ML20059J108

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Trip Rept of 931012 Visit to Auburn Steel Co,Ny to Gain Mgt Perspectives of Problem of Radioactive Matl in Metal Scrap
ML20059J108
Person / Time
Issue date: 11/01/1993
From: Lubenau J
NRC COMMISSION (OCM)
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NRC COMMISSION (OCM)
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ML20059J105 List:
References
NUDOCS 9311120028
Download: ML20059J108 (48)


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UNITED STATES :

NUCLEAR REGULATORY COMMISSION :

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WASHIN GTON, D.C. 20555

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. OF FICE OF THE COMSSIONER

. November 1, 1993

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TO:

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THRU:

Eileen McKenna FROM:

Joel O. Lubenau RE:

Trip Report

. VYsit to Auburn Steel Co., Auburn, NY

SUMMARY

On October 12, 1993 I visited _the Auburn Steel Co.

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"minimill" in Auburn, NY.

The Auburn mill had. incurred the first reported smelting of 'a radioactive source by a steel mill (in 1983) and had a repeat event in 1993.

Given their unique-experience coupled with a demonstrated willingness to share information, I

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visited the mill to gain management's perspectives of the problem of radioactive material in metal scrap.

The' visit, while touching on a-numoer of aspects of the problem focussed ' on preventing radioactive materials from being smelted and the costs resulting_

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from accidental smelting of a source (see October 4, 1993.Lubenau.

to Dacey letter, attachment 1).

Some key findings resulting from i

t the visit were:

l o The 1983 smelting involved 25 Ci of Co-60.

All of the'

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radioactive waste from that incident was disposed of at the Barnwell, SC LLW ' site.

Decontamination;and disposal costs totalled $4.4 million.

o The 1993 smelting involved 1 Ci of.Cs-137.

Under.1993 l

environmental' regulations much of the waste from this incident

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t (primarily 550 to 600 tons of fluedust) is classified as mixed waste.

Various treatment and. disposal' options are under study.

The decontamination, treatment ~ and disposal costs 'for-l this event are likely to range from $5 to 6 million for the most favorable scenario (treatment and partial-recycling off the fluedustiplus disposal) to $8'to $10 million for the worst-scenario-(disposal only).

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  • the cost of the 1983 smeltina is added to the estimated costNhf' the 1995 emeltina, the total, $9.4 to $14.4 million is-

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2 to'3-B=== *ha'=nnualized capital investment in the plant.

-l The cost consecuence of the 1993 event will be 5 to 10% of the i

annual revenues for the olant'.

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o The Cs-137 source passed undetected through an advanced radiation monitoring system installed in 1989 at.the plant's 4

weigh station.

It has since been upgraded to a current state-:

of-the-art model and a second unit will'be' installed atsthe~

l charge bucket loading ' station.

Beginning' January;1, 1994, Auburn Steel Co. will accept only scrap which the supplier 9311120028 931103-PDR COMMS NRCC CDRRESPONDENCE PDR

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certifies has been monitored for radioactivity.

I o Auburn officials estimate that only 50% of the_ US steel mills monitor their scrap for radioactivity and the percentage

-l for scrap processors is less than 50%.

Awareness of the problem in the steel industry is uneven.

Relevant technical information is not always readily available.

For these i

reasons Auburn Steel Co. management strongly recommended that j

NRC sponsor a national workshop / seminar for-industry managers on the problem of radioactive materials in metal scrap.

'I DISCUSSION:

The Auburn Steel Co. Inc. steel plant is located.in northern Auburn on York Street west of State Route 34.

Management representatives for the meeting were James A.

Dacey, General-Manager / Industrial Relations and Thomas E. Crawford, Manager / Safety I

& Personnel Services.

The plant has one electric arc furnace (EAF) l having a 65 ton capacity.

Construction of the plant began in 1973.

l The original capital cost was $21 million.2 The~ plant produces j

360,000 tons annually consisting of various small shapes including flats, bars, reinforcing bar, squares, rounds, angles and channels-

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in a variety of chemistry grades (attachment 2).

The plant employs about 300 persons.

Auburn Steel Co. also operates a steel mill.in-l Newport, AR and has plans to acquire a mill in Lemont, IL.

j The plant consumes about 375,000 tons of steel scrap annually, i

Steel scrap is supplied from about 100 suppliers on.the east coast.

A variety of types is purchased; the primary form is a modified #1 l

melt.

Scrap arrives by truck and passes through an Exploranium scrap monitoring system located at the weigh scale.

The unit was installed in 1989 and originally was a model 520.

Since the 1993 event, the unit was upgraded to a model 526.2 An additional'model 526 is being installed by the charge bucket loading station.

Effective January 1, 1994, suppliers selling scrap steel to Auburn.

a must certify that their scrap was monitored for radioactivity.

It is anticipated that this will add about 1 to 3% to the cost of the j

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scrap.

Auburn plans to institute a program to inspect suppliers who provide certification.

The original model 520 had a total down time of about 2 - 3 days.

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2The Auburn mill was one of the earlier minimills and one of i

i the first in the US using continuous casting technology.

Auburn j

has since invested about three times the original cost of the plant i

in improvements.

The total plant investment, $21 + (3 x 21) or $84 ll million over 20 years represents an annual plant investment of $4.2

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million (taking no account of inflation).

Therefore, the cost of the 1983 smeltina exceeded the annualized plant investment cost and-the cost of the 1993 smeltino may be more than twice as larce.

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The vendor claims for the model 526 the ability to detect a' 2

source contributing a radiation level of 0.001 mR/hr on the outside of a scrap carrying vehicle with a 99.'9% probability (see j

attachment 3).

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- Auburn personnel periodically independently check the monitor's.

. performance with an 8 microcurie Cs-137 source.

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'.The. false-alarm rate forthe 500 was.about.0.1%

It is higher with'the 526 but this is decreasing as experience is. gained.. The: 526 has' two active monitoring circuits. Under normal circumstances, they alternate in.-

use.

If one~ malfunctions, then'the unit' operates on the second.

Both circuits-are monitored by the vendor by.a telephone link to-the vendor's headquarter's office.

Auburn also monitors the samples :taken during ' melts' for radioactivity by surveying the solidified, cooled sample with a bench GM monitor.

This technique is suitable only for radioactive materials that alloy with the steel ( e. g -., co-60, but.not Cs-137) and is relatively insensitive.

There are no indications that the model--520 was not performing'as required in the time frame that-the Cs-137.' source passed through.

Plant officials have concluded that a unique combination of heavy source housing and surrounding scrap provided sufficient shielding to prevent detection.

The smelting was discovered wh~n e

contaminated fluedust being shipped ' to a recycler triggered _ the ;

monitor's alarm. As a protective measure taken af ter the discovery of the smelting, Auburn reloaded 21,000 tons of on-site scrap onto trucks and passed the scrap through the monitors again. No sources were found.

As a result of the smelting, Auburn accumulated between-550 to 600-tons of contaminated fluedust.

Specific activity ranges from 48,000 to less than 0.1 pCi/gm (see attachment 4 for results of-analysis of individual containers of fluedust).

Since the NRC determination that fluedust containing less than 2 pCi/gm could be handled without regard to its radioactivity, Auburn has been segregating

<2 pCi/gm fluedust ' for recycling.

The remainder remains in storage in a fenced, -locked, placarded area on the plant site.

Following the original smelting, Auburn shutdown.the melt shop for 17 days beginning on May 31, 1993 and commenced decontamination operations.

Afterwards, however, Auburn continued to generate fluedust containing Cs-137 at-levels above the 2 pCi/gm cutoff.

Auburn eventually deduced that there was residual Cs-137 in the EAF refractory brick which was bleeding out.

The EAF was rebricked in-July, 1993:. and. this solved the problem, -but. another 100 tons of contaminated fluedust was produced in the interval between the melt shop decontamination and the rebricking of the EAF.

Auburn officials subsequently learned that the NUCOR plant in Utah has discovered this phenomenon as a result of their 1990 smelting. Had Auburn known this,.they could have avoided generating 100 tons of fluedust and the associated costs of disposing of it.

Auburn officials cite this a s' an example of why better' communications

' Included were 4 or 5 cases where drivers' of the vehicles had undergone nuclear medicine procedures and triggered the alarm.

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within the metal recycling and steel' mill industries is needed.

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Another example was provided to illustrate the need for

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disseminating technical information. Auburn uses isetope gauges as

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part of the process control equipment for the continuous caster, specifically, to measure the level of the molten steel bath in the molds.

In the event of a " breakout" of molten steel, the gauge housings 'would be subject to damage, specifically, melting.and flowing of the lead shielding.

Cases like this have occurred.

Auburn learned that their gauge vendor, KayRay, can now supply

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source housing containing a tungsten alloy in lieu of' lead.

The former melts at 2,800 degrees F,

which 'is above the steel

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temperature and is therefore a preferred shielding material.

However, the gauge vendor does not advertise to its customers the

-l availability of this material to upgrade existing gauges.

l Auburn stated that they are not members of the Institute of Scrap i

Recycling Industries, Inc.

(ISRI).

They acknowledged that ISRI educational efforts have been excellent but believed that their effect is limited because few steel mills and not all scrap processors are members of ISRI.

The Steel Manufacturers Association could be influential, but' Auburn does not believe that all steel mills were members.

It was agreed that: many scrap

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suppliers are not members of either organization. Consequently, in their view, relying on industry trade organizations to-" spread the message" on the radioactivity problem will not lead to great success.

They strongly recommended that NRC sponsor a national workshop or seminar to provide' a means for enhancing awareness and l

for exchanging technical information.

Auburn suggested that the representatives of the mills and scrap processors be from management.

j Auburn is exploring a variety of options for disposal of the i

fluedust that. exceeds 2 pCi/gm.

Fluedust can be recycled to l

recover iron, zine and other recoverables.

Oregon Steel Mills,

-j Inc. has developed an alternative recycling process which consists j

of glassifying fluedust into

a. product that can be used as a substitute for mineral powders (attachment 5).

For Auburn to i

recycle contaminated fluedust, it must reduce the concentration to l

2pci/gm.

If this cannot be done, it could be disposed of at Clive, UT LLW site, however, the concentration of Cs-137 must be

<560 pCi/gm.

If this cannot be done, disposal at the Barnwell, SC LLW site must be done.

To dispose of the fluedust at either of the LLW sites will require converting the fluedust to an acceptable i

form. The conversion process will increase the volume of the waste

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by 30% and may have to be performed at the Auburn plant site.

The

-i conversion process will increase the volume of the waste by 30%.

a If all of the dust > 2 pCi/gm had to be disposed of at Barnwell,

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then the cost is estimated to be between $ 8 and 10 million.

If 90 i

to 95% of the fluedust can meet the Clive, UT LLW site cutoff of 560 pCi/gm, the cost for this disposal option would be between $ 5 to 6 million.

Auburn is negotiating with several companies for

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i proposals.to decontaminate the fluedust.'

Mills ' and scrap - processors that detect and. recover radioactive-sources are faced with disposal ' costs'for the sources, which may be as much as $10,000' unless the original: owners can1. be traced.

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Although. this is the environmentally correct solution, Auburn <

officials expressed concern that they must bear. the cost and asked if other solutions could be found?

Auburn officials praised the heads of.the New York l>epartment of.

