Guidance Manual 

for 

Iron and Steel Manufacturing 

Pretreatment Standards 
GUIDANCE MANUAL 

FOR 

IRON AND STEEL MANUFACTURING 

PRETREATMENT STANDARDS 

Prepared by 

The 

Industrial Technology Division 

Office of Water Regulations and Standards 

and 

Permits Division 

Office of Water Enforcement and Permits 

September 1985 

U.S. Environmental Protection Agency 

401 M Street, S.W. 

Washington, DC 20460 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON. D.C. 20460 

OFFICE OF 

WATER 

MEMORANDUM 

SUBJECT: Guidance Manual for Iron and Steel Manufacturing Pretreatment 

Standards 

FROM: Martha G. Prothro, Director 

Permits Division on (EN-336) 

Jeffery D. Denit, Director 

Industrial Technology Division 

TO: Users of the Guidance Manual 

This manual provides information to assist Control Authorities and 

Approval Authorities in implementing the National Categorical Pretreatment 

Standards for the Iron ad Steel Manufacturing Point Source Category (40 

CFR Part 420). It is designed to supplement the more detailed documents 

listed as reference in the manual; it Fe not designed to replace then. 

If you need more complete information on a specific item, you should 

refer to the appropriate reference. 

EPA developed this manual to fill several needs. First, it should 

be useful to Control Authorities in responding to most routine inquiries 

from regulated mills. More complex inquiries may require the use of the 

listed references. 

Second, the manual addresses application of the combined wastestream 

formula to Integrated facilities with regulated and unregulated wastestreams. 

It also provides current information on removal credits, variances and 

reporting requirements. It further incorporates the final amendment to 

the categorical standards reflecting the settlement of litigation issues 

for the final rule. 

The manual is the third, in a series of industry-specific guidance 

manuals for implementing categorical pretreatment standards, and several 

others will be Issued soon. We also plan to issue manuals covering 

removal credits, the combined wastestream formula and the conversion of 

production-based categorical standards to equivalent mass-based standards. 

Please feel free to write to either the Office of Water Regulations 

and Standards (WH-552) or the Office of Water Enforcement and Permits 

(EN-336) with suggestions, additions or improvements. 
ACKNOWLEDGEMENTS 

We wish to acknowledge the considerable efforts and cooperation of the many 

people whose contributions helped in the successful completion of this document. 

The document was prepared under the direction of Mr. Marvin Rubin, 

Chief, Analysis and Support Branch, Industrial Technology Division and 

Dr. James Gallup, Chief, Municipal Programs Branch, Off ice of Water 

Enforcement and Permits. Mr. Gary Amendola of EPA Region V, ad Hr. Ed 

Dulaney of the Industrial Technology Division are to be acknowledged for 

their valuable input. In addition, members of the Office of General 

Counsel and other members of the Industrial Technology Division and Office 

of Water Enforcement and Permits are acknowledged for their Important 

contributions. 

This document was prepared by JRB Associates under EPA Contract No. 

68-01-6514. 
TABLE OF CONTENTS 

Chapter 

page 

1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . l-l 

1.1 HISTORY OF THE IRON AND STEEL MANUFACTURING CATEGORICAL 

PRETREATMENT STANDARDS . . . . . . . . . . . ..I...................... 1.2 

2. IRON AND STEEL CATEGORICAL PRETREATMENT STANDARDS (40 CFR 

PART 420) . . . . . . . . . . . . . . . . ..................................... 2.1 

2.1 AFFECTED INDUSTRY ......................................... 2-1 

2.2 PRETREATMENT STANDARDS FOR THE IRON AND STEEL MANUFACTURING CATEGORY ........................................... 2-1 

2.3 RELATIONSHIP TO ELETROPLATING METAL FINISHING AND ......... 2-21 

2.4 POLLUTANTS EXCLUDED FROM REGULATION ....................... 2-21 

2.5 COMPLIANCE DATES .......................................... 2-21 

3. TREATMENT TECHNOLOGIES ......................................... 3-1 

. 

3.1 TREATMENT OF COKEMAKING ............................ WASTES 3-1 

3.2 TREATMENT OF SINTERING WASTE ............................. 3-2 

3.3 TREATMENT OF IRONMAKING WASTES ............................ 3-2 

3.4 TREATMENT OF STEELMAKING WASTES ........................... 3-3 

3.5 TREATMENT OF VACUUM DEGASSING ...................... WASTES 3-4 

3.6 TREATMENT OF CONTINUOUS CASTING .................... WASTES 3-4 

3.7 TREATMENT OF HOT FORMING WASTES ........................... 3.5 

3.8 TREATMENT OF SALT BATH DESCALING WASTES ................... 3.6 

3.9 TREATMENT OF ACID PICKLING WASTES ......................... 3.7 

3.10 TREATMENT OF COLD ROLLING WASTES .......................... 3.7 

3.11 TREATMENT OF ALKALINE CLEANING WASTES ..................... 3.8 

3.12 TREATMENT OF HOT COATING WASTES ........................... 3.8 

4. REQUIREMENTS THE OF GENERAL PRETREATMENT REGULATIONS.......... 4.1 

4.1 INTRODUCTION .............................................. 4-1 

4.2 CATEGORY DETERMINATION ............................ 4-2 

4.3 MONITORING AND REQUIREMENTS REPORTING OF THE GENERAL 

PRETREATMENT REGULATIONS .................................. 4-2 

4.3.1 Baseline Monitoring Reports ........................ 4-2 

4.3.2 Report on Compliance ............................... 4-4 

4.3.3 Periodic Reports and Continued Compliance .......... 4-4 

4.3.4 Notice of Slug Loading ............................. 4-5 

4.3.5 Monitoring and Analysis to Demonstrate 

Continued Compliance ............................. 4-5 

4.3.6 Signatory Requirements for Industrial Users 

Reports .......................................... 4-5 

4.3.7 Recordkeeping Requirements ......................... 4-5 

i 
TABLE OF CONTENTS (Continued) 

Chapter Page 

4.4 APPLICATIONS OF THE COMBINED WASTESTREAM FORMULA 4-6 

4.4.1 CWF Conditions .................................. 

4.4.2 Monitoring Requirements for Industrial Users 

Using the CWF ................................... 

4.4.3 Application of the CWF .......................... 

4.5 REMOVAL CREDITS ........................................ 4-11 

4.6 FUNDAMENTALLY DIFFERENT FACTORS VARIANCE ............... 4-12 

4.7 LOCAL LIMITS ........................................... 4-12 

REFERENCES . . . . . . . . . . ....................................... 

4-7 

4-7 

4-7 

R-1 

ii 
LIST OF TABLES 

Table Page 

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

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

2.3 POLLUTANTS EXCLUDED FROM IRON AND STEEL REGULATION ............. 2-22 

4.1 COMBINED WASTESTREAM FORMULA ................................... 4-8 

4.2 COMBINED WASTESTREAM FORMULA EXAMPLE CALCULATION ............... 4-9 

iii 
1. INTRODUCTION 

The National Pretreatment Program established an overall strategy 

for controlling the introduction of nondomestic wastes to publicly owned 

treatment works (POTWs) in accordance with the overall objectives of the 

Clean Water Act. Sections 307(b) and (c) of the Act authorize the 

Environmental Protection Agency to develop national pretreatment standards 

for new and existing dischargers to POTWs. The Act made these pretreatment 

standards enforceable against dischargers to publicly owned treatment 

works. 

The General Pretreatment Regulations (40 CFR Part 403) establish 

administrative mechanisms requiring nearly 1,500 POTWs to develop local 

pretreatment programs to enforce the general prohibitions, specific 

prohibitions and Categorical Pretreatment Standards. These Categorical 

Pretreatment Standards are designed to prevent the discharge of pollutants 

that pass through, interfere with, or are otherwise incompatible with the 

operation of the POTWs. The standards are technology-based for removal of 

toxic pollutants and contain specific numerical limits based on an 

evaluation of specific technologies for the particular industry, categories. 

As a result of a settlement agreement between EPA and the Natural Resources 

Defense Council (NRDC), EPA was required to develop Categorical Pretreatment 

Standards for 34 industrial categories with a primary emphasis on 65 

classes of toxic pollutants. 

This manual will provide guidance to POTWs on the implementation and 

enforcement of the Categorical Pretreatment Standards for the Iron and 

Steel Manufacturing Category. This document is based primarily on two 

sources: Federal Register notices, which include the official announcements 

of the Categorical Standards, and the Final Development Document for Iron 

and Steel Manufacturing, which provide a summary of the technical support 

for the regulations. Additional information on the regulations, 

manufacturing processes, and control technologies can be found in these 

sources. A listing of the references used in the development of this 

manual is provided at the end of this document. 

1-1 
1.1 HISTORY OF THE IRON AND STEEL MANUFACTURING CATEGORICAL PRETREATMENT 

STANDARDS 

Steel manufacturing involves many processes, which require large quantities of raw materials. Because of the variety of products and processes in 

this industry, operations vary from plant to plant. Steel facilities range 

from plants engaging in a few production processes to extremely large integrated complexes engaging in several or all processes. Even the smallest 

steel facility represents a large industrial complex. 

The steel industry can be segregated into two major components, raw 

steelmaking, and forming and finishing operations. In the first, coal is 

converted to coke, which is then combined with iron ore and limestone in a 

blast furnace to product iron. The iron is purified into steel in tither open 

hearth, basic oxygen or electric arc furnaces. Finally, the steel can be 

further refined by vacuum degassing. The second component, following the 

steelmaking processes, includes hot forming (including continuous carting) and 

cold finishing operations. Primary hot forming mills reduce steel ingots to 

slabs or blooms and secondary hot forming mills reduce them to billets, 

plates, shapes, strips, and other products. Steel finishing operations 

involve other processes that do little to alter the dimensions of the hot 

rolled product, but impart desirable surface or mechanical properties. 

Water is essential to the industry and is used in appreciable quantities 

in virtually all operations. An average of 40,000 gallons of water is used in 

producing every ton of finished steel, making this one of the highest water 

users of any manufacturing industry. During the raw steelmaking and forming 

and finishing operations, toxic, nonconventional and conventional pollutants 

enter the wastewaters. EPA’s survey of iron and steel mills identified 141 

pollutants in plant effluents. Some of these pollutants pass through POTW 

treatment systems, interfere with biological treatment, or contaminate POTW 

sludges. Pretreatment alternatives for the iron and steel industry art 

designed to control toxic metal pollutants and to recycle wastewater to the 

manufacturing process. Common treatment technologies include oil skimming, 

metals precipitation, sedimentation, steam stripping, solvent extraction, 

biological oxidation (coke wastes), thickening, filtration, and vacuum filter 

1-2 
dewatering. Typically, the design, purchase and installation of this 

eguipnent requires 18 to 36 months. 

Pretreatment standards for the iron and steel industry regulation were 

first proposed in February 1974, and wer8 first pmmlgated on June 28, 

1974. the most recent final regulations, which established specific 

nunberical limitations falling within 10 of the 12 subcategories, were 

propos& in January 1981 and finalized on May 27, 1982. 

