ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA-330/2-76-019
Characterization and Evaluation
of Wastewater Sources
United States Steel Corporation
Homestead Wheel and Axle Plant
Mc Kees Rocks, Pennsylvania
AUGUST 21-28, 1975
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER. COLORADO
JANUARY 1976
\ pro^°
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ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
CHARACTERIZATION AND EVALUATION OF WASTEWATER SOURCES
UNITED STATES STEEL CORPORATION
HOMESTEAD WHEEL AND AXLE PLANT
MC KEES ROCKS, PENNSYLVANIA
August 21-28, 1975
January 1976
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER - Denver, Colorado
and
REGION III - Philadelphia, Pennsylvania
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CONTENTS
I INTRODUCTION 1
II SUMMARY 4
III MONITORING PROCEDURES 9
IV MONITORING RESULTS 12
OUTFALL 018 17
OUTFALLS 019 AND 119 27
OUTFALL 020 30
GRAHAM STREET SEWER 31
EVALUATION OF WASTE OIL
TREATMENT FACILITY 32
V MONITORING REQUIREMENTS 39
APPENDIX
A HOMESTEAD WORKS RECONNAISSANCE
B FIELD STUDY METHODS
C CHAIN OF CUSTODY PROCEDURES
D ANALYTICAL PROCEDURES,
QUALITY CONTROL
E MARSH-MC BIRNEY FLOW METER
iii
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
1
2
3
TABLES
Industrial Waste Sampling 10
Process Status 13
Production Data, August 1975 14
Production Data, January-June 1975 .... 15
Field Measurements and TSS 18
Daily Oil and Grease Characteristics ... 19
Grab Sample Analysis, 0/G 20
Instantaneous Oil and Grease Loads .... 21
Summary of Metals Analyses 22
Self-Monitoring Data 23
Monitoring Schedule 24
Waste Loads per Unit Production 26
Organic Compounds 33
Waste OTP Evaluation 35
Recommended Monitoring Requirements ... 40
FIGURES
Homestead Wheel and Axle Plant 2
Wastewater Treatment Facility Flow
Diagram 34
Wheel Mill Separator 36
iv
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I. INTRODUCTION
The United States Steel Corporation (USSC) Homestead Works consists
of three separate areas. The Carrie Furnace area and the Main Homestead
area are on the Monongahela River, about 14.5 km (9 mi) upstream of the
confluence of the Ohio, Monongahela and Allegheny Rivers. The Wheel and
Axle works is on the Ohio River at McKees Rocks, Pennsylvania, about
4.8 km (3 mi) downstream from the confluence of the three rivers.
The McKees Rocks plant consists of the older manufacturing area
containing the permitted discharges, and the newer area containing
mostly dry operations [Fig. 1]. Railroad car axles and wheels are
manufactured at this plant from axle blooms and wheel blanks made at the
Main Homestead Plant.
Wastewaters are discharged through three outfalls: 018, 019 and
020.* All three outfalls discharge to the Graham Street storm sewer
which flows into the Ohio River, about 0.8 km (0.5 mi) east of the plant
property. USSC reported that outfall 018 contained 2,400 m3/day
(0.64 mgd) of untreated cooling water from the axle forge furnaces. Process
wastes in this sector are treated in an oil-water separator; the over-
flow from this separator, approximately 190 m /day (0.05 mgd), is piped
to the oil treatment facility. The separated oil is stored in an elevated
tank and hauled away by a commercial reclaimer. Outfall 019 receives
3
about 1,970 m /day (0.52 mgd) of cooling water from the wheel rolling
mill, 3,550 m /day (0.94 mgd) of untreated water from the power house,
and 2,915 m /day (0.77 mgd) of effluent from the oil treatment facility.
* Outfalls 001 through 017 are located at the Carrie Furnace and Main
Homestead areas.
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OATC
NEW BUILOIN08 AND tTOKASC PACIUTieS ACQUIRED OV
WHCCl AND AXLE DIVISION APPROXIMATELY 4 YEARS ASO
Flgur* I. U5SC and Axl• Dirhlon Plant, McK ft ffoclri, P»nniylvonlo
JULY 1975
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3
USSC has designated the effluent from the treatment facility as inter-
mediate location no. 119 for monitoring purposes. Influent to the oil
treatment plant is comprised of 2,725 m /day (0.72 mgd) process water
from the wheel mill plus the oil separator overflow from the axle forge
sector. Outfall 020 contains a minor cooling water discharge from the
machine shop quenching operation. USSC has withdrawn its application to
discharge through this outfall.
The plant obtains its water from a series of 5 or 6 wells on plant
property. Potable water is purchased from the municipality. Total
3
water supply currently amounts to 3,785 m /day (1 mgd).
On June 12, 1975, NEIC was requested to assist Region III in
investigating specific USSC discharges. A reconnaissance of the Home-
stead Works including the Wheel and Axle plant was conducted on July 23,
1975 [Appendix A]. In-plant monitoring of the waste sources and an
evaluation of the oil treatment facility was conducted on August 21-28,
1975. This report summarizes the results of this monitoring.
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4
II. SUMMARY
1. During August 21-28, 1975, the wastewater discharges from
outfalls 018, 019, 020, intermediate location 119, and the Graham Street
storm sewer were monitored. The two influents and the effluent from the
oil treatment facility were also monitored to determine treatment efficiency.
Flows were measured with NEIC and USSC devices, and pollutant loads were
calculated for each location except the Graham Street sewer (for which
flows were not measured).
2. Based on total production figures supplied by USSC for the
first six months of 1975 and August 21-28, the mill was operating at
production levels about 25% greater during the survey than in January
through June.
3. Outfall 018 contains only cooling water from the axle forge
O
sector. Company officials reported flows of 2,400 m /day (0.64 mgd).
During NEIC monitoring, flows ranged from 1,970 m /day (0.52 mgd) to
3,745 m^/day (0.99 mgd) and averaged 2,725 m^/day (0.72 mgd). The NEIC
monitoring data indicate that the discharge is essentially the only
cooling water, however oils or lubricants may also be discharged from
this outfall. All parameters tested were at detectable limits or very
low (except for oil/grease). USSC self-monitoring data also confirms
the NEIC data. The maximum oil/grease concentration found by NEIC was
16 mg/1; all other concentrations were 6 mg/1 or less. USSC data had
oil/grease concentrations ranging from 0.1 to 22 mg/1. On a unit
production basis, the average total suspended solids (TSS) and average
oil/grease loads over the seven days were as follows:
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5
Total Production*
TSS
Oil/Grease
(m.tons) (tons)
(kg/1,000 kg)(lb/ton)
(kg/1,000 kg)(1b/ton)
504 556
<0.06 <0.11
<0.01 <0.02
t Wheels and. Axles
USSC has riot proposed limitations for this outfall in their request
for an adjudicatory hearing.
4. Outfall 019 consists of untreated cooling water, water from
the power house, and the effluent from the oil treatment plant (inter-
mediate location 119 as designated by USSC). The total flow was reported
q
as approximately 8,300 m /day (2.2 mgd). During the NEIC survey, the
flows through outfall 019 ranged from 5,225 m^/day (1.38 mgd) to 6,470
3 3
m /day (1.71 mgd) and averaged 6,140 m /day (1.62 mgd), or about 75% of
the reported flow.
USSC has proposed that TSS and oil/grease be monitored at location
119 instead of 019. However, even though oil/grease and TSS concen-
trations were essentially equivalent at both locations, the loads must
be calculated on the total flow through outfall 019. Using the oil/
grease concentrations from location 119 and the flow from outfall 019,
the oil/grease load calculated is about 25% less than the oil/grease
load discharged through outfall 019, using flows and concentrations
measured at outfall 019. Since outfall 019 contains flow from all waste
sources in the wheel mill, power house, etc., while 119 consists of only
one waste source, monitoring should remain at outfall 019.
USSC has also proposed limitations for TSS and oil/grease (to be
monitored at 119) for the life of the NPDES permit. The proposed limitations
and the NEIC monitoring data are as follows:
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6
Param- USSC Proposed Limitations (119) Survey Data (019)
eter Daily Average Daily Maximum Daily Average Daily Maximum
(kg/day)(lb/day) (kg/day)(lb/day) (kg/day)(1b/day) (kg/day)(1b/day)
TSS 423 930 1,269 2,790 78 173 143 315
0/G 236 520 708 1,560 62 137 149 329
TSS and oil/grease loads were less than 20% and 30% of the daily average
proposed limitations. The maximum loads discharged for TSS and oil/grease
were only 10% and 21%, respectively, of the proposed maximum loads.
Using the USSC proposed limitations and the flow through outfall 019,
the average and maximum allowable concentrations would be 40 and 115
mg/1, respectively.
On a unit production basis for August 21-28, the average loads
discharged are compared with the proposed limitations.
Daily Average Waste Load
Par-am- USSC Proposed Actual (Aug. 21-28)
(kg/1,000 kg)(lb/ton) 0utfa11 019 Location 119
(kg/1,000 kg)(lb/ton)(kg/l,000 kg)(lb/ton)
TSS 0.84 1.67 0.15 0.31 0.03 0.07
0/G 0.47 0.94 0.12 0.25 0.01 0.03
5. Outfall 020, a non-permitted discharge,* contains quench water
o
from the machine shop. The flow averaged 8 m /day (2,300 gpd). TSS and
oil/grease levels were insignificant during August 21-28. However,
* USSC withdrew application for this outfall.
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7
self-monitoring data show TSS and oil/grease concentrations much greater
than those found during the NEIC survey. The TSS concentrations re-
ported by USSC ranged from 9 to 156 mg/1 and oil/grease concentrations
from 2 to 73 mg/1. NEIC personnel observed that quenching operations
were not being conducted whenever NEIC samples were collected. There-
fore, the self-monitoring data indicate that pollutants are discharged
from quenching operations.
6. The discharge from the Graham Street storm sewer at the Ohio
River, and a location in this sewer immediately above USSC1s connections
to the sewer,* were monitored to determine if USSC had additional con-
nections not reported. The data indicate that there are no additional
connections from the Wheel and Axle plant.
On August 25, a grab sample collected from the storm sewer dis-
charge to the Ohio River had low levels of organic compounds. Since the
compounds were not found in USSC's outfalls, they must have originated
downsewer from the USSC facility. The compounds, consisting of petroleum
hydrocarbons, ranged from Cg to C£q and appeared in a uniform pattern,
suggesting light-weight refined oils.
7. Due to fluctuations in USSC's effluent flow measuring device
(location 119), the degree of TSS and oil/grease removals in the waste
oil treatment facility could only be approximated. The treatment
process removed approximately 95% of the influent oil/grease load and
38% of the influent TSS load. The low solids removal efficiency is
partially attributed to the operating pH range of 5.4-7.5. Since the
effluent TSS concentration is <14 mg/1, additional solids removal is not
warranted. Effluent oil/grease concentrations ranged from 1-24 mg/1
and averaged 6 mg/1 over the seven-day period.
* Flows were observed upstream of USSC's connections to the storm sewer on
one occasion, during a rain storm.
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8
8. During the reconnaissance, USSC personnel stated that all
wastewater from the wheel mill flowed to the oil treatment facility.
Drawing no. BB-7410, submitted by USSC in response to the 308 Request
dated August 11, 1975, shows an intermittent flow from a sonic tester
sump to the wheel rolling mill flume containing up to 100,000 ppm oil.
About 1,890 1/min (500 gpm) of wastewater containing 200 ppm oil and 100
ppm TSS flows from this flume to the wheel mill oil separator prior to
discharge to the oil treatment facility. USSC personnel did not mention
this separator during the reconnaissance nor during the survey; there-
fore, it is unknown by NEIC personnel if all waste oil is directed to
the oil treatment facility.
9. USSC reports that total water pumped from their wells averaged
2
about 3,445 m /day (0.91 mgd) for January through June, 1975; during the
reconnaissance, USSC reported that the total water supply to the plant
O
averages 3s785 m /day (1 mgd). In their response to the 308 Request,
USSC stated that 120 m^/day (31,823 gpd) of sanitary wastes are dis-
charged to the Allegheny County Sanitary District. Effluent flows on
August 21-28 averaged 8,865 m^/day (2.34 mgd), and USSC previously
3
reported in the reconnaissance a total effluent flow of 10,750 m /day
(2.8 mgd). Therefore, based on the estimated intakes and measured
O C
effluents, about 3,785 m (1 X 10 gal) flows into the plant and about
9,000 m^ (2.4 X 10^ gal) flows from the plant per day. It is apparent
that USSC's methods of determining flows are not accurate or realistic.
