3
A complex central treatment system is also used at this plant. The
alkaline cleaning wastes comprise less than 1% of the total flow. The
alkaline cleaning solutions and rinses are combined with wastewaters
305

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from other sources and then undergo equalization, neutralization and
primary clarification in a thickener. From the clarifier, the
wastewaters enter a high-density-sludge (HDS) unit where the solids
and metals are settled out. The overflow from the HDS unit is then
filtered. The filtrate is discharged to a final polishing lagoon
where additional settling and temperature equalization is carried out
prior to discharge to a receving stream.
Plant 157 and I_ - Figure VII-4
The alkaline cleaning wastewaters from this mill are also treated in a
central treatment system. The two sources of wastewater from the
alkaline cleaning operation are treated differently.
The rinsewater from the process is treated with rinsewaters from other
process lines and receives only neutralization and settling in lagoons
prior to discharge. The spent cleaning solutions are collected and
used to help neutralize spent pickle liquor generated in nearby pickle
lines. After being mixed with the waste pickle liquor, the combined
wastes enter the settling lagoons where some sedimentaiton occurs.
The alkaline cleaning wastes at this plant make up less than 1% of the
total flow to the central treatment system.
306

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TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
Symbols
A.	Operating Modes
1.	OT	Once-Through
2.	Rt,a,n	Recycle, where t - type waste
8 ¦ stream recycled
n ¦ Z recycled
t: 0 ¦ Untreated
T ¦ Treated
P	Process Wastewater	Z of raw waste flow
F	Flume Only	Z of raw waste flow
S	Flume and Sprays	X of raw waste flow
FC	Final Cooler	Z of FC flow
BC	Barometric Cond.	Z of BC flow
VS	Abs. Vent Scrub.	Z of VS flow
FR	Fume Hood Scrub.	Z of FH flow
3. REt,n	Reuse, where t ¦ type
n ¦ Z of raw waste flow
t: U ¦ before treatment



T ¦ after treatment

4.
BDn
Blowdown, where n - discharge as Z of
raw waste flow
B.
Control Technology


10.
DI
Deionization

11.
SR
Spray/Fog Rinse

12.
CC
Countercurrent Rinse

13.
DR
Drag-out Recovery
C.
Disposal Methods


20.
H
Haul Off-Site

21.
DW
Deep Well Injection
307

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TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 2		
C.	Disposal Methods (cont.)
22. Qt,d	Coke Quenching, where t = type
d = discharge as Z
of makeup
t: DW ¦ Dirty Water
CW ¦ Clean Water
23.
EME
Evaporation, Multiple Effect
24.
ES
Evaporation on Slag
25.
EVC
Evaporation, Vapor Compression
Treatment
Techno logy
30.
SC
Segregated Collection
31.
E
Equalization/Blending
32.
Scr
Screening
33.
OB
Oil Collecting Baffle
34.
SS
Surface Skimming (oil, etc.)
35.
PSP
Primary Scale Pit
36.
SSP
Secondary Scale Pit
37.
EB
Emulsion Breaking
38.
A
Acidification
39.
AO
Air Oxidation
40.
GF
Gas Flotation
41.
M
Mixing
42.
Nt
Neutralization, where t = type
L ¦ Lime
C ¦ Caustic
A ¦ Acid
W ¦ Wastes
0 ¦ Other, footnote
308

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TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 3
D.	Treatment Technology (cont.)
43.	FLt	Flocculation, where t = type
t: L *¦ Lime
A ¦ Alum
P ¦ Polymer
M ¦ Magnetic
0 ¦ Other, footnote
44.	CY	Cyclone/Centrifuge/Classifier
44a. DT	Drag Tank
45.	CL	Clarifier
46.	T	Thickener
47.	TP	Tube/Plate Settler
48.	SLn	Settling Lagoon, where n - days of retention
time
49.	BL	Bottom Liner
50.	VF	Vacuum Filtration (of e.g., CL, T, or TP
underflows)
51.	Ft,m,h	Filtration, where t = type
m ¦ media
h ¦ head
	t	m	h	
D » Deep Bed	S - Sand	G ¦ Gravity
F ¦ Flat Bed	0 * Other, P ¦ Pressure
footnote
52.	CLt	Chlorination, where t ¦ type
t: A ¦ Alkaline
B ¦ Breakpoint
53.	CO	Chemical Oxidation (other than CLA or CLB)
309

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TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 4		
D.	Treatment Technology (cont.)
54. BOt	Biological Oxidation, where t » type
t » type

t: An =»
Activated Sludge
n «
No. of Stages
T -
Trickling Filter
B -
Biodisc
0 »
Other, footnote
55.	CR	Chemical Reduction (e.g., chromium)
56.	DP	Dephenolizer
57.	ASt	Ammonia Stripping, where t = type
t: F ¦ Free
L " Lime
C ¦ Caustic
58.	APt	Ammonia Product, where t » type
t: S = Sulfate
N * Nitric Acid
A * Anhydrous
P ¦ Phosphate
H ¦ Hydroxide
0 ¦ Other, footnote
59.	DSt	Desulfurization, where t " type
t: Q = Qualifying
N ¦ Nonqualifying
60.	CT	Cooling Tower
61.	AR	Acid Regeneration
62.	AU	Acid Recovery and Reuse
63.	ACt	Activated Carbon, where t ¦ type
t: P ¦ Powdered
G " Granular
64.	IX	Ion Exchange
65.	RO	Reverse Osmosis
66.	D	Distillation
310

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TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 5
D.	Treatment Technology (cont.)
67.	AA1	Activated Alumina
68.	OZ	Ozonation
69.	UV	Ultraviolet Radiation
70.	CNTt,n	Central Treatment, where t * type
n ¦ process flow as
Z of total flow
t: 1 ¦ Same Subcats.
2	¦ Similar Subcats.
3	¦ Synergistic Subcats.
4	¦ Cooling Water
5	¦ Incompatible Subcats.
71.	On	Other, where n ¦ Footnote number
72.	SB	Settling Basin
73.	AE	Aeration
74.	PS	Precipitation with Sulfide
311

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TABLE VII-2
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
ALKALINE CLEANING SUBCATEGORY
Raw Wastewater*
Co
N)
Effluents
Reference Code
Plant Code
Sapling Point
Flow(gal/ton)
C4TT
Reference Code
0176-01

01121-04

0432K


Plant Code
152


156


157
Average
Stapling Point
V


C


C


Flow(gal/ton)
8.5


67


254
379

Type
of Mill
Continuous

Batch


Continuous




¦g/1
lbs/1000 lbs
¦g/1

lbs/1000 lbs
¦g/1
lbs/1000 lbs
¦g/i
lbs/1000 lbs

Dissolved Iron
0.10
0.00034
0.34

0.000095
0.70
0.00074
0.38
0.00039

Oil & Grease
8.0
0.027
9.0

0.0025
21.3
0.023
12.8
0.018

Suspended Solids
3.5
0.012
11.0

0.0031
16.7
0.018
10.4
0.011

pH, units
8.9-9.1

7,
,2-8.1

10.
3-11.7
7.2-11.7

36
2, 6-Dinitrotoluene
ND
ND
ND

ND
0.047
0.000050
0.016
0.00017
39
Fluoranthene
ND
NS
*

Neg.
0.051
0.000054
0.020
0.000018
84
Pyrene
ND
ND
*

Neg.
0.032
0.00003A
0.014
0.000011
114
Antimony
NR
NR
NR

NR
0.048
0.000051
0.048
0.000051
121
Cyanide, Total
0.053
0.00018
0.003

Neg.
ND
ND
0.019
0.000060
122
Lead
0.065
0.00022
0.075

0.000021
0.060
0.000064
0.067
0.000010
125
Selenius
NR
NR
NR

NR
0.070
0.000074
0.070
0.000074
128
Zinc
0.03
0.00010
0.30

0.000084
0.049
0.000052
0.13
0.000079
0176-01()
152
(V/ZHZZ)
815
E, FLP, NC, MW, NA,CL, T, VF
01121-04
156
H
67
0432K
157
D
254


¦g/1
lbs/1000 lbs
¦g/1
lbs/1000 lbs
¦°g/*
lbs/1000 lbs

Dissolved Iron
0.8
0.0000012
0.045
0.000013
18.0
0.019

Oil & Grease
4.5
0.0039
4.0
0.0011
4.0
0.0042

Suspended Solids
16.5
0.00048
1.0
0.00028
91.7
0.097

pti, units
7.2-7.9

7.3-7.7

5.6-6.7

36
2,6-Dinitrotoluene
ND
ND
ND
ND
ND
ND
39
Fluoranthene
*
ND
*
Neg.
ND
ND
84
Pyrene
*
ND
*
Neg.
ND
ND
114
Antiaony
NR
NR
NR
NR
0.038
0.000040
121
Cyanide, Total
0.035
0.0025
0.001
Neg.
ND
ND
122
Lead
0.05
0.00015
0.075
0.000021
0.60
0.00064
125
Selenivm
*
NR
NR
NR
ND
ND
128
Zinc
0.04
Neg.
0.13
0.000036
0.29
0.00031
NOTE: For a definition of C&TT codes, See Table VII-1.
(1)	lbs/1000 lbs value for this operation cannot be derived directly froa the concentrations and flov rates shovo.
* : Less than 0.010 vg/1
Neg: Less than 0.0000010 lbs/1000 lbs
ND : Not Detected
NR : Not Reported

-------
MAKE-UP
5.6 l/SEC.(90 GPmT^
I.I I/SEC(I6.8 GPM)
0.38 l/SEC.(6.IGPM)
0.76 I/SEC.02 GPM)
0.88 I/SEC.04 GPM)
0.30 I/SEC.W.8 GPM)
a95 I/SEC.U5 GPM)
1.3 l/SEC.(20 GPM)
0.20 l/SEC.(3.0 GPM)
K> 0.44 l/SEC. (7.0 GPM)
11	6.6 I/SEC.Q06GPM)
12	0.22 I/SEC.135 GPM)
» 2.5 l/SEC.(40 GPM)
#3

HOT MILL

t
0.21 l/SEC.
<3.3 GPM)
PROCESS
HOT FORMING, PICKLING, SCALE REMOVAL. WIRE
COATING, ALKALINE CLEANING
PLANT 081,122,132,142,152
PRODUCTIONS-65 METRIC T0NS/TURN(72 TONS/TURN)
N(*l a*2 MILLS)-43 METRIC TONS/TURN
(48 TONS/TURN)
N(*4MILL)-64 METRIC TONS/TURN(70 TONS/TURN)
W * 2 BL0CK85 METRIC TONCTURNOO TONS/TURN)
BENCH CLEAMNG 7E METRIC TONS/T\JRN(B4 TONS/TURN)
XlK0LENE)-65 METRIC T0NS/TURN(94 TONS/TURN)
XlHYDRI0E)-75 METRIC TONS/TURN(83 TONS/TURN)
r-4.5 METRIC TONS/TURN (5 TONS/TURN)
Z-4.8 METRIC TONS/TURN(5.3 TONS/TURN)
DISC
INSPECTION
.2 l/SEC.—\
(114 GPM) \
27.7 l/SEC.
(439 GPM)
3.1 l/SEC.
(49 GPM)
0.66 l/SEC.
(10.5 GPM)
LAMELLA
SEPERATOR
354 GP
0 l/SEC
5 GPM)
3.1 l/SEC.
(49 GPM
75 l/SEC.
(1200 GPM)
20.5 l/SEC:
(325 GPM)
SEDIMENTATION
#1 8 #2
HOT MILL
5.7 l/SEC
(91 GPM)
1.8 l/SEC.
(28.2 GPM)
FURNACE COOLMG WATER
OVERFLOW
LAGOON
LIFT
STATION
KOLENE/HYOROCHLORIC RMSE
OTHER PROCESS
WASTEWATERS
SECONDARY RINSE
HOSE
RINSE
HEX CHROMIUM
TREATMENT
SCRUBBER
27.4 l/SEC
1438 GPM)
SCRUBBER
CENTRAL
TREATMENT
PLANT
SCRUBBER
ROOF
SAMPLE POINTS
NORTH SCRUBBER
Cu-NoOH RINSE
Cu/CN
TREATMENT
48.0 l/SEC.
(769 GPM)
Cu-PLATE
RINSE
DISCHARGE
0.6 l/SEC.
GPM)*
ENVIRONMENTAL
15.3 l/SEC(245 GPM)
PROTECTION AGENCY
LEAD COATING ACID
RINSE
STEEL INDUSTRY STUOY
HOT FORMING, PICKLING, SCALE REMOVAL,
WIRE COATING,ALKALINE CLEANING
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
HYDRIDE
QUENCH
SODIUM
RINSE
HOSE

FUME
SCRUBBER
F GURE En-1
* COMWVNY SUPPLIED (DCP RESPONSE) FLOW RATE

-------
SLUDGE TO
DISPOSAL
FLOCCULANT
AID
Clarifier Water
TO EMER6ENCY
OVERFLOW LAGOON
MECHANICAL
CENTRIFUGE
PROCESS: HOT FORMING, PICKLING.SCALE REMOMAL.
WIRE COATING, ALKALINE CLEANING
PLANT: 081,122,132,142,152
PRODUCTION: SAME AS FIGURE HI-1
Overflow
SURGE
TANK
h2so4
ADDITION
NaOH
ADDITION
TREATED WATER
FROM Cu/CN
h2so4
ADDITION
NaOH
ADDITION
INFLUENT-
EQUALIZATION
a
NEUTRALIZATION
COMPRESSED
AIR
NEUTRALIZATION
a
FLOCCULATION
COAGULANT/
FLOCCULATION AID
CLARIFIER
"/OIL SKIMMING

OUTFALL
Sludge
SLUDGE
CONCENTRATOR
SLUDGE TO
DISPOSAL
A
SAMPLE POINTS
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT FORMING .PICKING, SCALE REMOVAL,
WIRE COATING,ALKALINE CLEANING
CENTRAL TREATMENT PLANT
WATER FLOW DIAGRAM
•Z3E5ZD
1
I
FIGURE MtZ

-------
PROCESS: Z'ALKALINE CLEANING
SPRING WATER
SOUTH DEGREASER
ALKALINE RINSES
PLANT: 186
PRODUCTION; Z- 25.3 metric tons/turn
(27.9 tons/lurn)
NORTH AND SOUTH
GALVANIZER RINSES
3.9 GPM
(0.25 l/SEC)
-f ELECTROLYTIC
RINSES
58 GPM
(3.7 l/SEC)
BETHALUME Y
6.6 GPM
(0.42 l/SEC)
RANSOHOFF WASHER,
FURNACES, ETC.
70 GPM
(4.4 l/SEC)
LIME
10" MILL,
«	/HOT FORMING
ETC.
~ REACTOR
THICK!
/\SAMPLING POINT
4100 QPM
(261.5 l/SEC)
COIL DRAWING, ETC.
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
ACIO PICKLING, GALVANIZING, ALKALINE CLEANING
WASTEWATER TREATMENT SYSTEM
WATER FLOW OIAGRAM
TO STREAM AND/OR
RECYCLE
DWN.il/27/7E
LAGOON
DEEP
BED
FILTERS
HDS
FILTERS
EQUALIZATION
TANK

-------
u>
CTv
Z-CONTINUOUS ALKALINE CLEANING
process:
PLANT:
SOFTENER
production:
Z-BRITE ANNEAL 30.8 METRIC TONS STEEL/TURN
(34 TONS STEEL/TURN)
DECREASE
Penn-Salt Cleaner
OTHER PROCESS WASTEWATER
PICKLING "HOT ANNEAL'FUME
SCRUBBER SYSTEMS-ft ROLL
GRINDING SHOP
RINSE
COLD ANNEAL
AND
PICKLE LINE
(KOLENE)
ANNEAL
EQUALIZATION
TANK
LIME
SLURRY
PICKLING
WASTE PICKLE
LIQUORS
139 l/SEC
(2200 GPM)
RINSE
MIX
TANK
1.1 l/sec
(IB GPM)
142 l/SEC 1
(2250GPM))
SETTLING LAGOONS (2)
DISCHARGE TO
RECEIVING STREAM'
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
CONTINUOUS ALKALINE CLEANING a SCALE
REMOVAL-KOLENE SALT BATH
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
SAMPLING POINT
FIGURE EH-4

-------
ALKALINE CLEANING SUBCATEGORY
SECTION VIII
COST, ENERGY, AND NONWATER QUALITY IMPACTS
Introduction
This section presents the incremental costs incurred in applying the
different levels of pollution control technology to the alkaline
cleaning subcategory. The analysis also describes energy
requirements, nonwater quality impacts, and the techniques, magnitude
and costs associated with the application of proposed limitations and
standards.
Actual Costs Incurred by the
Operations Sampled for This Study
The water pollution control costs reported by the industry for
operations sampled during this study and for the operations for which
D-DCP responses were received are presented in Table-VIII-1. The
costs were updated to July 1978 dollars from the data supplied by the
plants at the time of sampling or from data supplied in D-DCP
responses. In these tables, standard costs of capital and
depreciation percentages were used so that these basic costs would be
comparable. Also, where central treatment systems were present the
industry often supplied total cost data for the entire.treatment
system. The Agency analyzed these costs and estimated that proportion
attributable to alkaline cleaning operations as accurately as
possible. Accordingly, only those costs due to the treatment of the
alkaline cleaning wastes are listed.
Because of the extensive use of central treatment for alkaline
cleaning wastewaters, the Agency could not directly verify its
model-based cost estimates for separate treatment of alkaline cleaning
wastewaters with cost data reported by the industry for central
treatment systems. However, the Agency did compare its model-based
separate treatment costs with industry costs for several central
treatment systems by summing the model-based separate treatment costs
for each subcategory included in the existing central treatment
systems. The results of this comparison presented in Volume I
demonstrate that the Agency's costing methodology accurately reflects
industry costs for central treatment facilities in general, and for
those systems including alkaline cleaning wastewaters in particular.
In fact, as shown by the data presented in Volume I, the Agency's cost
estimates for separate treatment for finishing operation wastewaters
are likely to be significantly higher than actual costs to be incurred
by industry for central treatment.
The treatment system components considered for BPT are presented in
Table VII1-2. The technologies described therein represent treatment
alternatives either in use or available to alkaline cleaning
317

-------
operators. In addition to listing the treatment methods available,
these tables also describe for each methods
1.	Status and reliability
2.	Problems and limitations
3.	Implementation time
4.	Land requirements
5.	Environmental impacts other than water
6.	Solid waste generation
Cost, Energy. and Nonwater Quality Impacts
General Introduction
The installation of the BPT, BAT, BCT, NSPS, and Pretreatment
alternative treatment systems involve additional expenditures of	money
and energy. In addition, the Agency considered the effect	those
systems will have on air pollution, water consumption, and solid	waste
disposal. The Agency estimated the cost and energy requirements	based
upon the treatment models developed in Sections IX through	XIII.
These estimates are presented in this section.
Estimated Costs for the
Installation of Pollution Control Technologies
A. Costs Required to Achieve the Proposed BPT Limitations
Based upon the status of the industry as of January 1978, the
Agency estimates that the industry will need to spend $7.1
million (capital cost) to upgrade existing water pollution
control facilities in the alkaline cleaning subcategory to
achieve the proposed BPT limitations. The total capital cost of
BPT is about $13.6 million. Additionally, about $4.2 million of
annual expenditures are required.
To develop the above costs, the Agency developed model plants
based upon average plant sizes at the proposed flow rates. The
model BPT treatment costs are presented in Tables VII1-3 and
VI11-4 for batch and continuous operations, respectively. Plant
by plant capital cost estimates were then made by factoring plant
production to the model plant size by the "six-tenth" rule. A
summary of the capital cost for each plant to achieve the BPT
level of treatment is presented in Tables VII1-5 and VII1-6 for
batch and continuous operations. This method yielded a cost
estimate for the subcategory which the Agency believes is
representative of the actual costs which the industry will bear.
The cost comparisons presented in Volume I verify the accuracy of
this costing methodology. Because the DCP responses listed the
treatment components already installed in the subcategory, the
Agency was able to separate the cost of "in-place" components
from the total estimated cost.
As a final note, it should be pointed out that the cost estimates
for this subcategory were developed based upon the assumption
that separate wastewater treatment systems would be installed at
318

-------
all lines. However, as pointed out earlier, all of the
operations in this subcategory which have treatment systems do so
in central systems. Treating wastewaters in a central system
reduces costs because of economies of scale and because duplicate
equipment components are not needed. Therefore, the Agency's
estimates are believed to be very conservative. Actual costs for
this subcategory are expected to be much less than the estimates
listed above.
B.	Costs Required to Achieve BAT Limitations
The Agency considered a BAT treatment system based upon recycle
of the BPT effluent. The model treatment costs associated with a
recycle system are presented in Tables VI11-7 and VI11-8 for
batch and continuous operations, respectively. The cost of 90%
recycle for the alkaline cleaning subcategory would amount to a
capital investment of $5.5 million.
C.	Costs Required to Achieve BCT Limitations
The Agency has also considered a BCT treatment system based upon
recycle of the BPT effluent. The model treatment costs
associated with a recycle system are presented in Tables VIII-9
and Vlll-10 for batch and continuous operations respectively.
The cost of 90% recycle for the alkaline cleaning subcategory
would amount to a capital investment of $5.5 million. The
results of the BCT cost test for both batch and continuous
operations are listed in Table VIII-11 and VIII-12. The results
of the BCT cost test indicate that the recycle system fails for
both batch and continuous operations. Therefore, the proposed
BCT limitations are being set at the same level as the proposed
BPT limitations.
D.	Costs Required to Achieve NSPS
The Agency considered one NSPS treatment system for the alkaline
cleaning subcategory. This treatment system uses the best and
most efficient treatment components demonstrated in the alkaline
cleaning subcategory. Model costs have been developed for the
model NSPS treatment system and are shown in Tables VIII-13 and
VIII-14 for batch and continuous operations.
E.	Costs Required to Achieve Pretreatment Regulations
The Agency is not proposing subcategory specific pretreatment
standards for alkaline cleaning. Hence, there are no additional
pretreatment costs.
Energy Impacts Due to the
Installation of the Requisite Technology
Very little energy will be required to operate the alternative
treatment systems for alkaline cleaning operations considered by the
Agency. The energy use at the various levels of treatment is
presented below.
319

-------
A.	Energy Impacts at BPT
The Agency estimated the energy expenditures for the proposed BPT
limitations based upon the assumption that all alkaline cleaning
operations will install treatment systems similar to the model
and that the operations will have discharge flows comparable to
the model BPT flows. The Agency estimates that the BPT treatment
systems for all alkaline cleaning operations will use
approximately 3.0 million kilowatt-hours of electrical energy.
This is less than 0.01% of the 57 billion kilowatt-hours used by
the steel industry in 1978.
B.	Energy Impacts at BAT
Additional energy will be required due to the installation of the
BAT model treatment system. The annual costs and the electricity
required for the model size treatment system are shown below.
Energy (kw) Annual Cost ($)
Batch Operations	5.3	800
Continuous Operations	1.3	-200
C. Energy Impacts at BCT
Additional energy will be required due to the installation of the
BCT model treatment model system. The annual costs and the
electricity required for the model size treatment system are
shown below.
Energy (kw) Annual Cost ($)
Batch Operations	5.3	800
Continuous Operations	1.3	200
D. Energy Impacts at NSPS
The energy required to achieve the proposed NSPS and the annual
costs for that electricity are shown below for the model sized
plants.
Energy (kw) Annual Cost ($)
Batch Operations	-3.3	500
Continuous Operations	20.7	3,100
Nonwater Quality Impacts
In general, there are minimal nonwater quality impacts associated with
the model treatment systems. Three impacts were analyzed: air
pollution, solid waste disposal, and water consumption. The analysis
conducted for the alkaline cleaning subcategory found that no
significant nonwater quality impacts will result from the installation
of the treatment systems under consideration.
320

-------
A.	Air Pollution
There are no significant impacts associated with any of the
treatment components being considered in the alkaline cleaning
subcategory.
B.	Solid Waste Disposal
Sedimentation of the alkaline cleaning wastewaters will result in
the generation of a moderate amount of sludge. The amount of
solid waste (assuming dry solids) generated in the BPT model
treatment system is listed below for each type of alkaline
cleaning operation.
Solid Wastes Generated
at BPT (Tons/Year)
Batch Operations	110
Continuous Operations	1,365
These sludges contain primarily settled solid material. However,
they also contain small amounts of toxic metals. These solid
wastes must be properly disposed of in a landfill as it is
unlikely that these wastes can be reused elsewhere at the plant.
As the wastes are presently collected in central treatment and
disposed of, the Agency believes the solid waste impacts
associated with this proposed regulation are reasonable and
justified.
The impacts due to the installation of the BCT model treatment
system will be minimal. Recycle treatment systems mainly reduce
flow and generate little or no solid waste.
There will be minimal impacts due to solid waste disposal at the
NSPS level of treatment due to the small number of operations
expected to install these technologies.
C.	Water Consumption
Because none of the treatment systems considered for alkaline
cleaning operations by the Agency employ cooling systems, little
or no water consumption is anticipated due to the installation of
the model treatment systems. Therefore, this impact did not
affect the selection of model treatment system or the development
of the proposed effluent limitations and standards.
321

-------
Summary of Impacts
The Agency concludes the effluent reduction benefits described below
for the alkaline cleaning subcategory justify any adverse impacts
associated with energy consumption, air pollution, solid waste
disposal, or water consumption.
Effluent Loadings (Tons/Year)
Raw Waste Proposed BPT BAT
Possible
BAT and BCT
Flow, MGD
Suspended Solids
Oil & Grease
Toxic Metals
Toxic Organics
1,521
60.8
0.8
0.2
2.9
76
30
0.8
0.2
2.9
0.29
7.6
3.0
0.08
0.02
322

-------
TABLE VIII-1
EFFLUENT TREATMENT COSTS
ALKALINE CLEANING SUBCATEGORY
(All costs are expressed in July, 1978 dollars)
Plant Code:	152*
Reference Code:	0176-01
Initial Investment	17,996
Cost
Annual Costs
Cost of Capital	774
Depreciation	1,800
Operation and Maintenance	3,493
Energy, Power, Chemicals, etc.	206
Other
TOTAL	6,273
$/Ton	2.00
156*	157*
01121-04	0432K	240B(01-04)
5,627	7,484	610,573
242	322	26,255
563	748	61,057
255	508	63,233
10.5	NA	11,007
16	-	5,714
1,087	1,578	167,266
0.21	0.05	**
* Estimated costs attributable to this subcategory. Costs were apportioned on the basis
of flow.
** This company has claimed its production as confidential information
NOTE: Cost of Capital is based on the formula, Initial Investment x 0.043.
Depreciation Cost is based on the formula, Initial Investment x 0.10.
323

-------
TABLE VII1-2
CONTROL AND TREATMENT TECHNOLOGIES
ALKALINE CLEANINC SUBCATEGORY
Treatment and/or
Control Method* Employed
A. k^ualizatiuii Tank with
Oil Skiver
Statu* and
Reliability
Practiced at a few mills
in this subcategory. Ef-
fective in equalising flow
and batch duaps.
Problem*
and Limitations
Removes primarily
floating oils
laplesen
cation
Time
Land
iequireaenti
1 months li'xiy
(batch)
Environmental
laipact Other
Than Water
None
20'x20'
(continuous)
Solid Waste
Generation and
Primary
Constituents
Oil sludge that
is collected must
be incinerated or
diaposed of in a
landfill.
B. Acid Neutralisation -
Ad«l acid to the effluent frus
Step A in a Mixing tank to
reduce the pH to (6-9).
Practiced at cumecau*
milla in thia subcategory.
Has proven to be an effec-
tive way to reduce the pH
of alkaline wastes.
Increased cost
unless source of
acid exists at
the plant.
6 months 2Vx2S'
to
to
C. Pulyiaer Addition - In the
same Mixing tank as in Step ft,
polymer to promote settling.
0. Clarifier ~ Used to remove
flocculated settleahle solids
i rua Step C.
Widely practiced at mills
in this subcategory. Reli-
able method of promoting
settling.
Practiced at a majority of
the mills in this subcate-
gory. Achieves more stable
effluent than numerous other
sedimentation devices.
Increased chemical
costs.
Needs considerable
maintenance.
6 months No addi-
tional apace
necessary.
15-18
months
20'x20'
(batch)
36'x36a
(continuous)
None
Can collect up
to 15 tons/day of
wet sludge.
No significant
amounts of
sludges genersted.
Sludges generated
must be disposed
of in a landfill.
The sludges may
contain amall
amounts of toxic
metals.

-------
TABU rill-2
COffTNDL AND TKEATtCNT TECHROLOGIES
ALKALIK CLEAHIHG SUBCATEGORY
PAGE 2
Treatment and/or
Control Methodi E ¦ployed
Status and
Reliability
Probleaa
and Limitations
Implemea-
tation	Land
Tiie Reguireaent»
Envi ronment al
Impact Other
Than Water
Solid Haste
Generation and
Primary
Consti tuents
E. Vacuus Filter - To devater
underflow froa Step D.
Practiced at many i
this subcategory.
tills in	Increased capital	15-18
and operating costa. Booths
10'xlO1
(batch)
20**20'
(continuous)
Dewatered sludges
require disposal.
Solids that are pro-
duced in the vacuus
filter aust be dis-
posed of in a land-
fill. The sludges
contain primarily
solids but small
amounts of toxic
metals may be
present.
U>
M
U1
Recycle - Returns a portion Practiced at a fev milla in
of the flew from Step D back
to the alkaline cleaning
process and in turn, reduces
the effluent flow (Step F
considered as a BAT and BCT
alternative).
this subcategory and exten-
sively throughout the steel
industry.
The potential exists
for scaling and
plugging due to in*
creased dissolved
solids associated with
recycle aystas.
12-15
months
20'x30'
(batch and
continuous)
Rone
Rone
G. Filtration - To further
reduce levels of solids, oils
and some metallic compounds
in flow from Step D. (Step G
used only in RSPS systems).
Used at several mills in this
subcategory and extensively
in the steel industry. Reli-
able method to reduce the
levels of solids, oils and
acme metallic compounds.
Increased capital and
operating costs.
15-18
months
25*x25*
(batch and)
continuous)
Seme solid wastes
can be generated.
Seme additional
sludges are gener-
ated when the
filters are back-
washed .

-------
TABLE VIII-3
BPT MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory:
Alkaline Cleaning
Carbon and Specialty
Batch
Model Size-TPD :
Oper. Days/Year:
Turns/Day	:
150
T5ff
C&TT Step
A
B
C
d<3>

Total
_3
Investment $ x 10
31
41
42
47
50
211
Annual Costs $ x 10~






Capi tal
1.3
1.8
1.8
2.0
2.1
9.0
Depreciation
3.1
4.1
4.2
4.7
5.0
21.1
Operation & Maintenance
Energy and Power
1.1
1.4
1.5
1.6
1.7
7.3
0.1
0.1
0.1
0.1
0.1
0.5
Chemical Costs
-
0.1
0.1
-
-
0.2
Sludge Disposal
-
-
-
-
0.1
0.1
TOTAL
5.6
7.5
7.7
8.4
9.0
38.2
Effluent Quality^^
Flow, gal/ton
Suspended Solids
Oil & Grease
Dissolved Iron
pH, Units
36 2,6-Dinitrotoluene
39 Fluoranthene
84 fyrene
114 Antimony
121	Cyanide
122	Lead
125 Selenium
128 Zinc
Raw
Waste
Level
50
500
20
0.50
9-12
0.020
0.015
0.010
0.015
0.010
0.020
0.015
0.20
Treated
Effluent
Level
50
25
10
0.50
6-9
0.020
0.010
0.010
0.015
0.010
0.020
0.015
0.20
(1)	Costs are all power unless otherwise noted.
(2)	All values are in mg/1 unless otherwise noted,
(3)	Treatment components are used in tandem.
KEY TO C&TT STEPS
A: Equalization tank with oil skimmer
B: Acid Neutralization
C: Polymer Addition
Dl Clarifier
Et Vacuum Filter
326

-------
TABLE VIII-4
HPT MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory:
Alkaline Cleaning
Carbon & Specialty
Continuous
Model Size-TPD : 1500
Oper. Days/Year: 250
Turns/Day	: 2
C&TT Step
A
B
C


Total
_3
Investment $ x 10
56
56
72
127
145
456
Annual Costs $ x 10-






Capital
2.4
2.4
3.1
5.4
6.2
19.5
Depreciation
5.6
5.6
7.2
12.7
14.5
45.6
Operation & Maintenance
Energy & Power
2.0
2.0
2.5
4.4
5.1
16.0
0.1
0.2
0.3
0.2
0.9
1.7
Chemical Costs
-
0.4
0.6
-
-
1.0
Sludge Disposal
—
•
—
—
0.6
0.6
TOTAL
10.1
10.6
13.7
22.7
27.3
84.4
Effluent Quality
Flow, gal/ton
Suspended Solids
Dissolved Iron
Oil & Grease
PH
36 2,6-Dinitrotoluene
39 Fluoranthene
84 Pyrene
114 Antimony
121	Cyanide
122	Lead
125 Selenium
128 Zinc
Raw
Waste
Level
50
500
0.50
20
9-12
0.020
0.015
0.010
0.015
0.010
0.020
0.015
0.20
Treated
Effluent
Level
50
25
0.50
10
6-9
0.020
0.015
0.010
0.015
0.010
0.020
0.015
0.20
(1)	Costs are all power unless otherwise noted.
(2)	All values are in mg/1 unless otherwise noted.
(3)	Treatment components are used in tandea.
KEY TO C&TT STEPS
A: Equalization tank with oil skinner	D: Clarifier
B: Acid Neutralization	E: Vacuum Filter
C: Polymer Addition
327

-------
TABLE VII1-5
BPT CAPITAL COST TABULATION
_o
Subcategory: Alkaline Cleaning	Basis: 7/1/78 Dollars x 10
: Carbon & Specialty	: Facilities in Place of 1/1/78
: Batch
C&TT Step
l*>
to
00
Plant
Code
006ON
0068
0112C
0112F
01121
02A0B
0240C
0248C
0384A
0460D
04600
046OH
0476A
0492A
0548
0548A
0548B
0580A
0580G
0636
0728
07760
0856N
0856Q
0916A
TPD
10
40
NA
2
354
399
102
13
858
55
19
42
NA
474
23
15
56
4
12
NA
75
NA
3
35
NA
6
14
2
52
56
25
7
88
17
9
14
62
10
8
17
4
7
20
3
13
8
19
3
69
74
33
9
117
22
12
19
82
11
12
23
5
9
27
4
17
8
19
3
70
76
33
10
120
23
12
20
84
14
11
23
5
9
28
4
18
9
21
4
79
85
37
11
134
26
14
22
94
15
12
26
5
10
31
4
20
E
10
23
4
84
90
40
12
142
27
14
23
100
16
13
28
6
11
33
5
21
In Place Required Total
14
0
0
200
215
0
42
342
98
26
0
0
42
22
0
5
0
0
33
27
96
16
154
166
168
7
259
17
35
98
422
26
32
117
20
46
139
20
56
41
96
16
354
381
168
49
601
115
61
98
422
68
54
117
25
46
139
20
89
*1039
*1921
*2960

-------
TABLE VIII-5
BPT CAPITAL COST TABULATION
PAGE 2
MA: Not Available
*: Totals do not include confidential plants.
MOTE: Underlined costs represent facilities in place.
KEY TO C6TT STEPS
A:
B:
C:
Equalisation, with Oil Skimer
Acid Neutralisation
Polyaer Addition
D: Clarifier
E: Vacuus Filter

-------
TABLE VII1-6
BPT CAPITAL COST TABULATION

Subcategory:
Alkaline Cleaning
Basis:
7/1/78 Dollars
x 10~3




:
Carbon & Specialty
:
Facilities in
Place of 1/1/78




•
•
Continuous










C&TT Step





Plant









Code
TPD
A
B
C
D
E
In Place
Required
Total
006OD
345
23
23
30
53
60
83
106
189
0068
104
11
11
15
26
29
0
92
92
0112A
5790
126
126
162
286
326
1026
0
1026
0112D
2770
81
81
104
184
210
450
210
660
01121
77
9
9
12
21
24
18
57
75
0176
73
9
9
12
21
24
66
9
75
0256D
89
10
10
13
23
27
0
83
83
0432A
2200
70
70
91
160
182
573
0
573
0432K
95
11
11
14
24
28
35
53
88
0448A
2565
77
77
99
175
200
175
453
628
0528
93
11
11
14
24
27
22
65
87
0580
61
8
8
11
19
21
19
48
67
0580A
4
1.6
1.6
2.1
3.
6 4.1
1.6
11
13
0580B
45
6.8
6.8
8.9
15
18
0
56
56
0580D
45
6.8
6.8
8.9
15
18
31
25
56
0580E
30
5.4
5.4
6.9
12
14
5.4
38
43
0580G
12
3.1
3.1
4.0
7.
0 8.0
0
25
25
0584E
1005
44
44
57
100
114
245
114
359
0584F
4754
112
112
144
254
290
0
912
912
0684C
1011
44
44
57
100
114
44
315
359
0760
65
8.5
T.5
11
19
22
0
69
69
0856D
2901
83
83
107
189
215
190
487
677
0856E
578
32
32
41
72
82
0
259
259
0856F
882
41
41
52
92
105
226
105
331
0856Q
38
6.2
6.2
7.9
14
16
20
30
50

-------
TABLE VIII-6
BFT CAPITAL ODST TABULATION
PACE 2
Plant
Code
TPP
A
B
c
D
0860B
7292
145
145
186
328
0864 B
4239
155
TO
ra
137
0866A
4052
157
157
ITT
I3T
0920G
2125
69
"59
"19
T5T
0920L
243
19
n
15
"53
09200
240
19
n
15
51
0948F
82
"9.8
"9.8
13
22
*3 Totals do not include confidential plants.
NOTE: Underlined costs represent facilities in place.
KEY TO C4TT STEPS
A: Equalisation Tank with Oil ftiaer
B: Acid Heutralisation
Cs Poljser Addition
E	In Place
374
804
270
579
263
464
179
315
49
86
48
38
25
0

*5516
Required
Total
374
1178
270
849
365
829
248
563
68
154
114
152
80
80
*5141
*10,657
D: Clarifier
E: Vacuua Filter

-------
TABLE VIII-7
BAT MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory
Alkaline Cleaning
Carbon & Specialty
Batch
Model Size-TPD
Oper. Days/Year
Turns/Day
150
250
2
C&TT Step
.-3
,-3
Investment $xlO
Annual Costs $xl0
Capi tal
Depreciation
Operation & Maintenance
Energy & Power
Chemical Costs
Sludge Disposal
TOTAL
45.8
2.0
4.6
1.6
0.8
9.0
Total
45.8
2.0
4.6
1.6
0.8
9.0
(2)
Effluent Quality
Flow, gal/ton
Suspended Solids
Oil & Grease
Dissolved Iron
pH, units
36	2,6-Dinitrotoluene
39	Fluoranthene
84	Pyrene
114	Antimony
121	Cyanide
122	Lead
125 Selenium
128 Zinc
BAT
Feed
Level
50
25
10
0.50
6-9
0.020
0.015
0.010
0.015
0.010
0.020
0.015
0.20
BAT
Effluent
Level
5
25
10
0.50
6-9
0.020
0.015
0.010
0.015
0.010
0.020
0.015
0.20
(1)	Costs are all power unless otherwise noted.
(2)	All values are in mg/1 unless otherwise noted.
KEYS TO C&TT STEPS
F: Recycle
332

-------
TABLE VII1-8
BAT MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory:
Alkaline Cleaning
Carbon & Specialty
Continuous
Model Size-TPD
Oper. Days/Year
Turns/Day
1500
250
-3
C&TT Step
Investment $xl0
Annual Costs $xl0
Capital
-3
Depreciation
Operation & Maintenance
Energy & Power
Chemical Costs
Sludge Disposal
114.8
4.9
11.5
4.0
0.2
TOTAL
20.6
Total
114.8
4.9
11.5
4.0
0.2
20.6
Effluent Quality
(2)
Flow, gal/ton
Suspended Solids
Oil & Grease
Dissolved Iron
pH, units
36	2,6-Dinitrotoluene
39	Fluoranthene
84	Pyrene
114	Antimony
121	Cyanide
122	Lead
125	Selenium
128	Zinc
BAT
Feed
Level
50
25
10
0.50
6-9
0.020
0.015
0.010
0.015
0.010
0.020
0.015
0.20
BAT
Effluent
Level
5
25
10
0.50
6-9
0.020
0.015
0.010
0.015
0.010
0.020
0.015
0.20
(1)	Costs are all power unless otherwise noted.
(2)	All values are in mg/1 unless otherwise noted.
KEYS TO C&TT STEPS
F: Recycle
333

-------
TABLE VIII-9
CONSTIX)RED BCT MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory
Alkaline Cleaning
Carbon & Specialty
Batch
Model Size-TPD
Oper. Days/Year
Turns/Day
150
250
2
C&TT Step
.-3
,-3
Investment $xl0
Annual Costs $xl0
Capital
Depreciation
Operation & Maintenance
Energy & Power
Chemical Costs
Sludge Disposal
TOTAL
45.8
2.0
4.6
1.6
0.8
9.0
Total
45.8
2.0
4.6
1.6
0.8
9.0
Effluent Quality
(2)
Flow, gal/ton
Suspended Solids
Oil & Grease
Dissolved Iron
pH, units
36	2,6-Dinitrotoluene
39	Fluoranthene
84	Pyrene
114	Antimony
121	Cyanide
122	Lead
125	Selenium
128	Zinc
BCT
Feed
Level
50
25
10
0.50
6-9
0.020
0.015
0.010
0.015
0.010
0.020
0.015
0.20
BCT
Effluent
Level
5
25
10
0.50
6-9
0.020
0.015
0.010
0.015
0.010
0.020
0.015
0.20
(1)	Costs are all power unless otherwise noted.
(2)	All values are in mg/1 unless otherwise noted.
KEYS TO C&TT STEPS
F: Recycle
334

-------
TABLE VIII-10
CONSIDERED BCT MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory: Alkaline Cleaning
: Carbon & Specialty
: Continuous
Model Size-TPD
Oper. Days/Year
Turns/Day
1500
250
C&TT Step
,-3
-3
Investment $xl0
Annual Costs $xl0
Capital
Depreciation
Operation & Ma^i^enance
Energy & Power
Chemical Costs
Sludge Disposal
TOTAL
114.8
4.9
11.5
4.0
0.2
20.6
Total
114.8
4.9
11.5
4.0
0.2
20.6
Effluent Quality
(2)
Flow, gal/ton
Suspended Solids
Oil & Grease
Dissolved Iron
pH, units
36	2,6-Dinitrotoluene
39	Fluoranthene
84	Pyrene
114	Antimony
121	Cyanide
122	Lead
125 Selenium
128 Zinc
BCT
Feed
Level
50
25
10
0.50
6-9
0.020
0.015
0.010
0.015
0.010
0.020
0.015
0.20
BCT
Effluent
Level
5
25
10
0.50
6-9
0.020
0.015
0.010
0.015
0.010
0.020
0.015
0.20
(1)	Costs are all power unless otherwise noted.
(2)	All values are in mg/1 unless otherwise noted.
KEYS TO C&TT STEPS
F: Recycle
335

-------
TABLE VIII-11
RESULTS OF THE BCT COST TEST
ALKALINE CLEANING SUBCATEGORY
BATCH OPERATIONS
A.	BCT Feed
Effluent concentration of conventional pollutants = 35mg/l
Flow = 0.0075 MGD
Days/Year = 250
lbs/year of conventional pollutants discharged = 547
B.	BCT Alternative
Effluent concentration of conventional pollutants = 35mg/l
Flow = 0.00075
Days/Year = 250
lbs/year of conventional pollutants discharged = 55
lbs/year of conventional pollutants removed via BCT treatment
(BCT Feed - BCT Alternative) = 547 - 55 ¦ 492
Annual Cost of BCT » $9,000
$/lb = 9000/492 = 18.3 FAILS
336

-------
TABLE VIII-12
RESULTS OF THE BCT COST TEST
ALKALINE CLEANING SUBCATEGORY
CONTINUOUS OPERATIONS
A.	BCT Feed
Effluent concentration of conventional pollutants ¦ 35og/l
Flow - 0.075 MGD
Days/year "250
lbs/year of conventional pollutants discharged - 5473
B.	BCT Alternative
Effluent concentration of conventional pollutant ¦ 35mg/l
Flow ¦ 0.0075 MGD
Days/year ¦ 250
lbs/year of conventional pollutants discharged « 547
lbs/year of conventional pollutants removed via BCT treatment
(BCT Feed - BCT Alternative) - 5473 - 547 - 4926
Annual Cost of BCT ¦ $20,600
$/lb - 20600/4926 - 4.2	FAILS
337

-------
TABLE VIII-13
NSPS MODEL
COST DATA:
BASIS 7/1/78 DOLLARS


Subcategory:
Alkaline Cleaning

Model
Size-TPD :
150


Carbon
& Specialty

Oper.
Days/Year:
25U


Batch


Turns/Day :
2

C&TT Steps
A
B
C
_d<2)
_E<»
G
Total
_3
Investment $ x 10
31
41
55
7
50
53
237
Annual Cost $ x 10







Capi tal
1.3
1.8
2.4
0.3
2.1
2.3
10.2
Depreciation
3.1
4.1
5.5
0.7
5.0
5.3
23.7
Operation & Maintenance
1.1
1.4
1.9
0.3
1.7
1.8
8.3
Energy & Power
0.1
0.1
0.1
-
0.1
0.1
0.5
Chemical Costs
-
0.1
0.1
-
-
-
0.2
Sludge Disposal
-
-
-
-
0.2
-
0.2
TOTAL
5.6
7.5
10.0
1.3
9.1
9.5
43.1
( 3)
Effluent Quality
Flow, gal/ton
Suspended Solids
Oil & Grease
Dissolved Iron
pH, Units
36 2,6-Dinitrotoluene
39 Fluoranthene
84 Pyrene
114 Antimony
121	Cyanide
122	Lead
125 Selenium
128 Zinc
NSPS
Feed
Level
50
500
20
0.50
9-12
0.020
0.015
0.010
0.015
0.010
0.020
0.015
0.20
NSPS
Effluent
Level
50
15
5.0
0.50
6-9
0.020
0.015
0.010
0.015
0.010
0.020
0.015
0.10
(1)	Costs are all power unless otherwise noted.
(2)	Treatment components are used in tandem.
(3)	All values are in mg/1 unless otherwise noted,
KEY TO C&TT STEPS
A: Equalization tank with oil skimmer
B: Acid Neutralization
C: Polymer Addition
D: Settling Basin
E: Vacuum Filter
G: Filtration
338

-------
TABLE VIII-14
NSPS MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory:
Alkaline Cleaning

Model
Size-TPD :
1500

•
•
Carbon &
Speci al ty

Oper.
Days/Year:


•
•
Continuous

Turns/Day :
2

C&TT Steps
A
B
C
D<"
e(2)
G
Total
-3
Investment $ x 10
56
56
72
35
145
189
553
Annual Cost $ x 10







Capital
2.4
2.4
3.1
1.5
6.2
8.1
23.7
Depreciation
5.6
5.6
7.2
3.5
14.5
18.9
55.3
Operation & Maintenance
2.0
2.0
2.5
1.2
5.1
6.6
19.4
Energy & Power
0.1
0.2
0.3
-
0.9
1.6
3.1
Chemical Costs
-
0.4
0.6
-
-
-
1.0
Sludge Disposal
-
-
—
-
0.6
—
0.6
TOTAL
10.1
10.6
13.7
6.2
27.3
35.2
103.1
(3)
Effluent Quality
Flow, gal/ton
Suspended Solids
Oil & Grease
Dissolved Iron
pH, Units
36 2,6-Dinitrotoluene
39 Fluoranthene
84 Pyrene
114 Antimony
121	Cyanide
122	Lead
125 Selenium
128 Zinc
NSPS
Feed
Level
50
500
20
0.50
9-12
0.020
0.015
0.010
0.015
0.010
0.020
0.015
0.20
NSPS
Effluent
Level
50
15
5.0
0.50
6-9
0.020
0.015
0.010
0.015
0.010
0.020
0.015
0.10
(1)	Costs are all power unless otherwise noted.
(2)	Treatment components are used in tandem.
(3)	All values are in mg/1 unless otherwise noted.
KEY TO C&TT STEPS
A: Equalization tank with oil skinner
B: Acid Neutralization
C: Polymer Addition
D: Settling Basin
E: Vacuum Filter
G: Filtration
339

-------
ALKALINE CLEANING SUBCATEGORY
SECTION IX
EFFLUENT QUALITY ATTAINABLE
THROUGH THE APPLICATION OF THE BEST
PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE
Introduction
The Best Practicable Control Technology Currently Available (BPT)
limitations were originally promulgated in March 1976.1 Since that
time, the Agency has further studied alkaline cleaning operations and
believes that the originally promulgated limitations are
substantiated. Two of the sampled plants have demonstrated the
ability to achieve the previous limitations. Dissolved iron,
dissolved nickel, and dissolved chromium were originally limited at
BPT. During the toxic pollutant survey, the Agency did not find these
pollutants at treatable levels aside from recycle of wastewaters.
Accordingly, the Agency is not proposing limitations for those
pollutants. A review of the treatment processes and proposed effluent
limitations for the alkaline cleaning subcategory follows.
Identification of BPT
The BPT model treatment system for the originally promulgated
limitations employed the following wastewater treatment steps:
equalization; oil skimming; neutralization with acid; addition of a
polymer followed by sedimentation in a flocculation-clarifier. The
sludges generated in this system are dewatered in vacuum filters. The
Agency believes that this treatment system is still appropriate as the
model treatment system for the proposed BPT limitations. Figure IX—1
depicts the above mentioned treatment system. The proposed BPT
limitations do not require the installation of the model treatment
system; any treatment system which achieves the proposed limitations
is acceptable.
The proposed BPT limitations, which represent 30-day average values,
are presented below.
kq/kkq (lbs/1000 lbs) of Product
Total Suspended Solids	0.0052
pH (Units)	6.0-9.0
*EPA 440/1-76/048-b, Development Document for Interim . Final Effluent
Limitations Guidelines and Proposed New Source Performance Standards
for the Forming, Finishing and Specialty Steel Segment of the Iron and
Steel Manufacturing Point Source Category.
341

-------
The maximum daily effluent limitation for TSS is three times the
average value presented above.
Rationale for BPT
Treatment System
As noted in Section VII, each of the BPT model treatment system
components are in use at a number of alkaline cleaning operations.
Justification of BPT Limitations
Table IX—1 presents sampled plant effluent data which support the
proposed BPT limitations. Two of the three sampled plants achieved
the proposed limitations. With additional sedimentation or
filtration, the other plant (157) could also meet the proposed BPT
limitations.
342

-------
TABLE IX-1
JUSTIFICATION OF BPT EFFLUENT LIMITATIONS
ALKALINE CLEANING SUBCATEGORY*
Proposed BPT
Effluent Limitations
Actual BPT Loads
152(0176-01)
156(01121-04)
Effluent Limitations (kg/kkg)
TSS
0.0052
D. Chromium D. Iron D. Nickel pH
NL
0.00048 Neg.
0.00028 0.0000084
NL
NL
6-9
C&TT
Components
E, SS,NA,
FLP,CL,VF
0.0000012 0.000012 7.2-7.9 E,NC,NW,
FLP,CL,VF
0.000013 0.0000056 7.3-7.7 E,NW,NL,
T.FDS
* The original BPT load was only for continuous plants. The proposed effluent limitations
now apply to both batch and continuous plants.
NL : No limit is being proposed.
Neg: Less than 0.000001
343

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[ACID I
POLYMER
THICKENER
Susp. Susp. 2 5 mg/l
pH	6" 9
Flow= 208 l/kkg (50 gal/ion)
VACUUM
FILTER
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
ALKALINE CLEANING
BPT MODEL
OWN. 6/KV0O
FIGURE TKr I

-------
ALKALINE CLEANING SUBCATEGORY
SECTION X
EFFLUENT QUALITY ATTAINABLE THROUGH THE
APPLICATION OF THE BEST AVAILABLE
TECHNOLOGY ECONOMICALLY ACHIEVABLE
Introduction
As pointed out earlier in this report, aside from recycle, the toxic
metals contained in alkaline cleaning process wastewaters are not
treatable. Accordingly, the Agency considered a BAT model treatment
system which incorporates 90% recycle. However, because it is unaware
of any discharger which recycles its wastewaters directly, the Agency
is not proposing BAT limitations based on that system. The Agency
believes that direct recycle or cascade rinsing of treated alkaline
cleaning rinsewaters may be possible. The Agency is soliciting
comments on flow reduction of the BPT effluent by recycle or other
means from alkaline cleaning operations. Depending upon comments
received and other information the Agency may obtain, the Agency may
decide to promulgate BAT limitations based upon the model treatment
system described below.
Development of BAT
The BAT model treatment system is a recycle system which reduces the
BPT flow of 50 GPT to 5 GPT (90% recycle). Figure X-l illustrates the
BAT model treatment system.
The BAT limitations associated with that system, although not
proposed, which represent 30-day average values are presented below.
ko/kkg (lbs/1000 lbs) of Product
Total Suspended Solids	0.00052
pH (units)	6.0-9.0
345

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u>
ir>
RECYCLE TO PROCESS (90%)
POLYMER
THICKENER
Susp. solids
PH
Flow
25 mg/l
6-9
5 gal/ton
BAT ALTERNATIVE
OIL
VACUUM
FILTER
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
ALKALINE CLEANING
BAT MODEL
Dwn-12/5/BO
FIGURE X-l

-------
ALKALINE CLEANING SUBCATEGORY
SECTION XI
BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY (BCT)
Introduction
The 1977 Amendments added Section 301(b)(4)(E) to the Act,
establishing "best conventional pollutant control technology" (BCT)
for discharges of conventional pollutants from existing industrial
point sources. Conventional pollutants are those defined in Section
304(b)(4) - BOD, TSS, fecal coliform, and pH - and any additional
pollutants defined by the Administrator as "conventional." On July
28, 1978, EPA proposed that COD, oil and grease, and phosphorus be
added to the conventional pollutant list (43 Fed. Reg. 32857). Only
oil and grease was added.
BCT is not an additional limitation, but replaces BAT for the control
of conventional pollutants. BCT requires that limitations for
conventional pollutants be assessed in light of a new
"cost-reasonableness" test, which involves a comparison of the cost
and level of reduction of conventional pollutants from the discharge
of POTWs to the cost and level of reduction of such pollutants from a
class or category of industrial sources. As part of its review of BAT
for certain "secondary" industries, EPA proposed methodology for this
cost test. (See 43 Fed. Reg. 37570, August 23, 1978).
Development of BCT
The Agency is currently considering a recycle system as a possible BCT
alternative. This recycle system would reduce the BPT flow of 50 GPT
to 5 GPT (90% recycle). Figure XI-1 illustrates the BCT model
treatment system.
The reference POTW treatment cost for conventional pollutants is
$1.34/lb. The results of the BCT Cost Test are presented in Table
VI11-11 and VI11-12. A summary is presented below.
Mill Type	BCT Cost Test Results
Batch	$18.30/lb
Continuous	$ 4.20/lb
As can be seen above, the reference POTW treatment cost of $1.34/lb is
exceeded for both batch and continuous operations. Thus, the BCT Cost
Test fails in both cases. Based on the BCT Cost Test results, the
proposed BCT limitations are the same as the proposed BPT limitations
for the alkaline cleaning subcategory.
347

