Document mOeBwbwk8jJVnDdRG0zYRqgg

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW ATLANTA, GEORGIA 30303-3104 ELECTRONIC MAIL CONFIRMATION OF RECEIPT REQUESTED Mr. Stan Atkins Steel Dynamics Inc. 1945 Airport Road Columbus, Mississippi 39701 Email: stan.atkins@steeldynamics.com Re: Compliance Evaluation Inspection Steel Dynamics Columbus MS Wastewater Treatment Facility National Pollutant Discharge Elimination System Permit No.: MS0059994 Dear Mr. Atkins: The U.S. Environmental Protection Agency Region 4 and the Mississippi Department of Environment Quality (MDEQ) conducted a Compliance Evaluation Inspection (CEI) of the above Wastewater Treatment Facility on June 8, 2022. Enclosed are the CEI report and photographs taken during the CEI. The EPA's inspection noted concerns as outlined in the enclosed CEI report. If you have specific questions regarding this CEI, please contact Mr. Richard Elliott, of my staff, at (404) 562-8691 or via email at elliott.richard@epa.gov. Sincerely, Digitally signed by Castillo, Jairo Date: 2022.08.10 12:24:34 Castillo, Jairo -04'00' Jairo Castillo, P.E., Chief Wastewater Enforcement Section Water Enforcement Branch Enclosure cc: Michelle Clark Mississippi Department of Environment Quality Email: MRClark@mdeq.ms.gov UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 4 Enforcement and Compliance Assurance Division Water Enforcement Branch 61 Forsyth Street, SW Atlanta, Georgia 30303 COMPLIANCE EVALUATION INSPECTION REPORT Steel Dynamics, Inc. WWTF 1945 Airport Road Columbus, Mississippi 39701 NPDES Permit No. MS0059994 Facility Address: 1945 Airport Road Columbus, Mississippi 39701 Inspection Date: June 08, 2022 Inspectors: Richard Elliott, P.E., Environmental Engineer, EPA Region 4 Tristan Odekirk, Environmental Engineer, EPA Region 4 Ronald Patton, MDEQ Inspection Report Prepared by: Richard Elliott, P.E. July 26, 2022 Project ID: CV- MS-0059994-06-08-2022 COMPLIANCE EVALUATION INSPECTION REPORT Steel Dynamics, Inc. Title and Approval Signature Page Title: Compliance Evaluation Inspection Report Steel Dynamics, Inc. Columbus, MS Enforcement Officer: RICHARD ELLIOTT Digitally signed by RICHARD ELLIOTT Date: 2022.08.10 12:59:41 -04'00' Richard Elliott, P.E., Environmental Engineer Date Wastewater Enforcement Section Water Enforcement Branch Approving Official: Digitally signed by Castillo, Castillo, Jairo Date: 2022.08.10 12:24:03 Jairo -04'00' Jairo Castillo, P.E., Chief Date Wastewater Enforcement Section Water Enforcement Branch 1 COMPLIANCE EVALUATION INSPECTION REPORT Steel Dynamics, Inc. Compliance Evaluation Inspection Steel Dynamics, Inc. Columbus, MS NPDES Permit No. MS0059994 I. INTRODUCTION On June 8, 2022, representatives from the United States Environmental Protection Agency, Region 4, and representatives from the Mississippi Department of Environment Quality (MDEQ) conducted a Compliance Evaluation Inspection (CEI) of Steel Dynamics Inc., Wastewater Treatment Facility (WWTF). The purpose of the CEI was to evaluate the facility's compliance with its National Pollutant Discharge Elimination System (NPDES) permit and to inspect the wastewater infrastructure at the facility. The inspection was conducted under the authority of Section 308 of the Clean Water Act (CWA), as amended. This narrative report presents the results of the inspection. The following people were present at this inspection: Name Richard Elliott Tristan Odekirk Ronald Patton Stan Atkins Anna Chappell Organization/Title US EPA/Inspector US EPA/Inspector MDEQ/Inspector Steel Dynamics Steel Dynamics Telephone 404-562-8691 404-562-9295 601-961-5522 662-245-4242 662-245-4262 II. INSPECTION PROCEDURES This facility was targeted for inspection because it has had multiple NPDES effluent exceedances in the last 12 quarters. Specifically, the facility was found to be in Significant NonCompliance (SNC) for the following effluent parameters: Copper, Cyanide, Iron, and Oil & grease. The overall objective of this CEI was to evaluate the cause(s) of these violations and to evaluate compliance with the other requirements of the NPDES Permit. Specific tasks included conducting interviews with the operators, reviewing facility records, and conducting a site visit of the treatment facility. III. FACILITY DESCRIPTION Steel Dynamics is one of the largest domestic steel producers and metal recyclers in the United States. The Columbus, MS operations is part of the company's flat rolled division producing 2 COMPLIANCE EVALUATION INSPECTION REPORT Steel Dynamics, Inc. rolled and coated sheet steel. The WWTF combines acidic process wastewater with cooling water that has had direct contact with product or machinery during the manufacturing process. The combined effluent is equalized, neutralized by the addition