Scrap Specifications

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Cascade Steel: A History of Quality

Since we began operating in 1969, a dedication to production of quality steel and the
communities in which our plant is located has been the hallmark of Cascade Steel.
As our mission statement declares,

“We are committed to the manufacture of quality steel products at a competitive


cost. We believe in maximizing profits using the latest technology with an emphasis
on safety, teamwork, and customer satisfaction, and are resolved to ensuring a
rewarding workplace for all.”

In 1984, Cascade Steel was acquired by Schnitzer Steel Industries which continues
a dedication to excellence through investment in technology. By combining this
modernization of equipment with our skilled employees, Cascade Steel Rolling Mills
remains on the forefront of quality steel production and delivery and its success
continues to benefit the local communities.

As the state’s largest recycler, we value our environment.

We take scrap metal and items that would otherwise be disposed of


– old car parts, metal from demolished buildings – and recycle them into
reusable products. Each year we recycle more than 800,000 tons of material,
demonstrating our dedication to our environment.

As one of the area’s largest employers, we contribute to a vital economy.

Cascade Steel provides the highest number of jobs in McMinnville, employing


more than 500 workers. We contribute to the economy by paying our
employees a family living wage and offering competitive benefits including
healthcare, continuing education and retirement.

As a leader in community service, we support local efforts for social


responsibility.

Through donations of time, money and product we demonstrate the value we


place on the community in which we live. In recent years, we’ve contributed to
a variety of community efforts including: the Yamhill County Fair Livestock Pen
Project, the McMinnville High School Welding Class, the Drew Ottley Memorial
Skate Park, Kids on the Block after-school program and Head Start of Yamhill
County.

Our skilled employees produce quality products.

High marks in our Jacobson and Associates annual customer satisfaction


report demonstrate the connection between our emphasis on finding and
retaining hard working, dedicated employees and the timely delivery of quality
products. Our customers are satisfied and our community benefits from our
continued success.
Scrap Specifications:
Why do we need them?
The Cascade Steel Scrap Acceptance Policy is based on scrap specifications. Scrap
suppliers need the details of what we are looking for in our raw materials to
determine if they can meet or exceed the criteria. The purpose of defining why you
need scrap specifications leads to detailing the materials in the melting process.
When we ask why we need certain things in steel making, we look to recycled
scrap materials that meet or exceed the expectations for the characteristics of the
customers steel requirements. Size, density, chemistry, cleanliness, and many more
unique features, all contribute to what we need in the specification. Each materials
variance in its physical and chemical form makes it unique from all other scrap types.

Shredded is not like bundles nor is it similar to machine shop turnings. They all
perform differently in a melting environment and that is where the need for clear,
well stated scrap specifications comes in. When we spend the time to define what
is needed for the melting environment and train the supply base on these needs,
we can expect materials that fit well in each of the categories. Information on
the melting traits of each scrap type is also vital to our process. A source may be
providing material that has great chemistry qualities – but is so light in density that
we use little of it. Changing the materials physical form allows for increased sales
of the material and better communication between consumer and supplier.

Radiation Statement:
Cascade Steel Rolling Mills policy is zero tolerance of radiation and radioactive
materials in our scrap. Every load of scrap delivered by truck and rail is
inspected for radiation. If a source is found we follow CSRM Safe Job Procedures
on radiation protocol and that includes notifying the appropriate state and local
radiation personnel. A yellow DOT placard is affixed to the vehicle with the
approved file number and released for transport. It is the responsibility of the
shipper or radiation processor to remove the DOT placard prior to release of the
vehicle and dispose properly. Please see pages 9, 11 and 16 for additional
radiation data.

Non-typical scrap buying:


Occasionaly scrap that does not conform to our general speicifcation is offered
to CSRM. Our policy is to have senior management, SSI-purchasing, melting and
logisitics staff review each material for chemical, physical, handling, pricing, etc.
aspects of each material. A determination will then be made as to the viabaility of
the scrap in the purchasing decision. Secondary "pup" coils are an example of
such an scrap.
Scrap Quality Remedies:
When a scrap delivery does not meet expectations based on scrap specifications,
the decision as to the disposition of this load, and potentially future loads, needs to
be made. We have four steps in our process to handle a poor quality load.

1) First offense for a new shipper, if the error is not egregious and able to
be handled with minimal reprocessing, a phone call and emails with pictures if
necessary to show what the problem is. No monetary value adjustment - just a
verbal warning.

2) New shipper and a current shipper to CSRM. If the error has not been
solved with the verbal warning then a downgrade of monetary value or grade
change may be in order. A minimum of $25 per net ton is the standard but may be
increased depending on the severity of the problem. The potential is for all loads
after this may also be subject to pricing adjustment in addition to the $25.

3) Rejection of the load. Based on the history of the shipper and the
contamination level of the load may constitute outright rejection of the load back to
the shipper. Automatic rejection applies for any radioactive materials and sealed
containers in a load. If a load passes top visual inspection but we find rejectionable
material lower in the load, we will reject the balance of the load and pay for what
has been taken out.

4) Suspension of Shipper. No future business until CSRM is satisfied issues


have been resolved. May include site visits and trials of material to determine
shippers ability to conform to specifications.

5) Remove shipper from SSI purchase contracts. We do this only as a


last resort and in rare occasions. Continued unacceptable performance may
eliminate a shipper from the CSRM purchasing process.
Table of Contents
Scrap Steel General Requirements 7-16

Good Scrap

#1 Factory Bundles 18

#2 Bundles 19

Bonus 20

Bushelings 21

Cast Iron 22

Hot Briquetted Iron 23

Mixed 1&2 HMS 24

Railroad OTM 25

Shredded 26

Tin Can Bales 27

Railroad Wheels 28

Pig Iron

Turnings 30

Bad Scrap

Cast 34-36

Copper 37-39

Dirt 40-42

Mixed Grades 43-45

Non Conductor 46-47

Oversized 48-50

UGLY SCRAP UGLY SCRAP UGLY SCRAP

Rubber, Fluff, Plastics

Sealed Containers 55-56

Oxidized 57-58

Area Source Rule Requirements 60-70


Raw Material Specifications

Steel Scrap
Material: Steel Scrap Grade: All

Scope:
These general specifications apply to all grades purchased by Cascade Steel
Rolling Mills Inc. for the purposes of remelting at the McMinnville, Oregon steel
works.

