EPA’s proposed Multi EPA’s proposed MSGP and the ...

June 1, 2020

Ms. Emily Halter

Office of Wastewater Management (4203M)

Office of Water

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue NW

Washington, DC 20460

Docket ID No. EPA-HQ-OW-2019-0372

Re: Docket ID No. EPA-HQ-OW-2019-0372

U.S. Environmental Protection Agency (EPA)

National Pollutant Discharge Elimination System

Proposed Multi-Sector General Permit (MSGP) for

Stormwater Associated with Industrial Activity

Dear Ms. Halter:

The American Iron and Steel Institute (AISI) on behalf of its U.S. producer members is pleased

to submit comments on US EPA’s proposed Multi-Sector General Permit (MSGP) for

stormwater. As set out below, AISI is offering comments in opposition to many aspects included

in EPA’s proposed MSGP and the accompanying proposed sector-specific stormwater control

measures (SCMs), many of which are clearly impractical and unreasonable for iron and steel

facilities. Furthermore, given the scope and prescriptive nature of the proposed MSGP and

proposed SCMs, we find that EPA’s assessment of the cost impacts of the proposed MSGP is

unrealistically low and inadequate.

Applicability of MSGP to AISI Facilities

The applicability of the proposed MSGP is set out at Part I, Section 1.1.3 (Limitations on

Coverage). It would establish that the following discharges would be excluded from coverage

under the proposed MSGP:

• 1.1.3.1: Discharges mixed with non-stormwater discharges;

• 1.1.3.2: Stormwater discharges associated with construction activity;

• 1.1.3.3: Stormwater covered by another NPDES permit; and,

• 1.1.3.4: Stormwater Discharges Subject to Effluent Limitations Guidelines.

25 Massachusetts Avenue, NW

Suite 800

Washington, DC 20001

Phone 202.452.7122

Fax 202.452.1039

E-mail [email protected]

www.steel.org

Docket ID No. EPA-HQ-OW-2019-0372 June 1, 2020

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Although the proposed MSGP and proposed Sector-Specific SCMs would not apply directly to

most AISI member facilities because they are regulated by NPDES permits that include

provisions for stormwater and combined process water/non-contact cooling water/stormwater

discharges, a final MSGP and final SCMs will likely have substantial impacts because it is very

likely that state regulatory agencies will use a final MSGP and final SCMs as EPA guidance for

their stormwater regulatory programs. We suspect this will happen even if most iron and steel

facilities will not be subject directly to a final MSGP.

EPA attempts to address the issue of potential costs accrued to this MSGP which are not directly

the result of this MSGP, but result from NPDES permits issued by authorized states (Cost

Analysis, page 4 of 54). EPA argues that NPDES-authorized states are not required to conform

or match their industrial stormwater permits to EPA’s MSGP. However, EPA goes on to

acknowledge that up to 77% of state MSGP permits are either substantially similar or somewhat

similar to EPA’s MSGP. EPA then states, “To the extent a given state decides to propose their

next MSGP to mirror any changes proposed in EPA’s MSGP, those state permittees would likely

incur similar incremental costs detailed in this analysis.” (page 4 of 54). EPA’s cost analysis

derives a per facility estimate for this MSGP of $2,363 per facility over the 5-year permit term.

As detailed below, we project the per facility costs for steel mills could range in the tens of

millions of dollars per facility if the proposed stormwater control measures (SCMs) for Section F

(Primary Metals) of Appendix Q are required to be implemented by state permitting agencies.

EPA did not factor implementation of the proposed SCMs, or any indirect costs associated with

the proposed SCMs, by states in their storm water management programs.

AISI and its member companies have serious concerns about the following points below. We

hope the detailed significant costs projected for our sector as a result of Appendix Q will provide

significant reason for EPA to take these concerns seriously, even though these costs may not be

directly attributable to this proposed MSGP.

• The proposed Universal Benchmark concentration for Chemical Oxygen Demand

(COD) set out in Part 8, Table 8.1.1

• The proposed Sector-Specific Benchmark concentration for aluminum set out in

Part 8.F.5 for Subsector F1 (Steel Works, Blast Furnaces, and Rolling and

Finishing Mills (SIC 3312-3317);

• Consideration of benchmark monitoring for PAHs (EPA request for Comment

20);

• Proposed Stormwater Control Measures (SCMs) for Sector F (Primary Facilities);

• EPA’s assessment of costs associated with the proposed MSGP; and,

• A number of implementation issues associated with the proposed MSGP.

In many respects, the proposed MSGP and proposed stormwater control measures (SCMs) are

duplicative of, but go well beyond, existing programs that are already being implemented at AISI

member facilities (i.e., facility-specific NPDES permits, SWPPPs, SPCC Plans, Title V and other

air permits, RCRA contingency plans). This is particularly true of the prescriptive Sector F

SCMs set out in Appendix Q. Given the expansive scope and the prescriptive nature of the

proposed MSGP and proposed SCMs, this will create considerable confusion among state


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regulators and AISI member facility environmental program personnel who implement

stormwater control programs. We believe this will result in significant waste of scarce resources

for the state agencies and for the AISI member facilities with no commensurate environmental

benefit.

Our specific concerns and comments are presented below and in exhibits to this letter.

Universal Benchmark Monitoring

AISI requests that universal benchmark monitoring for total suspended solids (TSS), chemical

oxygen demand (COD) and pH, if retained in the final MSGP, not apply to Sector F (Primary

Metals Facilities), and not apply to iron and steel mills in particular.

Part 8, Table 8.1.1 – Universal Benchmark Monitoring Applicable to All Sectors

The proposed MSGP at Table 8.1.1 contains the following universal benchmark concentrations

applicable to all sectors:

pH 6.0 to 9.0 su

Total Suspended Solids (TSS) 100 mg/L

Chemical Oxygen Demand

(COD)

130 mg/L

TSS and COD are not included in state ambient water quality standards for protection of human

health, aquatic life, wildlife or for enhancement of primary or secondary contact recreational

activities in and on the water. State narrative water quality standards typically prohibit

discharges of substances that will settle to form putrescent or otherwise objectionable deposits.

However, TSS discharged from iron and steel mills in treated process waters and in stormwater

are inorganic in nature are not associated with putrescent deposits. Thus, there is no direct link

between TSS discharged from iron and steel mills and either ambient narrative or numerical

water quality standards.

Furthermore, aside from process wastewaters from by-product cokemaking operations, COD is

not a significant component of process wastewaters from integrated steel mill “hot end” steel

manufacturing operations (i.e., sintering, blast furnaces, basic oxygen furnaces, vacuum

degassing operations, continuous casting, direct reduced iron), and from process wastewaters

from hot rolling and steel finishing operations (acid pickling, alkaline cleaning, hot dip coating,

electroplating). Electric arc furnace (EAF) plants at non-integrated steel mills have dry air

pollution controls and therefore have no COD component associated with EAFs. The continuous

casting, hot rolling and steel finishing operations at EAF steel mills are similar to those at

integrated steel mills. By the nature of the iron and steel manufacturing operations, industrial

stormwater is not characterized by contamination by organic materials that contribute to COD.

To the extent COD is present in stormwater from iron and steel mills, it is effectively regulated

by effluent limits for oil and grease that are typically applied at concentrations of 10 mg/L or 15


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mg/L for stormwater discharges and non-stormwater discharges, far less than the proposed

universal benchmark COD concentration of 130 mg/L.

Sector-Specific Benchmark Concentration for Aluminum

Part 8, Subpart F – Sector-Specific Benchmarks for the Primary Metals Sector

AISI requests that the proposed TR aluminum benchmark concentration of 750 ug/L be removed

from Table 8.F-1 for the final MSGP for iron and steel facilities.

Part 8.F.5 of the proposed MSGP at Table 8.F-1 includes a proposed benchmark concentration of

750 ug/L for total recoverable aluminum (TR aluminum) and a hardness-dependent benchmark

for total recoverable zinc (TR zinc). TR zinc benchmark concentrations would be 130 ug/L at a

freshwater hardness range of 100 to 125 mg/L, and 230 ug/L at a freshwater hardness range of

200 to 225 mg/L.

TR aluminum is not a useful metal for benchmarking the effectiveness of stormwater pollution

prevention measures at integrated iron and steel mills or at EAF steel mills. US EPA did not find

aluminum to be a pollutant of concern in iron and steel industry process wastewaters when 40

CFR Part 420 was promulgated in 1982 and later amended in 2002.1,2 Aluminum is not a

regulated pollutant in 40 CFR Part 420 for any iron and steel effluent limitations guidelines

process subcategory.

Furthermore, aluminum is not a useful benchmark pollutant because it is abundant as a natural

element in surface soils. Exhibit 1 is a brief report prepared in 2006 for comments on proposed

West Virginia water quality standards for aluminum and iron in the Ohio River. The report

highlights the following:

• Aluminum is found in Upper Ohio River basin surface soils at concentrations ranging

from 35,000 to 82,000 mg/kg (3.5 wt. % to 8.2 wt. %; median 5.4 wt. %), and at similar,

but somewhat lower ranges in Ohio River sediments;

• Runoff from surface soils and resuspension of Ohio River sediments account for elevated

concentrations of aluminum found in the Ohio River under high Ohio River flow

conditions. Daily mass flowing loads in excess of 500,000 pounds have been observed in

the Upper Ohio River under high flow conditions; and,

• Contributions of naturally occurring aluminum to the Upper Ohio River from surface

soils far exceed possible point source contributions from municipal and industrial

facilities.