caustic soda and clarified before discharge to a holding pond. The process utilizes four Equalization tanks, two Neutralization tanks and three 40-ft diameter clarifiers. Effluent pH is controlled during treatment and synthetic polymers are used to aid settling and metal precipitation. A Dissolved Air Floatation (DAF) separator is used to treat wastewater from a separate manufacturing area that produces coated steel. Effluent from the DAF is combined with acidic and direct contact wastewater in an equalization tank. DAF effluent is then treated as described above before discharge. Final effluent from the pond is discharged into an unnamed tributary to Gilmer Creek. The facility is permitted under the NPDES permit number MS0059994. IV. FIELD EVALUATION 1. Permit The NPDES permit became effective on April 01, 2022, and expires on March 31, 2027. The WWTF does not have a flow permit limit. The facility treats 45 to 60 Gallons per Minute of wastewater. The amount of wastewater treated depends on how much raw material the plant is processing. 2. Records/Reports Monthly Operating Reports (MORs) and Discharge Monitoring Reports (DMRs) and records for several months in 2022 were checked for agreement with NPDES self-monitoring program requirements regarding sampling documentation, equipment calibration, and reporting of parameter concentrations and loadings. The self-monitoring records, including the chain of custody records, calibration sheets, laboratory bench sheets, and commercial laboratory results, were maintained for a minimum of three years. Spot checking of NPDES monitoring data elements was conducted and the data reviewed was found to be consistent and accurately reported. 3. Operation & Maintenance The WWTF is staffed 24 hours per day for seven (7) days per week. The operators work on shifts to operate the WWTF. Routine maintenance of the facility is conducted by plant personnel, but specialized maintenance is done by contractors as needed. Polymers are added to the wastewater to enhance flocculation and settling. Wastewater is clarified and the sludge formed is processed by a plate-press before being hauled to a landfill for disposal. Effluent from the clarifier is further treated in lagoons before being discharged to the receiving stream. The facility has had difficulties meeting permit limits for Copper and Iron. 3 COMPLIANCE EVALUATION INSPECTION REPORT Steel Dynamics, Inc. 4. Sludge Handling The WWTF utilizes a press to reduce the water content of the sludge that is removed from the bottom of the clarifiers. Effluent from the filter press is returned to the beginning of the treatment process and the solids are hauled to the County landfill. 5. Sampling/Laboratory All NPDES required samples are collected by a contractor including in-situ testing, calibration and recording. All laboratory analyses are conducted by a commercial laboratory. The facility collects samples according to the sampling frequencies and sample type described in the permit. The contract laboratory collected samples at the required frequency. Composite samples are collected for Chromium, Copper, Cyanide, Iron, Lead, Zinc and Total Suspended Solids (TSS) analyses. Grab samples are collected for pH, Naphthalene, Oil & Grease and Tetrachloroethylene analyses. Calibration logs of instruments used for in-situ testing are maintained. All NPDES test methods conformed to 40 CFR 136 according to the commercial laboratory results. This facility will likely experience continued difficulties in consistently meeting effluent limits without significant improvements. The commercial laboratory is: Waypoint Analytical Laboratory 235 Highpoint Dr Ridgeland, MS 39157 601.957.2676 This commercial laboratory was not evaluated. 6. Flow Measurement The daily flow from the WWTF varies depending on production at the facility. The facility has the capacity to treat 45 to 60 Gallons per Minute. There is no flow limit in the permit. Flow from the facility is measured at the outfall using a Parshall flume and ultrasonic depth measure meter. 4 COMPLIANCE EVALUATION INSPECTION REPORT Steel Dynamics, Inc. 7. Effluent and Receiving Waters The final effluent was free of floating solids, visible sheen and other debris. Slight foaming was observed at the discharge point. The receiving water was not observed due to inaccessibility at the time of inspection. V. RECOMMENDATIONS a. The facility should consider hiring an outside contractor to investigate and ascertain the reason for the Copper and Iron effluent limit exceedances. b. The facility should consider installing additional tankage to provide redundancy in clarification and neutralization processes. Figure 1: Left - Pond & discharge weir. Right - Effluent from Pond prior to flow measurement. End of Report 5