Petitions to review the final iron and steel industry regulation wr8 

later filed by certain mmbers of the iron arxl steel industry arri the 

Natural Ftesources Defense Camcil Inc. (NRDC). The challenges raised 

wer8 consolidated into one lawsuit, at-d in February 1983, the petitiorrers 

and EPA reached a settltment agreemnt. This axqmzhensive settlenrent 

resolved issu8s related to th8 steel inckmtty stamkds and on Octcber 

14, 1983, changes to the regulation ore proposed. These major amm&mnts 

to the Ircm and Steel Standards ore prumlgated on May 17, 1984 (49 FR 

21024) and include: 

(1) An interim regulation establishing the method for calculating 

applicable mass-based pretreatmmt standards; 

(2) Establishment of July 10, 1985 as date of final mliance with 

iron and steel pretreabnent star&&s; 

(3 1 Pretreatment ma1 credits for phenols measured by the 4 AAP 

KU3thOd; 

(4 1 Starrdards that are slightly hfgher for lead ard zinc in the 

Sintering and Irommking Subcategories: 

(51 Standards that ar8 slightly higher for lead ad zinc in th8 

Acid Pickling Subcategory: 

(6) Modified effluent limitations and standards for zinc in th8 Hot 

coatirq Subcategoty; 

(7) Modified canbined wastestrean fomla to alI- control authorities 

t0 8~8rCi88 jtXkpU3nt t0 d8t8mine whether bloxlmm and fMmcoMaCt 

cmlirq strems are dilution or unregulated process stmaae; 

(81 Regulation for pemittirg nminal discharg8S of spent oil or 

water solution in the cold worked pipe and tube segnenta of the 

Cold Pollitx~ Subcategory, with a statenent that limits ard 

standards for process wastewaters not regulated by prior 

regdation are to be developed on a CaSeby-CaSe basis. 

l-3 
2. IRON AND STEEL CATEGORICAL PRETREATMENT STANDARDS 

(40 CFR PART 420) 

2.1 AFFECTED INDUSTRY 

The Iron and Steel Standards are applicable to wastewater discharged from 

industries included within the Standard Industrial Classification (SIC) Major 

Group 33 - Primary Metal Industries. Those parts of the industry covered by 

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

3316 and 3317 and parts of 3479. 

In developing this regulation, EPA determined that different effluent 

limitations art appropriate for distinct segments of the Industry. The Agency 

identified 12 main process subcategories which art: 

1. Cokemaking 7. Hot Forming 

2. Sintering 8. Salt Bath Descaling 

3. Ironmaking 9. Acid Pickling 

4. Steelmaking 10. Cold Forming 

5. Vacuum Degassing 11. Alkaline Cleaning 

6. Continuous Casting 12. Hot Coating 

These twelve Iron and Steel Operations art briefly diecussed below: 

1. Cokemaking 

Coke plants art operated at Integrated facilities to supply coke for 

producing iron in blast furnaces or at stand-alone facilities to 

supply coke to other users. Nearly all active coke plants also 

product usable byproducts such as coke oven gas, coal tar, crude or 

refined light oils, ammonium sulfate or anhydrous ammonia, and 

naphthalene. A byproduct coke plant consists of ovens in which 

bituminous coal is heated without air to drive off volatile components. The coke is supplied to blast furnaces, while the volatile 

components are recovered and processed into byproduct materials. 

The most significant wastewaters generated during byproduct cokemaking and byproduct recovery operations art excess ammonia liquor, 

final cooler wastewater, light oil recovery wastewaters, barometric 

condenser wastewaters from the crystallizer, desulfurizer wastewaters, and contaminated wastewater from air pollution emission 

scrubbers for charging, pushing, preheating, and screening operations. 

2-1 
2. Sintering 

Sintering is an agglomeration process in which iron bearing materials (generally fines) are mixed with iron ore, limestone, and 

finely divided fuel such as coke breeze. The fines consist of mill 

scale from hot rolling operations and dust from basic oxygen 

furnaces, open hearth furnaces, electric arc furnaces, and blast 

furnaces. The raw materials are mixed before they are placed on the 

traveling grate of the sinter machine. Near the head end of the 

grate, the surface of the raw materials is ignited by a gas fired 

ignition furnace located over the bed. As the mixture moves along 

the grate, air is drawn through the mixture at the wind boxes to 

enhance combustion and sinter (fuse) the fine particles. As the bed 

burns, carbon dioxide, cyanides, sulfur compounds, chlorides, 

fluorides and oil and grease are driven off with the gases. 

The sinter drops off the grate at the discharge end and is cooled 

(either by air or a water spray), crushed, and screened to maintain 

uniformity in the site of the sinter fed to blast furnaces. 

Improperly sized sinter and fines from screening are returned for 

reprocessing. 

3. Ironmaking 

Byproduct coke is supplied to blast furnace processes where molten 

iron is produced for subsequent steelmaking. Iron ore, limestone 

and coke are placed into the top of a blast furnace and hot air is 

blown into the bottom. Combustion of the coke provides heat and a 

reducing atmosphere that produce metallurgical reactions. The limestoat forms a fluid slag, which combines with unwanted impurities in 

the ore. Molten iron and molten slag, which floats on top of the 

iron, art periodically withdrawn from the bottom of the furnace. 

Blast furnace flue gas is cleaned and then used to preheat the 

incoming air of the furnace. 

Blast furnace operations use water for two purposes: (1) noncontact 

cooling of the furnace, stoves, and ancillary facilities not 

governed by these regulations, and (2) cleaning and cooling the 

furnace top gases. Other waters, such as floor drains and drip 

legs, art also part of the process wastewaters, but the volume from 

these sources is relatively low. 

4. Steelmaking 

Steel is an alloy of iron containing less than 1.0 percent carbon. 

Raw materials for steelmaking include hot metal, pig iron, steel 

scrap, limestone, burned lime, dolomite, fluorspar, iron ores, and 

Iron-bearing materials such as pellets or mill scale. In steelmaking operations, the furnace charge is melted and refined by 

oxidizing certain constituents, particularly carbon In the molten 

bath, to specified low Levels. Various alloying elements are added 

to product different grades of steel. Steelmaking processes in use 

today are the open hearth furnace, the electric arc furnace, and the 

2-2 
basic oxygen furnace (BOP) which is the only one currently associated with discharges to POTUs. 

Steelmaking processes generate fumes, smoke, and waste gases aa 

impurities are vaporized. Wastewatere are generated when reml-wet 

or wet gas collection systems are used to condition and clean the 

furnace off-gases. Partlculates and toxic metals In the gases are 

the main source of pollutants and contaminants in process wastewaters. 

Four main water systems are used in BOP steelmaklng operations: 

l Oxygen lance noncontact cooling 

l Furnace trunnfon ring and nose cone noncontact cooling 

a Hood noncontact cooling 

l Fume collection ecrubber and gae cooling. 

Host steeluaklng operations recycle wastewaters to some degree. 

Several plants recycle more than 90 percent of their process 

effluents. Recycling 1s a good water conservation practice as tt 

not only reducee the volume of fresh water needed by the gas 

cleaning system, but also reduces the volume of wastewater discharged. 

5. Vacuum Degassing 

In the vacuum degaeeing process, molten steel is subjected to a 

vacuum to remove gases (principally hydrogen, oxygen, sulfur, and 

nitrogen). The gasea can Impart detrimental qualities to finished 

steel products if they are not removed. 

Fumes and waste gases are generated by impurities in the steel. The 

hydrogen, oxygen (reacted uith carbon), and nitrogen dissolved in 

the steel are drawn out by the reduced pressurea in the vacuum 

chamber. Wastewaters are generated In the vacuum degassing procese 

when exhaust steam, used to educt the fumes and gases, is condensed 

in spray cooling (contact) chambers. Pollutants in the eystem 

exhaust contaminate the cooling water, which is discharged into a 

sump (hot well) through a stand-pipe. 

6. Cont inuoua Cast in& 

The.continuous casting subcategory includes both ingot casting and 

continuous casting processes. Ingot casting is the conventional 

procedure of casting molten steel into ingots followed by reheatfng 

and breakdown in primary hot rolling mills into semi-finished shapes 

known as billets, blooms, or slabs. 

In the continuour casting procesu, hot molten steel is poured from 

the ladle into a refractory lined tundleh. The tundiuh maintains a 

constant head of molten metal and can distribute the molten steel to 

more than one casting strand in multiple etrand operations. The 

2-3 
molten metal from the tundish poure through nozzles into an oecillating, water-cooled copper mold, where partial aolldification taker 

place. Lubricants, such as rape seed oil, are rprayed into the 

molds to aid steel movement through the mold. Aa the metal eolidiflea in the mold, the cast product is withdrawn continuously. After 

passing through the water-cooled molds, the partially rolldffled 

product loves into a secondary cooling zone, where water rpraya cool 

sad solidify it. 

The contlnuoue casting process has three main water ayrtems: 

l Copper rold noncontact cooling water system 

l Machinery aoncontact cooling water system 

0 Cart product rpray contact cooling water system. 

Only the cart product spray coatact cooling water is subject to this 

regulatioa aa the other two ayrtema uee noncontact cooling water 

only. Bowever, lcaka of noncontact cooling water into the process 

water ryatcm would also be treated. 

7. Hot Pormfaq 

Primary hot forming rills reduce ingots to l laba or blooma and 

recondary hot forming mills reduce slabs or blooma to billets, 

plates, rhapea, #trips, and other forms. 

The basic operation in a priury mill la the gradual coqre8aioa of 

the rtecl ingot between tM rotating rolls. Multiple pa8aea through 

the rolls, usually in a reversing mill, are required to rerhape the 

ingot into a l lab, bloom, or billet. Aa the ingot pure@ through 

the rolls, high prerrure water jets remove surface scale. The ingot 

paarea back aad forth between the horltontal aad vertical roll8 

while uaipulatora turn it. When the desired rhape ir achieved in 

the rolling operation, the end pieces (or cropr) are rheared off. 

The remi-finirhed pieces are rtored or sent to reheating furnaces 

for lyre ahaping. 

Scale, oil and grease are the conventional pollutants dircharged 

from rolling mill oper8tfoar. Aa the hot steel is rolled in the 

mill stands, the rteel rurface oxidizes and rcaler or flakea off. 

The l c8le particler, ranging in l lze from rutmicron to reveral 

millimetera, are carried by water to rcale pita where they rettle 

out 0 Tha particle8 are TO-75 percent iron aa ferrour oxide (PeO) 

and ferric oxide (Pe203). Overhead craae8 equipped with clam 

bucket8 are generally used to clean the scale pft8. Scale pit 

effluents are discharged to pl6ot l euera or are partially recycled 

back to the rills. The eurpended aollda in rcale pit overflow8 caa 

he as high as 300 w/l. These waatewatere can k Eurther treated by 

clarification, filtration, aad recycling. 0118, generally in the 

range of 15 to 45 q/l, are found in rolling mill waatewatere 

because of oil conditioning, oil l pilla, line rupture8, excessive 

dripping of lubricants, and equipmant waah-doun. Uartewater concentratioru as high aa 150 mg/l may be reached during line ruptures. 

2-4 
8. Salt Bath Descaling 

Oxidizing and reducing are the two procesaea within the salt bath 

descallng subcategory. The oxidizing process uses highly oxidizing 

salt bathe maintained at temperatures of 700-900’P. These salts 

react more aggreaalvely with scale than with the base metal and, as 

a result, produce a smoother surface than acid pickling. 

During the oxiditlng process the steel product la placed in the 

oxidizing bath after being tempered. After the product has been 

exposed to this chemical and thermal action, it is cooled in a 

“cold” water teak- Together, the chemical action and the sudden 

cooling and steam formation cause the surface scale to crack, so 

that aubaequent pickling operations can be more effective. 

