Site Visit Report

ArcelorMittal

— Indiana Harbor 3001 Dickey Road East Chicago, IN 46312 3210 Watling Street East Chicago, IN 46312 August 3 , 2009 1.0 Background and Objectives The Environmental Protection Agency (EPA) is in the process of developing 316(b) cooling water intake structure requirements that reflect the best technology available (BTA) for minimizing adverse environmental impact for all existing power plants and manu facturing facilities. As part of this process, EPA staff is visiting electric generators and manufacturers to better understand the cooling water intake structure (CWI S) technologies in use at facilities, including the site

specific characteristics of each facility and how these affect the selection and performance of CWI S technologies. EPA is also visiting facilities to better understand cooling water use and specific issues or technologies that can affect 316(b) compliance. ArcelorMittal ’s In diana Harbo r facilit y (Indiana Harbor) was selected for a site visit because it utilizes cooling water in manufacturing steel and other metal products. 1 2 .0 Facility Description ArcelorMittal ’s Indiana Harbor facility is located on a 3300 acre site on the shore of Lake Michigan in East Chicago, IN. The facility is actually comprised of two formerl y separate steel mills; the West side 2 was established in 1914 and the East side 3 began operations in 1907. Collectively , the facility employ s approximately 6500 personne l. The facility has two NPDES permits, one for each former mill (NPDES permit number s IN0000205 and IN0000094 , respectivel y). The permits have expired ( September 29, 1991 and May 31, 2001 , respectivel y) and are in the process of being renewed. 4 3 .0 Manufacturing Information Indiana Harbor produces over 10 millions tons of steel per ye ar, making it one of the 5 largest steel mills in the world

. It primaril y produces high

- end metal products (such as rolled steel) that are used in automobiles, applian ces, and

1 EPA provided a draft of this report to ArcelorMittal but did not receive any comments from the facility. 2 This is the former Indiana Harbor site, last ow ned by LTV Steel and acquired by ArcelorMittal. 3 This is the former Ispat Inland site and w as acquired by ArcelorMittal. The site occupies approximately 2100 acres; 400 acres on the historic “shoreline” and 1700 acres on the peninsula. 4 Facility representatives expect renewed permits to be issued in January 2010.pipes. 5 The West side is comprised of two blast furnaces, a hot strip mill, and a finishing mill. The East side operates the largest blast furnace in the U.S., as well as a second smaller blast furnace. The facility

has seen production slow sub stantially and idled ov er 1000 workers in earl y 2009, but has recently seen production begin to increase. 6 The facility’s location makes it more viable than other inland locations, as it has ready access to water, cheaper shipping, and is closer to the or e, much of which comes from Canadian mines. The West side was closed for approximately 18 months in the earl y part of this decade , but was purchased by I SG and brought back online in 2002 . I SG merged with Mittal Steel in 2005 , which w as then purchased by Arcelor in 2006

. The East side began as Inland Steel, was sold to I spat in 1998, and became part of Mittal. 4 .0 Cooling Water System and Intake Structure The location of the intake structures (and the configuration of the facility) has evolved over the ye ars; the facilit y was originall y located on the historic lakeshore but expanded outward into the lake. 7 The West side ’s CWI Ss with draw from the Indiana Harbor Ship Cana l, which bisects the two plants; the East side ’s CWI S s are located directly

on Lake Michigan. Most of the water withdrawn is used for once - through non - contact cooling; a large volume of process /contact water is also used onsite, but the facility has worked over the years to recirculate the majority of its pr ocess water. Makeup water for the process water s ys tems is also supplied by the CWI S s ; the fire suppression sy stem also uses the intake structures. 8 The West side has six cooling water s ys tems (CWSs) and four CWI Ss. The main CWI S (CWI S #2) is located at the end of a secondary intake canal (approximately 5500 feet in length) that withdraws water from the mouth of the Indiana Harbor Ship Canal through a riprap weir and runs into the center of the West side peninsula. CWI S #2 is connected to its primary water user (the power plant , which uses approximately 100 million gallons per day [mgd] ) via a 14 foot diameter tunnel 250 feet underground. Two other CWI Ss are also located in this

5 No construction

- grade materials are produced at Indiana Harbor

— foreign mills produce these materials at a low er cost and have overtaken this market. One small production area remains that is capable of producing these materials, but it has been idled for an extended period. 6 The facility has been operating at approximately 35

