Environmental Code of Practice for Non-Integrated Steel Mills: summary


Various substances that are released, produced, or used by the steel manufacturing sector have been declared toxic under the Canadian Environmental Protection Act (CEPA). A multi-stakeholder Strategic Options Process (SOP) was launched in April 1995 to address the management of these substances. The SOP culminated in the development of a Strategic Options Report (SOR) in December 1997.

The SOR recommended among other things that Environmental Codes of Practice be developed for non-integrated steel mills. The non-integrated mills segment of the steel manufacturing sector includes all facilities that use scrap steel and direct reduced iron as raw materials to produce primary steel products. Primary steel production processes include electric arc furnace steelmaking, continuous casting, hot rolling and, in some plants, cold rolling and finishing, but does not include pipe or tube making or steel fabrication facilities. There are currently 12 non-integrated steel mills in Canada.

This Code of Practice outlines environmental concerns and alternative methods, technologies, designs, and procedures that will minimize the adverse environmental effects associated with non-integrated steel mills. A simplified flowsheet is presented in Figure S.1 showing the major feeds to and environmental releases from non-integrated steel mills. Operational activities addressed in the Code include:

Figure S.1 Non-integrated Plant Steelmaking Simplified Flowsheet

Click the image to view full size version.

Non-integrated Plant Steelmaking Simplified Flowsheet
  • raw materials handling and storage;
  • direct reduction of iron;
  • steelmaking;
  • continuous casting;
  • hot forming;
  • cold forming;
  • pickling and cleaning; and
  • coating.

The Code advances recommendations aimed at preserving and enhancing the quality of the environment that is affected by these mills. Environmental performance standards are included for atmospheric emissions, water and wastewater, waste management, and environmental management practices. These recommended practices may be used by the steel sector, regulatory agencies, and the general public as sources of technical and policy guidance in the development and implementation of site-specific environmental protection practices and requirements.

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 that existing mills will strive to achieve through continual improvements over time. However, all municipal, provincial, and federal legal requirements must be met, and a commitment by companies to be consistent with Code recommendations does not remove obligations to comply with all regulatory requirements.

The Code was developed by Environment Canada in consultation with provincial environmental agencies, industry representatives, and other stakeholders. Federal, provincial, and international environmental guidelines and standards of relevance to the operation of non-integrated steel mills were considered in the development of Code recommendations, as were the environmental management practices recommended by various national and international organizations.

This Code of Practice will be adopted by Environment Canada and others as a guidance document that delineates appropriate environmental protection standards and practices for non-integrated steel mills. Some elements of the Code may be adopted under the Federal-Provincial/Territorial Environmental Harmonization Accord and associated sub-agreements such as Canada-Wide Standards. Some elements of the Code may be used in the development of initiatives or programs to achieve the objectives of cooperative agreements including the Canada-Ontario Agreement and St. Lawrence Vision 2000.

The Code may be adopted on a voluntary basis by individual steel sector corporations and facilities and by the Canadian Steel Producers Association (CSPA) and its members. It may be included as commitment to Code recommendations in Environmental Performance Agreements among Environment Canada, provincial environment departments, and steel companies or facilities. It may also be adopted in whole or in part by regulatory agencies.

The Code may be used for benchmarking best practices to achieve continual improvement in the environmental performance of non-integrated steel mills in Canada and other countries. Code recommendations may also be used as benchmark criteria for the conduct of audits aimed at assessing the environmental performance of sector facilities or companies.

A summary of the recommendations is presented in Table S.1. The full text of the recommendations, presented in Section 4, should be consulted for details.

