Document gak347k0Lb4kNmLdyGp9MvaxQ

REGION 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Time: Media: Statute(s)/Program(s): Type of inspection: Access: 04/20/2022 Announced: Yes Entry: 08:46 AM (ET) Exit: 04:19 PM (ET) Water Clean Water Act, NPDES, Industrial CEI - Compliance Evaluation Inspection with Sampling Granted Permittee Name: Facility or Site Name: Facility/Site Physical Address: (City, state, zip code) County/Parish: Facility GPS Coordinates: Mailing address: (If different) (City, state, zip code) REPUBLIC STEEL LORAIN PLANT REPUBLIC STEEL LORAIN PLANT 1807 EAST 28TH STREET LORAIN, OH 44055 41.448518, -82.133082 Facility/Site Identifier: Permit Number: SIC or NAICS: 110000385645 OH0001562 3312, 3317 Persons Participating in Inspection: Title Name Lead Inspector Dean Maraldo Inspector Mark Conti Inspector Matthew Schulte Environmental Director Compliance Officer Greg Bosiljcic Ed Pollock Phone 3123532098 (440) 250-1706 (312) 886-2405 (330) 507-0179 (412) 719-3507 Email Present at Present at Opening Conf. Closing Conf. Maraldo.Dean@e Yes Yes pa.gov conti.mark@epa. Yes Yes gov Schulte.Matthew Yes Yes @epa.gov GBosiljcic@Repu Yes Yes blicSteel.com Yes Yes Maintenance Manager Zoran Zoric No No 1 of 28 REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 Director of Thiago Ribeiro No Operations Lead Inspector: Dean Maraldo [Signature] DINO MARALDO Digitally signed by DINO MARALDO Date: 2022.04.26 07:18:46 -05'00' REGION 5 maraldo.dean@epa.gov Supervisor Review: Ryan Bahr Bahr, Ryan [Signature] Digitally signed by Bahr, Ryan Date: 2022.04.26 07:52:12 -05'00' REGION 5 bahr.ryan@epa.gov No (312) 353-2098 SECTION I - INTRODUCTION Site Entry and Inspection Objectives CEI and Order Monitoring Inspection. I, Region 5 Lead Inspector, Dean Maraldo, arrived at the Republic Steel Lorain Plant (the "Site" or "Facility"), located at 1807 East 28th Street, at 08:46 AM (ET) on 04/20/2022 for an announced inspection. Region 5 Inspectors Mark Conti and Matthew Schulte joined me for the inspection. I presented my credentials to Greg Bosiljcic and informed him that this was a Region 5 inspection to determine compliance with the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) permit program. I conducted the inspection under the authority of the Federal CWA Section 308. The table above identifies the attendees that participated in the inspection. This report is based on information supplied by Republic Steel Lorain Plant representatives, observations made by the Region 5 inspectors, and records and reports maintained by the permittee and the Region 5 inspectors, including: direct observations made by the Region 5 inspectors, photographs taken by Region 5 inspectors, physical evidence collected by the Region 5 inspectors, measurements taken by Region 5 inspectors, verbal or written statements made by and information supplied by Republic Steel Lorain Plant representatives (the permittee) during or subsequent to the on-site inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the Region 5 inspectors by Republic Steel Lorain Plant representatives during the on-site inspection. In addition, information gathered prior to or subsequent to the inspection from a review of USEPA, State, and public records may be included in this report. After introductions, I went over the proposed inspection plan, including: After opening conference, conduct records review including status of Republic Steel's efforts to comply with the June 9, 2021 Administrative Order on Consent ("AOC") with USEPA, reports required under the NPDES permit ("Permit"), and recent effluent limit violations. Conduct facility tour focusing on outfalls 002, 003, 005. Perform a closing conference to briefly highlight and discuss observations made during the inspection. Greg Bosiljcic said the plant was idled since early February, due to production issues in other plants. The plant may not return to normal operation until June. He added that when they are in operation only the 910" bar mill is used in production (status of other production units is provided below). Approximately 60 2 of 17 REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 people are currently laid off. All steel is produced at the Canton plant right now. Greg Bosiljcic said they currently use the 605 discharge wastewater treatment plant ("605 WWTP") for cooling tower blowdown. The 605 WWTP includes just sand filter treatment, with effluent going to outfall 005. He added that the 605 WWTP is only used as needed during the current plant shutdown. I asked about the status of the administratively continued NPDES Permit. Greg Bosiljcic said the Permit renewal is still in process. Facility/Site Description I asked the Republic Steel representatives to verify the Facility Description per the Permit Fact Sheet (2019). Greg Bosiljcic verified the status of the following operations (his response in italics): 2 Blast Furnaces for production of molten iron: No longer used and probably never again; 2 Basic Oxygen Furnaces (BOFs) for production of molten steel: No longer in operation; 2 Continuous Casters (bloom caster & billet caster): No longer in operation; 1 Vacuum Degasser for steel: No longer in operation; 1 Electric Arc Furnace (EAF) to process steel scrap into molten steel: No longer in operation; 2 Ladle Metallurgy Facilities (LMF): No longer in operation; 1 Primary Rolling Mill: No longer in operation; 1 9-10" Bar Mill: Yes, will operate when the plant is back on line. Greg Bosiljcic also confirmed the Standard Industrial Classification (SIC) category for the plant, including 3312, "Steel Works, Blast Furnace, Rolling" and 3317, "Steel Pipe and Tube". Facility/Site Information Responses provided by Greg Bosiljcic. Responsible official verified John Wilkinson What is the principal product generated? Coils when in operation What are the raw materials used? None, use product processed at other plants Size of Facility About 500 acres Outfalls (and do the numbers and locations match the permit?) Do you use in-house or contract out for laboratory analyses? Or both? Shifts/Hours of Operations: Operation schedule (days of operation, # shifts/day, # operators/shift, coverage overnight, weekends & emergencies), and is staffing sufficient for proper operation? Number of employees 002, 003, 005 are main outfalls. Outfall 004 historically dry. Outfall 605 is the only internal outfall currently managed All sampling and lab work handled by Test America. They analyze for pH and total residual chlorine ("TRC") in the field 2 shift of 8 hours. 5 day per week Maybe 20 currently. Maintenance only on 9" bar mill. Regular 3 of 17 REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 Status of expired permit? Any CBI concerns? Photo CBI? How are things going at the facility? Any wastewater or stormwater issues? Identify all active wastewater treatment plants Operators for 605 WWTP operations about 80 workers Still pending No. If they see something in the field, they will let us know 605 WWTP works well when in operation. 