USSC only measures flows from the waste oil treatment facility; all
other flows are estimated.
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Table 1
INDUSTRIAL WASTE SAMPLING
USSC HOMESTEAD WHEEL AND AXLE PLANT
August 21-28, 1975
Analyses Performed*
s£™!!!e TSS 0/G++ Phenol Total and Total and A1 Pb Sn 0rgan1cs+++
Description Type Dissolved Hexavalent
Fe Cr
Outfall 018 Composite X X X X X X
Grab X X
Influent to Composite X
011 Treatment Grab X
Plant from
Wheel Kill
Shop
Influent to Composite X
011 Treatment Grab X
Plant from
Axle Forge
Shop
Effluent from Composite X
Oil Treatment Grab X X
Plant,
Location 119
Outfall 019 -Composite X X X X X X
Grab X X
Outfall 020 Composite X
Grab X
Graham St. Composite X X X X X X
Sewer Grab X X
Upstream of
Outfall 018
Graham St. Composite X X X X X X
Sewer at Grab X X
Discharge to
Ohio River
t pH, temperature and flow were measured each time sample was collected at all stations (flaw was not measured
at either Graham St. sever location)
tt Oil/grease and phenol samples were collected three times during each 24-hour sampling period
ttt Organics sampled at 10 a.m. on August 25 and 1 p.m. on August 27
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11
and flow measurement techniques are contained in Appendix B. All
samples were collected and analyzed according to Chain of Custody
procedures [Appendix C] and analytical quality control procedures
[Appendix D].
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12
IV. MONITORING RESULTS
The various processes comprising the Wheel and Axle plant operate
on different schedules. USSC personnel, prior to sample collection,
verbally provided the following process schedule for the monitoring
period:
Process Number of Turns+ Time Days
Rolling Mill
1
0800-1600
Mon
thru
Sat
Axle Forge
3
0800-0800
Tue
thru
Sat
Circular Section
Forging ,
Finishing Areas
2
0800-2400
Mon
thru
Fri
3
0800-0800
Mon
thru
Fri
t A turn is equivalent to an 8-hour shift.
tt Include wheels circular section3 and axle areas
The above schedule was not completely followed due to equipment problems
and other operational difficulties. The actual process schedule during
the NEIC survey is listed in Table 2. The status of a particular
process was verbally provided by USSC personnel accompanying the NEIC
field teams during sampling periods.
Production data* provided by USSC for the monitoring period is
tabulated in Table 3. Production data* for the six-month period January
through June 1975 is tabulated in Table 4. The production data from
these two periods is summarized below.
* Data provided by USSC in response to the 308 Request dated August lly 1975.
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Table 2
13
PROCESS STATUS
USSC HOMESTEAD WHEEL AND AXLE PLANT
August 21-28s 1975
Process Date Time Periodt Process Status
(hours)
Axle Forge Thur. Aug. 21 0600 - 1800 Down
2000 - 2400 Up
Fri. Aug. 22 0001 - 0900 Up
1200 - 1500 Down
1800 - 2400 Up
Sat. Aug. 23 0001 - 1500 Up
1800 - 2100 Down
Sun. Aug. 24 0001 - 2400 Down
Mon. Aug. 25 0001 - 2400 Down
Tue. Aug. 26 0001 - 2400 Up
Wed. Aug. 27 0001 - 2400 Up
Thur. Aug. 28 0001 - 0600 Up
Rolling Mill Thur. Aug. 21 0600 - 1630 Up
1800 - 2400 Down
Fri. Aug. 22 0001 - 0455 Down
0600 - 0930 Up
1200 - 2400 Down
Sat. Aug. 23 0001 - 0630 Down
0930 - 1530 Up
1830 - 2130 Down
Sun. Aug. 24 0001 - 2400 Down
Mon. Aug. 25 0001 - 0300 Down
0300 - 1530 Up
1800 - 2400 Down
Tue. Aug. 26 0001 - 0630 Down
0900 - 1530 Up
1830 - 2400 Down
Wed. Aug. 27 0001 - 0630 Down
0900 - 1230 Up
- 1530 Down
- 1830 Up
2130 - 2400 Down
Thur. Aug. 28 0001 - 0600 Down
t Times are based on sampling schedules. Each time a sample was
collectedy USSC personnel stated whether1 the process was up or
down. This time period does not reflect accurately the time
periods the processes were operational; however} it does provide
the process status each time samples were collected.
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14
Table 3
PRODUCTION DATAf
USSC HOMESTEAD WHEEL AND AXLE PLANT
August 1975
Product^
Date Wheel Axle Total
(m. tori)(ton) (m. ton)(ton) (m. ton)(ton)
Thur. Aug.
21
403
444
40
44
443
488
Fri. Aug.
22
356
392
255
281
611
673
Sat. Aug.
23
208
229
160
176
368
405
Sun. Aug.
24
-
-
-
-
-
-
Mon. Aug.
25
423
466
-
-
423
466
Tue. Aug.
26
333
367
211
233
544
600
Wed. Aug.
27
389
429
250
276
639
705
t Data provided by USSC in November 5, 19753 transmittal to S. R.
Wassersug, Director, Enforcement Division, Region III, from James L.
Hamiltons Manager} Environmental Control - Water.
t+ Metric tons calculated from data (tons) provided by USSC.
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Table 4
PRODUCTION DATAf
USSC HOMESTEAD WHEEL AND AXLE PLANT
January-June 1975
Production Per Operating Day**
* + + +
Week ending Axle Production Wheel Production Total Production*
Maximum
Mi mmum
Avera<
5e
Maximum
Minimum
Averai
?e »
Averat
?e >
(m.ton)(ton)
(m.ton)(ton)
(m. ton)'
(ton)
(m.ton)(ton)
(m.ton)(ton)
(m.ton)i
[ton)
(m.ton)i
(ton)
1-4
N.O.**
N.O.
N.O.
N.O.
N.O.
N.O.
103
113
291
321
218
240
218
240
1-11
N.O.
N.O.
N.O.
N.O.
N.O.
N.O.
262
289
352
388
297
327
297
327
1-18
N.O.
N.O.
N.O.
N.O.
N.O.
N.O.
53
58
53
58
53
58
53
58
1-25
70
77
250
276
167
184
135
149
324
357
254
280
421
464
2-1
78
86
281
310
151
167
40
44
322
355
239
263
390
430
2-8
149
164
287
316
211
233
46
51
336
370
256
282
467
515
2-15
74
82
270
298
202
223
103
114
308
340
229
253
431
476
2-22
155
171
240
265
208
229
188
207
344
379
264
291
472
520
3-1
78
86
307
338
231
255
34
37
378
417
284
313
515
568
3-8
151
166
286
315
204
225
200
221
339
374
268
296
472
521
3-15
56
62
292
322
168
185
235
259
319
352
267
294
435
479
3-2Z
59
65
265
292
169
186
245
270
301
332
270
298
439
484
3-29
74
82
261
288
192
212
130
143
307
339
230
254
422
466
4-5
94
104
311
343
239
263
197
217
346
382
254
280
493
543
4-12
58
64
288
317
202
223
246
271
322
355
281
310
483
533
4-19
N.O.
N.O.
N.O.
N.O.
N.O.
N.O.
281
310
307
338
294
324
294
324
4-25
69
76
282
311
177
195
208
229
296
326
259
285
436
480
5-3
111
122
300
331
200
221
241
266
394
434
343
378
543
599
5-10
5
6
220
243
112
123
47
52
317
349
231
255
343
378
5-17
63
69
280
309
171
189
231
255
369
407
307
339
478
528
5-24
135
149
236
260
186
205
190
209
369
407
308
340
494
545
5-31
N.O.
N.O.
N.O.
N.O.
N 0.
N.O.
115
127
395
436
297
327
297
327
6-7
N.O.
N.O.
N.O.
N.O.
N.O.
N.O.
249
275
346
382
299
330
299
330
6-14
35
39
248
273
145
160
128
141
348
384
268
296
413
456
6-21
13
14
332
366
147
162
239
263
349
385
309
341
456
503
6-28
0.9
1
123
136
63
69
122
135
374
412
281
310
344
379
Six Month Avg.
73
81
268
295
177
195
164
181
317
349
253
279
400
441
+ Data provided by USSC in November 5, 1975, transmittal to S. R. Wassersug, Director Enforcement Division, Region III,
from James L. Hamilton, Manager Environmental Control - Water
tt Metric tons calculated from data (tons) provided by USSC
ttt Includes rolled wheels and circular sections. Production for the six-month period was 79.5% rolled wheels and 20.5%
circular sections.
* Total production calculated from USSC data
** Not Operating
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16
Production
Product Average Daily Daily Maximum
Aug. 21-28 Jan.-June Aug. 21-28 Jan.-June
(m.ton)(ton) (m.ton)(ton) Tm.ton)(ton) (m.ton)(tonIT
Wheels 352 388 253 279+ 423 466 395 436+
Axles 183 202 177 195 255 281 332 366
Total 504 556 400 441
t Includes rolled wheels and circular sections
Based on the total production figures, the data indicate that the Wheel
and Axle plant was operating at production levels about 25% greater than
production levels during the first six months of 1975.
Water used at the plant is obtained from USSC's wells.* Water
usage for the first six months of 1975 is tabulated below.**
_j Total Water Pumped Total Water Treated
(m3/mo.)(106gal/mo.)(m3/day)+(mgd)+ (m3/mo.)(106gal/mo.)
Jan.
72,500
19.150
2,350
0.62
40,100
10.590
Feb.
109,600
28.960
3,900
1.03
66,900
17.670
Mar.
114,800
30.340
3,700
0.98
67,700
17.890
April
119,600
31.600
4,000
1.05
72,500
19.150
May
105,600
27.900
3,400
0.90
59,500
15.700
June
100,950
26.670
3,350
0.89
52,000
13.740
t Calculated from number of days per month
3
The well water pumped averaged about 3,450 m /day (0.91 mgd).
During the survey, the total wastewater discharged averaged 8,790
m /day (2.32 mgd), or about 2.5 times the daily volume pumped during the
first six months. Because USSC reports a total average daily waste flow
of approximately 10,750 m3 (2.8 X 10^ gal), fresh water from the
* Waste loads are computed on a gross basis
** Provided by USSC in response to the 308 Bequest
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17
municipality must also be used in the processes or for cooling purposes
to make up the difference between pumped water and wastewater. Sanitary
wastes, discharged to the Allegheny County Sanitary District, amount to
120 m^/day (31,823 gpd); thus an additional 7,260 m^/day {1.92 mgd) of
fresh water must be used at the plant. However, total water supply is
reported at 3,785 m /day (1 mgd). Therefore, it appears that the USSC
method of determining water usage and wastewater volumes is not accurate
or realistic.
The in-plant monitoring results are tabulated by individual sampling
locatons and are summarized in Tables 5, 6, 7, 8, and 9. Self-
monitoring data and monitoring frequency for the period January through
June 1975 are summarized in Tables 10 and 11. Organic compounds were
only found in the Graham Street sewer discharge to the Ohio River and
are discussed in that section.
OUTFALL 018
According to USSC personnel, the discharge from the axle forge
sector only contains cooling water. The analytical results show that
the average daily TSS concentration for the seven-day period was
<10 mg/1.* This indicates that suspended solids were not added to the
cooling water from process operations. The oil/grease concentration
over the same period averaged about 2 mg/1.
During the five days the axle forge sector was operational, the
2
flow averaged 2,900 m /day (0.77 mgd). On the non-operating days,
* The detectable limit for TSS is 1 mg in 1 liter of water, by weight.
The TSS level for distilled water blanks, using 100 ml sampless was
less than 2 mg3 which corresponds to a detectable concentration of
<10 mg/l. Thereforey values of <10 mg/l TSS should be considered
as no net increase in solids over background levels.
