BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CLERK'S
OFFICE
SEP 0 8 2006
IN THE MATTER OF :
STATE OF ILLINOIS
PETITION OF BIG RIVER ZINC
Pollution Control Board
CORPORATION FOR AN ADJUSTED
AS 06-04
STANDARD UNDER 35 ILL . ADM. CODE
(Adjusted Standard -
Land)
720.131(c)
NOTICE OF FILING
To:
See Attached Certificate of Service
PLEASE TAKE NOTICE that on September 8, 2006, we filed with the Clerk of the
Illinois Pollution Control Board the attached
Amended Petition of Big River Zinc
Corporation, copies of which are attached hereto and hereby served upon you
.
Dated : September 8, 2006
One
e Attorneys for
itioner
Big River Zinc Corporation
John W. Watson
Sasha M. Reyes
BAKER & MCKENZIE LLP
One Prudential Plaza, Suite 3500
130 East Randolph Drive
Chicago, IL 60601
+1 312 861 8000
THIS DOCUMENT IS FILED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARDCLERK'S
E C
EOFFICEI
V E D
IN THE MATTER OF :
SEP 0 8 2006
PETITION OF BIG RIVER ZINC
CORPORATION
FOR AN ADJUSTED
STATE OF ILLINOIS
AS 06-04
Pollution Control Board
STANDARD UNDER 35 ILL . ADM . CODE
(Adjusted Standard
- Land)
720.131(c)
AMENDED PETITION OF BIG RIVER ZINC CORPORATION
Petitioner, Big River Zinc Corporation ("BRZ"), by its attorneys, Baker & McKenzie
LLP, hereby amends its Petition to the Illinois Pollution Control Board (the
"Board") under 35
Illinois Administrative Code 720 .130(c) and 720 .131(c) . BRZ seeks a determination that the
electric arc furnace dust ("EAFD") that BRZ will receive at its facility (the "Facility" or the
"BRZ Facility") in Sauget, St . Clair County, Illinois and use as feedstock for a new zinc
recycling process to be employed in its operations at the Facility, is not a solid waste
.
BRZ filed its Petition on June 29, 2006 . On August 4, 2006, the Board entered an order
granting BRZ expedited review in this matter and finding that BRZ had met the jurisdictional
requirement of providing newspaper notice of the Petition . Thereafter, on August 17, 2006, the
Board entered an order (the "Order") directing BRZ to file an amended Petition providing
additional information, as enumerated in the Order . BRZ responds to the five questions posed by
the Board as follows :
1 .
Pre-acceptance Process
a.
BRZ has established a two step process to ensure that EAFD received at the BRZ
Facility is suitable for processing in the LSXEW zinc recovery system . In the first instance,
' BRZ is allowed in its Amended Petition to incorporate by reference the original Petition, rather than
repeating the complete text and accompanying Exhibits of the Petition
. Also, because this Amended
Petition makes no substantive change in the relief requested in the original Petition, re-notice of the
Amended Petition pursuant to 35 IAC 104 .408 is not required . See 35 IAC 104.418(a)
and (d).
BRZ intends to solicit EAFD source material only from facilities that can demonstrate that the
recovered material contains zinc concentrations of acceptable grade for reclamation by BRZ
.
This solicitation will be based first on a historical review of zinc concentrations in EAFD
recovered at a given facility . Given the supply agreement between BRZ and Envirosafe Services
of Ohio, Inc . ("ESOI") and ESOI's broad customer base, historical analysis already exists for
EAFD from most potential suppliers of this zinc source material to BRZ
. For potential suppliers
where analysis is not already available, samples will be collected over a sufficient period of time
prior to any EAFD being shipped to BRZ to determine the appropriateness of the facility as a
supplier of recovered EAFD to BRZ .
The second step in the verification process provides for the sampling of incoming EAFD
to confirm the ongoing suitability of a supplier's EAFD material for recycling at the BRZ
Facility
. BRZ will regularly collect and analyze samples during the unloading of EAFD at the
BRZ Facility . BRZ. will analyze the collected samples utilizing X-ray fluorescence or similar
sampling methodologies commonly employed at RCRA permitted disposal facilities, such as
ESOI's Ohio facility, to obtain an elemental fingerprinting and determine the corresponding zinc
concentrations of the EAFD upon receipt . The results of this sampling will be reviewed on a
regular basis. If the grade becomes non-economically recoverable, BRZ will discontinue the use
of that EAFD source until such time that current source facility analysis once again demonstrates
that the recovered material contains zinc concentrations of acceptable grade for reclamation by
BRZ. Any EAFD shipped from a nonconforming source for any reason would be rejected
through the hazardous waste manifest process either to an alternate facility or back to the
generator . Given ESOI's role in the supply of the EAFD, it is anticipated that many of the
rejected loads would be redirected to the ESOI facility in Oregon, Ohio .
