5523 -•• 810R82101
IRON AND STEEL INDUSTRY REGULATION
RESPONSE TO PUBLIC COMMENTS
MAY 1982
EFFLUENT GUIDELINES DIVISION
OFFICE OF WATER REGULATIONS AND STANDARDS
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
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PREFACE
This document contains the Agency's response to comments received on
the proposed regulation for the Iron and Steel Industry (46 FR 1858).
The preamble to the final regulation also contains responses to
certain comments received on the proposed regulation.
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TABLE OF CONTENTS
Subcategory Comments Page
A. Cokemaking 4
B. Sintering 24
C. Ironmaking 30
D. Steelmaking 42
E. Vacuum Degassing 53
F. Continuous Casting 55
G. Hot Forming 57
H. Salt Bath Descaling 64
I. Acid Pickling 66
J. Cold Forming 74
K. Alkaline Cleaning 82
L. Hot Coating 84
General Comments 86
List of Commenters 111
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A. .COKEMAKING
1. COMMENT
The industry commented that the proposed total suspended solids
limitation based upon 100 mg/1 is "more rational" than the 50 mg/1
used in prior regulations, but that it may still not account for all
of the variations that can occur with biological treatment systems.
RESPONSE
The Agency agrees with this comment. Based upon a review of total
suspended solids effluent data for coke plant biological treatment
systems, the bases for the BPT total suspended solids limitations have
been increased to 140 mg/1 (30 day average) and 270 mg/1 (daily
maximum). As explained in detail in the development document, the
Agency believes BPT limitations based upon these concentrations can be
achieved with properly designed and well operated coke plant
biological treatment systems.
2.
COMMENT
The industry commented that the Agency did not take into account
properly the stoichiometric relationship concerning biological
oxidation of thiocyanate to ammonia-N. Under proper conditions
thiocyanate can be biologically broken down into its component parts,
one of which is ammonia-N. The industry states this would result in
in a doubling of the ammonia-N concentration across biological
treatment systems from levels found in ammonia still effluents which
preceed biological treatment systems.
RESPONSE
The Agency established the BPT ammonia-N limitations in this
regulation at the same level as in limitations promulgated in 1974.
The BPT ammonia-N limitations are demonstrated at plants that have
adequate pretreatment prior to biological treatment; that is, free and
fixed ammonia stills; oil and scum removal; and, adequate hydraulic
and waste loading equalization. Compliance with these limitations is
also demonstrated at plants without biological treatment. Data for
coke plant biological treatment systems indicate that partial
nitrification (ammonia-N removal) occurs, even in single stage
systems. The conversion of thiocyanate to ammonia-N is largely
compensated for by biological synthesis and nitrification of ammonia-N
from this source and ammonia-N in the feed to the biological treatment
system. Operating practices may have to be modified at some
biological treatment plants to promote sufficient nitrification to
achieve the ammonia-N limitations. The Agency believes that with
proper pretreatment, as provided for in the BPT model treatment
system, and proper operation, the ammonia-N limitations can be
consistently achieved at all coke plants.
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3. COMMENT
The industry commented that the 95% confidence level should be used t<
establish the model treatment system flow for the cokemakim
subcategory; and the model ammonia liquor flow should be 50 gal/ton v;
32 gal/ton. The ammonia liquor is largely comprised of moistun
liberated from coal during the cokemaking process.
RESPONSE
In this and other steel industry subcategories, the Agency determinec
the BPT model treatment system flow rates from the average of the best
performing plants or the production weighted average of all plants.
The Agency did, however, use statistically derived treated effluent
concentrations of the limited pollutants to establish the limitations
and standards. The Agency has not used statistically derived flows tc
develop limitations and standards, because the industry can control
discharge flow to an extent necessary to achieve the respective mode]
flow rates (upon which the limitations and standards are based),
whereas there are normal variations in treatment plant performance
(i.e. concentration).
The 32 gallons/ton model ammonia liquor flow rate was determined
consistent with the above approach. This flow is based upon the
average of ammonia liquor flows from many plants which process
different coking coals of varying moisture contents. The Agency
believes this model flow rate is representative of industry-wide
ammonia liquor flow rates. Furthermore, the limitations basis.
Furthermore, the limitations and standards do not require attainment
of the model ammonia liquor flow rate or, for that matter, any of the
individual components of the total model plant flow rate. As noted in
the development document, plants with varying flow rates for ammonia
liquor, benzol plant wastewaters, final cooler wastewaters, barometric
condenser wastewaters, wastewaters from miscellaneous sources, and
dilution flows for biological treatment, achieve the total model plant
flow rates.
4. COMMENT
The industry commented that the model coke plant dilution water flow
for optimization of biological treatment systems should be 175
gallons/ton vs 50 gallons/ton, and higher on a site-specific basis.
The industry claimed a dilution flow of 175 gallons/ton or higher is
needed for proper operation of coke plant biological treatment
systems; and, that it is not possible to predict dilution flow
requirements until after a treatment facility is built.
RESPONSE
The Agency found no evidence that properly designed, well operated
coke plant biological treatment systems require one to one dilution
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(175 gallons/ton of dilution water) to function properly. As shown
below, many systems operate with dilution rates of less than 50
gallons/ton. The Agency recognizes that biological treatment systems
at several plants operate with high dilution flows. However, improved
pretreatment, better equalization of hydraulic and waste loadings, and
improved wastewater and treatment system temperature control, should
result in the use of less dilution water. Under these conditions some
plants have operated for long periods of time without dilution water.
Indeed, pilot studies conducted at the U.S. Steel Clairton Works
indicate that dilution water is not needed. Dilution flows of less
than 50 gallons/ton have been reported for the following seven coke
plant biological treatment systems. Except for the treatment system
at Plant 0534C (which is under construction) the flow data are for
full scale biological treatment facilities.
Plant Code Dilution Flow
0012A 20 gal/ton
0426 48
0464E 36
0584C 41 (Design Basis)
0584F-01 48
0584F-02 35
0868A 8-30
The Agency believes that treatment facilities at the above listed
plants are among the better designed and operated treatment facilities
in the industry, and, that these plants are representative of the
model coke plant production facility. Nitrification (ammonia-N
removal) is practiced at Plant 0868A and is included in the treatment
facility design at Plant 0584C. The Agency also believes that a
dilution flow of 50 gallons/ton is achievable for new coke plant
biological treatment systems.
5. COMMENT
The industry commented that additional flow allowances should be
provided for those coke plants with ancillary chemical recovery
systems (i.e., Benzene, Toluene, Xylene).
RESPONSE
The model coke plant production facility is based upon recovery of
ammonium sulfate and crude light oils with no further refinement of
the crude light oils into the products noted above. The level of
by-product recovery included in the model production facility is
common to most cokemaking operations. However, there are a few coke
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plants with extensive by-product recovery facilities. For such
plants, the additional flows which are necessarily associated with
these additional by-product recovery operations were not taken into
account in establishing the limitations and standards for cokemaking
operations. The Agency believes the number of these plants is small,
the number of additional by-product recovery operations at such plants
vary and therefore should not be included in the basis for the general
limitation and standards. To the extent necessary, such plants should
receive additional flow allowances in determining applicable BPT and
BAT effluent limitations at the permit level. These allowances should
be granted only to the extent necessary, and only after all
practicable flow minimization systems or operating practices are
implemented.
6. COMMENT
The industry commented that due to construction and low production,
the data for the U.S. Steel Fairfield Alabama coke plant are not
representative and should not be used as a basis for the BAT
limitations. The Agency interprets this comment to mean that the
commenter suggested that at less than capacity production, the
treatment facility would perform better due to lower pollutant
loadings and increased hydraulic retention time.
RESPONSE
Based upon this comment, the Agency sought supplemental data for this
plant. The Agency now has data from November 1977, when the
wastewater treatment facility was put into operation, to May 1981.
These data demonstrate that the plant's performance is not
significantly affected by production or wastewater volume applied to
the treatment facility. The plant demonstrates compliance with the
BAT effluent limitations, both during periods when wastewater flows
approached the design basis for the treatment facility, and during
periods when wastewater flows were reduced and retention time in the
treatment facility was increased. Thus, the Agency believes data from
this plant are appropriate for establishing effluent limitations and
standards.
7 COMMENT
The industry commented that the BAT effluent limitations should be
developed to take into account variability in the levels of pollutants
in treated effluents that has been found to occur when different
wastewater treatment facilities are designed, constructed, and
operated to the same specifications.
RESPONSE
The BAT limitations are based upon the performance of the U.S. Steel
Fairfield Alabama coke plant wastewater treatment system which, in the
Agency's opinion, is the best performing coke plant biological
treatment system. The Agency has carefully examined the production
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facility and by-product recovery facilities at this plant and found no
factors which would make it unique in the industry or atypical in any
way which would affect its selection as the model BAT treatment
facility. Long-term compliance with the BAT limitations has been
demonstrated at this plant. The Agency does not agree with the
industry that compliance cannot be achieved due to plant to plant
variability.
In the example cited by the industry of two similar coke plant
treatment systems performing differently (U.S. Steel's plants at
Fairfield, Alabama and Clairton, Pennsylvania), the Agency notes
certain significant differences in both the coke plant production
facilities and the wastewater treatment facilities at these locations.
The Clairton coke plant has extensive chemical by-product operations
beyond those included in the Agency's model cokemaking production
facility. These additional by-product recovery operations contribute
significantly to the wastewater volume treated at the plant. The
Fairfield plant does not have extensive chemical by-product recovery
operations and conforms to the Agency's model cokemaking production
facility. Extensive studies were conducted at the Clairton Plant by
U.S. Steel for the Agency. From these studies, the Agency notes that
the performance of the Clairton wastewater treatment facility is
hampered by uneven distribution of pollutant loadings to the
biological aeration basins, sludge accumulation in the aeration
basins, and less than optimum process control. The Agency believes
that with minor modifications to the wastewater treatment facilities
and operating practices at the Clairton plant, improved effluent
quality consistent with the BAT limitations should result. Also,
since the Clairton plant has extensive by-product recovery operations,
additional discharge allowances may be appropriate as noted above.
8. COMMENT
The industry commented that the BAT total cyanide limitation based
upon 2.5 mg/1 is too stringent and may not be achievable on a
long-term basis. The industry suggested that the Agency re-evaluate
the total cyanide limitation and take into account what it
characterizes as non-treatment of complex cyanides by biological
treatment.
RESPONSE
The proposed total cyanide limitations based upon a 30-day average
effluent concentration of 2.5 mg/1 was derived from long-term, full
scale performance of the model BAT treatment system. All forms of
cyanide measured by the total cyanide test, including complexed
cyanides, are accounted for in the effluent limitation. In response
to this and other comments, additional performance data were obtained
from the above mentioned model BAT plant. As shown in the development
document, these data indicate a 30-day average total cyanide
limitation based upon 5.5 mg/1 is more appropriate and the final
limitation is based upon that value. The Agency believes the
promulgated BAT total cyanide limitations are consistently achievable
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with properly designed and well operated biological treatment
facilities.
The Agency considered limiting "free cyanide", or "cyanides amenable
to chlorination" for cokemaking and ironmaking operations in lieu of
total cyanide, but did not do so for the following reasons:
1. The Settlement Agreement and the Clean Water Act required
the Agency to regulate the discharge of cyanide and cyanide
compounds. Since the total cyanide test measures virtually
all forms of cyanide, limiting total cyanide meets this
requirement.
2. There are only limited data available for "free cyanide" and
"cyanides amenable to chlorination" for steel industry model
BAT treatment systems.
3. The Agency believes the reproducibility of the total cyanide
analytical method is superior to that for cyanides amenable
to chlorination.
4. The Agency believes that destruction of cyanide is
preferable to conversion of free or simple cyanides to fixed
cyanides with subsequent discharge. This could occur if
only cyanide amenable to chlorination was limited.
9. COMMENT
The industry commented that the proposed phenols (4AAP) limitation
based upon a 30-day average effluent concentration of 0.025 mg/1 is
too stringent. In making this comment the industry presented data
obtained by U.S. Steel analytical contractors at the U.S. Steel
Fairfield Works. .The U.S. Steel contractor data shows higher phenols
(4AAP) levels than do data obtained by U.S. Steel personnel. The
industry also commented that the limitation may not be achievable at
coke plants located in northern parts of the country in colder
climates.
RESPONSE
In response to this comment, the Agency reviewed the sampling and
analytical methods used by U.S. Steel and its contractors for
monitoring the coke plant biological treatment system at the Fairfield
Works. The phenols (4AAP) data reported by the contractors are
somewhat higher than those reported by U.S. Steel which are typically
in the range of 0.005 to 0.025 mg/1. Personnel at the U.S. Steel
Fairfield Works coke plant used the EPA promulgated analytical
methodology for low level determinations of phenols (4AAP) (i.e.,
chloroform extraction procedure, EPA Methods Manual p. 241; and,
Standard Methods - 14th Edition, p. 557); however, the samples were
sometimes held for up to twelve hours prior to preservation and
analysis. The samples obtained by U.S. Steel's contractors were
representative of the discharge and preserved properly, but were
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analysed by a "water phase" technique which is not sensitive at
concentrations below 0.200 mg/1. Thus, the U.S. Steel data may have a
low bias and the contractor data were obtained with analytical methods
designed to detect concentrations much higher than typically found at
the U.S. Steel Fairfield works. Thus, the U.S. Steel contractor data
are not suitable for use in establishing effluent limitations and
standards.
The Agency has a third set of phenols (4AAP) data for this facility
obtained by an EPA contractor. The discharge from the coke plant
biological treatment facility was sampled during both warm and cold
weather. These data were obtained with proper sampling, preservation,
and analytical techniques and verify that the phenol (4AAP)
concentrations are in the range determined by U.S. Steel plant
personnel as opposed to the U.S. Steel contractors. The EPA data
demonstrate the proposed 30-day average limitation based upon the
0.025 mg/1 concentration is achievable for warm weather and a 30-day
average limitation based upon a concentration of 0.043 mg/1 is
achievable for cold weather.
Based upon these data, the Agency based the final 30-day average BAT
limitation for phenols (4AAP) on a concentration of 0.050 mg/1 to take
into account cold weather performance. The Agency believes the
limitations are consistently achievable with properly designed and
operated biological treatment systems located in both northern and
southern parts of the country; and, that the limitations are well
demonstrated at the U.S. Steel Fairfield Works. As noted in the
response to comment A-19, the Agency made significant additions to the
model treatment facility to provide for proper chemical additions and
wastewater temperature control for cold weather operations such that
the BAT limitations can be achieved in all parts of the country.
10. COMMENT
The industry commented that advanced biological treatment for
cokemaking wastewaters should not be included as part of the model BAT
treatment technology and, as a result, the BAT ammonia-N limitation
should be increased from 15 mg/1 to 125 mg/1. The industry also
commented that ammonia-N should not be regulated at BAT, since it is
not a designated priority (toxic) pollutant and that National Steel's
pilot plant experience leads the industry to consider nitrification
(ammonia-N) removal as an experimental process.
RESPONSE
The Agency has considered whether or not to limit ammonia-N at BAT and
has decided to do so since cokemaking wastewaters contain substantial
amounts of ammonia-N. Ammonia-N is toxic to aquatic life irrespective
of its designation as a toxic pollutant. Ammonia-N has other adverse
environmental effects in addition to toxicity, and economically
achievable technologies are available and in use to treat ammonia-N.
For these reasons, the Agency has determined that it is appropriate to
limit ammonia-N at BAT.
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The Agency does not consider biological nitrification of cokemakini
wastewaters to be an experimental process. Advanced bi.ologica!
treatment of coke plant wastewaters, including nitrification, ii
currently achieved on a full scale basis at three coke plants rangin<
in capacity from about 2000 tons/day to over 20,000 tons/day. Anothei
advanced coke plant biological treatment system designed to achiev<
the BAT limitations is under construction (Plant 0584C), and anothei
is in design (Plants 0684 A and B). The industry has conductec
extensive research and development in the area of advanced coke plan!
biological treatment including second-stage treatment for ammonia-!
removal and modification of single-stage biological systems tc
accomplish the same end by increasing sludge age or by enhancement
through the addition of a substrate to .the system. The industry has
recently published reports on this research that clearly state the BAT
ammonia-N limitations are achievable. The Agency notes that the
design basis for ammonia-N in the effluent of the coke plant
biological treatment system at Plant 0584C is 10 mg/1. Plant 0584C is
a National Steel facility.
The BAT model treatment system includes extensive pretreatment
followed by two stage biological treatment. In many cases, the Agency
believes the industry will modify existing single stage biological
treatment systems to achieve the limitations; and, for those coke
plants without existing biological systems, install new single stage
systems specifically designed to achieve the BAT limitations.
Upon review of ammonia-N data for the U.S. Steel Fairfield Plant, the
Agency has found that ammonia-N effluent concentrations exhibit some
dependency considering monitoring results from consecutive days. The
Agency increased the ammonia-N concentration from 15 mg/1 to 25 mg/1
in establishing the BAT limitations to take this into account.
Ammonia-N removal to 25 mg/1 is well demonstrated at the U.S. Steel
Fairfield Plant. In addition, Armco Steel has demonstrated
nitrification at its Hamilton Plant. The Agency did not rely on data
from the Hamilton Plant to develop the limitations, because these data
were obtained with non-standard analytical methods.
11. COMMENT
The industry commented that phenols (4AAP) should be used as an
indicator pollutant for toxic organic pollutants and that benzene,
benzo(a)pyrene, and naphthalene should not be specifically limited.
The industry states that these pollutants can be removed in single
stage (BPT) biological treatment systems and need not be limited.
RESPONSE
Industry supplied no data to support their contention that phenols
(4AAP) can be used as an indicator for those toxic organic pollutants
limited at BAT. Data available to the Agency do not support the use
of phenols (4AAP) as an indicator for benzene, benzo(a)pyrene, and
naphthalene. These pollutants and phenols (4AAP) were selected as
indicators of the many volatile, base-neutral, and acid fraction toxic
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organic pollutants found in cokemaking wastewaters. Available data
generally show that when these pollutants are removed, other
pollutants in the respective classes are also removed. The data do
not demonstrate the same relationship with phenols (4AAP) and the
volatile and base-neutral pollutants.
While the Agency agrees that toxic organic pollutants can be removed
in properly operated single stage biological treatment systems,
biological treatment is not required to achieve the BPT limitations
(several plants use physical-chemical treatment without activated
carbon). The discharge of toxic organic pollutants from these
facilities can be quite high. Hence, the Agency believes it is
appropriate to limit these pollutants at the BAT level.
12. COMMENT
The industry recommended that the Agency provide effluent limitations
and standards based upon physical-chemical treatment as well as based
upon biological treatment for cokemaking wastewaters. The industry
cited the following reasons why limitations and standards based upon
physical/chemical treatment should be promulgated: (1) space
limitations at some older plants; (2) activated carbon adsorption is
an effective treatment for the removal of toxic organic pollutants;
<3) low levels of suspended solids and oil and grease can be achieved
with physical/chemical treatment; and (4) investment and operating
costs for biological and physical/chemical treatment systems are
similar. Another commenter opposed the setting of separate effluent
limitations for cokemaking operations with existing physical/chemical
treatment systems, and found the lack of cyanide limitations
unacceptable. The commenter stated that the Agency did not
demonstrate that separate limitations are necessary; failed to
document the economic impact that would be avoided; and failed to
explain the logic for not regulating cyanide.
RESPONSE
For the reasons set out in Section X of the cokemaking development
document, the Agency has provided separate, less stringent BAT
effluent limitations for cokemaking operations with existing full
scale physical-chemical treatment systems. The Agency does not
believe it is appropriate to establish alternative, less stringent
limitations and standards for other existing and new coke plant
sources because either the significant investments in
physical/chemical treatment facilities have not yet been made. The
Agency agrees that physical/chemical treatment systems, including
granular activated carbon adsorption, are effective for treatment of
toxic organic pollutants and conventional pollutants. However, new
physical/chemical systems can also be designed to control ammonia-N
and cyanide to levels comparable to those used to establish the BAT
limitations based upon biological treatment. The Agency has not
precluded the use of physical/chemical treatment. The industry may
use either method of treatment, provided that the appropriate
limitations or standards are achieved. The Agency does not believe
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that space limitations would preclude attainment of the , BA'
limitations at any plant.
The Agency believes it has taken a reasonable approach in establishin<
separate effluent limitations for the two existing full-seal*
physical/chemical treatment systems that include granular activatec
carbon. These systems are removing the toxic organic pollutants ii
the wastewaters to levels which are comparable to the levels achievec
by biological treatment systems. The capital costs for
physical/chemical and biological systems are similar. The Agencj
believes it would be unreasonable to require the operators of those
plants to replace the existing treatment systems with biological
treatment systems and incur a second capital expense to treat the sam«
wastewater. Physical/chemical treatment for cokemaking wastewaters
was considered as a BAT optional treatment technology in th«
development of the prior regulation.
The Agency did not include total cyanide limitations for the
physical/chemical facilities in the regulation, because it believes it
Is more appropriate to address those limitations at the permit level.
The development of these limitations will require highly complex,
site-specific evaluations of alternate treatment technologies, and for
that reason, the Agency has decided to defer that decision to the
permit stage. The absence of a cyanide limitation in this regulation
does not mean that cyanide discharges from these plants will be
unregulated. The Agency is providing technical assistance to the
States which have NPDES permitting authority for those facilities.
13. COMMENT
The industry commented that the BAT 30-day average ammonia-N
limitation should be 0.05742 lbs/1000 Ibs (or 134 mg/1 at 103 gallons
per ton) for physical/chemical coke plants; and, that the 30-day
average phenols (4AAP) limitation should be 0.000040 lbs/1000 Ibs (or
0.093 mg/1 at 103 gallons per ton). One company suggested that a
phenols (4AAP) limitation higher than that cited above would be
appropriate.
RESPONSE
The industry's suggested ammonia-N limitation is based upon the
performance of the ammonia stripping system at the Republic Steel
Cleveland District coke plant physical/chemical treatment system.
Long term data for the Cleveland plant demonstrate highly variable
control of ammonia nitrogen with large fluctuations not characteristic
of efficient ammonia stills. Republic Steel's original treatment
system design called for an average ammonia-N effluent concentration
of 50 mg/1. However, due to a series of design and operating
problems, including the inability to properly control pH, the design
value has never been consistently achieved. Since Republic Steel has
one of only two physical chemical treatment systems and the other has
advanced ammonia-N removal facilities, 60 mg/1 was used as the basis
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for , the , proposed 30-day average limitation. Republic Steel's design
criterion of 50 mg/1 was considered in proposing this limitation.
Well designed and operated free and fixed ammonia stills can achieve
ammonia-N concentrations less than 60 mg/1; however, this level is
restrictive for some plants. An advanced ammonia-N stripping system
operated by U.S. Steel and others consistently achieves concentrations
in the range of 25 to 30 mg/1. Also, Republic Steel developed an air
stripping system which is reported to be capable of achieving 50 mg/1.
Based upon data from well run conventional ammonia stills, the
concentration underlying the final 30-day average BAT effluent
limitation for physical-chemical coke plants was increased from 60
mg/1 to 75 mg/1 to allow for additional variability. This
concentration is also used as the basis for cokemaking PSES.
The Agency evaluated long-term data for the Republic Steel Cleveland
District Coke Plant treatment system which includes full scale
activated carbon adsorption systems. These data indicate a 30-day
average effluent concentration of 0.100 mg/1 is achievable and the
final limitation is based upon that concentration.
14. COMMENT
The industry commented that the proposed PSES and PSNS which are
equivalent to BAT are overly restrictive.
RESPONSE
The Agency agrees and has promulgated less stringent PSES and PSNS for
cokemaking operations which are based upon the same physical-chemical
pretreatment provided by the industry for its on-site coke plant
biological treatment systems. The reasons for establishing PSES and
PSNS at those levels is set out in the development document.
15. COMMENT
A commenter observed that flow equalization of indirect cokemaking
wastewaters, which is essential for proper POTW operation, was
apparently not considered.
RESPONSE
Flow equalization is part of the model treatment technology used to
establish the BPT and BAT effluent limitations and NSPS, PSES, and
PSNS. It was identified in the draft Development Document as the
settling basin, the treatment component immediately following the
ammonia stills. The Agency has corrected the labeling to clearly
designate the component as an equalization basin.
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16. COMMENT
The same commenter suggested that EPA consider ion-precipitate
flotation of iron cyanide complexes to treat the discharge of total
cyanide from cokemaking operations.
RESPONSE
The Agency did not consider this ion-precipitation flotation since it
is not demonstrated on cokemaking wastewaters and the Agency does not
have sufficient data to confidently project the performance,
reliability and cost of this system for treating cokemaking
wastewaters.
17 COMMENT
A commenter recommended that BAT Alternative 2, which includes the
addition of powdered activated carbon (PAC) to the two-stage
biological treatment system (BAT Alternative 1), be used as the BAT
model treatment technology. The commenter states available data
indicate that PAC will improve the removal of toxic organic
pollutants, as well as enhance biological nitrification.
RESPONSE
While the Agency agrees that PAC can enhance biological nitrification,
and would be particularly useful for upgrading single-stage biological
treatment systems, it does not believe the data cited demonstrate
improved toxic organic pollutant removal. The bench-scale study
(Bridle, T.R., et al, "Nitrogen and Contaminant Control of Coke Plant
Effluents in an Upgraded Biological System", EPA Symposium on Iron and
Steel Pollution Abatement Technology, Phildelphia, Nov., 1980) cited
by the commenter, indicates certain toxic organic pollutants may be
present at levels below the detection limit of the analytical method.