-------
u>
«>
CO
RECYCLE TO PROCESS (90%)
POLYMER
THICKENER
Susp. solids
25 mg/l
6-9
5 gal/ton
Flow
BCT ALTERNATIVE
OIL
VACUUM
FILTER
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
ALKALINE CLEANING
BCT MODEL
Dwn. 9/1/79
FIGURE XI "I

-------
ALKALINE CLEANING SUBCATEGORY
SECTION XII
EFFLUENT QUALITY ATTAINABLE THROUGH THE
APPLICATION OF NEW SOURCE PERFORMANCE STANDARDS
Introduction
A new source is defined as any source constructed after the proposal
of new source performance standards (NSPS). The degree of effluent
reduction achievable through the application of the best available
demonstrated control technology (BADCT), processes, operating methods,
or other alternatives, including, where practicable, a standard
permitting no discharge of pollutants. At this time, however, zero
discharge is not a feasible treatment alternative for the alkaline
cleaning subcategory. As discussed in Section VII, except for
evaporative systems, there are no technologies which could be applied
to all operations in this subcategory to attain zero discharge of
process wastewater pollutants. An evaporative system is extremely
costly and is not a demonstrated means of attaining zero discharge in
this subcategory.
Identification of NSPS
The Agency has selected the NSPS model treatment system based on the
best treatment components demonstrated in the alkaline cleaning
subcategory. This system is similar to the BPT model treatment
system, however, it employs filtration instead of clarification as its
primary solids and metals removal component. The NSPS system treats a
reduced flow in an equalization tank equipped with an oil separator.
After equalization, acid and polymer are added in mixing tanks.
Following chemical addition, preliminary sedimentation is carried out
in a settling tank where accumulated solids can be drawn off and dried
in vacuum filters. After sedimentation, filtration is carried out to
further reduce the concentration of the pollutants in the effluent.
This NSPS treatment system is depicted in Figure XII—1. The
corresponding effluent standards for NSPS are presented in Table
XII-1.
Rationale for the Selection of NSPS
The NSPS model treatment system employs those components that achieve
the most significant removal of toxic and conventional pollutants at a
reasonable cost. The Agency considered various other NSPS alternative
treatment systems including those that achieved zero discharge.
However, these systems were generally too costly. The rationale for
the NSPS model treatment system selected, and the flow and effluent
concentrations is set out below.
349

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Treatment Scheme
The NSPS model treatment system employs standard chemical addition,
sedimentation and filtration equipment. All proposed treatment
components are well demonstrated in this and other steel industry
subcategories. Equalization is used to reduce fluctuations in flow
and pollutant concentrations so that subsequent treatment components
will operate more effectively. Oil skimming is provided to reduce any
floating oils that may be present in the wastewaters. Acid is added
in a reaction tank to neutralize the pH of the incoming wastewater to
within the required range of 6.0 to 9.0. The neutralization step is
followed by polymer addition. Polymer is added to aid solids and
metals removal. The polymer addition is carried out in a mixing tank
to provide proper contact between the solids and the polymer.
After chemical addition, the wastewaters undergo preliminary settling
prior to filtration. A settling basin is used in the model since this
unit will reduce solids to a level which will not interfere with the
filtration equipment. Clarifiers or thickeners could also be used,
however, these units normally cost more. Following sedimentation the
wastewater is filtered to remove the remaining particulate matter and
oils. Filtration was chosen as a final step because it is
demonstrated in the steel industry and because it is effective at
reducing the levels of solids, oils, and metals. The filtration unit
costed for this study has been a multi-media pressure filtration unit
since this is the type of equipment most often used in the steel
industry. However, numerous types of filtration units can effectively
be used to treat alkaline cleaning wastewaters.
Flows
Batch and Continuous Operations
Proposed Flow Rate: 50 gal/ton
A model discharge flow of 50 gal/ton for both batch and continuous
operations is the basis for the proposed NSPS. This flow has been
demonstrated at numerous batch and continuous operations. Six batch
operations (approximately 23% of the batch operations submitting flow
data) and nine continuous operations (approximately 10% of the
continuous operation submitting flow data) have shown the ability to
achieve the model 50 gal/ton flow.
Pollutants
The Agency selected the following pollutants for which NSPS standards
are being proposed: total suspended solids, oil and grease, and pH.
Suspended solids is an important pollutant since solids can be
generated in significant levels in the alkaline cleaning process. Oil
and grease was added to the list so that any oils removed from the
product in the process can be controlled. Also, oils and greases are
limited in numerous Phase II operations. Therefore, the addition of
oil and grease to the list of pollutants limited will facilitate the
development of combined limitations for central treatment systems.
350

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Finally, pH is limited to insure that the wastewaters are properly
neutralized.
Effluent Concentrations
The proposed NSPS are set out in Table XII—1. These standards are
based upon the filtration system used in the NSPS model treatment
system. The rationale for selecting these levels is detailed in
Volume I under the discussion of filtration systems.
351

-------
Discharge Flow
(Gal/Ton)
Total Suspended
Solids
Oil & Grease
pH, Units
TABLE XII-1
NEW SOURCE PERFORMANCE STANDARDS
ALKALINE CLEANING SUBCATEGORY
	Batch & Continuous Operations
Effluent
Concentration	Standards
Basis (mg/1)	(kg/kkg of Product)
50
Ave.	15	0.0031
Max.	40	0.0083
Ave.
Max.	10	0.0021
Within the range of 6.0 to 9.0
352

-------
POLYMER
SETTLING
BASIN
Susp. mMs 15 mg/l
0(18 grsass S mg/l
pH	6-9
Flow- 206 l/kkfl (50 gol/ton)
Suapi solids 1250-2500 mg/l
Oil a
pH	9-12
low- 208 lAkg (50gal/ton)
20 mg/l
Air
OIL
ACID
VACUUM
FILTER
FILTERS
SOLIDS
TO
DISPOSAL
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUOY
ALKALINE CLEANING
NSPS MODEL
>¦*¦.9/1/79
FIGURE -XH-1

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ALKALINE CLEANING SUBCATEGORY
SECTION XIII
PRETREATMENT STANDARDS FOR
DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS
Introduction
This section discusses the alternative control and treatment systems
available to alkaline cleaning operations which discharge wastewaters
to publicly owned treatment works (POTWs). Separate consideration is
given to pretreatment of alkaline cleaning wastewaters for new sources
(PSNS) and existing sources (PSES). The Agency is not proposing
treatment standards for alkaline cleaning operations. Instead, the
General Pretreatment Regulations, 40 CFR Part 403, will apply. The
general pretreatment and categorical pretreatment standards applying
to alkaline cleaning operations are discussed below.
General Pretreatment Standards
For detailed information on Pretreatment Standards, refer to 43 FR
27736-27773, "General Pretreatment Regulations for Existing and New
Sources of Pollution," (June 26, 1978). In particular, 40 CFR Part
403 describes national standards (prohibited discharges and
categorical standards), revision of categorical standards, and POTW
pretreatment programs.
In establishing pretreatment standards for alkaline cleaning
operations, the Agency gave primary consideration to the objectives
and requirements of the General Pretreatment Regulations. The General
Pretreatment Regulations set forth general discharge prohibitions that
apply to all non-domestic users of a POTW to prevent pass-through of
pollutants, interference with the operation of a POTW, and municipal
sludge contamination. The regulations also establish administrative
mechanisms to ensure application and enforcement of prohibited
discharge limits and categorical pretreatment standards. In addition,
the Regulations contain provisions relating directly to the
determination of and reporting on Pretreatment Standards.
355

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HOT COATING SUBCATEGORY
SECTION I
PREFACE
The USEPA is proposing effluent limitations guidelines and standards
for the iron and steel industry. The proposed regulation contains
effluent limitations guidelines for best practicable control
technology currently available (BPT), best conventional pollutant
control technology (BCT), and best available technology economically
achievable (BAT) as well as pretreatment standards for new and
existing sources (PSNS and PSES) and new source performance standards
(NSPS), under Sections 301, 304, 306, 307 and 501 of the Clean Water
Act.
This part of the Development Document highlights the technical aspects
of EPA's study of the Hot Coating Subcategory of the Iron and Steel
Industry. Volume I of the Development Document discusses issues
pertaining to the industry in general, while other volumes relate to
the remaining subcategories of the industry.
357

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HOT COATING SUBCATEGORY
SECTION II
CONCLUSIONS
This subcategory report of the Development Document highlights the
technical aspects of EPA's study of the Hot Coating Subcategory of the
Iron and Steel Manufacturing Category. This subcategory includes the
hot dipped coating operations previously designated as the Hot Coating
- Galvanizing and Hot Coating - Terne subcategories, and adds another
subdivision for Hot Coating - Other Metals.
Based upon this current study and a review of previous studies, the
Agency has reached the following conclusions.
1.	The Agency is retaining the previous subdivision of this
subcategory based on differences in coating metal, and on
additional process water requirements for the use of fume
scrubbers. This subdivision provides for limitations of
different groups of metal pollutants, and provides additional
flow allowances where appropriate.
2.	The originally promulgated limitations covered galvanizing and
terne-coating operations only. This proposed regulation contains
an additional third subdivision which proposes limitations for
other metallic coatings. Metals identified as part of this
subdivision include aluminum, cadmium, lead, and tin, along with
combinations of these metals or combinations with zinc. As in
the original two subdivisions, the proposed regulation provides
additional allowances for hot coating lines which have fume hood
scrubbers and for certain product requirements (see number 3
below).
3.	The Agency concluded that the previously promulgated BPT
limitations are appropriate for strip, sheet and miscellaneous
product (plate, bars, rods, pipe, tube, architectural and
structural shapes) coating lines. Accordingly, it is proposing
BPT limitations which are the same as those previously
promulgated. However, the Agency also found that the previous
limitations are not appropriate for hot coating lines producing
nails, fasteners, and wire products (wire, wire cloth, barbed
wire, chain link and other fencing), because of a demonstrated
need for higher rinsing and scrubbing flow rates on a gallon per
ton basis. To achieve those limitations, a 70-80 percent flow
reduction through recycle or cascade rinsing would be required
while the strip, sheet, and miscellaneous products lines could
achieve the previous limitations with once-through treatment.
The proposed limitations provide additional flow allowances for
certain products from galvanizing and other metal coating lines.
These allowances are based on rinsewater applied rates of 2400
gallons per ton and fume hood scrubber applied rates of 1500
gallons per ton. Since all terne coating operations coat strip
359

-------
and sheet, no additional allowances are necessary for that
subdivision.
4. The Agency's sampling and analyses of hot coating plant
wastewaters identified the presence of more than 35 toxic organic
and toxic metal pollutants. However, none of the toxic organic
pollutants were found at concentrations which can be effectively
treated other than by flow reduction. Since the BAT model
treatment systems will effectively control nearly all toxic
metals, relatively few limitations are necessary to insure the
desired load reductions for all. The list of pollutants for
which BAT limitations are proposed is standardized for all hot
coating subdivisions to include chromium, lead, and zinc.
Cadmium is also limited for lines which use cadmium as a metal
coating. All other toxic metals will be controlled to acceptable
levels by the limitations established for these indicator
pollutants. A summary of raw waste, proposed BPT and proposed
BAT effluent loadings for the Hot coating subcategory follows:
Discharge Loadings (Tons/Yr)
Raw Waste Proposed BPT Proposed BAT & BCT
Flow, MGD 34.7	34.7	7.2
TSS	2,547	1,896	233
Oil and Grease	2,037	569	77.8
Toxic Metals	3,447	335	4.6
Toxic Organics 2.3	1.2	0.1
5. Based upon facilities in place as of January 1, 1978, the Agency
estimates the following costs to the industry will result from
compliance with the proposed BPT and BAT limitations for the hot
coating subcategory.
Costs (Millions of July 1, 1978 Dollars)
	Investment Costs	 Annual
Total In Place Required Costs
BPT	64.1	28.2	35.9	12.8
BAT	11.1	3.9	7.2	3.3
6.	The Agency evaluated the "cost-reasonableness" of controlling
conventional pollutants (TSS, oils and grease, pH), and concludes
that control costs based upon the BCT model treatment system are
less than the costs experienced by publicly owned treatment works
(POTWs) for all segments of hot coating - galvanizing
subdivision, and for most of the other segments as well. For the
two segments where the cost test fails (terne coating without
scrubbers; other metal coating, wire products and fasteners with
scrubbers), the proposed BCT limitations are the same as the
proposed BPT limitations for conventional pollutants. The Agency
is proposing more stringent BCT limitations for all other
subdivisions based on the BCT model treatment systems.
7.	Proposed NSPS for all hot coating subdivisions are equal to the
proposed BAT limitations and are based upon the same model
360

-------
treatment system. Flow reduction steps are incorporated at the
beginning of treatment, and thus costs are reduced for the
remainder of the treatment system. Data for existing plants
support the proposed NSPS.
8. EPA is proposing pretreatment standards covering new and existing
sources (PSNS and PSES) which discharge wastewaters to POTWs
which are equal to the proposed BAT limitations. These standards
are designed to minimize the impact of pollutants which would
interfere with, pass through, or otherwise be incompatible with
POTW operations.
9 With regard to the remand issues, the Agency found that their
applicability to hot coating operations is limited to the
following:
a.	Impact of age on the cost and "ease of retrofit."
Age does not significantly affect either the cost or a
discharger's ability to retrofit wastewater treatment
systems to existing production facilities.
b.	The adequacy of cost estimates, especially with respect to
site-specific costs.
The Agency has found that its estimates of the cost of
installing the model treatment systems are sufficiently
generous to cover all but the most unusual site-specific
conditions. Actual investment costs were reported for
eleven different hot coating operations covering a variety
of products. Plant expenditures varied between $14,310 and
$2,958,000. The sum total for the ten plants which provided
comparable data was $4.24 million, while EPA's estimate for
those same facilities in-place was $6.64 million. Cost data
for the eleventh plant could not be used since reported
costs for this plant include operations other than hot
coating and industrial categories other than iron and steel
manufacturing. Costs provided for the plants included items
generally regarded as site-specific and where applicable,
included those expenditures made necessary because treatment
facilities had to be retrofitted to existing production
lines. Hence, the Agency concludes that its model-based
cost estimates are sufficient to cover site-specific and
retrofit costs for both separate and central treatment
systems. For more detail on cost comparisons refer to
Section VI11.
c.	Water Consumption
The impact of the proposed limitations and standards for the
hot coating subcategory upon water consumption is
insignificant. The cascade rinsing and recycle components
of the model treatment systems do not elevate the
361

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temperature of the water to the point where evaporation
becomes significant.
10.	Although wastewaters for more than three-fourths of all hot
coating lines are treated jointly with other wastewaters in
central treatment facilities, the proposed limitations and
standards are achievable by either separate or central treatment.
Most of the plants which were sampled and served as the basis for
the Agency's conclusions regarding wastewater treatability were
central treatment systems.
11.	The Agency received comments from a small segment of the industry
suggesting that limitations should be based on a load per surface
area coated basis rather than on a load per production weight
basis. Although that approach may have some merit, the Agency
understands that most hot coating lines do not keep records of
surface areas, and to base limitations upon that unit would
result in burdensome recordkeeping for the industry as a whole.
The Agency believes that any benefit to operators which might
accrue from a surface area based limitation has already been
provided by the proposed additional allowances for the wire
products and fasteners segments of hot coating. Effluent
limitations and standards are proposed on a kg of pollutants per
kkg of coated metal product (lbs per 1000 lbs) basis.
12.	The Agency found several hot coating plants without fume hood
scrubbers that achieve no discharge. Those plants are in the
following segments:
a.	Galvanizing - strip, sheet, and miscellaneous products (pipe
and tube)
b.	Galvanizing - wire products and fasteners (wire)
c.	Other coatings - strip sheet, and miscellaneous products
(strip).
The Agency is soliciting comments on whether the above segments
should be further subdivided, and, whether zero discharge
limitations at the BAT, BCT, NSPS, PSES, and PSNS levels should
be promulgated for the above product lines, based upon the
demonstrated performance of plants within this subcategory. No
additional costs beyond BPT will be required to achieve zero
discharge.
13.	Table 11 — 1 presents the treatment model flow and effluent quality
data used to develop the proposed BPT effluent limitations for
the hot coating subcategory, and Table I1-2 presents these
proposed limitations. Table I1-3 presents the treatment model
flow and effluent quality data used to develop the proposed BAT
and BCT effluent limitations and the proposed NSPS, PSES, and
PSNS for the hot coating subcategory; Table I1-4 presents these
proposed limitations and standards.
362

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TABLE II-1
BPT TREATMENT MODEL FLOWS AND EFFLUENT QUALITY
HOT COATING SUBCATEGORY
u>

U>
118
119
122
128
Pollutant
Flow, gal/ton:
Strip Sheet &
Strip Sheet &
Wire Products
Wire Products
TSS
Oil & Grease
Cadmium
Chromium,
Chromium,
Chromium,
Lead
Zinc
Tin
pH, Units
Misc. Prod. - No Scrubbers
Misc. Prod. - With Scrubbers
& Fasteners - No Scrubbers
& Fasteners - With Scrubbers
Total:
Total:
Strip Sheet & Misc. Prod.
Wire Products & Fasteners
Hexavalent
Galvanizing
600
1200
2400
3900
50
15
3.0
1.0
0.02
5.0
6.0 to 9.0
Monthly Average Concentration
(1)
Terne Coating
600
1200
NA
NA
50
15
0.5
5.0
6.0 to 9.0
Other Metal Coatings
600
1200
2400
3900
50
15
0.5
0.2
0.5
0.5
3.0
(2)
6.0 to 9.0
(1)	Concentrations are expressed as mg/1 unless otherwise noted. Maximum daily concentrations are three times the monthly
average concentrations presented above.
(2)	Only applies to operations using cadmium as the coating metal.
NA: Not Applicable. There are no terne coating lines processing wire product or fasteners.

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TABLE II-2
PROPOSED BPT EFFLUENT LIMITATIONS
HOT COATING SUBCATEGORY
Pollutant
TSS
O&G
118	Cadmium
119	Chromium, Total:
Chromium, Total:
Chromium, Hexavalent
122 Lead
128 Zinc
Tin
pH, Units
Strip, Sheet & Misc. Prod.
Wire Products & Fasteners
Monthly Average Effluent Limitations
	Ckg/kkg of Coated Product)	
(I)
Galvanizing
0.125
0.0375
0.0075
0.010
0.00005
0.0125
6.0 to 9.0
Terne Coating
0.125
0.0375
0.00125
0.0125
6.0 to 9.0
Other Metal Coatings
0.125
0.0375
0.00125
0.00050
0.00500
0.00125
0.0075
6.0 to 9.0
(2)
(1)	Maximum daily limitations are three times the monthly average limitations presented above. Stated limitations are
basic allowances for strip, sheet and miscellaneous product coating lines which do not have fume scrubbers. For other
operations, the basic limitation is multiplied by the following factors:
Operation	Factor
Strip, Sheet, & Miscellaneous Product
Coating Lines with Fume Scrubbers	2.0
Wire Product & Fastener Coating Lines -
No Fume Scrubbers	4.0
Wire Product & Fastener Coating Lines -
With Fume Scrubbers	6.5
Note that for total chromium, basic limitation already differ according to product coated. In this case, strip,
sheet & miscellaneous coating lines with scrubbers are limited to 2.0 times the basic limitation for strip, sheet &
miscellaneous coating lines as above, but wire product and fastener coating lines with scrubbers are limited to
1.63 times the basic limitation for those products.
(2)	Only applies to operations using cadmium as the coating metal.

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TABLE II-3
TREATMENT MODEL FLOWS AND EFFLUENT QUALITY
HOT COATING SUBCATEGORY
Pollutant
BAT
Monthly Average Concentration
(1)
BCT
NSPS
PSES
PSNS
W
cn
U1
Flow, gal/ton:

Strip, Sheet & Misc. Prod.
- No Scrubbers
150
150
150
150
150

Strip, Sheet & Misc. Prod.
- With Scrubbers
200
200
200
200
200

Wire Products & Fasteners
- No Scrubbers
600
600
600
600
600

Wire Products & Fasteners
- With Scrubbers
750
750 (2)
15,30,50^'
10*, 15
750
750
750

TSS

-
15
-
-

Oil & Grease
Cadmium

-
10*
-
-
118

0.1
-
0.1
0.1
0.1
119
Chromium, Total

0.1
-
0.1
0.1
0.1
122
Lead

0.1
-
0.1
0.1
0.1
128
Zinc
pH, Units

0.1
6.0 to 9.0
0.1
6.0 to 9.0
0.1
0.1
(1) Concentrations are expressed as mg/1 unless otherwise noted. Maximum daily concentrations are based upon multiplying
the monthly average concentrations presented above by the following factors:
Pollutants	Factor
TSS for lines coating with other metals, but
with no fume scrubbers	2.0
TSS for all galvanizing lines, and for terne
and other metal strip, sheet & misc. product
lines with fume scrubber	2.67
TSS and O&G for terne lines without fume scrubbers
and for other metal wire product and fastener
coating lines with scrubbers, and all cadmium,
chromium, lead and zinc	3.0

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TABLE II-3
TREATMENT MODEL FLOWS AND EFFLUENT QUALITY
HOT COATING SUBCATEGORY
PAGE 2
(2)	The TSS concentration at BCT is 15 mg/1 for all galvanizing, and for terne and other metal strip, sheet and misc.
product lines with fume scrubbers; 30 mg/1 for other metal coating lines with no fume scrubbers and 50 mg/1 for terne
lines no fume scrubbers and other metal wire product and fastener lines with fume scrubbers.
(3)	The 0&G monthly average concentration is 15 mg/1 for terne lines with no scrubbers, and for other metal wire product
and fastener coating lines with scrubbers. The maximum daily concentration (there is no monthly average concentration
for these segments) is 10 mg/1 for all galvanizing, for terne and other metal strip, sheet and misc. product coating
lines with fume scrubbers, and for other metal coating lines with no fume scrubbers.
(4)	Only applies to operations using cadmium as the coating metal.
*: As shown, daily maximum concentration only. No monthly average concentration applies.
U)
o\

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TABLE I1-4
PROPOSED EFFLUENT LIMITATIONS AND STANDARDS
HOT COATING SUBCATEGORY
118
119
122
128
Pollutant
TSS
Oil & Grease
Cadmium
Chromium, Total
Lead
Zinc
pH, Units
BAT
6.26
6.26
6.26
6.26
Monthly Average Concentration
(kg/kkg of Coated Product)
(1)
BCT
938(3)
i88o;^:
12500 (2) (3)
626^)
3750
NSPS
6.0 to 9.0
938
626*
6.26
6.26
6.26
6.26
6.0 to 9.0
PSES
6.26
6.26
6.26
6.26
PSNS
6.26
6.26
6.26
6.26
(1) Proposed limitations and standards have been multiplied by 10 to obtain the values presented in this table. The
values shown are basic allowances for strip, sheet and miscellaneous product coating lines which do not have fume
scrubbers. For other operations, the basic allowance is multiplied by the following factors:
u>

-------
TABLE II-4
PROPOSED EFFLUENT LIMITATIONS AND STANDARDS
HOT COATING SUBCATEGORY
PAGE 2
(2):	For all galvanizing, and for terne and other metal strip, sheet & miscellaneous product lines with fume scrubbers.
(3):	For all other metal coating lines with no fume scrubbers.
(4):	For terne lines with no fume scrubbers, and for other metal wire product & fastener lines with fume scrubbers.
(5):	Only applies to operations using cadmium as the coating metal.
* :	As shown, daily maximum limitation or standard only. No equivalent average monthly limitation or standard applies.
u>
CO

-------
HOT COATING SUBCATEGORY
SECTION III
INTRODUCTION
Background
The following discussion covers two of the subparts of the originally
promulgated regulation:
Subcategory T - Hot Coating - Galvanizing
Subcategory U - Hot Coating - Terne Plating
In addition, this section discusses a third process (Hot Coating -
Other Metals) for operations previously not covered by the hot coating
subcategories.
The originally promulgated limitations were primarily based upon data
obtained through field sampling at six hot coating facilities. This
present study included field sampling at two of the same plants and
five additional hot coating operations, and, in addition, an overall
review of flow and wastewater treatment components used at the hot
coating plants surveyed by basic data collection portfolios (DCPs).
Summaries of the responses to these DCPs are shown as Table III—1 for
galvanizing operations, Table III—2 for terne coating operations, and
Table 111-3 for hot coating operations which apply aluminum, cadmium,
lead, tin or combinations of these metals with zinc. These tables
identify products, coatings, ages, sizes, operating modes, applied and
discharged wastewater flows, control and treatment technologies, and
ultimate discharge mode for each hot coating production line for which
data have been received. Ninty-eight percent of the responses
contained sufficiently detailed data for use in these summaries. The
remaining lines were either inactive at the time of the request, or
were being phased out.
DCP responses were solicited from about five-sixths of the domestic
hot coating line operators representing 97 percent of the nation's hot
coating capacity. The Agency's data collection effort focused on
acquiring data from the ten largest steel companies, from selected
other companies known to have wastewater treatment systems in place,
and, from a representitive group of the smaller operators. This
approach has provided data on lines as small as 525 pounds per turn
and as large as 940 tons per turn. The largest steel corporation in
the country provided data for 28 hot coating lines varying in size
from a 1.8 ton per turn wire coating line to a 321 ton per turn
continuous strip and sheet galvanizer. The Agency is confident that
the DCP responses are representative of all hot coating operations,
including those plants not solicited for data. Following a review of
the DCP responses, detailed data collection portfolios (D-DCPs)
requesting cost data and analytical results were forwarded to nine
plants, including one plant previously sampled. Overall, field
sampling covered 14% of the plants with annual capacities equal to 17%
369

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of the estimated domestic hot coating capacity. Detailed pollutant
concentration and load data as well as cost data were sought from
plants accounting for an additional 17% of the national production
capacity, and basic data were requested for plants comprising 97% of
national capacity. Table 111-4 summarizes the data base for the
entire hot coating subcategory.
The Agency obtained both in-process and end-of-pipe samples during the
field sampling visits. Data on raw wastewater and effluent
characteristics, water use and cost information supplied for
individual plants from historical records were also obtained during
such visits. The NPDES permit application data were of limited value
for the purposes of this study since most of these data are for
outfalls serving more than one operation. Moreover, formats used for
permits frequently were deficient in one or more of the components
needed to correlate the data (e.g., daily production rates, shift
schedules for multi-line operations).
The alternative treatment systems and effluent limitations were
derived, to the maximum extent possible, from available data on the
actual performance of existing plants. Plants employing treatment
components equivalent or similar to the BPT model treatment systems
were reviewed to verify the achievabi1ity of the March 29, 1976
limitations. Additional plants were reviewed for demonstrated
technologies which, together with field sampling data, provide the
basis for various BAT, BCT, NSPS, PSES, and PSNS treatment systems.
Descriptions of Hot Coating Operations
Hot coating processes in the steel industry involve the immersion of
clean steel into baths of molten metal for the purpose of depositing a
thin layer of the metal onto the steel surfaces. The coatings provide
desired qualities, such as resistance to corrosion, safety from
contamination, or a decorative bright appearance. Finished products
retain the strength of steel while gaining the improved surface
quality of the coated metal for a fraction of the cost of products
made entirely of that metal alone.
All methods for applying protective coatings to steel products require
careful attention to proper surface preparation - the primary and most
important step in the coating process. Without proper surface
preparation, good adhesion is impossible. Surface preparation methods
vary depending on the type of coating applied and on the shape of the
surface being coated, but all methods aim at cleanliness and
uniformity of the surface. The most common methods used are acid
pickling to remove scale or rust, alkaline or solvent cleaning to
remove oils and greases, and physical desurfacing with abrasives to
eliminate surface imperfections.
The two major classes of metallic coating operations in the industry
are hot coating and cold coating. Zinc, terne, and aluminum coatings
are most often applied from molten metal baths, while tin and chromium
are usually applied electrolytically from plating solutions. For
details on cold coating operations, refer to the Development Document
for the Electroplating Industry.
370

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Hot Coating
Hot-dipped coating operations using baths of molten metal are
practiced in the steel industry as a batch-dip operation for sheet,
plate, pipe or other pre-formed products, or on a continuous basis for
coiled wire or strip and sheet as the base metal source. Mill
processes vary, depending on the coating being applied. Refer to
Figures 111 — 1, 111 — 2 and III-3 for typical process flow diagrams
covering galvanizing (zinc) coating operations, and to Figures III—4
and III—5, for terne coating and aluminizing process flow diagrams.
Aluminum is shown as an example of other metal coating, but the
diagram also applies to cadmium, lead, hot-dipped tin, and mixtures of
various metals. Also, the lines may be either batch dip or continuous
operations.
Galvanizing
The batch-dip operation normally follows hot rolling, batch annealing,
cold rolling, and pre-forming or cutting to size operations. Rolling
lubricants are removed by alkaline cleaning, and final surface
preparation is usually provided by acid pickling in stationary tubs
with slight agitation. Following pickling, residual acid and iron
salts are removed either by an alkaline dip, water rinsing, or
prolonged immersion in boiling water. The latter practice has the
added advantage of minimizing hydrogen embrittlement. Clean base
metal forms are then conveyed, manually or by moving belt, through the
flux box section of the coating pot, and immersed in the molten metal.
Coated products are withdrawn from the bath and dried by a warm air
blast, or chemically treated with ammonium chloride, sulfur dioxide,
chromate or phosphate solutions to provide special finishes and
surface characteristics. The product may then be rinsed with water
and prepared for shipment.
Continuous hot-dip galvanizing, which accounts for more than 60% of
total galvanizing production, is practiced with several arrangements
of processing steps. The simplest version starts with annealed and
tempered steel which receives a light muriatic acid (HC1) pickle and
rinse, then proceeds directly through a layer of fluxing agent to the
molten zinc bath. The coated product is dried and recoiled, or cut to
size for shipment. More elaborate continuous galvanizing lines employ
additional stages preceding and following the hot-dip step. At least
one strip galvanizer incorporates a sequence of pickling in hot
sulfuric acid; rinsing and scrubbing with brushes; a dip into a hot
alkaline cleaning solution; scrubbing in alkaline solutions; an
electrolytic hot alkaline cleaning step, rinsing and scrubbing with
brushes; a light pickle in hot sulfuric acid; rinsing and scrubbing
with brushes; a dip into a hot zinc sulfate flux bath; a hot dip into
molten zinc; dip and spray with chromate or phosphate solutions; a
final water rinse; drying with hot air; and recoiling.
Other producers use a so-called "furnace line" to condition the steel
product prior to coating with zinc. The incoming coils are very hard
following the cold reduction step unless a separate annealing step is
practiced. Furnace line operators include this step in their
continuous galvanizing sequence, as follows: cold rolled coils are
371

-------
given a hot alkaline cleaning, rinsing, and scrubbing and a light
pickling in hot acid followed by water rinses. The strip is then
placed in a controlled atmosphere heating chamber (annealing furnace)
up to 60 meters (200 ft.) in length with a series of independently
controlled heat zones to provide temperatures required for annealing,
yet sufficient cooling so that strip exits the furnace at temperatures
slightly above the molten bath temperature. A mixture of NX gas
(principally nitrogen, with controlled amounts of methane, carbon
monoxide, and carbon dioxide) and cracked ammonia is used in some
annealing furnaces to prevent oxidation and decarburization during the
annealing process. The exit end of the furnace discharges strip below
the surface of the molten zinc bath. A sinker roll submerged near the
surface of the molten zinc is used for controlling the thickness and
distribution of the coating. Forced air blasts are used to cool the
exiting strip and to help solidify the zinc coating. A dip or spray
chromate or phosphate chemical treatment may be provided at this point
to retard formation of white corrosion products on the coating. A
final rinse and drying step may also follow. Finished coated strip is
recoiled or cut to size ready for shipment.
Another type of furnace line subjects cold rolled strip to a complex
furnace gas containing hydrogen chloride. After annealing and
cooling, a light pickling in hydrochloric acid is done immediately
prior to entering the flux section of a conventional molten zinc pot.
In place of the usual exit rolls for controlling coating thickness,
flexible wipes are used to yield very thin, but extremely adherent
zinc coatings.
Terne Metal
Terne is an inexpensive, corrosion-resistant hot-dipped coating
consisting of lead and tin in a ratio typically near five or six parts
lead to one part tin. Lead alone does not alloy with iron, but does
form a cohesive solution with tin, which in turn alloys readily with
iron, although requiring higher temperatures than for tin alone. A
major portion of all terne coated material is used in the automobile
industry to manufacture gasoline tanks, with lesser amounts going into
the production of automotive mufflers, oil pans, air cleaners, and
radiator parts. Other end products made of terne metal include
roofing materials, portable fire extinguishers, and burial caskets.
As in the case of hot-dipped galvanizing processes, both batch and
continuous terne coating processes are used, although the continuous
process is used to supply by far the larger portion of the market.
Both metals used in terne coating are corrosion-resistant, as is their
combination. But since both lead and tin are cathodic to iron in most
environments, corrosion is actually accelerated if any portion of the
base metal is exposed. For this reason, terne coatings are usually
thicker than other metallic coatings. For maximum corrosion
resistance, even the thickest terne coatings benefit from painting or
other protective finishing.
The batch-dip terne coating operation normally is performed on cold
reduced, batch annealed, and temper rolled coils cut into sheets.
Oils and greases are removed by alkaline or solvent (mineral spirits)
372

-------
cleaning, and final surface preparation requires a hydrochloric acid
dip just prior to coating. Excess acid is squeezed from the sheets by
rubber rolls, and the sheets are conveyed through a flux box
containing a hot solution of zinc chloride in hydrochloric acid, or a
molten zinc chloride salt bath, to remove any residual iron oxides,
and leave a dry steel surface. The sheets are then passed downward
through a molten terne metal bath maintained at 325°C to 360°C (617°F
to 680°F), where the coating is applied, then upward through an oil
bath floating atop the terne pot. This oil tends to maintain the high
temperature long enough for oil rolls to control deposition and
coating thickness evenly over the sheet surfaces. Although most
batch-dipped terne coatings use a single unit as described above, the
wider range of coating weights sometimes makes necessary a pass
through a second molten metal bath of the same type, but including
another oil bath instead of the zinc chloride flux box prior to the
application of the second coat.'
The steel strip fed to a continuous terne coating operation receives
the same preliminary treatment as the steel processed on the batch-dip
line, except that it remains in the coil form, and the cleaning
procedure prior to pickling is most often done electrolytically. The
normal sequence is oil and grease removal in an electrolytic alkaline
unit; rinsing and scrubbing with brushes, pickling, terne coating, and
oiling by a process similar to batch dipping. After cooling, residual
oils are removed in a "branner", which consists of tandem sets of
cleaning rolls made of thousands of tightly compressed flannel discs.
Middlings from grain milling, called bran, are fed to the first set of
rolls to absorb moisture and excess oil, while the remaining rolls
distribute a light oil film evenly over the entire coated surface.
The final product is then recoiled, or cut to size for shipment as
terne coated flats. Additional detail for a terne line is illustrated
in Figure 111—4.
Aluminum
Another metallic coating applied using the hot-dip technique is
aluminum. Products made of aluminum coated steel include bright and
matte finished sheets and strip used as building materials in marine,
industrial, or other environments where a high degree of resistance to
corrosion is required. Aluminum coated wire is used for chain-link
and field fencing, barbed wire, telephone wire, and screening.
The batch coating process uses either a conventional molten metal
bath, as in zinc or terne coating, or a special cementation process
called calorizing. Thoroughly cleaned, degreased, and dried steel
products are packed in a rotating drum, along with a mixture of
aluminum powder, aluminum oxide, and ammonium chloride. As the drum
rotates inside a furnace at 940°C-955°C (1,724°C-1,751°F) a reducing
gas is passed into the drum, and the mixture is tumbled for 4-5 hours.
A cohesive solution of aluminum in iron, richest in aluminum near the
surface, forms the coating. This type of coating is especially
effective in protecting steel from oxidation at high temperatures*
hence it is used in pyrometer and superheater tubes, and in a variety
of oil refinery applications.
373

-------
The continuous aluminum coating process starts with cold rolled steel
strip or steel wire. The strip lines are usually furnace lines, with
an annealing step just prior to the hot-dip into molten aluminum. The
sequence is much the same as zinc coating on a furnace line. The cold
rolled steel coils are cleaned in a hot alkaline solution, rinsed, and
given a light pickling in hot acid, followed by a final rinse. An
annealing furnace softens the otherwise hard carbon steel, and the
coating is applied immediately following the furnace. The strip
exiting the aluminum bath is cooled, oiled if required, and recoiled
or cut to size for shipment. There is usually no chemical treatment
or final rinse following the aluminizing dip.
In making aluminum-coated wire products by the hot-dipped process,
clean, cold-drawn carbon-steel wire is passed through the molten
aluminum bath at 660°C-680°C (1,220-1,256°F). This temperature is
high enough to soften the carbon-steel wire sufficiently that an
annealing furnace is not required, but the tensile strength of the
wire is reduced, rendering it unsuited for certain applications. This
problem is readily corrected by cold-drawing the coated wire, which
not only raises the tensile strength, but also provides a very bright
final finish to the coating.
Additional detail for an aluminizing line is illustrated in Figure
II1-5.
Other Hot-Dipped Metallic Coatings
Other hot coating operations involve combinations of zinc and
aluminum, zinc and cadmium, or zinc, tin and cadmium. There are also
some wire coating operations which use molten tin, or cadmium alone as
the coating agent. However, the latter processes comprise a minor
fraction of hot-dipped coating operations. The other widely practiced
steel coating operation is done from cold solutions using electrical
current. Most tin plating production at steel plants is electrolytic,
as is all chromium plating and a limited amount of zinc coating.
These operations are regulated by guidelines applicable to the
electroplating industry.
374

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TABLE III-l
HOT COATING SUBCATEGORY - GALVANIZING SUtMARY
U>
-4
Flant

1st
Production Rate



Disch*
Code

Tear of
Tons/
Turns/
Oper.
Applied Flow (GPT)
(GI
Wo.
Product
Prod.
Turn
Day
Mode
Rinse
Scrubbers
Rinse
0060-01
Strip
1946
111
<1
C
MR
-
NR
0060-02
Strip
1960
326
2
C
NR
-
NR
0060&-01
Strip
1955
126
<1
C1
v£7C
-]

00601-02
8trip
1967
265
3
C J
AO/J
"J
SO / J
00606-01
Hire
'1940
*
*
C
*
*
*
0060G-02
Hire
1965
*
*
C
*
*
~
00606-03
Hire
1965
*
*
c
*
*
*
00606-04
Hire
1967
*
*
c
*
*
*
00606-05
Hire
1968
•
*
c
*
*
*
00606-06
Fast.
1966
*
*
B
*
*
*
00606-07
Fast.
1969
*
*
B
*
*
*
0060k
Sheet,Plate
1975
61.2
1
B
942
-
314
00608-01
Hire
'1950
*
*
C
*
*
*
00608-02
Hire
'1950
*
*
c
*
*
*
00608-03
Hire
1970
*
*
c
*
*
*
0068-01
Strip,Bar
1934
13.1
<1
B
916
-
916
0060-02
Fence
1934
34.6
<1
c
693
-
693
0068-03
Hire
1947
29.6
3
c
1103
-
(1103)
0068-04
Rails
1920
3.3
3
BC
1425
-
1425
0112A-01
Rails
1926
29 hi.
<1
B
MR
_
NR
0U2A-02
Fipe
1929
79

B
NR
-
NR
0112A-03
Sheet
1952
El 50

C
E490
-
(E464)
0112A-04
Sheet
1955
K250
2
C
E313
-
(301)
0112A-05
Hire
1926
I
I
c
I
-
I
0112A-06
Hire
1926
13
2
c
NR
2585
NR
0112B
Strip
1962
359
3
c
101
308
101
Scrubbers
i]
2585.
308
Treatment Coaponentg
Process Central
NL,AE,FLP,SS,
CL.VF
H(acid)
HH
H(acid)
CR f NL f AE) FLF y
CL,CT,VF
("E,AE,
f HL,TP
}
E , NC, NA,
SL
^ NL,AE
ScriAE fNL,SS ,
FLA,FLP,T,CY
Trt.
Mode.
OT
RUX
ReTx
ReTx
RU61;RT25
RU61;RT25
RU61;RT25
RU76;RT10
RU65;RT21
RT85
RT85
RU67
RU88
RU88
RD78
OT
OT
ReUlOO
OT
(1)
OT
OT
ReU95
ReU96
(2)
(2)
Discharge
Mode
D
D
D
0
P
P
P
P
P
P
P
NL,AE,CL,SS,FDSP OT

-------
TABLE III-l
HOT COATIHG SUBCATEGORY - GALVANIZING SUMMARY
PAGE 2		
Plant
Code
No.
0112F-01
0112F-02
Product
Hire
Wire
1st
Year of
Prod.
1955
1965
Production Rate
Tons/
Turn
6.7
3.6
Turns/
Day
1
<1
Oper.
Mode
C
C
Applied Flow (GPT)
Rinse Scrubbers
880
627
2152
4000
0112G
0112H
Fasteners
Hire
^•1930
1971
4
1.14
<1
2
NR
895
900
01121-01
01121-02
0196A-01
0196A-02
0196A-03
0196A-04
0196A-05
Fasteners
Hasher,Rod
Hire
Hire
Hire
Hire
Hire
1922
1970
1908
1908
1916
1955
1959
21.6
7.5
1
<1
NR
NR
*
*
*
*
*
0256D-01
0256D-02
0256G-01
0256G-02
0264-01
0264-02
0264-03
0264A-01
0264A-02
Strip
Strip
Pipe
Pipe
Hire
Hire
Fence
Rod
Rod
1955
1965
•T1940
^1940
1959
1963
1961
1965
1965
114
228
78.5
78.5
12.2
11.9
18.1
8.2
10.5
C
C
B
B
C
C
C
B
B
568
274
107
107
1580
1210
451
1754
1371
509
360
Dry
Dry
395
403
Dry
585
457
0264D-01
0264D-02
Hire
Hire
1966
1972
18.6
20.9
3226
2641
Dry
344
0384A-01
0384A-02
0384A-03
0384A-04
0432A
Strip
Strip
Strip
Strip
Pipe
1951
1954
1955
1968
1930
106
153
200
286
59
31.6
21.9
16.8
168
NR
Dry
814
Discharge Flow
(GPT)
Rinse
Scrubbers
747
143
533
267
NR
NR
895
-
NR
-
NR
-
*
o
*
* V
*
* r
*
* I
*

568
211
274
147
107
Dry
107
Dry
596
395
605
403
4.5
Dry
877
585
686
457
1032
Dry
574
344
31.6

21.9
-
16.8
-
168
Dry
NR
NR
Treatment Componente
Process Central
N0(3)
NC
E,NL,FLP,C1,SL
NH,NL,AE,SS,
T,FDSP,SL
NL,CL \ SS, SL
}
]
]
]
NL,FLL,FLP,
CL,VF
no(3),cl
no(3),cl
no(3),cl
PSP.SS
FLL,FLP,FLA,CL,
SSc,NL,NC,FLP,
SS,CL,T,VF
Trt.
Mode
RU71
RU83
OT
OT
ReTx
ReTx
OT
OT
OT
OT
OT
RU28
RD34
OT
OT
RU50
RU38
RU99
RU37
RU37
RU68
RU69
OT
OT
OT
OT
RUx
Discharge
Hode
P
P
P
D
D
D
D
D
D
D
D
D
D
D
D
P
P
P
P
P
P
P
D
D
D
D

-------
TABLE III-l
HOT COATING SUBCATEGORY - GALVANIZING SUMMARY
PAGE 3
Plant

1st
Code

Tear <
Ho.
Product
Prod.
0432B
Strip
1956
0432D
Sheet/Strip
1968
0448A
Sheet
1967
0460A-01
Hire
1932
0460A-02
Hire
1944
0460A-03
Hire
1932
0460A-04
Hire
1930
0460A-05
Hire
1934
0460A-06
Hire
1934
0460A-07
Hire
1934
046OA-OS
Hire
1947
0460A-09
Hire
1949
0460ft-10
Hire
1950
046OA-11
Hire
1974
046OC
Hire
1967
0460D-01
Hire
'1927
0460D-02
Hire
'1927
04601-01
Hire Cloth
1970
0460B-02
Hire
1947
.0460F-01
Hire Cloth
1965
0460P-02
Hire
1965
04606
Hire
1968
0460H-01
Hire
1925
0460H-02
Hire
1925
0476A-01
Hire
'1930
0476A-O2
Hire
'1930.
0476A-03
Pipe
1930
Production Rate
Ton*/	Turns/ Oper.
Turn	Day	Mode
180	3	C
346	3	C
212	3	C
4.0	3	C
9.7	3	C
21.6	3	C
21.6	3	C
18.2	3	C
18.2	3	C
29.9	3	C
13.3	3	C
8.3	3	C
3.3	3	C
11.7	3	C
18.6	3	C
15.1	3	C
15.1	3	C
1.8	3	C
16.5	3	C
0.34	3	C
3.1	3	C
10	3	C
1.8	2	B
1.8	2	B
3.6	2	C
5.6	3	C
60	1	B
Applied Flow (GPT)
Rinse Scrubber*
2.2
289
0.95
4560
2227
1000 316
1222
1451
1187
722
1913
1908
2327
2872 583
1080 806
993
993
1311
873
706
627
1344
507
507
2950 1609
1886 1029
56	Dry
Discharge Flow
(GPT)	 Treatment Components
Rinse Scrubbers Process Central
Trt.
Mode
Discharge
Mode
2.2
289
0.95
4200
1979
889
1111
1319
1055
642
1805
1735
2182
2667
316
FLL,FLW,T,FDSP
N0(3>
OT
OT
OT
583
RUB
RDll
RUB
RU9
RU9
PSP,AK,NL,FLP,CL, RU11
SL	RU11
RU6
RU9
RU6
RU6
5.4
ROT 9+
NR
NR
1311
873
141
125
1344
507
507
2950
1886
56
1609
1029
Dry
J
]
3
RLyFLP f CL)T|VF
FLPpHlfCLfFDSPp
CL,NA
no(3),sl
SCR,SS,NL,AKI
FLP,CL,VF
RTx
RTk
OT
OT
RT80
RT80
OT
OT
OT
OT
OT
OT
D
D
D

-------
TABLE III-l
HOT COATING SUBCATEGORY - GALVANIZING SUMMARY
PAGE 4
Co
-J
00
Plant

1st
Production Rate


Code

Year of
Tons/
Turns/
Oper.
Applied
No.
Product
Prod.
Turn
Day
Mode
Rinse
0492A
Pipe
1962
62
1
C
1355
0580A-01
Wire Cloth
1962
1.3
3
C
4615
0580A-02
Hire Cloth
1962
1.3
3
C
4615
0580G-01
Wire
J-1960
0.38
<1
C
5600
0580G-02
Wire
J'1960
0.75
<1
C
2800
0584C-01
Strip
1956
91
1
C
1688
0584C-02
Strip
1962
214
2
C
710
0584C-03
Strip
1964
161
3
C
1043
0584E-01
Sheet
1960
135
2
C
NR
0584E-02
Sheet
1970
291
3
C
NR
0584F-01
Strip
1957
207
3
C
1391
0584F-02
Strip
1958
79
1
C
3646
0584F-03
Strip
1966
187
3
C
1540
0612-01
Wire
J*1950
22.3
3
C
1510
0612-02
Wire
J"1950
22.3
3
C
1510
0612-03
Wire
'1950
22.3
3
c
1510
0612-04
Wire

-------
TABLE III-l
BOT COATIHC SUBCATEGORY - GALVANIZING SUMfARY
PACE 5 	
Plant
Code
Ho.
0684 B
06841
0684 Y
Product
Strip
Strip
1st
Year of
Prod.
1962
1958
Production Rate
Rod,Plate, 1934
Struct.
Tons/
Turn
154
171
*
Turns/
Day
3
2
*
Oper.
Mode
C
C
B
Applied Flow (GPT)
Rinse Scrubbers
2026
1951
*
312
Dry
0724A
Sheet
1952
106
O(dry)
U)
-j
ID
0728
0856D-01
0856F-01
0856F-02
0856H-01
0856H-02
0856H-03
0856P
0856S-01
0856S-02
Pipe
Sheet
Sheet
Pipe
Pipe
Pipe
Pipe
Hire
Hire
Hire
1952
1947
1968
1953
1947
1941
1908
1917
1927
1937
25
144
266
74
150
78
77
5.6
6.3
1.8
1
1
2
<1
<1
<1
<1
1
3
2
B
C
C
B
C
C
B
C
C
C
480
333
586
2270
112
214
218
15,540
0(dry)
0(dry)
Dry
189
7784
14,520
0860D-01
Sheet/Strip
1950
321
1
C
935
-
0860D-02
Sheet/Strip
1957
160
1
C
1385
-
0860D-03
Sheet/Strip
1962
109
2
C
1835
-
0860F-01
Hire
1942
23
2
C
3130
-
0860F-02
Hire
1942
12.5
1
C
5760
-
0860F-03
Hire
1942
12.5
1
C
5760
-
Discharge Flow
(GPT)	 Treatsent Components
Rinse Scrubbers Process Central
Trt.
Mode
Discharge
Hode
2026 0	H(acid) SL.SS	ReU13	D
1951 Dry	-	RH.BOAl,SL,SS	OT	D
~	-	-	E,NL,CL,FLP,FDSP OT	D
0(dry) -
-(dry
operation)
0
333
586
2270
0
0
0
15,540
0(dry)
0(dry)
935
1385
1835
157
9.6
6.4
Dry
189
0
]
H(acid)
PSP.SS
FDSP
SL,PSP,SSP,CT
NL,FLP,T,SS
RT100
OT
CR,HH,NL,FLP,CL,SS OT
GF,FLP,SL.BOAl,SS RU77
RT100
RT100
RT100
H(acid)
-(dry
operation)
-(dry
operation)
3
NL,FLP,SL
~)	~| NL,NA,PSP,T,
>	DH(acid) > VF,FDSP,CT
ReU48
OT
OT
OT
RU95.RT4.5
RU97,RT2.6
RU95.RT4.5

-------
TABLE III-l
ROT COATING SUBCATEGORY - GALVANIZING SOMMRY
FACE 6
Plant
Code
No.
Product
1st
Year of
Prod.
Production Rate
Ton*/ Turn*/
Turn Day
Oper.
Mode
Applied
Rinae
Flow (6FT)
Scrubbers
Discharge Flow
(6PT)
Rinse Scrubbers
Treatment Components
Process Central
Trt.
Mode
Discharge
Mode
0860C-01
Wire
1942
8.8
2
C
8182
_
0
1


.
RX100
Z
08606-02
Wire
1940
23.8
2
C
3025
-
0
-
PSP

-
RT100
Z
08606-03
Hire
1944
4.6
I
C
I
-
I
J


-
1
-
08641-01
Wire
1937
19.7
2
C
4386
-
4386
_
—


OT
D
0864B-02
Hire
1943
9.4
2
C
6128
-
6128
-
-

RL)M)FLLf
or
D
08648-03
Mails
1943
7.1
2
B
6761
2028
6761
0
-
»
FIP|CL|SK
RU23
D
08648-04
Sheet
1951
121
3
C
2182
-
1091
-
-


ReU50
D
08648-0S
Sheet
1963
288
2
C
325
8.3
325
8.3
-
i

OT
D
08648-06
Pipe
1966
132
<1
B
727
145
727
0
-

R017
D
0868A-01
Sheet
1948
87
3
C
182
	
(182)
_

)
at,FDSF,CL,SS,SL
ReTSS
D
0868A-02
Sheet
1952
117
3
C
135
-
(135)
-


ReT88
D
0868A-03
Sheet
1968
313
3
c
169
15.3
(169)
(15.3)

3
FLP,FLW,NL,CL,
ReT88
D












SS,SL


0868A-04
Hire
1914
12
3
c
960
-
960
-
DW(acid)

-
OT
D
0868A-05
Rail*
1914
7
2
B
2326
-
2326
-
PSP

-
OT
D
0916A-01
Pipe
1937
200
1
B
O(dry)
Dry
O(dry)
Dry
-(dry

_
_
Z










operation)



0916A-02
Pipe
1974
142
1
B
O(dry)
Dry
O(dry)
Dry
-(dry

-
-
Z










operation)



0916A-03
Coupling*
1942
4
<1
B
120
-
0
-
-

-
RU100
Z
09200-01
Pipe
1950
75
2
B
640
640
64
1
dcb een

-
RT45.RU50
D
09200-02
Pipe
1972
40
1
B
120
1620
120
0
rar osr

-
RU93
D
0920K-01
Sheet/Strip
1966
331
2
C
116
290
116
290
1 NL.FLP,

_
OT
D
0920* 02
Sheet/Strip
1955
212
2
c
136
430
136
430
f T.VF

-
OT
D
0920K-03
Sheet/Strip
1953
146
2
c
164
395
164
395
J

-
OT
D
0948A
Pipe
1922
63
2
B
7.6
Dry
7.6
Dry
-

AO,FLL,FLP,TP,VF
OT
D
0948C-01
Strip
1961
171
2
C
140
_
140
_

\
n i vi n 00
or
D
0948C-02
Strip
1964
261
3
C
92
-
92
-


rLL9rLP,T)SS
OT
D

-------
TABLE III-l
HOT COATING SUBCATEGORY - GALVANIZING SUMMARY
PACK 7				
Key to Abbreviation! and Symbols
GPT:	Gallon per ton of coated product
C s	Continuous coating operation
B :	Batch coating operation
:	Approxiaateiy
NR :	Data not reported by plant
* :	Company has requested confidential treatment of this data
D :	Direct discharge
P !	POTW
Z :	Zero
OT :	Once-through
Footnotes
(1)	Reused at HjSO^ pickler
(2)	Reused as nil service water
(3)	Neutralisation using amaunia
NOTE: For abbreviations used under "Treatment Components," see Table V1I-1
u>
CD
RU : Recycled to coating operation untreated
RT : Recycled to coating operation after treatment
ReU: Untreated wastewater reused elsewhere
ReT: Treated
I : Line is now inactive
( ): Indicates flow reused elsewhere
- : None
x : Percent unknown
For RU,RT,ReU, and ReT, number following symbol
indicates percent of flow recycled or reused.

-------
TABLE III-2
HOT COATING SUBCATEGORY - TERNE COATING SUMMARY
Plant

1st
Production Rate
Code

Year of
Tons/
Turns/
No.
Product
Prod.
Turn
Day
0060-03
Strip
1949
71
2
0060-04
Strip/Sheet
1962
103
3
0648
Strip
1968
4.5
<1
0684B-03
Strip
1957
75
3
08S6D-02
Strip/Sheet
1964
187
3
0920F
Sheet
1962
51
3
Discharge Flow
Oper.
Applied Flow (GPT)
(GPT)
Mode
Rinse
Scrubbers
Rinse
Scrubbers
C
C
E670
E466
El 16
E670
E466
El 16
C
533
Dry
533
Dry
C
640
1280
640
1280
C
2567
128
2567
128
SC
301
-
160H
141D
-
Treatment Components	Trt.	Discharge
Process Central	Mode	Mode
J NL, FLP, SS,	OT	D
) CL,VF,AE	OT	D
None	None	OT	P
H(acid) SL,SS	OT	D
SS t NL,FLP,T	OT	D
H(acid),SS -	H53Z,	D
BD47Z
Lo		
00
GPT: Gallons per ton of terne coated product
E : Estimated flow from plant DCP response
C : Continuous
SC : Semi-continuous
1 l Hauled off-site by contractor
D : Discharged directly to receiving stream
OT : Once-through
BD : Blowndovn from treatment (discharged)
P : Discharged indirectly via a publicly owned treatment works (municipal sewage treatment plant)
NOTE: For abbreviations under "Treatment Components," see Table VII-1.