Reducing operations are alnilar except that they depend upon the 

strong reducing properties of sodium hydride (1.5 to 2 percent by 

weight) In a fueed caurtic soda bath at 700.P. Reducing operations, 

like oxidlting operationa, are operated as integral parts of the 

plckliag process. 

9. Acid Pickling 

Acid pickling ir the process in which 8teel products are IPrereed in 

heated acid aolutionr to remove eurface scale. 

Waatewaterr are generated by three major aourcea la pickling 

operations. The largest source La the rinse water used to clean the 

product after it has been imersed in the pickling solution. The 

second source la the spent pickling solution, or liquor, that has 

become too weak to continue to treat the steel products. The spent 

pickle liquor la a small volume, but La very acidic and contains 

high concentrations of iron and toxic metal pollutants. It is diecharged intermittently. The third Bource la wastewater frw wet 

fume scrubbers. 

10. Cold Rolling 

Cold-reduced flat rolled products are made by cold rolling pickled 

strip steel. The thicknear of the steel is reduced by 25 to 99 

perceat in this operation to produce a smooth, dense surface. 

The major procear water use in cold rolling ml116 la for cooling and 

lubricating the rolls and the steel product. This la done with 

flooded lubrication system, where a water-all emulsion la sprayed 

diractly on the product and rolls. Each stand usually has separate 

rprayr and, if ured, a separate recycle system. Paet practice waa 

to discharge the water-oil wastes directly to the sewer. However, 

the high cost of rolling oila and pollution control regulations have 

changed this. Recycle and recovery system are now in comon use. 

In fact, wat of the sewer cold rolling mills use recirculated oil 

eolutlon ayateu to reduce oil use and pollutant dischargea. 

2-5 
11. Alkaline Cleaning 

12. Hot Coating 

Alkaline cleaning is used where vegetable, mineral, and animal fate 

and oils must be rewved from the steel surface prior to further 

proceaaing. Solutions of various compoeitions, concentrations, and 

temperaturea are often used for cleaning. Electrolytic cleaning pray 

be used for large scale production or where a cleaner product is 

required. The alkaline cleaning bath is a water solution of 

carbonates, alkaline slllcatea, phosphates, and sometimes wetting 

agents to aid cleaning. 

Wastewaters are discharged from two sources in alkallne cleaning 

lines : the cleaning solution tank and the subsequent rinsing steps. 

The cleaning solution tank contains a caustic solution with high 

levels of sodium compounds and other components. At some lines, the 

cleaning solution Is reused contlnously. Fresh solution is added to 

make up for dragout and evaporative loeaea. The baths are diacharged periodically to limit the buildup of contaminants (dissolved 

solids and oils), or a8 soon as the cleaning ability of the solution 

la weakened. A process being developed includes an ultrafiltratlon 

ayatem that continuously treats the alkaline cleaning solutions and 

allows higher reuse ratea. 

Because wet alkaline baths are used to clean large awunta of 

steel, pollutants can build up to high levels. Typical levels of 

pollutants found in alkaline cleaning baths are shown belowr 

Pollutant or 

Wastewater Characteriatlc Typical Value8 (mg/l) 

Alkalinity 1,ODo 

Iron, total 100 

Oil 6 Crease 1,500 

pEl (unite) 12-13 

Total Dissolved Sollda 25,000 

Total Suspended Solids 1,000 

Temperature 70’-2OO.P 

The other tsource of wastewaters from the alkallne cleaning process 

I8 the rinse step, which follows the cleaning operation, and is 

required to rewve residual cleaning solution from the product. 

Rineing is done in spray chambers or one or reveral dip tanks 

depending upon the degree of rinalng required. Although l oae lines 

have standing rinse tanks (no continuous flow through the tanks), 

many lines have rinse tanks with continuous water feed and overflow 

to keep the rinse water cleaner and to cool the product. 

Hot coating proceeaea involve dipping clean steel Into baths of 

wlten metal to deposit a thin layer onto the steel bufface. These 

coatings provide desired qualitiee, such as reeistance to corrosion, 

eafety from contamination, or a decorative bright appearance. The 

2-6 
two major classes of mtalllc coating operations In the industry are 

hot coating and cold coating. Zinc, terne, and aluminum coatings 

are wet often applied from molten metal baths, while tin and 

chromium are usually applied electrolytically from plating solut lone. Nearly all hot coating operations discharging to POTUs use 

the galvanizing process (zinc). 

The major wastewater flows originating from hot coating operations 

fall Into three groups: 

l Continuous dilute wastewatere from rinses following chemical 

treatment or surface paeslvation steps and final product rinses 

after hot dipping. These water8 contain suspended and dissolved 

solids, chlorides, sulfates, phosphates, elllcatee, oily matter, 

and varying awunts of dissolved metals (iron, zinc, chromium, 

lead, tin, aluminum, cadmium) depending on which coating metal Is 

used. 

s Concentrated Intermittent discharges (including fluxes), chemical 

treatment solutiona, and regenerant solutions from in-line Ion 

exchange systems. These discharges contain higher concentrations 

of the pollutants noted above. Discharge volumes from these 

sources can be minlrized by close attention to maintenance and 

operating conditions, and by using dragout recovery units. Hot 

dipped coating bathe themselves are never discharged. In8 tead, 

they are recovered and continuously regenerated as part of the 

coating operation, or by outside contractors. 

l Fume scrubber wastewaters are produced by the continuous scrubbing of vapors and mists collected from the coating steps. 

Scrubber wastewaters may be used as process rinses, since only 

volatile components are present in the air to be scrubbed. Less 

than 40 percent of all hot coating lines have wet fuPe scrubbers. 

A few plants have dry fume absorbers. 

Many of the subcategories were further divided to account for differences 

in manufacturing procereea and equipment. Separate limits were then developed 

for each subdlvlslon. 

2.2 PRETRRATFIENT STANDARDS FOR THE IRON AND STEEL MANUFACTURING CATEGORY 

The categorical pretreatment standards for the Iron and steel Industry 

dlatinguish between exleting sourcee and new sources. As a general rule, EPA 

establiahe8 pretreatment standards on the basis of concentration. However, 

for the rteel industry, the Agency bellevee the standards should be based upon 

mesa limltation8 (kg/kkg) to ensure that effective toxic pollutant control is 

provided and to minlnlte the hydraulic impact of large volume discharges on 

2-7 
POTUS. These standards are expressed as maximum 30-day average and maximum 

dally mass llmftatlons in kilograms per 1000 kilograms (lbs/lOOO lba) of 

product (except for acid pickling and hot coating operations with fume 

scrubbers where mass limitations are expressed in kilograms per day for each 

scrubber). 

The pretreatment standards for existing sources (PSES), with the exception of cokemaking, are equivalent to best available technology (BAT) for 

direct dischargers. BAT represents the wastewater treatment processes 

necessary to achieve best available economic performance of wastewater 

treatment at plants of different ages, sitea, production rates, and other 

factors. The standards for cokemaking facilltles are based on treatment 

technologies installed to pretreat cokemaking wastewater prior to on-site 

biological treatment. These levels of treatment include technologies for 

removing toxic pollutants, both by process wdlflcation and by end-of-pipe 

treatment , which could parse through or otherwise be incompatible with the 

operation of a POTU. Pretreatment standards have been developed by EPA for 10 

of the 12 iron and steel subcategories. The two eubcategorles which do not 

have pretreatwnt standard8 are Subpart G - Hot Forming and Subpart K - 

Alkaline Cleaning. For these two subcategories, EPA has determined that there 

are not significant quantities of toxic pollutants to upset or pass through 

PO’fW treatment plants or limit POTU sludge management alternatives. For the 

10 regulated subcategories, the limits are presented in Tablee 2.1, a-f. 

The pretreatment standards for new sources (PSNS) apply to iron and steel 

manufacturing facllltles for which construction began after January 7, 1981, 

the date of the proposed regulation. New facilities are able to incorporate 

process controls that reduce pollutant loadings, so in come cases the PSNS are 

more stringent than PSES. The PSNS are based on the beet available demonstrated technologies and for wet subcategories are identical to the PSES. 

The exceptions are: Subpart I - Acid Pickling, Subpart J - Cold Forming, and 

Subpart L - Hot Coating. The PSNS for these three subcategories ate presented 

in Tables 2.2, a-f. 

2-8 
rnEtUlllmlT STANCURDS ror KxtsTIE SOUIUS (Pscs) 

POUIJTAJIT LlNlTs (la kg/K&g of pro&cc umlea* 0rhen1.0 nocod) 

s&part 

Pbonol llxpbtba- Tetrachloro- Cyoalk tbxxroIoar 

-1x Cblorloo (hAr) Len l thyA.0. Chralvr (Total) Lad YLcLcl Zinc Cbraium 

&. cukutly 

1. ICM wd SCWll ho. 0.0122 0.0215 0.00159 

wax. 0.0645 0.043 O.OL72 

2. krchut2 Avm. 0.0315 0.025 0.0100 

ka. 0.0751 0.0501 0.0200 

B. Sl*t~rly’ AW. 0.00501 0.oooo501 0.00150 0.ooo150 0.000225 

Max. 0.0150 0.000100 0.00300 0.000451 0.000674 

C. Iroahklry 

Irw *v*. 0.00292 0.0000292 0.000@16 O.OtXJO616 0.0001 II 

kx. O.OWlb O.OOMM4 0.00175 0.000263 0.000394 

?.rr0- 

uplUW.* 

0. Ito* ldle# 

1. maslc osygu 

hruu 

(roP)c kriut* 

2. DOP: uot-opom AVO. O.OOOlY 0.oOO201 

uu. o.oocM13 o.mo620 

3. Bw: uot- b*. O.Oooo62b o.OOoo939 

wppmood nax. 0.ooo1u 0. ooo282 

2-9 
TABLK 2.lb 

PNfTIM’TwwT STAllDMDS 1011 EXlStt~ !%UXC@!Zi (PStS) (Contfnued) 

wLuJTu(t LflllTS (In CSfrkS of product unleso otherufse noted) 

subpmt 

Phenol naphtha- ret rachloto- Cyanide Ntrav~lcnC 

tinta Chlorlar (QAP) ltne ethylene Chraluo (Total 1 LLad n1ctc1 ZlOC cbraluo 

5. Il0ctrlc Arc 

Purnoco UN): 

kalwt* 

6. UP: u*c AW. 0.omluI 0.00020~ 

MU. 0.oow13 o.ooo62o 

K. VW- AVO. o.aMo311 O.moo669 

oegumiy hx. o.OooO939 O.ooa14L 

r. Comt1muouo Ave. 0.0000111 O.OOOOb69 

comt l*I au. o.oom939 0.ooo161 

C. Not ?ormly** 

4. OxldlrIng - 

1. Batch. Sheet Ave. 

sod plate Mu. 

