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            Environmental Protection
            Agency
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            /Vasr.r-gton DC 20^60
           Water
&EFA
Guidance  Manual
for

Iron and Steel Manufacturing
Pretreatment  Standards

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             GUIDANCE MANUAL
                   FOR
       IRON AND STEEL MANUFACTURING
          PFETFEATMENT STANDARDS
               Prepared by
                   The
      Industrial Technology Division
Office of Water Regulations and Standards
                   and
             Permits Division
 Office of Water Enforcement and Permits
              September 1985
   U.S. Environmental Protection Agency
            401 M Street, S.W.
          Washington, DC  20460

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             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                               WASHINGTON. D.C.  20460
                                                                   OFFICi OF
                                                                    WATER
MEMORANDUM

SUBJECT:  Guidance Manual  for Iron and Steel Manufacturing Pretreataent
          Standards

FROM:     Martha G. Prothro,  Director^VVx\>- .V ^s \   U
          Permits Division (EN-336)
                                        i  i
          Jeffery D.  Denit, Director
          Industrial  Technology Divis
/&>iH
TO:       Users of the Guidance Manual
     This manual provides  information to assist Control Authorities and
Approval Authorities in implementing the National Categorical Pretreataent
Standards for the Iron and Steel Manufacturing Point Source Category (40
CFR Part 420).  It is designed  to  supplement the more detailed documents
listed as reference in the manual;  it ia not designed to replace them.
If you need more complete  Information on a specific item, you should
refer to the appropriate reference.

     EPA developed this manual  to  fill several needs.  First, it should
be useful to Control Authorities in responding to moat routine inquiries
from regulated mills.  More complex Inquiries may require the use of the
listed references.

     Second, the manual addresses  application of the combined wastestream
formula to Integrated facilities with regulated and unregulated wastestreams.
It also provides current information on removal credits, variances and
reporting requirements. It further incorporates the final amendment to
the categorical standards  reflecting the settlement of litigation Issues
for the final rule.

     The manual is the third, in a series of industry-specific guidance
manuals for implementing categorical pretreatment standards, and several
others will be issued soon. We also plan to issue manuals covering
removal credits, the combined waatestream formula and the conversion of
production-based categorical standards to equivalent mass-based standards.

     Please feel free to write  to  either the Office of Water Regulations
and Standards (WH-552) or  the Office of Water Enforcement and Permits
(EN-336) with suggestions, additions or improvements.

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                             ACKNOWLEDGEMENTS
     We wish to acknowledge the considerable  efforts and cooperation of the many
people whose contributions helped in the successful completion of this document.

     The document was prepared under the direction of Mr. Marvin Rubin,
Chief, Analysis and Support Branch,  Industrial Technology Division and
Dr. James Gallup, Chief,  Municipal Programs Branch, Office of Water
Enforcement and Permits.   Mr.  Gary Amendola of EPA Region V, and Mr. Ed
Dulaney of the Industrial Technology Division are to be acknowledged for
their valuable input.  In addition,  members of the Office of General
Counsel and other members of the Industrial Technolgy Division and Office
of Water Enforcement and  Permits are acknowledged for their important
contributions.

     This document was prepared by JRB Associates under EPA Contract No.
68-01-65H.

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                            TABLE OP CONTENTS
Chapter
                                                                     Page

1.  INTRODUCTION	  1-1

    1.1  HISTORY OF THE IRON AND STEEL MANUFACTURING CAIEQORICAL
         PRETREATMENT STANDARDS	  1.2

2.  IRON AND STEEL CATEGORICAL PRETREATMSNT STANDARDS (40 CFR
    PART 420}	  2.1

    2.1  AFFECTED INDUSTRY	  2-1
    2.2  PRETREATMENr STANDARDS FOR THE IRON AND STEEL MANUFAC-
         TURING CATEGORY	  2-1
    2.3  RELATIONSHIP TO ELETROPLATING AND METAL FINISHING	  2-21
    2.4  POLLUTANTS EXCLUDED FROM REGULATION	  2-21
    2.5  COMPLIANCE DATES	  2-21

3.  TBSATMSNT TECHNOLOGIES	  3-1

    3.1  TREATMENT OF COKEMAKING WASTES	  3-1
    3.2  TREAT*NT OF SINTERING WASTES	  3-2
    3.3  TREATMENT OF IROW1AKING WASTES	  3-2
    3.4  THE ATMS NT OF STEELMAKING WASTES	  3-3
    3.5  TREATMENT OF VACUUM DEGASSING WASTES	  3-4
    3.6  TREATMENT OF CONTINUOUS CASTING WASTES	  3-4
    3.7  TREATMENT OF HOT FORMING WASTES	  3.5
    3.8  TREATMENT OF SALT BATH DSSCALING WASTES	  3.6
    3.9  TREATMENT OF ACID PICKLING WASTES	  3.7
    3.10 TREATMENT OF COLD ROLLING WASTES	  3.7
    3.11 TREATMENT OF ALKALIS CLEANING WASTES	  3.8
    3.12 TREATMENT OF HOT COATING WASTES	  3.8

4.  REQUIREMENTS OF THE GENERAL PRETREATMENT REGULATIONS	  4.1

    4.1  INTRODUCTION	  4-1
    4.2  CATEGORY DETERMINATION REQUEST	  4-2
    4.3  MONITORING AND REPORTING REQUIREMENTS OF THE GENERAL
         PRETREATMSNT REGULATIONS	  4-2

           3.1  Baseline Monitoring Reports	  4-2
           3.2  Report on Compliance	  4-4
           3.3  Periodic Reports and Continued Ccnpliance	  4-4
           3.4  Notice of Slug Loading	  4-5
           3.5  Monitoring and Analysis to Demonstrate
                  Continued Compliance	  4-5
         4.3.6  Signatory Requirements for Industrial Users
                  Reports	  4-5
         4.3.7  Recordkeeping Requirements	  4-5

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                      TABLE OF CONTENTS  (Continued)


Chapter                                                             Page

     4.4  APPLICATIONS OF THE COMBINED WASTESTREAM FORMULA          4-6

          4.4.1  CWF Conditions	    4-7
          4.4.2  Monitoring Requirements for Industrial  Users
                 Using the CWF	    4-7
          4.4.3  Application of the CWF	    4-7

     4.5  REMOVAL CREDITS	    4-11
     4.6  FUNDAMENTALLY DIFFERENT FACTORS VARIANCE	    4-12
     4.7  LOCAL LIMITS	    4-12

     REFERENCES	    R-l

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                                LIST OP TABLES






Table                                                                Page




2.1  PRETREATMENT STANDARDS FOR EXISTING SOURCES (PSES)	  2-9




2.2  PRETREATMENT STANDARDS FOR NEW SOURCES (PSNS)	  2-15




2.3  POLLUTANTS EXCLUDED FROM IRON AND STEEL REGULATION	  2-22




4. 1  COMBINED WASTESTREAM FORMULA	  4-8




4.2  COMBINED WASTESTREAM FORMULA EXAMPLE CALCULATION	  4-9
                                      111

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                             1.  INTRODUCTION

     The National Pretreatment Program established an overall strategy
for controlling the introduction of nondomestic wastes to publicly owned
treatment works {POTWs) in accordance with the overall objectives of the
Clean Water Act.  Sections 307(b) and (c) of the Act authorize the
Environmental Protection Agency to develop national pretreatment standards
for new and existing dischargers to POTWs.  The Act made these pretreatment
standards enforceable against dischargers to publicly owned treatment
works.

     The General Pretreatment Regulations (40 CFR Part 403) establish
administrative mechanisms requiring nearly 1,500 POTWs to develop local
pretreatment programs to enforce the general prohibitions, specific
prohibitions and Categorical Pretreatment Standards.  These Categorical
Pretreatroent Standards are designed to prevent the discharge of pollutants
that pass through, interfere with, or are otherwise incompatible with the
operation of the POTWs.  The standards are technology-based for removal of
toxic pollutants and contain specific numerical limits based on an
evaluation of specific technologies for the particular industry categories.
As a result of a settlement agreement between EPA and the Natural Resources
Defense Council (NRDC), EPA was required to develop Categorical Pretreatment
Standards for 34 industrial categories with a primary emphasis on 65
classes of toxic pollutants.

     This manual will provide guidance to POTWs on the implementation and
enforcement of the Categorical PretreaOnent Standards for the Iron and
Steel Manufacturing Category.  This document is based primarily on two
sources: Federal Register notices, which include the official announcements
of the Categorical Standards, and the Final Development Document for Iron
and Steel Manufacturing, which provide a surinary of the technical support
for the regulations.  Additional information on the regulations,
manufacturing processes, and control technologies can be found in these
sources.  A listing of the references used in the development of this
manual is provided at the end of this document.
                                    1-1

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1,1  HISTORY OF THE IRON AND STEEL MANUFACTURING CATEGORICAL PRETREATMENT
     STANDARDS
     Steel manufacturing involves many processes, which require large quanti-
ties of raw materials.  Because of the variety of products and processes in
this industry, operations vary free plant to plant.  Steel facilities range
from plants engaging in a few production processes to extremely large Inte-
grated complexes engaging in several or all processes.  Even the smallest
steel facility represents a large industrial complex.

     The steel industry can be segregated into two major components, raw
steelmaking, and forming and finishing operations.  In the first, coal is
converted to coke, which is then combined with iron ore and limestone in a
blast furnace to produce iron.  The iron is purified into steel in either open
hearth, basic oxygen or electric arc furnaces.  Finally, Che steel can be
further refined by vacuum degassing.  The second component, following the
steelmaking processes, includes hot forming (Including continuous casting) and
cold finishing operations.  Primary hot forming mills reduce steel ingots to
slabs or blooms and secondary hot forming mills reduce these to billets,
plates, shapes, strips, and other products.  Steel finishing operations
involve other processes that do little to alter the dimensions of the hot
rolled product, but impart desirable surface or mechanical properties.

     Water is essential to the Industry and is used in appreciable quantities
in virtually all operations.  An average of 40,000 gallons of water is used in
producing every ton of finished steel, making this one of the highest water
users of any manufacturing industry.  During the raw steelmaking and forming
and finishing operations, toxic, nonconventional and conventional pollutants
enter the wastewaters.  EPA'a survey of iron snd steel mills identified  141
pollutants In plant effluents.  Some of these pollutants pass through POTW
treatment systems, Interfere with biological treatment, or contaminate POTW
sludges.  Pretreatment alternatives for the iron and steel industry are
designed to control toxic metal pollutants and to recycle wastewater to  the
manufacturing process.  Common treatment technologies include oil skimming,
metals precipitation, sedimentation, steam stripping, solvent extraction,
biological oxidation (coke wastes), thickening, filtration, and vacuum filter
                                     1-2

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dewatering.  Typically, the design, purchase and installation of this

equipment requires 18 to 36 months.


Pretreatinent standards for the iron and steel industry regulation were
first proposed in February 1974, and were first promulgated on June 28,
1974.  the most recent final regulations, which established specific

numberical limitations falling within 10 of the 12 subcategories, were
proposed in January 1981 and finalized on May 27, 1982.