1 Development Document for Effluent Limitations Guidelines and Standards for the Iron and Steel

Manufacturing Point Source Category. United States Environmental Protection Agency. Effluent Guidelines

Division. Washington, DC. EPA 440/1-82/024. May 1982. [Volume 1, Appendix C]. 2 Development Document for Final Effluent Limitations Guidelines and Standards for the Iron and Steel

Manufacturing Point Source Category. United States Environmental Protection Agency. Office of Water.

Washington, DC. EPA-821-R-02-04. April 2002.


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This indicates that if a stormwater benchmark concentration of 100 mg/L were imposed for TSS,

and when TSS is associated with natural surface soils at iron and steel mills, aluminum

concentrations in excess of the proposed TR aluminum benchmark concentration of 750 ug/L

can be expected routinely. Consequently, AISI requests that the proposed TR aluminum

benchmark concentration be removed from Table 8.F-1 for the final MSGP for iron and steel

facilities.

Consideration of PAHs for Stormwater Benchmark Monitoring

AISI requests that benchmark monitoring for polynuclear aromatic hydrocarbons (PAHs) not be

included in the final EPA MGSP.

By its Request for Comment No. 20, EPA is soliciting comments about whether PAHs should be

considered for stormwater benchmark monitoring. AISI believes stormwater benchmark

monitoring for PAHs is unwarranted as a universal benchmark requirement and for iron and steel

mills in particular. Benchmark monitoring for PAHs should not be required or set out as EPA

guidance that would apply to iron and steel facilities.

Aside from byproduct cokemaking operations, PAHs are not characteristic of any integrated steel

mill or EAF steel mill operations (see references at footnotes 1 and 2). For those iron and steel

mills without by-product cokemaking operations, existing controls through stormwater effluent

limits for oil and grease and through provisions of SPCC Plans are sufficient to address possible

stormwater discharges of PAHs.

PAH in process water discharges from by-product coke plants are regulated by the categorical

BAT effluent limitations guidelines at 40 CFR Part 420, specifically at §420.13(a). It is

standard practice at by-product coke plants to collect stormwater from the immediate process

areas and treat that stormwater with process wastewaters. This is encouraged and provided for

by 40 CFR Part 420 at §420.08 where NPDES permit effluent limits for regulated pollutants are

adjusted to account for additions of stormwater from the immediate process area. Also, PAH

monitoring is required at combined non-contact cooling water/stormwater discharges at certain

by-product coke plants. Consequently, stormwater from process areas at by-product coke plants

is effectively monitored and regulated. If any PAH stormwater benchmark monitoring is

proposed for the iron and steel industry, it should only apply to stormwater discharges associated

with by-product coke plants, and not stormwater discharges associated with other iron and steel

operations or outdoor slag processing operations.

Also, we reiterate our above comments regarding the proposed Universal Benchmark Monitoring

Concentration for COD. Stormwater discharges and combined process water/non-contact

cooling water/stormwater discharges at iron and steel mills are typically limited to 10 mg/L or 15

mg/L of oil and grease. Thus, these existing controls would apply to PAHs as well.

Furthermore, benchmark monitoring for PAHs is not cost effective and would be superfluous at

many iron and steel mills where oil and grease monitoring is required.


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AISI requests that EPA not include benchmark monitoring for PAHs as an element of a final

MSGP.

Proposed Stormwater Control Measures (SCMs) for Sector F – Primary Metals Facilities

AISI requests the proposed Stormwater Control Measures (SCMs) for Sector F – Primary Metals

Facilities be withdrawn and replaced with reasonable and appropriate SCMs.

Appendix Q of the proposed MSGP sets out EPA’s proposed sector-specific SCMs. The

proposed SCMs for the Primary Metals Facilities are listed under Sector F. AISI and its member

companies find that many, if not the majority, of the proposed sector-specific SCMs are

impractical and unreasonable for iron and steel mills. If they were required to be implemented

by state agencies as part of their stormwater programs, the cost impacts in terms of capital

investments for new facilities and requirements for new staff to implement the SCMs would be

unreasonable and wholly out of proportion to any possible environmental benefits that could be

realized. As described below, if one or more of the proposed Sector F SCMs were required to be

implemented by state permitting agencies, the investment costs for integrated iron and steel mills

and EAF steel mills would be in the tens of millions of dollars on a per facility basis.

Most of the prescriptive SCMs and requirements set out in Appendix Q for Sector F are

duplicative of the non-numeric technology-based effluent limit requirements set out in the

following sections of the proposed MSGP:

• Section 2.1.2.1 (Minimize Exposure);

• Section 2.1.2.2 (Good Housekeeping);

• Section 2.1.2.3 (Maintenance);

• Section 2.1.2.4 (Spill Prevention and Response);

• Section 2.1.2.5 (Erosion and Sediment Controls);

• Section 2.1.2.6 (Management of Runoff);

• Section 2.1.2.8 (Employee Training);

• Section 2.1.2.9 (Non-Stormwater Discharges); and,

• Section 2.1.2.10 (Dust Generation and Vehicle Tracking of Industrial Materials).

Accordingly, these overly prescriptive SCMs should not be duplicated in the Appendix Q

checklists, and they should be removed.

Our specific comments on the proposed SCMs are presented in Exhibit 2. We took the approach

of providing comments in a Word file of Sector F, with our comments typed in red alongside the

proposed SCMs.

Several proposed SCMs advise providing cover for intermediate steel products temporarily

stored outdoors; providing cover or maintaining raw materials indoors; storing slag indoors,

under cover or in enclosed containers; and, providing asphalt or concrete pads for stockpiling

materials.


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Each of these proposed requirements is not feasible for iron and steel mills. Exhibit 3 presents

annotated aerial photographs for two integrated steel mills and two EAF steel mills where the

raw material storage areas, intermediate product storage areas and slag processing areas are

highlighted. Summaries are provided in Table 1.

Table 1

Raw Material and Intermediate Product Storage Areas

and Slag Processing Areas at Iron and Steel Mills

Outdoor Raw Material,

Intermediate Product Storage

and Slag Processing Areas

Integrated Steel Mills EAF Steel Mills

Mill A

(Exhibit

3A)

Mill B

(Exhibit

3B)

Mill C

(Exhibit

3C)

Mill D

(Exhibit 3D)

Coal 17 acres 24 acres - -

Coke 34 acres 31 acres - -

Coke, Iron Ore & Flux 9 acres 31 acres - -

Iron Ore 8 acres 11 acres - -

Iron Ore, Flux & Slag - 7 acres - -

Flux, Scrap Metal, Mill Scale &

Slag - 75 acres - -

Scrap Metal 13 acres 28 acres

35 acres

51 acres Pig Iron - -

Direct-Reduced Iron (DRI) - - -

Hot Briquetted Iron (HBI) - - -

Slag Processing and Mill Scale 170 acres 19 acres 30 acres 45 acres

Wastewater Treatment

Residuals - 27 acres - -

Slab Storage - 47 acres - -

Coil Storage 28 acres 1 acre 17 acres 33 acres

Beam Storage - - 38 acres -

Total Above Areas 279 acres 301 acres 120 acres 129 acres

Approximate Total Facility

Area 3,000 acres 2,100 acres 800 acres 690 acres

Per Cent of Total Facility Area 9.3 % 14 % 15 % 19 %

Clearly, the respective proposed SCMs that address the areas highlighted in Exhibit 2 and Table

1 are impractical, unreasonable and not appropriate for iron and steel mills. There is even a

proposed Sector F SCM for Pollutant Source 14 (Materials Handling and Storage) that states:

“Maintain dry ground surfaces.” This is a nonsensical requirement that cannot be met at any iron

and steel mill. Given that raw material, product storage areas and slag processing areas at iron

and steel mills are outdoors, it is simply not possible to maintain dry ground surfaces.


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As an example of the impracticality of the proposed SCMs, the potential cost impacts of

providing impervious surfaces for raw material storage areas is addressed in our comments

below on EPA’s assessment of costs associated with the proposed MGSP.

AISI member companies could also be affected by proposed SCMs for other sectors where AISI

member companies have related activities such as Landfills (Sector L), Scrap Recycling (Sector

N), and Fabricated Metal Products Manufacturing Facilities (Sector AA). The Appendix Q

requirements for those sectors were reviewed and we have similar concerns for those sectors as

well as duplicative requirements of Section 2.1 of the proposed MSGP and duplicative

requirements for air and solid waste regulations.

Because many of the proposed SCMs are so far afield, AISI and its member companies propose

to set up a working group with EPA to develop appropriate and reasonable SCMs for iron and

steel mills that would build on existing and effective industry best management practices (BMPs)

for stormwater and existing successful facility SWPPPs. We believe the contemporary

environmental standards of performance for stormwater control across the iron and steel industry

meet Clean Water Act objectives.

EPA Assessment of Cost Impacts

In addition to withdrawing the proposed Stormwater Control Measures (SCMs) for Sector F,

AISI requests that EPA include in its cost assessment, the likely costs to facilities from state

implementation of the proposed MGSP in iron and steel facility-specific NPDES permits.

EPA’s Cost Impact Analysis for the Proposed 2020 Multi-Sector General Permit (MSGP) is

faulty primarily because it ignores the secondary implementation and administrative costs that

will likely be imposed on iron and steel facilities by state agencies, and it does not account for

massive investment costs that would be required to implement the proposed SCMs. EPA also

did not take into account indirect costs associated with implementation of the proposed MSGP

such as maintenance of covered areas, changes in material handling practices and others. These

ongoing costs, along with the high capital investment costs would be excessive and burdensome

with no commensurate environmental benefit.

As noted above, we firmly believe that state agencies, as they have in the past, will use a final

MSGP and final sector-specific SCMs as part of the stormwater control programs they

implement through NPDES permits for iron and steel facilities that are not subject to the MSGP.

