CWA COMPLIANCE EVALUATION INSPECTION REPORT
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 5

Purpose:

Compliance Evaluation Reconnaissance Inspection
Facility:

Cleveland Cliffs Burns Harbor, LLC
250 US-12

Burns Harbor, Indiana 46304
Porter County
41.625, -87.117

NPDES Permit Number:

IN0000175

Date of Inspection:

December 12, 2022

EPA Representatives:

Joan Rogers, Environmental Scientist	312-886-2785

Rogers .j oan@epa.gov

State Representatives:

Nicholas Ream, Indiana Department of Environmental Management	219-730-1691

Wastewater Inspector
nream@idem .IN. gov

Ramelito Biscocho, Indiana Department of Environmental Management	219-464-0233

Wastewater Inspector

rbiscoch@idem.in.gov

Facility Representatives:

Tom Maicher, Manager of the Environmental Plant	219-787-4961

Robert.maciel@ClevelandCliffs.com

Morgan Swanson, Environmental Engineer	219-787-2646

Morgan.swanson@ClevelandCliffs.com

Patrick Gorman, Operator
Patrick.gorman@ClevelandCliffs.com

Vinod Barot, Senior Environmental Engineer	219-787-2964

Vinod.barot@ClevelandCliffs.com

Report Prepared by:

ROGERS

Joan Rogers

IO A M	Digitally signed by JOAN

JVJMI\I	ROGERS

Date: 2023.02.15

Inspector Signature/Date: rAWVJI~rAO	15:46:34 -ogoo1

Approver Name and Title: Ryan Bahr. Supervisor. Section 2. WECAB	

Digitally signed by Ryan

Approver Signature/Date: Ryan Bahr 	

16:42:00 -06'00'

3	Cleveland-Cliffs Burns Harbor

December 12, 2022


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1. BACKGROUND

The purpose of this report is to describe and document the reconnaissance inspection at the Cleveland
Cliffs Burns Harbor facility on December 12, 2022. This inspection was performed pursuant to Section
308(a) of the Federal Water Pollution Control Act, as amended. This was a joint inspection by EPA and
the Indiana Department of Environmental Management (IDEM).

The Cleveland Cliffs Burns Harbor (CCBH) facility is one of the largest fully integrated steel mills in
North America, with the capacity to produce approximately 5 million tons of raw steel per year. They
operate under NPDES Permit No. IN0000175, which was issued on January 1, 2022, and expires on
December 31, 2026.

The inspection on December 12, 2022 was a Compliance Evaluation Reconnaissance Inspection to
discuss the operations in the Reclamation Services Building (RSB) and observe the outfalls.

2. SITE INSPECTION

Site Entry and Opening Conference

Arrival Time:

9:00 A.M.

Presented credentials?

Yes.

Credentials presented to whom and at what time?

9:14 A.M. to Tom Maicher, Morgan
Swanson, Pat Gorman, and Vinod Barot.

Was an opening conference held? With whom?

Yes. Mr. Maicher, Ms. Swanson, Mr.
Gorman, and Mr. Barot.

If photographs or documents were taken, does the facility consider any to be
Confidential Business Information (CBI)?

No.

Which information does the facility consider to be CBI?

None.

EPA vehicle parked in approved location?

Yes.

Location where EPA vehicle was parked?

Enviromnental Services Building.

EPA inspector, Ms. Joan Rogers, and IDEM inspectors Mr. Nick Ream, and Mr. Ramelito Biscocho,
followed Ms. Swanson to the Environmental Services Building conference room from the main office
after EPA and IDEM inspectors received their visitor badges. During the opening conference at 9:15
A.M., the inspection team explained that the focus of the inspection was to discuss the operations in the
Reclamation Services Building (RSB) and observe the outfalls.

The discussion started with a question about the fingerprinting analysis that facility personnel were doing
on the foam at Outfall 002 that was observed in a previous inspection and was misclassified in documents
from Microbac. Facility personnel stated that there was no analysis back yet. Microbac sent the foam
sample to another laboratory for fingerprinting and DNA analysis. They will inform the agencies when
the results arrive.

On December 9, 2022, IDEM was notified by a ship captain that he noticed a sheen on the west side of
his ship as he was parked along the CCBH dock. IDEM emergency responders went to the site. CCBH
personnel also went to the dock, but they stated that they did not see any sheen.

Reclamation Services Building (RSB)

Inside the RSB, three processes to reclaim and separate solids from water are performed. CCBH calls
these three processes "phases". Here is a short description of each phase.

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•	In Phase I, the underflow from the Basic Oxygen Furnace (BOF) Thickeners flows to the Hi-Cap
Thickener. The underflow from the Hi-Cap Thickener is squeezed and becomes the BOF sludge,
which then flows to plate and frame filter presses. The overflow from the Hi-Cap Thickener flows
into Outfall 111 and then to the Dirty Industrial Waste (DIW) which flows to the Secondary
Wastewater Treatment Plant (SWTP).