Petitions to review the final iron and steel industry regulation were
later filed by certain members of the iron and steel industry and the
Natural Resources Defense Council Inc. (NRDC).  The challenges raised
were consolidated into one lawsuit, and in February 1983, the petitioners
and EPA reached a settlement agreement.  This comprehensive settlement
resolved issues related to the steel industry standards and on October
14, 1983, changes to the regulation were proposed.   These major amendments
to the Iron and Steel Standards were promulgated on May 17, 1984 (49 FR

21024) and include:
     (1)  An interim regulation establishing the method for calculating
          applicable mass-based pretreatment standards;

     (2)  Establishment of July 10, 1985 as date of final compliance with
          iron and steel pretreatment standards;

     (3)  Pretreatntent removal credits for phenols measured by the 4 AAP
          method;

     (4)  Standards that are slightly higher for lead and zinc in the
          Sintering and Ironmaking Subcategories;

     (5)  Standards that are slightly higher for lead and zinc in the
          Acid Pickling Subcategory;

     (6)  Modified effluent limitations and standards for zinc in the Hot
          Coating Subcategory;

     (7)  Modified combined wastestrean formula to allow control authorities
          to exercise judgment to determine whether blowdown and noncontact
          cooling streams are dilution or unregulated process streams;
          and

     (8)  Regulation for permitting nominal discharges of spent oil or
          water solution in the cold worked pipe and tube segments of the
          Cold Rolling Subcategory, with a statement that limits and
          standards for process wastewaters not regulated by prior
          regulation are to be developed on a case-by-case basis.


                                   1-3

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             2.  IRON AND STEEL CATEGORICAL PRETREATMENT  STANDARDS
                               (40 CFR PART 420)
2.1  AFFECTED INDUSTRY

     The Iron and Steel Standards are applicable  to vastevater discharged  from

industries included vithin the Standard Industrial Classification  (SIC) Major

Croup 33 - Primary Metal Industries*  Those parts of  the  industry  covered  by

this regulation are the subgroup SIC numbers  3312 (except  Coil Coating), 3315,

3316 and 3317 and parts of 3479.


     In developing this regulation, EPA determined that different  effluent

limitations are appropriate for distinct segments of  the  industry.   The Agency

identified 12 main process subcategories which are:
     1.  Cokemaklng
     2.  Sintering
     3.  Ironmaklng
     4.  Steelmaklng
     5.  Vacuum Degassing
     6.  Continuous Casting
7.   Hot Forming
8.   Salt Bath Descaling
9.   Acid Pickling
10.  Cold Forming
11.  Alkaline Cleaning
12.  Hot Coating
These twelve Iron and Steel Operations are briefly discussed  below:

     1.   Cokemaking

          Coke plants are operated at integrated facilities to  supply  coke  for
          producing iron in blast furnaces or at stand-alone  facilities  to
          supply coke to other users.  Nearly all active coke plants also
          produce usable byproducts such as coke oven gas, coal tar, crude  or
          refined light oils, ammonium sulfate or anhydrous ammonia, and
          naphthalene.  A byproduct coke plant consists of ovens  in which
          bituminous coal is heated without air to drive off  volatile  compo-
          nents.  The coke is suppled to blast furnaces, while  the volatile
          components are recovered and processed into byproduct materials.

          The most significant wastewaters generated during byproduct  coke-
          making and byproduct recovery operations are excess ammonia  liquor,
          final cooler wastewater, light oil recovery wastewaters, barometric
          condenser wastewaters from the crystalllzer, desulfurizer waste-
          waters, and contaminated wastewatera from air pollution emission
          scrubbers for charging, pushing, preheating, and screening opera-
          tions.
                                     2-1

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2.   Sintering

     Sintering la an agglomeration process in which iron bearing Bate-
     rials (generally fines) are nixed with iron ore, limestone, and
     finely divided fuel such as coke breeze.  The fines consist of mill
     •cale from hot rolling operations and dust from basic oxygen
     furnaces, open hearth furnaces, electric arc furnaces, and blast
     furnaces*  The rav materials are mixed before they are placed on the
     traveling grate of the sinter machine.  Near the head end of the
     grate, the surface of the raw materials Is ignited by a gas fired
     ignition furnace located over the bed.  As the mixture moves along
     the grate, air is drawn through the mixture at the wind boxes to
     enhance combustion and sinter (fuse) the fine particles.  As the bed
     burns, carbon dioxide, cyanides, sulfur compounds, chlorides,
     fluorides and oil and grease are driven off with the gases.

     The sinter drops off the grate at the discharge end and is cooled
     (either by air or a water spray), crushed, and screened to maintain
     uniformity in the size of the sinter fed to blast furnaces.
     Improperly sized sinter and fines from screening are returned for
     reprocessing.

3.   Ironmaking

     Byproduct coke is supplied to blast furnace processes where molten
     iron is produced for subsequent steelmaking.  Iron ore, limestone
     and coke are placed into the top of a blast furnace and hot air is
     blown into the bottom.  Combustion of the coke provides heat and a
     reducing atmosphere that produce metallurgical reactions.  The lime-
     stone forms a fluid slag, which combines with unwanted impurities in
     the ore.  Molten iron and molten slag, which floats on top of the
     Iron, are periodically withdrawn from the bottom of the furnace.
     Blast furnace flue gas is cleaned and then used to preheat the
     Incoming air of the furnace.

     Blast furnace operations use water for two purposes:  (1) noncontact
     cooling of the furnace, stoves, and ancillary facilities not
     governed by these regulations, and (2) cleaning and cooling the
     furnace top gases.  Other waters, such as floor drains and drip
     legs, are also part of the process wastewaters, but the volume from
     these sources Is relatively low.

*•   Steelmaking

     Steel is an alloy of iron containing less than 1.0 percent carbon.
     Raw materials for steelmaking include hot metal, pig iron, steel
     scrap, limestone, burned lime, dolomite, fluorspar, iron ores, and
     iron-bearing materials such as pellets or mill scale.  In steel-
     making operations, the furnace charge is melted and refined by
     oxidizing certain constituents, particularly carbon in the molten
     bath, to specified low levels.  Various alloying elements are added
     to produce different grades of steel.  Steelmaking processes in use
     today are the open hearth furnace, the electric arc furnace, and the
                                  2-2

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     basic oxygen furnace (BOP) which Is the only one currently associ-
     ated with discharges to POTVs.

     Steelmaking processes generate fumes, smoke, and waste gases as
     impurities are vaporized.   Wastewaters are generated when semi-wet
     or wet gas collection systems are used to condition and clean the
     furnace off-gases.  Particulates and toxic metals in the gases are
     the main source of pollutants and contaminants in process waste-
     waters.

     Pour main water systems are used in BOP steelmaking operations:

     •  Oxygen lance noncontact cooling
     •  Purnace trunnion ring and nose cone noncontact cooling
     •  Hood noncontact cooling
     •  Fume collection scrubber and gas cooling.

     Most steelmaking operations recycle wastewaters to some degree.
     Several plants recycle more than 90 percent of their process
     effluents.  Recycling is a good water conservation practice as It
     not only reduces the volume of fresh water needed by the gas
     cleaning system, but also reduces the volume of wastewater dis-
     charged.

5.    Vacuum Degassing

     In the vacuum degassing process, molten steel is subjected to a
     vacuum to remove gases (principally hydrogen, oxygen, sulfur, and
     nitrogen). The gases can impart detrimental qualities to finished
     steel products if they are not removed.

     Fumes and waste gases are generated by impurities in the steel.  The
     hydrogen, oxygen (reacted with carbon), and nitrogen dissolved in
     the steel are drawn out by the reduced pressures in the vacuum
     chamber.  Wastewaters are generated in the vacuum degassing process
     when exhaust steam, used to educt the fumes and gases, is condensed
     in spray cooling (contact) chambers.  Pollutants in the system
     exhaust contaminate the cooling water, which is discharged into a
     sump (hot well) through a stand-pipe.

6.    Continuous Casting

     The continuous casting subcategory includes both ingot casting and
     continuous casting processes.  Ingot casting is the conventional
     procedure of casting molten steel into ingots followed by reheating
     and breakdown in primary hot rolling mills into semi-finished shapes
     known as billets, blooms, or slabs*

     In the continuous casting process, hot molten steel is poured from
     the ladle into a refractory lined tundish.  The tundish maintains a
     constant head of molten metal and can distribute the molten steel to
     more than one casting strand in multiple strand operations.  The
                                2-3

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     molten metal from the tundish pours through nozzles  into  an  oscil-
     lating, water-cooled copper mold, where partial solidification  takes
     place.  Lubricants, such as rape seed oil, are sprayed  into  the
     •olds to aid steel movement through the mold.  As the metal  solidi-
     fies in the mold, the cast product is withdrawn continuously.  After
     passing through the water-cooled molds, the partially solidified
     product moves into a secondary cooling zone, where water  sprays cool
     and solidify it.

     The continuous casting process has three main water  systems:

     •  Copper mold noncontact cooling water system
     •  Machinery noncontact cooling water system
     •  Cast product spray contact cooling water system.

     Only the cast product spray contact cooling water is subject  to this
     regulation as the other two systems use noncontact cooling water
     only.  However, leaks of noncontact cooling water into  the process
     water system would also be treated.

7.    Hot Forming

     Primary hot forming mills reduce ingots to slabs or  blooms and
     secondary hot forming mills reduce slabs or blooms to billets,
     plates, shapes, strips, and other forms.

     The basic operation in a primary mill is the gradual compression of
     the steel ingot between two rotating rolls.  Multiple passes  through
     the rolls, usually in a reversing mill, are required to reshape the
     ingot into a slab, bloom, or billet.  As the ingot passes through
     the rolls, high pressure water jets remove surface scale.  The  Ingot
     passes back and forth between the horizontal and vertical rolls
     while manipulators turn it.  When the desired shape  is  achieved In
     the rolling operation, the end pieces (or crops) are sheared  off.
     The semi-finished pieces are stored or sent to reheating  furnaces
     for more shaping.

     Scale, oil and grease are the conventional pollutants discharged
     from rolling mill operations.  As the hot steel is rolled in  the
     mill stands, the steel surface oxidizes and scales or flakes  off.
     The scale particles, ranging in size from submlcron  to  several
     millimeters, are carried by water to scale pits where they settle
     out.  The particles are 70-75 percent iron as ferrous oxide  (FeO)
     and ferric oxide (Fe.O.).  Overhead cranes equipped with  clam
     buckets are generally used to clean the scale pits.  Scale pit
     effluents are discharged to plant sewers or are partially recycled
     back to the mills.  The suspended solids in scale pit overflows can
     be as high as 300 mg/1.  These wastewaters can be further treated by
     clarification, filtration, and recycling.  Oils, generally in the
     range of 15 to 45 mg/1, are found in rolling mill wastewaters
     because of oil conditioning, oil spills, line ruptures, excessive
     dripping of lubricants, and equipment wash-down.  Wastewater  con-
     centrations as high as 150 mg/1 may be reached during line ruptures.
                                2-4

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8.   Salt Bach Descaling

     Oxidizing and reducing are Che two processes within  the  sale  bach
     descaling subcategory.  The oxidizing process uses highly oxidizing
     salt bachs maintained aC temperatures of 700-900'P.  These  salts
     react acre aggressively with scale Chan with the base oecal and, as
     a result, produce a smoother surface Chan acid pickling.

