1
Date:
August
23,
2003
Subject:
Telephone
Conference
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
clarify
industry's
technical
comments
on
the
proposed
taconite
NESHAP.

II.
Date
May
01,
2003
III.
Attendees
U.
S.
Environmental
Protection
Agency
Conrad
Chin,
OAQPS/
ESD/
MG
Steve
Fruh,
OAQPS/
ESD/
MG
Industry
Representatives
Brad
Anderson,
EVTAC
Dave
Crouch,
Cleveland­
Cliffs
LaTisha
Gietzen,
National
Steel
Gus
Josephson,
Inland
Mining
Bill
Kubiak,
U.
S.
Steel
John
Meier,
Cleveland­
Cliffs
Leonard
Parker,
Tilden
Mining
Nancy
Smith,
Northshore
Alpha­
Gamma
Technologies
Chris
Sarsony
Chuck
Zukor
OAR­
2002­
0039
IV­
E­
15
2
IV.
Discussion
of
Industry's
Technical
Comments
on
the
Proposed
Rule
A.
Fugitives
Emissions
Control
Plan
Comment:
All
provisions
related
to
the
fugitives
dust
plan
should
be
deleted
to
avoid
duplication
and
potential
conflicts
with
existing
Title
V
permits.
Discussion:
All
plants
have
a
fugitive
dust
plan
in
place.
Industry's
primary
concern
was
duplicative
or
conflicting
requirements.
The
EPA
explained
that
plants
can
submit
existing
plans
to
satisfy
the
requirement
in
the
proposed
taconite
NESHAP.
Based
on
this,
the
industry
representatives
acknowledged
that
no
change
was
necessary.

B.
Compliance
Testing
Comment:
Regarding
the
grouping
of
similar
OCH
and
PH
emission
units
for
initial
performance
tests,
remove
the
specific
criteria
defining
similar
units
and
refer
to
criteria
established
by
the
state
Agency
or
Title
V
permit.
Discussion:
Industry's
primary
concern
is
with
the
criteria
that
the
flow
rate
of
the
units
be
within
10%
of
the
representative
unit
and
that
the
process
throughput
of
the
units
be
within
10%
of
the
representative
unit.
Industry
believes
that
these
criteria
are
too
restrictive.
The
EPA
will
consider
the
technical
merit
of
their
concern.

Comment:
The
simultaneous
testing
of
multiple
stacks
is
costly,
unpractical,
and
possibly
not
even
feasible.
Discussion:
Industry
representatives
explained
that
some
furnaces
have
up
to
five
stacks
and
that
testing
all
five
simultaneously
is
impractical
and
costly.
Some
facilities
have
tested
two
stacks
simultaneously.
Based
on
historical
tests,
stacks
are
generally
tested
sequentially
over
a
period
of
a
few
days.
The
EPA
will
assess
the
practicality
of
simultaneously
testing
multiple
furnace
stacks.
EPA
will
also
consult
with
in­
house
testing
experts
on
the
time
period
in
which
all
stacks
for
a
furnace
should
have
the
tests
completed.

Comment:
Cleveland
Cliffs
(
CCI)
commented
that
test
frequency
should
mimic
Title
V
requirements
for
furnaces.
Stack
testing
for
furnaces
should
only
be
required
when
the
operation
is
modified.
Discussion:
The
EPA
explained
to
the
industry
that
testing
furnaces
twice
per
permit
term
is
necessary
to
ensure
that
the
NESHAP
is
enforceable.
The
EPA
pointed
out
that
about
99
percent
of
the
HAP
and
PM
emissions
come
from
the
furnaces.
Industry
stated
that
although
some
plants
will
have
to
test
their
furnaces
more
frequently
they
accepted
the
requirement
for
testing
furnaces
twice
per
permit
term.
3
C.
Operating
Limits
Comment:
In
their
written
comments
some
taconite
plants
objected
to
using
operating
limits
established
during
the
initial
performance
test
to
determine
compliance.
Discussion:
Industry
stated
that
their
concern
regarding
the
operating
limits
is
related
to
their
specific
technical
concerns
regarding
their
ability
to:
°
maintain
a
constant
pressure
drop
on
venturi­
rod
scrubbers,
°
measure
a
pressure
drop
on
dynamic
wet
scrubbers,
and
°
obtain
meaningful
readings
from
COMs.
To
help
resolve
these
technical
issues
industry
will
investigate
availability
of
historical
operating
data
(
pressure
drop,
water
flow,
etc.)
to
estimate
the
lowest
(
water
flow,
pressure
drop)
or
highest
(
COM
reading)
operating
limits
while
still
meeting
the
MACT
emission
limits.
The
EPA
will
investigate
approaches
used
on
other
similar
rulemakings
(
i.
e.
do
they
allow
the
use
of
historical
data?).