After the BOF sludge is pressed by the plate and frame filter presses, the solids go to the landfill
while the liquids go to the Final Thickener.

•	In Phase II, the blowdown from the Sinter Plant (aka the Recycle Plant), is first treated to
neutralize the pH in a neutralization tank. After floe is added to the flow, it is sent to the Final
Thickener. The underflow from the Final Thickener is conditioned and then sent to the plate and
frame filter presses. The overflow from the Final Thickener goes to Outfall 111 and then to the
Dirty Industrial Waste (DIW) which flows to the Secondary Wastewater Treatment Plant
(SWTP).

After the Final Thickener underflow is pressed by the plate and frame filter presses, the solids go
to the landfill while the liquids go back to the Final Thickener.

The Sinter Plant blowdown contains TCDF. Solids are added to the Final Thickener to remove
the TCDF and samples are taken at Outfall 111 to confirm removal.

•	In Phase III, the underflow from each Blast Furnace Thickeners goes to hydrocyclones which
spin off the solids. There are four hydrocyclones for each blast furnace for a total of eight
hydrocyclones in the RSB. The overflow from the hydrocyclones merges with the Sinter Plant
Blowdown in the neutralization tank (Phase II). It then follows the same flow as the Sinter Plant
blowdown. The underflow from the hydrocyclones goes to vacuum presses.

After the hydrocyclone underflow is pressed by the vacuum presses, the solids are sent to the
Sinter Plant for recycling while the liquids go to the Final Thickener. Note, the liquids do not go
to the Final Thickener during the times of the year when the ammonia limits in the Permit are
low, because this flow can add 160-170 pounds of ammonia per day.

EPA observed the Reclamation Service Building Operator - End of Turn Report for Turn 1 on 12/12/22.
It included influent and effluent grab sample pH results at the Final Thickener. It also listed the turbidity
results because turbidity is used to give immediate feedback for TCDF removal because the samples take
a month to get results from the lab.

The Final Thickener will be taken down approximately one time per year for maintenance. The Final
Thickener will be down for a few days at that time.

EPA and IDEM requested End of Turn reports for every Monday from October 1, 2022 through
December 12, 2022 for all three shifts. Ms. Swanson sent those reports on December 13, 2022. EPA
reviewed the reports and noted that on many of the reports, the question of whether the RSB I&II
Operators filled out the new RSB Phase II Operators Turn Checklist was completed was left blank.

Facility Walkthrough

See Attachment A for the photolog of the photos taken during the facility walkthrough.

EPA and IDEM concluded the interview portion of the inspection and stated that they would like to

observe the processes at the RSB and Outfall 002, Outfall 003, Outfall 011, and Outfall 001.

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Final Thickener

The inspection team followed the CCBH personnel to the Final Thickener which is outside the RSB. The
team arrived at the Final Thickener at 10:25 A.M. Mr. Gorman explained that ferric chloride is not being
added to the Final Thickener since they are not operating the ammonia plant. When the ammonia plant is
being operated, solids are reduced and need to be reintroduced at the Final Thickener to remove TCDF.

EPA observed the manhole where the flow from the Hi-Cap Thickener overflow and Final Thickener
overflow merge. EPA also observed the auto-sampler for TCDF samples on the walkway over the Final
Thickener.

Reclamation Services Building

Inside the RSB, EPA observed the cake from the vacuum presses that separate the solids from the liquids
from the hydrocyclone underflows. The solids are returned to the Sinter Plant (aka Recycle Plant) and the
liquids are sent to the Neutralization Tank. EPA observed four of the eight hydrocyclones that receive the
underflow from the Blast Furnace Thickeners. The overflow from the Blast Furnace Thickeners goes to
the Blast Furnace Pump Station and is recycled.

EPA also observed the vacuum pumps for the vacuum presses and the plate and frame filter presses. The
last thing the inspection team observed in the RSB was Sampling Point 2 and the pH meter.

Outfall 003

EPA, IDEM and CCBH personnel then drove to Outfall 003 and arrived at 11:25 A.M. EPA observed that
the water in Outfall 003 was clear.

Outfall 002

The inspectors followed the facility personnel to Outfall 002 and arrived at 11:42 A.M. Prior to the July
inspection, Mr. Barot designed and installed a spray bar at the head of the outfall structure. The spray
consisted of recirculated lake water and was intended to knock down the foam in the outfall. Since then,
Mr. Barot designed and installed a second spray bar closer to the end of the outfall structure. This spray
bar is intended to knock down any foam that escapes the first spray bar. Both spray bars run continuously
and Mr. Barot checks on the spray bars daily.