If some of the more impractical and unreasonable proposed SCMs are imposed as requirements

in facility Stormwater Pollution Prevention Programs (SWPPPs), the cost impacts across the

industry would be in the billions of dollars.

This is demonstrated in Table 2, where we provide estimates of investment costs for providing

impervious surfaces for raw material and other material storage piles, as would be required by

the following proposed SCM for Sector F:


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Practice good stockpiling practices such as storing materials on concrete or

asphalt pads and/or surrounding stockpiles using diversion dikes or curbs to

limit run-on and to slow runoff.

AISI’s estimates of the investment costs for providing impervious surfaces for raw material

storage areas are based on the following considerations:

• Because of the large volumes of raw materials and slags that must be stored at

iron and steel mills, and the weight of those materials, asphalt pads would not be

suitable for such applications;

• A 2-foot thick concrete pad with heavy steel reinforcement would be required to

provide structural support for the massive weight of raw material and slag storage

piles; and,

• Nominal estimate for installed cost for concrete of $300 and $500 per cubic yard.3

Table 2

Estimated Investment Costs for Impervious Surfaces

for Raw Material Storage Areas at Iron and Steel Mills

Raw Material

Storage Area

Cubic Yards of Concrete

Required for 2-Foot Base

Estimated Investment Costs

$300/cu yd $500/cu yd

10 acres 33,267 $9,680,000 $16,100,000

25 acres 80,667 $24,200,000 $40,300,000

50 acres 161,333 $48,400,000 $80,700,000

100 acres 322,677 $96,800,000 $161,000,000

200 acres 645,333 $194,000,000 $323,000,000

Table 2 does not include estimated costs for maintenance of the concrete pads, diversion dikes or

curbs as noted in the proposed SCM, or for covering raw material stockpiles as noted in other

SCMs. The proposed SCMs that would require concrete pads would also result in increased

surface runoff that, in many cases, would require additional stormwater control facilities. The

substantial investment and operation and maintenance costs for such stormwater control facilities

are also not included in Table 2.

If the costs set out in Table 2 were applied to the raw material and product storage areas for the

two integrated steel mills and the two EAF steel mills described in Table 1 and Exhibit 3, the

aggregate cost for the four steel mills would be more than $800,000,000 to $1,300,000,000. The

cost across the industry would be staggering and unbearable. This is clearly an unreasonable and

3 Installed costs for concrete are regional. The estimated investment cost estimates presented in Table 2

are directly proportional to unit costs ($/cubic yard) for installed concrete.


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perhaps unintended consequence of the proposed MSGP and proposed SCMs for Primary Metals

Facilities.

MGSP Implementation Issues

1. Public Sign Related to MSGP Permit Coverage

AISI requests that EPA remove the proposed requirement for signage at iron and steel facilities.

All relevant NOI information is already available publicly and online. Requiring permit holders

to create a website and install a sign is duplicative and a waste of resources that would provide

no environmental benefit. Additionally, specific to the iron and steel sector, member facilities

have significant perimeter and safety setbacks. For many facilities, finding locations for signs

that serve any useful purpose would be difficult. Furthermore, this could potentially create a

safety hazard for the public when trying to observe such signs.

2. Proposed Stormwater Sample Timing

AISI requests that EPA provide flexibility within the MSGP permit to allow reasonable

stormwater outfall sampling requirements based on the site-specific circumstances at each

facility with respect to the sampling frequency and numbers of stormwater outfalls to be

sampled.

Section 4.1.4 of the proposed MGSP would require stormwater samples to be collected “within

the first 30 minutes of a discharge associated with a measurable storm event.” Under the

proposed MGSP, this would apply to all stormwater outfalls regulated by the permit. There are

iron and steel mills that have more than 40 stormwater outfalls. Many other iron and steel

facilities have several outfalls that are located across large sites. It is not possible to sample all

outfalls in the proposed MSGP timeframe. It would also be difficult and costly to sample more

than 40 outfalls during a quarter. Consideration should be given to allow selective sampling of

“substantially identical or representative” outfalls during a sampling period to lessen the burden.

Furthermore, requiring quarterly sampling is excessive, and the permit should allow for less

frequent sampling if outfalls are below benchmarks for several sampling events.

3. Consideration of Major Storm Control Measure Enhancements.

AISI requests that EPA not adopt the proposed new requirement that facilities consider major

storm control measure enhancements to address flooding issues.

Existing Best Management Practices (BMPs) at iron and steel mills should already account for

site-specific conditions, including potential flooding or other extreme weather-related events. To

the extent that EPA considers “extreme weather” to include the 100-year, 50-year, or even 20-

year storm events, imposing requirements on that basis in this permit is improper. The MSGP is

a 5-year permit, and facilities are responsible for controlling pollutants from the types of

conditions that should be expected to occur. In addition, most facilities covered by the MSGP


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have maintained coverage since at least 1995, so they have 25 years of experience with the types

of conditions that should be expected. Additional requirements in this area are excessive and

unnecessary.

4. Eligibility for Facilities using Coal-Tar Sealcoat on Paved Surfaces

AISI requests that EPA not ban use of coal-tar sealcoats on paved surfaces.

EPA Request for Comment 2 solicits comments about an effective ban on using coal-tar

sealcoats on paved surfaces where industrial activities are located. Coal-tar sealcoats are

manufactured using refined crude coal tar which is a by-product of cokemaking. This effective

ban would shrink the market for coal-tar sealcoats, which would reduce the outlet for crude coal

tar and possibly reduce the amount of coal tar beneficially reused. It could lead to disposal of

crude coal tar as a waste material. The Clean Water Act does not authorize EPA to condition

eligibility under the MSGP on the use of coal-tar sealants (or any product for that matter),

because such a condition effectively prohibits the use of a particular product. In addition, the

mere use of a product, such as coal-tar sealants, is not, without proof of actual discharge, an

activity that is related to the discharge of pollutants “associated with industrial activity” as that

term is defined by EPA’s regulations.

EPA did not consider or account for the potential cost impacts of a ban on the use of coal-tar

sealants in its cost assessment for the proposed MSGP. Such impacts would include potential

incremental costs associated with substitute materials for coal-tar sealants, loss of market shar for

the by-product cokemaking segment of the Primary Metals sector, and costs associated with off-

site disposal of coal tar as a waste material.

Some AISI member companies belong to the Coke Oven Environmental Task Force which

partnered with the Pavement Coatings Technology Coalition to submit comprehensive comments

to EPA on this issue. Reference is made to those comments which have been provided under

separate cover.

5. Additional Implementation Measures

AISI requests that EPA provide for broad availability of the proposed exceptions for “aberrant”

events, pollutant run-on from neighboring properties, and natural background levels within the

Additional Implementation Measures (AIM) protocol.

The MSGP permit should contain various triggers for corrective actions, whether related to

inspections or limited monitoring, but the AIM scheme that EPA has built from the prior MSGP

settlement misrepresents the settlement negotiations and creates unjustified confusion and related

financial impacts on regulated parties. To the extent EPA proceeds with the AIM program, it

should provide for broad availability of the proposed exceptions for “aberrant” events, pollutant

run-on from neighboring properties, and natural background levels within the AIM protocol.


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Summary and Recommendations

AISI and its US producer members request and recommend the following:

• That universal benchmark monitoring for total suspended solids (TSS), chemical oxygen

demand (COD) and pH, if retained in the final MSGP, not apply to Sector F (Primary

Metals Facilities), and not apply to iron and steel mills in particular.

• That EPA withdraw the proposed Universal Benchmark concentration for COD, or make

it a Sector-Specific Benchmark Concentration only where warranted. This would not

apply to iron and steel facilities that do not have by-product cokemaking operations.

• That EPA withdraw the Sector-Specific Benchmark Concentration for total recoverable

aluminum (TR aluminum) that is proposed for iron and steel facilities at Subsector F.1.

• That EPA not adopt a Universal Benchmark Concentration or a Sector-Specific

Benchmark Concentration for PAHs, or require stormwater monitoring for PAHs as may

be applied to iron and steel facilities;

• That EPA withdraw the proposed SCMs for Sector F (Primary Metals Facilities). AISI

and its member companies propose to work with EPA to develop reasonable and

effective SCMs for iron and steel facilities that would build on existing and effective best

management practices for stormwater control that are being implemented at iron and steel

mills; and,

• That EPA conduct a comprehensive cost impact analysis that takes into account state

agency implementation of a proposed revised MSGP and proposed revised SCMs

through NPDES permits for iron and steel facilities that are not subject to the MSGP;

• That EPA remove the proposed requirement for signage at iron and steel facilities.

• That EPA provide flexibility within the MSGP permit to allow reasonable stormwater

outfall sampling requirements based on the site-specific circumstances at each facility

with respect to the sampling frequency and numbers of stormwater outfalls to be

sampled.

• That EPA not adopt the proposed new requirement that facilities consider major storm

control measure enhancements to address flooding issues.

• That EPA provide for broad availability of the proposed exceptions for “aberrant” events,

pollutant run-on from neighboring properties, and natural background levels within the

Additional Implementation Measures (AIM) protocol.

EXHIBIT 1

Page Q-100 of 672

Attachment B: Appendix Q, Sector F (Primary Metals Sector) – Proposed Storm Water Control Measures (SCMs)

Page Q-101 of 672

Products/scrap metal is stored over large areas. These SCMs are impractical given the large storage areas in the facilities. Installing and maintaining this equipment would be infeasible and a costly burden. Remove condition.

Stormwater Control Measures: Sector F – Primary Metals Facilities

SCMs Reason Why Inappropriate / Not Done

Pollutant Source 1: Metal Product Storage - Foundry Returns, Scrap Metal, Turnings, Fines, Ingots, Bars, Pigs, Wire

Pollutant source present? ☐ YES ☐ NO (if NO, skip to next section)

□ Confine storage to designated and labeled areas outside of drainage pathways and away from surface waters.