However, the data do not show that PAC added to those bench-scale
units would result in the removal of these organic pollutants. The
Agency believes the sludge in coke plant biological treatment systems
tends to adsorb and concentrate many of the toxic pollutants contained
in the wastewater feed; and, that much of the removal is accomplished
in that fashion.
The study (Ostanowski, R., et al, "Advanced Treatment of Coke Plant
Wastewater Using Physical/Chemical and Biological Techniques", Ibid.)
conducted at Wheeling-Pittsburgh Steel Corporation does show that
granular activated carbon (GAC) systems will remove toxic organic
pollutants from the effluent of biological treatment systems to levels
below the detection limits. However, PAC, added to biological systems
will not necessarily perform at the same level as GAC.
The data available at this time do not justify the application of PAC
as the BAT model treatment .technology. The selected model BAT
treatment technology will remove toxic organic pollutants to levels at
or near the respective detection limits, as shown by the performance
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of the model technology on a full-scale basis at the U.S. Steel
Fairfield Works.
18. COMMENT
In response to the Agency's solicitation of comments regarding the use
of single-stage biological treatment systems as the basis for
establishing the BAT limitations, a commenter stated that the BAT
limitations are not reliably achievable with single-stage systems and,
therefore, this system should not be used as the BAT model treatment
technology.
RESPONSE
The Agency did not select single-stage biological treatment as the
model BAT treatment technology. The Agency does, however, expect that
some dischargers will use single-stage systems to achieve the BAT
limitations and achieve compliance at less cost than projected by the
Agency.
19. COMMENT
The industry commented that the Agency did not adequately address
energy and chemical requirements of advanced biological treatment
systems for cokemaking wastewaters and that the limitations may not be
achievable in northern climates because of these inadequacies.
RESPONSE
In response to this comment, the Agency evaluated the model treatment
system used to develop the proposed limitations and made the following
modification to properly account for energy and chemical requirements.
ENERGY CONSIDERATIONS
1. Equalization tank insulation was added to conserve heat
during cold weather months.
2. Addition of steam through indirect heat exchangers was
included to optimize and maintain biological activity during
cold weather months.
3. A heat exchanger (non-evaporative cooling tower) was added
to waste heat during warm weather months.
CHEMICAL ADDITION
1. Chemical addition equipment was included for the purpose of
adding phosphoric acid, caustic and soda ash to optimize and
maintain biological activity.
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The investment and operating costs associated with these modification
to the model treatment system are set out in the Development Document
The Agency believes that with these modifications the BAT limitation:
for cokemaking operations can be achieved throughout the year at cok<
plants located in all parts of the country.
The Agency reviewed the costs submitted by the industry for energy
consumption necessary to heat coke plant biological treatment system-
during cold weather months and finds these costs to be overstated. Ii
its comments, the industry stressed the need for heat addition durinc
cold weather months, particularly in northern climates. However, th<
industry's cost estimate is based upon year round steam addition at
all coke plants regardless of location. The Agency has added only the
cost of additional energy required for cold weather months at al]
plants to its cost estimates.
20. COMMENT
One merchant coke producer stated that while coke plants have some
similarities, there are plant-to-plant differences that cause
significant variations in the wastewaters generated at each plant.
The commenter cites two coke plants with similar BPT treatment systems
that discharge total suspended solids at significantly different
levels. The commenter states that he and his consultants could not
determine which differences in the coke or chemical recovery processes
cause the different results. The commenter also noted that some coke
plants are part of large integrated steel plants with single central
treatment systems, thus masking the contribution of pollutants from
cokemaking operations; and, that receiving waters are affected
differently by cokemaking operations. In summary, the commenter
recommended that the effluent limitations and standards be issued as
guidelines with the flexibility to consider plant-to-plant variations
in treatment performance and receiving water characteristics in
establishing final effluent limitations.
RESPONSE
In developing the proposed and final effluent limitations and
standards for cokemaking operations, the Agency carefully considered
several factors pertaining to subcategorization. Among those are
wastewater characterisics and treatability. While there are
plant-to-plant variations in cokemaking raw wastewater concentrations,
the Agency found no basis to further subdivide cokemaking operations
based upon those factors. Based upon effluent data obtained from
several cokemaking wastewater treatment facilities, the Agency
believes that wastewaters from all cokemaking operations can be
treated to the final limitations and standards with the model
treatment system.
With respect to the commenters experiences with two cokemaking
wastewater treatment facilities producing different effluent levels of
suspended solids, the commenter did not provide sufficient information
on the cokemaking by-product recovery processes and the design and
Of»f^f •£ ff
UtJ&JC. i
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operation of the wastewater treatment facilities for the Agency to
draw any conclusions. However, owing to the nature of biological
treatment facilities, the Agency believes that the design and
operation of the wastewater treatment facilities, rather than
production processes, influence effluent suspended solids
concentrations. As noted earlier, the Agency has increased the
suspended solids BPT model treatment system concentration to 140 mg/1
for both merchant cokemaking operations and those associated with iron
and steel production facilities. The Agency believes the BPT
suspended solids limitations can be achieved at cokemaking operations
with properly designed and operated wastewater treatment facilities.
Although the commenter suggests that pollutants from cokemaking
operations can be diluted at large integrated steel plants with
central treatment systems, the Agency used data from full scale
wastewater treatment facilities serving only cokemaking operations to
establish the limitations and standards. Thus, the data relied upon
by the Agency were not affected by dilution by wastewater or cooling
waters from other operations.
The Agency believes it is appropriate to establish nationwide effluent
limitations and standards of performance for point sources that are
applicable regardless of receiving water and, that its decision to do
so is consistent with the requirements of the Clean Water Act.
Consequently, the Agency did not establish these limitations and
standards on the basis suggested by the commenter
21. COMMENT
One commenter suggested that the Agency's proposed prohibition of
combined or co-treatment of cokemaking wastewaters with wastewaters
from other operations is unreasonable. The commenter stated that this
proposed prohibition could potentially double the aggregate total cost
of treatment of cokemaking and ironmaking wastewaters at the
commentor's plant. Finally, the commenter characterized the Agency's
concern about the potential for dilution rather than treatment of
pollutants found in cokemaking wastewaters as overstated and
ill-founded.
RESPONSE
First, the Agency did not propose to, and has not, prohibited
expressly the combined treatment of wastewaters from cokemaking
operations with those from ironmaking operations. In the preamble to
the proposed regulation and in the preamble to this regulation, the
Agency has set out its policy for addressing central treatment
problems in the steel industry. Based upon several examples of
inadequate treatment of cokemaking wastewaters in central treatment
systems (Plants 06841, 0856F, 0864A), the Agency believes it is not
appropriate to treat wastewaters from cokemaking operations with
wastewaters from most other steel plant operations and has so stated
in those preambles. The dilution of cokemaking wastewater by other
wastewaters in these systems makes it impossible to achieve the same
OOOGI8
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level of effluent reduction that can be achieved with separate
treatment of cokemaking wastewaters. Under the final regulation;
dischargers can co-treat cokemaking wastewaters with compatible
wastewaters from other operations provided the sum of the applicable
limitations and standards are achieved. However, from a practical
standpoint, the Agency does not believe this can be done to any great
extent because of the nature of cokemaking wastewaters and the
applicable limitations and standards. The Agency believes that, under
certain conditions, it may be appropriate to co-treat cokemaking and
ironmaking wastewaters from existing and new sources. For example,
the blowdown from BPT recycle systems on blast furnaces may be
co-treated in coke plant biological treatment systems.
Information provided by the commenter indicated that the commenter's
existing treatment system for ironmaking wastewaters cannot accomodate
cokemaking wastewaters. The Agency notes that most of the model BPT
and BAT treatment technolgies are installed for ironmaking operations
at this plant and that some cokemaking wastewaters are pretreated and
discharged to a POTW and others are disposed of by means of deep well
injection.
22. COMMENT
One commenter stated that the "building block" approach to the
development of limitations and standards for cokemaking operations is
impractical and leads to erroneous conclusions regarding the level of
treatment available.
RESPONSE
The Agency's building block approach as it pertains to by-product
cokemaking operations includes the development of model coke
production operations with certain common by-product facilities. The
Agency developed one model for merchant coke production and another
one for coke plants affliliated with steel production to account for
the differences in wastewater generation rates at these operations.
The models are based upon wastewater flows for the cokemaking and
by-product recovery operations (waste ammonia liquor, benzol plant
wastewaters, final cooler wastewater, barometric condenser recycle
system blowdown, miscellaneous wastewater, and dilution water for
optimization of biological treatment systems). In addition, special
allowances for qualifying wet coke oven gas desulfurizing operations
and indirect ammonia recovery operations are provided in the
regulation for both iron and steel and merchant cokemaking operations.
The Agency has also recognized that extensive by-product recovery is
practiced at a few coke plants and that site-specific effluent
limitations for the by-product recovery operations not included in the
model cokemaking production facilities should be developed. As noted
in the development document, the model flow rates and BPT and BAT
effluent limitations for cokemaking operations are well demonstrated.
The Agency found the above comment confusing in that the commenter did
not provide any detail regarding why he thinks a building block
eOQCI9
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approach is not practical. Specifically, the commenter did not detail
which aspects of the Agency's methodology it finds ojectionable; or,
how the Agency might improve its building block approach for
cokemaking operations. Rather, the commenter made reference to its
other comments regarding the achievability of the cyanide limitations,
which are addressed separately (See response to comment A-8). Neither
did this commenter, nor any other, provide any specific technical data
or other information about differences in cokemaking or by-product
recovery operations which the Agency could evaluate to determine if
other approaches to developing limitations and standards for
cokemaking operations might be appropraite.
In summary, the Agency believes its approach to developing limitations
and standards for cokemaking operations is logical and appropriate.
The Agency examined the individual sources of wastewaters at
cokemaking operations and formed model treatment systems that includes
those sources. This method provides for the development of achievable
limitations and standards for all cokemaking operations and for
additional allowances for those wastewaters not found at all
cokemaking operations.
23. COMMENT
The industry commented that the Agency has substantially
underestimated the costs of the model BAT treatment system for
cokemaking operations and has not included several important annual
cost items (chemical addition, energy costs), or underestimated others
(operation and maintenance, capital recovery and depreciation charges,
sludge disposal costs). The industry presented estimates of
investment costs to install the model BAT treatment system prepared by
Bethlehem Steel which are about four times higher than the Agency's
estimates ($3.82 million versus $0.87 million). The industry also
commented that the Agency did not include investment costs for
removing suspended solids from pushing emission control wastewaters
used to take the place of dilution water in the Agency's model BAT
treatment system.
RESPONSE
The Agency believes its model based cost estimates for the cokemaking
subcategory accurately reflect the actual costs to be incurred by the
industry in complying with this regulation. As set out in the
development document, the Agency's model based cost estimates compare
favorably with actual industry costs for several BPT and BAT coke
plant wastewater treatment systems, including both biological and
physical/chemical treatment systems. Thus, the Agency believes its
estimated industry-wide costs based upon the model BAT treatment
system, which includes many of the same components as the model BPT
treatment system, are also representative of the costs industry will
incur in complying with the limitations. With respect to the items
the industry cited as not being included in the Agency's estimates,
the Agency notes the following:
OODC20
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a. Investment costs for suspended solids removal from pushir
emission control wastewaters were not included as part of th
Agency's wastewater treatment costs/ since these costs wer
included as part of the air pollution control system costs by th
Agency's air programs office.
b. As set out in the development document, the Agency has include
additional costs for sodium hydroxide and sodium carbonate t
operate the biological treatment systems. The Agency believe
the amount of chemicals specified and associated costs ar
sufficient. The use of these chemicals was not included in th
Agency's model treatment system used to develop the propose
regulation.
c. As set out in the development document and in response to Commen
A-19, the Agency made modifications to the model BAT treatmen
system to provide additional energy for cold weather operations.
d. The Agency's listed annual operating and maintenance cost base<
upon 3.5% of the investment cost is basically a labor cost foi
required operation and maintenance and is substantiated by datt
for many plants. The annual costs of operations in terms oJ
chemical requirements, energy usage, etc. are accounted foi
separately. Thus, the Agency believes it has properly accountec
for these costs.
e. The industry contends that capital recovery and depreciatior
charges based upon 7% interest and 10% depreciation are too low.
As set out in the development document and in the economic impact
analysis of this regulation, the Agency revised its capital
recovery and depreciation charges. The Agency believes its
revised factors are appropriate.
f. The industry contends that sludge disposal costs at $5/ton are
understated, notably in light of RCRA requirements. The Agency
has revised its disposal costs for hazardous sludges to $18/ton
from $5/ton to account for the higher costs of disposing of
sludges considered hazardous under RCRA. Based upon information
submitted by the industry and studies conducted by the Agency,
the Agency believes these costs are representative of costs
incurred for large scale operations typical of the steel
industry.
Regarding the industry's estimate of investment costs to install the
model BAT treatment system, used to develop the proposed limitations,
the Agency notes the following:
Onr
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a. The Bethlehem Steel estimate includes $2.2 million (January 1980
. dollars) for a nitrification facility and $2.4 million (1980
dollars) for an effluent filter for a process flow of 413 GPM.
The total system cost is presented as $4.6 million. The
production plant size is 5200 tons/day and the design flow rate
is about 115 gal/ton. The Agency's estimate for the
nitrification system at the Bethlehem plant (the model treatment
system used to develop the final treatment system) is about $1.7
million (January 1980 dollars). Thus, the Agency's estimate
compares reasonably well with that provided by Bethlehem Steel
for the model BAT treatment system used to develop the final
limitations. (The model treatment system does not include
filters). The estimate presented by the industry was not
sufficiently detailed to permit the Agency to make a more
detailed comparison. The Agency notes that where the industry
representatives have supplied more detailed estimates (for these
and other operations), the Agency has found that excessive
indirect costs were included, and some of the costs for equipment
items and installation were overstated. Reference is made to the
record for additional information on this issue.
b. The Agency finds that the nitrification system noted above, for
which Bethlehem Steel presented cost estimates, is virtually the
same as the single-stage BPT treatment system installed at the
Bethlehem plant. Bethlehem Steel reported to the Agency (letter
of December 11, 1980 from H.A. Conahan) that the installed cost
of that treatment facility is $1.2 million (1980 dollars). The
Agency can find no evidence that the estimated cost for the
nitrification facility should be 80% higher than the installed
cost of the existing single-stage biological treatment system.
The Agency's estimate for the in-place single-stage biological
treatment system agrees with the actual installed cost within 5%
(Agency cost estimate higher). Also, the Agency's estimated cost
for the entire treatment facility installed at this plant
(ammonia stills, biological treatment) also agree within 5%
(Agency cost estimate low) when allocated costs for free ammonia
recovery are deleted. (The Agency notes that free and fixed
ammonia recovery at this plant are conducted in one operation.
The Agency attributed about 35% of the total ammonia still costs
to free ammonia recovery, a typical ratio for conventional free
and fixed ammonia stills). As noted in the development document,
the Agency considers free ammonia recovery to be a by-product
recovery process and not water pollution control.
c. Filtration is no longer included in the BAT model treatment
system, however, the Agency believes the $2.4 million cost
estimate presented above by Bethlehem Steel is overstated. The
Agency could not find any basis for a $2.4 million filter cost to
process 413 GPM. The industry supplied the following actual cost
data for various filtration systems:
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Plant Flow (Cost 1980 Dollars)
0920A 1600 GPM 0.81 million
0920N 1600 GPM 0.39 million
0920N 9400 GPM 1.09 million
As shown above, these costs are significantly less than the estimat
presented by Bethlehem Steel for a much smaller filter system. Whil
different types of filters than those noted above are sometimes use
to treat biological effluents, the Agency could find no data t
support the Bethlehem Steel estimate.
As noted above, based upon numerous comparisons of model-based cos
estimates and actual industry costs, the Agency has determined tha
its model-based cost estimates are representative of actual industr;
costs and appropriate for estimating industry-wide costs to compl;
with the regulation.
24. COMMENT
The operator of Plant 0584F-B indicated the Agency has incorrectlj
listed the benzol plant flow at 15.6 gallons/ton, when it is actuallj
32.2 gallons/ton.
RESPONSE
The Agency reviewed the data for this plant and agrees with the
commenter. The appropriate change was made in the data base for
cokemaking operations.
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B. SINTERING
1. COMMENT
The industry commented that the model flow of TOO gal/ton used to
develop the proposed BPT effluent limitations, while higher than 50
gal/ton used to develop prior effluent limitations, is too stringent.
The industry also requested the subcategory be further subdivided to
take into account the difficulty of recirculating windbox scrubber
waters vs recirculating other wastewaters.
RESPONSE
Based upon this comment and others regarding the achievability of the
BPT model treatment system flow rate, the Agency re-evaluated
available flow data for all sintering operations. As set out in the
development document, a revised BPT model treatment system flow rate
of 120 gal/ton was established. This flow rate is achieved at plants
with windbox scrubbers without significant fouling, scaling and
plugging problems. The Agency included data from only those plants
for which representative flow data are available. The Agency believes
it is not necessary to subdivide the sintering subcategory on the
basis suggested by the industry, since plants with windbox scrubbers
as well as other plants that do not have windbox scrubbers can achieve
the revised model flow rate (120 gal/ton). At some plants this flow
can be achieved on a once-through basis with no recycle. The Agency
believes this model flow rate is achievable at all sintering
operations.
2. COMMENT
The industry commented that alkaline chlorination of sintering
wastewaters should not be used as the model BAT treatment technology
due to its cost and the small level of pollutant removals achieved
with this technology. The industry also commented that filtration of
sintering wastewaters should not be used as model treatment technology
since the technology is not demonstrated on a full scale basis for
stand alone sintering plants with windbox scrubbers and cost of
conventional pollutant removal is too high.
RESPONSE
The Agency reviewed available data and agrees that the relatively low
levels of ammonia-N, total cyanide and phenols (4AAP) found in
sintering wastewaters do not justify the installation of alkaline
chlorination technology for stand alone sintering operations. Toxic
metals are found at treatable levels in sinter plant recycle system
blowdowns. These metals are primarily in particulate form and can be
removed by filtration, which is the BAT model treatment technology.
Based upon the installation of filtration systems in this subcategory
and in other subcategories with wastewaters of similar character, the
Agency believes filters can be successfully installed to treat
wastewaters from stand alone sinter plants with windbox scrubbers and
000024
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those in central treatment systems. Based upon the ab.ove, ,and cos
comparisons noted in the development document, the Agency believes it
cost estimates for filtering sintering wastewaters are accurate. A
noted above, the filters are primarily included in the model treatmen
system for toxic metal removal; since the Agency has reserved BC
limitations for sintering operations, the BCT cost question is not a
issue at this time. It should be noted that the industry is no
required to use filters to achieve the BAT limitations for toxii
metals Data in the record indicate that lime precipitation am
sedimentation are as effective as filters in removing toxic metals.
3. COMMENT
A comrnenter suggested that the Agency should consider dry gas cleaninc
methods, and fully evaluate their effluent reduction capabilities anc
non-water quality impacts.
RSSPONSS
The Agency recognizes that the use of dry gas cleaning systems foi
sintering operations will result in eliminating the discharge of
wastewater. However, the Agency does not believe that it is
appropriate to establish water effluent limitations and standards that
would require the industry to abandon existing wet air pollutior
control systems, particularly, for those plants which are ir
compliance with applicable air pollution or emission standards.
Additionally, the Agency does not believe it should establish effluent
limitations and standards that would restrict the industry's
flexibility to have viable alternatives to comply with air pollutior
requirements. Based upon current trends, the Agency believes that wet
air pollution control systems, rather than dry systems, are likely tc
be used to comply with air quality requirements for sintering
operations.
4. COMMENT
A commenter stated that long-term effluent data from two plants do not
provide sufficient basis to establish BPT limitations which are less
stringent than the previous BPT limitations published at 40 CFR
420.32. The commenter suggested that additional data should be
obtained prior to relaxing the BPT limitations.
RESPONSE
The doubling of the proposed BPT limitations from the previously
promulgated limitations is the result of doubling the model flow rate
from 50 gal/ton to TOO gal/ton. This was based upon the analysis of
all flow data available at that time. The long-term effluent data
from two plants were used to support the effluent concentration basis
for the proposed BPT limitations and to demonstrate the achievability
of those limitations. The Agency believes that the two plants are
representative of other sintering operations and that it is
appropriate to rely upon the respective concentration data to
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establish or demonstrate compliance with the BPT limitations.
However, as discussed previously, the Agency reevaluated all currently
available data for well operated systems and, on that basis,
established the BPT model flow rate at 120 gal/ton.
5. COMMENT
A commenter, expressing concern about the formation of chlorinated
organic by-products as a result of treatment by alkaline chlorination,
recommended that granular activated carbon be included in the model
BAT treatment technology prior to the alkaline chlorination. The
commenter also suggested that effluent limitations be established for
benzo(a)pyrene to regulate the discharge of base/neutral toxic organic
pollutants.
RESPONSE
The Agency has reviewed available data and has concluded that the
levels of ammonia, cyanide and phenols (4AAP) (those pollutants
amenable to treatment by alkaline chlorination) are found in sintering
wastewaters at sufficiently low levels that establishing BAT
limitations based upon alkaline chlorination treatment is not
appropriate. The Agency did not find toxic organic pollutants in
wastewaters from sintering operations at levels that would justify
limiting benzo(a)pyrene or other toxic organic pollutants. Only one
base/neutral toxic organic pollutant was found in sintering
wastewaters. This pollutant was found was at relatively low levels
that cannot be significantly reduced by activated carbon or other
available treatment technologies.
6. COMMENT
One commenter noted that the Agency did not base the limitations and
standards for sintering operations on in-plant controls available for
sintering operations. Recycle of treated process wastewater was cited
by the commenter as being practiced at twelve plants.
RESPONSE
Aside from recycle of wastewaters from air pollution control systems,
the Agency is not aware of any in-plant water pollution control or
process control methods available for sintering operations. Recycle
is included in the BPT model treatment system. The effluent
limitations and standards have been based upon 92% reduction in
effluent volume for those plants with wet air pollution control
systems and applied water rates equivalent to that of the Agency's
model treatment facility.
7. COMMENT
One commenter stated that only three sintering operations were
monitored for toxic pollutants and recommended that the Agency
continue the, development of the data base for sintering operations
COGC26
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after the regulation is promulgated. The same commenter also
requested that the Agency clearly explain how the calculations .for
concentration buildup (pickup per pass or pickup for recycle) were
made.
RESPONSE
Data for the three sampled sintering plants are used to characterize
the wastewaters from five stand alone sintering operations. The
Agency believes the sampled plants are representative of the industry
and the data. Thus, the Agency believes that the data base for the
sintering subcategory is adequate.
With respect to the pick-up for pass calculations, the Agency believes
those calculations are adequately explained in the development
documents. These calculations were used only to assist the Agency in
determining those pollutants that may be added by the process.
8. COMMENT
One commenter noted that the sintering operation at Plant 0112B is
listed incorrectly in the development document as having wet air
pollution control systems at both ends of the sintering process.
RESPONSE
In response to this comment the Agency reviewed information and data
provided for this plant and found that a wet air pollution control
system is used to control air emissions from both ends of the
sintering operation. However, this system does not control air
emissions from the windbox itself. The Agency has made the
appropriate corrections in its data base for sintering operations.
9. COMMENT
The industry commented that the Agency improperly calculated "the cost
benefit ratio" for the proposed BPT limitations for sintering
operations by taking full credit for the pollutant removal at Plant
0112A from the raw waste to the BPT level of treatment, while
considering only the incremental cost from current level of treatment
{which is at or close to BAT) to the BPT level of treatment.
RESPONSE
For the sintering and other steel industry subcategories, the Agency
considered the total cost of application of the BPT technology
(including costs for facilities in-place as well as costs for
facilities required) and the total effluent reduction benefits. For
the regulation as a whole, and for each subcategory, the Agency
determined that the effluent reduction benefits justify these costs.
The remaining costs to comply with the regulation were developed to
assess the economic impact of the regulation on the industry.
003027
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10. COMMENT
The industry commented that the data obtained by the Agency do not
include representative data for plants with wet windbox scrubbers.
The industry recommended that the Agency restudy sintering operations
with discharges from windbox scrubbers.
RESPONSE
The Agency believes it has adequate data to characterize wastewaters
from sintering operations with windbox scurbbers. The industry
indicated data for Plant 0112D are not representative because the
sinter plant recycle system blowdown (windbox wastewaters included) is
directed to a central treatment system. The Agency notes that
wastewaters sampled at this plant are representative of BPT recycle
system blowdowns. The industry reported corrosion at only this one
plant. The Agency believes that, based upon the lack of similar
problems of any significance noted for other plants, that corrosion in
these recycle systems is controllable. Also, data obtained by the
Agency at Plant 0060F, while from a clarifier underflow, are useful
for determining the character of sinter plant wastewaters.
Furthermore, the Agency conducted its pilot filtration studies at
Plant 0060 which has windbox scrubbers.
11. COMMENT
The industry commented that the Agency should use the same
concentrations to develop limitations for sintering and ironmaking
operations since wastewaters from those operations are often treated
together.
RESPONSE
The proposed BAT limitations for sintering operations are based upon
different concentrations for the limited pollutants. In response to
this comment, the Agency based the promulgated BAT limitations for
sintering and ironmaking operations on the same effluent
concentrations.