     During Che oxidizing process Che steel product is placed in Che
     oxidizing bath after being tcapered.  After the product  has been
     exposed to this chemical ami thermal action, It is cooled in  a
     "cold" water tank.  Together, the chemical action and the sudden
     cooling and steam formation cause the surface scale  to crack, so
     that subsequent pickling operations can be more effective.

     Reducing operations are similar except that they depend  upon  the
     strong reducing properties of sodium hydride (1.5 to 2 percent by
     velght) in a fused caustic soda bath at 700°P.  Reducing operations,
     like oxidizing operation*, are operated as integral  parts of  the
     pickling process.

9.   Acid Pickling

     Acid pickling is the process in which steel products are immersed  in
     heated acid solutions to remove surface scale.

     Wastewatera are generated by three major sources in  pickling
     operations.  The largest source is the rinse water used  Co clean the
     product after it has been immersed in the pickling solution.  The
     second source is the spent pickling solution, or liquor, that has
     become too weak to continue to treat Che steel products.  The spent
     pickle liquor is a small volume, but is very acidic and contains
     high concentrations of iron and toxic metal pollutants.  It is dis-
     charged intermittently.   The third source is wastewater from wet
     fume scrubbers.

10.   Cold Rolling

     Cold-reduced flat  rolled products are made by cold rolling pickled
     strip steel.  The  thickness of the steel is reduced by 25 to 99
     percent in this operation to produce a smooth, dense surface.

     The major process  water use in cold rolling mills is for cooling and
     lubricating the rolls and the steel product.   This is done with
     flooded lubrication systems, where a water-oil emulsion is sprayed
     directly on the product and rolls.   Each stand usually has separate
     sprays and, if used, a separate recycle system.   Past practice was
     to discharge the water-oil wastes directly to the sewer.  However,
     the high cost of rolling oils and pollution control regulations have
     changed this*  Recycle and recovery system* are now in common use.
     In fact,  most of the newer cold rolling mills use reclrculated oil
     solution systems to reduce oil use and pollutant discharges.
                                2-5

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11.   Alkaline Cleaning

     Alkaline cleaning is used where vegetable, mineral, and animal fats
     and oils oust be removed from the steel surface prior to further
     processing*  Solutions of various compositions, concentrations, and
     temperatures are often used for cleaning.  Electrolytic cleaning may
     be used for large scale production or where a cleaner product is
     required.  The alkaline cleaning bath is a water solution of
     carbonates, alkaline silicates, phosphates, and sometimes wetting
     agents to aid cleaning.

     Wastewaters are discharged from two sources in alkaline cleaning
     lines:  the cleaning solution tank and the subsequent rinsing steps.
     The cleaning solution tank contains a caustic solution with high
     levels of sodium compounds and other components.  At some lines, the
     cleaning solution is reused continously. Fresh solution is added to
     make up for dragout and evaporative losses.  The baths are dis-
     charged periodically to limit the buildup of contaminants (dissolved
     solids and oils), or as soon as the cleaning ability of the solution
     is weakened.  A process being developed Includes an ultrafiltration
     system that continuously treats the alkaline cleaning solutions and
     allows higher reuse rates.

     Because most alkaline baths are used to clean large amounts of
     steel, pollutants can build up to high levels.  Typical levels of
     pollutants found in alkaline cleaning baths are shown belowr

              Pollutant or
        Wastewater Characteristic        Typical Values (mg/1)

        Alkalinity                             1,000
        Iron, total                            100
        Oil & Grease                           1,500
        pH (units)                             12-13
        Total Dissolved Solids                 25,000
        Total Suspended Solids                 1,000
        Temperature                            70°-2(WP

     The other source of wastewaters from the alkaline cleaning process
     is the rinse step, which follows the cleaning operation, and is
     required to remove residual cleaning solution from the product.
     Rinsing is done in spray chambers or one or several dip tanks
     depending upon the degree of rinsing required.  Although some lines
     have standing rinse tanks (no continuous flow through the tanks),
     many lines have rinse tanks with continuous water feed and overflow
     to keep the rinse water cleaner and to cool the product.

12.   Hot Coating

     Hot coating processes involve dipping clean steel into baths of
     molten metal to deposit a thin layer onto the steel surface.  These
     coatings provide desired qualities, such as resistance to corrosion,
     safety from contamination, or a decorative bright appearance.  The
                                2-6

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           two  major  classes  of  metallic  coating operations in the industry are
           hot  coating and cold  coating.   Zinc,  terne,  and aluminum coatings
           are  Host often applied  from molten metal  baths, while tin and
           chromium are usually  applied electrolytically from plating solu-
           tions.  Nearly all hot  coating operations  discharging to POTWs use
           the  galvanizing process  (zinc).

           The  major  waatewater  flows  originating from  hot coating operations
           fall Into  three groups:

           •  Continuous  dilute  wastewaters  from rinses following chemical
             treatment or surface  passivation steps  and final product rinses
             after hot dipping.  These waters contain  suspended and dissolved
             solids,  chlorides, sulfates, phosphates,  silicates, oily matter,
             and varying amounts of dissolved metals (iron,  zinc, chromium,
             lead, tin,  aluminum,  cadmium)  depending on which coating metal is
             used.

           •  Concentrated Intermittent discharges (including fluxes), chemical
             treatment solutions,  and  regenerant solutions from in-line ion
             exchange  systems.  These  discharges contain higher concentrationa
             of the  pollutants  noted  above.   Discharge volumes from these
             sources  can be  minimized  by close  attention to  maintenance and
             operating conditions, and by using dragout recovery units.   Hot
             dipped  coating  baths  themselves  are never discharged.   Instead,
             they are  recovered and continuously regenerated as part  of the
             coating operation, or by  outside contractors.

           •  Fume scrubber wastewaters are  produced  by the continuoua scrub-
             bing of  vapors  and mists  collected from the coating steps.
             Scrubber  wastewaters may  be used as process rinses,  since only
             volatile  components are  present  in the  air to be  scrubbed.   Less
             than 40  percent  of all hot  coating lines  have wet  fume  scrubbers.
             A few plants have  dry fume  absorbers.


     Many  of the subcategories were further divided  to account  for  differences
in manufacturing processes and equipment.   Separate  limits were  then  developed
for each subdivision.
2.2  PRETREATMENT STANDARDS FOR THE IRON AND STEEL MANUFACTURING CATEGORY

     The categorical pretreatment standards for the iron and steel industry

distinguish between existing sources and new sources.  As a general rule, EPA
establishes pretreatment standards on the basis of concentration.  However,
for the steel industry, the Agency believes the standards should be based upon
mass limitation* (kg/kkg) to ensure that effective toxic pollutant control is

provided and to minimize the hydraulic Impact of large volume discharges on
                                     2-7

-------
POTWs.  These standards are expressed as maximum  30-day  average  and  maximum
daily mass  limitations in kilograms  per  1000  kilograms  (Ibs/LOOO Ibs)  of
product (except  for acid pickling and hot  coating operations with fume
scrubbers where  mass  limitations are expressed  in kilograms p«r  day  for each
scrubber).

     The pretreatment standards for  existing  sources  (PSES), with the  excep-
tion of cokemaking, are equivalent to best available  technology  (BAT)  for
direct dischargers.   BAT represents  the wastewater  treatment processes
necessary to achieve  best available  economic  performance of wastewater
treatment at plants of different ages, sizes, production rates,  and  other
factors.  The standards for cokemaking facilities are based on treatment
technologies installed to pretreat cokemaking wastewater prior to on-site
biological  treatment.  These levels  of treatment  Include technologies  for
removing toxic pollutants, both by process modification  and by end-of-plpe
treatment,  which could pass through  or otherwise  be incompatible with  the
operation of a POTW.  Pretreatment standards  have been developed by  EPA for 10
of the 12 iron and steel subcategories.  The  two  subcategories which do not
have pretreatment standards are Subpart G  - Hot Forming  and Subpart  K  -
Alkaline Cleaning.  For these two subcategories,  EPA  has determined  that there
are not significant quantities of toxic pollutants  to upset or pass  through
POTW treatment plants or limit POTW sludge management alternatives.  For the
10 regulated subcategories, the limits are presented  in Tables 2.1,  a-f.

     The pretreatment standards for new sources (PSNS) apply to  iron and steel
manufacturing facilities for which construction began after January  7, 1981,
the date of the  proposed regulation.  New  facilities  are able to incorporate
process controls that reduce pollutant loadings,  so in some cases  the  PSNS are
more stringent than PSES.  The PSNS are baaed on  the  best available  demon-
strated technologies  and for most subcategories are identical to the PSES.
The exceptions are:   Subpart I - Acid Pickling, Subpart J - Cold Forming, and
Subpart L - Hot Coating.   The PSNS for these  three subcategories are presented
in Tables 2.2, a-f.
                                     2-8

-------
                                                                          TABU 2.1*

                                                                   STANBAIDS KM UISTIHC soutccs (PSKS)

                                                POLLUTANT LIMIT* (In kg/Kkf of produce yg««
        (•OP):
        IMt*
2.  tOt:  W«t-op*a    Av*.
                                                                                                                O.OOOIM
                                                                                                                0.000411
                                                                                                             0.000207
                                                                                                             0.000620
    1.
          W*t-        Av*.
                      MM.
                                                                                                                0.0000626
                                                                                                                O.OOOIM
                                                                                                             0.0000919
                                                                                                             0.000282
        Op«n U««rtb
        Furncc*:  ttet*
                                                                               2-9

-------
                                                                     TABLE 2.1 b

                                            PBETREATMENT  STANDAJtDS  FOB  EXISTING SOURCES  (PSES)  (Continued)

                                            POLLUTANT LIMITS  (In k|/Kk| of product  unteea otherwise noted)
Subparc
Phenol
As»onti ChlorlM (4AAP)
Naphtha-
lene
Tetrachloro*
ethylene Chroalua
Cyan Id*
(Total) Lead Nickel
Heuvtlent
Zinc Chro«luBj
5.   Blectrle Arc
    Purnace (*A/):

t.
p.
c.
». BAP: Wet
VacwM
Degaaalaf
Coatlxiowa
Casting
Mot Poralag**
Ave.
Ka».
A«e.
Max.
Ave.
Nai.