Labor and the Department of.. Environmental - Conservation radiation-

. control programs, Rita Aldrich and Paul Merges, for their technical-knowledge and expertise and their assistance to Auburn to address the radiological and regulatory problems. The NRC determination of the 2 pCi/gm levels for allowing recycling'or_other. disposal of fluedust was an initial, helpful government action at the federal' level.

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  • Presumably, the problems associated with disposal of the-contaminated fluedust that confront Auburn are_also~being faced by the other US steel mills that'have smelted Cs-137 sources since 1984 (see Table 1).

Assuming similar costs at these.other mills, this means that these smeltings will collectively cost-the US steel i

making industry between S.55.to 110 million.

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Table.1

l Documented U S.

Smeltings of Radioactive Sources h

Year Metal Facility, State IsotoDe GBc Decon $M L

1 Au unknown, NY RaDEF unk

'unk 2

83 Au unknown, NY

"*Am unk unk 3

83 Fe Auburn Steel, NY "Co 930 4.4 4

84 Fe US Pipe & Foundry,AL 22'Cs 0.37-1.9 0.6 5

85 Fe TAMCO, CA 2Cs

'56 1.5 I

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87 Fe Florida Steel, TN 2Cs 0.93 0.2*

7 87 Al United Tech,IN 22'Ra 0.74 0.5 8

88 Pb ALCO Pacific, CA 2Cs 0.74-0.93' O.2*

9 88 Cu Warrington, MO Accel unk unk 10 89 Fe Bayou Steel, LA 2Cs 19 0.05*

11 89 Fe Cytemp Spec, PA Th unk 0.1 12 90 Fe NUCOR, UT 1Cs unk 2.0 13 92 Fe Newport Steel., KY 22'Cs 12 1.0*

14 92 Al Reynolds, VA 22'Ra unk unk 15 92 Fe Border Steel, TX 2Cs 4.6-7.4 0*

16 92 Fe

-Keystone Wire, IL 2Cs unk 2.3*

17 93 Fe Auburn Steel, NY 22'Cs 37 5 - 10 18 93 Fe Newport Steel, KY 2Cs 7.4 unk i

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19 93 Fe Chaparral Steel, TX 22'Cs unk unk 20**

93 Zn Southern Zinc, GA DU unk.

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Notes

-# Multiple cases have been reported. - The earliest occurred about 1937.

  • Does not' include' costs'of disposal'of LLW.
    • Pending confirmation.

10/25/93

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UNITED STATES

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g c9 NUCLEAR REGULATORY COMMISSION r,;

y WASHINGTON. D.C. 20555

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OFFICE OF THE c uurss ONen October 4, 1993 James A.

Dacey Manager - Personnel Auburn Steel Company P.O.

Box 2008 Auburn, NY 13021

Dear y:

My plans for visiting Auburn Steel have solidified.

Unfortunately, following the visit I must return to Washington, so it won't be possible for me to move on and visit some of the other steel mills that recently smelted radioactive sources.

Nonetheless, I think the visic to Auburn Steel could be very helpful to gain a better understanding of the impacts upon mills resulting from such experiences.

I expect to arrive in Auburn late Monday afternoon, Oct. 11, 1993 by rental car from the Syracuse airport.

I will be happy to meet you at the plant as early as you like on Tuesday morning.

I will be staying at the Auburn Day's Inn and messages for me can be left there.

My itinerary calls for my returning via a 4:45 pm flight from the Syracuse airport.

As a courtesy, I informed Rita Aldrich of the New York Department of Labor Radiological Health Unit of my visit. She indicated that she would like to attend.

If time permits, and if it is convenient for Auburn staff, I would appreciate a tour of the plant, at least of those portions of plant operations dealing with radiation monitoring of incoming scrap.

As I indicated in our telephone conversation, Jim Yusko and I realize that our estimates of cost impacts seriously underreport the real costs.

In most cases, the figures that we have reported reflect decontamination costs only.

The costs of disposal options for the contaminated fluedust and other materials and other costs such as losses resulting from shutdown during decontamination have not been included.

Jim and I would grateful for information that Auburn Steel Co. can share that would permit us to construct a more a realistic description of the national impact of_this problem upon the industry.

Given that there have been 13 recorded smeltings involving US steel mills, the national cost is likely to be significant and we should try.to get a handle on it.

I also would like to discuss what can or should be done to increase industry awareness of the problem and enhancing protective measures.

For example, from a technical point of view, radiation monitoring of incoming scrap at a mill is the least desirable place to monitor for radioactivity because the scrap arrives in large volumes and in relatively dense form.

Both of these attributes contribute to the shielding that can prevent detection of a source.

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Additional radiation monitoring of scrap upstream of the mill would make better sense,'for example at scrap processers whose incoming scrap arrives in smal?.er volumes and more loose form.

How can this be encouraged?

Lastly, I would be happy to serve as sounding board (or messenger) for ideas, suggestions or concerns-that Auburn Steel Co.

representatives: may have that could help address this problem.

I look forward to seeing you on Tuesday morning.

Sincerely, 4

oel O.

Lubenau, CHP Technical Assistant to Commissioner E. Gail de Planque cc: JYusko RAldrich

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Persons you might like to meet AUSTEEL Memorable Events:

1993 KOJU e ANGAi Ground Breaking WILUAM J. HUMEs, JR June 24,1973 Pressdent oAVID E. BLACKWELL First Tapping Of Electric Furnace Exec. Vice President May 30,1975 MARTIN E. FANNING sener Vice President First Rolling Of Steel HisA uMl,,(E J May 20,1976 MA v e.

.s secretary / Treasurer 4,000,000 Ton Shipped JOHN A. ROSsl vice President - Operatens March 12,1993 Seeing t< morrow, innovating today T,Z (or quality and produClivity.

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FacAties Planrung. OA & Production Pianrung This is how over 300,000 tons of GNrNManahdies quality-Austeel Steel is created each year.

Austeel creates a variety of products in Aubum Steel Company, better known as nearly 120 sizes. Available as Merchant Bar SALES DEPARTMENT vic Mowischan - Distoct Manager -

Austeel, has had a singular purpose ever since Ouality (MBO) and Special Bar Quality New England Temtory the day we were founded in 1973: To provide (SBO), these products include *-

Jerry Re.ards - District Manager -

high quality steel for our custoiners. We've

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consistently achieved that goal, and we're

  • Reinforcing Bars g,,,

g Westem Temtory committed to continuing our success.

  • Rounds Ken Walls -

t Manager -

Using the most advanced steel making

. Squares equipment and technology ava.7lable, Austeel

  • FMs sharon Faneliv - Manager -

inside sales has met the steel needs of a diverse customer sales conespondents-Mary caster base for more than two decades.

  • Angfes Tern scoltan
  • Channels sam Thomas After the segregated steel scrap is selected and GARY s CALDWELL weighed, our modem 70 ton electric arc furnace
  • Customer Special Sections General Manager - Purchas6ng rapidly melts and prepares it inr refining.

JAMES A. CHARLTON General Manager - Accounting & Assistant Treasurer During the refining process, various additives Ou r chemistry grades ( ASTM /AISI/CSA) a re:

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N,$r# IMger-industrialRelations am jtrodu P P

  • Carbon Grades 1008 to 1095 era 9,d y

rthe ce ana - FacAties Planning. OA eventual end use. Our Quality Assurance

  • High Strength low Alloy (HSLA)

CHR s

& Production [ tanning laboratory is equipped with the finest

  • Alloy Grades ROM COLELLA technological instrumentation Currently available,

, Boron Steels Am@ CW all operatad by skilled, trained exports.

  • ASTM Bar Size Structural Grades THOMAS CRAWFORD Manager - safety & Personal services The molten steelis then transported to Austeel's
  • Customer Specifications E. R HAR FR "

curved mold caster. This modern caster pe n, n - Maintenance Produces billets, which continue on to our rolling THOMAS L. HuGHEs Manager - Credit mill to be reheated and rolled.

Auburn Steel Company, Inc.

  1. N"intendent - noning Ma Then it's cut to length, automatically stacked and P.O. Box 2008 DERNARD MEADE neatly but,ded. After a finalinspection,it's

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Manager -information systems marked for shipment to the Austeel customer.

Quarry Road MAsAKI(MAsA) sAsAMOTO Auburn, New Yorg 13021 Manager - Corporate Planning & Assistant secretary Our wide variety of steel products finds its way RIC W s0 into the metal fabricating and forging industries, Phone: 315-253-4561 t I t

nd ing bar Toll Free: 1-800-424-1494 EARL WOKuTCH fabricators across America and Canada who Manager-Warehouse & shipping MAsAMI (MITCH) YOKOYAMA demand Consistently excellent quality steel.

Fax: 315-253-5377 Tae6,e.e st Aetoierw

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EXPLORANIUM j

Radiation Detection Systems i

Rad'oactive l

Scrap Stops Here.

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Problem:

Radioactive Sources in Scrap Metal

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j Highly rad;cactNe sources encased in meta! shieids are in widescread use in industrial applications throughout the P

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worid, w:th an estimated 600.000 in North Amenca alone.

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j Dumg the past decade there have been numerous i

incidents where inese shielced sources have been l

acodenta!!y mixed rn with scrap meta!, and have j

suDseQuently been meted or ruptured in the steel maxing process. Most of these incidents nave resu!!ed in significant l

leve!s of radroadve contamination with the attendant nsks f

to emDoyees and the general pubirc. C;ean-up costs g

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j resuting from such incioents have ranged as hign as 1

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severai mMon Collars.

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In 1987, in order to prevent j

I tnese expensNe and a

potentia"y dangerous accidents, gg i

Expioranium developed the first of its rad:ation 4

detection systems designed soecifically to detect the presence of sn,eieed sources deepty buried in scraa.

l Since the introduction of this first system, Exploranium has 1

conducted extens ve Researon and Development worx to l

'urther cereico the product line to satisfy the demancing

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l reoutrements of the steelindustry.

l Based on this deveicoment actvty and the expenence j

4 gained from workang with customers throughout the world, Exotoranium nas acneved a major milestone in developing l

the GR 526 wnch incorporates the hignest level of l

sens:tyty, ease of operation and system reliability acnevable.

High Sensitivity To illustrate the importance of high sensit' iy of the M

detection system, the diagram shows a typicaj radioactve source buried in a load of scrap steel producing an exposure rate of 13,500 (mR/hr) inside the lead shield.

The exposure rate at the outside i

Oursee Source 7 surface of the shield of 2.5 mR/hr is i

further reduced by the scrap metal and '

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Oursce of PSde Source mR/hr on the outside of the venicle.

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The GR-526 will detect such a source,

' buried anywhere in the scrap vah a

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{ probabilityof 99.9% -

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The GR-526 u

2 Radiation Detection System I

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The GR-526 Radiaton Detecton System reoresents a u..

3 major tecnnologcal advance in ncreased senstvity of

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j rad:aton Oetecton systems for the steel ocustry.

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d This camaDc improvement in sensrtMry has been achieved

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througn tne apolicaton of very advanced electronic circuit j

designs and unrQue electronic anafys!s techncues enacing 1

the aetecton of extremeh low levels of radioactMty, wn6e GR-526 f

virtua!!y eirminating false alarms.