2
b.
It is proposed that the solid waste determination will take effect once any
shipment of EAFD enters the gate and is physically present on the BRZ property
.
c.
BRZ will institute appropriate recordkeeping procedures to document the results
of its pre-acceptance verification and sampling activities as described above . These
recordkeeping procedures shall include providing requested access to these records to the Illinois
Environmental Protection Agency
. The following sampling and recordkeeping conditions are
proposed :
•
BRZ shall maintain records that document the sources of all EAFD material that BRZ
accepts under this adjusted standard ;
• BRZ shall maintain records that demonstrate the completion of pre-acceptance
evaluations and document the results of testing to determine zinc concentrations in
EAFD shipped to the BRZ Facility from individual sources
;
• Representative samples shall be collected and tested in accordance with generally
accepted practices, such as X-ray fluorescence and those specified in "Test Methods
for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication No . SW-
846 (Third Edition) ; and
• BRZ shall maintain the records required under this Order for a period of three years
and shall make such records available for inspection and copying at any reasonable
time during normal business hours upon the Illinois Environmental Protection
Agency's request.
2 .
Zinc Concentration in EAFD
Zinc coating of steel (galvanizing) is a highly efficient and widespread way of protecting
steel from corrosion, thereby prolonging the life of the steel product . The zinc in EAFD is
derived from the zinc associated with galvanized scrap . There are various grades of scrap that
are blended together to produce an iron feed mix of the correct composition to suit the final
product types being produced by an individual steel mill . The scrap feed blend will use different
types and grades of scrap containing differing amounts of galvanized material . Therefore, the
grade of zinc in EAFD will vary from one mill to another
. Furthermore, the scrap recycling
3
process and equipment varies throughout the industry and such variations will affect the nature
of the EAFD, even assuming the same scrap feed . Typically, the grade of zinc in EAFD will be
in the range 15% to 24% as stated in the Petition . However, some mills using zinc rich feeds
may have much higher grades of zinc yielding up to 35% or even higher concentrations of zinc
in EAFD. The opposite is also true ; zinc concentrations in EAFD can fall below the typical 15%
to 24% range
. Concentrations of zinc in EAFD below this typical range can still nonetheless be
processed profitably
. Certainly, BRZ is not targeting for solicitation EAFD with very low grades
of zinc, as processing of such material would ultimately prove uneconomical
. As described
above, a two step acceptance evaluation will be conducted on each source to confirm that only
economically recyclable grades of zinc are processed at the BRZ Facility .
3 .
LSXEW process waste streams and pollution control equipment
The LSXEW process directly produces two waste streams : wastewater and filter cake
.
Two types of pollution control equipment will be used related to the LSXEW process, air
pollution controls and wastewater treatment. (Management of the filter cake is discussed below
in #4 .)
The wastewater will be pre-treated on site through a typical wastewater treatment system
to produce: a) effluent that will be discharged to the American Bottoms Regional Wastewater
Treatment Facility ("American Bottoms") under appropriate discharge authorization, and b)
wastewater residue that will be landfilled off-site.
BRZ currently has a wastewater treatment plant that uses lime and settling technology to
lower the heavy metals content in all process water to categorical standards . The precipitated
solids are filtered, tested regularly to ensure that they are non-hazardous, and suitably disposed
of in a non-hazardous waste landfill in the area . The processed water is combined with all
4
sanitary and storm waters, and the mixture is discharged to American Bottoms for additional
heavy metals removal and mixing with all other industrial and residential wastewater discharges
from the area . The water from the BRZ wastewater plant is sampled hourly and a composite is
made for analysis of each shift's results. The flow and composition of the combined water
leaving the site is measured daily
.