0.0001M 0.000207
0.000413 0.000*20
0.0000)11 0.0000469
0.0000939 0.0001*1
0.0000113 0.0000469
0.0000919 0.000141

N. SaU l*th
Deacallof






a. Oxldl(ln« -
1. latch. Sheet
aad Plate
2. Batch. Bod
aad Wire
J. Batch. Pipe
a*d Tuba
4. Cottttnuoua
b. Beduclof -
1. Batch
2. Continuous
A»e.
Ha*.
Ave.
Mat.
Ave.
Has.
Ave.
Ha«.
Ave.
Max.
Aye.
Hai.
0.00117 0.0008/6
0.00292 0.0026}
0.000701 0.000i26
0.00175 0.00158
0.00284 0.00213
0.00709 0.00638
0.000551 0.000413
0.00118 0.00124
0.000542 0.000119 0.000407
0.00136 0.00102 0.00122
0.00304 0.00190 0.00228
0.00759 0.00569 0.00681
                                                                      2-10

-------
                                                             TAIL! 2.lc

                                    PUTUATNUrr  STANDARDS  fOt  EXISTING SOUKCIS  (PSES)  (Continued)

                                    POLLUTANT  LIMITS  (la  fee/*** •* product  ualaaa  othcrvla*  aoted)
Subpart Ai
I. Acid Pickling
a. Sulfurtc
Acid Pickling -
1. tod. Mir*. Av*.
aad Call Max.
2. Iar. illlet. Av*.
aad Blooa MM.
3. Strip, Av*.
Sheet . Max.
aad Plat*
4. Pip*. Tub*. Av*.
aad Other Max.
4. Pua* ^
Scrubber Av*.
b. Hydrochloric
Acid Pickling ~
1. tod, Hlr*. Av*.
•ad Coll Max.
2. Strip.
Md Plat* Nax.
3. Pip*. Tub*. Av*
•ad Otb*r Nax.
4. Pua* . Av*.
Scrubber Mai.
4. Acid Ke- Av*.
general lo* Mai.
Phenol Naphtha- Tetrachloro- Cyanide
•KM la Chlorine (4AAP) l*o* ethylene Chroalua (Total) Lead Nickel
0.000174
0.000426
0.0000463
0.000169
0.000113
0.00033*
O.OOO3I3
0.00093*
0.0123
0.0368
0.000307
0.000920
0.000174
0.000426
O.OOOblo
0.00192
0.0123
0.036*
0.0819
0.244
kiciavalent
Zinc Chroalue)
0.000234
0.000701
0.0000741
0.000224
0.000140
0.000441
0.000417
0.00124
0.0164
0.0491
O.OOO409
0.00123
0.000234
0.000701
0.000»41
0.00244
0.0lt>4
0.0491
0.109
0.032/
(Absorber
vcot icrubber)
(h«/day)
                                                                  2-11

-------
                                                              TA»LI 2. Id

                                                 STANDARDS rot EXISTING soutccs (PSU) (Continued)

                                    POLLUTANT LIHITS (In kf/Ut| of product iMleea otherwise noted)
Suopart
                                         Phaool
                              Chlorine   (4AAP)
                                                                 baptitha-   Tatrachloro-             Cyanide
                                                                 lane       ethyl ana      Chroeiluei   (Total)    Lead
                                                                                                                Nlckal
                                                                                                                              Zinc
                                                         Haxavalant
                                                         Chrovlu*
    c.   Coejelnatlon
          Acid Plckllnt
        1.  tod. Wire.    Ave.
            and Coll      Max.
                                                                              0.000*52
                                                                              0.00213
                                  0.000638
                                  0.00192
        2.   lar. Billet.  Ave.
            and •looet     Mas.
                                                                              O.OOOM4
                                                                              0.000960
                                  0.000288
                                  O.OOOM4
        3.   Strip. Sheet. Ave.
            •nd Plate -   Max.
                                                                              0.002V)
                                                                              0.00*2*
                                  0.00188
                                  0.00563
        4.   Strip. Sheet, Ave.
            •nd Hate -   Max.
            latch
                                                                              0.0007U
                                                                              0.00192
                                  0.000576
                                  0.00173
            Pipe. Tuhe.   Ave.
            •nd Other     Max.
                                                                              0.00129
                                                                              0.00322
                                  0.000964
                                  0.00289
Scruktor
              Ava.
              Mai.
0.0327
O.MI9
                                                                                                                            0.0245
                                                                                                                            0.0735
J.  Cold Poralnc
    a.  Cold to 1lln(
        1.  teclrcvla-    Ave.
            tlon, Single  Max.
            Stand
                                                                              0.00000*4
                                                     0.0000021  0.0000031     0.0000209
                      0.0000031
                      0.0000094
                                                                                                                            0.0000061  0.0000021
                                                                                                                            0.0000188  0.0000063
        2.  taclrcula-    Ave.
            tlo*. Mult I-  Max.
            pie Standa
                                                     0.0000104  O.OOOQlia     0.0000418
                                                                              O.OOOIO4
                      0.0000156
                      0.0000469
                                                                                                                            0.0000313  0.00001O4
                                                                                                                            0.0000939  0.0000313
        ).  Combination   Av«.
                          Max.
                                                     0.00012)   O.OOOIM
O.OOOWI
0.00125
                                                                                                    0.000188
                                                                                                    0.000561
                                                                                                                            0.000376   O.OOOI25
                                                                                                                            0.00113    0.000376
                                                               2-12

-------
                                                                        TAftU 2.U

                                               PUTUATWNT STAMOAIDS rot CXISTIMC sotmcu  (PSIS)

                                               POLLUTANT L IK ITS (!• kg/Ik* of arooitct ualoia  othervlae  aotee1)
Suhpart
                                                    Phenol
                                    la   ChlorlM   (4AAP)
                                                               Naphtha-   Tetrachloro-             Cyantoe
                                                               UM       ethyUae      ChroaliaB   (Total)    UU
                                                                                                                         Hlckcl
                                                                                                                                       Zinc
        4.  Ott.et
                         Mai.
                                                               0.000017*  O.OOOOS41
                                                                                       O.OOOIM)
                                                                                       0.00017k
                     O.OOOOM1   0.0001II   0.0000176
                     O.OOOU*    0.0003)*   0.00011)
        5.   Direct
                         A**.
                         (torn.
                                                               0.000167   0.000250
0.00066*
0.00167
0.0002V)
0.0007)1
O.OOOW1    0.000167
0.00150    O.OOOV)!
    ».  CoU
                 Ttota
        Nllli
K. AUallM
Cl«aal«c**
L. Hot Coatlaft
a. Cclvaalilafl A»«.
«U Othar Ham.
Coat !•«• -
Stria. SkMt.
aaa Nlac.
•. Cal«aalila< ~ A*a.
Wlr« ProaWcta Ha«.
a«4 Paata*ara
c. PIMM A*«.
Scritkkara Wa«.
(ki/4ar>
O.OO0176 O.OOOM) O.OOOOMI
O.OOIU 0.001M) O.OOOIW
0.00 IX) 0.00200 0.000200
O.OO*il 0.00601 0.000601
0.012) 0.0164 0.0016)
0.0 J6» 0.04*1 0.00490
A»«. - Average of 4ally »al«ee  for  M cowaecutlv*
Hai. • HailaMB for any o«e  4ajr

*Thi«
••No ruwrical  lavlc* MC« ««tai>Ual>ed for thi»
                 ItaguUtiara in 40 CTK 403.
                                                                    However,  ttwy *r»  «ubj«ct  to th*
                                                                            2-13

-------
                                                                       TAiL£  2.If

                                             PUTUATMUrr STANDARDS FOI EXISTING SOUICES  (PSCS)  (Continued)

locreaaad loadings, not to exceed 24 percent of these standards, are allowed  for by-product  coke planta  that  have wet  deaulfurlzstIon systeas,  but  only to
the extant that auch ayateas generate a« Increaaed effluent voluae.  Incraaaad  loadinga,  not  to  exceed M  percent of  these  standards, are  allowed  for
by-product coke planta that have Indirect aaaonta recovery aycteew, but only  to tha extent that  auch  ayateaa  generate  an Increased  effluent  volua*.

lacraaaed loadlnf*. not to esce«d 21 percent of theae atandarda are allotted for by-product coke  planta that have  wet desulfurlcatlon  ayateaa.  but  oaly  to
tke extent that auch eyatee» fenarate an ta
-------
                                                                         TABLE 2.2*

                                                                      STANDARDS pot New SOURCES (PSNS)

                                                POLLUTANT  LIMITS  (In kft/Kk|  of product unlesa  otherwlee not«
-------
                                                                         TABLE 2.2b

                                                  RETREATMeMT STANDARDS FOR NEW SOURCES (PSNS) (Continued)

                                               POLLUTANT LIMITS (In kf/Kkf of product unlaaa othamlaa ootad)
Stiaaarl
Phenol
naannu Chlorin* (4AAf)
Naahtha-
lana
Tatrachloro-
athyiana Chroailuai
Cyanlda
(Total) Laad
Hcmavalaat
Nlckal Zinc Chroaiiua
    5.  lUctrlc Arc
        PurMc* (CAT):
6. BAT: Wat
1 KT,,
P. Coatlmioua
Ava.
Max.
Ava.
Ava.
Mam.
0.000138
0.000413
0.0000313
0.0000939
0.0000313
0.0000939
0.000207
0.000620
0.0000469
0.000141
0.0000469
0.000141
C. Hot For«l«t**
H.  Salt Bath
a. Omtdlilm« -
1. Batch, Sha«t
aad Plata
2. Batch. Bod
ud Hlra
3. Batch, Hf»
aad T«ha
4. Co.t, 	
b. Beduclnf -
1. Batch
2. ContlMMMta
Ava.
Ma*.
Ava.
Ham.
Ava.
Has.
Ava.
Nam.
Avc.
Ham.
Ava.
Ham.
0.00117
0.00292
0.000701
0.0017)
0.00284
0.00709
0.000))!
0.00138
0.000)42 0.0003)9
0.00136 0.00102
0.00304 0.00190
0.007)9 0.00)69
0.000876
0.00263
0.000)26
0.001)8
0.00213
0.00638
0.000413
0.00124
0.000407
0.00122
O.OO228
0.00683
                                                                           2-16

-------
                          TAaU 2.2c




   PUTUATMtWT STAMQAIDS POt MCW SOUICKS  (PSNS)  (CoatlMMd)




POLLUTANT LIMITS (la kf/Kk( of product  *•!•••  otherwise not*d)
Subpart
I. Acid Pickling
a. Sulfurlc
Acid Ptcklloc -
1. kod. Hlr«.
•nd Coll
2. i«r, IllUt,
u»4 llooa
3. Strip,
Sh««t.
•ad Plat«
4. Pip*. Tub*,
•»d OtlMC
5. PWM
Scri>bb*r*
(kg/day)
b. Hydrochloric
Acid Ptckll*« -
1. tod. Wlr*.
Md Coll
2. Strip,
Sa**t.
Md Plat*
3. Pip*. Tub*.
«U Ocb*r
*. fu^-
Scrubber
A
Av*.
Naa.
A»«.
Hai.
Av*.
Max.
Av*.
Has.
Av*.
Max.
Av*.
Has.
Av*.
Max.
Av*
Nai.
Av«.
Nai.
Phenol Naphtha- Tctrachloro- Cyaold*
•Ktola ChlorlM («AAP) l*o* •thyl*m« Chroalu* (Total) Uad Hlck*l
0.0000313
0.0000939
O.OOOOIM
O.OOOOM3
0.00002 SO
0.00007!^
0.0000434
0.000131
0.0123
0.03M
0.0000376
0.000113
0. 00002 W
0.0000741
O.OOOO6M
0.00020*
0.0123
0.034A
Mciuval*nt
Zinc ChroaluB
O.OOOO4I7
0.00012)
O.OO002SO
0.00007 SI
U.00003M
0.000100
0.0000i«4
O.OOOI7i
0.0164
0.0491
0.0000 Mil
o.ooooix>
0.0000)34
0.000100
O.OOOO9I8
0.00027)
0.0164
0.0491
                             2-17