Specific scrap types and grades are following which detail what Cascade Steel
Rolling Mills Inc. will likely consume during a typical monthly buying cycle.

Receiving Hours:
Monday 6am - 9pm; Tuesday–Friday, 5am–9pm
Questions, call: (503) 472-4181 ext. 3650

Special Definitions

“Area Source Rule” Recently promulgated federal regulation, 40


CFR Part 63, Subpart YYYYY (National Emission
Standards for Hazardous Air Pollutants for
Area Sources: Electric Arc Furnace
Steelmaking Facilities).

“Chlorinated Plastics” Solid polymeric materials that contain chlorine


in the polymer chain, such as polyvinyl chloride
(PVC) and electrical wiring insulators.

“Downgrade” When a particular load of scrap does not meet


the Raw Material Specification, it may, with
consent of Cascade and the shipper, be considered
and accepted as a lower quality scrap grade.
Financial repercussions may also be included
within the downgrade action.

“EAF Steelmaking A steel plant that produces carbon, alloy or


Facility” specialty steels using an Electric Arc Furnace.

“Free of” When specified to be “free of”, the grade shall


not contain any amount of prohibited material
greater than that which is unavoidable in the
customary preparation and handling of that
material (i.e. the extent practicable).


“Free of Alloy” Scrap is “free of alloy” if the residual level of each
element listed contained in the scrap does not
occur at levels consistent with the purposeful
creation of an alloyed steel grade.

Carbon (C) 0.50%


Chromium (Cr) 0.25%
Nickel (Ni) 0.25%
Molybdenum (Mo) 0.06%
Copper (Cu) 0.30%
Tin (Sn) 0.02%
Manganese (Mn) 1.65%
Sulfur (S) 0.05%

All listed elements combined shall not exceed


0.75% with the exclusion of Manganese. All other
elements shall be 0.001% maximum

“Free Organic Liquids” Material that fails the paint filter test by EPA
Method 9095B, after accounting for water using
a moisture determination test by ASTM Method
D2216-05 (40 CFR § 63.14). If, after conducting
the moisture determination test, any portion of
the material passes through and drops from the
filter within the 5-minute test period, the material
contains “free organic liquids.”

“Grade” or “Type” A classification of scrap type based upon the


Institute of Scrap Recycling Industries (ISRI)
ferrous scrap classification, or Cascade
description.

“Leaded Steel” Steel that must meet a minimum specification


for lead content (typically 0.25% or more) and for
which lead is a necessary alloy. Scrap used
for the production of leaded steel is subject to
approval prior to acceptance.

“Mercury Switch” Each mercury-containing capsule or switch


assembly that is part of a convenience light switch
mechanism installed in a vehicle.

“Motor Vehicle” or An automotive vehicle not operated on rails and


“Automobile” usually operated with rubber tires for use on
highways.


“Motor Vehicle Scrap” Vehicle or automobile bodies, including
automobile body hulks that have been processed
through a shredder. “Motor vehicle scrap”
does not include automobile manufacturing
bundles, or miscellaneous vehicle parts, such as
wheels, bumpers, or other components that do not
contain mercury switches.

“Non-Ferrous Metals” Any pure metal other than iron or any metal alloy
for which an element other than iron is its major
constituent by percent in weight.

“Off-Grade” A load of scrap shall be considered off grade if it


fails to meet:

1. Applicable requirements of quality or
chemistry.

2. Applicable requirements of material
“type” or “grade”

3. Applicable size limitations as specified in


the material’s (grade’s) Raw Material
Specification.

“Rejection” Scrap may be rejected if gross quality, chemistry,


or sizing of material occurs. All costs incurred,
including demurrage charges if applicable, will be
charged to the shipper’s account.

“Scrap Provider” The person (including a broker) who contracts with


Schnitzer Steel Industries, Inc. to provide scrap
metal to Cascade Steel.

Gate Policy

All scrap is subject to inspection prior to acceptance and is subject to


classification based upon visual and/or chemical analysis, inspection
for prohibited materials, sizing constraints, mechanical weighing on
certified scales and/or radiation detection. Inspection of scrap will be
conducted according to the Cascade Steel Rolling Mills, Inc.’s Scrap
Inspection Checklist. This checklist can be found on page 12 and all
conditions and requirements outlined in this document apply.


Scrap Acceptance Guidelines

This document clarifies our policies for accepting recyclable metals.


These requirements reflect our commitment to responsible environmental
management. Please be aware that many of our policies are controlled by
state and federal regulations which apply both to us and to our customers.

This list is not inclusive: other items not listed may be inappropriate for
recycling as scrap metal. Please read this brochure carefully, and contact us
if you have questions about specific items. Remember that any load may be
rejected at your cost if these guidelines are not followed.

The following materials will NOT be accepted at our facility:

Refrigerants (including CFCs and HCFCs) in refrigerators and air


conditioners. Please note that Clean Air Act regulations (§608(b)(1)
and §608(c)) prohibit any release of refrigerants to the atmosphere, and
require persons handling refrigerants to follow specific procedures.
Our customers are REQUIRED to sign a statement certifying that all
refrigerants have been properly removed (40 CFR §82).

Asbestos or asbestos containing materials, such as pipe insulation


and surfacing material commonly found on I-beams, tanks, and other
structural and demolition debris (40 CFR §61.150).

Oils, gasoline, other petroleum products and antifreeze. This


includes hydraulic fluids, gear oils and grease. Hydraulic equipment
must have hydraulic hoses removed and cylinders cut open and drained.

Lead-acid batteries or battery parts, including automobile batteries


(40 CFR §273).

Items that contain or have contained PCBs, including small capacitors,


flourescent light ballasts and electrical transformers or transformer
components (TSCA and 40 CFR §258 and §261).

Automobile airbags, which contain sodium azide (40 CFR §261).

Paint cans or other paint containers.

10
Acetylene bottles and other sealed containers. Sealed containers are
described as air or water tight containers without visible openings.

Flourescent lights, neon, high intensity or mercury vapor lights.

Any material containing hazardous or toxic substances.

Military scrap of any kind, unless approved in advance.

Explosives, fracturing guns and tubes, or any explosive residues.

Radioactive materials of any kind.

Tires, wood, dirt, yard debris, concrete, asphalt, glass, excessive fluff,
rubber, or other non-metallic materials.