System Console i

The pnncoa! components of the GR-526 system are ine t

system conscie and two cetector assemblies. These The system conso4e collects Gamma-ray informaton from 4

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assemches conta n large poly.nnyttoluene detectors wnch the detectors, anc displays it on a bnght graphics disotay 1

i capture the Gamma-rays em:tted by a radroactive source showing Dackground radiation levels, system parameters i

buned in the scrao !f the system cetermres that a source ano ala m informaton. When a radcactve source is a

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of radcacivity is present, an audio atarm sounds and tne cetected. aucc and visual a! arms alert the operator, i

a:am' informaton :s c: splayed on the console.

A pnnter to provce hard coo!es of alarm information, and 4

The cetector assemblies are normally located on the a modem to enacle remote ma nienance support are i

inooand approach to a wegh scale. Arthough other otecra! parts of the console. The conscie also performs 4

j locatons are feasible, tne estanaton of the detectors continuous interneJ system d:agnos:s, and in the event of a immeciatery n front of the sca:e provices the maximum fault, the system alerts the operator while contnuing to i

i protecton to workers, and also the best opportunity to provide a hgn level of operational capabMy using duplcate 1

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reject tne scrao before 4 enters the site.

components cesgned into :ne sistem.

i Whde tne onnccai aceticaton of the GR-526 is the t

a monitonng of trucks and railcars for sheeiced sources. the versatihty of the system makes it equally acaptable to I

a monitonng of charge buckets.

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i Ease of 2eeee I

Operation 1I'T2 Ease of operaton was a major consideration n the l

i cesign of ine GR-526 system. When the system i

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l ceterm:nes that a racioactve source s present, audio O

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anc visual a. arms are acwated, and deta:ied a: arm System Ready

-nformaton. including the acorox; mate locaten of the f

source o Ine cac. is c:sotayed. The only ac* ion required oy me coerator :s to cress the ALARM button to s;ience i

tne a:a:m ana to reset the system. The aiam oformation 16:30:45 04 S2/93

s automatcal!y stored in memory for subsecuent 051 lie h i c l a I t1 052 i

retreval, or may oe onnted out automatcalty for eacn a; arm. The operator :s also alerted if a venice 20000 l

Casses the Ce+ectors at an excessive speed.

j f

Tne conscie also performs cont nuous system dGgnosis.

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11916 i

A yeiow STATUS but on flashes wnen the system cetects a fautty component. and signais are re-routed to e

tase advantage of recundant systems designed oto the GR-526. Any system fauts that are oetected are Vehicle In I

c:sp;ayed so that maintenance can be scneduled.

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Alarm Summary i

i

EXPLORANIUM Experanium has speciakzed in the design and manufacture of radcactNe l

[

detecton systems for use in industnal, environmental and geophyscal aoplications

(

jg since 1968. As a result of its reputaton as a leader in low level radiaton I

l measurement. Exploranium was approached by a major steel plant in 1987 to Oevelop a system capable of reliably detming radcac!Ne sources buned in loacs of scrap steel i

l' Snce the introduction of this first system. Evoloranium has become the largest l

suopher of this equipment witn 200 systems going into operat:on dunng the first j

}

fue years of production. Based on ongoing research activey and the expenence i

gained from working with customers in North Amenca. Euroce, and Ase, l

Expioranium nas made a major tecnnoicgcal aavance in the desgn of its latest system, the GR-526. This system incorporates the hghest level of sens;tMty. ease of operaton and system refebihty available for the steel industry.

l Exploranium is a!so a world teacer in airborne surveil lance systems for t' e h

" EA detecton of low level radoactNe rnatenal from fixed wing aircra+t and helicopters.

i j

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= r-The company supphes a full range of other radation monitonng systems for I

i environmental applicatons.

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l Related Product:

~

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GR-110S Portable Radiation Detector i

l The GR-110S portable radeton detector is a compact. Pgntwegnt battery l

Operated instrument desgned to combine maximum sens:tMty with fully automatic j

operaton. The instrument is equipped wah an audo alarm whch indicates the j

strength of radoactve,emissons. The GR-110S also incorporates an easy to i

read dgtal display whch assists in locating radioactue matenalin areas where excessNe noise is a problem.

Thisinstrument is desgned l

for fast and reliable detection of

-.r I

shallow 6y buned radoactive j

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matena!.and is hghty effectue in g.

p g,,

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determining the precise location of e:::c,,re:tdw.id-rr

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the radicactue sou ce after it has l

k been oetected by the GR-526 radeten detecton sys*em.

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Radiation Deteption Systems s

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s EXPLORANIUM 4400 cubc incnes / 72 iitres) i S

Radiation Detection System i1

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  • Single button operator control

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  • Vehcle speed monttonng and alarm 1

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  • 'ndividual venicle alarm ana!ysis j,

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  • Large grapncs display ana pnnter l!

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output to vie'N alarms o

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  • High reliabildy througn advanced i

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design and duplicate electroncs i

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  • Continuous system self-diagnoss ri1
  • Remote servce support via built in modem

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Front Elevation b*

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J Exploranium U.S.A Exploranium Canada 101 Bracford Road 55 Healey Road Wexford. PA 15090 Botton, Ontano L7E 5A2 l

1 i

Tel (412)934-5422 Tel (416) 857-3670 Fax (412)934-3376 Fax (416) 857-3679 f,

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EXPLORANIUM

EXPLORANIUM

~

101 Bradford Roadj Wexford. PA 15090 ~

Radiation Detection Systems Tel: (412) 934-5422 FAX: (412) 934-3376 EXPLORANIUM GR-500 INSTALLATIONS CUSTOMER LOCATION UNITS DATE INSTALLED.

Lasco Steel Whitby, ONT 1:

' October,1988 i

Timken Canton. OH 1.

January,1989 Courtice Cambridge, Ont.

1 August,1988 Armco Kansas City, MO

.1 June,1988 Newport Steel -

Wilder, KY 2

January,1989 -

Lasco Whitby, Ont.

1

. September,1988 -

i Armco-Butler, PA 2

February,;1989 Sheffield Sandsprings, OK 2

December,1988-North Star Steel St. Paul, MN

'2 May,1990-

_ Washington Steel Houston, PA 1

January,1989 Northwestern Steel Sterling, IL 3

. June,1989 Magnimet Monroe, MI 3

. October,1989 Magnimet Toledo, OH 1

September,1990 l

Magnimet Wilton, IA 1

Febmary,1989 North Star Steel

. Wilton, IA 1

February,1989 North Star Steel Youngstown, OH 2

May,1989 North Star Steel Milton, PA 2

North Star Steel Texas 2

August,1989 Timken Canton, OH 3

June,1989:

J&L Midland, PA 2

June,1989

-TAMCO San Diego,'CA

.1 April,1990 Sidbec Dosco Mentreal, Que.

1 July,1989 National Steel G= nite City,IL 2

May,1990 Auburn Auburn, NY 1

November,1989

_Tippins/ Sydney Steel Nova Scotia 2

December,1989

.. -i Empire Detroit Mansfield, OH 2

December,1989 Slater Steel Hamilton, Ont.

2 October,1989 Roanoke Steel Roanoke, VA 1

March,1990 Stelco Hamilton, Ont.

1 November,1989 1

Standard Steel Burnham, PA 1

Febmary,1990

~

Cascade Steel

.L McMinnville, OR 1

November?1990 '

Structural Metals ^

Seguin, TX 1

February,1990-SMI, Inc.

Birmingham, AL 1

Jarinary,1990 !

g Lasco Steel Whitby, ONT '

- 2 March,1990..

ij Luntz ' Corp.

Canton, OH

.1 June,1990

~ Florida Steel Knoxville, TN 1

A'pril,1990 '

Eastern Stainless Baltimore, MD 1

October,1990

.j Ivaco Rolling Milb L' Original, Ont.

-1 April,1990 i

Geneva Steel Provo, UT 1

April,1991_

I Bayou Steel Laplace, LA 3

September,1990

)

^ Sydney Steel Sydney, N.S. July,1990

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INSTALLATIONS:

CUSTOMER LOCATION UNITS DATE INSTALLED Nucor Steel Plymouth, UT 2

July,1990 I

Nucor-Yamato Blythesville, AR 3

August,1990 Nucer Steel Darlington, SC 1

April,1991 Nucor Steel Norfolk, NE 3

February,1991

_Nucor Steel Jewett, TX 2

April,1991 Nucor Steel Crawfordsville,1N 1

March,1991 1

Ellwood-Uddeholm New Castle, PA 2

October,1990 Eastern Stainless Baltimore, MD 1

October,1990 IPSCO Regina, SASK -

2 October,1990

._ Birmingham Steel Jackson, MS 1

March,1991 Birmingham Steel Birmingham, AL 2

December,1991 Birmingham Steel Bourbonnais, IL 2

July,1991 Irish Steel LTD.

County Cork V

1 December,1990 Florida Steel Knoxville, TN 1

December,1990 Nucor-Yamato Blythesville, AK 1

January,1991 Hylsa Monterrey, MX X 2

May,1991

[

Laclede Steel Alton, IL 2

July,1991 f

Harrison Steel Attica, In 1

April,1991 Arkansas Steel Newport, AR 1

August,1991 Atlantic Steel Atlanta, GA 4

August,1991

" United Metals Kernersville, NC 1

October,1991 Salmon Bay Steel Seattle, WA 2

November 1991 Nucor Steel Crawfordsville, IN 1

October,1991 Zubick I & M London, Ont.

1 October,1991 1

_ General Waste Evansville, IN 1

November,1991 Chambers Development Providence, RI 1

October,1991 Chambers Development Charles City, VA 1

November,1991 l

Arkansas Steel Newport, AR 1

August,1991 1

November,1991 l

North Bay Salvage North Bay, Ont.

_ Irish Steel Ltd.

County Cork, Ireland v 1

September,1991 Quebec Metal Recycle Laval, PQ 2

February,1992 Stelco Contreceur, PQ -

1 April,1992 Brenner I & M Winston-Salem, NC 1-March,1992 John Deere Waterloo, IA l'

August,1993 3

,Goldin Industries t '

Gulfport, MS 1

April,1992 i

Goldin Industries Mobile, AL 2

April,- 1992

- Goldin Industries New Orleans, LA 1

April,1992 Suisman-Blumenthal Hartford, CT IL April,1992 Timken Canton, OH 1

March,1992

_ Nucor Steel Hickman, AR 3

June,1992 North Star Steel Beaumont, TX 1

October,1992 FirstMiss Steel Hollsopple, PA 1

April,1992 -

t Borg Compressed Steel Tulsa, OK 1

June,1992 Southern Metals Wilmington, NC 1

July,1992

. Arkansas Steel Newport, AR 1

July,1992Sidbec Feruni Contrecoeur, P.Q. -

1 August,1992

%. i 9 - 3 Ec P, - 8 C4 - 1 i 37 52.

J INSTALLATIONS:.

CUSTOMER.

LOCATION UNITS DATE INSTALLED Dominion Nickel Oakville, Ob T.~.

1 August,1992 i

Western Steel Calgary, ALT. -

1 August,1992 CitiSteel USA Claymont, DE 1

September,1992 Strasser Alloy Steel Burlington, ONT.-

1 October,1992

_ Industrial Metal Spartanburg, SC 1

October,1992 Industrial Metal Greenville, SC 1

November,1992 National Material Serv.

