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HomeMy WebLinkAboutIndustrial Discharge Permit Renewal - Cleveland-Cliffs New Carlisle Works April 21, 2026 Board of Public Works City Hall 215 S. Dr. MLK Jr. Blvd South Bend IN 46601 RE: Renewal of Industrial Wastewater Discharge Permit Dear Board Members: The Division of Wastewater Department of Public Works recommends approving the renewal of the Industrial Discharge Permit for Cleveland-CliƯs New Carlisle Works (formerly known as Cleveland- CliƯ TEK and Cleveland-CliƯ Kote), on May 12, 2026, Board of Public Works meeting. Cleveland-CliƯ New Carlisle Works is a metal finisher under categorical standards 40 CFR 420.126, 420.106, 420.96, 420.08, and 433.17. Cleveland-CliƯ New Carlisle Works’s requirements were reviewed for necessary changes to ensure the industrial permit remains legally substantiated. After review of requirements and historical data, pollutant limitations for select parameters have been adjusted. Otherwise there have been no significant changes to the permit. If you should have any questions, please do not hesitate to contact me (574)-235-5798 or at sshane@southbendin.gov. Sincerely, Serena Lozano-Shane Pretreatment Manager Division of Wastewater Department of Public Works 3113 Riverside Drive South Bend IN 46628 Enclosures - Industrial Discharge Permit Board of Public Works Signature Page, Park I EƯluent Limitations, Agenda Request Form Cleveland-Cliffs New Carlisle Works Industrial Wastewater Discharge Permit page 11 of 55 Facility Description The Cleveland-Cliffs New Carlisle Works I L.P. facility engages in the acid pickling and cold rolling of steel coils at the Continuous Descale Cold Mill. A Continuous Anneal Process Line also includes nickel electroplating and a skin pass mill. The Cleveland-Cliffs New Carlisle Works II L.P. facility also engages in electrogalvanizing and hot dip galvanizing of steel strip. The coils are not conversion coated or painted. PART I – EFFLUENT LIMITATION A. Sample Port and Collection Location 1. The sampling site designated for this facility (126) is located on the southeast corner inside a shed where the combined outfall is located. The entire process facility flow is discharged through this sampling location 2. Any discharge of water or waste having a pH lower than 6.0 S.U. or a pH higher than 11.0 S.U. is prohibited. In addition, the permittee’s wastewater discharge shall not exceed the following effluent limitations: Effluent limitations for Sample Site Outfall # 126: Parameter Daily Maximum Limit (mg/L) Monthly Average Limit (mg/L) Arsenic (mg/L) Report* Report* Cadmium (mg/L) Report* Report* Chromium (mg/L) 1.71 1.06 Copper (mg/L) Report* Report* Cyanide (mg/L) 0.74 0.4 Lead (mg/L) Report* Report* Mercury (mg/L) 0.00019 -na- Naphthalene (mg/l) 0.009 -na- Nickel (mg/L) 2.46 0.8 Oil and grease (mg/l) 300 -na- Oil and Grease TPH (mg/l) 100 -na- Silver (mg/L) Report* Report* Temp (C) 65 -na- Tetrachloroethylene (mg/l) 0.013 -na- TTO (mg/L) 1.32 -na- Zinc (mg/L) 1.81 0.98 PERMIT BRIEFING MEMO 1. Facility Description The Cleveland-Cliffs New Carlisle Works I L.P. facility engages in the acid pickling and cold rolling of steel coils at the Continuous Descale Cold Mill. A Continuous Anneal Process Line also includes nickel electroplating and a skin pass mill. The Cleveland-Cliffs New Carlisle Works II L.P. facility also engages in electrogalvanizing and hot dip galvanizing of steel strip. The coils are not conversion coated or painted. The sampling site designated for this facility (126) is located on the southeast corner inside a shed where the combined outfall is located. The entire facility flow is discharged through this sampling location. Process Lines: The Cleveland-Cliffs New Carlisle Works I L.P. facility has two main process lines and a maintenance procedure: a. Continuous Anneal Process Line (CAPL) which consists of electroplating and a single stand cold rolling skin pass mill operated as a direct application mill(i.e., once-through process water flow). b. Continuous Descale Cold Mill (CDCM) which consists of hydrochloric acid pickling and a cold rolling Tandem Mill equiped for recirculation of the rolling solution. The CDCM has has one fume scrubber that services the pickling portion of the line. All of the above wastewater is treated at the Cleveland-Cliffs New Carlisle Works I L.P. wastewater treatment plant (WWTP) with the exception of the wastewater from the CAPL skin passmill . The CAPL skin pass mill wastewater is treated at the Cleveland-Cliffs New Carlisle Works II L.P. facility. Stormwater from outdoor containment areas is treated at the Cleveland-Cliffs New Carlisle Works I L.P. WWTP. The Cleveland-Cliffs New Carlisle Works II