Scrap Inspection Checklist:


The next page illustrates the Scrap Inspection Checklist form we use on all
inbound scrap loads. The Restricted Scrap will tend to have more contamination
potential, derived by the Area Source Rule, namely the element mercury.
However, other contaminants are also found usch as dirt and liquids that must
be inspected for and dealt with. We will place more effort to these scrap types
than the Unrestricted which will not normally have any Area Source Rule
infractions.

It is the intent of the process that when a problem exists, the weigh scale personnel
have the authority to hold for inspection any load not conforming to the Scrap
Specifications. A supervisor or person knowledgable in scrap may elect to
perform a follow up inspection. Photographs are usually taken to verify the
problem and these can be attached as supporting documents to the inspection
report. Loads which do not conform will be flagged and email notices sent to
those in CSRM management and SSI purchasing.

11
Cascade Steel Rolling Mills, Inc. Scrap Inspection Checklist

Inspector: Date: / /
Shipper: Scale Ticket #:

Restricted Scrap Identification Unrestricted Scrap Identification


□ #2 Bundles □ Tin Can Bales □ Low Residual □ #1 Factory Bundles
□ Cast Iron □ Turnings □ Pig Iron □ Bushelings
□ Shredded □ Mixed 1 & 2 HMS □ Tire Wire □ Railroad Wheels
□ Bonus □ RR Rail □ RR OTM
□ Other: _________________ □ HBI
Inspection Guidelines
This scrap, to the extent practical, does not contain any of the following items:
Pass Fail
□ □ free organic liquids (oils, antifreeze, fuels, lubricants, hydraulic fluids,
grease, etc.), including un-drained oil filters.
□ □ chlorinated plastics (PVC, electrical insulators, etc.).
□ □ lead and lead containing components of scrap (batteries, battery cables,
wheel weights, etc.).
□ □ sealed containers (barrels, gas cylinders, propane bottles, paint cans,
aerosol cans, etc.).
□ □ non-metallic debris (wood, dirt, yard debris, concrete, asphalt, glass,
rubber, etc.).
□ □ Mercury switches, fluorescent, neon, HID, mercury vapor lights, hazardous or
toxic substances, all refrigerants and air conditioners, asbestos or asbestos
containing materials, any items that contain or did contain PCBs, explosives or
military scrap, and all non-ferrous metals (brass, copper, bronze, aluminum, tin).
Pass Fail
□ □ This scrap load has failed visual inspection due to reasons other than those
identified above. Explanation:

This load has been found to be (unacceptable) (acceptable) according to Cascade Steel
Rolling Mills, Inc.’s scrap acceptance guidelines and scrap specifications. If this load has been
found to be unacceptable, describe the course of action required.
□ Downgrade Reject□
______________________________________________________________________________

ascade Steel Rolling Mills, Inc.


General Specifications

Cast Iron Unless specifically purchased as a Cast Iron, Pig Iron or


Hot Briquetted Iron, all scrap grades shall not contain
more than 1% (by weight) cast iron products. This
includes, but is not limited to, Cast Iron, Pig Iron,
Hot Briquetted Iron, engine blocks and parts, castings,
machines bases, composite brake shoes, etc.

Sealed All scrap grades shall not contain Closed, Enclosed or


Containers Sealed Containers. Such containers may be accepted
providing they have such that: one end has been
removed, a minimum of two large holes broach the sealed
portion of the container, or the container has been cut in
half. Closed, Enclosed or Sealed Containers include, but
are not limited to:

• Hydraulic or gas cylinders
• Shock absorbers
• Air, Freon, acetylene, oxygen, propane tanks
• Closed ball valves
• Automotive rear ends
• Sealed units e.g. refrigerant compressors
• Any vessel which contains and retains gasses, oils
or fluids

Cleanliness All scrap grades shall be free of excessive dirt, corrosion,


rust, oil, or grease. No mill scale, grinding swarf, torch
drippings, slag, municipal waste or incinerated scrap in
any amount will be cause for rejection.

Inspection All material is to be suitable and acceptable to Cascade


Steel Rolling Mills.

Hazardous All grades shall not contain any hazardous materials


Materials including, but not limited to, Materials explosives,
radioactive materials in any form, medical waste, oil
filled devices (e.g. Transformers – even if drained may
contain PCB residue), etc.

Loading Scrap must be capable of being loaded and unloaded by


electromagnet.

Mercury All grades shall have zero Mercury and Mercury


containing materials. Mercury containing materials
include, but are not limited to: Mercury wetted or
containing relays, switch gear, rectifiers, gauges,
manometers, barometers, fluorescent lighting fixtures,
etc.

Lead All scrap grades are not allowed to contain any amount
of lead. Such items containing lead include, but are

15
not limited to: batteries, lead-based paints, gasoline
tanks, terne plate, wheel balancing weights, metal
guttering, mufflers, tailpipes, Babbitt, solder, radiators,
leaded joints in soil pipe, equipment counterweights,
bearing journals, etc.

Tin All grades shall be free of tin coated or tin containing


materials with the exception of tin can bales which are
bought as a separate grade.

Stainless Steel All grades shall be free of stainless steel materials.

Non-Ferrous All grades are to be free of Non-ferrous materials. Non-


ferrous materials include, but are not limited to: copper
(wiring, motors, piping, and compressors), lead,
aluminum, brass, bronze, etc.

Non-Metallic All scrap grades are to be free of Non-metallic material.


Non-metallic materials include, but are not limited to:
wood, plastics, paper, cardboard, fiber, rubber, foam,
slag concrete, dirt, grease, oil, etc.

Radioactivity All grades of scrap shall not contain radioactive material.


Such scrap found with radioactive materials shall be
processed pursuant to the CSRM Radioactive guidelines.
Under no circumstances shall any radioactive scrap be
accepted through downgrading.

Counterweights All grades of scrap shall not contain counterweights in


any form.

Further information, in the form of Area Rule Requirements, begins on page 59.

16
THE GOOD
Raw Material Specifications

#1 Bundles Specifications

Material: Steel Scrap Grade: #1 Bundles

ISRI #s: 208 AKA: #1 Factory Bundles

Description:
Clean steel sheet, clippings, bushelings, wire or skeletons hydraulically compressed
into a bundle. May include tightly wound mandrel bundles if banded or welded across face
and secured for magnet handling.

