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Environmental Code of Practice for Non-Integrated Steel Mills: section 4

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Section 4: Recommended Environmental Protection Practices

This section presents recommended mitigative measures for activities of potential environmental concern. These recommendations were derived from regulatory and non-regulatory standards, in particular on environmental practices, published by various agencies and organizations.

The overall objective of the Code is to identify minimum environmental performance standards for new non-integrated steel mills and to provide a set of environmental performance goals for existing mills to achieve through continual improvement over time.

Application of the recommendations to individual mills may involve practices that are not mentioned in this Code of Practice but achieve an equivalent or better level of environmental protection.

Site-specific municipal, provincial, federal, legal, and non-legal requirements must be taken into account where they exist.

4.1 Atmospheric Emissions Management

The guidelines recommended in RN101 and RN102 are based on the application of demonstrated emission control technologies, such as fabric filters, and are generally considered technically and economically feasible for application to non-integrated steel mills. These guidelines are consistent with standards and practices currently in place in Canada, the United States, Europe, and other jurisdictions. More stringent criteria may be required by local regulatory authorities where deemed appropriate to the circumstances.

The effective control of particulate emissions will result in attendant reductions of metal emissions, which, in combination with the management practices recommended in RN103, RN104, and RN105, will reduce the overall environmental impact associated with air releases of CEPA toxics by the steel sector.

4.1.1 Release Guidelines for Particulate Matter

Recommendation RN101 Each facility should target on achieving the following emission guideline for particulate matter after the emission control device:

  1. electric arc furnaces: 20 mg/Nm3.

Emission testing should be carried out on an annual basis in a manner that is consistent with Reference Methods for Source Testing: Measurement of Releases of Particulate from Stationary Sources,11 as amended from time to time. In cases where the emission control system does not have a stack, emission testing should be carried out in a manner that is consistent with the U.S. Environmental Protection Agency Method 5D - Determination of Particulate Matter Emissions from Positive Pressure Fabric Filters.12 It is recognized that particulate emission estimates for facilities without stacks are typically less accurate than emission estimates for facilities equipped with stacks and that relative accuracy must be taken into account in assessing the results of tests conducted in accordance with Method 5D.

More stringent criteria may be required by local regulatory authorities where deemed appropriate to the circumstances.

4.1.2 Environmental Performance Indicator

Recommendation RN102 Each facility should target on limiting particulate emissions in accordance with the following:

  1. electric arc furnaces: less than 150 grams per tonne of raw steel produced.

The calculation of this Environmental Performance Indicator should be undertaken in accordance with Section A.1 of Appendix A.

4.1.3 Collection of Electric Arc Furnace Emissions

Recommendation RN103 Adequately sized facilities should be engineered and installed, and documented operating and maintenance procedures should be developed for the collection of emissions associated with:

  1. primary steelmaking including both primary and secondary emission control, scrap, and other materials charging operations, tapping and slagging operations, and slag transfer and processing; and
  2. secondary steelmaking including hot metal transfer, furnace operations, and continuous casting operations.

4.1.4 Control of Fugitive Emissions

Recommendation RN104 Adequately sized facilities should be engineered and installed, and documented procedures should be developed for the control of emissions associated with materials handling and storage operations, steelmaking operations, the crushing and screening of slag, the disposal of by-products and wastes, and maintenance operations. These procedures should include:

  1. enclosure and/or hooding with emission controls, where appropriate, of those operations that are potential sources of fugitive emissions;
  2. operating practices that minimize fugitive emissions from those operations that are not amenable to enclosure or hooding; and
  3. criteria for building, working, and maintaining bulk-material storage piles.

4.1.5 Chlorinated Solvents Used in Solvent Degreasing

Recommendation RN105 Documented procedures for the control or elimination of chlorinated solvent emissions from degreasing operations should be developed and implemented in accordance with the multi-stakeholder Strategic Options Report13for solvent degreasing and the associated regulations that may be promulgated from time to time.

