Document jBvJy1yj8KOLnnjjgOB6gkBXp

CWA COMPLIANCE EVALUATION INSPECTION REPORT U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 5 Purpose: Compliance Evaluation Inspection Facility: Cleveland Cliffs Burns Harbor, LLC 250 US-12 Burns Harbor, Indiana 46304 Porter County 41.625, -87.117 NPDES Permit Number: IN0000175 Date of Inspection: April 19, 2021 EPA Representatives: Joan Rogers, Environmental Scientist Rogers.joan@epa.gov State Representatives: Nicholas Ream, Indiana Department of Environmental Management Wastewater Inspector nream@idem.IN.gov Robert Lugar, Indiana Department of Environmental Management RLugar@idem.IN.gov Facility Representatives: Tom Maicher, Manager of the Environmental Plant Robert.maciel@ClevelandCliffs.com Morgan Swanson, Environmental Engineer Morgan.swanson@ClevelandCliffs.com Cary Mathias, Regional Waste Manager Cary.mathias@ClevelandCliffs.com Patrick Gorman, Operator Patrick.gorman@ClevelandCliffs.com Rick Balunda, Operations Manager Balunda.Rick@ClevelandCliffs.com 312-886-2785 219-730-1691 317-234-6019 219-787-4961 219-787-2646 330-659-9124 Cleveland Cliffs Burns Harbor April 19, 2021 Courtney Zunica -Notetaker for Cleveland Cliffs Burns Harbor Report Prepared by: Joan Rogers JOAN Digitally signed by JOAN ROGERS ROGERS Date: 2021.06.08 Inspector Signature: __________________1_0_:5_4_:5_3_-0_5_'0_0_' _________________________ Approver Name and Title: _Ryan Bahr, Chief, Section 2, WECAB______________ RYAN Digitally signed by RYAN BAHR BAHR Date: 2021.06.08 Approver Signature/Date: _________________1_3_:1_1_:5_6_-_0_5_'0_0_' _____________________ 1. BACKGROUND The purpose of this report is to describe and document the discussion and site inspection at the Cleveland Cliffs Burns Harbor facility on April 19, 2021. This inspection was performed pursuant to Section 308(a) of the Federal Water Pollution Control Act, as amended. This was a joint inspection by EPA and the Indiana Department of Environmental Management (IDEM). The Cleveland Cliffs Burns Harbor (CCBH) facility is one of the largest fully integrated steel mills in North America, with the capacity to produce approximately 5 million tons of raw steel per year. They operate under NPDES Permit No. IN0000175, which was issued on May 27, 2016 and expires on June 30, 2021. A permit renewal application has been submitted to IDEM. The facility was previously owned by ArcelorMittal and was known as ArcelorMittal Burns Harbor. The inspection on April 19, 2021 was a Compliance Evaluation Inspection to document compliance with the facility's permit. EPA and IDEM also requested the following documents to be sent prior to the inspection (if possible): a. February 2021 analytical results and associated Chain-of Custody reports. b. Most recent flow meter calibration records. c. Sludge disposal records for February 2021. d. DMRs and MMRs for January and February 2021. e. Any additional ammonia analysis from the Storm Water Ditch sampling. f. Any new information regarding sludge depths or analysis of the sludge in the lagoons. g. Information regarding cyanide destruction and ammonia stripping within the blast furnace recycle system. h. Information regarding the elevated, although not over permit limits, cyanide results for the January 24 - February 2, 2021 timeframe. A notification requesting these documents and information was sent to CCBH on April 13, 2021. 2 2. SITE INSPECTION Cleveland Cliffs Burns Harbor April 19, 2021 Site Entry and Opening Conference Arrival Time: 8:30 A.M. Presented credentials? Yes. 8:30 A.M. to Morgan Swanson. Credentials presented to whom and at what 9:00 A.M. to Tom Maicher, Cary time? Mathias, Pat Gorman and Courtney Zunica. Was an opening conference held? With whom? Yes. Ms. Swanson, Mr. Maicher, Mr. Mathias, Mr. Gorman and Ms. Zunica. If photographs or documents were taken, does the facility consider No. any to be Confidential Business Information (CBI)? Which information does the facility consider to be CBI? None. EPA vehicle parked in approved location? Yes. Location where EPA vehicle was parked? Environmental Services Building. EPA inspector, Ms. Joan Rogers, and IDEM inspectors