Typical Appearance

Physical Appearance

Sizing: 36” x 24” x 24” Typical Density: 70 (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%) 0.10 0.75 0.03 0.03 0.50 0.10 0.10 0.10 0.03 0.01 0.04

Exclusions:
Auto Body parts, Fender stock, De-Tinned materials, Electrical steels over 0.50 silicon,
Metal coated, limed or vitreous enameled steels.
Permissible:
Zinc or galvanized coated steels and wire products such as barbed, pencil, or baling wire.
Allowances: (N/A)

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

18
Raw Material Specifications

#2 Dealer Bundles

Material: Steel Scrap Grade: #2 Dealer Bundles

ISRI #s: 209 AKA: #2 Bundles

Description:
Old black and galvanized sheet steel scrap from a scrap yard, not to exceed 3 feet in any
one direction. Free of tin and lead coated metals, limed, vitreous enameled, and electrical
coated sheet over 0.50% silicon. No auto bales, auto slabs or shredder logs allowed.

Typical Appearance

Physical Appearance

Sizing: 24” x 24” x 36” Typical Density: 50 - 60 (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%) 0.50 1.50 0.05 0.05 0.50 0.35 0.20 0.20 0.03 0.015 0.04

Exclusions:
Municipal scrap, incinerated materials, lead and tin coated, metal coated, limed steels, non-
metallics and non-ferrous materials. No auto bales, auto slabs or shredder logs.
Permissible:
Zinc or galvanized coated steels and vitreous enameled materials up to 15% by weight
provided the “white goods” do not contain wiring harnesses, motors, compressors, or
capacitors. Any single bale may include up to 15% reinforcing bar.
Allowances: (N/A)

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply. 19
Raw Material Specifications

Bonus Grade

Material: Steel Scrap Grade: Bonus

ISRI #s: 236; 231 AKA: Bonus; Plate & Structural; P & S

Description:
Clean plate and structural steel scrap 1/4 inch and over in thickness. May include heavy
walled pipe split in half if larger than 8 inch diameter, large diameter pipe cut in thirds if
over 24 inches in diameter, and heavy railroad scrap such as bolsters, side frames, knuck-
les, except car sides. Railroad wheels to be bought separately from the Bonus grade.

Typical Appearance

Physical Appearance

Sizing: 36” x 24” x 2” Typical Density: 60-70 (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%) 0.50 1.50 0.05 0.05 0.50 0.20 0.15 0.15 0.04 0.015 0.04

Exclusions:
All counterweights, and cast iron including but not limited to engine blocks, machinery,
brake calipers, rotors, truck brake drums, etc. Free of non-ferrous and non-metallics,
vitreous enameled material. Railroad wheels are to be separated for independent sale.
Permissible:
Attached cast iron content not to exceed 5% by weight
Allowances:
Alloyed steel may not exceed 15%.

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.
20
Raw Material Specifications

Bushelings

Material: Steel Scrap Grade: #1 Bushelings

ISRI #s: 207 AKA: Bushelings; clippings; punchings; BHP; coils ends; low residual; charge clips

Description:
Clean steel scrap from a factory, not to exceed 4 feet in any one direction, may include
slitter, low residual, punchings, BHP, coils ends, sheet clippings, stampings, etc.

Typical Appearance

Physical Appearance

Sizing: 48” x 24” x 1/2” Typical Density: 70-90 (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%) 0.15 1.50 0.05 0.05 0.50 0.10 0.10 0.10 0.03 0.01 0.04

Exclusions:
Free of coated metals, limed, vitreous enameled, and electrical coated sheet over 0.50%
silicon. May not include old auto body and fender stock or excessively oily or greasy
materials.
Permissible:
Zinc or galvanized coated steels.
Allowances: (N/A)

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

21
Raw Material Specifications

Cast Iron

Material: Steel Scrap Grade: Cast Iron

ISRI #s: 259; 263 AKA: Clean Auto cast

Description:
Clean auto cast iron, broken or unbroken, free of nonferrous and non-metallics. May in-
clude small amounts of grating, truck brake hubs, diesel cast and small machinery bases
and steel parts.

Typical Appearance

Physical Appearance

Sizing: 36” x 18” x 4” Typical Density: (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%) 4.50 0.75 0.035 0.10 2.35 0.20 0.15 0.15 0.06 0.02 0.04

Exclusions:
All counterweights, stove plate, burnt iron, brake shoes or foreign materials. No dirty motor
blocks or whole engines.
Permissible:
May include steel parts which does not exceed 15 percent of the load.
Allowances:
Malleable iron parts allowed.

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

22
Raw Material Specifications

Hot Briquetted Iron

Material: Hot Briquetted Iron Grade: Hot Briquetted Iron

ISRI #s: AKA: HBI

Description:
Iron ore fines that have been subjected to a reducing atmosphere, passivated for transpor-
tation and compressed into briquettes.

Typical Appearance

Physical Appearance

Sizing: 4” x 1” x 2” Typical Density: 300 (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%) 1.5 0.25 0.05 0.05 0.25 0.10 0.05 0.05 0.02 0.01 0.01

Exclusions:
Permissible:
Allowances:

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

23
Raw Material Specifications

Mixed 1 & 2 HMS

Material: Steel Scrap Grade: Mixed 1 & 2 HMS

ISRI #s: 201; 205 AKA: #1, #2, Heavy Melt, HMS

Description:
Clean steel scrap ¼ inch and over in thickness. Individual pieces not over 36 inches by 18
inches by 2 inches. Prepared in a manner to insure compact charging. Thin gauge materi-
als not to exceed 30% of the load.

Typical Appearance

Physical Appearance

Sizing: 36” x 18” x 2” Typical Density: 45-60 (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%) 0.50 1.50 0.05 0.05 0.50 0.50 0.25 0.25 0.06 0.02 0.04

Exclusions:
Sealed containers in any form. Municipal, incinerated, tin cans, oil filters, sheared white
goods, turnings and cast iron borings, railroad brake shoes, copper clad or copper plated
steel. Loose cable and wire (not cut to 3’), all counterweights, and all loose cast iron
including but not limited to engine blocks, machinery, brake calipers, rotors, truck brake
drums, etc. Free of non-ferrous and non-metallics, vitreous enameled material.
Permissible:
Attached cast iron content not to exceed 5% by weight.
Allowances:
Alloyed steel may not exceed 15%.

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.
24
Raw Material Specifications

Railroad OTM (Other Track Materials)

Material: Steel Scrap Grade: Railroad OTM

ISRI #s: (4),(5),(6),(34),(34A) AKA: OTM, plates, spikes, joint bars

Description:
OTM = Other Track Material including all spikes, track bolts and nuts, lock washers, rail
anchors, tie plates, rail joints, angles, and/or splice bars and all steel coil springs.