605 WWTP only Staffed by maintenance department Inspection Units Unit/Area Flow Monitoring Operations and Maintenance Description Interview questions Interview questions Self Monitoring Records Review Field Inspection Internal Outfall 605 Interview questions Interview questions Field Inspection Notes and Observations. Began field inspection at 12:35 p.m. on 4/20/2022 , led by Greg Bosiljcic and Ed Pollock. Area includes the manhole to internal outfall 605 and the 605 WWTP Scale Pit Bar mill scale pit (inside building). Outfall 005 Outfall flowing at time of inspection. Sample collected (pH, TRC, Temp) Outfall 002 Outfall flowing at time of inspection. Sample collected (pH, TRC, Temp) Outfall 003 Outfall not flowing at time of inspection. Unidentified Outfall Just Outfall flowing at time of inspection. Sample collected (pH, TRC, Temp) East of Outfall 003 4 of 17 REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 SECTION II - INTERVIEW Interview observations and record reviews may not be in sequential order. Unit: Flow Monitoring Contains CBI: No Observation #: OB-01 Date: 04/20/2022 Mark Conti asked about flow monitoring. Greg Bosiljcic said that for effluent flow monitoring they are currently estimating based on the bucket test method at outfalls 005 and 003. For outfall 002 they report no flows because they have no flow meter and can't estimate flow. They are hoping to correct this within two or three weeks. A consultant is looking into laser sensors for outfalls 002 and 005. They will continue with the bucket method at Outfall 003 given low flows. Greg Bosiljcic acknowledged it is difficult to bucket test outfalls at 100 gallons per minute ("gpm"). Republic Steel relies on system control of 100 gpm as the estimated flow for outfall 605. This estimate was based on an initial vendor test. However, flow at outfall 605 has not been measured since. The Permit Part 1.A. requires 24-hour total flow monitoring for outfalls 002, 003, 005, and 605. Unit: Operations and Maintenance Contains CBI: No Observation #: OB-02 Date: 04/20/2022 I asked several operation and maintenance-related questions (below) and Greg Bosiljcic provided the following responses (his responses in italics): On a regular basis, do operators monitor the key operating parameters at the 605 WWTP? Operations and maintenance staff check sand filter pressures daily, and change sand out about once a month. Any bypasses? Was Ohio EPA notified of any bypassing? Since restarting last year, the plant experienced one treatment bypass. An exposed line from a closed loop system broke and wastewater entered an old pipe leading to the Black River. Greg Bosiljcic estimated less than a gallon or two of discharge and thought the bypass occurred in September or October. Greg Bosiljcic said the bypass was reported to Ohio EPA. I asked for a copy. Does the wastewater treatment facility have an alarm system for all essential equipment? No alarms. [Greg Bosiljcic later clarified that the 605 WWTP sand filter unit has a sound alarm]. Are routine and preventive maintenance scheduled performed and recorded? Operations andmaintenance staff keep daily maintenance records, like sand change outs from sand filter. Is a logbook kept which documents all plant activities on a daily basis? No forms, but operations and maintenance staff use daily maintenance logs, as per Republic Steel SOP. Does the facility have standby power for all treatment units? They have diesel generators. But if power is lost protocol is to shut down all wastewater operations. 5 of 17 REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 Unit: Self Monitoring Observation #: OB-03 Contains CBI: No Date: 04/20/2022 I asked several self monitoring-related questions (below) and Greg Bosiljcic provided the following responses (his responses in italics): Are composite samples flow proportioned? Composite samples are time proportioned as flow cannot be determined. [Republic Steel does not have operable flow metering at any outfalls where composite samples are required, and cannot collect flow proportioned composite samples as required by the Permit Part II.G]. Are composite samples cooled to <4C to properly preserve them during the compositing period?(40 CFR 136)? Composite samplers not refrigerated. [The Permit requires composite sampling for parameters with cooling preservation criteria < 6C, including total suspended solids, and nitrogen, Ammonia (NH3)]. I asked where outfall samples are collected: Greg Bosiljcic said they collect samples directly from outfalls 002, 003 and 005, using a pole for grabs and a sampling tube for the composite samplers. Internal outfall 605 is a manhole with direct access for sampling. According to the Permit Part I.A., 24-hour composite samples are required for total suspended solids, zinc, lead, and copper. Greg Bosiljcic said that pursuant to a 2019 Ohio EPA order, they now take grab samples twice per week at outfall 605 for all parameters listed in the Permit, include parameters with 24-hour composite sampling requirements. Ohio EPA's September 4, 2019 Order (page 4) provides "Limits and Monitoring Requirements for Temporary Discharge", including a requirement to collect grab samples, at outfall 605. However, the Order only allows the temporary discharge from outfall 605 if the water has been treated pursuant to the alternative treatment system described in Attachment A of the Order, which included two-stage pH adjustment, clarification, and use of chemical additives. During the inspection Greg Bosiljcic said that treatment at the 605 WWTP was limited to sand filters and a bag filter. He did not mention two-stage pH adjustment, clarification, or the use of chemical additives. Ohio EPA's September 4, 2019 Director's Final Findings & Orders included in Appendix 3 - Reference Documents. Document(s) 1. OhioEPA_DFFO_20190904.pdf Record: Record Review - DMR Reports AOC: Yes Ref #: RR-01 Reviewed By: Dean Maraldo Reviewed Date: 04/20/2022 I reviewed recent effluent limit exceedances for outfalls 002 and 005 during the Enforcement Order Milestones record review below (RR-02). Greg Bosiljcic provided field sheets for August 2021 through April 13, 2022: a pH effluent limit exceedance was recorded on March 17, 2022 at outfall 002 (9.48). No other issues were identified during review of field sheets. 6 of 17 REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 Greg Bosiljcic provided copies of DMRs for January and February 2022. I reviewed DMRs and noted the following effluent limit exceedances: Mercury effluent limit exceedance on February 2, 2022 at outfall 002 (4.8 ng/l); Mercury effluent limit exceedances on January 19, 2022 at outfall 002 (8.6) ng/l and outfall 005 (3.6 ng/l). Other Permit effluent limit exceedances for the period January 1, 2021 to January 31, 2022 are summarized in the document "ECHO_ELEs_20220413.pdf" included in Appendix 3 - Reference Documents. Document(s) 1. ECHO_ELEs_20220413.pdf Record: Record Review - Enforcement Order Milestones Ref #: RR-02 Reviewed By: Dean Maraldo AOC: No Reviewed Date: 04/20/2022 Review of June 9, 2021 AOC status: Outfall 002: Total Residual Chlorine violations: Greg Bosiljcic said that Republic Steel TRC violations are the result of "anomalous false positives". In late 2021 (6 week trial) a consultant, Microbac, conducted a titration method side-by-side study with Test America. Republic Steel considering using titration method moving forward. Currently using colorimetric method. I requested a copy of the TRC study. Greg Bosiljcic added that they only use river water now. No chlorinated water used for process anywhere. pH: effluent limit exceedances continuing through January 2022 at outfall 002. Greg Bosiljcic sees improvement with additional flow, but not enough. Republic Steel looking