Mr. Bob Lugar and Mr. Nick Ream followed Ms. Swanson to the Environmental Services Building conference room from the main office where EPA and IDEM inspectors received their visitor badges. The inspection team explained that the purpose of the inspection was to document compliance with the NPDES permit, obtain information and view the locations at the facility requested in the April 13, 2021 notification. The inspection team discussed safety considerations with the facility personnel. Ammonia Treatment Process The conversation began with a description of ammonia treatment from the Blast Furnace Recycle System (BFRS) blowdown. Currently, the facility is utilizing a cooling tower to remove ammonia from the BFRS blowdown. Facility representatives commented that it has experienced a lot of solids build-up in the cooling tower. They plan to install equipment to remove the hardness before the flow goes to the cooling tower. The equipment is already ordered for rental through the summer, when the Permit's ammonia limits are lower. They will observe the process over the next couple of summers, demobilizing the system for the winter because it isn't freeze-proof. Mr. Mathias stated that because of the solids in the blowdown, the ammonia reduction is 50%, at best, in the cooling tower. They stated that it is only removing about half of the hardness in blowdown with the system they currently have. This hardness is from calcium carbonate. The other half is from sulfates and they believe they need soda ash to assist in that removal. They plan to introduce soda ash after the chlorine dioxide (ClO2) system that is designed for cyanide destruction. The flow will then go through two cooling towers before flowing to the Secondary Wastewater Treatment Plant (SWTP) and then out through Outfalls 011 and 001. 3 Cleveland Cliffs Burns Harbor April 19, 2021 An additional plan to remove solids from the Reclamation Services Building (RSB) thickener underflow with a centrifuge and then send the centrate back to the BFRS will also provide more ammonia removal from the final effluent because that flow will now go through ammonia removal during blowdown before flowing to the Secondary Wastewater Treatment Plant (SWTP) and then out through Outfalls 011 and 001. Lagoon Soundings In November 2020, CCBH conducted surveys of the lagoon depths and have new soundings from those surveys. Using the unit of Cubic Yards Dry (CYD), the soundings were used to calculate the current water volume capacities of the influent channel, Cell 1 (South Cell), Cell 2 (North Cell), and the effluent channel. The current capacities in each location were compared to the design capacities. From the 2020-12-23 WWTP Lagoon Hydrographic Survey drawings provided to EPA and IDEM, there is significant reduction in capacity in the influent and effluent channels and each cell's capacity is reduced by approximately 30% of the design capacity. CCBH is most concerned about the influent channel capacity. The design capacity was 37,887 CYD and currently there is only 8,421 CYD of water volume left. They consider this a pinch point of the lagoon system and have begun developing plans to dredge the influent channel. Since the influent channel cannot be isolated from the whole system, like the cells could be, CCBH is carefully considering how to dredge the influent channel without causing permit exceedances. Storm Water Ditch EPA and IDEM asked if there had been any additional testing for ammonia on the Storm Water Ditch. CCBH stated that there has been. They decided that testing for ammonia only wasn't giving them enough data. They added some instrumentation on April 2, 2021 to also test for temperature and conductivity. The instruments sample the water in the Storm Ditch every two minutes. They plan to download the data every 20 days and they recently downloaded the first batch of data and are in the process of reviewing the results. They plan to install these instruments from the SWTP all the way to Outfall 011. Meanwhile, they are still taking composite samples for ammonia from certain stretches along the Storm Water Ditch. Additionally, they redid the ammonia