Typical Appearance

Physical Appearance

Sizing: 36” x 18” x 1” Typical Density: 125-150 (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%) 0.70 0.75 0.025 0.035 0.35 0.15 0.15 0.15 0.03 0.01 0.04

Exclusions:
All other railroad scrap including bolsters, side frames, car sides and roofs, railroad rail,
brakes, linkages, cast iron in any form, manganese in all forms.
Permissible:
Allowances:

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

25
Raw Material Specifications

Railroad Rail

Material: Steel Scrap Grade: Railroad Rail

ISRI #s: 27, 28A, 28B, 28C, 29 AKA: Cropped, cut, or broken rail

Description: Railroad rail cut 2 to 4 feet in length, may include joint bars and splices.

May be broken, sheared or torch cut to size. No manganese attachments allowed.

Typical Appearance

Physical Appearance

Sizing: 48”
48125-150
x ” xx 7” x 2”
3) Typical
Typical
Density:
Density:
-150 125-150
125-150
(Lbsft3)
(Lbs/ft3)
(Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%) 0. 0.75


0.70 0.75 0.025
0.0250.035
0.0350.35
0.35 0.15 0.15 0.15 0.03 0.01 0.04

Exclusions:
All other railroad scrap including bolsters, side frames, car sides and roofs, railroad rail,
brakes, linkages, cast iron in any form, manganese in all forms.
Permissible:
Allowances:

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

26
Raw Material Specifications

#2 Shredded

Material: Steel Scrap Grade: #2 Shredded

ISRI #s: 210; 211 AKA: Auto Shred; Fragmentized; Shredded

Description:
Homogenous shredded steel scrap magnetically separated from automobiles, unprepared
#1 Heavy Melt and #2 Heavy Melt steel, and miscellaneous sheet goods.

Typical Appearance

Physical Appearance

Sizing: 8” x 8” x 1” Typical Density: 55-75 (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%) 0.25 1.50 0.05 0.05 0.50 0.22 .10 .10 0.03 .015 0.01

Exclusions:
Free of coated metals, limed, vitreous enameled, and electrical coated sheet over 0.50%
silicon. Municipal, incinerated, tin cans, excessive oil filters, excessive fluff, copper clad or
plated steel.
Permissible:
Zinc or galvanized coated steels. Cast iron content not to exceed 5% by weight.
Allowances:
Due to the nature of processing this grade, small amounts of copper wiring and motor
windings will be entrapped with the steel.

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.
27
Raw Material Specifications

Tin Can Bales

Material: Steel Scrap Grade: Tin Can Bales

ISRI #s: 213 AKA: Tin Bales, Steel Can Bales

Description:
Clean steel can scrap compressed for easy magnet handling and weighing not less than
45 pounds per cubic foot. Cans may be baled without removal of paper labels, but free of
all other non-metallics and food products. Minimum of 7 wire bands around the bale.

Typical Appearance

Physical Appearance

Sizing: 48” x 36” x 24” Typical Density: 45-55 (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%) 0.10 0.30 0.020 0.055 0.25 0.05 0.05 0.05 0.005 0.45 0.025

Exclusions:
All non-metallics such as plastics, wood, aluminum, other than can labels.
Permissible:
De-tinned materials allowed with prior melt shop approval.
Allowances:
Clean, triple rinsed 5 gallon tin coated containers.

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

28
Raw Material Specifications

Railroad Wheels

Material: Steel Scrap Grade: Railroad Wheels

ISRI #s: (2),(2A),(3),(3A),(42) AKA: Railroad Wheels and axles

Description:
Solid car, locomotive friction bearing and roller bearing axles, and solid cast steel wheels,
pressed, forged and/or rolled steel car and/or locomotive wheels not over 43 inches in
diameter. Axles may be cut in half between wheels or at wheel connection.

Typical Appearance

Physical Appearance

Sizing: 43” x 18” x 6” Typical Density: 80-100 (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%) 0.80 0.75 0.025 0.025 0.50 0.10 0.10 0.10 0.03 0.01 0.04

Exclusions:
All other railroad scrap including bolsters, side frames, car sides and roofs, railroad rail,
OTM (Other Track Materials), brakes, linkages, cast iron in any form, manganese in all
forms.
Permissible:
Roller bearings and friction bearings without the brass/bronze bearings.
Allowances:
(N/A)

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.
29
Raw Material Specifications

Pig Iron

Material: Steel Scrap Grade: Pig Iron

ISRI #s: AKA: Pig Iron

Description:
Pig iron formed in the casting machine for uniform size. May be from United States, Brazil,
or Russian source based on carbon and silicon content.

Typical Appearance

Physical Appearance

Sizing: 36” x 6” x 6” Typical Density: 180-200 (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%) 4.50 .50 0.050 0.060 .25 0.05 0.05 0.05 0.01 0.010 0.025

Exclusions:
All non-metallics such as plastics, wood, aluminum.
Permissible:
May be linked between sections up to 3 feet long.
Allowances:
(N/A)

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

9
Raw Material Specifications

Turnings

Material: Steel Scrap Grade: Turnings

ISRI #s: 219; 221 AKA: Machine Shop Turnings; Shoveling Turnings

Description:
Clean steel turnings drillings, or screw cuttings. May include any such material whether
resulting from crushing, raking, or other processes. May contain small amounts of springy
or bushy material.

Typical Appearance

Physical Appearance

Sizing: Typical Density: 45-55 (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%) 0.50 0.75 0.035 0.08 0.75 0.35 0.25 0.25 0.10 0.02 0.04

Exclusions:
Free from tangled, matted material, lumps, cast iron borings, badly rusted or corroded
stock, and oil/cutting fluids. No mill scale, grinder swarf, grinder sludge, polishing filter
media, nonferrous materials such as but not limited to brass, bronze, copper, lead, tin,
aluminum, etc.
Permissible:
Small amounts of solids from rod stock or other turned materials.
Allowances: (N/A)

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.
31
THE BAD
Raw Material Specifications

Cast Mixed with Other Grades

Material: Cast Grade: Cast CSRM Code:

ISRI #s: AKA:

Description:
Cast in all forms, but not limited to, machinery, valves, brake shoes, calipers, drums, all
engine parts, all diesel engine parts, manhole covers, grating, etc.