The new LSXEW process will have a wastewater treatment plant . The BRZ Facility will
be operated both to allow a sound internal water balance and to meet American Bottoms and/or
categorical standards, as appropriate, for any regulated constituents . The new plant will also
employ lime and settling technology and will be fitted with additional provisions (potentially
such as sulfide addition or ferrous sulfide addition) to control specific problems if encountered
from time to time
. The residue will be shipped to a non-hazardous waste landfill, and testing and
analyses are underway to determine if it will be possible to produce a gypsum product suitable
for use by the cement industry. Stormwater discharges associated with the new LSXEW process
will also be managed in compliance with applicable requirements and discharged to the new
wastewater treatment plant . Sampling of the processed water at the wastewater plant will be
hourly, and the overall site discharge will be measured and sampled daily .
Air pollution controls will also be utilized for the LXSEW process . The EAFD
unloading, blending, and slurrying will take place in a building maintained under negative
pressure and vented through a baghouse . The contents of rail cars and trucks will be conveyed to
blending silos, which will also be equipped with baghouses. The dust collected in the baghouses
will be recycled back into the start of the process . The slurry tanks will have baghouses with wet
filters to reduce emissions within the building
. The leaching tanks may produce some acid mist
and these tanks will be covered and vented to an alkaline venturi scrubber to remove the fumes
.
5
The EAFD mixing operation will occur within sealed mixing screws in an enclosed building .
The Solvent Extraction (SX) system uses new technology that totally encloses the process . This
is a great advance over traditional "open tank" SX systems
. Therefore, the only emissions of
organic materials from the SX system will be from smaller pump tanks and storage tanks, which
are closed vessels that vent to a thermal oxidizer emission control device
. Finally, a covered
conveyor system will be used to transfer the LSXEW filter cake and wastewater treatment
residue to the area where these wastes will be loaded for off-site shipment, and this load-out area
will also be equipped with baghouses .
4 .
Management of LSXEW waste residue
As explained above in #3, the leaching step of the LSXEW process will generate a solid
waste filter cake . It is possible that a certain quantity of this filter cake may be characteristically
hazardous for certain metals
. The waste will be characterized in accordance with the RCRA
generator standards found at 35 III . Adm . Code Section 722 .111 and the testing methods at 35
IAC 721
. If the filter cake is determined to be non-hazardous, it will be transferred off-site for
disposal
. If the filter cake is found to be characteristically hazardous, it will either be treated on-
site to render it non-hazardous or sent off-site for treatment and disposal at a facility permitted to
accept the waste material.
On-site treatment will involve standard stabilization technologies such as pozzolonic,
oxidation/reduction, and precipitation reactions
. Stabilization reagents will be added to the filter
cake, thoroughly mixed, and then transferred for off-site disposal . The treatment will comply
with the requirements of 35 IAC 722, including the requirements in 35 IAC 722.134 for the
treatment of waste in accumulation tanks or containers . 2 In addition, treatment will be conducted
2 Treatment in tanks or containers is permissible, and does not subject a facility to the RCRA treatment
facility requirements, as long as the accumulation standards and corresponding tank and container
6
within a facility building designed to properly manage the filter cake from generation to loading
for off-site disposal
.
5.
Facility Address
The address for the BRZ Facility is
: Big River Zinc Corporation, 2401 Mississippi
Avenue, Sauget, Illinois 62201
.
WHEREFORE, Big River Zinc respectfully requests that the Board grant BRZ an
adjusted standard in the form of a solid waste determination that the electric arc furnace dust that
BRZ will use as feedstock for a new zinc recycling process to be employed in its operations at
the Facility is not a solid waste .
Dated: September 8, 2006
Respectfully submitted,
John W. Watson
Sasha M
. Reyes
BAKER & MCKENZIE LLP
One Prudential Plaza, Suite 3500
130 East Randolph Drive
Chicago, IL 60601
+1312 861 8000
CHIDMS I /2459344
.1
One o
e Attorneys for Peti er
Big River Zinc Corporation
requirements
10146, 10168
at
; March
35 IAC
24,
7221986).134
are met and provided that the treatment is not thermal treatment
. (56 FR
7
CERTIFICATE OF SERVICE
The undersigned certifies that copies of the
Amended Petition of Big River Zinc
Corporation
were served on this 8th day of September, 2006
.
Upon the following by hand delivery
:
Dorothy Gunn
Clerk of the Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, IL 60601
And upon the following by U
.S. First Class Mail:
Mike Roubitchek
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P
.O
. Box 19276
Springfield, IL 62794-9276