Kankakee,IL 1

November,1992 Birmingham Steel Bourbonnais, IL 2

November,1992 Mississippi Steel Jackson, MS 2

April,1992

_ Salmon Bay Steel Seattle, WA 2-July,1993 Fers et Metaux Rec.

1.a Prairie, P.Q. -

1 December,1992 Fers et Metaux Rec.

Scoudouc, N.B. -

1 January,1993 Hylsa Monterrey, MX

  • 1 December,1992 Copperweld Steel Warren, OH I

January,1993 Luntz Corporation l Warren, OH I

January,1993 Keystone Steel & Wire Peoria, IL 4

February,1993 Birmingham Steel Birmingham, AL 1

June,1993 -

Ferrous Processing Detroit, MI 4

April,1993 Irish Steel Ltd.

County Cork 1

August,1993 v

,0cean States Steel Providence, RI 1

June,1993 Armco Steel Kansas City, MO 1

May,1993 Siderurgica Guadalajara, MX v 2

US Pipe & Foundry Birmingham, AL 1

June,1993 Commonwealth Aluminum Lewisport, KY 1

September,1993

, State Line Scrap So. Attleboro, MA

.3 September,1993 Samuels Recycling Madison, WI 4

September,1993 B. Abrams & Sons Harrisburg, PA 2

July,1993 Florida Steel Tampa, FL 1

September,1993 Siderurgica

- Mexicali, MX Y 3

, Slater Steels Fort Wayne, IN 1-Republic Eng. Steel Canton, OH 3

Armco Steel Middletown, OH 2

June,1993 Green River Steel Owensboro, KY 1

Roanoke Elect. Stsel~

Roanoke, VA 1

August,1993

_ Shredded Productsf Roanoke, VA 1-August,1993 Florida Steel Jacksonville, FL 2

Tennessee Valley Steel Harriman, TN 1.

August,1993 Auburn Steel -

Auburn, NY 2

August,1993 Jessop Steel Washington, PA 1

Florida Steel Charlotte, NC 2

'Alta Steel Edmonton, Alta -

1 Armco Steel Ashland, KY 2

Florida Steel Knoxville, TN 2

s

.j 09/14/93

<33 5ff s

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I EXPLORANIUM i

101 Bradford Road. Wexford, PA 15090 l

Radiation Detection Systems Tel: (412) 934-5422 FAX: (412) 934-3376

'l i

EXPLORANIUM GR-526-RADIATION DETECTION SYSTEM q

The possibility of introducing radioactive material into a scrap processing facility is a very real issue because of the thousands of radioactive sources in use today. _ Employee ~. health hazard, product liability and social responsibility _are major concerns.

t Including clean-up, the cost resulting from a single' incident of processing radioactive scrap can amount to millions of dollars.

Exploranium has specialized in the design and manufacture of very t

sensitive radiation detection systems since - 196 8.

The GR-520 system was introduced in 1987 specifically to serve the needs of the scrap recycling industry by providing the capability to detect a fully shielded radioactive source deeply buried in a vehicle I

loaded with scrap metal.

Continuous research and product development over the past five years and hundreds of tests in field applications have led to the GR-526 System, by f ar the most advanced technology in the industry.

Many significant operating features and user benefits have been l

incorporated into the product line from the first GR-520 systems, through the GR-515/525, to the current GR-510.

During this evolution there was also modest increase in system sensitivity and these systeas are significantly more sensitive than any o ther i

system on the market.

-i The GR-510, available in six size configurations suitable for a wide range of applications, will continue to be a major product line with the flexibility to meet the needs of eaph individual scrap dealer as well as many metal producers.

THE GR-526 SYSTEM - - A TECHNOLOGICAL BREAKTHROUGH:

The GR-526 Industrial Radiation Detection System represents the first dramatic increase in sensitivity since the inception of large vehicle monitoring systems.

I Unique, patented, electronic analysis techniques permit setting parameters to extremely low alarm thresholds and energy levels of radioactivity, while still eliminating false alarms.

This results l

in GR-526 detection capabilities at least' 25% greater than ever before achievable.

1 i

This high level of performance is critical to any producer whose objective is to detect a shielded source deeply buried in dense scrap before it is introduced into the furnace.

The GR-526 may l

be used to monitor trucks, rail cars, or charge buckets.

k e

i

I

-GR-526 SYSTEM FEATURES AND BENEFITS:

In addition to increased sensitivity, the GR-526 System offers significant operating and maintenance benefits to the end user.

Following is a list of some of the enhanced features.

l 1)

Microprocessor controlled electronics unit provides 5

complete system monitoring and control functions.

2)

LCD Graphic display screen helps locate the position of the alarm within a. vehicle.

The screen also indicates l

system operating status and maintenance menu.

3)

There are four (4) alarm levels for operator protec-tion, alarm qualification, and guidance on procedures l

to be followed in the event of an alarm.

4)

The alarm threshold is established individually for each vehicle and, depending on vehicle density, is usually below the surrounding background level.

5)

Dual optical sensors detect vehicle presence and speed with an audio alarm for excessive speed.

6)

The system automatically performs continuous self-diagnostic checks to ensure that all electronics and photo-multiplier tubes are operating properly.

7)

The detector assemblies have substantial back-up in electronics, with automatic switchover in the event of a malfunction, providing maximum system reliability.

8)

Alarm data and system history are stored in. memory for future access and retrieval-by authorized personnel.

l 9)

Numeric keyyad with password protection prevents acci-dental access, shut-off or parameter settings being changed by unauthorized personnel.

10)

(T,he system is modular in construction and can be easily.

i serviced by semi-skilled personnel.

i 11)

Telephone link via modem interface allows remote access for operating and maintenance support from the factory; Exploranium can also supply the software for. authorized personnel to perform operating checks, alarm analysis-l and parameter adjustment remotely from a PC.

12)

An AC Constant Voltage Transformer provides system circuit protection against voltage surges.

13)

System restart is automatic following a power failure.

b

[ =EKPLORANIUM GR-110s

-Radiation Detection Systems RADIAT10N DETECTOR 1

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DESCRIPTION i

FULLY AUTOMATIC BATTERY OPERATED 1

PRESET AUDIO ALARM LEVEL DIGITAL READ-OUT i

LIGHTWEIGHT PROTECTIVE LEATHER CASE l'

SODIUM IODIDE CRYSTAL LOW BATTERY ALERT I

l The GR-1108 is fully automatic and requires little operator interaction.

An audio alarm indicates the strength (or proximity) i 1

of any radioactive material and this alarm level is automatically adjusted to compensate for natural background radiation levels.

The GR-1108 can be hand held or carried " Hands Free" on a waist belt or shoulder strap.

Either of these methods allow constant monitoring for radiation.

The GR-1108 also has an easy to read LCD display which assists in locating radioactive material where excessive noise levels are a problem.

L'XPLORANIUM r

l Radiation Detection Systems 904 MOUNT ROYAL BLVD.

55 HEALEY RD., UNIT 7 AGENT l

PITTSBURGH, PA 15223 BOLTON, ONTARIO L7E SA2 TEL:(412) 487-8459 TEL:(416) 857-3670 FAX: (412) 487-7106 FAX: (416) 857-3679 l

L J

AUEURN 3 i c=_ CCNTAINER and RAM STCRAGE AREA INVENTCRY

r. 2 2 9.7 7 :: CS; DATE NET (uRihr)

(pCilg)

(mci)

CCNTAINEm Fil ! cD WE!GHT DESCR'm O.C.

3 FT.

CONC.

ACTMTY S-1 5 93 33000 DUST 40K n/s 48137 721.0 S-2 5 93 33400 DUST 9000 nis 3040.

46.1 S-3 5 93 30080 DUST 800 n/s 1082 14.E S-4 5 93 33560 DUST 2400 nis 514.5 7.2 S-5 5 93 37560 DUST 400 n/s 361 6.2 S-6 5 93 31960 DUST 11K n/s 44630 647.6' S-8 5 93 37360 DUST 8500 n/s 3238.

54.5 M-10 6 93 4790 DUST 300 100 755 1.E M -11 6 93 4090 DUST 300 120 878 1.E M-12 6 93 10050 DUST 38 38 22.

0.1 M -13 6 93 6350 DUST 40 30 23 0.1 M-14 6 93 7710 DUST 150 60 197-0.7 '

M-15 6 93 5430 DUST 100 40 100 0.2 M-16 6 93 7210 DUST 130 60 275 0.9 M-17 6 93 6970 DUST 200 70 12 O

M-18 6 93 4790 DUST 50 40 56 0.1 M-19 6 93 9270 DUST 100 50 111 0.5 -

M-20 6 93 5930 DUST 50 40 292 0.8 M -21 n/a equipment n/s n/s n/s n/a M-22 6 -1 5 - 93 310 TRASH 100 40 n/s n/a M --23 6 93 1930 DUST 26 20 13 0

M-1A 7 93 5800 DUST / trash 60 40 15 0

M-24 7-6-93 9520 C.C. REFRACTORY 140 20 n/s n/a M -25 7 93 8720 S.A. DUST / SCALE 60 30 152 0.6 M -26 7 93 4060 S. A. DUST / SCALE 70 15 42 0.1 M -27 7 93 1960 DUST 15 8

27 0

M -28 7 93 10240 FURNACE-BRICK 420 100 n/s n/a M-29 7 93-9860 FURNACE BRICK 400 50 n/s n/a M -30 7 93 9200 FURNACE BRICK 180 75 n/s n/a M-31 7 93 7200 FURNACE BRICK 250 100 n/s n/a M-32 7 93 9120 FURNACE BRICK 500 100 n/s n/a M-33 7 93 8660 FURNACE BRICK 460 100 n/s n/a M-34 7 93 10160 FURNACE BRICK 450 70 n/s n/a M-35 7 93 10040 FURNACE BRICK 200 45 n/s

.n/a M -36 7 93 10580 FURNACE BRICK 35 12 n/s n/a M-37 7 93 9960 FURNACE BRICK 30 to n/s n/a M-38 7 93 10780 FURNACE BRICK 160 30 n/s n/a M -39 7 93 9080 FURNACE BRICK 120 60 n/s n/a M-40 7 93 9240 FURNACE BRICK 220 20 n/s n/a M -41 7 93 11460 FURNACE BRICK 30 10 n/s n/a M -42 7 93 9920 FURNACE BRICK 8

25 n/s n/a M -43 7 93 600 DUST 10 10 n/s n/a,

M -44 8 93 150 TRASH 15 15 n/s n/a h.Y L

DATE NET (uRihr)

(pCi/g)

(mCil CONTAINER Fil ! :D WE!GHT DESCRIP.

O.C.

3 FT.

CONC.

ACTMT/

W-21 5 93 13500 DUST 150 60 529 3.2 W-22 5 93 13920 CUST 140 70 132 0.E W-23 5 93 14600 DUST 150 80 153 1

W-24 5 93 11200 DUST 200 80 290 1.!

W-25 5 93 14400 DUST 120 60 176 1.:

W-26 5 93 10580 DUST 100 60 102 0.!

W-27 5 93 9620 DUST 170 80 71 0.:

W-28 5 93 12840 DUST 100 50 185 1.