-------
TABLE III-3
HOT COATING SUBCATEGORY - OTHER METAL COATING SUMMARY
Plant
Code
Ho.	Product
u>
oo
ui
0112A-07 Sheet Al/Zn 1972
1st
Coat- Year of
ing Prod.
(1)
Productioa Rate
Turn*/
Tons/
Turn
125
0112C
Hire
A1
1960
8.8
01121-03
Fasten-
A1
1955
1.2

ers



0384A-5
Strip
A1
1961
208
0460H-0 3
Mire
Sn
1925
0.7
0460H-04
Hire
Sn
1925
0.7
0460H-05
Hire
Sn
1925
0.7
0460H-06
Hire
Sn
1925
0.7
0460H-07
Hire
Sn
1964
0.7
0460B-08
Hire
Sn
1973
0.7
0460H-09
Hire
Sn
1973
0.7
0580G-03
Hire
Sn
.T1960
0.3
05806-04
Hire
Sn
•r I960
1.0
05806-05
Hire
Cd

-------
TABLE I11-3
HOT COATING SUBCATEGORY - OTHER METAL COATING SUMMARY
PAGE 2
Key to Abbreviations and Symbola
GPT: Gallons per ton of coated product
C : Continuous coating operation
B : Batch coating operation
: Approximately
MR : Data not reported by plant
OT : Once-through
Rel): Reused untreated
RU : Recycled to coating line untreated
RT " Recycled to coating line treated
D : Discharge directly
P : Discharged via POTW
Z : No discharge
: None
A1 : Aluminum
Sn : Tin
Cd : Catkiium
Zn : Zinc
u>
03 Footnotes
its. 	
(1)	Converted from galvanizing to Al/Zn in 1972; line actually built in 1956.
(2)	Reused as mill service water.
NOTE: For abbreviations under "Treatment Components," see Table VII-1.

-------
No. of
Plants
Plants sampled for
DD - 3/76
Plants sampled for
this study
Total plants sampled
Plants to receive
detailed DCP
Plants sampled and/
or solicited via
detailed DCP
Plants responding to
basic DCP
Estimated total no. of
hot coating plants in
industry
G
7 (incl.
2 above)
11
9 (inc1.
1 above)
19
66 sites*
80 sites
* Representing 174 production lines
TABLE III-4
HOT COATING DATA BASE
Z of Total
No. of Plants
7.5
8.8 (incl.
2.5 above)
13.8
11.3(incl.
1.3 above)
23.8
82.5
100.0
Annual Capacity
of Plants
In Data Base
1,128,920
1,067,300 (incl.
683,200 above)
1,513,020
1,989,260 (incl.
537,420 above)
2,964,860
8,469,560
8,725,000
% of Total
Est imated
Annual Capacity
12.9
12.2	(incl.
7.8 above)
17.3
22.8 (incl.
6.1 above)
34.0
97.1
100.0

-------
FEED TO
COATING LINE
HOT H-i SO4
AfeOUT ISt,
H,0
FMKlSE i
SCROb
fcHELATtMO, AGEUTS
\ WE.T T 1 WG> AG.E.KJTS
J ki^ OH
po^.
I M a_ S| Oj
(other SmOKJCi ALKALIES
Hot
ALKALIME. DIP
&-SOZ./GAL.
I
INTERMITTENT
DISCHARGE
HjO
T
HOT
ALKAUME.
SCROE.
HOT
ELE.C TROLYTIC
ALKHLINE CLEAN
INTERMITTENT
DISCHARGE
H.O
R.INS.E j
SCRUB
HjO
jol
AvOD PtP
IS7. H, SO4-
H,0
I
IKJTE.RMITTEMT
oischAvR.se
RIKJSE. j
SCROfe
HiO
NOT
FLUX TA.HK.
ZM SP4.
IN TERM ITT EKJT
DISCHARGE.
H^O
HOT
DIP TIMC.
DIP OR SPR.KV
CHEMICAL.
TREATMENT
C R. Oa- OR POd.
1
RIS1S EL
COOUVSiC. HtO
^NON-CONTACT)
T
-~<3AUVAM\"ZeD PRODUCT
HiO
E_K1 VI R.QKJ KA EWJTAA_ PROTECTlOU AGENCY
STEEL IWOUSTR.Y STaDV
HOT COAT IM G GALVAKJlZISiG^Z-N^
TYPE. I
PROCESS Fi-ovs/ DIAGRAM
D WS. 2 4-74-
REV. I l-H-76
Rtv.J lZS-%
figure on-1

-------
CLEANING SOLUTIONS
CAUSTIC SODA
SODIUM PHOSPHATE
SODIUM SILICATE
Chelating agents
WETTING. AGENTS
WATER
WATER
FEED TO
COATING LINE
INTERMITTENT
DISCHARGE
WATER
WATER
COOLING
WATER
COOLING
WATER
GALVANIZED
PRODUCT
COOLING
WATER
COOLING
RINSE
HOT DIP
2INC
DIP OR SPRAY
CHBOMA7E OR
PHOSPHATE
TREATMENT
HCL DIP
COOLING
WATER
(NON-CONTACT)
COOLING
WATER
(NON-CONTACT)
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATING GALVANISING (IN*)
TYPE II U.S. STEEL PROCESS
PROCESS FLOW DIAGRAM
DWG 2-6-14-
RCVI 2-IVJfc
RCV 2 2 25-74,
FIGURE 311-2

-------
Feed to
Coating Line
Cooling
Water
Cooling
Water
(Non-contact)
Cooling
Water


FURNACE
LINE




HOT DIP
Zn
Cooling
Water
(Non-contact)
Water
RINSE
DIP OR SPRAY
Cr04 OR PO4
_ GALVANIZED
PRODUCT
Water
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATING GALVANIZING (Zn)
TYPE n
PROCESS FLOW DIAGRAM
Dwn. 2/22/79
FIGURE 3E-3

-------
F ume
Feed to
Coating Line
MINERAL
SPIRITS
CLEANING
Fume
HOT DIP
Pb/Sn
TERNE
COATED
PRODUCT
Cooling
Water
(Non-contact)
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATING TERNE PLATE
PROCESS FLOW DIAGRAM
Dwn. 2/21/79
FIGURE IH-4

-------
Cooling
Water
Feed to
Coating Line*
FURNACE
LINE
Cooling
Water
(Non-contact)
Cooling
Water
A LUMINIZE
, ALUMINIZED
PRODUCT
Cooling
Water
(Non-contact)
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATING ALUMINIZING
PROCESS FLOW DIAGRAM
Own. 2/21/79
FIGURE HI-5

-------
HOT COATING SUBCATEGORY
SECTION IV
SUBCATEGORIZATION
Plants involved in forming and finishing steel assume a wide variety
of configurations, from simple layouts (e.g., a wire drawing operation
starting with purchased rod or heavy wire brought in from elsewhere)
to extremely complex (e.g., an integrated steel plant with all steel
melting, refining, forming and finishing operations at a single site).
Moreover, forming and finishing operations at any particular site may
be of one type (pipe and tubemaking, cold rolling, coating), or may be
a sequence involving many operations (primary breakdown of ingots into
slabs, rolling of slabs into coils of strip, pickling and cold
reduction of strip, cleaning and hot-dipping of strip to form a final
galvanized product). The basic subcategorization of forming and
finishing operations into subprocesses has been retained. This
section deals with coating operations only, and in particular with hot
dipped metallic coatings. Factors evaluated with respect to
subcategorization and further subdivision are discussed below.
Factors Considered in Subcategorization
Manufacturing Process and Equipment
The inherent manufacturing or production processes associated with the
production of steel products serves as a basis for defining
subcategories. The types of equipment used, and the processes
themselves, vary sufficiently to justify their separation into
different subcategories and into further subdivision within certain
subcategories.
Coating operations within the steel industry are usually performed by
.either of the following methods:
Hot Dip Process
Steel is immersed in a molten bath of the coating metal, then removed
from the bath in such a way that the coating is uniformly distributed
over the metal surface as free of discontinuities as possible. Most
zinc coatings, and all aluminum and terne (a lead/tin alloy) coatings
are applied in this manner. In the past, tin was also applied as a
hot-dipped coating, but the electrolytic tin plate process has almost
completely supplanted this practice, except for hot dip coating of
wire and wire products. Other metallic coatings which are applied by
the hot dip process include aluminum, cadmium, lead, and combinations
of these metals with each other or with zinc.
Electrolytic Process
Most tin coatings, all chromium coatings and a minor fraction of zinc
coatings are applied electrolytically. For details on this process
391

-------
and for applicable limitations refer to 40 CFR Part 413 as amended,
and to the Development Document for the Electroplating Point Source
Category.
Raw Materials
The primary raw material, carbon steel, is common to all hot coating
operations observed. However, the other different raw materials used
in hot coating processes indicated a potential need to subdivide the
hot coating subcategory by coating metal. In addition to the coating
metals, the other raw materials used include pickling acids and
rinses, cleaning solutions, fluxes and oils. Not all operations
involve all raw materials. For example, all terne coating and wire
galvanizing lines surveyed were found to be using fluxes, as were
virtually all galvanizers coating miscellaneous shapes. However,
fluxes are used in only 21% of strip and sheet galvanizing operations.
Pickling acids vary in strength and in composition. Rinsing depends
to some extent on the strength and nature of the acids, but even more
so on the shapes being coated. Such differences contribute to the
need for subdivision of hot coating operations along the lines
selected, that is, by type of metallic coating and by type of product
being coated. Further discussion follows in Sections V and VI.
Final Products
A variety of final products are made when coatings are applied to
different steel shapes. The most common hot coated products include
galvanized steel strip, sheet, pipe, tube, rods, bars, fasteners, wire
and wire products, nails, plate, couplings, and various structural
shapes. Strip and sheet may in turn be formed into useful shapes,
such as auto parts, architectural components, containers, gutters," and
channels. In some cases, certain formed shapes are redipped into
molten baths to insure that the coatings are completely covering the
base metal.
Hot coated products other than galvanized ware include terne coated
strip and sheet which is used for automobile parts, burial caskets,
fire extinguishers, steel bands and roofing materials.
Aluminum coatings are applied to steel strip and sheet for decorative
and corrosion resistant qualities. These flat products are then
formed into architectural shapes, gutters, channels, auto body
components, and other uses. Nails, bolts, nuts, fasteners, and wire
are also aluminized by hot coating processes.
Wire and wire products (chain-link fence, wire cloth) are usually
galvanized, but other hot coatings are also routinely applied, namely
tin, cadmium, aluminum, and combinations using tin, cadmium, and zinc.
Another product involving combinations of metals is strip which has
been coated with "galvalume", a combination of aluminum and zinc.
The use of such diverse coating metals to cover a variety of shapes
and sizes had led the Agency to subdivide the hot coating operations
into three major groupings - galvanizing, terne coating, and other hot
metallic coatings. For galvanizing and other coating, further
392

-------
differences occur for selected final products where appropriate, due
to differences in water application rates. These are discussed in
more detail in this section under "Process Water Usage," and in
Sections V and VI.
Wastewater Characteristics and Treatability
Wastewater characteristics and treatability are related to the coating
metal, and provide further justification for the need to subdivide hot
coating processes into galvanizing, terne coating and other metallic
coatings. Certain pollutants are generated when galvanizing is
practiced that are not generated by terne coating, and vice versa.
And the absence or presence of such pollutants determine, to a large
extent, the treatment of the wastewater prior to final treatment. For
example, hexavalent chromium from some galvanizing operations must be
reduced to the trivalent state prior to neutralization and
precipitation as the hydroxide. This requires equipment that is
unnecessary for the treatment- of terne coating or aluminizing
wastewaters. On the, other hand, the presence of lead in terne coating
effluents necessitates special precautions to prevent discharge of
that pollutant from rinses or scrubber wastewaters from terne coating
lines. These wastewater characteristics and treatability differences
support a subdivision of hot coating operations into different parts
based upon metallic coating and product coated.
Size and Age
The Agency considered the impact of size and age on the need to
further subdivide hot coating operations and found the impact to be
much less signficant than the other factors evaluated. No impact from
age of hot coating lines was found. Some of the most advanced
wastewater treatment systems treat wastewaters from old coating lines.
Very often these systems treat wastewaters from a variety of finishing
operations, old and new, at the same time. The quality
characteristics of raw wastewater and its treatability were likewise
found to be unaffected by the age of a given hot coating line. Data
for those plants responding to data collection portfolios (DCPs) were
plotted showing applied flow versus the year of installation of the
oldest active hot coating operation on-site and is shown in Figure
IV-1. No correlation was found between age and process flows. Plants
of all "ages" appear to have both extremes of applied flow, with most
flows between 400 and 2000 gallons per ton of coated product.
A similar plot shown in Figure IV-2, of applied flow versus production
rate (size) indicated that size is reflected indirectly when final
products are considered. Continuous strip galvanizing lines are
considerably larger in terms of production than their aluminizing or
terne coating counterparts. Likewise, strip and sheet coating lines,
no matter what metal is involved in coating, are larger than wire
coating lines, or lines coating any of the miscellaneous shapes. But
these differences are better accounted for by subdividing the
subcategory based upon the type of metal coating and on process water
usage due to product requirements, rather than on the basis of size or
age of a plant.
393

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Figure IV-2 also shows how size appears to be significant in the
number of plants which discharge wastewaters to POTWs. The large hot
coating operations (strip, sheet, and larger miscellaneous shapes
which are produced at rates exceeding 200 tons per turn) rarely
discharge wastewaters to POTWs, while approximately 40% of the wire
and wire products lines discharge to municipal treatment plants. Such
differences are accounted for in the development of separate effluent
limitations and standards for the wire products and fasteners
segments. Thus, subdivision by size becomes unnecessary since
potential size-related distinctions have been covered by subdivision
according to metal coating and final product. Size and age in
themselves do not affect the attainability of the proposed limitations
or standards.
The Agency also investigated the effect of age on the feasibility and
cost of retrofitting pollution control equipment at hot coating lines.
Comparison of the age of a hot coating line with the year in which
pollution control facilities were installed (see Table IV-1),
demonstrate that pollution control equipment can be retrofitted. The
discussion in the preceding paragraphs show that similar rates of
pollutant discharge are achievable at hot coating lines of all ages.
As a result the Agency has concluded that retrofitting pollution
control to hot coating lines is feasible.
The cost of retrofitting wastewater treatment systems to existing
production units was investigated as part of detailed data collection
portfolios (D-DCPs) circulated to selected hot coating operations.
Operators were asked to identify costs which would not have been
incurred if treatment was installed concurrently with production units
or during major rebuilds of production facilities. Nine plants
responded to this portion of the DCP. Four plants could not determine
retrofit costs for hot coating treatment since a central treatment
plant had been installed, and costs, if any, could not be segregated.
Four plant's central treatment systems could not quantify retrofit
costs, either because they were insignificant or impossible to
estimate with sufficient accuracy. No retrofit costs were reported
for two plants, the smallest galvanizer and a terne coating line. In
one case, a lagoon was added to an existing treatment facility, but
this was considered by the plant to be an upgrading cost, not a
retrofit cost. Retrofit costs for the remaining three plants were
listed as unknown, although the operator of a $1,650,000 central
treatment system estimated that he could have saved 25-50 percent if
he were building a greenfield system adjacent to his production units.
Treatment had to be installed 1500 to 2000 feet from the wastewater
sources, most of which were acid pickling operations. The Agency
estimates that $670,000 of this $1,650,000 central treatment plant is
attributable to the treatment of hot coating wastewaters. Model-based
estimates of treatment facilities on-site at this location indicates
BPT facilities costing $694,000 are dedicated to hot coating
wastewater, a figure which is only 3.6 percent greater than plant
reported costs. Even though plant personnel estimate that 25-50
percent of their costs are attributable to "retrofit", the money spent
is not significantly different than estimated costs based on the
models used throughout this study. It is likely that a portion of the
394

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so-called "retrofit" costs are really site-specific since new plants
have, in the past, constructed central treatment systems at
considerable distances from the wastewater sources (Plant 0856F).
A similar case was observed at Plant NN-2/118. Costs reported for
this plant treating galvanizing wastewater alone were an initial
investment of $1,500,930, versus EPA's estimated in-place cost of
$1,965,000 based on model costs. This treatment plant is also
detached by a considerable distance from the production units, yet
reported costs compare reasonably well with other plants and with
model-based estimates. Hence, the Agency concludes that its
model-based cost estimates are sufficient to cover site-specific and
retrofit costs for both separate and central treatment systems.
The Agency, thus, concludes that size and age have no significant
effect on further subdivision or segmenting of the subcategory.
Geographic Location
Hot coating operations are widespread, with no significant
distinctions noted due to geographic location. DCP respondents
included plants from twenty-one different states, and a recent
membership list of the American Hot Dip Galvanizers Association
indicates that galvanizing is practiced in forty-one different states.
However, about 60% of all hot coating operations are situated in four
states - Pennsylvania, Illinois, Ohio and California. Since
operations are nearly always confined within an enclosed building, the
effects of climate and adverse weather are greatly minimized. Special
consideration of water problems for "arid" or "semi-arid" regions is
not necessary, since the model treatment systems do not involve
significant water consumption. "Arid" or "semi-arid" region plants
are presently operating coating lines and wastewater treatment systems
comparable to those employed in other parts of the nation and will
have no unusual problems in upgrading existing systems. Hence, the
Agency concluded that further subdivision of the hot coating
subcategory based upon geographic location was not warranted.
Process Water Usage
The Agency reviewed the process water applied rates and effluent
discharge rates using data obtained from the basic DCPs. This review
revealed that most hot coated products required similar application
rates for rinsing and fume scrubbing regardless of coating metal.
This is particularly true for coating operations for strip, sheet,
pipe, tube, rod, bar, plate and miscellaneous structural shapes.
Exceptions were noted for fasteners, nails, wire and wire products.
Uniformly higher process water application rates are required for
these products regardless of coating metal. These rates were
substantially different from the basic flows for other products
because of the large increase of surface areas per unit of weight for
wire, nails, fasteners, and wire products. Hence, the Agency made
adjustments for additional water requirements for rinsing and fume
scrubbing. Refer to Section V (Water Use and Waste Characterization)
for further discussion of these differences. The impact of water
usage is significant enough to require additional allowances under the
395

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established subdivisions but does not require changing the basis for
subcategorization itself. The once-through process wastewater flows
are identical with applied flows for all hot coating subdivisions and
are as follows:
Rinsewater Flow Fume Scrubber Flow
(Gal/Ton)	(Gal/Ton)
All Strip, Sheet,	600	600
Pipe, Plate, Rod,
Structural & Misc.
Products
All Wire, Nail,	2,400	1,500
Fastener, Chain Link
Fence and Other Wire
Products
Note that process water usage is independent of the metallic coating
being applied, but highly dependent on product coated. Justification
for the subdivision by product is provided in Section IX.
396

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TABLE IV-1
HOT COATING PLANTS THAT HAVE DEMONSTRATED
THE ABILITY TO RETROFIT POLLUTION CONTROL EQUIPMENT
Plant Reference

Coating
Plant Age
Treat ent
Code
Product
Operation
(Year)
(Year)
0112B
Strip
Galvanizing
1962
1971
0112G
Fasteners
Galvanizing
^1930
1973
01121
Fasteners
Galvanizing
1922
1977
01121
Fasteners
Aluminizing
1955
1977
0384A
Strip
Galvanizing
1951
1970
0384A
Strip
Aluminizing
1961
1970
0448A
Sheet
Galvanizing
1967
1970
0460A
Wire
Galvanizing
1932
1968
0476A
Wire
Galvanizing
^1930
1977
047 6A
Pipe
Galvanizing
1930
1977
0492A
Pipe
Galvanizing
1962
1976
0580A
Wire Cloth
Galvanizing
1962
1967
0584C
Strip
Galvanizing
1956
1965
0640
Fencing
Galvanizing
1936
1961
0640
Wire
Galvanizing
1936
1961
0856D
Strip
Terne Coating
1964
1978
0856D
Strip
Galvanizing
(Al/Zn)
1949
1978
397

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5000-
4000-
3000-
2000-
1000-
(15,450)
(10,800) (7,200)
J >t
S)
IS
a
•	a
is	'
a	*
a1
®
E
LEGEND
•	Rinses only-Direct
x	Rinses a fume scrubbers-Direct
®	Rinses only- POTW
BO	Rinses 9 fume scrubber-POTW
a
s

X	X

13
• x
SI
13
• •
ti ri 111' 11111' if 1111 11' 1111111' 111111111 iti r m i 111fi 111 [l|)i 11111111 n 1
1906 I9J6 1926 1936 1946 1956 1966 1976
YEAR OF INSTALLATION-OLDEST ACTIVE COATING LINE
HOT COATING OPERATIONS
APPLIED FLOW vs AGE
FIGURE EE-I
398

-------
(10,800)
(7,200) | (IS,490)
L®x j
mrt	1
5000
O
LU
K 4000-]
<
o
o
h-
O
O
0C
Q.
-13
3000-
Ct
LU
a.
%
_i
<
o
2000 —
it
s
o
Q
U
Hi
CL
CL
<
1000-
LEGEND
•	Rinses only-Direct
*	Rinses & fume scrubbers-Direct
13 Rinses only - P0TW
(S Rinses & fume scrubber-POTW
IS
B1

x •
X X
JB
X
-je-
ll
81 iC
T	1"	1	1	1	1	1	1	1	1
0 100 200 300 400 500 600 700 800 900 950
PRODUCTION RATE-TONS PER TURN
HOT COATING OPERATIONS
APPLIED FLOW vs SIZE
FIGURE EC-2
399

-------
HOT COATING SUBCATEGORY
SECTION V
WATER USE AND WASTE CHARACTERIZATION
The Agency evaluated process water use and total wastewater volumes
based on data from the basic DCP responses received for most domestic
hot coating operations. When fume scrubbers were employed, the Agency
determined the additional wastewaters attributable to fume scrubber
operation. It identified existing wastewater control and treatment
technology for each plant, and examined the eventual disposal of
wastewater.
Waste characterization is based upon analytical data obtained during
the field sampling programs. Additional waste load and water quality
data were sought from nine selected companies by detailed data
collection portfolios (D-DCPs), which were used to supplement
available cost information.
Water use rates discussed below pertain only to process wastewaters,
and do not include a consideration of noncontact or nonprocess cooling
waters.
Water Use in Hot Coating Operations
Variations in applied water flow rates were noted in Tables III—1
through 111 — 3 for the various hot coating operations. Figures 111 — 1
through 111 — 5 illustrate why such variations are necessary. Note that
Figure 111-1 (galvanizing) depicts at least eight potential sources of
process wastewaters plus at least one source of noncontact cooling
water. Total wastewater flow from this line would be quite high. On
the other hand, Figure 111—3 also depicts a galvanizing operation with
only three potential sources, and two of these three are noncontact
cooling water. The actual process wastewater flow from this line
would be a fraction of the flow from the line shown in Figure III-l,
yet both could be producing galvanized ware of comparable size, shape
and quantity.
The choice of line configuration is dictated by product requirements,
as are the number and nature of the intermediate steps in the process.
As the process becomes more complex, the opportunity arises to reduce
flows by recycle of a portion of the wastewater, and at the same time
recover chemical values from such wastewater. An example appears in
Figure 111— 1, where three consecutive steps in preparing the product
for final coating involve the use of alkaline cleaners. Note that
wastewater overflows from the hot electrolytic alkaline cleaning tank
for reuse in the hot alkaline scrubber, which in turn is reused as
makeup to the hot alkaline dip tank. Instead of three separate
wastewater discharges from this cleaning step, each contributing
objectionable amounts of alkalis and phosphates, a single intermittent
discharge occurs. Such flow reduction and chemical conservation
401

-------
techniques can be employed to keep the total process wastewater
discharge from even the most complex coating line to a minimum.
The major wastewater flows originating from hot coating operations in
the steel industry fall into several distinct groupings:
1.	Continuously running dilute rinse waters from rinsing and
flushing operations following alkaline or acid cleaning steps;
rinses following chemical treatment or surface passivation steps:
and, final product rinses after hot dipping. These waters
contain suspended and dissolved matter, chlorides, sulfates,
phosphates, silicates, oily matter, and varying amounts of
dissolved metals (iron, zinc, chromium, lead, tin, aluminum,
cadmium) depending on which coating metal is used.
2.	More concentrated intermittent discharges, including spent
alkaline and acid cleaning solutions, fluxes, chemical treatment
solutions, and regenerant solutions from in-line ion exchange
systems. These discharges contain higher concentrations of the
pollutants noted above. Discharge volumes from these sources can
be minimized by close attention to maintenance and operating
conditions, and through provision of dragout recovery units
whenever possible. Spent cleaning baths are normally collected
separately for disposal or treatment, and the plating baths
themselves are never discharged. Instead, they are recovered and
continuously regenerated as part of the coating operation, or
sold to outside contractors for processing and recovery.
3.	Fume scrubber wastewaters are produced by continuously scrubbing
vapors and mists collected from the cleaning and coating steps.
Scrubbers may be once-through or recirculating, and produce
wastewaters that may be used as process rinses, since only
volatile components are present in the air to be scrubbed. Less
than 40 percent of all hot coating lines have wet fume scrubbers.
A few plants use dry fume absorbers, but most lines do not
provide for any vapor and mist control from coating operations,
other than acid tank covers, or fans to divert fumes out of the
work area. In many cases the coating line has been designed to
minimize the potential for releasing mists and vapors to the air.
4.	Noncontact cooling waters are used to control temperatures of the
furnaces and molten bath pots associated with coating operations.
Except for an increase in temperature, these waters are not
contaminated with pollutants during their pass through the
coating lines, and thus, require no treatment if they are kept
separate from contaminated process waters. Responses for some
plants indicate that process and noncontact cooling waters
sometimes share a common sewer prior to treatment. Capital
investment and annual operating costs are increased unnecessarily
due to the larger volumes requiring treatment in such cases.
Where possible, flow rates shown in Tables III—1 through III-3,
and on Figures IV—1 and IV-2 reflect process wastewaters only.
In some instances, plants did not separate process flow data from
noncontact flow data, so the flows shown for such plants are
high.
402

-------
Applied Flow Rates
Responses to DCPs were reviewed for applied rinse and fume scrubber
flow rates. Separate compilations were made for the various coating
metals, and for various final coated products. Data are summarized in
Table V-l in terms of gallons of process water applied per ton of
coated product. Wire and its associated products have consistently
higher average flow rates than do strip, sheet or miscellaneous
shapes. The Agency could not determine whether this is due entirely
to rinsing requirements, or to a greater likelihood for wire mills to
include noncontact cooling waters in DCP responses. In either case,
some wire mills were operating successfully with considerably less
water. However, even a comparison of minimum applied flows bears out
the fact that wire and related products require more water than strip,
sheet or miscellaneous shapes. In addition to surface area, another
contributing factor may be that all but one out of 83 wire mills use
fluxes, thus increasing the rinsing requirements, while only 20% of
the strip and sheet mills use fluxes. For these reasons, the Agency
is proposing limitations for wire and related products which are based
upon the higher water usage rates observed.
Waste Characterization
The Agency obtained information on wastewater quality from sampling
programs at eleven selected hot coating operations, two of which were
revisited two years after an initial sampling survey. It also
solicited long-term data from nine hot coating operations. A summary
of pollutants found in galvanizing, terne-coating and aluminizing
operation wastewaters is shown in Tables V-2, V-3 and V-4
respectively.
Note the large variations in the levels of most pollutants. These are
due mainly to coating line configuration. For example, lead is used
at some plants to anneal products prior to coating, while others do
not. If a pickling or rinsing step follows lead annealing,
considerable lead may be found in the wastewater. Otherwise, lead is
essentially absent except as a contaminant in the zinc metal used for
coating. Zinc was found to be essentially absent at several of the
galvanizing lines listed. In those cases where zinc content is high
in the raw wastewaters, it is often the result of repickling and
coating previously galvanized product which failed to pass inspection
of the coating following previous passes down the line. Similar
findings were noted for chromium and nickel.
Relatively low concentrations of toxic organic pollutants were found
in raw wastewaters from all coating operations during the toxic
pollutant survey. The phthalates and methylene chloride were
universally present but the Agency believes that they are attributable
to sampling and analytical techniques. The remaining toxic organics
tended to be present in plant intakes at levels equal to or greater
than those found in hot coating wastewaters. However, these toxic
pollutants appear at levels below treatability except by recycle.
4m

-------



TABLE V-t






PROCESS WATER
APPLIED RATES - HOT
COAT INC
OPERATIONS


Costing
Typ« of
Rinsevater in gal/ton

Fume Scrubber
Water in
gal/ton
Metal
Product
Maximum
Mininun
Avg.
Maximun
Minimum

Zinc
All
Types
15,540
1.0
1, 781
14,520
8.3
1,454
Zinc
Wire,Wire
Products,
Nails,
Fasteners
13,540
447
2, 613
14,520
316
2,284
Zinc
Strip k
Sheet
3,646
1.0
797
1,319
8.3
350
Zinc
Misc.
Shapes
2,270
7.6
683
7, 784
145
I, 554
Terne
All types:
(Strip &
Sheec Only)
2,567
301
863
1,280
116
508
Aluminum
All types
10,800
16
5,408
11,520
11,520
11, 520
Aluminum
Wire
10,800
10,800
.10,800
U, 520
11, 520
11,520
Aluminum
Strip
16
16
16
Dry
Dry
Dry
Tin
All Types
Wire
Strip
7,200
7,200
80
80
300
80
1, 570
i, 719
80
Dry
None
Dry
Dry
None
Dry
Dry
None
Dry
Cadmium
Wire Only
2,424
2,424
2,424
None
None
None
Aluminum/
Zinc
All
(Sheet
Only)
558
461
510
Hone
None
None
Cadoiun/
Zinc
All
(Wire
Only)
I, 832
I, 831
1,832
None
None
None
Cadmium/
Tin/Zinc
All
(W i re
Only)
5,250
5,250
5,250
None
None
None
All Hoc
All Types
15,540
1.0
1,828
14,520
8.3
1,547
Coating
404

-------
TABLE V-2
NET RAW WASTEWATERS - HOT COATING GALVANIZING
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
TOXIC POLLUTANT SURVEY
O
tn
Plant Codes
Staple Point (s)
Flow, gal/ton
Product
0612
JH>
1414
Wire
0 3 96A
112
D
287
Strip/Sheet
lbs/1000

mg/1
lbs
ng/1
Suspended Solids
67
0.395
326
Oil and Grease
20
0.118
13
Hexavalent Chromium
0. 002
0.000012
0.015
pH, units
7.4
-
1.7
Benzene
ND
ND
ND
1,1,1 Trichloroethane
0.067
0.000395
ND
Chloroform
0.015
0.000088
0.010
1,3 Dichlorobenzene
ND
ND
ND
Fluoranthene
ND
ND
0.024
Methylene Chloride
0,115
0.000677
0.012
Pentachiorophenol
ND
ND
ND
Bis~(2-ethyi hexyl) phthalate
0.086
0*000506
0. 307
Butyl benzyl phthalate
ND
ND
0. 005
Di-n-butyl phthalate
ND
ND
0.047
Di-n-octyl phthalate
ND
ND
ND
Diethyl phthalate
0.005
0.000029
ND
Diaethyl phthalate
0.005
0.000029
0.010
Tetrachloroethylene
0. 013
0.000077
0.010
Trichloroethylene
0.046
0.000271
ND
Arsenic
NA
NA
0.03
Chroaiim
0. 14
0.000824
0.22
Copper
0.06
0.000353
2.5
Cyanide
0.007
0.000041
0.02
Lead
0.20
0.00118
25
Nickel
0.03
0.000177
1.3
Silver
<0.02
<0.000118
0.05
Zinc
3.2
0.0188
50
Total Iron
NA
NA
NA
094 8C
114
B
211
Strip
01121
116
D
592
Fas teners

0920E
118
C
1177v
Strip/Sheet
_ (2)(3)
0476A
119
D
147
Pipe
Ave r a ge
Toxic Survey Only
Dissolved Iron
5.0
0.0295
195
lbs/1000
lbs
0.390
0.0155
0.000018
ND
NO
0.000012
ND
0.000029
0.000014
NO
0.000367
0.000006
0.000056
ND
ND
0.000012
0.000012
ND
0. 000036
0.000263
0.00299
0.000024
0.0299
0.00155
0. 000060
0.0598
m
0.233
HA
0.04

lbs/1000

lbs/1000

lbs/1000

lbs/1000

lbs/1000
¦»g/l
lbs
mgtl
lbs
ng/1
lbs
ing/ 1
lbs
nig/ 1
lbs
104
0.0914
127
0.313
74
0. 363
5
0.00306
117
0.259
208
0.183
16
0.0395
46
0.226
5
0.00306
51
0.0975
7
0.00615
0.002
0.000005
0.003
0.000015
0. 006
0.000004
1.40
0.00103
7.3
-
3.4
-
2.5
-
8.3
-
1.7-7.4
-
ND
ND
0.005
0.000012
0.010
0.000049
0.005
0.000003
0.003
0.000011
0.010
0.000009
ND
ND
0.003
0. 000015
ND
ND
0.013
0.000070
0.010
0.000009
0.011
0.00002 7
0.074
0.000363
0.068
0.000042
0.031
0.000090
ND
ND
ND
ND
0.153
0.000750
ND
ND
0.026
0.000125
0.010
0.000009
0.005
0.000012
0.015
0.000074
0.005
0.000003
0.010
0.000021
0.016
0.000014
0.018
0.000044
2.50
0.0123
0.010
0.000006
0.445
0.00218
0.022
0.000019
0.005
0.000012
ND
ND
ND
ND
0.004
0. 000005
0.156
0.000137
0.053
0.000131
0.035
0.000172
0,105
0.000064
0.124
0.000229
0.005
0.000004
0.010
0.000025
0.041
0.000201
0.005
0.000003
0.011
0.000040
0.026
0.000023
0.020
0.000049
0.031
0.000152
0.010
0.000006
0.022
0.000048
ND
ND
ND
ND
0,057
0.000280
ND
ND
0.010
0.000047
0.010
0.000009
0.011
0.000027
ND
ND
ND
ND
0.004
0.000011
0.010
0.000009
0.005
0.000012
0.019
0.000093
ND
ND
0.008
0.000026
0.005
0.000004
0.005
0.000012
0.014
0.000069
ND
ND
0.008
0.000029
ND
ND
ND
ND
ND
ND
ND
ND
0.008
0.000045
NA
NA
NA
NA
0.021
0.000103
NA
NA
0.026
0.000070
10
0.00879
0.10
0.00024 7
2.92
0.0143
<0.025
<0.000015
<2.23
<0.00407
0.02
0.000018
0.19
0.000468
0.12
0* 000589
0.02
0.000012
0.48
0.000738
0.014
0.000012
0.006
0.000015
0.019
0.000093
0.006
0.000004
0.012
0.000031
<0.05
<0.000044
0.19
0.000468
#
t
0.41
0.000251
<5.17
<0.00637
0.02
0.000018
0.09
0.000222
#
#
<0.02
<0.000012
<0.29
<0.00040
<0. 02
<0.000018
<0.02
<0.000049
#
#
<0.02
<0.000012
<0.026
<0.00005
0.6
0.00052 7
15
0.0370
82.0
0.402
2. 7
0.00165
25.6
0.0866
NA	97
0.000035 78
0.239
0. 192
10. 5
9.0
0.0515
0.0441
NA
0.03
NA
0.000018
54
48
0. 145
0.0831

-------
TABLE V-2
NET RAW WASTEWATERS - HOT COATING GALVANIZING
SUMMARY OF ANALYTICAL DATA FflDM SAMPLED PLANTS
PACE 2	
ORIGINAL SURVEY
Plant Code

0856P
0936
0856F
0920E(1)
Average




1-2
V-2

m-
•2
NN<
-2
Original
Overal1
Ssmple Point(s)

4
2+3

4-fl
:«>
3
(-n
Survey Only
Average
Flow, gal/ton

220
1655
69S
1233




Product

Wire
Wire
Sheet
Sheet/Strip






lhs/1000

lbs/1000

lbs/1000

lbs/1000

lbs/1000

lbs/1000

¦8/1
lbs
¦r/1
lbs
68
lbs
mg/l
lbs
wg/1
lbs
wg/1
lbs
Suspended Solids
94
0.0662
16
0.110
0.256
104
0. 534
75
0.247
100
0.254
Oil and Grease
15
0.0138
5
0.0345
48
0.140
20
0.103
22
0.0728
39
0.0876
Hexavalent Chronim
NA
NA
NA
NA
0.003
0.000009
0.011
0.000057
0.007
0.000033
0.177
0.000684
pH, Units
A. 5-5
i.O
1.8-8.7
1.2-11.
.2
2.6
-
1.2-11
.2
1.2-11
.2
Arsenic
NA
NA
NA
NA
NA
M
NA
NA
NA
NA
0.026
0.000070
Chroaius, Total
NA
NA
NA
NA
4.5
0.0131
1.8
0.00925
3.2
0.0112
2.47
0.00585
Copper
NA
NA
NA
NA
0. 22
0.000641
0.05
0.0002 57
0.14
0.000449
0.394
0.000666
Cyanide
NA
NA
NA
NA
0.005
0.000015
0.039
0.000200
0.022
0.000108
0.0145
0.000050
Lead
NA
NA
37.5
0.259
0.10
0.000291
0.26
0.00134
12.6
0.0869
7.96
0.0366
Nickel
NA
NA
NA
NA
0.027
0.000079
0.043
0.000221
0.035
0.0001 50
0.217
0.000329
Silver
NA
NA
NA
NA
NA
M
NA
NA
NA
NA
<0.026
<0.000050
Zinc
NA
NA
0.3
0.00207
0.2
0.000583
145
0.745
48.5
0.249
33.2
0.141
Total Iron
33
0.0303
1010
6.97
15.4
0.0449
11.6
0.0596
267
1.78
196
0.926
Dissolved Iron
7.1
0.00651
203
1.40
0.043
0.000125
9.0
0.0462
54.8
0.363
50.7
0.195
(1)	Plant vai tanpled during both surveys.
(2)	Flow includes non-contact cooling waters.
(3)	Flow includes fuse hood scrubber waters.
HD: Not Detected
NA: Not Analysed
# : Values for determination are qualified as less than sone masher veil over the linit of detection, e.g., <0.6, or <0.25 m$/1

-------
TABLE V-3
NET RAW WASTEWATER - HOT COATING - TERNE
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
Plant Codes
Sample Point
Flow, gal/ton
Product
Suspended Solids
Oil and Grease
Tin
pH
Chloroform
Methylene Chloride
Phenol
Bis-(2-ethyl hexyl) phthaiate
Tetr achl oroethylene
Chromiun
Copper
Lead
Nickel
Zinc
Iron, Total
Iron, Dissolved
TOXIC POLLUTANT SURVEY
(1)
ORIGINAL SURVEY
mg/1
0856D
113
C
1006'
Sheet/S trip
(2) (3)
11
4
<0.4
5.2-6.5
0.053
2.50
0.011
0. Oil
0.014
2.68
0.040
0.067
0.590
0.093
12.0
4.4
lbs/lOOO lb
0.0461
0.0168
<0.00168
0.000222
0.0105
0.000046
0.000046
0.000059
0.0112
0.000168
0.000281
0.00247
0.000390
0.0503
0.0184
mg/1
48
13
<2
2.2-4.1
NM
NM
NM
NM
NM
0.03
0.03
0.20
0.06
1.1
109
74
0060
00-2
4
516
Sheet/Strip
(1)
lbs/1000 lb
0.103
0.0280
<0.00430
0
NM
NM
NM
NM
NM
0.000065
0.000065
0.000430
0.000129
0.00237
0.234
0.159
mg/1
9
5
<2
3.6-5.2
NM
NM
NM
NM
NM
0.17
<0.02
<0.05
0.03
0.09
20.3
14. 9
0856D
PP-2
2
2194
Sheet/Strip
(2)(3)
lb/1000 lb
0.0823
0.0457
0.0183
NM
NM
NM
NM
NM
0.00155
<0.000183
<0.000457
0.000274
0.000823
0.186
0.136
Cl)	Plant was sampled during both surveys
(2)	Flow includes non-contact cooling water
(3)	Flow includes fune hood scrubber water
NM:	Not measured in original survey

-------
TABLE V-4
NET RAW WASTEWATER - HOT COATING - ALUMINIZING
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
TOXIC POLLUTANT SURVEY
Plant Codes
Sample Point(s)
Flow, gal/ton
Product
Suspended Solids
Oil and Grease
Aluminum
Hexavalent Chromium
PH
Methylene Chloride
Bis-(2-ethyl hexyl) phthalate
Butyl benzyl phthalate
Di-n-butyl phthalate
Diethyl phthalate
Cadmium
Chromium
Copper
Lead
Zinc
Nickel
Iron, Total
Iron, Dissolved
01121
116
E
3882
Fasteners
mg/1	lbs/1000 lb
231	3.74
19	0.307
12	0.194
0.007	0.000113
8.4
0.015	0.000242
0.052	0.000841
0.060	0.000970
0.038	0.000614
0.011	0.000178
<0.01	<0.000162
0.10	0.00162
0.21	0.00340
0.39	0.00631
0.35	0.00566
0.18	0.00291
49	0. 793
NM	NM
NM: Not measured, pH is sufficiently high to eliminate need for analysis of
dissolved iron.
408

-------
HOT COATING SUBCATEGORY
SECTION VI
WASTEWATER POLLUTANTS
For hot coating operations, the pollutants of interest originally
limited were oil and grease, suspended solids, lead, chromium (total
and hexavalent), tin, zinc, and pH. As a result of the toxic
pollutant survey and the addition of other hot coating operations
besides galvanizing and terne coating, other pollutants, (e.g.
aluminum, cadmium, copper, dissolved iron and nickel) have been
considered as possible additions to the list of selected pollutants in
certain hot coating alternative treatment systems. The Agency found
other pollutants to be present in significant quantities in hot
coating wastewaters (e.g., chlorides, sulfates, dissolved solids), but
is not proposing limitations for them. In general, these pollutants
are nontoxic in nature and difficult to remove. Treatment for these
pollutants is not commonly practiced in any industry.
Raw wastewater quality and treated effluent characteristics are
described in detail in Sections V and VII. Refer to Tables V-2 and
VI1-2 for galvanizing, Tables V-3 and VII-3 for terne coating, and
Tables V-4 and VII-4 for aluminizing.
Conventional Pollutants
The Agency originally promulgated limitations for suspended solids,
oil and grease artd pH in 1976. Suspended solids not only are
routinely present in raw wastewaters, but also are generated during
treatment as dissolved metals are precipitated out of solution. Thus,
effective removal of suspended solids is necessary to minimize the
discharge of toxic metal pollutants.
Oil and grease was selected for limitation because of the use of
lubricants and oil baths in the hot coating processes. Sampling
indicated the presence of up to 200 mg/1 of oil and grease.
Finally pH was chosen primarily because of the detrimental effect of
extremes in pH levels, and because control of pH significantly affects
the removal of dissolved metals. Without such control, unacceptable
discharges of toxic metals could occur.
These pollutants are common to all hot coating operations. Thus,
effluent limitations for these pollutants are being proposed at the
BPT and BCT levels.
Toxic Pollutants
Analytical results for 51 toxic pollutants found in raw and treated
wastewaters are summarized in Table VI-1 through VI-3. Thirty-eight
different toxic organics were identified as present and quantified at
the seven hot coating plants sampled for priority pollutants/ although
409

-------
only about half that number were identified at any single plant.
Fifteen of the thirty-eighf pollutants were found at only one of the
plants, usually at concentrations less than 0.01 mg/1. Eleven of the
thirty-eight organic pollutants were found in excess of 0.01 mg/1 in
either raw or treated hot coating wastewaters, and one, methylene
chloride, is believed to be an artifact. In treated effluents,
methylene chloride, chloroform, 1,1,1 trichloroethane and
4,6-dinitro-o-cresol were found in excess of 0.01 mg/1, with only
methylene chloride exceeding 0.05 mg/1. Phthalates were also found
universally where automatic samplers were used to collect samples
indicating a problem with leaching of plastic tubing plasticizers into
the sample.
Of the 130 different pollutants listed as toxics, 50 (excluding
methylene chloride) have been found to be present in measurable
concentrations in raw wastewater or treated effluent from the seven
plants surveyed during the toxic pollutant survey of this subcategory.
Not all of the 50 pollutants are directly related to the plant
operations. As many as 28 have been identified in the water used as
makeup at the surveyed plants, although concentrations tend to be less
than 10 micrograms per liter for most pollutants in the intake waters
tested.
No definite source was ascribed to the organic priority pollutants
found in wastewater from hot coating operations. Residual oils
applied during cold rolling operations prior to coating is one
possible source of low level contamination of coating wastewaters by
so many different organics. Trichloroethylene, tetrachloroethylene,
and 1,1,1 trichloroethane may be present in the degreasing solvent
used as a cleaner prior to coating. Toxic metal pollutants are more
directly related to the coating operations. Not only are certain
toxic metals like zinc, cadmium, lead, and chromium used in the hot
dipped coating processes, but most of the other toxic pollutant metals
are also found as trace contaminants in the baths associated with hot
coating. Cadmium, chromium, copper, lead, nickel, and zinc were found
in raw and treated wastewater from all hot coating operations. Most
concentrations were reduced to a considerable extent by treatment,
with zinc proving to be the most difficult to treat.
The treatment systems used at these hot coating plants were not
designed to control and treat more than about a dozen of the 130 toxic
pollutants listed; however, most plants show some reduction of the
quantity of pollutants found in their wastewaters. Toxic organics in
effluents were incidentally treated along with other pollutants to
levels for which no specific organic removal step is practical other
than recycle. Toxic metal removal was also accomplished to low levels
through the use of precipitation, flocculation, and sedimentation (or
filtration). As a result, the Agency believes that an acceptable
control of the various toxic wastewater pollutants from hot coating
operations can be achieved by establishing limitations on a relatively
small number of indicator pollutants. For a summary of pollutants
selected for limitation, refer to Table VI-4.
Data are also available for a variety of nontoxic pollutants for which
limitations are not being proposed. These pollutants were measured to
410

-------
enable evaluation of factors such as scale formation and corrosion
where recycle of wastewater is considered, and to aid in evaluation of
chemical treatment costs and sludge loads. Additional measurements in
hot coating operations included acidity/alkalinity, calcium, chloride,
iron, solids (dissolved), and sulfate.
411

-------
TABLE VI-1
TOXIC POLLUTANTS IN HOT COATING - GALVANIZING WASTEWATERS
(All concentrations in mg/1)
Toxic Pollutants
Orpanics
1
Raw
11
112

114
116

ne

119
Trt .*
Raw
Trt.*
Raw
Trt.*
Raw
Trt.*
Raw
Trt.
Raw
Trt.*
1
Ace naphthene
ND
0.005
ND
0.005
ND
0.005
0.005
ND
ND
0.003
ND
0.005
4
Benzene
ND
0.005
HD
0.005
ND
0.010
0.005
ND
0.011
0.007
0.005
ND
11
lf1, 1-Trichloroethane
0.067
ND
ND
ND-
0.010
0.032
ND
ND
ND
ND
ND
0.005
20
2-Chioronajhthalene
ND
ND
ND
0.005
ND
ND
ND
ND
ND
0.003
ND
ND
21
2f 4,6-Trichlorophenol
ND
ND
ND
ND
ND
0.005
0.005
ND
ND
ND
0.010
ND
23
Chi orof or*
0.015
0.005
0.010
0.010
0.010
0.019
0.012
0.010
0.106
0.048
0.069
0. 014
24
2-Chlprophenol
ND
ND
0.005
ND
ND
0.005
ND
ND
ND
0.003
0.010
ND
26
1,3-Dichiorobenrene
ND
ND
ND
ND
ND
ND
ND
ND
0.144
ND
ND
ND
30
1,2-trans-dichloroethylene
0.005
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
31
2,4-Dichlorophenol
0.005
0.010
ND
ND
0.005
ND
0. 005
ND
ND
ND
ND
ND
39
Fluoranthene
ND
0.010
0.024
0.010
0.010
0. 010
0. 005
0,005
ND
0.007
0.005
0.005
44
Methylene chloride
0.115
0.021
0.013
0.013
0.016
0.230
0.018
0.010
ND
ND
0.010
0.011
48
Dichloro br on an et hane
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.010
ND
55
Naphthalene
ND
ND
ND
0.010
ND
0.010
ND
ND
ND
ND
ND
ND
57
2-Nitrotfcenol
ND
ND
ND
ND
ND
0.005
ND
0.005
ND
ND
ND
ND
59
4,6-Dinitrophenol
ND
ND
ND
ND
ND
0.005
0.005
ND
ND
ND
ND
ND
60
4,6-Dinitro-o-cresol
ND
ND
ND
0.020
ND
ND
ND
ND
ND
0.003
ND
ND
64
Pentachloro phenol
ND
0.005
ND
ND
0.022
0.005
0.005
ND
ND
0.003
ND
ND
65
Rienol
ND
ND
ND
0.010
ND
0.005
0.005
ND
ND
ND
ND
ND
72
Benso(a )anthrace ne
ND
ND
ND
ND
ND
ND
ND
0.005
ND
ND
ND
ND
73
Benzo(a)pyrene
ND
0.010
ND
0.005
ND
0.005
ND
ND
ND
0.003
ND
ND
76
Chrysene
ND
ND
ND
ND
ND
ND
ND
0.005
ND
ND
ND
ND
77
Acenaphthylene
ND
0.005
ND
0.010
0.010
0.010
ND
ND
ND
0,003
ND
0.005
78
Ant hr ace ne
ND
ND
ND
ND
ND
ND
ND
ND
0.005
0.007
ND
ND
80
Fluorene
0.005
ND
ND
0.005
ND
0.010
0.010
ND
ND
0.003
ND
0. 005
81
Rienanthrene
ND
ND
ND
ND
ND
ND
ND
ND
0.005
0.007
ND
ND
84
Pyrene
0.005
0.010
0. 021
ND
0.010
0.010
0.005
0.005
ND
0.007
0.005
0. 005
85
Tetrachloroethylene
0.014
ND
0.010
ND
0.005
0.005
0.006
ND
0.017
0.008
ND
ND
86
Toluene
ND
ND
ND
0.005
0. 005
0.010
ND
ND
0.010
0.010
ND
ND
87
Trichloroethylene
0.046
0.010
HD
ND
ND
HD
ND
ND
ND
0.003
ND
ND
Honor panics












114
Antimony
NA
NA
NA
NA
NA
NA
NA
NA
0.003
0.003
NA
NA
115
Arsenic
NA
NA
0.04
0. 010
0. 010
0.010
NA
NA
0.014
0.007
NA
NA
117
Beryll ium
NA
NA
NA
NA
NA
NA
NA
NA
<0.02
<0.02
NA
NA
118
Cadmium
0.010
0.02
0.020
<0.02
<0.02
<0.02
0.010
0.010
<0. 2
<0. 2
0. 010
0. 010
119
Chromiin
0.15
0.04
0.23
0.15
10.2
0.02
0.10
<0.03
2.32
0.20
<0. 02
<0.02
120
Copper
0.06
0.03
2. 5
0. 17
0.02
<0.02
0.20
0.020
0.120
<0.04
0.020
0.03
121
Cyanide
0.008
0.021
0.018
0.002
0.014
0.008
0.006
0.002
0.019
0.014
0.006
0. 012
122
Lead
0.20
0. 19
25
0. 58
<0.05
<0. 05
0.19
0. 10
<0. 50
<0. 60
0. 42
<0. 10
123
Mercury
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
124
Nickel
0.03
0.03
1.3
0. 27
0.03
0.04
0.09
0.03
<0. 50
<0. 50
<0.02
0.030
125
Selenium
NA
NA
<0.01
0.010
<0.010
0.010
NA
NA
0.005
0.012
NA
NA
126
Silver
<0.02
0.02
0.06
0.09
<0.02
<0.02
<0.02
<0.02
<0.25
<0.25
<0.02
<0.02
127
Thalliua
NA
NA
NA
NA
NA
NA
NA
NA
<0.05
<0.05
NA
NA
128
Zinc
3.2
0.13
50
0.25
0. 65
0.07
15
0. 13
88. 9
7.7
2.8
o
o
<3"
*: Indicates water quality of central treatment effluent
NA: Not Analyzed
ND: None Detected

-------
TABLE VI-2
TOXIC POLLUTANTS IN HOT COATING - TERNE COATING WASTEWATERS
(All concentrations in mg/1)
Toxic Pollutants 113
	Or sanies		Raw
I	Acenaphthene	0.003
4 Benzene	0.007
II	1, 1, 1-Trichloroethane	0.003
21	2, 4, 6-Trichlorophenol	0.003
22	Parachlorometacresol	0.003
23	Chloroform	0.053
29	1, 1-Dichloroethylene	0.003
30	1,2-Trans-dichloroethylene	0.009
31	2, 4-Dichlorophenol	0.003
35	2,4-Dinitrotoluene	0.003
36	2, 6-Dinitrotoulene	0.003
38	Ethylbenzene	0.003
39	Fluoranthene	0.007
44 Methylene chloride	0.833
54 Isophorone	0.003
64	Pentachlorophenol	0.007
65	Phenol	0.011
73	Benzo(a )pyrene	0.003
74	3 , 4-Benzof luoranthene	0.003
75	Benzo(k)f luoranthene	0.003
76	Chrysene	0.007
78 Anthracene	0.007
80	Fluorene	0.003
81	Hienanthrene	0.007
84	Pyrene	0.007
85	Tetrachl oroethylene	0.014
86	Toluene	0.007
Nonorganics
114	Antimony	<0.006
115	Arsenic	<0.002
117	Beryllium	<0.008
118	Cadmium	<0.080
119	Chromium	2.675
120	Copper	0.040
121	Cyanide	0.003
122	Lead	<0.067
123	Mercury	0.0007
124	Nickel	<0.230
125	Selenium	<0.002
126	Silver	<0.025
127	Thallium	<0.050
128	Zinc	0.093
NOTE: Plants' wastewater treatment under construction at time
of sampling. Raw wastewater sample was the only one
available.
413

-------
TABLE VI-3
TOXIC POLLUTANTS IN HOT COATING - ALUMINIZING WASTEWATERS
(All concentrations in mg/1)
Toxic Pollutants		116	
	Or ganics		Raw	Treated*
23 Chloroform	0.010	0.010
39 Fluoranthene	0.005	0.005
44 Methylene Chloride	0.015	0.010
60 4,6-Dinitro-o-cresol	0.006	ND
64 Pentachlorophenol	0.005	ND
73 Benzo (a) Pyrene	0.005	ND
77 Acenaphthylene	0.005	ND
84	Pyrene	0.005	0.005
85	Tetrachlorethylene	0.005	ND
Nonorganics
114	Antimony	NA	NA
115	Arsenic	NA	NA
117	Beryllium	NA	NA
118	Cadmium	1.010	0.010
119	Chromium	0.13	<0.03
120	Copper	0.22	0.02
121	Cyanide	0.002	0.002
122	Lead	0.40	0.10
123	Mercury	NA	NA
124	Nickel	0.18	0.03
125	Selenium	NA	NA
126	Silver	<0.02	<0.02
127	Thallium	NA	NA
128	Zinc	0.36	0.13
*: Indicates water quality of central treatment effluent
NA: Not analyzed
ND: Not detected
414

-------
TABLE Vl-4
SELECTED POLLUTANT PARAMETERS
HOT COATING OPERATIONS
Cihanitini
iU
M
in

BPT
BCT
Total Suspended Solids
X
X
Oils and Greases
X
X
ptl, Units
X
X
ChroadiM, total
X