into other ways to get additional water to the outfall. Hope to know within 30 days if they can find additional water flow. If that doesn't work out they will look into pH adjustment. Hg: in compliance since 8/31/2019. Outfall 005: TRC: last violation in 9/2021, but this was during Microbac study showing it was false positive, according to Greg Bosiljcic. They submitted results to Ohio EPA, but did not amend DMR. pH: in compliance since 4/30/2021. Hg: in compliance since 5/31/2019. Record: Record Review - Process Description/Flow Diagram AOC: No Ref #: RR-03 Reviewed By: Dean Maraldo Reviewed Date: 04/20/2022 We reviewed treatment process diagrams from a recent Permit application. Greg Bosiljcic confirmed that Figure 3-2 is accurate and only the bar mill wastewater treatment system (605 WWTP) is in operation, with flow through outfall 605 then to outfall 005 to the Black River. He added that rolling mill blow down water 7 of 17 REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 goes to outfall 005, along with basement water (based on basement levels) which goes through an oil water seperator. Also, the bloom caster goes through a sand filter occasionally, based on basement/scale pit levels, via outfall 612 to outfall 002. Outfall 003 currently only receives occasional stormwater and any groundwater infiltrating. Figure 3-2 is included in Appendix 3 - Reference Documents. Document(s) 1. Wastewater Flow Diagram 3-2_PermitApp_201712.pdf Record: Record Review - Mercury Pollutant Minimization Program Ref #: RR-04 Reviewed By: Dean Maraldo AOC: No Reviewed Date: 04/20/2022 I asked for an update on the Mercury Pollutant Minimization Program. Greg Bosiljcic said Amendola Engineering is currently preparing a revised mercury variance for facility. Greg Bosiljcic said water from the legacy blast furnace operation is contributing to mercury effluent limit exceedances at outfall 003. I asked for a copy of the last Mercury Pollutant Minimization Program annual report (due March 1, 2022; Permit Part II.N.4)). Record: Record Review - Stormwater SWPPP Ref #: RR-05 Reviewed By: Dean Maraldo AOC: No Reviewed Date: 04/20/2022 SWPPP I asked for the dates of the last: Routine Facility Inspections Quarterly Visual Assessments Quarterly Comprehensive Site Inspection Annual Greg Bosiljcic said that Test America does the routine quarterly and visual sampling, and Republic Steel does the annual report. He added that Test America is here three days per week and can handle wet weather and snow melt observations. I asked Greg Bosiljcic to provide copies of the most recent reports for the above SWPPP inspections and assessments, and to check the SWPPP to make sure all consultants, including Test America, are included on the SWPPP Pollution Prevention Team list (Permit Part IV.D.1.). 8 of 17 REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 SECTION III - PHYSICAL INSPECTION Unit: Field Inspection/Internal Outfall 605 Contains CBI: No Observation #: OB-04 Date: 04/20/2022 I observed the manhole for internal outfall 605 and the 605 WWTP sand filter unit (see Photo Log). Greg Bosiljcic mentioned that the sand filter unit does have a sound alarm. Photo(s) 1. REPL0001.JPG 2. REPL0002.JPG Unit: Field Inspection/Scale Pit Observation #: OB-05 Contains CBI: No Date: 04/20/2022 We walked into a building in the bar mill area and observed the scale pit (see Photo Log). We were joined by Zoran Zoric (Maintenance Manager) and Thiago Ribeiro (Director of Operations). Greg Bosiljcic said that current flows to the scale pit consist only of basement water. Zoran Zoric added that flows also enter the scale pit from cooling tower recirculation water (north side discharge) and mill cooling water (east side) when in operation. See the site map in Appendix 4 for the location of the scale pit. Photo(s) 1. REPL0003.JPG 2. REPL0004.JPG Unit: Field Inspection/Internal Outfall 605 Observation #: OB-06 Contains CBI: No Date: 04/20/2022 We returned to the internal outfall 605 area with Greg Bosiljcic, Ed Pollock, Zoran Zoric and Thiago Ribeiro. Zoran Zoric corrected the earlier description of the 605 WWTP system, which includes a bag filter (<100 micron filter) in addition to the sand filter. He said the filter has an average influent flow of 300 gpm. Thiago Ribeiro further described the current 605 WWTP process, adding that scale pit water flows to the bag filter then the sand filter. The effluent from the sand filter is split between outfall 605 (100 gpm) and the cooling tower equalization ("EQ") tank (200 gpm) to be used for mill cooling water. A photo of the EQ tank is included in the Photo Log. See the site map in Appendix 4 for the location of internal outfall 605. Photo(s) 1. REPL0005.JPG 9 of 17 REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 Unit: Field Inspection/Outfall 005 Observation #: OB-07 Contains CBI: No Date: 04/20/2022 Outfall 005: Sample collected by Dean Maraldo at 1:38 pm ET with sample pole through a hatch in the top of the outfall. Sample from outfall 005 was cloudy with visible settleable solids (see Photo Log). Outfall 005 sample results: Total residual chlorine ("TRC"): 0.64 mg/l pH: 8.71 S.U. Temp: 10.0 C Note, the Extech Model Oyster 10 Probe was used to measure water samples for pH and Temperature in the field. The calibration record is included in Appendix 3 - Reference Log. The Hach Pocket Colorimeter 2 was used to measure water samples for TRC in the field. At 7:45 a.m. on April 20, 2022, I tested the Hach Pocket Colorimeter 2 against TRC standards (expiration date July 1, 2022). All tests were within Hach's recommended margin of error. See the site map in Appendix 4 for the location of outfall 005. Document(s) 1. Extech Oyster 10 pH meter_calibration and QC_ 20220420.pdf Photo(s) 1. REPL0006.JPG 2. REPL0007.JPG Unit: Field Inspection/Outfall 002 Contains CBI: No Observation #: OB-08 Date: 04/20/2022 Outfall 002. Sample collected directly from outfall by Matthew Schulte at 2:05 pm ET. See the site map in Appendix 4 for the location of outfall 002. I observed debris in bottom of outfall 002 (see Photo Log). Outfall 002 sample results: pH: 9.16 S.U. TRC: 0.05 mg/l Temp: 10.0 C Photo(s) 1. REPL0009.JPG 2. REPL0008.JPG Unit: Field Inspection/Outfall 003 Observation #: OB-09 Contains CBI: No Date: 04/20/2022 Outfall 003: no flow observed. Photo of access holes in the top of outfall 003 included in the Photo Log. See the site map in Appendix 4 for the location of outfall 003. Photo(s) 1. REPL0010.JPG 10 of 17 REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 Unit: Field Inspection/Unidentified Outfall Contains CBI: No Observation #: OB-10 Date: 04/20/2022 Unidentified outfall just east of Outfall 003. See the site map in Appendix 4 for the location of the unidentified outfall. The outfall was flowing at the time of inspection (approximately 8.5 gpm*) and I observed a continuous discharge from the outfall flowing down a slope and into the Black River (see Photo Log). The discharge results in light colored deposits and staining right up to the Black River (see Photo Log). Greg Bosiljcic said the observed flow was the heaviest he's seen and sometimes the outfall does not discharge. He added that the discharge may be associated with the Blast Furnace Basement. This outfall is not identified in the facility's NPDES Permit. I collected a sample directly from the outfall at 2:40 pm ET. Unidentified outfall