-------
                                                                          TABLE 2.24

                                                   rUTUAimNT STANOABDS  fOB NEW SOUBCES (PSHS) (Continued)

                                                POLLUTANT LIMITS (}a k|/tk( of product  unleaa otharvlaa noted)
Subearc At
c. Co*klaatlaa>
Acid rtckllnc
i. Bed, Hire. A»e.
aad Coll Max.
1. Bar. BllUt, **•.
••d Blooa Mu.
1. Sirlf, Sheet, *•«.
Md PUt« - Mu.
Coctlaooa*
*. Stit». SlM«t. AM.
Md Plat* - Mu.
fetch
i. Pip*. Tub*. *••.
wd OtlMr NM.
*. PWW A*«.
Scrnbter Nu.
(k«/d*y)
Pb*MOl Naphtha- T«tr«chJoro- Cyanide
•Mia CkloriM (4AAP) I«M «tbyl«M ChroaluB (Total) Laad
0.000117
0.0002*2
0.0000667
0.000167
0.000284
0.000710
0.000100
0.0002 SO
0.000167
0.000418
0.0)27
0.0819
Naiavalant
Nickel Hoc Chroaluai
O.OOOO876
0.00026)
O.OOOOMI
0.0001M
0.00021)
0.0006)8
0.00007)1
0.00022)
0.00012)
0.000)76
0.024)
0.07))
J.  Cold Pora
    a.  Cold
        I.  Baelrrala
            tlo*.
A**.
                         0.0000084
0.0000021  0.00000)1     0.0000209
                      0.00000)1   0.000006)  0.0000021
                      0.0000094   0.0000188  O.OO0006)
        2.  Baclrcvla-    A««.
            tlo*. iMltl-  HM.
            pla Staa^a
0.0000042  0.000006)
0.0000167
0.0000418
                                               0.000006)   0.000012)  O.OOOOO42
                                               0.0000188   0.0000)76  0.000012)
        ).  Coablnatloa   ••«.
                          Mac.
0.0000)42  O.OOOO81)
0.000217
0.000)4)
                                               0.0000814   0.00016)   O.OOOO)42
                                               0.000244    0.000488   0.00016)
                                                                           2-18

-------
                                                                         TABU 2.2*

                                                  PUTUATMNT STANOAftM  POI NM lOUKCtS (PSNS) (Coatlau**)

                                               POLLUTANT LIMITS (la kf/KkC  of •rodwcc ualaaa otharvlaa •otaa')
                                                       Naphtha-   Tatrachloro-             Cyaalda
                            »ta   ChlorlM   (4AAP)      IBM       athyUaa      Chroalva   (Total)
                                                                                                                         Nickel
                                                                                                                                       Zlac
                                                                                                                                               Haiavalant
                                                                                                                                               Chroaluai
4.  Dlract
    A«*Uea
    SU«U
                                                                0.0000104  0.00001!*
0.0000411
0.000104
0.00001i»   0.0000)1)  0.0000104
0.0000449   0.00009)9  0.0000)13
).  Direct
    Applies
    MMltlfl*
                          A««.
                                                                0.000121   O.OOOIS2
0.0004»4
0.00121
0.0001(2
0.000)4)
0.000)4)   0.000121
0.00109    0.000)4)
     k.  CoU W*rka4


        Nllla7
 K.
L. Mot Coat lag
a. Calvaalslac A*a. 0.00009)9
a^ Othar Ma>. 0.0002(2
aarf Mlac.
k. Cal*aal. O.OM(
(kf/aay)
O.OOOI2)
0.000)74
0.000)0
0.001)0
0.01*4
0.0491
0.000012)
0.0000)74
O.OOOO)OI
0.0001V)
0.0016)
O.O0490
 Ava. - A*«raf«  •(  aally valaaa (*r X> coaaacatlva  ««y«
 Ma«. - NailaMa  for aar «M 4ay
*Thi»

••Mo
       !• r»M«LV«d.

        llBlta wra ••Ublislwd for thi* •Uxrataqocy.  Houcvcr, they an •tl>j«ct to  Uw General
        Regulation-. In 40 CTR 403.
                                                                              2-19

-------
                                                                       TABLE  2.2f

                                                rUTUATMCNT STANOAIDS FOt NEW SOURCES  (PSNS)  (Continued)

Increaaed loadings, not to exceed 2* percent of theae etandarde, are allowed  for by-product  coke  plant*  that  have wet  deaulfurltatIon *y*teae,  but only to
the extent that aueh eyete*a generate aa Increaaed effluent volua*.  Increaaed loading*,  not to exceed i8 percent of  thea* ataodarda, ate allowed for
by-product coke planta that have Indirect aaaxMla recovery *yateaa, but only  to the  extent  that auch ayatea*  generate an Increaaed  effluent voluaa.

lacreaaed loading*, not to exceed 21 percent of theee ataodarda are allowed for by-product  coke planta that have wet  deaulfurlutIon *y*t*aa,  but only to
toe extent that auch ayateaa generate an lacreaaed effluent voluaw.  lacreaaed loadlnga,  mot to exceed 5Q percent of  the** atandard*. are allowed for
by-product coke pleat* that have Indirect aaaxmla recovery ayateaa, but only  to the  extent  that auch ayateaa  generate  an Increaaed  effluent voluat*.

The (tandarda for aaaBOnta-H, cyanide, and phenol* (4AAF) are applicable only  when  alnterlag waatewater la treated along with  Ironcaklng waatewater.

The** Halt* apply to each fuate acrubber aaaoclatad with aulfurlc acid pickling operatlona.

Theae Halt* apply to each fuate acrubber aaaoclated with hydrochloric *cld pickling  operatlona.

for procaaaea regulated by Subpart J, the Halt* on chroalua and nickel apply In lieu of  the Halt*  on lead and tine  when cold rolling waatawatera are
treated with deecaliag or combination acid pickling water*.

Dlachargea froa theee operationa to  Publicly Owned Treataent Work* are prohibited.
                                                                           2-20

-------
2.3  RELATIONSHIP TO ELECTROPLATING AND METAL FINISHING

     In certain cases there may be sane question regarding whether a
production process  is covered by Iron and Steel Categorical pretreatment
standards or Metal  Finishing pretreatment standards.  For iron and steel
manufacturing operations also covered by metal finishing, the more specific
standards apply, i.e., iron and steel.

      For example,  if a plant performs pickling and electroplating at an
iron and steel then the metal finishing PSES apply only to the discharge
fron electroplating while the iron and steel PSES apply to the discharge
frcm the surface preparation operation of pickling.  Normally, the metal
preparation operation (pickling),  would be subject to the metal finishing
regulation, however, because the iron and steel regulations specifically
include this operation performed in iron and steel mills, the iron and
steel regulation takes precedence for this wastestream.

2.4  POLLUTANTS EXCLUDED FROM REGULATION

     The EPA excluded fron relation 81 of the 126 toxic pollutants that
are given priority  consideration.  These pollutants are found either in a
small nunber of sources and are uniquely related to those sources, or are
detected in the effluent in trace quantities, which are not likely to
cause toxic effects.  These 81 pollutants are presented in Table 2.3.

2.5  COMPLIANCE DATES

     In accordance with the settlement agreement, all existing industries
engaged in the manufacture of steel must comply with the Iron and Steel
Categorical pretreatment standards, by July 10, 1985 except for those
facilities identified in the regulations as being considered under separata
rulemaking for central waste treatment facilities.  All new steel
manufacturing facilities must comply with pretreatment standards at the
time discharge commences.
                                   2-21

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                                   TABLE 2.3

              POLLUTANTS EXCLUDED FROM IRON AND STEEL REGULATION
                                         Unique                   Trace
     Pollutant                         Occurrence               Quantities


l,2-Dlchloro«thant                                                   x
1,1,2-Trlchloroathane                       X
1,1,2,2-Tatrochloro«than«                                            x
2-Chloronaphthal«na                                                  *
2,4,6-Trichlorophanol                                                x
2-Chlorophenol                                                       *
1,2-Dlchlorobenzena                                                  x
1,4-Dlchlorobenzene                                                  X
1,1-Dlchloroethylent                        X
1,2-Tranadichloroathylent                                            x
2,4-Dlchlorophenol                                                   X
1,2-Diphenythydrazene                                                X
Methylenechloride                                                    X
Dlchlorobroaooethane                                                 X
Isophorone                                                           x
Nitrobenzene                                                         x
2-Nltrophenol                                                        x
2,4-Dlnltrophenol                                                    x
3,4-Benzofluoranthene                       X
Benzo(K)fluoranthene                        X
Benzo(ghl)p«rylene                          X
Dlbenzo(a,h)~anthracene                     X
IndenoC1,2,3 cd}pyrene                      X
Vinyl Chloride                              X
Aldrln                                      X
Diedrln                                     X
Chlordane                                   X
4,4-DDT                                     X
4,4-DDE                                     X
4,4-DDD                                     X
a-endoaulfan-Alpha                          X
b-endosulfan-Beta                           X
Endoaulfan aulfate                          X
Endrln                                      X
Endrln aldehyde                             X
Heptachlor                                  X
Heptachlorepoxide                           X
a-BHC-Alph«                                 X
b-BHC-Beta                                  X
r-BHC-Gama                                 X
g-BHC-Delta                                 X
PCB-1242                                    X
PCB-1254                                    X
PCB-1221                                    X
                                       2-22

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                                   TABLE 2.3

        POLLUTANTS EXCLUDED PROM IRON AND STEEL REGULATION (Continued)
                                         Unique                   Trace
     Pollutant                         Occurrence               Quantities


PCB-1232                                    X
PCB-1248                                    X
PCB-1260                                    X
PCB-1016                                    X
Toxaphene                                   X
Beryllium                                                            X
Mercury                                                              X
Manganese                                   X
                                        2-23

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                          3.  TREATMENT TECHNOLOGIES

     The treatment technologies described in thia section are currently used
by iron and steel (manufacturers to remove wastewater pollutants generated by
industrial processes.  The technologies are grouped according to the subcate-
gorles where they are used, and include oil skimming, metals precipitation,
sedimentation, steam distillation, solvent extraction, thickening and vacuum
devatering.