12. COMMENT
The industry commented that the Agency improperly calculated waste
loads for sintering operations by multiplying high concentrations
obtained at plants with recycle systems with high flows obtained at
plants without recycle, thereby increasing projected BPT waste load
removals. The industry recommended that the Agency properly
recalculate late raw waste loadings from sintering operations.
RESPONSE
COOC28
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The Agency believes that its methodology used to characterize ra
waste loadings is proper. Reference is made to Appendix C, Volume
of the Development Document for a tabulation of the raw waste loading
for sintering operations. Those data were obtained by determinin
appropriate concentrations of the respective pollutants in untreate
sintering wastewaters and multiplying these concentrations by th
aggregate applied model flow for the wet sintering operations. Th
Agency also believes its assessment of the pollutant removal at th
BPT level is representative of actual removal to be achieved by th
industry.
000029
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C.' 'IRONMAKING
1. COMMENT
The industry commented that alkaline chlorination should not be the
BAT model treatment technology for ironmaking wastewaters; the Agency
should not use demonstrated flows from one plant and pilot plant data
from another plant to establish the limitations; and, should the
Agency select alkaline chlorination as the model BAT treatment
technology/ the ammonia-N limitations should be based upon the
performance of the technology on a full scale basis rather than upon
pilot plant data. The industry also commented that the proposed BAT
limitations were so stringent that promulgation of the proposed
limitations would preclude the industry from using other treatment
technologies, including biological treatment, for complying with BAT
requirements.
RESPONSE
The Agency disagrees with the industry regarding alkaline
chlorination. This technology is installed on a full scale basis at
several plants in the industry and is particularly effective at
removing ammonia-N, total cyanide, and phenols (4AAP) from blast
furnace BPT recycle systems blowdowns. As explained in detail in the
development document, this technology provides significant removals of
those pollutants and other toxic pollutants from BPT recycle system
blowdowns. The Agency has determined that the effluent reduction
benefits associated with alkaline chlorination justify the costs. The
Agency also believes that the generation of small amounts of
chlorinated organic pollutants that may result from alkaline
chlorination of ironmaking wastewaters is outweighed by the
substantial removals of ammonia-N, total cyanide, phenols (4AAP) and
other pollutants. While the industry has commented against the use of
alkaline chlorination as the model BAT technology, it had offered no
alternatives, other than to request BAT limitations that are the same
as "proper" BPT limitations. The Agency recently received information
from the industry indicating that it would prefer BAT limitations
based upon a model treatment system flow rate of 35 gal/ton with no
further treatment. In other words, a BPT recycle system operated with
a minimal blowdown. The Agency rejected this alternative as it does
not provide for significant effluent reduction benefits beyond those
achieved at the BPT level of treatment.
With respect to the second and third parts of the above comment, the
Agency had only pilot plant data available at the time of proposal.
In response to this comment, full scale performance data were
solicited and obtained from the industry. These data were used to
develop the final BAT ammonia-N limitation which is based upon a 30-
day average concentration of 10.0 mg/1. A concentration of 1.0 mg/1
was used to develop the proposed limitation. As noted in the
development document, the achievability of the revised ammonia-N
limitation as well as the achievability of the cyanide and phenols
(4AAP) limitations is demonstrated on a full scale basis in the
COOC30
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industry. Notwithstanding the above, the Agency believes it is
appropriate to use demonstrated flow rates from one plant to establish
model BAT flow rates and pilot plant data from another plant tc
establish BAT limitations, provided the plant used to establish the
flow rate is representative of the industry and the wastewaters
treated in the pilot study are also representative. In the case at
hand, at proposal the Agency made the finding that both operations are
representative and that use of the data in this fashion was
appropriate.
The Agency believes that the promulgated BAT limitations for
ironmaking operations can be achieved by wastewater treatment
technologies other than alkaline chlorination. One major steel
company has submitted an application to use a technology which it
considers innovative to comply with the BAT limitations for one of its
blast furnace operations. The data submitted with this application
clearly demonstrate that this technology, which includes biological
treatment, can be used to achieve the BAT limitations.
2. COMMENT
The industry also commented that the model BAT flow of 70 gal/ton was
not well demonstrated; the model flow should be no less than the BPT
model flow, or 125 gal/ton; and, NPDES permit writers should be
instructed to consider site-specific moisture balances when
establishing NPDES permit limits.
RESPONSE
The Agency disagrees. There are several blast furnace recycle systems
operating consistently with blowdown rates less than 70 gal/ton. In
response to the industry comment, additional data were solicited from
a number of companies. Data for plants 0528A and 08561 demonstrate
that 70 gal/ton is achievable on a long term basis and recent short
term data for a number of other plants also support this value. For
the reasons discussed in greater detail in the development document,
the Agency believes it is appropriate to establish the BAT limitations
based upon a 70 gal/ton model flow rate. In addition, recent
information submitted by the industry indicates that 35 gal/ton
blowdown rate may well be achievable on a long-term basis. At least
one major steel company recommended that the Agency establish BAT
limitations using this flow rate.
In support of its comments, the industry provided corrected and
additional data for Plant 0112. Data for this plant were used by the
Agency (at proposal) to demonstrate the achievability of the 70
gal/ton BAT model flow rate. The average of the 33 months of data
submitted by the industry is 77.8 gal/ton compared to 70.3 gal/ton
calculated from the smaller data base available to the Agency at the
time of proposal. The flow rates in the expanded data base range from
27 gal/ton to 138 gal/ton. The industry contended that flows
"substantially below the average discharge rate" cannot be maintained
for extended periods, due to buildup of dissolved solids which leads
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to increased potential for stress corrosion and mineral scaling; and,
that the' high discharge rates are necessary for proper operation under
certain conditions.
The Agency does not believe that corrosion and scaling problems would
arise at blowdown rates of 70 gal/ton. This is clearly demonstrated
by the fact that the recycle system at plant 0112, as well as others
in the industry, have been operated with discharge flows of 70 gal/ton
and less for extended periods of time without experiencing operating
problems. The company owner of Plant 0112 previously submitted
information in response to Agency questionaires showing that the
typical discharge rate at this plant is about 71 gal/ton and that
scaling, fouling, or plugging problems were not experienced at this
plant. The owner also reported that the 71 gal/ton flow rate was
typical of the operation of the recycle system. The plant has been
operating with a recycle system since 1962. The company also
indicated the blowdown rate is controlled to achieve a water quality
standard for cyanide in the receiving water (i.e., increased or
decreased depending upon flow in the river) and not controlled on the
basis of dissolved solids. Thus, the Agency believes that flow rates
higher than 70 gal/ton at this plant are more the result of operating
practices that did not emphasize consistent achievement of minimum
discharge flow rates. Based upon performance at other plants, the
Agency does not believe that variations in weather conditions, raw
material moisture content, make-up water quality, or furnace operating
conditions would prevent attainment of 70 gal-ton at this plant.
The industry also presented flow data for plant 0112B which had an
average discharge flow rate of 175.8 gal/ton. The industry contends
that this high flow rate illustrates the wide variation in discharge
flow rates caused by differences in geographical location, raw
materials and furnace operations. No specific information was
provided to indicate that this plant has been operated in a manner to
achieve low or minimum levels of discharge. In fact, NPDES permit
limitations have not been established for this discharge. Compliance
is determined by monitoring in the receiving stream upstream and
downstream of the plant. Thus, there has been no incentive for the
company to maintain low discharge rates. As a result, the Agency does
not believe that the operation of this plant is representative of well
operated recirculation systems. Furthermore, the discharge flow rate
of 70 gal/ton is being achieved at plants in different geographic
locations using different raw materials.
Finally, the industry stated that the inventory of discharge flow
rates for the 54 ironmaking plants presented in the draft Development
Document, indicates the discharge rates from most of these plants are
well in excess of the BPT model flow rate (125 gal/ton). While the
data presented in the draft Development Document show many plants
discharging at blowdown rates in excess of 125 gal/ton, the Agency
does not believe those data are characteristic of minimum blowdown
rates achievable at blast furnace recycle systems. These data reflect
operations in 1976 when several recycle systems were just put into
operation. ' Since that time, the industry has made significant
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advances in reducing blast furnace recycle system blowdown' rates.
Moreover, the 1974 BPT limitations were based upon' fairly higf
concentrations suspended solids, ammonia-N, total cyanide, and phenols
(4AAP). Hence, many dischargers can achieve the BPT limitations
without paying particular attention to blowdown rate. Many have not
taken steps to minimize blast furnace recycle system blowdowns anc
blowdown rates of 200 to 300 gal/ton are still common. Those that
have made the efforts to reduce flows, have achieved blowdown rates
that meet the more stringent BAT model flow rate of 70 gal/ton. The
Agency is aware of flow data for one of the blast furnace recycle
systems at plant 0684F which demonstrates that blowdown rates of 3!
gal/ton and less are achievable on a long-term basis without
significant fouling, scaling, or plugging problems; and, as notec
above, one major steel company suggested the Agency base BA1
limitations on a model flow rate of 35 gal/ton. Thus, the Agencj
believes the 70 gal/ton model flow rate used to develop the BAT
limitations is appropriate, and probably higher than necessary.
3. COMMENT
The industry recommended that the Agency use the 95% confidence level
to develop the model effluent flows used to establish the BPT and BAT
effluent limitations in the ironmaking subcategory.
RESPONSE
The Agency has not used statistical methods to establish the mode]
flow rates, since blowdown rates are not random statistical variables.
Rather, at the levels at which the model flows are established, the
Agency believes that the blowdown rates are within the control of the
operator. The BPT model flow rate was developed using the average of
the best performing plants in the development of the prior regulation.
The BAT model flow rate is slightly higher than the average of the
current flow data from those plants with the lowest discharge flov
rates. For the reasons set out in the ironmaking subcategory report,
the Agency believes the BAT model flow is achievable at all ironmakinc
plants. Higher flow rates, on the other hand, are unnecessary anc
result from poor operating practice. The Agency believes that the
model flow rates are reasonable, and in conjunction with the
performance values (concentrations) for the limited pollutants, whict
were developed using a statistical methodology (equivalent to the 953
and 99% confidence intervals), appropriate effluent limitations anc
standards were developed.
4. COMMENT
The industry commented that it is not possible to evaporate 70 gal/tor
of blast furnace blowdown on slag produced in the furnaces.
RESPONSE
The Agency has not based the ironmaking BAT limitations on disposal of
blast furnace recycle system blowdown by evaporation on slag.
000033
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Nevertheless, there are some plants that operate in this manner. A
close review of the draft Development Document demonstrates that the
Agency did not indicate that the evaporation of 70 gal/ton on slag is
the basis for BAT Alternative 1, but rather that the blowdown rate
would be in balance with the consumptive use of the slag quenching and
cooling system at a given furnace. This is possible, as demonstrated
by some plants, and will likely become more widespread with various
types of expanded slag production being considered for several blast
furnaces. At the least, disposal by slag quenching can be used at
furnaces with adjacent slag operations to minimize the volume of
blowdown requiring additional treatment, thus minimizing investment
and operating costs to comply with the BAT limitations.
5. COMMENT
One commenter, with some reservation, concurred with the Agency's
decision to promulgate only BPT limitations for ferromanganese blast
furnaces, and to leave the BAT and BCT limitations, and NSPS, PSES and
PSNS for case-by-case determinations at the permit level. The
commenter was concerned about leaving any segment of the industry
without guidelines. The industry, on the other hand, recommended that
the effluent limitations be established on a case-by-case basis.
RESPONSE
The Agency has not promulgated limitations and standards, other than
BPT limitations, for the ferromanganese blast furnace operations.
These limitations are the same as the BPT limitations proposed in
January 1981, and previously promulgated in 1974. The Agency believes
that it is not necessary to promulgate any effluent limitations or
standards other than BPT since there are no ferromangeanese blast
furnaces in operation or projected for operation in the future. The
Agency believes the limitations or standards can be effectively
developed on a case-by-case basis at the permit level for any future
operations and that the BPT limitations provide a firm basis to
establish the appropriate BAT effluent limitations. The model
treatment technologies used to develop the BAT limitations, and NSPS,
PSES and PSNS for ironmaking operations are appropriate for
ferromanganese operations and should be used to establish appropriate
limitations or standards.
6. COMMENT
The industry commented that it would not be appropriate for the Agency
to promulgate zero discharge as NSPS and PSNS for ironmaking
operations on the basis of evaporation of recycle system blowdown on
slag. The industry commented that such a standard may interfere with
furnace operations (imbalance of slag production and blowdown rate);
may limit slag handling practices; and, . may curtail expansion of
ironmaking operations. Another commenter, however, recommended that
the zero discharge standard be promulgated, since there are no
apparent reasons why slag operations cannot be installed adjacent to
new blast furnaces.
000034
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RESPONSE
The Agency considered these comments and has not promulgated NSPS anc
PSNS on the basis of zero discharge. Although slag operations can b«
installed adjacent to new blast furnaces/ the type of slag produced is
dependent upon the available market and water consumption in a slac
operation is related to the type of slag produced. Most of the slac
production methods currently practiced by the industry are capable of
consuming most, if not all, of the wastewater blowdown from wel]
operated blast furnace recycle systems. However, the Agency has
decided not to promulgate a zero discharge standard since it coulc
restrict furnace design and operations. NSPS and PSNS are the same as
the BAT limitations for toxic and non-conventional pollutants.
7. COMMENT
A commenter recommended that activated carbon be added to the model
BAT treatment system prior to alkaline chlorination to remove toxic
organic pollutants, and, thereby, prevent the formation of chlorinated
organic by-products.
RESPONSE
The Agency does not believe that the levels of toxic organic compounds
present in ironmaking wastewaters or the levels of chlorinated organic
compounds produced as by-products from chlorination of ironmaking
wastewaters justify the addition of activated carbon to the model BA1
treatment system. The data available at proposal of this regulation
indicate the formation of chlorinated organics is in the parts per
billion range. Additional pilot studies conducted by EPA show
formation of similar levels of chlorinated organic compounds in
two-stage alkaline chlorination systems preceeded by lime
precipitation. This is the BAT model treatment system. Chlorinated
organics approaching 1 mg/1 were found in the effluent from
single-stage pilot plant systems not preceeded by lime precipitation.
The available data indicate most of the precursors to chlorinated
organic compounds are removed by lime precipitation and that costly
activated carbon for removing these precursors is not warranted.
Two-stage chlorination with lime precipitation is required to achieve
the BAT limitations because single stage systems are not capable of
achieving all of the limitations. In addition, the Agency believes
that alternative methods, e.g., slag quenching and innovative
treatment methods without the potential for generation of chlorinated
organic compounds will be used extensively in the industry to comply
with the BAT limitations. As a result, the potential for discharge of
chlorinated organic compounds will be minimized. This is discussed in
greater detail in the ironmaking subcategory report.
8. COMMENT
One commenter recommended that effluent limitations should be
established for fluoride, since it is present at levels in ironmaking
wastewaters at levels equivalent to those limited in other industries.
OOQG35
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RESPONSE
The treatment technology commonly applied for fluoride removal is lime
precipitation which is the same technology used for toxic metals
removal. The model BAT treatment system for ironmaking operations
includes this technology. Thus, fluoride will be simultaneously
removed to levels equivalent to those limited in other industries. In
any event, the Agency does not believe that industry-wide effluent
limitations or standards for fluoride, at levels found in ironmaking
wastewaters, are warranted based upon its toxicity and environmental
effects and because of co-treatment considerations.
9. COMMENT
One commenter noted that the BAT alternative based upon sulfide
precipitation followed by filtration will most likely be subject to
system failure and lengthy periods of downtime. The commenter stated
that sulfide precipitation will result in a rapid buildup of floe
which will in turn, plug the filters. The commenter further noted
that the Agency's basis for not selecting this treatment system, i.e.,
lack of demonstration within the subcategory and marginal incremental
removal of toxic metals, is contradicted by the Agency's prior
statement that this technology is demonstrated in the metals industry,
could be transferred to this subcategory, and would remove substantial
amounts of metal sulfides when compared to the removal of metal
hydroxides.
RESPONSE
The Agency is no longer considering sulfide precipitation with
filtration as a BAT technology in the ironmaking subcategory. The
Agency agrees with the commenter that this technology is transferrable
the ironmaking subcategory and would result in removal of toxic
metals. However, the data available to the Agency indicate that
sulfide precipitation will not accomplish a greater degree of toxic
metals removal than lime precipitation in this particular application.
This conclusion is based upon studies conducted on sintering and
steelmaking wastewaters.
10. COMMENT
One commenter contends that EPA considered sulfide precipitation only
as an add-on and ignored the less expensive alternative of
retrofitting an existing BPT system with sulfide precipitation and
plate settler packs.
RESPONSE
As noted above, sulfide precipitation is no longer a BAT alternative
treatment technology. With regard to the suggested alternative, the
Agency does not believe that treatment of the entire wastewater flow
(model flow of 3200 gal/ton) using sulfide precipitation and tube
plate settlers would be less expensive, from an investment and
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operating standpoint, than providing separate chemical .addition an
filtration for a substantially reduced flow (70 gal/ton). The Agenc
also does not consider the suggested alternative feasible becasue o
the substantial retrofit problems involved.
11. COMMENT
The commenter recommends that the Agency re-evaluate the cyanid
(total) limitation and provide new limitations which take into accoun
the non-treatability and non-toxic nature of complexed cyanides.
RESPONSE
The Agency believes that the effluent limitations established fo
cyanide takes into account all forms of cyanide present in ironmakin
wastewaters. The Agency is required to limit cyanide and all cyanid
compounds by the Settlement Agreement (see response to comment A-8)
The concentration basis for the effluent limitations are based upo;
and supported by pilot plant data and by the performance of the mode
treatment technology installed on a full-scale basis. Effluent dat,
from pilot treatment systems demonstrate the achievability of th<
cyanide levels at different plants. These data indicate that cyanide:
present in ironmaking wastewater are treatable to below the level:
used to develop the limitations and standards with the model treatmen
technology.
12. COMMENT
The industry commented that the proposed pretreatment standards basei
upon BAT Alternative 4 (alkaline chorination) are too stringent.
RESPONSE
The Agency has promulgated categorical pretreatment standards foi
ironmaking operations based upon the same technology as the model BA1
technology. As set out in the development document, the Agenc
believes these standards are appropriate to minimize pass through o:
toxic pollutants at POTWs.
13. COMMENT
The industry commented that the Agency's comparison of its model basei
estimate for one of the ironmaking BAT alternative treatment system;
with an unsolicited estimate from an engineering firm shows th<
Agency's estimated cost is only one-tenth of the estimate supplied b;
the engineering firm, not within 4.1 percent as claimed by the Agency
On this basis, the industry also commented that the Agency understate!
the economic impact of the regulation.
RESPONSE:
The commenter apparently misread the development document with respec
to this issue. As clearly stated on page 376 of Volume II of th<
000037
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draft" development document (EPA 440/1-80/0245, December 1980), the
estimates compared are the second BAT alternative presented in the
October 1979 Draft Development Document (contractor's report) (EPA
440/1-79/0243, October 1979). This alternative includes alkaline
chlorination followed by activated carbon. As shown, the comparison
between this Agency's model based cost estimate and that supplied by
the engineering firm agree within 4.1 percent. Thus, the Agency
believes its cost estimates for ironmaking operations are
representative and that it has not understated the impact of the
regulation.
14. COMMENT
The industry commented that the Agency has seriously understated the
investment costs required for alkaline chlorination treatment of
ironmaking wastewaters. In making this comment, the industry claims
the Agency's investment costs are 5.6 times lower than actual costs
incurred at Plant 0860B for alkaline chlorination treatment, and 17
times lower for annual costs.
RESPONSE:
The Agency examined cost data presented for Plant 0860B in detail and
found that when appropriate considerations are made for the size of
the treatment system installed at Plant 0860B, the actual treatment
components installed, and year of the expenditures, the actual costs
incurred for this plant compare reasonably well with the Agency's cost
estimate for the model treatment system used to develop the final
limitations.
The alkaline chlorination treatment system installed at Plant
0860B includes alkaline chlorination, filtration, and activated
carbon. This system is equivalent to the Agency's BAT Alternative 5
rather than Alternative 4 which was used to develop the proposed and
final BAT effluent limitations. According to the industry, this plant
was designed for a flow of 4.0 mgd, far above the Agency's model flow
rate. The Agency notes that this treatment system was designed and
constructed before the BPT recycle system at Plant 0860B was completed
and before flow minimization of the BPT recycle system belowdown had
occurred. Thus, the blowdown treatment facility was not sized to the
minimum blowdown rates now being achieved in the industry. The
installed treatment system at Plant 0860B also includes other
treatment components (classifiers, hydroclones, and a bleach
generation plant) not included in the Agency's model.
The Agency does not believe that classifiers and hydrocyclones are
necessary to achieve the BAT limitations, since adequate suspended
solids removal equipment (thickeners and clarifiers) are included in
the model BPT and BAT treatment systems. Vacuum filters are also not
necessary for BAT treatment, since they are included on a larger scale
as part of the BPT model treatment system. The additional sludge
generated with BAT Alternatives 4 and 5 is small (less than 1 percent)
compared to that produced at the BPT level; and, the vacuum filters
0038
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included in the model BPT treatment system are adequate for de-waterinc
this sludge. A bleach generation unit is not included in' the Agency's
model, since chlorine rather than bleach (sodium hypochlorite) is usec
as the oxidizing agent. The Agency has included costs foi
chlorinators in its model treatment system.
In its comments/ the industry scaled the cost of the wastewatei
treatment facility installed at Plant 0860B ($17.7 million) to th«
size of the Agency's treatment system on the basis of flow using th«
0.6 factor. This resulted in a projected investment cost for i
similar sized facility of $4.6 million. The industry compared this
cost to the Agency's cost for BAT Alternative 4 of $0.82 million anc
stated the Agency's investment costs are low by a factor of 5.6. Th«
Agency believes this comparison is not appropriate because it does not
take into account the treatment facilities installed at Plant 0860B.
The Agency's investment cost estimate for BAT Alternative 5 is $3.1!
million dollars. The Agency estimates that the cost for the items
installed at Plant 0860B but not required to comply with the BA1]
limitations is about one million dollars. Taking these costs intc
account, the Agency's model plant estimate and the industry's costs
for a similar sized plant agree within 10 percent. Thus, the Agency
believes its model based cost estimates accurately reflect actua]
industry costs.
In response to public comments, the Agency made substantial revisions
to the annual costs for the model BAT treatment system. Chemical us*
costs were increased by a factor of about 10 and overall annual costs
including sludge disposal costs were increased accordingly. Th<
Agency believes these revised costs, including the costs for solic
waste disposal, are appropriate. These revised costs also compare
favorably with industry's estimated annual costs for Plant 0860B wher
appropriate considerations are made for the size and type of th«
wastewater treatment facilities installed at Plant 0860B. Th«
industry presented total annual costs of $2.83 million based upon th«
industry's scaled down investment cost of $4.6 million. In makinc
this estimate the industry did not adjust the operation anc
maintenance expense (listed as an annual cost equivalent to 25% oi
capital investment) to the size of the smaller model plant, anc
assumed the energy requirements for the model plant would only be om
half those of the larger plant, although the full scale plant is ter
times larger than the model plant and includes substantially mor«
energy consuming equipment. The Agency notes that elsewhere in th<
industry's comments, the industry stated that operation anc
maintenance expenses and capital charges and depreciation amount t<
27% of capital investment vs. the 25% cited above for only operations
and maintenance.
Finally, with respect to chemical usage, Plant 0860B is operated witl
caustic soda and sodium hypochlorite for alkaline chlorination. Th<
Agency's treatment system is based upon the use of lime and chlorim
gas, which are less expensive. Either set of chemicals can be used t<
achieve the BAT limitations. However, the Agency believes it£
selection of treatment chemicals is more cost effective. Both lim<
OOOG39
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and chlorine gas are used on a full scale basis in the industry for
wastewater treatment.
Given the above, the Agency believes that both its model based
investment costs and annual costs are appropriate for the selected BAT
alternative treatment system.
15. COMMENT
The industry also compared the Agency's capital and annual costs for
the proposed BAT Alternative 4 model treatment system with cost
estimates made by the industry for this treatment system. The
industry concluded that the Agency's estimated capital cost is less by
a factor of more than 6 and the annual costs by a factor of 8.
RESPONSE;
The Agency evaluated the information provided and found that its cost
estimates for those few mechanical equipment items which could be
isolated in the industry's cost estimate are not substantially
different than those presented by industry. The level of detail
provided in the industry's estimate is not sufficient for the Agency
to make a detailed evaluation of other direct cost items. However,
the Agency notes the following: The industry's model treatment system
is similar to the Agency's proposed BAT-Alternative 4 model treatment
system, except that vacuum filters are included and the flow rate (125
gal/ton) used to estimate pollutant loadings to the treatment system
is nearly 80% higher than the Agency's model flow rate. As noted
previously, the Agency does not believe that vacuum filters are
necessary for sludge dewatering in the BAT treatment system. This
equipment is included in the BPT model treatment system and is capable
of processing the additional sludge produced at BAT. The Agency's BAT
Alternative 4 model treatment system is based upon 70 gal/ton. Hence,
the rate of chemical usage and the annual chemical and other operating
costs for the industry's model would be considerably higher than
estimates made using the Agency's model. The associated equipment
costs would also be higher than the Agency's costs for the same
equipment since the equipment in the industry's model would have to be
larger to treat the higher wastewater volume. Based upon the
demonstrated flow rate used to develop the model BAT treatment system,
the Agency believes its cost estimates are appropriate. The industry
also included over $1 million of site specific costs in its estimates
for demolition of an old blast furnace to make room for the BAT
treatment facilities. The Agency believes that other sites may be
available at this plant and that such high site specific costs would
not be incurred. In any event, the Agency believes that the
demolotion of old blast furnaces to make room for BAT treatment
facilities is not required across the industry.