- 40% capacity (the West side w as essent ially idled at the time of the site visit, but the East side w as operating at about 80%), but industries that it typically supplies have been operating at approximately 60% capacity, indicating that these industries w ere using on

hand stocks of metal produ cts in their products, but will likely be running out soon and require a new supply. 7 Fill material was used to create the peninsulas on which the facility is currently located. 8 Facility representatives noted that much of the remaining process water is critical to the plant operations (e.g., scaling water) and could not be reduced or eliminated without adversely affecting the production of steel.canal (one low

- head intake near the terminus of the canal, the other approx imately 2000 feet from the canal entrance 9 ), while the other one (CWI S #1) withdraws from the Ship Canal. In total, the West side ’s design intake flow is 627 mgd. Its average actual intake flow (AIF) is approximately 370 mgd. The West side uses a mixtur e of once

- through and recirculating cooling s ys tems. As stated above, most of the once

- through cooling water is for the power plant; cooling water at the hot strip mill and hot mill is recy cled through onsite lagoons. The blast furnaces also recy cle much of the process water. Facilit y representatives stated that they do not precisely measure the intake flow. CWI S #2 has 5 pumps, #1 has 4 (with only 1

- 2 usually

operational), and #3 has 3 72 mgd pumps (operating 2 when the hot strip mill is operating). E ach of the pumphouses are linked to the same circulating water sy stem and work cooperativel y to maintain proper flow and pressure levels. CWI S #2 also provides water to the tin plant onsite, which is still owned by US Steel. The West side ’s main intake w ithdraws water through a bar rack and into the screenhouse with 5 bay s. Each bay has one coarse mesh traveling screen, but two bay s have been closed. CWI Ss #1 and #3 have a similar configuration, with #1 having three coarse mesh screens and #3 having 11 bay s but onl y 6 screens. 10 All of the screen use a high pressure wash and discharge an y debris or impinged organisms to the trash. The East side also uses a mixture of once

- through and recirculating cooling sy stems. An extensive tunnel sy stem was constructed in the bedrock beneath the facility to facilitate recirculation of cooling water between process areas; facility representatives stated that approximately 56 9 mg d of water is recycled within the sy stem via 5 pumphouses at various locations. 11 T he East side has been expanded and modified over the ye ars as needed and has two treatment plants. The East side has two CWSs, which are each served by a single CWI S. The primary CWI S (CWI S #2) is located at the end of a 1000 foot long intake canal at th e southeastern end of the facilit y. This CWI S provides the majority of the cooling water for the East side . The second CWI S (CWI S #1) , located approximately

halfway out the peninsula, provides cooling water to the northern

9 This intake (CWIS #3) primarily feeds a recirculating CWS for the northwestern portion of the West side; a holding pond is used to dissipate heat before w ater is reused. 10 The remaining bays are closed; the facility built the CWIS to allow for additional withdrawal capacity, but never needed to expand. 11 A series of legal actions in the 1960s led the facility t o construct the Master Recycle System. The estimated flow is based on materials used in developing the facility’s NPDES permit and reflects the additional flow volume that they expect would need to be withdrawn from Lake Michigan if the system were not in place.half of the East side

. The Eas t side ’s DIF is 569 mgd 12 and its AIF is approximately

160 mgd. The East side ’s primary

CWI S draws water through bar racks 13 and over a “lift wall” 14 in the canal into a tunnel at the pumphouse. Within the pumphouse, 5 intake bay s (each with a 3/8” coarse mesh traveling screen) feed a common sump with 7 pumps with a design intake flow (DIF) of 360 mgd. 15 Screens are rotated infrequentl y, as facility representatives noted that there is normall y minimal debris (mostly

plastic bags) or impingement (fish are on ly observed for a few day s each ye ar); all materials are disposed in a landfill. The main user of cooling water from the East side ’s CWI S #2 is the blast gas furnace power house, located near the intake canal. 16 The vast majority of the water withdrawn (a

pproximately

115 mgd) for the power house is once

- through non - contact cooling water. The East side ’s second CWI S (CWI S #7) supplies a distribution area on the site for the former coal