There was no foam inside or outside the booms at Outfall 002 on the day of the inspection.

EPA and IDEM observed and documented material on the water near the shoreline outside of Outfall 002.
It was very faint and did not have the rainbow coloring like an oil sheen.

Outfall 011

The inspection team followed the facility personnel to Outfall 011 and arrived at 12:17 P.M. In previous
inspections, EPA and IDEM noted vegetation growing on the weirs of the lagoons. The vegetation was
still present. In the sample building for Outfall 011, there was a warning on the ISCO sampler to change
the pump tubing. According to the tag on the sample tubing, it was last changed on November 1, 2022,
but the pump tubing was changed on November 28, 2022. The sampler was otherwise working properly
and maintaining the proper temperature inside.

EPA and IDEM then noted that there was a sheen on the water at Outfall 011. This sheen had the
appearance of an oil sheen. The sheen was continuous on the water flowing past Outfall 011. EPA
documented the sheen with photographs.

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EPA and IDEM then observed the overflows from the lagoons at 12:27 P.M. and observed that the sheen
was present at that location, also. The overflow from the lagoons is upstream of Outfall Oil.

Outfall 001

EPA and IDEM followed facility personnel to Outfall 001 and arrived there at 12:40 P.M. The auto-
sampler in the sample building appeared to be functioning properly. The flow at Outfall 001 was 87,200
GPM at that time.

The inspection team could not observe a sheen on the fast flowing and turbulent water at Outfall 001.
Closing Conference

EPA and IDEM provided a closing conference to the facility personnel at Outfall 001. The areas of
concern observed during the inspection were the sheen observed at the overflow from the lagoons and at
Outfall 011 and the vegetation on the weirs from the lagoons.

EPA exited the facility at 1:05 P.M.

3.	DOCUMENTS RECEIVED FROM FACILITY

•	Reclamation Services Building Phase II process diagram.

•	RSB process diagram via email on December 13, 2022.

•	Reclamation Service Building Operator - End of Turn Reports for each Monday from October 1,
2022, through December 12, 2022, via email on December 13, 2022.

4.	AREAS OF CONCERN

A.	The sheen observed at the overflow from the lagoons and at Outfall 011 which is upstream of the
external Outfall 001. There is no treatment after Outfall 011 which would prevent the sheen from
exiting at Outfall 001.

B.	The vegetation on the weirs from the lagoons is still present.

5.	LIST OF ATTACHMENTS

A) Photolog

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December 12, 2022


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ATTACHMENT A
Cleveland-Cliffs Burns Harbor
EPA Inspection December 12, 2022
All photos taken by Joan Rogers, Environmental Scientist/Inspector, U.S. EPA

Camera: Samsung Galaxy S8

1:20221212 103205

Description: Looking down into the manhole where the Hi-Cap Thickener overflow and Final Thickener

overflow merge.

Location: Outfall 111.

Camera Direction: Down.

Date/Time: December 12, 2022/10:35 A.M.

Page 1

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December 12, 2022


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2: 20221212 103316

Description: The TCDF sampling is taken from the Final Thickener. Note the auto-sampler on the walkway

above the Final Thickener.

Location: Final Thickener.

Camera Direction: Southeast.

Date/Time: December 12, 2022/10:33 A.M.

3: 20221212_103622

Description: The Final Thickener is on the left and the Hi-Cap Thickener is on the right. Hi-Cap Thickener was

being cleaned on the day of the inspection and was not in use.

Location: Final Thickener.

Camera Direction: Southwest.

Date/Time: December 12, 2022/10:36 A.M.

Page 2

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December 12, 2022


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4: 20221212_104852

Description: The cake from the vacuum press from the hydrocyclone underflows. The cake goes to the Sinter
Plant for recycling.

Location: Reclamation Services Building (RSB).

Date/Time: December 12, 2022/10:48 A.M.

5: 20221212_105005

Description: The underflow for each Blast Furnace Thickener goes to a tank and is then pumped to the

hydrocyclones.

Location: RSB.

Camera Direction: Down.

Date/Time: December 12, 2022/10:50 A.M.

Page 3

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6: 20221212 105216

Description: The four (of eight total) hydrocyclones spin off the solids from the Blast Furnace Thickener

underflows.

Location: RSB.

Date/Time: December 12, 2022/10:52 A.M.

7: 20221212_105356

Description: The four (of eight total) hydrocyclones spin off the solids from the Blast Furnace Thickener

underflows.

Location: RSB.

Date/Time: December 12, 2022/10:53 A.M.

Page 4

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December 12, 2022


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8:20221212 105845

Description: Two vacuum pumps for the two vacuum presses that press the liquid from the hydrocyclone

underflow.

Location: RSB.