sample results: pH: 12.20 TRC: 0.13 mg/l Temperature: 8.1 C * I collected the flow from the outfall in a one quart glass jar to estimate the outfall discharge rate. I repeated the collection three times and recorded the time it took to fill the jar each time (1.74, 1.66, and 1.87 seconds). Averaging the three fill times results in an estimated outfall discharge rate of 8.5 gpm. We drove up to the bluff above the unidentified outfall and I took a photo of the area receiving the discharge from the unidentified outfall and the Black River (see Photo Log). We concluded the field inspection at 3:30 pm ET and returned to the administration building to conduct the closing conference. Photo(s) 1. REPL0012.JPG 2. REPL0011.JPG 3. REPL0013.JPG 4. REPL0016.JPG 11 of 17 REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS Measurement Data Summary Table Measurement Reference# Date Location 04/20/2022 ME1:47 PM (ET) 003 04/20/2022 ME- 1:47 PM (ET) 002 04/20/2022 ME1:47 PM (ET) 001 04/20/2022 ME- Outfall 005 2:11 PM (ET) 006 04/20/2022 ME2:11 PM (ET) 005 Outfall 002 04/2/2022 ME-004 2:11 PM (ET) 04/20/2022 ME-009 2:52 PM (ET) 04/20/2022 2:28 PM (ET) 04/20/2022 ME- 008 ME- 007 Unidentified outfall just east of outfall 003 2:48 PM (ET) * All measurement samples analyzed by Mark Conti Measurement Sample Collector* Dean Maraldo Matthew Schulte Dean Maraldo Equipment Extech Hach Pocket Colorimeter 2 Extech Hach Pocket Colorimeter 2 Extech Extech Hach Pocket Colorimeter 2 Extech Extech Parameter /Result (unit) Temperature 10.0 C Total Residual Chlorine 0.64 mg/L pH 8.71 S.U. Total Residual Chlorine 0.05 mg/L Temperature 10.0 C pH 9.16 S.U. Total Residual Chlorine 0.13 mg/L Temperature 8.1 C pH 12.20 S.U. Collection Method GRAB GRAB GRAB GRAB GRAB GRAB GRAB GRAB GRAB 12 of 17 REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 SECTION V - AREAS OF CONCERN Areas of Concern may not be in sequential order. The presentation of areas of concern does not constitute a formal compliance determination or violation. Unit: Records Review RR-01 Area: DMR Reports Greg Bosiljcic provided copies of DMRs for January and February 2022. I Citations: Permit Part I.A. reviewed DMRs and noted the following effluent limit exceedances: Mercury effluent limit exceedance on February 2, 2022 at outfall 002 (4.8 ng/l); Mercury effluent limit exceedances on January 19, 2022 at outfall 002 (8.6) ng/l and outfall 005 (3.6 ng/l). Other Permit effluent limit exceedances for the period January 1, 2021 to January 31, 2022 are included in the document "ECHO_ELEs_20220413.pdf" included in Appendix 3 - Reference Documents. Greg Bosiljcic provided field sheets for August 2021 through April 13, 2022: a pH effluent limit exceedance was recorded on March 17, 2022 at outfall 002 (9.48). Citations: Permit Part I.A. Unit: Field Inspection OB-07 Sample from outfall 005 was cloudy with visible settleable solids (see Photo Log). Outfall 005 sample results: TRC: 0.64 mg/l Unit: Field Inspection OB-08 Observed debris in bottom of outfall 002 (see Photo Log). Outfall 002 sample results: pH: 9.16 S.U. 13 of 17 Area: Outfall 005 Citations: Permit Effluent Limit Exceedance - Permit Part I.A.; Cloudy discharge with settleable solids - Permit Part III.2 Area: Outfall 002 Citations: Permit Effluent Limit Exceedance - Permit Part I.A.; Debris in outfall - Permit Part III.3.A. (Facility Operation And Quality Control) REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 Unit: Field Inspection OB-10 Area: Unidentified Outfall Just East ofOutfall 003 Unidentified outfall just east of Outfall 003. The outfall was flowing at the time of inspection (approximately 8.5 gpm) and I observed a continuous discharge from the outfall flowing down a slope and into the Black River (see Photo Log). Citations: Section 301 (a) of the Clean Water Act, 33 U.S.C. 1311(a) The discharge results in light colored deposits and staining right up to the Black River (see Photo Log). Greg Bosiljcic said the observed flow was the heaviest he's seen and sometimes the outfall does not discharge. He added that the discharge may be associated with the Blast Furnace Basement. This outfall is not identified in the facility's NPDES Permit. Unidentified Outfall sample results: pH: 12.20 S.U. TRC: 0.13 mg/l Unit: Self Monitoring OB-03 Composite samplers are not refrigerated, according to Greg Bosiljcic. The Citations: Composite sampling Permit requires composite sampling for parameters with cooling requirements - Permit Part I.A.; preservation criteria < 6C, including total suspended solids, and nitrogen, preservation of samples - 40 CFR Ammonia (NH3). 136. Composite samples are time proportioned, not flow proportioned as required by the Permit Part II.G., since Republic Steel does not have operable flow metering at any outfalls where composite samples are required by the Permit. Citations: Permit Part II.G. Internal outfall 605 is a manhole with direct access for sampling. According to the Permit Part I.A., 24-hour composite samples are required for total suspended solids, zinc, lead, and copper. Greg Bosiljcic said that pursuant to a 2019 Ohio EPA order, they now take grab samples twice per week at outfall 605 for all parameters listed in the Permit, include parameters with 24-hour composite sampling requirements. Ohio EPA's September 4, 2019 Order (page 4) provides "Limits and Monitoring Requirements for Temporary Discharge", including a requirement to collect grab samples, at outfall 605. However, the Order Citations: Permit Part I.A. 14 of 17 REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 only allows the temporary discharge from outfall 605 if the water has been treated pursuant to the alternative treatment system described in Attachment A of the Order, which included two-stage pH adjustment, clarification, and use of chemical additives. During the inspection, Greg Bosiljcic said that treatment at the 605 WWTP was limited to sand filters and a bag filter. He did not mention two-stage pH adjustment, clarification, or the use of chemical additives. Ohio EPA's September 4, 2019 Director's Final Findings & Orders included in Appendix 3 - Reference Documents. Unit: Flow Monitoring OB-01 Mark Conti asked about flow monitoring. Greg Bosiljcic said that for effluent flow monitoring they are currently estimating flow based on the bucket test method at outfalls 005 and 003. For outfall 002, they report no flows because they have no flow meter and can't estimate flow. They are hoping to correct this within two or three weeks. A consultant is looking into laser sensors for outfalls 002 and 005. They will continue with the bucket method at Outfall 003 given low flows. Greg Bosiljcic acknowledged it is difficult to bucket test outfalls at high flow rates of 100 gpm. Citations: The Permit Part 1.A Republic Steel relies on system control of 100 gpm as the estimated flow for outfall 605. This estimate was based on an initial vendor test. However, flow at outfall 605 has not been measured since. The Permit Part 1.A. requires 24-hour total flow monitoring for outfalls 002, 003, 005, and 605. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference I held a closing conference with Facility personnel at 04:19 PM (ET) on 04/20/2022 for the inspection. During the closing conference, I discussed the observations and Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. We went over AOCs and followup items, and reviewed documents received (DMRs for Jan-Feb 2022, and field sheets from August 2021 to March 2022). Greg Bosiljcic said he would get all the requested followup documents to me by the end of the following week. I asked if there were any questions. There were no questions from Ed Pollock or Gregory Bosiljcic. 