The Environmental Contribution

Recyclability

The member companies of the SMA are among the world’s most competitive steel producers and make a contribution each year to the environment through recycling that is unsurpassed in any industry.

By using steel scrap as a primary feedstock, EAF steel companies prevent millions of tons of ferrous scrap from being deposited as refuse in landfills, or from littering the countryside. Massive tonnages of steel scrap in the form of fourteen million automobiles junked each year, or structural shapes from demolished buildings, or discarded home appliances are recaptured from the scrap supply and recycled to provide new steel products every year in electric arc furnaces.

In fact, steel is recycled five times more than the sum of all of the other metals combined (aluminum, copper, lead, nickel, chromium, and zinc).

In addition to its strength and value, one of steel’s best attributes is its recyclability. Steel can be recovered over and over again to make brand new, high quality products. The White House Task Force on Recycling listed eight categories of benefits from recycling, all applicable to steel:

  • Reduces the need for new landfills;
  • Prevents emissions of many air and water pollutants;
  • Saves energy;
  • Supplies valuable raw materials to industry;
  • Creates jobs;
  • Reduces greenhouse gas emissions;
  • Stimulates the development of greener technologies; and
  • Conserves resources for our children’s future.

The recyclability of steel in North America’s electric arc furnaces is one of the best environmental success stories of the of the past ten years. As the largest recyclers, SMA members are extremely proud of their contribution to the nation’s environment.

Guiding Environmental Principles

The Guiding Environmental Principles For Members of the Steel Manufacturers Association demonstrate a commitment by each company to the nation’s environment, to local communities and to the people who work in and live in areas surrounding steel mills.

The SMA Board of Directors has adopted the following principles:

Guiding Environmental Principles
for Members of the
Steel Manufacturers Association

Recognizing that steel is the most recycled material in North America, we advocate:

  • the promotion of steel recycling;
  • the implementation of continuous improvement in environmental performance; and
  • the participation with government and community groups in creating responsible laws, regulations, and standards to safeguard the community and the environment.

Recognizing that people are our most important asset, and that we live in the communities surrounding the facilities, we commit to:

  • the integration of environmental awareness in our operations by educating our employees on the environmental impact of our processes and involving them in decisions that will have a direct impact on the environment;
  • meet or exceed the requirements of environmental laws and rules;
  • the distribution of information to local communities about our operations and their impact on the environment through reasonable efforts; and
  • the advancement of research on the health, safety, and environmental effects of our industry.

Recognizing that steelmaking is an energy intensive process, we encourage:

  • the optimization of energy efficiency of our production processes for the conservation of natural resources.

Annual Distinguished Recycler Award

Recognizing the need to acknowledge the environmental accomplishments of the steel industry, the SMA will present its 2004 Annual Distinguished Recycler Awards to Nucor Steel – Arkansas, and to the Filter Manufacturers Council for their contributions to the environment, the community, and the industry through recycling.

Nucor Steel – Arkansas has made significant contributions to the environment through its innovative process of the utilization of a waste stream of a neighboring industrial facility (Proctor & Gamble) to mix with an effluent from its own mill. The result of the process is an overall net positive decrease in the amount of material entering landfill.

The Filter Manufacturers Council has made significant contributions to the electric arc furnace iron & steel industry and to the environment through the promotion of the recycling of used oil filters, as well as through the Council’s work to eliminate lead- terne plating in the manufacture of new oil filters. The results of the FMC’s efforts can be seen in the continued increase in recycling rates of used oil filters.

Past recipients of the SMA Annual Recycler of the Year Award have included Tempel Steel, the Delaware Solid Waste Authority, Gallatin Steel, TAMCO, Gerdau Ameristeel, Gerdau Ameristeel - Courtice and the Regional Municipality of Waterloo’s Cambridge Landfill, Jersey Shore Steel and the Clinton County Landfill, and the Florence Special Disabilities and Special Needs Board and Nucor Steel – Darlington.

Mercury

As the largest recyclers in North America, the member companies of the Steel Manufacturers Association are committed to practical and cost-effective removal of mercury from the scrap metal supply. Mercury provides no benefit to steel minimills and has no place in the manufacture of steel. Unfortunately, several of the products recycled at minimills contain mercury, most notably vehicles. The use of mercury in these products is unnecessary and results in minimal cost savings to the manufacturer. To avoid mercury entering the environment, pollution prevention is the key. Mercury must be eliminated from the design of new vehicles and other products. In the short term, mercury switches and other components must be removed from end-of-life vehicles and other products prior to crushing or shredding. In contrast, removing mercury from steel industry air emissions is technically infeasible. Likewise, mercury can not be removed from the steel mill scrap feed after the recycled material has been crushed or shredded. End- of-pipe regulations are not only expensive and impractical but also would threaten the viability of steel mills’ valuable recycling efforts. The SMA supports a national pollution prevention initiative to control mercury in the scrap supply at the source of the problem and that includes all relevant stakeholders.

The SMA supports a national pollution prevention initiative to control mercury in the scrap supply at the source of the problem. The initiative has several necessary components:

  • Elimination of mercury from vehicles and other recycled products. This may require federal or state legislation or the exercise of regulatory authority.
  • Education and training of scrap suppliers and salvage yards to increase removal rates of vehicle switches and other mercury- containing materials.
  • Financial incentives to compensate scrap suppliers and salvage yards for their mercury removal efforts. Funding should be provided primarily by vehicle and other manufacturers of products containing mercury. Procedures for providing reimbursements also must be developed.
  • Development of a mechanism to collect and manage recovered switches and other mercury-containing materials.

The SMA is ready and willing to continue its support for realistic mercury removal and recovery programs in which all stakeholders, particularly those that benefit from the use of mercury, contribute to the solution. End-of-pipe regulation of mercury at steel mills is neither feasible nor fair.

Radioactive Scrap

A Major Environmental Problem

Steel companies are confronted each day by the possible presence of radioactive materials in scrap. These materials are usually in the form of:

  • sealed radioactive sources, typically installed in measurement gauges used in manufacturing operations or in hospital equipment;
  • scrap from decommissioned nuclear power and US DOE facilities; and
  • imported scrap.

The presence of spent radioactive materials in the ferrous scrap supply presents significant health and safety risks to steel workers and to the general public.

In the past fifteen years, over 50 known incidents have occurred worldwide in which metals companies inadvertently melted shielded radioactive sources. Fortunately, none of these incidents resulted in worker injuries or loss of life. But they have caused major economic injury.

Current US Nuclear Regulatory Commission (NRC) regulations for generally licensed devices do not provide for tracking of individual owners. The lack of accountability makes it easy for licensees negligently to discard sealed sources in scrap and evade prosecution. In response to this regulatory gap, steel companies have installed sophisticated radiation detection systems to monitor all incoming shipments of scrap by truck , rail and vessel. However, no system is airtight.

The economic effects of inadequate control of radioactive sources include: the purchase of sophisticated detection systems, training personnel in detection, delays in steelmaking operations, costs for disposal of sources that steel companies find, and worst of all, for a company that has inadvertently melted a radioactive source, millions of dollars of business interruption losses and clean-up costs.

Historically, penalties for improper source disposal have been minuscule – often a fine of a few thousand dollars levied against the negligent licensee for a source that, if inadvertently melted, would cost a steel company many millions of dollars. (The total cost associated with decontaminating a facility after an inadvertent melting of a radioactive device can range up to $15 million). Recently, NRC amended its enforcement policy to allow fines equal to the cost of proper disposal. The SMA lauds this change in policy. Also, NRC recently proposed an annual registration program for generally licensed sources. SMA has been working with NRC for almost a decade on this issue and urges the Commission to proceed expeditiously with a final rule.

No Contaminated Scrap from Decommissioned Facilities

For the past 25 years the US Department of Energy (DOE) has maintained a policy of “free release” of obsolete equipment and materials at weapons production and research facilities across the country. Free release means that the material is cleaned, and if necessary, declassified, and then released into the stream of commerce for unrestricted use. In the past, the amount of such material released was not significant. Following the end of the Cold War, DOE is decommissioning and dismantling several facilities across the nation and expects to release hundreds of tons of scrap metal from these facilities for recycling at steel companies without any dose-based clearance standards.

SMA member companies have not, and will not, accept scrap that is known to be radioactively contaminated.

SMA members would be the primary intended recipients of this scrap, much of which is radioactively contaminated, and stand to suffer serious economic injury from this policy. SMA members are trying to keep radioactivity out of their mills and therefore oppose free release. DOE’s policy is simply inequitable and shortsighted and could develop into a public policy disaster.

Free release of radioactive scrap could adversely affect the marketability of steel products made from recycled scrap. The public perception is that any level or type of radioactivity is unsafe. Metal recycling industries have worked hard to build public confidence in the safety and utility of products made from recycled metal. This confidence would be lost if the public, rightly or wrongly, perceives such products to be unsafe. For this reason, SMA member companies have not, and will not, accept scrap that is known to be radioactively contaminated.

Furthermore, the unrestricted release of radioactively contaminated metal from nuclear facilities for recycling would tarnish the image of recycling, and potentially lead consumers to avoid products made of steel, especially those with a high recycled scrap steel content.

DOE should adopt a policy of restricted release of scrap, provided the scrap meets specified health-based standards. Restricted release should be specifically limited to either of the proposed eligible uses:

  1. Recycling or recovery at a dedicated, licensed facility for use only at an NRC-licensed fuel cycle facility or at nuclear facilities operated by the DOE where the use of low level radioactive material is not an issue; or
  2. Disposal into licensed radioactive waste landfills, or into municipal or industrial landfills, as long as the material meets the specified health-based levels. If these levels are met, the landfill need not be licensed as a radioactive waste landfill.

DOE should not authorize any release of material from nuclear facilities until it establishes health-based standards that reflect sound science. NRC is currently evaluating whether and how to establish dose-based clearance levels that will adequately protect health and safety. It is expected that DOE would follow NRC’s standards. It is prudent public policy that material not be released until firm, publicly accepted standards and procedures for attaining and measuring compliance are developed through the standard setting process.

SMA opposes policies or rulemaking activities that sanction the free release of radioactively contaminated scrap metals from nuclear power plants or DOE facilities, without any additional regulatory controls. The US steel industry cannot be the dumping ground for the discards of the global nuclear age.

Clean Air

Clean Air Act

For the past several years, EPA has been aggressively implementing its stationary source emission control program through expanded enforcement under the New Source Review (NSR) Program. NSR requires new or modified sources to construct state of the art emission controls (Best Available Control Technology (BACT)). As currently being implemented, however, EPA is seeking to require BACT-level controls and emission limits for minimal process changes or modest maintenance activities that are unlikely to cause any actual significant increase in emissions. As a consequence, industry has little or no incentive to modernize or improve the efficiency of operations. SMA is working with EPA to develop alternative strategies for New Source Review reform that will yield genuine air quality benefits without penalizing industry for capital investments intended to improve overall manufacturing efficiency.

As a result of a recent court decision, EPA has been given the green light to begin implementation of new, more stringent National Ambient Air Quality Standards (NAAQS) for ozone and fine particulate matter (PM2.5). The new standards will be implemented on a state-by-state basis through updates to State Implementation Plans over the next several years. SMA will continue working with EPA to devise the most efficient means of implementing the new standards.

Electric arc furnace (EAF) facilities constructed or modified after 1982 are required to meet a New Source Performance Standards limit of 3 percent opacity from baghouse facilities. EAF baghouses constructed with a single stack must install a Continuous Opacity Monitor (COM) to ensure proper baghouse performance. Compliance with the 3 percent opacity standard is measured via Method 9, a visual observation method. Because COMs are generally not accurate for readings below 10 percent opacity, the NSPS COMs data were traditionally used merely as an indicator of baghouse performance, and not a means of measuring compliance with the 3 percent opacity standard. However, in recent years, state and citizen enforcers have begun to rely upon the raw COM data as credible evidence of a violation of the NSPS opacity limits. As a consequence, SMA has been working with EPA to develop an alternative means to measure baghouse performance and obtain normal EPA recognition that COMs data are not suitable for determining compliance with the 3 percent opacity limit.

