1
Date:
May
15,
2003
Subject:
Telephone
Conference
Summary
­
EPA
and
representatives
from
the
taconite
industry
From:
Conrad
Chin,
EPA
To:
Docket
OAR­
2002­
0039
I.
Purpose
The
primary
purpose
of
the
meeting
was
to
clarify
comments
from
the
taconite
industry
on
the
proposed
rule.
The
discussion
topics
were
the
continuation
of
previous
discussions
from
conference
calls
held
on
April
21,
May
1,
and
May
9.

II.
Date
May
15,
2003
III.
Attendees
U.
S.
Environmental
Protection
Agency
Steve
Fruh,
OAQPS/
ESD/
MG
Conrad
Chin,
OAQPS/
ESD/
MG
Taconite
industry
representatives
Tishie
Woodwell,
U.
S.
Steel
Leonard
Parker,
Tilden
Mining
John
Meier,
Cleveland­
Cliffs
Gus
Josephson,
Ispat
Inland
Mining
Dennis
Wagner,
Northshore
Mining
Brad
Anderson,
EVTAC
Bill
Kubiak,
U.
S.
Steel
LaTisha
Gietzen,
National
Steel
Raymond
Potts,
U.
S.
Steel
Dave
Skolasinski,
Northshore
Mining
Don
Ahola,
Empire
Mining
Andrea
Hayden,
Hibbing
Taconite
Alpha­
Gamma
Technologies
Chuck
Zukor
Chris
Sarsony
OAR­
2002­
0039
IV­
E­
6
2
IV.
Discussion
Parametric
Monitoring
A.
Venturi­
Rod
Deck
Scrubbers
°
Minntac
informed
the
EPA
that
they
cannot
adjust
their
scrubber
fans
to
maintain
a
certain
pressure
drop
across
the
scrubber.
The
dampers
to
the
fans
are
controlled
to
maintain
the
overall
indurating
process.

°
The
EPA
inquired
about
the
possibility
of
establishing
a
correlation
between
pressure
drop
and
throughput
rate.
Minntac
agreed
to
look
into
it.

°
The
EPA
stated
that
it
may
be
possible
to
consider
using
historical
data
from
recent
compliance
tests
in
addition
to
the
initial
compliance
test
for
establishing
the
operating
limits
for
venturi­
rod
deck
scrubbers.
Industry
will
investigate
if
this
possibility
will
help
them
alleviate
some
of
their
concerns.

B.
Wet
ESP
°
Northshore
indicated
that
water
flow
would
be
a
good
parametric
monitoring
choice.
Because
of
scaling
problems,
Northshore
stated
that
secondary
voltage
fluctuates
too
much
and
would
not
be
a
good
monitoring
parameter.
Northshore
will
investigate
whether
the
fluctuation
decreases
after
maintenance
to
determine
if
this
concern
is
more
of
a
maintenance
problem.

°
The
EPA
suggested
another
possible
monitoring
parameter:
outlet
gas
temperature.
This
suggestion
was
provided
by
an
in­
house
expert
and
the
suggestion
was
sent
to
Northshore
and
Tilden
for
reference.
Both
plants
will
follow
up
with
this
suggestion.

°
Tilden
concurred
that
water
flow
monitoring
for
its
wet
ESP
is
a
good
indicator
of
emission
control
performance.
Tilden
is
currently
not
monitoring
secondary
voltage
and
current
from
its
wet
ESP,
but
will
also
study
suggestions
from
EPA
on
these
monitoring
parameters.

C.
Dry
ESP
°
Empire
stated
that
their
dry
ESPs
are
computer
controlled
(
e.
g.,
spark
rate,
amps,
volts).
If
some
of
the
set
parameters
fail,
alarms
will
then
be
triggered.
Empire
suggested
that
if
no
alarms
are
triggered,
then
it
should
meet
EPA's
monitoring
requirements.
However,
EPA
was
concerned
that
the
current
corrective
action
plan
in
place
when
alarms
are
triggered
may
be
inadequate.
Under
their
current
title
V
permit
operation
of
the
ESP
continues
unless
visible
emissions
are
observed
at
the
stacks.
The
EPA
pointed
out
that
this
malfunction
plan
would
not
be
acceptable
because
of
the
more
stringent
MACT
emission
limit.
The
plant
would
3
not
be
able
to
observe
a
visible
emission
even
if
the
MACT
limit
is
not
met.
Furthermore,
the
plant
has
operated
and
tested
in
the
past
with
some
ESP
modules
off­
line.
This
practice
would
not
be
acceptable
under
the
MACT
rule.
Empire
will
review
current
corrective
action/
malfunction
plan
and
provide
EPA
with
a
suggestion
how
to
resolve
these
issues.

D.
Dynamic
Scrubbers
°
Industry
concurs
with
the
EPA
that
fan
amperage
and
water
flow
rate
are
appropriate
performance
parameters
for
dynamic
wet
scrubbers.

E.
Water
Pressure
as
a
Surrogate
for
Water
Flow
°
Industry
concurs
with
EPA's
concern
that
water
line
pluggage
can
give
an
inaccurate
water
pressure
reading.

°
EVTAC
indicated
that
the
costs
of
installation
of
water
flow
meters
are
their
real
major
concern.
They
estimated
they
would
need
to
install
three
flow
meters
for
their
furnaces
at
a
total
cost
of
approximately
$
30K
(
about
$
10K
per
flow
meter).
EVTAC
will
investigate
how
to
resolve
the
water
line
pluggage
issue.
Without
resolving
this
concern,
it
will
be
difficult
for
EPA
to
accept
the
use
of
water
pressure
as
a
surrogate
for
water
flow.

°
National
Steel
indicated
that
they
have
approximately
28
wet
scrubbers
that
they
are
currently
using
water
pressure
as
an
indicator
of
performance.
These
are
all
on
smaller
emission
units
and
the
cost
for
installing
flow
meters
on
smaller
units
is
approximately
$
100
per
flow
meter.

°
Tilden
also
reported
that
they
use
some
water
pressure
gauges
and
will
review
their
situation
for
the
next
conference
call.

F.
Rolling
6­
hour
Average
for
Compliance
Determination
°
Industry
is
not
sure
how
this
concept
will
benefit
the
plants.
Minntac
indicated
that
a
six­
hour
averaging
period
would
not
resolve
the
venturi­
rod
deck
issues.
The
EPA
will
explore
this
possibility
more
for
the
next
discussion.

Emissions
Testing
for
Furnaces
°
Industry
informed
EPA
that
half
of
the
plants
are
already
testing
their
furnaces
at
twice
per
permit
term.
Based
on
this
information,
it
is
difficult
for
EPA
to
justify
any
changes
from
the
proposed
test
frequency.

°
Industry
suggested
that
EPA
allow
plants
to
reduce
their
testing
frequency
if
they
can
demonstrate
that
they
are
able
to
meet
the
MACT
limit
by
an
ample
margin
for
a
few
tests
in
a
row.
The
EPA
stated
it
would
consider
this
suggestion.