15 of 17 REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 Follow Up The following items were requested by the inspector at the time of the inspection. Unit: Records Review RR-02 Copy of the TRC study. RR-04 Copy of the last Mercury Pollutant Minimization Program annual report (due March 1, 2022; Permit Part II.N.4)). RR-05 Copies of the most recent reports for the above SWPPP inspections and assessments. I asked Greg Bosiljcic to check the SWPPP to make sure all consultants, including Test America, are included on the SWPPP Pollution Prevention Team list (Permit Part IV.D.1.). Unit: Operations and Maintenance OB-02 Since restarting last year, the plant experienced one treatment bypass. An exposed line from a closed loop system broke and wastewater entered an old pipe leading to the Black River. Greg Bosiljcic estimated less than a gallon or two of discharge and thought the bypass occurred in September or October of 2021. Greg Bosiljcic said the bypass was reported to Ohio EPA. I asked for a copy. 16 of 17 REPUBLIC STEEL LORAIN PLANT Inspection Date: 04/20/2022 Communication Log No additional information received by REGION 5 after exiting the Facility on 04/20/2022. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 3. Reference Documents 4. Site Map 17 of 17 REPUBLIC STEEL LORAIN PLANT Inspection Date(s): APPENDIX 1: PHOTOLOG (Camera Model: RICOH WG-4) Manhole for internal outfall 605 REPL0001.JPG 04/20/2022 12:46 PM (ET) Dean Maraldo Field Inspection/Internal Outfall 605 No CBI No PII 605 WWTP Sand Filter REPL0002.JPG 04/20/2022 12:50 PM (ET) Dean Maraldo Field Inspection/Internal Outfall 605 No CBI No PII Scale Pit REPL0003.JPG 04/20/2022 01:05 PM (ET) Dean Maraldo Field Inspection/Scale Pit No CBI No PII view from the south side of scale pit. Appendix 1-1 04/20/2022 - 04/20/2022 REPUBLIC STEEL LORAIN PLANT Inspection Date(s): Scale Pit REPL0004.JPG 04/20/2022 01:09 PM (ET) Dean Maraldo Field Inspection/Scale Pit No CBI No PII view of flows into north and east side of scale pit. EQ Tank REPL0005.JPG 04/20/2022 01:24 PM (ET) Dean Maraldo Field Inspection/Internal Outfall 605 No CBI No PII 605 WWTP EQ Tank Outfall 005 Sample Location REPL0006.JPG 04/20/2022 01:37 PM (ET) Dean Maraldo Field Inspection/Outfall 005 No CBI No PII Hatch in outfall 005 used to collect sample. Appendix 1-2 04/20/2022 - 04/20/2022 REPUBLIC STEEL LORAIN PLANT Inspection Date(s): Outfall 005 Sample Bottle REPL0007.JPG 04/20/2022 01:39 PM (ET) Dean Maraldo Field Inspection/Outfall 005 No CBI No PII Sample used to measure pH, total residual chlorine, and temperature at outfall 005. Note cloudy water in sample bottle Outfall 002 REPL0008.JPG 04/20/2022 01:59 PM (ET) Dean Maraldo Field Inspection/Outfall 002 No CBI No PII Note debris in outfall and support structure for inoperable flow meter. Sample Bottle Outfall 002 REPL0009.JPG 04/20/2022 02:06 PM (ET) Dean Maraldo Field Inspection/Outfall 002 No CBI No PII Photo of bottle filled with sample from outfall002 Appendix 1-3 04/20/2022 - 04/20/2022 REPUBLIC STEEL LORAIN PLANT Inspection Date(s): Access holes to top of outfall 003 REPL0010.JPG 04/20/2022 02:36 PM (ET) Dean Maraldo Field Inspection/Outfall 003 No CBI No PII No flow was observed from outfall 003 at time of inspection. Filled Sample Bottle - Unidentified Outfall REPL0011.JPG 04/20/2022 02:42 PM (ET) Dean Maraldo Field Inspection/Unidentified Outfall Just East of Outfall 003 No CBI No PII Photo of sample collected from Unidentified Outfall (in background of photo) just east of outfall 003. Unidentified Outfall Discharge Area REPL0012.JPG 04/20/2022 02:42 PM (ET) Dean Maraldo Field Inspection/Unidentified Outfall Just East of Outfall 003 No CBI No PII The discharge from the Unidentified Outfall just east of outfall 003 results in light colored deposits leading right up to the Black River. The discharge from the Unidentified Outfall was observed flowing into the Black River. Appendix 1-4 04/20/2022 - 04/20/2022 REPUBLIC STEEL LORAIN PLANT Inspection Date(s): Discharge into the Black River REPL0013.JPG 04/20/2022 02:47 PM (ET) Dean Maraldo Field Inspection/Unidentified Outfall Just East of Outfall 003 No CBI No PII Photo of the discharge from the Unidentified Outfall just east to outfall 003 cascading into the Black River. 04/20/2022 - 04/20/2022 View of Black River and discharge from Unidentified Outfall REPL0016.JPG 04/20/2022 03:21 PM (ET) Dean Maraldo Field Inspection/Unidentified Outfall Just East of Outfall 003 No CBI No PII View from the bluff directly above the Unidentified Outfall just east of outfall 003. Note the light color of the area impacted by outfall discharge. Note: Image REPL0014 is a video of the discharge from the unidentified outfall just east to outfall 003 cascading into the Black River. Image REPL0015.JPG was taken in error and not included in the Photolog. Appendix 1-5 REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 - 04/20/2022 APPENDIX 2: DOCUMENT LOG Document Type Discharge Monitoring Report (January and February 2022) Field sheets (August 2021 - April 13, 2022) Document Name Republic Lorain DMRs_JanFeb2022. pdf Republic Lorain FieldSheets_Aug2021A pr2022.p df Contains CBI No No Contains PII No Pages 30 No 31 Date Received 04/20/2022 04/20/2022 Appendix 2-1 REPUBLIC STEEL LORAIN PLANT Inspection Date(s): APPENDIX 3: REFERENCE DOCUMENTS Document Type DMR Summary Report Process Description/Flow Diagram Calibration Records Ohio EPA's September 4, 2019 Director's Final Findings& Orders Document Name Contains CBI ECHO_ELEs_20220413. No pdf Wastewater Flow No Diagram 3- 2_PermitApp_201712.p df Extech Oyster 10 pH No meter_calibration and QC_ 20220420.pdf OhioEPA_DFFO_201909 No 04.pdf Contains PII No Pages 1 No 1 No 1 No 16 04/20/2022 - 04/20/2022 Appendix 3-1 Effluent Limit Exceedances Report OH0001562: REPUBLIC STEEL LORAIN PLANT, LORAIN, OH 44055-1803 Monitoring Period Date Range: 01/01/2021 to 01/31/2022 Exceedance Details Monitoring Period Date 1/31/2021 1/31/2021 2/28/2021 2/28/2021 2/28/2021 3/31/2021 4/30/2021 4/30/2021 5/31/2021 5/31/2021 6/30/2021 6/30/2021 6/30/2021 6/30/2021 6/30/2021 6/30/2021 7/31/2021 7/31/2021 7/31/2021 7/31/2021 8/31/2021 8/31/2021 8/31/2021 9/30/2021 9/30/2021 9/30/2021 9/30/2021 10/31/2021 10/31/2021 10/31/2021 11/30/2021 11/30/2021 1/31/2022 Outfall 2 5 2 3 5 2 2 5 2 604 2 2 2 5 5 5 2 2 2 3 2 2 2 2 2 5 5 2 3 3 2 3 2 Parameter Description pH pH pH Mercury, total low level pH pH pH pH pH pH pH Chlorine, total residual Chlorine, total residual Oil and grease (soxhlet extr.) Chlorine, total residual Chlorine, total residual pH Chlorine, total residual Chlorine, total residual Mercury, total low level pH Chlorine, total residual Chlorine, total residual pH Oil and grease (soxhlet extr.) Chlorine, total residual Chlorine, total residual pH Chlorine, total residual Chlorine, total residual pH Mercury, total low level pH Limit Type DAILY MX DAILY MX DAILY MX MO AVG DAILY MX DAILY MX DAILY MX DAILY MN DAILY MX DAILY MX DAILY MX DAILY MX MO AVG DAILY MX MO AVG DAILY MX DAILY MX MO AVG DAILY MX MO AVG DAILY MX DAILY MX MO AVG DAILY MX DAILY MX DAILY MX MO AVG DAILY MX MO AVG DAILY MX DAILY MX MO AVG DAILY MX DMR Value 10.41 9.06 10.62 1.7E-05 9.08 9.9 9.02 5.84 9.88 9.04 9.92 0.14 0.14 14 0.15 0.15 9.25 0.1 0.1 2.3E-05 9.73 0.09 0.09 9.42 20 0.06 0.06 9.28 0.18 0.18 9.76 9.8E-05 9.11 DMR Value Unit SU SU SU mg/L SU SU SU SU SU SU SU mg/L mg/L mg/L mg/L mg/L SU mg/L mg/L mg/L SU mg/L mg/L SU mg/L mg/L mg/L SU mg/L mg/L SU mg/L SU Limit Value 9 9 9 1.2E-05 9 9 9 6.5 9 9 9 0.024 0.014 10 0.016 0.027 9 0.014 0.024 1.2E-05 9 0.024 0.014 9 10 0.027 0.016 9 0.013 0.024 9 1.2E-05 9 Limit Value Qualifier <= <= <= <= <= <= <= >= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-2 REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-3 REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-4 rhoio Environmental Protection Agency Mike DeWine, Governor Jon Husted, Lt. Governor Laurie A. Stevenson, Director 9/4/2019 Mr. John Wilkinson, Executive V.P. Republic Steel 2633 8th Street NE Canton, OH 44704 RE: Director's Final Findings & Orders NPDES Lorain County. 