Table S.1 Summary of Recommendations
Number Subject Summary of Recommendation
Atmospheric Emission Management
RN101 Release Guidelines for Particulate Matter

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.
RN102 Environmental Performance Indicator

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.
RN103 Collection of Electric Arc Furnace (EAF) Emissions Adequately sized facilities should be engineered and installed, and documented operating and maintenance procedures should be developed for the collection of emissions associated with primary and secondary steelmaking.
RN104 Control of Fugitive Emissions Adequately sized facilities should be engineered and installed, and documented operating and maintenance procedures should be developed for the control of emissions associated with primary and secondary steelmaking.
RN105 Solvent Degreasing 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 Solvent Degreasing Strategic Options Report and the associated regulations that may be promulgated from time to time.
RN106 Ambient Air Quality Monitoring

An ambient air quality monitoring program should be developed and implemented by each facility in consultation with the appropriate regulatory authorities. 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.
Water and Wastewater Management
RN107 Effluent Guidelines

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 quality prior to release to cooling water or to local receiving water body:

On a continuous basis:
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
0.1 mg/l
Chromium (total)
0.5 mg/l
0.2 mg/l
0.01 mg/l
Nickel (total)
0.5 mg/l
0.5 mg/l
No more than 50% mortality in100% effluent

Wastewater treatment facilities approved 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.

RN108 Environmental Performance Indicators

Each facility should target on limiting total suspended solids discharges 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.
RN109 Wastewater Collection All wastewater streams that exceed the effluent criteria should be directed to an approved treatment facility prior to discharge.
RN110 Water Use/Reuse 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.
RN111 Wastewater Containment Sizing

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 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).
RN112 Environmental Effects Monitoring An environmental effects monitoring program should be developed and implemented where appropriate by each facility in consultation with the appropriate regulatory authorities.
Waste Management
RN113 Location and Construction of Waste Disposal Sites

Expansions to existing waste disposal sites 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.
RN114 Development of Solid Waste Disposal Sites

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

  1. the disposal area should be developed in modules or cells;
  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
  4. all disposal sites should be reclaimed for beneficial uses before final closure.
RN115 Management of Waste Disposal Sites

All waste disposal sites should be managed 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.
RN116 Monitoring of Waste Disposal Sites

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;
  2. a program of pre-operational monitoring of groundwater regimes should be initiated;
  3. groundwater samples should be collected at least quarterly; and
  4. each groundwater sample should be analyzed for pH, total dissolved solids, and other appropriate (site-specific) parameters.
RN117 Liquid Storage and Containment 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.
RN118 Reduction, Reuse, and Recycling Each corporate entity responsible for the operation of a non-integrated steel mill should develop, implement, and maintain a reduction, reuse, and recycling program.
Best Environmental Management Practices
RN119 Implementation of an Environmental Management System (EMS) Each facility should develop, implement, and maintain an EMS that is consistent with the requirements of a recognized national standard such as ISO 14001.
RN120 Environmental Policy Statement Each facility should develop and implement an environmental policy statement.
RN121 Environmental Assessment 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.
RN122 Emergency Planning Each facility should develop and implement an Emergency Plan aimed at ensuring that facility management meet all legal requirements in developing, maintaining, exercising, and reporting emergency preparedness and resource activities.
RN123 Pollution Prevention Planning Each facility should develop and implement a Pollution Prevention Plan aimed at avoiding or minimizing discharges to the environment.
RN124 Decommissioning Planning 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. All site closures should be undertaken in accordance with the CCME's National Guidelines for the Decommissioning of Industrial Sites.
RN125 Environmental Training 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.
RN126 Environmental Facility Inspection Each facility should develop and implement an Environmental Inspection Plan.
RN127 Monitoring and Reporting Documented procedures for the monitoring and reporting of environmental performance data should be developed and implemented.
RN128 Environmental Auditing Each facility should conduct periodic internal environmental audits throughout the operating life of the facility.
RN129 Environmental Performance Indicators Each facility should develop a set of environmental performance indicators that provides an overall measure of the facility's environmental performance.
RN130 Life Cycle Management Each facility should develop and implement a Life Cycle Management (LCM) Program aimed at minimizing the environmental burdens associated with the products used and produced by its steelmaking facilities over the product life cycle.
RN131 Community Advisory Panel 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.

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