L.P. facility also has two process lines: a. Electrogalvanzing Line (EGL) which is an electroplating line. b. Continuous Galvanizing Line (CGL) which consists of hot dip galvanizing and a single stand cold rolling skin pass mill operated as direct application mill. The CGL is equipped with three fume scrubbers, two for the galvanizing operation and one for the skin pass mill. Process wastewaters from the above processes are treated at the Cleveland-Cliffs New Carlisle Works II L.P. WWTP. Stormwater from outdoor containment areas is also treated at the Cleveland-Cliffs New Carlisle Works II L.P. WWTP. 2. Discharge description: Cleveland-Cliffs New Carlisle Works’s facility wastewater flow is combined prior to discharge. This includes process flows and whole facility sanitary flow as well as storm water that is pumped out of outdoor secondary containment structures. Cleveland-Cliffs New Carlisle Works I L.P. has its own WWTP. The Cleveland-Cliffs New Carlisle Works I L.P. treatment plant treats all wastewater produced at the Cleveland-Cliffs New Carlisle Works I L.P. facility except wastewater from the Nickel Solutions Filter at the CAPL Post Treatment. Periodically, wastewater from the CAPL entry cleaning section and Pretreatment Tank may be sent to the Cleveland Cliffs New Carlisle II L.P. WWTP facility. The Cleveland-Cliffs New Carlisle Works I L.P. facility also treats storm water that is collected in outdoor secondary containments located on the Cleveland-Cliffs New Carlisle Works I L.P. facility grounds. The Cleveland-Cliffs New Carlisle Works II L.P. facility also has its own WWTP. The Cleveland- Cliffs New Carlisle Works II L.P. treatment plant treats all wastewater produced at Cleveland- Cliffs New Carlisle Works II L.P. facility, storm water from secondary containments and the following additional sources: 1. New Carlisle I L.P. wastewaters from the Nickel Solution Filters at the CAPL Post Treatment is treated at the New Carlisle II L.P. WWT Nickel Reclamation System (NRS). 2. Periodic discharge of New Carlisle I L.P. wastewater from the CAPL entry cleaning section may be treated at the New Carlisle II L.P. WWT Oil Waste System (OWS). Periodic discharge of New Carlisle I L.P. wastewater from the Pretreatment Tank may be treated at the New Carlisle II L.P. WWT Oil Waste System. The total average wastewater flow of the Outfall #126 is 1.41 MGD. The Maximum daily total wastewater flow measured since 2021 is 2.77 MGD. 3. Sample Site Description Sample Site Outfall #126 is located in a sample shed on the south-east corner of the Cleveland- Cliffs New Carlisle Works facility site near the security gate. This is a combined outfall consisting of the entire facility’s flow. 4. Wastewater Treatment Cleveland-Cliffs New Carlisle Works I L.P. WWT Plant The Cleveland-Cliffs New Carlisle Works I L.P. WWTP is designed to remove oils and precipitate out iron from solution prior to discharging to the City of South Bend. Oil bearing wastewater flows into two oil/water separators designed to collect floating oils and remove them to the light oil tank. The source of the flow to the oil/water separators is predominantly rinse water from the caustic cleaning section of the Continuous Anneal Process Line (CAPL) at Cleveland-Cliffs New Carlisle Works I L.P. The effluent from the oil/water separators then flows into the Neutralization Tank and combines with the metal bearing flows coming from the descale section of the Continuous Descale Cold Mill (CDCM) at Cleveland-Cliffs New Carlisle Works I L.P. The descale section of Cleveland-Cliffs New Carlisle Works I L.P. generates acidic iron bearing rinse water from the hydrochloric acid pickling process. In the Neutralization Tank, the pH of the combined flow is adjusted to approximately 8.5 to precipitate the ferrous iron from the solution. The chemical used to adjust the pH is slaked lime. There are two mixers located on the top of the neutralization tanks to keep the precipitate suspended. From the Neutralization Tank, the combined flows then go to a Lamella Clarifier. In the clarifier, the precipitated solids fall to the bottom of the unit and are periodically pumped to a sludge holding tank or flow by gravity. A high molecular weight anionic polymer is used to flocculate the precipitate solids in the clarifier. The sludge tank is used to store sludge from the clarifier. Based on the sludge density in the storage tank, sludge is periodically drawn off to a Parkson Belt Press to dewater the sludge. A high molecular weight anionic polymer is used to condition the sludge prior to pressing. The metal hydroxide sludge is shipped off-site for disposal. Emulsified oils generated from the Tandem Cold Mill and Caustic Cleaning