Chroaiuw, Kexavaleot
X

Cadatim, total


Zinc, total
X

Tinv total


Lead, total


BAT
BPT
X
X
X
Terne Coating
BCT
X
X
X
BAT
(1) Limitation only applies to opcrationa where cidniw it used at a coating Mtil.
X: Selected pollutant parameter.
Other Metal Coatings
BPT	BCT	BAT
(1)
(I)

-------
HOT COATING SUBCATEGORY
SECTION VII
CONTROL AND TREATMENT TECHNOLOGY
A brief summary of the treatment practices emplpyed at hot coating
operations visited by the Agency shows the variety of wastewater
treatment techniques employed in the industry. Also included are
descriptions of the potential applications of other technologies, and
more detailed discussions of technologies useful to treat or control
specific pollutants. A standard list identifying all technologies
observed throughout the industry is shown as Table VII-1, which also
serves as a key to abbreviations and symbols used.
In developing the alternative- treatment systems, limitations and
incremental costs, the Agency considered the level of existing
wastewater treatment for most plants. The alternative treatment
systems were then formulated in an "add-on" fashion to these basic
levels. The various treatment systems (levels of treatment) are
summarized in Section VIII in Tables VIII-4 through VIII-6 for
technology and Tables VIII-7 through VI11—19 for costs.
Summary of Treatment Practices
Currently Employed for Hot Coating Operations
As noted previously, the process wastewaters generated during hot
coating operations include alkaline and acidic cleaners and rinses,
fume scrubbing wastewaters, and chemical treatment solutions and
rinses. Wastewaters are often treated in central treatment systems
along with wastewaters from other forming and finishing opreations.
DCP data indicate that more than 75% of all hot coating wastewaters
are treated jointly with wastewaters from pickling, cold rolling, hot
forming, and other finishing operations. Most of the remaining 25%,
provide some degree of separate treatment for hot coating lines, prior
to central treatment used for further polishing.
The more common hot coating treatment practices are listed below
according to the degree of treatment they provided:
1. No matter what wastewater treatment technique is used, an
important first step is to minimize the quantity of wastewaters
requiring treatment. This is accomplished by providing dragout
recovery tanks downstream of the main cleaning tanks; by
employing high pressure spray rinses with recycling or reuse of
rinsewaters; and by careful, even critical, attention to
maintenance of equipment such as rolls and squeegees designed to
reduce solution losses. Some hot coating lines with slower line
speeds minimize carryover of wastes so effectively that no
treatment of wastewaters is practiced. Spent pickling and
cleaning solutions at these plants are collected separately for
disposal via contract hauling, or deep wells.
417

-------
Cascade rinse systems and recycle of fume hood scrubber wastes
are two effective methods of minimizing wastewater volunres
requiring treatment.
2.	The simplest "treatment" of wastewaters from hot coating
operations usually begins with blending acidic and alkaline
wastes, then providing space and time for suspended precipitates
to settle. This blending of wastewaters is practiced at 12% of
hot coating plants. Oily matter breaks out of solution, becoming
susceptible to removal by either skimming or through adherence to
the settleable solids. To avoid slugs of extremely acidic or
alkaline wastewaters, concentrated solutions are collected
separately, stored, and then allowed to combine with rinses
gradually to provide the best mixing conditions possible in this
relatively crude system.
3.	A significant improvement in treatment technology is attained
through controlled neutralization of the combined wastewaters,
using an alkaline material such as lime, ammonia, or caustic soda
to achieve higher pH levels than is normally possible through
simply blending the wastewaters. Three-fourths of the existing
hot coating operations use this technology currently. A polymer
is also used at 40% of all hot coating wastewater treatment
plants to enhance settling characteristics,	and
flocculator-clarifiers are installed at 60% of the operations to
efficiently handle the large volumes of metal hydroxides which
precipitate out. Sludges are sometimes dewatered using vacuum
filters (by 18% of the plants) and are then transferred to
landfill areas. Wet sludges are landfilled or lagooned at many
hot coating operations.
4.	Other treatment methods depend upon the source of the
wastewaters. These are tailored to specific needs, for example:
Reduction of Hexavalent Chromium - Galvanizing and other metallic
coating operations producing wastewaters contaminated with
chromate or dichromate ions have separate pretreatment stages to
reduce toxic Cr+« to Cr + J prior to neutralization. Most often,
pickling rinse solutions or spent pickle liquors are blended with
the chromium wastewaters to acidify the wastewaters and provide
the required reductant. In some cases, (9% of the galvanizing
wastewater treatment plants) additional reducing agents such as
bisulphites or sulfur dioxide gases are used in place of or in
addition to pickling wastes. The reduced chromium containing
wastes are then passed along to a controlled neutralization
treatment stage, where the addition of lime, ammonia, or caustic
soda precipitates all chromium as hydroxide. Alternatively, the
chromates may be precipitated out of solutions by the addition of
barium salts, such as sulfates or carbonates. A precipitate of
barium chromate is separated out for subsequent recovery of
barium and chromium. Also, ion exchange techniques have been
utilized at several coating lines to recover clean chromic acid
from strong solutions contaminated by iron and trivalent
chromium. The recovered acid is reused in the coating or
chemical treatment operations.
418

-------
Precipitation of Aluminum, Cadmium, Copper, Lead, Tin, and Other
Metals - As described previously in Section VI, the sources of
these metallic pollutants in hot coating operations are the
cleaning and pickling of the steel prior to application of
coatings, the rinsing or quenching of the product after the
coatings have been applied, and in the disposal of spent coatings
solutions. They can be found in the spent pickle liquors and in
the rinse water following the pickling and coating operations.
The wastewaters are generally acidic in nature, and so the
wastewater treatment is focused on the neutralization of the acid
with subsequent precipitation of dissolved metals as hydroxides
or as sulfides.
Hydrated lime, ammonia, or caustic soda is used to raise the pH
of the wastewaters to 8.5-9.0. At this pH, metal hydroxides are
precipitated and can be settled out. This treatment sequence is
very common in this industry, and in fact, 75% of all hot coating
wastewaters undergo alkaline precipitation. The pH must be
controlled within a narrow range to prevent resolubi1izing
certain metals. An improved heavy metal precipitation step has
been used in the metal finishing industry, and is considered
applicable to similar wastewaters from coating operations. The
treatment procedure involves the addition of soluble sulfides
(such as sodium sulfide or sodium hydrosulfide) or a freshly
prepared ferrous sulfide slurry (prepared by reacting ferrous
sulfate with sodium hydrosulfide) to form insoluble metal
sulfides which can be separated prior to discharge. Although
this system shows considerable promise of attaining lower heavy
metal concentrations than achievable by hydroxide precipitation
alone, it remains to be demonstrated on hot coating wastewaters.
Since most of the components are similar to the hydroxide
precipitation sequence, the sulfide treatment can serve as a
backup polishing system following conventional lime or caustic
soda treatment.
Ferrous iron is also present in wastewaters generated during
coating operations. Aeration, with subsequent neutralization is
currently the most widely used method for treating ferrous iron
in the dilute rinse waters resulting from the hot coating
operation. This is usually done in a rapid mixing tank where the
pH of the wastewater is adjusted to 8.5 with lime. The treated
waste is then pumped to a clarifier, thickener or settling lagoon
where the precipitated iron in the hydroxide form settles out
along with other metal hydroxide precipitates. In a properly
designed and operated treatment plant, the dissolved iron in the
discharge from the sedimentation unit should be significantly
less than 1 mg/1.
Oil and Grease - The removal of oil and grease from wastewaters
can be effected by the following techniques used either alone or
in a combination with each other, depending on the nature of the
wastewater.
Gravity Separation - With the exception of filtration, free oil
removal processes are based on density separation. The process
419

-------
is applicable to the removal of both floatable substances (i.e.,
free oil and greases, fine oil-coated solids, water-oil
emulsions), and heavier-than-water materials, such as the larger
oil-coated metal and oxide particles. The choice of a particular
type of separator would be determined by the type of wastewater
encountered, and could range from the simplest separator in which
only floatable substances are removed to the more complex dual
function scale pits and clarifiers (with or without chemical
treatment) in which both the floatable and nonfloatable phases
are removed. Currently, slightly more than half of the hot
coating wastewater treatment plants utilize surface skimmers to
remove floating oil.
Suspended Solids - Suspended solids in the hot coating
subcategory for the most part consist of metals removed during
pickling, cleaning and rinsing, and metal hydroxides generated
during lime neutralization of wastewaters containing of dissolved
metals. Suspended solids are usually treated by gravity
techniques. For the most part, (60% of the plants) treatment has
been confined to the use of clarifiers or thickeners which, when
provided with appropriate organic flocculant aids, achieve
excellent solids separations. Forty percent of the treatment
systems include polymer addition. About 21 percent of the plants
remove the suspended solids by filtration.
5. Joint treatment systems combining wastewaters from many different
sources into one terminal treatment operation are common in
integrated steel mills and in the larger forming and finishing
mills. In these systems, wastewaters from hot coating lines
usually represent a minor portion of the total flow, notably when
hot forming wastes are present. Such terminal treatment systems
may incorporate any or all of the individual treatment stages
mentioned above prior to mixing with other wastewaters. At some
plants all wastewaters are combined before treatment commences.
This results in dilution of the wastes and reduces the
effectiveness of subsequent treatment. The only way to be
certain that such loads are in fact reduced is to provide
pretreatment prior to mixing with other wastewaters.
Plant Visits
Visits were made to eleven plants to study the individual operations
included in the hot coating subcategory. Tables VII-2 through VII-4
present the treated effluent waste loads from these plants.
Plant 1-2 - Figure VII-1
Wire galvanizing wastewaters are treated by dilution and reaction with
other mill wastes in a terminal lagoon, with subsequent discharge to a
receiving stream.
Plant V-2 - Figure VI1-2
Wastewaters from wire hot coating and pickling, are combined and
neutralized with caustic soda prior to discharge to a POTW.
420

-------
Plant MM-2 - Figure VII-3
Hot and cold strip/sheet coating wastewaters are combined with
wastewaters from other sources. Treatment includes equalization, oil
separation, aeration, sedimentation, lagooning, and recirculation to
service water with intermittent blowdown to the river.
Plant NN-2 z Figure VII-4
This plant uses equalization, mixing, two-stage lime addition, polymer
feed, and clarification for treatment of batch and continuous
galvanizing wastewaters from strip, sheet and miscellaneous shape
production lines. Clarifier underflows are vacuum filtered then used
as landfill. Overflows are discharged to a receiving stream.
Plant 00-2 - Figure VII-5
This plant uses mixing and dilution of rinsewaters from terne coating
of strip/sheet prior to discharge. Solution dragout is minimized
through strict attention to maintenance of equipment.
Plant PP-2 z Figure VII-6
This plant uses mixing and dilution of rinsewaters from terne coating
of strip/sheet prior to river discharge. Solution dragout is
minimized through strict attention to maintenance of equipment.
Plant HI - Figure VII-7
Wiper waters from wire galvanizing operations are collected, recycled
via hot rolling mills, with a small continuous bleed-off to treatment.
Pickling rinses and spent HC1 concentrates are combined with wastes
from nail and fence galvanizing, treated with lime, aeration,
clarification, and pressure filtration through sand prior to
discharge.
Plant 112 - Figure VII-8
Wastewaters from continuous galvanizing are combined with pickling
concentrates and rinses, treated with lime and polymer, clarified, and
discharged to a POTW.
Plant 113 - Figure VII-9
During the toxic survey (March, 1977), wastewaters from this
continuous strip/sheet terne coating line were discharged without
treatment. A combined chemical treatment plant is under construction.
Meanwhile, solution dragout is minimized through strict attention to
maintenance of equipment.
Plant 114 - Figure VI1-10
Galvanizing wastewaters from continuous strip/sheet coating lines are
blended with wastes from pickling, cold rolling, and electrolytic
421

-------
coating lines, equalized, treated with lime, settled, skimmed free of
oils, treated with polymer, clarified and discharged.
Plant 116 - Figure VII-11
Wastewaters from galvanizing, aluminizing, electrolytic coating, and
alkaline degreasing of wire, fasteners, and special shapes, are
combined, treated with lime and polymer, clarified, filtered and
stored in a large lagoon for reuse or discharge.
Plant 118 - Figure VII-12
Spent galvanizing solutions, rinsewater, fume scrubber water and some
noncontact cooling water from continuous strip/sheet and batch
miscellaneous shape coating lines, are blended, treated with lime in
two stages, fed polymer, clarified and discharged once-through.
Clarifier underflows are vacuum filtered.
Plant 119 - Figure VI1-13
Wastewaters from pipe and tube pickling and galvanizing are combined
with wastewaters from other plant sources, equalized, skimmed free of
oil, aerated, treated with lime and polymer, clarified and discharged.
422

-------
TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
Symbols
Operating Modes
1.	OT	Once-Through
2.	Rt,s,n	Recycle, where t =	type waste
s =	stream recycled
n =	% recycled
t:	U = Untreated
T = Treated
s	n
p
Process Wastewater
%
of
raw waste
flow
F
Flume Only
%
of
raw waste
flow
S
Flume and Sprays
%
of
raw waste
flow
FC
Final Cooler
%
of
FC flow

BC
Barometric Cond.
%
of
BC flow

VS
Abs. Vent Scrub.
%
of
VS flow

FH
Fume Hood Scrub.
%
of
FH flow

REt,n
Reuse, where
t =
type

n = % of raw waste flow
t: U ¦ before treatment
T = after treatment
4. BDn	Blowdown, where n = discharge as % of
raw waste flow
Control Technology
10.
DI
Deionization
11.
SR
Spray/Fog Rinse
12.
CC
Countercurrent Rinse
13.
DR
Drag-out Recovery
Disposal Methods
20.	H	Haul Off-Site
21.	DW	Deep Well Injection
423

-------
TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 2	
C*	Disposal Methods (cont.)
22. Qt,d	Coke Quenching, where t = type
d = discharge as %
of makeup
t: DW = Dirty Water
CW = Clean Water
23.
EME
Evaporation, Multiple Effect
24.
ES
Evaporation on Slag
25.
EVC
Evaporation, Vapor Compression
Treatment
Technology
30.
SC
Segregated Collection
31.
E
Equalization/Blending
32.
Scr
Screening
33.
OB
Oil Collecting Baffle
34.
SS
Surface Skimming (oil, etc.)
35.
PSP
Primary Scale Pit
36.
SSP
Secondary Scale Pit
37.
EB
Emulsion Breaking
38.
A
Acidification
39.
AO
Air Oxidation
40.
GF
Gas Flotation
41.
M
Mixing
42.
Nt
Neutralization, where t » type
t: L ® Lime
C = Caustic
A « Acid
W = Wastes
0 = Other, footnote
424

-------
TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 3
D.	Treatment Technology (cont.)
43.	FLt	Flocculation, where t = type
t: L = Lime
A = Alum
P = Polymer
M = Magnetic
0 = Other, footnote
44.	CY	Cyclone/Centrifuge/Classifier
44a. DT Drag Tank
45.	CL	Clarifier
46.	T	Thickener
47.	TP	Tube/Plate Settler
48.	SLn	Settling Lagoon, where n = days of retention
time
49.	BL	Bottom Liner
50.	VF	Vacuum Filtration (of e.g., CL, T, or TP
underflows)
51.	Ft,m,h	Filtration, where t ¦ type
m = media
h = head
	t	ra	h	
D ¦ Deep Bed	S = Sand	G = Gravity
F » Flat Bed	0 ¦ Other, P = Pressure
footnote
52.	CLt	Chlorination, where t = type
t: A = Alkaline
B * Breakpoint
53.	CO	Chemical Oxidation (other than CLA or CLB)
425

-------
TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 4		
D.	Treatment Technology (cont.)
54.	BOt	Biological Oxidation, where t = type
t: An	= Activated Sludge
n	= No. of Stages
T	= Trickling Filter
B	= Biodisc
0	= Other, footnote
55.	CR	Chemical Reduction (e.g., chromium)
56.	DP	Dephenolizer
57.	ASt	Ammonia Stripping, where t = type
t: F = Free
L * Lime
C = Caustic
58.	APt	Ammonia Product, where t = type
t: S = Sulfate
N ¦ Nitric Acid
A ¦ Anhydrous
P = Phosphate
H = Hydroxide
0 ¦ Other, footnote
59.	DSt	Desulfurization, where t = type
t: Q = Qualifying
N = Nonqualifying
60.	CT	Cooling Tower
61.	AR	Acid Regeneration
62.	AU	Acid Recovery and Reuse
63.	ACt	Activated Carbon, where t » type
t: P = Powdered
G = Granular
64.	IX	Ion Exchange
65.	ro	Reverse Osmosis
66.	D	Distillation
426

-------
TABLE VII-1
OPERATING MODES, CONTROL AND TREATMENT
TECHNOLOGIES AND DISPOSAL METHODS
PAGE 5
D. Treatment	Technology (cont.)
67.	AA1	Activated Alumina
68.	OZ	Ozonation
69.	UV	Ultraviolet Radiation
70.	CNTt,n	Central Treatment, where t = type
n " process flow as
% of total flow
t: 1	= Same Subcats.
2	= Similar Subcats.
3	= Synergistic Subcats.
4	¦ Cooling Water
5	= Incompatible Subcats.
71.	On	Other, where n = Footnote number
72.	SB	Settling Basin
73.	AE	Aeration
74.	PS	Precipitation with Sulfide
427

-------
TABLE VII-2
EFFLUENT WASTE LOADS - HOI COATING - GALVANIZING
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
to
OD
A. Toxic Pollutant Survey
Plant Codes
Sample Points
Flow, gal/ton
C&TT
Suspended Solids
Oils and Greases
Chromium *6
pH, Units
4	Benzene
11	1,1,1-Trichloroethane
23	Chloroform
26	1,3-Dichlorobenzene
39	Fluoranthene
44	Methylene Chloride*
64	Pentachlorophenol
66	Bis(2-ethylhexyl)phthaiate*
67	Butylbenzyl phthalate*
68	Di-n-butyl phthalate*
69	Di-n-octyl phthalate*
70	Diethyl phthalate*
71	Dimethyl phthalate*
85	Tetrachloroethylene
87	Trichloroethylene
115	Arsenic
119	Chromium
120	Copper
121	Cyanide
122	Lead
124	Nickel
126	Silver
128	Zinc
0612
111
(J/B+-C+D+EJH
1414
HL,CL,FDSP
lbs/1000 lbs
0.0649
0.0236
0.000035
0.005
ND
0.005
WD
0.010
0.021
0.005
0.130
ND
0.018
ND
0.010
0.005
ND
0.010
NA
0.04
0.03
0.021
0.18
0.02
0.02
0.12
0.000029
ND
0.000029
ND
0.000059
0.OOOI24
0.000029
0.0007 66
ND
0-000106
ND
0.000059
0.000029
ND
0.000059
NA
0.000236
0.000177
0.000124
0.00106
0.000118
0-000118
0.000707
0396A
112
(d/b+e+d+j)h
287
AE T NL, FLP,CL , VF, POTW
mg/1 lbs/1000 lbs
43
6
0.005
9.0
ND
ND
0.010
ND
0.010
0,013
ND
0.104
0.005
0.010
ND
0.005
0.007
ND
ND
0,01
0.07
0.17
.002
.57
.27
0.09
0.24
0.(
0.1
0.2
0.0514
0.00718
0.000006
ND
ND
0.000012
ND
0.000012
0.000016
ND
0.000124
0.000006
0.000012
ND
0.000006
0.000008
ND
ND
0.000012
0.000084
0-000203
0.000002
0.000682
0.000323
0.000108
0.000287
094 8C
114
(B/G)H
211
NL,FLP,T,SS
mg/1 lbs/1000 lbs
6 0.00528
6 0.00528
0.006 0.000005
7.7 -
0.010
0.032
0.018
ND
0.010
0.230
0.005
0.062
0.005
0.010
ND
0.010
0.010
0.005
ND
0.01
0.02
<0.02
0.007
0.005
0.04
#
0.07
0.000009
0.000028
0.000016
ND
0.000009
0.000202
0.000004
0.000055
0.000004
0.000009
ND
0.000009
0.000009
0.000004
ND
0.000009
0.000018
<0.000018
0.000006
0.000044
0.000035
ISD
0.000062
01121
116
(D/F+B)H
592
NL, FLP ,T, FDSP
mgTl lbs/1000 lbs
0.00272
0.00987
0.000007
0.003
0.010
0.000025
0.005
0.000012
0.010
0.000025
0.010
0.000025
0.005
0.000012
0.010
0.000025
0.005
0.000012
0.03
0.000075
0.02
0.000049
0.001
0.000002
0.10
0.00024 7
0.03
0.000074
0.00032
0920E
118
D
1177
NL,FLP,T,VF
mg/1 lbs/1000 lbs
37	0.181
5	0.02^5
0.077	0.000378
8.9
0.007
ND
0.048
ND
0.007
<0.010
0.003
0.012
0.007
0.007
0.003
ND
0.003
0.008
0.003
0.007
0.27
<0.04
0.014
7. 75
#
6. 73
0.000034
ND
0.000236
ND
0.000034
<0.00005
0.000015
0.000059
0.000034
0.000034
0.000015
ND
0.000005
0.000039
0.000015
0.000034
0.00132
<0.000196
0.000069
ISD
0.0380
ISD
0.0330
0476A
119
(D/E)G
147
SS,NL,FLP,CL,VF
mg/1 lbs/1000 lbs
4
11
0.008
7.8
ND
0.005
0.014
ND
0.010
0.011
ND
0. 150
ND
0.013
ND
ND
0.010
ND
ND
NA
0.025
0.03
0.012
0.10
0.03
#
0.05
0.00245
0.00674
0.000005
ND
0.000003
0.000009
ND
0.000006
0.000007
ND
0.000092
ND
0.000008
ND
ND
0.000006
ND
ND
NA
0.000015
0.000018
0.000007
0.000061
0.000018
ISD
0.000031

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TABLE VH-2
EFFLLEJff HASTE LOADS - HOT (DATING - GALVANIZING
SUMWRY OF ANALYTICAL DATA FROM SAMPLED PLANTS
PAGE 2		
B. Original Guidelines Survey
Plant Codes
Sanple Points
F1 ow - ga1/ton
C&TT
Suspended Solids
Oils and Greases
Chroaitn -*-6
pH, Units
119	Chromiui
120	Copper
121	Cyanide
122	Lead
124	Nickel
128	Zinc
0856P
1-2
5
220
	SL	
lbs/1000 lbs" mg/1
39
14
NA
6.7
NA
NA
NA
NA
NA
NA
0.0358
0.0128
NA
NA
NA
NA
NA
NA
NA
0936
V-2
4
1655
NC;P0TW
0856 F
MM-2
6
699
0920E
NN-2
4
1233
CR,NL,FLP,CL,SS
NL,FLP,T, VF
lbs/1000 lbs mg/1 lbs/1000 lbs rag/1 lbs/1000 I
276
9.3
NA
2.5
NA
NA
NA
11.0
NA
NA
1.91
0.0641
NA
NA
NA
NA
0.0759
NA
NA
60 0.175
22.5 0.0655
0.005 0.000015
4.1-11.5
0.86 0.00251
<0.03 <0.000087
0.014 0.000041
<0.07 < 0.0002
0.03 0.000087
0.04 0.000117
0.03
<0.02
0.018
<0. 05
<0.02
1.51
0.0308
0.0498
0.000062
0.000154
<0.0001
0.000093
<0.00026
<0.0001
0.00776
^	ND: None detected,
to	MA: Not analyzed.
^	* : Artifacts not originally present in wastewater.
# : Analyses were reported as less than soae fairly large value (e.g., <0.6. <0.25).
ISD: Insufficient data to accurately quantify.

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TABLE VII-3
EFFLUENT WASTE LOADS - HOT COATING - TERNE
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS


Toxic
Pollutant Survey

Original
Guidelines
Survey
Plant
Code

0856D
(1)

(2)
0060V '
0856D(1)



113


00-2

PP-
2
Sample Points

C
(3)

4

2
(3)
Flow.
gal/ton

1006


517

2194
C&TT

Under Construction

None

None



mg/1

lbs/1000 lbs
mg/1
lbs/1000 lbs
mg/1

lbs/1000 :
Suspended Solids
11

0.0461
48
0.103
9

0.0823
Oil and Grease
4

0.0168
10
0.0215
4. 3

0.0393
Hexavalent Chromium
0.002

0.000008
<0.002
<0.000004
0.0034

0.000031
Tin

<0.1

<0.000042
<2
<0.00431
<2

<0.0183
pH, units
5.2-6.
5
-
2.2-4.1
-
3.6-5.2

-
115
Arsenic
0.008

0.000034
NA
NA
NA

NA
119
Chromium
2.68

0.0112
0.03
0.000065
0.158

0.00144
120
Copper
0.04

0.000168
NA
NA
<0.02

<0.000183
121
Cyanide
0.003

0.000013
0.001
0.000002
0.006

0.000055
122
Lead
0.07

0.000293
0.20
0.000431
<0.05

<0.00046
123
Mercury
0.0001

<0.000001
<0.0003
<0.000001
0.0003

0.000003
124
Nickel
0. 59

0.00247
NA
NA
0.03

0.0002 74
126
Silver
<0.025

<0.000105
NA
NA
NA

NA
128
Zinc
0.039

0.000390
0.91
0.00196
0.12

0.00110
Dissolved Iron
7.6

0.0319
74.0
0.159
13.3

0. 122
(1)	Plant visited during both surveys
(2)	Data covers two Terne Coating operations
(3)	Includes non-contact cooling water
NA: Not Analyzed

-------
TABLE VII-4
EFFLUENT WASTE LOADS - HOT COATING - ALUMINIZING
SUMMARY OF ANALYTICAL DATA FROM SAMPLED PLANTS
Toxic Pollutant Survey
Plant Codes
Sample Point
Flow- gal/ton
C&TT
Suspended Solids
Oils and Grease
Hexavalent Chromium
pH, units
115	Arsenic
118	Cadmium
119	Chromium
120	Copper
121	Cyanide
122	Lead
124	Nickel
126	Silver
128	Zinc
Dissolved Iron
01121
116
(e/(f+b))h
3960
NL,FLP,CL,FDSP
mg/1
<1
4
0.003
7.3 - 7.7
NA
<0.01
<0.03
0.02
0.001
<0.08
<0.025
<0.02
0.13
0.04
lbs/1000 lbs
<0.0165
0.0661
0,000050
NA
<0.000165
<0.000495
0.000330
0.000017
<0.00132
<0.000413
<0.000330
0.00215
0.000661
NA - Not analyzed
431

-------
MILL SERVICE:
W4T&IZ
CbG.00 GPM)
•t*.
00
NJ
*4. PiCkLE
3 5"7 £/5£C
3 (3 PM)
FWE5H
ROD
MILL
SPRfcV
QIKfafc
357i/5£C
(5347 GPM)
PICKLE
T4NW
RINS
*5 PIC UlE LI NEl
3-S4 1/ SBC
l'l5(2> (3Phi)
PQOCfcSSs
PLAN"
PRODUCTION
MOT PORMING-SSCTIQN'-
PICLLIMQ M2SQ4-HCI
HOT COATING GALVANIZING
1-2
: I332> ME.TO.IC TON'S
usaaToNsypaf gob
834 ME-TOMC TONS
1319 TONS)/ PAY
Mg604 F=»t£ZIZ. 1—I NJC5
Cb5 MErTdlC. TONS
(72. TONS)/ DA.V MCI
PICKLING £ GALVANING
PUME HOOD
(.NO SCBUBSING)
¦ WATEB sprays
Q-7 l/SEC- (|_I_GPM)
HCl_

RUNNING

HOT

WOT
PlCHLE
TAW IL

RIN3&

STANDING
RINSE;

D 1 P
GALV.
337je/aec
(5347 GPM)
SP&NT AC ID
TO CONTC&CT&D
DISPOSAL.
I3.ag/5£C
(glS GPM)
A OjJ/SEC
(H&PM)
¦* 3SO l/5£C. (S55G> &PM)
TO RECEIVING STREAM
TERMINAL SETTLING LA&OON
A-Cn , 7QO ,OQO g
(17. ,<200,000 GAL.)
A-
SAMPLING) POI NTS
ENVIRONMENTAL PROTECTION AGENCY
0W& fc -24-14
STEEL INDUSTRY STUDY
COMBINED WIRE, ROD, PICKLING 8
WIRE GALVANIZING LINES
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM	
(?EV.l 7-20 It
ft* 2 2 2616
FIGURE 3Z3E-1

-------
HOT COATING-GALVANIZING
process:
V-2
PLANT:
PRODUCTION: 5.3 METRIC TONS OF STEEL/TURN
(5.8 TONS OF STEEL/TURN)
CITY WATI
0.63 l/SEC.
(10 GPM)
0.63 l/SEC. (10 GPM)
/ V
WIRE
MOLTEN
ZINC
WATER
COOL
HCI
PICKLE
WATER
RINSE
WATER
QUENCH
MOLTEN LEAD
ANNEALING
0.63 l/SEC
(10 GPM)
CITY WATER
0.63 l/SEC—
(10 GPM)
0.63 l/SEC. (10 GPM)
j 1.26 l/SEC. (20 GPM)
AREA DRAIN
NoOH
STORAGE
BATCH
BATCH RINSE
FROM HOT COATING LINES
FLOOR
DRAIN
NON-CONTACT
COOLt NG
TO METROPOLITAN
SANITARY DISTRICT
ENVIRONMENTAL PROTECTION AGENCY
		
4.7 3 l/SEC.
(75 GPM)
STEEL INDUSTRY STUDY
HOT COATING LINE"GALVANIZ I NG
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
NEUTRALIZATION
TANK
Dwn.4/17/79
^\= SAMPLING POINTS
FIGURE m-Z

-------
Ms1 INHNE l\C\D j fr,L*AL> RinsE.
«	UN£	RAUSE
.TWUNt KOti R\V»SE
*~zt	 	
ASe>L.vANiliNvi LINE MN£.kVK*U R^-SE
PROCESS' COMING'S HOT- GA\_VAN\Z\t\l(»
Coatings - Cold -Tin- PSA
COKTiMCiS - COLCs-CH^OtAE
PlKNl ; fANVS.
PRODOC"T\ON	METRVCTON^h-ISTonS)/
Oi\y T i N PlATE.
&l6tv\LTR>tTo^v^OO"[ONb) /
TiNr ClAROfAiOtA PlME
q9 e, VNETH\CTons 0 \ OO TONS) /
gmv(\n>ied product
OAK\F»tR
(FOUR')
*~7&r
¦* ^^A\.VAr-n7.n\& fT IN- NM^CJElLKNt-OUS £ai^P5 ETC
)__		RtCOVERtD
OuS\OfcAGE~VANK.?,
y— average Flow so.t 5/sec
-7^\	0Z18 ^PtA)
Oil- ==>EPp>RfCTQR
„~To SLUDGE
L^OON
RtORCUC^TE
"To "be.vivice.
WasT e w
\*ST O R AG E LffiOON
~\0 RWE.R
SEOtMfcHTK* \0N
sas^* z
"TO RW6.R
lO SKtKtALD CML
*• sioR-^at "Tank
kt«M\ON i
SEDIMENTATION ~TKHK
^CW-tPtT E.FFL0E.NT
COVsE. "PLANT "WASTED
B^-ewujtkSH water
fRoN\ power uoose
^1R
A
"Vo kludge \_AGiOON
"^/\hAPL>N(a Po\NTS>
ENVIRONMENTAL PROTECTION fvG,E.NCY
•=>TE.E\_ \NOO$TV?y 5\UDV
. hot g Cold coktwg, lines
VV /\ST E-N AT ER T S.tMVsEHT "&Y STElA
WATER TlOW tM/V^RAtA

atv ?-^l&
atv? ?-ZVIfr
FIGURE 3ZI-3

-------
POOCESga COATINGS - MOT
G^LV^NI IIN6
PLANT : N N - 7-
PRODU)CTIONI : IS&& METRIC. TONS
OF ST&E.L. / DAY
fiT51 TONS OP-STeE-L.
/ day)
SPENT PICKLIN6* CLEANUPS SOLUTION!
POLYMER
AV6 PLOW-
RIN5& WATER
RINS£ WATER
NON-CONTACT COOUNS
WATER FROM ALL LINES
ia.?>TU(kO £T.)DIAW&TEQ.
> j55,OOOe.( 300,000 GAM
COMBINED MILL
SERVICE. WAT&as t
USED frS Pi NS&
RINSE m/ATEQ.
SOLIDS TO
LAUOPILL.
A CITV WATER
I S>3.Q - 76.7 JL/sac.
(ioc>o- izoo &pm)
TO R&CE-IVIMG
ENVIRONMENTAL PROTECTION A&ZNCV
WELL. WAT&Q-
2Q.t ~ 2S. 1 £/SEC
(31C5 -4-OQ &PAf)
STEEL INDUSTRY STUDY
MOT COAT I NIG LINE
WA^TErWATEC TREATMENT SY5T&M
wiTEB. Plow di&&c.am
Z\= SAMPLING POINTS
DW6 fc-g>-T4|g&/2 Mi lt
ee.
-------
PROCESS: COAT IMG.
PLATE
plant ¦ 00-2
¦ hot- terne
PRODUCTION.' 4"51 METRIC TONS OFSTEEL/DAY
(541 TOM'S OF STEEL/ DAY")
COLD
ROLLED
COILS ^
DEGREASING
SPRAY
	1>
H2SO4.
DIP
SPRAY
SECTION
rinse

PICKLE TANK
TAKIK
rinse

lead/tin


HOT
HOT WATER
CONDITIONER
HOT DIP
--
3^
V^ATER
SPRAY

tank


Dip tank
Rinse
TERWE
. plated
PRODUCT
TREATED
WATER A
1.89£/SEC
025GPM*
PRtTREATMENT
OP RIVER WATER
RIVER
WATER
WELL WATER
	zisr
4.35i/SEC
(&"5 &PM)
MOT WATER
COLD










ROLLED
DEGREASING
SPRAV

H2SO4
DIP
SPRAY

	1>
SECTION
RINSE
	5>
PICKLE TANK
TANK.
RINSE
	>.
COILS










LEAD/TIN

HOT
HOT WATER
CONDITIONER
HOT Dl P
	»-
WATER
SPRAY

TANK

DIP TANK
RINSE
TERNE
PLATED
PRODUCT
-&T
TO RIVER
I2.2i/ SEC
(194 GPM)
ENVIRONMENTAL PROTECTION AGENCY
5TEEL INDUSTRY STUDY
HOT COATiNG-TERNE PLATING
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
ou; & e. is
It ml Z-l<3-7fc
i?ty? 227 11,
FIGURE M-5

-------
PROCESS; COATIKIGS-HOT-TERME PLATE.
PLA.NT' PP-2
PRODUCTION ; 47.T»M
WASfEWATER TREATMENT SYSTEM
WATER Fuo\fJ DIAGRAM
^^SAMPLIPOINTS
0WG.6.-C-"7S
FIGURE 30L-6

-------
PROCESS: T-CONTINUOUS GALVANIZING
to
00
NON-CONTACT COOLING H,0
CHILLER CONOENSATE
DISCHARGE ONLY OPERATES
AT BO°F
TO ATMOSPHERE
MAKE-UP
Z»NC AMMONIA
CRYSTALS
MAKE-UP7TY*1
plant:
PRODUCTION. T-84 METRIC TONS WIRE/TURN
(93 TONS WIRE/TURN)
galv
i	9
uftunup=

NO RlkSC MATER
&CiO Dump onl
COOLING
HP 1
ACID
iank
GAL*
ZINC
BATH
:hromaie
RINSE
IANK
RINSE
MAX
RINSE
FLUX
REELERS
kiNSE
TANK
f?00 MILL
17.3 i/Mc(274apm}
RECYCLE
TO M1.L
RIVER
0 631 lf\tt
0 63l/»ec
N»4 PICKLING ( GALVANIZING LINE
ON BASEMENT)
rh
(lO GPU)
MATER
10 ATMOSPHERE

WIPER WATER
LIFT STATION
N«4 L»-T
f wr©
STATION
RECYCLE I RIVER WATER
PUMP HOUSE
DISCHARGE TO
RIVER
CMROMME
COOLING
HINSE
TANK
HCi
ACID
TANK
RINSE
TANK
FLUX
TANK
RINSE
WAX
REELERS
ZINC
RINSE
ROD MILL
CONTINUOUS
BLEED
6 J/«
NO 3 PICKLING (GAL VANIZING LINE
(GROUNO FLOOR)
b GPIJ
PRESSURE
SAND FILTERS
I OPERATING
I STANDBY
ATMO-
OTl J
25 GPU)
20 48I/«tc
(324 5 GPUI
FROM LEAO
TUfTU
CLARlFlERS
ANNEALING
SPHAV WAJEB
48Mtc (7t CPU
furnace
LIME FEED
(TYPl
SLURRY
1514 J/»«C
CHROMA!E
RINSE
TANK
RINSE
RINSE
WAX
REELERS
(24 GPUI
TANK
0 7171/1
VACUUM DRUM
FILTER
5
168 GPM>
2 CPU)
21 99J/tee
1548 S GPU
2 62 l/i
N 2 PICKLING t GAI VANI7tNft 1 INF
(GROUND FLOOR)
MAKE-UP
(20 GPU)
lb 6 GPU)
£rt WATER TREATMENT PLANT
REACTION
~XIQAT ION
TANKS
BOILER
LFT STAIION
[BLOW OWN)
0 2 8 4 Ltf c.
14 $ G PM
W7U
5 t*»
(224 GPU
LOULING
GALV I ICHROMAIE!
ZINC r RINSE
h?so4
RINSE
TANK
FLUX
RINSE
WAX
REELERS
RINSE
H?SO
RINSE
£ TANK
ANING
BATH
67lA«c (16 3 GPU)
N° T PICKLING ( GALVANIZING LINE
NAIL
GALVANIZING
IGROUNO FLOOR)
S5i/»»
(60 GPU
SPENT HC
b IDkAGE
SAMPLING POINT
(NO ACID)
6,815 i/
(>08 GPM)
HC A TANKS OUMPEO
EVER* FRIDAY N'GHT
A NO METERED INTO
TREATMENT SYSTEM
FlNlSHEO MONOAY
MORNING
ENVIRONMENTAL PROTECT ON
AGENCY
4 007 i/»»c 7
(6) 3 GPU)
LIFT STATION
STEEL INDUSTRY STUDtT
HCI-NELTTRALIZATION— CONTINUOUS GALVANIZING
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
PARS HALL
5 3»6//»tc (24 4 CPU)
MAIN LIFT STATION
I 39 I Ate (180 *> GPU)
L UMt
FIGURE 331-7

-------
Ul
ID
I'roci:
f- HOT COATING GALVANIZING
RIVER
WATER
(5 LINES)
PRODUCTION: 129 METRIC TONS/TURN
{142 TONS/TURN)
CONTINUOUS
HCL
PICKLING LINES
H2S04 TUB
PICKLER LIQUOR
TRUCKED FROM
another plant
CONTINUOUS
galvanizing
LINES
OIL STORAGE
TANK -SPENT
c
COLD ROLLING
t
r
r
MILL OILS
plant:
1.55 l/SEC
(24.5 GPM)
STEAM
l/SEC.
(184.5
IO.I l/SEC
(160 GPM)
SPENT
PICKLE
MILK OF LIME
0 l/SEC.
(0 GPM)	
REACTOR
LIQUOR
STORAGE
TANK
TANK
PURCHASED
HOLDING
MILK OF LIME
TANK
ooo o
NO TRUCK LOAOS
DURING SAMPLING
RUN
0.41 l/SEC.
(6.5 GPM)
5.36 l/SEC
(85 GPM)
O l/SEC
(0 GPM)	4>
17.42 l/SEC
(276 GPM)
SUMP
17.42 l/SEC
(276 GPM)
POLYMER
0.57 l/SEC
(9 GPM)
AVAILABLE
SAMPLING
CLARIFIER
Sludge
VACUUM
FILTER
DWN 8/1/78
SAMPLING POINT
SOLIDS TO
LANDFILL
METROPOLITAN
SANITARY
DISTRICT
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
PICKLING AND GALVANIZING
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
FIGURE 331-8

-------
.fe.
o
P/eoC££S:'l-H^7 , "clAT/A/u,i -TERNE PLWt
P£/)AJT : 113
P&OOUCT/OM:T-IC,e. METRIC TONS/TUUN
(/8G TONS/TURN)
&/l>££ iaJ/9T££
A' - SAmPUaJ£ Pq/aJT
TO WASTE T££/)TAf£A/T
plaajt /tup £i>/)p&e./)r/asj
POA/OS
PRODUCT PLOAJ
Sati£££Lt
/>A/n
WAT££
CO£)L//\JG
Ct£Afu
HZ So4
£L£CTZALfl/C
P/T /)££/)
UMCO/l££S
WATER.
£tfJS£
CrQ4
TPMTM£A)T
&/)S/fd
BATH
W£LO/Al(Z
AJo/j-caAj?/)cr
A/OAJ-COMTACr
COOL/AlC MAT££. ^
COOl/AJC HJJT££
/\.3AAiPLlfJC, POINT
MS! A!
TO £/U££_
Ca/O T/e£/)TM£AJT)
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATINGS TERNE PLATE
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
L-/S TO 3C &fe£C fsoa - 48QCPM)
SAMPLED /)T D/S~C///>£G£ /aiTO MM
DWN.8-10-77
FIGURE 3ZI-9

-------

LAKE

SERVICE WATER
L
process: t-continuous galvanizing
plant :
LIME FEED
POLYMER
FEED
LIME
FEED
PRODUCTION:T'392 METRIC TONS OF STEEL/TURN
(432 TONS OF STEEL/TURN)
PRIMARY
MIX
TANK # I
263.5 l/SEC
(4176 GPM)
Cm}
EFFLUENT
DISCHARGE
LIME FEED
PRIMARY
SCALPING
TANK #1
PRIMARY
MIX
TANK#2
RARSHALL
FLUME
TANK
a
PRIMARY
SCALPING
TANK #2
SCUM
BOX
TANK
FLOCCULATING
CL ARIFIERS
24.29 l/SEC
<385 GPM)
OIL
SKIM
TANK
Sludge
/£\lift
STATION
WEL L
THICKENER
SLUDGE
PUMPS
0.947 l/SEC.
(15 GPM)
116.55
l/SEC
(1847 GPM]
Filtrate
OIL
SEPARATION
TANK
OIL
STORAGE
TANK
ELECTROLYTIC
PLATING LINES
LIFT
STATION
CENTRIFUGES
SLUDGE CONVEYOR
CONTRACT
HAULER TO
LANDFILL
N I TIN MILL
3 STAND C.R.SJ4
CONTRACT
HAULER
DC
LIFT
STATION
ENVIRONMENTAL PROTECTION AGENCY
N" 2
PICKLER
LIFT
STATION
STEEL INDUSTRY STUDY
CONTINUOUS H2S04- CONTINUOUS GALVANIZING
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
25.75 l/SEC
(406 GPM)
N I
PICKLER
SAMPLING POINT
DWN 8/3/78
FIGURE 331-0

-------
PROCESS: T-HOT COAT ING - GALVANIZING
SPRIbtCj WAT£/?
SOUTH PEQREASCR
ALKALINE. RINSES
PLANT: 116
PRODUCTION:T-2.7 METRIC TONS/TURN
(3.0 TONS/TURN)
NORTH AND SOUTH
qALVANlZER RINSES
EL EC TftOLYT IC
RINSES
ALUMINIZINC\
RINSES S—
RAMSOHOFF WASH£«, y
ru/MACES, ETC.
lO qPM
(4.4- 6/SEC)
IO MILL,
HOT FORMING,
ETC.
/\ SAMPLING POINT
COIL 0RAW!N$% ETC.
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
ACID PICKLING, ALUMINIZING,
GALVANIZING, ALKALINE CLEANING
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
TO STREAM AVo/oR
RECYCLE
FIGURE MM I
deep
Bed
FILTERS
Has
FILTERS

-------
r	 /.?6>£/SEC
\ f20£FM)
PROCESS,: T-HOT COATINQ tiALVANIZ/fl/6
PLAajt: //&
P£6DUC7/aAj : T - 44-iM£ 7E/C 70/US S7'i. J TURK)
(48? TOAJS STL . /tUUKJ)
SPEAJ7 P/CXl/AJC f Cl£AM/AlC SALUT/OMS
L/ME /

FUMl MOOO Sce/JA&SS
tamir
so. loo £
(A.0OO6JL )
CAII/AA/H/AJ&
e/ust
VACUUM IXliM
F/trae
t/t£0
LME A
cxiftci
morr) a/A
/,/lS.OOOJL
<500.000£Al.\
fume hooc sceo&6££ t House wA/e/t
2£2 ekec
C40CPM)
A^JOUJZK
FUME MtX> ScBtiBAOLS
/T*			^
(U.40&PM )

C/6&Q CfM)
CALl/AAJU/AJO.
UfJE "C"
fume hooo seen tun 1 hmze wAre/t
combmEu m/u se&mce
watees used as e/AJSE
NON-CON TACT
COOLING WATER
c/rr wr£/t
7£.7 &t& {/sec
('too - /lOO GP/rt )
*to 2£cei\/iajc> sm£/)M
t
ENVIRONMENTAL PROTECTION AGENCY
STOSM EOAiOFFS
f£6M HEA/f XAM5
fX/O/l 70 SAMF>L/U6
steel inoustry study
HOT COATINGS-GALVANIZING
WASTEWATER TREATMENT SYSTEM
WATER FLOW DIAGRAM
W£LL_JMA7£k
25 2- 27 / 4 /SEC
!4oO-43o CfM )
A - SAMPLING point
JWN.-3?
-------
TUBE MILL
RINSE
TANK
"I
A A
RINSE
TANK
RINSE
TANK
O.e Jf/SEC
RINSE AREA
SUMP
0.7A 9/SEC
r\\n QPM
O.2. S/SEC
3 qPM
COOLING
BOSH
O.I5
/:5
l^m
L
-A-
*—^-0.3 jysec
^ qpm
XL
2 jyscc
19 qPM
0.08.2. i>/SEC
1.3 GiPM -—^
A
1.7 QPM' *>
OTHER PLANT SOURCES-
/37 //SEC
2170 QPM

ao^5 jyfeEC
<>—oy» qPM
PKOCI SS-- T - BATCH GALVANIZING- PIPE 8 TUBE
PLANT:	119
PRODUCT ION *.T¦ 63 METRIC TONS TUBE/TURN
(69 TONS OF TUBE/TURN)
CROWN
SYSTEM RINSE
EQUALIZATION
AND OIL
SKIMMINQ .
— /39 J/SEC
2203 <^PM
AERATION
CHEMICAL
ADDITION ^
MIXING
LARIFIER
EMERQENCV
IMPOUNDMENT
TO LAQOON
14-1 //SEC
22 38 CfPM
DISCHARGE
A~»
PARSHALL
FLUME
/\sAMPLING POINT
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
SULFURIC ACID PICKLING-BATCH GALVANIZING
WASTEWATER TREATMENT
WATER FLOW DIAGRAM
DWN.il/l6/78
FIGURE 3ZH-I3

-------
HOT COATING SUBCATEGORY
SECTION VIII
COST, ENERGY, AND NONWATER QUALITY IMPACTS
Introduction
This section presents the incremental costs incurred in applying the
different levels of pollution control technology to the hot coating
subcategory. The analysis also describes energy requirements,
nonwater quality impacts (including air pollution, solid waste
disposal and water consumption), and the techniques, magnitude, and
costs for each level of technology for model plants.
Varying degrees of the technology described below are in use. Also,
many combinations of various treatment methods are possible. Thus,
not all plants are required to add all of the treatment technologies
or incur all of the incremental costs indicated to bring existing
facilities into compliance with the proposed effluent limitations and
standards. Summaries of the alternative treatment systems applicable
to each hot coating operation are depicted in Figures V111 — 1 through
VII1-3.
Costs
The water pollution control costs for seven of the nine plants visited
during the study are presented in Table VII1-1. The remaining two
plants provided no usable cost estimates. With the exception of Plant
116 (see footnote 2 on table), all costs apply to galvanizing
operations only. At Plant 116, costs cover aluminizing and alkaline
cleaning in addition to galvanizing. Terne coating wastewater
treatment systems were under construction at three sites, but costs
were not available at this writing. The treatment systems net raw
waste and gross effluent loads are described in Sections V, VI, and
VII. The costs were supplied by each plant, with all costs converted
to July, 1978 dollars. Standard cost of capital and depreciation
percentages were used so that these basic costs would be comparable.
Cost Comparisons for Facilities in Place
In order to determine whether its cost estimates were accurate and
would cover actual site-specific costs, the Agency compared costs
reported by plants (including all site-specific and retrofit costs)
with model-based estimates of facilities in place. These data are
summarized below:
445

-------
Plant
Coated
Product
Plant
Reported Costs
Table VIII-1
For Plants Which Were Sampled
1121
396A
47 6A
612
856F
856P
920E
Subtotal
Fasteners
Strip/Sheet
Pipe & Tube
Wire
Sheet
Wire
Strip/Sheet
2,958,00a1
509,050
61,500
670,020
944,270
14,310
1.500,930
3,700,080
Model-based
Estimate of
Facilities In Place
518,000*
541,000
290,000
807,000
1,221,000
23,000
1,965,000
4,847,000
For Plants Which Provided Costs in D-DCP Responses
0580A
0728
0868A
0920F
Subtotal
Wire
Pipe
Strip
Strip(Terne)
TOTAL (excluding 1121)
TOTAL (including 1121)
55,137
211,785«
233,232
36,800
536,954
4,237,034
7,195,034
56,000
105,000
1,580,000
54,000
1,795,000
6,642,000
7, 160,000
1Costs omitted from subtotal. Plant reported costs cover many
operations other than hot coating, while model-based estimates are for
hot coating only. See text discussion below for Plant 1121.
2Plant reported costs included a cooling tower, model-based costs do
not.
Model-based estimates tend to be higher than actual plant costs,
reflecting that model estimates adequately take into account
site-specific costs. The few widely divergent costs reflect problems
in apportioning total treatment plant costs for large central
treatment systems back to individual small lines. Plant 1121 broke
down the $9.7 million capital expense of a plant-wide treatment system
by assigning $5.4 million to the chemical treatment portion of this
system, then further estimating that about 50-60 percent of such costs
pertain to galvanizing, aluminizing, alkaline cleaning, and
electrolytic coatings. No further breakdown was attempted, so the
$2.9 million shown covers more operations than is expressed by the
$518,000 model-based estimate.
Plant 476A also uses a large, plant-wide central treatment plant
costing $7.1 million. Problems were encountered in factoring the 2200
GPM treatment facility costs back to the 20 GPM pipe and tube
galvanizing line. Model-based estimates which are based upon separate
treatment are five times higher than apportioned costs where
galvanizing flows were less than one percent of total flows. A
similar situation exists at Plant 0868A, where model-based estimates
are nine times higher than plant-apportioned costs, even though the
446

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total treatment plant costs for Plant 0868A are listed as $4.86
million. Conversely, Plant 0728 costs include a cooling tower
necessary to recycle wastewater to processes other than galvanizing,
while model-based estimates do not require the use of cooling
equipment. However, these were exceptions to generally comparable
actual and estimated investment costs, and overall estimates based on
model treatment systems appear reasonable and accurate. For the two
plants where separate treatment of hot coating wastewaters is
practiced, model-based estimates are higher than plant-reported actual
costs. Based upon the above, the Agency concludes that its model
based cost estimates are sufficiently generous to cover site specific
and retrofit costs for the hot coating subcategory.
Control and Treatment Technology (C&TT)
The range of wastewater treatment technology in use or available for
hot coating line operations is presented in Tables VIII-4 through
VII1-6. In addition to presenting the range of treatment methods
available, these tables also describe for each method:
1.	Status and reliability
2.	Problems and limitations
3.	Implementation time
4.	Land requirements
5.	Environmental impacts other than water
6.	Solid waste generation
Costs associated with the full range of treatment technology including
investment, capital depreciation, operation and maintenance, and
energy and power are presented on water treatment cost tables VII1-7
through VIII-19. Columns on cost tables are identified by letters
corresponding to the appropriate treatment technology identified in
Tables VIII-4 to VIII-6.
Estimated Costs for the
Installation of Pollution Control Technologies
A. Costs Required to Achieve Proposed BPT Limitations
The BPT level of treatment provides for the following control
measures: the blending and equalization of wastes from all
rinsing and scrubbing operations; chromium reduction (if
hexavalent chromium is present); neutralization of all
wastewaters with lime or other suitable alkali; the addition of
polymer with flocculation and settling in a clarifier or
thickener; vacuum filtration of underflow sludges; and continuous
surface skimming for oil removal. All flows from rinsing and
scrubbing operations including fume scrubbing are discharged
once-through following treatment.
Cost estimates for these BPT model treatment systems are provided
in Tables VII1-7 through VII1-9. Using model costs as a basis,
estimates were made of the cost of bringing each hot coating
plant into compliance with the proposed BPT limitations. DCP
data were reviewed to establish in-place components at each hot
447

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coating location. At the same time, the cost of each BPT model
component was calculated, based on the production capacities
reported for each plant. Results of this tabulation are shown in
Tables VIII-20 through VIII-24 for the hot coating subdivisions.
Table VIII-25 summarizes the expenditures which have been made
and which are still necessary to bring all hot coating operations
into compliance with the proposed BPT limitations. The estimated
total cost of compliance for hot coating operations to attain the
proposed BPT limitations is about $36 million. Total annual
operating costs for these systems will be $12.8 million. These
costs are conservative, since they are based only on co-treatment
of hot coating wastewaters at a given site. In actual practice,
most plants combine hot coating wastewaters with those from other
forming and finishing operations for joint treatment. The
economies of scale which result reduce capital investment and
annual operating costs. Also, plants which are currently
achieving zero discharge by internal recycle or reuse will not
need to add those components which would be required for any
plant discharging directly or indirectly.
B.	Costs Required to Achieve the Proposed BAT Limitations
The Agency evaluated three alternative treatment systems to
further reduce toxic pollutant discharges through further
treatment of hot coating wastewaters. All three include cascade
rinsing to minimize flows from the process, and where fume
scrubbers are used, most of the water is recycled through the
scrubber with minimal blowdown to treatment. Due to flow
reductions, the existing BPT treatment system is able to function
more efficiently, achieving lower effluent concentrations. As
alternatives, this BAT effluent may be further treated either by
sulfide precipitation followed by filtration, or by an
evaporation and condensation system designed to produce dry
solids and pure water. This latter alternative produces an
effluent of virtually potable grade, and may be recycled in its
entirety to the hot coating process as final rinsewater, or to
any other use requiring water of such high quality. This
treatment alternative achieves zero discharge of pollutants to
receiving streams, but requires the expenditure of large amounts
of energy and capital. It effectively controls all pollutants
while producing a steady source of pure water.
BAT alternative treatment system costs are provided in Tables
VIII-10 thorugh VIII-12. Refer to Section X for further
discussion of estimated cost impacts and rationale for selecting
the first alternative as the BAT model treatment system. The
total capital cost for all hot coating operations to attain the
proposed BAT limitations is estimated to be $11.2 million
dollars, while annual operating costs will increase by $2.8
million over BPT costs.
C.	Costs Required to Achieve the Proposed BCT Limitations
Table VII1-13 presents the incremental cost per pound for
removing conventional pollutants (total suspended solids and oil
448

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and grease) employing the various BCT alternative treatment
systems. The table included in this section is devoted to costs,
but discussion of its interpretation and the BCT requirement is
provided in Section XI, along with the rationale for selecting
the appropriate BCT alternative treatment system. The capital
and annual costs associated with the proposed BCT limitations are
included in those for BAT.
D.	Costs Required to Achieve the Proposed
New Source Performance Standards (NSPS)
Two NSPS alternative treatment systems are described for hot
coating operations. Both systems are the same as the BAT
alternative treatment systems previously described. Model
capital and annual operating costs are provided in Tables VII1-14
through VI11—16.
E.	Costs Required to Achieve the Proposed Pretreatment Standards
Pretreatment standards apply to those plants discharging to POTW
systems currently or in the future. For new source POTW
dischargers, the proposed PSNS are the same as the proposed NSPS.
For plants currently discharging to POTWs, the Agency considered
two alternative treatment systems which are the same as the BAT
alternative treatment systems. Refer to Model Cost Tables
VIII-17 through VIII-19 for initial capital investments and
annual operating costs for typical plants. The PSES costs on a
subcategory bases are included in the BPT and BAT costs.
Energy Impacts Due to the
Installation of the Requisite Technology
Moderate amounts of energy are required to operate wastewater
treatment systems for hot coating operations. Most of the energy is
consumed in operating the BPT model treatment systems, and many of
these are already in place. It is estimated that BPT model treatment
systems will use approximately 22 million kilowatts of electricity per
year. This is a relatively insignficant portion of the 57 billion
kilowatts used in the steel industry in 1978. Ninety percent of the
electricity needed to operate hot coating treatment systems is
associated with galvanizing lines. Refer to Table VII1-2 for a
breakdown by hot coating subdivisions.
The additional requirements for upgrading BPT treatment systems to BAT
levels are shown in Table VII1-3. Note that two of the three BAT
alternative treatment systems consume very minor additional energy
loads. Only Alternative No. 3, the one involving evaporation
technology, consumes significant additional electricity, enough to
mitigate against its selection as a BAT model treatment system. The
selected BAT model treatment system (No. 1) will not increase energy
consumption over BPT levels.
Energy impacts at NSPS and PSNS levels are slightly less than those at
BPT, since flow reduction steps are incorporated as early as possible
to minimize volumes requiring treatment. The Agency did not, however,
449

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calculate total subcategory impacts for NSPS and PSNS since
predictions of expansion in this subcategory are not included in this
study. Indirect discharger energy consumption is included in that for
BPT and BAT.
Nonwater Quality Impacts
Air Pollution
Air pollution impacts from hot coating treatment systems are minimal.
No cooling towers are required, and the only treatment step which
could potentially affect air quality is the chromium reduction step
required by a few galvanizing lines. Even there, relatively simple
precautions can eliminate the potential for liberating sulfur dioxide,
and well-maintained plants have demonstrated that no air pollution
impact need occur.
BAT Alternative No. 2 would require the addition of sulfide
precipitation as a dissolved metal control, and similar constraints
would need to be applied to insure no release of hydrogen sulfide to
the atmosphere. The use of ferrous sulfide as a sulfide source would
minimize potential impacts from this step. No other air pollution
impacts will result from installation of BAT, NSPS, or the
Pretreatment systems.
Sol id Wastes
The major nonwater quality impact associated with the treatment of
wastewaters from hot coating operations is the generation of metallic
hydroxide sludges during treatment. The BPT level of treatment would
yield 400-500 tons per year of sludge from a typical 800 TPD
galvanizing operation. On a dry weight basis, over 7700 tons of
solids per year are generated by BPT model treatment systems, and an
additional 1700 tons per year result from BAT systems for all hot
coating operations. Contamination from trace amounts of the metals
and from high concentrations of iron reduce the effectiveness of
recovery processes. As a result, most hot coating wastewater
treatment sludges are disposed of at landfills on or off site. Since
some of the sludges are leachable, care must be taken to prevent
redissolving precipitates at the landfill site. Even though metal
hydroxides are relatively insoluble, toxic metal pollutants could find
their way into groundwater or surface streams.
BAT nonwater quality impacts are less severe than those cited for the
BPT model treatment systems, since the bulk of the sludge is generated
at BPT. The sludge characteristics for Alternatives 1 and 2 are
similar to BPT, and the previous discussion on sludge disposal applies
to those two alternatives for each hot coating variation. Alternative
3 converts all remaining pollutants in the effluent from hot coating
into dry solids, but these solids are much more soluble than the metal
hydroxides and sulfides from BPT and BAT Alternatives 1 and 2. The
major solids recovered by Alternative 3 are sulfates, chlorides, and
carbonates, all of which can be readily leached out of open disposal
pits. Prevention of runoff or percolation into subsurface aquifers is
even more important under Alternative 3. Storage areas should have
450

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impervious liners to prevent percolation from the 75-100 additional
tons per year of dry solids generated by Alternative 3 at a typical
800 TPD galvanizing operation. Since these solids are completely
dewatered, and since the metal salts are soluble, consideration can be
given to methods for recovery of metal values by electrolysis,
ion-exchange, or reverse osmosis techniques. A choice of preferred
method from among those available would involve additional research
into the processes, their applicability and economics, but would be an
important step in conservation of resources, especially where critical
metals like chromium are involved.
However, notwithstanding the above, the Agency believes that the
effluent reduction benefits associated with compliance with these
proposed limitations and standards justify any adverse environmental
effects associated with solid waste disposal. Most of the solid
wastes described above are presently being generated and disposed of.
The Agency believes that these wastes can be disposed of properly and
in a safe manner.
Water Consumption
Water consumption caused by BPT model hot coating wastewater treatment
systems is limited to the insignificant evaporation resulting from the
installation of clarifiers or thickeners for removal of suspended
matter. Impacts on water consumption at BAT levels are minimal or
nonexistent. Temperatures are not raised sufficiently, due to
countercurrent or cascade rinsing, or due to scrubber recycle, to
significantly increase losses by evaporation. Hence, the Agency
concludes that there are no significant water consumption impacts
associated with the hot coatings subcategory.
Summary of Impacts
The Agency concludes that the benefits of pollutant control in the hot
coating subcategory described below outweigh any adverse nonwater
quality impacts associated with energy consumption, air pollution,
solid waste disposal, and water consumption:
Effluent Loadings (Tons/Yr)
Raw	Proposed	Proposed
Waste	BPT	BAT & BCT
Flow, MGD 34.7	34.7	7.2
TSS	2,547	1,896	233
Oil and Grease	2,037	569	77.8
Toxic Metals	3,447	335	4.6
Toxic Organics 2.3	1.2	0.1
451

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TABLE VIII-1
EFFLUENT TREATMENT COSTS REPORTED BY SAMPLED PLANTS
HOT COATING - GALVANIZING
Plant
1-2*
MM-2*
NN-2^
111*
112*
116*
118(1)
119*

0856P
0856F
0920E
0612
0396A
01121
0920E
0476A
Initial Investment
14,310
944,270
1,500,930
670,020
509,050
(2)
2,958,000
1,500,930
61,500
Annual Costs








Operating Labor
NR
13,349

20,365

90,500
36,893
1,709
Utilities
NR
42,858
129,423
44,804
30,496
24,000
67,224
1,588
Maintenance
225
18,737

37,987

25,000
67,695
1,128
Depreciation
1,431
94,427
150,093
67,002
50,905
295,800
150,093
6,150
Costs of Capital
615
40,604
64,540
28,811
21,889
127,194
64,540
2,645
Other
136
36,768
-
-
-
8,500
-
2,582
TOTAL
2,407
246,743
344,056
198,969
103,290
570,994
386,445
15,802
$/Ton
0.559
1.376
0.755
2.586
0.933
13.56
1.079
0.980
$/1000 gal trt.
2.54
2.565
0.612
1.835
3.249
20.86
0.906
6.67
(1)	NN-2 and 118 are the same plant. This solo-treated galvanizing operation was sampled during both surveys.
(2)	Plant estimated share of total cost attributed to processes surveyed at this site. Costs include
galvanizing, aluminizing, and alkaline treatment systems on-site.
*: Portion attributed to this subcategory only.
NR: No costs provided by company.