W-29 5 93 13840 DUST 100 55 293 1.1,

W-30 5 93 15840 DUST 70 40 80 0.(

W-31 5 93 14440 DUST 80 50 189 1.: '

W-32 5 93 17000 DUST 60 30 79 0.( '

W-33 5 93 15420 DUST 90 45 139 W-34 5 93 1 6320 DUST 130 50 167 1.:

W-35 5 93 13380 DUST 90 50 422 2.t W-36 5 93 16540 DUST 80 50 50 0..

W-37 5 93 15720 DUST 100 50 81 0.t W-38 5 93 9720 DUST 80 40 60 0.:.

W-39 5 93 13880 DUST 70 40 50 0.: :

W-40 5 93 13180 DUST 70 50 88 0.!

W-41 5 93 14520 DUST 80 50 57~

0..

W-42 5 92 13260 DUST 80 50 42 0.:

W-43 5 93 16020 DUST 42 28 48 0.:

W-44 5 93 15120 DUST 100 80 41 0.:

W-45 5 93 5720 DUST 240 130 561 1.!

W-46 6 93 6100 DUST 200 80 373 W-47 6 93 7100 BAGS 800 250 n/s ni:

W-48 6 93 7560 BAGS 1400 420 n/s nh W-49 6 93 8300 BAGS 600 200 n/s nh W-50 6 93 3470 BAGS 500 140 n/s nh W-51 6-8 8980 DUST 1200 300 1125 4.(

W-52 6-6-93 17500 DUST 600 240 1030 8.:

W-53 6 93 23000 DUST 320 50 72 0.1 W-54 6 93 14380 DUST 25 15 11 of W-55 6 93 14560 DUST 140 20 37 0.

W-56 6 93 7960 DUST 250 24 63 0.:

W-57 6 93 17740 DUST 70 20 9

0/

W-58 6 93 17580 DUST 26 16 6

(

W-59 6-93 16180 DUST 20 10 5

(

W-60 6 93 14580 DUST 26 14 8

Oc W-61 6 93 22300 DUST 44 20 14 Oc W-62 6 93 16460 DUST 15 8

7 Oc W-6S 6 93 13060 DUST 18 12 5

(

W-64 6 93 16740 DUST 15 10 3

(

W-65 6 93 14080 DUST 10 10 2-.

(

W-66 6 93 14700 DUST 10 to 3

(

W-67 6 93 19120 DUST 30 10 4-C M

W-68 5 93 20220 DUST 600 200 744 6.! :

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DATE NET (uR/hr)

(pCilg)

(mci)

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CONTAINER Fil I cn WEIGHT DESCRIP.

O.C.

3 FT.

CONC.

ACTIVITf !

W-70 5 93 19520 DUST (S-7) 300 150 300 2.7 :

W-71 5 93 10520 DUST (S-7) 250 100 154 0.7 :

W-1 A 6 93 14000 DUST 220 n/a 2

0 W-2A

  • 6 93 14000 DUST nis n/s 3

0; W-3A 6 93 14020 DUST 430 120 2

0; W-4A 7 93 16920 DUST 6

N/D 2

0 W-72 5 7-06 -93 16900 DUST 10 10 9

0.1 W-73 S 7 93 13280 DUST 10 10 4

0:

W-74 S 7 93 13760 DUST 10 10 9

0.1 W-75 5 7-07 -93 14000 DUST 10 10 4

O!

W-76 5 7-08 -93 14000 DUST 10 10 1

0; W-77

  1. 8 93 19740 DUST 15 15 ns n/a :

W-78

  1. 8 93 17660 DUST 20 15 ns n/a !

W-79

  1. 8 93 18560 DUST 15 15 ns n/a!

W-80

  1. 8 93 19140 DUST 15 15 ns.

n/a:

W-81

  1. 8 93 18380 DUST 15 15 ns nie :

1.23E+06 1556.7 ~

W = WOODEN STORAGE BOX

  • = DUST FROM AFTER DECON OF BAGHOUSE S = DUST FROM AFTER REBRICKING FURNACE
  1. = DUST FROM AFTER MAINTENANCE SHUTDOWN n/s = not sampled / surveyed ADDITIONAL MATERIAL:

RUST FEDERAL SERVICES "VEC-LOADER" (1) 20' SEA-LAND CONTAINER WITH:

3 (3) 55 gailon drum vacuums and one Haco Minuteman vacuum HEFA pre-fiker assemblies VEC-Loader hose (11) boxes of characterization samples extension ladder misc. project equipment i

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i GLASSIFICATION'"

OF ELECTRIC ARC FURNACE DUST (KO61)

\\ND OTHER BYPRODUCTS OF STEELMAKING i

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Glassification~ International Ltd.

1 Therrnal Conversion Of industry Byproducts Into Safe And Profitable Products For The Future

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D GLASSIFICATION""

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OF ELECTRIC ARC FURNACE DUST (KO61)

AND OTHER BYPRODUCTS OF STEELMAKING i

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Jerry Richartz Oregon Steel Mills, Inc.

Portland, Oregon

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l, THE PERMANENT SOLUTION TO Tile DISPOSAL OF ELECTRIC ARC DUST Following the United States Environmental Protection Agency's (USEPA) Land Ban Mandate of 1988 for land disposal of the hazardous waste K061, electric are furnace (EAF) dust, Oregon Steel Mills, Inc. participated with other Northwest steel mills in an extensive investigation of processes that could treat, store or dispose of EAF dust within the j

parameters set forth in this mandate. The additional factors of increased disposal costs and heightened emironmental awareness, elevated the importance of the research. Although pollution prevention is catching on as the preferred method to reduce waste generation, many industries are still faced with large quantities of hazardous waste destined for end-of-the-pipe treatment. In this instance, EAF dust represents the second largest ha~ rdous n waste stream in the United States.

Evaluating Options and Testing fj

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The most commonly used process, High Temperature Metal Recovery (HTMR), provides a means for generators of EAF dust to reclaim zinc for beneficial reuse; however, the residue generated from this treatment process leaves a significant amount of waste residue that can have high concentrations of leachable heavy metals. There is concern over long term liability associated with HTMR treatment and subsequent disposal or land application of waste residues.

Based on the results of pilot tests, Oregon Steel concluded that the most environmentally sound method to eliminate EAF dust was vitrification. The oxide additives used in

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commercial glass manufacturing were found to be readily available in EAF dust. Table I lists the typical elemental composition found in EAF dust.

In 1990, Glassification" International Ltd. was formed. A joint venture between Oregon Steel Mills and Roger B. Ek & Associates, Inc., a glass and ceramics research/ development firm. Glassification" International Ltd.'s goal was to develop and market the process for i

vitrification and recycling of EAF dust.

The Glassification" Process uses EAF dust to produce glass products. The dust is used as

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a substitute for mineral powders which are consumed in large quantities in the United States for producing colored glass, colored ceramic compounds, and other uses. The glass making process is able to utilize not only the EAF dust, but also other waste streams that would require disposal, including slag, millscale and spent refractories. Through the licensed Glassification" Process, these materials are atomically bonded with other glass forming materials to produce products that pass all Toxic Characteristics Leaching Procedure (TCLP) tests and have been determined to be legitimate recycled products under USEPA criteria.

The process uses 100% of the hazardous waste stream to produce a non-hazardous glass frit j

and results in the complete elimination of the EAF dust with zero waste.

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.o' Construction and Permitting In the summer of 1991, construction of the Glassification"" Process plant was begun at Oregon Steel's Portland, Oregon facility. The plant is located adjacent to the facility's baghouse, eliminating transportation risks. During the course of construction, state and federal permittingwere completed. Concurrently, the Oregon Department of Environmental Quality (DEQ) and the USEPA determined that the Glassification" Process was in fact, legitimate recycling. Test runs began in December of 1992 and production started the following month.

Glassification" International Ltd. is currently marketing recycled EAF dust as blasting grit, steel slag fluidizer, and roofing granules. Other products that can be produced through the -

process include glazes and colorants for brick and tile products, colored glass and glass ceramics, as well as non-reactive fillers that require high ultraviolet opacity.

The Glassification"" Process provides not only aviable alternativa to expensive transportation and disposal cost, approximately $2,000,000 annually for Oregon Steel, but also produces marketable products which will resiilt iiiipproximately $1,600,000)er year in revenues from -

Oregon Steel's plant.

THE GLASSIFICATION"" PROCESS

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EAF dust is collected from the baghouse and conveyed into a bin which holds one or two days supply for mining with other ingredients. Glass former materials and modifiers are stored in bins which feed a blending system along with the EAF mineral powder. Spent refractories, slag and other metal bearing byproducts are crushed into a minus 16 mesh graded product consistent with glass melting raw material preparation practice. The blending system uses a weigh hopper to measure the batch ingredients before they are blended and delivered to the glass furnaces.

Glass melting takes place at approximately 2,500 F, in a glass furnace heated by molybdenum electrodes submersed in the molten glass bath. The glass furnace is of proprietary design. Glass batch materials are fed into the furnace through a screw feeder.

The newly added batch floats on the surface of the molten glass, forming a blanket that provides excellent thermal insulation. The temperature of the outer surface of the batch blanket typically ranges from 130-300*F. Volatilized metals are condensed in the cool

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blanket and reintroduced into the melt.

Any fugitive emissions are captured and I

reintroduced into the baghouse.

j The operation is a continuous process, new feed materialis added to the furnaces as molten glass exits into a stabilizing trough and flows to a granulator. Here it is fractured with a cold water bath to form the glass frit. The shattered glass is then dried, crushed and screened i

for proper size prior to storage in bins. Glass that does not meet product specifications can r

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be recycled through the furnace or taken to a melt shop where it is substituted for olivine sand and used as a slag fluidizer in the ladie metallurgy furnace.

Component Availability The furnace equipment, glass molding and handling equipment; batch formulators, blenders and conveyors are constructed from readily available components. Through innovation, existing components and technology are used to benefit the metals industry.

The glass plant operated by Oregon Steel consists of three electric furnaces housed in a 10,000 square foot building, capable of processing 12,000 tons of EAF dust per year. The plant operates as a totally computer integrated manufacturing facility, using level one programmable logic controllers and level two personal computers. These are linked to the mainframe business computers through a data network. Under normal operation, all plant functions are computer controlled. However, an operator can interface and take control in a semi-automatic mode.

A MARKETABLE END PRODUCT The end product of the Glassification" Process, glass granules known' as glass frit, is manufactured on site at the generator's plant. The frit may be sized through screening for sale as blasting grit or roofing granules or steel slag fluidizer. The market for these products is stable and able to absorb large quantities of glass frit, an important consideration for a i

large steel making facility. By altering the glass formers, the Glassification" Process can manufacture products for which there is less demand, but whose dollar per ton value is greater.

Glass Ceramics 3

The frit can be crushed and sized as powders for colorants and glazes. A variation in glass

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composition can produce granules for remelting and casting into glass and glass ceramic shapes. The glass ceramics exhibit chemical resistance and abrasion resistance superior to l

stone products and common glazed ceramic tile.

Mineral powder mixtures also work well in creating ceramic colors such as lustrous, shiny and matte black, brown, silver, steel gray and bronze. Natural stone colors closely resembling obsidian, olivine, pyroxene and black marble can be prepared as fully re-

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crystallized ceramics, known as glass ceramics.- Glass ceramic tiles, table tops, hearths, inlays l

and other architectural and decorative articles can be produced using the glass frit.