• Products/scrap metal are stored over large areas. Labeling/signage is impractical

and an ineffective SCM. Storage outside of drainage pathways/away from surface

waters is also infeasible given the large storage areas in the facilities. Duplicative of

Section 2.1.2 of MSGP. Remove condition.

□ Provide temporary cover (e.g., tarps) for the storage area.

• Products are stored over large areas. Impractical and unrealistic for intermediate

products at steel mills where flat-rolled products (coils) are produced and at steel

mills where long products (bar products, steel tubes) are produced. Duplicative of


□ Minimize material storage through effective inventory and shipping controls.

• The amount of on-site metal product storage is primarily a function of production

levels and overall market conditions. It is neither feasible nor practical to consider

inventory control as an SCM. Furthermore, there is no reasonable potential for

significant storm water contamination from temporary outdoor storage of

intermediate metal products (i.e., slabs, coils, long products). Remove condition. □ Minimize run-on from adjacent properties using diversion dikes, berms, curbing, surface grading, or other equivalent measures.

• Products/scrap metal are stored over large areas. These SCMs are impractical given

the large storage areas in the facilities. Installing and maintaining this equipment

would be infeasible and a costly burden. Duplicative of Section 2.1.2 of MSGP.

Remove condition.

□ Stabilize areas with exposed soil using diversion dikes, berms, curbing, concrete pads, etc.

• Products/scrap metal are stored over large areas. These SCMs are impractical given

the large storage areas in the facilities. Installing and maintaining this equipment

would be infeasible and a costly burden. Duplicative of Section 2.1.2 of MSGP.

Remove condition.

Pollutant Source 2: Storage and Handling of Fluxes


□ Visually inspect treatment chemical loading and unloading areas frequently during and after activities to identify and clean up any spills or leaks.

• This is a common Best Management Practice (BMP) and part of storm water pollution

prevention plans (SWPPPs) throughout the iron and steel industry. Duplicative

requirement, remove condition.

Page Q-102 of 672



□ Cover and/or enclose treatment areas or apply log treating chemicals on an impervious containment pad.

• Not applicable. Log treating chemicals are not used at iron and steel mills.

Nonetheless, it would be impractical and unreasonable to cover and/or enclose

process water treatment areas at iron and steel mills. Remove condition.

Pollutant Source 3: Coke and Coal Storage Piles, Bins, and Material Handling



• Coke and coal piles are stored over large areas. It is common practice to confine

coke and coal storage to designated areas outside of drainage pathways and

away from surface waters. However, that is not practical at all locations. Labeling

of storage piles is not common and is not considered useful as an SCM

Labeling/signage is impractical given the large storage areas in the facilities.

Duplicative of Section 2.1.2 of MSGP. Remove condition.

□ Divert stormwater around storage areas using vegetated swales and/or berms.

• It is common practice to contain storm water within coal and coke piles and/or to

collect and treat runoff from these area in storm water retention basins. Duplicative

of Section 2.1.2 of MSGP. Remove condition.

□ Where possible store coke and coal under cover, indoors, or with other structures to prevent wind-blown losses.

• It would be impractical and unreasonable to store coke and coal under cover or

indoors. See annotated aerial photographs of iron and steel mills that show the

extensive raw material storage areas. Duplicative of Section 2.1.2 of MSGP. Remove

condition.

□ Use control measures such as berms, silt fencing, or waddles to prevent sediment from leaving storage area.




□ Practice good stockpiling practices such as storing materials on concrete or asphalt pads and/or surrounding stockpiles using diversion dikes or curbs to limit run-on and to slow runoff.

• It would be impractical and unreasonable to store coke and coal on concrete or

asphalt pads. See annotated aerial photographs of iron and steel mills that show the

extensive raw material storage areas. Duplicative of Section 2.1.2 of MSGP. Remove

condition.

□ Trap particulates originating in coke or coal storage/handling areas with filter fabric fencing, gravel outlet protection, sediment traps, vegetated swales, buffer strips of vegetation, catch-basin filters, retention/detention basins, or equivalent.




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□ Minimize quantities of coke or coal stored on site through implementation of effective inventory control.

• Steel mills use and store massive quantities of coke and coal. Inventory control is

managed to support production business objectives. Restricting inventory as a SCM

would be unrealistic and unreasonable. Remove condition.

□ Practice good housekeeping measures such as frequent removal of dust and debris. Cleanup methods may include mobile sweepers, scrapers, or scoops.

• It is common practice at iron and steel mills, and required by air permits, to control

dusts from roadways. In most cases this is done, depending on conditions, with water

application to roadways using tank trucks. Duplicative of Section 2.1.2 of MSGP.

Remove condition.

□ Use properly designed basins for collection, containment, and recycling of pile spraying materials.

• Where space allows, it is common practice to contain storm water within coal and

coke piles and/or to collect and treat runoff from these area in storm water retention

basins. Remove condition.

□ Train applicable employees in good housekeeping measures within the first week of employment followed by refresher training annually and as needed.

• Employee training is typically a component of SWPPPs. A requirement to conduct

such training within one week of employment is not feasible and overly prescriptive.

A significant aspect of employee training is on-the-job training that occurs over many

months. Duplicative of Section 2.1.2 of MSGP. Duplicative requirement. Remove

condition. Pollutant Source 4: Storage and Handling of Casting Sand



• Casting sand is typically not used at iron and steel mills. Nonetheless, comments

about the impracticality and unreasonableness of proposed MSGP SCMs for other

raw materials would be applicable to casting sand as well. Remove pollutant source

section.

□ Store raw sand in silos or covered hoppers or store indoors whenever possible.




section.

□ Cover storage pile with tarps or awning. • Casting sand is typically not used at iron and steel mills. Nonetheless, comments



section.

□ Practice good stockpiling practices such as storing materials on concrete or asphalt pads and/or surrounding stockpiles using diversion dikes or curbs to limit run-on and to slow runoff.




section.

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□ Install sediment basins, silt fencing, vegetated filter strips, or other sediment removal measures downstream/ downslope.




section.

□ Minimize quantities of sand stored on site through implementation of effective inventory control.




section.

Pollutant Source 5: Slag or Dross Stored or Disposed of in Piles or Drums



• Slag is stored over large areas. Labeling/signage is impractical given the large

storage areas in the facilities. Where space allows, it is common practice to locate

slag processing areas outside of drainage pathways and to contain storm water

within the slag processing areas. Duplicative of Section 2.1.2 of MSGP. Remove

condition. □ Store slag and dross indoors, under cover, or in sealed containers.

• Slag is stored over large areas. It would be impractical and unreasonable to store

blast furnace slag, basic oxygen furnace steelmaking slag and electric furnace

steelmaking slag indoors, under cover or in sealed containers. See annotated aerial

photographs of iron and steel mills. Slag processing areas encompass tens of acres

at most steel mills. Duplicative of Section 2.1.2 of MSGP. Remove condition. □ Establish regular disposal of slag or dross to minimize quantities stored and handled on site.

• See annotated aerial photographs of iron and steel mills. Slag processing areas at

iron and steel mills are expansive. Slag processing is typically managed by third-

party contractors. These is no realistic way to minimize quantities stored on site. On-

site storage of slag is a function of market conditions. Remove condition.

□ Minimize run-on to slag storage areas using diversion dikes, berms, curbing, or vegetated swales.

• It is common practice to contain storm water within slag processing areas and/or to

collect and treat runoff from these area in storm water retention basins. Slag

processing is conducted in large area. Infeasible to install berming, etc. Duplicative


□ Trap particulates originating in slag storage areas with silt fencing, gravel outlet protection, sediment traps, vegetated swales, buffer strips of vegetation, catch-basin filters, and/or retention/detention basins, or equivalent.

• Where space allows, it is common practice to contain storm water within slag

processing areas and/or to collect and treat runoff from these area in storm water

retention basins. Slag processing is conducted in large area. Infeasible to install

berming, etc. Duplicative of Section 2.1.2 of MSGP. Remove condition.

Page Q-107 of 672



Pollutant Source 6: Fly Ash, Particulate Emissions, Dust Collector Sludges and Solids, and Baghouse Dust


□ Store all dusts and sludge indoors to prevent contact with precipitation or losses due to wind.

• Electric arc furnace (EAF) steelmaking baghouse dust is a listed hazardous waste

(K061) and is managed as such at non-integrated steel mills in enclosed systems. It is

not practical to store all other dusts and sludges indoors as an SCM. Duplicative of


□ Establish regular disposal schedule to minimize quantities stored and handled on site.

• EAF baghouse dust is managed and stored as a hazardous waste. Other air pollution

control dusts and wastewater treatment sludges are managed and disposed of as

generated with respect to variable production schedules. Regular disposal

schedules are not practical in many cases. Disposal timelines are regulated by waste

regulations and air regulations. Air regulations require air pollution controls

dusts/sludges to be contained such that they will not impact stormwater. Remove

condition. □ Inspect all residue hauling vehicles for proper

covering over the load, adequate gate sealing, and overall integrity of the body or container.

• Unrelated to stormwater management. Covered by waste/DOT regulations, and

could institute new requirements. Impossible to cover intricacies of applicable

regulations in a single line in a checklist. Not needed. Remove condition.

Pollutant Source 7: Storage and Disposal of Waste Sand and Refractory Rubble in Piles


□ Store piles under cover or tarps whenever possible.

• Waste sand is typically not generated at iron and steel mills. It would be impractical

to store piles of refractory rubble under cover or tarps. Duplicative of Section 2.1.2 of

MSGP. Remove condition.