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Table 6
SUtKART OF FIELD MEASUREMENTS AND TOTAL SUSPENDED SOLIDS
BCHESTLAD VHUL AND AXLE. PLANT
August 21-28, 197S
18
Flow
(m-Vday)
Station Description
Date
(August)
(m
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19
Table 8
DAILY OIL AND GFEASE CHARACTERISTICS
VSSC HOMESTEAD WHEEL AND AXLE PLANT
Auguot 21-28, 197S
Date
(August)
(6 a.m -6am)
Units
Outfall
018
Outfall
019
Outfall
020
Location
119
Influent to
OTP' from
Wheel Mill
Influent to
OTP from
Axle Shop
Graham St.
Sewer at
Ohio River
21-22
Flow •
m^/day
2610
6470
11
1380
1345
35
Flow
mqd
0.69
1.71
0.003
0.365
0.355
0.0098
Cone
mg/1
< 1.34
12
< 1
4
62
530
23
Load
kg/day
<3.5
78
< 0.01
6
84
20
Load
lb/day
< 7.7
171
< 0.03
13
185
43
22-23
Flow
m /day
2760
6395
8
1530
1415
115
Flow
mgd
0.73
1.69
0.002
0.405
0.374
0.0303
Cone
mg/1
< 1
8
< 3
3
88
470
< 1
Load
kg/day
< 2.8
54
< 0.02
3.8
125
54
Load
lb/day
< 6.1
120
< 0.05
8.4
275
119
23-24
Flow
m ./day
2345
6170
4
1145
1075
70
Flow
mgd
0.62
1.63
0.0011
0.302
0.284
0.0183
Cone
mg/1
< 5 •
8
< 2
15
121
533
5
Load
kg/day
10.6
49
< 0.006
16.9
130
37
Load
lb/day
23.3
109
< 0.01
37
286
81
24-25
Flow
m /day
1970
5225
0
220
220
0.4
Flow
mgd
0.52
1.38
0
0.058
0.058
0.0001
Cone
mg/1
< 2
4
0
6
65
110
< 3
load
kg/day
< 3.9
19
0
1.3
14
0.04
Load
lb/dav
< 8.7
42
0
2.9
31
0.09
25-26
3,,
Flow
m /day
2535
6210
6
1485
1485
0
Flow
mgd
0.67
1.64
0.0016
0.392
0.392
0
Cone
mg/1
< 1
24
< 1
5
131
0
5
Load
kg/day
< 2.5
149
< 0.006
7.4
194
0
Load
lb/day
< 5.6
328
< 0.01
16.4
427
0
26-27
3.,
Flow
m /day
3030
6210
12
1310
1260
50
Flow
mgd
0.80
1.64
0.0032
0.346
0.333
0.0132
Cone
mg/1
< 4
in
< 1
8
108
575
7
Load
kg/day
< 12.1
60
< 0.01
10.1
136
29
Load
lb/day
< 26.7
133
< 0.03
22.4
300
63
27-26
Flow
m^/day
3745
6320
9
1515
1440
75
Flow
mgd
0.99
1.67
0.0024
0.400
0.380
0.0199
Cone
mg/1
< 1
4
< 1
5
133
380
7
Load
kg/day
< 3.8
25
< 0.009
7.1
191
29
Load
lb/day
< 8.3
56
< 0.02
15.6
420
63
7-Day Average
3
Flow
m /day
2725
6140
8
1225
1175
58
Flow
mgd
0.72
1.62
0.0023
0.324
0.311
0.0153
Cone
mg/1
< 2
10
< 2
6
106
482
7 m
Load
kg/day
< 5.6
62
< 0.01
7.5
125
28
Load
lb/day
< 12.3
137
< 0.03
16.5
275
61
+ Oil Treatment Plant
tt Flou-ueighted average concentration
ttt Arithmetic average concentration
-------
Table 7
CRAB SAMPLE ANALYSES (OtL AND GREASE? PHENOL)
VSSC HOMESTEAD WHEEL AND AXLE PLANT
August 21-28, 1975
Sampling Location Influent to Oil Influent to 011 Graham Street
Date
Uutraii
om
Uutfall
uig
uutTai1
Ui?U
Locatl
on IIS
Treatment
Plant
Treatment
Plant
Sewer at Ohio
iollected
T. tt
Time
(hours)
From Wheel
Hill
From Axle Shop
River
August)
0/G
(mq/1)
Time
(hours)
0/G
(mq/1)
Time
(hours)
0/G
(mq/1)
Time
(hours)
0/G
(mq/1)
Phenol
(UQ/I)
Time
(hours)
0/G
f mq/1>
Time
fhours)
0/G
(mq/1)
Time
(hours)
6/6
(mq/1)
21
1425
< 1
1455
5
1505
< 1
153bt+t
1
< 1
1445
78
1440
NF*
1520
11
21
2007
< 1
2125
25
2145
1
2205**
7
NA***
2100
79
2040
' 780
2230
4
22
0415
2
0505
6
0520
1
0545
5
< 1
0455
30
0430
280
0600
53
22
1505
< 1
1540
2
1550
5
1625
3
1
1530
113
1520
100
1610
< 1
22
2100
< 1
2145
15
2150
< 1
2250
2
2
2135
63
2115
840
2220
1
23
0610
< 1
0635
4
0645
< 1
0710
5
1
0630
62
0620
610
0704
2
23
1505
2
1535
9
1545
1
1619
16
1
1525
210
1520
460
1605
6
23
1810
14
1850
8
1900
2
1945
14
1
1840
140
1810
530
1920
4
24
0002
1
0030
11
0040
NF
0115
24
< 1
0025
71
0001
NF
0055
8
24
1500
< 1
1515
5
1530
NF
1535
NF
NF
1515
NF
1510
NF
1535
< 1
24
1655
2
1706
4
1835
NF
1900
NF
NF
1703
NF
1810
NF
1720
3
25
0255
3
0320
2
0335
NF
0400
6
1
0313
65
0300
110
0350
4
25
1403
< 1
1423
39
1430
< 1
1455
9
1
1412
200
1408
NF
1445
3
25
2100
< 1
2120
9
2125
NF
2200
1
1
2110
61
2100
NF
2145
6
26
1300
< 1
1335
7
1345
< 1
1415
7
8
1325
260
1315
1060
1400
10
26
18C5
6
1830
12
1840
NF
1920
3
6
1821
77
1810
440
1905
7
26
2100
4
2130
9
2135
NF
2205
7
5
2120
53
2100
92
2150
5
27
0300
5
0330
11
0330
NF
0405
14
5
0320
42
0303
710
0350
6
27
1500
1
1530
4
1545
1
1625
2
5
1525
140
1513
150
1610
11
27
1800
< 1
1830
5
1835
NF
1915
6
5
1825
210
1805
370
1855
7
28
0303
< 1
0330
3
0350
< 1
0403
6
4
0315
48
0305
620
0400
2
+ All oil/grease samples corrected for blank value of 3 mg/l
tt Time scnple uas collected
ttt Phenol sanple collected at 15SS on August 21
* NF = Ho Flou
** Phenol sample collected at 002S on August 22
*** Phenol sanple not analyzed because bottle was broken in shipment from Pittsburgh to Denver
-------
Table 8
INSTANTANEOUS OIL AND GREASE LOADS
OUTFALL 019 and LOCATION 119
USSC HOMESTEAD WHEEL AND AXLE PLANT
August 21-28, 197S
Date
(Aug.)
Outfall
019
Location
119
Time
Collected
(hr)
Instantaneous Flow
0/G
Time
Collected
(hr)
Instantaneous Flow
0/G
(m3/day)
(mgd)
(mg/i)
(kg/day)
(lb/day)
(m3/day)
(mgd)
(mg/1)
(kg/day)
(lb/day)
21
1455
6,170
1.63
5
31
68
1535
2,505
0.662
1
2.5
5
2125
7,570
2.0
25
189
417
2205
820
0.216
7
5.7
13
22
0505
6,700
1.77
6
40
89
0545
820
0.216
5
4
9
1540
5,980
1.58
2
12
26
1625
2,725
0.720
3
8
18
2145
5,940
1.57
15
89
196
2250
820
0.216
2
1.6
4
23
0635
6,170
1.63
4
25
54
0710
820
0.216
5
4
9
1535
6,055
1.60
9
54
120
1619
820
0.216
16
13
29
1850
6,170
1.63
8
49
109
1945
545
0.144
14
7.6
17
24
0030
6,245
1.65
11
69
151
0115
545
0.144
24
13
29
1515
4,960
1.31
5
25
55
1535
0
0
NF
-
-
1706
4,805
1.27
4
19
42
1900
0
0
NF
-
-
25
0320
5,600
1.48
2
11
25
0400
435
0.115
6
2.6
6
1423
6,740
1.78
39
263
580
1455
2,190
0.576
9
20
43-
2120
6,890
1.82
9
62
137
2200
545
0.144
1
0.5
1
26
1335
6,245
1.65
7
44
96
1415
2,725
0.720
7
19
42
1830
5,715
1.51
12
69
151
1920
1,090
0.288
3
3
7
2130
6,055
1.60
9
54
120
2205
1,090
0.288
7
7.6
17
27
0330
5,790
1.53
11
64
140
0405
820
0.216
14
11
25
1530
6,020
1.59
4
24
53
1625
2,045
0.540
2
4
9
1830
6,740
1.78
5
34
74
1915
820
0.216
6
5
11
28
0330
7,570
2.00
3
23
50
0403
820
0.216
6
5
11
Arithmetic
Average
6,195
1.64
9
59
131
1,210
0.319
7
7.3
16
-------
Table 9
SUMMARY OF METALS ANALYSES
VSSC HOMESTEAD WHEEL AND AXLE PLANT
August 21-28, 1975
Total
Station
Description
Date
(August)
Total Iron
Dissolved Iron
Chromium*
(mq/1 )
A1
(mq/1 )
Lead
Tin
Gnq/1 ) (kq/day)
(lb/day)
(mq/1 ) (kq/day)
(lb/day)
(mq/1 ) (kq/day)
(lb/day)
(mq/1 ) (kq/day)
21-22
0.14
0.37
0.81
0.08
0.21
0.46
< 0.01 ++
0.2
0.07
0.18
0.40
<
0.5
22-23
0.17
0.47
1.04
0.08
0.22
0.49
< 0.01
0.2
0.05
0.14
0.30
<
0.5
23-24
0.04
0.09
0.21
0.04
0.09
0.21
< 0.01
0.2
0.05
0.12
0.26
<
0.5
24-25
0.08
0.16
0.35
0.04
0.08
0.17
< 0.01
0.2
0.05
0.10
0.22
<
0.5
25-26
0.18
0.46
1.01
0.05
0.13
0.28
< 0.01
0.2
<
0.05
<
0.5
26-27
0.15
0.45
1.00
0.03
0.09
0.20
< 0.01
0.2
<
0.05
<
0.5
27-28
0.18
0.68
1.49
0.04
0.15
0.33
< 0.01
0.2
<
0.05
0.9
3.4
7-Day Avg.*
0.14
0.38
0.84
0.05
0.14
0.31
< 0.01
0.2
0.03
0.08
0.17
0.13
0.5
21-22
1.03
6.7
14.7
0.10
0.65
1.43
< 0.01
0.2
0.06
0.388
0.86
<
0.5
22-23
0.83
5.3
11.7
0.08
0.51
1.13
< 0.01
0.2
<
0.05
1.2
7.7
23-24
1.07
6.6
14.5
0.08
0.49
1.09
< 0.01
0.2
<
0.05
<
0.5
24-25
0.71
3.7
8.2
0.13
0.68
1.50
< 0.01
0.2
<
0.05
<
0.5
25-26
1.02
6.3
14.0
0.19
1.18
2.60
< 0.01
0.2
<
0.05
<
0.5
26-27
1.41
8.8
19.3
0.12
0.75
1.64 -
< 0.01
0.2
0.11
0.683
1.51
<
0.5
27-28
1.07
6.8
14.9
0.12
0.76
1.67
< 0.01
0.2
<
0.05
<
0.5
7-Day Avg.