Physical Appearance

Sizing: Various Typical Density: (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%)

Exclusions: (N/A)
Permissible: (N/A)
Allowances: (N/A)

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

33
Typical Appearance

Automotive Head

Brake Calipers

Disc Brake Calipers

34
Truck Brake Drums

Fly Wheel

35
Raw Material Specifications

Copper

Material: Copper Grade: Copper CSRM Code:

ISRI #s: AKA:

Description:
Copper in all forms that are free formed such as copper tubing and wiring, and coated
wiring, radiator fins, etc.

Physical Appearance

Sizing: Various Typical Density: (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%)

Exclusions: (N/A)
Permissible: (N/A)
Allowances: (N/A)

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

36
Typical Appearance

Copper Motor

Copper Tubing

37
Copper Pipe
Copper Wiring

Truck Radiator

38
Raw Material Specifications

Dirt

Material: Dirt Grade: Dirt CSRM Code:

ISRI #s: AKA:

Description:
Dirt in all forms including dust, clumps, etc.

Physical Appearance

Sizing: Various Typical Density: (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%)

Exclusions: (N/A)
Permissible: (N/A)
Allowances: (N/A)

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

39
Typical Appearance

40
41
Raw Material Specifications

Mixed Grades

Material: Mixed Grades Grade: Mixed Grades CSRM Code:

ISRI #s: AKA:

Description:
Any shipment of scrap not consistent with the individual scrap specification as agreed to
between CSRM and the SSI purchasing/brokerage/shipping point entity. This does not
include the intentional mixing of #1 and #2 materials to form the grade of mixed #1 &
2. It does pertain to items such as turnings mixed into shred or mill scale mixed into low
residual.

Physical Appearance

Sizing: Various Typical Density: (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%)

Exclusions: (N/A)
Permissible: (N/A)
Allowances: (N/A)

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

42
Typical Appearance

Turnings

Turnings

43
Tire Wire

Grinder Balls

44
Raw Material Specifications

Non Conductor

Material: Non Conductor Grade: Non Conductor CSRM Code:

ISRI #s: AKA:

Description:
Non Conductors of electricity including wood in all forms including, but not limited to, logs,
timbers, telephone poles, building lumber, sheets, pallets, boxes, etc.; concrete items like
ecology blocks, cement filled bollards, large attached cement on rebar, etc.; whole tires;
plastic lined pipe/tubing; paper rolls; rocks; clothing.

Physical Appearance

Sizing: Various Typical Density: (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%)

Exclusions: (N/A)
Permissible: (N/A)
Allowances: (N/A)

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

45
Typical Appearance

Wood

46
Raw Material Specifications

Oversized Materials

Material: Oversized Grade: Oversized CSRM Code:

ISRI #s: AKA:

Description:
Oversized materials in all forms, but not limited to, Bonus, Mixed #1 & #2, Dealer Bundles,
Cast Iron, Railroad scrap, home scrap, etc.

Physical Appearance

Sizing: Various Typical Density: (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%)

Exclusions: (N/A)
Permissible: (N/A)
Allowances: (N/A)

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

48
Typical Appearance

8 ft. Pipe

I-Beam

Side Frame

Center Beam

48
Center Beams

8 ft. Long Billets

49
UGLY SCRAP
UGLY SCRAP
UGLY SCRAP
Raw Material Specifications

Rubber, Fluff, Plastic

Material: Rubber, Fluff, Plastic Grade: Rubber, Fluff, Plastic CSRM Code:

ISRI #s: AKA:

Description:
Rubber, shredder fluff, plastic materials in all forms

Physical Appearance

Sizing: Various Typical Density: (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%)

Exclusions: (N/A)
Permissible: (N/A)
Allowances: (N/A)

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

5
Typical Appearance

Mattress

Hydraulic Hose

5
Car Seat Fluff

Plastic Chunk Fiberglass

Bucket

Fender

5
Raw Material Specifications

Sealed Containers

Material: Sealed Containers Grade: Sealed Containers CSRM Code:

ISRI #s: AKA:

Description:
Sealed Containers in all forms that have the ability to hold a gas or liquid. These include,
but are not limited to, all tanks and cylinders, shock absorbers and struts, paint cans, sealed
units e.g. refrigerant compressors, any other vessel that has the ability to hold liquids or
gases.

Physical Appearance

Sizing: Various Typical Density: (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%)

Exclusions: (N/A)
Permissible: (N/A)
Allowances: (N/A)

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

5
Typical Appearance

Torque Converters

Torque Converters

55
Raw Material Specifications

Oxidized Materials

Material: Oxidized Grade: Oxidized CSRM Code:

ISRI #s: AKA:

Description:
Oxidized materials in all forms.

Physical Appearance

Sizing: Various Typical Density: (Lbs/ft3)

Chemistry: C Mn P S Si Cu Ni Cr Mo Sn Al

(Maximum wt%)

Exclusions: (N/A)
Permissible: (N/A)
Allowances: (N/A)

Inspection Criteria:
Material is subject to visual inspection and classification based on visual and chemical
analysis, inspection for prohibited materials, sizing constraints, mechanical weighing on
certified scales and radiation detection. All conditions and requirements of the CSRM Raw
Material Specifications for Steel Scrap General Requirements apply.

5
Typical Appearance

Oxidized Slag

Oxidized Torch Drippings

57
Area Source
Rule Requirements
Area Source Rule Requirements

The following information details scrap requirements under 40 CFR Part 63,
Subpart YYYYY (National Emission Standards for Hazardous Air Pollutants for Area
Sources: Electric Arc Furnace Steelmaking Facilities).

National Vehicle Mercury Switch Recovery Program

The National Vehicle Mercury Switch Recovery Program (NVMSRP)


is a national partnership of steel producers, scrap recyclers, vehicle
manufacturers, State agencies, environmental organizations, and the U.S.
Environmental Protection Agency (EPA) formed with the goal of reducing
mercury in the scrap feedstock for Electric Arc Furnace (EAF) Steelmaking
Facilities. The NVMSRP program is designed to facilitate the removal of
mercury-containing switches from end-of-life vehicles before they are
flattened, shredded, and melted to make new steel. Participation in the
NVMSRP is required by all parties in the scrap supply chain in order to
achieve the desired mercury reduction goals.
The NVMSRP is administered by the End of Life Vehicles Solutions
Corporation (“ELVS”). At no cost, ELVS will supply scrap providers with a
collection bucket, educational materials and detailed shipping instructions
for the switches. ELVS will cover all of the shipping and disposal costs
for the switches collected by participating scrap providers. Monetary
incentives for participation are also provided by ELVS. For additional
information, and to participate in the program and receive these materials
at no cost, scrap providers should contact ELVS at www.elvsolutions.org, or
by calling toll free, 1-877-225-3587.