□ Establish regular disposal schedule to minimize quantities stored on site.

• Waste sand is typically not generated at iron and steel mills. Refractory rubble piles

are intermittently accumulated. It would be impractical to establish a regular

disposal schedule. Remove condition.

□ Stabilize areas of waste product storage and perform daily sweeping of area.

• Waste sand is typically not generated at iron and steel mills. Refractory rubble piles

are intermittently accumulated. It would be impractical to stabilize and daily sweep

piles and areas. Daily sweeping is overly burdensome and would impose excessive

costs. Remove condition.

Page Q-108 of 672

Pollutant Source 8: Scrap Processing Activities (Shredding, etc.)


Good Housekeeping

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□ Schedule frequent cleaning of accumulated fluids and particulate residue around all scrap processing equipment.

• Scrap processing (e.g., automobile and appliance shredding and material

separation) is not practiced at most non-integrated steel mills. Remove

condition/pollutant source section.

□ Conduct routine preventive maintenance of equipment per original equipment manufacturer (OEM) recommendations. Replace worn or malfunctioning parts.

• Unrelated to stormwater management. If oil spills are the concern, SPCC

requirements and requirements to clean up spills in 2.1.2.1.c would cover this.

Duplicative requirement. Remove condition.

□ Conduct periodic maintenance and clean out of all sumps, oil/water separators, media filters. Dispose of residual waste materials properly, e.g., according to Resource Conservation and Recovery Act (RCRA).

• Does not directly impact stormwater. Waste regulations should not be included in a

stormwater permit. Duplicative requirement. Remove condition.

□ Provide alarm, pump shutoff, or sufficient containment for hydraulic reservoirs in the event of a line break.

• SPCC requirement. Shouldn’t be in a Stormwater permit. Duplicative requirement.

Remove condition.

□ Provide site gages or overfill protection devices for all liquid and fuel storage reservoirs and tanks.


Remove condition.

□ Provide containment bins or equivalent for shredded material, especially lightweight materials such as fluff (preferably at the discharge of these materials from the air classification system).


Remove condition.

Minimizing Exposure

□ Where practicable, locate process equipment (e.g., balers, briquetters, small compactors) under cover.

• Impractical to locate large process equipment under cover. Duplicative of Section

2.1.2.1 of MSGP. Remove condition.

□ Provide diversion berms, dikes, or vegetated swales around the perimeter of the area to limit run-on.

• Not feasible for large areas. Duplicative of Section 2.1.2.1 of MSGP. Remove

condition.

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□ Cover hydraulic equipment and combustion engines.

• Not feasible for large mobile equipment. Unrelated to stormwater management. If

oil spills are the concern here, SPCC requirements and requirements to clean up spills

in 2.1.2.1.c would cover this. Duplicative requirement. Remove condition.

□ Stabilize high-traffic areas around processing equipment (e.g., concrete pads, gravel, and pavement) where practicable.

• Duplicative of Section 2.1.2.1 of MSGP. Remove condition.

Management of Runoff

□ Site process equipment on elevated concrete pads or provide runoff diversion structures, berms, containment trenches, or surface grading around process equipment. Discharge runoff from within bermed areas to a sump, oil/water separator, media filter, or discharge to sanitary sewer.

• Requiring elevated concrete pads imposes significant cost to permitted facilities with

little to no added benefit. SPCC requirement. Shouldn’t be in a Stormwater permit.

Duplicative of Section 2.1.2.6 of MSGP. Remove condition. Remove condition.

□ Provide dry cleanup materials (e.g., dry absorbents, drip pans) to prevent contact of hydraulic fluids, oils, fuels, etc., with stormwater runoff.

• SPCC requirement. Shouldn’t be in a Stormwater permit. Duplicative of Section

2.1.2.6 of MSGP. Remove condition. Remove condition.

Pollutant Source 9: Storage and Disposal of Waste Sand and Refractory Rubble in Piles


□ Store piles under cover or tarps whenever possible.

• This is a duplicate of Source 7. Remove entire section.

□ Establish regular disposal schedule to minimize quantities stored on site.


□ Stabilize areas of waste product storage and sweep daily.


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Pollutant Source 10: Charging of Coke Ovens or Sintering Plants


□ Cover any exposed areas related to furnace charging/ material handling activities.

• It is not practical to cover exposed areas related to coke oven charging and

material handling activities. By-product and non-recovery coke plants and sinter

plants are massive manufacturing facilities with significant outdoor operations that

cannot be covered. Remove condition

□ Stabilize areas around all material handling areas and sweep regularly.

• It is not practical to sweep regularly. Some air permits require watering of these

areas. Remove condition.

□ Route runoff from particulate-generating operations to sediment traps, vegetated swales, buffer strips of vegetation, catch-basin filters, retention/detention basins, or equivalent.


collect and treat runoff from these area in storm water retention basins. The costs for

mechanical filtration systems would be excessive with little added benefit.

Duplicative of Section 2.1.2 of MSGP. Remove condition.

Pollutant Source 11: Blast Furnaces, Electric Arc Furnaces, Induction Furnaces, and Emissions Control Equipment


□ Use dust collection systems (e.g., baghouses) to collect airborne particles generated by handling operations.

• It is not clear what “handling operations” means. Raw materials when charged to

blast furnaces are in enclosed structures. Raw materials charging to steelmaking

furnaces is conducted indoors. Some facilities are equipped with secondary air

emission control systems for fugitive emissions; however, such facilities are not

necessary at all facilities to comply with air permits. This would be overly broad as a

SCM.

• Unrelated to stormwater management. Covered by air regulations, and could

institute new requirements that would not otherwise be required. Impossible to cover

intricacies of applicable regulations in a single line in a checklist. Not needed.

Remove condition.

Page Q-113 of 672

□ Promptly dispose of waste materials from dust collection systems and other operations.

• EAF steelmaking baghouse dust is a listed hazardous waste (K061) and is managed

as such at non-integrated steel mills in enclosed systems. EAF baghouse dust is

managed and stored as a hazardous waste. Other air pollution control dusts and

wastewater treatment sludges are managed and disposed of as generated with

respect to variable production schedules. Regular disposal schedules are not

practical in many cases. Disposal timelines are regulated by waste regulations and

air regulations. Air regulations require air pollution controls dusts/sludges to be

contained such that they will not impact stormwater. Duplicative requirement.

Remove condition.

□ Remove spilled material and settled dust from paved portions of the facility by shoveling and sweeping on a regular basis.

• Hot end steelmaking operations (sinter plants, blast furnaces, basic oxygen and

electric arc furnace steelmaking, continuous casting) are inherently dusty

operations. It would be impractical and unreasonable to implement the routine

housekeeping measures from this proposed SCM. Duplicative of Section 2.1.2 of

MSGP.

□ Regularly clean material handling equipment and vehicles to remove accumulated dust and residue.

• Hot end steelmaking operations (sinter plants, blast furnaces, basic oxygen and

electric arc furnace steelmaking, continuous casting) are inherently dusty

operations. It would be impractical and unreasonable to implement the routine

housekeeping measures from this proposed SCM. Duplicative of Section 2.1.2 of

MSGP.

Page Q-114 of 672



□ Route runoff from particulate generating operations to sediment traps, vegetated swales, buffer strips of vegetation, catch-basin filters, retention/detention basins, or equivalent.

• Impractical/cost prohibitive to treat stormwater over possibly huge areas. The costs

for mechanical filtration systems would be excessive with little added benefit.

Duplicative of Section 2.1.2 of the MSGP. Remove condition.

□ Determine an appropriate schedule for inspection and maintenance of all pollution control equipment and implement it—check for any particulate deposition from leaks, spills, or improper operation of equipment.

• Proper operation & maintenance of air pollution control equipment and proper

operation & maintenance of water pollutant control equipment is regulated by Title

V and NPDES permits, respectively. This would be redundant and should not be

considered in the MSGP. Unrelated to stormwater management. Covered by air

regulations, and could institute new requirements that would not otherwise be

required. Impossible to cover intricacies of applicable regulations in a single line in a

checklist. Not needed. Remove condition. □ Train applicable employees in in good

housekeeping, inspection and maintenance of emission control equipment, and spill prevention and control within first week of employment followed by refresher training annually and as needed.



Furthermore, much of new employee training is in the form of on-the-job training

which occurs over many months. Duplicative of Section 2.1.2 of the MSGP. Remove

condition.

Pollutant Source 12: Storage of Obsolete Equipment


□ Where possible, dispose of unused equipment properly, or move indoors.

• Not feasible and not necessarily related to stormwater management. Covered by

other regulations, and could institute new requirements that would not otherwise be


checklist. If concern is fluids remaining in unused equipment, SCM should be

directed at management of fluids. Duplicative of Section 2.1.2 of the MSGP. Remove

condition.


• Products/scrap metal are stored over large areas. Labeling/signage is impractical

and an ineffective SCM. Infeasible to store outside of drainage pathways/away from

surface waters is also infeasible given the large storage areas in the facilities.

Duplicative of Section 2.1.2 of the MSGP. Remove condition.

□ Cover obsolete equipment with a tarp, awning, or roof.

• Covering obsolete equipment with tarps or awnings is not practical for the number

and size of large equipment items at iron and steel mills. Not feasible and not

necessarily related to stormwater management. Section 2.1.2.1 already requires

drain fluids from equipment that will be decommissioned. Remove condition.

Page Q-115 of 672

□ Provide diversion berms, dikes, or vegetated swales around the perimeter of the area to limit run-on.

• Not feasible and not necessarily related to stormwater management. Duplicative of

Section 2.1.2 of the MSGP. Remove condition.

Page Q-110 of 672



□ Place equipment on a concrete pad. • Placing equipment on concrete pads is not practical at iron and steel mills. Not

feasible and overly restrictive. Remove condition.