0.00117 O.WO616 

0.00292 0.00263 

2. Satch. Rod Ave. 0.ooo701 0. WO526 

od Ylro ks. 0.00175 0.0015I 

3. Such. ?lfm Ave. 0.00216 0.002I3 

sod Tu’ubr Hal. 0.00709 0.006M 

4. CO*ttWOW h*. 0.000551 O.ooo6l3 

ka. 0.001 M 0.00126 

A**. 0.000512 0.0001l9 0.wo607 

nw. 0.00136 0.00102 0.00122 

2. Cont I wou, Art. 0.00304 0.00190 0.0022lJ 

kx. 0.00159 0.00569 0.00683 

2-10 
TAAU 2.1~ 

PUTMA- STUlOUDS IOI KXLSTINC !XUCCCS (PSRS) (Coatlnud) 

PtlLlVIUlT LlnITS (in 4/Kkr of product ~18~ ocbond~8 noted) 

Subpart 

?hOIbol Naphtha- Totrachloro- Cyanid neruvalsnt 

-la Chlorlv (4Au) 1.M l tbylorm Chrodur (Total) Load WlCk.1 zinc chrom1ur 

I. Acid ?lcklly 

4. Sulfuric 

Acid ?lckllag - 

1. bd. Wm. Ave. O.oabl75 0.000234 

od coil nu. 0.000526 0.ocK4~01 

2. hr. Slllet. Ave. o.OwO563 o.oaOlu51 

ad Bloa lbl. o.mlL9 O.ooO225 

3. Strip. AU. 0.m1 I3 0.Ooul50 

shut , @Iax* 0.000339 0.000451 

ad wat* 

4. ?lpe. Tub., Ave. O.oOo3l3 O.UOO411 

4 Otbor ka. o.Qoo93m 0.00125 

5. Irw 

Scrubber’ Ave. 0.0123 0.0164 

(kg/&y) max. 0.0368 0.0491 

b. Mydrochlorlc 

&Id Plcklly - 

1. Knd, Ylra. AV8. O.OUOM? u. ow409 

od 42311 lla8. o.Ooo92o 0.00121 

2. Strip. 

--t, Ave. 0.000115 0.000214 

J r1ato lamx. 0.000526 0.oou101 

3. ?lpm, Tub., Avo o.wob38 O.ooo651 

nd Other Itax. 0.00192 0.00255 

4. ?w 

Scrubber’ 

Ave. 0.0123 O.UlbC 

km. 0.0368 0.0491 

5. Acid Be- Art. 

~totrmr loo6 k8. 

0.0819 U.lU9 

0.245 0.012/ 

(*bBorbtr 

vent scrubber 1 

(kI/dAY) 2-11 
TABU 2.Ld 

~RcTMA~cI~T ST*wDuW IOI EXiSTlm; SOURCU (PSCS) (Comt1nu.d) 

POLLUTANT l.lHtTS (la kg/Us of prodact unleoa orbonl~~ noted) 

Subpart 

tbam 1 !lqhtha- Tat rachloro- Cyamlda nexavaleat 

*ronla Cblorlna (UN) 1.m ethylma c?lhrorlur (Total) Lead Ylckal ZlfU Chratur 

c. cooblutloa 

Acid Plckllag 

I. Rod. Ylrm. Ave. 0.000952 0.0006M 

ond Coil h. 0.00213 0.00192 

2. Bar. Btllar, Ave. 0. ow384 0.ow2.0 

and Bloom #Ia=. 0.0009bO 0.WO.W 

3. Strip, Shot, Ave. 0.00250 O.WlM 

ud mat. - Mu. 0.0012b 0.00563 

coat lmuou~ 

4. Strip. Shut. Ave. O.OW?M 0.00057b 

l d Plato - kx. 0.00192 0.001~3 

kCCb 

5. Pipe. T&R, Ave. 0.00129 0. ooo9b4 

and Otbm ks. 0.00322 0.00219 

Ava. 0.0327 0.0245 

nan. 0.0819 0.0735 

.I. Cold PormlaS’ 

. . Cold RolllnS 

I. Iocltcula- Ave. 

Clam, Slyle ltmx. 

stmd 

O.OOOOO84 0.oOOoO31 o.OoOm63 o.aNaOo21 

o.anKN321 0.OOOm31 0.OOOo209 0.m 0.OoOo1M o.amO63 

2. Roclrcula- Ave. 0.m104 O.OOoQl56 O.oaOO4lI 0.0000156 0.OoOO313 0.m104 

Cloa, bltl- max. 0.000104 0.0000169 o.oooo939 0.oOoO313 

plo scan& 

I. Curblnac Ion AV. O.OwMJl 0.0001S4 O.ooO37b O.WO125 

maa. 0.000125 0.ooo198 0.00125 0.000563 0.001l3 O.OOU376 

2-12 
TUU 2.h 

-TlWlfT STUDUW IOI CXISTIE SOUyEts tPS#S) (b~t1m.d) 

mLvtyn Lll(lTS (lm kg/Us of product ulom othorr100 noted) 

Subart 

tin01 nqbtha- Totrachloro- Cyul1& nouva lomt 

*roala Chlorlw (4AM) 1.0. l thyh8# Chralv (Total) Iad Mlck.1 Xlnc Cbralvr 

4. Olrmct 

Appllcstlom. Am. 0.m150 o.Oooo563 O.ofJoI I3 O.Oooo376 

SlR#lO nox. O.oooo316 o.oooo543 O.ooo37b O.ooo169 o.ooo338 0.aIO1 I3 

stnd 

5. Dlroct A-. O.WObM 0.000250 O.WO501 0.ooOlbl 

4ppllcatlom. ka. 0.000161 o.wo25o 0.00167 O.o00?51 0.00150 0.000501 

lblt lplo 

Btud 

b. Cold Uorkd 

ripa #d hk 

tllllr 

I(. AlkalIno 

c1*u1a#** 

L. mot rawlm# 

. . calrul~l~ Ave. O.OW31b O.WOW 0.amo501 

am4 Orbar umx. O.Wl13 O.Wl50 O.WOlY) 

Co~Cl~ - 

Strip. Shot. 

l d ltlac. 

b. calvul~ly - Ave. O.Wl50 o.w2w o.ooo2oo 

Ylra Pro&em nos. 0.00451 O.oowl 0.ooo6o1 

04 Putomro 

c. Pur 

krrbbro 

(kr/day) 

A-. 0.0123 O.OlU 0.00163 

noa. 0.03bLI o.oI91 0.00490 

Ava. - Averqo of dally vmlwo for 30 co~~c~tlvo daya 

ka. - kale for uy oy day 

)Ttrim~imtvtomnfd. 
TABLE 2.lf 

PUTUATlWfT STANDARDS IOU KXlSTINC SCWKCS (PSCS) (Conttnuad) 

1 Iocreuod lod11~0, not to exceed 24 porcoot of thaa l taadarda, art l llwod for by-product coke plonta that have uot dtmlfurlr~tloo l yrtcr, krt only to 

tbm utoat that ouch l yotor gtnorato oo lncroaood l fflwnt volume. Incrouod loadlqe, not to oxcood M porcoat of theme l rmdarda, are l llouod for 

by-product coke planta that bare idlroct -14 rocovory l yotomo, but only to tho oxtent that ouch l yrtm powrat an increamed l fflunc volur. 

2 Imcromod 141-o. not to oxcood 21 porcomt of thro l tandarda are l llowd for by-product coke plaatm that have uot dosulfurlcatlon l y#tou. hut ooly to 

tbo l stont that ouch ayam aoaorato a lmcrooood effluent vole. Incroaood Loadlngo, oat to l mcoed )o percent of theme l tmndardm, arm l lloumd for 

by-pm&cc co&o plaoto that bare ldlroct -la rocovory l yotom, but only to tbo oRtent that ouch l yatea ~ooororo an lacreaood offluont vol\w. 

3 

Ibo l tmdordo for -lo+, cyoolb, omd pboaols (4Au) are l ppllcablo only tiea l lnrorlnS uastouator lo treated along vlrh ironmaking waatowotvr. 

4 Tbooo llmlto apply to each flrr rcrubbor l ooocIatod ulth l ulfurlc l ctd plckllrq oporatlomo. 

5 Thomo llmlto apply to each fuu l crubbor uooclatod rlth hydrochloric acid plckllng opormtlonr. 

6 Woo llmlto apply to aboorbor root l crubbor uwtouacor l oooclatod rlth bydrochlorlc acid regoooratloo planto. 

lor procooaoo roaulatod by Subport J, rho llmltr oo chromium and nlckol apply lo llou of the lloltr oa led and slnc mboa cold rolllly wastvuat8ra vro 

trmtd rlth &ocallq or cdlnatla wld plckllly water.. 

B Dlwhargoo frm thou operatlonm to habllcly md Treatrnt York. l rm prohlbltod. 

2-14 
TMLP 2.2a 

PYETfU!ATIffUlT STUIDAllNi Iw MU SWIUZS (PSUS ) 

POLU~TANT LIMlTS (In kg/Kka of pru&cKt unltmm otherulo. noted) 

Subpart 

Ph*OOl hphLhC T.t r.chloro- CyanId. IkXAVAl~llL 

tile Cblor lly (SAAF-1 18lw l cbylona Chromlm (Tor.1) 4.d Ylcktl Zinc Chralum 

A. COkOOOklpI 

1. lroo end St-l’ Ave. 0.0322 0.0215 0.001)59 

naa. 0.0645 0.043 O.Ul~2 

2. ltercbat2 AVO. 0.0315 0.025 O.OlW 

ka. 0.0751 0.0501 0.0200 

3. B..hl vd 

B. Slmr*rlmg3 AV.. o.w501 O.WWMl uO.Wu)l o.awlw O.ooo225 

flu. 0.0150 0.ooo1w 0.00100 0.ooo451 O.OUOb?b 

C. lroauklnc 

I. lroa Ave. 0.00292 O.WW292 0. My)292 O.WW?M O.wwU1b 

kx. O.otm?6 0. oooo544 O.ooO% O.WO219 O.OW263 

2. Perro- 

~&l~NhOU~ 

D. SL..lm&1~ 

I. Bulc Oxy#on 

lurnaco 

(aoP)G somlwet’ 

2. mp: Yet-op8n AV.. 0.w13LI U.WUlU? 

Hex. 0.ow411 O.WfmZO 

3. Boot: umt- AV8. O.WW626 o.cinnEa39 

l 94ppremoed )(u. O.OOUlfld 0. Wo2a2 

4. Open Hearth 

Purntct: utt* 

2-15 
TABU 2.2b 

RETREATWWT STANDARDS 1011 YtY SODRCJ!S (PSNS) (ContImed) 

PIXLUTANT LIMITS (In k#/Kk# of product unleae oLhorula8 noted) 

Subport 

Pheno 1 Nephthe- Tot r.chloro- Cyoddo N.a~vm10.L 

-1. Chlorln. (4cwl 1elU ethylon. Chralw (Tot.1) b.d Nlck.1 Zinc Chralur 

5. Ilectrlc Arc 

Puruce (WI: 

sod-umt* 

6. w: uot A-. 0.000139 0.ow207 

hex. o.OW413 o.wob2o 

K. VoclBum Ave. o.mOO313 0. ooOo469 

Do~00. 1y nu. o.Oom939 0.000l41 

1. cortlCut1y 

c. not PotnlyH 

AVO. o.WW313 O.oOoD469 

Max. o.oow939 O.cNJoL41 

Y. Salt math 

oooully 

. . Oaldlrly - 

I. Botch, Soot Ave. 

mod ?1*t. nu. 