4

The mixtures of mineral powders, drosses and other chemicals currently available in the market place, especially those used to color the newly prepared "used brick" products, do a

Glassification'" Brand not pass Toxic Characteristic Leaching Procedure (TCLP) tests.

products pass all TCLP tests, an incentive for consumers of mineral powders to switch from the more toxic powders.

ENVIRONMENTAL ADVANTAGES An electric are furnace typically generates about 20 to 40. pounds of EAF dust per ton of steel produced. The Glassification'" Process completely recycles EAF dust,' leaving no hazardous waste residues. The process does not require that the EAF dust be pre-treated or processed. Therefore, the amount of dust which can to be recycled is limited only by the size of the plant and the demand for the end product.

The relatively insignificant quantities of wastewater generated as a result of blowdown from the molten glass quenching and fritting operations can typically be recycled with the plant cooling water. The cooling water blowdown generated in the steel mill is generally treated to remove suspended and dissolved solids in the plants' water treatment and cooling plant.

Electric Power

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Although the Glassification'" Process allows the choice of fuels, electric powered furnaces are preferable. They are more compact,-easier to maintain, less costly to operate and j

eliminate waste off-gases associated with the combustion of other fuels. The particulate generated from the glass furnace is captured and collected in the baghouse and recycled with the EAF dust.

Waste Reduction Waste reduction benefits are realized by the elimination of transportation and disposal of wastes. Eliminating the need for transportation results in an equivalent reduction in the generation of CO from the combustion of fossil fuels. The HTMR method recovers and -

2 recycles the zinc, lead and cadmium in EAF dust. However, this accounts for only about 30% of the mass of the dust. The remaining 70% is 'still considered a hazardous waste residue requiring disposal. The Glassification"" Process completely eliminates the need for disposal.

Table II illustrates the waste reduction that can be achieved by using the Glassification""

Process instead of the HTMR method. If 250,000 tons of the approximately 650,000 tons of EAF dust generated nationally each year were to be recycled using the Glassification'"

Process, the annual impact on waste reduction would be 3.7E+05 tons. Based on a disposal 5

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cost of $30 per ton, the cost of disposal of the waste residue generated from treating 250,000 tons of EAF dust through the HTMR process is estimated to be $10,500,000. This does not include transportation and HTMR treatment costs.

t Energy Savings Using the same comparison and the same assumptions, the HTMR method consumes more t

energy in the form of transportation to regional HTMR treatment centers and cost of the recycling process. By converting 250,000 ton per year of EAF dust to the Glassification'"

process, national energy savings of about 2.30E+08 Btu may be realized with an estimated cost savings of approximately $11,500,000 (Table III).

i REGULATORY CONSIDERATIONS Beginning in 1990, Oregon Steel sought a " Legitimate Recycling Determination" for the Glassification'" Process; A Part B permit, required for treatment of hazardous waste under the Resource Conservation and R.ecovery Act (RCRA), is not required for a legitimate l

recycling process. Part B permits have been one of the major stumbling blocks for recycling projects which produce residual hazardous waste.

The determination was based on criteria established by the USEPA to provide a consistent i

interpretation oflegitimate recycling. The criteria were developed to implement Congress's intent to encourage hazardous waste recycling. The Glassification'" Process met all the established criteria and passed all laboratory and physical tests. The determination was j

completed in October 1992 and approved by the Oregon Department of Environmental Ouality in December 1992.

Testing i

Glassification'" Brand products may provide an attractive alternative to other products made or derived from mineral powders. The USEPA has begun to test ceramic products and i

found that many conventional products now on the market are easily leached in acid water environments and do not pass TCLP testing. All products manufactured through the~

a Glassification'" Process pass USEPA's newly defined list of TCLP metals,which includes the eight Appendix VIII listed metals, as well as nine additional metals recently listed for K061 j

recycling residues. Finished products are continually monitored under Glassification'"'

International Ltd.'s quality assurance program. The products have never failed a leaching test. Table IV summarizes the results of the TCLP testing for blasting abrasives produced l

in the Glassification'" Process as compared with other commercial blasting abrasives.

Glassification'" Brand products show excellent leach resistant by comparison.

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c The USEPA evaluated the Glassification* Process under provisions of the Waste Reduction Innovative Technology Evaluation (WRITE) Program. Science Applications International o

Corporation (SAIC), an environmental consulting firm under contract to the USEPA, observed all the activity required to produce glass products at the E.M. Jorgensen Forge facility, Seattle, Washir.ct' n. Several glass compositions were produced during separate o

testing conducted by SAiG and Glassification* International Ltd., and were used to prepare examples of the end products manufactured from the glass frit and powders.

SAIC observed raw material selection, blending, batching, melting and glass ceramic casting activities. Glass samp!cs were taken and submitted by Glassification" International Ltd. and

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SAIC for TCLP testing. Comparison of the data indicates that the results from two independent analytical tests produced very similar results. The end products fall within USEPA cpecified parameters for leachability, especially those responsible for the K061 designated listing (cadmium, chromium, and lead).

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THE GIASSIFICATION" PROCESS IS TIIE SOLUTION The Glassification" Process is the only process available to the metals industry whereby EAF dust and numerous other byproducts can be utilized in a process that not only recycles 100% of the hazardous material, but also produces a marketable commodity. Products generated by the sale of these products have the potential to offset or even exceed costs.

Physical plant and equipment costs necessary to build a Glassification" plant is dependent on plant location, as well as EAF dust processing capacity. Glassification" International Ltd. can provide steel industry clients with specific :osts for glass production and equipment

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costs. These costs are determined in the Glassification" I and II feasibility studies provided by Glassification* International Ltd.

Glassification" Brand products can be produced from EAF dust in categories which include both high and low zinc contents as normally found in the primary steel industries. It is also applicable to foundries where elevated chromium, manganese and nickel contents are reported in EAF dust analysis.

The recycling of K061 and other waste streams into glass products exceeds land disposal restriction requirements. More importantly, use of the process will effectively demonstrate the commitment by the steel industry to produce quality products within the framework of a conscientious stewardship of the ervironment.

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Table I Elemental Composition of Typical EAF Dust' 1

Total J

Typical Constituents Appendix Element EAF Dust

(Weight Percent) l VIII l

Iron 30.0 Zine 20.0 Calcium 13.0 j

Manganese 3.0 Lead 2.0 X

Magnesium 2.0 Chromium 0.5 X

Cadmium 0.1 X

Sodium 0.4 Nickel 0.1 X

Copper 0.2 Potassium 0.4 Carbon 2.0 Sulfur 0.5

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Chlorine 2.0 Fluorine 2.0

  • Source: Roger B. Ek & Associates, Inc.

6 From Horsehead Resource Development, Inc.,1988 Conference on Thermal Treatment of Industrial Residual Sources, New York, New York h

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i 41 Table II Total Waste Reduction Per Ton of Steel Produced t

Waste Reduction Components Glassification'"

HTMR Waste

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Technology Technology Reduction (ton / ton)

(ton / ton)

(ton / ton)

Waste (CO ) generated in trans-2 porting EAF dust to recycling 0.00E+00 6.04E-04 6.04E-04

'i center

.l Additional waste residue generated 0.00E+00 1.05E-02 1.05E-02 i

after recycling process Total waste reduction 1.11E-02 National impact on waste reduction, tons 3.70E+05 l

National impact based on 250,000 tons EAF dust @ $30/ ton for disposal

$10,500,000 r

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Table III Total Energy Use Per Ton of Steel Produced 1

Energy Consuming Components Glassification'"

HTMR Energy

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Techno!ogy Technology Savings (Bru/ ton)

(Btu / ton)

(Bru/ ton)

A.

Typical energy consumed 0.00E+00 7.5E+03 7.5E+03 for transporting EAF dust B.

Typical energy consumed by 2.13E+06 5.0E+06 2.9E+06 recycling process C.

Total energy savings, Btu 2.9E+06 Annual national impact, assuming 250,000 tons of dust, Btu 2.3E+08 Annual national savings @ $0.05/KW

$11,500,000 9

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Table IV TCLP Test Results for Abrasive Blasting Medium (mg/1)

Constituent Regulatory OSM Product Range Commercial Product (TCLP Metals)

Standard (ppm)

(ppm)

Arsenic 5

<0.0165

<0.0169-0.0205 Barium 100

<0.0001-0.7825

<03316-0.6005 Cadmium 1

<0.0012-0.0036

<0.0012-0.023 Chromium 5

<0.0038-0.0141

<0F39-0.0218

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Lead

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<0.0247-03332

<0.0252-0.8081 i

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Mercury 0.2

<0.00011-0.0002

<0.0001-0.0002 Selenium 1

<0.0158

<0.0153-0.0237 Silver 5

<0.0022

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  • O 3-UNITED STATES ENVIRONMENTAL P50TtcTicN ActNcr h

WASHINGTON, D.C. 2M40 i

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sou: wasvt no swa noency assroass i

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!n Mr. WEam M. Guerry, Jr.

Collier, Shannon, RM & Sect!

l 3050 K Street, N.W.

1 Suits 400 l

WasPJni.cc D.C. 20007

Dear Mr. Guerry:

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As a follewup to our meeting with you and representatives cf G!assification 1

International. Umsted (GIL) en September 22,1982. EPA has considered the i

infermaton ycu have previded on the GIL glassifcation process for electric are furneos (EAF) dust cf KOS1 when the EAF dust is a hazardcus waste. Based on the 1

informatbn tat you have provided us, EPA understands that GIL utmzes EAF dust 1 from steel mills to produce a glass frft which is then sold for use as abrasive blast, and i

as an Ingred!ent h mak!ng roof!ng granules, glass ceramic and ceramio glaze.

j Throughout our discussions, the mairi issue regarding the regulatory status of the GIL j

process and glass frtt product has been whether EAF dust h;&porated into GIL glass 1

fnt meets tne definition of a solid weste (and therefers also a hazardcus waste, i.e...

1 K061) under the Resource Ccnservation and Recovery Act (RCRA).

-l Ycu speci".caly sought EPA Headquarters' concurrence that these uses are excluded from the defrveon_of scild waste under Sechon 261.2(e). The focus of this determinaden is the ultimate end use of the secondary matedal or the product

- containing the secondary material. When secondary mateAals or producta centaining secccdary rnateriais are app!!ed to or placed on the land in a manner that constrtutes disposal, the material er the product containirg it is a scild wasts and also a hazardous waste (See 40 CFR Seebons 281.2(c)(1) and 261.2(e)(2)(i)).' Products used j

in a manner ccr45f.ng disposal are not el@;ible for'the'exdusion.

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- As meerd Ed above, GIL intends to sail its glass frit for use as abasive blast, i

and as an' ingredient in producing roofing granules, glass ~ ceramic and ceramic glaze.

j Regardlng abrasNe blast, EPA believes that in general this and use is not applied to or <

placed.on the land in a manner constituting diW. The other and uses (roofing i

granules, g'. ass ceramics, ceramic glaze) are also net typ'ce!!y appr d to 'or plemd on i

e the land in a manner constrhth;; disposal.