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TABLE VIII-2
ENERGY REQUIREMENTS TO ACHIEVE BPT LIMITS
HOT COATING OPERATIONS
Power	Annual Cost
Required	7/1/78
Process Mode	kw	hg	Dollars
Galvanizing
Strip/Sheet & w/scrubbers	81.4	109	12,700
Misc. Products wo/scrubbers	53.2	71.3	8,300
Wire Products w/scrubbers	44.2	59.3	6,900
& Fasteners wo/scrubbers	25.6	34.3	4,000
Terne Coating
Strip/Sheet w/scrubbers	43. 6	58.5	6,800
wo/scrubbers	30.1	40.4	4,700
Other Coatings
Strip/Sheet & w/scrubbers	57. 7	77.4	9,000
Misc, Products wo/scrubbers	33.3	44. 7	5,200
Wire Products w/scrubbers	10.3	13.8	1,600
& Fasteners wo/scrubbers	7.1	9.5	1,100
453

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TABLE VIII-3
ENERGY REQUIREMENTS TO ACHIEVE BAT LIMITATIONS
HOT COATING OPERATIONS
Power	Annual Cost
Required	7/1/78
Process
Alternative
Mode
kw
h£
Dollars
Galvanizing




Strip/Sheet &
I
w/scrubbers
-
-
-
Miscellaneous Products

wo/scrubbers
-
-
-

II
w/scrubbers
3.8
5.1
600


wo/scrubbers
3.2
4.3
500

III
w/scrubbers
600
805
93,500


wo/scrubbers
448
600
69,900
Wire Products &
I
w/scrubbers
_
—
_
Fas teners

wo/scrubbers
-
-
-

II
w/scrubbers
2.6
3.5
400


wo/scrubbers
1.9
2.5
300

III
w/scrubbers
281
377
43,800


wo/scrubbers
227
304
35,400
Terne Coating





Strip/Sheet
I
w/scrubbers
-
-
-


wo/scrubbers
-
-
-

II
w/scrubbers
2.6
3.5
400


wo/scrubbers
1.9
3.5
300

III
w/ scrubbers
275
369
42,900


wo/scrubbers
205
275
32,000
Other Metal Coatings





Strip/Sheet &
I
w/ scrubbers
-
_
_
Miscellaneous Products

wo/scrubbers
-
-
-

II
w/scrubbers
2.6
3.5
400


wo/scrubbers
2.6
3.5
400

III
w/ scrubbers
374
502
58,400


wo/scrubbers
281
377
43,800
Wire Products &
I
w/scrubbers
_
_

Fasteners

wo/scrubbers
-
-
-

II
w/scrubbers
1.3
1.7
200


wo/scrubbers
1.3
1.7
200

III
w/scrubbers
43.6
58.5
6,800


wo/scrubbers
33.3
44.7
5,100
454

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TABLE VIII-4
CONTROL AND TREATMENT TECHNOLOGY
	HOT (EATING - GALVANIZING
Treatment and/or
Control Methods Employed
A. Blend and equalize flows of
acidic and alkaline wastewaters
Status and
Reliability
Practiced at majority of
treatment plants
B. Add lime or other alkali to pH Widely practiced (77* of all
8-10 ioLi reactor tank with mixing, plants) in this subcategory.
Mr	® 1 _ 			.. «.lJ . 		»»-__	t 1 .L1 		•.	i
(If Cr'v is present, this step
follows Step C.)
C.	If Cr is present, install
chemical redaction system. Pro*
vide sufficient retention time to
reduce all chromios.
D.	Add polymer selected to improve
flocculation and sedimentation.
E.	Add automatic surface skimming
(to thickener-Step P) for recovery
of floating oils.
F.	Install thickeaer or clarifier
to provide efficient settling of
precipitates and other suspended
matter.
Very reliable control.
About 10Z of all plants are
now practicing chroaitm re-
duction.
Nearly 5QX of all plants use
this technology.
Probl ems
and Limitations
Itnpl emen-
tation
Time
Uses up valuable space 2-3
months
Requires high level	6-12
of maintenance and	months
monitoring of treat-
ment process.
Increased chemical and 3-4
instrumentation costs months
are required.
Increased chemical	1-2
costs sre required. months
About 40Z of all plants recover None
floating oils.
Nearly two-thirds of plants
use this technology; very
reliable.
Largest capital cost
equipment in common
use.
2-3
months
6-12
months


Solid Waste

Envi ronmental
Generation and
Land
Impact Other
Primary
Requi renents
Than Water
Constituents
2500 to
Aesthetically
Some solids
10,000 sq.ft.
unappealing
settle out;


<1 ton per


day per plant.
120 to
Sludges which
Metal hydroxide
500 sq.ft.
form are not re-
sludges accumul.

usable; potential
at from 2 to 10

for air pollution
tons per day

while handling
per plant.

lime.

150 to
None
Negligible
600 sq.ft.


100 to
None
Improves sludge
250 sq.ft.

characteristics


Sludge is more


easily de-


watered.
No additional
Minor, since
No impact on
land is re-
the recovered oils
sol id waste
qui red.
are recyclable.
generation.
750 to
Increased
Recovers
5000 sq.ft.
energy conaimp-
sol ids

tion.
generated


at Steps A


and B in the


form of a


slurry with


about 5%


solids.

-------
TABLE VIII-4
CONTROL AND TREATMENT TECHNOLOGIES
HOT COATING - GALVANIZING
PAGE 2		
Treatment and/or
Control Methods Employed
G. Add vacuum filtration of
thickener underflow*; recycle
filtrates to thickener, sludge
to landfill (end-of BPT system).
Status and
Reliability
About 25Z of the plants do
this.
Probl ems
and Limitations
High level of
maintenance is re-
quired for filters.
Implemen-
tation
Time
2-4
months
Environmental
Land	Impact Other
Requi rements Than Water
2 50 to
1000 sq.ft.
Uses more energy.
Sol id Waste
Generation and
Primary
Constituents
Sludges from E
are dewatered
to 30-501 solid
consistency.
Reduces impact
at disposal site.
Ln
H-l. Install cascade rinsing	Less than 10Z of the plants
system to minimise rinsewater flow; cascade rinse, although about
equip fuse hood scrubber to run a third of plants with scrub-
on recycled water, either before bers do recycle to minimise
or after treatment. Slowdown 6-10Z flow discharged,
of flow from scrubber and 25X of
rinsewater applied rate to existing
treatment•
H-2. (For lines with no scrubbers)
Install cascade rinsing system to
reduce flow by 75%. Discharge to
existing treatment system (end of
BAT Alternative 1).
I. Install sulfide precipitation
system to treat dissolved metals.
Iron sulfide system has fewer
problems, and is reco«s ended over
systems using soluble sulfides.
None in hot coating sub-
category, but is used on very
similar wastes in metal
finishing & electroplating.
Scrubber must be	4-6
designed to run on	months
recycled water; cas-
cade rinse system is
installed during mill
shutdown period. Bene-
fits outweigh disad-
vantages .
Soluble sulfide com- 2-4
pounds are unstable & months
difficult to store.
Use FeS.
From no addi- Minimal increase Same as in once-
tional land to in energy require- through system,
50-100 sq.ft. ments.	except that the
depending on	new, longer re-
presence or	tention time
absence of	yields a denser,
scrubbers.	more readily
devat ered
s ludge.
100 to
500 sq.ft.
Potential for
air pollution
from H^S if
soluble sulfides
are used.
Only minor
increase over
BAT Alt. 1
system; sul-
fide precpi-
tates are less
leachable than
hydroxides.
J. Install pressure filter to treat 21Z of all galvanising lines
blowdown from sulfide precipitation now use pressure filtration,
step. Return filter backwash to
thickener (Step F) (end of BAT
Alternative 2).
Higher operating and
maintenance costs.
Benefits outweigh
disadvantages.
6-8
months
200 to
750 sq.ft.
Filter backwash
ends up as part
of load at Step
G.

-------
TABUS VIII-4
CONTROL AND TREAT IE NT TECHNOLOGIES
HOT COATING - GALVANIZING
FACE 3	
Treatment and/or
Control Method* Employed
K. Folliwng Step H-l or H-2t add
an evaporation and condensation
system to produce potable-grade
vater and dry solid*.
L. Install recycle pump station
to convey condensate ftorn Step K
back to process, or other use
where pure water is retired.
(End of BAT Alternative 3).
Status and
Reliability
Not practiced in this
industry. Is done in Other
industries at locations where
pure water is in short supply.
About 15% of the plants
recycle and 20% reuse water
of poorer quality than this
condensate.
Pro bless
and Limitati ens
Very high investmentt
operating. Mainte-
nance and energy costs.
Must have use for the
pure water produced.
None
Implemen
tation
Time
12-18
months
1-2
months
Land
Requirements
4,000-10,000
square feet.
Included in
Step K
Envi ronment al
Impact Other
Than Water
Very high energ
den and.
Solid Waste
Generation and
Primary
Constituents
Converts all
pollutants to
dry solids, many
of which are read
leachable.
None

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TABLE VIII-5
CONTROL AND TREATMENT TECHNOLOGY
	HOT COATING - TERNE 	
Treatment and/or
Control Methods Employed
A. Blend and equalize flowa of
acidic and alkaline wastewaters
Status and
Reliability
Practiced at Majority of
treatment plants
B. Add line or other alkali to pH Practiced at 50Z of all
8*10 in a reactor tank with nixing, plants in this subcategory.
Very reliable control.
Problems
and Limitations
Implemen-
tation	Land
Time Requirements
Uses up valuable space 2-3
months
Requires high level
of maintenance and
monitoring of treat-
ment process.
6-12
months
1,000 to
7,500 sq.ft.
120 to
500 sq.ft.
Envi ronment al
Impact Other
Than Water
Aest het i cal1y
una ppealing
Sludges which
form are not re-
usable; potential
for air pollution
while handling
1 ime.
Sol id Waste
Generation and
Primary
Consti tuents
Some sol ids
settle out;
< 1 ton per
day per pi ant.
Metal hydroxide
sludges accumulate
at from 2 to 10
tons per day
per plant.
C.	Provide for aeration of all
wastewaters via mechanical
agitation or blowers.
D.	Add polymer selected to improve
flocculation and sedimentation.
About 202 of all plants are
now practicing aeration.
Nearly 50Z of all plants use
this technology.
Increased energy	3-4
cons inpt ion to	months
operate equipment.
Increased chemical	1-2
costs are required.	months
150 to
600 sq.ft.
100 to
250 sq.ft.
None
None
Negl igi ble
Improves sludge
characteristics.
Sludge is more
,easi 1 y de-
wate red.
Ul
CD
E.	Add automatic surface skimming
(to thickener-Step F) for recovery
of floating oils.
F.	Install thickener or clarifier
to provide efficient settling of
precipitates and other suspended
matter.
About 40 Z of all plants recover None
floating oils.
Nearly half of plants
use this technology; very
reliable.
Largest capital cost
equipment in coomion
use.
2-3
months
6-12
months
No additional Minor, since	No impact on
land is re- the recovered oils solid waste
quired.	are recyclable. generation.
750 to
5000 sq.ft.
Increas ed
energy consunp-
tion.
Recovers
sol ids
generated
at Steps A
and B in the
f orm of a
slurry with
about 5Z
s olids.

-------
TABLE VIII-5
CONTROL AND TREATMENT TECHNOLOGIES
HOT COATING - TERNE
PAGE 2	
Treatment and/or
Control Mettods Employed
G. Add vacuua filtration of
thickener underflows; recycle
filtrates to thickener, sludge
to landfill (end of BPT systea).
Status and
Reliability
About 202 of the plants do
this.
H-l. Install cascade rinsing
systea to ainisize rinsewater flow;
equip fune hood scrubber to rtsi
on recycled water, either before
or after treatment. Blowdown 8-102
of flow fioa scrubber and 252 of
rinsewater applied rate to existing
treatment.
H-2. (For lines with no scrubbers)
Install cascade rinsing systea to
reduce flow by 752. Discharge to
existing treatment systea (end of
BAT Alternative 1).
Pro bless
and Linitations
High level of
maintenance is re-
quired for filters.
Implemen-
tation	Land
Time Requirements
2-4
months
Less than 102 of the plants
cascade rinse, si though about
a third of plants with scrub-
bers do recycle to ainiaize
flow discharged.
No plants practice
rinse flow reduction.
Technology is trans-
ferable froa gal-
vanizing; all scrubbers
are currently once-
through but could be
recycled as in
galvanising.
4-6
months
Sol id Waste
Environmental	Generation and
Impact Other Primary
	 Than Water Constituents
250 to	Uses more energy. Sludges from E
1000 sq.ft.	are dewatered
to 30-502 solid
consistency.
Reduces impact
at disposal site.
From no addi- Minimal increase Same as in once-
tional land Co in energy require- through system,
50-100 sq.ft. ments.	except that the
depending on	new, longer re-
presence or	tention time
absence of	yields a denser,
scrubbers.	more readily
dewatered
sludge.
4^
Ln
lO
I. Install sulfide precipitation
system to treat dissolved aetsls.
Iron sulfide systea has fewer
probleas, and ia reto—ended over
aysteas using soluble sulfides.
J. Install pressure filter to
treat blowdown froa sulfide
precipitation step. Return filter
backwash to thickener (Step F)
(End of BAT Alternative 2).
Hone in hot coating sub-
cstegory, but is used on very
siailar wastes in aetsl
finishing & electroplating.
No terne lines practice
filtration, but the tech-
nology is readily
transferrable froa other
hot coating operationa.
Soluble sulfide coa- 2-4
pounds are unstable & months
difficult to store.
Use FeS.
Higher operating and 6-6
maintenance costs.	months
Benefits outweigh
disadvantages.
100 to
500 sq.ft.
200 to
750 sq.ft.
Potential for
air pollution
from H^S if
soluble sulfides
are used.
None
Only minor
increase over
BAT Alt. 1
systea; sul-
fide precpi-
tatea are less
leachable than
hydroxides.
Filter backwash
ends up as part
of load at Step
C.

-------
TABLE VIII-5
CONTROL AND TREATMENT TECHNOLOGIES
HOT COATING - TERNE
PAGE 3
Treatment and/or
Control Methods Employed
K. Follivng Step H-l or H-2, add
an evaporation and condensation
system to produce potable-grade
water and dry solids.
L. Install recycle pump station
to convey condensate from Step K
back to process, or other use
where pure water is required.
(End of BAT Alternative 3).
Status and
Reliability
Not practiced in this
industry. Is done in other
industries at locations where
pure water is in short supply.
No teme lines currently
practice recycle. Technology
is transferrable from
galvanising.
Problems
and Limitations
Very high investment,
operating, mainte-
nance and energy costs.
Must have use for the
pure water produced .
None
Impl men-
tation	Land
Time Requirements
12-18
months
1-2
months
4,000-10,000
square feet.
Included in
Step K
Envi ronment al
Impact Other
Than Water
Very high energy
demand.
None
Sol id Waste
Generation and.
Primary
Constituents
Converts all
pollutants to
dry solids, many
of which are read
leachable.
None

-------
TABLE VIII-6
CONTROL AND TREATfCNT TECHNOLOGY
	HOT COATING - OTHER FCTALS
Treatment and/or
Control Methods Employed
A, Blend and equalize flows of
acidic and alkaline wastewaters
Status and
Reliability
Practiced at majority of
treatment plants
B. Add lime or other alkali to pH Practiced at 501 of all
8-10 in a reactor tank with mixing, plants in this subcategory.
Very reliable control.
Probl ems
and Limitations
Requires high level
of maintenance and
monitoring of treat-
ment process.
Impleraen-
tat ion
Time
Uses up valuable space 2-3
months
6-12
months
Land
Requirements
1,000 to
7, 500 sq.ft.
120 to
500 sq.ft.
Envi ronmental
Impact Other
Than Water
Aesthetically
unappealing
Sludges which
form are not re-
usable; potential
for ai r pollution
while handling
1 ime.
Solid Waste
Generation and
Primary
Consti tuents
Some sol ids
settle out;
< I ton per
day per plant.
Metal hydroxide
sludges accumulate
at from 2 to 10
tons per day
per plant.
o\
C.	Provide for aeration of all
wastewaters via mechanical
agitation or blowers.
D.	Add polymer selected to improve
flocculatioo and sedimentation.
E.	Add automatic surface skimming
(to thickener-Step F) for recovery
of floating oils.
F.	Install thickener or clarifier
to provide efficient settling of
precipitates and other suspended
matter.
About 20Z of all plants are
now practicing aeration.
Increased energy	3-4	150 to
consumption to	months 600 sq.ft.
operate equipment.
None
Negligible
Nearly 50% of all plants use
this technology.
Increased chemical
costs are required.
1-2
months
100 to
250 sq.ft.
Hone
Improves sludge
characteristics
Sludge is more
easily de-
watered.
About 40 Z of all plants recover
floating oils.
None
2-3
months
No addi tional
1 and i s re-
qui red.
Minor, since
the recovered oils
are recyclable.
No impact on
sol id waste
generation.
Nearly half of plants
use this technology; very
reliable.
Largest capital cost
equipment in common
use.
6-12
months
750 to
5000 8 q. f t.
Increased
energy consunp*~
tion.
Recovers
sol ids
generated
at Steps A
and B in the
form of a
slurry with
about 52
sol ids.

-------
TABLE VIII-6
CONTROL AHD TREATMENT TECHNOLOGIES
HOT COATING - OTHER METALS
PAGE 2	 	
Treatment and/or
Control Method* Employed
G. Add vacuum filtration of
thickener underflows; recycle
filtrates to thickener, sludge
to landfill (end of BPT system).
Status and
Reliability
About 20Z of the plants
this.
Problems
and Limitations
High level of
maintenance is re-
quired for filters.
Implemen-
t at ion	Land
T ime Requi rement s
2-U
months
2 50 to
1000 sq.ft.
Envi ronment al
Impact Other
Than Water
Uses more energy.
Sol id Waste
Generation arid
Primary
Constituents
Sludges from E
are dewatered
to 30-50% solid
consi stency.
Reduces impact
at disposal site.
H-l. Install cascade rinsing	Less than 102 of the plants
system to minimize rinsewater flow; cascade rinse* although about
equip ftane hood scrubber to run a third of plants with scrub-
on recycled water, either before
or after treatment. Slowdown 8-10%
of flow from scrubber and 252 of
rinaewater applied rate to existing
treatment.
H-2. (For lines with no scrubbers)
Install cascade rinsing system to
reduce flow by 75X. Discharge to
existing treatment system (end of
BAT Alternative 1).
bers do recycle to minimise
flow discharged.
Only one plant	4-6 From no addi-
practices rinse flow	months tional land to
reduction. Technology	50-100 sq.ft.
is transferrable from	gal- depending on
vanising. The only	presence or
scrubber currently	absence of
recycles at a very	scrubbers,
high rate.
Minimal increase
in energy requi re-
Same as in once-
through system,
except that the
new, longer re-
tention time
yields a denser,
more readily
dewatered
s I ud ge.
G\
to
I. Install sulfide precipitation
system to treat dissolved metals.
Iron sulfide system has fewer
problems* and is recommended over
systems using soluble sulfides.
None in hot coating sub-
category, but is used on very
similar waates in metal
finishing & electroplating.
Soluble sulfide com-
pounds are unstable &
difficult to store.
Use FeS.
2-4
months
100 to
500 sq.ft.
Potential for
air pollution
from HjS if
soluble sulfides
are used.
Onl y mi nor
increase over
BAT Alt. 1
system; sul-
fide precpi-
tates are less
leachable than
hydroxides.
J. Install pressure filter to
treat blowdown from sulfide
precipitation step. Return filter
backwash to thickener (Step F)
(End of BAT Alternative 2).
18Z of the plants practice
filtration.
Higier operating and
maintenance costs.
Benefits outweigh
di sad vantages.
6-8
months
200 to
750 sq.ft.
Filter backwash
ends up as part
of load at Step
G.

-------
TABLE VlII-6
CONTROL AND TREATMENT TECHNOLOGIES
HOT COATING - OTffiR METALS
PACE 3		
Treatment and/or
Control Method* Employed
K. Folliwng Step H-l or H-2, add
an evaporation and condensation
system to produce potable-grade
water and dry solids.
L. Install recycle pump station
to convey condensate fro* Step t
back to process, or other use
where pure water is required.
(End of BAT Alternative 3).
Status and
Reliability
Not practiced in this
industry. Is done in other
industries at locations where
pure water is in short supply.
25Z of the plants
currently recycle or reuse
water of poorer quality than
this.
Problems
and Lisiitations
Very high investment,
operating, Mainte-
nance and energy costs.
Must have use for the
pure water produced.
None
Implemen-
taticn	Land
Tiaie Requirements
12-18
months
1-2
months
4,000*10,000
square feet.
Included in
Step K
Environment al
Impact Other
Than Water
Very high energy
demand.
Sol id Waste
Generation and
Primary
Consti toent8
Converts all
pollutants to
dry solids, many
of which are readily
teachable.
None

-------
TABLE VII1-7
BPT MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory
Hot Coating-Galvanizing
Strip/Sheet/Misc. Prod.
With Scrubbers
Model Size-TPD
Oper. Days/Year
Turns/Day
800
260
3
C&TT Steps
A
E
B
A-
154
C
CR
D
FLP
E(1)
SS
pd)
CL
G(l)
VF
Total
-3
Investment $ x 10
228
123
126
11
413
180
1235
Annual Cost $ x 10








Capital
9.8
6.6
5.3
5.4
0.5
17.7
7.7
53.0
Depreciation
22.8
15.4
12.3
12.6
1.1
41.3
18.0
123.5
Operation & Maintenance
8.0
5.4
4.3
4.4
0.4
14.4
6.3
43.2
Sludge Disposal^j
Energy & Power
-
-
-
-
-
-
6.2
6.2
4.7
1.8
0.9
1.3
0.2
1.2
2.6
12.7
Chemical Costs
-
3.6
8.1
7.5
-
-
-
19.2
Oil Disposal
-
-
-
-
0.5
—
-
0.5
TOTAL
45.3
32.8
30.9
31.2
2.7
74.6
40.8
258.3


Raw





Waste



Effluent Quality
Load




Flow, gal/ton
1200
1200
1200 1200 1200 1200 1200
1200 1200

Total Susp. Solids
50
50
250
50

Oil & Grease
40
40
40
15

Hexavalent Chromium
1.0
1.0
1.0
0.02

Dissolved Iron
50
50
2.0
1.0

pH (Units)
2-10
4-8
6-9
6-9
115
Arsenic
0.1
0.1
0.1
0.1
119
Chromium, total
5
5
5
3
120
Copper
1.0
1.0
1.0
0.5
122
Lead
5
5
5
1.0
124
Nickel
0.6
0.6
0.6
0.5
128
Zinc
80
80
80
5
464

-------
TABLE VII1-7
BPT MODEL COST DATA:
PAGE 2
BASIS 7/1/78 DOLLARS
Subcategory:
Hot Coating-Galvanizing

Model Size-
-TPD :
800
•
•
Strip/Sheet/Misc.
Prod.

Oper. Days/Year:
260
•
•
Without Scrubbers


Turns/Day

	3

A
B
C
D
E(1>
F(1)
G(1)
C&TT Steps
E
-4-
CR
FLP
SS
CL
VF
-3
Investment $ x 10 ,
145
112
87
97
9
288
154
Annual Cost $ x 10







Capi tal
6.2
4.8
3.7
4.2
0.4
12.4
6.6
Depreciation
14.5
11.2
8.7
9.7
0.9
28.8
15.4
Operation & Maintenance 5.1
3.9
3.0
3.4
0.3
10.1
5.4
Sludge Disposal..
-
-
-
-
-
-
5.2
Energy & Power
2.3
1.2
0.5
1.0
0.2
0.9
2.2
Chemical Costs
-
1.8
4.1
3.7
-
-
-
Oil Disposal
-
-
-
-
0.5
-
-
TOTAL
28.1
22.9
20.0
22.0
2.3
52.2
34.8
Total
892
38.3
89.2
31.2
5.2
8.3
9.6
0.5
182.3


Raw










Waste








Effluent Quality
Load









Flow, gal/ton
600
600
600
600
600
600
600
600
600

Total Susp. Solids
75
75
450





50

Oil & Grease
60
60
60





15

Hexavalent Chromium
2.0
2.0
2.0





0.02

Dissolved Iron
75
75
2.0





1.0

pH (Units)
2-9
3-8
6-9





6-9
115
Arsenic
0.2
0.2
0.2





0.1
119
Chromium, total
10
10
10





3
120
Copper
2
2
2





0.5
122
Lead
8
8
8





1.0
124
Nickel
1.0
1.0
1.0





0.5
128
Zinc
150
150
150





5
465

-------
TABLE VIII-7
BPT MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE 3	
Subcategory
Hot Coating-Galvanizing
Wire/Wire Products/Fasteners
With Scrubbers
Model Size-TPD
Oper. Days/Year
Turns/Day
100
260
3


B


„(D
„
-------
TABLE VIII-7
BPT MODEL COST DATA:
PAGE 4
BASIS 7/1/78 DOLLARS
Subcategory:
Hot Coating-Galvanizing
Wire/Wire Products/Fasteners
Without Scrubbers
Model Size-TPD : 100
Oper. Days/Year: 260
Turns/Day	: 3

A
B
C
D
E(l)
p(l)
G(l)
C&TT Steps
E

CR
FLP
SS
CL
VF
-3
Investment $ x 10
92
74
62
72
8
202
111
Annual Cost $ x 10







Capital
3.9
3.2
2.7
3.1
0.4
8.7
4.8
Depreciation
9.2
7.4
6.2
7.2
0.8
20.2
11.1
Operation & Maintenance
3.2
2.6
2.2
2.5
0.3
7.1
3.9
Sludge Disposal , .
Energy and Power
-
-
-
-
-
-
1.8
1.2
0.6
0.2
0.4
0.1
0.6
0.9
Chemical Costs
-
0.9
2.0
1.9
-
-
-
Oil Disposal
-
-
-
-
0.1
-
-
TOTAL
17.5
14.7
13.3
15.1
1.7
36.6
22.5
Total
621
26.8
62.1
21.8
1.8
4.0
4.8
0.1
121.4


Raw





Waste



Effluent Quality
Load




Flow, gal/ton
2400
2400
2400 2400 2400 2400 2400
2400 2400

Total Susp. Solids
150
150
300
50

Oil & Grease
40
40
40
15

Hexavalent Chromium
1.0
1.0
1.0
0.02

Dissolved Iron
75
75
2.0
1.0

pH (Units)
3-9
4-8
6-9
6-9
115
Arsenic
0.2
0.2
0.2
0.1
119
Chromium, total
2.5
2.5
2.5
1.0
120
Copper
0.8
0.8
0.8
0.4
122
Lead
2.0
2.0
2.0
1.0
124
Nickel
0.5
0.5
0.5
0.2
128
Zinc
35
35
35
5
(1)	Components in tandem.
(2)	Costs are all power.
(3)	mg/1 unless specified.
KEY TO C&TT STEPS
D : Polymer Addition
E : Oil Skimming
F : Clarifier
G : Vacuum Filter
A: Equalization
B: Adjust pH to 6-9 with lime
C: Chemical Reduction
467

-------
TABLE VIII-8
BPT MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory: Hot Coating-Terne
: Strip/Sheet
: With Scrubbers
Model Size-TPD : 365
Oper. Days/Year: 260
Turns/Day	: 3

A
B
C
D
C&TT Steps
E
-Sl-
AE
FLP
_3
Investment $ * 10 ,
143
110
100
95
Annual Cost $ x 10




Capital
6.1
4.7
4.3
4.1
Depreciation
14.3
11.0
10.0
9.5
Operation & Maintenance
5.0
3.8
'3.5
3.3
Sludge Disposal . .
Energy and Power
-
-
-
-
2.3
0.9
0.9
0.8
Chemical Costs
-
1.7
-
3.4
Oil Disposal
-
-
-
-
TOTAL
27.7
22.1
18.7
21.1
,<1) „
-------
TABLE VIII-8
BPT MODEL COST DATA:
PAGE 2
BASIS 7/1/78 DOLLARS
Subcategory
Hot Coating-Terne
Strip/Sheet
Without Scrubbers
Model Size-TPD
Oper. Days/Year
Turns/Day
365
260
C&TT Steps
A
E
L-
C
AE
D
FLP
S<1)
SS
?(1)
CL
3(1)
VF
Investment $ x 10
91
74
69
72
8
187
111
Annual Cost $ x 10







Capital
3.9
3.2
3.0
3.1
0.4
8.1
4.8
Depreciation
9.1
7.4
6.9
7.2
0.8
18.7
11.1
Operation & Maintenance
3.2
2.6
2.4
2.5
0.3
6.6
3.9
Sludge Disposal , .
Energy and Power
-
-
-
-
-
-
1.2
1.2
0.6
0.9
0.4
0.1
0.6
0.9
Chemical Costs
-
0.8
-
1.7
-
-
-
Oil Disposal
-
-
-
-
0.1
-
-
TOTAL
17.4
14.6
13.2
14.9
1.7
34.0
21.9
Total
612
26.5
61.2
21.5
1.2
4.7
2.5
0.1
Effluent Quality^^
Raw
Waste
Load



Flow, gal/ton
600
600
600

Total Susp. Solids
75
75
200

Oil & Grease
40
40
40

Hexavalent Chromium
0.04
0.03
0.03

Dissolved Iron
75
75
2.0

Tin
10
10
10

pH (Units)
3-9
4-8
6-9
115
Arsenic
0.1
0.1
0.1
118
Cadmium
0.1
0.1
0.1
119
Chromium, total
5
5
5
120
Coppe r
1.0
1.0
1.0
122
Lead
1.0
1.0
1.0
124
Nickel
2.0
2.0
2.0
128
Zinc
2.0
2.0
2.0
600
600
600
600
600
600
50
15
0.02
1.0
5
6-9
0.1
0.1
2
0.3
0.5
0.4
0.5
(1)	Components in tandem.
(2)	Costs are all power.
(3)	mg/1 unless specified.
KEY TO C&TT STEPS
A: Equalization
B: Adjust pH to 6-9 with lime
C: Aeration
D :	Polymer Addition
E :	Oil Skimming
F :	Clarifier
G :	Vacuum Filter
469

-------
TABLE VII1-9
BPT MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory
Hot Coating-Other Metallic Coatings
Strip/Sheet/Misc. Products
With Scrubbers
Model Size-TPD : 500
Oper. Days/Year: 260
Turns/Day	: 2

A
B
C
D
E(1>
F(1>
GU)

C&TT Steps
E
-A-
AE
FLP
SS
CL
VF
Total
—3
Investment $ x 10
223
142
165
123
11
396
180
1240
Annual Cost $ x 10~







Capital
9.6
6.1
7.1
5.3
0.5
17.0
7.7
53.3
Depreciation
22.3
14.2
16.5
12.3
1.1
39.6
18.0
124.0
Operation & Maintenance
7.8
5.0
5.8
4.3
0.4
13.8
6.3
43.4
Sludge Disposal ,-v
Energy and Power
-
-
-
-
-
-
4.8
4.8
3.1
1.2
1.5
0.9
0.2
0.8
1.3
9.0
Chemical Costs
-
2.3
-
4.7
-
-
-
7.0
Oil Disposal
-
-
-
-
0.5
-
-
0.5
TOTAL
42.8
28.8
30.9
27.5
2.7
71.2
38.1
242.0
Ef£luent Quality^
Raw
Waste
Load



Flow, gal/ton
1200
1200
1200

Total Susp. Solids
250
250
320

Oil & Grease
50
50
50

Hexavalent Chromium
0.02
0.02
0.02

Dissovled Iron
20
20
2.0

Tin
5
5
5

Aluminum
25
25
25

pH (Units)
5-9
5-9
6-9
115
Arsenic
0.1
0.1
0.1
118
Cadmium
2.0
2.0
2.0
119
Chromium, total
0.2
0.2
0.2
120
Copper
0.5
0.5
0.5
122
Lead
1.5
1.5
1.5
124
Nickel
0.5
0.5
0.5
128
Zinc
5
5-
5
1200 1200 1200 1200
1200
1200
50
15
0.02
1.0
3
5
6-9
0.1
0.5
0.2
0.3
0.5
0.3
3
470

-------
TABLE VIII-9
BPT MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE 2		
Subcategory: Hoc Coating-Other Metallic Coatings
: Strip/Sheet/Misc. Products
: Without Scrubbers
Model Size-TPD : 500
Oper. Days/Year: 260
Turns /Day	: 	2
C&TT Steps
Investment $ x 10
-3
.-3
Annual Cost $ x 10
Capital
Depreciation
Operation & Maintenance
Sludge Disposal
Energy and Power
Chemical Costs
Oil Disposal
TOTAL
Raw
(3)	w"te
Effluent Quality 		Load
Flow, gal/ton	600
Total Suap. Solids	400
Oil & Grease	60
Hexavalent Chromium 0.02
Dissolved Iron	30
Tin	8
Aluminum	30
pH (Units)	4-10
115 Arsenic	0.1
118	Cadmium	4.0
119	Chromium, total	0.2
120	Copper	1.0
122 Lead	2.5
124 Nickel	0.5
128 Zinc	8
A
B
C
D
E
A-
AE
FLP
142
97
101
94
6.1
4.2
4.3
4.0
14.2
9.7
10.1
9.4
5.0
3.4
3.5
3.3
1.6
0.5
0.6
0.5
•
1.1
•
2.3
26.9
18.9
18.5
19.5
600
600
600
600
400
500


60
60


0.02
0.02


30
2.0


8
8


30
30


5-9
6-9


0.1
0.1


4.0
4.0


0.2
0.2


1.0
1.0


2.5
2.5


0.5
0.5


8
8


600
G(1)
VF Total
175 890
7.5 38.2
17.5 89.0
6.1 31.2
3.7 3.7
1.3 5.2
3.4
0.3
36.1 171.0
600
600
50
15
0.02
1.0
3
5
6-9
0.1
0.5
0.2
0.3
0.5
0.3
3
471

-------
TABLE VIlt-9
BPT MODEL COST DATA:
PAGE 3
BASIS 7/1/78 DOLLARS
Subcategory
Hot Coating-Other Metallic Coatings
Wire/Wire Products/Fasteners
With Scrubbers
Model Size-TPD
Oper. Days/Year
Turns/Day
JJ5
260
2


A
B
C
D
E(1>
i(1>
G(i)

C&TT Steps

E
nl
AE
FLP
SS
CL
VF
Total
_3
Investment $ x 10 __

55
48
51
49
8
122
80
413
Annual Cost $ x 10








Capital

2.3
2.1
2.2
2.1
0.3
5.2
3.4
17.6
Depreciation

5.5
4.8
5.1
4.9
0.8
12.2
8.0
41.3
Operation & Maintenance

1.9
1.7
1.8
1.7
0.3
4.3
2.8
14.5
Sludge Disposal ...

-
-
-
-
-
-
0.3
0.3
Energy and Power

0.4
0.2
0.4
0.2
-
0.2
0.2
1.6
Chemical Costs

-
0.2
-
0.5
-
-
-
0.7
Oil Disposal

-
-
-
—
—
—
-

TOTAL

10.1
9.0
9.5
9.4
1.4
21.9
14.7
76.0

Raw








( *\
Waste








Effluent Quality
Load








Flow, gal/ton
3900
3900
3900
3900
3900
3900
3900
3900
3900
Total Susp. Solids
100
100
150





50
Oil & Grease
25
25
25





15
Hexavalent Chromium
0.02
0.02
0.02





0.02
Dissolved Iron
12
12
2.0





1.0
Tin
3
3
3





3
Aluminum
12
12
12





5
pH (Units)
5-9
5-9
6-9





6-9
115 Arsenic
0.1
0.1
0.1





0.1
118 Cadmium
1.0
1.0
1.0





0.5
119 Chromium, total
0.8
0.8
0.8





0.5
120 Copper
0.3
0.3
0.3





0.3
122 Lead
1.0
1.0
1.0





0.5
124 Nickel
0.3
0.3
0.3





0.3
128 Zinc
3
3
3





3
472

-------
TABLE VIII-9
BPT MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE 4	
Subcategory: Hot Coating-Other Metallic Coatings	Model Size-TPD
: Wire/Wire Products/Fasteners	Oper. Days/Year
: Without Scrubbers	Turns/Day
15
260
2

A
B
C
D
E(1)
p(l)
G(l)

C&TT Steps
E

AE
FLP
SS
CL
VF
Total
-3
Investment $ x 10 __
41
36
41
39
8
97
79
341
Annual Cost $ x 10








Capital
1.7
1.6
1.8
1.7
0.3
4.1
3.4
14.6
Depreciation
4.1
3.6
4.1
3.9
0.8
9.7
7.9
34.1
Operation & Maintenance
1.4
1.3
1.4
1.4
0.3
3.4
2.8
12.0
Sludge Disposal .
-
-
-
-
-
-
0.3
0.3
Energy & Power
0.2
0.2
0.2
0.1
-
0.2
0.2
1.1
Chemical Costs
-
0.1
-
0.3
-
-
-
0.4
Oil Disposal
TOTAL
7.4
6.8
7.5
7.4
1.4
17.4
14.6 62.5


Raw




/ O \
Waste



Effluent Quality
Load




Flow, gal/ton
2400
2400
2400 2400 2400 2400 2400
2400 2400

Total Susp. Solids
150
150
300
50

Oil & Grease
40
40
40
15

Hexavalent Chromium
0.03
0.03
0.03
0.02

Dissolved Iron
25
25
2.0
1.0

Tin
5
5
5
3

Aluminum
25
25
25
5

pH (Units)
5-9
5-9
6-9
6-9
115
Arsenic
0.1
0.1
0.1
0.1
118
Cadmium
2.0
2.0
2.0
0.5
119
Chromium, total
1.0
1.0
1.0
0.5
120
Copper
0.5
0.5
0.5
0.3
122
Lead
1.5
1.5
1.5
0.5
124
Nickel
0.5
0.5
0.5
0.3
128
Zinc
5
5
5
3
(1)	Components in tandem.
(2)	Costs are all power.
(3)	mg/1 unless specified.
KEY TO C&TT STEPS
A: Equalization	D	:	Polymer Addition
B: Adjust pH to 6-9 with lime	E	:	Oil Skimming
C: Aeration	F	:	Clarifier
G	:	Vacuum Filter
473

-------
TABLE VIII-10
BAT MODEL COST DATA; BASIS 7/1/78 DOLLARS
Subcategory: Hot Coating-Galvanizing Model Sise-TPD :	800
: Strip/Sheet/Misc.Products Oper. Days/Year:	260
: With Scrubbers Turns/Day : 3
vj
C&TT Step
Alt.
. 1

Alt. 2


Alt.
3

H-l
Total
H-l
l(l)
JU)
Total
H-l
K
L
Total

FHR;CC

FHR;CC
PS
FP

FHR;CC
EVC
RTP100

_3
Investment $ x 10 .
265
265
265
28
135
428
265
2448
36
2749
Annual Cost $ x 10










Capital
11.4
11.4
11.4
1.2
5.8
18.4
11.4
105.3
1.6
118.3
Depreciation
26.5
26.5
26.5
2.8
13.5
42.8
26.5
244.8
3.6
274.9
Operation & Maintenance
9.3
9.3
9.3
1.0
4.7
15.0
9.3
85.7
1.3
96.3
Sludge Disposal..
Energy & Power
"l.7<4)
_
~1.7<4)
0.1
0.5
0.6
"l.7(4)
93.5
0.6(4)
93.5
Chemical Costs
-
-
"
0.7
-
0.7
-
-

-
Replacement Parts
24.7
24.7
24.7
-
-
24.7
24.7
-
-
24.7
TOTAL
71.9(4)
71.9
71.9(4)
5.8
24.5
102.2
71.9(4>
529.3
6.5(4>
607.7
Effluent Quality^
Flow, gal/too
Total Suap. Solids
Oil k Grease
Hexavalent Chromium
Dissolved Iron
pH, Units
115	Arsenic
119	Chroain, Total
120	Copper
122	Lead
124	Nickel
126	Zinc
BAT
Feed
Quality
1200
50
IS
0.02
1.0
6-9
0.1
3
0.5
1.0
0.5
5
200
30
5
0.02
0.2
6-9
0.1
0.1
0.1
0.1
0.2
0.1
200
15
5
0.02
0.3
6-9
0.1
0.1
0.1
0.1
0.1
0.1

-------
TABU Vlll-10
BAT MODEL COST DATA: BASIS 7/1/78 DOLLARS
FASE2	
Subcategory: Hoc Coating-Galvanizing Model Sise-TPD : 800
: Strip/Sheet/Miac.Products Oper. Days/Tear: 260
: Ho Scrubbers	Turns/Day	: 	3
C&TT Step

Alt.
. 1

Alt. 2


Alt.
3

H-2
Total
H-2
I<1)
J(1>
Total
H-2
K
L
Total


CC

CC
PS
FP

CC
EVC
RTF100

-3
Investment $ x 10 «

188
188
188
28
117
333
188
2277
36
2501
Annual Coat $ x 10











Cap!tal

8.1
8.1
8.1
1.2
5.0
14.3
8.1
97.9
1.5
107.5
Depreciation

18.8
18.8
18.8
2.8
11.7
33.3
18.8
227.7
3.6
250.1
Operation i Maintenance

6.6
6.6
6.6
1.0
4.1
11.7
65.6
79.7
1.2
87.5
Sludge Disposal..

-
-
-
-
-
-
-
-
(4)
-
Energy 6 Power

-
-
-
0.1
0.4
0.5
-
69.9
0.6
69.9
Cheaical Costs

-
-
-
0.5
-
0.5
-
-
-
-
Replacement Parts

24.7
24.7
24.7
-
-
24.7
24.7
-
-
24.7
TOTAL

58.2
58.2
$8.2
5.6
21.2
85.0
58.2
475.2
6.3<«>
539.7

BAT










(3)
Effluent Quality
Feed










Quality










Flow, gal/ton
600

150



150



0
Total Susp. Solids
50

30



15



-
Oil & Grease
15

5



5



-
Hexavalent Chroniua
0.02

0.02



0.02



-
Dissolved Iron
1.0

0.5



0.3



-
pR, Units
6-9

6-9



6-9




11S Arsenic
0.1

0.1



0.1



-
119 Chroaiua, Total
3

0.1



0.1



"
120 Copper
0.5

0.1



0.1




122 Lead
1.0

0.1



0.1



-
124 Nickel
0.5

0.2



0.1



-
128 Zinc
5

0.1



0.1





-------
TABLE VII1-10
BAT MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE 3		
Subcategory: Hot Co«tiig-GilT»iiiiag	Model Sise-TPD : 100
t Wire/Hire Product»/F«»tener* Oper. Days/Year: 260


: With Scrubbers


Turns/Day
s 3





Alt.
. 1

Alt. 2


Alt.
3

C&TT Step

H-l
Total
H-l
I<1)

Total
H-l
K
L
Total


FHK;CC

FHR;CC
PS
pp

FBK;CC
EVC
RTF100

Inreabaenc $ x 10 ^.

108
108
108
25
104
237
108
2027
29
2164
Annual Goat $ x 10











Capital

4.6
4.6
4.6
1.1
4.5
10.2
4.6
87.1
1.2
92.9
Depreciation

10.8
10.8
10.8
2.5
10.4
23.7
10.8
202.7
2.9
216.4
Operation & Maintenance

3.8
3.8
3.8
0.9
3.6
8.3
3.8
70.8
1.0
75.7
Sludge Dispoaal..
Energy i Power

~0.6(4)
:
"o.6(4)
0.1
0.3
0.4
~0.6<*>
43.8
0.2(4)
43.8
Chcaical Coat*

-
-
-
0.3
-
0.3

-
-
-
Replacement Parts

7.1
7.1
7.1
-
-
7.1
7.1
—
-
7.1
TOTAL

26.3<*>
26.3
26.3(4)
4.9
18.8
50.0
26.3<*>
404.5
5.1(4)
435.9

BAT










Effluent 0uality(3)
Feed










Quality










Plow, gal/ton
3900

750



750



0
Total Snap. Solid*
SO

30



15



-
Oil i Creaae
IS

5



5



-
Hexaralent Chroaiun
0.02

0.02



0.02



-
Dissolved Iron
1.0

0.2



0.2



-
pH, Unit*
6-9

6-9



6-9



-
1IS Arsenic
0.1

0.1



0.1



-
119 Chrasiua, Total
1.0

0.1



0.1



-
120 Copper
0.4

0.1



0.1



-
122 Lead
1.0

0.1



0.1



-
124 Nickel
0.2

0.2



0.1



-
128 Zinc
5

0.1



0.1



-

-------
BAT MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE 4	
Subcategory: Hot Coating-Galvanising Model Sise-TPD : 100
: Hire/Hire Products/Fasteners Oper. Days/Year: 260
: Ho Scrubbers	Turns/Day	: 	3
Ale. 1	.	Alt. 2	Alt. 3
C4TT Step

H-2
Total
H-2
l(l)

Total
H-2
K
L
Total


CC

CC
PS
FP

CC
ETC
RTP100

Inreltaent } x 10 '

54
54
54
23
97
174
54
1920
26
2000
Annual Coat $ z 10











Capital

2.3
2.3
2.3
1.0
4.2
7.5
2.3
82.6
1.1
86.0
Depreciation

5.4
5.4
5.4
2.3
9.7
17.4
5.4
192.0
2.6
200.0
Operation i Maintenance

1.9
1.9
1.9
0.8
3.4
6.1
1.9
67.2
0.9
70.0
Sludge Disposal..