O.Wll7 0.000876 

0.00292 0.00263 

.I. Bmtcb. bd Ave. o.a30701 O.OW526 

mmd Ulro Mea. 0.00175 O.Wl5I 

3. Botch. l lpa AN. 0.00284 0.00213 

ad Tub Roa. 0.00709 0.00638 

4. Cortl- Ave. o.Wo551 o.Wo413 

kx. O.WlM 0.00124 

b. IeducIng - 

I. Bet CL Ave. o.WO542 0.000339 0. ooo6Ol 

Il.=. O.Wl36 O.WlO2 O.Wl22 

2. CodfwoM Ave. o.w304 O.Wl90 0.00228 

ka. O.Wl59 0.00569 0.00683 

2-16 
tau 2.2c 

-m stAnMRDS m luu sou8us (rsus) (c4aar1nued) 

PoLlmAut Llnlts (lo kg/UC of product rul.~~ 0thorutB. OoCd) 

tieno 1 UBphthB- tat rachloro- CyBUl& lkruvBlent 

konh rnlorlm (u&t) LBnB l chylem rnrau (lord) Leti YlCk~I Zinc mhr0dur 

I. AC14 Plcklly 

. . Sulfuric 

Acid Plckllrq - 

I. Eod, Ylra, AW. O.UOOO3ll O.cxKnL17 

l sd co11 b. o.wM3939 O.oooL25 

2. Bar, 1111at, Ave. O.oooO18C 0.owo250 

ad gloom k8. 0.0000563 O.UOOO75L 

3. Srrlp, Are. 0.ooOO250 lLa300334 

Stuot, aax. O.oouo?5~ O.CWJLoO 

Bed PlBU 

4. ?lpe. t&B, Are. 0.000013ll o.OOoO584 

~4 Qber ibaa. o.ooo131 0.000175 

5. lun 

Serubbac' 4ro. 

(kg/&y) kx. 

0.0123 O.OLb4 

0.03bc 0.0491 

b. Yydrochlorlc 

Acid ?lcLlly - 

L. Cod. Yirm, AVO. O.UOOO37b O.UOOO5Ul 

Bad ceil mm. 0.000113 O.OOCU150 

2. Strip, 

abet, Ave. 0.0000250 u.m334 

Bd rIBto kl. o.oooo751 O.ooOloO 

3. ?lp. tube, Avm O.UOUObU O.OUOO918 

Bad OtbBr ka. o.ooo2Oh 0.000275 

4. vuou 

Scrubber 5 

Ave. 0.0123 0.0164 

ha. o.o%a 0.0491 

(L#/dBf) 

2-17 
hem I Uaphtha- Totrachloro- Cyanide lbxavalont 

-18 Cblorlw (WI l*w l tby1.u Chrorlur (Total) kad NLckel Zlac Chralu 

c. CombIutla 

&cl4 ?1cklly 

1. W, Yiro. Avm. O.omll7 O.OOOtM?tJ 

d co11 au. 0.000292 0. ooo263 

2. asr, Billet, Am. O.oOOO667 O.WClO5Ol 

ad Bloa ha. O.om167 O.ooOl5O 

3. Strip. Skeet, ha. 0.#0284 0.000213 

aad Plate - lhx. o.oOO71o 0.000638 

brhaame 

4. Strip, Sheet, ti. O.OOOlOO 0.oom751 

aad r1at* - *u. o.ow25o o.ooo225 

kCCb 

5. l lpm. Tub., Am. 0.ooo167 O.ooOl25 

aad Ocher ka. O.OOCbbI8 0.000176 

Ave. 0.032 7 0.02b5 

au. 0.0819 0.0735 

J. cold lO”‘mS 

a. cold billy 

1. Smclrcml*- Am. O.fJOCKKW O.OOOOO31 o.OOooo63 O.OOooOZL 

Clam, SlmSl* Ilu. 0.OwoO21 0.Oam31 0. oOaI209 O.OOOOO94 0.oom18a o.cmmo63 

ttnd 

2. Recirculs- Awe. O.cmOo167 o.cmooO63 o.aMO125 o.oamo4z 

1101. rltl- awa. O.oomo62 o.ooOaM3 0.00004l8 0.000018R O.owO376 O.oooOl25 

pla St& 

3. Combimatla Ave. 0.000217 0.00008I4 0.000163 o.oOoOu2 

ma. o.oooO542 O.oaMMI 3 0.000543 0.000216 O.ooO48R 0.000163 

2-16 
&WI llaphtha- Tet rachloro- CYWl& nasaval*nt 

ata Qloclu (urr) 1.M l c hy lwo hramlwm (Total) lad IlChl Zlac Chromlrw 

4. mm 

~llculr. Ave. O.OOW418 0.0000156 0.Oooo313 0.oooo104 

a1al.m Ilu. 0.oooo104 O.ooaOLsI 0.om106 0.0000469 0.0000939 o.oaIo313 

5. D1ru.t Am. 0.000484 0.000182 o.ooo363 0.000121 

Appllcrla. Iha. 0.mo121 O.WO182 0.00121 o.ooo545 0.00109 0.000363 

lhll IpI. 

scad 

I(. Altd lr 

Clmalap 

L. Mot cootl~ 

4. cdvwlsly AVO. o.aum39 o.wQ121 0.oooo125 

d Otbmr *u. O.ooO282 O.OaJ37b O.OWO376 

coattym - 

Strip, Shot. 

aad lItme. 

b. calvulal~ - 

Ylm ho&eta 

nd ?wtomn 

AVO. O.ooo376 0.00050 0.oooo50l 

km. 0.00113 0.00150 0.0041w 

c. I- A-. 0.0123 0.0164 0.00163 

&rob&r0 ha. 0.0368 0.0491 0.00490 

(U/day) 

2-19 
TMU! 2.21 

PUTRKATiUNT STAftMlDS FtM NW SOUWf!S (?SftS) (Cont1ou.d) 

1 Incraaeed loadla8., not to exceed 24 percent of the.. l tendarda. l re allwed for by-product coke planta that have wet deeulfurlzatlon ryateu, but only to 

the extent that much my&au gwbat~ra aa Lacreued l fflwnt volu. fncreued 14logm. nat to exceed 58 perceot of thea. l taodard.. are allowed for 

by-product co&e plant8 that heve Indirect IYI~ recovery l yotm, but only to tb l rtont that l uch eyetea Bowrate an increemed l fflwnc voluw. 

2 lwteaoed l~dllym. oat to l xcwd 21 percent of the.8 rtaadwdr are l llowed for by-product cob. plant. that have uet deeulfurlz~tlon l yeteu. but only to 

ttu l mt*nt tht aach l yotom s*nor*t* aa lacreuod l fflunt volu. lacreued loadllya. mot to l xcwd 50 percent of there l tendardr. l re allowed for 

by-product co&e plamta that bar. Iadtrect -ia recovery myatom, but only to the ertent that l ucb ryotor generate l n Increased effluent volu. 

3 Tb. rtandardo for -la-If, cysald., and pbenolr (4W) l re l ppllcabl. oaly Aen rinterlly uaeteuator 1. croated along with lronuLln# weceuater. 

4 l?uee llrlro apply to each fu l crubbor l @ooclated with mulfurlc @cl6 picklIly operatloae. 

5 Tbeoo limit. apply to each fur scrubber l .eoc1at.d uIth hydrochloric l cld plcklinl owratlona. 

6 yor proceeeea regulated by Subpert J, the lflltr on chromlu. and nlckol apply In lieu of tha lialt~ on lead snd rlnc when cold rolling w~etoweter. are 

tr**td rlth drscally or combllutloa l cld plcklin8 uatoro. 

7 Dlmchr8eo from theoe operatloo. to yubllcly md treatwnt York. l re prohlblted. 

2-20 
2.3 REUTImIP To ELECIFOPIATINC AND METAL FINISHIK; 

In certain cases there may be sane question regarding whether a 

production process is cuvered @ Iron and Steel Categorical pretreatment 

standards or Metal Finishing pretreatment standards. For iron and steel 

manufacturing operations also covered by metal finishing, the ~y)re specific 

standads apply, i.e., iron and Steel. 

For example, if a plant perfollae pickling artd electqlatiq at an 

iron iyd steel then the metal finishing PSES apply only to the discharge 

fran electrqlatirq while the iron and steel PSES apply to the discharge 

fran the surface preparation operation of pickling. Normally, the metal 

preparation cperation (picklifq), would be subject to the metal finishing 

regulation, hawever, because the iron and steel regulations specifically 

include this operation performed in iron aml steel mills, the iron and 

steel regulation takes precedence for this wastestrem. 

The EPA excluded frm relation 81 of the 126 toxic pollutants that 

are given priority consideration. These pollutants are famd either in a 

small nunber of sources and are uniquely related to those sources, or are 

detected in the effluent in trace quantities, which are not likely to 

cause toxic effects. These 81 pollutants am presented in Table 2.3. 

2.5 CQQLIANCE IXf’ES 

In aazordance with the settlenent agreerbent, all existing irrbstriea 

engaged in the manufacture of steel mst cmply with the Iron and Stem1 

Ca tegorlcal pretreatment sbndards, by July 10, 1985 except for thee 

facilities identified in the regulations as being considered under 6eparate 

ruler&&q for central waste treatment facilities. All new steel 

manufacturing facilities mat canply with pretreatment atam%3n3s at tb 

time dischaqe ammmnces. 