□ Use sand filters or other end-of-pipe treatment as back-up measures for outfalls receiving drainage from areas where oil is potentially present.

• Management and control of oil discharges is regulated by categorical effluent

limitations guidelines (40 CFR Part 420) for iron and steel mills, and by the Oil Pollution

Prevention regulations (i.e., SPCC Plans). This proposed SCM is redundant and, if

interpreted literally, would cost hundreds of millions of dollars if not more across the

iron and steel industry.

Pollutant Source 13: Storage of Products Outside After Machining, Painting, Pickling, or Cleaning Operations



• It is common practice to temporarily store semi-finished steel products (e.g., pickled

and cold-rolled steel coils; metal coated steel coils) indoors prior to shipment.

Remove condition.

□ Store all materials inside or under cover whenever possible.

• It is common practice to temporarily store certain semi-finished steel products (e.g.,

pickled and cold-rolled steel coils; metal coated steel coils) indoors prior to shipment.

However, due to production quantities and the size of the products, it is impractical

to cover or store all intermediate and final product indoors. Remove condition.

□ Prevent run-on to product storage areas through curbs, berms, dikes, etc.

• Duplicative of Section 2.1.2 of the MSGP. Remove condition.

□ Use sand filters or other end-of-pipe treatment as back-up measures for outfall receiving drainage from areas where oil is potentially present.

• Management and control of oil discharges is regulated by categorical effluent

limitations guidelines (40 CFR Part 420) for iron and steel mills, and by the Oil Pollution

Prevention regulations (i.e., SPCC Plans). This proposed SCM is redundant and, if

interpreted literally, would cost hundreds of millions of dollars if not more across the

iron and steel industry. Remove condition.

Page Q-111 of 672

□ Remove residual chemicals from intermediate or finished products before storage or transport outside.

• Not necessarily related to stormwater management. Covered by DOT regulations,

and could institute new requirements that would not otherwise be required.

Impossible to cover intricacies of applicable regulations in a single line in a checklist.

Remove condition.

• Some customers required their steel to be coated with chemicals prior to shipment so

the steel can be drawn down at customer facilities. Typically, these products are

wrapped to retain the coating or transported in covered trucks.

□ Stabilize storage areas and establish and implement an appropriate sweeping schedule.

• It would be impractical to stabilize and daily sweep piles and areas. Daily sweeping

is excessive. Duplicative of Section 2.1.2 of the MSGP. Remove condition

Page Q-112 of 672



Pollutant Source 14: Materials Handling and Storage


Storage Areas – General

□ Store materials on concrete pads to facilitate cleanup of leaks/spills.

• Duplicative section. Materials handling and storage occurs over large areas. Storing

materials on concrete pads is not practical at iron and steel mills. Not feasible and

overly restrictive. Remove condition.

□ Provide secondary containment for storage tanks and drum storage areas.

• Duplicative section. Covered by SPCC and storage tank regulations, and could


intricacies of applicable regulations in a single line in a checklist. Duplicative of


□ Maintain dry ground surfaces. • This is unreasonable and highly impractical because outdoor ground at iron and

steel facilities is not covered. Furthermore, watering roads and some storage piles is

required by air permits. Remove condition.

□ Confine storage to designated and labeled areas outside of drainage pathways and away from high-traffic areas and surface waters.


□ Shelter chemical and material handling and storage areas with roofs, covers, or other appropriate forms of protection.


□ Store and handle reactive, ignitable, or flammable liquids in compliance with applicable local fire codes, local zoning codes, and the National Electric Code.

• Duplicative of requirements already required by local codes. Remove condition.

□ Prevent run-on to storage area. • In some cases, storage areas comprise significant areas and preventing run-on may

be impossible. Duplicative of Section 2.1.2 of the MSGP. Remove condition.

Page Q-113 of 672



□ Divert stormwater around storage areas using vegetated swales and/or berms.


Storage Areas – Liquid Fuel

□ If area is uncovered, connect sump outlet to sanitary sewer (if possible) or to appropriate treatment such as an American Petroleum Institute (API) or Coalescing Plate (CP) oil/water separator, catch basin filter, or other appropriate system.

• Containment and management of storm water for fueling areas is regulated by the

SPCC program. Reference should be made to facility SPCC Plans rather than

include a new SCM in the MSGP. Duplicative of Section 2.1.2 of the MSGP. Remove

condition.

□ If connecting to a sanitary sewer, check with the system operator to ensure that the discharge is acceptable.

• Duplicative of requirements outside of MSGP in industrial user permits issued by

POTWs. Remove requirement.

□ If implementing separator or filter technologies, ensure that regular inspections and maintenance procedures are in place.


Permanent Tanks

□ Store permanent tanks on an impervious surface surrounded by dikes with a height sufficient to contain a spill (the greater of either 10 percent of the volume of all containers or 110 percent of the volume of the largest tank).

• Secondary containment for oil storage tanks is regulated by the Oil Pollution

prevention regulations (i.e., SPCC Plans) and state storage tank regulations. It is

standard practice at iron and steel mills to provide secondary containment for

chemical storage tanks (e.g., pickling acids, caustic cleaners). It would be

impractical and unreasonable to require such containment for all permanent

storage tanks (e.g., water and wastewater tanks). The cost to implement secondary

containment across the industry would be in the hundreds of millions of dollars, if not

more. □ Clearly label all permanent tanks. • Unrelated to stormwater management. Covered by storage tank management



checklist. Not needed. Remove condition.

Page Q-114 of 672

□ Provide controls for aboveground tanks. • This proposed SCM is not well-defined. Unrelated to stormwater management.

Covered by storage tank management regulations, and could institute new

requirements that would not otherwise be required. Impossible to cover intricacies of

applicable regulations in a single line in a checklist. Not needed. Remove condition.

Page Q-115 of 672



□ Use double-walled tanks. • This proposed SCM is impractical and unreasonable. Larger iron and steel mills

typically have hundreds of tanks. Double-walled tanks are not a reasonable SCM.

Regardless, covered by storage tank management regulations, and could institute

new requirements that would not otherwise be required. Impossible to cover


Remove condition. □ Provide tanks with overflow protection. • Covered by storage tank management regulations, and could institute new



□ Provide fuel level indicators. • Covered by storage tank management regulations, and could institute new


applicable regulations in a single line in a checklist. Not needed. Duplicative of


□ Keep valves on permanent storage tanks in “off” position and locked at all times, except when collected water is removed.

• Covered by SPCC/storage tank management regulations, and could institute new



□ Institute protocols for testing stormwater in containment areas prior to discharge.

• Covered by SPCC/storage tank management regulations, and could institute new



□ Check/test stormwater in containment areas prior to discharge.

• Covered by storage tank management regulations, and could institute new



□ Maintain good integrity of all drums and tanks. • Covered by storage tank management regulations, and could institute new



□ Keep liquid transfer nozzles/hoses in secondary containment area.

• Covered by storage tank management regulations, and could institute new



Page Q-116 of 672



Portable Drums and Containers

□ Store drums, including empty or used drums, in secondary containment with a roof or cover (including temporary cover such as a tarp that prevents contact with precipitation). Store drums indoors when possible.

• Covered by SPCC/other regulations, and could institute new requirements that

would not otherwise be required. Impossible to cover intricacies of applicable

regulations in a single line in a checklist. Impractical due to the quantity of

miscellaneous chemicals used throughout the process. Not needed. Remove

condition.

□ Provide secondary containment, such as dikes or portable containers, with a height sufficient to contain a spill (the greater of 10 percent of the total enclosed drum volume or 110 percent of the volume contained in the largest tank).

• Covered by SPCC/other regulations, and could institute new requirements that



□ Clearly label drums with their contents. • Unrelated to stormwater management. Covered by various other regulations, and

could institute new requirements that would not otherwise be required. Impossible to

cover intricacies of applicable regulations in a single line in a checklist. Not needed.

Remove condition.

□ Identify potentially hazardous materials, their characteristics, and their use.

• Unrelated to stormwater management. Covered by various other regulations, and



Remove condition.

□ Clearly identify whether a drum contains materials that should be stored outdoors or indoors. Drums stored outdoors should be stored under cover.




Remove condition.

□ Use temporary containment and portable drip pans where required.

• Covered by SPCC/storage tank management/other regulations, and could institute



Remove condition.

□ Use spill troughs for drums with taps. • Covered by SPCC/storage tank management/other regulations, and could institute



Remove condition.

□ Empty containment units with manually operated pumps or ejectors.

• Covered by SPCC/storage tank management/other regulations, and could institute



Remove condition. Also, overly prescriptive. Facilities can determine how to empty

their own containments in accordance with applicable regulations.

Page Q-117 of 672

Page Q-118 of 672



□ If facility drainage is not engineered as listed above, equip the final discharge point of all facility sewers to prevent discharge in the event of an uncontrolled spill.

• This proposed SCM is not practical and is unreasonable. Many iron and steel mills

have numerous storm water-only outfalls, some with more than 40 outfalls. Expensive

and burdensome. No environmental benefit. Remove condition.

Materials Handling and Inventory Management

□ Document potentially hazardous materials including their characteristics and use.




Remove condition.

□ Limit purchases of potentially hazardous materials. Also limit the storage and handling of such materials.

• The purchase and use of potentially hazardous materials at iron and steel mills is a

function of process and production needs. Limiting purchase and storage of such

materials is not a reasonable SCM. Remove condition.

□ Secure and carefully monitor hazardous materials to prevent theft, vandalism, and misuse.

• Unrelated to stormwater management. Covered by SPCC/Storage

tank/Waste/other regulations, and could institute new requirements that would not

otherwise be required. Impossible to cover intricacies of applicable regulations in a

single line in a checklist. Not needed. Remove condition.