mass balance with the Sinter Plant running. The Sinter Plant was not operating during the last ammonia mass balance testing. A report will be generated once the calculations are complete. Cyanide Elevations from January 24 - February 2, 2021 During review of daily sample analysis reports, EPA noted that during the period from January 24, 2021 through February 2, 2021, the level of total cyanide at Outfalls 011 and 001 were elevated. The data from the sample analysis from that time frame are: 4 Date 1/24/21 1/25/21 1/26/21 1/27/21 1/28/21 1/29/21 1/30/21 1/31/21 2/1/21 2/2/21 2/3/21 2/4/21 2/5/21 2/6/21 Cleveland Cliffs Burns Harbor April 19, 2021 Outfall 011 Total Cyanide (mg/L) 0.0054 0.0090 0.010 0.018 0.018 0.014 0.015 0.0086 0.0077 0.0076 0.0080 0.0062 0.0076 0.0050 Outfall 001 (mg/L) <0.0040 0.0056 0.0068 0.0094 0.012 0.011 0.011 0.0058 <0.0040 0.0056 0.0054 0.0041 0.050 0.0042 Total Cyanide Although they never reached a level that would exceed a permit limit, EPA and IDEM were interested to know if there were any production changes or problems that caused the elevated levels of cyanide. CCBH personnel stated that they have not identified anything different in the production during that timeframe. Mr. Mathias pointed out that 0-4 ppm variability is normal in their operations. Mr. Gorman stated that the facility observed that the total cyanide in the Cold Well also went up to 2 ppm during that time period. The facility doesn't take any additional actions until the samples in the Cold Well are at 4 ppm. Once the level of cyanide in the Cold Well reaches 4 ppm for two sample periods, the facility personnel increase the sampling frequency to every two hours. If the cyanide levels persist for two of those samples, the facility utilizes the ClO2 to destruct the cyanide. The level of cyanide in the Cold Well did not reach a point where ClO2 was needed. Mr. Mathias stated that the facility gets about 85% reduction in cyanide with the use of the ClO2. The Agencies were provided a hard copy from the report for the ClO2 system titled Preliminary Pilot with Field Data that shows the percentage of cyanide removal using the ClO2. Facility Walkthrough See Attachment A for the photolog of the photos taken during the facility walkthrough. After the interview and discussion in the conference room, EPA and IDEM began the walkthrough of the facility. At 11:14 A.M., Ms. Rogers, Mr. Ream, and Mr. Lugar inspected the lab. In the lab, they observed that the log for the refrigerator temperature was maintained and showed that the refrigerator temperature was in the proper range. The thermometer was properly kept in water inside the refrigerator. Additionally, all the buffers were not expired. 5 Cleveland Cliffs Burns Harbor April 19, 2021 At 11:29 A.M., the inspection team traveled to the Cooling Towers and observed the equipment in the control room. In the control room, facility personnel use colorimetric tests for cyanide and ammonia. They use a dilution for the ammonia testing because the test only reads to 10 mg/L and there is usually 140 mg/L in the water. Operators perform the ammonia and cyanide tests every eight-hour shift. The operators report to their supervisors who create a report that Mr. Gorman reads. EPA and IDEM inspectors observed the control screen. The facility was not currently feeding ClO2 to the system because the cyanide levels were too low. EPA and IDEM inspection team then accompanied the facility personnel outside and observed the Cooling Towers. All five of the BFRS cooling towers have been rehabbed and there are now two cooling towers for ammonia reduction. The inspection team also saw the area next to the cooling towers where the new ammonia treatment will be installed. EPA and IDEM then observed Outfall 111. This is an internal outfall for water from the Hi-Cap Thickener and the RSB Final Thickener effluents. Currently, these flows go to the Dirty Industrial Wastewater (DIW) pipe which takes the flow to the SWTP. As mentioned in the Ammonia Treatment Processes section above, in the future, the plan is to divert these flows to a centrifuge to remove solids. The solids will be landfilled