2-21 
TABLE 2.3 

POLLUTANTS EXCLUDtD ?ROkf IRON AND STEEL REGULATION 

Pollutant 

Unique Trace 

Occurrence Qusntitiee 

1,2-Dfchloroathme 

1,1,2-Trlchloroethmc 

1,1,2,2-Tattochlorotthane 

2-Chloroarphthrlrnr 

2,4,6-Trichlorophrnol 

2-Chlorophenol 

1,2-Dichlorobenzenr 

1,4-Dichlorobeazenr 

1,1-Dichloroethylenr 

1,2-Trmedichlororthylene 

2,4-Dichlorophenol 

1,2-Diphenythydratene 

Methylenechloride 

Dichlorobromomethane 

Iaophorone 

Nit robenzene 

2-Nitrophcnol 

2,4-Dinit rophenol 

3,4-Bentofluoranthene 

Benzo(K)fluoranthene 

Benzo(ghi)prrylene 

Dlbenzo(a,h)-anthracene 

Indeno(l,2,3 cdjpyrene 

Vinyl Chloride 

Aldrin 

Dledrin 

Chlordane 

4,4-DDT 

4,4-DDE 

4,4-DDD 

a-endorulfaa-Alpha 

b-endorulfan-Beta 

Endorulfan rulfate 

Endrin 

Endrin aldehyde 

Heptachlor 

Heptachlorepoxide 

r-BHC-Alpha 

b-BHC-Beta 

r-BHC-Carra 

g-BBC-Delta 

PCB-1242 

~~~-1254 

PCB-1221 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

x 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

2-22 
TABLE 2.3 

POLLUTANTS EXCLUDED PROM IRON AND STEEL REGULATION (Continued) 

Pollutant 

Unique Trace 

Occurrence Quantfties 

PCB-1232 

PCB-1248 

PCB-1260 

PCB-1016 

Toxaphene 

Beryllium 

Mercury 

Manganese 

X 

X 

2-23 
3. TREATMENT TECHNOLOGIES 

The treatment technologies described in this sections are currently used 

by iron and steel manufacturers to remove wastewater pollutants generated by 

industrial processes. The technologies are grouped according to the subcategories where they are used, and include oil skimming, metals precipitation, 

sedimentation, steam distillation, solvent extraction, thickening and vacuum 

dewatering. 

3.1 TREATMENT OF COKEMAKING WASTES 

Treatment of wastewaters from this subcategory can be accomplished with a 

system such as that illustrated below. 

With this system, process wastewaters are mixed with waste ammonia liquor 

and enter a dephenolizer, which recovers phenolic compounds. The benzol plant 

wastes and final cooler blowdown are initially treated In a gas flotation unit 

where waste pickle liquor is used to break emulsions and an inert gas mixture 

Is introduced to enhance the separation of oils and greases. The above two 

waste streams are then combined, free ammonia is stripped and recovered and 

lime or caustic soda Is added to raise the pH to 11 or 12. Fixed ammonia 

stripping is used to remove as much ammonia as possible prior to further 

treatment. Wastes are then retained in an equalization/sedimentation basin 

with approximately one day’s retention time. Unreacted lime particles and 

other suspended utter separates out, and is periodically removed by clamshell 

bucket or transferred to vacuum filters. The overflow from the basin is then 

neutralized and aerated prior to discharge to the POTW. 

3-1 
3.2 TREATMENT OF SINTERING WASTES 

Sintering process wastewaters result from dust and gas scrubbing equipment and from sinter cooling. The common practice is to combine wastewater 

streams for treatment. A treatment system suitable for meeting pretreatment 

limitations for this subcategory is diagramed below. 

With this system process wastewaters enter a thickener where oils and 

grease are removed by skimming and solids are settled with the aid of a 

polymer. Sludge removed from the thickener is dewatered on a vacuum filter. 

Ninety-two percent of the thickener effluent is returned to the process. 

Wastewater is discharged from the system after pressure filtration or metals 

precipitation. 

3.3 TREATMENT OF IRONMAKING WASTES 

Prior to the mid-1970s, treatment of Ironmaking wastewaters involved 

removal of suspended solids by sedimentation, aided by flocculating agents to 

Improve removal rates. These clarified wastewaters were discharged without 

further treatment. Today, about 90 percent of blast furnace wastewater 

treatment systems include recycling (after the thickener), and discharge only 

a relatively small percentage (generally 5 to 10 percent) of the process flow. 

Cooling towers are often used to lower the temperature of recycled waste. The 

3-2 
thickener underflow are typically dewatered with the filtrate returned to the 

thickener Influent. The devatered solids are either sent to sfntering 

operations or to off-site diSpO8al. A typical wastewater treatment system for 

meeting pretreatment regulations is diagramed below. 

In addition to the eollds removal and recycle technologies, treatment 

fncludes a two-stage chlorination process to destroy cyanide and to oxidize 

phenols and amonia. Followlag chlorlnatlon a reducing agent such as sulfur 

dioxide Is added to remove reeldual chlorine. 

3.4 TREATMENT OF STEELMAKING WASTES 

Uasteuatcr treatment for discharge8 from this subcategory can be accomplished with a system such as that diagramed below. 

(1) Rccych rates: 95% - Bssic Oxygen Furnace - Swpmsscd 

Zxbustion 

9OS - Basic Oxvaen furnace - Own CocnbuStll 
Waatevater initially enter. a thickener, uhich reducer l u8pended solids 

with the aid of a polymer or other coagulant aid. The rolidr are reroved and 

thickened on 8 vacuum filter. A rujor portion of the effluent from the 

thickener 18 recycled to the procesr; the remainder flova to an inclined plate 

separator after lime is added for removal of toxic metals. 

3.5 TREATMENT OF VACUUN DEGASSING WASTES 

A waatevater treatment syrtem capable of meeting pretreatment regulations 

for this subcategory is dimgraDed below. 

mn 

The firrt rtep in the pretreat-at process lnvolver gravity sediwatatloa 

in a 8Cale pit to remove l uapended rolidr. The effluent from the scale pit 

flour to a sump and la either recycled to the procers through a cooling tOuer 

or ia treated with liw to precipitate metalr. Wartewater is discharged after 

solids and toxic rstals are removed by lime preclpltatlon and clarlflcatlon In 

an inclined plate separator. 

3.6 TltEARIBHT OF CONTINUOUS CASTING WASTES 

The pretreatment rtandards for this rubcategory can be mt using the 

treat-at syrtem diagramed below. 

3-4 
scale plt 

(process wrsteurters) 

The process wastewater first enter a rcale pit where solid8 are removed 

by sedimentation and oil la skimed. A flat bed filter Is then uaed for 

additional solids removal (a prerrure filter ir recomended for meeting PSNS). 

About 96 percent of the filter effluent la returned to the procerr; the rest 

is treated with lime to precipitate metal8 la an inclined plate reparator. 

3.7 TR&AMNT OF HOT POBnINc WASTES 

About 20 hot forring operatioar discharge uartewaterr to POTUs. In many 

cases, theme wastewaterr are racycled to mlnlmlze uaer fear to the industry 

and to avoid hydraulically overloading POTWe. EPA bellevea that future 

discharges to POlWa from hot forming operationa, if any, will recefve slailar 

treatment and will not contain high levela of toxic mtalr. The Agency 

believes that the pasr-through of toxic pollutant8 from hot forming operations 

Is not a problem. Thus, categorical pretreatment standards for hot forming 

wsetewaterr were not promulgated. 

3-5 
3.8 TBBATHENT OF SALT BATH DESCALINC WASTES 

Wastewaters are generated at two points In oxldltlng operations: in the 

salt bath tank and in the rinse steps after it. The bath Is a molten salt 

solution that contains high levels of sodium compounds and other components. 

The solution rtaye In the bath for a long time before being replaced. Because 

of its highly contaminated nature and relatively small volume, this spent salt 

solution waste is generally hauled off-site for disposal by private contractore. These salt solutions are treated at some plants by bleedfng a small 

volume of the waste solution into the pretreatment system over a period of 

hours or days. 

The other source of wastewater from oxidlzlng operatlone is the rinse 

step that follows the descallng operation. This Is the primary wastewater 

source regulated by EPA. Wastewaters are produced In the same way for 

reducing operations. Alro, oxldltlng operations are the main concern of POTUs 

since they far outnumber reducing operations. The pretreatment of these 

wastewaters can be accomplished with the following rystem. 

Using this process, vaetewater 1s treated with acid and sulfur dioxide to 

reduce hexavalent chromium to trivalent chromium. The effluent from the 

chromium reduction process first Is treated by skimming to remove floating oil 

and solids and then metals are preclplt8ted In a clarifier using lime and a 

polar. Solid8 are deuatered with a vacuum filter. 

3-4 
3.9 TREATMENT OF ACID PICKLING WASTES 

The system described below is capable of meeting PSES. A more complex 

system would be needed to meet PSNS. 

The eeveral waste stream are combined la an equalltatlon tank where oils 

are eklacd. The wastewater is then treated with lime and a polymer and 

aerated to oxidize iron from the ferrous co ferric state. Next, it enters a 

clarifier to aettlr out solids and toxic metals, which l ra dowatered on a 

vacuua filter. 

3.10 TREAI?IENT OF COLD ROLLING WASTES 

Treatment of waateuatarr from thir subcategory can be met using the 

following system: 

3-7 
The treatment process includes 011 removal and solids removal. Floating 

oil is removed, then alum and acid are added to break emulsions. Solids and 

oil are removed by air flotation following lime and polymer addition. A 

vacuum filter is used to deuater sollds. 

3.11 TREATHENT OF ALKALINE CLEANING UASTES 

Wastewaters from alkaline cleaning operations are relatively clean 

compared to waetewatera from other steel industry operations. Toxic pollutante are present in untreated alkaline cleaning wastewater only at levels 

below or near treatability levela. EPA has not promulgated numerical ptetreatment standards for this subcategory. 

3.12 TREATMENT OF HOT COATING WASTES 

Pretreatment of galvanizing wastewaters can be achieved with a syntea 

similar CO that discussed under waste treatPent for the Salt Bath Descaling 

subcategory. 

3-8 
4. REQUIREMENTS OF THE GENERAL PRETREATMENT REGULATIONS 

4.1 INTRODUCTION 

The section provides a brief overview of the General Pretreatment 

Regulations and identifies those provisions of the Regulations that have a 

direct bearing on the application and enforcement of Categorical Pretreatment 

Standards for the Iron and Steel Manufacturing category. 

The General Pretreatment Regulations for Existing and New Sources 

(40 CFR Part 403) establish the framework and responsibilities for 

implementation of the National Pretreatment Program. The effect of 40 

CFR Part 403 is essentially three-fold. First, the General Pretreatment 

Regulations establish general ad specific discharge prohibitions as 

required by Section 307(b) and (c) of the Clean Water Act. The general 

and specific prohibitions are described in Section 403.5 of the Pretreatment 

Regulations. they apply to all nondomestic sources introducing pollutants 

into a POTW whether or not the source is subject to Categorical Pretreatment 

standards. 

Second, the General Pretreatment Regulations establish an administrative 

mechanism to ensure that National Pretreatment Standards (Prohibited 

Discharge Standards and Categorical Pretreatment Standards are applied 

to and enforced against industrial users. Approximately 1,500 POTWs are 

required to develop a locally run pretreatment program to ensure that 

nondomestic users comply with applicable pretreatment standards and 

requirements. 

Third, and most importantly for the purpose of this guidance manual, 

the General Pretreatment Regulations contain provisions relating directly 

to the implementation and enforcement of the Categorical Pretreatment 

Standards. They include the combined wastestream formula, reporting 

requirements, local limits, monitoring or sampling requirements, and 

category determination provisions POTW representatives should refer to 

40 CFR Part 403 for specific language and requirements where appropriate. 

4-1 
4.2 CATEGORY DETERMINATION REQUEST 

An existing industrial user (IU) or its POTW may request written certification from EPA or the delegated State specifying whether the industrial user 

falls within a particular Industry category or subcategory and is subject to a 

categorical pretreatment standard. The deadline for submitting a category 

determination request by existing industrial users subject to the Iron and 

Steel Manufacturing categorical pretreatment standards has passed. A new 

industrial user or its POTW may request this certification for a category 

determination any time prior to commencing its discharge. The contents of a 