1.03
6.3
13.9
0.12
0.72
1.58
< 0.01
0.2
0.03
0.15
0.34
0.18
1.1
21-22
1.25
0.15
< 0.01
0.2
<
0.05
<
0.5
22-23
0.79
0.07
< 0.01
0.2
<
0.05
<
0.5
23-24
0.64
0.06
< 0.01
0.2
<
0.05
<
0.5
24-25
0.41
0.06
< 0.01
0.2
<
0.05
0.5
25-26
0.82
0.10
< 0.01
0.2
<
0.05
<
0.5
26-27
1.13
0.08
< 0.01
0.2
<
0.05
<
0.5
27-28
0.67
0.09
< 0.01
0.2
<
0.05
<
0.5
7-Day Avg.**
0.82
0.09
< 0.01
0.2
<
0.05
<
0.5
(lb/day)
Outfall 018
Outfall 019
Graham Street
Sewer at River
7.4
1.1
16.9
2.4
t All hexavalent chromium less than total chronrium values
tt All values with < (lees than) eign considered as zero
* Flow-weighted average
** Arithmetic average
ro
ro
-------
23
Table 10
SUKIARY OF SELF-MONITORING DATA*
USSC HOMESTEAD WHEEL AND AXLE PLANT
January-June, 197S
Month
pH
Range
Temp.
Range
TSS
Range
0/G Phenol
Range Range
CN, CN,
Range Range
T0C
Range
(S.U.)
(°C)
(mg/1)
(rag/1) (mg/1)
(mg/1) (mg/1)
(mg/1)
OUTFALL 018
January
February
March
April
Hay
June
6.0
6.8-7.0
6.5
21.1
23.9-24.4
16.7
7
7
0 030
0.1-22.1 0.022-0.036
1.4-2.7 0.037
OUTFALL 019
0 014 0 002
0.006-0.017 0.00-0 010
0.002 0 000
10.4-17 8
21.6
January
February
March
April
Kay
7.2
7.0
23
20
21-27
20.6
2.4
4-17
11.5-13.6
4.3-43.5 0.014-0 024
1.7-43.7 0.02-0.158
LOCATION 119
0.003-0 014 0.000-0.012
0.006-0.037 0.00-0.023
7 1-56.7
6.7-19.8
January
February
March
April
May
June
5.8-7.4
6.7-7.05
6.4-6.5
6.8
27
19-29
20
19-20.6
30.6-32.2
20.6
24
20
14
11.5-18
10.2-31 8
0.03-0 204
4-12.7 0 04-0.064
10.2-16.2 0.042
OUTFALL 020
0.003-0 273 0.000-0.251
0 008 0.00
0.001
2.4-56.7
221
19.4
January
February
March
April
May
June
6.7-6.9
7.0
15-15.6
16.1
70-156
9-26
13
24.4-72 9 0 022-0 026
1.7-42.2 0.018-0 058
1.8-43.2 0.028
0.026-0.030 0.000-0.014
0.009 0.000
0.001 0.000
16.1
8.2-21.1
21.9
t Single data value indicates only one sample analyzed.
-------
24
Table 11
MONITORING SCHEDULE+
USSC HOMESTEAD WHEEL AND AXLE PLANT
Outfall
Effluent
Parameter
Monitoring
Frequency
Sample
Type
018
Flow
1/quarter
measured
Temperature
1/quarter
"i-s"
pH
1/quarter
grab
019
\
Flow
1/month
measured
Temperature
1/month
"i-s"
PH
1/month
grab
TSS
1/month
24-hour
composite
Oi1/grease
1/month
3 grab/
24 hours
020
None
[location)
119
None
t Minimum monitoring required by NPDES Permit
-------
25
3
Sunday and Monday, the flows decreased to 1,970 m /day (0.52 mgd) and
q
2,535 m /day (0.67 mgd) respectively. The TSS and oil/grease concen-
trations were similar to the concentrations found on the other five
days. The NEIC results indicate that TSS is not significant in this
outfall. However, one oil/grease concentration of 14 mg/1 indicates
that oils or lubricants may be discharged through this outfall.
The effluent was analyzed for various metals which could possibly
be present. The data [Table 9] shows that metal concentrations were
insignificant in this outfall.
Self-monitoring data were available from USSC for March through
June 1975.* Flows were not included in the data sheets, thus loads
could not be compared with the NEIC monitoring data. TSS concentrations
were equivalent to concentrations found in August 22-28. Oil/grease
concentrations ranged from 0.1 to 22 mg/1, again indicating that oils or
lubricants may be discharged from this outfall. NEIC did not monitor
for phenol, cyanide, or total organic carbon (TOC); USSC data indicate
these constituents are insignificant.
The waste loads discharged per unit production** are summarized in
Table 12. Over the seven-day monitoring period the TSS and oil/grease
loads discharged were less than 0.06 kg/1,000 kg (0.11 lb/ton) and less
than 0.01 kg/1,000 kg (0.02 lb/ton) of production, respectively.
In response to the 308 Request, USSC provided drawing no. BB-7410,
showing the API*** separator in the axle forge sector; dimensions were
not given on the drawing. NEIC personnel estimated the dimensions
* USSC response to the 308 Request, August lly 1975
** Sampling occurred between 6 a.m. and 6 a.m. for each 24-hour period
while total production reported by USSC was for the period of 12 mid-
night to 12 midnight. Therefores waste loads per unit production are
only approximate values.
*** American Petroleum Institute.
-------
Table 12
SUMMARY OF WASTE LOADS PEP UUTT PRODUCTION*
USSC HOMESTEAD WHEEL AND AXIS PLANT
August 21-28, J975
Total Outfall 018 Outfall 019 Location 119
Date
Production
Tss
o/r,
TSS
TSS
0/fc
(Aug.)
(m.tonj(ton)
(kg/1000 kgHlb/ton)
(kg/1000 kg)(lb/ton)
(kq/1000 kg>(lb/ton)
(kg/1000 kg J(lb/ton >
(kg/1000 kq)(lb/ton)
(kg/1000 kgJ(lb/ton)
21-22
443
488
0.06
0.12
<0.01
<0.02
0.23
0.47
0.18
0.35
0.06
0.13
0.01
0.03
22-23
611
673
<0.05
<0.09
<0.01
<0.01
<0.10
<0.21
0.09
0.18
<0.02
<0 05
0.01
0.01
23-24
368
405
0.08
0.15
0.03
0.06
<0.17
<0.34
0.13
0.27
0.05
0.10
0.05
0.09
24-25
0
0
-
-
-
-
-
-
-
-
-
-
-
-
25-26
423
466
o.os
0.12
<0.01
<0.01
<0.15
<0.29
0.35
0.70
0.06
0.13
0.02
0.04
26-27
544
600
<0.06
<0.11
<0.02
<0.04
0.26
0.53
0.11
0 22
<0.02
<0.05
0.02
0.04
27-28
639
705
<0.06
<0.12
<0.01
<0.01
0.10
0.20
0.04
0.08
<0.02
<0.05
0 01
0.02
7-day
Average
504
556
<0.06
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27
to be 1-1/4 m wide x 4-1/4 m long x 1-1/4 m deep (4 ft x 14 ft x 4 ft).
The heavy oil is reclaimed and the underflow is sent to the waste oil
treatment plant. According to the drawing, 132 1/min (35 gpm) of waste-
water flows to the waste oil treatment plant and the separated oil flows
to the recovered oil storage tank. NEIC monitoring results show that
the flow to the waste oil treatment facility averaged about 40 1/min (11
gpm) and contained approximately 60 mg/1 TSS and 480 mg/1 oil/grease.
USSC has not proposed effluent limitations for this outfall in
their adjudicatory hearing request.
The sampling location selected by USSC for monitoring this outfall
is satisfactory. Flows are not measured by USSC at this location.
However, conventional flow measuring devices can be installed in the
manhole.
OUTFALLS 019 AND 119
In their adjudicatory hearing request, USSC proposed that another
location be designated for monitoring outfall 019, and proposed that the
effluent from the waste oil treatment plant be designated as outfall 119
and be monitored for TSS and oil/grease.
According to USSC, outfall 019 receives untreated cooling water,
untreated water from the power house, and the effluent from the oil
treatment facility. The seven-day average flow through outfall 019,
measured by NEIC, was 6,140 m /day (1.62 mgd); the flow from the waste
oil treatment plant comprised about 20% of this flow. Monitoring
results show that the effluent from the oil treatment facility averaged
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28
approximately 14 mg/1 TSS. Over the same period, the TSS concentration
discharged through outfall 019 averaged 13 mg/1. The TSS levels were
equivalent at both monitoring points and approached the detectable
limit.
On a flow-weighted basis [Table 6], the oil/grease concentrations
in discharges 019 and 119 averaged 10 and 6 mg/1 respectively. On an
arithmetic, non-flow-weighted basis, the corresponding oil/grease
concentrations were 9 and 7 mg/1 respectively [Table 8]. Therefore, it
would appear that the location for monitoring oil/grease and TSS could
be either outfall 019 or 119. However, daily waste loads must be
calculated from the flow measured at outfall 019. The average instan-
taneous oil/grease load for the seven days discharged through outfall
019 was 59 kg/day (131 lb/day) while the load discharged through location
119 was 7 kg/day (16 lb/day). Although the flow contributed by location
119 was 20% of the total flow through outfall 019, the waste load
discharged from outfall 119 was only 12% of the total oil/grease load.
Calculating the oil/grease load from concentrations found in location
119 and the flow through outfall 019 results in an oil/grease load
approximately 25% less than the load actually discharged. Since outfall
019 contains waste streams from all sources while location 119 does not,
representative samples can only be collected at outfall 019; flows
should also be measured at outfall 019 to provide accurate data on waste
loads.
In their adjudicatory hearing request, USSC has proposed that the
TSS and oil/grease loads be established at the levels listed below for
location 119 for the entire life of the NPDES permit. Concentration
limits were listed as not applicable (N/A).
Parameter
Daily Average
Daily Maximum
(kg/day) (lb/day)
(kg/day) (lb/day)
TSS
423 930
1,269 2,790
0/G
236 520
708 1,560
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29
Using the proposed limitations for location 119 and the total
average daily flow from outfall 019 of 6,140 m /day (1.62 mgd), the
average oil/grease concentration would be about 40 mg/1 and the maximum
concentration would be 115 mg/1. The average concentrations for the
seven-day period for both outfalls were 10 mg/1 (019) and 7 mg/1 (119)
while the maximum concentrations were 39 mg/1 (019) and 24 mg/1 (119).
The proposed limitations would allow waste loads approximately 25
times greater than the daily average TSS load and 32 times greater than
the daily average oil/grease load discharged through location 119 during
NEIC monitoring. If these proposed limitations were applied to outfall
019, the waste loads would be 5 times and 4 times greater than, re-
spectively, the actual TSS and oil/grease loads discharged.
On a unit production basis, the average waste loads discharged are
compared below with the proposed limitations, based on the production
for August 21-28.
Daily Average Waste Load
Actual (Aug. 21-28)
Parameter USSC Proposed Outfall 019 Location 119
(kg/1 ,000 kg)(lb/ton) (kg/1 ,000 kg)(lb/ton) (kg/1,000 kg)(lb/ton)
TSS 0.84 1.67 0.15 0.31 0.03 0.07
0/G 0.47 0.94 0.12 0.25 0.01 0.03
Clearly, the proposed limitations do not reflect actual conditions at
either monitoring point, even at the high production levels experienced
during the survey.
Total and dissolved iron concentrations were higher in this dis-
charge than those concentrations found in outfall 018, which contains
only cooling water and thus would reflect background conditions.
-------
30
However, the higher concentrations were not significant. Chromium,
aluminum, lead, and tin concentrations were equivalent to the levels
found in the cooling water (e.g. outfall 018 concentrations).
Self-monitoring data provided by USSC for January through June 1975
did not include, flows; therefore, loads could not be determined.
Concentrations reported for TSS and oil/grease were equivalent to those
found August 21-28. Additional parameters monitored by USSC, cyanide,
phenols, and TOC were not present at significant levels.
The sampling location selected by USSC for monitoring outfall 019
is satisfactory. However, if the steel plate covering the pit remains
in place during monitoring, flows cannot be measured. Moreover, the 28
cm (11 in) square opening in the plate limits the access for represen-
tative sample collection. Foreign material could be introduced into the
sample from the pit's walls, resulting in erroneous data. Flows through
this outfall are not measured by USSC.
OUTFALL 020
USSC withdrew their application to discharge wastewater through
this outfall. However, water from quenching operations in the machine
shop is discharged through this outfall. The fresh water valve control-
ling the inflow to the quenching tank was open only for the 8 a.m. to 4
p.m. turn. The TSS concentrations were at the detectable levels and
oil/grease concentrations were not significant. The flow averaged about
O
8 m /day (2,300 gpd). The discharge was essentially fresh water.