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@ h*wwanaserswac 1

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l Sc, when EAF dust is legtmately used as an ingredient to make a product that is not used in a manner constituting d!sposal (e.g., glass frit used to produce abrasives, recfing granules, glass caramics or coranJe g!aza), it is net a solid wasta under RCRA. Therefers, when producing stass fnt for ins and uses menboned above, the GIL process would not be subject to MCRA permitt!ng requirements.

Please be aware that under Section 3006 cf RCRA (42 U.S.C. Section 6825)-

indMdual states can be authorized to administer and anfcres their own hazardeus i

waste programs in !ieu of the federal program. When states are net authenzad to '

administer their cwn program, the appicpi.i. EPA Region administers the program l

and Is the apprcprista contact for any case-specMc determinations. Please afsc nete that under Section 3000 of RCRA (42 U.S.C. Sectbn 6929) states retain autWty to promulgats regulatory requirements that are mers stringent than federal regulatory

- requirements.

Thank you again for your Interest in th!s rnatter, if you have further questiens, please contact Mike Petn.:ska cf my staff at (202) 250-8551.

Sincerely,

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h Offes of Sc!!d Waste t

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{ 261.2 40 CFR Ch. I (7.192 Edition)

Environmental Protection Agency 9 261.2 ptrt,is still a solid waste and a hazard-(6) " Scrap metal" is bits and pieces (ii) Recycled, as explained in para-are otherwise contained in products ous wtste for purposes of these sec-of metal parts (e.g..) bars, turnings.

graph (c) of this section; or that are applied to or placed on the tions If:

rods, sheets, wire) or metal pieces that

( 111 ) Considered inheren tly waste.

land (in which cases the product itself (1) In the case of sections 3007 and may be combined together with bolts like, as explained in paragraph (d) of remains a solid waste).

3013, EI'A has reason to believe that or soldering (e.g. radiators, scrap auto-this section.

(!!) llowever commercial chemical the mtterial may be a solid waste mobiles, railroad box cars), which (b) Materials are solid waste If they pmducts listed in i 261.33 are not solid althin the meaning of section 1004(27) when worn or superfluous can be recy-are abandoned by being:

wastes if they are applied lo the Innd cf TLCitA and a hazardous waste cled.

(1) Disposed of; or and that is their ordinary manner of within the meaning of section 1004(5)

('l) A material is " recycled" If it is (2) flurned or incinerated, or

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  • of ItCitA; or used, reused, or reclaimed.

(3) Accumulated stored or treated Materials noted with a 'Y.'in column 2 (11) In the case of section 7003, the (8) A material is " accumulated spec-(but not recycled) before or in lieu of sts.tutory riements are established.

ulatively" If it is accumulated before being abandoned by being disposed of.

of {nble I are s lid wastes when they "I*'

(c) For the purposes of Il 261.2 and being recycled. A material is not accu-burned or incinerated.

(1) A " spent material" is any materi-person accumulating it can show that l

(c) Materials are solid wastes if they

[e"d 261.6:

mulated speculatively, however, if the prod e I

or am are recycled-or accumulated, stored. otherwise contained in fuels (in which cl that has been used and as a result the material is potentially recyclable or treated before recycling-as spect-cases the fuel itself remains a solid of contamination can no lenger serve and has a feasible means of being recy-fled in paragraphs (c)(1) through (4) waste)jiowever commercial chemical the purpose for which it was produced cled; and that-during the calendar of this section.

(ggy without processing; year (commencing on January I)-the (1) Used in a manner constituffng products listed in i 261.33 are not solid (2) " Sludge" has the same meaning amount of material that is recycled or disposal (I) Materials noted with a "*" wastes if they are themselves fuels.

usad in i 260.10 of this chapter; transferred to a different site for recy-In Column 1 of Table I are solid wastes (3) Reciatmed. Materials noted with (3) A "bytroduct" is a matertal that cling, equals at least 'l5 percent by when they are:

a "*" in column 3 of Table I are solid is not one of the primary products of a weight or volume of the amount of (A) Applied to or placed on the land wastes when reclaimed.

production process and is not solely or that material accumulated at the be-In a manner that constitutes disposal; (4) Accumulated speculaticely. Mate-sepitz.tely produced by the production the period. In calculating or rials noted with a "*" in column 4 of ginning o[lage of turnover, the'i$ per-tH) Used to produce products that Table 1 are solid wastes when accumu-process. Examples are process residues the percen such cs slags or distillation column cent requirement is to be applied to

(

are applied to or placed on the land or lated speculatively.

bottoms. The term does not include a each matetlal of the same type (e.g..

I co-product that is produced for the slags from a single smelting process)

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general public's use and is ordinarily that is recycled in the same way (Le..

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TAeLE 1 u;cd in the form it is produced by the from which the same materialis recov-u process.

ered or that is used in the same way).

con w ang L

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(4) A material ls " reclaimed" If it is Materials accumulating in units that J M,n ti rei rna l

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is tu rum processed to recover a usable product, would in exempt from regulation or !! It is regenerated. Examples are under i 261.4(c) are not be included in m

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m recovery of Itad salues from spent bat-inaking the calculation. (Materiais 5 s, um,w.. _.. _. _..... _ _......

n n

n teries and rrgeneration of spent sol-that are already defined as solid suspe emo m eo cm par Mi st a at sa - -

n n

n n

d ve. nts-wastes also are not to be included in sw. ne+aing s ch.cw.nc en.., dies ano n

n n

(5) A material is "used or reused.. if making th( calculation.) Materials are s pamet pm.a m ao ce n pert ai s,t a rei sa -

e n

n n

n e,,o,uc,..mn,. cs.,n

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.e*

n n

n

- it is etther:

no longer in this category once they comm c.e ca ac, prodat hme = ao cin rei 33.

n n

(1) Employed as an Ingredient (In-are removed from accumulation for re.

sme rn.iai - --

n n

n n

ciuding use as an intermediate) in an cycling, however.

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.t Industrial process to make a product (for example, distillation bottoms (45 Fit 33119. May 19.1980.1s amended at 48 Fit 14293, Apr.1.1983. So Fil 663. Jan. 4.

(d) Inherently traste-like materials. except for brominated material that from one process used as feedstock in 1985: 51 Fit 10l'l4. Mar. 24.1986. 51 Fit The following materials are solid meets the following criteria:

il t sa sf t is c I'l o 40636. Not 7.19861 wastes when they are recycled in any (1) The material must contain a bro-

  1. ""C#"

I""8 tinct components of the material are jp261.2 I efinition of miid u n=te.

recovered as separate end products (as I (1) llazardous Waste Nos. F020. F021 and when metals are recovered from (aM1) A solid teoste is any discarded (unless used as an Ingredient to make (Il> The material must contain less metal containing secondary materials); material that is not excluded by a product at the site of generationi. than a total of 1",

of toxic organic i 261.4(a) or that is not excluded by F022. F023. F026 and M)28.

compounds listed In appendix Vill;

'or

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(3) line Adtutmstrator will use the k tnnjun rk et or disposttion for the, under ll :tiu 2u and 260.22 of t his of t hese soh ents tother than the following criteria to add wastes to that. gmarial and that (IIey meet the chapter-list:

terrns o[ t he exclusion or exeruption.

(llD It is a mixture of a solid waste amounts that can be demonstrated not to be discharged to wastewater) divid-(IM A) The materials are ordinarily In doing so, they must provide appro, and a hazardous waste that is listed in ed by the average weekly flow of

<hsposed of, burned, or incinerated; or priate documentation (such as con.

subpart D of this part solely b-cause it (11) The materials contain toxic con-tracts showing that a second person exhibits one or tuore of the character-wastewater into the headworks of the stituents listed in appendix Vill of uses the material as an ingredient in a istics of hazardous waste identified in f acility's wastewater treattnent or pre-part 261 and these constituents are production process) to demonst rate subpart C of this part, unless the re-treatment system does not exceed 25 parts per million; or not ordinarily found in raw materials that the material is not a waste. or is sultant mixture no longer exhibits any (C) One of the followis:g wastes or products for which the materials exerupt from regulation. In addition, characteristic of hazardous waste iden" listed in i 261.32-heat exchanger substitute (or are found in raw materi-owners or operators of facilities claim.

tified in subpart C of this part or als or products in smaller concentra-Ing that they actually are recycling unless the solid waste is excluded from bundle cleaning sludge from the petro.

tions) and are not used or reused materials must show that they have regulation under i 261.4(bM7) and the leum refining industry (EPA Ilazard during the recycling process; and the necessary equipment to do so.

resultant mixture no longer exhibits ous Waste No. K050); or (ill The material may pose a sub.

any characteristic of hazardous waste (D) A discarded commercial chemi-stantial hazard to human health and ISO FH 664. Jan. 4.1985. as arnen led at 50 the environment when recycled.

Mt 3350. Aua. 20.1985; 56 Mt 7208. Feb.

Identified in subpart C of this part for cal product or chemical Intermediate i

5 iel Afafenals thaf are nof solid seaste 21,1% 56 m 32688 Juh IL N 56 m which the hazardous waste listed in In I adsing imm de min 6

' when recircled. (1) Materials are not

[*

' ^ " ' '

I subpart D of this part was listed.

mu losses of these materials frmn (iv)It is a mixture of solid waste and manu ac ng operadons in which solid wastes when they can be shown # 261.3 Definition of hazardnu. waste.

One or rnore hazardous wastes listed in mate als e ] i me manufac-s raw ma4 to be recycled by being:

g,, pmd i

subpart D of this part and has not f

(1) Used or reused as ingredients in (a) A solid wast e, as de fined in been excluded from paragraph (aM2) udng pmcess. N purposes of this an industrial process to make a prod.

1261.2, is a hazardous waste if:

of this section under ll 260.20 and paragraph (aM2mXm, "de minimis" uch provided the materials are not (1) It is not excluded from regula.

260.22 of this chapter; however, the I sses indude those from normal ma-t. being reclaimed; or tion as a hazardous waste under following mixtures of solid wastes and terial handHng operations (e.g., spills (11) Used or reused as effective sub.

I 261.4(b); and hazardous wastes listed in subpart D from the unloading or transfer of ma-stltutes for commercial products; or (2) It meets any of the following cri.

of this part are not hazardous wastes terials from bins or other containers, (111) Iteturned to the original process teria:

(except by application of paragraph leaks from pipes, valves or other de-from which they are generated. with.

(1) It exhibits any of the characterls-(aM2) (1) or (11) of this section) If the vlees used to t ransfer materials);

out first being reclaimed. The material tics of hazardous waste identified in generator can demonstrate that the min r leaks of process equipment, must be returned as a substitute for subpart C except that any mixture of mixture consists of wastewater the dis-storage tanks or containers; lealus from i

raw material feedstock, and the proc.

a waste from the extraction beneficia.

charge of which is subject to regula-well maintained pump packings and ess must use raw materials as principal tion, and processing of ores and miner.

tion under either section 402 or sec.

seals; sample purgings; relief device feedstocks.

als excluded under i 261,4(b)(7) and tion 307(b) of the Clean Water Act (In-discharges; discharges from safety

/

(2) The following materials are solid any other solid waste exhibiting a cluding wastewater at facilities which showers and rinsing and cleaning of

{ wastes, even 11 the recycling Involves characteristic of hazardous waste have eliminated the discharge of personal safety equipment; and rin-t

- use, reuse, or return to the original under subpart C of this part only if it wastewater) and:

state from empty containers or from i,

process (described in paragraphs (e)(1) exhibits a characteristic that would (A) One or more of the following sol, containers that are rendered empty by (I) through (ill) of this section):

not have been exhibited by the ex.

vents listed in i 261.31-carbon tetra-that rinsing; or til Materials used In a manner ton, cluded waste alone if such mixture chloride, tetrachloroethylene, trichlor.