category determination request and procedures for review are presented in 

Section 403.6(a) of the General Pretreatment Regulations. 

4.3 MONITORING AND REPORTING REQUIREMENTS OF THE GENERAL PRETREATMENT 

REGULATIONS 

In addition to the requirements contained in the Iron and Steel Manufacturing categorical pretreatment standards, industrial users subject to 

these standards must fulfill the reporting requirements in Section 403.12 of 

the General Pretreatment Regulations. These requirements include the submission of baseline monitoring reports, compliance schedules, compliance 

reports (initial and periodic), notices of slug loading, and recordkeeping. 

Each reporting requirement is summarized briefly below. 

4.3.1 Baseline Monitoring Reports 

All industrial users subject to categorical pretreatment standards must 

submit a baseline monitoring report (BMR) to the Control Authority. The 

purpose of the BMR is to provide information that the Control Authority needs 

to document the industrial user’s current status of compliance with a categorical pretreatment standard. The Control Authority is defined as the POTW 

if It has an approved pretreatment program; otherwise the BMR will be submitted to the State (if the State has an approved State Pretreatment Program) 

or to the EPA Region. Additional guidance on BMR reporting is available from 

the EPA Regional Pretreatment Coordinator. 

4-2 
BHR Due Dates 

Section 403.12(b) requires that BMRs be submitted to the Control Authority within 180 days after the effective date of a Categorical Pretreatment 

Standard or 180 days after the final administrative decision made on a 

category detemination request (403.6(a)(4)], whichever date 1s later. BMRs 

for industries regulated by the Iron and Steel Manufacturing standards were 

due January 6, 1983. 

BMR Content 

A BMR must contain the following information as required by Section 

403.12(b): 

1. Naw and address of the facility and names of operator(a) and 

owner(s). 

2. List of all environmental control permits bald by or for the facility. 

3. Brief description of the nature, average production rate, and SIC 

code for each of the operation(s) conducted, including a acheaatic 

process diagram that indicates points of discharge from the regulated 

processes to the POTU. 

4. Plov measurement information for regulated process streams discharged 

to the municipal system. Plow measurements of other vaotestream 

will be necessary if application of the combined vastestream fonula 

is neces8aryg 

5. Identification of the pretreatment standardr applicable to each 

regulated process and rerults of measurements of pollutant masseeD 

All samplsr arat bs represeatative of daily operations and rssults 

reported muot include values for daily maximum and average concentration (or ~#a, where required). If the flow of the regulated 

atream bslng sampled is less than or equal to 250,000 gallons per 

day, the industrial user arst take three samples vithfn a two veek 

period. If the flow of the stream ir greater than 250,000 gallon, 

per day, the industrial uoer a*lst take six samples within a tvo veek 

period. If aampler cannot be taken imdiately dovnstream from the 

regulated process and other wastevaters are mixed vith the regulated 

procers, ths industrial user should measure flovr and concentrations 

of the other wastcstreama sufficiently to allov use of the combined 

vastestream formula. 

6. Statement of certification concerning compliance or noncompliance 

with the Pretreatment Standards. 

4-3 
7. If not in Ocnpliance, a schedule must be submitted with the RMR that 

describes the actions the user will take and a timetable for canpleting 

those actions to achieve qliance. This ccnpliance schedule mst 

contain specific increments of prqress in the form of dates for thr, 

cmmncment and corpletion of major events. However, no increnent of 

the schedule shall exceed 9 months. Within 14 days of each cuqletion 

date in the schedule, the industrial user shall suhuit a progress 

L-eprt to the Control Authority indicating whether it carplied with 

the increnent of pra~ress to be met on such date, or, if not, the 

date on which it expects to amply and the steps beirq taken to return 

to the schedule. 

4.3.2 Report cm Canpliance 

Within 90 days after the compliance date for the Iron and Steel 

ManuEacturing pretreatment standards or, in the case of a new sauce, 

follcwirrq cammcment of the intrabtion of wastewater into the PDIW, 

arty industrial user subject to the standards nust subnit to the Control 

Authority a report on carpliance that states whether applicable pretreatment 

standards are being consistently met. ‘lhe report rmst also indicate the 

nature and mass of all regulated pollutants in the facility’s *ated 

process uastestreaus. If the facility is not in qliance, the report 

nust explain the additional operation and maintenance and/or pretreatment 

that will be necessary to achieve carpliance (see 40 CFR 403.12(d)). 

4.3.3 Periodic Reports on Continued Ccrrpliance 

Unless required more frequently by the Control Authority, all 

imbstrial users sbject to the Iron and Steel Wanufacturing categorical 

pretreatment standards nust subnit a seuiannual periodic carrpliance report 

in the months of June and Decenber (or other months specified by the 

Control Authurity). The report shall indicate the nature and masses of 

the regulated pollutants in the IU’s discharge to the po?w, the average 

and maximun daily flcm rates of the facility, the methods used to sarQle 

and analyze the wast&rater, and a certification that the smp1ir-q and 

analytical metbds confom to thoee methods outlined in the regulations 

(See 40 CFR 403.12(e) 1. 

4-4 
4.3.4 Notice of Slug Loading 

Section 403.12(f) requires industrial users to imediately notify the 

POTW of a slug load of any pollutant released to the POTU, including oxygen 

demanding pollutants (BOD, etc.) that may cause interference at the POW. 

4.3.5 Uonitoring and Analysis to Demonstrate Continued Compliance 

Section 403.12(g) states that the frequency of monitoring to demonstrate 

continued coapliance shall be prescribed in the applicable pretreatment etaadard. The Iron and Steel Manufacturing pretreatment standards do not ertablish any monitoring frequency. Therefore, the appropriate Control Authority 

must establish monitoring frequency to adequately demonstrate that indirect 

dischargers subject to the pretreatment standards comply with them. Unleas 

otherwise noted in the appropriate paragraph of Section 403.12, the aoaitoring 

frequency established by the Control Authority shall be used in the bsseline 

monitoring report (403.12(b)(5)), the report on compliance vith categorical 

pretreatment standard deadline (403.12(d)), and the periodic reports on continued compliance (403.12(e)). 

Sampling and analysis shall be conducted In accordance vith the procedures established in 40 CPR Part 136 and any aeeadments to it or shall be 

approved by EPA. When Part 136 techniques are not available or are Inapproprfate Ear any pollutant, then sampling and analysis shall be conducted in 

accordance with procedures established by the POW or other validated procedure. All procedures for sampling and analysir not included in Part 136 mst 

be approved by EPA. 

4.3.6 Signatory Requirements for Industrial User Reporta 

All reportr submitted by industrial users (BMRs, initial reports on 

compliance, periodic reports , etc.) murt be signed by an authorized representative of the company in accordance vith Section 403.12(k). 

4.3.7 Recordkeeping Requirements 

Any industrial user subject to the reporting requirewnts of the General 

Pretreatment Regulations shall maintain recordr of all inforution that 

results from any monitoring activities required by 403.12 for a minirum of 

4-5 
three years [403.12(n) I. These records shall be available for irrspection 

and copying by the Control Authority. 

4.4 APPLICATION CF OXBINZD WA!XESTEAH FU+XJKA 

One provision of the General Pretreatnrent Regulations that will 

of ten be used by m and indratries to prqerly mnitor and report on 

ccnpliance with categorical pretreatment standards is the Canbined 

Wastestrean Fonda (CWF) [40 CFR 403.6(e)]. The CWF is a mechanisn for 

ca.lculcr:ing appropriate limits specified in applicable regulations for 

wastewater in whi& process wastestreenrs are mixed with effluent. The 

CWP Is applied to the mixed effluent to account for the presence of the 

additional wastaetmam. 

As part of the Settlement reflected in the Hay 17, 1984 rme*nt, 

the preamble (49 PR 21027) states that m-based limits (mass/day) should 

be applied to integrated facilitieta covered by procktion+ased stan&* 

only and a caMnation of production-based and concentratiebased 

stanhrds. 

The following definitions and ccndi tions are important to the p-r 

use of m?. 

Def initiom 

0 Requlated m Wastestreun - itistrial process wastestreun 

regulated by Rational Categorical Pretreatment Standards. 

O Unregulated procesS Wastes- - in&strial process vastestrem 

that is not regulated by a categorical standard. 

O Dilute Wastest- - boiler blm, sanitary wastewater, 

noncontact cooling water blmdown, and Paragraph 8 excluded 

wastestrem containing none or only a trace unount of the 

regulated pollutant. 

Rote: These definitions apply to individual pollutants. A wastestreun 

fran a process may be “regulated” for one pollutant and 

“unregulated for another. In addition, the May 17, 1984 

aae*nt to the CWF allows the Control Authority to exercise 

its discretion to detennf ne whether boiler blclJdaJn and 

nonwntact moling etrems are dilution or unregulated process 

StreanS. 

O Concentration-based Limit - limit based on the relative strength 

of a pollutant in a wastmtrean. usually expressed in nq/l 

(lb/gal). 

O Pzuductimbased Limit - limit based on the actual guantity of a 

pollutant in a wastestrean, usually expressed in kg/m unit of 

prtiction for a given -ration, such as square meter ( lb/square 

foot per operation). 
O Mass-basedLimit- Limit based on the actual quantity of a 

pollutant in a wastestrean and the was&stream volum, usually 

expressed in kg/day (lb/day). 

4.4.1 cm Conditions 

To ensure prqoer application of the CUP, the follaring conditions 

must be met by a mnicipality and its in&stries [40 CFR 403.618)): 

O Alternative discharge limits that are calculated in place of a 

categorical pretreatmnt standard nust be enforceable M cateqrical 

standards. 

O Calmlation of alternative limits must be perfonaed by the Control 

Authority (FUIW) or by the in&strial user with written permission 

fran the KJIW. 

O Alternatim limits rrust be established for all regulated pollutants 

in each of the regulated processes. 

O Both dally fmxinnmt and long-term avenge (usually mnthly) 

alternative limits nust be calculated for ea& regulated pollutant. 

* Alternative limits mst be established for all regulated pollutant 

in each of the regulated pmcesses. 

O If process dmges at an in&stry warrant, the Control Authority 

may recalculate the alternative limits at its discretion or at 

the request of the itistrial user. The new alternative limits 

mst be calculated and becum effective within 30 days of the 

process rfrange. 

O The Control Authority may we stricter alternative limits, but 

may mt inpoee alternative limits that are less stringent than 

the calculated limits. 

O A calculated alternative limit cannot be used if it is belay the 

analytical detectim limit, the N mst either; 1) not ca&ine 

sam of the dilute stream before they read the mined treatment 

facility, or 2) segregate all wastestream entirely. 

4.4.2 Monitoring Requimmmts for Industrial Users Using the CW 

Requirements for selfmitoring by ah industrial user are necessary 

to ensure ccrppliance with the alternative categorical limit. Because the 

Iron and Steel Manufacturing pretmawnt standarde do no include selfmnitoriq requirments, the Control Authority will establish iqprcpriate 

self9mitoring requiremnts. 

4.4.3 Application of the CWP 

The canbimd formla for mss-based limit8 is in Table 4.1. Table 

4.2 presents ah example of hm the CW is used to calculate alternative 

limits for specific imn and steel mfufacturing qerations. Before 

4-7 
TABLE 4.1 

COMBINED UASTESTREAn FDRMJU 

n t - aImnative UII limit for the pollutant 

“I - Categorical Pretmatmnt Stan&m! mms limit for the pollutant in 

regulated stm I (the Categorical Retrmbnmt prchcticmbased 

standard limit nultiplied by the appmpriats measure of pmduction) 