The Agency believes that its cost estimates based upon its model
treatment systems are accurate and appropriate for estimating
industry-wide costs. As demonstrated in the previous comment, the
Agency's estimates compare favorably with industry costs for Plant
CCOG40
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0860B. Moreover, as presented in the Volume I and in the i'ronmaki
subcategory report of the Development Document, the Agency h
compared its estimates with actual costs incurred at sever
ironmaking facilities within the industry. This comparison furth
demonstrates that the Agency's estimates are reasonable, and in fac
exceed costs reported by the industry.
000041
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D. STEELMAKING
1. BOF-OPEN COMBUSTION
a. COMMENT
The industry commented that effluent limitations should be established
for suspended solids only, since blowdown treatment for toxic metals
has not been demonstrated for BOF-Open Combustion operations; the
industry also commented that the Agency's proposed limitations for
toxic metals are not achievable with the model BAT treatment
technology.
RESPONSE
The model treatment system upon which the final BAT limitations are
based -is lime precipitation followed by sedimentation in clarifiers.
The model treatment system upon which the proposed BAT limitations are
based included the above components and filtration of the clarified
effluent. The Agency made this change in the model treatment system
because available data show that filters do not perform substantially
better than clarifiers with respect to toxic metals removal after
precipitation and sedimentation has occurred. The final BAT
limitations and standards are based upon a treatment technology which
is well demonstrateds on a full-scale basis at BOF-Suppressed
Combustion and Open Hearth-Wet operations and on a pilot-scale at an
Electric Arc Furnace operation. The wastewaters from operation in
these steelmaking subdivisions have characteristics similar to
wastewaters from BOF-Open Combustion operations. In fact, as set out
in the development document and in the response to Comment D°46,
Electric Arc Furnace wastewaters contain much higher levels of toxic
metals than any of the other steelmaking operations. The
concentrations of toxic metals used to develop the BAT effluent
limitations are based upon data from the EAF system. As a result, the
application of the model treatment technology to wastewaters from
BOF-open combustion operations will produce the same or better
effluent quality.
The high levels of toxic metals in the BPT recycle system blowdowns
for wet steelmaking operations (the wastewaters after treatment to
achieve the BPT limitations) justify the need for treatment at the BAT
level. Zinc was found in the sampled effluents at levels ranging from
0.32 mg/1 to 2.8 mg/1; chromium in the range from 0.01 mg/1 to 30.1
mg/1; and lead in the range of 0.04 mg/1 to 13.6 mg/1. The Agency
considers toxic metals at these levels to be significant and at
treatable levels. BAT limitations are established for only lead and
zinc based on achievable concentrations of 0.30 mg/1 and 0.45 mg/1,
respectively. The Agency believes that it is appropriate to establish
specific limits for these toxic metals and that limitations based upon
these levels can be achieved at all steelmaking operations.
Limitations based upon suspended solids alone will not effectively
control the discharge of toxic metals in steelmaking wastewaters since
these metals are in both the dissolved and particulate forms. It
CGG6£2
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should be noted that if the commenter is claiming that the levels o
toxic metal pollutants are found below the established BAT limitation
and standards (and the Agency believes that this is not the case a
many plants), then no additional treatment beyond that necessary b
achieve the 3PT limitations would be necessary.
b. COMMENT
The industry commented that the model flow of 65 gal/ton for BOF-opei
combustion operations should be reevaluated because the plant (0584F
at which this flow is achieved is unique. The industry noted that th<
use of fuel oil is used to fire waste heat boilers at this plant coul<
affect the quality of the scrubber water to the extent that highei
recycle rates could be achieved.
RESPONSE
The industry supplied no information or data to support theii
contention that the use of fuel oil at this plant could affecl
scrubber water to the point higher recycle rates could be achieved,
The Agency does not believe this practice would significantly affecl
the ability to recycle EOF wastewaters. Nevertheless, the Agencj
reevaluated flow data for BOF-Open Combustion operations and found th<
applied flow rate at plant 0584F is substantially lower than the mode]
treatment system applied flow rate (265 gal/ton vs 1100 gal/ton), anc
the recycle rate at this plant is only 75%. Since this flow is not it
line with the model applied flow, the Agency evaluated all BOF-Oper
Combustion systems with recycle rates of 90% or greater and founc
these plants to be representative of the industry and practicing gooc
wastewater treatment. Thus, the model treatment system effluent flov
rate was established at 110 gal/ton. This flow is being achieved at
20% of the BOF-Open Combustion operations and can be achieved at al]
BOF-Open Combustion plants with properly designed and operated recycle
systems.
C. COMMENT
One commenter stated that the Agency did not properly evaluate treatec
effluent data for BOF wet-open combustion steelmaking operations,
citing the Agency's use of central treatment plant data. Th€
commenter noted the BOF effluent at Plant 0020B is diluted anc
therefore the data are not valid; that the BOF discharge at plant
0112D receives further treatment which the Agency did not consider ir
its analysis; and, for plants 0856B and 0868A, the Agenci
misrepresented the quantity of toxic pollutants to be removed by the
application of the proposed BPT and BAT limitations.
RESPONSE
The Agency disagrees with the commenter and believes that its analysis
of the data used to determine raw waste loadings is proper. However,
the Agency discovered an error in the data used to represent the rav
wastewater pollutant loads for Plant 0868A. Mistakenly, the quality
COGC£3
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of .the .make-up water was used instead of the actual raw wastewater
quality. This has been corrected. This error resulted in an
understatement of the effluent reductions achieved at BPT, in that the
raw waste loads were significantly understated. The raw waste data
for the other plants (0020B, 0112D and 0856B) are representative of
raw wastewater discharges from EOF wet-open combustion systems.
The Agency also believes that its analysis of the treated effluent
data is proper. Samples for all of these plants were taken at the
blowdown frcr. the recycle systems. The effluent quality from those
plants is representative of the effluent from BPT systems. The only
exception is the effluent load total suspended solids at Plant 0112D,
which exceeded the BPT limitations. Increased recycle will not affect
the effluent quality with respect to the limited pollutants since the
concentration of these pollutants is reduced in the thickeners, which
perform independently of wastewater recycle. Thus, the effluent data
are representative of the discharge from BPT systems and are
appropriate for calculating effluent reductions.
The treated effluent at Plant 0020B includes wastewater discharges
from a cupola. The effluent quality for the BOF discharge was
therefore calculated from a proportional share of the effluent load
attributable to the BOF. The load was apportioned on the basis of
relative wastewater volumes.
Although the pH values measured at Plants 0856B and 0112B are higher
than the prescribed maximum of 9.0 standard units, the concentration
of toxic metals will remian unchanged even if the pH is lowered. The
toxic metals were measured as total metals, and are unaffected by pH
alone. Therefore, the toxic metals data are representative of
effluents from BPT systems.
The Agency believes that its analysis of the data is proper and that
it has not misrepresented the amount of toxic metal pollutants removed
at BPT and BAT.
2. STEELMAKING-BOF-SUPPRESSED COMBUSTION
COMMENT
The industry commented that blowdown treatment for metals is not
justified since the treatment system installed at the exemplary plant
(Plant 0684F) does not remove any metals. Effluent limitations should
therefore, be established for suspended solids only.
RESPONSE
Plant 0684F was not used as the exemplary plant upon which the
proposed BAT limitations were based. Lime precipitation and
clarification, the model BAT treatment system, is installed at this
plant to treat the blowdown from a BPT recycle system. The Agency
notes that toxic metals were not being removed during its sampling
survey across the blowdown treatment system installed at plant 0684F
GGOCS4
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due to the low levels of toxic metals in the influent to 'the 'blowdow
treatment system. The toxic metals in this wastewater were bein
removed prior to blowdown treatment because of the operation of th
recycle system. Lime precipitation is practiced on the total flow o
the recycle system rather than on the small blowdown as included i
the Agency's BAT model treatment system. The high pH of the ra
wastewater at plant 0688F results in the precipitation an
sedimentation of the toxic metals in the primary BPT treatment system
The effluent from the BPT treatment system installed at this plan
complies with the final BAT limitations.
Treatment of toxic metals in this subdivision is justified since thes
metals are present at treatable levels. The 30-day averag
concentration basis for zinc is 0.45 mg/1 and for lead 0.30 mg/1. A
noted above, these concentrations are based upon a pilot stud;
conducted on wastewaters from a wet EAF operation which ii
representative of such operations. Wet EAF wastewaters typicall;
contain toxic metals at levels much higher than contained ii
wastewaters from other steelmaking operations. Limitations on tota
suspended solids alone will not effectively control toxic metals
since these metals are present to some extent in the dissolved state
As noted above, if the commenter is claiming that the levels of toxii
metals in the BPT effluent at a particular plant are in compliance
with the BAT limitations, then additional treatment facilities beyon<
that required to achieve the BPT limitations are not required.
3. STEELMAKING-BOF-SEMI-WET
a. COMMENT
The industry commented that effluent limitations based upon reasonabl<
blowdown rates should be established in lieu of the proposed (BPT an<
BAT) zero discharge limitations since achievement of zero discharg<
through the application of the model treatment technology has not beet
demonstrated.
RESPONSE
The model treatment technology to achieve zero discharge has beer
modified to conform to the system installed at Plant 0432A, which is
in compliance with the zero discharge limitation. The performance at
this plant is the basis for the final BPT and BAT limitations,
However, the model treatment technology used as the basis for th«
proposed limitations included wastewater treatment and sludge handlinc
equipment more sophisticated than installed at Plant 0432A. That
model technology included vacuum filters which minimize water loss
through the sludge as opposed to drag out tanks used with most
semi-wet gas cleaning systems. The water loss as moisture in sludge
is not considered a discharge. This water loss, however, serves as
blowdown from the system and prevents dissolved solids from increasing
to levels at which scaling would occur. Thus, zero discharge can be
achieved by attention to water application rate and sludge handlingg.
The Agency recognizes, however, that there may be unique, plant
OGDOS5
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specific, factors which could not be taken into account in this
regulation which may limit the owner or operator's ability to achieve
zero discharge at certain semi-wet steelmaking operations. In such
cases the owner of that facility may pursue alternative limitations at
the permit writing stage based upon this fundamentally different
factor. Reference is made to Section IV of the steelmaking
subcategory report of the development document for additional
information.
b. COMMENT
One comrnenter recommended that three additional BOF semi-wet plants be
sampled in order to determine whether this segmentation of the BOF
subdivision is proper.
RESPONSE
The Agency believes that sufficient information is available to
justify segmenting the BOF subdivision to separately regulate the
semi-wet plants. The fact that semi-wet operations include water use
primarily for conditioning and cooling the gases prior to dry gas
cleaning clearly distinguish these plants from those where the gases
are cleaned in wet scrubbers. The information submitted by industry
and the sampling data collected by the Agency demonstrate that the
water application rates and untreated wastewater contamination at
semi-wet plants are an order of magnitude less than at wet plants;
and, that recycle to extinction is feasible at semi-wet plants where
water is used for gas conditioning purposes. Zero discharge cannot be
achieved at plants with wet scrubbers due to scaling problems.
4. STEELMAKING - EAF
a. COMMENT
The industry commented that the flow basis for the EAF-Wet subdivision
should be reevaluated, since the two plants identified as achieving
the 50 gal/ton model flow rate actually discharge at higher levels.
RESPONSE
Data used by the Agency to develop the model flow rate of 50 gal/ton
for the proposed BAT limitations were submitted by the industry in
response to questionnaires. The Agency has corrected the data base
for EAF plants based upon more detailed information submitted by the
owners. The model treatment system flow rate has been increased to
110 gal/ton, which represents the average of those plants that achieve
a recycle rate greater than or equal to 90 percent. For the reasons
set out in the steelmaking subcategory report, the Agency believes
that this is an appropriate flow rate upon which to base the BAT
limitations.
GGOC£6
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b. COMMENT
The industry commented that effluent limitations should be establishe
for suspended solids alone, since the need to limit toxic metals an
the validity of the underlying treatment technology has not bee
justified. In its comments, the industry presented concentrations o
toxic metals determined from ratios of concentrations of suspende
solids and toxic metals to indicate that higher toxic metal
limitations are justified. The industry also commented that th
Agency did not present dissolved metals data for its pilot plant stud
to support its view that much of the toxic metals loading is, in fact
in the form of dissolved metals.
RESPONSE
As for the other steelmaking subdivisions, the proposed BA
limitations are based upon lime precipitation followed b;
clarification and filtration. The final BAT limitations are, however
based upon lime precipitation and clarification. Filtration has bee
deleted from the model treatment system since the incremental remova
of toxic metals after lime precipitation and clarification is no
significant.
Pilot studies were conducted on wastewaters from an EAF-wet operation
This plant (0612) is representative of other wet EAF plants, and has
discharge close to the model flow rate. The data from this stud
clearly indicate that a large portion of the toxic metals found i
steelmaking wastewaters are present in the dissolved state, and lim
precipitation followed by clarification effectively removes thes
metals. Filtration or other technologies that remove suspended solid
alone are not-effective for dissolved metals removal. The dissolve
metals data were in the record at proposal; and, have been included i
the development document. The Agency has evaluated the methodolog
used by the industry (ratio of suspended solids to toxic metal
effluent levels) and finds it to be erroneous since, as noted above,
considerable portion of the toxic metals in EAF wastewaters ar
dissolved toxic metals, and a ratio of total suspended solids b
dissolved metals is meaningless.
The levels of toxic metals present in BPT system effluents justify th
need for treatment beyond the BPT level. Effluent data collecte
during the Agency's sampling surveys and other data submitted b
industry show that zinc levels range from 3.2 mg/1 to 48 mg/1, an
lead from 1.0 mg/1 and 25 mg/1. These data demonstrate that EA
wastewaters contain the highest level of toxic metal pollutants. Th
pilot plant study noted above demonstrated that the model BA
treatment technology can remove lead and zinc to levels of 0.3 mg/
and 0.45 mg/1 on a 30-day average basis, respectively. As note
earlier, the Agency used these data as the basis for the BA
limitations for all wet steelmaking operations. The Agency believe
that since EAF wastewaters are the most highly contaminate
steelmaking wastewaters with respect to toxic metals, it i
appropriate to base effluent limitations and stanadards for the les
*
Onr«f>r n
u U b £ i
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contaminated steelmaking wastewaters upon treatability and performance
data developed for EAF operations.
c. COMMENT
The industry commented that effluent limitations should be established
for the EAF semi-wet subdivision in lieu of the zero discharge
standards/ since zero discharge is no longer achieved at the plant
upon which this standard was based, and zero discharge is not achieved
at other plants in this subdivision.
RESPONSE
Plant 0432C was one of the models for the zero discharge standard for
EAF semi-wet operations. The gas conditioning system at this plant
was converted to once-through discharge as a result of scaling
experienced at the spray nozzles, in the gas conditioning system after
several years of operation at zero discharge. The Agency found that
Plant 0584A operates in a zero discharge mode, despite the fact that
provision for discharge is included in the design of the facility.
Information recently submitted by the company indicate that wastewater
discharge at this plant occurs only inadvertently when leaks develop
in the spray towers, or an imbalance in the flow system occurs. These
discharges are reported to occur on an infrequent basis. The Agency
considers these infrequent and inadvertant discharges to be upsets
which are not precluded under the zero discharge standard. The Agency
believes the achievability of the zero discharge standard is
demonstrated at this plant. As noted above, this technology is also
demonstrated in the EOF semi-wet subdivision in the same type of
application. In the Agency's opinion, the demonstration of zero
discharge at EOF semi-wet plants is applicable to EAF semi-wet
operations. The Agency recognizes, however, that there may be unique,
plant specific factors which could not be taken into account in this
regulation which may limit the owner or operator's ability to achieve
zero discharge at certain semi-wet steelmaking operations. In such
cases, the owner of that facility may pursue alternative limitations
at the permit writing stage based upon this fundamentally different
factor. Reference is made to Section IV of the steelmaking
subcategory report of the Development Document for additional
information.
5. STEELMAKING-OPEN HEARTH
a. COMMENT
The industry commented that the open hearth semi-wet segment should be
deleted since the single plant covered by this segment has wet gas
cleaning systems.
RESPONSE
In response to this comment, the Agency reviewed available information
for Plant 0864A and found that wet air pollution control systems are
-------
installed on the open hearth steelmaking operations at this plant.
Accordingly, the open hearth-semi-wet segment has been deleted,and th«
plant is now listed as an open hearth-wet operation.
b. COMMENT
The industry commented that effluent limitations should be established
for suspended solids only, since the model BAT treatment technology
has not been demonstrated for open hearth-wet operations and the toxic
metal effluent limitations cannot be consistently achieved because of
fluctuations in raw waste loads.
RESPONSE
As for the other steelmaking operations, the model treatment
technology used to establish the proposed BAT limitation included
filtration of the effluent from a lime precipitation and clarificatior
system. The model treatment technology used for the final BAT
limitations is lime precipitation and clarification. This technology
is demonstrated at Plant 0864A, as well as for the other steelmakinc
subdivisions. At Plant 0864A, lime is added in the primary BP1!
recycle loop upstream of the clarifiers. In the model BAT treatment
system lime precipitation and clarification is performed on the
blowdown from the BPT recycle system. Nonetheless, the same effluent
concentrations with respect to toxic metals are achievable in both
systems. This is also demonstrated at Plant 0684F (see Response tc
Comment D-2). The effluent at Plant 0864A is in compliance with the
BAT limitations. These limitations were established on the basis of c
pilot plant study conducted at Plant 0612. As noted in the response
to Comment D-4b EAF operations have the highest levels of toxic meta]
contamination. The Agency has determined it is appropriate to base
the BAT limitations upon those data for all wet steelmakinc
operations.
Fluctuations in influent loads to the BAT treatment system at oper
hearth operations should not affect the effluent quality of well
designed treatment facilities. In the Agency's opinion, properly
designed and operated treatment facilities are capable of treating
varying raw waste loadings to a level which achieves the BAT
limitations. Moreover, the BPT recycle systems installed at these
facilities serve to equalize and dampen the fluctuations in the loads
discharged to the blowdown treatment system. If such fluctuations are
unavoidable at a particular plant, surge capacity for the blowdown car
be installed prior to the BAT treatment system at low cost to achieve
the desired blowdown rate and the applicable effluent limitations.
Establishing effluent limitations for suspended solids will not
adequately control the discharge of toxic metals since the toxic
metals are present, to a large extent, in the dissolved state. The
need for treatment of toxic metals is justified since these pollutants
are present at treatable levels. Zinc has been found at levels
ranging from 4.4 mg/1 to 26 mg/1. Although lead was found belov
treatable levels in open hearth wastewaters, limitations have beer
COOG49
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established for this pollutant to facilitate co-treatment with other
compatible wastewaters.
6. STEELMAKING-GENERAL
a. COMMENT
A commenter stated that the Agency in reviewing the alternative BAT
treatment technologies for steelmaking wastewaters, did not consider
high gradient magnetic separation.
RESPONSE
The Agency agrees that high gradient magnetic separation may be a
promising wastewater treatment technology for removal of iron-bearing
particles. However, the Agency has no data to demonstrate how this
technology would perform with respect to removal of dissolved toxic
metals, and lacks sufficient data to confidently project the
reliability and cost of such systems. As a result, this technology
was not considered.
b COMMENT
The same commenter stated that in-plant control measures for reducing
wastewaters from steelmaking operations should be given more
consideration.
RESPONSE
Aside from recycling of wastewaters, the Agency is not aware of other
in-plant controls that could be used at all steelmaking facilities to
reduce the discharge of wastewaters. Recycle is a major component of
the model treatment systems evaluated by the Agency.
c. COMMENT
One commenter believes that sulfide precipitation, rather than lime
precipitation should have been selected as the model BAT and NSPS
treatment systems, since this technology is less costly and should
remove toxic metals to lower levels.
RESPONSE
Theoretically, sulfide precipitation should remove toxic metals to
lower levels than lime precipitation. However, the study conducted by
the Agency on steelmaking wastewaters demonstrate that lime, sulfide
and carbonate precipitation reduced metals to equivalent levels. The
Agency concluded that it was appropriate to base the BAT limitations
on lime precipitation since this technology is widely used in the
industry and the studies conducted by the Agency demonstrate similar
performance with other precipitation systems.
OOOC50
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d. COMMENT
One commenter contends that the retrofit of lime precipitatioi
technology in the model BPT recycle treatment system, rather thai
using it for blowdown would reduce costs. The commenter stated thai
the installation of plate settler packs in existing clarifiers anc
thickeners would be standard engineering practice.
RESPONSE
The Agency balieves that placing tube plate settler packs in a full
flow treatment sytsem and providing the requisite chemical additioi
would be substantially more costly than providing separate chemica!
addition and sedimentation for a substantially reduced effluent flow
The Agency also believes that there would be substantial retrofil
problems implementing this technology at most plants. Notwithstanding
the above, the regulation does not preclude this method of operation.
e COMMENT
The commenter recommends that the Agency collect additional data foi
fluoride in steelmaking wastewaters and reconsider the need t<
regulate fluoride discharges in the steelmaking subcategory. This
commenter cited three specific examples of high fluorid*
concentrations in raw wastewaters (one EAF-semi-wet and two oper
hearth operati ons).
RESPONSE
The Agency agrees that fluoride is present in EAF and open heartl
furnace steelmaking wastewaters at treatable levels. However, th«
Agency believes that the model treatment system used to establish th«
BAT effluent limitations for toxic metals will also effectively
control fluoride. Lime precipitation is a commonly used technology tc
remove fluoride. Those operations with high fluoride concentrations
were also observed to have low raw wastewater pH and high toxic metals
concentrations. Therefore, lime addition sufficient to achieve th«
level of control specified for the limited toxic metal pollutants wil]
also achieve effective removal of fluoride. The Agency does not
consider the expected discharge levels of fluoride to be higher thai
treatability levels and thus, does not believe that limitations an<
standards for fluoride are appropriate.
f. COMMENT
One commenter recommended that EPA eliminate pelletizing am
associated credits from the cost estimate for the steelmakinc
subcategory since steelmaking sludges are not frequently re-used.
C00051
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RESPONSE
The Agency re-evaluated steelmaking sludge credits and agrees with the
commenter. Although recovery of steelmaking sludges is practiced at
two plants, the Agency has concluded that such practices are not
applicable on an industry-wide basis. Thus, credit for sludge
recovery has been deleted from the cost estimates for this
subcategory.
000052
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E, VACUUM DEGASSING
1. COMMENT
In response to the Agency's solicitation for comments on the
feasibility of establishing a BAT limitation of zero discharge for
vacuum degassing operations, one commenter recommended that zero
discharge be adopted.
RESPONSE
While zero discharge has been reported for two vacuum degassing
operations, the Agency does not believe that zero discharge can be
achieved at all vacuum degassing operations unless costly evaporative
technologies are used. The Agency believes that a small blowdown may
be necessary to prevent the build-up of dissolved salts in the recycle
systems. The Agency has concluded that the incremental pollutant
removal between the promulgated BAT limitations based upon 98% recycle
of vacuum degassing wastewaters and zero discharge does not justify
the high cost involved. To the extent that zero discharge can be
achieved at low cost to attain compliance with the appropriate
limitations and standards, the Agency encourages the industry to do
so.
2. COMMENT
A commenter contends that the Agency should evaluate the use of
coagulant aids prior to filtration in the Vacuum Degassing
subcategory. The commenter states that when used for gas scrubbing
purposes waters should contain no more than 200 mg/1 of TSS, that low
suspended solids loadings would permit complete recycle and eliminate
the need for a discharge.
RESPONSE
While the use of coagulant aids can can enhance filter performance in
certain cases, consideration must be given to the nature of the
wastewater being filtered. In this case, the nature of the
wastewaters (i.e., discrete particulate matters, etc.) do not warrant
coagulant aid addition. In fact, the model raw wastewater suspended
solids concentration is 60 mg/1, much lower than found in other
steelmaking wastewaters. The sampled plant monitoring data
demonstrate that high rate recycle can be achieved at vacuum degassing
operations without the use of coagulant aids and filtration. The
Agency does not believe filtration would allow complete recycle of
vacuum degassing operations. As noted above, the Agency did not
establish a zero discharge standard for these operations, because it
believes zero discharge can only be achieved universally with costly
evaporative technologies.
000053
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3. COMMENT ' , ,
The commenter states that the Agency should have considered hig
gradient magnetic separation for the removal of fine iron particulate
from vacuum degassing scrubber wastewaters. The commenter states tha
such a device is capable of producing an effluent with less than 2
mg/1 of TSS.
RESPONSE
Filtration, which is a component of the BAT model treatment system
will achieve similar effluent TSS levels. Filtration has th
significant advantage of being demonstrated in this subcategory. I:
addition, filtration offers significant investment and operating cos
benefits as well.
C00054
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FV.. CONTINUOUS CASTING
1. COMMENT
The industry commented that the BAT limitations should be set equal to
the BPT limitations since toxic metals are not contributed by the
process in significant amounts nor are they removed by the proposed
BAT treatment technology (filtration).