3.1  TREATMENT OF COKEMAKING WASTES
     Treatment of wastewatera from this subcategory can be accomplished vith
system such as that illustrated below.
                 ri   . ------ 1
                   L-^OPWOUtCTI
                  J   L— — '
                       LuL
                                                                       .«• rarw
     With this system, process wastewaters are mixed with waste ammonia liquor
and enter a dephenolizer, which recovers phenolic compounds.  The benzol plant
wastes and final cooler blowdown are Initially treated In a gas flotation unit
where waste pickle liquor Is used to break emulsions and an inert gas mixture
is introduced to enhance the separation of oils and greases.  The above two
waste streams are then combined, free ammonia is stripped and recovered and
lime or caustic soda Is added to ralae the pH to 11 or 12.  Fixed ammonia
stripping is used to remove as much ammonia as possible prior to further
treatment.  Wastes are then retained in an equalization/sedimentation basin
with approximately one day's retention time.  Unreacted lime particles and
other suspended matter separates out, and is periodically removed by clamshell
bucket or transferred to vacuum filters.  The overflow from the basin Is then
neutralized and aerated prior to discharge to the POTW.
                                     3-1

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3.2  TREATMENT OP SINTERING WASTES
     Sintering process wastewaters result  from dust and gas  scrubbing  equip-
ment and from sinter cooling.  The common  practice  is to combine wastewater
streams for treatment.  A treatment system suitable for meeting pretreatment
limitations for this subcategory is diagrammed below.
     With this system process wastewaters enter a thickener where oil* and
grease are removed by skimming and solids are settled with the  aid  of a
polymer.  Sludge removed from the thickener is dewatered on a vacuum filter.
Ninety-two percent of Che thickener effluent is returned to the process.
Wastewater is discharged fro* the system after pressure filtration  or metals
precipitation.

3.3  TREATMENT OF IRONMAKING WASTES
     Prior to the mid-l970§, treatment of ironmaking wastewaters involved
removal of suspended solids by sedimentation, aided by flocculating agents  to
Improve removal rates.  These clarified wastewaters were discharged without
further treatment.  Today, about 90 percent of blast furnace wastewater
treatment systems include recycling (after the thickener), and  discharge only
a relatively snail percentage (generally 5 to 10 percent) of the process flow.
Cooling towers are often used to lower the temperature of recycled  waste.   The
                                     3-2

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thickener underflows  are typically dewatered with  the  filtrate returned to the
thickener Influent.   The dewatered solids are either sent  to sintering
operations or  to  off-site disposal.  A typical waatewater  treatment system for
•eeting pretreatment  regulations is diagrammed below.
— ^— -^ *
n*tr
ttut
outmrn-
titan
Q>
M^^M^M^^





SCON*
tlM*
OI.C«M-
*"°*
                                                                      To POT*
      In  addition to the solids removal and recycle  technologies, treatment
includes a  two-stage chlorlnation process to destroy  cyanide and to oxidize
phenols  and anoonia.  Following chlorlnation a  reducing agent such as sulfur
dioxide  is  added to remove residual chlorine.
3.4  TREATMENT OF STEELMAKINC WASTES
     Wastewater  treatment for discharges from  this  subcategory can be accot
plished with a system such as that diagrammed  below.
                           I   (1)  Recycle rates: 95J - Basic Oxygen Furnace - Suppressed
                           *                        Coobustlon
                                      3-3
                                               90X - Basic Oxvoen Furnace - Ooen Co«bust1

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     Hastevater initially enter* a thickener, which reduce*  suspended  solids
with the aid of a polymer or other coagulant aid.  The solids  are  removed  and
thickened on a vacuum filter.  A major portion of the effluent  from  the
thickener is recycled to the process; the remainder flows  to an inclined plate
separator after lime is added for removal of toxic metals.
3.5  TREATMENT OP VACUUM DEGASSING HASTES
     A wastewater treatment system capable of
for this subcategory is diagrammed below.
eetlng pretreatment regulations
     The first step in the pretreatment process  involves  gravity  sedimentation
in a scale pit to remove suspended solids.  The  effluent  from the scale  pit
flows to a sump and Is either  recycled to  the  process  through a  cooling  tower
or is treated with lime to precipitate metals.   Haste water  is discharged after
solids and toxic metals are removed  by lime precipitation and clarification  in
an Inclined plate separator.
3.6  TREATMENT OF CONTINUOUS CASTING HASTES
     The pretreatment standards  for this  subcategory  can be  met  using the
treatment system diagrammed below.

-------
ftocycto

\COOUWQ { ^
\TOWC«y


I
 Soil*
                                                                         To POTW
             scale pit
         (process wastewaters)
INCLINCO
H.ATC
SCMAATOft
                                                              Ta
                                                            Ottposol
     The process wastewaters  first  enter a scale pit where solids are  removed
by sedimentation and oil  is skimmed.   A flat bed filter is then used for
additional solids removal (a  pressure filter is recommended for meeting PSNS).
About 96 percent of the filter effluent is returned to the process; the rest
is treated with lime to precipitate metals in an Inclined plate separator.

3.7  TREATMENT OF HOT FORMING WASTES
     About 20 hot forming operations  discharge wastewaters to POTWs.   In many
cases, these wastewaters  are  recycled to minimize user fees to the Industry
and to avoid hydraulically overloading POTWs.  EPA believes that future
discharges to POTWs from  hot  forming  operations, if any, will receive  similar
treatment and will not contain high levels of toxic metals.  The Agency
believes that the pass-through of  toxic pollutants from hot forming operations
is not a problem.  Thus,  categorical  pretreatment standards for hot forming
wastewaters were not promulgated.
                                      3-5

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3.8  TREATMENT OF SALT BATH DESCALING WASTES
     tfastewaters are generated at two points  in oxidizing  operations:   in  the
salt bath tank and in the rinse steps after it.  The  bath  is  a molten  salt
solution that contains high levels of sodiua  compounds  and  other  components.
The solution stays in the bath for a long time before being replaced.   Because
of Its highly contaminated nature and relatively small  volume, this  spent  salt
solution waste is generally hauled off-site for disposal by private  contrac-
tors.  These salt solutions are treated at some plants  by  bleeding a small
volume of the waste solution into the pretreataent  system  over a  period of
hours or days.

     The other source of wastewater from oxidizing  operations is  the rinse
step that follows the descaling operation.  This is the primary wastewater
source regulated by EPA.  Wastewaters are produced  in Che  same way for
reducing operations.  Also, oxidizing operations are  the main concern  of POTWe
since they far outnumber reducing operations.  The  pretreataent of these
wastewaters can be accoaplished with the following  system.
                             Recycle
     Using this process, wastewater is treated with acid and  sulfur  dioxide  to
reduce hexavalent chromium to trlvalent chromium.  The effluent  froa the
chromium reduction process first is treated by skimming to  remove  floating oil
and solids and then metals are precipitated in a  clarifier  using  lime  and a
polymer.  Solids are dewatered with a vacuum  filter.
                                     3-6

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3.9  TREATMENT OP ACID PICKLING WASTES
     The system described below la capable of meeting PSES,  A more  complex
system would be needed to meet PSNS.
     The several waste aCreams are combined la an equalization tank where oils
are skimmed.  The waatewater ia then treated with lime and a polymer and
aerated to oxidize iron fro* the ferrous to ferric state.  Next,  it enters a
clarifier to aettla out solids and toxic metals, which are dewatered on a
vacuum filter.

3.10  TREATMENT OP COLO ROLLING HASTES
     Treatment of waatewaters from this subcategory can be met using the
following system:
                                     3-7

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              •Mill UNM
              c«.o MX HIM
              OHUIOI
     The treatment process includes oil removal and solids removal.  Floating
oil is removed, then alum and acid are added to break emulsions.  Solids  and
oil are removed by air flotation following lime and polymer addition.  A
vacuum filter is used to dewater solids.

3.11  TREATMENT OF ALKALINE CLEANING WASTES
     Wastewatera from alkaline cleaning operations are relatively clean
compared to wastewaters from other steel industry operations.  Toxic pollu-
tants are present in untreated alkaline cleaning wastewater only at levels
below or near treatability levels.  EPA has not promulgated numerical  pre-
treatment standards for this subcategory.

3.12  TREATMENT OF HOT COATING WASTES
     Pretreatment of galvanizing wastewaters can be achieved with a system
similar to that discussed under waste treatment for the Salt Bath Descaling
subcategory.
                                     3-8

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         4.  REQUIREMENTS OF THE GENERAL PRETREATMENT REGULATIONS

4.1  INTRODUCTION
     The section provides a brief overview of the General Pretreatment
Regulations and identifies those provisions of the Regulations that have a
direct bearing on the application and enforcement of Categorical Pretreatment
Standards for the Iron and Steel Manufacturing category.

     The General Pretreatment Regulations for Existing and New Sources
(40 CFR Part 403) establish the framework and responsibilities for
implementation of the National Pretreatraent Program.  The effect of 40
CFR Part 403 is essentially three-fold.  First, the General Pretreatment
Regulations establish general and specific discharge prohibitions as
required by Section 307(b) and (c) of the Clean Water Act.  The general
and specific prohibitions are described in Section 403.5 of the Pretreatment
Regulations,  they apply to all nondcmestic sources introducing pollutants
into a POTW whether or not the source is subject to Categorical Pretreatment
Standards.

     Second, the General Pretreatment Regulations establish an administrative
mechanism to ensure that National Pretreatment Standards (Prohibited
Discharge Standards and Categorical Pretreatment Standards) are applied
to and enforced against industrial users.  Approximately 1,500 POTWs are
required to develop a locally run pretreatment program to ensure that
nondcmestic users comply with applicable pretreatment standards and
requirements.

     Third, and most importantly for the purpose of this guidance manual,
the General Pretreatment Regulations contain provisions relating directly
to the implementation and enforcement of the Categorical Pretreatment
Standards.  They include the contained wastestream formula, reporting
requirements, local limits, monitoring or sanpling requirements, and
category determination provisions.  POTW representatives should refer to
40 CFR Part 403 for specific language and requirements where appropriate.
                                       4-1

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4.2  CATEGORY DETERMINATION REQUEST
     An existing industrial user (IU) or Its POTW may request written certifi-
cation from EPA or the delegated State specifying whether the industrial user
falls within a particular industry category or subcategory and  la subject to a
categorical pretreatment standard.  The deadline for submitting a category
determination request by existing industrial users subject to the Iron and
Steel Manufacturing categorical pretreatment standards has passed.  A new
industrial user or its POTW may request this certification for a category
determination any time prior to commencing its discharge.  The contents of a
category determination request and procedures for review are presented in
Section 403.6(a) of the General Pretreatment Regulations.

4.3  MONITORING AND REPORTING REQUIREMENTS OP THE GENERAL PRETREATMENT
     REGULATIONS
     In addition to the requirements contained in the Iron and Steel Manu-
facturing categorical pretreatment standards, industrial users subject to
these standards must fulfill the reporting requirements in Section 403.12 of
the General Pretreatment Regulations.  These requirements Include the sub-
mission of baseline monitoring reports, compliance schedules, compliance
report* (initial and periodic), notices of slug loading, and recordkeeping.
Each reporting requirement is summarized briefly below.