31000028 Ladies and Gentlemen: Transmitted herewith is one copy of the modified Director's Final Findings & Orders in.the referenced matter. Sincerely, Kevin J. Fowler, Supervisor Permit Processing Unit Division of Surface Water KJF/kep Enclosure CERTIFIED MAIL cc: L. Reeder, DSW R. Demuth, DSW L. Kaldy, DSW B. Palmer, DSW D. Stoll, NEDO/DSW M. McCarron, PIC H. Griesmer, PIC J. Lee, PIC Pete Simcic, Legal J. Dragovich, DEFA Journal Room File 50 West Town Street Suite 700 P.O. Box 1049 Columbus, OH 43216-1049 epa.ohio.gov (614) 644-3020 (614) 644-3184 (fax) REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-5 BEFORE THE OHIO ENVIRONMENTAL PROTECTION AGENCY i ~hi EF'N SEF 19 EntF r -I?uf' n.al In the Matter of: Republic Steel 2633 8th Street, NE Canton, Ohio 44704 . Director's Final Findinqs . and Orders Respondent PREAMRLE It is agreed by the Parties hereto as follows: JURISDICTION These Modified Director's Final Findings and Orders ("Orders") are issued to Republic Steel ("Respondent") pursuant to the authority vested in the Director of the Ohio Environmental Protection Agency ("Ohio EPA") under Ohio Revised Code ("ORC") 6111.03 and 3745.01, and supercede the Director's Final Findings and Orders issued to Respondent on August 16, 2019. 11. PARTIES BOUND These Orders shall apply to and be binding upon Respondent and successors in interest liable under Ohio law. No change in the composition of Respondent shall in any way alter Respondent's obligations under these Orders. III. DEFINITIONS Unless otherwise stated, all terms used in these Orders shall have the same meaning as defined in ORC Chapters 6111 and 3745, and the rules promulgated thereunder. IV. FINDINGS The Director has made the following findings: 1. Respondent owns and operates a steel manufacturing facility located at 1807 E. 28th Street, Lorain, Ohio ("the Facility".) Currently, the Facility is idle and groundwater/stormwater has been accumulating in basements, cellars and pits throughout the Facility. Certain equipment is either under water or is in imminent threat of being submerged as water levels continue to rise at the Facility. Respondent has identified the following equipment at risk, with potentially more equipment still needing to be inventoried: REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-6 Republic Steel Director's Final Findings and Orders Page 2 Bar Mill Water coming into basements in the Bar Mill threatens to destroy the following equipment: 4 2300-volt motors feeding process water pumps for the Bar Mill; 6 2300-volt breakers that feed power into the cellar; 4 480-volt 5 horsepower motors for the hydraulic pumps; 3 480-volt 10 horsepower motors for the precipitron room fans; 4 total 480-volt 5 horsepower motors for the two lube systems in the adjoining pile systems. Rolling Mill In the Rolling Mill, the oil clears are already underwater. The substation basement is now flooding and has about 2 feet of water in this location. 3 different rotating MG sets and regulator contractor boards are located in this cellar. This equipment is no longer manufactured and would be costly to replace; Approximately four 5-horsepower and three10-horsepower fans are located in this cellar; There are a number of buss connections located in this cellar that will have to be dried out before it can be determined if they are a total loss. 2. On February 5, 2019, Respondent reported to the Emergency Response Spill Hotline an oil sheen to Ohio EPA. Remedial measures were taken, and it was determined that the source of the oil was most likely the Rolling Mill area of the Facility. An NOV was issued on February 5, 2019 for the illegal discharge of oil to waters of the state. 3. Respondent has notified Ohio EPA that is was pumping groundwater and stormwater from basements, cellars and pits located in the Bar Mill and Rolling Mill. Respondent submitted analytical data to Ohio EPA via eDMRs during the time period Republic Steel was pumping water from the basements, cellars and pits at the Facility. Monitoring data from Outfall 005 did not show significant issues. Monitoring data form Outfall 005 did show an occasional REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-7 Republic Steel Director's Final Findings and Orders Page 3 chlorine residual exceedance which Respondent was actively working with Ohio EPA to address. Ohio EPA raised concern that the monitoring at Outfall 005 where the discharge was being directed did not include a full suite of parameters, including metals, SVOCs or VOCs (although such sampling is not required under the current NDPES permit). Ohio EPA and Respondent are currently negotiating language in Respondent's renewal National Pollutant Discharge Elimination System ("NPDES") permit regarding discharges of groundwater and stormwater from basements, cellars and pits at the Facility. 4. On June 26, 2019, Respondent reported to the Emergency Response Spill Hotline that an oil sheen was being discharged from the Facility to the Black River. Ohio EPA discovered that a pump from the Bar Mill scale pit was causing the release of oil to a storm sewer and then to the Black River. Ohio EPA, Respondent, and Respondent's consultant took remedial measures to contain the oil spill. Ohio EPA issued a Notice of Violation letter on June 26, 2019 for the illegal discharge of oil to waters of the state. 5. Currently, Respondent has been pumping the water to four 21,000-gallon frac tanks in the Bar Mill. Respondent is currently hauling the water from the tanks to a facility in Youngstown for disposal at significant cost. Respondent continues to experience issues with day-to-day management of water levels that threatens to damage equipment. 