-
-
-
-
-
-
-
-
(4)
-
Energy & Power

-
-
-
0.1
0.2
0.3
-
35.4
0.2V '
35.4
Cheaiical Coats

-
-
-
0.3
-
0.3
-
-
-
-
Replacement Parte

7.1
7.1
7.1
-
-
7.1
7.1
-
-
7.1
TOTAL

16.7
16.7
16.7
4.5
17.5
38.7
16.7
377.2
4.6U)
398.5

BAT










Effluent Quality^
Feed










Quality










Flow, gal/ton
2400

600



600



0
Total Suap. Solida
50

30



15



-
Oil 1 Creaae
15

5



5



-
Hexavalent Chraaiua
0.02

0.02



0.02



-
Diaaolved Iron
1.0

0.2



0.2



-
pB, Units
6-9

6-9



6-9



-
115 Arsenic
0.1

0.1



0.1



_
119 Chroaiiaa, Total
1.0

0.1



0.1



-
120 Copper
0.5

0.1



0.1



-
122 Lead
1.0

0.1



0.1



-
124 Nickel
0.2

0.2



0.1



-
128 Zinc
5

0.1



0.1



-
(1)	Components used in tandem
(2)	Coat* are all power
(3)	aig/1 unless specified
(4)	Total coat does not include power, because a credit is applied for existing process water needs.
KEY TO CfcTT STEPS
I:	Precipitation with sulfide
J:	Filtration
K:	Install vapor coapression/evaporation system
L:	Recycle distillate t-o process
H-l: Install counter current or cascade rinae systea
Recycle fuse hood scrubber with 8-101 blowdown
H-2: Install counter-current or cascade rinse systesi

-------
TABLE VIII-11
BAT MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory: Hot Coating-Terne Model Size-TPD : 365
: Strip/Sheet Oper. Days/Tear: 260
: With Scrubbers	Turns/Day	I 	3
Alt. 1		Alt. 2	 	Alt. 3
C&TT Step
H-l
Total
H-l
t(l)
J(1>
Total
H-l
K
L
Total

FHR;CC

FHR;CC
PS
FP

FHR;CC
EVC
STP100

Imreataent $ i 10 ^
1S7
187
187
25
104
316
187
2016
29
2232
Annual Coat $ x 10










Capital
8.0
8.0
8.0
l.l
4.5
13.6
8.0
86.7
1.2
95.9
Depreciation
18.7
18.7
18.7
2.5
10.4
31.6
18.7
201.6
2.9
223.2
Operation 6 Maintenance
6.5
6.5
6.5
0.9
3.6
11.0
6.5
70.6
1.0
78.1
Sludge Diapoaal ...
Energy and Power
0>>
_
0.9*4*
0.1
0.3
0.4
0>>
42.9
0.2(4)
42.9
Cheaical Coat*
-
-

0.3
-
0.3

-
-
-
Replacement Parta
15.5
15.5
15.5
-
-
15.5
15.5
-
-
15.5
TOTAL
48.7(4>
48.7
48.7(4>
4.9
18.8
72.4
48.7(4)
401.8
5.1(4>
455.6

BAT



Effluent Quality*3*
Peed
Quality



Flow, gal/ton
1200
200
200
0
Total Soap. Solida
50
30
15
-
Oil 6 Greaae
15
5
5
-
Hexavalent Chrnita
0.02
0.02
0.02
-
Diasolved Iron
1.0
0.2
0.2
-
Tin
5
3
0.1
-
pH (Units)
6-9
6-9
6-9
~
115 Araenic
0.1
0.1
0.1
"
118 Cadaiua
0.1
0.1
0.1

119 Chrcaiua, total
2
0.1
0.1
-
120 Copper
0.3
0.1
0.1
-
122 Lead
0.5
0.1
0.1
—
124 Hickel
0.4
0.2
0.1
-
128 Zinc
0.5
0.1
0.1
-

-------
TABLE VIII-U
BAT MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE 2	
Subcategory: Hot Coating-Terae
: Strip/Sheet
: Without Scrubber*
Model Size-TPD : 365
Oper. Days/Year: 260
Turns/Day	: 3
CttT Step
Alt.
1

Alt. 2


Alt.
3

H-2
Total
H-2
id)

Total
H-2
t
L
Total

CC

CC
PS
FP

CC
ETC
RTF100

Inveataent $ x 10"^,
117
117
1X7
22
87
226
117
1874
26
2017
Annual Coat $ x 10










Capital
5.0
5.0
5.0
1.0
3.7
9.7
5.0
80.6
1.1
86.7
Depreciation
11.7
11.7
11.7
2.2
8.7
22.6
li.7
187.4
2.6
201.7
Operation 4 Maintenance
4.1
4.1
4.1
0.8
3.0
7.9
4.1
65.6
0.9
70.6
Sludge Diapoaal ...
-
-
-
-
-
-
-
-

-
Energy and Power
-
-
-
0.1
0.2
0.3
-
32.0
0.2
32.0
Choaical Coata
-
-
-
0.2
-
0.2
-
-
-
-
¦eplaceaent Fart*
15.5
15.5
15.5
-
-
15.5
15.5
-
-
15.5
TOTAL
36.3
36.3
36.3
4.3
15.6
56.2
36.3
365.6
4.6(4>
406.5

BAT



effluent Quality"1
Feed
quality



Flow, gal/toa
600
150
150
0
Total Soap. Solid*
50
30
15
-
Oil t Creaae
15
5
5
-
Bcxavalent Chroaita*
0.02
0.02
0.02
-
Diaaolved Iroa
1.0
0.2
0.2
-
Tin
5
3
0.1
-
p> (Onita)
6-9
6-9
6-9
-
115 Araeaic
0.1
0.1
0.1
-
11S Cadaiiua
0.1
0.1
0.1
-
119 Chroaiw, total
2
0.1
0.1
-
120 Copper
0.3
0.1
0.1
-
122 Lewi
0.5
0.1
0.1
-
124 Miekel
0.4
0.2
0.1
-
128 Zinc
0.5
O.l
0.1
-
(1)	Component* used ia ttndea.
(2)	Costs are all power.
(3)	R|/l unless specified.
(4)	Total coat does not include power, becauae a credit ia applied for existing process water needs.
KEY TO C&TT STEPS
B-li Install counter current or caacade rinse syaten
Recycle f«e hood scrubber with 8-1QX blovdown
H-2i lostall counter-current or caacade rinse syatea
1:	Precipitation wieh sulfide
J:	Filtration
K:	Install vapor compression/evaporation systen
L:	Recycle distillate to process

-------
TABLE VIII-12
BAT MODEL COST DATA; BASIS	7/1/78 DOLLARS
Subcategory: Hot Coating-Other Netala	Model Size-TPD :	500
: Strip/Sheet/Mise. Products	Oper. Days/Tear:	260
s With Scrubbera	Turns/Day : 	2
Alt. 1		Alt. 2	 	Alt. 3
CiTT Step
H-l
Total
H-l
I>
-
i:2(4>
0.1
0.3
0.4
1>>
58.4
o>>
58.4
Chemical Costs
-
"
-
0.4
-
0.4
-
-
"
-
Replacement Parts
18.7
18.7
18.7
-
-
18.7
18.7
-
"
18.7
TOTAL
57.7(A)
57.7<*>
57.7(*>
5.1
24.3
87.1
57.7(4)
487.2
6.5(4)
551.4

BAT



Effluent Quality^
Feed



Quality



Flow, gal/ton
1200
200
200
0
Total Susp. Solids
50
30
15
-
Oil & Grease
15
5
5
-
Hexavalent Chromium
0.02
0.02
0.02
-
Dissolved Iron
1.0
0.2
0.2
-
Tin
3
1.5
0.1
-
Aluminum
5
2.5
0.1
-
pH (Units)
6-9
6-9
6-9
-
115 Arsenic
0.1
0.1
0.1
-
118 Cataium
0.5
0.1
0.1
-
119 Chromium, total
0.2
0.1
0.1
-
120 Copper
0.3
0.1
0.1
-
122 Lead
0.5
0.1
0.1
-
124 Nickel
0.3
0.2
0.1
-
128 Zinc
3
0.1
0.1
-

-------
TABLE Till-12
BAT MODEL COST DATA: BASIS 7/1/7B DOLLARS
FACE 2
Subcategory: Rot Coating-Other Metallic Coating*
: Strip/Sheet/Nisc. Product*
: Without Scrubber*
C4TT Step
laveataent $ x 10~\
Aanual Coat 9 i 10
Capital
Depreciation
Operation fc Maintenance
Sludge Diapoaal ...
Energy and Power
Ckcaical Coats
Keplaceaent Coata
TOTAL
Alt. 1		
H-2	Total	8-2
CC	CC
141	141	141
6.1	6.1	6.1
14.1	14.1	14.1
4.9	4.9	4.9
18.7	18.7	18.7
43.8	43.8	43.8


BAT

Kffluent Quality^
Feed
Quality


Plow, gal/ton
600
150

Total Soap. Solida
50
30

Oil t Creaae
15
5

Bexavalent Chrcaitn
0.02
0.02

Diaaolved iron
1.0
0.2

Tin
3
1.5

Altaian
5
2.5

pH (Unita)
6-9
6-9
115
Araenic
0.1
0.1
118
Cacfciua
0.5
0.1
119
Chroaioa, total
0.2
0.1
120
Copper
0.3
0.1
122
Lead
0.5
0.1
124
Rickel
0.3
0.2
128
Zinc
3
0.1
Model Size-TFD : 500
Oper. Daya/Tear: 260
Turns/Day		2
Alt. 2	 	Alt. 3
1°>
,(1)
Total
H-2
K
L
Total
PS
rr

CC
EVC
rrpioo

25
117
283
141
2242
36
2419
1.1
5.0
12.2
6.1
96.4
1.5
104.0
2.5
11.7
28.3
14.1
224.2
3.6
241.9
0.9
4.1
9.9
4.9
78.5
1.2
84.6
0.1
0.3
0.4
-
43.8
0>>
43.8
0.3
-
0.3
-
-
-
-
-
-
18.7
18.7
-

18.7
4.9
21.1
69.8
43.8
442.9
6.3<*>
493.0
ISO	0
15
5
0.02
0.2
0.1
0.1
6-9
0.1
0.1
0.1
0.1
0.1
0.1
0.1

-------
TABLE VIII-12
BAT MODEL COST DATA; BASIS 7/1/7B DOLLARS
PACE 3	
Subcategory: Hot Coating-Other Metallic Coatings
Wire/Wire Products/Fasteners
: With Scrubbers
C4TT Step
Investment ? i 10 ,
Annual Cost $ x 10
Capital
Depreciation
Operation 4 Maintenance
Sledge Disposal ...
Eaergy and Power
Cli—ical Costs
Replacement Parts
TOTAL
Alt. 1
H-l
Total
H-l
FHR;CC

FHRjCC
51
51
51
2.2
2.2
2.2
5.)
5.1
5.1
1.6
1.8
1.8
0:,«>
-
0.1(4)
2.3
2.3
2.3
11.4<*>
11.4<4'
11.4<4)


BAT

KMUrat Ou«lity(3)
Feed
Quality


riov, gal/toa
3900
750

Total Suap. Solida
50
30

Oil 6 Graaac
15
5

Hexavalent Chroaiuai
0.02
0.02

Dissolved Iron
1.0
0.2

Tin
3
1.5

AluBima.
5
2.5

pH (Units)
6-9
6-9
115
Araenic
0.1
0.1
118
Cadaiua
0.5
0.1
119
Chroaiua, total
0.5
0.1
120
Copper
0.3
0.1
122
Lead
0.5
0.1
124
Nickel
0.3
0.2
128
Zinc
3
0.1
Model Sise-TPD ; 15
Oper. Days/Year: 260
Turns/Day	: 2
Alt. 2			Alt.	3	
i(o jd) Total	H_j	K	L	Tottl
PS FP	FHB;CC	tVC	rrpioo
19 61 131	SI	1404	20	147S
O.a 2.6 5.6	2.2	60.4	0.8	63.4
1.9 6.1 13.1	5.1	140.4	2.0	147.5
0.7 2.1 4.6	1.8	49.1	0.7	51.6
0.1 0.1 0.2	0.1(4) 6.8	0.1«>	6.8
0.1 0.1 -
2.3	2.3 -	-	2.3
3.6 10.9 25.9	11.4(*'	256.7	3.5<4)	271.6
750
15
5
0.02
0.2
0.1
0.1
6-9
0.1
0.1
0.1
0.1
0.1
0.1
0.1

-------
TABU VIII-12
BAT MOOKL COST HUt BASIS 7/1/78 MLLAM
PACE 4	
Subcategory: Hot Coating-Other Metallic Coating* Model Sise-TFD : 15
: Vire/Vire Producta/Fastenera Oper. Daya/Year: 260
: Ho Scrubbera	Turns/Day	: 	2
Alt. 1
Alt. 2
Alt. 3
CfcTT Step
B-2
Total
H-2
i«>
j(l)
Total
H-2
K
L
Total

CC

CC
PS
PP

CC
EVC
RTF100

Investment $ x 10
17
17
17
19
57
93
17
1306
19
1342
Annul Coit $ * 10










Capital
0.7
0.7
0.7
O.S
2.4
3.9
0.7
56.2
0.8
57.7
Depreciation
1.7
1.7
1.7
1.9
5.7
9.3
1.7
130.6
1.9
134.2
Operation 6 Maintenance
0.6
0.6
0.6
0.7
2.0
3.3
0.6
45.7
0.7
47.0
Sludge Diapoeal.v
-
-
-
-
-
-
-
-

-
Energy ft Power
-
-
-
0.1
0.1
0.2
-
5.1
0.1U}
5.1
Cheaieal Coat*
-
-
-
0.1
-
0.1
-
-
-
-
fteplaceaent Perta
2.3
2.3
2.3
-
-
2.3
2.3
-
-
2.3
TOTAL
5.3
5.3
5.3
3.6
10.2
19.1
5.3
237.6
3.4<*>
246.3
oo
CJ
Effluent Qualitr^^
Flow, gal/ton
Total Snap. Solida
Oil 4 Grease
Hexavalent Chraaiia
Dieeolved Iron
Tie
Aluainua
pB, Unita
US Arsenic
118	Cadaiua
119	Chroaiua, Total
120	Copper
122 Lead
124 Nickel
128 Zinc
MX
Feed
OwlitT
2400
SO
IS
0.02
1.0
3
5
6-9
0.1
O.S
O.S
0.3
O.S
0.3
3
600
30
S
0.02
0.2
1.5
2.5
6-9
0.1
0.1
0.1
0.1
0.1
0.2
0.1
600
15
5
0.02
0.2
0.1
0.1
6-9
0.1
0.1
0.1
0.1
0.1
0.1
0.1
(1)	Coaponents used in tandea.
(2)	Costs are all power.
(3)	ag/1 unless specified.
(4)	Total coat does not include power, because a credit is applied for existing process
water needs.
KEY TO C4TT STEPS
H-l: Inatall countercurrent or caacade rinae system
Recycle fuse bood scrubber water with 8-10Z blowdown
H-2s Install countercurrent or caacade rinse sytoa
I. Precipitation with sulfide
J: Filtration
K: Install vapor compression/evaporation ayatea
L: kecycle distillate to proceas

-------
TABLE VIII-13
RESULTS OF BCT COST TEST
HOT COATING-GALVANIZING
Strip/Sheet
Wire Prod.


Misc.
Prod.
& Fasteners
A. BAT/BCT Feed

w/scrub
no scrub
w/ scrub
no scrub
Effluent concentration -
conventional pollutants
65
65
65
65
Flows in MGD

0.96
0.48
0.39
0.24
Days/Year

260
260
260
260
lbs/Year of conventional
pollutants
135,310
67,655
54,970
33,830
B. BCT-1





Effluent concentration -
conventional pollutants
35
35
35
35
Flows in MGD

0.16
0.12
0.075
0.060
Days/Year

260
260
260
260
lbs/Year of conventional
pollutants
12,145
9110
5690
4555
lbs/Year of conventional
pollutants




removed by treatment

123,165
58,545
49,280
29,275
Annual cost of BCT-1($)

71,900
58,200
26,300
16,700
$/lb of conventional pollutants removed
0.58
0.99
0.53
0.57
Pass/Fail

Pass
Pass
Pass
Pass
C. BCT-2^





Effluent concentration -
conventional pollutants
20
20
20
20
Flows in MGD

0.16
0.12
0.075
0.060
Days/Year

260
260
260
260
lbs/Year of conventional
pollutants
6940
5205
3255
2600
lbs/Year of conventional
pollutants




removed by treatment

128,370
62,450
51,715
31,230
Annual Cost of BCT-2($)

96,400
79,400
45,100
34,200
$/lb of conventional pollutants removed
0.75
1.27
0.87
1.10
Pass/Fail

Pass
Pas 8
Pass
Pass
484

-------
TABLE VIII-13
RESULTS OF BCT COST TEST
HOT COATING-TERNE
PAGE 2
A. BAT/BCT Feed
Strip/Sheet/Miscellaneous Products Only
With Scrubbers	No Scrubbers
Effluent concentration - conventional
pollutants
Flows in MGD
Days/Year
lbs/year of conventional pollutants
B. BCT-1
Effluent concentration - conventional
pollutants
Flows in MGD
Days/Year
lbs/year of conventional pollutants
lbs/year of conventional pollutants
removed by treatment
Annual Cost of BCT-1($)
$/lb of conventional removed
Pass/Fail
C. BCT-2
(2)
Effluent concentration - conventional
pollutants
Flow in MGD
Days/Year
lbs/year of conventional pollutants
lbs/year of conventional pollutants
removed by treatment
Annual Cost of BCT-2
$/lb of conventional pollutants removed
Pass/Fail
65
0.438
260
61,735
35
0.073
260
5,540
56,195
48,700
0.87
Pass
20
0.073
260
3,165
58,570
67,500
1.15
Pass
65
0.219
260
30,865
35
0.055
260
4,175
26,690
36,300
1.36
Fail
20
0.055
260
2,385
28,480
51,900
1.82
Fail
485

-------
TABLE VIII-13
RESULTS OF BCT COST TEST
HOT COATING-OTHER METALS
PAGE 3
A.	BAT /BCI Feed
Effluent concentration - conventional
pollutants
Flows in MGD
Days/Year
lbs/year of conventional pollutants
B.	BCT-1(3)
Effluent concentration - conventional
pollutant8
Flows in MGD
Days/Year
lbs/year of conventional pollutants
lbs/year of conventional pollutants
removed by treatment
Annual Cost of BCT-1($)
$/lb of conventional pollutants removed
Pass/Fail
BCT-2
(4)
Effluent concentration - conventional
pollutants
Flows in MGD
Days/Year
lbs/year of conventional pollutants
lbs/year of conventional pollutants
removed by treatment
Annual Cost of BCT-2($)
$/lb of conventional pollutants removed
Pass/Fail
Strip/Sheet
Wire
Prod.
Misc.
Prod.
& Fasteners
w/scrub
no scrub
w/ scrub
no scrub
65
65
65
65
0.600
0.300
0.0585
0.0360
260
260
260
260
84,570
42,285
8,245
5,075
35
35
35
35
0.100
0.075
0.0113
0.0090
260
260
260
260
7,590
5,690
860
685
76,980
36,595
7,385
4,390
57,700
43,800
11,400
5,300
0.75
1.20
1.54
1.21
Pass
Pas 8
Fail
Pass
20
20
20
20
0.100
0.075
0.0113
0.0090
260
260
260
260
4,335
3,255
490
390
80,235
39,030
7,755
4,685
82,000
64,900
22,300
15,500
1.02
1.66
2.88
3.31
Pass
Fail
Fail
Fail
(1)	Selected BCT Alternative.
(2)	Selected BCT Alternative for lines with scrubbers only. Lines with no
scrubbers have BCT limitations based on BPT.
(3)	Selected BCT Alternative for lines with no scrubbers only.
(4)	Selected BCT Alternative for strip, sheet and miscellaneous product lines
with scrubbers only. Wire product and fastener lines with scrubbers have
BCT limitations based on BPT.
486

-------
TABLE VII1-14
USPS MID PSHS MODEL COST DATA: EASIS 7/1/78 DOLLARS
Subcategory: Hot Coating-Galvanizing Model Sixe-TPD : 800
: Strip/Sheet/Mi*c. Product Opet. Days/Year: 260
: With Scrubber*	Turns/Day I 	3
Alternative #1
Alternative >2
00
-J
Effluent Quality'3''
Hast*
Load

Flow, gal/ton
1200

Suspended Solida
SO

Oil and Create
40

Hexavaleot Chroaiua
1.0

Dissolved Iron
so

pB (Units)
2-10
11S
Arsenic
O.i
119
Chroaiua
3
120
Copper
1.0
122
Lead
5
124
Nickel
0.6
128
Zinc
80
200
30
5
0.02
0.2
6-9
0.1
0.1
0.1
0.1
0.2
0.1
CiTT Steps
A
B
C
D
E
r
£1

I
Total

^U)
Total
Investment ) » 10 '
188
172
116
93
95
8
312
136
77
1197
28
135
1360
Annual Cost $ * 10













Capital
8.1
7.4
5.0
4.0
4.1
0.4
13.4
5.8
3.5
51.5
1.2
5.8
58.5
Depreciation
18.8
17.2
11.6
9.3
9.5
0.8
31.2
13.6
7-7
119.7
2.8
13.5
136.0
Operation and Maintenance
6.6
6.0
4.1
3.2
3.3
0.3
10.9
4.8
2.7
41.9
1.0
4.7
47.6
Sludge Disposal . .
Energy end Power
-
-
-
-
-
-
-
6.2
-
6.2
-
-
6.2
-
3.0
1.2
0.6
0.8
0.2
0.8
1.7
1.7
10.0
0.1
0.5
10.6
Cheaical Costs
-
-
2.4
5.1
4.7
-
-
-
-
12.2
0.7
-
12.9
Oil Disposal
-
-
-
-
-
0.5
-
-
-
0.5
-
-
0.5
Expendable Part*
24.7
-
-
-
-
-
-
-
-
24.7
-
-
24.7
TOTAL
58.2
33.6
24.3
22.2
22.4
2.2
56.3
32.1
15.4
266.7
5.8
24.5
297.0
200
13
5
0.02
0.2
6-9
0.1
0.1
0.1
0.1
0.1
0.1

-------
TABLE V1II-14
NSPS AND PSNS MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE 2
Subcategory: Hot Coating—Galvanizing Model Size-TPD : 800
: Strip/Sheet/Misc. Product Oper. Days/Tear: 260
: Without Scrubbers	Turns/Day	: 	3
Alternative #1
Alternative #2
C&TT Steps
A
B
C
D
E
F
G^
hU>
Total
J(1)
R(I>
Total
Investment $ x 10
188
63
49
38
42
4
125
67
576
28
117
721
Annual Cost $ x 10












Capital
8.1
2.7
2.1
1.6
1.8
0.2
5.4
2.9
24.8
1.2
5.0
31.0
Depreciation
18.8
6.3
4.9
3.8
4.2
0.4
12.5
6.7
57.6
2.8
11.7
72.1
Operation and Maintenance
6.6
2.2
1.7
1.3
1.5
0.1
4.4
2.3
20.1
1.0
4.1
25.2
Sludge Disposal . .
Energy and Power
-
-
-
-
-
-
-
5.2
5.2
-
-
5.2
-
1.2
0.5
0.3
0.4
0.1
0.3
0.7
3.5
0.1
0.4
4.0
Chemical Coats
-
-
0.9
2.1
1.9
-
-
-
4.9
0.5
-
5.4
Oil Disposal
-
-
-
-
-
0.5
-
-
0.5
-
-
0.5
Expendable Parts
24.7
-
-
—
-
-
-
-
24.7
-
-
24.7
TOTAL
58.2
12.4
10.1
9.1
9.8
1.3
22.6
17.8
141.3
5.6
21.2
168.1
00
00
Effluent Quality^'
Raw
Haste
Load

Flow, gal/ton
600

Suspended Solids
75

Oil and Grease
60

Hexavalent Chroaiua
2.0

Dissolved Iron
75

pR (Units)
2-9
115
Arsenic
0.2
119
Chroaiua
10
120
Copper
2
122
Lead
8
124
Nickel
1.0
128
Zinc
150
150
30
5
0.02
0.2
6-9
0.1
0.1
0.1
0.1
0.2
0.1
150
15
5
0.02
0.2
6-9
0.1
0.1
0.1
0.1
0.1
0.1

-------
TABLE VIII-14
USPS AMD PSMS MODEL COST DATA: BASIS 7/1/78 DOLLARS
PACT 3	
Subcategory: Hot Coating-Galvanizing
: Wire Products and Fasteners
: With Scrubbers
-3
CtTT Steps
Investment $ x 10
Annual Cose ) i 1(
Capital
Depreciation
Operation and Maintenance
Sludge Disposal
Energy and Power
Chenical Costs
Oil Disposal
Expendable Parts
TOTAL
A
34
2.3
5.4
1.9
7.1
16.7
B
92
3.9
9.2
3.2
1.3
17.6
C
68
2.9
6.8
2.4
0.5
0.9
13.5
D
56
2.4
5.6
2.0
0.3
1.8
12.1
03
ID
Effluent Quality*3)
Plow, gal/ton
Suspended Solids
Oil and Crease
Hexavalent Chroaiun
Dissolved Iron
pH (Units)
115 Arsenic
119	Chronica
120	Copper
122 Lead
124 Rickel
128 Zinc
Rav
Waste
Load
3900
100
25
0.5
40
3-9
0.1
1.0
0.4
1.0
0.2
20
Model Size-TPD : 100
Oper. Days/Tear: 260
Turns/Day	s 	3
Alternative #1 	 	 		Alternative #2
g
F

H(l)
I
Total

*
Total
62
6
178
99
54
669
25
104
798
2.7
0.3
7.6
4.3
2.3
28.7
1.1
4.5
34.3
6.2
0.6
17.8
9.9
5.4
66.9
2.5
10.4
79.8
2.2
0.2
6.2
3.4
1.9
23.4
0.9
3.6
27.9
-
-
-
2.5
-
2.5
-
-
2.5
0.4
0.1
0.5
1.0
0.6
4.7
0.1
0.3
5.1
1.7
-
-
-
-
4.4
0.3
-
4.7
-
0.1
-
*
-
0.1
-
-
0.1
-
-
-

-
7.1
-
-
7.1
13.2
1.3
32.1
21.1
10.2
137.8
4.9
18.8
161.5
750	750
30	15
5	5
0.02	0.02
0.2	0.2
6-9	6-9
0.1	0.1
0.1	0.1
0.1	0.1
0.1	0.1
0.2	0.1
0.1	0.1

-------
TABLE VIII-14
USPS AMD PSNS MODEL COST DATA: BASIS 7/1 /78 DOLLARS
PACE 4
Subcategory: Hot Coating-Galvanizing	Model Sixe-TPD : 100
: Wire Products and Fasteners	Oper. Days/Year: 260
: Without Scrubbers	Turns/Day	: 3
Alternative #1		Alternative #2
C4TT Steps
A
B
C
D
E
F
ciil

Total


Total
Investment $ x 10 *
54
40
32
27
31
3
88
48
323
23
97
443
Annual Cost $ x 10












Capital
2.3
1.7
1.4
1.2
1.3
0.1
3.8
2.1
13.9
1.0
4.2
19.1
Depreciation
5.4
4.0
3.2
2.7
3.1
0.3
8.8
4.8
32.3
2.3
9.7
44.3
Operation and Maintenance
1.9
1.4
1.1
0.9
1.1
0.1
3.1
1.7
11.3
0.8
3.4
15.5
Sludge Disposal ( .
-
-
-
-
-
-
-
1.8
1.8
-
-
1.8
Energy and Power
-
0.3
0.2
0.1
0.1
0.1
0.2
0.3
1.3
0.1
0.2
1.6
Cheaical Coats
-
-
0.3
0.5
0.5
-
-
-
1.3
0.3
-
1.6
Oil Disposal
-
-
-
-
-
0.1
-
-
0.1
-
-
0.1
Expendable Parts
7.1
-
-
-
-
-
-
-
7.1
-
-
7.1
TOTAL
16.7
7.4
6.2
5.4
6.1
0.7
15.9
10.7
69.1
4.5
17.5
91.1
<£>
O
(3)
Effluent Quality
Raw
Waste
Load

Flov, gal/ton
2400

Suspended Solids
150

Oil and Create
40

Hexavalent Chroaiua
1.0

Dissolved Iron
75

pH (Units)
3-9
115
Arsenic
0.2
119
Chroaiua
2.5
120
Copper
0.8
122
Lead
2.0
124
Nickel
0.5
128
Zinc
35
600
30
5
0.02
0.2
6-9
0.1
0.1
0.1
0.1
0.2
0.1
600
15
5
0.02
0.2
6-9
0.1
0.1
0.1
0.1
0.1
0.1
(1)	Components are used in tandea.
(2)	Costs ere all power.
(3)	All values are in ag/1 unless otherwise specified.
KEY TO C4TT STEPS
A:
Install cascade or counter-current rinse systesi.
F:
Oil Skinming
B:
Equalisation
G:
Flocculator/Clari fier
C:
Adjust pH to 6-9 with lise
H:
Vacuum filtration of thickener underflow
D:
Chemical Reduction
I:
Recycle fuse hood scrubber waters, with 8-10Z blowdown
E:
Polymer Addition
J:
Precipitation with sulfide


K:
Filtration

-------
TABLE VI1I-15
MSPS AND PSWS HODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory:
Hot Coating-Terne
Strip/Sheet
With Scrubbers
Model Size-TPD
Oper. Days/Year
Turns/Day
365
260
3
Alternative #1
Alternative #2
A
VO
Effluent 0uality(3)
Plow, gal/ton
Suspended Solid*
Oil and Great*
Hexavalent Chroaiu
Dissolved Iron
Tin
pit (Units)
US Arsenic
118	Cadaiia
119	Cbroaiua
120	Copper
122 Lead
124 Nickel
128 Zinc
taw
Haste
Load
1200
50
25
0.02
50
5
3-9
0.1
0.1
3
0.5
0.5
0.8
1.0
200
30
5
0.02
0.2
3
6-9
0.1
0.1
0.1
0.1
0.1
0.2
0.1
C&TT Step*
A
B
C
D
E
F
C<*>
sill
I
Total
ii11
eIH
Total
Investment 5 x 10 '
117
108
83
75
72
6
206
82
70
819
25
104
948
Annual Cost $ x 10













Capital
5.0
4.6
3.6
3.2
3.1
0.3
8.9
3.5
3.0
35.2
1.1
4.5
40.8
Depreciation
11.7
10.8
8.3
7.5
7.2
0.6
20.6
8.2
7.0
81.9
2.5
10.4
94.8
Operation and Maintenance
4.1
3.8
2.9
2.6
2.5
0.2
7.2
2.9
2.5
28.7
0.9
3.6
33.2
Sludge Disposal
-
-
-
-
-
-
-
1.9
-
1.9
-
-
1.9
Energy and Power
-
1.5
0.6
0.6
0.5
0.1
0.6
0.6
0.9
5.4
0.1
0.3
5.8
Cheaical Costs
-
-
1.1
-
2.2
-
-
-
-
3.3
0.3
-
3.6
Oil Disposal
-
-
-
-
-
0.1
-
-
-
0.1
-
-
0.1
Expendable Parts
15.5
-
-
-
-
-
-
-
-
15.5
-

15.5
TOTAL
36.3
20.7
16.5
13.9
15.5
1.3
37.3
17.1
13.4
172.0
4.9
18.8
195.7
200
15
5
0.02
0.2
0.1
6-9
0.1
0.1
0.1
0.1
0.1
0.1
0.1

-------
TABLE VIII-15
USPS AND PSNS MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE 2
Subcategory
Rot Coating-Terne
Strip/Sheet
Without Scrubbers
Model Size-TPD
Oper. Days/Year
Turns/Day
365
260
3
Alternative #1
Alternative #2
C4TT Steps
A
B
C
D
E
F

^O)
Total

^U)
Total
Investment $ x 10 \
117
40
32
30
31
3
81
48
382
22
87
491
Annual Coat $ * 10












Capital
5.0
1.7
1.4
1.3
1.3
0.1
3.5
2.1
16.4
10
3.7
21.t
Depreciation
11.7
4.0
3.2
3.0
3.1
0.3
8.1
4.8
38.2
2.2
8.7
49.1
Operation and Maintenance
4.1
1.4
1.1
1.1
1.1
0.1
2.8
1.7
13.4
0.8
3.0
17.2
Sludge Disposal - .
Energy and Power
-
-
-
-
-
-
-
1.2
1 2
-
-
1.2
-
0.3
0.2
0.3
0.1
0.1
0.2
0.3
1.5
0.1
0.2
1.8
Chemical Coats
-
-
0.2
-
0.5
-
-
-
0.7
0.2
-
0.9
Oil Disposal
-
-
-
-
-
0.1
-
-
0.1
-
-
0.1
Expendable Parts
15.5
-

-
-
-
-
-
15.5
-
-
15.5
TOTAL
36.3
7.4
6.1
5.7
6.1
0.7
14.6
10.1
87.0
4.3
15.6
106.9


Raw




Waste


( 3 J
Effluent Quality
Load



Flow, gal/ton
600
150
150

Suspended Solids
75
30
15

Oil and Greaae
40
5
5

Heuvilent Chrosiia
0.04
0.02
0.02

Dissolved Iron
75
0.2
0.2

Tin
10
3
0.1

pH (Units)
3-9
6-9
6-9
115
Arsenic
0.1
0.1
0.1
lie
Cadmium
0.1
0.1
0.1
119
Chromium
5
0.1
0.1
120
Copper
1.0
0.1
0.1
122
Lead
1.0
0.1
0.1
124
Nickel
2.0
0.2
0.1
128
Zinc
2.0
0.1
0.1
(1)	Components are used in tandem.
(2)	Coats are all power.
(3)	All values are in mg/1 unless otherwise specified.
KEY TO C4TT STEPS
A:
Install cascade or counter-current rinse system.
F:
Oil Skimming
B:
Equalisation
G:
Flocculator/Clari fier
Cs
Adjust pH to 6-9 with lime
H:
Vacuimi filtration of thickener underflow
D:
Aeration
I:
Recycle fume hood scrubber waters, with 8-10Z blowdovn
E:
Polymer Addition
J:
Precipitation with sulfide


K:
Fi1tration

-------
TABLE VIII-16
USPS MODEL COST DATA; BASIS 7/1/78 DOLLARS
Subcategory: Hot Coating-Other Metallic Coatings Model Size-TFD :	500
: Strip/Sbeet/Misc. Products Oper. Days/Year:	260
s With Scrubbers	Turns/Day	: 	2
Alternative #1
Alternative #2
u>
Effluent Quality^
Flow, gal/ton
Suspended Solids
Oil and Crease
Hexavalent Chroni
Dissolved Iron
Tin
Altainia
pH (Onits)
115 Arsenic
118	Cadai.ua
119	Chrosiiua
120	Copper
122	Lead
124	Hickel
128 Zinc
Raw
Haste
Load
1200
250
50
0.02
20
5
25
5-9
0.1
2.0
0.2
0.5
1.5
0.5
5
200
30
5
0.02
0.2
1.5
2.5
6-9
0.1
0.1
0.1
0.1
0.1
0.2
0.1
C&TT Steps
A
B
C
D
E
F
G(1)
H(1)
I

Total
J(1>
K(1)
Total
_3
Investment $ * 10 __
141
168
107
124
93
8
299
136
78

1154
26
135
1315
Annual Cost $ x 10














Capital
6.1
7.1
4.6
5.3
4.0
0.3
12.8
5.8
3.
.4
49.6
1.1
5.8
56.5
Depreciation
14.1
16.8
10.7
12.4
9.3
0.8
29.9
13.6
7,
,8
115.4
2.6
13.5
131.5
Operation and Maintenance
4.9
5.9
3.7
4.3
3.3
0.3
10.5
4.8
2.
.7
40.4
0.9
4.7
46.0
Sludge Disposal
Energy and Power
-
-
-
-
-
-
-
4.8


4.8
-
-
4.8
-
2.0
0.8
1.0
0.6
0.2
0.5
0.9
1.
.2
7.2
0.1
0.3
7.6
Cheaical Costs
-
-
1.5
-
3.0
-
-
-


4.5
0.4
-
4.9
Oil Disposal
-
-
-
-
-
0.5
-
-


0.5
-
-
0.5
Expendable Parts
18.7
-
-
-
-
-
-



18.7
-
-
18.7
TOTAL
43.8
31.9
21.3
23.0
20.2
2.1
53.8
29.9
15.
1
241.1
5.1
24.3
270.5
200
15
5
0.02
0.2
0.1
0.1
6-9
0.1
0.1
0.1
0.1
0.1
0.1
0.1

-------
NSPS AND PSNS MODEL COST DATA: BASIS 7/1/78 DOLLARS
PACE 2
Subcategory: Hot Coating-Other Metallic Coating	Model Siie-TPD
: Strip/Sheet/Misc. Products	Oper. Days/Tear
: Without Scrubbers	Turns/Day
500
260
2
Alternative #1		Alternative #2
C&TT Steps
A
B
C
D
E
F


Total
J(1)
^(1)
Total
Investswnc $ x 10 '
141
62
42
44
41
3
119
76
528
25
117
670
Annual Cost $ x 10












Capital
6.1
2.7
1.8
1.9
1.7
0.1
5.1
3.3
22.7
1.1
5.0
28.8
Depreciation
14.1
6.2
4.2
4.4
4.1
0.3
11.9
7.6
52.8
2.5
11.7
67.0
Operation and Maintenance
4.9
2.2
1.5
1.5
1.4
0.1
4.2
2.7
18.5
0.9
4.1
23.5
Sludge Disposal , .
-
-
-
-
-
-
-
3.7
3.7
-
-
3.7
Energy and Power
-
0.4
0.2
0.2
0.2
0.1
0.2
0.4
1.7
0.1
0.3
2.1
Cheaical Costs
-
-
0.3
-
0.6
-
-
-
0.9
0.3
-
1.2
Oil Disposal
-
-
-
-
-
0.3
-
-
0.3
-
-
0.3
Expendable Parts
18.7
-

-
—
-
—
-
18.7
—
—
18.7
TOTAL
43.8
11.5
8.0
8.0
8.0
0.9
21.4
17.7
119.3
4.9
21.1
145.3
VO
Effluent Quality^^
Flow, gal/ton
Suspended Solids
Oil and Crease
Hexavalent Chroaiua
Diasolved Iron
Tin
Aluainus
pH (Units)
115 Arsenic
118	Cadaiua
119	Chraaiiat
120	Copper
122	Lead
124	Nickel
128	Zinc
Raw
Haste
Load
600
400
60
0.02
30
8
30
4-10
0.1
4.0
0.2
1.0
2.5
0.5
8
150
30
5
0.02
0.2
1.5
2.5 •
6-9
0.1
0.1
0.1
0.1
0.1
0.2
0.1
150
15
5
0.02
0.2
0.1
0.1
6-9
0.1
0.1
0.1
0.1
0.1
0.1
0.1

-------
TABLE VIII-16
NSFS AMD PS US MODEL COST DATA: BASIS 7/1/78 DOLLARS
PACE 3
Subcategory: Hot Coating-Other Metallic Coating	Model Siie-TPD
: Nire Products and Fasteners	Oper. Days/Year
: With Scrubbers	Turns/Day
15
260
2
Alternative #1
Alternative tl
C4TT Steps
A
B
C
D
E
F
G<»
H(l)
I
Total

R(l)
Total
_3
Investment $ i 10,
17
38
33
35
34
6
84
55
34
336
19
61
416
Annual Cost $ z 10













Capital
0.7
1.6
1.4
1.5
1.5
0.3
3.6
2.4
1.5
14.5
0.8
2.6
17.9
Depreciation
1.7
3.8
3.3
3.5
3.4
0.6
8.4
5.5
3.4
33.6
1.9
6.1
41.6
Operation and Maintenance
0.6
1.3
1.2
1.2
1.2
0.2
3.0
1.9
1.2
11.8
0.7
2.1
14.6
Sludge Disposal ...
-
-
-
-
-
-
-
0.3
-
0.3
-
-
0.3
Energy and Power
-
0.3
0.2
0.3
0.2
0.1
0.2
0.2
0.1
1.6
0.1
0.1
1.8
Cheaical Costs
-
-
0.2
-
0.3
-
-
-
-
0.5
0.1
-
0.6
Oil Disposal
-
-
-
-
-
0.1
-
-
-
0.1
-
-
0.1
Expendable Parts
2.3
-
-
-
-
-
-
-
-
2.3
-
-
2.3
TOTAL
5.3
7.0
6.3
6.5
6.6
1.3
15.2
10.3
6.2
64.7
3.6
10.9
79.2
ft
l£>
in
EffliMBt 0ualitr(3>
Raw
Waste
Load

Plow, gal/ton
3900

Suspended Solids
100

Oil and Crease
25

Hexavalent Chroaiua
0.02

Dissolved Iron
12

Tin
3

Alusimas
12

pi (Units)
5-9
115
Arsenic
0.1
118
Cadaiusi
1.0
119
Chroaitai
0.8
120
Copper
0.3
122
Lead
1.0
124
Nickel
0.3
128
Zinc
3
750
30
5
0.02
0.2
1.5
2.5
6-9
0.1
0.1
0.1
0.1
0.1
0.2
0.1
750
15
5
0.02
0.2
0.1
0.1
6-9
0.1
0.1
0.1
0.1
0.1
0.1
0.1

-------
TABLE VIII- 16
NSPS AND PSNS MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE 4
Subcategory
Hot Coating-Other Metallic Coating	Model Size-TPD :
Wire Products and Fasteners	Oper. Days/Year:
Without Scrubbers	Turns/Day	:
15
260
2




Alternative #1





Alternative
#2
C&TT Steps
A
B
C
D
E
F

"ill
To tal
iii!
Kill
To ta]
Investment $ x 10 \
17
18
16
18
17
3
42
34
165
19
57

241
Annual Cost § x 10














Capital
0. 7
0.8
0.7
0.8
0. 7
0.1
1.8
1.5
7.
1
0.8
2.
,5
10.4
Depreciation
1.7
1.8
1.6
1.8
1.7
0.3
4.2
3.4
16.
3
1.9
5.
7
24.1
Operation and Maintenance
0.6
0.6
0.6
0.6
0.6
0.1
1.5
1.2
5.
8
0.7
2 .
.0
8.5
Sludge Disposal
Energy and Power
-
-
-
-
-
-
-
0.3
0.
3
-


0.3
-
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.
7
0.1
0,
.1
0.9
Chemical Costs
-
-
0.1
-
0.1
-
-
-
0-
2
0.1


0. 3
Oil Disposal
-
-
-
-
-
0.1
-
-
0.
1
-


0. 1
Expendable Parts
2.3
-
-
-
-
-
-
-
2 .
3
•
-

2.3
TOTAL
5.3
3.3
3.1
3.3
3.2
0. 7
7.6
6. 5
33.
0
3.6
10.
.3
46.9
•U
v£>
0>
Effluent Quality^^
Flow, gal/ton
Suspended Solids
Oil and Grease
Hexavalent Chromium
Dissolved Iron
Tin
Aluminuai
pH (Units)
115 Arsenic
118	Cadm i\m
119	Chroaiw
120	Copper
122 Lead
124 Nickel
128 Zinc
Raw
Waste
Load
2400
150
40
0.03
25
5
25
5-9
0.1
2 .0
1 .0
0.5
1.5
0.5
5
600
30
5
0.02
0.2
1.5
2-5
6-9
0. 1
0. 1
0.1
0.1
0.1
0.2
0.1
60O
15
5
0.02
0.2
0.1
0.1
6-9
0.1
0.1
0.1
0.1
0.1
G. 1
0.1
(1)	Components are used in tandem.
(2)	Costs are all power.
(3)	All values are in mg/1 unless otherwise specified.
KEY TO C&TT STEPS
A:
Install cascade or counter-current rinse system.
F:
Oil Skinning
B:
Equalization
C:
Flocculator/Clari fier
C:
Adjust pH to 6-9 with lime
H:
Vacuum filtration of thickener underflow
D:
Aeration
Is
Recycle fume hood scrubber waters, with 8-10Z blowdown
E:
Polyner Addition
J:
Precipitation with sulfide


K:
Filtration

-------
TABLE VIII-17
PSKS MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory: Hot Coating-Galvanixing	Model Size-TPD : 800
: Strip/Sheet/Miac. Product	Oper. Daya/Year: 260
: With Scrubber*	Turns/Day	: 3
Alternative #1
Alternative #2
vo
Effluent Quality*3'
lav
Haste
Load

Flow, gal/ton
1200

Suspended Solid*
50

Oil and Creaae
40

Hexavalent Chroaiua
1.0

Dissolved Iron
50

pH (Units)
2-10
US
Arsenic
0.1
119
Chroaiua
5
120
Copper
1.0
122
Lead
5
124
Hickel
0.6
128
Zinc
80
200
30
5
0.02
0.2
6-9
0.1
0.1
0.1
0.1
0.2
0.1
C4TT Steps
A
»
C
D
E
P
c<*>
£1
I
Total


Total
Investment $ x 10 '
188
172
116
93
95
8
312
136
77
1197
28
135
1360
Annual Coat $ x 10













Capital
8.1
7.4
5.0
4.0
4.1
0.4
13.4
5.8
3.3
51.5
1.2
5.8
58.5
Depreciation
18.8
17.2
11.6
9.3
9.5
0.8
31.2
13.6
7.7
119.7
2.8
13.5
136.0
Operation and Maintenance
6.6
6.0
4.1
32
3.3
0.3
10.9
4.8
2.7
41.9
1.0
4.7
47.6
Sludge Disposal . .
Energy and Power
-
-
-
-
-
-
-
6.2
1~.7W
6.2
-
-
6.2
-
3.0
1.2
0.6
0.8
0.2
0.8
1.7
8.3
0.1
0.5
8.9
Chesucal Coses
-
-
2.4
5.1
4.7
-
-
-
-
12.2
0.7
-
12.9
Oil Disposal
-
-
-
-
-
0.5
-
-
-
0.5
-
-
0.5
Expendable Parts
24.7
-
—
-
—
—
—
—
_
24.7
-
-
24.7
TOTAL
S8.2
33.6
24.3
22.2
22.4
2.2
56.3
32.1
13.7<*>
265.0
5.8
24.5
295.3
200
15
5
0.02
0.2
6-9
0.1
0.1
0.1
0.1
0.1
0.1

-------
TABLE VII1-17
PSES MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE 2
Subcategory: Hot Coating-Galvanising Model Size-TPD : 800
: Strip/Sheet/Misc. Product Oper. Days/Year: 260
: Without Scrubbers	Turns/Day	: 	3
Alternative #1			Alternative #2
C&TT Steps
A
B
C
D
E
F


Total


To tal
Investment S x 10 ^
188
63
49
38
42
4
125
67
576
28
117
721
Annual Cost $ x 10












Capital
8.1
2.7
2.1
1.6
1.8
0.2
5.4
2.9
24.8
1.2
5.0
31.0
Depreciation
18.8
6.3
4.9
3.8
4.2
0.4
12.5
6.7
57.6
2.8
11.7
72.1
Operation and Maintenance
6.6
2 .2
1.7
1.3
1.5
0.1
4.4
2.3
20.1
1.0
4.1
25.2
Sludge Disposal
Energy and Power
-
-
-
-
-
-
-
5.2
5.2
-
-
5.2
-
1.2
0.5
0.3
0.4
0.1
0.3
0.7
3.5
0.1
0.4
4.0
Chemical Costs
-
-
0.9
2.1
1.9
-
-
-
4.9
0.5
-
5.4
Oil Disposal
-
-
-
-
-
0.5
-
-
0.5
-
-
0.5
Expendable Parts
24.7
"
-
-
-
-
-
-
24.7
-
-
24.7
TOTAL
58.2
12.4
10.1
9.1
9.8
1.3
22.6
17.8
141.3
5.6
21.2
168.1
4*
VO
00
Effluent Qualitv^^
Raw
Waste
Load

Flow, gal/ton
600

Suspended Solids
75

Oil and Grease
60

Hexavalent Chrowii*
2.0

Dissolved Iron
75

pH (Units)
2-9
115
Arsenic
0.2
119
Chroa iua
10
120
Copper
2
122
Lead
8
124
Nickel
1.0
128
Zinc
150
150
30
5
0.02
0.2
6-9
0.1
0.1
0.1
0.1
0.2
0.1
150
15
5
O.02
0.2
6-9
0.1
0.1
0.1
O.l
0.1
0.1

-------
TABLE VIII-17
PSES MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE 3		
Subcategory: Hot Coating-Galvanizing
: Hire Product* and Fastener*
With Scrubbers
CtTT Step*
Investaent $ i 10 '
Annual Cost $ x 10
Capital
Depreciation
Operation and Maintenance
Sludge Disposal ...
Energy and Power
Cheaical Costs
Oil Disposal
Expendable Parts
TOTAL
A B	C D
54 92	68	56
2.3	3.9	2.9 2.4
5.4	9.2	6.8 5.6
1.9 3.2	2.4 2.0
1.3	0.5 0.3
0.9 1.8
7.1	-
16.7 17.6	13.5	12.1
Effluent Quality^^
Raw
Haste
Load

Flow, gal/ton
3900

Suspended Solids
100

Oil and Crease
25

Hexavalent Chroaiuai
0.5

Dissolved Iron
40

pH (Units)
3-9
115
Arsenic
0.1
119
Chroaiita
1.0
120
Copper
0.4
122
Lead
1.0
124
Mickel
0.2
128
Zinc
20
Hodel Siie-TPD : 100
Oper. Days/Year: 260
Turns/Day	s 	3
Alternative #1 		Alternative #2
C(D	H(l)	j	Totlll	j(l>	K(l>	Total
62 6	178 99 54	669 25 104 798
2.7
0.3
7.6
4.3
2.3
28.7
1.1
4.5
34.3
6.2
0.6
17.8
9.9
5.4
66.9
2.5
10.4
79.8
2.2
0.2
6.2
3.4
1.9
23.4
0.9
3.6
27.9
-
-
-
2.5
" ft. \
2.5
-
-
2.5
0.4
0.1
0.5
1.0
0.6
4.1
0.1
0.3
4.5
1.7
-
-
-
-
4.4
0.3
-
4.7
-
0.1
-
-
-
0.1
-
-
0.1
-
-
-
-
-
7.1
-
-
7.1
13.2
1.3
32.1
21.1
9.6*4)
137.2
4.9
18.8
160.9
750	750
30	15
5	5
0.02	0.02
0.2	0.2
6-9	6-9
0.1	0.1
0.1	0.1
0.1	0.1
0.1	0.1
0.2	0.1
0.1	0.1

-------
TABLE VIII-17
PSES MODEL COST DATA: BASIS 7/1/78 DOLLARS
PACE 4 			
Subcategory: Hot Coating-Galvanising Model Size-TPD : 100
: Hire Product* and Faateners Oper. Days/Tear: 260
t Without Scrubbers	Turns/Day	: 	3
Alternative »l		Alternative #2
C4TT Step*
A
¦
C
D
E
F

gO)
Total
ill!
siii
Total
Investment $ a 10~'
54
40
32
27
31
3
88
48

323
23
97
443
Annual Cost $ a 10













Capital
2.3
1.7
1.4
1.2
1.3
0.1
3.S
2,
.1
13.9
1.0
4.2
19.1
Depeeciatioa
5.4
4.0
3.2
2.7
3.1
0.3
8.8
4.
.8
32.3
2.3
9.7
44.3
Operation and Maintenance
1.9
1.4
1.1
0.9
1.1
0.1
3.1
1,
.7
11.3
0.8
3.4
IS. 5
Sludge Disposal . .
Energy and Power"'
-
-
-
-
-
-
-
1.
.8
1.8
-
-
1.8
-
0.3
0.2
0.1
0.1
0.1
0.2
0.
,3
1.3
0.1
0.2
1.6
Choiical Coats
-
-
0.3
o.s
0.5
-
-


1.3
0.3
-
1.6
Oil Disposal
-
-
-
-
-
0.1
-


0.1
-
-
0.1
Expendable Parts
7.1
-
—
-
-
-
—


7.1
-
-
7.1
TOTAL
16.7
7.4
6.2
5.4
6.1
0.7
15.9
10.
7
69.1
4.5
17.5
91.1
Ui
O
O
Effluent Quality*"
Eaw
Haste
Load

Plow, gal/ton
2400

Suspended Solid*
150

Oil and Crease
40

¦exavalent Chroaitas
1.0

Dissolved Iron
75

pa (Onits)
3-9
US
Arsenic
0.2
119
Chraaiua
2.5
120
Copper
0.8
122
Lead
2.0
124
Rickel
0.5
128
Zinc
35
600
30
5
0.02
0.2
6-9
0.1
0.1
0.1
0.1
0.2
0.1
600
IS
S
0.02
0.2
6-9
0.1
0.1
0.1
0.1
0.1
0.1
(1)	Coapooents are used in toda.
(2)	Coats are all power.
(3)	All values are in ag/1 unless otherwise specified.
(A) Total cost does oot include power as a credit is applied for existing process water needs.
KEY TO CUT STEPS
A:
Install caacade or counter-current rinse systea.
F:
Oil Skinaing
B:
Equalisation
C:
Flocculator/Clari fier
CI
Adjust pB to 6-9 with list
H:
Vacuua filtration of thickener underflow
D:
Cheaical fteduction
I:
Recycle fuae hood scrubber water*, with 8-10Z blowdown
E:
Foljmer Addition
J:
Precipitation with sulfide


K:
Filtration

-------
TABLE VIII-18
PSES MODEL COST DATA: BASIS 7/1/78 DOLLARS
Subcategory: Hot Coating-Terne Model Size-TPD :	365
: Strip/Sheet Oper. Days/Year: 260
: With Scrubbers	Turns/Day	: 	3
Alternative #1
Alternative #2
<_n
o
C&TT Steps
A
B
C
D
E
F
G(,)
H( 1)
I
Total
J(1)

Total
-3
Investment $ x 10 _3
117
108
83
75
72
6
206
82
70
819
25
014
948
Annual Cost $ x 10













Capital
5.0
4.6
3.6
3.2
3.1
0.3
8.9
3.5
3.0
35.2
1.1
4.5
40.8
Depreciation
11.7
10.8
8.3
7.5
7.2
0.6
20.6
8.2
7.0
81.9
2.5
10.4
94.8
Operation and Maintenance
4.1
3.8
2.9
2.6
2.5
0.2
7.2
2.9
2-h)
28.7
0.9
3.6
33.2
Sludge Disposal , .
Energy and Power
-
-
-
-
-
-
-
1.9

1.9
-
-
1.9
-
1.5
0.6
0.6
0.5
0.1
0.6
0.6
0.9
4.5
0.1
0.3
4.9
Cheaical Costs
-
-
1.1
-
2.2
-
-
-
-
3.3
0.3
-
3.6
Oil Disposal
-
-
-
-
-
0.1
-
-
-
0.1
-
-
0.1
Expendable Parts
15.5
-
-
-
-
-
-
-
-
15.5
-
-
15.5
TOTAL
36.3
20.7
16.5
13.9
15.5
1.3
37.3
17.1
12.5(4)
171.1
4.9
18.8
194.8
Effluent Quality^
Raw
Waste
Load

Flow, gal/ton
1200

Suspended Solids
50

Oil and Grease
25

Hexavalent Chroaira
0.02

Dissolved Iron
50

Tin
5

pH (Units)
3-9
115
Arsenic
0.1
118
Cadaiun
0.1
119
Chroaiua
3
120
Copper
0.5
122
Lead
0.5
124
Nickel
0.8
128
Zinc
1.0
200
30
5
0.02
0.2
3
6-9
0.1
0.1
0.1
0.1
0.1
0.2
0.1
200
15
5
0.02
0.2
0.1
6-9
0.1
0.1
0.1
0.1
0.1
0.1
0.1

-------
TABLE VIII-18
PSES MODEL COST DATA: BASIS 7/1/7B DOLLARS
PAGE 2
Subcategory: Hot Coating-Terae
: Strip/Sheet
: Without Scrubbers
Model Siie-TPD : 365
Oper. Days/Year: 260
Turns/Day	: 	3
Alternative #1
Alternative #2
C&TT Steps
A
B
C
D
E
F

^(1)
Total


To tal
InveBtaent $ x 10~\
117
40
32
30
31
3
81
48
382
22
87
491
Annual Cost $ x 10












Capital
5.0
17
I 4
1.3
1.3
0.1
3.5
2.1
16.4
1.0
3.7
21.1
Depreciation
11.7
4.0
3.2
3.0
3.1
0.3
8.1
4.8
38.2
2.2
8.7
49.1
Operation and Maintenance
4.1
1.4
1.1
1.1
1 1
0.1
2.8
1.7
13.4
0.8
3.0
17.2
Sludge Disposal
-
-
-
-
-
-
-
1.2
1.2
-
-
1.2
Energy and Pover
-
0.3
0.2
0.3
0.1
0.1
0.2
0.3
1.5
0.1
0.2
1.8
Chemical Costs
-
-
0.2
-
0.5
-
-
-
0.7
0.2
-
0.9
Oil Disposal
-
-
-
-
-
0. 1
-
-
0. 1
-
-
0.1
Expendable Parts
15.5
-

-
-
-
-
-
15-5
-
-
15.5
TOTAL
36. y
7.4
6.1
5.7
6.1
0. 7
14.6
10.1
87. 0
4.3
15.6
106.9
Ui
O
to
Effluent Quality^^
Flow, gal/ton
Suspended Solids
Oil and Grease
Hexavalent Chroaiia
Dissolved Iron
Tin
pH (Units)
115	Arsenic
116	Cadmium
119	Chromium
120	Copper
122 Lead
124 Nickel
128 Zinc
Raw
Waste
Load
600
75
40
0.04
75
10
3-9
0.1
0.1
5
1.0
1.0
2.0
2.0
150
30
5
0.02
0.2
3
6-9
0.1
0.1
0.1
0.1
0.1
0.2
0.1
150
15
5
0.02
0.2
0. 1
6-9
0. 1
0. 1
0.1
0.1
0.1
0.1
0.1
(1)	Components are used in tandem.
(2)	Costs are all power.
(3)	All values are in mg/1 unless otherwise specified.
(4)	Total cost does not include power as a credit is applied for existing process water needs.
KEY TO C&TT STEPS
A:
Install cascade or counter-current rinse system.
F:
Oil Skinning
B:
Equalisation
G:
Flocculator/Clari fier
Cs
Adjust pH to 6-9 with lime
H:
Vacuus filtration of thickener underflow
D:
Aeration
Is
Recycle fume hood scrubber waters, with 8~10Z blowdown
E:
Polymer Addition
J:
Precipitation with sulfide