RESPONSE
The Agency believes that it is appropriate and feasible to reduce the
discharge of toxic metals from continuous casting operations.
Available data clearly show that chromium and zinc are present in the
untreated continuous casting wastewaters and in BPT effluents in the 1
to 2 mg/1 range. Lead is also present at treatable levels.
Consequently, the Agency has promulgated BAT limitations that are more
stringent than the BPT limitations (which limit conventional
pollutants only).
Filtration of the BPT recycle system blowdown was used as the BAT
model treatment system to develop the proposed BAT limitations. In
response to the above comment, the Agency reevaluated available
monitoring data and found that a considerable portion of the toxic
metals found in continuous casting wastewaters are in a dissolved
state. The Agency believes that some of the dissolved metals may
originate in chemical additives used in the high rate recycle systems
at the sampled plants or, are actually fine particulate metals
measured as dissolved metals by the analytical methodology. The
Agency agrees that filtration does not effectively control these
metals. Accordingly, the Agency has selected lime precipitation and
sedimentation as the model BAT technology. This technology is
effective for treating both dissolved and fine particulate toxic
metals. The Agency used data on achievable toxic metal concentrations
obtained from pilot plant studies at electric furnace operations to
develop the BAT limitations for continuous casting operations. As
explained in the development document, the Agency believes it is
appropriate to rely on the data to establish the BAT limitations for
continuous casting operations. Moreover, the limitations and
standards for continuous casting, vacuum degassing, and all wet
steelmaking operations are based upon the same treatment technology
and concentrations. Co-treatment of compatible wastewaters from these
subcategories is feasible.
2. COMMENT
In response to the Agency's solicitation of comments on whether zero
discharge would be appropriate as BAT for continuous casting
operations, the industry commented that zero discharge is not possible
due to comingling of other extraneous wastewaters and the need for
blowdown to control levels of dissolved solids in the recycled water.
000055
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RESPONSE
The final BAT limitations are not based upon zero discharge becaus
the Agency believes zero discharge can only be universally achieve
through the use of costly evaporative technologies. However, th
Agency notes that zero discharge has been reported for several plants
and, to the extent zero discharge can be achieved to attain complianc
with the appropriate limitations and standards, the Agency encourage
the industry to continue this practice.
000056
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G. HOT FORMING
1 . COMMENT
The industry commented that the Agency should not promulgate BAT
limitations for hot forming operations because toxic metals are not
contributed by hot forming processes to its wastewaters. The industry
also commented that BAT limitations for suspended solids and oil and
grease should be established at a level no more stringent than BPT.
Others commented that the BAT limitation for hot forming operations
should be zero discharge.
RESPONSE
In response to these comments, the Agency reviewed its existing data
for the hot forming subcategory and conducted additional extensive
sampling programs at fifteen hot forming operations in cooperation
with the industry. These data clearly demonstrate that significant
quantities of toxic metals are generated by hot forming operations,
are present in hot forming raw wastewaters, and, are also present in
the wastewaters discharged from the primary scale pits used to recover
mill scale. These data also demonstrate that toxic metals are removed
to very low levels at plants with the model BPT treatment system
installed (i.e., primary scale pit, partial recycle, secondary
settling, and filtration). The average gross effluent concentration
of all toxic metals in the wastewaters of these plants after treatment
is about 0.07 mg/1. The Agency believes that, at these levels, the
toxic pollutants have been effectively controlled and that the
substantial cost (more than $300 million on an industry-wide basis) of
full scale (96 percent) recycle of these wastewaters to further reduce
the discharge of toxic metals is not justified.
While zero discharge is reported to be achieved at some hot forming
operations, the Agency found that many of these systems do, in fact,
have small discharges. The Agency does not believe that zero
discharge can be achieved at all hot forming operations without the
use of costly evaporative technologies. The data for several hot
forming operations demonstrate that wastewater recycle rates of up to
99% are achievable on a long term basis.
Based upon these factors, the Agency has not promulgated BAT
limitations for the hot forming subcategory. As explained in greater
detail in the development document, the final BPT limitations were
revised from those proposed to take into account actual performance of
the BPT technology with respect to suspended solids, oil and grease,
and flow. The Agency has maintained high rate recycle (96%) as the
basis for NSPS since this technology is well demonstrated throughout
the industry and will substantially reduce the total pollutant loading
discharged from the process.
000057
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2. COMMENT . . •,
The industry commented that the Agency should retain its definition oj
"carbon" steels from the March 1976 development document and adopt c
new definition of "specialty" steels.
RESPONSE
In response to this comment, the Agency has reviewed both th<
definition of "specialty" steels contained in the proposed regulatior
and the definition suggested by the commenter. The Agency believes
the commenter's suggested definition, being consistent with industry
usage, is more appropriate and has adopted that definition oJ
"specialty" steels.
3. COMMENT
The industry recommended that the Agency reevaluate its toxic metal
discharge loadings from the hot forming subcategory, notably witt
respect to concentrations reported as being less than the detectable
limit of the analytical methodology.
RESPONSE
The toxic metal loading data for all subdivisions of the hot forminc
subcategory were reviewed and revised accordingly. All loading dat<
are now presented as long term averages as opposed to 30 day average:
based upon the effluent limitations. Concentrations reported as less
than the analytical level of detection have been considered as zero,
The Agency believes that treatment of the data in this fashion ii
appropriate.
4. COMMENT
The industry commented that the pollutant loading data for the hoi
forming subcategory are biased because production weightec
concentrations were not used in developing the loading estimates. Th<
industry contends the overall loadings are overly influenced by small
plants with poor treatment.
RESPONSE
The Agency has analyzed the data and concluded that it would b<
inappropriate to average concentrations on a production weighte<
basis. Effluent quality is unrelated to production and is, in fact,
related primarily to the performance of the wastewater treatmenl
facilities. Since the concern is with the pollutant loading.'
discharged from a facility, the appropriate method for computin<
weighted averages, if necessary, would be on a flow weighted basis
The Agency has computed the flow weighted averages for the exampl<
presented by AISI in its comment (Table 12, p. 167). The following
comparison of the methods for calculating the averages demonstrate;
C00058
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that differences between the flow weighted method and the arithmetic
average method used by the Agency are not significant.
EPA
Average
(Arithmetic)
EPA
Average
(Flow
Weighted)
AISI
Average
(Production
Weighted)
Flow, gal/ton
TSS
Oil and Grease
Lead
Nickel
Zinc
Total Toxic Metals
6,590
1.47
0.28
0.0011
0.0058
0.0015
0.0084
6,590
1.69
0.26
0.0007
0.0073
0.0013
0.0093
6,419
0.78
0.24
0.0011
0.00092
0.0015
0.0035
000059
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In any event, the issue of computing toxic metal loadings for h
forming operations is not particularly relevant, since the Agency h
not promulgated toxic metal limitations and standards for hot formi
operations.
5. COMMENT
The industry commented that not all sources of wastewater flow we
considered for hot forming pipe and tube operations at Plants 068
and 0948A; that some of the data for Plants 0060R and 0684A we:
misinterpreted or incorrect and, that there are no seamless tul
operatons at Plant 0856C.
RESPONSE
The Agency reevaluated the data submitted by the industry for Planl
0060R and 0684A, and made appropriate corrections to its data bas<
For Plant 0856C, the Agency found that operations at this plai
include the manufacture of pressure vessels by seamless pipe methoc
and has kept data for this plant in the data base. The own*
classified the operation as a seamless tube hot forming plant and tl
Agency believes the operation should be classified accordingly becaus
of the manufacturing process used. With respect to Plant 0684H, tl
Agency's contractor could not quanitfy the flow at this plant durii
the sampling survey. However, data reported for this plant by tl
owner were used by the Agency. Reference is made to Table X-12, (
the hot forming subcategory report in the draft development documer
and to Table IX-9 in the hot forming subcategory report in the fin;
development document.
In response to the comment regarding the seamless tube finishing ar«
flows for Plant 0948A, the Agency reevaluated the flow data reporte
by the owner. The Agency did not include the applied flow rate
associated with the seamless tube finishing operations at this plar
(quenching, tempering, and upsetting) in its determination of th
average applied flow for all seamless pipe and tube operations
Because of the inordinately high applied flow rates at this plant fc
these operations, the Agency does not believe it is appropriate t
bias the average rate for all mills with data for a one mill wit
ancilliary operations. Since such finishing operations are practice
at only a few plants and the flow rates at those plants are variable
the Agency has decided that case-by-case determinations should be mac
for those facilities at the permit writing stage.
6. COMMENT
The Agency solicited comments as to whether the carbon and specialt
steel hot forming operations should be subdivided to a greater degre
to account for the differing levels of toxic metal contributed fc
either type of operation. In response, one commenter stated tha
further subdivision is not warranted, since the data showed tha
carbon steel operations occassionally discharged higher loadings c
GOOC60
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toxic metals, and the toxic metal levels in the discharge from both
carbon arid specialty steel operations are similarly treatable.
RESPONSE
The Agency agrees with the commenter. In addition, available data
indicate that after application of the model BPT treatment technology,
the levels of toxic metals in the discharge from both types of
operations are the same. As a result the Agency, has not further
subdivided the hot forming subcategory.
7. COMMENT
One commenter suggested that the Agency use sulfide precipitation for
toxic metals removal from hot forming wastewaters as the model BAT and
NSPS treatment systems.
RESPONSE
The Agency considered sulfide precipitation as an alternative
treatment technology for toxic metals removal. However, this
technology was not selected as part of the BAT model treatment system
since the Agency concluded that toxic metals are effectively
controlled by the BPT model treatment system and, therefore, BAT
limitations are not necessary.
8. COMMENT
The same commenter suggested the Agency did not adequately consider
the transfer of wastewater demineralization technology used to treat
continuous casting wastewaters for the treatment of wastewaters from
hot forming operations. The commenter implies that demineralization
technology could be used to reduce or eliminate the discharge from hot
forming wastewaters.
RESPONSE
The Agency believes demineralization technology is neither appropriate
nor necessary for the treatment of hot forming wastewaters. As noted
above, the Agency has not promulgated BAT limitations or NSPS for
toxic metals for hot forming operations. Demineralization is not
demonstrated for treatment of hot forming wastewaters. Based upon
widespread application in the industry, the Agency found that
sedimentation, clarification, and filtration systems produce water of
sufficient quality for recycle rates of up to 99 percent. Thus, the
application of dimineralization to hot forming wastewaters provides no
significant benefits in terms of effluent quality.
9. COMMENT
The industry commented that the Agency should not use comingling
factors (factors used to adjust the costs of separate treatment
facilities for combined treatment of hot forming wastewaters) to
000061
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estimate the cost of compliance with the proposed BAT limitations fo:
hot forming operations, because the economies of scale realized witi
comingling factors may be offset by site-specific costs. The industr
also commented that its estimated investment costs for industry-widi
compliance with the proposed BAT limitations is higher than tin
Agency's estimate by a factor of 1.4. In making this comment, th<
industry cited estimates prepared by Bethlehem Steel for one plant ai
the basis for its industry-wide estimate. The industry furthei
commented that the Agency's annual cost estimtes are likely to be loi
because the industry believes the cost of capital, depreciation an<
operation and maintenance is likely to be 27% vs. 20% used by th<
Agency for these factors; and, because the Agency overstates mil!
scale credits.
RESPONSE
As noted -above, the Agency has decided not to promulgate the propose*
BAT limitations for hot forming operations. Comingling factors wer<
not used to estimate the cost of compliance with the final BP'
limitations or with NSPS.
Reference is made to the hot forming subcategory report of th<
development document for a detailed cost comparison of actual industrj
expenditures and Agency model based estimates for 24 hot formim
treatment systems. This comparison clearly demonstrates the Agency's
estimated costs for treatment of hot forming operations accurately
reflects actual costs incurred by the industry including site-specifi<
and retrofit costs. With respect to annual costs, the Agency has
revised the operating cost credits allocated to recovery of mill scal<
and modified the capital recovery factor used to estimate annualizec
costs of capital. The revised factor is set out in Volume I of th<
development document and was used to determine annual costs. Th<
Agency believes the use of this factor is appropriate.
10. COMMENT
The industry commented that the cost comparisons for BCT treatment
systems considered for nearly all hot forming operations would nol
pass a BCT cost test based upon $0.27/lb of conventional pollutant
removed.
RESPONSE
As noted in the development document, the Agency has promulgated BC
limitations for hot forming operations that are the same as th<
respective BPT limitations.
11. COMMENT
One commenter questioned the Agency's specification of filtratior
systems for oil and grease removal.
RESPONSE
D062
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The model treatment technology for hot forming operations includes
filtration for suspended solids and oil and grease removal. Most of
the oil removed from hot forming wastewaters is removed at primary
scale pits or in secondary settling systems where oil skimmers are
used. The filters included in the BPT model treatment systems are
capable of removing much of the oil remaining after oil skimming
operations. The Agency agrees with the commenter that filtration
systems cannot be used as a primary oil removal system, particularly
for hot forming wastewaters with high oil levels. Reference is made
to the development document for filter performance data for oil and
grease removal.
000063
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H. SALT BATH DESCALING
1. COMMENT
The industry commented that model treatment system flows for bo
Kolene (oxidizing) and Hydride (reducing) descaling operatioi
operations should reflect the distinction between the type of produi
or operating mode, i.e., batch and continuous operations.
RESPONSE
As set out in detail in the Development Document, the Agency hi
reevaluated the data and found the revised rinsewater flow f<
different products and operating modes are appropriate. Tl
limitations and standards for descaling operations are based up<
these revised flow rates.
2. COMMENT
The industry commented that flow rates used to establish the effluei
limitations must account for the fact that process waters used fc
rinsing the descaled products are also used concurrently for produ<
cooling.
RESPONSE
Since actual rates reported by the industry were used to establi!
model treatment system flow rates and the effluent limitations ai
standards, all uses of the process waters have been taken into accoul
The Agency believes the revised model flow rates are sufficient 1
accomodate concurrent rinsing and cooling of the product. The Agent
does not have any data which demonstrates a need for additional fl<
allowances beyond that provided by the revised flows noted above.
3. COMMENT
The industry commented that the flow data for the only continuoi
hydride operation (Plant 0176) were excluded from the data base. Th«
contend these data should be included and scrubber water flows at thi
plant should also be considered.
RESPONSE
The reducing (hydride) subdivision has been segmented into batch ai
continuous operations. As described in the development document, tl
flow data for Plant 0176 were used as the basis for the model fl<
rate for continuous hydride operations. The scrubber waste at thi
plant was not included in the data base for descaling operations sin<
the scrubber in question is associated with a combination aci
pickling operation the Agency has included the scrubber data in tl
data base for the acid pickling subcategory.
000064
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4. COMMENT
The industry commented that the effluent limitations and standards for
scale removal operations should be based upon data for treatment
systems specific to scale removal operations, rather than on central
treatment plant systems that do not include scale removal operations.
RESPONSE
The proposed limitations were based upon data from several steel
finishing operations. In response to industry comments, the Agency
based the final effluent limitations and standards upon performance
data for a wastewater treatment facility at the Armco Steel - Butler
Works that is used to treat wastewaters from descaling and combination
acid pickling operations. The performance data were submitted as part
of industry's comments, and subsequently supplemented with additional
data submitted by the company at the request of the Agency. Hence,
the basis for the descaling effluent limitations and standards reflect
combined treatment of descaling and combination acid pickling
wastewaters, which is common practice in the industry. The agency
considers wastewaters from these operations to be compatible for
purposes of co-treatment.
5. COMMENT
An industry commenter noted that the Agency did not properly use
central treatment plant data to demonstrate that the proposed BPT
limitations are achievable. This commenter cited the use of data from
Plant 139 as an example of the improper use of such data.
RESPONSE
The Agency agrees that data from Plant 139 are not appropriate to
justify the BPT limitations, because the wastewaters at this plant are
not properly treated. Only a crude treatment system is installed at
this plant. Data for this plant are no longer used to justify the
limitations. However, the Agency has continued to use central
treatment plant data to establish and justify the promulgated
limitations and standards. The Agency believes that effluent data
from properly designed and operated central treatment systems for
compatible wastewaters are suitable for this purpose. As explained
throughout the development document, these treatment systems are
common in the industry. The Agency has structured the final
regulations to facilitate co-treatment of compatible wastewaters by
limiting common pollutants in those subcategories with compatible
wastewaters.
000065
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I. ACID PICKLING
1. COMMENT
The industry commented that the model flow rate for each acid picklinc
subdivision, (i.e., sulfuric, hydrochloric and combination acid),
should be reevaluated to consider discharge rates associated witl
different products and that the subcategory should be furthei
segmented to account for these variations.
RESPONSE
In response to this comment, the Agency reevaluated available flov
data and determined that rinsewater flows are related to product type.
Accordingly, the Agency has resegmented each of the acid picklinc
subdivisions. Separate effluent limitations and standards art
established for the following groups of products: (1) rod, wire anc
coil; (2) bars, billet and blooms; (3) strip, sheet and plate; and (4)
pipe, tube and other products. The model flow rates better reflect
actual rinsewater requirements by product type than did the model flov
rates used to develop the proposed limitations. As discussed in the
development document these model flows were developed using the
production weighted method and included nearly all of the reportec
flow data.
2. COMMENT
The industry commented that the cost and feasibility of retrofittinc
cascade rinse systems to existing pickling lines should be
reevaluated.
RESPONSE
In light of the information submitted by the industry, the Agency has
increased model costs for retrofitting cascade rinse systems. Ir
addition, the Agency has determined that space limitations and the
configuration of certain pickling lines may require major
reconstruction of some lines to permit retrofitting of cascade rinse
systems. This would result in prohibitive retrofit costs. Cascade
rinse systems were, therefore, not selected as the basis for BAT
limitations. The Agency considers retrofit of cascade rinse systems
at acid pickling lines substantially different than retrofitting end-
of-pipe pollution control systems. Cascade rinse systems are
essentially process modifications which substantially alter process
water usage, whereas end-of-pipe treatment systems, including those
with internal and end-of-pipe recycle, do not affect the interna]
workings of the production processes to any great extent. As noted ir
the development document, less expensive rinsing systems now beinc
marketed should provide the opportunity to achieve rinsewater flov
reduction at some pickling lines at less cost than conventional flov
reduction methods. However, because these systems are relatively nev
and sufficient information is not available, the Agency did not use
this technology as model flow reduction systems for BAT at this time.
000066
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As a .result, the BAT limitations are the same as the BPT limitations.
However, 'cascade rinse systems are included in the NSPS and PSNS model
treatment systems, since cascade rinse systems can be designed into
new pickling lines without retrofit problems.
3. COMMENT
The industry commented that the fume scrubber flow allowances should
be reevaluated and flow allowances should be determined on a
site-specific basis at the permit writing stage, since these flows are
independent of production rates.
RESPONSE
The Agency has reevaluated fume scrubber flow data for all acid
pickling operations and concluded that the flow rates are independent
of production, scrubber type, or the air flow rate through the
scrubbers. Fume scrubber wastewaters are commonly recycled to a high
degree. Based upon this review, a model flow rate of 15 gpm (which
represents a blowdown of 15% from recycled fume scrubber systems) was
established. This model flow rate is used as the basis for the daily
mass effluent limitations and standards separately established for
fume scrubbers. The Agency believes it is more effective to establish
uniform limitations in this regulation rather than on a site-specific
basis at the permit level, because the data demonstrate that recycle
of fume scrubbers is feasible at all plants and there is no need to
defer this issue for case-by-case determinations at the permit level.
4. COMMENT
The industry commented that effluent data from carbon steel operations
should not be used to establish toxic metals limitations and standards
for specialty steel operations. The industry suggested the Agency use
data for the Armco Steel-Butler Works as a basis for the appropriate
limitations and standards.
RESPONSE
Based upon this comment, additional effluent data from the Armco Steel
- Butler Works (a specialty steel operation) were obtained. These
data were used to establish toxic metals limitations and standards for
specialty steel operations (i.e., combination acid pickling and salt
bath descaling operations). Effluent data for carbon steel operations
are no longer considered with data from specialty steel operations.
5. COMMENT
The industry commented that the model flow rates for new sources
improperly assumes that flows can be reduced (beyond the rate for
existing sources) by using dirty fume scrubber blowdown as make-up to
the cascade rinse system.
000067
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RESPONSE
Based upon this comment, the Agency has changed its NSPS mode
treatment system to provide for separate mass-based discharges fo
fume scrubber recycle system blowdowns. The Agency no longer include
use of this water as make-up to the cascade rinse system included i
the NSPS model treatment system. The Agency believes, however, tha
the fume scrubber recycle system blowdown can be used, at least on a
intermittent basis, as make-up to the acid tanks, thus minimizing th
discharge.
6. COMMENT
The industry recommended that pickle line wastewater flows should b
reevaluated to develop allowances for flows from wet looping pits
The industry cited a wet looping pit at Plant 0384A with a wastewate
discharge of 108 gpm as demonstrating a need for such an allowance.
RESPONSE
The Agency has not established separate allowances for discharges froi
wet looping pits. Available data indicate that discharges fro:
looping pits are uncommon. The Agency contacted representatives o
Plant 0384A to obtain additional information regarding wet looping pi
flows at this plant. These representatives reported that the flow o
108 gpm for these wet looping pits is unrealistically high and tha
the four wet looping pits at Plant 0384A are now operated on a batci
basis. Water is added to replace water lost through drag-out on thi
product. They also reported that the pits are periodically bate!
dumped. Both the water make-up rate and the frequency of dumping th<
pits were reported to be unknown. The Agency believes that separate
allowances for wet looping pits are not appropriate in most cases
since the discharge rates appear to be minimal in relation to the higl
volume acid pickling rinsewater flows. To the extent additiona.
allowances may be necessary, this should be addressed at the permil
writing stage as a fundamentally different factor variance issue.
7. COMMENT
Two commenters stated that the Agency did not adequately evaluat<
process requirements that affect rinsewater rates for combination aci<
pickling operations. The commenters site such factors as line speed
strip width, strip gauge and multiple strand arrangements that cai
cause wide variations in rinsewater rates at a single process.
RESPONSE
The Agency agrees that these process requirements can affecl
rinsewater rates. However, the Agency believes that all of th<
significant factors were considered in establishing the final effluenl
limitations and standards. The Agency's consideration of thes<
factors resulted in the subdivision and segmentation of the aci<
pickling subcategory as well as in estalishing appropriate flow rates,
GOQG68
-------
As explained in the development document, the subdivision takes into
account the different types of acids used and the process differences
between carbon and specialty steel operations. Segmentation of the
subdivisions takes into consideration the different water usage rates
associated with the various products and processes. The flow
variations that may occur within a particular segment or a specific
pickling line are taken into account by the method used to establish
the model flow rates.
All of the flow data reported by the industry were used to establish
the model flows for each segment. The data submitted by the industry
are typical flows which include flow variations at a single process.
Additionally, since all of the flow data were used to establish the
model flow rates, a broad range of process variations are encompassed
(e.g., line speed, strip gauge) and taken into account. The Agency
believes that appropriate consideration has been given to the factors
that significantly affect rinsewater rates. A more detailed
discussion of this issue is presented in the acid pickling subcategory
report.
8. COMMENT
Two commenters stated that the Agency did not adequately take into
account process differences that affect the amount of acid used per
ton of steel processed. The commenters cited such factors as the type
of acid, and temperature, alloy type and process intended, (i.e.,
removal of scale and surface defects vs. brightening to remove
tarnish.)
RESPONSE
The Agency agrees that process factors including those cited by the
commenters affect the amount of acid used. The Agency has taken these
factors into account. The model spent pickle liquor discharge rates
directly account for the differences in acids and are based upon the
operation that consumes the largest amount of acid. This provides for
conservative spent acid flow rates. The difference in acids has been
addressed in the subdivision of the subcategory by acid type and
different spent pickle liquor flow allowances established for the
three acid subdivisions. The data used to establish the spent pickle
liquor allowances include only those operations where scale and
surface defects are removed. Much lower spent pickle liquor
generation rates for light pickling operations, such as brightening
were not used. The other process factors are taken into account by
the fact that all flows (with the exception of those from light
pickling operations) reported by the industry were used to establish
the model flow rates. The Agency believes that the data base is broad
enough to encompass the process variations raised by the commenters.
The Agency also believes that the model flow rates are sufficiently
generous to account for relatively minor variations that result from
other factors, including acid temperature and the type of steel
pickled.
GGGG69
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9. COMMENT
A commenter stated that the method in which the Agency apportioned th
loads from central treatment plants to demonstrate achievability o
effluent limitations for the acid pickling and scale remova
subcategories is inappropriate. The commenter suggested that tota
effluent loads from a central treatment plant should be compared wit
the aggregate of the BPT limitations for the contributing sources.
RESPONSE
The Agency believes that the method it has used to apportion the tota
effluent load from a central treatment plant is appropriate an
provides an indication of the effluent loads attributable to th
contributing sources. The Agency agrees with the commenter tha
comparing the total effluent load from a central treatment plant wit
the aggregate BPT limitations for the contributing sources is als
appropriate. The Agency has done this for central treatment system
which co-treat compatible steel industry wastewaters and for whic
adequate production data are available to compute the aggregat
effluent limitations. Reference is made to the development documen
for examples. These data indicate the limitations and standards ar
achievable with central treatment systems.
10. COMMENT
The industry recommended that the Agency not include cascade rins
systems in the model treatment systems used to develop the limitation
and standards for combination acid pickling operations. According t
this industry, the technology has not been clearly demonstrated a
combination acid pickling operations.