6. Respondent had proposed to resume discharging the water onsite after additional treatment was to be provided through portable treatment units while Respondent gathered additional sampling to address Ohio EPA's concerns that sampling is needed to characterize the condition of water in the basements, cellars and pits, including sampling for VOCs, SVOCs and metals. Respondent was unable to procure the portable treatment units and has proposed an alternative treatment system as set forth in Attachment A to these Orders. The proposed treatment will discharge at a rate of 50 gpm. 7. The Director has given consideration to, and based her determination on, evidence relating to the technical feasibility and economic reasonableness of complying with these Orders and to evidence relating to conditions calculated to result from compliance with these Orders, and its relation to the benefits to the people of the State to be derived from such compliance ih accomplishing the purpose of ORC Chapter 6111. V. ORDERS Order No. 1 of the August 16, 2019 Orders is hereby modified as follows: 1. Respondent may immediately recommence discharging the accumulated water from the Bar Mill (Ouffall 605) and Primary Mill (Outfall 604) scale pits, provided that the water has been treated pursuant to the alternative treatment system described in Attachment A, which is hereby incorporated into and made a part of these Orders. REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-8 Republic Steel Director's Final Findings and Orders Page 4 2. The treated water shall meet the following temporary discharge Iimits: Table 1. Limits and Monitoring Requirements for Temporary Discharge Parameter Reporting Code Concentration Limits 30-day Daily avera e maximum Monitoring Frequency Flow estimate (MGD) 50050 24-Hr. Estimate llday pH (S.U.) 00400 6.5-9.0 2/week Total Suspended Solids (mg/L) 00300 -- l 65 2/week Oil and Grease (mg/1) 00552 -- 10 2/week Zinc, Total Recoverable ug/I 01094 Monitor 1/week Chlorine, Total Residual mg/I 50060 -- l 0.019 2/week All sampling set forth in Table 1 shall be grab samples. (Reports should be submitted after the end of each month during which you have coverage under these Orders, regardless of whether or not a discharge occurred during the month. Instructions for electronic submittal of data can be found on Ohio EPA's website at: http://epa.ohio.gov/dsw/edmr/eDMR.aspx The chlorine limit listed above is less than the Ohio EPA Quantification Level (OEPA QL) for the approved analytical procedure promulgated at 40 CFR 136. Compliance with an effluent limit that is below the OEPA QL is determined in accordance with ORC Section 6111.13 and OAC Rule 3745-33-07(C). For maximum effluent limits, any value reported below the OEPA QL shall be considered in compliance with the effluent limit. Respondent must utilize the lowest available detection method currently approved under 40 CFR Part 136 for monitoring total residual chlorine. All analytical results, even those below the OEPA QL (listed below), shall be reported. Analytical results are to be reported as follows: Results above the QL: Report the analytical result for the parameter of concern. Results above the MDL, but below the QL: Report the analytical result, even though it is below the QL. Results below the MDL: Analytical results below the method detection limit shall be REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-9 Republic Steel Director's Final Findings and Orders Page 5 reported as "below detection" using the reporting code "AA".) 3. The following table of quantification levels will be used to determine compliance with total residual chlorine in these Orders: Parameter Chlorine, tot. res. PQL 0.050 mg/l Order No. 4 of the August 16, 2019 Orders is hereby modified as follows: 4. The discharge of the following treatment additives in the emergency discharge are approved at the following concentrations: Table 2. Approved Treatment Additives Additive Concentration (ppm) ChemTreat P8281 L 100 Sodium Hydroxide caustic 100 BL1301 ChemTreat P817E 15 ChemTreat RL 124 10 5. Respondent shall submit an after the fact Permit to Install ("PTI") for the installation of the alternate treatment unit and an NPDES permit modification for the discharge. Respondent shall operate the alternate treatment system pursuant to the requirements of these Orders until such time as the PTI is approved and a new or modified NPDES permit has been issued which includes the discharge or until a request pursuant to Order number 7 has been granted. 6. Within thirty (30) days, Respondent will also obtain two more rounds of sampling from the scale pits associated with the Bar Mill and Rolling Mill where water is pumped to, and will analyze for the full set of parameters (i.e. Form 2C sampling) as was previously done with the Bar Mill sampling. 7. Once sufficient data has been obtained demonstrating that the alternate treatment unit is consistently meeting the proposed discharge limits, Respondent may request to reduce monitoring. In addition, if sampling of the water prior to treatment shows the condition of the water does not warrant treatment with the portable treatment unit, Respondent may request that treatment with the alternate treatment unit or portions thereof may be discontinued. REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-10 Republic Steel Director's Final Findings and Orders Page 6 VI. TERMINATION These Orders shall terminate automatically when both the after-the-fact PTI has been approved by Ohio EPA and a new or modified NPDES permit has been issued which includes the discharge from the pits or a request pursuant to Order 7 has been granted. Otherwise, Respondent's obligation under these Orders shall terminate when Respondent certifies in writing and demonstrates to the satisfaction of Ohio EPA that Respondent has performed all obligations under these Orders and the Chief of Ohio EPA's Division of Surface Water acknowledges, in writing, the termination of these Orders. If Ohio EPA does not agree that all obligations have been performed, then Ohio EPA will notify Respondent of the obligations that have not been performed, in which case Respondent shall have an opportunity to address any such deficiencies and seek termination as described above. The certification shall contain the following attestation: "I certify that the information contained in or accompanying this certification is true, accurate and complete." This certification shall be submitted by Respondent to Ohio EPA. VII. OTHER APPLICABLE LAWS All actions required to be taken pursuant to these Orders shall be undertaken in accordance with the requirements of all applicable local, state and federal laws and regulations. These Orders do not waive or compromise the applicability and enforcement of any other statutes or regulations applicable to Respondent. VIII. MODIFICATIONS These Orders may be modified by agreement of the parties hereto. Modifications shall be in writing and shall be effective on the date entered in the journal of the Director of Ohio EPA. IX. RESERVATION OF RIGHTS Ohio EPA and Respondent each reserve all rights, privileges, defenses and causes of action, except as specifically waived in Section XI of these Orders. Without admission of law, fact, violation or liability, Respondent consents to the issuance of these Orders and agrees to comply with these Orders. X. NOTICE Unless otherwise specified, all documents required to be submitted by Respondent pursuant to these Orders shall be addressed to: REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-11 Republic Steel Director's Final Findings and Orders Page 7 Ohio Environmental Protection Agency Northeast District Office 2110 East Aurora Road Twinsburg, Ohio 44087 Division of Surface Water XI. WAIVER Respondent hereby waives the right to appeal the issuance, terms and conditions, and service of these Orders, and Respondent hereby waives any and all rights Respondent may have to seek administrative or judicial review of these Orders either in law or equity. Notwithstanding the preceding, Ohio EPA and Respondent agree that if these Orders are appealed by any other party to the Environmental Review Appeals Commission, or any court, Respondent retains the right to intervene and participate in such appeal. In such an event, Respondent shall continue to comply with these Orders notwithstanding such appeal and intervention unless these Orders are stayed, vacated or modified. XII. EFFECTIVE DATE The effective date of these Orders is the date these Orders are entered into the Ohio EPA Director's journal. REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-12 Republic Steel Directors Final Findings and Orders Page 8 XIII. SIGNATORY AUTHORITY Each undersigned representative of a party to these Orders certifies that he or she is fully authorized to enter into these Orders and to legally bind such party to these Orders. IT IS SO ORDERED AND AGREED: Ohio Environmental Protection Agency ^ Laurie A. Stevenson Director Date IT IS SO AGREED: Republic Steel gnature 9- z g- or7 Date Z I d&7NS J.~ Printed or Typed Name REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-13 Attachment A REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-14 Engineering Report For Republic Steel By: John Titus, PE Cleveland, OH 44103 August 27, 2019 Project No. 1001697 REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-15 Treatment System Overview This application submittal is for a proposed temporary wastewater treatment system that will provide continuous treatment of water from the bar mill and rolling mill scale pits located at Republic Steel, 1807 E. 28th St., Lorain, OH 44055. Water from the scale pits has total suspended solids and O&G that will be treated with this system. The total continuous flow to treatment will approximate 50 gal./min. The proposed treatment system will employ conventional treatment strategies and be rated for up to 72,000 gal/day. Chemtreat has bench tested samples of the scale pit water, and it was determined that the proposed treatment scheme is the best approach for clarification of this waste stream. Dosages based on treatability are listed at the end of the report. Process Narrative The process begins with the transfer of water located in the scale pit to an oil/water separator, then will gravity flow to the first stage neutralizer, N-1. Pump P-1 is a submersible pump with a float switch that will operate as long as the water level is above the float level. 1St Staae oH Adiustment Wastewater from the scale pit will be pumped to the 1st stage pH adjustment tank (N-1) at a projected flow rate of 50 gal./min. The 1,850 gallon tank capacity of N1 will provide an initial reaction time of approximately 37 minutes based on this flow rate. An iron based coagulant (P8281 L) will be added to N-1 via chemical metering pump CP-1 as long as P-1 is running. The tank is fitted with a 2 HP mixer, MX-1, to ensure proper solution blending. Flow from N-1 will flow via gravity to the 2"d stage pH adjustment tank (N-2). 2"a Stage pH Adiustment The 2"d stage pH adjustment tank (N-2) will receive the flow from the 1st stage for final pH adjustment and chemical addition prior to the flocculation and clarification stage of treatment. The 1,850 gallon tank capacity of N-2 will provide an additional reaction time of approximately 37 minutes based on the flow rate of 50 gal/min. The pH will be adjusted to 8.5-9 via the automatic addition of sodium hydroxide with chemical metering pump CP-2. The pump utilizes a 4-20mA proportional signals. pH instrumentation (pH-2) located in the 2"d stage adjustment tank will control the chemical metering pump activity. The tank is fitted with a 2 HP mixer, MX-2, to ensure proper solution blending. Flow from N2 will flow via gravity to the inclined plate clarifier. REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-16 Clarification and sludae holdina Flow from N-2 will flow into the flash mix chamber, located on the inclined plate clarifier, CL-1. Anionic polymer (P817E) is added via metering pump CP-3 into the flash mix chamber as long as P-1 is running. The flow exits the flash mix chamber into the flocculation chamber, prior to gravity flowing into the clarifier influent launder assembly. CL-1 will have a projected settling area of 900 square feet. Based on the projected flow rate of 50 gal/min, the projected settling area will provide a hydraulic loading of 0.06 gpm/ft2. Clarifier supernatant will overflow to the final pH sampling tank. Sodium metabisulfite will be added to the final pH sampling tank via chemical metering pump CP-4 as long as P-1 is running, in case of potential elevated total chlorine levels. Grab samples will be taken to periodically monitor for pH and oil & grease. Effluent from the final pH sampling tank will be discharged to the permitted outfall. Clarifier underflow, expected to be 1%-2% solids will be transferred to a frac tank (or other customer supplied container) by air diaphragm pump, through the use of an adjustable frequency/duration timer for the automatic blowdown valve. The blowdown can also be manually operated as required. Sludge will be hauled away as required. Treatment scheme 1.) Addition of 100 ppm of the ChemTreat P8281 L coagulant 2.) Addition of 100 ppm of 50% Sodium Hydroxide caustic BL1301 to raise raw water pH level from 6.00 to 8.50-9.00 3.) Addition of 15 ppm of the ChemTreat P817E emulsion polymer 4.) Addition of 10 ppm of the ChemTreat RL124 dechlorination product as the water leaves the portable treatment system and heads to outfall Based on a treatment rate of 50 gpm or 72,000 gallons per day, the associated amounts of chemicals are as follows: 1.) 7.2 gallons per day of the ChemTreat P8281 L coagulant 2.) 7.2 gallons per day of the Sodium Hydroxide caustic - this is a commodity that Republic Steel should purchase directly from a commodity vendor 3.) 1 gallon per day of the ChemTreat P817E emulsion polymer 4.) 0.75 gallons per day of the ChemTreat RL124 dechlor product REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-17 -_ . isi~~ miummmmumuui ~ s I I~~~~~~~~~~~~~~~~~~~~~~~~~ _______ ~Ii~_u_~~~~I~I~ ~~ mluummumunuuu :_______ =_=_____ ,s;er~~ m umuumummm~~ : ~~ ~~ - ------ - -- - 58 o)co NOTE: " ELEVATED BY CUSTOMER" REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-18 REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-19 A 1 2 3 5 8 7 8 B C D E Z f Pf f MX-i PH_1 MX-2 PH_2 MX-3 OWS F G H 4 EFFLUENT TO flNAL PH SAMPIlNG TANK Y ~ O ~ , 2 PIT SUMP Z T O 1-~ CP-1 CT-1 COAGULANT -~ N z 1- 1-1~ N-1 NEULRALRATION 1850 GALLON `1 Q ~ x `` Jv=i o ~ N-2 NEUTRALIZATION 1850 GALLON CL -- ~ 900 S.F. Z Z ~Z 1 -~' 1. \ O Cp-2 ax~arr : e CP-3 I a~/ar CP_4 9 .~'H H- a~ NqpwG Br o-lao Psi p ww R S 4 FROM CL-1 u ~ re ax/ar M 4TO DISCHARGE P 8 S' a N ~ n O ~ W N } tn Z w w O. w ~ Q W Q - _ CT-2 CAUSTIC CT-3 POLYMER OAY TANK CT-4 MBS FINAL PH 850 GALLON SAMPLING TANK je t e~g ti Wu 4aP j ~j # W~ REPUBLIC STEEL LORAIN PLANT Inspection Date(s): 04/20/2022 -4/20/2022 Appendix 3-20 i RverBe ndDr l Back i Rver ck i Rver Outfall 003 Unidentified outfall Outfall 002 Bla Outfall 005 Internal Outfall 605 Scalepit OakwoodAve SenecaAve Pearl Ave GlobeAve nRd Fulto E28thSt E29thSt U.S.EPAInspecto inReport RepublicSteelLorainPlant April 20, 2022 Outaflls Scalepit E28thSt E28thSt E29thSt E29thSt Source:Esri,Maxar,GeoEye,EarthstarGeographics,CNES/AirbusDS,USDA,USGS,AeroGRID,IGN,andtheGISUserCommunity Appendix4:SiteMap 0 500 1,000 US Feet