Comment:
Remove
the
pressure
drop
requirement
and
rely
on
the
operation
and
maintenance
plan
for
compliance.
Operators
cannot
directly
control
the
pressure
drop
in
a
rod
deck
scrubber.
In
addition,
the
industry
claimed
that
monitoring
pressure
drops
for
rotoclones
would
be
technically
infeasible.
Discussion:
Minntac,
Hibbing,
and
Inland
will
investigate
availability
of
historical
data
(
pressure
drop,
water
flow,
etc.)
to
estimate
the
lowest
(
water
flow,
pressure
drop)
operating
limits
while
still
meeting
the
MACT
emission
limits.
In
addition,
correlation
between
throughput
rate
and
pressure
drop
will
be
investigated
and
the
data
will
be
presented.
Possible
alternative
monitoring
parameters
will
also
be
investigated
by
the
above
mentioned
three
plants
and
then
proposed
to
EPA.
Industry
will
consult
with
rotoclone
vendors
and
provide
technical
justification.
The
EPA
also
requested
industry
to
suggest
alternative
monitoring
parameters
for
rotoclones.

Comment:
In
addition
to
pressure
drop,
allow
plants
to
use
water
pressure
to
demonstrate
that
wet
scrubbers
are
operating
properly.
Discussion:
EPA
will
investigate
the
feasibility
of
using
water
pressure
as
a
surrogate
for
water
flow
rate.

Comment:
The
requirement
that
the
bag
leak
detection
system
not
alarm
for
more
than
5%
of
the
time
should
be
deleted
from
the
rule.
The
same
commenter
requested
that
a
requirement
be
added
that
provides
wet
scrubbers
a
5%
allowance
for
operating
in
alarm
conditions.
Discussion:
Industry
stated
that
this
comment
is
no
longer
applicable,
since
we
have
removed
the
requirement
of
5%
or
less
of
the
alarm
time
limit
for
the
bag
leak
detection
system.

Comment:
EPA
fails
to
acknowledge
the
actual
opacity
during
compliant
operations
4
will
be
much
less
than
10%
and
normally
close
to
zero.
EPA
provides
no
evidence
that
COMS
can
even
accurately
measure
opacity
when
the
actual
opacity
is
less
than
10%.
Discussion:
Industry
will
investigate
and
present
during
the
next
conference
call
the
typical
moisture
content
of
the
flue
gas
and
how
the
moisture
content
will
affect
the
accuracy
of
the
COM.
Industry
will
also
consult
with
COM
vendors
on
this
issue
and
provide
technical
justification.
Industry
will
also
investigate
possible
alternative
monitoring
parameters
for
dry
and
wet
ESPs.
The
plant
in
Michigan
will
also
present
technical
data
and
operating
experience
on
its
COM
operation.
Data
should
include
correlation
between
moisture
and
fluctuation
in
COM
reading
etc.

Comments:
CCI
suggests
the
same
provisions
as
are
contained
in
the
Portland
Cement
NESHAP
be
adopted
for
opacity
monitoring.
Discussion:
The
EPA
will
investigate
whether
exceeding
operating
limits
should
be
considered
an
exceedance
or
merely
trigger
corrective
action.

Comments:
CCI
does
not
support
a
case­
by­
case,
site­
by­
site,
and
stack­
by­
stack
operating
limit
as
determined
by
the
COMS.
Discussion:
Refer
to
above
discussions.

Comments:
The
opacity
will
be
low
enough
to
be
outside
of
the
range
of
error
for
the
test
method
(
the
COMS)
and
sources
could
create
a
reportable
deviation
without
truly
exceeding
the
actual
opacity
limit.
Discussion:
Refer
to
above
discussions.

D.
Monitoring
Comment:
The
monthly
transducer
checks,
quarterly
gauge
calibration
checks,
semiannual
flow
sensor
calibration
checks,
daily
pressure
tap
pluggage
check,
and
monthly
electrical
connection
continuity
checks
are
overly
burdensome
and
costly.
Discussion:
The
EPA
explained
that
these
requirements
have
been
dropped
in
other
rulemakings.
To
be
consistent
with
these
rulemakings,
EPA
will
remove
these
requirements
from
the
taconite
NESHAP.

E.
Test
Data
Comment:
U.
S.
Steel
has
more
recent
testing
data
that
can
be
used
to
update
the
emission
estimates.
Discussion:
Both
industry
and
EPA
will
check
with
Minntac.

F.
Other
Question:
What
is
the
reason
why
fabric
filters
are
not
used
on
indurating
furnaces?
Discussion:
High
moisture
content
in
flue
gas
stream.
The
moisture
will
cake
up
the
bag
filters.