Section are sent to the Cleveland-Cliffs New Carlisle Works I L.P. Pretreatment Tank. The Cleveland-Cliffs New Carlisle Works I L.P. Pretreatment Tank has a capacity of 90,000 gallons. This emulsified wastewater can be treated in two separate systems. First, an ultra-filtration unit rated at 25 gpm can be used to treat the emulsified oily waste. Second, the emulsified oily wastewater can be pumped at a rate of 20 gpm to the Cleveland-Cliffs New Carlisle Works II L.P. Oily Waste System for treatment. Cleveland-Cliffs New Carlisle Works II L.P. WWT Plant The Cleveland-Cliffs New Carlisle Works II L.P. WWT Plant is segregated into three treatment streams: Oily Waste, Neutralized Waste, and Nickel Reclamation Waste. The Oily Waste System (OWS) receives rinse water from the caustic cleaning sections of the Electrogalvanizing Line (EGL) and Continuous Galvanizing Line (CGL) at Cleveland-Cliffs New Carlisle Works II L.P. The wastewater is treated with sulfuric acid and a de-emulsifier. The wastewater is further treated with a coagulant aid and then processed by dissolved air flotation. The separated oil is transferred to a storage tank and is shipped to an oil recycler. The Neutralized Waste System (NWS) receives rinse water from zinc electroplating at the EGL. The Nickel Reclamation System (NRS) receives rinse water from the zinc electroplating at the EGL and the nickel solution filters at the CAPL Post Treatment. In both of these systems, the wastewater is treated with sodium hydroxide, a cationic coagulant aid, and an anionic polymer to aid settling. The pH of the wastewater is adjusted to approximately 10.5 to precipitate the zinc and nickel from the solution. The precipitated metals are concentrated to approximately 5% in gravity belt thickeners. Sludge from the gravity belt thickeners is stored in sludge tanks prior to dewatering by filter presses. The metal hydroxide sludges are shipped off-site for disposal. The filtrate from the gravity belt thickeners flows to Lamella Clarifiers. A Polymeric Metal Ion Precipitant Program is used on the Lamella Clarifiers. This program is necessary due to chelating or complexing agents which block their ability to precipitate the zinc simply by pH adjustment. 5. Classification Cleveland-Cliffs New Carlisle Works is categorized as an A industry per the City’s Industrial Pretreatment Program based on minimum requirement all industries that discharge greater than 100,000 gallons a day are classified as A industries. Discharges from Cleveland-Cliffs New Carlisle Works are regulated by 40 CFR 433 and 40 CFR 420. Specifically: Cleveland-Cliffs New Carlisle Works I L.P. Wastewater Treatment Plant (Outfall 127) Operation Applicable Regulation CDCM hydrochloric acid pickling 40 CFR Part 420.96(b)(2) - Pretreatment standards for new sources - hydrochloric acid pickling, strip sheet and plate CDCM hydrochloric acid pickling fume scrubber 40 CFR Part 420.96(b)(4) - Pretreatment standards for new sources - hydrochloric acid pickling fume scrubber CDCM Tandem Mill 40 CFR Part 420.106(a)(2) - Pretreatment standards for new sources - cold rolling multiple stand recirculation mill Treated contaminated storm water 40 CFR 420.08 - Non-EGL wastewater flows CAPL Electroplating 40 CFR 433.17 Pretreatment Standards for New Sources Cleveland-Cliffs New Carlisle Works II L.P. Wastewater Treatment Plant (Outfall 128) Operation Applicable Regulation CGL Galvanizing 40 CFR Part 420.126(a)(1) - Pretreatment standards for new sources - galvanizing terne coating and other coatings; strip, sheet, misc. CGL Galvanizing Fume Scrubber 40 CFR Part 420.126(c) - Pretreatment standards for new sources - galvanizing terne coating and other coatings; fume scrubbers CGL Skin Pass Mill 40 CFR Part 420.106(a)(4) - Pretreatment standards for new sources - cold rolling single stand direct application CGL Skin Pass Mill Fume Scrubber 40 CFR 420.08 - Non-EGL wastewater flows CAPL Skin Pass Mill 40 CFR Part 420.106(a)(4) - Pretreatment standards for new sources - cold rolling single stand direct application Treated contaminated storm water 40 CFR 420.08 - Non-EGL wastewater flows EGL Electroplating 40 CFR 433.17 Pretreatment Standards for New Sources 6. Calculation of Limits Based on 40 CFR 433 and 420 PSNS In accordance with 40 CFR 403.6(e), the concentration-based categorical pretreatment limits for Cleveland-Cliffs New Carlisle Works, Outfall 126, were developed by summing the total mass discharge allowance of each pollutant of concern for each of Cleveland-Cliffs New Carlisle Works’s federal categorical operations, then dividing the sum by the average effluent flow to the City of South Bend’s sewer system from January 2021 to October 2023. January 2021 to October 2023 time frame was most representative of future operations. Cleveland-Cliffs New Carlisle Works’s effluent to Outfall 126 consists of regulated flows and unregulated flows. [Cleveland-Cliffs New Carlisle Works I L.P. Operations mass (lbs/day)] + [Cleveland-Cliffs New Carlisle Works II L.P. Operations mass (lbs/day)] [Average discharge to City (mgd) X 8.345 (conversion factor)] See Attachment 3 for more information regarding the calculation of limits for Cleveland-Cliffs New Carlisle Works. The City of South Bend Industrial Pretreatment Group applied the more stringent limits between local limits and categorical limits. 