□ Use fluid level indicators. • Covered by SPCC/storage tank management/other regulations, and could institute


intricacies of applicable regulations in a single line in a checklist. Not practical for

drums. Not needed. Remove condition.

□ Maintain an inventory of fluids to help identify any leakage. Identify quantity, receipt date, service life, users, and disposal procedures.

• Unrelated to stormwater management. Overly prescriptive with little or no

environmental benefit. Otherwise, covered by SPCC/storage tank

management/other regulations, and could institute new requirements that would

not otherwise be required. Impossible to cover intricacies of applicable regulations

in a single line in a checklist. Not needed. Remove condition.

□ Clearly identify accumulation dates on the outside of waste chemical storage units.

• Unrelated to stormwater management. Covered by Waste/other regulations, and



Remove condition.

□ Properly dispose of chemicals that are no longer in use by taking them to a hazardous waste recycling center or contracting with a qualified disposal company. Keep records to identify quantity, receipt date, service life, users, and disposal routes.

• Unrelated to stormwater management. Not all chemicals are hazardous, and are

not classified as hazardous waste and should not be managed as so. Overly

prescriptive. Covered by Waste/other regulations, and could institute new



Page Q-119 of 672

Page Q-120 of 672



□ Keep waste chemicals segregated when reuse or recycling is possible.

• Unrelated to stormwater management. Overly prescriptive with no environmental

benefit. Covered by Waste/other regulations, and could institute new requirements

that would not otherwise be required. Impossible to cover intricacies of applicable


□ Return toxic material packaging to the supplier for re-use.

• Unrelated to stormwater management. Overly prescriptive with no environmental

benefit. Covered by Waste/other regulations, and could institute new requirements


regulations in a single line in a checklist. Cannot force suppliers to take their

packaging material back for reuse. Not needed. Remove condition.

Spill Containment and Prevention

□ Develop and implement spill plans or spill prevention, control, and countermeasure (SPCC) plans, if required for your facility.

• Reference should be made to facility SPCC Plans which address the proposed SCMs

in this section. These proposed SCMs are redundant and not useful. Covered by

SPCC regulations, and could institute new requirements that would not otherwise be


checklist. Not needed. Remove condition. □ Keep spill kits readily available. • Covered by SPCC regulations, and could institute new requirements that would not



□ Have materials such as absorbent pads easily accessible to clean up spills.

• Covered by SPCC regulations, and could institute new requirements that would not



□ Clean up leaks and spills immediately. Use dry methods if possible.




□ Provide drip pads/pans where chemicals are transferred from one container to another to recover and reuse leaks/spills.




□ When using portable drip pans, employ temporary containment.




Batteries

Page Q-121 of 672

Page Q-122 of 672



□ Store used lead-acid batteries on an impervious surface, under cover, protected from weather and freezing.

• Covered by waste regulations, and could institute new requirements that would not



□ If a battery is dropped, treat it as if it is cracked.

• Treating a battery that is not cracked as cracked is burdensome. No benefit.

Remove condition.

□ Neutralize acid spills, such as with baking soda, and dispose of the resulting waste as hazardous.

• Covered by waste/safety regulations, and could institute new requirements that



Dust Control

□ Use dust collection systems (i.e., baghouses) to collect airborne particles generated as a result of material handling operations or aggregate drying.

• Unrelated to stormwater management. Covered by air regulations, and could



Remove condition.

□ Promptly dispose of waste materials from dust collection systems and other operations.

• Unrelated to stormwater management. Covered by waste regulations, and could



Remove condition.

□ Remove spilled material and dust from paved portions of the facility by regularly shoveling, sweeping, or vacuuming.

• Impractical/infeasible. Duplicative of air permit requirements for dust control.

Remove condition.

□ Clean material handling equipment and vehicles to remove accumulated dust and residue on a regular basis.

• Impractical/infeasible for large material handling systems at iron and steel mills.

Remove condition.

□ Utilize catch basins to collect potentially contaminated stormwater.

• Size of facility and facility layout determinative of whether this is a feasible option.

Not practical at all locations. Remove condition.

Page Q-123 of 672



□ Use a detention pond or sedimentation basin to reduce suspended solids.

• Size of facility and facility layout determinative of whether this is a feasible option.

Not practical at all locations. Remove condition.

Inspections and Training

□ Inspect berms, curbs, and secondary containment systems weekly. Perform repairs as needed.

• Duplicative of section 2.1.2 of draft MSGP. Also, covered by existing regulations, and



Remove condition.

□ Inspect storage tanks and piping systems (pipes, pumps, flanges, couplings, hoses, and valves) for failures or leaks weekly and during significant rainfall events. Inspect monthly for deterioration such as corrosion, cracks, or damage. Perform preventive maintenance as needed.

• This proposed SCM is impractical and unreasonable. Also, covered by SPCC/storage

tank regulations, and could institute new requirements that would not otherwise be



□ Conduct container integrity testing annually or as recommended and provide leak detection. Ensure that a qualified professional does integrity testing.

• This is unreasonable and not all containers require leak detection. Covered by

SPCC/storage tank regulations, and could institute new requirements that would not



□ Inspect the storage area for filled drip pans and other problems weekly or more frequently, as needed.

• Duplicative of section 2.1.2 of draft MSGP. Remove condition.

□ Inspect and maintain baghouses monthly to prevent the escape of dust from the system. Immediately remove any accumulated dust at the base of exterior bag houses.

• Reference should be made to facility Title V and other air permits for O&M

requirements for baghouses and other air pollution control equipment. This section

of proposed SCMs is redundant and not useful. Covered by air regulations, and



Remove condition. □ Train applicable employees in good

housekeeping, spill prevention and control, and materials management and disposal procedures within the first week of employment followed by refresher training annually and as needed.





condition.

Page Q-124 of 672



Pollutant Source 15: Vehicle and Equipment Fueling


□ Conduct fueling operations (including the transfer of fuel from tank trucks) on an impervious or contained pad, or under a roof/canopy where possible. Covering should extend beyond spill containment pad to prevent precipitation from entering.

• See above comments regarding reference to SPCC Plans. Covered by




□ When fueling in an uncovered area, conduct fueling operations on a concrete pad (asphalt is not chemically resistant to the fuels being handled).

• Unrelated to stormwater management. Covered by SPCC/storage tank regulations,



Not needed. Remove condition.

□ Use drip pans where leaks or spills of fuel can occur and where making and breaking hose connections.





□ Use fueling hoses with check valves to prevent hose drainage after filling.





□ Use spill and overflow protection devices. • Unrelated to stormwater management. Covered by SPCC/storage tank regulations,




□ Use dry cleanup methods for fuel area rather than hosing down the fuel area.





□ Keep spill cleanup material readily available. Clean up spills and leaks immediately.





Page Q-120 of 672



□ Minimize/eliminate run-on into fueling areas using diversion dikes, berms, curbing, surface grading, or other equivalent measures.

• Covered by SPCC/storage tank regulations, and could institute new requirements



□ Place absorbent material between contaminated runoff and discharge point.




□ Direct contaminated runoff through an oil/water separator before discharge.

• Overly prescriptive. Also, covered by SPCC/NPDES regulations, and could institute



Remove condition.

□ Clean and empty oil/water separators at the appropriate intervals as recommended by the manufacturer.

• Unrelated to stormwater management. Covered by SPCC/storage tank/NPDES




□ Inspect oil/water separators at least monthly. Follow procedures for sweeping up absorbent as soon as spilled substance have been absorbed.

• Unrelated to stormwater management. Covered by SPCC/storage tank/NPDES




□ Provide curbing or posts around fuel pumps to prevent collisions from vehicles and equipment.

• Restate berming objection. Covered by SPCC/storage tank regulations, and could



Remove condition.

□ As an alternative to other SCMs (e.g., diversion SCMs), collect stormwater runoff and provide treatment or recycling.

• Confusing wording and unclear how this is different from other SCMs. Remove

condition.

□ Prohibit “topping off” of fuel tanks. • Unrelated to stormwater management. Covered by SPCC/storage tank regulations,




□ Inspect storage tanks weekly to detect leaks or spills and monthly for deterioration such as corrosion, cracks, or damage. Perform preventive maintenance as needed.

• See above comments regarding weekly tank and piping inspections




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Page Q-122 of 672



□ Inspect the fueling area for leaks and spills daily.





□ For mobile fueling, ensure the fueling vehicle is equipped with a manual shutoff valve.





□ Train personnel who perform vehicle and equipment fueling within the first week of employment followed by refresher training annually and as needed.





condition.

Pollutant Source 16: Vehicle and Equipment Maintenance


Good Housekeeping

□ Eliminate floor drains that are connected to the stormwater or sanitary sewer. If necessary, install a sump that is pumped regularly. Collected wastes should be properly treated or disposed of by a licensed waste hauler.

• Unrelated to stormwater management. Covered by NPDES regulations, and could



Remove condition.

□ Do not pour liquid waste into floor drains, sinks, outdoor storm drain inlets, or other storm drains or sewer connections.

• Unrelated to stormwater management. Covered by waste/other regulations, and



Remove condition.

□ Inspect all equipment and vehicles for leaking fluids, such as oil and antifreeze, each day when in use and monthly otherwise.

• Requirement for daily inspections is unreasonable. Unrelated to stormwater

management. Covered by SPCC/storage tank regulations, and could institute new



□ Take leaking equipment and vehicles out of service and prevent leaks from spilling on the ground using pans until repaired.

• Unrelated to stormwater management. Impractical. Infeasible. Covered by




Page Q-123 of 672



□ Do all cleaning at a centralized station so the solvents stay in one area.