RESPONSE
The Agency disagrees with this comment. Cascade rinse systems hav<
been installed at combination acid pickling operations at Plant 02561
(4 lines). The Agency considers this plant representative of th<
industry. The Agency also notes that the industry's comments indicate
that cascade rinse systems have been installed on the combination aci<
pickling operations at Plant 0060. Although the Agency has no flo<
data for these plants, the Agency believes that the model flow rate:
are achievable by the use of cascade rinsing. The Agency also note:
that the model flow rates are being achieved at other plants in th'
combination acid pickling subdivision. Thus, although the Agency hai
used cascade rinsing as the model technology for flow reduction, othe
methods are available to the industry.
Furthermore, cascade rinsing is well demonstrated for both sulfuri<
and hydrochloric acid pickling operations and the technology ai
applied to combination acid pickling operations is not different
Based upon the widespread use of this technology, the Agency believe:
that equal or better product quality can be maintained. As noted ii
the development document, other acid pickling rinse systems with
OOG070
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discharge, rates can be applied to new sources. Accordingly, the
Agency based the NSPS and PSNS upon model treatment systems that
include cascade rinse systems. As noted above, the Agency has not
based the limitations and standards for existing sources upon this
technology.
11. COMMENT
One commenter stated that the data from one of the plants (Plant U)
should not have been used to demonstrate the achievability of the BPT
effluent limitations for metals since the pH of the discharge was 10.4
standard units.
RESPONSE
The Agency disagrees with the commenter. The Agency does, however,
agree that the pH does exceed the allowable range of 6.0 - 9.0, and
the discharge will have to be acidified to achieve compliance. This
will have no effect on the levels of toxic metals present in this
discharge, since the sample measurements are made for total metals.
The effluent limitations for metals are also established on the basis
of total metals. Acidification may change the relative proportion of
particulate and dissolved metals. However, the level of total metals
will remain unchanged.
12. COMMENT
One commenter stated that effluent limitations should not be
established for fluorides at combination acid pickling operations.
The commenter further noted that additional treatment may be needed at
certain central treatment plants to comply with the proposed fluoride
limitation, and that the benefits of minimal incremental removal would
not justify additional treatment.
RESPONSE
The Agency has not established effluent limitations for fluorides, as
it believes that the limitations established for toxic metals will
effectively control the discharge of fluorides. The same treatment
technology (lime precipitation) used to remove toxic metals, will also
remove fluorides.
13. COMMENT
A commenter stated that the Agency was incorrect in identifying
certain plants (Plants 121, 0 and C) that did not support the BPT
limitations as having inadequate treatment. The commenter noted that
the information presented in the Development Document indicated that
these plants do have adequate treatment.
RESPONSE
0071
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The Agency agrees with the commenter that the treatment compohent
installed at Plants 121, 0 and C are adequate, in'that'they ar
consistent with the model treatment system. However, the Agenc
believes that these treatment systems are not properly operated, ar
thus the wastewaters are not adequately treated. In the case of Plar
C it is clear from the plant diagram in Section VII that the aci
rinsewaters were by-passing the neutralization/precipitation step c
the treatment system. The effluent data in Section VII demonstrat
the discharge was not being properly treated. The effluent was acidi
(average pH of 5.0) and as a result contained high levels of toxi
metals. At Plant 0 the sampling conducted by the Agency showed highe
levels of chromium (2.66 mg/1) and copper (0.11 mg/1) in the effluen
than in the influent to the treatment system. Additionally, samplin
conducted at this same plant at subsequent dates to acquire data fc
salt bath descaling operations show much lower levels of chromium i
the effluents, despite the much higher influent concentrations. Thus
the Agency does not believe that the data in Section VII of the aci
pickling subcategory report for this plant are representative of th
capability of this treatment facility. The same discrepency i
effluent quality was observed at Plant 121, during two separat
surveys.
14. COMMENT
One commenter claimed that the use of caustic in fume scrubbers t
achieve state air pollution requirements could result in fouling o
plugging problems if high fume scrubber recycle rates are practiced.
RESPONSE
The Agency believes that the limitations and standards for fum
scrubbers can be achieved at all plants including those operated wit
caustic. However, to the extent a state air pollution requiremen
would require operating practices that would preclude the attainmen
of the fume scrubber limitations and standards, the owner or operate;
could apply for a "fundamentally different factors" variance on tha1
basis.
15. COMMENT
One steel company commented that excess quench water from <
combination acid pickling operation was not considered by the Agenc;
in developing the limitations and standards for those operations.
RESPONSE
The Agency re-evaluated the information submitted by the company foi
this plant and found that all reported wastewater flows were includec
in the development of the limitations and standards. However, th<
company did not specifically list excess quench flows as a process
wastewater flow at this plant. Nevertheless, if there are process
wastewater flows not considered by th- ' Agency in developing th«
regulation, the discharger may seek allowances for these flows at th€
000072
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NPDES permit level through a "fundamentally different factors"
variance.'
G00073
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J. COLD FORMING
1 . COMMENT
The industry commented that flow data for one-stand cold rolling mill
should not be included in the data base for multi-stand mills, sine
the one-stand flow rates are much lower. The industry requested
separate subcategory for one-stand cold rolling mills.
RESPONSE
In response to this comment, cold rolling flow data were reviewed an
the recirculation and direct application subdivisions have bee
segmented to separately account for the one-stand operations. Sine
combination mills necessarily have more than one-stand, no separat
segment has been established for this subdivision.
2. COMMENT
The industry commented that the BPT and BAT model flow rates fo
application mills have been established at such low levels tha
production of certain cold rolled products may be discontinued as
result.
RESPONSE
The Agency evaluated all of the information provided by the industr
on this issue. Unfortunately, the Agency did not receive any detaile
information or data from the industry during the comment perio
despite a specific request for data and documentation of the data (4
FR 1874). Aside from that request for information, the Agency sent
supplemental request to the American Iron and Steel Institute whic
was responded to by Bethlehem Steel. That response indicates tha
Bethlehem Steel may have problems achieving the model flow rates a
two plants with direct application mills, primarily because of th
thickness reduction achieved on these mills and the volume of solutio
required for product cooling and cooling of the work rolls. As se
out in the development document, the Agency compared the thicknes
reduction obtained at several mills with the respective flow rates a
those mills. This comparison led the Agency to conclude that th
model discharge flows for cold rolling operations are appropriate an
that they can be achieved at most, if not all plants, without produc
quality related problems.
The high flows experienced at some mills are not always related t
product requirements, but instead result from the continuous discharg
of wastewater during periods when products are not being rolled. I
addition, cold rolling mills are not devoted to the production of
single product. The product can vary on a day-to-day basis, and eve
within shifts on a given day. Therefore, if the water/oil applicatic
rates are related to the type of product being rolled as the industr
contends (the data available to the Agency does not support thi
contention), the discharge rates will vary over the same time period
000074
-------
As a,result the high flows associated with one product will be offset
by low flows associated with another product. Nevertheless, should a
particular mill or product requirement necessitate continuous use of
higher volumes of water or oil solutions, such unique situations are
more appropriately addressed on a case-by-case basis in a
"fundamentally different factor" variance proceeding at the permit
writing stage.
\
3. COMMENT
The industry commented that toxic organic pollutants should not be
limited since those pollutants appeared at levels higher than those
used to develop the proposed limitations in the effluent from only one
plant. Another commenter recommended that the Agency sample
additional cold rolling operations to better quantify the presence and
magnitude of toxic organics in the discharge from these operations.
RESPONSE
The Agency sampled raw wastewaters, and treated and partially treated
effluents at 26 different cold rolling and cold worked pipe and tube
mills. The cold rolling plants included recirculation, combination
and direct application mills. The resulting data demonstrate
pervasisive contamination of waste oil solutions and effluents by
toxic organic pollutants. Thirty different toxic organics were found
at significant and treatable levels at the 26 mills sampled. These
pollutants were present at varying levels and diversity among the
mills. The waste oils from only two operations (an electric weld tube
mill and a plant that contract hauled its waste oil and had no
discharge) showed no contamination. These data clearly demonstrate
the widespread nature and diversity of toxic organic pollutant
contamination and the need for control of these pollutants.
Limitations were promulgated for two toxic organic pollutants
(naphthalene and tetrachloroethylene) for each cold rolling sudivision
(i.e., recirculation, combination and direct application), rather than
the four toxic organic pollutants included in the proposed regulation
for the recirculation subdivision. Naphthalene and
tetrachloroethylene are common in most cold rolling and cleaning
solutions.
Naphthalene is the most commonly found toxic organic pollutant. It
was found in the wastewaters at 50% of the plants sampled at levels
greater than 0.10 mg/1, which is the concentration basis for the
effluent limitations. Levels up to 165 mg/1 were found.
Tetrachlorethylene is a solvent used for cleaning the oil systems at
cold rolling mills. It was found in the wastewaters at one-third of
the plants. The limitations for tetrachloroethylene (concentration
basis of 0.15 mg/1) are established to control the indiscriminate
dumping of cleaning solutions.
Due to the wide variation in toxic organic pollutants the Agency does
not believe that naphthalene and tetrachloroethylene can adequately
serve as indicators for other toxic organic pollutants found in these
000075
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wastewaters. Rather, the Agency has excluded the other toxic ; organi
pollutants from this regulation pursuant to Paragraph VIII of th
Consent Decree. This will allow permit writers to establis
site-specific limitations for toxic organic pollutants on a case h
case basis. NPDES permit writers are advised to completely revie
toxic organic pollutants associated with cold rolling operations on
site-specific basis prior to finalizing NPDES permits/ ar
periodically thereafter, to ensure adequate control is provided fc
all toxic organic pollutants
4. COMMENT
The industry commented that BAT limitations more stringent than BE
limitations should not be promulgated since toxic organic pollutant
were found at high levels at only one plant and the proposed BA
treatment technology does not effectively remove toxic metals.
RESPONSE
The Agency has promulgated BAT limitations which are the same as th
BPT limitations for toxic pollutants. The BPT model treatmer
technology is the same as used to develop the proposed limitations
Contrary to the comment and as noted above, toxic organic pollutant
were found in the wastewaters at many plants at treatable levels
Through extensive sampling at a plant that has the BPT model treatmen
technology installed, the Agency determined that this technolog
provides adequate control for the toxic organic pollutants for whic
limitations have been established. As a result, no treatment beyon
BPT is required for these pollutants. Site-specific effluen
limitations may be established for other toxic organic pollutants tha
may be present in these wastewaters as explained above.
5. COMMENT
The industry commented that the data base used to establish the zer
discharge requirement for cold worked pipe and tube operations usin
water improperly includes mills that use soluble oil rather tha
water.
RESPONSE
Those mills using soluble oils have been deleted from the data bas
for mills using water. However, zero discharge is achieved at six ou
of the remaining 15 mills using water. THe zero discharge mill
account for 40% of those mills using water for which flow data wer
reported.
6. COMMENT
The industry commented that due to the extreme variation of proces
flow rates, the zero discharge requirement is not appropriate for col
worked pipe and tube operations using water, and this subdivisio
should be further segmented on a flow basis.
000076
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RESPONSE
The process flow rate should not by itself affect the ability to
recycle the wastewater. The Agency received flow data for 15 mills;
zero discharge was reported for six mills. The Agency believes these
zero discharge plants have good water management practices. The nine
plants that discharge wastewaters have wide variations in flow. The
highest flows are associated with plants that are operated in a
once-through mode. Partial recycle is practiced at other plants. The
Agency has determined there are no factors that distinguish these
plants from those that have higher rate recycle and achieve zero
discharge. The Agency believes that zero discharge can be achieved at
those plants with discharges. Hence, the Agency believes it is not
appropriate to further segment the cold worked pipe and tube
subdivision tc accomodate those operations.
7. COMMENT
The industry commented that the proposed BAT limitations which were
based upon filtration of wastewaters from cold rolling mills are based
upon inadequate data, and additional sampling of other cold mill
wastewater filtration systems are necessary.
RESPONSE
Filtration is no longer used as the model BAT treatment technology for
cold rolling operations. The BAT limitations are the same as the BPT
limitations, which are based upon a model treatment system that
includes dissolved gas flotation.
8. COMMENT
The industry commented that new source requirements should be
established for each type of cold rolling mill (i.e., recirculation,
combination and direct application), rather than restricting all new
source cold rolling operations to recirculation mills.
RESPONSE
The Agency has established NSPS and PSNS for each type of cold rolling
mill. This will provide industry the flexibility to install
facilities it believes is best suited for the intended purposes. The
model treatment technology is the same as the model BPT and BAT
technology. However, the model flow rates are based upon the better
operated recirculation, combination, and direct application mills.
9. COMMENT
One steel company commented that two of its cold worked pipe and tube
operations were incorrectly classified as hot forming operations.
000077
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RESPONSE
In response to this comment, the designation of the mills in questioi
has been changed to indicate that they are cold worked pipe and tub*
operations.
10. COMMENT
Another steel company commented that two of its cold roll in;
operations were incorrectly classified as recirculation mills when ii
fact they are direct application mills.
RESPONSE
As a result of this comment, the cold rolling data base has bee)
revised to reflect the reclassification of these two cold rollin<
operations.
11. COMMENT
One commenter suggested that EPA encourage the use of "clean oils
(oil solutions free of the toxic organic compounds) for cold formini
operations.
RESPONSE
As indicated in the responses to previous comments, the Agency foum
that most rolling solutions are highly contaminated with toxic organii
pollutants. The Agency continues to encourage the use of rollim
solutions that are free of contamination of toxic organic pollutants
to the extent possible. However, the Agency did not promulgate
limitations and standards on the basis of substituting clean rollim
solutions for contaminated solutions at all mills because it does no
have sufficient information and data to determine that "clean
solutions can be substituted for those solutions formulated with toxii
organic pollutants. As a result, the Agency has promulgated effluen
limitations and standards for certain toxic organic pollutants base<
upon emulsion breaking and dissolved gas flotation of cold rollim
wastewaters. The limitations and standards for these pollutants, an<
those for other toxic organic pollutants that may be established a
the permit level may be achieved through the use of "clean" rollim
solutions.
12. COMMENT
One commenter indicated that EPA did not consider sulfid
precipitation as a BAT option for cold forming operations. Th
commenter stated that lower solubilities of metal sulfides, as oppose
to hydroxides, would result in better removal of toxic metals.
RESPONSE
000078
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The Agency has not considered sulfide precipitation as an alternative
BAT' treatment system since the toxic metals found in cold forming
wastewaters are principally present as metal oxides. Other forms of
toxic metals are found when wastewaters from pickling operations are
used to break the oil emulsions. In subsequent treatment of the
oily-wastewater, lime is added to neutralize the wastewater prior to
dissolved gas flotation. As a result, toxic metals are precipitated
as metal hydroxides. The Agency has determined that in treating acid
pickling wastewaters, sulfide precipitation does not result in
substantially more removal of toxic metals than precipitation with
lime. This finding is applicable to this subcategory since the toxic
metals amenable to precipitation generally originate in the acid
pickling wastewaters used to treat cold forming wastewaters.
13. COMMENT
One commenter contended that the Agency did not consider magnetic
separation as an alternate BAT technology for cold rolling operations.
RESPONSE
The Agency did not consider magnetic separation as a alternate cold
rolling wastewater treatment technology since emphasis was placed on
those technologies for which adequate performance data are available.
The technologies considered by the Agency are capable of removing
toxic metals to low levels. The Agency limited its review in this
fashion to maintain a manageable list of alternate treatment
technologies. The Agency is aware that magnetic separation is used at
some recirculation mills to remove the scale {iron oxide particles)
from the oil solutions prior to reuse. However, since toxic metals
are not magnetic, these pollutants will be removed only to the extent
that they are bound with the iron oxides. As a result, it is unlikely
that magnetic separation will remove toxic metals to a greater degree
than achieved by the alternate treatment technologies considered by
the Agency.
14. COMMENT
The industry commented that the limited data presented in the
development document for the proposed regulation show that wastewater
from combination mills do not contain any organic or metallic priority
pollutants. Therefore, the industry recommends that BAT be set equal
to a "proper" BPT.
RESPONSE
As pointed out above, additional sampling at several cold rolling
mills was conducted after the proposed regulation was issued to
provide an expanded data base on the presence of toxic pollutants.
Six additional combination operations were surveyed by the Agency.
Data gathered during these surveys confirm that untreated wastewaters
from combination mills contained high levels of toxic organic
pollutants and toxic metals. Concentrations of toxic organic
OOGC79
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pollutants as high as 26.2 mg/1 were detected in the raw wastewaters
Additionally, toxic metals were detected in the wastewater at elevate
levels. Limitations and standards have been promulgated for certai
toxic pollutants at the BPT, PSES, PSNS, and NSPS levels of treatment
The ability to control toxic pollutants common in cold rollin
wastewaters is demonstrated for the model treatment technologies.
15. COMMENT
The industry disagreed with the zero discharge standard proposed fo
cold worked pipe and tube operations using oil solutions. Th
commenter states that this limitation ignores the future effect o
RCRA regulations on the disposal of oily wastes.
RESPONSE
The Agency has retained the zero discharge requirement for cold worke
pipe and tube operations using oil. The model treatment system fo
these operations includes a recycle system for the soluble oil with
blowdown of 0.5 gal/ton. This blowdown is stored and periodical!;
hauled off-site for disposal, so there will be no discharge ti
navigable waters from these operations. The Agency has taken int<
account the costs for disposing of these wastewaters by contrac
hauling. These costs are included in the annual operating costs fo
this subdivision. Approximately 79% of the cold worked pipe and tub
using soluble oils presently have spent oil solutions hauled off sit
for disposal.
As described in the development document, the Agency evaluated a
alternate treatment system based upon treatment and discharge of thes
wastewaters. The capital and annual costs for this alternat
treatment system are significantly higher than the costs for achievin
the zero discharge standard. Moreover, sludge with characteristic
similar to the oily waste is produced as a result of treatment
Disposal of this sludge requires the same considerations as disposa
of the oily wastes. Hence, the commenters concerns would not b
alleviated by providing for treatment and discharge of wastewater:
from cold worked pipe and tube operations.
16. COMMENT
The industry commented that the Agency should consider establishin
limitations and standards on the basis of the surface area o
products.
RESPONSE
The Agency considered this comment and found that the necessary dat
are not available to establish limitations and standards for col'
rolled or coated products in the steel industry. The industr;
generally does not keep detailed surface area records and the Agenc;
OOGG80
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believes it would be burdensome for both the industry and the Agency
to keep and track such data.
ooocei
-------
LL. ALKALINE CLEANING
1. COMMENT
The industry commented that the BPT model flow rate of 50 gal/ton is
inconsistent with the data base, which contains flows up to 20 times
that amount, particularly, since flow reduction systems are not
included in the model treatment systems.
RESPONSE
The Agency has reevaluated all flow data for alkaline cleaning
operations. The subcategory has now been separated into batch and
continuous subdivisions to better reflect the rinsewater flow
differences due to operating modes, and indirectly, the different
products. The model flow rates used as the basis for the limitations
are 250 gal/ton and 350 gal/ton for batch and continuous operations,
respectively. These flows are the averages for all plants in the
respective subdivisions with flow rates less than 1000 gal/ton. Based
upon its review of the flow rates reported for different products and
modes of operation, the Agency concluded that at lines with flows
higher than 1000 gal/ton, water conservation is not practiced to any
significant degree and is not representative of plants employing good
water conservation practices.
In batch operations, 27 lines have reported flow rates ranging from 0
to 8000 gal/ton with an average of 1067 gal/ton. Lines with flows
less than 1000 gal/ton (20 lines; 75%) have an average flow of 236
gal/ton. A flow rate of 250 gal/ton was used as the basis for the
limitations. Thirteen of the lines (48% of all lines) have reported
flows of less than 250 gal/ton. In continuous operations 84 lines
have flow rates ranging from 1 to 16,899 gal/ton with an average of
114^0 gal/ton. Lines with flows less than 1000 gal/ton (62 lines> 75%)
have an average flow of 351 gal/ton. A flow rate of 350 gal/ton was
selected for continuous operations. Thirty-four lines (40%) have
reported flows of less than 350 gal/ton.
The Agency believes the selected flows can be achieved at all lines
with proper attention to water application rates; and, based upon
those batch and continuous lines operated at flows less than 250
gal/ton and 350 gal/ton, respectively, product quality will not be
adversely affected at those flows.
2. COMMENT
The industry commented that the effluent limitations should be based
upon a concentration of 25 mg/1 for total suspended solids and that
there should be no restriction on flows, since toxic pollutants are
not discharged from alkaline cleaning operations.
000082
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RESPONSE
The Agency agrees that the quantities of toxic pollutants added t
process wastewaters from these operations are not significant. Th
Agency has concluded that it is appropriate to base the 30-day averag
mass effluent limitatiupons upon 30 mg/1 for total suspended solid
(and 10 mg/1 for oil and grease) and the model flow rates describe
above. The model total suspended solids concentration was set at 3
mg/1 to conform to the limitations for other finishing operations.
Wastewaters from nearly all nearly all alkaline cleaning operation
are treated jointly with wastewaters from other steel finishin
operations in central treatment systems. Large uncontrolled volume
of wastewaters from this source would dilute the wastewaters fro
other sources, potentially resulting in increased discharges of toxi
metal pollutants from central treatment systems. Thus, the Agenc
believes it is appropriate to establish mass-based effluen
limitations and standards for alkaline cleaning operations.
OOOC83
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L. HOT COATING
1. COMMENT
The industry commented that the BAT model flow, which is based upon
cascade rinsing and fume scrubber recycle to reduce the discharge
volume, has not been demonstrated. Consequently, it suggests that BAT
model flow be set at the same level as the BPT model flow.
RESPONSE
As it did for pickling operations, the Agency reevaluated the cost and
feasibility of retrofitting cascade rinse systems at existing hot
coating operations. The Agency has concluded that unlike all end-of-
pipe model treatment systems, cascade rinse systems are actually
process modifications. The space limitations and configurations at
some hot coating lines, may preclude the installation of cascade rinse
systems at all existing lines without major reconstruction. For that
reason, the Agency believes that the cost of installing the system
would be substantially higher than originally estimated. The Agency
adjusted its costs for cascade rinse systems based upon data submitted
by the industry, but the Agency has no basis to estimate the
significantly higher reconstruction costs that may be required at some
facilities. These considerations lead the Agency to delete cascade
rinsing as a basis for the BAT limitations. The final BAT limitations
are the same as the BPT limitations for those hot coating lines
without fume scrubbers. These limits are based upon once-through
flows for rinsewaters. NSPS are, however, based on the use of cascade
rinsing or other demonstrated flow reduction technologies.
The Agency promulgated separate limitations and standards for fume
scrubbers, since these dischargers are independent of production rate,
scrubber type and gas flow through the scrubbers. These allowances,
which are established as the quantity of pollutant allowed to be
discharged per day, are to be added to the limitations for other
wastewaters from hot coating lines when the NPDES permit is being
written. The BPT model treatment system is based upon once-through
flow, while at BAT, the model treatment system includes 85% recycle of
these scrubber wastewaters. Recycle of fume scrubbers at that rate is
demonstrated at several hot coating operations, as well as at many
pickling operations. The BAT limitations for hot coating operations
with fume scrubbers reflect this flow reduction.
2. COMMENT
The industry commented that the Agency's model cost estimate for
cascade rinse systems is understated.
RESPONSE
The Agency has reviewed its cost for cascade rinse and agrees that the
costs used for the proposed regulation are low. As noted above, the
Agency evaluated the cost data submitted by the industry, and, based
000084
-------
upon those costs, the model costs for cascade rinse systems wer
increased.
3. COMMENT
The industry commented that the Agency has not presented informatio
demonstrating cascade rinse systems for hot coating operations; tha
product quality considerations may preclude the use of cascade rins
systems; that the Agency should establish the BAT model treatmen
system flow rate equal to the model BPT flow rate; and the Agenc
should base the limitations and standards on published solubility dat
for toxic metals.
RESPONSE
As noted above, the Agency promulgated BAT limitations that are th
same as the respective BPT limitations for those hot coatin
operations without fume scrubbers. Recycle of fume scrubbe
wastewaters is the model BAT technology for those hot coatin
operations with fume scrubbers. As set out in the developmen
document, this technology is well demonstrated in the hot coatini
subcategory. For new sources, the Agency included rinsewater flo'
reduction in the model treatment systems. As set out in th<
development document, rinsewater flow reduction to the level specifier
by the Agency is well demonstrated in the industry for all produc
types. Thus, product quality considerations evidently do not affec
the ability to operate at the NSPS model flow rates or less. Fo
costing purposes, the Agency developed alternative BAT and NSPS mode
treatment systems and BAT industry-wide costs on the basis of cascad
rinse systems. The Agency believes it has developed conservativ
costs in this manner.
With 'respect to the effluent quality used to develop and demonstrat
the achievability of the limitations, the Agency believes the us
central treatment plant data is appropriate provided that the centra
treatment plants are treating compatible wastewaters (as set out ii
the preamble to the regulation), and the treatment facilities ar<
properly designed and operated. For reasons set out in the preamble
the Agency has determined that the limitations and standards must b<
based upon total rather than soluble metals, and that publisher
solubility data are not representative of industry performance an<
thus are not appropriate for developing effluent limitations an
standards. Based upon widespread demonstration in the industry, th
Agency believes the limitations and standards are achievable at plant;
that are properly designed and operated. Proper operation include
minimization of dragout from pickling and hot coating operation
through proper maintenance of wringer rolls, etc.
OOG085
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GENERAL COMMENTS
1. COMMENT
The Agency received several comments regarding the use of "indicator"
pollutants in the proposed regulation. The industry commented that
the use of indicator pollutants should be expanded and offered the
following specific examples:
(a) Phenols (4AAP) should be used as an indicator for all toxic
organic pollutants found in cokemaking wastewaters.
(b) Total suspended solids should be used as an indicator for
toxic metal pollutants in several subcategories.
Environmental groups, on the other hand, suggested the Agency limit
more, or in some cases, all of the toxic metal and toxic organic
pollutants found in steel industry wastewaters to insure adequate
control of those pollutants. One industry commenter requested all of
the methodologies and associated correlation data and statistical
analyses used by the Agency in developing its proposed use of
indicator pollutants.
RESPONSE
The Agency carefully considered these comments and has determined that
its general approach with respect to the use of indicator pollutants
in the proposed and final regulations is appropriate. The Agency
relied heavily upon its engineering judgment in establishing the
indicator pollutants. This engineering judgment included
consideration of the nature and chemical properties of the pollutants
present in the wastewaters, the treatability of these pollutants, and
the model treatment system involved. For example, where toxic metals
were found at treatable levels, the Agency established limitations for
two of the toxic metals. The limitations for these metals will
require the installation and proper operation of the necessary
treatment systems, which in turn ensures that other toxic metals, as
well as other pollutants amenable to the same treatment are
effectively removed.
In selecting and using indicator pollutants, the Agency gave highest
consideration to insuring that adequate control is provided for toxic
organic and toxic metal pollutants found in steel industry
wastewaters. As set out in the development document and in response
to several comments, this cannot be done by using suspended solids as
an indicator. Instead, the Agency established limitations for certain
toxic pollutants with characteristics similar to other toxic
pollutants. Thus, the Agency believes the toxic pollutants not
directly limited will be adequately controlled. Consideration was
also given to developing a common list of limited pollutants for those
subcategories with compatible wastewaters to facilitate more cost
effective co-treatment, where appropriate; and finally, the Agency
restricted the number of limited toxic pollutants to foster
000086
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development of practical monitoring programs for the industry that cai
be implemented through NPDES permits at reasonable costs.
The Agency used indicator pollutants for the regulation in th<
following instances:
a. Cokemaking Operations
Phenols (4AAP) is used as an indicator for the acid fractioi
toxic organic pollutants found in cokemaking wastewateri
Benzene, and benzo(o)pyrene and naphthalene are used a:
indicator pollutants for volatile and base neutral toxi<
organic pollutants, respectively. The Agency consideret
whether or not phenols (4AAP) would be an appropriat<
indicator for all toxic organic pollutants found ii
cokemaking wastewaters. However, available data for th<
model BAT biological treatment facility show no correlatioi
between the effluent levels of phenols (4AAP) and th<
volatile and base/neutral toxic organic pollutants
However, those data do show a relationship between the thre<
limited toxic organic pollutants and other pollutants ii
their respective classes. Thus, the Agency does not believ<
that phenols (4AAP) can serve as an effective indicator foi
all toxic organic pollutants found in cokemakini
wastewaters.
b. Toxic Metals in Other Subcategories
Lead and zinc are used as indicators for toxic metals foi
all but the specialty steel finishing operations. For thos<
operations, chromium and nickel are indicators for the othei
toxic metals. The Agency believes these metals ar<
effective indicators as demonstrated by the monitoring dat<
presented in the development document. The Agenq
considered total suspended solids as an indicator for toxi<
metals but found that total suspended solids is a pooi
indicator for toxic metals, notably when these metals an
present in the dissolved state or as fine particulates.
The Agency believes its approach to indicator pollutants is consisten
with the requirement to effectively regulate toxic pollutants, and
yet provide for reasonable limitations and monitoring requirements
Alternatively, the Agency would have to specifically limit all toxii
pollutants, placing an unmanageable monitoring burden on industry and
in some cases, restricting co-treatmant of compatible wastewaters
The Agency suggests that it would be appropriate for permit writers t<
require dischargers to conduct confirmatory monitoring for a brie:
period of time to ensure that there are no unique plant-specifL
factors which would prevent the effective use of indicator pollutant:
at individual plants. While the Agency is confident that it:
"indicator" policy effectively controls the discharge of all treatabL
toxic pollutants found in subcategory wastewaters, it also believe:
that this confirmatory analysis is appropriate.
OOOG87
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2. • COMMENT
One commenter recommended that the Agency closely review the validity
of the statistical formula used to determine the daily maximum
variability factor which is used to establish the daily maximum
effluent limitations. The commenter was unable to derive the formula.
RESPONSE
The Agency has reviewed the statistical formula in question and
believes it is valid for determining the daily maximum varibility
factor. The techniques used to define the formula for the daily
maximum variablity factors are based upon well known and widely
applied statistical methodologies. The derivation of the formula
which was referenced in the development document, can be found in
Appendix XII-A1 (pp. 415-417) in the Development Document for
Existing Source Pretreatment Standards for the Electroplating Point
Source Category, EPA 440/1-79/003, August 1979.
3. COMMENT
One commenter questioned the use of different methods to calculate the
daily variability factor; why 100 observations was chosen as the
criterion for different methods of analysis; how well the
statistically calculated 99th compares with the observed 99th
percentile for plants with greater than 100 observations; and, if
there are noticeable differences in this comparison, what is the
Agency's rationale for using the nonparametric technique to establish
the daily maximum limitations as opposed to the statistical method.
RESPONSE
The points raised in this comment are discussed in Appendix A of
Volume I of the development document. For plants with over 100
observations the nonparametric technique of the empirical distribution
function was used to estimate daily limitations. The empirical 99th
percentile used to obtain the daily limits was calculated according to
the following definition given by J. Gibbons.* The qth percentile is
the estimated effluent concentration of rank r (ranked from smallest
to largest such that
r = n x q if (n x q) is an integer
{(n x q) + 1} if (n x q) is not an integer
where { } means to take the largest integer not exceeding the quantity
in the brackets and n is the total number of observed effluent
concentrations. For example, if n = 100 and q = 0.99, r = (100)(0.99)
= 99 and the 99th percentile is estimated by the 99th largest (of the
100) value. If n = 225 and q = 0.99, r = {(225H0.99) + 1) = {222.75
+ 1 } » {223.75} = 223 and the 99th percentile is estimated by the
223rd largest (of the 225 values). Using this definition a plant
would require at least 100 effluent observations for the empirical
OOOC88
-------
99th percentile not to be the largest of the observations. Therefore
100 observations were considered the minimum number to be used i:
estimating the daily variability factor using nonparametrii
techniques.
When the number of observations were less than 100, a parametric mode
(in this case, the lognormal) was used to estimate the 99tl
percentile. It has been shown that the assumption that the pollutan
effluent data are lognormally distributed is reasonable {see page 26
and Figures A-l through A-4 of the development document as well a:
Appendix A of the development document for Electroplatim
Pretreatment, EPA 440/1-79/003). This model has been used ' an<
supported in the development of several categorical standards and ha:
been generally accepted by industry.
In response to this comment, the Agency completed a compaison betweei
the two methods used to calculate the 99th percentile for plants witl
more than 100 observations. For most plants, the two methods compar<
favorably. At several plants the actual 99th percentile is lesi
stringent than the calculated values, while at the remaining plant:
the 99th percentile value is more stringent than the calculate*
values. Since the comparison showed there was no bias to eithe;
method, the Agency has continued to use the 99th percentile value fo:
plants with more than 100 observations. The agency believes that thi:
nonparametric statistical estimation technique is a valid an*
appropriate method for developing achievable concentration levels.
*Gibbons, Jean, Nonparametric Statistical Inference, McGraw Hill,
4. COMMENT
The same commenter stated the Agency has made no effort to rationaliz
its selection of the 99th percentile for calculating daily maxima an<
95th percentile for calculating 30-day averages.
RESPONSE
The selected percentiles have been used by the Agency in setting man;
of the categorical limitations and standards, and, in fact have bee
recommended and used by the industry for NPDES permits. Th
justification for using the 99th and 95th percentiles are presented i
Appendix A of the development document.
OOOG89
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5.. COMMENT
Several commenters were received from the industry that the Agency's
solid waste disposal cost of $5.00/ton is understated, notably with
respect to disposal of solid wastes considered hazardous under RCRA.
The industry presented several alternative estimates ranging from
$13/ton to $200/ton for disposal.
RESPONSE
In response to these comments, the Agency reevaluated solid waste
disposal costs and determined that a cost of $5/ton is a
representative cost for disposal of non-hazardous solid wastes for
large industries. The Agency agrees, however, that a disposal cost of
$5/ton for hazardous solid wastes as defined by RCRA is understated.
Accordingly, the Agency evaluated information submitted by the
industry and material prepared by the Agency's Office of Solid Wastes.
The Agency based its hazardous solid waste disposal cost estimates
($18/ton) upon information developed by the Agency's Office of Solid
Waste and by information submitted by the industry, particularly
information submitted for Plant 0320, which the Agency found to be
representative of steel industry operations. As set out in the
development document, the Agency reevaluated solid waste generation
rates for each subcategory, and made revisions to its estimates, where
appropriate.
6. COMMENT
One commenter indicated that the equation used to describe sulfide
precipitation presented in Volume I of the draft development document
is incorrect.
RESPONSE
The Agency agrees. The appropriate corrections have been made in the
development document.
7. COMMENT
One commenter states that because the proposed PSES are identical to
the proposed BAT, there is no reason for indirect discharges to
continue discharging to POTW systems; that POTW operations could fall
below optimum efficiency due to loss of hydraulic loading; and, some
POTWs could lose revenue from the indirect dischargers that would no
longer discharge to the POTWs. The commenter states that these lost
revenues would have to be made up by local residents.
RESPONSE
The Agency has promulgated PSES that are the same as the BAT
limitations for all steel industry operations except for cokemaking,
where the PSES are based upon the same type of pretreatment the
industry provides for its on-site biological treatment systems. As
G8G030
-------
set out in the development document, the Agency has determined tha
these PSES will prevent pass through of toxic pollutants at POTWs to ,
significantly greater degree than would occur if steel industr
wastewaters were discharged to POTWs untreated. In certain cases
indirect dischargers may find it less costly to discharge directly an<
comply with the applicable BAT limitations than to comply with th
PSES and continue discharging to POTWs. However, the Agency note:
that indirect dischargers will be able to obtain credits for th
pollutant removals experienced at POTWs and may therefore, find i
less costly to be discharged to POTWs. Based upon the numbers am
types of indirect steel industry discharges, the Agency does no
expect POTW operations to fall below optimum efficiency because of th<
lack of hydraulic loading from the steel industry. If anything, les:
hydraulic loading would be a benefit at many POTWs, notably those tha
are being operated at or beyond their design capacity and those witl
combined sewerage systems. While the Agency cannot argue that no POT1
may lose revenues because of less steel industry indirect discharges,
this would not affect the Agency's decision on promulgating PSES thai
minimize pass through of toxic pollutants at POTWs. The Agency note;
that the company which raised this point discharges partially treate<
cokemaking wastewaters to a POTW that is experiencing operating
problems and is passing through pollutants associated with cokemakint
operations.
8. COMMENT
One commenter indicated the Agency's discussion on sedimentatioi
presented in Volume I of the draft development document is no'
correct. The commenter points out that overflow rates (rate o:
particle settling) is the primary factor which governs suspendei
solids removal. He also states that tube plate settlers do nol
actually increase the effective surface area but increase th<
effective sludge collection area.
RESPONSE
The Agency agrees with these comments and has revised the discussioi
of sedimentation in Volume I accordingly.
9. COMMENT
The same commenter stated that the data presented in Table VI-1 ii
Volume I of the draft development document are not confirmed by dati
presented in "Carbon Adsorption Isotherms for Toxic Organics," (EPA-
600/8-80-02).
RESPONSE
The data presented in Table VI-1 of the draft development document foi
those toxic organic pollutants associated with cokemaking operation:
were obtained from the full scale activated carbon treatment syster
installed at Plant 0684F. The Agency believes that full scal<
demonstration of the technology on the specific wastewaters bein<
OOOC91
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regulated provides more representative data than a reference based
primarily on adsorption studies on single compound systems.
Nonetheless, the reference cited by the commenter indicates that
activated carbon can be used to achieve the limitations for toxic
organic pollutants where the Agency has included activated carbon in
the model treatment system.
10. COMMENT
The same commenter also questioned the design procedures used to
determine the area requirements and the costs of the treatment
facilities presented in the draft development document.
RESPONSE
The Agency determined the area requirements for the model treatment
facilities on the basis of the area required for each component (e.g.,
scale pits, clarifiers, filters, aeration basins). The area for each
component is based upon the size of the component necessary to process
the volume of wastewater for the model treatment system. For scale
pits, clarifiers, and thickeners, the overflow rate is the primary
factor influencing the size of the equipment. The area requirements
for other equipment items were determined from engineering cost
references or based upon typical installations found in the industry.
With respect to the Agency's cost estimates, reference is made to
Volume I of the development document for a review of these estimates
and how they compare with actual industry costs.
11. COMMENT
One commenter implied that the Agency did not adequately address the
difference between large and small mills. The commenter stated that
the smaller specialty steel mills may have to incur additional
wastewater treatment costs due to different minimum solubility of the
various metals; the actual process, operation, constraints and
pollutants at specialty steel mills are different than at the larger
iron and steel plants, although the steelmaking processes are
basically the same; and, sulfuric acid recovery at specialty steel
mills would be cost intensive, whereas it any be cost effective at
large iron and steel plants.
RESPONSE
The Agency believes it has adequately addressed the differences
between the larger iron and steel mills and the smaller specialty
steel mills, and that the water pollution control costs incurred at
specialty steel mills would be similar to the costs incurred at iron
and steel mills. The Agency has established separate effluent
limitations for specialty steel operations where process, flow, or raw
wastewater or effluent quality indicated separate limitations are
appropriate. For example, certain hot forming subdivisions have been
segmented to separately cover specialty steel operations; and the acid
pickling subcategory has been subdivided to separately account for
OOuG92
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combination acid pickling which is essentially a specialty stee
operation. Moreover, the concentration bases for the ' toxic meta
effluent limitations for combination acid pickling and salt bat
descaling operations are different than those used for the othe
pickling subdivisions, which are generally associated with larger iro
and steel mills. Thus, the Agency has taken into account th
different solubilities of the toxic metals in specialty stee
operations. On the issue of sulfuric acid recovery, the Agenc
disagrees that the cost effectiveness would be substantially differen
between large and small plants. Such systems are installed at smal
plants (e.g., Plants 0476A and 01121) and large plants (e.g., Plan
0112C). In any event, sulfuric acid recovery is not required fo
compliance with the regulation.
12. COMMENT
One commenter stated the Agency's cost for filtration systems include
in the model treatment systems used to develop the propose
limitations and standards are not consistent when the costs per uni
volume of wastewater filtered are considered, even after adjustment
were made for economies of scale. The commenter also noted that are
requirements for filters were not consistent.
RESPONSE
In response to this comment, the Agency reevaluated its costs and are
requirements for filtration systems and, as described in the preamble
also refined its costing methodology to address the problems note
above. The data presented below demonstrate that the filtration cost
and area requirements used for the final regulation are generall
consistent. The increases in unit costs ($/gpm) in the 300 to 500 gp
range result from interpolation.
OOOG93
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Filter Cost Comparison
Flow
(GPM)
6
21
24
67
257
292
334
500
750
3306
5160
€814
12889
Capital Cost
(Dollars)
15,400
32,000
35,400
105,400
246,700
285,500
401,000
513,400
539,300
1,660,100
2,168,500
2,392,000
2,857,500
Cost
($/GPM)
Land
(Ft«)
2566,
1523,
1475,
1573,
959,
977,
1200,
1026,
719,
502,
420.
351 ,
221 .
7
8
0
1
9
7
6
8
1
1
3
0
7
*
3520
5300
8800
*Land area of 1700 ft2 specified.
13. COMMENT
One commenter suggested that intensive sampling surveys similar to the
Agency's intensive sampling survey conducted with the industry at
several hot forming operations should be completed for other
subcategories as well. The commenter contends the data base is not
adequate in other subcategories and the results from the hot forming
surveys allowed the Agency to have a complete data base and make
proper interpretations of the data for that subcategory.
RESPONSE
The Agency has not conducted intensive sampling surveys for other
subcategories because it believes its existing data base for all
subcategories obtained through extensive monitoring of the industry,
responses to Agency questionnaires, NPDES permit records, and data
submitted during the comment period is adequate. With respect to the
hot forming subcategory, the additional data obtained from the joint
sampling survey with industry are not different than the data
available prior to the joint survey. The Agency did, however,
reevaluate the hot forming data and reached different conclusions
regarding the discharge of toxic pollutants at different levels of
treatment. Long term average discharges were evaluated in selecting
the model treatment technologies for the final regulation, rather than
discharges based upon regulated levels of the limited pollutants which
were evaluated for the proposed regulation. Also, for the final
regulation, the Agency considered concentrations of pollutants
reported less than detectable levels as not present (or zero);
whereas, for the proposed regulation, those concentrations were
considered to be present at the detectable levels. The Agency made
000094
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the above changes for all subcategories and believes its-evaluation
the data for all subcategories is appropriate.
14. COMMENT
Several commenters noted that the Agency had not completed
regulatory impact analysis for the proposed regulation pursuant
Executive Order 12291.
RESPONSE
The Agency had not conducted a Regulatory Impact Analysis (RIA) fi
the proposed regulation because Executive Order 12291 was not issu
until after this regulation was proposed. However, the Agency h.
completed an extensive Regulatory Impact Analysis for the fin.
regulation. The RIA includes a cost-effectiveness analysis of tl
model treatment technologies including an evaluation of the coi
effectiveness of treatment beyond the current level of discharge
limited water quality analyses of about 30 stream segments with ste<
industry discharges; detailed water quality analyses for three streai
highly affected by steel industry operations; an assessment of tl
potential benefits associated with steel industry compliance with t)
final regulation for those three stream segments; and, a rou<
assessment of the aggregate benefits of industry compliance with ti
regulation. The industry participated in the selection of the stre<
segments studied by the Agency and had considerable correspondeni
with the Agency during the conduct of the associated benefil
analyses.
The Agency has determined that the RIA supports the fine-
regulation, and, to the extent allowed by law, the informatic
contained in the RIA was considered by the Agency in developing tl
final regulation.
15. COMMENT
The Agency received several comments from industry recommending the
the limitations and standards be promulgated on a "net" basis; the
is, to allow for full credit or pass through of the levels of tl
limited pollutants in the intake waters.
RESPONSE
The Agency has not promulgated net limitations and standards. Th
Agency specifically considered whether or not such standards should t
developed and applied on a net or gross basis, and determined the
gross limitations and standards are appropriate. As set out in eac
subcategory report of the development document, the Agency found the
the levels of the limited pollutants found in make-up waters do nc
significantly add to the raw waste loadings at most plants, and thi
do not affect the industry's ability to comply with the limitations c
a gross basis using appropriate pollution control technologies
Accordingly, the agency has promulgated the regulation with r
OGOG95
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provision for net credits, and has determined that the limitations and
standards' should be applied on a gross basis, except to the extent
provided by 40 CFR Part 122.63(h).
16. COMMENT
The Agency received comments from operators of POTWs suggesting that
PSES and PSNS be promulgated on the basis of concentrations rather
than as mass-based standards. The commenters cited the difficulty of
monitoring for compliance with mass-based PSES and PSNS where both
flow monitoring and frequent solicitation of industrial production
records would be required.
RESPONSE
The Agency considered promulgating PSES and PSNS on the basis of
concentration only, but did not do so because it believes that pass
through of toxic pollutants from steel industry discharges at POTWs
can more effectively be regulated with mass-based PSES and PSNS. The
commenters appear to have some misconceptions about how to apply the
mass-based PSES in their pretreatment programs. These standards would
be applied in the same way the limitations and standards are applied
for direct dischargers in NPDES permits. That is, the production
capacity of the facility in question, or a production rate
representing high production operations, is used to determine the
mass-based standards in terms of kg/day or Ibs/day. Once the
pretreatment standards are fixed, there would be no need to monitor or
solicit additional industrial production data. However, the standards
would have to be modified to take into account any new capacity
additions or retirements. The flow of the steel industry discharge to
the POTW and the concentrations of the limited pollutants would be
monitored to determine compliance. The Agency believes these are
reasonable requirements.
17. COMMENT
One commenter stated that the Agency has used engineering judgment to
interpret information without defining the criteria used to make that
judgment. The commenter noted that since engineering judgment is not
necessarily objective, it was difficult for the commenter to fully
evaluate some of the data presented by the Agency.
RESPONSE
The Agency has used engineering judgment to identify plants which it
believes have state-of-the-art treatment systems and are
representative of other similar operations. The Agency has also used
its judgment to analyze operating data, discharge flow rates, and
effluent data to identify well designed and operated treatment
facilities which it used to establish the effluent limitations. The
Agency recognizes that engineering judgment is not always objective.
However, the Agency does not believe that a universally applicable set
of objective criteria can be established due to the wide variations of
OOGG96
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conditions that must be evaluated. The Agency has therefor
appropriately used the expertise of its staff and its consultants t
exercise engineering judgment on a case-by-case basis.
18. COMMENT
One commenter, while agreeing that the 0.6 factor is a reasonab]
means of estimating costs for different sizes of similar wastewat«
treatment facilities, stated that the method is not universal]
applicable. The commentor was particularly concerned that the Agenc
used production rates rather than wastewater volumes to scale tt
costs.
RESPONSE
The 0.6 factor is a commonly applied method for scaling costs c
identical facilities for different sizes. This method is used in bot
the public and private sector to estimate costs, as indicated by U
industry's comments on costs. The commenters concern regarding tl
Agency's use of production rather than flows for scaling is unfoundec
The Agency has determined that flows and production rates are relate<
Thus, on the assumption that the model treatment technologies at tl
model flow rates will be installed by the industry to achiei
compliance with the effluent limitations, scaling costs on the bas:
of production or flow rates will yield the same result. The Agency :
well aware that in actual practice different treatment technologi<
will be used, and different discharge rates will be attained 1
achieve compliance with the same limitations. Some dischargers wi!
attain lower discharge rates than the model flow rates, while othei
will have higher discharge rates. It is well beyond the ability <
the Agency to perform its cost estimates on the basis of the actu;
treatment technologies and flows that are and will be used at ea<
plant, Moreover, the Agency has previously compared (see Volume I <
the Development) cost estimates made by scaling model costs on tl
basis of production and flow rates with site specific engineering co;
estimates. This comparison clearly showed that the estimates usii
either production or flows for scaling compare favorably with si
specific cost estimates, and in the aggregate, the estimates made <
the basis of production more closely approximated the site specif
costs. The Agency has also compared its cost estimates with actui
costs for over ninety wastewater treatment facilities reported by t
industry. This comparison also demonstrates that the Agency's meth
of developing cost estimates is appropriate.
19. COMMENT
A commenter pointed out that the equation for the capital recove
factor shown in Volume I is incorrect.
RESPONSE
The commenter is correct in identifying the typographical error in t
Development Document. It should be noted, however, that the Agen
OOGC97
-------
has .revised the method used for annualizing capital costs. This is
discussed in detail in Section VII of Volume I of the Development
Document.
20. COMMENT
A commenter expressed concern that insufficient consideration has been
given to treatment of toxic pollutants/ listed in Appendix B of the
preamble to the proposed regulation as "not treatable" and "regulation
considered" which the Agency excluded from the proposed regulation.
The commenter stated that more stringent treatment requirements are
needed at the point of discharge to eliminate the possibility, that
multiple discharges to a receiving water used as a source of drinking
water will raise the levels of toxic pollutant to the point where more
expensive and difficult removal at potable water treatment facilities
will be necessary. The commenter concurred with the use of
appropriate indicator pollutants, but recommended that a complete
analysis of the discharge be made on some infrequent basis to ensure
that no change has ocurred in the wastewater characteristics.
RESPONSE
The Agency has regulated toxic pollutants wherever toxic pollutants
were present at treatable levels. The Agency accomplished this by
directly limiting certain toxic pollutants and using these toxic
pollutants as indicators of the presence and treatment of other toxic
pollutants found in the wastewaters. The Agency believes that removal
of the indicator pollutants will result in comparable removal of other
toxic pollutants found in the same wastewaters. Moreover, the
treatment technologies used to establish the effluent limitations
removes toxic pollutants to levels at which only marginal incremental
removal can be achieved by other state-of-the-art treatment
technologies. The Agency believes it has given sufficient
consideration to treatment of toxic pollutants on an industry-wide
basis. The Agency recognizes that in certain instances local water
quality or drinking water considerations could warrant more stringent
treatment requirements. These considerations are, however, more
properly addressed at the local level, and where warranted more
stringent treatment requirements may be imposed through NPDES Permits.
The toxic pollutants which the Agency has identified as "not
treatable" were found in steel industry wastewaters at concentrations
at or below those achievable by state-of-the-art technology. The
Agency expects that the levels of these pollutants will remain at or
near these concentrations. Those toxic pollutants which the Agency
considered but did not establish effluent limitations, were present at
or near treatability levels or are otherwise controlled by indicator
pollutants. Hence, the Agency believes that the concentration of
those toxic pollutants which were not specifically limited will be
present in steel industry discharges only at or near treatability
levels. Thus, in most cases, no further treatment except costly
evaporative and recycle technologies could be used to further reduce
the discharge of these pollutants.