(E) Wastewater resulting from labo.

stltuting disposal, or used to produce had not occurred or if it continues to octhylene-Provided. That the maxi.

ratory operations containing toxic (T) products that are appiled to the land; exhibit any of the characteristics ex.

mum total weekly usage of these sol.

wastes listed in subpart D of this part, or hibited by the non exchided wastes vents (other than the amounts that Prceided. That the annualized average l

(11) Materials burned for energy re, prior to mixture. Further, for the pur.

can be demonstrated not to be d5 flow of laboratory wastewater does not covery, used to produce a fuel. or con.

poses of applying the Toxicity Charac.

charged to wastewater) divided by the exceed one percent of total wastewater i

l tr.ined in fuels; or teristic to such mixtures, the mixture average weekly flow of wastewater flow into the headworks of the facill-( 111 ) Materials accumulated specula. Is also a hazardous waste if it exceeds into the headworks of the facility's ty's waste water treatment or pre treat-l tively; or the maximum concentration for any wastewater treatment or pretreatment ment system, or provided the wastes, (iv) Materials listed in paragraph contaminant listed in table I to system does not exceed I part per mij.

combined annualized average concen-(dH I) of this section, i 261.24 that would not have been ex.

lion;or tration does not exceed one part per l

(I) Documentation of claims that creded by the excluded waste alone if (B) One or more of the following million in the headworks of the facill-materials are not sohd teostes or are the mixture had not occurred or if it spent solvents listed in i 261.31-meth.

ty's wastewater treatment or pre treat-conditionally exempt from regulation. continues to exceed the maximum ylene chloride. 1.1.1-trichloroethane, ment facility. Toxic (T) wastes used in flespondents in actions to enforce reg.

concentration for any contaminant ex.

chh,robenzene, o-dichlorobenzene, cre.

laboratories that are demonstrated ul:.tlons implementing subtitle C of ceeded by the nonexempt waste prior sols, cresylle acid, nitrobenzene, tolu. not to be discharged to wastewater are ItCitA s ho raise a claim that a certain to mixture.

ene, methyl ethyl ketone, carbon di.

not to be included in this calculation.

material is n<W a m1M e ne le -

'H5 " "HM 8"

l l

g Legitimate Recycling Determination Process t Feedstock 4 Process &

Products

4

= Determine constituents

= Compare and

= Show that Appendix

= Perform testing to obtain and concentrations of t

demonstrate similarity Vill constituents product properties:

K061 Appendix vili in standard process and contribute beneficia!iy Compare new products constituents recycling process to the product with existing products

= Determine statistical

= Compare process

= Perform environmental

= Marketabihty and consistency of results equipment tests on both feasibihty commercial and

= Compare the commercial

= Complete mass and product feed stock tc energy balance for recycled products and

- Perform market l

Commercial constituents and standard process and compare with

[

analysis for the Feed Stock.

c ncentrations in the recycling process regulatory standards products recychng process such as TCLP

= Show that Appendix Vlit

- Economic feasibility of the products constituents contribute i

beneficially to the

- Letters ofintent from

<i process i

manufacturers for the i

products

)

Recycling Criteria:

= 15 the secondary material

= What degree of

= Are the toxic constituents

= What is the value of the similar to an analogous processing is required to actually required?

secondary material?

raw material?

produce a final product?

= 15 the secondary product

= ls there a guaranteed

= Are the toxic similar to an analogous market for the end constituents actually product?

product?

= What are the economics

= is the secondary material of the recycling process?

handled in a manner consistent with the commercial feed stock 1 SMA Presentation, August 2,1993 oregon sicel Mills,Inc.

i Kathi futomkk, Prolett Monoger, Cil2M 11111

, _ _ _. ~ _.. -

~

m

~_

Dece=ber 23, 1992 DEPARTMENT ENVIRONMENT Mr.

J. Kenneth Bray QUALITY -

Director, Corporate Engineering Oregon Steel Mills P.O.

Box 2760.

Portland, OR 97208 Mr. Jerry O.

Richartz Manager, Environment and Energy Oregon Steel Mills P.O.

Box 2760 Portland, OR 97208 Mr. Roger B.

Ek Glassification International, Ltd.

2711 226th S.E.-

Issaquah, WA 98027 Re:

Recycling Determination Using K061 Electric-Arc Furnace Dust as an Ingredient for Roofing Granules and Ceramic Glaze / Colorants.

ORD 009 106 055

Dear Gentlemen:

Recycling Detarmination The Oregon Department of Environmental Quality (DEQ]

reviewed two documents, Recuest for Recycline Determination (January 1992) and Addendum to Orecon Steel Mills Recuest for Reeveline Determination (October 1992)' when responding to the.

Oregon steel Mills (OSM] and Glassification International, Limited (GIL] request that DEQ determine the recycling legitimacy of producing glass granules (glas's frit) from RCRA K061 hazardous waste.

DEQ has-determined that the production of glass frit (glassification) constitutes legitimate recycling, provided that' glass frit is used only as a roofing granule or ceramic glaze / colorant.

' n SW Sixth Avenue 8

8 Ecth documents were submitted as " confidential business Portland. OR 9C041:

information" (CBI) and with copies with the CBI material expunged. (503) C9-3696 TDD (303) 29-6993 DEQ-)

i

Oregon Steel Mills K061 Recycling Determination Page 2 Discussion Oregon Administrative Rule (OAR) 34C-100-002 adopts Title 40 Code of Federal Regulations (40 CFR] Parts 260 to 266, 268, 270 and Subparr A of 124.

This means that federal recycling regulations are not only state. regulations, but also under the auspices of federal RCRA authorization the state of Oregon implerents and interprets such regulations.

For recycling interpretive purposes, DEQ uses a series of questions developed by EPA called the " criteria."2 Answers to the questions help us analyze the recycling operation, and then perform a " weight of evidence" analysis to a conclusion of either legiti= ate recycling or " sham" recycling, the difference being-that legitimate recycling involves an economic benefit from the recycling product while " sham" recycling evades proper hazardous waste management.

Based on the two documents submitted by OSM and GIL, DEQ has determined that OSM electric-arc furnace dust is not a hazardous waste when used in the production of roofing granules and ceramic glaze / colorant.

Instead, it is a material used or reused as an ingredient in an industrial process.'

By using the " weight of evidence" standard DEQ finds that there are data and analyses sufficient to determine legitimacy.

Another recycling regulation adopted by the state of Oregon is 5 261.2 (f).

This regulation requires that a recycler must possess a demonstration of legitimate recycling known as "the burden of proof."

If the recycler does not possess an' adequate demonstration, then the default presumption is that the operation is " sham" recycling.

DEQ determines that the two documents fulfill the demonstration of legitimate recycling for roofing granules and ceramic glaze / colorant; however, in addition to the two documents, DEQ's opinion is that the " burden of proof" that OSM must possess should include future documentation of the customers who purchase the glass frit.

This documentation would insure that glass frit is in such products that would constitute legitimate recycling.

The criteria were laid out in an EPA memo (TOC 6 Feeveline, Fran Sylvia Lowrance, Directer of of fice of Solid Waste, dated April 26, 1989) that derives from Federal Register preamble discussions.

3 40 CTR Part 261.2 (c) (5) and 261.2 (e) (1) (1)

Oregon Steel Mills K061 Recycling Determination Page 3 the consideration of environmental risk of the glass fritDEQ's d Addendum provided a good indication of the environmental risk by The comparing leached toxic metal constituents to both the OSM glass frit and the commercial products.

glass frit is environmentally superior,While DEQ cannot say that the environmentally equivalent to similar commercial products.it seems that the frit is Other Issues Need for Part A and Part B Application:

If the glass frit is an ingredient for a product to be appIIed to the land,' then the EAF dust would be a hazardous waste.

This means that the subject to RCRA regulations.glassification furnaces would be But because the proposed products are not land applied, from RCRA regulation due to legitimate recycling.then the glassification require a Part B permit application and recommends that 05M DEQ will not withdraw the Part A application.

Other Products Produced from OSM Glass Frit:

hazardous waste with a similar com=ercial ingredient.One function the criteria are applied to each new product using glass frit as Therefore, an ingredient.

If OSM anticipates selling glass frit as an ingredient for other products, then "the burden of proof" again requires each new product.acequate documentation to substantiate legitimate recycling for l

inspection.

This documentation must be available for DEQ K061 EAF Dust and Off-Specification Glass Frit as Ingredient:

The DEQ determination of legitimate recycling does not fully answer the question, "Where in the glassification process does EAF dust become legally a non-hazardous ingredient?"

For purposes of enforcement, DEQ has determined that all EAF dust outside the glassification building would be considered K061 hazardous vaste.

All EAF dust inside the building would be I

  • 40 CTR Part 261.2 (e) (2) (1)

I

3 oregon Steel Mills K061 Recycling Determination Page 4:

'i considered an ingredient and 'not a. solid waste, except'that any.

l EAF dust found inside the glassification building that is not, or.

.will not,'be.used for glass frit. production will be' considered'

'i K061 waste (e.g.,

off-specification EAF dust, EAF dust spillage).-

off-specification glass frit will be considered an ingredient, just as EAF dust is, when placed or prepared to be t

placed, in the " prepared slag bin."s off-specification glass' frit'not intended for use in.the glassification process will be considered K061 hazardous waste and must be managed:accordingly..

Conclusion OSM submitted two documents to support that glassification:

'l of K061 into a glass frit used as an-ingredient in roofing granules or ceramic glaze / colorants is, indeed, legitimate recycling.

DEQ's review concurs with this position.

This determination regarding legitimate' recycling should not be interpreted as an endorsement'of glassification as the best way to manage K061.

Sincerely, Fred H. Hansen Director 5

l 1

i Chuck Clinton, DEQ Northwest he Tion cc:

Michael F. Gearheard, IPA:Regiot. X Evar Lices, EPA ORD Laboratory Kathi Futornick, ClyGlill Jeffrey W.

Ring, Heller, Ehrman, White & M'Auliffe I

i This bin-is used for storage of of f-specification frit that is eventually.

8 blended with the other ingredients to produce more glass frit.--

I i

O Oregon Steel' Mills'K061' Recycling Determination Page 5 Chuck Clinton, DEQ Northwest Region cc:

1500 S.W. First Avenue Suite 750 Portland, OR 97201-5884 Michael F. Gearheard, EPA Region X 1200 Sixth Avenue (HW-102]

Seattle, WA 98101 Evar Lices, EPA ORD Laboratory 26 West Martin Luther King Drive Cincinnati, OH 45268-1072 Kathi Futornick, CHyGlill S

825 N.E. Multnomah Suite 1300 Portland, OR 97232-2146 Jeffrey W. Ring, Heller, Ehrman, White & PfAuliffe 3400 First Interstate Bank Tower 1300 S.W.

Fifth Avenue Portland, OR 97201-5696 e

4 t