Additional Pollutants Under the Area Source Rule

The Area Source Rule which requires removal of mercury switches


from end-of-life vehicles further defines the standards for scrap which is
acceptable for purchase by EAF Steelmaking Facilities. Included in the
following pages is Cascade’s Pollution Prevention Plan for the Control of
Contaminants in Scrap Under the Area Source Rule for Electric Arc Furnace
(EAF) Steelmaking Facilities (PPP). The PPP details Cascade’s compliance
strategy for the Area Source Rule.

 As of September 25, 2008 the “bounty” for recovered mercury switches submitted to ELVS
was $4.00/switch.
61
Area Source Rule Requirements

Pollution Prevention Plan for the Control of Contaminants in


Scrap Under the Area Source Rule for Electric Arc Furnace
(EAF) Steelmaking Facilities

Contaminants such as chlorinated plastics, free organic liquids, lead


(except for leaded steel) and mercury are not appropriate or desired for
the production of steel in EAF facilities. However, these contaminants are
found in the scrap metal that is the basic feedstock for the production of
new steel.
EPA has identified EAF facilities as potential sources of HAP
emissions and, on December 28, 2007, promulgated final regulations
(codified at 40 CFR part 63, subpart YYYYY) intended to control or minimize
such emissions.
The regulations require EAF facilities, among other things, to restrict
the use of certain scrap or follow a pollution prevention plan (PPP) for scrap
purchased as production feedstock to minimize the amount of specified
contaminants in such scrap.
Schnitzer Steel, Inc. is the sole agent for purchasing scrap for
Cascade Steel Rolling Mills, Inc. (CSRM). As the agent for scrap purchased
for CSRM, SSI accepts this PPP and its conditions for all scrap consumed.
CSRM is committed to complying with the requirements of the EAF
Area Source Rule and to the goal of removing at least 80% of mercury
convenience-light switches from motor vehicle scrap. CSRM is also
committed to minimizing to the extent practicable the presence of other
contaminants in scrap that may result in the emission of hazardous air
pollutants (HAP).
Accordingly, CSRM has adopted and will comply with the provisions
of this PPP designed to control the presence of such contaminants in scrap
that is consumed in the EAF by adopting:

1. A specification for scrap that addresses contaminants


identified by EPA
2. Procedures for verifying compliance with the specification
3. Procedures for taking corrective action against vendors who
do not comply with the specification
4. Program policies, implementation elements, and training and
outreach materials sufficient to demonstrate how CSRM will
62
Area Source Rule Requirements

appropriately implement its responsibilities under the EPA-


approved National Vehicle Mercury Switch Recovery Program
(NVMSRP) or other EPA-approved program.

This PPP must be approved by USEPA or a delegated authority. Any


deficiencies identified by the permitting authority must be addressed
within 60 days of disapproval of the PPP. A copy of the plan and supportive
documentation must remain onsite for a period of three years.
The terms used in this Pollution Prevention Plan and in the outreach
materials attached and incorporating to the PPP shall have the same
definitions as those enumerated in EPA’s Final Area Source Rule found at 40
CFR Part 63 Subpart YYYYY. As outlined in the final rule, the term “mercury
switch” denotes only mercury switches that are part of a convenience light
switch mechanism installed in a vehicle.

I. General Scrap Specifications:


The following restrictions apply to all scrap steel purchased or used by
CSRM in its EAF steelmaking process:

A. Scrap materials must be depleted to the extent practicable


of undrained used oil filters, chlorinated plastics, and free
organic liquids at the time of charging to the furnace.
B. Lead-containing components of scrap, such as batteries,
battery cables, and wheel weights, must be removed, to the
extent practicable, prior to charging in the furnace unless the
scrap is used to produce leaded steel.
C. Scrap must be purchased from providers that have minimized
the presence of mercury in scrap through participation in the
NVMSRP or another EPA-approved program.

II. Verification of Compliance with Specifications



A. Free Organic Liquids, Chlorinated Plastics, Lead and Lead-
Containing Components:

1. Visual Inspection: CSRM conducts a visual


inspection of incoming scrap loads to

63
Area Source Rule Requirements

ensure that the scrap meets existing quality and/


or purchase order specifications for grade, type,
density, and content. Scrap inspection will be
required also to determine whether there is an
obvious presence of free organic liquids,
chlorinated plastics, or lead-containing
components. Records of scrap inspections will
be maintained on site for one year. Scrap
inspection records shall include the identity
of the scrap provider for any load that fails visual
inspection.

2. Inspection for Free Organic Liquids:
Turnings, borings, and other forms of scrap that
were generated as a result of the processing of
metal with use of cutting, lubricating or cooling
fluids will be visually inspected prior to charging
to the furnace to ensure that such scrap does not
contain free organic liquids.

3. Depletion of Lead and Chlorinated Plastics
from Shredded Scrap: Scrap that has been
processed through a shredder that utilizes
magnetic or density separation techniques to
separate ferrous and non ferrous materials will
be presumed to be depleted scrap of chlorinated
plastics and lead to the extent practicable.

4. Inspections: CSRM shall identify any scrap


provider whose scrap (except as described in
Paragraph 5 below) is not subject to inspection
pursuant to this plan. CSRM shall audit or inspect
the facilities from which such uninspected scrap
is provided on a periodic basis at a rate of not
less than 10-25% of such facilities each year.

5. Unrestricted Scrap: Certain types of scrap,


including:
64
Area Source Rule Requirements

Bonus
Busheling
Coils
Factory bundles
Flashings
HBI
Home scrap
Low residual
Pig iron
Pit scrap
Plate and structural
Return scrap
Rail
Railroad wheels
Slitter
Tire wire
as defined by common industry practice, as
well as similar uncontaminated scrap, are
not expected to contain free organic liquids,
chlorinated plastics, or lead and will be
presumed to be free of these contaminants.
This scrap is not subject to the inspection and
verification requirements of this plan.

6. Baghouse Bags, Internal Process and


Maintenance Materials: Baghouse bags
and baghouse maintenance materials that are
routinely recycled by charging to the electric arc
furnace, including personal protective equipment
(PPE) and baghouse dust, are exempt from
this PPP and not subject to the inspection and
verification requirements of this plan.