Self-monitoring data for March through May show solids and oil/
grease concentrations much greater than those found during the NEIC
survey. Survey concentrations were about 10 mg/1 TSS and 1 mg/1 oil/
grease. The TSS concentrations reported by USSC ranged from 9 to 156
mg/1. Oil/grease concentrations ranged from 2 to 73 mg/1. NEIC
-------
31
personnel observed that quenching operations were not being conducted
whenever samples were collected. However, self-monitoring results
reported by USSC indicate that solids and oil/grease constituents are
discharged from quenching operations. The Company does not measure
flows through this outfall.
Access to the outfall is a pit, usually covered with a steel
plate, inside the machine shop. A 28 cm (11 in) square opening has been
cut in the plate for monitoring. Flow measurement is not possible
without removing the steel plate and representative samples cannot be
collected through the 28 cm square opening because direct access to the
waste stream is not possible. Complete access to the outfall pipe can
only be achieved with the cover removed.
USSC has not proposed limitations for this outfall.
GRAHAM STREET SEWER
USSC is not required to monitor the effluent discharged from the
Graham Street storm sewer into the Ohio River. NEIC personnel monitored
the discharge at the river and the wastewater flowing in the storm sewer
upstream of the outfall 018 connection, to determine if USSC had addi-
tional connections to the storm sewer. Flows were not determined at
either location. The upstream location was dry except on one occasion
(discussed previously) when there was a heavy rain. Based on concen-
trations found in the wastewaters discharged to the Ohio River, it
appears that there are no additional connections from the Wheel and Axle
Plant to the storm sewer. USSC personnel have stated that there are no
additional connections to the storm sewer.
Grab samples were collected twice during the survey for analysis
for organic compounds. Petroleum hydrocarbons, primarily normal paraffins,
were found at low levels in the sample collected from the Graham Street
-------
32
sewer discharge to the Ohio River on August 25. These hydrocarbons
ranged from Cg to C£q and appeared in a uniform pattern suggesting
light-weight refined oils [Table 13]. Since these compounds were not
present in the discharges from the Wheel and Axle Plant, they must
originate from sources downsewer of the USSC facility.
EVALUATION OF WASTE OIL TREATMENT FACILITY
To evaluate the efficiency of the oil treatment facility, the two
influent waste streams and the effluent waste stream were sampled for
TSS and oil/grease [Fig. 2]. Due to the fluctuations in the effluent
flow measuring device discussed in Appendix B, the treatment efficiency
can only be approximated. Influent and effluent waste loads were calcu-
lated based on the daily flow [Table 14]. The treatment process removed
approximately 95% of the influent oil/grease load over the seven-day
period. Suspended solids removal averaged about 38% because the pH of
the effluent ranged between 5.4 to 7.5. A higher percentage solids
removal could be achieved if the pH were adjusted to the 8 to 8.5 range
after the oil/grease had been removed. However, the effluent TSS
concentration averaged <14 mg/1 with a maximum concentration of 29 mg/1;
therefore, additional solids recovery is not warranted.
During the reconnaissance, USSC personnel stated that all waste-
water from the wheel mill flows to the oil treatment facility where it
is treated with the axle forge sector API separator underflow. Drawing
no. BB-7410 shows an intermittent flow containing up to 100,000 ppm oil
from a sonic tester sump to the wheel rolling mill flume. From this
flume, 1,890 1/min (500 gpm) of wastewater containing 200 ppm oil and
100 ppm TSS is pretreated in the wheel mill separator before discharge
to the oil treatment facility [Fig. 3]. USSC personnel did not discuss
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33
Table 13
SUMMARY OF ORGANIC COMPOUNDS
USSC WHEEL AND AXLE PLANT (GRAHAM STREET SEWER)
August 25y 1975
Compound Concentration
Ciig/T]
Cg - Nonane
Trace
C-jq - Decane
3
C-j ^ - Undecane
3
C-|2 - Dodecane
8
C-j3 - Tridecane
10
C-|4 - Tetradecane
17
C-|5 - Pentadecane
15
C-jg - Hexadecane
15
C-j y - Heptadecane
14
C-jg -Octadecane
10
C^ -Nonadecane
8
C2Q -Eicosane
3
-------
FROM AXLE FORGE API SEPARATOR
>
>s
V •»
W •*
I u
r Z
e
e
* a
* a
C e
W «J
O
o
F«C I* DAY TAN K3
B
"Feco HOPPER
/
MIXING TANK
AIR
U
A 1R SATURATION
TANK
POLYMER MIX SYSTEM
H
<
*
U
y
>
c
u
to
hL_.
I
SLUDGE _J
DISSOLVED AIR FLOTATION
CLAR IFIER
-SAMPLE LOCATION 110
V7
\Z7
SETTLING BOXES FOR
SLUDGE DISPOSAL
RETURN WATER SUMP
EFFLUENT TO GRAHAM STREET SEWER
TANK
TRUCK
SCUM SEPARATING TANKS
flgvt* 2. Woiftwolar Tr»atm*nt Facility Flew Dlagram^Homottoad Whttl and Axl» Works
(From US5C Drawing No BB-7410)
co
4^
-------
Table 14
WASTE OIL TREATMENT PLANT EVALUATION +
USSC HOMESTEAD WHEEL AND AXLE PLANT
August 21-283 1975
Combined Influent** Effluent Treatment Efficiency***
Date TSS 0/G TSS 0/G % Removal
(Aug.) (mg/1)(kg/day) (mg/1)(kg/day) (mg/1)(kg/day) (mg/1)(kg/day) (TSS) (0/G)
21-22
22
30
75
104
20
28
4.3
6
7
94
22-23
18
28
117
179
10
15
2.5
3.8
46
98
23-24
25
28
146
167
16
18
14.8
16.9
36
90
24-25
22
5
65
14
29
6
6
1.3
0
91
25-26
19
28
131
194
18
27
5
7.4
4
96
26-27
24
31
126
165
10
13
7.8
10.1
58
94
27-28
27
41
145
220
10
15
4.7
7.1
63
97
7-Day
Average
22
28
125
153
14
17.5
6.1
7.5
38
95
+ Flows are presented in Table 6
++ Influent from Axle Forge Sector and from Wheel Mill
ttt Based on load
co
cn
-------
36
feOMP - EXIGT1NQ
- flpvro 3. Wh»al Mil) Soparotor (from USSC Drawing No. 08-74)0}
-------
37
this separator during the reconnaissance or the survey; therefore, it is
unknown by NEIC personnel if all waste oil is directed to the oil treat-
ment facility.
Survey data show that the flow from this separator averaged about
815 1/min (215 gpm) and contained about 100 mg/1 oil/grease and 20 mg/1
TSS.*
Chemicals used in the treatment plant, according to USSC's response
to the 308 Request, average about 2-1/4 kg (5 lb)/day of Betz No. 3320
polymer mixed with 330 1 (88 gal) of ferric chloride and 2,670 1 (712
gal) of water. The average flow during operating periods is 1,890 1/min
(500 gpm). Average flow from the oil treatment plant, indicated by the
flow indicator, averaged only 850 1/min (225 gpm) during the survey,
even though the mill was operating at high production levels. During
the reconnaissance, the flow indicator read 1,630 1/min (430 gpm).
The treatment plant operator informed NEIC personnel on July 17,
1975 that the influent and effluent to the treatment plant are sampled
every 2 hours to rate treatment efficiency in terms of TSS and oil/
grease removals. The operator stated that the plant was achieving waste
removals somewhat less than 90% for both parameters and the system was
less effective in soluble oil removal compared to non-soluble oil
removal. The operator also stated that influent samples are collected
at a number of points in the axle and wheel process operations and that
approximately 90-95% of the influent is sampled. In response to the 308
Request question on treatment efficiency and data, USSC stated that the
"efficiency of the waste water treatment facility for oil, turbidity and
TSS is unknown. Plant records are only kept on the effluents from the
* Assuming that the sampling location designated by USSC contained the
effluent from the wheel mill API separator and no other wastestream.
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38
plant and are reported on the monthly NPDES forms which are already in
your possession. Separate data on removal of soluble vs. non-soluble
oils is not available." Data on the soluble and non-soluble oil removals
have apparently been collected by USSC but have not been reported to
EPA.
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39
V. MONITORING REQUIREMENTS
Recommended monitoring requirements for outfalls 018, 019 and 020
are tabulated in Table 15. The rationale is discussed below.
Outfall 018 - The NEIC survey data and self-monitoring data in-
dicate that only cooling water is discharged, precluding the necessity
for flow determinations. Equal volume composite samples, collected over
a 24-hour period, will provide data on TSS concentrations. Individual
aliquots should be collected at least every 3 hours when the axle forge
sector is operating. Three oil/grease grab samples, collected over the
same 24-hour period, are needed to determine if cooling water is being
contaminated from sources within the axle forge sector. Since the
cooling water is recycled within the area from a sump, there is a
possibility that oils or lubricants could enter the system through floor
drains. Oil/grease concentrations ranged up to 22 mg/1 in the self-
monitoring data for January through June 1975. Temperature and pH
should be monitored each time a sample is collected. Because the flow
is estimated, concentration rather than load limitations should be
required for TSS and oil/grease. At flows of approximately 2,725 m /day
(0.72 mgd), the minimum monitoring frequency should be once per month.*
Outfall 019 - All monitoring should be conducted at this outfall
rather than the USSC proposed location 119, as all waste streams flow
through the outfall. Because oil/grease concentrations exceed 10 mg/1,
frequent monitoring of this parameter is necessary to determine
* Permit Program Guidance for Self-Monitoring and Reporting Requirementss
Office of Permit Programs, U. S.E.P.A., Washington, D. C., April 30,
1973, page 12.
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40
Table 15
RECOMMENDED MONITORING REQUIREMENTS
USSC HOMESTEAD WHEEL AND AXLE PLANT
OUTFALLS 018} 0193 020
Effluent Parameter Measurement Sample Type
Frequency
Outfall 018
TSS
1/month
Equal volume composite
0/G
1/month
3 grab samples/24 hours
PH
1/month
Grab sample
Temperature
1/month
Grab sample
Flow
1/month
Estimated
Outfall 019
TSS
1/week
Flow-weighted composite
0/G
1/week
3 grab samples/24 hours
pH
1/week
Grab sample
Temperature
1/week
Grab sample
Flow
Daily
Measured continuously
Outfall 020
TSS
1/month
Equal volume composite
0/G
1/month
2 grab samples/8 hours
pH
1/month
Grab sample
Temperature
1/month
Grab sample
Flow
1/month
Estimated
-------
41
O
compliance. The flow averaged 5,675 m /day (1.5 mgd); therefore the
minimum monitoring frequency should be once per week.* Waste load
limitations should be established for oil/grease and TSS parameters.
Flow measurement will be necessary to determine these waste loads.
Temperature and pH should be measured each time samples are collected.
Outfall 020 - The minor flow through this outfall does not warrant
frequent monitoring. If uncontaminated cooling water were discharged,
the only parameters required for monitoring would be pH and temperature.
However, the self-monitoring results show that high concentrations of
oil/grease and TSS were present in the discharge; thus, monitoring
should also include these parameters. Monitoring must be done only when
the machine shop is operating. Flow measurement is not necessary at
present operating conditions, allowing concentration limitations to be
established.
* Permit Program Guidance for Self-Monitoring and Reporting Requirements,
Office of Permit Programs, U.S.E.P.A., Washington, D. C., April 30,
1973, page 12.
-------
Appendix A
Homestead Works Reconnaissance
-------
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL FIELD INVESTIGATIONS CENTER-DENVER
BUILDING 53, BOX 25227, DENVER FEDERAL CENTER
DENVER, COLORADO 80225
McKees Rocks, Pennsylvania
Date of Inspection/Visit: July 17, 1975
Attendees: NEIC-Denver - Barrett Benson
Jim Pennington
Ed Struzeski, Jr.
EPA, Region
III - Matt Miller
Pete Schaul
State of Pa.