7. Monitoring Frequency Monitoring frequencies are based on South Bend’s US EPA approved industrial pretreatment program monitoring plan. Cleveland-Cliffs New Carlisle Works is categorized as an A industry per the City’s Industrial Pretreatment Program based on minimum requirement that all industries that discharge flows greater than 100,000 gallons a day be categorized as an A industry. Cleveland-Cliffs New Carlisle Works is required to sample weekly because of Cleveland-Cliffs New Carlisle Works’s potential, as the largest discharger to the sewer, to cause an upset at the POTW. Cleveland-Cliffs New Carlisle Works’s average wastewater flow makes up approximately 5% of the POTW’s influent flow. Please note that Naphthalene and Tetrachloroethylene have been waived, as an individual testing requirement, upon request. These parameters will still remain in the semi-annual testing requirement for TTO’s. In lieu of monitoring for these pollutants, Cleveland-Cliffs New Carlisle Works shall submit the following Statement: “Based on my inquiry of the person or persons directly responsible for managing compliance with the Pretreatment Standard for 40 CFR 420.106, I certify that, to the best of my knowledge and belief, there has been no increase in the level of naphthalene and tetrachloroethylene in the wastewaters due to the activities at the facility since filing of the last periodic report under 40 CFR 403.12(e)(1)”. 8. Industrial Operator Certification Requirement Operator Certification Requirement: D Industrial operator certification requirements are based on the criteria listed in Indiana Administrative Code, Title 327, 5-22-5. City of South Bend Department of Public Works Industrial Pretreatment Program Significant Industrial User – Permit No. 161591-88966 In accordance with all the terms of Chapter 17 of the City of South Bend’s Municipal Code, and with any applicable provisions of federal or state law and regulations, permission is hereby granted to: Cleveland-Cliffs New Carlisle Works 30755 Edison Road New Carlisle IN 46552 for the contribution of wastewater into the City of South Bend Publicly Owned Treatment Works. This permit is granted in accordance with the application filed on 18 February, 2026. Effective on: 22 May, 2026 Expires on the: 21 May, 2031 Any violation of the terms and conditions of this permit shall be deemed a violation of the City of South Bend Municipal Code and will subject the permittee to the sanctions set out in section 17-11 through 17-13 of the Municipal Code. The permittee shall file an application for a renewal permit, a minimum of 90 days prior to the expiration date. Approved By: May 7, 2026 BOARD OF PUBLIC WORKS AGENDA ITEM REVIEW REQUEST FORM Date 4/21/2026 Name Serena Lozano-Shane Department UTILITIES BPW Date 5/12/2026 Phone Extension 5798 Review and Approval Required Prior to Submittal to Board Diversity Compliance and Inclusion Officer Officer Name BPW Attorney Attorney Name Dept. Attorney Attorney Name Purchasing Check the Appropriate Item Type – Required for All Submissions Professional Services Agreement Contract Proposal Open Market Contract Amendment/Addendum Special Purchase, QPA Bid Opening Bid Award Req. to Advertise Title Sheet Quote Opening Quote Award Reject Bids/Quotes Proposal Opening C/O & PCA No. PCA Chg. Order, No. Traffic Control Resolution x Other: Cleveland-Cliffs New Carlisle Works – Industrial Discharge Permit Renewal Required Information Company or Vendor Name New Vendor Yes If Yes, Approved by Purchasing No MBE/WBE Contractor MBE WBE Completed E-Verify Form Attached Yes No Project Name Project Number Funding Source Account No. Amount Terms of Contract Purpose/Description _______________________________________________________________ __________________________________________________________________________________________________________________ For Change Orders Only Amount of Increase Decrease $ ($ ) Previous Amount $ Current Percent of Change: Increase Decrease % ( %) New Amount $ Total Percent of Change: Increase Decrease % ( %) Time Extension Amount: New Completion Date: