DNREC Initiatives, Efforts Reduce Claymont Steel Pollution and Protect Community
Cleanup requirements at the Claymont Steel site ordered by the Department of Natural Resources and Environmental Control include reducing emissions for dust and mercury. Background information and related documents are available below.
Evraz Claymont Steel Inc. (formerly known as CitiSteel) operates a steel mini-mill located at 4001 Philadelphia Pike, in Claymont, Del. Claymont Steel, which was bought in 2007 by Evraz Group S.A., a Russian consortium, recycles scrap automotive metal, among other things, at the facility, and some of the scrap material utilized contains mercury. In addition, Claymont Steel stores steel refinery slag at the facility where particulate matter from the slag and other activities at the facility may become airborne and deposited in the surrounding area.
Claymont Steel is now owned by Evraz Group, S.A., a Russian consortium. But DNREC's requirements for cleaning up the site remain in place.
On October 23, 2006, DNREC issued a Notice of Conciliation and Secretary’s Order No. 2006-A-0048 to notify Claymont Steel that the facility was in violation of air emissions regulations (7 Del. C. § 6003(a)(1)) for causing or contributing to the release of an air contaminant, slag dust, occurring on October 1, 2005 and November 4, 2005. The order required Claymont Steel take action to correct its violations by specific dates and abate dust slag emissions from the facility that are causing or contributing to air pollution in the adjacent community
DNREC issued a second Notice of Conciliation and Secretary’s Order No. 2006-A-0058 on November 29, 2006 notifying Claymont Steel that the facility was in violation of air emission regulations (7 Del. C. § 6003(a)) related to the continuing discharge of mercury. Order No. 2006-A-0058 stated that the presence of mercury compounds in the outdoor atmosphere in the amounts indicated by the results of stack testing completed in January 2006 may be of sufficient quantity, character and duration as to have the potential to make a significant contribution to accumulated mercury in the environment.
This significant contribution has the potential to be injurious to human, plant, or animal life, or to unreasonably interfere with the enjoyment of life or property. The DNREC Orders require Claymont Steel to take actions at the facility, including a fugitive dust study and mercury reductions in order to come into compliance with state and federal air quality regulations.
DNREC’s Air Quality Management Section and Claymont Steel initiated a series of informational meetings for the community in March 2007 on the Claymont Steel fugitive dust study and draft implementation plan.
The meetings included representatives from DNREC, Claymont Steel, and Earth Tech, the engineering firm completing the fugitive dust study.
Fugitive dust control and monitoring at Claymont Steel
The Division of Air and Waste Management has worked with Claymont Steel and the surrounding community to control and monitor dust arising from the facility’s operations. In late 2006, DNREC issued two enforcement orders (see above). The first required Claymont Steel to conduct a study on how to control dust. The second order required the facility to reduce mercury emissions from process operations. As the Division’s Air Quality Management Section and Claymont Steel met with the community on the study’s findings, the community requested a special air monitoring program to be put in place to track fugitive dust emissions. Claymont Steel has submitted a proposed implementation schedule that has the ambient air monitors installed and operational by January 31, 2008.
In the meantime, Claymont Steel has begun implementing dust control measures at its facility, including major modifications to process operations involving slag processing, and steel scrap handling. The company also is in the process of studying the ventilation system at the melt shop, which, in its initial stages, has led to closing off the shop’s roof vents.
Finally, Claymont Steel ceased recycling activities associated with the used oil filters at the facility to further reduce dust emissions.
Earth Tech is the consultant that prepared the “Fugitive Emissions Control Study.” The study was funded by Claymont Steel and initially presented to the community at a public meeting Aug.1, 2007.
Starting a community "Bucket Brigade"
The Claymont community is working together to establish an independent neighborhood air monitoring program in the area. The program will be funded by a grant to the Claymont Community Coalition from Claymont Steel. The funding will be used to train a volunteer group, the Claymont Community Monitoring Team, on ambient air quality standards and how to use monitoring devices to document air quality.
Independent Contractor AECOM's Ambient Monitoring Results for the Evraz-Claymont Steel Dust Study, Including Quality Assurance/Quality Control
Claymont Steel documents:
- Claymont Progress Report 1 - Feb. 1, 2008
- Claymont Progress Report 2 - March 1, 2008
- Claymont Progress Report 3 - April 1, 2008
- Claymont Progress Report 4 - May 15, 2008
- Claymont Progress Report 5 - June 1, 2008
- Claymont Progress Report 6 - July 1, 2008
- Claymont Progress Report 7 - Aug. 1, 2008
- Claymont Progress Report 8 - Sept. 1, 2008
- Claymont Progress Report 9 - Oct. 1, 2008
- Claymont Progress Report 10 - Nov. 1, 2008
- Claymont Progress Report 11 - Dec. 1, 2008
- Claymont Progress Report 12 - Jan. 1, 2009
- Evraz-Claymont Progress Report - Feb. 2009
- Evraz-Claymont Progress Report - March 2009
- Evraz-Claymont Progress Report - April 2009
- Evraz-Claymont Progress Report - May 2009
DNREC presentation: Claymont Steel - Fugitive Dust and Mercury Emissions (PowerPoint)
Claymont residents will independently monitor the effectiveness of emissions dust controls from “hot spots.” These "hot spots" are locations that the community has identified as the most impacted by fugitive dust fallout. Sometimes called a "bucket brigade," this monitoring method has been successful in equipping communities with data generated by sampling methods and equipment that meets USEPA sampling protocols. By doing so, community residents are able to make use of sound technical data to find solutions to environmental problems in their neighborhood.
What are mercury and methylmercury?
Mercury is a persistent, bioaccumulative neurotoxin. Mercury can be found in the environment in a variety of forms depending on use, environment and microbial activity. Metallic mercury can be present in switches (particularly certain automobile switches), thermostats and a variety of medical and industrial applications.
Metallic mercury is a volatile compound that can result in high air concentrations in industrial and occupational settings. Health effects attributed to exposure to high concentrations of metallic mercury and associated vapors include permanent damage to the brain and kidneys, as well as tremors, changes in vision and hearing and memory problems.
Methylmercury is an organic compound formed when elemental mercury makes its way into water and soils where microbes convert the mercury to methylmercury through an anaerobic biochemical reaction. Methylmercury can then bioaccumulate in fish through food chain biomagnification, leading to exposure to significantly higher concentrations of methylmercury through consumption of affected fish.
The electric arc steelmaking furnace at Claymont Steel, purchased in 2007 by the Russian consortium, Evraz, which has inherited cleanup requirements ordered by DNREC.
Health effects associated with adult exposure to high concentrations of methylmercury include damage to the kidneys, stomach and large intestine. As with other toxic substances, children and pregnant women are more sensitive to lower dose exposures of methylmercury during fetal and early childhood development. The effects can range from minor decreases in intelligence to more serious developmental delays to severe brain damage.
Reducing mercury emissions in Delaware
In 2006, DNREC decided to take more stringent measures to reduce mercury releases. DNREC’s Pollution Prevention (P2) program initiated an educational program for medical and allied health professionals on preventing releases of mercury from thermometers and devices like blood pressure cuffs. The education program was followed by a focus on mercury air emissions.
Prior to 2006, DNREC believed that the Occidental Chemical (Oxychem) Company facility in Delaware City was the largest emitter of mercury to Delaware’s air, followed by Delaware’s power plants (Edgemoor and Indian River). DNREC adopted new air quality regulations in November 2006 that require power plants to reduce mercury emissions by more than 80 percent. Under these regulations, initial reductions are required by May 2009 and full compliance is required by January 2012.
When Oxychem decided to close down its production line that used mercury, the Division’s Air Quality Management Section took a closer look at other sources of mercury in the state. Since regulations were being implemented to control mercury emissions from the power plants, Air Quality Management moved to the next source on the list of mercury emitters. According to emission estimates submitted to the Division through the Toxic Release Inventory (TRI), Claymont Steel was the next largest emitter of mercury. Because Claymont Steel submitted estimates of mercury emissions based on mathematical calculations, rather than actual emission testing (a standard and acceptable practice under TRI), the Division requested that the company undertake stack sampling for mercury.
The results were staggering. Claymont Steel previously reported mercury emissions ranging from 28 to 39 pounds per year over the past five years. The stack testing of air emissions conducted in 2006 indicated that mercury emissions from the facility’s electric arc furnace (EAF, the device used to melt scrap metal), were actually 360 pounds per year with a potential to reach or exceed 500 pounds per year with the plant operating at full capacity.
Upon learning the results of the Claymont Steel stack test, DNREC ordered Claymont Steel to reduction mercury emissions from its EAF, either by reducing the mercury entering the furnace or by using end-of-pipe controls. The facility immediately discontinued the use of municipal scrap metal as a first step in reducing mercury emissions, as some household appliances, such as washers and dryers, can also contain mercury switches.
The results of a stack test done in December 2006 indicated a 40 percent reduction in mercury emissions compared to the test done earlier in the year. Claymont Steel is continuing to look at additional ways to reduce its mercury emissions in accordance with DNREC’s Order.
Notice of Violation for Electric Arc Furnace and Associated Equipment at Evraz Steel (formerly Claymont Steel)
Comments on Dust Study Progress and Mercury Reduction Order Progress at Evraz Steel
Evraz Nov. 2008 Response Letter regarding Dust Order 2006
Mercury switches and ELVS
Claymont Steel uses scrap vehicles to make steel slag at its facility. Another potential source of mercury in Claymont Steel’s emissions is the mercury switches found in some automobile makes and models. DNREC is working with the auto salvage yard industry to remove these switches prior to scrapping vehicles.
To assist Claymont Steel in reducing its mercury emissions, and to prevent other releases of mercury into Delaware’s environment, DNREC asked the non-profit corporation ELVS to come to Delaware. ELVS, which stands for End of Life Vehicle Solutions, was created by the auto industry to promote recyclability, education, outreach and proper management of substances of concern.
In 2006, ELVS formed the National Vehicle Mercury Switch Recycling Program (NVMSRP). The goal of the NVMSRP is to remove mercury switches from automobiles before the steel in the vehicle is recycled. Mercury switches can be found in convenience lights in trunk and hood compartments and in anti-lock braking system (ABS) modules of some vehicles built before model year 2003.
In December 2006, 63 Delaware scrap and salvage dealers were invited to participate in NVMSRP to remove and recycle mercury switches from pre-2003 vehicles before they are crushed, shredded and melted down as part of the steel recycling process. Mercury can be released to the environment during any of these three steps.
By participating in the NVMSRP, scrap and salvage dealers are eligible to receive, on a first-come, first-served basis, $1 for each mercury switch lighting assembly and $3 for each anti-lock braking system (ABS) module removed and submitted. Switches do not need to be removed from assemblies. Payments out of a $4 million fund began in January 2007, with switches sent in before January 1 eligible for compensation. ELVS will send participants, free of charge, a mercury switch collection bucket, updated educational materials, a list of vehicles with the potential to contain mercury switches, and a detailed instruction sheet on shipping full collection buckets. The buckets are returned with postage paid and additional buckets are available on request, also at no cost.
DNREC continues to encourage scrap and salvage dealers to participate through additional mailings. To join the program or for more information, please contact ELVS at 877-225-ELVS (3587) or visit: End of Life Vehicle Solutions. For more information on recycling mercury switches, please contact Karen G. J’Anthony of the Division of Waste & Hazardous Substances' Solid & Hazardous Waste Management Section at 302-739-9403 or firstname.lastname@example.org.