K:
Filtration

-------
TABLE VII1-19
PSES MODEL COST DMA: BASIS 7/1/78 DOLLARS
Subcategory: Rot Coating-Other Metallic Coatings Model Size-TPD : 500
: Strip/Shaet/Hisc. Products Oper. Days/Year: 260
: With Scrubbers	Turns/Day	: 	2
Alternative #1		Alternative #2
CtTT Step*
A
«
C
D
e
r
c«>
H(1)
I
Total
j(l>
siii
Total
lavtitMnt $ i I0"'.
1*1
168
107
124
93
8
299
136
78
1134
26
135
315
Annual Coat 1 * 10













Capital
6.1
7.2
4.6
5.3
4.0
0.3
12.9
5.8
3.4
49.6
1.1
5.8
56.5
Depreciation
14.1
16.1
10.7
12.4
9.3
o.s
29.9
13.6
7.8
115.4
2.6
13.5
131.5
Operation ad Maintenance
*.9
5.9
3.7
4.3
3.3
0.3
10.5
4.8
2.7
40.4
0.9
4.7
46.0
Sludge Diapoaal ...
-
-
-
-
-
-
-
4.8
(A)
4.8
-
-
4.8
Energy and Power
-
2.0
o.s
1.0
0.6
0.2
0.5
0.9
1.2W
6.0
0.1
0.3
6.4
Chaaical Coat*
-
-
1.5
-
3.0
-
-
-
-
4.5
0.4
-
4.9
Oil Disposal
-
-
-
-
-
o.s
-
-
-
0.5
-
-
0.5
Expendable Parta
ia.7
¦
-
-
-
-
-
-
-
18.7
-
-
18.7
TOTAL
43.•
Jl.»
21.3
23.0
20.2
2.1
53.1
29.9
13.9(4>
239.9
5.1
24.)
269.3
lav
BffUteat QealitY(3)
Haste
Load


rien, gal/cm
1200
200
200
Seapentad Solids
250
30
IS
Oil and Crease
50
5
5
¦esavaleat Cknaiaa
0.02
0.02
0.02
Masolved Iroe
20
0.2
0.2
Tia
S
l.S
0.1
Altaian*
25
2.5
0.1
pi (Baits)
5-9
6-9
6-9
IIS Arsenic
0.1
0.1
0.1
US Cadwiua
2.0
0.1
0.1
119 C>rsai«
0.2
0.1
0.1
120 Capper
O.S
0.1
0.1
122 Laad
l.S
0.1
0.1
124 Nickel
O.S
0.2
0.1
12* line
s
0.1
0.1

-------
TABU VIII-19
PSES MODEL COST DATA: BASIS 7/1/78 DOLLARS
PAGE 2
Subcategory: Hot Coating-Other Metallic Coating Model Siie-TPD : 500
s Strip/Sheet/Hisc. Products Oper. Days/Year: 260
! Without Scrubber#	Turn*/Day	: 	2
Alternative #1	Alternative #2
C&TT Steps
A
B
C
D
E
F


Total
J(1)

Total
Investaent $ * 10~'-
141
62
42
44
41
3
119
76
528
25
117
670
Annual Cost $ i 10~












Capital
6.1
2.7
1.8
1.9
1.7
0.1
5.1
3.3
22.7
1.1
5.0
28.8
Depreciation
14.1
6.2
4.2
4.4
4.1
0.3
11.9
7.6
52.8
2.5
11.7
67.0
Operation and Maintenance
4.9
2.2
1.5
1.5
1.4
0.1
4.2
2.7
18.5
0.9
4.1
23.5
Sludge Disposal ...
Energy and Power
-
-
-
-
-
-
-
3.7
3.7
-
-
3.7
-
0.4
0.2
0.2
0.2
0.1
0.2
0.4
1.7
0.1
0.3
2.1
Cheaical Costs
-
-
0.3
-
0.6
-
-
-
0.9
0.3
-
1.2
Oil Disposal
-
-
-
-
-
0.3
-
-
0.3
-
-
0.3
Expendable Parts
18.7
—
-
-
-
-
-
-
18.7
-
-
18.7
TOTAL
43.8
11.5
8.0
8.0
8.0
0.9
21.4
17.7
119.3
4.9
21.1
145.3
Ln
O
Effluent Quality^
Flow, gal/ton
Suspended Solids
Oil and Create
Hexavalent Chroai
Dissolved Iron
Tin
Aluaima
pB (Onita)
115 Arsenic
118	Cadaiua
119	Chroaiua
120	Copper
122 Lead
124 Rickel
128 Zinc
Raw
Haste
Load
600
400
60
0.02
30
8
30
4-10
0.1
4.0
0.2
1.0
J.5
0.5
8
150
30
5
0.02
0.2
1.5
2.5
6-9
0.1
0.1
0.1
0.1
0.1
0.2
0.1
150
15
5
0.02
0.2
0.1
0.1
6-9
0.1
0.1
0.1
0.1
0.1
0.1
0.1

-------
TABLE ¥111-19
PSES MODEL COST DATA: BASIS 7/1/78 DOLLARS
FACE 3			
Subcategory: Hot Coating-Other Metallic Coating Model Sise-TPD : 15
t Hire Product® and Faatenera	Oper. Daya/Year: 260
: With Scrobbera	Turna/Day	2
Alternative #1		Alternative #2
COT Steps
A
>
C
0
E
F
C»>
,(1)
1
Total
j
64.6
3.6
10.9
79.1
U1
O
U1
emu—t o—utyCi)
Nov, |al/to*
InptM SolL4a
Oil aa4 Crease
¦•Ufiltit Chnaiaa
Dissol*e4 Iran
Tia
Alaaiaaa
|H (Baits)
IIS Araaaic
111 C.AniiM
119	Cknaia
120
122
124
12$
Vaate
Michel
Ziae
3900
100
25
0.02
12
3
12
J-9
0.1
1.0
0.0
0.3
1.0
0.3
3
750
30
J
0.02
0.2
1.5
2.5
6-9
0.1
0.1
0.1
0.1
0.1
0.2
0.1
750
15
5
0.02
0.2
0.1
0.1
6-9
0.1
0.1
0.1
0.1
0.1
0.1
0.1

-------
TABLE VIII-19
PSES MODEL COST EATA: BASIS 7/1/78 DOLLARS
PAGE 4
Subcategory: Hot Coating-Other Metallic Coating Model Size-TPD t 15
: Wire Products and Fasteners Oper. Days/Year: 260
: Without Scrubbers	Turns/Day	: 	2
Alternative #1	Alternative #2
C&TT Steps
A
B
C
D
E
F
G
CD

Total


)
Total
Investment $ * 10 ^
17
18
16
18
17
3

42
34
165
19
57

241
Annual Cost $ x 10















Capital
0.7
0.8
0.7
0.8
0.7
0.
1
1
8
1.5
7.1
0.8
2.
5
10.4
Depreciation
1.7
1.8
16
18
1.7
0.
3
4
.2
3.4
16.5
1.9
5-
7
24.1
Operation and Maintenance
0.6
0.6
0.6
0.6
0.6
0.
1
1
.5
12
5.8
0.7
2.
0
8.5
Sludge Disposal
Energy and Power
-
-
-
-
-




0.3
0.3
-


0.3
-
0.1
0.1
0.1
0.1
0.
1
0
. 1
0.1
0.7
0.1
0.
. 1
0.9
Chemical Costs
-
-
0. i
-
0.1




-
0.2
0.1


0.3
Oil Disposal
-
-
-
-
-
0.
1


-
0.1
-


0.1
Expendable Parts
2.3
-
-
-
-




-
2.3
-


2.3
TOTAL
5.3
3.3
3.1
3.3
3.2
0.
7
7
.6
6.5
33.0
3.6
10.
.3
46.9

-------
TABLE VI11-20
BPT CAPITAL COST TABULATION
Subcategory: Hot Coating - Galvanising	Baais: 7/1/78 Dollars * 10 3
: Strip, Sheet, and Miscellaneous Products	Facilities in Place as of 1/1/78
Plant
C4TT Step
Ul
O
-J
Code
TPD
A
B
C
D
E
r
G
Id-Place
Required
Total
0060
1311
195
151
117
130
12
387
207
887
312
1199
006OB
1173
182
141
109
122
11
362
194
928
193
1121
006OR
184
60
46
36
40
4
119
64
0
369
369
0068
39
24
18
14
16
2
47
25
0
146
146
0112A
1437
103-103
159
124
138
13
409
219
•22
446
1268
0112B
1077
273
184
147
151
13
496
215
693
786
1479
02S6D
1026
265
179
143
146
13
479
209
1013
421
1434
0256C
472
106
82
63
71
5
210
112
0
649
649
0264A
56
46
31
25
26
2
84
37
130
121
251
0384A
2235
269
207
161
180
17
533
285
286
1366
1652
0432A
177
92
62
50
51
4
167
73
357
142
499
0432B
540
115
88
69
77
7
227
122
0
705
705
04320
1038
170
131
102
113
11
337
180
468
576
1044
044 SA
637
126
98
76
85
8
251
134
98
680
778
0476A
180
59
46
36
40
4
118
63
290
76
366
0492A
186
95
64
51
53
5
172
75
100
415
515
0584C
1398
319
215
172
176
15
577
252
721
1005
1726
0584E
12 78
302
204
163
167
15
547
238
1231
405
1636
0JS4F
1419
205
158
123
137
13
406
217
218
1041
1259
0664A
213
66
51
39
44
4
130
70
0
404
404
06S4B
462
164
111
88
91
8
297
129
172
716
888
06841
513
111
86
67
74
7
221
118
118
566
684
0728 (1)
0856D
75
35
-
-
-
2
-
-
37
0
37
432
100
77
60
67
6
199
106
0
615
615
0856F
1020
264
178
142
146
13
478
208
1221
208
1429
0860D
1770
234
180
140
156
14
464
248
570
866
1436
0846B
1623
286
203
160
171
15
535
255
1210
415
1625
0868A
1551
277
198
156
165
15
521
248
1580
0
1580
0920D
345
138
93
74
76
7
249
109
145
601
746
0920E
2067
403
272
217
223
19
730
318
1965
217
2182
0948A
189
61
47
37
41
4
61-60
65
214
162
376
0948C
1296
194
150
116
130
12
385
206
871
322
1193
16,345*
14,946*
31,291*
*: Totals do not include confidential plants or dry operations.
MOTE: Underlined costs repesent facilities in place. Where two figures appear in the ssne coluan, the underlined portion is in place;
the nonunderlined portion reaaint to be installed.
KEY TO C&TT STEPS
A: Equalization	E: Oil Skiaaing
B: Adjust pH to 6*9 with line	F: Clarifier
C: Chemical Reduction	C: Vacuusi Filter
D: Polyaer Addition

-------
TABLE VIII-21
I FT CAPITAL COST TABULATION
Subcategory: Ret Coating - Galvanizing	Basis: 7/1/78 Dollar* x 10"'
: Wire, Hire Products, Fasteners	Facilitiea in Place as of 1/1/78
U1
O
00
Plant
Code
0068
0112A
011ZF
0112G
0112H
01121
0264
0264D
046OA
046OC
0460D
046OS
046OF
046OC
046OH
0476A
0580A
0S80C
0612
0640
06408
0856P
0860F
0860G
08MB
0868A
0936
CtTT Step
TPD
A
»
C
P
E
F
C
Io-Place
Required
203
141
113
95
110
12
309
170
0
950
126
53-53
85
71
83
9
232
128
462
252
31
66
49
40
46
4
128
71
49
355
12
37
28
23
25
2
72
40
28
199
3.5
12
10
8
10
1
27
15
60
23
M
85
69
57
67
7
187
103
518
57
127
154
114
93
104
9
298
165
412
525
119
124
91

90
9
255
141
346
444
481
240
203
169
195
20
554
303
1201
492
56
94
70
57
64
6
182
101
0
574
90
86
69
58
68
8
190
104
431
152
54
63
51
43
50
6
140
77
318
112
10
23
18
16
18
2
51
28
18
138
30
45
36

35
4
98
54
179
123
11
24
20
16
19
2
54
29
0
164
28
62
46
38
42
4
120
67
341
38
8
20
16
14
16
2
44
24
40
96
5
15
12
10
12
1
33
18
0
101
284
172
138
116
135
15
378
208
807
355
181
131
106
89
103
11
288
158
563
323
15
29
26
20
23
3
65
36
112
88
17
46
34
28
31
3
66-23
49
23
257
144
114
92
77
90
10
251
138
467
305
112
98
-

-
-
-

98
0
108
105
82
69
80
8
226
122
501
191
57
66
53
44
51
6
144
79
66
377
8
20
16
14
16
2
22-22
24
58
	78








7098*
6769*
Total
950
714
404
227
83
>75
937
790
1693
574
583
430
156
302
164
379
136
101
1162
886
200
280
772
98
692
443
136
13,867*
*: Totals do not include confidential plants or dry operations.
NOTE: Underlined costs repesent facilities in place. Where two figures appear in the saie coluan, the underlined portion is in place;
the nonunderlined portion remains to be installed.
KEY TO C&TT STEPS
A: Equalization	E: Oil Skimming
B: Adjust pH to 6-9 with lime	F: Clarifier
C: Chemical Reduction	C: Vacuum Filter
D: Polymer Addition

-------
TABLE VlU-22
BPT CAPITAL COST TABULATION
Subcategory: Hot Coating	Basis: 7/1/78 Dollars x 10 ^
: Teme	: facilities in Place as of 1/1/78
Plant	C&TT Step
Code	TPP
0060	522
0648 18
0684B,	225
0856D	561
0920F	153
*
B
C
D
E
F
C
In-Plaee
Required
Total
144
114
105
104
10
285
136
754
144
898
13
12
11
12
2
31
18
0
101
101
107
82
75
71
6
51-153
81
138
488
626
ias
142
129
123
10
353
141
185
898
1083
54
44
41
43
5
111
66
59
305
364
1136	1936	3072
^	(1) Treatment plant under construction in 1978. Expected completion in 1979.
O
10	NOTE: Underlined coata repesent facilities in place. Vhere two figures appear in the isk coltmm, the underlined portion is in place;
the nonund«rlined portion reiaaina to be installed.
KET to CfcTT STEPS
A: Equalisation	E: Oil Skimming
B: Adjust pH to 6-9 with lime	F: Clarifier
C: Aeration	C: Vacuum Filter
D: Polymer Addition

-------
TABLE VIU-23
BPT CAPITAL COST TABULATION
Subcategory: Hot Coating - Other Hetals	Basic 7/1/78 Dollars i 10 '
: Strip, Sheet	Facilities in Place a* of 1/1/78
Plant		CtTT Step	
Total
749
1016
907
1320	1352	2672
Code
TPD
A
8
C
P
E
r
C
In-Flace
Required
0112A
375
119
82
85
79
7
230
147
7*9
0
0384A
625
81-81
111
115
107
9
312
200
90
926
0856D
516
1?5
99
103
96
I
278
178
481
426
NOTE: Underlined costs represent facilities in place. Where two figures appear in the we colisin, the underlined portion is in place;
the nonunderliiMd portion rcaains to be installed.
KEY TO CfcTT STEPS
A: Equalization	E: Oil Skiving
Ln	8: Adjust pfl to 6-9 with liae	F: Clarifier
£	C: Aeration	C: Vacuus Filter
0: Poljmr Addition

-------
TABLE VIII-24
BPT CAPITAL COST TABULATION
Subcategory: Hot Coating - Other Hetals
Basis: 7/1778 Dollars x 10
-3
Plant


: Uire,
Uire Products,
and Fasteners
C&TT Step


Facilities
in Place as of
/1/78
Code
TPD
A
_B_
C
D
E
F
G
In-Place
Required
0112C
26
29
26
29
28
6
70
57
154
91
01121
3.6
17
15
17
17
3
41
34
90
54
046 OR
17
44
39
44
42
9
105
85
0
368
0S80G
7.5
27
24
27
26
5
64
52
0
225
06848
3
16
14
16
15
3
37
30
82
49
0792*
0.8
7
6
7
7
1
17
14
0
59
0860F
45
106
93
98
95
15
236
155
703
95
Total
245
144
368
225
131
59
798
1029*
941*
1970*
U1
*: Total* do not include confidential plants or dry operations.
NOTE: Underlined costs repesent facilities in place. Where two figures appear in the sose coluan, the underlined portion is in place;
the nonunderlined portion reaains to be installed.
KEY TO CfcTT STEPS
A:	Equalisation
B:	Adjust pH to 6-9 with liae
C:	Aeration
D:	Polyaer Addition
E: Oil Skiaaing
F: Clarifier
C: Vacuua Filter

-------
TABLE VIII-25
BPT COST REQUIREMENTS
HOT COATIMG SUBCATEGORY
(All costs in millions of 7/1/78 dollars)
Capital Investment Costs
In Place
Required Total Capital
Current
(1)
Annual Costs
Additional
(2)
Total Annual
(3)
Galvanizing
Strip, Sheet, Miscellaneous	16.85	18.31	35.16
Hire Products and Fasteners	7.02	13.24	20.26
Subtotal - Galvanizing	23.87	31.55	55.42
3.47
1.37
4.84
3.77
2.59
6.36
7.24
3.96
11.20
Terne Coating
Sttip, Sheet Only
1.16
2.58
3.74
0.22
0.50
0. 72
Ui
to
Other Metals
Strip, Sheet, Miscellaneous	1.36	1.31	2.67
Hire Products and Fasteners	1.74	0.37	2.11
Subtotal - Other Metals	3.10	1.68	4.78
Hot Coating Totals	28.13	35.81	63.94
0.26
0.31
0.57
5.63
0.25
0.07
0.32
7.18
0. 51
0.38
0.89
12.81
(1)	Annual operating costs for BPT treatment components already in place.
(2)	Annual operating costs for BPT treatment components yet to be installed to attain limits.
<3) Total projected annual costs to attain BPT limits.
NOTE: Costs are based on model plant costs on a stand-alone basis. Due to the prevalence of
central treatment systems, actual capital investment still required is estimated to be 75Z
of the total mnunt shown, or nearly $27,000,000. Annual operating costs will also be
correspondingly lover.

-------
in
H
CJ
BPT
—I polymerI
| ACID |
CLARIFIER
EQUALIZATION
TANK
BAT-
lACID
LIME |
BAT-2
SULFIDE
EQUALIZATION
TANK
REACTION TANK
BAT-3
IOO% RECYCLE
TO PROCESS
CENTRIFUGE
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATINGS/GALVANIZING
SUBCATEGORY
TREATMENT MODELS SUMMARY
Own. 8/7/80
FILTER
SULFUR
DIOXIDE
SULFUR
DIOXDE
EVAPORATION
VACUUM
FILTER
VACUUM
FILTER
FUME HOOO
SCRUBBER
(ONCE-THROUGH)
COATING
RINSE
WATER
FUME HOOO
SCRUBBER
SLOWDOWN
CASCADE
RINSE

-------
BPT
| LIME | 	1 POLYMER
OIL
CLARIFIER
Air
BAT- I
	1 POLYMER
| LIME
OIL
BAT-2
CLARIFIER
SULFIDE
Air
REACTION TANK
BAT-3
100% RECYCLE
TO PROCESS
ENVIRONMENTAL PROTECTION AGENCY
CENTRIFUGE
STEEL INDUSTRY STUDY
HOT COATINGS/TERNE
SUBCATEGORY
TREATMENT MODELS SUMMARY
Own. 8/7/80
FIGURE m-2
FILTER
EVAPORATION
VACUUM
FILTER
VACUUM
FILTER
CASCADE
RINSE
FUME HOOD
SCRUBBER
SLOWDOWN
FUME HOOD
SCRUBBER
(ONCE-THROUGH)
COATING
RINSE
WATER

-------
bpt
—| POLYMER
LIME
OIL
CLARIFIER
Air
BAT- I
—1 POLYMER
LIME
OIL
BAT-2
CLARIFIER
SULFIDE
Air
REACTION TANK
BAT -3
100% RECYCLE TO PROCESS
ENVIRONMENTAL PROTECTION AGENCY
CENTRIFUGE
STEEL INDUSTRY STUDY
HOT COATINGS/OTHER METALS
SUBCATEGORY
TREATMENT MODELS SUMMARY
FIGURE 3Zni-3
FILTER
EVAPORATION
VACUUM
FILTER
VACUUM
FILTER
FUME HOOD
SCRUBBER
(ONCE-THROUGH)
CASCADE
RINSE
FUME HOOD
SCRUBBER
BLOWDOWN
COATING
RINSE
WATER

-------
HOT COATING SUBCATEGORY
SECTION IX
EFFLUENT QUALITY ATTAINABLE THROUGH THE
APPLICATION OF THE BEST PRACTICABLE CONTROL
TECHNOLOGY CURRENTLY AVAILABLE (BPT)
Identification of BPT
Based upon the information contained in Sections III through VIII, the
Agency determined that effective pollutant load reductions for hot
coating operations for the BPT level of treatment can be accomplished
through the use of the following treatment systems:
A. Galvanizing Operations
This treatment system sequence includes: equalization of various
wastewater sources; blending; chromium reduction by adding
chemical reducing agents where necessary to control hexavalent
chromium; lime neutralization with mixing in a reactor tank;
polymer addition to enhance flocculation and sedimentation;
automatic oil skimming; and provision for a thickener or
clarifier with sufficient retention time to settle suspended
solids. All wastewaters, including fume scrubber wastewaters,
are treated once-through by this system.
The Agency has costed chromium reduction for the total wastewater
flow from galvanizing operations. However, it is less expensive
to treat only the chromate rinsewaters for hexavalent chromium.
B- Terne and Other Metal Coating Operations
All steps in the BPT model treatment system are the same as for
galvanizing, except that a separate chromium reduction step is
generally not required. Ferrous iron from pickling rinses
normally provides sufficient reducing capability to accomplish
the desired elimination of any hexavalent chromium which may be
present. An aeration step is substituted for chromium reduction
in the BPT model treatment system. As before, all process and
fume scrubber wastewaters are treated once-through by this
system.
The proposed BPT limitations are summarized in Tables IX—1
through IX-3. Figures IX-1 through IX-3 present the BPT model
treatment system.
Rationale for Selection of BPT
The following discussion summarizes the factors evaluated by the
Agency in selecting the proposed BPT limitations.
517

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BPT Flows
In determining the proposed BPT limitations, the Agency did riot rely
upon all flow data. In some cases, DCP respondents made no effort to
distinguish between process and noncontact cooling water, thus
overstating process flow rates. At other times, maximum design flows
were given, which when paired with "typical" production data, yielding
artificially high gallons/ton figures. The flow rate eventually
selected as the BPT model flow is the average of most of the reported
flows, omitting only those which were far outside the flows of the
general population. A summary of flows shows the following
comparisons. Since BPT model flows are all once-through, only applied
rates are used.
Average
Applied
Flow Rates
in GPT
Galvanizing
Strip,Sheet,Misc. Products:
Rinsewaters
Scrubbers
607
583
No. of Plants
Included in
Average
29
11
of
of
31
11
Wire Products & Fasteners:
Rinsewaters	2409	26 of 27
Scrubbers	1459	10 of 12
Terne Coating
Strip,Sheet,Misc. Products:
Rinsewaters	522	5 of 6
Scrubbers	508	3 of 3
Other Metal Coatings
Strip,Sheet,Misc. Products:
Rinsewaters	366	3 of 4
Scrubbers	*	»
Wire Products & Fasteners:
Rinsewaters	2053	13 of 14
Scrubbers	(11520)2	1 of 1
lAll scrubbers are listed as "dry".
20nly one scrubber reported data, although its effluent, combined with
the highest rinsewater flow, was reported as 640 GPT.
Since flow rates by product are similar regardless of applied coating,
the BPT model flow was standardized at levels resembling galvanizing
flows (since more data points exist there). Flows used are 600 GPT
for strip, sheet, and miscellaneous product rinsewaters, and 600 GPT
for strip, sheet and miscellaneous product scrubber wastewaters. For
518

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wire products and fasteners, the flows are 2400 GPT for rinses and
1500 GPT for scrubbers.
The ability of surveyed plants to achieve the proposed BPT limitations
is summarized below.
Hot Coating - Galvanizing
The Agency is proposing BPT limitations for TSS, oil and grease, total
zinc, total chromium, hexavalent chromium, and pH. Refer to Table
VII-2 for data concerning effluent wasteloads for these pollutants.
Total Suspended Solids (TSS)
Of the nine plants surveyed (one visited twice), only one, Plant V-2,
was not providing sufficient retention time in a settling basin to
achieve effective suspended solids removal, and that plant discharges
its wastewaters to a POTW. Effluent data for the other plants are as
follows:
Percent of
TSS Load	Proposed
Plant Product Scrubbers kq/kkq BPT Limitation
1-2	Wire	Yes	0.0358	4.4
MM-2	Sheet	Yes1	0.175	93.3
NN-22	Sheet	Yes	0.0308	12.3
111	Wire	No	0.0649	13.0
112	Strip	No	0.0514	41.1
114	Strip	No	0.0053	4.2
116	Fasteners No	0.0027	0.5
118a	Sheet	Yes	0.181	72.4
119	Pipe	No	0.0025	2.0
*Plant has scrubber on one line, but not on the other. BPT allowance
calculated on a 0.1875 kg/kkg basis.
^Revisited Plant.
All eight plants (NN-2 and 118 are the same plant) achieved the
proposed BPT limitations, six by comfortable margins. Only final
effluents were used in this evaluation. All data support the proposed
BPT limitations for TSS.
Oil and Grease
All plants provided for some degree of oil removal, and most were
successful. Some plants accomplished this by skimming, others by
flocculation and settling.
519

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Effluent
O&G Load
Percent of
Proposed
Plant
Product
Scrubber
kq/kkq
BPT Limit
1-2
Wire

Yes
0.0128
5.2
V-2
Wire

No
0.0641
42.7
MM-2
Sheet

Yes1
0.0655
116.3
NN-2
Sheet

Yes
0.0498
66.4
1 1 1
Wire

No
0.0236
15.7
1 1 2
Strip

No
0.0072
19.2
1 1 4
Strip

No
0.0053
14.1
1 1 6
Fasteners

No
0.0099
6. 6
1 1 8
Sheet

Yes
0.0245
32. 7
1 1 9
Pipe

No
0.0067
17.9
xPlant
has scrubber
on
one line, but not
on the other
calculated on a 0.0563
kg/kkg
basis.

BPT allowance
The only discharger failing to achieve the proposed BPT limitations
for oil and grease was Plant MM-2. An excessive contribution of 22.5
mg/1 oil and grease was found in plant effluents. This effluent also
contained cold rolling mill wastes. All other data support proposed
BPT limts on oil and grease.
Zinc
Data exist for seven of the plants, indicating compliance with the
proposed BPT limitations at all but one plant.
Effluent Percent of
Zinc Load Proposed
Plant
Product
Scrubber
kq/kkq
BPT Limitation
MM-2
Sheet
Yes1
0.000117
0.6
NN-2
Sheet
Yes
0.00776
31 .0
111
Wire
No
0.000707
1 .4
112
Strip
No
0.000287
2.3
114
Strip
No
0.000062
0.5
1 16
Fasteners
No
0.000321
0.6
118
Sheet
Yes
0.0330
132
119
Pipe
No
0.000031
0.2
*Plant has scrubber on one line, but not on the other. BPT allowance
calculated on a 0.01875 kg/kkg basis.
All plants shown achieve the proposed BPT limitations for zinc except
for Plant 118 during the second visit to that site. That visit was
marred by flood conditions in a sump feeding the treatment plant, so
that solids separations (including zinc hydroxide precipitates) were
less effective than normal. A better effluent quality from that plant
was achieved during an earlier visit (Plant NN-2) when TSS removals
were effective and zinc loads were less than a third of the 30-day
average limit. The proposed BPT limitations for zinc are being
attained by plants visited using separate or central treatment
systems.
520

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Total Chromium
Excellent chromium removals were achieved at all plants for which data
are available. Chemical reduction and precipitation are effective in
converting dissolved hexavalent chromium to suspended solids which
could then be separated out even where no reductant is added other
than ferrous iron already present. Data for seven plants are
summarized below.
Effluent	Percent of
Cr Load	Proposed
Plant
Product
Scrubber
kq/kkq
BPT Limitation
MM-2
Sheet
Yes1
0.00251
22. 3
NN-2
Sheet
Yes
0.000154
1 .0
1 11
Wire
No
0.000236
2.4
112
Strip
No
0.000084
1 . 1
11 4
Strip
No
0.000018
0.2
1 16
Fasteners
No
0.000075
0.8
118
Sheet
Yes
0.00132
8.8
1 19
Pipe
No
0.000015
0.2
1Plant has scrubber on one line, but not on the other. BPT allowance
calculated on a 0.01125 kg/kkg basis.
The above data show that proposed BPT limitations for total chromium
are less stringent than might otherwise be justified. Five of the
seven plants listed above are approaching proposed BAT limitations for
total chromium.
Hexavalent Chromium
As in the case of total chromium removal, hexavalent chromium was also
effectively controlled at most plants which were visited, down to low
concentration levels. These data are summarized below:
Plant Product Scrubber
MM-2	Sheet	Yes1
NN-2	Sheet	Yes
111	Wire	No
112	Strip	No
114	Strip	No
116	Fasteners No
118	Sheet	Yes
119	Pipe	No
Effluent

Hexavalent
Percent of
Cr Load
Proposed
kq/kkq
BPT Limitation
0.000015
20.0
0.000062
62.0
0.000035
17.5
0.000006
12.0
0.000005
10.0
0.000007
3.5
0.000378
378
0.000005
10.0
lPlant has scrubber on one line, but not on the other. BPT allowance
calculated on a 0.000075 kg/kkg basis.
The excessive amount reported by Plant 118 is related to the problem
defined above in the discussion on zinc. Poor solids separation
521

-------
allows for a greater carryout of all precipitates, and increases the
likelihood of some dissolved materials also being carried out on the
surface of the solids. Again, this same plant was complying with the
limitation when operating with better solids removals (see Plant
NN-2). All other data support the proposed BPT limitations for
hexavalent chromium.
Of the plants visited, three were found to be operating outside the
proposed pH limitations for at least part of the time, while the other
six were achieving pH limits of 6.0 to 9.0 during the sampling runs.
Plant V-2 is equipped with pH controls, but insufficient neutralizing
agents were being added to elevate pH levels to near neutral prior to
discharge to a large POTW. Plant MM-2 also has pH contol, but is
apparently subject to wide fluctuations in pH because of the variety
of wastewater jointly treated in a large central treatment facility.
Plant 112 was usually within pH constraints, but overshot to pH 9.5
for approximately six hours during the sample runs. In any case, the
proposed BPT pH limitations are demonstrated to be readily achievable
through the application of proper control technology and monitoring
equipment.
Hot Coating - Terne Metal
The Agency is proposing BPT limitations for five pollutants: TSS, oil
and grease, lead, tin, and pH. Refer to Table VII-3 for data
concerning effluent loads for these pollutants as found during field
sampling at two continuous strip terne coating lines (note that one
plant was visited twice). Neither plant was treating terne line
wastewaters at the time of sampling in October, 1973 and March, 1977,
but both were exercising close attention to maintenance of rolls and
squeegees, and were controlling solution rinses with dragout recovery
tanks to minimize carryover of strong wastewater. Where control
technology would be necessary to attain prescribed limits, it should
be readily transferred from the hot coating galvanizing subcategory.
In fact, by 1977 both sampled plants were constructing treatment
systems which will jointly treat wastewaters from hot coating - terne
and from other forming, finishing and coating lines, including
galvanizing. Plant 113 has already reduced wastewater flow rates
significantly. Flows reported as 2,194 gallons/ton during the first
sampling visit to the site were measured at 1,006 gallons/ton during
the revisit two years later. Since other characteristics of the raw
wastewaters were similar, this plant achieved a 50 percent reduction
in effluent load due to flow reductions alone.
Total Suspended Solids (TSS)
Data from all three sampling surveys indicate that plants were
achieving the proposed BPT limitations for TSS even though no
treatment was installed. The hot coating operations generate little
scale, and since no neutralization was being practiced, no metallic
hydroxides were formed to increase TSS concentration.
522

-------
Effluent	Percent of
TSS Load	Proposed
Plant Product	Scrubber kq/kkq	BPT Limitation
00-2	Strip	No	0.103	82.4
PP-2	Strip	Yes	0.0823	32.9
113	Strip	Yes	0.0461	18.4
Plants were attaining the proposed BPT limitations for TSS even
without treatment, but are expected to generate additional solids
during treatment as the wastewaters are neutralized. However, well
designed systems have not had any problems in controlling TSS in hot
coating effluents. Refer to the galvanizing plant visit summary for
details on effective TSS control.	^
Oi1 and Grease (O&G)
As in the case of TSS, all three sampling surveys showed oil and
grease loads in untreated effluents in compliance with proposed BPT
limitations. And in this case, no additional increases in oil and
grease are anticipated, so the installation of treatment facilities
can only improve an already acceptable level of oils. These examples
illustrate how tight control of process operating conditions can
greatly aid the pollutant load reduction goals of conscientious plant
operators. Dollars spent on maintenance and control of line
operations can save dollars from being spent on pollution control and
treatment plants. Note the improvement at Plant 113 (formerly PP-2)
brought about through flow reduction alone.
Plant
00-2
PP-2
113
Product
Strip
Strip
Strip
Scrubber
No
Yes
Yes
Effluent
0&G Load
kq/kkq
0.0215
0.0393
0.0168
Percent of
Proposed
BPT Limitation
57.3
52.4
22.4
Lead
In all three cases the proposed BPT limitation for lead from terne
coating lines were being met, again despite the absence of treatment.
Plant
00-02
PP-2
11 3
Product
Strip
Strip
Strip
Scrubber
No
Yes
Yes
Effluent
Pb Load
kq/kkq
0.000431
<0.00046
0.000293
Percent of
Proposed
BPT Limitation
34.5
<18.4
11.7
Since total lead was analyzed, the eventual lead content in treated
effluents is likely to be at least as low as the values shown above.
As long as the industry continues to maintain process control at the
current level, no problems with lead are anticipated. Hence, the
proposed BPT limitations can be achieved.
523

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Tin (Sn)
As with all other pollutants discussed thus far, the tin content of
untreated effluents from the terne coating lines surveyed and sampled
met the proposed BPT limitation.
Plant
00-2
PP-2
1 1 3
Product
Strip
Strip
Strip
Scrubber
No
Yes
Yes
Effluent
Tin Load
kg/kkg
<0.0043
<0.0183
<0.000042
Percent of
Proposed
BPT Limitation
<34. 4
<73.2
<0.2
as
BPT
Total tin content in treated effluents is expected to be at least
low as in the untreated effluents shown above. The proposed
limitations should be effectively met by all terne-coating lines.
None of the plants surveyed were consistently achieving the desired pH
levels of 6-9 in plant effluents, since acidic rinsewaters comprised
the major portion of the untreated rinses leaving terne coating lines.
The pH measurements made during the three visits typically showed
values ranging between 2.2 and 5.2 units, with only an occasional rise
to 6.5 during the revisit to Plant 113. However, the installation of
treatment facilities at both locations included pH controls to
consistently maintain the proper pH levels for discharge. Since the
necessary technology has been demonstrated on a wide variety of
wastewater, including the wastes from hot coating - galvanizing, no
problems are anticipated for terne lines in achieving the proposed BPT
pH limitations.
Hot Coating - Aluminizinq
BPT limitations for hot coating operations for metals other than zinc
and terne mixtures were not previously promulgated. BPT limitations
covering other hot coating operations and controlling discharges of
cadmium, lead, suspended solids, oil and grease, zinc, and pH are
being proposed herein. All data shown below are for a single plant -
Plant 116, a fastener aluminizing line. Effluent data showed the
following at a discharge flow of 3960 gallons/ton. The BPT model flow
is 2400 gallons/ton.
524

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Pollutant
Cone.	Load in kq/kkq	Percent of Proposed
mq/1 Effluent Prop. BPT BPT Limitation
Chromium
Cadmium
Lead
Zinc
TSS
O&G
pH
<0.03
<0.01
<0.08
0. 13
<1
4
7.3-7.7
<0.0005
<0.00017
<0.00132
0.00215
<0.0165
0.0661
0.0050
0.0050
0.0050
0.030
0.500
0.150
6-9
<10.0
<3.4
<26.4
7.2
<3.3
44
Plant 116 complies with all proposed BPT limitations for this
subcategory.
The above limits are also applicable to hot coatings other than
aluminum. The treatability of specific metallic pollutants is such
that the proposed limitations are attainable using the BPT model
treatment system.
525

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TABLE IX-1
BPT EFFLUENT LIMITATIONS GUIDELINES
HOT COATING - GALVANIZING
BPT Effluent Limitations in kg/kkg (lbs/1000 lbs)^^
Strip, Sheet, Miscellaneous
Products, Basic
Add for scrubbers
TSS
0.125
0.125
O&G
0.0375
0.0375
Chromium, Total Chromium +6
0.0075
0.0075
0.00005
0.00005
PH
Zinc Units
0.0125
0.0125
6-9
6-9
Flow
Bas is
GPT
600
600
Estimated Cost
$/kkg $/ton
0.97
0.41
0.88
0.37
Wire Products and
Fasteners, Basic
Add for scrubbers
U1
to
ON
0.500
0.313
0.150
0.094
0.010
0.0063
0.00020
0.00013
0.050
0.0313
6-9
6-9
2400
1500
5.15
1.71
4.67
1.55
(1) 30-day average limitations. Daily maximum values are three times the limitation stated.

-------
TABLE IX-2
BPT EFFLUENT LIMITATIONS GUIDELINES
HOT COATIHC - TERNE METAL
(BPT Effluent Limitations in kg/kkg (lbs/1000 lbs)^*^
Flow
pH	Basis	Estimated Cost
TSS	O&C	Lead	Tin	Units	CPT	$/kkg	$/ton
Strip, Sheet, Miscellaneous
Products, Basic	0.125 0.0375	0.00125 0.0125 6-9	600	1.37	1.24
Add for scrubbers	0.125	0.0375	0.00125	0.0125 6-9	600	0.53	0.48
(1) 30-day average limitations. Daily aaximtM values are three tines the limitation stated.
Ui
to
-a

-------
TABLE IX-3
BPT EFFLUENT LIMITATIONS GUIDELINES
HOT COATING - OTHER METALS
BPT Effluent Limitations in kg/kkg (lbs/1000 lbs)^^
Strip, Sheet, Miscellaneous
Products, Basic
Add for scrubbers
TSS
0.125
0.125
O&G
0.0375
0.0375
Chromium
0.00050
0.00050
Lead
0.00125
0.00125
Zinc
0.007 5
0.0075
(2)
Cadmium
0.00125
0.00125
pH
Units
6-9
6-9
Flow
Basis 	
GPT $/kkg $/ton
600
600
Estimated Cost
1.46
0.61
1.32
0.55
Wire Products and
Fasteners, Basic
Add for scrubbers
0.500
0.313
0.150
0.0938
0.00500
0.00313
0.00500
0.00313
0.0300
0.0188
0.00500
0.00313
6-9
6-9
2400
1500
17.67
3.81
16.03
3.46
Ui
M
CD
(1)	30-day average limitations. Daily maximum values are three times the limitation stated.
(2)	Applies only to operations using cadmium as a coating metal.

-------
Ui
KJ
vO
|No2S205 addition system
} used only if required to
<—< supplement reducing
/ ] capabilities of the
/ L~"

NOj S205
SOLUTION
(OPTIONAL)
EQUALIZATION
TANK
Alkaline
Waste
LIME
Susp. solids	c 50 mg/l
Oil 8k grease < 15 mg/l
Zinc	< 5 mg/l
Chromium	<3 mg/l
Chromium*6	<0.02 mg/l
pH 6-9
Flow:S«M	M to
POLYMER
CLARIFIER
Wyrvi i pi/i Kurrt
CHROME REDUCTION TANK
REACTOR
FLOCCULATOR
EQUALIZATION
TANK
Susp. solids
Oil 8 grease
Zinc
Chromium
(Chromium
'pH
Flow= Strip/*h«et 8
mics. product*
Wire product*
& fast.
50-200 mg/l
25 -75 mg/l
20-200 mg/l
4 -24 mg/l
2 -20mg/l
2 -10
Solids to
Disposal'
VACUUM
FILTER
T~Q-
BPT MODEL
(1200 gal/ton)
16,260 l/kkg
(3900 gal/ton)
i*
(600 gal/ton)
10,000 l/kkg
(2400 gal/ton)
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATING/GALVANIZING
SUBCATEGORY
BPT MODEL
Dwn. 1/31/79
FIGURE IX-1

-------
LIME
ACID
WASTES
POLYMER
EQUALIZATION
TANK
SUSR SOLIDS <50 mg/l
OIL a GREASE < 15 mg/l
TIN	< 5 mg/l
LEAD	<0.5 mg/l
pH	6-9
FLOW = 5000 l/kkg(l200 GAL/TON)
with scrubbers
= 2500 l/kkg (600 GAL/TON)
without scrubbers
OIL
ALKALINE
WASTES
~
o»o
EQUALIZATION
TANK
REACTOR
CLARIFIER
"/OIL SKIMMER
FLOCCULATOR
SUSR SOLIDS
OIL a GREASE
TIN
LEAD
PH
50*200 mg/l
25*75 mg/l
5-15 mg/l
0.5*2.0 mg/l
3-9
VACUUM

FILTER

\

FLOW = 5000 l/kkg (1200 GAL/TON)
with scrubbers
= 2500 l/kkg (600 GAL/TON)
without scrubbers
Solids to
Disposal
BPT MODEL
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATINGS"TERNE
SUBCATEGORY
BPT MODEL
DWN. 2/2/79
FIGURE JX-2

-------
ACID
WASTES
EQUALIZATION
TANK
ALKALINE
WASTES
EQUALIZATION
TANK
LI Mt
POLYMER
REACTOR
Susp. solids
Oil 8 grease
Aluminum
Cadmium
Chromium
Chromium*6
Copper
Nickel
Zinc
Tin
Lead
PH
<	50 mg/l
<	15 mg/l
<	5 mg/l
<0.5 mg/l
<	0.5 mg/l
<	0.02 mg/l
<0.3 mg/l
<0.3 mg/l
< 3 mg/l
<3 mg/l
<0.5 mg/l
6-9
Flow-Sam* as food to treatment
OIL
FLOCCULATOR
CLARIFIER
i* / nil criuuPD
Susp. solids
Oil 8 grease
Aluminum
Cadmium
Chromium
Chromium*®
Copper
Nickel
Zinc
Tin
Lead
pH
100*400 mg/l
25-60 mg/l
12-30 mg/l
1-4 mg/l
Q02-2 mg/l
0.02-1 mg/l
0-3-2 mg/l
0.3-2 mg/l
9- 20 mg/l
2- 10 mg/l
1-6 mg/l
3-9
FILTER
Flow* Strip/sheet
— & misc. product
Wire product
& fact.
With scrubber*
5000 l/kkg
(1200 gal/ton)
16,260 l/kkg
(3900 gal/ton)
Solids to
Disposal
No scrubbers
2500 l/kkg
(600 gal/ton)
10,000 l/kkg
(2400 gat/ton)
BPT MODEL
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATINGS-OTHER METALS
SUBCATEGORY
BPT MODEL
Own. 3/5/79
FIGURE JX.-3

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HOT COATING SUBCATEGORY
SECTION X
EFFLUENT QUALITY ATTAINABLE THROUGH
THE APPLICATION OF THE BEST AVAILABLE TECHNOLOGY
ECONOMICALLY ACHIEVABLE
Introduction
The Best Available Technology Economically Available (BAT) effluent
limitations are to be attained by July 1, 1984. BAT is determined by
reviewing subcategory practices and identifying the best economically
achievable control and treatment technologies employed within the
subcategory. In addition, a technology that is readily transferable
from another subcategory or industry may be identified as BAT.
This section identifies the BAT alternative treatment systems
considered for the hot coating subcategory. The rationale for
selecting the BAT alternative treatment system is presented along with
the proposed BAT limitations.
The BAT alternative treatment systems for hot coating operations are
summarized in Tables VIII-4 through VIII-6. Tables VIII-10 through
VIII-12 provide costs of the control and treatment technology
applicable or normally employed to reach the pollutant levels
indicated for each of three alternatives. Tables X-l through X-3
present the limitations for each coating metal subdivision. Figures
X-l through X-9 present the BAT alternative treatment systems matching
the appropriate tables. The effluent levels shown herein are not
necessarily the lowest values attainable (except where no discharge of
process wastewater pollutants to navigable waters is indicated) by the
alternative treatment systems but rather they represent values which
can be readily achieved on a regular basis.
It should be noted that these effluent loads represent values not to
be exceeded by any monthly average. Reference is made to Appendix A
of Volume I for the derivation of monthly average and daily maximum
performance standards.
Identification of BAT
In selecting the BAT model treatment systems, the Agency considered
the responses to the DCPs and D-DCPs, operating conditions observed at
the plants surveyed, and industry comments.
As indicated previously in Section III and IX, significant differences
exist among hot coating lines because of product requirements.
However, mass loadings of the various limited pollutants can be
* reduced from the proposed BPT levels through the application of
additional treatment. Flow rates from certain wastewater sources can
be minimized by cascade or countercurrent rinsing and recycle or
reuse.
533

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Wastewater discharge flow rates are reduced prior to treatment as a
first step toward control of toxic pollutants. Pickling, cleaning,
and final product rinses are cascaded to minimize discharges. Where
fume hood scrubbers exist, these wastewaters are recirculated either
before blowdown to treatment or by recycling treated wastewater to the
scrubber. DCP responses show that water flows at all types of
galvanizing lines have been reduced by these methods. Well run
scrubbers operate with 5-10% blowdown in controlling fumes from
galvanizing. All terne coating line scrubbers were reported as
once-through, although two out of three reported discharge flows are
less than 130 gallons per ton. Scrubbers are rare on lines coating
with other metals. The only wet scrubber flow rate reported by other
metal coating lines is from a wire aluminizer who cites an applied
flow rate of 11,520 GPT. Despite this enormous flow, the total
combined discharge (rinses and scrubber blowdown) leaving that line is
640 GPT. For a summary of recycle data applicable to scrubbers, refer
to Table X-4.
Several sheet and strip coating lines operate with rinsewater flows as
low as 1 to 30 gallons per ton. However, these cases represent the
lowest flow rates attained. The model BAT rinsewater flow is less
restrictive. All three BAT alternative treatment systems include flow
reduction so that rinsewaters will total 150 gallons/ton and fume hood
scrubber blowdown is reduced to 50 gal/ton for strip/sheet and
miscellaneous shapes. Wire, wire products and fastener coaters would
reduce flows to 600 gallons/ton for rinses and 150 gallons/ton for
fume hood scrubber blowdowns. Examples of those discharge levels are
summarized in Table X-5.
Concentration levels which the alternative BAT treatment systems can
attain are reviewed in Appendix A of Volume I. The technologies were
summarized in Table VII1-4 through VII1-6 and are described below.
The increase in operating costs in dollars per kkg ($/ton) of finished
product over costs necessary to operate the BPT model treatment system
is also indicated on the appropriate tables.
BAT Alternative No. 1_
The first BAT alternative relies on flow reductions described above to
increase retention times through the BPT treatment components.
Effluent concentrations are lower than at BPT due to increased solids
removal efficiency at the lower flow.
BAT Alternative No. 2
In Alternative 2, a sulfide precipitation step is added, followed by
filtration to provide optimum solids separation. The sulfide
precipitation technique has been used to treat similar wastewaters in
the metal finishing industry, while the filtration step has been used
in this subcategory. See Tables III-l and III-3, Plants 0112B, 01121, .
0432D, 0460E, 0580A, 0584C, 05B4E, 0612, 0684Y, 0856N, and 0860F, also
plant visits to Plants 111 and 116.
534

-------
BAT Alternative No. 3
The third alternative evaporates all wastewaters from the reduced flow
effluent, recondensing it as potable grade water for recycle to the
process or reuse elsewhere wherever high quality water is required.
Effluent Limitations
A review of analytical data shows that control over relatively few
toxic metal pollutants provides adequate control over all other toxic
metal pollutants in the wastewater. Therefore, the Agency is
proposing BAT limitations for three toxic metals (chromium, lead, and
zinc) for all hot coating operations, plus a fourth metal, cadmium,
for lines coating with cadmium. Refer to Section XI for proposed
effluent limitations for three conventional pollutants: TSS, oil and
grease, and pH. The available long-term data on these conventional
and toxic metal pollutants are summarized in Table X-6.
Selection of BAT Alternative
The Agency selected the BAT Alternative No. 1 as the BAT model
treatment system upon which the proposed BAT limitations are based.
After reviewing the costs involved and the pollutant load reductions
obtained, the third alternative was eliminated on the basis of high
capital and annual operating cost (especially energy costs) in
relation to the benefits achieved. The second alternative was not
selected since Alternative 1 can provide for about the same control of
toxic metals at less cost.
535

-------
TABLE X-l
BAT Effluent Limitations Guidelines
	Hot Coating - Galvanizing	
BAT Effluent Limitations in kg/kkg (lbs/1000 lbs)^"
A- Alternative 1*
Chromium
Lead
Zinc
Flow
Basis
GPT
Estimated Cost
(2)
$/kkg
$/ton
1.	Strip, Sheet, Misc. Prod. Basic	0.000063	0.000063	0.000063	150
Add to A1 for scrubbers	0.000021	0.000021	0.000021	50
2.	Wire Products & Fast. Basic	0.000250	0.000250	0.000250	600
Add to A2 for scrubbers	0.000063	0.000063	0.000063	150
0.31
0.07
0.71
0.41
0.28
0.07
0.64
0.37
B. Alternative 2
Cn
U>
1.	Strip, Sheet, Misc. Prod. Basic
Add to B1 for scrubbers
2.	Wire Products & Fast. Basic
Add to B2 for scrubbers
C. Alternative 3
1. All Products, w/ or vo/scrubbers
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
No discharge of process wastewater
pollutants to navigable streams.
150
50
600
150
0.45
0.09
1.62
0.06
2.86
0. 36
16.90
1.59
0.41
0.08
1.49
0.05
2.59
0.33
15.33
1.44
(1)	30-day average limitations. Daily maximiss values are three times the limitations stated.
(2)	Incremental additional cost over BPT.
*: Selected BAT alternative.

-------
TABLE X-2
BAT Effluent Limitations Guidelines
	Hot Coating - Terne Metal
BAT Effluent Limitations in kg/kkg (lbs/1000 lbs)^"
Alternative 1*
1.	Strip, Sheet, Misc. Prod. Basic
2.	For lines with scrubbers
Chroaiun
0.000063
0.000083
Lead
0.000063
0.000083
Zinc
0.000063
0.000083
Flow
Basis
GPT
150
200
Estimated Cost
(2)
$/fcfcg
0.55
0.74
$/ ton
0.50
0.67

-------
TABLE X-3
BAT EFFLUENT LIMITATIONS GUIDELINES
HOT COATING - OTHER METALLIC COATINGS
BAT Effluent Limitations in kg/kkg (lbs/1000 lbs)^'^
Ui
Ul
00
Chromium
Lead
Zinc
Cadmium
(2)
Flow
Bas is
GPT
Estimated Cost
(3)
69.53
7.16
$/ton
A.
Alternative 1*









1.
Strip, Sheet,
Hisc. Prod. Basic
0.000063
0.000063
0.000063
0.000063
150
0.37
0.34


Add to A1 for
scrubbers
0.000021
0.000021
0.000021
0.000021
50
0.12
0.11

2.
Wire Products
& Fast. Basic
0.000250
0.000250
0.000250
0.000250
600
1.50
1.36


Add to A2 for
scrubbers
0.000063
0.000063
0.000063
0.000063
150
1.72
1.56
B.
Alternative 2









1.
Strip, Sheet,
Hisc. Prod. Basic
0.000063
0.000063
0.000063
0.000063
150
0.60
0.54


Add to B1 for
scrubbers
0.000021
0.000021
0.000021
0.000021
50
0.14
0.13

2.
Hire Products
h Fast. Basic
0.000250
0.000250
0.000250
0.000250
600
5.40
4.90


Add to B2 for
scrubbers
0.000063
0.000063
0.000063
0.000063
150
1.92
1.74
C.
Alternative 3









1.
All products,
w/ or wo/scrubbers
No discharge
of process
wastewater

0
4.18
3.79




pollutants to navigable
streams.


0.50
0.45
63.15
6.49
(1)	30-day average limitations. Daily maximum values are three times the limitations stated.
(2)	Limits on ca As iurn only apply to operations which use cadmium as a coating metal.
(3)	Incremental additional cost over BPT.
*:	Selected BAT alternative.