□ If parts are dipped in liquid, remove them slowly to avoid spills.





□ Use drip pans, drain boards, and drying racks to direct drips back into a fluid holding tank for reuse.





□ Drain all parts of fluids prior to final disposal. Empty oil and fuel filters before final disposal. Oil filters can be crushed and recycled.


SPCC/waste regulations, and could institute new requirements that would not



□ Promptly transfer used fluids to the proper container. Do not leave full drip pans or other open containers around the shop. Empty and clean drip pans and containers.


SPCC/waste regulations, and could institute new requirements that would not



□ Clean up leaks, drips, and other spills without using large amounts of water. Use adsorbents for dry cleanup whenever possible.





□ Prohibit the practice of hosing down an area where the practice would result in the discharge of pollutants to a stormwater system.


SPCC/NPDES/waste regulations, and could institute new requirements that would not



□ Clean without using liquid cleaners whenever possible.

• Unrelated to stormwater management. Impractical. Infeasible. No

environmental benefit. Remove condition.

Page Q-124 of 672



□ Collect liquid wastes in a properly labeled container.




Remove condition.

□ Dispose of wastes by a licensed waste hauler or other appropriate method.




Remove condition.

□ Maintain an organized inventory of materials. • Unrelated to stormwater management. No environmental benefit. Covered by

various existing regulations, and could institute new requirements that would not



□ Eliminate or reduce the number and amount of hazardous materials and waste by substituting nonhazardous or less hazardous materials.

• Unrelated to stormwater management. No environmental benefit. Restate previous

objection regarding facilities deciding what material is required for use. Remove

condition.

□ Label and track the recycling of waste material (e.g., used oil/oil filters, spent solvents, batteries).




Remove condition.

□ Store batteries and other significant materials inside or in a covered secondary container.




Remove condition.

□ Dispose of greasy rags, oil filters, air filters, batteries, spent coolant, and degreasers in compliance with Resource Conservation and Recovery Act (RCRA) regulations.




Remove condition.

□ Keep manifests of all waste materials hauled away from the facility.




Remove condition.

Vehicle and Equipment Washing

Page Q-125 of 672



□ Prohibit washing parts or equipment outside, if possible.

• Duplicative of Section 2.1.2 of draft MSGP. Remove condition.

□ When conducting washing operations outdoors, cover the cleaning operation and ensure that all wash water drains to the intended collection system.


□ Contain and recycle wash water. • Unrelated to stormwater management. Covered by NPDES regulations, and could



Remove condition.

□ Confine activities to designated areas outside drainage pathways and away from surface waters.


□ Use phosphate-free biodegradable detergents. • Unrelated to stormwater management. No environmental benefit. Remove

condition.

□ Collect stormwater runoff from the cleaning area and provide treatment or recycling.

• Covered by NPDES regulations, and could institute new requirements that would not


single line in a checklist. Not needed. Also, overly prescriptive. Facilities might not

be able to provided treatment/recycling and only be able to dispose. Remove

condition. □ Train applicable employees on proper washing procedures within first week of employment followed by refresher training annually and as needed.





condition.

Minimizing Exposure

□ Perform all cleaning operations indoors or under covering when possible. Conduct the cleaning operations in an area with a concrete floor and no floor drainage other than to sanitary sewers or treatment facilities.


Page Q-126 of 672



□ Check vehicles closely for leaks. Use drip pans to collect fluid when leaks occur.


□ Park vehicles and equipment indoors or under a roof whenever possible and maintain proper control of oil leaks/spills.

• It is impractical and unreasonable to park employee vehicles and most equipment

at iron and steel mills indoors. Many non-integrated steel mills have from 300 to 500

to more than 1,000 employees and integrated steel mills can have upwards of 2,000

employees. Most of the heavy mobile equipment is used outdoors and parked

outdoors when not in use. □ If operations are uncovered, perform them on a concrete pad that is impervious and contained.

• Many operations at iron and steel mills involve large equipment items and process

systems that are located outdoors. It is not feasible to provide concrete pads. Use of

concrete pads could result in moving materials collected in storm water away from

the process area. Duplicative of Section 2.1.2 of draft MSGP. Remove condition.

Management of Runoff

□ Use berms, curbs, vegetated swales, or other diversion measures to ensure that stormwater runoff from other parts of the facility does not flow over the maintenance area.


□ Collect the stormwater runoff from the cleaning area and provide treatment or recycling.

• Covered by NPDES regulations, and could institute new requirements that would not


single line in a checklist. Not needed. Also, overly prescriptive. Facilities might not

be able to provided treatment/recycling and only be able to dispose. Remove

condition. □ Discharge vehicle wash or rinse water to the sanitary sewer (if allowed by sewer authority), wastewater treatment, or a land application site; or recycle on site. Do not discharge wash water to a storm drain or to surface water.

• Unrelated to stormwater management. Covered by NPDES regulations, and could


intricacies of applicable regulations in a single line in a checklist. Not needed. Also,

overly prescriptive. Facilities might not be able to provided treatment/recycling and

only be able to dispose. Remove condition.

Inspections and Training

□ Inspect the maintenance area weekly to ensure SCMs are implemented.

• It is not practical to conduct weekly inspections of areas within iron and steel mills

that are subject to SCMs. Facility storm water pollution prevention plans (SWPPPs) set

out inspection schedules and requirements to document inspections. This proposed

SCM is duplicative and should be removed from the Sector F SSCMs. Duplicative of

Section 2.1.2 of draft MSGP. Remove condition.

•

Page Q-127 of 672

□ Inspect wash areas daily for evidence of discharges to the stormwater drainage system and correct as needed.

• It is not practical to conduct weekly inspections of areas within iron and steel mills

that are subject to SCMs. Facility storm water pollution prevention plans (SWPPPs) set

out inspection schedules and requirements to document inspections. This proposed

SCM is duplicative and should be removed from the Sector F SSCMs. Remove

condition.

Page Q-128 of 672



□ Train maintenance employees on waste control and disposal procedures within the first week of employment followed by refresher training annually and as needed.





condition. Pollutant Source 17: Vehicle and Equipment Storage and Parking


□ If possible, park/store vehicles and equipment indoors or under a roof.

• See prior comments about parking vehicles and mobile equipment indoors.

□ Inspect for leaks all incoming vehicles, parts, and equipment that will be stored temporarily outside.

• This proposed SCM is impractical and unreasonable and should be removed from

the Sector F SCMs. See above comments about the number of employees. Iron and

steel mills also utilize many contractors for maintenance and other functions and

trucking firms to ship product.

□ Inspect all equipment and vehicles monthly for leaking fluids such as oil, antifreeze, etc. Take leaking equipment and vehicles out of service and prevent leaks from spilling on the ground until repaired.


□ When parking/storing vehicles and equipment outside, install berms and dikes in storage areas.


□ Use absorbents and dry cleanup. • Duplicative of Section 2.1.2 of draft MSGP. Remove condition.

□ Clean oil and grease from paved surfaces daily.

• Daily cleaning requirement is unduly burdensome. It should be “as necessary: or

“regularly” to provide the permittee with flexibility in response. Duplicative of Section

2.1.2 of draft MSGP. Remove condition.

Page Q-129 of 672



□ For vehicles and equipment waiting for maintenance, place drip pans underneath.


□ Provide dust control where necessary. • Duplicative of Section 2.1.2 of draft MSGP. Remove condition.

□ Inspect the storage area for full drip pans and other problems weekly or more frequently, as needed.


□ Train applicable employees on procedures for storage and inspection items within the first week of employment followed by refresher training annually and as needed.





condition.

Coke(~21 acres)

MillScale

BOF Slag

Blast FurnaceSlag

Coke,Iron Ore& Flux

(~9 acres)

Coke(~10 acres)

Iron Ore(~8 acres)

Coke(~3 acres)

ScrapMetal

(~13 acres)

Coal(~17 acres)

(~170 acres)

Coil Storage(~28 acres)

Exhibit 3 - Mill A

Approximate Facility Property Line

Approximate Total Facility Area: 3,000 acres

Coal(~24 acres)

Coke(~18 acres)

Coke(~13 acres)

Coke,Iron Ore& Flux

(~31 acres)

Scrap Metal, Flux, Mill Scale

& Slag(~75 acres)

Slag(~15 acres)

Slabs(~3 acres)

Scrap Metal(~26 acres)

BOF Slurry, Hydrocyclone Sludge

(~27 acres)

Slabs(~13 acres)Slabs

(~3 acres)

Slag(~3 acres)

Iron Ore(~10 acres)

Slabs(~31 acres)

Mill Scale(~1 acres)

Flux,Iron Ore& Slag

(~7 acres)

Coils(~1 acres)

Scrap Metal(~2 acres)

Lump Ore(~1 acre)

Exhibit 3 - Mill B

Approximate Facility Property Line

Approximate Total Facility Area: 2,100 acres

Exhibit 3 - Mill C

Approximate Facility Property Line Not Shown

Approximate Total Property Area: >4,500 acresApproximate Total Facility Area: 800 acres

Raw Materials: Scrap Metal, DRI, HBI, Pig Iron

Slag Processing(~30 acres)

Raw Materials(~3 acres)




BeamStorage

(~2 acres)

BeamStorage

(~5 acres)Beam Storage

(~16 acres)

CoilStorage

(~4 acres)

CoilStorage

(~4 acres)

CoilStorage

(~3 acres)

Beam Storage(~15 acres)

Exhibit 3 - Mill D

Approximate Facility Property Line Not Shown

Approximate Total Property Area: 2,100 acresApproximate Total Facility Area: 690 acres

Slag Processing(~45 acres)

Mill Scale(<1 acre)

Scrap Metal and Pig Iron(~51 acres)



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