Pittsburgh
Office - Bob Shilcosky
USSC - Dick McCarthy, Chief Environmental
Officer, Homestead Works
Bob Dunham, Corporate, Pittsburgh
S. A. (Jeff) Davis, Corporate, Pittsburgh
Minimal field data were obtainable from USSC concerning the Homestead Works.
The inspection team relied heavily on support data given previously with
the permit.
Background on Wheel and Axle Plant, McKees Rocks, Pa.
The wheel and axle plant is involved in the manufacture of and finished
steel products, specifically the production of forged steel railroad car
axles and rolled railroad car wheels. The McKees Rocks installation consists
of an "older" manufacturing area containing the permitted discharges; and
a "newer" area north of the first, containing mostly dry operations, i.e.
machine tool manufacturing, etc. The 1971 permit application of USSC defines
three Outfalls; 018, 019 and 020. The 018 Outfall was said to comprise
overflow waters from an oil separation tank serving a sump in the axle
forge sector. The 019 discharge was described as overflow from a settling
tank used for oil and solids separation following a rolling mill. This
overflow is combined with cooling waters. The 020 Outfall was described
-------
T. P. Gallagher, Director
July 23, 1975
as water from the axle finishing and machine shop area combined with storm
water. The official record stipulates that USSC withdrew their permit appli-
cation for Outfall 020. However, we found on July 17 that this Outfall is
once again flowing, presumably now an illegal discharge. Subsequent informa-
tion for the wheel and axle plant shows that changes have taken place
since 1971 including installation of an oil treatment plant for sewer
019 wastes.
The EPA Fact Sheet on the mid-1974 draft permit for the Homestead Works
describes Outfalls 018 to 020 as follows:
Outfall 018 cooling water flows from axle forge furnaces, are not treated.
Process flows of 0.05 MGD from the axle forge sector are directed to the
treatment facilities on the 019 sewer. Cooling flows from the axle forge
area of 0.64 MGD are released via the 018 Outfall. The 019 Outfal1, as >
per the Fact Sheet, was said to receive 0.94 MGD power house effluent
(untreated) plus 0.52 MGD cooling waters from the wheel rolling mill
(untreated), plus 0.77 MGD from the new oil treatment facility for a total
of 2.23 MGD. Influent to the oil treatment plant was made up of 0.72 MGD
process waters from the wheel mill plus 0.05 MGD process oil separator
overflow from the axle manufacturing area. Outfall 020, serving machine
shop(s) was shown to have a flow of 0 MGD and this outfall was withdrawn
by USSC from the NPDES permit. A schematic of the wheel and axle facilities
as observed July, 1975 is shown in the enclosed Figure.
Current Operations
On the morning of Tuesday, July 15, we collected background data on the
wheel and axle plant prior to our Thursday visit. Wheel and axle manu-
facturing is currently going strong in contrast to iron and steel making.
In addition to railroad axles and wheels, some wheels may be made for
trucks. Only rarely does McKees Rocks assemble together the railroad
car axles and wheels. Machining operations represent critical or "bottle-
neck" processing at this USSC installation.
The production plants are operating about 15 turns (shifts) per week,
I.e., 5 for the wheel plant and around 10 at the axle plant, whereas the
machining sections are operating 20 or so turns per week. The 018 Outfall
was the site a few weeks ago of a serious oil spill to the Ohio River. It
is reported that one or more valves on waste oil storage tanks were inadver-
tently left open or were not shut off.
The McKees Rocks Plant receives its water supply from a series of 5 or 6
wells. Potable water supply is obtained from the municipality (hence,
gross limits on the NPDES permit.) Total water supply currently amounts
to about 1 MGD. Average water usage for June, 1975 was recorded as 0.9
MGD. At McKees Rocks, the wheel and axle division no longer maintains a
boiler house, generates no steam, and has no water treatment since the
botler house is down. Mention was made of possible conditioning for
-------
T. P. Gallagher, Director
July 23, 1975
hardness but no details were secured. The power plant may still be opera-
tional in part, serving air compressors and other essential operations.
All waste flows at the wheel and axle plant have been, and continue to
be expressed in terms of estimated values. The only known air pollution
control equipment at the wheel and axle plant is a wet scrubber installed
in 1973 at the shot cleaner station, i.e. where shot is used for surface
treatment of railroad wheels. This scrubber has replaced a baghouse
previously deployed at this location.
Axle Forge Building and Outfalls 018 and 019
On our visit of Thursday, July 17 to the wheel and axle plant, we first
inspected MH018 used for sampling by the Company. This manhole is located
in the middle of one of the inner plant roads. On our walk outside the
forge and mill buildings, we were joined by a Walt Stern of the wheel and
axle plant of USSC. Depth to the sewer from the top of the 018 MH was
about 10 feet. This MH has no access ladder. The dye dilution technique
is necessary to determine flow on this sewer. A metal cover on 018 can
be easily removed and the MH is readily sampled. There is another MH on
the 018 line just downstream. For dye injection purposes, it is also
possible to add dye at the axle forge furnaces within the axle building,
the dye to be subsequently measured at one or both of the downstream
manholes.
We entered the axle forge building in the area of billet storage and con-
ditioning. We traversed the building from west to east. The axle building
consists entirely of dirt floors. We next passed two axle reheat furnaces.
Cooling waters from the reheat furnaces flow to the 018 sewer. Major
shaping of axles is carried forth in a single hammer forge machine. This
forge stand represents a major source of waste oil and other pollution.
Extensive drainings and leakage from the forge stand area are allowed to
run into a series of shallow, ground level pits and then picked up into
a small collection tank. From this tank, the wastewater flows into an
"equivalent" API separator with a surface retainer at the far end. We
estimate the oil skim box to have been roughly 4' wide X 14' long X 4'
deep. Heavy black oil on the surface of the box is collected and delivered
to an oil reclaimer. Underflow from this basin is sent to the 019 waste
oil treatment plant. Just behind the surface retainer, we noted a milky-
white emulsion on the furthest downstream (effluent) section of the API
separator. USSC personnel claimed this was soluble oil. I feel strongly
an oil dispersant may have been used.
The forged axles are then passed through a series of three heat treating
furnaces. The axles are loaded onto a moving conveyor and arrayed like
"rungs on a ladder" for the required heat treatment. The sequence is
heating-cooling, heating-cooling, heating-cooling. We observed considera-
ble oil on the floor and around the base of heat treating furnaces. Mc
Carthy and Dunham indicated most of the cooling water from these furnaces
is recycled for reuse. Contact cooling waters reported as directed to 018
-------
T. P. Gallagher, Director
July 23, 1975
and oily waters are sent to the 019 sewer. Nevertheless, the 018 sewer
is believed to receive considerable contact-cooling waters together with
oily waters.
The axle building has very extensive machining (lathing et. al.) opera-
tions for both the ends and central core of the axles which yield the
final product. In and around the machining areas were noted many bins
containing accumulations of metal scraps and shavings. Some of these bins
were partly filled with liquid drainings. According to Steel, this liquid
overburden never reaches the sewer. Metal scraps are said to be totally
recycled to the open hearth furnaces at the main Homestead Works, lhe
completed axles grooved at both ends and polished throughout are said to
weigh about 600 pounds. The axles are finally taken to the inspection and
storage sectors of the plant. Whatever wastewaters (primarily spent cool-
ing flows) originate from the machining and axle finishing sectors, enter
Outfall 019. Some of these waste flows are sent to the oil treatment
plant, whereas others are bypassed around treatment.
Machine and Repair Shop, Outfall 020
The tour was continued through the repair and machine shop and we were
shown sampling point 020 inside a tool-gear storage shop. Besides general
repair, this part of the plant specializes in heat-treating, quenching and
otherwise manufacturing unique tools for direct use in the wheel and axle
plant. The 020 MH was covered with a steel plate having an 8" square
opening. Upon removing the plate, it should be possible to descend the MH,
a 4' X 4' box with a ladder, some 15' deep. Flow was observed to be
extremely slow-moving inside the MH although we could not clearly see in-
side due to lack of lights. McCarthy estimates this flow to be around
5 gpm. More detail is needed for the 020 manhole. The 020 Outfall is
more or less an illegal discharge because the Company has previously
officially withdrawn the NPDES permit application for this waste line.
The 020 MH may possibly be weired. Otherwise, dye may be added to 020
with subsequent measurement of the dye in Graham Street storm sewer down-
stream.
019 Sewer and Manhole
The 019 manhole located immediately south of the wheel storage sheds and
at the fence line running down Graham Street was inspected. We observed
that an 11" square hole had been cut in the metal plate covering the
manhole. The manhole itself was approximately 4' X 4' with a ladder
descending dov/n to the sewer about 20 feet below ground level. We should
request that the Company remove the metal plate during the EPA sampling
survey. The ladder appears rusty and corroded, probably due to strong
organics and/or acids carried in the sewer. We observed fumes coming
off the manhole believed due to organic cleaning solvent and/or degreasers
present. The manhole contained a good waste flow. The 019 manhole is
located just off Graham Street inside of USSC property. It is also
directly across and road from the Pepsi Cola plant approximately 200'
east of the Pepsi Cola main gate.
-------
T. P. Gallagher, Director
July 23, 1975
The Wheel Mill Buildings
McCarthy stated some of the waste flows in the wheel building going to
the 119 treatment plant are subjected to magnetic or sonic separation.
Unfortunately, we did not solicit further information on these procedures.
At the beginning of the wheel building, we observed wheel "blanks" being
being heated in rotary furnaces. A cross section of a typical wheel blank
is shown below. Sizes of wheels range from 11" in diameter up to about
40". Off to the side, we observed blanks placed on stands with the
interior of the blanks being specially heated with an open flame. The
fully heated, red-hot blanks are injected into a stamping or milling
machine where the rough wheel is formed via a 2-step operation. Dies
are interchanged between the first and second press. The wheels are then
received into a second pressing or milling machine serving to widen the
v/heel and roll out the edges of the wheel. A third machine stamps holes
into the wheels. The wheels are then hung up on a continuous conveyer
line. Wastewaters from these various furnaces and milling operations are
reported to be directed entirely to the 119 treatment plant.
The wheels hung on the conveyor line are taken through heat treating
furnaces. Wheels otherwise may be temporarily stored and later brought
through the heat-treating furnaces. The wheels then enter an equalizing
tunnel, are subjected to heat treating furnaces a second time, are passed
through "a (6 unit) wheel quench operation where only the outer rim of the
v/heel receives quenching, and for a third time, progress through the heat
treating or annealing furnaces. The wheel quench operation is served by
a scale bucket underneath the machine. Finally, the wheels are passed
through a long "Slow-Cool Tunnel" before final polishing, finishing, etc.
McCarthy showed us a discharge trough situated between and beneath the
heat treatment furnaces and the slow cool tunnel for possible dye dumping
and/or for sampling. This location described in the sketch shown on the
following page was stated by USSC as approximating the discharge at 019.
However, observed flow at this upstream point was much smaller than at KH
019. Practically all spent waters from the axle plant find their way
to the 019 sewer except for some trenches/drains feeding to the 018
system.•
Wheel blank
-------
T. P. Gallagher, Director
July 23, 1975
Oil Waste Treatment Plant, 119 Location
We next went through the oil treatment plant. This system is approximately
two years old and consists of air injection for flotation; a mix tank where
wastes are blended with FeCl3 on a continuous or batch (both reported) basis-,
a large thickener-settler; 2 scum tanks for oils and flotables (taken to
a re-refinery; and 2 sludge underflow storage tanks. The scum tanks comprise
one tank in service and one as standby. The sludge underflow tanks are
similarly operated. Polymers are added with the FeCl3. The surface layer
on top of the thickener was light brown in color and the main contents of
the tank were milky-white. We were told effluent from the thickener is
ordinarily sampled by the Company as sampling station 119. The thickener
has two takeoff Dipes for sampling purposes: a) one line to sample scum
transfer and; b) a second to sample normal effluent off the thickener.
McCarthy stated influent to the thickener varies considerably but can be
sampled. The FeCl3 was supposedly added to the top of the mix tank and
there was sampling access on the waste line just ahead of the mix tank.
However, after tracing the inflow line, it was learned the FeClo is added
considerably upstream. We were consequently told there is no other access
point on the waste inflow but with some difficulty, we are fairly certain
another location can be found; this can be done on the next EPA visit to
the wheel and axle plant.