-------
TABLE X-4
JUSTIFICATION OF BAT FLOW BASIS
HOT COATING SUBCATEGORY
FUM5 HOOD SCRUBBER RECYCLE SYSTEMS
Plant Data
Demonstrates:


Applied
Discharged
Percent

Percent
Plant
Product
GPT
GPT
Recycle
GPT
Reduction
BAT Basis
SSM
600
50
91.7



WPF
1,500
150
90.0
-
-
0060G-1
WPF
*
*
90.9

X
0060G-2
WPF
*
*
90.9

X
0060G-3
WPF
*
*
90.9

X
0060G-4
WPF
*
*
90.9

X
0060G-5
WPF
*
*
91.1

X
0060S-1
WPF
*
*
95.0

X
0060S-2
WPF
*
*
95.0

X
0060S-3
WPF
*
*
91.1

X
0112F-1
WPF
2,152
143
93.4
X
X
0112F-2
WPF
4,000
267
93.3

X
0112F-A11
WPF
2, 796
186
93.3

X
0460C
WPF
806
0
100.0
X
X
0492A
SSM
387
0
100.0
X
X
0584C-1
SSM
1,319
158
88.0


0684B
SSM
312
0
100.0
X
X
0856F-2
SSM
7,784
0
100.0
X
X
0856 P
WPF
14,520
0
100.0
X
X
0864B-3
WPF
2,028
0
100.0
X
X
0864B-5
SSM
8.3
8.3
0.0
X

0864B-A11
Both
57
8.1
85.8
X

0868A-3
SSM
15.3
15.3
0.0
X

0920D-1
SSM
640
0
100.0
X
X
0920D-2
SSM
1,620
0
100.0
X
X
0920D-A11
SSM
981
0
100.0
X
X
0860F-4
WPF-AL
11,520
0
100.0
X
X
* : Plants requested confidential treatment of pro duct ion-related data.
X : Data supports stated BAT blowdown flow basis or recycle rate as indicated.
SSM: Strip, sheet and miscellaneous products.
WPF: Wire products and fasteners.
WPF-AL: Aluminizing line coating wire. All others are galvanizing lines.
539

-------
TABLE X-5
JUSTIFICATION OF BAT FLOW BASIS
HOT COATING SUBCATEGORY
RINSEWATER FLOW REDUCTION SYSTEMS
P lant	Product
BAT Basis:
SSM

WPF
0112B
SSM
0112F
WPF
0256 G-l
SSM
02 56 G-2
SSM
0264-1
WPF
0264-2
WPF
0264-3
WPF
0264-All
WPF
0264 Th 2
WPF
0384A-1
SSM
0384A-2
SSM
0384A-3
SSM
0384A-4
SSM
0384A-A11
SSM
0432B
SSM
044 8A
SSM
0460C
WPF
0460F-1
WPF
0460F-2
WPF
0460F-A11
WPF
0460H-1
WPF
0460H-2
WPF
0476A-3
SSM
0612-1
WPF
0612-2
WPF
0612-3
WPF
0612-4
WPF
0640-1
WPF
0728
SSM
0856 N-l
SSM
0856 N-2
SSM
0856 N-3
SSM
0856N-A11
SSM
Applied
Discharged
GPT
GPT
600
150
2,400
600
101
101
627
533
107
107
107
107
1,580
596
1,210
605
451
4.5
991
345
2,641
574
31.6
31.6
21.9
21.9
16.8
16.8
168
168
78.0
78.0
2.2
2.2
0.95
0.95
1,080
5.4
706
141
627
125
641
127
507
507
507
507
56
56
1,510
196
1,510
196
1,510
196
1,510
196
529
529
480
0
112
0
214
0
218
0
165
0
Plant Data
Demonstrates:
Percent	Percent
Reduction GPT Reduction
75.0
-
-
75.0
-
-
0.0
X

15.0
X

0.0
X

0.0
X

62.3
X

50.0


99.0
X
X
65.0
X

78.3
X
X
0.0
X

0.0
X

0.0
X

0.0


0.0
X

0.0
X

0.0
X

99.5
X
X
80.0
X
X
80.0
X
X
80.0
X
X
0.0
X

0.0
X

0.0
X

87.0
X
X
87.0
X
X
87.0
X
X
87.0
X
X
0.0
X

100.0
X
X
100.
X
X
100.0
X
X
100.0
X
X
100.0
X
X
540

-------
TABLE X-5
JUSTIFICATION OF BAT FLOW BASIS
HOT COATING SUBCATEGORY
RINSEWATER FLOW REDUCTION SYSTEMS
PAGE 2		
Plant Data
Demonstrates;
Applied Discharged Percent	Percent
Plant
Product
GPT
GPT
Reduction
GPT
Reduction
0860F-1
WPF
3,130
157
95.0
X
X
0860F-2
WPF
5,760
9.6
99.8
X
X
0860F-3
WPF
5,760
6.4
99. 9
X
X
0860F-A11
WPF
4,500
79.4
98.2
X
X
0860G-1
WPF
8,182
0
100.0
X
X
0860G-2
WPF
3,025
0
100.0
X
X
0868A-1
SSM
182
182
0.0


0868A-2
SSM
135
135
0.0
X

0868A-3
SSM
169
169
0.0


0868A-A11
SSM
163
163
0.0


0916A-3
SSM
120
0
100.0
X
X
0920D-1
SSM
640
64
90.0
X
X
0920D-2
SSM
120
120
0.0
X

0920D-A11
SSM
459
83. 5
81.8
X
X
0920E-1
SSM
116
116
0.0
X

0920E-2
SSM
136
136
0.0
X

0920E-3
SSM
164
164
0.0


0920E-A11
SSM
132
132
0.0
X

094 8A
SSM
7.6
7.6
0.0
X

0948C-1
SSM
140
140
0.0
X

0948C-2
SSM
92
92
0.0
X

0948C-A11
SSM
111
111
0.0
X

0920F
SSM
301
141
53.2
X

(Terne)






0384A( Al)
SSM
16
16
0.0
X

0580G-3(Sn)
WPF
300
300
0.0
X

0792B(Sn)
SSM
80
0 (1)
640
100.0
x( 1)
xu;
X
0860F-4(A1)
WPF
10,800
94.1
X
(1) Flow included scrubber blowdown. Demonstrates combined discharge
flow basis of 750 GPT.
X : Data supports stated BAT discharge flow basis or percent reduction as
indicated.
SSM: Strip, sheet and miscellaneous products.
WPF: Wire products and fasteners.
( ): Coating metal shown within parentheses. All others are
galvanizing lines.
541

-------
TABLE X-6
LOIR-TERM DATA EVALUATION
HOT OOATIHG - CM.VAHIZIH6
Plant 0612*
Wire Mill, no scrubbers:
Applicable BAT limitatioaa
Plant Data - 96 Samplea
Percent of BAT Limitations
Present Effluent Loads in kg/khg
(1)
TSS
(2)
O&G
(3)

Max.
0.0375
0.00245
6.5

Max.
0.100
0.0123
12.3
0.000327
Chromium
Avg.
0.0250
0.00354
14.2
0.00025
NA
Max.
0.00075
HA
Lead
Avg.
Max.
0.00025 0.00075
0.000016 0.000074
6.4	9.9
Zinc
Avg.
Max.
0.00025 0.00075
0.000172 0.000687
68.8 91.6
Plant 0868A
Sheet Mill, 601 with acrubbera. 401 no scrubbers
Applicable BAT limitations
Plant Data - 148 samples
Percent of BAT limits
Plant Data - omit each maxi
Percent of BAT limits
(4)
0.0113
0.0216
191
0.0160
142
0.0303
0.846
2792
0.00360
0.00345
0.00751
0.0258
344
0.000075
<0.000031
<41.3
<0.000028
<37.3
0.000225
0.000360
160
0.000075
NA
NA
0.000225
NA
NA
0.000075 0.000225
NA
NA
NA
NA
cn
to
Plant 0580*
Wire Cloth Mills, no scrubbers
Applicable BAT limitations
Plant Data - 101 ssmples
Percent of BAT limits
Plant Data - oeit each maximu
Percent of BAT limits
(4)
0.0375
0.0392
104
0.0326
86.9
0.100
0.701
701
NA
NA
0.0250
NA
NA
0.00025
NA
NA
0.00075
NA
NA
0.00025
NA
NA
0.00075
NA
NA
0.00025
0.0219
8760
0.0152
6080
0.00075
0.701
93,467
(1)	Loads calculated from average and maximum concentrations applied to long term average flows reported by plants.
(2)	BCT limits only (30-day average and maximum daily).
(3)	BCT limits only (maximum daily limit only).
(4)	Average value recalculated by diacarding maximum concentration and dividing by one leas than the total number of samples.
NA: Plant did not report any long term data on this parmaeter.
* : Plant 0612 has technology equivalent to BAT in place and operating well. Meets all limitations for
which data are provided. Short term aampling indicatea that effluent contains only 13Z of the BAT average chromium limit.

-------
^Fresh water makeup
210 l/kkg (SO gal/ton) for Itrip & sheet
625 l/hkqU5Q qol/ton) for wire prod. & fastener!
-Recycle to wet fume hood
scrubber. 2295 l/kkg(550 gal/ton)
for slrip & sheet. 5630 l/kkg
(I350gol/ton)for wire prod,
fosteners.
"NO2S2O5 addition system is used
only if required to supplement reducing
capabilities of the available acid wastes
Acid
Wastes
equalization!
TANK j
Cascade rinse system to
minimize f low-625 l/kkg
(150 gal/ton)for stripAheet
& mite, product*.
2500 l/kkg (600 gal/ton) for
win product* a fast.
SOLUTION
(OPTIONAL) |
L I ME
POLYMER'
Alkaline
Wastes
¦Mao
I cJo I
EQUALIZATION T	I
j	I
TANK
Susp. solids
c
30 mg/l
Oil S grease
<
5 mg/l
Zinc
<
0.1 mg/l
Chromium
<
01 mg/l
Chromium*6
<
0.02 mg/l
Lead
<
01 mg/l
PH

6-9
Effluent flow

With scrubber*
StripAheet a

835 l/kkg
misc. products

(200 gol/ton)
Wire products

3130 l/kkg
& fast.

(750 gal/ton)
CHROME
REDUCTION
TANK
REACTOR
FLOCCULATOR
No scrubbers
625 l/kkg
050 gal/ton)
2500 l/kkg
(600 galAon)
RECYCLE PUMP
STATION
(Fume hood scrubber
systems only)
CLARIFIER |
' w/OIL SKIMMER 1
1 Susp. solids
1 Oil 8 grease
IZinc
/Chromium
. Chromium
I Lead
PH
Flo«« Strip/sheet 8
misc. products
Wire products
8k fast.
80-265 mg/l
35-100 mg/l
40-250 mg/l
6"30 mg/l
4-24	mg/l
0.2 -6 mg/l
5-9
Solids to4
disposol
VACUUM
FILTER
FB I	!	I * — »
.With twvMm
3130 l/kkg
(750 gal/ton)
No scrubbers
625 l/kkg
(150 gal/ton)
BPT MODEL
BAT MODEL
8760 l/kkg 2500 l/kkg
(2100 gal/ton) (600 gal/ton)
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATINGS/GALVANIZING
SUBCATEGORY
BAT MODEL-ALTERNATIVE I
Dwn. 1/31/79
FIGURE X" I

-------
-Fresh water makeup
210 !Akg(50 gal/ton)for strip a sheet
625 l/kkg (150 gol/ton) for wire prod. 8 fasteners
	Recycle to wet fume hood
scrubber. 2295 l/kkg(550gal/ton)
for strip 8 sheet. 5630 l/kkg
(1350 gal/ton) for wire prod.
8 fasteners.
Acid
Wastes
equalization!
TANK
Cascade rinse system 10
minimize flow-625 l/kkg
(150 gal/ton)for strip/sheet
8 misc. products.
2500 l/kkg{600 gd l/ton) for
wire products a fost.
Alkaline
Wastes
1 cJo |
EQUALIZATION T	I
i	1
N0 2O2 05
SOLUTION
(OPTIONAL)
CHROME
REDUCTION
TANK
Na2S205 addition system is used
only if required to supplement reducing
capabilities of the available acid wastes.
TANK
Susp. solids
Oil 8 grease
i Zinc
Chromium
Chromium*®
Leod
PH
Effluent flow
Strip/sheet ft
misc. products
Wire products
fast.
<15 mg/l
< 5 mg/l
<0.1 mg/l
<0.1 mg/t
<0.02 mg/l

-------
Recycle to process
4	
— CrAgk M0ter Mki'HD
210 l/kkg (50 gal/Ion) for strip a sheet
625 l/kkg(l50 gal/Ion) for wire prod. 8 fasteners
«-	
~F
Z
CONDENSER »
EVAP
SYSTEM
Recycle to wot fuM hood
2295 l/kkg<550 gal/ton) for strip 8 sheet
5630 l/kkg (1350gal/Ion)for wire prod8 fasteners J Ra£siOs
4	1 SOLUTION |
IJ^TJONAUj
-NotStOj addition systeM
is mod only if required to
supplement reducing capabilities
of the available acid wastes
Add
Was toe
| o»o
EqaailzatlaiiT
Tank
I
I
llj«1
Coscads rinse syetsni
to mIhImIzs flow
625 ISkhftlSOffllStan)
for stripAfcoaf &
Misc. products
2900l/tk«|GOO gat/ton)
wirs products a fast.
-y—f-—*
-4
L _
POLYMER |
f J

Dry solid**
CENTRIFUGE
AIMIm
Wastes
I
~
I
I
|^cJo 1
EyNtinllmr1
Tank
I
4__.
c»lo ! ! o»o



OIL
I
I
I
~1
I
I
• CLARIFIER WITH
SKIMME
Cferomo Reduction
Took
Reactor
Solids to
Disposal
"Susp. solids
Oil 8 grease
Zinc
Chromium
Chromium*6
Lead
pH
Flow
StripAhsst 8
misc. products
Wirs products
L ft fast.
80-265 mg/1
35-100 Mg/l
40-250 mg/1
6-30 mg/l
4-24 Mg/l
0.2-6 Mg/l
5- 9
With scrubbers
3130 l/kkg
(750 gal/ton)
8760 l/kkg
(2100 gal/ton)
Flocculator Recycle Pump Station 	
(Fums hood scrubber system only)
r^Ji
LFILTERJ w—C—Vj Chromium** <002 Mfl'/lY
yZt	Lead	<0-1 mg/l I
Jsuep. solids < 30 ngTT)
Oil A grease < 5 Mg/l/
inc	
-------
^Frt'^h walor ni(ikku|<
210 l/kkqtSO fjal/lon)
- Recycle to wet fume
scrubbers2295 l/kkg
(550 gal/ton)
Acid
Wastes
• LIME •
	• POLYMER"
equalization!
TANK ^	
Case ode rinse system to
miniinize flow-625 l/kkg
(150 gal/ton)
£3
Susp. solids
Oil 8 grease
Tin
Lead
Chromium
Zinc
PH
Flow835 t/Kkg (200 gal/ton)
"•/scrubbers
625 l/kkg(l50 gal/Ion)
"°/scrubbers
C30 rng/l
< 5 mg/l
3 mg/l
O.I mg/l
<0.1 mg/l
Alkaline	LJ
H-H
LcJoJ
EQUALIZATION T	I
T4"K *	J
Snap. eoikta
Oil a grease
Tin
Lead
Chromium
Zinc
PH
REACTOR
80-265 mg/l
35-100 mg/l
8-20 mg/l
0.8-2.4 mg/l
5-15 mg/l
2-4 mg/l
6-9
FLOCCULATOR
&
Solids lo^
disposal
VACUUM
FILTER
RECYCLE PUMP
STATION
(FUME SCRUBBER
SYSTEMS ONLY)

CLARIFIER
"/OIL SKIMMER
Flow* 3128 l/kkg (750 gal/ton)
"/scrubbers
625 l/kkg (150 gal/ton)
^ ""/scrubbers
¦BPT MODEL
•BAT MODEL
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATINGS" TERNE
SUBCATEGORY
BAT MODEL - ALTERNATIVE I
DWN.2/I/7S
I
IGURE X-4

-------
.-Fresh water
210 l/kkg(50 gal/Ion)
-Recycle to wet fume
scrubbers 2295 l/kkg
(550 gal/ton)
Acid
Wastes
EQUALIZATION T
TANK ^	
Cascade rinse system to
minimize flow"625 l/kkg
(ISO gal/ton)
rr
Alkaline	L-l
Wastes _ | I
Lc^J
EQUALIZATION I
TANK
L.J
• LIME i
Susp. solids
< 15 mg/l
Oil d grease
< 5 mg/l
Tin
< 0.1 mg/l
Lead
< 0.1 mg/l
Chromium
< 0.1 mg/l
Zinc
< 0.1 mg/l
pH
6-9
Flow= 835 l/kkg(200 gal/ton) |
"/scrubbers
= 625 l/kkg(l50 gal/ton) ]
""Vscrubbers
POLYMER!

REACTOR

IRON
SULFIDE
MIX
TANK	I
Rhl
i
¦fi
J
ML
FLOCCULATOR RECYCLE PUMP
STATION
(Fume Scrubbers
Syitemt Only)
Solid* to^_
disposal
fsisp. solids 80*265 mg/l
\ Oil fi grease 35-100 mg/l
I Tin	8*20 mg/l
J Lead	0.8-2.4 mg/l
Chromium 5*15 mg/l
) Zinc	2-4 mg/l
/ pH	6-9
/ Flow 3130 l/kkg (750 gal/ton) "/scrubbers
V	-625 l/kkg(l50 ga'/ton)wo/scrubbers
VACUUM
FILTER
r^H
L-


-BPT MODEL
-BAT MODEL
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATINGS-TERNE
SUBCATEGORY
BAT MODEL " ALTERNATIVE 2
DWN.2/I/7S
FIGURE X"5

-------
Ul
00
Recycle to Process
<4	^
Fresh water make-up
210 l/kkg (50 gal/ton)
r- Recycle to wet fume scrubbers
\2295 l/kkg (550 gal/ton)
CONDENSER
EVAP
SYSTEM
-f
¦V
Dry
Solids
CENTRIFUGE
Acid
Wastes
~
I
' LIME
I	
I
Li^ ;
Equalization!
Tank I
I

POLYMER
n
Cascade rinse system
to minimize flow
625 l/kkg()50 gal/ton)

~
i	1
! oil !
I
	*!
6o
Alkaline
Waste s_
~
I
oko I
Equalization!
I
4—^
Tank
I
• OO ,
I	I
Reactor
Flocculator
Recyc
Tl
Vis
e pump station
CLARIFIER/W
OIL SKIMMER
(Flume hood scrubbers only)
Susp. solids
80-265 mg/l
Oil 8 grease
35- 75 mg/l
Tin
8-20 mg/1
Lead
0.8-2.4 mg/l
Chromium
5-15 mg/l
Zinc
2-4 mg/l
pH
6-9
FIqv«= 3130 l/kkq(750 gal/tonlw/scrubb&rs.
_j VACUUM jj	
l_ FILTERJ

	j*
Susp. solids
Oil & grease
Tin
Lead
Chromium
Zinc
pH
Flow1
= 625 l/kkg(l50 gal/lon)wo/scrubbers
	BPT MODEL
	 BAT MODEL
<30 mg/l
<	5 mg/l
<	3 mg/l
<0.1 mg/l
<01 mg/l
<0.1 mg/l
6-9
035 l/kkg(200gal/ton)|
"/scrubbers
625 l/kkg(150 gat/ton)
w0/scrubbers
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATINGS-TERNE
SUBCATEGORY
BAT MODEL-ALTERNATIVE 3
>M0-28-77
FIGURE 2-6

-------
Cn
.fe.
ID
-Fresh water makeup
210 l/kkg(50 gal/ton) for strip, sheet 9 misc. prod.
625 l/kkgU50 go l/ton) for wire prod, a fasteners.
«p	Recycle to wet fume scrubbers
2295 l/kkg(550 gol/ton)for strip, sheet & misc. prod.
5630 l/kkg(l350 gal/ton) for wire prod. S fasteners
Acid
Wastes
EQUALIZATION T
TANK	|
Cascade rinse system
minimize flow-625 l/kkg
(150 gal/ton)for stripAheet
8 misc. products
2500 l/kkg(600 gal/ton) for
wire products & fast.
Alkaline
Wastes
EQUALIZATION
TANK
L I ME .
Susp. solids	<30 mg/l
Oil & grease	c 5 mg/l
Aluminum	<2.5 mg/l
Cadmium	<0.1 mg/l
Chromium	<0.1 mg/l
Chromium'6	<002 mg/l
Zinc	<0.1 mg/l
Tin	<1.5 mg/l
Lead	<0.1 mg/l
Copper	<0.1 mg/l
Nickel	<0.2 mg/l
pH	6-9
Effluent flow
Strip/sheet 8
misc. products
Wire products
ft fast.
With scrubbers
835 l/kkg
(200 gal/ton)
3130 l/kkg
1750 gal/ton)
No scrubbers
625 l/kkg
(150 gal/ton)
2500 l/kkg
(600 gal/ton)
POLY MER•
REACTOR
FL 0CCUL.AT OR
RECYCLE PUMP
STATION
(FUME HOOD SCRUBBER
SYSTEMS ONLY)
CLARIFIES
w/OIL SKIMMER
Susp. solids
Oil a grease
Aluminum
Cadmium
Chromium
Chromium^®
Zinc
Tin
Lead
Copper
Nickel
PH
Flow
180-500
mg/l
4-100
mg/l
15-50
mg/l
612
mg/l
2- 5
mg/l
1 - 4
mg/l
5-30
mg/l
5-30
mg/l
2-10
mg/l
0.1-1.0
mg/l
o.i-1.0
mg/l
Solids to4
disposal
VACUUM
FILTER
-_T^n_ J
L-^-J
6-9
With scrubbers
StripAheet 8 3130 l/kkg
misc. products (750 gal/ton)
Wire products
& fast.
8760 l/kkg
(2100 gal/ton)
No scrubbers
625 l/kkg
(150 gal/ton)
2500 l/kkg
(600 gal/ton)
	 BPT MODEL
	 BAT MODEL
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATINGS-OTHER METALS
SUBCATEGORY
BAT MODEL-ALTERNATIVE I
Dwn. 3/6/79
FIGURE X-7

-------
-Fresh water makeup
210 l/kkg(50 gal/ton) for strip, sheet a misc. prod.
625 l/kkg(>50 gal/ton) for wire prod. 8 fasteners.
-Recycle to wet fume scrubbers
2295 l/kkg(550 gal/ton) for strip, sheet fl misc. prod.
5630 l/kkg(1350 gal/ton) for wire prod, a fasteners.
Acid
Wastes
EQUALIZATION T
TANK ^	
Cmcode rinse system
minimize flow~625IAkg
(150 gal/ton )for (trip/sheet
8 misc. products
2500 l/kkg (600 gal/ton) for
wire products 8 fast.
Alkaline
Wastes
£
olo
EQUALIZATION
TANK
t	
Susp. solids
Oil & grease
Aluminum
Cadmium
Chromium
Chromium'6
Zinc
Tin
Lead
Copper
Nickel
Effluent flow
Strip/fcheet 8
misc. products
Wire products
6 fast.
<15 mg/l
< 5 mfl/l
<0.1 mg/l
<0.1 mg/l
<0.1 mg/l
<0.01 mg/l
<0.1 mg/l
<0.1 mg/l
<	0.1 mg/l
<	0.1 mg/l
<0.1 mg/l
With scrubbers
8 35 l/kkg
(200 gal/ton)
3130 l/kkg
(250 gal/ton)
No scrubbers
62S l/kkg
(150 gal/tori)
2500 l/kkg
(600 gal/ton)
I ME i
IRON
SULFIDE
POLYMER
PRESSURE
FILTER
MIX
TANK

RECYCLE PUMP
STATION
FLOCCULATOR
REACTOR
Susp. solids
l80-500mg/l

Oil 8 grease
4-100 mg/l

Aluminum
15-50 mg/l

Cadmium
6-12 mg/l
1
Chromium
Chromium®
2-5 mg/l Solids to
disposal
1-4 mg/l
1
1
Zinc
5"30 mg/l

Tin
5-30 mg/l

Lead
2-10 mg/l

Copper
0.1-1.0 mg/l

Nickel
0.1 -1.0 mg/l

PH
5-9

Flow
With scrubbers
Ng »?rvt>btrt
Strip/UiMt a
3130 l/kkg
625 l/kkg
misc. products
(750 gal/ton)
(150 gal/ton)
Wire products
8760 l/kkg
2500 l/kkg
a fast.
(2100 gal/ton)
(600 gal/ton)
VACUUM
F ILTER
	r~&i
BPT MODEL
BAT MODEL
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATINGS "OTHER METALS
SUBCATEGORY
BAT MOOEL - ALTERNATIVE 2
3wn. 3/5/79
FIGURE X-8

-------
U1
Cn
RECYCLE TO PROCESS
Fresh water makeup
210 l/kkg (50 gal/ton) for strip, sheet ft misc. prod.
625 l/kkg(ISOgal/ton) for wire prod, a fasteners.
z
CONDENSER
EVAP
SYSTEM

Recycle to wet fume scrubbers
2295 IAkg(550 gal/ton) for strip, sheet 8 misc. prod.
5630 l/kkg(l350 gal/ton) for wire prod. 8 fasteners.
DRY
SOLIDS_
I
CENTRIFUGE
ACID
WASTE
EQUALIZAHOM
Cascade rinse
system to minimize flow.
625 l/kkg (150 gal/ton )for
strip/sheet 8 misc. products
2500 l/kkg(600 gal/ton)for
wire products 8 fasL
ALKALINE
WASTES
equalization!
TANK
t—J
I LIME
J,G
POLY
^ELECTROLYTE
OK)
REACTOR

I	1
Sb
Susp. solids
Oil & grease
Aluminum
Cadmium
Chromium
Chromium'6
Zinc
Tin
Lead
Copper
Nickel
PH
Flow
180-500 mg/l
4-100	mg/l
15-50
6- 12
2-5
1-4
5-30
5-30
2-10
0.1 -1.0
0.1-1.0
6-9
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
FLOCCULATOR
SOLIDS TO
DISPOSAL^"
RECYCLE PUMP STATION
(FUME SCRUBBERS ONLY)
V
I
	OIL
CLARIFIER/W
SKIMMER
VACUUM
"Lf'lterJ"
Susp. solids
I Oil 8 grease
Aluminum

SfrifrthMt ft
misc. products
Wire products
a fast.
With scrubbers
3130 l/kkg
(750 gal/ton)
8760 l/kkg
(2100 gal/ton)
No scrubbers
625 l/kkg
(150 gal/ton)
2500 l/kkg
1600 gal/ton)
Cadmium
Chromium
Chromium
Zinc
Tin
Lead
Copper
Nickel
pH
BPT MODEL
BAT MODEL
»6
<30 mg/l
< 5 mg/l
<2.5 mg/l
<0.1 mg/l
<0.1 mg/l
<0.02 mg/l
<0.1 mg/l
<1.5 mg/l
<01 mg/l
<0.1 mg/l
< 0.2 mg/l
6-9
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATINGS "OTHER METALS
SUBCATEGORY
BAT MODEL-ALTERNATIVE 3
Dvrn. 3/6/79
FIGURE X-9

-------
HOT COATING SUBCATEGORY
SECTION XI
BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY (BCT)
Introduction
The 1977 Amendments added Section 301(b)(4)(E) to the Act,
establishing "best conventional pollutant control technology" (BCT)
for discharges of conventional pollutants from existing industrial
point sources. Conventional pollutants are those defined in Section
304(g)(4) - BOD, TSS, fecal coliform and pH - and any additional
pollutants defined by the Administrator as "conventional." On July
28, 1978, EPA proposed that COD, oil and grease, and phosphorus be
added to the conventional pollutant list (43 Fed.Reg. 32857). Only
oil and grease was added.
BCT is not an additional limitation, but replaces BAT for the control
of conventional pollutants. BCT requires that limitations for
conventional pollutants be assessed in light of a new
"cost-reasonableness" test, which involves a comparison of the cost
and level of reduction of such pollutants from a class or category of
industrial sources. As part of its review of BCT for certain
"secondary" industries, EPA proposed methodology for this cost test.
(See 43 Fed.Reg. 37570, August 23, 1978).
For hot coating operations, the conventional pollutants of concern are
total suspended solids, oils and greases, and pH. The proposed pH
limitations are identical for BPT and BCT, so the need to justify the
control of pH under BCT cost test guidelines is obviated.
Development of BCT
Two BCT alternative treatment systems are shown in Figure XI-1. The
first alternative includes cascade rinsing and recycle of fume hood
scrubbers, while the second alternative includes filtration of the
resultant effluent from Alternative No. 1.
The costs of treating TSS and O&G to more stringent levels were
estimated for the two BCT alternative treatment systems and were
presented in Section VIII. A summary of that industry/POTW cost
comparison follows.
553

-------
Costs in $/lb of
Conventional Pollutant Removed
Alt. 2
Alt. 1
POTW
Galvanizing
Strip/Sheet/	1.34
Misc., w/scrub
Strip/Sheet/	1.34
Misc.,wo/scrub
Wire Prod. &	1.34
Fast.,w/scrub
Wire Prod. &	1.34
Fast.,wo/scrub
Terne Coating
Strip/Sheet/	1.34
Misc., w/scrub
Strip/Sheet/	1.34
Misc.,wo/scrub
Other Metal Coatings
Strip/Sheet/	1.34
Misc., w/scrub
Strip/Sheet/	1.34
Misc.,wo/scrub
Wire Prod. &	l.34
Fast.,w/scrub
Wire Prod. &	1.34
Fast.,wo/scrub
Selection of a BCT Alternative
With two exceptions, the BCT Alternative 1 technology passes the cost
test, and with four exceptions, the BCT Alternative 2 technology
passes the cost tests. On this basis, the proposed BCT limitations
are based upon the proposed BPT limits (terne-coating without
scrubbers and other metal coatings-wire products and fasteners with
scrubbers); BCT-1 (other metal coatings - strip, sheet, and
miscellaneous products without scrubbers, and wire products and
fasteners without scrubbers); and BCT-2 for the six remaining
segments. Proposed BCT limitations for each of the hot coating
subdivisions are shown in Tables XI—1 through XI-3.
0.58	0.75
0.99	1.27
0.53	0.87
0.57	1.10
0.87	1.15
1.36	1.82
0.75	1.02
1.20	1.66
1.54	2.88
1.21	3.31
554

-------
Development of BCT Limitations
The Agency is proposing limitations for suspended solids, oil and
grease, and pH at BCT for all hot coating segments. The BCT
limitations for terne coating without scrubbers and other metal
coatings - wire products and fasteners with scrubbers are the same as
the respective BPT limitations. The BCT limitations for all other
segments of the hot coating subcategory are based on the BCT
Alternative 1 or Alternative 2 as discussed above.
555

-------
TABLE XI-1
BCT EFFLUENT LIMITATIONS GUIDELINES
HOT COATING - GALVANIZING
BCT Effluent Limitations in kg/kkg (lbs/1000 lbs)
A. Alternative 1*
TSS
(1)
0il anf?1
Grease
pH
Unit 8
Flow
Basis
BPT
1.	Strip, Sheet, Misc. Prod. Basic	0.00938
Add to A1 for Scrubbers	0.00313
2.	Wire Products & Fast. Basic	0.0375
Add to A2 for Scrubbers	0.00938
0.00626
0.00209
0.0250
0.00626
6-9
6-9
6-9
6-9
150
50
600
150
B. Alternative 2
1.	Strip, Sheet, Misc. Prod. Basic	0.00938
Add to A1 for Scrubbers	0.00313
2.	Wire Products & Fast. Basic	0.0375
Add to A2 for Scrubbers	0.00938
0.00626
0.00209
0.0250
0.00626
6-9
6-9
6-9
6-9
150
50
600
150
(1)	30-day average limitations. Daily maximum values are 2.67 times the limitations stated.
(2)	Daily maximum limitations only. There is no 30-day average limitation for Oil and Grease.
Selected BCT alternative.
556

-------
TABLE XX-2
BCT effluent limitations guidelines
HOT COATING - TERNE METAL	
BCT Effluent Limitations in kg/kkg (lbs/1000 lbs)
A.	Alternative 1*
Strip, Sheet, Misc. Prod. Lines;
Without Scrubbers
With Scrubbers
B.	Alternative 2
Strip Sheet, Misc. Product Lines:
Without Scrubbers
With Scrubbers
TSS
(1)
0.125
0.0125
0.125
0.0125
Oil and,.
Grease
0.0375
0.00834
0.0375
0.00834
pH
Uni ts
6-9
6-9
6-9
6-9
Flow
Basis
BPT
600
200
600
200
(1)	30-day average limitations. Daily maximum values are 2.67 times the stated limitation
for lines with scrubbers, and 3 times the stated limitation for lines without scrubbers.
(2)	Daily maximum limitations only. There is no 30-day average limitation for Oil and Grease.
*: Selected BCT alternative.
557

-------
TABLE XI-3
BCT EFFLUENT LIMITATIONS GUIDELINES
HOT COATING - OTHER METALLIC COATINGS
BCT Effluent Limitations in kg/kkg (lbs/1000 lbs)
TSS
(1)
Oil and v
Grease
pH
Units
Flow
Basis
BPT
A. Alternative 1*
2.
Strip, Sheet, Misc. Prod. Lines:
Without Scrubbers	0.0188
With Scrubbers	0.0125
Wire Product & Fast. Lines:
Without Scrubbers	0.0751
With Scrubbers	0.813
0.00626
0.00834
0.0250 .
0.244
6-9
6-9
6-9
6-9
150
200
600
3900
B. Alternative 2
Strip Sheet, Misc. Product Lines:
Without Scrubbers	0.0188
With Scrubbers	0.0125
Wire Products & Fast. Lines:
Without Scrubbers	0.0751
With Scrubbers	0.813
0.00626
0.00834
0.0250.»
0.244
6-9
6-9
6-9
6-9
150
200
600
3900
(1)	30-day average limitations. Daily maximum values are 2.0 times the stated limitation
for lines with no scrubbers, and 2.67 times the stated limitation for strip, sheet, &
misc. prod, lines with scrubbers and 3.0 times the stated limitation for wire product
& fastener lines with scrubbers.
(2)	With one exception (see note 3) these are daily maximum limitations only.
(3)	30-day average limitation. Daily maximum values are 3.0 times the stated limitation.
558

-------
BPT
(TERNE WITHOUT SCRUBBERS AND OTHER METALS,
,		| LIME| —| POLYMER
-•l	[OIL	1 I 1	1	
CLARIFIER
Air
(TERNE AND
OTHER METALS)
(OTHER METALS
WITHOUT SCRUBBERS)
BCT-I
,N02S2O5'
1 SOLUTION 1
' f ~ J| OIL
1 LIMeI —I POLYMER
BCT-2
( ALL GALVANIZING, TERNE WITH
SCRUBBERS AND OTHER METALS.
WIRE PRODUCTS FASTENERS
WITHOUT SCRUBBERS.)
CLARIFIER
Air
(TERNE AND
OTHER METALS)
- - OPTIONAL COMPONENT, DEPENDING
UPON COATINS METAL.
FILTER
VACUUM
FILTER
VACUUM
FILTER
COATING
RINSE
WATER
FUME HOOD
SCRUBBER
(Once-Through)
CASCADE
RINSE
FUME HOOD
SCRUBBER
SLOWDOWN
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATINGS SUBCATEGORY
ALL METALS
BCT MODELS SUMMARY
Dwn.ll/20/BC
FIGURE XI

-------
HOT COATING SUBCATEGORY
SECTION XII
EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICATION
OF NEW SOURCE PERFORMANCE STANDARDS (NSPS)
Introduction
The effluent limitations which must be achieved by new sources, i.e.,
any source, the construction of which is started after proposal of new
source performance standards, are to specify the degree of effluent
reduction achievable through the application of the best available
demonstrated control technology, processes, operating methods, or
other alternatives, including, where practicable, a standard
permitting no discharge of pollutants.
For this subcategory, several plants in the industry are reported to
operate with no discharge. On the basis of demonstrated performance
at Plant 0856N, the Agency believes this option is viable for batch
pipe and tube galvanizing operations. However, the technology
employed at this plant may not be universally applicable to all hot
coating operations. A "no discharge of pollutants" limit is possible
for all hot coating operations through the use of advanced
technologies, e.g., vapor compression and distillation (BAT
Alternative 3) which have yet to be demonstrated on wastewaters from
hot coating operations. The technology exists and is listed as a
possible alternative for BAT.
Identification of NSPS Technology
The Agency considered two alternative treatment systems for new hot
coating operations. Variations in flow, product, and metal coating
affect the costs as shown in Tables VIII-14 through VIII-16, but the
basic treatment systems are very similar. Refer to Figure X11 — 1 and
XII-2 for NSPS treatment systems, and to Tables X11 — 1 through XII-3
for the individual limitations.
NSPS Alternative ]_
All new hot coating lines have the opportunity to minimize process
wastewater flows with cascade rinsing systems. Also, for those lines
with fume scrubbers, consideration is made for installing recycle
loops for scrubber wastewaters with minimum blowdowns to treatment.
These flow reduction methods should be part of all NSPS treatment
systems, since the extensive degree of treatment to follow is most
economically done on the smallest possible volumes. The remaining
steps in Alternative 1 include chromium reduction where necessary,
precipitation and flocculation with lime and polymers, clarification
with vacuum filtration of clarifier underflows, and recycle of a
portion of the treated wastewater back to the process. For discussion
of the efficacy of this sequence, refer to individual pollutant loads
in Section X, in particular to data from Plant 119. Note that
561

-------
although costs are higher for NSPS than for BAT, the technologies
include much that is considered part of BPT for existing plants.
Thus, NSPS is less expensive for new plants than the sum of BPT plus
BAT for existing plants, primarily because flow reductions occur
before other treatment facilities, so that smaller components are
required to achieve the same results.
NSPS Alternative 2
Alternative 2 includes all steps and components shown in Alternative
1, plus two additional steps. The clarifier overflow is further
polished with ferrous sulfide precipitation of dissolved metals,
followed by filtration using a deep bed pressure filter. Improved
solids and oil removals are obtained at modest increase in costs.
Filtration technology is currently practiced successfully by Plant
116. Refer to data tables and discussion in Section X.
Selection of NSPS
As in the case of BAT, the Agency selected NSPS Alternative 1 as the
NSPS model treatment system upon which the proposed new source
performance standards are based.
562

-------
TABLE XII-1
USPS Effluent Limitation* Guidelines
	Hot Coating - Galvanising	
ISPS Effluent Limitations in kg/Meg (lba/1000 lb«)(1)
A. Alternative I*
TSS
(2)
OtC
(3)
Chromium
Lead
Zinc
P"
Units
ui
ov
1.	Strip, Sheet, Kite. Prod. Basic
Add to A1 for scrubbers
2.	Hire Products t Fast* Basic
Add to A2 for scrubbers
I. Alternative 2
0.00938
0.00313
0.0375
0.00938
0.00626
0.00209
0.0250
0.00626
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
6-9
6-9
6-9
6-9
150
50
600
150
1.	Strip, Sheet. Hisc. Prod. Basic	0.00938	0.00626
Add to B1 for scrubbers	0.00313	0.00209
2.	Hire Products 6 Past. Basic	0.0375	0.0250
Add to B2 for scrubbers	0.00938	0.00626
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
6-9
6-9
6-9
6-9
150
50
600
150
(1)	30-day average limitations. Daily saiira values are three tines the limitations stated, except for TSS and O&C. See Notes (2) and (3).
(2)	Daily aaximus values for TSS are 2.67 times the limitations stated.
(3)	Daily maxiaw limit only. There is no 30-day average limit for oil and grease.
*: Selected USPS alternative.

-------
TABLE XII-2
NSPS Effluent Limitations Guidelines
	Hot Coating - Terne Metal	
NSPS Effluent Limitations in kg/kkg (lbs/1000 Ibs)^"
Flov
A. Alternative 1*
1. Strip, Sheet, Misc. Prod. Basic
Add to A1 for scrubbers
I. Alternative 2
1. Strip, Sheet, Misc. Prod. Basic
Add to B1 for scrubbers
in
o\
(1)	30-day average limitations. Daily maximum values are three times the limitations stated, except for TSS and CXfcC. See Motes (2) and (3).
(2)	Daily maximum values for TSS are 2.67 times the limitations stated.
(3)	Daily maximum limit omly. There is mo 30-day average limit for oil and grease.
TSS
(2)
O&C
(3)
Chromiiaa
Lead
Zinc
PH
Units
Bas is
GPT
0.00934
0.00313
0.00626
0.00209
0.000063
0.000021
0.000063
0.000021
0.000063
0.000021
6-9
6-9
ISO
50
0.00938
0.00313
0.00626
0.00209
0.000063
0.000021
0.000063
0.000021
0.000063
0.000021
6-9
6-9
150
50
*t Selected USPS alternative.

-------
TABLE XI1-3
USPS EFFLUENT LIMITATIONS GUIDELINES
HOT COATING - OTHER METALLIC COATINGS
NSPS Effluent Limitations in kg/kkg (lbs/1000 lbs)''^
Alternative 1*
TSS
O&G
(3)
Chromium
Lead
Zinc
Cadmium
(4)
pH.
Uni ts
Flow
Bas is
GPT
1.	Strip, Sheet, Hisc. Prod. Basic
Add to A1 for scrubbers
2.	Wire Products & Fast. Basic
Add to A2 for scrubbers
B. Alternative 2
1.	Strip, Sheet, Misc. Prod. Basic
Add to B1 for scrubbers
2.	Wire Products & Fast. Basic
Add to B2 for scrubbers
0.00938
0.00313
0.0375
0.00938
0.00938
0.00313
0.0375
0.00938
0.00626
0.00209
0.0250
0.00626
0.00626
0.00209
0.0250
0.00626
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
0.000063
0.00021
0.000250
0.000063
0.000063
0.00021
0.000250
0.000063
6-9
6-9
6-9
6-9
6-9
6-9
6-9
6-9
150
50
600
150
150
50
600
150
Ui

-------
tn

Fresh water makeup
2IO l/kkg(50 gal/ion) for strip, sheet and misc. products
625 l/kkg(ISO gal/ton) for wire products and fasteners
Acid
Wastes*
Recycle to wel fume hood scrubber
2295 l/kkg(550gal/ton) for
strip, sheet and misc. prod. No-SpO. addition system is used only
5630 l/kkg(l350 gal/ton) jf required to supplement reducing
for wire prod, and fasteners capabilities of the available acid
wastes.—7
I	I
j n°2s205 I
j^SOLUTIONj
0>0	"
~
EQUALIZATION
TANK
Cascade rinse system to minimize
flow. 625 IAkgG50 gal/ton) for
strip/sheet B misc. products.
2500 IAkg(600 gal/ton) for
wire products & fasteners.
~t >
Alkaline
Wastes-
~
OkD
EQUALIZATION
TANK
L.^J
CHROME
REDUCTION
TANK
(Galvanizing Only)
POLYMER
LIME
REACTOR
Solids to
Disposal
/Susp. solids
Oil & grease
Zinc
Chromium
Cadmium
Copper
Lead
Nickel
PH
Flow
SIrip/sheet
misc. prod.
Wire prod.
. fasteners
5-9
"/scrubber
> 3130 l/kkg
(750gal/Ion)
, 8760 l/kkg
(2100 gal/ton)
Susp. soli^sj
Oil ft grease/
Zinc I
Chromium V
Cadmium f
Copper I
Lead \
Nickel 	)
PH
Flow:
StripAheef 8
misc. prod.
Wire prod. &
fasteners

Refer to Figures
1-1,1-4 and I"7
for water quality.
6-9
"/scrubber
835 l/kkg
(200 gal/ton)
3130 IA kg
(750 gal/ton)
w0/scrubber
625 l/kkg
(ISO gal/ton)
3500 l/kkg
(600 gal/Ion)
CLARIFIER "/OIL
SKIMMER
FLOCCULATOR
AirlTerne and other
metals only)
Refer to Figures
I"I, I"4 and X*7
for water quality.
VACUUM

FILTER

r^-
RECYCLE PUMP
STATION
(Fume hood scrubber
systems only)
""Vsc rubber
625 l/kkg
(150 gal/ton)
2500 lAkg
(600 gal/ton)
OPTIONAL COMPONENT
NSPS MODEL
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATINGS/ALL TYPES
SUBCATEGORY
NSPS MODEL-ALTERNATIVE I
DmiO/KV79
FIGURE M-l

-------
U1
/kkfl(l50 got/ton) for wire prod, a fasteners. |f required f0 eupptement reducing
capabilities of the available add
Acid
Wastes-
~
c>o
EQUALIZATION
TANK
to minimize
flow. 625 l/kfcgtlSO gal/ton) fcr
strlpfthsst a misc. products.
2500 l/kkrffiOO gal/ten) for
win products 8 fasteners.
Afeatine
~




o
o
EQUALIZATION
TANK
~
z
[no2S20~!
jSOLUTIONj


LIME
Susp. solids ^
Oil a grease I
Zinc
Chromium
Cadmium
Copper
Lead
Nickel
PH
Flows
Strip/sheet 8
misc. prod.
Wire prod, a
fasteners
J
Refer to Figures
X-2, x-5 ft X-8
for water quality.
6-9
w/scrubber
835 l/kkg
(200 gal/ton)
3130 l/kkg
1750 gal/ton)
w0Acrubber
625 l/kkg
(150 gal/ton)
2500 l/kkg
1600 gal/ton},
CHROME
REDUCTION
TANK
(Galvanizing only)
{REACTOR
IRON
SULFIDE
PRESSURE
FILTER











FLOCCULATOR
{ Sotdt to
I Disposal <
Air
(Teme a other
<§usp. soHdT>»*1ata «'*)
Oil a grease /
Zinc
Chromium
Cadmium
Copper
Lead
"S Nickel
pH
Flow
StTip/stwet a
misc. prod.
Wire prod, a
fasteners
VACUUM

FILTER

r^
RECYCLE PUMP
STATION
(Fume hood scrubber
systems only)
I f
h
Refer to Figures
X-2.X-5 a X-8
for water quality.
3-9
"Acrubber
3130 l/kkg
(790 gal/ton)
8760 l/kkg
(2100 gal/ton)
"0/scrubber
625 l/kkg
(ISO gal/ton)
2500 l/kkg
(600 gal/ton)
OPTIONAL COMPONENT
NSPS MODEL
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATINGS/ALL TYPES
SUBCATEGORY
NSPS MODEL-ALTERNATIVE 2
Own.ll/2/T9
(FIGURE XH.-2

-------
HOT COATING SUBCATEGORY
SECTION XIII
PRETREATMENT STANDARDS FOR HOT COATING PLANTS
DISCHARGING TO PUBLICLY OWNED TREATMENT WORKS
Introduction
This section discusses the alternative control and treatment systems
available for hot coating operations which discharge waste solutions
to publicly owned treatment works (POTW). Consideration has been
given to the pretreatment of hot coating process wastewaters from new
sources (PSNS) and from existing sources (PSES).
The main factor considered in the development of a pretreatment system
is the need to insure that the hot coating wastewaters are treated or
limited sufficiently to avoid overloading the POTW treatment system
and to avoid the introduction of pollutants to the POTWs which would
interfere with, pass through, or otherwise be incompatible with its
operations.
General Pretreatment Standards
For detailed information on Pretreatment Standards, refer to 43 FR
27736-27773, "General Pretreatment Regulations for Existing and New
Sources of Pollution," (June 26, 1978). In particular, 40 CFR Part
403 describes national standards (prohibited discharges and
categorical standards), revision of categorical standards through
removal allowances, and POTW pretreatment programs.
The General Pretreatment Regulations set forth general discharge
prohibitions that apply to all non-domestic users of a POTW to prevent
pass-through of pollutants, interference with the operation of the
POTW, and municipal sludge contamination. The regulations also
establish administrative mechanisms to ensure application and
enforcement of prohibited discharge limits and categorical
pretreatment standards. In addition, the Regulations contain
provisions relating directly to the determination of and reporting on
Pretreatment Standards.
Categorical Pretreatment Standards
In establishing pretreatment standards for hot coating operations, the
Agency gave primary consideration to the objectives and requirements
of the General Pretreatment Regulations.
Due to the presence of toxic pollutants in wastewaters from hot
coating operations, extensive pretreatment must be provided to ensure
that these pollutants do not interfere with or, pass through, or are
otherwise not compatible with POTW operations or cause harm to the
treatment plant. In general, the pretreatment wastewater treatment
technologies are the same as the BAT level treatments. Pretreatment
569

-------
standards for suspended solids and oil and grease are not proposed
because these pollutants, in the amounts present in this subcategory,
are compatible with POTW operations and can be effectively treated at
POTWs.
PSES alternative treatment systems are the same as the BAT alternative
treatment systems. The PSES standards associated with each
alternative treatment system for all hot coating operations are set
out in Tables XIII-1 through XIII-3. The alternative systems are
based on the BAT alternative treatment systems, and are shown in
Figures XIII-1 and XII1-2. Cost estimates were shown in Tables
VI11-17 through VIII-19.
A.	PSES Alternative 1
This alternative begins with flow minimization by cascade rinsing
and fume scrubber recycle, followed by chemical reduction of
chromium (if present as hexavalent chromium) or aeration (for
terne and other metal coatings), lime precipitation, flocculation
with polymers, and clarification with vacuum filtration of
underflows. Justification of this technology and its
effectiveness in controlling toxic metals is provided in Sections
IX and X.
B.	PSES Alternative 2
Alternative 2 is based on Alternative 1, with the addition of
sulfide precipitation to enhance removal of dissolved toxic
metals. The lower solubility of sulfides when contrasted with
hydroxides provides more complete conversion of dissolved toxic
metals into solid precipitates. These in turn are removed by
filtration just prior to discharge to the POTW.
New Sources
The alternative pretreatment systems for new sources are identical to
the pretreatment systems for existing sources discussed above.
Rationale for the Selection of Pretreatment Technologies
The pretreatment systems identified above are means of reducing toxic
metal pollutant levels and loads. Pretreatment standards must be
provided for toxic metals as toxic metals can inhibit the POTW
treatment process, pass through the POTW, contaminate the POTW
sludges, or otherwise interfere with the operation of the POTW.
Certain toxic metals inhibit the biological treatment process. The
use of the alternative pretreatment systems will minimize the
discharge of toxic metals from hot coating operations. The
possibility exists that a POTW could discharge undesirable levels of
toxic metals when accepting industrial process wastewaters. Inasmuch
as domestic wastewaters typically do not contain objectionable
concentrations or quantities of toxic metals, it is incumbent upon
industrial process wastewater contributors to a POTW to control the
levels and loads of toxic metals discharged to POTWs.
570

-------
The toxic metals, which do not pass through a POTW, concentrate in the
POTW sludges. Generally, land application is the most advantageous,
yet least expensive method of POTW sludge disposal as the sludge can
be used to replace soil nutrients. However, excessive amounts of
toxic metals in sludges could inhibit plant growth thus rendering the
sludge unfit for use as a soil nutrient supplement. In addition,
these metals could enter either the plant and/or animal food chains or
could leach into the groundwater. For the above reasons, the control
of toxic metals discharges to a POTW is essential.
Selection of Pretreatment Standards
The Agency selected Alternative 1 as the PSES model treatment system.
The proposed PSES are based on that treatment system. It provides for
the minimization of the discharge of toxic metals which may otherwise
adversely affect the performance of POTWs.
The Agency is not proposing standards for suspended solids or oil and
grease, because these pollutants, in the amounts present in hot
coating wastewaters, are compatible with POTW operations and can be
effectively treated at POTWs. However, it should be noted that the
control of suspended solids is an important factor in control of toxic
metals.
571

-------
TABLE XIII-1
PSES EFFLUENT LIMITATIONS GUIDELINES
HOT COATING - GALVANIZING	
PSES Effluent Limitations in kg/kkg (lbs/1000 lbs)^^
Chromium
Lead
Zinc
Flow
Basis
GPT
A.	Alternative 1*
1.	Strip, Sheet, Misc. Prod. Basic	0.000063	0.000063	0.000063	150
Add to A1 for scrubbers	0.000021	0.000021	0.000021	50
2.	Wire Products & Fast. Basic	0.000250	0.000250	0.000250	600
Add to A2 for scrubbers	0.000063	0.000063	0.000063	150
B.	Alternative 2
1.	Strip, Sheet, Misc. Prod. Basic	0.000063	0.000063	0.000063	150
Add to B1 for scrubbers	0.000021	0.000021	0.000021	50
2.	Wire Products & Fast. Basic	0.000250	0.000250	0.000250	600
Add to B2 for scrubbers	0.000063	0.000063	0.000063	150
(1) 30-day average limitations. Daily maximum values are three times the limitations stated.
*: Selected PSES alternative.

-------
TABLE XII1-2
PSES EFFLUENT LIMITATIONS GUIDELINES
	HOT COATING - TERNE METAL
PSES Effluent Limitations in kg/Ickg (lbs/1000 lbs)^
A.	Alternative 1*
1. Strip, Sheet, Misc. Prod. Basic
Add to A1 for scrubbers
B.	Alternative 2
1. Strip, Sheet, Misc. Prod. Basic
Add to B1 for scrubbers
Chromium
0.000063
0.000021
0.000063
0.000021
Lead
0.000063
0.000021
0.000063
0.000021
Zinc
0.000063
0.000021
0.000063
0.000021
Flow
Basis
GPT
150
50
150
50
(1) 30-day average limitations.- Daily maximum values are three times the limitations stated.
*: Selected PSES alternative.

-------
TABLE XII1-3
PSES EFFLUENT LIMITATIONS GUIDELINES
HOT OOATIHC - OTHER METAL COATINGS
PSES Effluent Limitation* in kg/kkg (lbs/1000 lba)^
Chromium
Lead
Zinc
Cadmiun
(2)
Basic
GPT
A. Alternative 1*
1.	Strip, Sheet, Misc. Prod. Basic
Add to A1 for scrubbers
2.	Hire Products i Fast. Basic
Add to A2 for scrubbers
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
150
50
600
150
B. Alternative 2
l_n
1.	Strip, Sheet, Misc. Prod. Basic	0.000063
Add to B1 for scrubbers	0.000021
2.	Wire Products & Fast. Basic	0.000250
Add to B2 for sscrubbers	0.000063
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
0.000063
0.000021
0.000250
0.000063
150
50
600
150
(1)	30-day average limitations. Daily suisin values are three tines the limitations stated.
(2)	Limits on cadmium apply only to operations which use cadmium as a coating metal.
*: Selected PSES alternative.

-------
Fresh water makeup
210 l/kkg (50 gal/ton) for strip, sheet & misc. prod.
625 t/kkg(l50 gol/ton)for wire prod. 8 fasteners.
Acid
Wastes *
Recycle to wet fume hood scrubber
2295 l/kkg(550 gal/ton)
5630 l/kkg(l350 gal/ton) re(flllre(j t0 supplement reducing
for wire prod. & fasteners, capabilities of the available acid
wastes.—y
I	i
Na2S205 |
|S0LUTI0Nj
0»0	"
~
EQUALIZATION
TANK
Cascade rinse system to minimize
flow. 625 lAkgSSO gal/tan) for
strrp/sheet a misc. products.
250O l/kkg(600 gal/ton) for
wire products & fasteners.
Alkaline
Wastes*
~
0*0
EQUALIZATION
TANK
POLYMER
LIME
CHROME
REDUCTION
TANK
(Galvanizing only)
Zinc )
Chromium [
Cadmium \
Copper (
Lead I
Nickel _)
PH
Flow:
Strip/sheet
misc. prod.
Wire prod.
l fasteners
^REACTOR
I
I Solids to
| Disposal1
Air
(Teme 6 other
metals only)
Refer to Figures
1-1,1-4 8X-7
for water quality.
5-9
"/scrubber
i 3,130 l/kkg
(750 gal/ton)
k 6760 l/kkg
12100 gal/ton)
Zinc |
Chromium j
Cadmium \
Copper [
Lead I
Nickel 	)
PH
Flow:
Strip/sheet 8
misc. prod.
Wire prod. &
fasteners
"\
Refer to Figures
1-1,1-4 8 X-7
for water quality.
6-9
"/scrubber
835 l/kkg
(200 gal/ton)
3130 l/kkg
(750 gal/ton)
w0Acrubber
625 l/kkg
(150 gal/ton)
2500 lAkg
(600 gal/ton)/
CLARIFIER "/OIL
SKIMMER
FLOCCULATOR
VACUUM

FILTER


RECYCLE PUMP
STATION
(Fume hood scrubber
systems only)
"°/scrubber
625 l/kkg
(150 gal/ton)
2500 l/kkg
(600 gol/ton)
OPTIONAL COMPONENT
PSES MODEL
ENVIRONMENTAL PROTECTION AGENCY
STEEL INDUSTRY STUDY
HOT COATINGS/ALL TYPES
SUBCATEGORY
PSES MODEL-ALTERNATIVE I
Dwn.lO/13/79
FIGURE xnr-1

-------
-Fresh water makeup
210 l/kkg(50 gal/ton) for strip, sheet 6 misc. prod.
625 l/kkg(l50gal/ton) for wire prod. & fasteners
for water quality.
Na2 s205 addition system is used only
if required to supplement reducing
capabilities of the available acid wastes.
Copper
Nickel
6-9
SOLUTION
3130 l/kkg 2500 l/kkg
(750 gal/ton) (600 gal/ton)
Wire prod. &
fasteners
LIME
EQUALIZATION
TANK
IRON
SULFIDE
OIL
PRESSURE
FILTER
Cc">cade rinse system to
minimize flow. 625 l/kkg
(150 gal/ton) for strip, sheet
& misc. prod. 2500 l/kkg
(600gal/ton) for wire prod.
8 fasteners.
< >
| REACTOR
' Solids to
| Disposal
FLOCCULATOR
CHROME REDUCTION
TANK
(Galvanizing only)
RECYCLE PUMP
STATION
(Fume hood scrubber
systems only)
VACUUM
FILTER
Air
(Teme & other
metals only)
SUBCATEGORY
PSES MODEL-ALTERNATIVE 2
FIGURE 2EI-2

-------