- fired generating unit. 17 A concrete culvert in the shoreline opens to L ake Michigan at the end of a small inlet bay ; water then passes into the adjacent screenhouse. The CWI S has a trash rack and seven coarse mesh traveling screens. 18 There are three circulating pumps (approximately 58 mgd each) and four service water pumps (approximately 43 mgd each) for a total DIF of 345 mgd. However, due to process changes and reductions in water usage, the facility onl y operates one service water pump at approximately half capacity

(an actual intake flow (AIF) of approximately 20 mgd). Facility

representatives estimated that half of the water withdrawn was used for once

- through equipment cooling, with the remainder being used as makeup water for various s ys tems. The screens are rotated infrequently (debris loading is small) and materia ls are returned to Lake Michigan via a debris return. Facility representatives stated that the intake velocit y is approximately 0.3 fps. The East side ’s fire suppression sy stem withdraws from both the CWI Ss and the recirculation tunnels.

12 Facility representatives noted that the circulating flow w ithin the tunnel system was the original design flow for the East side. 13 The bar racks are removed in the winter to prevent the formation of ice blockages at the CWIS. 14 The lift w all ens ures that water levels within the plant stay relatively constant. 15 Five are circulating pumps and two are service water pumps. Pumps are steam driven (not electric) and have significant flexibility to vary the pumping rate. The facility is currently removing two other inactive pum ps. 16 Originally, the pumphouse was at the lakefront (circa 1919); the plant has since expanded. The pow er plant’s cooling system is over 65 years old and was originally designed as a once

- through system. The pow er plant also supplies steam to tw o other operations in the northern section of the East side. 17 The 400 MW generating unit operated from 1965 to 2000 and closed as part of a consent agreement. 18 At the time of the site visit, only 4 of the screens were operable.Indiana Harbor withdraws water even when the facility is not producing steel; the volume is much lower, but moving water keeps pipes clear of fouling organisms. Chlorination is also used at each CWI S to control fouling; zebra mussels and quagga mussels are problematic in the Great Lakes. 19 Overall, facility representatives stated that they do not experience significant clogging from fouling organisms. 5 .0 Flow Diagram Following the site visit, the facilit y provided a water balance diagram for the East side. (See Atta chment C .) The diagram shows the major recirculation s ys tems. Attachment D shows the general flow diagram for the West side. 6 .0 Electricity Generation and Transmission Facilit y representatives stated that approximately 30

- 40% of the plant’s power need s are generated onsite. Indiana Harbor Coke 20 provides the majority of the generation via the coke plant in the northern section of the East side

. The West side also has a generating unit that was built in the 1930s . Facility representatives stated that it is difficult to estimate the electricity generated by

these units, as they are used for multiple purposes

— power generation, steam generation, and to drive turboblowers that provide wind within the blast furnaces

. As noted in Section 4.0 above, the East side previously operated a 400MW coal

fired generating unit, but that unit has been taken out of service. The coal yard is still active, however, as it stores fuel for the blast furnaces. 7 .0 Impingement and Entrainment Information Facilit y representatives noted that scientists from Purdue Universit y conducted a biological survey

in the 1980s. 8 .0 Cooling Tower Feasibility The West side recycles some of its cooling water via cooling lagoons 21 and also has a 4 mechanical draft coolin g towers onsite. Its largest water user of once

through water (the power plant) is located in a congested area, making a cooling tower retrofit difficult; the towers would likel y be located over a half mile away.

19 Faci lity representatives noted that quagga mussels are beginning to displace zebra mussels, as quagga have a greater thermal tolerance. 20 Indiana Coke is a separate company (owned by Sun Oil) that takes waste products from the steelmaking process to generate p ow er. 21 Facility representatives noted that the lagoons do not dissipate large volumes of heat, especially in the summer; their primary function is for settling (primary treatment) and to store w ater for future reuse.The East side employ s 35 cooling towers of various sizes across the facility ; the facility began adding them in the 1960s and facility representatives noted that virtually every process line has a cooling tower. 22 The towers are operated by existing staff at each unit or by centralized utilities staff and normally operate ye ar - round, except for a 6

- 8 week period in winter. Facility representatives stated that there was no significant problem with drift or plume from the towers. Most of the towers at Indiana Harbor hav e been built since the 1970s, in response to the Clean Water Act and other regulatory initiatives. Facility

representatives estimated the cycles of concentration for all towers rang e from 1.5 to 3, depending on whether the tower is used for process or non

- contact cooling and whether the tower serves a blast furnace. Facilit y representatives stated that 11 of the towers (between both sites) are used for exclusively process water cooling and 5 towers are used for exclusively non - contact cooling. As noted i n Section 4.0 above, the East side ’s power plant uses a large volume of once - through cooling water. Facility representatives noted that the existing underground recirculation tunnels do not have sufficient circulating capacity to add the power plant flows . They also stated that adding cooling towers would be feasible, 23 but given the age of the s ys tem, would not be a financially sound decision. The power house is also likely to be very

expensive to demolish. Facilit y representatives also stated that they do not expect that a cooling s ystem retrofit could be accomplished during a normal scheduled outage. 24 Facilit y representatives stated that the blast furnaces generally do not have regularl y scheduled maintenance outages. The furnaces are taken offline approximately

10 day s per y ear (one day at a time) for maintenance. 25 The steel shops are batch processors, however, and may have opportunities for longer downtime periods. Facility representatives noted that many of the steel shops (including the smaller specialt y shops) can operate independentl y of the remainder of the facility

and can share materials with other sites to remain operational. Facilit y representatives noted that a pair of 2

- cell cooling towers do cause some problems with plume and visibili ty under certain conditions; roads may be closed

22 The 10

- cell tow er on the shore of th e ship canal was the largest cooling tower in the world at the time of its construction in the 1960s. 23 Potential sites for the towers could be as much as a half mile aw ay , due to limited space nearby, existing underground utilities, and other potential co nflicts. 24 The facility does use modular (temporary) cooling tow ers when existing tower units are being repaired or replaced. 25 The blast furnaces are the critical component of the facility; their output drives all other processes onsite. Facility represe ntatives estimated that downtime at a blast furnace producing 12,000 tons per day may cost the facility as much as $600 per ton (of finished product). Steel shops would suffer similar losses due to dow ntim e; facility representatives stated that steel shop s must operate at 70

- 80% capacity in order to be profitable.due to the fogging due to the safet y hazard posed by rail traffic during slab operations. 9 .0 Future Activities Facilit y representatives did not indicate an y plans to expand the facility or its intake flow s in the foreseeable future. As noted above, the facility is hopeful that its production will increase soon. 10 .0 Cooling Ponds As noted in Section 4.0 above, the West side does use some cooling lagoons as part of a recirculating s ys tem. 1 1 .0 316(a) EPA did not collect any

information on thermal discharges. 1 2 .0 Ash Handling EPA did not collect any

information on ash handling procedures. 1 3 .0 Air Emissions Controls Facilit y representatives stated that a $43 million scrubber was recentl y installed at the #4 blast furnace. EPA did not collect an y further information on air emissions controls. 1 4 .0 Issues with Debris Facilit y representatives did not note any significant issues with debris management. Some intake structures are equipped with air bu bblers to prevent ice formation in the winter. 15. 0 Additional Information Facilit y representatives stated that the age of the site and the incremental expansion over time has created significant process inefficiencies; a newl y constructed steel mill wou ld be configured very differently

. The West side is more logically

laid out and also has process units that are smaller and require less cooling water. The adjacent British Petroleum refinery recentl y implemented a major expansion in refining capacit y to accommodate processing of Canadian crude oil. As such, there is no nearb y land available for purchase.Almost all raw materials are delivered b y ship to the ship canal. Coal is delivered by rail.

Attachments Attachment A List of Attendees Attachment B Aerial Photos Attachment C Water Balance Diagram for East Side Attachment D Water Flow Diagram for West Side Attachment E Si te Visit PhotosAttachment A -- List of Attendees

Paul Shriner, EPA Jan Matuszko, EPA Sean Ramach, EPA Region V John Sunda, SAI C Kelly Meadows, Tetra Tech Tom Barnett, ArcelorMittal Simonne Benoit, ArcelorMittal Kevin Do yl e, ArcelorMittal Tom M alinkowski , ArcelorMittal Richard Dean, ArcelorMittal Mike Rossner, ArcelorMittalAttachment B

— Aerial Photos Please see DCN 10

- 6551A accompanying this document. Attachment C

—Water Balance Diagram for East Side Please see DCN 10

- 6551B accompanying this document. Attachment D

—Water Flow Diagram for West Side Please see DCN 10

- 6551C accompanying this document. Attachment E

— Site Visit Photos Please see DCNs 10

- 6551D through K accompanyingthis document.