and the centrate will be piped back into the BFRS. When the water leaves the BFRS through the blowdown, it will be treated for ammonia. At 12:07 P.M., EPA and IDEM inspectors drove to and observed Outfall 003. The water in the bermed area was clear. At 12:27 P.M., EPA and IDEM inspectors drove to and observed the Deerfield Retention Basin. The level of the water in the basin on the day of the inspection was 80" and the basin has a capacity of 144" to the top of the berm. At 12:53 P.M., EPA and IDEM inspectors drove to Outfall 002 and observed that the water was clear. There was a small amount of scum and debris along the back wall of the outfall. At 1:20 P.M., EPA and IDEM inspectors drove to the SWTP. CCBH Operations Manager, Mr. Rick Balunda, joined the inspection team. They began their inspection of the SWTP on the Cold Mill side. EPA and IDEM observed that there was oil on the effluent in the clarifiers. Mr. Balunda stated that he thought there was not enough solids in the influent to "grab" the oil and grease and that was the reason for the oil on the effluent. EPA and IDEM also observed a clarifier that was empty for cleaning. There were solids built up in the corners of the square clarifier. Mr. Balunda stated that this is a typical problem with square clarifiers and the sludge built up in the corners needs to be cleaned periodically. EPA and IDEM also observed vegetative growth on the weirs of one of the clarifiers. 6 Cleveland Cliffs Burns Harbor April 19, 2021 On the Hot Mill side of the SWTP, EPA and IDEM observed that there was also an oil sheen on the effluent in the clarifiers on this side of the plant. Ms. Rogers asked Mr. Balunda if there would be a problem running the SWTP in the future if the facility reduces solids from the waste stream even further. Mr. Balunda stated that it wouldn't be a problem because he could use his Return Activated Sludge (RAS) to reseed if needed. EPA observed the sample data from the cyanide testing done at the SWTP during the time period of elevated cyanide from January 25, 2021 to February 3, 2021. During this timeframe, SWTP personnel had increased the monitoring frequency. Mr. Balunda stated that when the level reaches 3 ppm, he reports that and ClO2 treatment was supposed to begin. None of the samples showed elevated cyanide over 3 ppm. Mr. Gorman thought that the trigger level was 4 ppm, but Mr. Balunda believed it to be 3 ppm. EPA and IDEM inspectors left the plant and traveled to Outfalls 011 and 001, arriving at Outfall 011 at 2:30 P.M. On the way to Outfall 011, EPA observed the influent channel to the lagoons. Clearing of the brush alongside the influent channel had already begun in preparation for the dredging. EPA observed that the water was clear at Outfall 011. In the sample building for Outfall 011, the temperature of the reagent refrigerator and the temperature of the sample refrigerator were both 3 and the log entries were complete. EPA and IDEM inspectors arrived at Outfall 001 at 2:44 P.M. The water was clear at Outfall 001. In the sample building, EPA and IDEM noted that the screen on the autosampler showed that the temperature in the sampler was -0.5, but the thermometer inside read 8. The thermometer was in water inside the auto sampler. EPA and IDEM looked for the logbook for the temperature observations, but it was not in the sample building. EPA and IDEM requested that the log entries be submitted electronically. EPA and IDEM provided a brief closing conference at Outfall 001. 3. LIST OF DOCUMENTS RECEIVED FROM FACILITY Preliminary Pilot with Field Data (1 page) with percent destruction of cyanide after use of ClO2. 2020-12-23 - WWTP Lagoon Hydrographic Survey (provided on April 16, 2021). January and February 2021 DMRs and MROs (provided on April 16, 2021). Calibration logs and flow records for all Outfalls (provided on April 16, 2021). Sludge disposal records (provided on April 16, 2021). Outfall 001 Sample Log Entries 20210413-20210419 (provided on April 20, 2021). 