4.1.6 Ambient Air Quality Monitoring

Recommendation RN106 An ambient air quality monitoring program should be developed and implemented by each facility, in consultation with the appropriate regulatory authorities, with the objective of enabling the facility to demonstrate that operations are being conducted in a manner that is consistent with the National Ambient Air Quality Objectives for Air Contaminants14 as amended from time to time. This program should include monitoring of particulate matter (total, PM10, and PM2.5), taking into account:

  1. the location of emission sources under the control of the facility operator; and
  2. local meteorological conditions such as direction of the prevailing winds.

4.2 Water and Wastewater Management

Technologies capable of achieving the criteria recommended in RN107 and RN108 have been demonstrated and are considered technically and economically feasible for application to non-integrated steel mills. These criteria are consistent with standards and practices currently in place in Canada, the United States, Europe, and other jurisdictions.

Although limits have not been prescribed for all parameters of potential environmental concern, the application of technologies capable of achieving the specified criteria, in combination with the water and wastewater management practices recommended in RN109 through RN112, will reduce the overall environmental impact associated with water use and wastewater discharges. More stringent criteria may be required by local regulatory authorities where deemed appropriate to the circumstances.

4.2.1 Effluent Guidelines

Recommendation RN107 All wastewater treatment facilities approved for construction and operation after the publication of this Code of Practice should be designed, constructed, and operated to achieve the following effluent criteria prior to release to cooling water or to local receiving water body:

Wastewater treatment facilities approved by the appropriate regulatory authorities prior to the publication of this Code of Practice should be so operated that effluent quality is as close to satisfying the above-listed criteria as is practicably possible.

Wastewater testing should be carried out on a continuous basis for pH, on a daily basis for total suspended solids, and on a weekly basis for the balance of the substances. Toxicity testing should be conducted quarterly.

Wastewater sampling and analyses should be carried out in accordance with documented, performance-based standards approved by the appropriate regulatory authorities.

On a continuous basis:

pH
6.0-9.5

On a monthly average basis:

Total suspended solids (TSS)
25 mg/l
Chemical oxygen demand (COD)
200 mg/l
Oil and grease
10 mg/l
Cadmium
0.1 mg/l
Chromium (total)
0.5 mg/l
Lead
0.2 mg/l
Mercury
0.01 mg/l
Nickel (total)
0.5 mg/l
Zinc
0.5 mg/l
Toxicity :
No more than 50% mortality in 100% effluent when tested in accordance with Environment Canada Reference Methods 1/RM/13 15 and 1/RM/14. 16

4.2.2 Environmental Performance Indicators

Recommendation RN108 Each facility should target on limiting total suspended solids discharges from wastewater to less than:

  1. 20 grams per tonne of raw steel for facilities without cold forming and finishing operations; and
  2. 30 grams per tonne of raw steel for facilities with cold forming and finishing operations.

The calculation of these Environmental Performance Indicators should be undertaken in accordance with the methodology presented in Section A.2 of Appendix A.

4.2.3 Wastewater Collection

Recommendation RN109 All wastewater streams that may exceed the effluent criteria specified in RN107 should be directed to an approved treatment facility prior to discharge to a local receiving water body. To the extent practicable, system designs should provide for the segregation and collection of similar wastewaters (e.g. oily, acid, cleaning, and sanitary wastes).

4.2.4 Water Use/Reuse

Recommendation RN110 Water use should be minimized through the reuse or recycling of water and the cascading of cooling water and wastewater between production processes. Facilities should target on achieving 90% reuse of water. Flow measurements should be carried out in accordance with documented, performance-based standards approved by the appropriate regulatory authorities. Engineering design data or estimates should be used where flow measurements are not feasible.

The calculation of this Environmental Performance Indicator should be undertaken in accordance with the methodology presented in Section A.3 of Appendix A.