Date/Time: December 12, 2022/10:58 A.M.

9: 20221212110328

Description: Plate and frame filter presses are used to remove liquid from the basic oxygen furnace sludge and
the Final Thickener underflow. Two plate and frame filter presses are run at a time.

Location: RSB.

Date/Time: December 12, 2022/11:03 A.M.

Page 5

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December 12, 2022


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10:20221212 111355

Description: The pFI meter and sampling point 2 (SP2).
Location: RSB.

Date/Time: December 12, 2022/11:13 A.M.

11: 20221212_112249

Description: Brown air fumes observed on way to Outfall 003.
Location: Northern portion of the facility.

Camera Direction: Northeast.

Date/Time: December 12, 2022/11:22 A.M.

Page 6

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December 12, 2022


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St*5

12: 20221212_112920

Description: There was no sheen observed at Outfall 003 on the day of the inspection.

Location: Outfall 003.

Camera Direction: Northwest.

Date/Time: December 12, 2022/11:29 A.M.

13: 20221212 114649

Description: Spray nozzles are intended to knock down any foam from Outfall 002 before it can leave the

outfall structure.

Location: Outfall 002.

Camera Direction: East.

Date/Time: December 12, 2022/11:46 A.M.

Page 7

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14: 20221212 114811

Description: The external boom at Outfall 002. EPA did not observe any foam on the day of the inspection.

Location: Outfall 002.

Camera Direction: Southwest and down.

Date/Time: December 12, 2022/11:48 A.M.

15:20221212 115054

Description: EPA observed material on the water near Outfall 002.
Location: South of Outfall 002.

Camera Direction: Southwest and down.

Date/Time: December 12, 2022/11:50 A.M.

Page 8

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16: 20221212 115318

Description: EPA observed material on the water near Outfall 002.
Location: South of Outfall 002.

Camera Direction: West and down.

Date/Time: December 12, 2022/11:53 A.M.

17: 20221212 122338

Description: Looking upstream at the water from Outfall 011.

Location: Outfall 011.

Camera Direction: West.

Date/Time: December 12, 2022/12:23 P.M.

Page 9

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18: 20221212_122346

Description: Looking downstream at the water from Outfall Oil.

Location: Outfall Oil.

Camera Direction: East.

Date/Time: December 12, 2022/12:23 P.M.

19: 20221212 122830

Description: The sheen was observed at the overflow wiers from the lagoons before Outfall Oil.
Location: East side of the lagoons.

Camera Direction: Southwest.

Date/Time: December 12, 2022/12:28 P.M.

Page 10

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20:20221212 125511

Description: Looking upstream, it was difficult to observe the sheen due to the velocity of the water at Outfall
001.

Location: Outfall 001.

Camera Direction: Northwest.

Date/Time: December 12, 2022/12:55 P.M.

21: 20221212_125557

Description: Looking downstream from Outfall 001, EPA could not di scern a sheen due to the velocity of the
water.

Location: Outfall 001.

Camera Direction: South.

Date/Time: December 12, 2022/12:55 P.M.

Page 11

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590

REPLY TO ATTENTION OF
ECW-15J

VTA EM ATI.

Mr. Tom Maicher
Environmental Manager
Cleveland Cliffs Burns Harbor
250 West U.S. Highway 12
Burns Harbor, IN 46304

Subject: December 12, 2022 Reconnaissance Inspection Report for Cleveland-Cliffs Burns
Harbor, NPDES Permit Number IN0000175

Dear Mr. Maicher:

Enclosed, please find a copy of the U.S. Environmental Protection Agency Inspection Report
that describes and documents the activities at Cleveland-Cliffs Burns Harbor, LLC on
December 12, 2022.

The purpose of the reconnaissance inspection at Cleveland-Cliffs Burns Harbor, LLC was to
discuss and observe the ammonia treatment system, among other topics.

If you have any questions or concerns regarding this letter, or the inspection report, please
contact Joan Rogers at (312) 886-2785 or at rogers.joan@epa.gov.

Sincerely,

Ryan Bahr

Digitally signed by Ryan
Bahr

Date: 2023.02.15
16:42:20 -06'00'

Ryan J. Bahr, Section 2 Supervisor

Water Enforcement and Compliance Assurance Branch

Enclosure


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cc: Nicholas Ream, Environmental Engineer

Indiana Department of Environmental Management

Jason House, Branch Chief of Wastewater
Compliance Indiana Department of
Environmental Management

Ramelito Biscocho, Wastewater Inspector
Indiana Department of Environmental Management

Morgan Swanson, Environmental Engineer
Cleveland-Cliffs Burns Harbor

Vinod Barot, Senior Environmental Engineer
Cleveland-Cliffs Burns Harbor

2

Cleveland-Cliffs Burns Harbor
December 12, 2022


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