Clean Water

Effluent Limitations Guidelines

Pursuant to a consent decree entered into between EPA and the Natural Resources Defense Council (NRDC), the Iron and Steel Industry was selected as an industry for which EPA is required to develop revised Clean Water Act effluent limitation guidelines (ELGs). ELGs are the technology-based standards upon which wastewater discharge permit limits are established.

On October 17, 2002, EPA issued a final Iron and Steel ELG rule that declined to revise the existing limitations and standards applicable to electric arc furnace steel makers. The final rule was a success for SMA’s effort to demonstrate to EPA that more stringent limits proposed in December 2000 were unreasonable and not supported by data representative of facilities in the industry. Accordingly, the existing ELG standards at 40 C.F.R. Part 420 remain in effect.

Clean Water Act

Congressional reauthorization of the Clean Water Act is long overdue. Advances in technology, changing priorities, diminishing returns, and movement away from the traditional command-and-control regulatory approach have fueled industry’s desire to modernize the Clean Water Act approach. The Clean Water Act has been weakened by significant litigation and statutory obligations that are neither efficient nor provide significant environmental benefit. Most stakeholders believe the statute must be modernized.

Waste Generation

EAF Dust Disposal

EAF steel producers collect emissions from the scrap melting furnaces in special units called baghouses. The emissions are captured in the form of a dust (baghouse dust) which is a listed hazardous waste (EPA hazardous waste code KO61). EAF dust is rich in zinc and also contains trace levels of lead, cadmium and chromium.

Currently, options for recycling and disposal of this dust are limited. There is insufficient capacity and inadequate competition in the market to recycle EAF dust. The only other option is chemical treatment and disposal.

EAF dust represents the largest hazardous waste stream in the US by weight, not by toxicity. The SMA will continue to communicate to the EPA that EAF dust should be delisted as a hazardous waste to encourage wider recycling. We shall emphasize to the EPA that it should encourage EAF steel production to promote the recycling of scrap containing the residuals of concern, and their capture in the baghouse and safe recycling or disposal. Thus, we continue to urge EPA to maximize the number of environmentally sound options for KO61 recycling or disposition.

Definition of Solid Waste

In October 2003, following several court decisions and many years of internal agency deliberations, EPA issued a proposed rule concerning EPA’s jurisdiction over recycling activities of secondary materials. The stated purpose of the proposal is to establish a basis for excluding from the definition of solid waste certain recycled secondary materials not intended for discard and thus not subject to hazardous waste requirements under Subtitle C of the Resource and Conservation and Recovery Act (“RCRA”). Unfortunately, EPA’s narrow proposal would only exclude from RCRA jurisdiction those materials that are recycled in a “continuous industrial process within the [same] generating industry.” This limited exclusion ignores the common sense views, enunciated by the D.C. Circuit Court of Appeals, that (1) a material is not subject to RCRA unless it is discarded by being abandoned or thrown away; and (2) a material that is legitimately recycled is not discarded. SMA believes that EPA can fulfill the court’s mandate, promote recycling, and adequately protect the environment by taking the position that all materials that are legitimately recycled and managed pursuant to a reasonable set of specified conditions are excluded from RCRA jurisdiction.

Superfund Reform

The Comprehensive Environmental Response, Compensation and Liability Act of 1980 (“CERCLA”), or “Superfund,” was initiated with the purpose of cleaning up hazardous waste sites and thus protecting human health and the environment. The program today is bogged down in litigation with the Courts attempting to sort out the responsibilities for cleanup. The Act needs to be reformed in order to expedite the pace of cleanups, eliminate litigation costs, and return sites to productive use. Although some Superfund reform has occurred, including legislative incentives for redevelopment of Brownfield sites, more progress is needed to insure that scarce resources are directed appropriately.

Here are some of the problems associated with the Superfund program:
  • Cleanup standards are arbitrary and inflexible.
  • The liability system thrives on protracted litigation and inequity.
  • The federal government second-guesses the states.
  • Natural resource damage claims can be exorbitant because the law is unfocused and unclear.
  • Federal lands cannot be put back into productive use.
  • Superfund taxes are not directed to cleanup.

From the list above, it is clear that a Congressional review and legislative update of CERCLA is a necessity.