4.2.5 Wastewater Containment Sizing

Recommendation RN111 Wastewater collection and containment facilities constructed after the publication of this Code of Practice should be designed to contain the maximum volume of liquid that could reasonably be expected to be in storage prior to any of the following events, and:

  1. the maximum volume of wastewater that would be generated during the time required to shut down wastewater generating processes, plus 50%;
  2. 110% of the volume that could enter the containment facility in the event of a leak or spill; or
  3. the accumulated precipitation from a 50 year return period, 24-hour precipitation event that is collected in an outdoor containment (e.g. rain that falls on the open surface or inside the containment berm).

4.2.6 Environmental Effects Monitoring

Recommendation RN112 An environmental effects monitoring program should be developed and implemented where appropriate by each facility in consultation with the appropriate regulatory authorities. This program should be sufficiently comprehensive to enable the facility to:

  1. measure changes in receiving water quality, aquatic sediments, and important aquatic and terrestrial organisms; and
  2. assess the need to incorporate changes in operational activities and procedures affecting the receiving environment.

The frequency and duration of this monitoring activity should be assessed, in consultation with the appropriate regulatory authorities, on the basis of test results.

4.3 Waste Management

For the purposes of this Code "wastes" are defined as substances or objects that are disposed of, or are intended to be disposed of, or are required to be disposed of by the provisions of national, provincial, or municipal law.17 The recommendations presented in this section are based on guidelines, practices, and procedures currently in place in Canada with regard to the management of wastes generated by industrial facilities. The nature of the waste material (e.g. hazardous, solid, liquid), local site conditions, and local regulatory requirements should be considered in the development of waste management plans and strategies. More stringent requirements may be stipulated by local regulatory authorities where deemed appropriate to the circumstances.

4.3.1 Location and Construction of Waste Disposal Sites

Recommendation RN113 Expansions to existing waste disposal sites that extend beyond the spatial bounds of areas that have been approved by the appropriate regulatory authority, before the publication of this Code of Practice, and location and construction of new sites should be undertaken so as to ensure that:

  1. the site plan is updated to show clearly the location and dimensions of the new or expanded site;
  2. the perimeter of the disposal area is far enough away from all watercourses to prevent contamination by runoff, seepage, or fugitive emissions;
  3. the surface drainage from off-site areas is diverted around the disposal area;
  4. the expanded area is hidden from view by fences, berms, or buffer zones to the extent practicable; and
  5. the beneficial uses of the site after closure have been considered.

4.3.2 Development of Solid Waste Disposal Sites

Recommendation RN114 Solid waste disposal sites should be developed in accordance with the following practices:

  1. the disposal area should be developed in modules or cells throughout its operational life;
  2. all wastes should be so placed that they have physical and chemical stability suitable for land reuse;
  3. contouring, capping, and reclamation of cells should be undertaken throughout the operating life of the site and, where feasible, should include the re-establishment of vegetation as a means of controlling fugitive emissions and the erosion of side slopes; and
  4. all disposal sites should be reclaimed for beneficial uses before final closure.

4.3.3 Management of Waste Disposal Sites

Recommendation RN115 All waste disposal sites should be managed throughout their operational life in accordance with documented, site-specific waste management plans approved by the appropriate regulatory authority so that:

  1. solid, liquid, and hazardous wastes are disposed of only in facilities specifically designed, approved, and operated for that purpose;
  2. access to the site is controlled and disposal activities are supervised by trained personnel; and
  3. records are maintained of the types, approximate quantities, and point of origin of the wastes.

4.3.4 Monitoring of Waste Disposal Sites

Recommendation RN116 A groundwater monitoring program should be developed, to the extent that is feasible, for all waste disposal sites in accordance with the following guidelines:

  1. a permanent system of appropriately located piezometers and wells should be provided for monitoring the quantity, quality, and flow direction of groundwater;
  2. a program of pre-operational monitoring of groundwater regimes that may be affected by new facilities should be initiated at least one year prior to the commencement of disposal activities;
  3. groundwater samples should be collected at least quarterly from all monitoring wells during the first two years of well operation and at a frequency based on the results of this test program in subsequent years; and
  4. each groundwater sample should be analyzed for pH, total dissolved solids, and other appropriate (site-specific) parameters.