A Foxboro recorder is present on the effluent from the waste treatment plant
which was reading about 430 gpm during our visit. Effluent (and possibly
-------
T. P. Gallagher, Director
July 23, 1975
influent) is analyzed for pH, turbidity, oils and TSS. The treatment plant
operator verbally reported to us that they sample every 2 hours in and out,
and rate treatment efficiency in terms of TSS and oil removals. They have
had problems with the FeCl3 feed since installation and these difficulties
continue. They are getting somewhat less than 90% waste removals. The
system is far less effective in soluble oils compared to non-soluble oils.
We asked how the influent loads are accounted for. The operator indicated
they sample at a number of points in the axle and wheel process operations
and they are picking up maybe 90-95% of the waste treatment plant input
loads.
We visited a building directly west of the oil treatment plant housing
an old pressure type accumulator. This building, including the
accumulator, which leaks like a sieve, were all draining to the 018 sewer
rather than to the 019 line. This was an example of the trenches/drains
contributing to the 018 sewer. These drains merge with axle furnace cool-
ing waters and enter the 018 manhole as a single flow. The large majority
of waste flow into the018 MH enters from the east side; flow leaves the
018 MH heading south toward Graham Street.
Graham Street Storm Sewer to Ohio River
We looked for manholes on the Graham Street storm sewer. Diameter of this
storm sewer is unknown. We were able to locate an upstream control at a
manhole in the middle of the intersection of George Street, Nichol Avenue
and Graham Street. However, this manhole was not raised. We were not
successful in finding a manhole on the Graham Street sewer below station
020. Considerable flow enters the Ohio River at the foot of Graham Street
but this flow was submerged. The terminus of the Graham Street sewer may
be sampled but flow cannot be directly measured. Personal contact is
strongly suggested with Stowe Twsp. and/or McKees Rocks Boro regarding
the Graham Street storm sewer. At the foot of Graham Street, both the
smell and sight of oil were observed.
Suggested Sampling Points for Wheel and Axle Plant:
018
Influent to Oil Waste Treatment Plant
119 (Effluent from Treatment Plant)
019
020
Graham Street storm sewer; upstream
Graham Street storm sewer, immediately downstream
-------
GATE
"New" Buildings & Storaqe Facilities acquired by
Wheel & Axle Division approx. 4 years ago
etJConditioninq
fi Storaqe
coolinq u some
flow from
wheel rnfg.
sector
Sampling MH 018
Shipping
Axle
Forging
API Separator
Axle
Heat
Treating
Machi ni ng
Lathes
Inspection
Sampling
Pt, 119
Oi 1 trmt
Plant
Si te
L
Furnaces
Mil ling
S. 010
Sewer
S\.
Power House
(not in use)
Hardening•
Peernng Facili ty
Lathes
S
SI ow "S
Finishinn
Uiu'c 1
Inspection
Cool
Furnaces I I
Storage -—'
_______ 019 ij) &nni)lin'i Mil
vAxle
Bldgs.
Samplint
Pt. 020
a.
•O Q.
O
i. .c
»- oo
T3
Q-
i
r Alleged
Di rectlon
of Sewer
Werner
Trucking
Graham Street & Storm Sewer
1.
Uniroyal
HOMESTEAD WHEEL 8. AXLE DIVISION PLANT - MCKEES ROCK^, PA.
JULY 1975
('•
<:
-------
Appendix B
Field Study Methods
USSC Homestead Wheel and Axle Plant
-------
FIELD STUDY METHODS
FLOW DETERMINATIONS
Outfall 018
The sampling location is described in the NPDES permit as follows:
"Outfall 018 to Graham Street Sewer, which discharges to the Ohio River."
For monitoring purposes, the company selected a manhole inside the plant
property in the roadway adjacent to the Axle Forge Shop. A 90° V-notch
weir was installed by NEIC personnel at the inlet to the effluent pipe
from the manhole.1 A Manning Model F 3000 flow recorder was used to
obtain continuous flows over the seven-day period.
Intermediate Location 119
In the amended adjudicatory request, USSC describes the sampling
location as "At discharge of treatment plant, sample point 119, which
discharges through 019." A sampling port has been installed by USSC in
the effluent pipe located inside the treatment plant building. Flows
are continuously measured with a Company-installed Foxboro flow recorder.
Flows are recorded on a strip chart which is connected to a differential
pressure cell. Pressure differential, caused by an orifice plate in
the effluent line, is transmitted to the strip chart recorder and is
converted into flow. The calibration of the flow device was checked on
August 18, 1975 by Wheel and Axle personnel and adjustments were made to
indicate correct flows. The calibration procedure was checked by NEIC
personnel and was found to comply with the method in the Foxboro in-
struction manual.
-------
Outfall 019
The NPDES permit describes this sampling location as "Outfall 019
to Graham Street Sewer, which discharges to the Ohio River." Samples
were collected by USSC personnel from a pit, approximately 6 m (20 ft)
deep, next to the wheel mill. A Marsh-McBirney electromagnetic flow
meter [Appendix E] was used by NEIC personnel to measure the instan-
taneous velocity of the wastewater stream. The flows were calculated
from the cross-sectional area of the wastewater stream flowing in the
circular pipe.2
Outfall 020
No description of the sampling location was contained in the NPDES
permit. The sampling location, identified by USSC personnel, is a
manhole inside the machine shop. A small quantity of flow was observed
discharging from a 30.5 cm (12 in) diameter pipe approximately 2.4 m
(8 ft) above the invert of the manhole. A 5 cm (2 in) diameter pipe was
installed by NEIC personnel inside the 30.5 cm diameter pipe and sand-
bagged. Flows, except for a minor leak which could not be measured
accurately and which represented less than 1% of the total flow, were
measured with a bucket and stop watch. The flow was measured three
times when a sample was collected, and the average time was used to
compute the instantaneous flow.
Graham Street Sewer, Upstream of Outfall 018
Flows were not measured at this location. Flow was observed during
a rain storm on August 26, at 4:15 p.m. USSC personnel stated that the
flow was probably due to the Graham Street sewer backing up instead of
contributions from upstream connections. All upstream connections to
the sewer in Nichol Street from USSC were reported by Company personnel
as being plugged.
-------
Graham Street Sewer at Discharge to the Ohio River
Flows were not measured at this location.
Influent to Oil Treatment Plant from Axle Forging Sector
The influent piping to the waste oil treatment plant consisted of a
small pipe carrying about 2.84 liters/sec (45 gpm)* from the axle
forging sector and about 28.4 liters/sec (450 gpm)* from the wheel mill.
Both influent pipes discharged into a common inlet header on the reactor
tank. At the header location, only the flow from the axle forging
sector could be measured due to the configuration of the influent pipes.
This flow was measured with a bucket and stop watch three times whenever
a sample was collected, and the average time of the three measurements
was used to calculate the instantaneous flow.
Influent to Oil Treatment Plant from Wheel Mill
The flow contributed from the wheel mill was determined by sub-
tracting the axle forge sector influent flow from the total effluent
flow. The effluent flow was recorded each time an influent sample was
collected and each time an effluent sample was collected.
SAMPLE COLLECTION PROCEDURE
Twenty-Four Hour Composite Samples
Beginning at 6 a.m. on August 21, individual grab samples were
collected from each location, except the Graham Street sewer discharge
~* Flows were provided verbally by USSC Wheel and Axle Plant personnel.
-------
to the Ohio River, on a 2-hour frequency and stored in an ice chest at
4°C. At the end of 24 hours, these samples were composited on a flow-
weighted basis for each station. The Graham Street sewer discharge was
continually composited, on a 2-hour frequency, into a 9.5 liter (2.5
gal) cubitainer on an equal-volume basis and stored at 4°C. Beginning
at 6 a.m. on August 22, and lasting through the duration of the survey,
individual samples were collected on a 3-hour frequency. The time of
collection was altered to provide sufficient time for the NEIC field
personnel on the 6 p.m. to 6 a.m. shift to collect and composite the
samples for the six stations. Table B-l lists the method used to
collect samples from each location.
Grab Samples
Grab samples for oil/grease* and phenols (Outfall 119 only) were
collected in 0.95 liter (1 qt) glass jars three times for each 24-hour
period. (Times of collection are shown in Table 7 of the main text).
Oil/grease samples were preserved with 2 ml H^SO^ after collection and
stored at 4°C. At outfalls 018 and 019, the glass jars were immersed
into the wastewater stream by means of a special sampler** constructed
by NEIC personnel for this purpose. At all other stations, the oil/grease
samples were manually collected directly into the bottle without using
the special sampler. The samples for phenol analysis were collected
directly from the sample port into the glass jars. Each jar used for
phenol samples contained 1 gram CuSO^ before the sample was collected.
After collection, the pH of the sample was reduced to <4.0 with H^PO^
and stored at 4°C.
* Fveon extractable material
** Sampler similar to APHA bacti sampler
-------
Table B-l
COMPOSITE SAMPLE COLLECTION METHOD
HOMESTEAD WHEEL AND AXLE PLANT
August 21-28, 1975
Station Description
Sample Collection Method
Outfall 018
1.9 liter (0.5 gal) plastic^ container
used to collect sample (container
used only for this location). Sample
poured into 1.9 liter plastic container
and stored at 4°C.
Location 119
Sample collected directly from sample
port into 1.9 liter plastic container and
stored at 4°C.
Outfall 019
Sample collected directly into 1.9 liter
plastic container and stored at 4°C.
Outfall 020
Sample collected directly into 1.9 liter
plastic container and stored at 4°C.
Graham St. sewer upstream
of Outfall 018
Composite samples not collected since
there was no flow except at 4:15 p.m. on
August 26.
Graham St. sewer at
Ohio River
Sample collected into 1.9 liter plastic
container (used only for this location);
equal volume measured in plastic
graduated cylinder, and poured into
9.5 liter (2.5 gal) plastic cubitainer
stored at 4°C.
Influent to Oil Treatment
Plant from Axle Forge
Sector
On 6 a.m.-6 p.m. shift, sample collected
into stainless steel bucket and poured
into 1.9 liter plastic container. On
6 p.m.-6 a.m. shift, sample collected
directly into 1.9 liter plastic container
All samples stored at 4°C.
Influent to Oil Treatment
Plant from Wheel Mill
Sample collected directly from sample
port (in the wheel mill) into 1.9 liter
plastic container and stored at 4°C.
t Polyethylene
-------
At 10 a.m. on August 25, and at 1 p.m. on August 27, grab samples
were collected for analysis for organic constituents. All samples were
collected with a 1.8 liter (0.48 gal) stainless steel bucket, poured
into a 11.4 liter (3 gal) stainless steel bucket, and then poured into a
3.79 liter (1 gal) brown glass bottle. The bottle contained 8 ml H^SO^
and was sealed with a teflon cap. Both stainless steel buckets were
rinsed three times with freon, then rinsed three times with the waste
stream water prior to sampling. On August 25, a blank consisting of
distilled water was prepared identically to the samples collected from
the outfalls. The samples were stored at 4°C.
REFERENCES
1. Water Measurement Manual, U. S. Dept. Interior, Bureau of Reclamation,
Denver, Colo., 1974, Chapters 2 and 6.
2. Ibid, Chapter 5.
-------
Appendix C
Chain-of-Custody Procedures
-------
ENVIRONMENTAL PROTECTION AGENCY
Office Of Enforcemenf
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Building 53, Bo* 25227, Denver Federal Center
Oenver, Colorado 80225
July 24, 1974
CHAIN OF CUSTODY PROCEDURES
General:
The evidence gathering portion of a survey should be characterized by the
minimum number of samples required to give a fair representation of the
effluent or water body from which taken. To the extent possible, the quan-
tity of samples and sample locations will be determined prior to the survey.
Chain of Custody procedures must be followed to maintain the documentation
necessary to trace sample possession from the time taken until the evidence
is introduced into court. A sample is in your "custody" if:
1. It is in your actual physical possession, or
2. It is in your view, after being in your physical possession, or
3. It was in your physical possession and then you locked it up in
a manner so that no one could tamper with it.
All survey participants will receive a copy of the survey study plan and will
be knowledgeable of its contents prior to the survey. A pre-survey briefing
will be held to re-appraise all participants of the survey objectives, sample
locations and Chain of Custody procedures. After all Chain of Custody samples
are collected, a de-briefing will be held in the field to determine adherence
to Chain of Custody procedures and whether additional evidence type samples
are required.