GQOC98
-------
With regard to the recommendation to establish a monitorinc
program to completely analyze discharges for toxic pollutants, th<
Agency does not believe that it is appropriate to establish that typs
of program in this regulation. It should be noted, however, thai
complete analyses of discharges for toxic pollutants are performed ii
conjunction with the filing of NPDES permit applications.
21. COMMENT
Two commenters stated that the Agency has not recognized that centra!
treatment facilities treat wastewaters from sources other than thos<
covered by the guidelines. One of the commenters recommended that th<
Agency include in the regulation guidance and reference sources to b<
used to determine allowances for these other sources.
RESPONSE
The Agency has established effluent limitations for those operation:
in the steel industry which are the primary sources of pollutants
The Agency is aware that wastewaters from other production 01
ancillary operations are discharged from steel plants. Thos<
operations generally contain lower levels of pollutants or are nol
widely used in the industry. The treatment and discharge of thes<
wastewaters with steel industry wastewaters is recognized throughoul
the Development Document. The Agency believes that it would be mor<
effective to establish the effluent limitations for these operation:
on a case-by-case basis at the permit level. The Agency, however
does not believe that it would be appropriate to set forth guidance ii
the regulation on this issue.
22. COMMENT
One commenter stated that although the annual electric powe:
consumption estimated by the Agency for compliance with the proposei
regulation amounts to only 3.6 percent of the electric powe
consumption of the industry, and only 0.6 percent of the total energ;
consumed by the industry, his experience at one plant is that electri
power amounted to 14 percent of the energy consumed, but accounted fo
39.2 percent of the total energy cost. On this basis, the commente
concludes that the actual energy cost to industry is higher tha
indicated by the Agency.
RESPONSE
The Agency believes that its cost estimates for electric powe
consumption necessary to comply with the regulation are accurate; and
as set out in the economic impact analysis, the Agency has accounte
for escalation of power costs and other energy costs over the perio
of time covered by the economic impact analysis. Differences in cost
for power and fuel noted above by the contractor were also accounte
for in the economic impact analysis. The Agency notes that the powe
COG099
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consumption associated with compliance with the final regulation is
about one- third less than that for the proposed regulation. Most of
the difference is attributed to the Agency's decision not to
promulgate BAT Limitations based upon high rate recycle systems for
hot forming operations.
23. COMMENT
The Agency received comments from a manufacturer of water pollution
control equipment recommending that a specific technology be
considered as the best available technology. The commenter states
this technology could be used to achieve the BAT limitations for toxic
metals at less cost than with chemical reduction or ion exchange
treatment.
RESPONSE
The Agency reviewed the information submitted by the commenter and
believes that this technology is one of several that may be used by
the industry to comply with the limitations and standards for toxic
metals. However, the Agency based the limitations and standards for
toxic metals upon classic chemical reduction and lime precipitation
technologies that are well demonstrated in the steel industry. As
noted in the development document, the industry may use any wastewater
treatment technology to achieve the limitations, including that
suggested by the commenter.
24. COMMENT
Two commenters noted that the Agency did not consider technologies
transferrable from foreign industry to establish the effluent
limitations. The commenters did not endorse these technologies, but
argued they should have been evaluated and considered.
RESPONSE
The Agency did not consider any technologies for which it did not have
sufficient operating and performance data for establishing effluent
limitations. In some cases, the foreign technologies could not be
fully evaluated to confidently project costs, reliability and
achievable effluent levels, and to determine its effects or
acceptability from the perspective of energy, air pollution and solid
waste. Based upon limited information available through the Agency's
Office of Research and Development which evaluated foriegn
technologies, the Agency believes that the American steel industry is
at least as advanced as foreign steel makers in the field of
wastewater treatment.
25. COMMENT
One commenter stated that for some subcategories and treatment options
the effluent data presented in the draft development document are
insufficient for confidently predicting statistical variability. The
000100
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commenter identified specific pollutants for certain treatment option
in six subcategories (cokemaking, ironmaking, steelmaking, ho
forming, pickling and alkaline cleaning) which contained less than 2
observations.
RESPONSE
The Agency believes that, where effluent limitations and standard
have been promulgated, a sufficient quantity of high quality data ar
available to develop and support the limitations and standards. Th
Agency believes that the data so used are representative of th
discharge, and therefore, sufficient for evaluation of the process an
to establish the limitations and standards Nearly all of the dat
cited by the commenter were not relied upon to establish effluen
limitations for most of the pollutants. For example, the phenol
(4AAP) data for pickling wastewaters, and phenols (4AAP), cyanide an
ammonia data for hot forming wastewaters indicate these pollutant
were present in the make-up water supply at levels found in th
wastewaters. Effluent limitations or standards for iron have not bee
established for any subcategory and toxic metals have not bee
directly limited at hot forming operations. In other instances, th
treatment technologies identified by the commenter were not selecte
as basis for the effluent limitations.
Effluent limitations have been established for several of th
pollutants identified by the commenter, i.e., naphthalene, benzo-a
pyrene and benzene for cokemaking operations; and, lead for ironmakir
operations. The Agency believes that the data for these pollutant
are representative of the operation of the treatment systems and th
discharge from such operations. Thus, the Agency used these data t
establish effluent limitations. The Agency is confident that th
limitations it has established are reasonable and appropriate.
26. COMMENT
The same commenter questioned the possible inadequacy of the data bas
used to develop the effluent limitations. The commenter stated tha
while the data may be adequate, not enough information was presente
in the Development Document to make a proper evaluation. Th
commenter was concerned that the facilities sampled were no
adequately characterized to determine whether the facilities an
pollutants found are representative of the industry.
RESPONSE
The Agency believes that the facilities sampled and the pollutant
found during these surveys are representative of the industry. Th
toxic sampling survey was designed and conducted to produc
representative information. Initially, the Agency selecte
representative plants (10 steelmaking and 11 forming and finishin
plants) on the basis of its knowledge and experience for screenin
surveys to characterize the wastewaters from operations in eac
subcategory. The Agency then reviewed the information provided by th
C001C1
-------
iridustry. in response to the DCPs to identify representative operations
with treatment facilities in-place. Verification sampling was then
conducted at these facilities, which were not the same facilities at
which the screening surveys were performed. Additional sampling was
also conducted at many hot and cold forming operations. In all,
verification sampling was conducted at 21 steelmaking and 113 forming
and finishing plants. The effluent data from the screening and
verification sampling surveys were similar with respect to the
pollutants found and the levels at which they were present in the
wastewaters. As a result, the Agency did not distinquish the data
from the screening surveys from that obtained during the verification
surveys. All of these data are presented in the respective
subcategory reports of the development document. In addition, each
subcategory report provides descriptions of each of the facilities
sampled. The basic information on the production processes/
wastewater treatment facilities and discharge modes are presented in
Section III, while further description of the wastewater treatment
facilities as they were operated at the time of the sampling
inspections are provided in Section VII along with diagrams of the
wastewater sources and treatment facilities. More detailed
information on the production and treatment facilities, and operating
modes as reported by the industry are contained in the DCPs and D-DCP
which are in the record. Additional information acquired during the
sampling surveys is presented in the volumes of trip reports which are
also in the record.
27. COMMENT
The industry commented that the regulation must be reproposed for
additional public comment after the Agency completed its determination
of what the final limitations and standards should be. One industry
coinmenter indicates that the Agency's data gathering efforts were
still underway during the comment period and the industry would not
have an opportunity to comment on the Agency's final conclusions.
RESPONSE
The Agency obtained information and data from the industry during the
comment period and after it was closed, particularly financial
information concerning plants which might be adversely affected by the
regulation. The information and data obtained by the Agency after the
public comment period was closed was obtained in direct response to
certain industry comments that were unclear, or for other comments,
where the points raised by the industry required the Agency to obtain
additional information to complete its evaluation. The supplemental
information so obtained by the Agency is generally corroberative of
information at hand at the time of proposal.
The Agency believes it was neither feasible nor appropriate to
repropose its findings and conclusions on this regulation before
promulgation. The Agency believes that industry and the public have
had more than ample time and opportunity to make their views on the
regulation known to the Agency. Draft contractor's reports were
COG102
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distributed for public comment in October 1979; the Agency held <
public meeting in May 1980 to receive comments on these reports; th<
public comment period on the proposed regulation was extended twice a1
the request of the industry to a total of 120 days and, the industry
has participated heavily in the process of completing the Regulator^
Impact Analysis.
28. COMMENT
One industry commenter, when discussing the issue of watei
consumption, stated that there are inconsistencies between th<
Agency's estimates of evaporation rates in the iron and steel drafi
development document,, and the estimates contained in the steal
electric generating development document. The commenter noted tha'
the data in the steam electric document indicate that water loss ii
cooling towers is about twice that of once-through in stream cooling
whereas the discussion in the steel document implies a nearly equa
water loss for both systems.
RESPONSE
The Agency has reviewed the water consumption discussion in the Steai
Electric Development Document and has not found any significan
inconsistencies between the two methodologies. In fact certai;
portions of the methodology used in Steam Electric were included i
the Agency's water consumption analysis for the Iron and Stee
Industry.
The Agency's review of the Steam Electric documents shows that bot
approaches present the same relative evaporation rates for differen
types of cooling systems. For example, the steam electric data show
that a mechanical draft wet cooling tower will result in 2.25 time
the amount of water evaporated in a once-through system. Th
evaporation rate presented in the steel industry document for we
cooling towers is 2.2 times the once-through rate.
Based upon the above, the Agency has concluded that its estimates o
water consumption for the steel industry are appropriate an
consistent with the approach used in the Steam Electric study.
29. COMMENT
One commenter suggested that the Agency establish in this regulatio
some reference points or standards for which the design and th
adequacy of the treatment facilities can be measured against upsets
The commenter stated that the definition of upset in NPDES regulatio
and pretreatment standards are overly broad.
RESPONSE
The Agency believes that it is neither appropriate nor possible t
establish reference points or standards against which upsets can b
measured. The events and conditions under which upsets can occur ar
000103
-------
numerous and highly site-specific. The Agency believes that the upset
provision contained in the NPDES regulation at 40 CFR 8122.60 is
adequate.
30. COMMENT
A commenter requested that EPA continue the stay of the effective data
of amendments to the general pretreatment regulations (40 CFR Part
403) promulgated on January 28, 1981 (46 Fed. Reg. 9404); stay the
general pretreatment regulations promulgated on June 26, 1978 (43 Fed.
Reg. 27736); review and reconsider the entire pretreatment program
pursuant to Executive Order 12291; and, make major changes to the
pretreatment program.
RESPONSE
These comments were responded to in the Agency's action deferring the
effective data of certain protions of the amendments to the general
pretreatment regulations. See, 47 Fed. Reg. 4518 (February 1, 1982).
31. COMMENT
A commenter requested that the categorical pretreatment standards for
this point source category be stayed pending review of the general
pretreatment program.
RESPONSE
Under Section 307(b) of the clean Water Act, categorical pretreatment
standards are required if EPA determines that the introduction of
pollutants from this point source category would interfere with, pass
through or otherwise be incompatible with the publicly owned treatment
works. The data contained in this rulemaking record establish that
categorical pretreatment standards are appropriate and necessary to
prevent pass through of pollutants. Accordingly, EPA has established
these pretreatment standards.
32. COMMENT
Commenters requested clarification of the deadline for obtaining a
category determination under 40 CFR 403.6(a) and a fundamentally
different factors variance under 40 CFR 403.13 of the general
pretreatment regulations.
RESPONSE
This comment was responded to in a letter sent to one of the
commenters by the Assistant Administrator for Water. This letter is
included in the record of this rulemaking.
33. COMMENT
000104
-------
Several commenters suggested that the Agency not establish categorica
pretreatment standards for steel industry operations for a variety o
reasons including: the purported lack of water quality benefit fo:
receiving waters; that certain POTWs achieve a level of toxL
pollutant removal comparable to that achieved by PSES and PSNS (am
the Agency's purported failure to account for that removal); and, tha
Agency's failure to compare the minimization of the pass through o:
toxic pollutants through POTW as it relates to the incrementa
removals achieved through the BAT limitations.
RESPONSE
As discussed in detail in the subcategory reports in the developmen
document, the Agency has determined that the PSES and PSNS in th<
regulation will prevent pass through of toxic pollutants at POTWs to i
significantly greater degree than would otherwise occur without sucl
standards. The Agency reached these conclusions after comparing thi
toxic pollutant removal achieved by compliance with PSES and PSNS wit!
the percentage of toxic pollutant removal achieved at POTWs. Thi!
comparison revealed that PSES and PSNS are appropriate to prevent thi
pass through of those pollutants.
In the unlikely event that an individual POTW achieves the same level
of toxic pollutant removal at PSES and PSNS, this can be accomodate*
through the removal credits provisions of the general pretreatmenl
regulation. The Agency believes, therefore, that the PSES and PSN!
contained in this regulation are appropriate.
34. COMMENT
One commenter said that it was inappropriate for the Agency t<
establish pretreatment standards based upon limitations of POTW sludg<
disposal alternatives.
RESPONSE
The Agency has established the pretreatment standards contained ii
this regulation to minimize the pass through of toxic metal pollutant*
through POTWs and, in once case, to prevent interference with POTf
operations. It did not base its pretreatment upon possibl<
limitations of POTW sludge disposal alternatives. The Agency
determined that the metals pass through POTWs and that pretreatmenl
standards (with one exception) should be analogous to BAT level
treatment because the model treatment systems remove a greatei
percentage of the toxic metals found in steel industry wastewaters
than well operated POTWs achieving secondary treatment.
35. COMMENT
Several commenters noted that the projected cost of the regulatioi
contained in the draft development was different than the drafl
economic analysis.
000105
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RESPONSE
• •
As explained in greater detail in the economic analysis report, the
Agency could not use identical cost projections for both the technical
development document and the economic analysis.
The Agency did, however, reduce the difference between these costs as
much as possible. The remaining differences are not significant in
terms of the economic impact of the regulation.
36. COMMENT
One commenter suggested that the Agency's economic analysis include a
consideration of the following: the effects of enforcement of the
trigger price mechanism; the expiration of the governments anti-
inflation program; and other capital investments required of the steel
industry to satisfy governmental requirements.
RESPONSE
The Agency's economic analysis includes these factors. With respect
to capital investments necessary to satisfy governmental requirements,
the analysis included those investments when they could be determined
witb a reasonable degree of certainty. For example, in the case of
OSHA requirements, the costs were not included because they could not
be determined with a reasonable degree of certainty.
37. COMMENT
The industry contends the Agency used flow data from plants with the
lowest flows, and concentration data from plants with the lowest
concentrations to develop the limitations and standards. The industry
states that plants with low flow rates invariably have higher
pollutant concentrations in the wastewaters than do plants with lower
flows.
RESPONSE
The Agency disagrees. In all cases, the Agency believes it has
established the model treatment flow rates at levels that can be
achieved by the industry. Where recycle systems are included in the
model treatment systems, the Agency selected model treatment system
blowdown flow rates on the basis of actual performance in the industry
at representative plants, i.e., plants with applied water rates
generally in the range of the model treatment system applied flow
rates. For those subcategories where recycle is not part of the model
treatment system, the Agency established the model treatment flow
rates at levels that can be achieved with good water management
practices. The pollutant concentrations used to establish the
limitations and standards are based upon performance of treatment
systems at plants which have representative untreated wastewaters.
Thus, as noted above, the Agency believes it has used representative
data to establish the limitations and standards.
OOulOG
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38. COMMENT
"^™""~^^™"' • •
The industry commented that when the Agency establishes effluen
limitations or standards based upon the "average of the best" plants
about half of the best plants would not be able to comply with th
limitations.
RESPONSE
The Agency disagrees. The "average of the best" concept, as used b
the Agency, does not mean that arithmetic averages of the bes
effluent loads were used as basis for the effluent limitations an
standards. The effluent limitations and standards were developed o
the basis of model flow rates and effluent concentrations. The mode
flow rates were determined from the "average of the best" plants
which generally included a large proportion or all of the flow dati
reported by the industry. The exceptions were for situations when
the model discharge flow rates were based upon the recirculation o:
the wastewaters. In these instances a smaller data base was use<
since not all plants are operated to minimize the discharge froi
recycle systems. In any event, as presented in each subcategor?
report of the development document, the model flow rates ar<
demonstrated to be achievable by all plants in the respectiv<
subcategories. The effluent concentrations were developed froi
available effluent data. These data were statistically analyzed an<
the effluent concentration bases for the effluent limitations an<
standards were projected at the 95th percentile level for the 30-daj
average effluent concentration and the 99th percentile level for th<
daily maximum. These effluent concentrations are achievable a1
properly designed and well operated treatment systems. Thus, sinc<
both the model flows and effluent concentrations are demonstrated tc
be achievable. The Agency believes the effluent limitations anc
standards established on this basis are achievable by all plants tc
which the limitations and standards apply.
39. COMMENT
For several subcategories, the industry commented that the Agency die
not consider the chemical and energy effectiveness of the selectee
model treatment technologies including indirect energy consumption,
water losses, and other indirect factors associated with manufacture
of chemicals, power, and other items required to operate the mode]
treatment systems. In some cases, the industry commented that th€
chemical dosages specified by the Agency are not adequate.
RESPONSE
As noted in the subcategory reports and in responses to other
comments, the Agency reevaluated the chemical dosage requirements for
the model treatment systems and made adjustments as appropriate. Th€
Agency has determined that the use of treatment chemicals and the
expenditure of energy to operate the treatment systems to achieve the
effluent limitations and standards is appropriate and justified. With)
CGulO?
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respect .to indirect energy consumption to produce the treatment
chemicals, indirect water losses associated with the generation of
power to manufacture the chemicals, and other indirect impacts, the
Agency believes it is neither appropriate nor possible for it to
evaluate each and every indirect factor associated with the
regulation.
40. COMMENT
One commenter suggested that the Agency did not adequately consider
the adverse air quality impacts associated with industry compliance
with this regulation.
RESPONSE
As noted in the development document, the Agency specifically
considered the adverse air quality impacts associated with the
alternative treatment systems considered by the Agency for selection
as model treatment systems. In addition, the Agency concluded that
adverse air quality impacts associated with industry compliance with
this regulation are justified by the effluent reduction benefits.
41. COMMENT
Several cornmenters objected to the Agency's use of "indicator"
pollutants in conjunction with the "alternative effluent limitations"
(40 CFR Part 423.03) because it would result in the discharge of an
greater amount of toxic pollutants than would occur without the
alternative effluent limitations.
RESPONSE
The Agency disagrees. In developing the alternative effluent
limitations, the Agency analyzed the nature of the wastewaters of the
various steel industry operations. It believes that if dischargers
satisfy the requirements associated with 40 CFR 423.03, there will be
no significant increase in the amount of toxic pollutants than would
have occured without the application of those alternative limitations.
42. COMMENT
Several commenters said that the provisions for alternative effluent
limitations contained in 40 CFR 423.03 is illegal and inappropriate.
RESPONSE
The Agency disagrees. As expalined in the preamble to the regulation,
the alternative effluent limitations provide a discharge with an
alternative means of achieving the same level of effluent reduction as
required by 40 CFR Part 423 Parts A-L, but at a reduced cost. The
Agency believes this is an appropriate approach to implement the
requirements of the Clean Water Act.
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43. COMMENT
~"~ r~~ ~ 4 v
One commenter claimed that it and others in the industry have achievei
the BPT limitations using non-standard technologies, and that it ma;
cost substantially more than the Agency estimates for the commente:
and others to achieve the BAT limitations.
RESPONSE
The Agency believes that its model-based costing methodology ii
appropriate for developing industry-wide costs. The Agency hai
verified its costing methodology by comparing model based cos
estimates with actual industry costs (see Volume I). The Agenc
believes that most of the problems cited by the commenter ar'
associated with central treatment facilities. The Agency hai
addressed this problem to the maximum extent possible by structurini
the regulation to facilitate co-treatment of compatible wastewater:
and by separately addressing central treatment problems at certai:
plants. Reference is made to the preamble for a complete discussio:
of this issue.
44. COMMENT
The industry commented that the Agency does not have the authority t<
regulate flow and that attainment of the flows used by the Agenc;
might result in process changes for certain operations or produc
quality problems.
RESPONSE
The Agency believes it appropriate to establish mass-based limitation
and standards based upon flow reduction and good water managemen
practices. As set out in the development document, the Agenc
believes the model treatment system flow rates used to establish th
limitations and standards are achievable at all plants without proces
changes; and, that product quality will not be adversely affected.
45. COMMENT
One commenter stated that the Agency should undertake a more complet
analysis of the impact of solid waste disposal costs and problems.
RESPONSE
The Agency believes that it has adequately considered costs an
problems associated with solid waste. Where the RCRA regulation
lists certain solid wastes as hazardous, and the solid waste i
produced as a result of the wastewater treatment, the Agency ha
included appropriate costs ($18/ton) for disposal of these soli
wastes. Other solid wastes have been addressed as non-hazardou
wastes with appropriate sludge disposal costs ($5/t.on). These cost
include site considerations for minimizing or eliminating any advers
environmental effects that may result from the disposal of thes
CGul09
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wastes, e.g./ proper lining of the disposal site. The Agency does not
presently have data which would allow it to precisely determine or
project which other wastes, if any, might be considered hazardous
under RCRA.
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LIST OF COMMENTERS
IRON AND STEEL INDUSTRY PROPOSED REGULATION
Comment
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
(46 FR 1858— Due May
Commenter
AM. Water .W. Serv. Company
Armco, Inc.
Anaco, Inc.
National Steel
Armco, Inc.
Jones & Laugh 1 in Steel
Jones & Laugh 1 in Steel
Northwestern Steel & Wire
Company
Armco, Inc.
United States Steel
Corporation
Kolene Corporation
Midwest Steel
And co
American Water Works Service
Company, Inc. (Duplicate)
Alabama By-Products
Corporation
LaClade Steel Company
Jones & Laugh 1 in Steel
Rooks, Pitts, Fullagar and
8, 1981)
Author
D. L. Kelleher
J. E. Barker
J. E. Barker
H. R. Wood
J. E. Barker
D. H. Miller
D. H. Miller
J. E. Barker
J. C. Moniot
D. S. Shoemaker
K. L. Armour
Joseph G. Duffey
Daniel L. Kelleher
Wm. C. Jones
Dale L. Elsenraich
David H. Miller
James T. Harrington
Comment
Dated
2/11/81
2/24/81
M 3/4/81
2/26/81
2/27/81
M 3/2/81
3/5/81
3/13/81
3/13/81
3/16/81
3/13/81
3/26/81
2/17/81
3/2/81
2/23/81
2/11/81
4/3/81
4/6/81
4/8/81
4/10/81
19
Poust
Colt Industries
R. H. Wills, Jr.
4/8/81
cooni
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LIST OF COMMENTERS
IRON AUD STEEL INDUSTRY PROPOSED REGULATION
PAGE 2
Commenter
Comment
No.
20 Carpenter Technology
Corporation
21 Koppera
22 U.S. Si.ee! Corporation
23 County Sanitation District of
Los Angeles County
24 Natural Resources Defense
Council, Inc.
25 Jones & Laughlin Steel
26 Donald Caless
27 Arkansas Science Information
Exchange
28 Bass Anglers Sportsman Society
29 National Steel Corporation
30 William V. Peterson
31 CF & I Steel Corporation
32 CF & I Steel Corporation
33 Welborn, Dufford, Cook & Brown
34 United States Steel Corporation
35 Citizens for a Better
Environraent
36 Jones & Laughlin Steel
37 J. A. Buzzelli
Author
Harold W. Miller
Charles P. Brush
Stephan K. Todd
Jay G. Kremer
Craig Koralek
Donald Caless
John S. Miller, Ph.D
Bob Barker
Ralph W. Purdy
William V. Peterson
Billy D. Egley
John C. Winkley
William C. Robb
J. D. Moniot
Michael E. Belliveau
David H. Miller
J. A. Buzzelli
Comment
Dated
4/7/81
4/7/81
4/13/81
4/16/81
4/29/81
4/29/81
5/8/81
5/4/81
5/4/81
5/6/81
5/2/81
5/7/81
5/13/80
9/11/80
5/8/81
5/7/81
5/7/81
5/2/81
000)1?
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r>« »rr
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LIST OF COMMENTERS .
IRON AND STE'EL INDUSTRY PROPOSED REGULATION
PAGE 3
Comment
No.
38
39
40
41
42
43
44
45
46
47
48
Coinmenter
Author
Rooks, Pitts, Fullagar and
Poust
Bethlehaa Steel Corporation
Inland Steel
Republic Steel
Group Against Smog and
Pollution (GASP)
Sierra Club
General Counsel of the United
States Department of Commerce
American Iron & Steel Institute
Pickands Mather
Northwestern Steel & Wire
Company
Ford Motor Company
James T. Harrington
David M. Anderson
D. C. Lang
W. L. West
Patricia B. Pelkofer
Martha E. Ture
Gerald C. lannelli
E. F. Young, Jr.
T. J. Manthey
Dale R. VanDeVelde
A. B. M. Houston
Comment
Dated
5/8/81
5/6/81
4/28/81
5/6/81
5/6/81
5/6/81
5/8/81
5/8/81
5/8/81
5/6/81
5/7/81
GGulI?
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