4.3.5 Liquid Storage and Containment

Recommendation RN117 Liquid storage and containment facilities should be designed and constructed to meet the requirements of the appropriate standards, regulations, and guidelines of the pertinent regulatory agency. This recommendation applies to liquid fuels, acids, petroleum products, solvents, and other liquids that are combustible or potentially harmful to the environment.

4.3.6 Reduction, Reuse, and Recycling

Recommendation RN118 Each corporate entity responsible for the operation of a non-integrated steel mill should develop, implement, and maintain a reduction, reuse, and recycling program that:

  1. identifies opportunities for in-plant reduction, reuse, and recycling of wastes;
  2. develops and implements plans for the evaluation and implementation of reduction, reuse, and recycling opportunities;
  3. identifies and evaluates market opportunities for waste with a view to maximizing waste reduction, reuse, and recycling (this includes the sale of by-products, such as slag, that would otherwise be considered wastes); and
  4. develops and implements a research and development program for reducing, reusing, and recycling residual wastes.

4.4 Best Environmental Management Practices

In the context of this Code of Practice, Best Environmental Management Practices (BEMPs) can be broadly defined as those activities, actions, processes, and procedures that go beyond legal requirements in helping to ensure that facilities have minimal impact on the environment in which they operate. The effective development and implementation of BEMPs will also facilitate efforts to achieve continual improvement in the overall environmental performance of non-integrated steel mills.

The recommendations presented in this section are based on the policies, principles, and commitments advanced by Environment Canada, the CCME, provinces, the Canadian Steel Producers Association, and the International Iron and Steel Institute.

4.4.1 Implementation of an Environmental Management System

Recommendation RN119 Each facility should develop, implement, and maintain an environmental management system that is consistent with the requirements of a nationally recognized standard such as ISO 14001.18

4.4.2 Environmental Policy Statement

Recommendation RN120 Each facility should develop and implement an environmental policy statement. The International Iron and Steel Institute's Statement on Environment, provides a good example of the principles that should be considered in the development of the policy statement.

4.4.3 Environmental Assessment

Recommendation RN121 The development of new facilities and changes to existing facilities that could significantly increase releases to the environment should be subjected to an internal environmental assessment process, with the aim of identifying potential problems and formulating cost-effective solutions that address the concerns of stakeholders. This self-assessment process should be initiated during the early stages of pre-project planning and continue as an iterative process through the project design, construction, and operations phases. Consideration should be given to potential impacts on air quality, water quality, water supply and use, land use, flora and fauna, and local infrastructure.

4.4.4 Emergency Planning

Recommendation RN122 Each facility should develop and implement an Emergency Plan aimed at ensuring that facility management meets all legal requirements in developing, maintaining, exercising, and reporting emergency preparedness and resource activities. This plan should be consistent with a nationally recognized guideline such as the Canadian Standards Association's Emergency Planning for Industry Major Industrial Emergencies.19 An appropriate emergency plan should:

  1. ensure the safety of workers, response personnel, and the public;
  2. reduce the potential for the destruction of property or for actual product losses;
  3. reduce the magnitude of environmental and other impacts;
  4. assist response personnel in determining and performing proper remedial actions quickly;
  5. reduce recovery times and costs; and
  6. inspire confidence in response personnel, industry, and the public.