Sample Collection:
1. To the maximum extent achievable, as few people as possible should
handle the sample.
2. Stream and effluent samples shall be obtained, using standard field
sampling techniques.
3. Sample tags (Exhibit I) shall be securely attached to the sample
container at the time the complete sample is collected and shall
contain, at a minimum, the following information: station number,
station location, date taken, time taken, type of sample, sequence
number (first sample of the day - sequence No. 1, second sample -
sequence No. 2, etc.), analyses required and samplers. The tags
must be legibly filled out in ballpoint (waterproof ink).
-------
Chain of Custody Procedures (Continued)
Sample Collection (Continued)
4. Blank samples shall also be taken with preservatives which will
be analyzed by the laboratory to exclude the possibility of
container or preservative contamination.
5. A pre-printed, bound Field Data Record logbook shall be main-
tained to record field measurements and other pertinent infor-
mation necessary to refresh the sampler's memory in the event
he later takes the stand to testify regarding his action's
during the evidence gathering activity. A separate set of field
notebooks shall be maintained for each survey and stored in a
safe place where they could be protected and accounted for at
all times. Standard formats (Exhibits II and III) have been
established to minimize field entries and include the date, time,
survey, type of samples taken, volume of each sample, type of
analysis, sample numbers, preservatives, sample location and
field measurements such as temperature, conductivity, DO, pH,
flow and any other pertinent information or observations. The
entries shall be signed by the field sampler. The preparation
and conservation of the field logbooks during the survey will
be the responsibility of the survey coordinator. Once the
survey is complete, field logs will be retained by the survey
coordinator, or his designated representative, as a part of the
permanent record.
6.. The field sampler is responsible for the care and custody of the
samples collected until properly dispatched to the receiving lab-
oratory or turned over to an assigned custodian. He must assure
that each container is in his physical possession or in his view
at all times, or locked in such a place and manner that no one can
tamper with it.
7. Colored slides or photographs should be taken which would visually
show the outfall sample location and any water pollution to sub-
stantiate any conclusions of the investigation. Written documenta-
tion on the back of the photo should include the signature of the
photographer, time, date and site location. Photographs of this
nature, which may be used as evidence, shall also be handled
recognizing Chain of Custody procedures to prevent alteration.
Transfer of Custody and Shipment:
1. Samples will be accompanied by a Chain of Custody Record which
includes the name of the survey, samplers signatures, station
number, station location, date, time, type of sample, sequence
number, number of containers and analyses required (Fig. IV).
When turning over the possession of samples, the transferor and
transferee will sign, date and time the sheet. This record sheet
-------
Chain of Custody Procedures (Continued)
allows transfer of custody of a group of samples in the field,
to the mobile laboratory or when samples are dispatched to the
NFIC - Denver laboratory. When transferring a portion of the
samples identified on the sheet to the field mobile laboratory,
the individual samples must be noted in the column with the
signature of the person relinquishing the samples. The field
laboratory person receiving the samples will acknowledge receipt
by signing in the appropriate column.
2. The field custodian or field sampler, if a custodian has not
been assigned, will have the responsibility of properly pack-
aging and dispatching samples to the proper laboratory for
analysis. The "Dispatch" portion of the Chain of Custody Record
shall be properly filled out, dated, and signed.
3. Samples will be properly packed in shipment containers such as
ice chests, to avoid breakage. The shipping containers will be
padlocked for shipment to the receiving laboratory.
4. All packages will be accompanied by the Chain of Custody Record
showing identification of the contents. The original will accom-
pany the shipment, and a copy will be retained by the survey
coordinator.
5. If sent by mail, register the package with return receipt request-
ed. If sent by common carrier, a Government Bill of Lading should
be obtained. Receipts from post offices and bills of lading will
be retained as part of the permanent Chain of Custody documentation
6. If samples are delivered to the laboratory when appropriate person-
nel are not there to receive them, the samples must be locked in
a designated area within the laboratory in a manner so that no
one can tamper with them. The same person must then return to the
laboratory and unlock the samples and deliver custody to the
appropriate custodian.
Laboratory Custody Procedures:
1. The laboratory shall designate a "sample custodian." An alternate
will be designated in his absence. In addition, the laboratory
shall set aside a "sample storage security area." This should be
a clean, dry, isolated room which can be securely locked from the
outside.
2. All samples should be handled by the minimum possible number of
persons.
3. All incoming samples shall be received only by the custodian, who
will indicate receipt by signing the Chain of Custody Record Sheet
-------
Chain of Custody Procedures (Continued)
accompanying the samples and retaining the sheet as permanent
records. Couriers picking up samples at the airport, post
office, etc. shall sign jointly with the laboratory custodian.
4. Immediately upon receipt, the custodian will place the sample
in the sample room, which will be locked at all times except
when samples are removed or replaced by the custodian. To the
maximum extent possible, only the custodian should be permitted
1n the sample room.
5. The custodian shall ensure that heat-sensitive or light-sensitive
samples, or other sample materials having unusual physical
characteristics, or requiring special handling, are properly
stored and maintained.
6. Only the custodian will distribute samples to personnel who are
to perform tests.
7. The analyst will record in his laboratory notebook or analytical
worksheet, identifying information describing the sample, the
procedures performed and the results of the testing. The notes
shall be dated and indicate who performed the tests. The notes
shall be retained as a permanent record in the laboratory and
should note any abnormalities which occurred during the testing
procedure. In the event that the person who performed the tests
1s not available as a witness at time of trial, the government
may be able to introduce the notes in evidence under the Federal
Business Records Act.
8. Standard methods of laboratory analyses shall be used as described
in the "Guidelines Establishing Test Procedures for Analysis of
Pollutants," 38 F.R. 28758, October 16, 1973. If laboratory
personnel deviate from standard procedures, they should be prepared
to justify their decision during cross-examination.
9. Laboratory personnel are responsible for the care and custody of
the sample once it is handed over to them and should be prepared
to testify that the sample was in their possession and view or
secured in the laboratory at all times from the moment it was
received from the custodian until the tests were run.
10. Once the sample testing is completed, the unused portion of the
sample together with all identifying tags and laboratory records,
should be returned to the custodian. The returned tagged sample
will be retained in the sample room until it is required for trial.
Strip charts and other documentation of work will also be turned
over to the custodian.
-------
Chain of Custody Procedures (Continued)
11. Samples, tags and laboratory records of tests may be destroyed
only upon the order of the laboratory director, who will first
confer with the Chief, Enforcement Specialist Office, to make
certain that the information is no longer required or the samples
have deteriorated.
-------
EXHIBIT I
EPA, NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Station No.
Date
Time
Sequence No.
Station Location
fnmpi
o
_BOD
Solids
_COD
_Nutrients
_Mefa!s
.Oil and Grease
J).0.
_Bact.
.Other
Samplers:
Remarks/Preservative:
Front
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
BUILDING 53, BOX 25227, DENVER FEDERAL CENTER
DENVER, COLORADO 80225
Back
-------
EXHIBIT II
FOR
SURVEY, PHASE.
DATE
TYPE OF SAMPLE.
ANALYSES REQUIRED
STATION
NUMBER
STATION DESCRIPTION
ac
hi
Z
Z
o
u
PRESERVATIVE
3
z
<
o
OL
o
C3
or
o
z
LU
X
a.
REMARKS
-------
_ IBI _I
Somplori: __
FIELD DATA RECORD
STATION
NUMBER
DATE
TIME
TEMPERATURE
•c
CONDUCTIVITY
fx mhos/cm
pH
S.U.
D.O.
mg/l
Gage H».
or Flow
Ft. or CFS
-------
EXHIBIT IV
ENVIRONMENTAL PROTECTION AGENCY
Office Of Enforcement
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Building 53, Box 25227, Denver Federal Center
Denver, Colorado 80225
CHAIN OF CUSTODY RECORD
SURVEY
SAMPLERS: (Signature}
STATION
NUMBER
STATION LOCATION
DATE
TIME
SAMPLE TYPE
SEQ
NO
NO Of
CONTAINERS
ANALYSIS
REQUIRED
Woter
Air
Comp
Grab
Relinquished by: (Sig nofurej
Received by: (Signature;
Date/T
ime
Relinquished by: (Srgnofure/
Received by: (Stgnaiuio)
Date/Ti
me
Relinquished by:
Received by: (Stgnatvrej
Date/Ti
i me
Relinquished by:
Received by Mobile Laboratory for field
analysis.
Date/Time
Dispatched by: fSignafuro/
Date/Ti me
Received for Laboratory by:
Date/T
ime
Method of Shipment:
Distribution: Orig — Accompany Shipment
1 Copy—Survey Coordinator Fiold Fitos
cpo es« - <"•''
-------
Appendix D
Analytical Procedures and Quality Control
-------
ANALYTICAL PROCEDURES AND QUALITY CONTROL
Samples collected during this survey were analyzed, where appro-
priate, according to procedures approved by EPA for the monitoring to
industrial effluents.* The analytical procedures for characterizing
trace organic chemical pollutants are described below. The remaining
procedures are listed in the following table.
Parameter
A1, Cr, Fe,
Pb, Sn
TSS
Phenol
Method
Atomic absorption
Gravimetric
Automated Colori-
metric
Oil and grease Freon extraction
Reference
EPA Methods for Chemical
Analyses of Hater and
Wastewater, 1971, p 83
ibid., p 278
EPA Methods for Chemical
Analyses of Water and
Wastes, 1974, p 243
Standard Methods 13th Ed.,
p 254
Samples for organic chemical pollutant analysis were collected in
clean, solvent rinsed one-gallon glass containers. These samples were
air freighted to Denver and extracted with methylene chloride. The
extract was dried with anhydrous sodium sulfate, concentrated, exchanged
into acetone, and analyzed by hydrogen flame ionization gas chroma-
tography. Those samples that showed adequate response were set aside
for characterization by combined gas chromatography-mass spectrometry
(GC/MS). The GC/MS analyses were carried out with a Finnigan Model 1015
Quadropole Mass Spectrometer and a Systems Industries Model 150 com-
puterized data system. Mass spectra were compared to data files in the
* Federal Registery Vol. 40, No. Illt June 9, 1975.
-------
NIH Computer System and also to listings in the Eight Peak Index of Mass
Spectra, Second Edition, 1974, compiled by the Mass Spectrometry Data
Center. All identifications are considered preliminary until authentic
standards of the suspected chemical compounds can be obtained and analyzed
under similar conditions to match the mass spectrum and gas chromato-
graphic retention time. This procedure does not detect highly volatile
organic chemical pollutants since their presence is masked by the ex-
traction solvent.
Reliability of the analytical results was documented through an
active Analytical Quality Control Program. As part of this program,
replicate analyses were normally performed with every tenth sample to
ascertain the reproducibility of the results. In addition, where
appropriate, every tenth sample was spiked with a known amount of the
constituents to be measured and reanalyzed to determine the percent
recovery. , These results were evaluated in regard to past AQC data on
the precision, accuracy, and detection limits of each test. On the
basis of these findings, all analytical results reported for the survey
were found to be acceptable with respect to the precision and accuracy
control of this laboratory.
-------
Appendix E
Marsh-McBirney Flow Meter
-------
FLOW MEASUREMENT USING THE MARSH-McBIRNEY
ELECTROMAGNETIC FLOW METER
The flow meter is provided with a Faraday-type electromagnetic flow
sensor which has two perpendicular axes so that both X and Y directional
vectors can be measured. The operator can obtain from the measurement
both the direction and magnitude of the water velocity. All sensors are
cylindrically shaped and have no moving parts which are susceptible to
clogging or fouling.
The sensor consists of a cylinder containing an electromagnet
internally and two pairs of external electrodes in contact with the
water. Flow around the cylinder probe intersects magnetic flux lines
causing voltages to be generated which are linearly proportional to the
water velocity. The voltages are detected by the electrodes, processed
at the signal conditioner and presented as analog voltages linearly
proportional to the X and Y components of the velocity vector.
The accuracy of an electromagnetic sensor includes linearity, zero
drift, and absolute calibration. Linearity allows direct reading without
a correction chart and accurate recording of steady flow in the presence
of fluctuations. All March-McBirney instruments are accurate to at
least +2% of reading or +0.07 feet per second, whichever is larger.
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