4.3.1  Baseline Monitoring Reports
     All industrial users subject to categorical pretreatment standards must
submit a baseline monitoring report (BMR) to the Control Authority.  The
purpose of the BMR is to provide information that the Control Authority needs
to document the industrial user's current status of compliance with a cate-
gorical pretreatment standard.  The Control Authority Is defined as the POTW
if it has an approved pretreatment program; otherwise the BMR will be sub-
mitted to the State (if the State has an approved State Pretreatment Program)
or to the EPA Region.  Additional guidance on BMR reporting is available from
the EPA Regional Pretreatment Coordinator.
                                     4-2

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BUR Due Dates

     Section 403.12(b) requires that BMRs be submitted  to the  Control  Author-

ity within 180 days after the effective date of a Categorical  Pretreatment
Standard or 180 days after the final administrative decision made  on a

category determination request [403.6(a)(4)J, whichever date is  later.   BMRs

for industries regulated by the Iron and Steel Manufacturing standards  were

due January 6, 1983.


8MR Content

     A BMR oust contain the following information as  required  by Section

403.12(b):


     1.  Name and address of the facility and names of  operator(s)  and
         owner(s).

     2.  List of all environmental control permits held by  or  for  the  facil-
         ity.

     3.  Brief description of the nature, average production rate,  and SIC
         code for each of the operation(a) conducted, Including  a  schematic
         process diagram that indicates points of discharge from the regulated
         processes to the POTW.

     4.  Flow measurement information for regulated process stream* discharged
         to the municipal system.  Flow measurements  of other  waatestreame
         will be necessary if application of the combined wastestream  formula
         is necessary.

     5.  Identification of the pretreatment standards applicable to each
         regulated process and results of measurements  of pollutant masses.
         All samples muse be representative of dally  operations  and results
         reported must Include values for daily maximum and average concen-
         tration (or mass, where required).  If the flow of the  regulated
         stream being sampled is less than or equal to  250,000 gallons  per
         day, the industrial user must take three samples within a two week
         period.  If the flow of the stream is greater  than 250,000 gallons
         per day, the industrial user must take six samples within a two week
         period.  If samples cannot be taken immediately downstream from the
         regulated process and other waatewaters are  mixed with  the regulated
         process, the Industrial user should measure  flows  and concentrations
         of the other was testreams sufficiently to allow use of  the combined
         wastestream formula.

     6.  Statement of certification concerning compliance or noncompliance
         with the Pretreatment Standards.
                                     4-3

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7.  If  not  in  compliance,  a  schedule must be  submitted with  the BMR that
    describes  the actions  the user will take  and a timetable for completing
    those actions to achieve compliance.  This compliance schedule must
    contain specific increments of progress in the form of dates for the
    commencement and completion of major events.  However, no  increment of
    the schedule shall exceed 9 months.  Within 14 days of each completion
    date in the schedule,  the industrial user shall submit a progress
    report to  the Control Authority indicating whether it complied with
    the increment of progress to be met on such date, or, if not, the
    date on which it expects to comply and the steps being taken to return
    to  the schedule.
4.3.2   Report  on Compliance
     Within 90 days after the compliance date for the Iron and Steel
Manufacturing pretreatment standards or, in the case of a new source,
following commencement of the introduction of wastewater into the POTW,
any industrial user subject to the standards must submit to the Control
Authority a report on compliance that states whether applicable pretreatment
standards are being consistently met.  The report must also indicate the
nature and mass of all regulated pollutants in the facility's regulated
process wastestrearas.  If the facility is not in compliance, the report
must explain the additional operation and maintenance and/or pretreatment
that will be necessary to achieve compliance (see 40 CFR 403.12(d)).

4.3.3  Periodic Reports on Continued Compliance

     Unless required more frequently by the Control Authority, all
industrial users subject to the Iron and Steel Manufacturing categorical
pretreatment standards must submit a semiannual periodic compliance report
in the months of June and December {or other months specified by the
Control Authority).  Tne report shall indicate the nature and masses of
the regulated pollutants in the lU's discharge to the POTW, the average
and maximum daily flow rates of the facility,  the methods used to sample
and analyze the wastewater, and a certification that the sampling and
analytical methods conform to those methods outlined in the regulations
(see 40 CFR 403.12(e)).
                                   4-4

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4.3.4  Notice of Slug Loading
     Section 403.12(f) requires Industrial users to immediately notify  the
POTV of a slug load of any pollutant released to the POTV, Including oxygen
demanding pollutants (BOO, etc.) that may cause Interference at the POTV.

4.3.5  Monitoring and Analysis to Demonstrate Continued Compliance
     Section 403.12(g) states that the frequency of Monitoring to demonstrate
continued compliance shall be prescribed in the applicable pretreatment stan-
dard.  The Iron and Steel Manufacturing pretreatment standards do not estab-
lish any monitoring frequency.  Therefore, the appropriate Control Authority
must establish monitoring frequency to adequately demonstrate that Indirect
dischargers subject to the pretreatment standards comply with them.  Unless
otherwise noted in the appropriate paragraph of Section 403.12, the monitoring
frequency established by the Control Authority shall be used in the baseline
monitoring report (403.12(b)(5)), the report on compliance with categorical
pretreatment standard deadline (403.12(d)), and the periodic reports on con-
tinued compliance (403.12(e)).

     Sampling and analysis shall be conducted In accordance with the proce-
dures established in 40 CFR Part 136 and any amendments to it or shall be
approved by EPA.   When Part 136 techniques are not available or are inappro-
priate for any pollutant, then sampling and analysis shall be conducted in
accordance with procedures established by the POTW or other validated proce-
dure.  All procedures for sampling and analysis not Included in Part 136 must
be approved by EPA.

4.3.6  Signatory Requirements for Industrial User Reports
     All reports submitted by industrial users (BMRs, initial reports on
compliance, periodic reports, etc.) must be signed by an authorised represen-
tative of the company in accordance with Section 403.12(k).

4.3.7  Recordkeeping Requirements
     Any Industrial user subject to the reporting requirements of the General
Pretreatment Regulations shall maintain records of all information that
results from any monitoring activities required by 403.12 for a minimum of
                                     4-5

-------
three years  [403.12(n}].  These records shall be available for inspection
and copying by the Control Authority.

4.4  APPLICATION OF COMBINED WASTESTfEAM FORMULA

     One provision of the General Pretreatment Regulations that will
often be used by POTWs and industries to properly monitor and report on
compliance with categorical pretreatment standards is the Combined
Wastestmam Formula (CWF) [40 CFR 403.6(e)J.  The CWF is a mechanism for
calculating appropriate limits specified in applicable regulations for
wastewater in which process wastestrearos are mixed with effluent.  The
CWF is applied to the mixed effluent to account for the presence of the
additional wasteatreams.

     As part of the Settlement reflected in the Nay 17, 1984 amendment,
the preanble (49 PR 21027) states that mass-based limits (mass/day) should
be applied to integrated facilities covered by production-based standards
only and a combination of production-based and concentration-based
standards.

     The following definitions and conditions are important to the proper
use of CWF.

     Definitions

     *  Regulated Process Wastestream - industrial process wastestream
        regulated by National Categorical Pretreatment Standards.
     •
     0  Unregulated Process Wastestrearo - industrial process wastestream
        that is not regulated by a categorical standard.

     0  Dilute Wastestream - boiler blowdown, sanitary wastewater,
        noncontact cooling water blowdown, and Paragraph 8 excluded
        wastestreams containing none or only a trace amount of the
        regulated pollutant.

     Note:  These definitions apply to individual pollutants.  A wastestream
            from a process may be "regulated" for one pollutant and
            "unregulated for another.  In addition,  the Nay 17, 1984
            amendment to the CWF allows the Control Authority to exercise
            its discretion to determine whether boiler blowdown and
            noncontact cooling streams are dilution or unregulated process
            streams.

     0  Concentration-based Limit - limit based on the relative strength
        of a pollutant in a wastestream. usually expressed in rag/1
        (Ib/gal).

     0  Production-based Limit - limit based on the actual quantity of a
        pollutant in a wastestream, usually expressed in kg/some unit of
        production for a given operation, such as square meter (Ib/square
        foot per operation).
                                   4-6

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     0  Mass-based Limit - Limit based on the actual quantity of a
        pollutant in a wastestrearo and the wastestream volume, usually
        expressed  in kg/day  (Ib/day).

4.4.1  CWF Conditions

     To ensure propoer application of the CWF, the following conditions
must be met by a municipality and its industries  [40 CFR 403.6(e)J:

     0  Alternative discharge limits that are calculated in place of a
        categorical pretreatment standard must be enforceable as categorical
        standards.

     0  Calculation of alternative limits must be performed by the Control
        Authority (PCTW) or by the industrial user with written permission
        frcm the POTW.

     0  Alternative limits must be established for all regulated pollutants
        in each of the regulated processes.

     9  Both daily maximum and long-term average (usually monthly)
        alternative limits must be calculated for each regulated pollutant.

     *  Alternative limits must be established for all regulated pollutant
        in each of the regulated processes.

     9  If process changes at an industry warrant, the Control Authority
        may recalculate the alternative limits at its discretion or at
        the request of the industrial user.  The new alternative limits
        must be calculated and become effective within 30 days of the
        process change.

     0  The Control Authority may impose stricter alternative limits, but
        may not impose alternative limits that are less stringent than
        the calculated limits.

     0  A calculated alternative limit cannot be used if it is below the
        analytical detection limit, the ID must either:  1) not combine
        some of the dilute streans before they reach the combined treatment
        facility, or 2) segregate all wastestreans entirely.

4.4.2  Monitoring Requirements for Industrial Users Using the CWF

     Requirements for self-monitoring by an industrial user are necessary
to ensure compliance with the alternative categorical limit.  Because the
Iron and Steel Manufacturing pretreatment standards do no include self-
monitoring requirements, the Control Authority will establish appropriate
self-monitoring requirements.

4.4.3  Application of the CWF

     The combined formula for mass-based limits is in Table 4.1.  Table
4.2 presents an example of how the CWF is used to calculate alternative
limits for specific iron and steel manufacturing operations.  Before

                                   4-7

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                                    TABLE  4.1

                          COMBINED  WASTESTREAM FORMULA
     Limit Formula
Mt  ~ alternative •«•• Halt for the pollutant

MI  - Categorical Pretreatment Standard mass limit for the pollutant in
      regulated stream i (the Categorical Pretreatnent production-based
      standard limit multiplied by the appropriate measure of production)

F!  - average daily flow (at least 30 day average) of regulated stream i

F
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                                TABLE 4.2

             COMBOCD WASTKSTHEAM FORMULA EXAMPLE CALCULATION

                                 EXAMPLE
This example demonstrates for one of the regulated pollutants (lead)
how production-based pretreatment standards from an acid pickling operation
(limited under 40 CFR Part 420 (Iron and Steel Point Source Category),
compliance date of July 10, 1985) are combined with concentration-based
pretreatment standards from a metal finishing (electroplating) operation
(limited under 40 CFR Part 433 compliance date of February 15, 1986) to
arrive at combined mass-based limit.  The calculations below are made
with the assumption that both compliance dates have passed.  (Note:
For calculations prior to the metal finishing compliance date, the electro-
plating wastestreatn would be considered unregulated and the flow value
(Fj) from the iron and steel operations would be necessary to use the
CWF.)
     Acid Pickling Production:
       Hydrochloric Acid Pickling-Strip Products
       Number of fume Scrubbers
     Electroplating Wastewater flow (plating
       bath and final rinses only)
                 —  2150 tons/day
                  -  3 units
                  -  403,200 gpd
             MSTAL FINISHING
            (ELECTROPLATING)
              403,200 gpd
 HYDROCHLORIC
 ACID PICKLING
OF STRIP PRODUCTS
  2150 tons/day
 3 fume scrubber
Categorical PSES
40 CFR 433 (mg/1)
     Monthly  Daily
      Ave.     Max.