4.4.5 Pollution Prevention Planning

Recommendation RN123 Each facility should develop and implement a Pollution Prevention Plan aimed at avoiding or minimizing environmental releases that is consistent with a nationally recognized guideline such as the Canadian Standards Association’s Guideline for Pollution Prevention.20

4.4.6 Decommissioning Planning

Recommendation RN124 Planning for decommissioning should begin in the design stage of the project life cycle for new facilities and as early as possible in the operating stage for existing facilities. Decommissioning should be carried out in a way that ensures that limited adverse risk to the environment or human health will remain after closure. All site closures and associated decommissioning activities should be undertaken in accordance with the CCME’s National Guidelines for the Decommissioning of Industrial Sites.21

4.4.7 Environmental Training

Recommendation RN125 Each facility should establish and maintain procedures to identify its environmental training needs and ensure that all personnel whose work may create a significant impact upon the environment have received appropriate training. The organization should also require that contractors working on its behalf are able to demonstrate that their employees have the requisite training. The environmental training program should include:

  1. a list by job title or classification of all personnel that require training; and
  2. an outline of the topics to be covered, the training methods to be used, and the required frequency of refresher training for each group of personnel.

4.4.8 Environmental Facility Inspection

Recommendation RN126 Each facility should develop and implement an environmental inspection plan including:

  1. documented procedures for the inspection of each environmental facility including air emission control equipment; wastewater treatment facilities; liquid handling, storage, and containment facilities; waste handling, storage, and containment facilities; and air emission and wastewater monitoring and control instrumentation;
  2. visual observations for air emission excursions and liquid leaks;
  3. a documented schedule for inspections including timing of inspections and identification of a responsibility centre;
  4. documented procedures for the reporting of inspection results to both internal management and external agencies; and
  5. documented procedures for follow-up to inspection reports.

4.4.9 Monitoring and Reporting

Recommendation RN127 Documented procedures for the monitoring and reporting of environmental performance data should include:

  1. the identification of all parameters to be monitored and the associated sampling frequency;
  2. definition of the procedures and protocols to be followed in sample collection, preservation, handling, shipment, and analysis;
  3. action(s) to be undertaken when prescribed environmental criteria have been exceeded;
  4. the means by which data are to be reported to government agencies and other stakeholders;
  5. quality assurance/quality control of the monitoring data;
  6. reporting to the National Pollutant Release Inventory (NPRI) and, where applicable, the Accelerated Reduction/Elimination of Toxics (ARET) program; and
  7. reporting on the status of implementation of this Environmental Code of Practice.

4.4.10 Environmental Auditing

Recommendation RN128 Each facility should conduct periodic internal environmental audits throughout the operating life of the facility as a means of assessing environmental risk, ensuring conformance with regulatory, appropriate non-regulatory, and corporate requirements, and identifying opportunities for improving environmental performance. The recommendations advanced in this Code of Practice should be included in the audit criteria.

4.4.11 Environmental Performance Indicators

Recommendation RN129 Each facility should develop a set of environmental performance indicators that provide an overall measure of the facility’s environmental performance. These indicators would include a broad and practical set of ecological and economic elements that offer significant opportunities to link environmental performance to financial performance. An Environmental Performance Data Sheet that could be used for the development of environmental performance indicators is contained in Appendix B.

4.4.12 Life Cycle Management

Recommendation RN130 Each corporate entity responsible for the operation of a non-integrated steel mill should develop and implement a Life Cycle Management (LCM) Program aimed at minimizing the environmental burdens associated with the materials used and produced by its steelmaking facilities over the product life cycle. The LCM Program should include consideration of:

  1. types of materials used;
  2. sources of supply of materials;
  3. sources of energy used;
  4. type and amount of packaging; and
  5. management of manufacturing by-products and wastes.

A summary of the International Iron and Steel Institute’s Policy Statement on Life Cycle Assessment is available on their website.

4.4.13 Community Advisory Panel

Recommendation RN131 Each facility should establish a Community Advisory Panel to provide a forum for the review and discussion of facility operations, environmental concerns, emergency preparedness, community involvement, and other issues that the Panel may decide are important.

The range of constituency categories could include local residents.

The Panel should be an advisory group and not a decision-making body.

4.4.14 Other

Other recommendations may follow.

Footnotes

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