1
Date:
August
22,
2003
Subject:
Meeting
Summary
­
EPA
and
representatives
from
the
taconite
industry
From:
Chris
Sarsony,
Alpha­
Gamma
Technologies,
Inc.

To:
Docket
OAR­
2002­
0039
I.
Purpose
The
primary
purpose
of
the
meeting
was
to
discuss
the
following
issues
with
representatives
of
the
taconite
industry:

°
the
industry
de­
listing
petition
and
the
petition
process,
°
the
potential
use
of
risk­
based
approaches,
°
the
economic
impact
of
the
proposed
rule,
and
°
technical
comments
on
the
proposed
rule.

II.
Date
March
18,
2003
III.
Attendees
U.
S.
Environmental
Protection
Agency
Steve
Fruh,
OAQPS/
ESD/
MG
Conrad
Chin,
OAQPS/
ESD/
MG
Kelly
Rimer,
OAQPS/
ESD/
REAG
Dave
Guinnup,
OAQPS/
ESD/
REAG
Alex
Schmandt,
OGC
Taconite
industry
representatives
Don
Ahola,
Empire
Mining
John
Meier,
Cleveland­
Cliffs
Brad
Anderson,
EVTAC
Rhonda
Ross,
Warner
Norcross
&
Judd
Dave
Crouch,
Cleveland­
Cliffs
Larry
Salmela,
U.
S.
Steel
Mr.
Bill
Kubiak
­
U.
S.
Steel
Dave
Skolasinski,
Northshore
Mining
LaTisha
Gietzen,
National
Steel
Andrea
Hayden,
Hibbing
Taconite
Alpha­
Gamma
Technologies,
Inc.

Chris
Sarsony
OAR­
2002­
0039
IV­
E­
12
2
IV.
Discussion
De­
listing
Petition
and
the
Petition
Process:

°
At
industry's
request
the
EPA
explained
the
time
line
for
de­
listing
proposals
and
provided
an
update
of
the
status
of
other
de­
listing
petitions.

°
EPA
stressed
that
the
taconite
NESHAP
has
a
court
ordered
promulgation
deadline
of
August
of
2003.
Therefore,
the
de­
listing
petition
will
not
affect
the
promulgation
date.

°
Taconite
industry
representatives
indicated
that
they
will
submit
a
de­
listing
petition
to
EPA
by
the
end
of
June
2003.

Potential
use
of
risk­
based
approaches:

°
Industry
representatives
provided
additional
detail
regarding
their
public
comments
on:

°
Subjecting
the
source
category
to
one
of
the
more
innovative
risk­
based
approaches
as
was
done
in
the
Brick
and
Structural
Clay
Products
and
Clay
Ceramics
NESHAP
and
several
other
rulemakings.

°
Splitting
the
category
into
indurating
sources
and
non­
indurating
sources
as
was
done
in
the
Brick
and
Structural
Clay
Products
and
Clay
Ceramics
NESHAP.
Then
they
proposed
de­
listing
the
non­
indurating
sources.

°
EPA
explained
that
the
Brick
and
Structural
Clay
Products
and
Clay
Ceramics
NESHAP
split
out
plants
that
were
making
completely
different
types
of
products.
They
did
not
split
out
certain
steps
of
a
continuous
process,
as
the
taconite
industry
is
suggesting.

Economic
Impact
of
the
Proposed
Rule:

°
Industry
stated
that,
as
explained
in
their
written
comments,
the
proposed
rule
will
have
a
significant
impact
on
the
taconite
industry.

°
The
EPA
asked
if
the
industry
could
provide
updated
cost
impacts
for
each
plant.
The
industry
representatives
agreed
that
they
could
provide
the
cost
information
in
the
next
2
to
3
weeks.

Technical
Comments
on
the
Proposed
Rule:

°
Industry
representatives
highlighted
some
of
the
technical
concerns
that
were
included
in
their
written
public
comments.
These
included:
°
continuous
monitoring
requirements,
°
simultaneous
testing
of
indurating
furnace
stacks,
°
pressure
drop
is
hard
to
control
for
some
emission
control
devices,
such
as
venturi­
rod
scrubbers
and
dynamic
wet
scrubbers,
°
excluding
pellet
cooler
stacks
and
pellet
galleries
from
the
definition
of
finished
pellet
handling,

°
Minntac
agreed
to
contact
the
venturi­
rod
manufacturer
regarding
maintaining
a
constant
pressure
drop.
They
will
also
look
at
the
pressure
drop
readings
from
their
historical
emissions
tests.