Lead   0.45   0.69
       	Categorical PSES 40 CFR 420
          Subpart I, Section 420.95(b){2)
          and (b)(4)
                       30 Day     Daily
                       ave.       maximum
       PICKLING  LEAD  0.0001750.000526
       (1/1000 I
      I Product)
                                              Fume      LEAD  0.0123
                                              Scrubber
                                            (kg/day ea.)
                                 0.0368
                                      _Applicable
                                       Pretreatment
                                       Standards
                               Lead

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Example Calculations

For the Lead Calculation;

Iron and Steel Lead Daily Maxinun Limit « Limits for (Pickling) +3(Fume Scubber)

               » Categorical Standard for Pickling x Production Rate
                 for Pickling +3 x (Categorical Standard for each fine
                 scrubber)

               - 1(0.000526 f/1000 I product) x (2150 tons/day x 2000 #/ton x
                 1 1/1000 I product)] + 3 (0.0368 kg/day ea. x 2.2 IbsAg)


  Lead (Iron and Steel) - 2.2618 + 0.2429 - 2.50 t/day Daily Max.

Metals Finishing Lead Daily Maximum Limit « Categorical Standard x flow

               « 0.69 rag/1 x (403,200 gpd x 8.34/106 Conversion Factor)

  Lead (Metal Finishing) - 2.32 t/day Daily Max.

Since there is no dilution flow the applicable pretreatntent lead daily
maximm limit for the facility is:

Lead Daily Maximum - 2.50 I/day +2.32 I/day
                   -4.82 I/day

The 30-day limitation, calculated in a similar manner, is 2.28 I/day.
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using the CWF, remember that when two or more regulated wastestreams are
mixed prior to treatment, it is necessary to determine which pretreatment
regulation applies to each regulated wastestream before they are mixed.
For additional information on categorical pretreabnent standards and the
combined wastestream formula, refer to the manual entitled "Guidance
Manual for the Use of Production-based Pretreatment Standards and the
Combined Wastestrean Formula"  (September 1985).  For calculation of the
total toxic organics (TTO) limit, refer to the manual entitled, "Guidance
Manual for Implementing Total Toxic Organics (TTO) Pretreatment Standards
(September 1985).

4.5  REMOVAL CREDITS

     A removal credit allows a POTW to provide its categorical industrial
users with a credit (in the form of adjusted categorical pretreatment
standards) for removal of pollutants by the POTW.  Industrial users
receiving such a credit are allowed to discharge to the POTW greater
quantities of regulated pollutants than otherwise permitted by applicable
categorical standards.  Hiether or not to seek authority to grant removal
credits is at the discretion of the POTW.  Section 403.7 of the General
Pretreatment Regulations establishes the conditions under which a POTW
can obtain approval to grant removal credits and specifies the means by
which these removal credits are to be determined.

     In 1977, Congress amended section 307(b) of the Clean Water Act to
provide for removal credits.  EPA originally implemented that provision
and established the conditions under which POTWs could obtain authorization
to grant removal credits in the June 26, 1978, General Pretreatment
Regulations.  On January 28, 1981, the removal credits provision was
agained amended.  On August 3, 1984 (49 Fed. Reg. 31212) the removal
credits provision was again amended.  Under the current provision, any
POTW seeking removal credit authority is required to demonstrate its
removal performance by sampling its influent and effluent and calculating
its removal rates based on these data.  Removal capability of each POTW,
therefore, is to be determined on a case-by-case basis.  In addition to
the sampling requirements, the provision specified the other prerequisites
for obtaining removal credit authority.  Only the Approval Authority
(either EPA or the State) can grant removal credit authority to a POTW.
For more information on removal credits, refer to the manual entitled
"Guidance Manual for Preparation and Review of Removal Credit Applications"
(September 1985).

     As part of the amendments to the iron and steel categorical standards
(40 CFR 420.06) EPA acknowledged that biological treatment systems employed
at PCTW's will, in large measure, remove those pollutants for which
phenols (4A^P) is used as an indicator pollutant to the same degree as
they remove phenols (4AAP).  Thus, removal allowances pursuant to 40 CFR
403.7(a)(l) may be granted for phenols (4AAP) limited in the iron and
steel industry whether or not it is used as an indicator or surrogate
pollutant.
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4.6  FuNuAMSwTALLz DIFFEI^NT FACTOiS VARIANCE

     A request for a fundamentally different factors  (FDF) variance  is a
mechanism by which a categorical pretreatment standard may be adjusted on
a case-by-case basis.  If an indirect discharger, a FOro, or any interested
person believes that the factors relating to a specific indirect discharger
are fundamentally different front those factors considered during development
of the relevant categorical pretreatxnent standard and that the existence
of those factors justifies a different discharge limit from that specified
in the Categorical Standard, then they may submit a request to EPA for
such a variance (See 40 CFR 403.13).

4.7  LOCAL LIMITS

     Local limits are numerical pollutant concentration or mass-based
values that are developed by a POTW for controlling the discharge of
conventional, non-conventional, or toxic pollutants from indirect sources.
They differ from national categorical pretreatment standards in that
categorical pretreatment standards are developed by EPA and are based on
the demonstrated performance of available pollutant control technologies
for specific categorical industries.  These technology-based categorical
standards do not consider local environmental criteria or conditions, but
are developed to assure that each industry within a specified category
meets a minimum discharge standard that is consistent for all POTWs across
the United States.  Local limits, on the other hand, are developed to
address specific localized impacts on POTWs and their receiving waters.
Local limits are typically designed to protect the POTW from:

     <3  Introduction of pollutants into the POTW that could interfere
        with the operation

     o  Pass-through of inadequately treated pollutants that could violate
        a POTW's NPDES permit or applicable water quality standards

     o  Contamination of a POTW's sludge, which would limit sludge uses
        or disposal practices.

     Local limits, as the name implies, take into consideration the
factors that are unique to a POTW, whereas categorical pretreatment
standards are developed only for a general class of industrial dischargers.
Local limits are required under 40 CFR 403.5.  For more information on the
minimum local limit requirements for POTWs with approved pretreatment
programs and the relationship between local limits and categorical standards,
refer to the memorandum signed by Rebecca Hanmer on August 5, 1985 entitled
"Local Limit Requirements for POTW Pretreatment Programs".

     To assist municipalities in developing defensible and technically
sound numerical effluent limits, EPA has prepared general guidelines on
limit development in its document "Guidance Manual for POTW Pretreatment
Program Development."  Appendix L of the manual lists the general
methodology, required formulas, and typical environmental criteria used
to develop local limits.  The manual is available from EPA Regional
offices and delegated States and should be carefully followed when


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developing local limits.  A more detailed guidance manual for local limit
development is currently under development.  The general methodology
includes the following four steps:

     Step 1 - Determine the maximum headwords loading (for each specific
              pollutant) that will assure that the objectives of the
              pretreatment program are met.

     Step 2 - Calculate the allowable loading to the POTW by subtracting
              the uncontrollable portion of pollutant discharge to the
              PCTW (from domestic, commercial, and infiltration/inflow
              sources) from the total headwords loading value.

     Step 3 - Distribute the controllable loading to industrial users
              through an allocation process.

     Step 4 - Derive specific local limits from the allocation results.

     This four-step process must be followed for each pollutant that the
POTW determines may need a specific local limit.  As a general rule, the
limit setting analysis should be performed for all pollutants that: are
discharged to the POTW in significant quantities.  The POTW can identify
pollutants of concern through its industrial waste survey.  A procedure
for evaluating industrial waste survey results is included in the EPA
guidance manual mentioned above.

     To assist POTWs with the development of local limits, EPA has also
developed a computer program that incorporates the general methodology
required to develop local limits and performs a substantial number of the
calculations required to develop these limits.  This computer program has
the following capabilities.

     o  Performs the four-step limit setting analysis on microcomputer or
        mainframe

     o  Screens input data provided by the POTW

     o  Supplements POTW data with built-in files containing data on
        industrial and municipal wastewater characteristics, POTW removal
        rates and POTW inhibition values

     o  Allocates controllable pollutant loads using several different
        methodologies

     o  Compares calculated local limits to EPA categorical standards.


POTWs may obtain information on this computer program by contacting the
EPA Regional office.  Instructions are available on how to obtain and
use the computer program as well as how to gain access to a computer
system that supports it.
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                                fiEFE FENCES
IRON AND STEEL

Final Regulations Promulgated
Amended (Effective Date)
Amended (Coding and minor errors)
Amended (Final and interim regulation)
Correction Notice
Correction Notice
Amended (Final)

G5N£RAL PFETBEATMENT PECULATIONS

40 CFR 403
40 CFR 403
40 CFR 403

FE PORTS AND MANUALS
Final Development Document -
  Iron and Steel Vol. I-VI May 1982 440/1-82/024
Guidance Manual for POTW
  Pretreatroent Program Development

Procedures Manual for Reviewing
  a POIW Pretreatment Program
  Submission

Guidance Manual for Electroplating
  and Metal Finishing Pretreatment Standards

Guidance Manual for Preparation of Removal
  Credits Applications

Guidance Manual for Implementing Total Toxic
  Organics (TTO) Pretreatment Standards
Guidance Manual for the Use of Production-based
  Pretreatment Standards and the Combined Wastestream
  Formula
FEDERAL REGISTER NOTICE.'

05/27/82  47FR  23258
06/07/82  47FR  24554
09/22/82  47FR  41738
10/14/83  48FR  46942
11/10/83  48FR  51647
11/14/83  48FR  51773
04/17/84  49FR  21024
01/28/81  46FR  9404
04/17/84  49FR  21037 (Amnended)
08/03/84  49FR  31212

       NTIS or GPO
          Number

       PB82-240425
       PB82-240433
       PB82-240458
       PB82-240466
       PB82-240474
           October 1983

           October 1983



           February 1984


           September 1985


           September 1985


           September 1985
                                   R-l

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Miscellaneous

RCPA Information for Publicly Owned Treatment Works       September 1985

Local Limits Requirements for POTW Pretreatment  Programs,  memorandum
signed by Rebecca Hanmer on August 5,  1985.

Copies of the technical and economic documents may be  obtained from the
National Technical Information Services, Springfield,  VA.  22161 (703/487-
4650).  Pretreatment Program Manuals may be obtained from  U.S. EPA,
Permits Division (EN-336), Washington, DC  20460.
                                         OOVMNMINT PMNTINO OWCt: 1»85
                                                                      217 31,935
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