pi - avetaps dally flar (at least 30 day average) of regulated stmtaa I 

Fd - average daily flar (at least 30 day average) of dilute wastestream 

Ft - average daily flaw (at least 30 day averap) thmmgh the a~&i;lsa 

tmatmmt facility (including regulated, unregulated, and dilute 

wasteatrea) 

N - total ruder ti regulated stmmus 

4-0 
TABLE 4.2 

This example demmstrates for one of the regulated pollutants (lead) 

bar pra&tion-based pretreatment standa& fmn an acid pickling operation 

(limited under 40 CFR Part 420 (Iron and Steel Point Source Category), 

carpliance date of July 10, 1985) are canblned with concentratior&ased 

pretreatmnt Stan&m& from a metal finishirq (electrwlatinl) -ration 

(limiterl under 40 CFR Part 433 carpliance date of February 15, 1986) to 

arrive at ccmbined mass-based limit. The calculations belw are made 

with the assumption that both carpliance dates have passed. (Note: 

FW calculations prior to the metal finishing canpliance date, the electroplating waste&rem wcxlld be considered unregulated and the flow value 

(Pi) fran the iron and steel operations would be necessary to use the 

CWF., 

Acid Pickling Production: 

Hydrochloric Acid Pickling-Strip Pmkts --- 

NunberoffumScrubbem3 s-m 

Electrqlating Wastwater flaJ (platirq 

bath and final rinses only) 

lWlROCHLIoRIC 

ACID PICKLIK; 

KU% FINISHII’G 

(ELECIWPCATfffi) 

403,200 c@ 

I 

oFsrRxPPEumlcrS 

2150 tons/day 

3fmes4xubber 

I 

Cateqorical P%S 

40 CFR 433 hg/l) 

Monthly Daily 

Ave. Max. 

Lead 0.45 0.69 1 

1 

2150 tom/day 

3 units 

403,200 gpd 

Categorical PSES 40 CFR 420 

-subpart I, Secticm 420.95(b)(2) 

and (b)(4) 

30 Day Daily 

ave. llulxirlun 

PICKLING; U%D ~.000175 0.000526- 

0/1000 # 

Prcdct) 

I 

lEAD 0.0123 0.0368 

scrubber 

(kg/day ea. 1 
Exmple Calculations 

For the Lead Calculation: 

Iron and Steel Lead Deily Haxinm Limit - Limit3 for (Pickling) +3(Rme Scubber) 

= Categorical Standard for Picklirq x Production Rate 

for Pickling +3 x (Categorical Standard for each fme 

scrubber) 

= [(0.000526 t/l000 # prabct) x (2150 to&day x 2000 */ton x 

1 #/lo00 # product)] + 3 (0.0368 kg/day ea. x 2.2 lb/kg) 

Lead (Irm and Steel) - 2.2618 + 0.2429 = 2.50 #/day Daily Max. 

Metals Pinishinq Lead hily Maximm Limit - Categorical Standard x flm 

- 0.69 nq/l x (403,200 gpd x 8.34/106 Ccmersion Factor) 

Lead (,Hetal Finishing) = 2.32 #/day Daily Max. 

Since there is m dilution flaJ the applicable pretreabrmt lead daily 

mximn limit for the facility Is: 

Isa Daily ,~imm = 2.50 #/day + 2.32 #/day 

= 4.82 #/day 

The 3O-day limitation, caladatd In a similar manner, fs 2.28 )/day. 

4-10 
using the CWF, rancher that &en txo or mre regulated wastestreufm are 

mixed prior to treatmnt, it is necessary to determine which pretreatnrwrt 

regulation applies to each regulated wastestreun before they are mixed. 

For additional informaticn on categorical pretreamnt standards and the 

canbined waste&rem fomula , refer to the manual entitled “CxIidancw 

Mama1 for the Use of Production-based Pretreatmnt Standards and the 

Canbfnsd wastes- Pornulae (Septenber 1985). For calculation of the 

total toxic organic23 (TIO) limit, refer to the rmnual entitled, “Guidance 

Marual for Inplenenting Total Toxic Organ& (TI’O) Pretreatment Standards 

(September 1985). 

4.5 EEMNAL CFUZDITS 

A remval credit allam a FUIW to provide its categorical i&.mtrial 

users with a credit (in the form of adjusted categorical pretreabmnt 

standards) for remval of pollutants by the IUTW. Inb3trial users 

receiving such a credit are allawed to discharge to the POIW greater 

quantities of regulated pollutants than otherwise permitted by applicable 

categorical standards. *ether or not to seek authority to grant r-al 

credits is at the discretion of the PUTW. Section 403.7 of the General 

Pretreatment Regulations establishes the conditions under uhicfi p FUTW 

can obtain approval to grant ma1 credits ad specifies the mans by 

which these removal credit3 am to be determined. 

In 1977, Congress anended sectian 307(b) of the Clean Water Act to 

provide for ranoval credits. EPA originally hplermnted that provision 

and established the amditions under which KXWs ccruld obtain authorization 

to grant remval credits in the June 26, 1978, General Pretreatment 

Regulations. On Jamary 28, 1981, the remval credits pruvisim was 

agained anended. On Aucpst 3, 1984 (49 Fed. Reg. 31212) the removal 

credits provisicm was again amnded. UGthe arrent provision, ary 

ETlIw seeking removal credit authority is required to derrPrrstrate its 

r-1 perfomnce by saaplirq its influent and effluent and calculating 

its r-1 rates based on these data. Removal capability of each m, 

therefore, is to be determined on a -by-case basis. In tiition to 

the sampling requirements, the provision specified the other prerequisites 

for obtaining remval credit authority. Only the Approval Authority 

(either EPA or the State) can grant ranoval credit authority to a RYIW. 

For rrpre information on removal credits, refer to the meal entitled 

“c;Uidance Hamal for Preparation and Review of Remsval Credit Applications” 

(September 1985). 

As part of the mmcbmts to the im and steel categorical star&H3 

(40 CFR 420.06) EPA acknowledged that biological treatment system arplayed 

at EUIW’s will, in m measure, rmve those pollutants for which 

phenols (4A4P) is used as an indicator pollutant to the same degm3 as 

they remvet phenols (4AAP). Thus, remval allaJames pursuant to 40 CFR 

403.7(a)(l) may be granted for phenols (4AAP) limited in the iron and 

steel incbstzy whether or not it is used as an indicator ot- surrogate 

pollutant. 

4-11 
4.6 FUKWENIXLY DIFFERWI’ FAC’mE VARIANCE 

A rquest for a fundmmntally different factors (PIP) variance is a 

me&ani8n by which a categorical pretreatment standard my be adjusted on 

a caseby-case basis. If an indirect discharger, a KYIW, or any interested 

pemon believes that the factors relating to a specific indirect discharger 

are fundmmntally different frm thcee factors amsidemd during development 

of the relevant catwrical pretreatmnt standard and that the existence 

of thase factors justifies a different discharge limit frm that specified 

in the Categorical Standard, then they my suhit a request to EPA for 

such a variance (See 40 CFR 403.13). 

4.7 ulcAL+ LIMITS 

Local limits are nxnerical pollutant conmntratim or mass-based 

values that are develcped by a KJIW for oontmlling the discharge of 

conventional, nomxmventional, or toxic pollutants fzm indirect saxces. 

They differ fram national categorical pretmatmnt standards in that 

catqoriml pretmatmnt standards are c&eloped by EPA and are hsed on 

the chmmtrated perfonmnce of available pollutant 03ntrol technologies 

for specific categorical itistries. These technology-based categorical 

standards Q not comider local enviromental criteria or oamlitions, ht 

are developed to assure that each itistry within a specified category 

met8 a minimm dis&arge standard that is consistent for all KJIW acmss 

the United States. m limits, on the other hand, are developed to 

address specific localized @acts on FUIW and their reoeiviq waters. 

Local limits are typically designed to pr&e& the PUIW franr 

d Introduction of pollutants into the FUW that could interfere 

with the -ration 

o Pass-thmJgh of inadequately treated pollutants that omld violate 

a RYXW’s NPIES pennit or applicable water quality standards 

o Contuninatim of a RXW’s sludge, which muld limit sluaQe uses 

or disposal practices. 

bcal limits, as the nmne implies, tdce into axmideration the 

factors that are unique to a FUlW, hemas cateqxical pretreatmnt 

standa& am develqed only for a general class of inchstrial dischargers. 

Local limits are required urxler 40 CFR 403.5. For mm infomaticn m the 

minknm local limit requifemnts for IUIWB with approved pretreabmmt 

pmgrm3 and the relatiomhip between local limits and categorical standards, 

refer to the nmmran&m signed by Rebecca liamer cm August 5, 1985 entitled 

“kxal Limit Rquirmmnts for PllcIIw Pretreatment Program’. 

To assist rmmicipalities in devel@q deferrsible and technically 

sowd ruwrical effluent limits, EPA has prepared general guidelines on 

limit develqmnt in its doamxmt %&lance Mama1 for FUW Pretmatnmt 

Prcgraa Develqqmt. ” Appndix L of the nmual lists the general 

below, required fornulas, and typical envirmnental criteria used 

to *lap local limits. The wmal is available fran EPA ~egim1 

offices and delegated States and should be carefully followed when 

4-12 
develcpirg local limits. A rrpre detailed guidance mama1 for local limit 

development is currently under dewlopnent. The general rrretha%logy 

includes the follaJirg four steps: 

step 1 - Determine the maximum headworks loading (for each specific 

pollutant) that will assure that the objectives of the 

pretreatment progran are met. 

step 2 - Calculate the allowable loading to the PUIW by subtracting 

the uncontrollable portion of pollutant discharge to the 

RXW (frun -tic, cannercial, and infiltration/infla 

sources) fran the total headworks loading value. 

step 3 - Distribute the controllable loading to industrial users 

thrargh an allocation process. 

step 4 - Derive specific local limits fran the allocation results. 

This four-step process mst be follcwed for each pollutant that the 

HlIw determines my need a specific local limit. As a general rule, the 

limit setting analysis sharld be perfo& for all pollutyrts that are 

discharged to the FQlW in significant quantities. The IUlW can identify 

pollutants of -rn thmqh its itistrial waste suw. A procedure 

for evaluating inckstrial waste SULVB~ results is included in the EPA 

guidance manual mentioned above. 

To assist PUIWs with the development of local limits, EPA has also 

developed a caquter program that incorporates the general methodology 

required to develm local limits ard perfonm a substantial &r of the 

calculations required to develop these limits. This cuqx&er program has 

the follawiq @illties. 

0 Performs the four-step limit setting analysis on micmter or 

mainfrm 

0 Screens irgut data provided by the EUIW 

o Supplanents FUTW data with built-in files containing data on 

indrstrfal and rmnicipal wastaJater &aracteristics, KYlW r-al 

rates and PUlW inhibition values 

o Allocates controllable pollutant loads usiq several different 

~thod&XJiES 

0 Carpares calculated local limits to EPA cateprhl standards. 

RYlWs may obtain information on this cuquter prapzfn by contacting the 

EPA Regiord office. Instructions are available on hew to obtain and 

use the caquter program as well as how to gain accB99 to a carputer 

systen that supports it. 

4-13 
REFERENCES 

IRON AND STEEL FEDERAL REGISTER 

Final Regulations Promulgated 

Amended (Effective Date) 

Amended (Coding and minor errors) 

Amended (Final and interim regulation) 

Correction Notice 

Correction Notice 

Amended (Final) 

GENERAL PRETREATMENT REGULATIONS 

40 CFR 403 

40 CFR 403 

40 CFR 403 

05/27/82 47FR 23258 

06/07/82 47FR 24554 

09/22/82 47FR 41738 

10/14/83 48FR 46942 

11/10/83 48FR 51647 

11/14/83 48FR 51773 

04/17/84 49FR 21024 

REPORTS AND MANUALS 

Final Development Document - 

Iron and Steel Vol. I-VI May 1982 440/l-82/024 

Guidance Manual for POTW 

Pretreatment Program Development 

Procedures Manual for Reviewing 

a POTW Pretreatment Program 

Submission 

Guidance Manual for Electroplating 

and Metal Finishing Pretreatment Standards 

Guidance Manual for Preparation of Removal 

Credits Applications 

Guidance Manual for Implementing Total Toxic 

Organics (TTO) Pretreatment Standards 

Guidance Manual for the Use of Production-based 

Pretreatment Standards and the Combined Wastestream 

Formula 

01/28/81 46FR 9404 

04/17/84 49FR 21037 (Amended) 

08/03/84 49FR 31212 

NTIS or GPO 

Number 

PB82-240425 

PB82-240433 

PB82-240458 

PB82-240466 

PB82-240474 

October 1983 

October 1983 

February 1984 

September 1985 

September 1985 

September 1985 

R-1 
Miscellaneous 

RCRA Information for Publicly Owned Treatment Works September 1985 

Local Limits Requirements for POTW Pretreatment Programs, memorandum 

signed by Rebecca Hanmer on August 5, 1985. 

Copies of the technical and economic documents may be obtained from the 

National Technical Information Services, Springfield, VA. 22161 (703/487- 

4650). Pretreatment Program Manuals may be obtained from U.S. EPA, 

permits Division (EN-336), Washington, DC 20460. 

U.S. GOVERNMENT PRINTING OFFICE 1985 461 217 34935 

R-2