B. Mercury

1. Schnitzer Steel, Inc. shall ensure that motor
vehicle scrap providers are participating

65
Area Source Rule Requirements

in the National Vehicle Switch Recovery Program


(NVMSRP) by conducting a review of the End of
Life Vehicle Solutions (ELVS) database to confirm
that the motor vehicle scrap provider is enlisted
as a participating member. SSI will conduct
a semi-annual review of the ELVS database
to determine whether the provider remains
identified as an NVMSRP participant;

a. SSI may not be able to confirm


that some motor vehicle scrap
providers such as Brokers are
enlisted as a participating member
in the NVMSRP through the ELVS
database. In these cases SSI
will confirm that the broker is
participating in the NVMSRP or
another EPA-approved program by
obtaining from the broker written
assurance that any motor vehicle
scrap provided by such broker to
CSRM was procured from other
suppliers who are signed up for and
are participating in the NVMSRP or
another EPA-approved program;

b. SSI will require motor vehicle


scrap brokers to confirm such
written assurance on a semi-annual
basis.

2. SSI will conduct a semi-annual review


the ELVS database to corroborate that the
participant is implementing appropriate steps
to minimize the presence of mercury in scrap
from end-of-life vehicles by turning in mercury
switches.
66
Area Source Rule Requirements


a. Some motor vehicle scrap providers
participating in the NVMSRP or
another EPA-approved program
may not be able to demonstrate
their participation in NVMSRP or
another EPA-approved program to
minimize the presence of mercury
in the motor vehicle scrap from
end-of-life vehicles by turning in
mercury switches because they
refuse to accept motor vehicle scrap
that contains mercury switches.
Examples would be a broker who
purchases motor vehicle scrap from
program participants, or a shredder
that accepts only flattened vehicles
from which the mercury switches
already have been removed to the
extent practicable prior to delivery
to the shredder. For these motor
vehicle scrap providers, SSI will
obtain written assurances from the
provider or obtain other means
of corroboration to verify that
the participant is implementing
appropriate steps to minimize the
presence of mercury in the scrap
from end-of-life vehicles. Written
assurance will be confirmed on a
semi-annual basis.

3. If a motor vehicle scrap provider does not


participate in or demonstrate through written
assurance that it purchases motor vehicle scrap
through NVMSRP or another EPA-approved
program for the removal of mercury switches,
76
Area Source Rule Requirements

SSI shall only purchase motor vehicle scrap from


such provider pursuant to an EPA-approved
facility-specific program for the removal of
mercury switches.

III. Corrective Action

A. Lead, Chlorinated Plastics, Free Organic Liquids

1. If, during inspection of scrap pursuant to Part


II(A) above, CSRM determines that the scrap
provider has not met the specifications in part I,
the scrap provider will be subject to corrective
action.

a. A nonconforming scrap load will


be rejected, the vendor may ship
Unrestricted Scrap so long as it
adheres to the provisions outlined in
Part II(a)(5).

b. After a failure to meet the
scrap specifications in Part I,
the scrap provider must sign
a statement acknowledging
the requirements of the scrap
specifications and provide either
certification or another comparable
form of reasonable assurance that
the scrap specifications will be met
in the future.

c. If the vendor continues to fail to


meet the scrap specifications, SSI
will consult with the scrap provider
on the cause or reasons why the
scrap loads are nonconforming and
68
Area Source Rule Requirements

will inform the scrap provider that it


may be suspended if the problem is
not resolved.

B. Mercury

1. If, SSI reasonably believes, either as a result
of inspection, site visits to a scrap yard, or review
of the ELVS database or by other means, that a
scrap supplier is not taking appropriate steps to
minimize the presence of mercury switches in
scrap from end-of-life vehicles, the facility shall:

a. Issue a letter to the scrap provider


reiterating the requirements of
the NVMSRP or another EPA-
approved program and threatening
suspension if the scrap provider
fails to fulfill its responsibilities
under the NVMSRP or another EPA-
approved program.

b. Suspend the scrap provider if,


within six months of receipt of
the letter described above, the
scrap provider again fails to show
that it is aware of the need for
and is implementing appropriate
steps to minimize the presence of
mercury switches in auto shred.
The suspension shall only apply to
shipments of motor vehicle scrap
by The provider will then have
to re-qualify by demonstrating
that it has cured the defect that
caused the failure to meet the scrap
specification.
69
Area Source Rule Requirements

c. For purposes of Section III A and B, if


the nonconforming scrap is
purchased through a broker, SSI
will require the broker to provide
written assurances that the broker
implemented corrective action as
set forth in Section III of this plan
with respect to the supplier of such
non-conforming scrap.

9
Cascade Steel recognizes that education, continual learning, skills development,
and a successful business go hand-in-hand. To assist in developing essential skills
for our personnel, this course along with others are being introduced.

We also encourage professional certification and development of skills through


recognized organizations. Here’s the value in becoming certified:

Everybody knows that MD following an individual’s name means Medical Doctor,


and that CPA signifies Certified Public Accountant. Associations and professions
use certification to recognize qualified and competent individuals.

The certification process is one of the single most important steps in career
development. Some advantages are:

1. Certification grants you professional credentials.

2. Certification demonstrates your commitment to the profession.

3. Certification enhances the profession’s image.

4. Certification reflects achievement.

5. Certification builds self-esteem.

6. Certification can improve career opportunities and advancement.

7. Certification may provide for greater earnings potential.

8. Certification improves skill and knowledge.

9. Certification prepares you for greater on-the-job responsibilities.

10. Certification offers greater recognition from peers.

Any use, duplication or reproduction of this program, its contents or pictures by


persons other than authorized Cascade Steel Rolling Mills corporate personnel is
strictly prohibited.
Cascade Steel is firmly committed to maintaining a safe and healthful work
environment. In keeping with this commitment to safety, all employees are
required to be trained in the proper safe operating procedures for their jobs
and specialized equipment.

No training program can cover all potential safety issues that you may
encounter during work. In the event you are faced with a question about a
procedure and/or safety when working, follow the procedures outlined in
the current company safety policies and procedures to prevent accidents or
injuries, consult with your shift supervisor and use your good judgment. 01

3200 North Highway 99 • McMinnville, Oregon 97128


(503) 472-4181 • csrm.com

a subsidiary of the Schnitzer Corporation


01.2015

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