4. AREAS OF CONCERN A. Influent channel is a pinch point for flow to the lagoons due to buildup of sludge in the channel. B. Oil sheen observed in the clarifier effluent in both sides of the SWTP. C. Algae on weirs on the Cold Mill side of the SWTP. D. Temperature readout on the auto-sampler at Outfall 001 is out of range. 7 5. LIST OF ATTACHMENTS Cleveland Cliffs Burns Harbor April 19, 2021 A) Photolog B) 2020-12-23 - WWTP Lagoon Hydrographic Survey C) Preliminary Pilot with Field Data. D) Outfall 001 Log entries. 8 ATTACHMENT A Attachment A - Photolog Cleveland Cliffs Burns Harbor - Inspection April 19, 2021 Photo taken by Nick Ream, IDEM Wastewater Inspector Description: Area near the cooling towers. Location: Near the Cooling Towers Camera Direction: Southwest Date/Time: April 19, 2021 / Approximately 11:50 A.M. The remaining photos were taken by EPA inspector, Joan Rogers, with an Olympus Tough TG-4 camera. 1: P4190001 Description: Outfall 111 is an internal outfall for Hi-Cap Thickener and RSB Thickener effluent flows. Location: Near the BFRS Camera Direction: Down Date/Time: April 19, 2021 / 12:01 A.M. 2: P4190002 Description: Deerfield Retention Basin was designed for leachate for the 75-acre landfill. Location: South of the Deerfield Landfill. Camera Direction: Southeast Date/Time: April 19, 2021 / 12:36 P.M. Page 2 Cleveland Cliffs Burns Harbor April 19, 2021 3: P4190003 Description: Deerfield Retention Basin. Location: South of the Deerfield Landfill. Camera Direction: South Date/Time: April 19, 2021 / 12:36 P.M. 4: P4190004 Description: Deerfield Retention Basin. Location: South of the Deerfield Landfill. Camera Direction: Southwest Date/Time: April 19, 2021 / 12:36 P.M. Page 3 Cleveland Cliffs Burns Harbor April 19, 2021 5: P4190005 Description: Pump station for the leachate from the Deerfield Landfill to the Deerfield Retention Basin. Location: South of the Deerfield Landfill. Camera Direction: Northeast Date/Time: April 19, 2021 / 12:39 P.M. 6: P4190006 Description: Oil sheen observed on the effluent from the claifiers in the Cold Mill side of the SWTP. Location: Clarifier in the Cold Mill side of the SWTP. Camera Direction: Down Date/Time: April 19, 2021 / 1:37 P.M. Page 4 Cleveland Cliffs Burns Harbor April 19, 2021 7: P4190007 Description: Clarifier is empty for cleaning. Note the build-up of sludge in the corners of the clarifier. This is a typical problem for square clarifiers, according to CCBH operator, Mr. Balunda. Location: Clarifier in the Cold Mill side of the SWTP. Camera Direction: North Date/Time: April 19, 2021 / 1:38 P.M. 8: P4190008 Description: There was vegetative growth on the weirs of the clarifiers in the Cold Mill side of the SWTP. Location: Cold Mill side of the SWTP. Camera Direction: West Date/Time: April 19, 2021 / 1:41 P.M. Page 5 Cleveland Cliffs Burns Harbor April 19, 2021 9: P4190009 Description: Readout of the auto-sampler at Outfall 001 shows that the internal temperature is -0.5. Location: Inside the sample building at Outfall 001. Date/Time: April 19, 2021 / 2:48 P.M. 10: P4190010 Description: Duplicate photo of the readout of the auto-sampler at Outfall 001 shows that the internal temperature is -0.5. Location: Inside the sample building at Outfall 001. Date/Time: April 19, 2021 / 2:48 P.M. Page 6 Cleveland Cliffs Burns Harbor April 19, 2021 ATTACHMENT B Indiana 2 4 9 S tRaatmepR o a d Westbound U.S. Highway 12 Eastbound U.S. Highway 12 Influent Cell 1 Cell 2 Effluent Sediment Volumes 2020 vs. Design 12,355 CYD 2020 vs. 2012 1,419 CYD 2020 vs. Design 46,812 CYD 2020 vs. 2012 23,207 CYD 2020 vs. Design 51,650 CYD 2020 vs. 2012 29,978 CYD 2020 vs. Design 1,929 CYD 2020 vs. 2012 173 CYD Influent Cell 1 Cell 2 Effluent Water Volumes Water Elev. vs 2020 Water Elev. vs 2012 Water Elev. vs Design Water Elev. vs 2020 Water Elev. vs 2012 Water Elev. vs Design Water Elev. vs 2020 Water Elev. vs 2012 Water Elev. vs Design Water Elev. vs 2020 Water Elev. vs 2012 Water Elev. vs Design 8,421 CYD 12,271 CYD 37,887 CYD 150,524 CYD 174,777 CYD 210,619 CYD 148,813 CYD 179,735 CYD 219,697 CYD 3,273 CYD 3,491 CYD 6,298 CYD DL Z DLZ INDUSTRIAL, LLC Indiana 2 4 9 S tRaatmepR o a d Westbound U.S. Highway 12 Eastbound U.S. Highway 12 DL Z DLZ INDUSTRIAL, LLC ATTACHMENT C Attachment C ATTACHMENT D Attachment D