1
Date:
May
23,
2003
Subject:
Telephone
Conference
Summary
­
EPA
and
representatives
from
Cleveland
Cliffs
From:
Conrad
Chin,
EPA
Chris
Sarsony,
Alpha­
Gamma
To:
Docket
OAR­
2002­
0039
I.
Purpose
This
conference
call
was
requested
by
Mr.
David
Crouch
of
Cleveland
Cliffs.
The
primary
purpose
of
the
meeting
was
to
clarify
some
of
the
technical
discussions
from
previous
conference
calls
between
EPA
and
the
taconite
industry.

II.
Date
May
23,
2003
III.
Attendees
U.
S.
Environmental
Protection
Agency
Conrad
Chin,
OAQPS/
ESD/
MG
Taconite
industry
representatives
Leonard
Parker,
Tilden
Mining
Dave
Skolasinski,
Northshore
Mining
John
Meier,
Cleveland­
Cliffs
David
Crouch,
Cleveland­
Cliffs
Dennis
Wagner,
Northshore
Mining
Rhonda
Ross,
Warner,
Norcross
&
Judd
Alpha­
Gamma
Technology,
Inc.

Chris
Sarsony
IV.
Discussion
Parametric
Monitoring
A.
Wet
ESP
°
Cleveland
Cliffs
inquired
if
EPA
can
issue
a
"
generic"
type
of
parametric
monitoring
requirement
for
the
states
to
approve.
Cleveland
Cliffs
will
provide
an
example
of
the
concept
for
EPA
to
review.
EPA
will
review
the
concept
prepared
by
Cleveland
Cliffs.
OAR­
2002­
0039
IV­
E­
7
2
°
For
wet
ESPs,
the
Agency
is
considering
the
following
monitoring
parameters:
outlet
gas
temperature,
water
flow
rate,
secondary
current
and
voltage
etc.

B.
Dry
ESP
°
Tilden
indicated
that
they
would
like
to
have
the
option
of
using
COMS
as
parametric
monitoring.

Grouping
of
Similar
Units
°
Cleveland
Cliffs
seemed
to
be
confused
regarding
EPA's
request
for
them
to
group
their
emission
units.
The
EPA
explained
that
the
purpose
of
the
exercise
was
to
estimate
how
many
initial
performance
tests
each
of
the
plants
will
have
to
conduct.

Rounding
°
The
EPA
explained
to
Cleveland
Cliffs
that
rounding
to
two
decimal
places
would
apply
to
existing
furnace
sources
only.

Baseline
emissions
based
on
Table
4
of
MPCA's
document
(
Taconite
Iron
Ore
Industry
in
the
United
States
­
A
Background
Information
Report
for
MACT
Determination,
December
30,
1999)
°
Cleveland
Cliffs
stated
that
the
MPCA
had
overestimated
the
baseline
emissions
of
acid
gases
and
formaldehyde,
as
documented
in
an
email
by
MPCA
regarding
a
recent
test
at
Minntac.
This
will
alter
the
EPA's
emissions
reduction
estimates
(
and
thus
the
cost
effectiveness).
The
EPA
will
review
the
new
emissions
data
and
revise
the
baseline
emissions
and
emission
reduction
estimates
as
appropriate.
°
An
industry
representative
indicated
that
there
was
also
another
recent
test
at
Minntac
on
its
marble
bed
scrubber.
The
results
of
that
test
showed
very
low
PM
emissions,
leading
him
to
believe
that
the
metallic
HAP
emissions
at
Minntac
were
overestimated
for
the
nonfurnace
sources.
This
representative
however
could
not
provide
additional
information
on
when
this
test
was
performed.
The
EPA
contacted
Minntac
for
this
recent
test
data.
According
to
Minntac,
the
purpose
of
the
February
2002
tests
on
the
five
marble
bed
scrubbers
was
to
evaluate
the
performance
of
the
marble
bed
scrubbers
under
optimum
operating
conditions.
Hence,
these
tests
should
add
to
and
not
replace
the
existing
test
database
for
the
marble
bed
scrubbers.
In
addition,
Minntac
does
not
believe
the
new
emission
rates
will
significantly
affect
the
average
of
the
entire
baseline
emissions
for
the
non­
furnace
sources.
°
Northshore
indicated
that
it
had
also
recently
tested
for
formaldehyde
and
will
provide
EPA
with
the
data.
°
Tilden
indicated
that
it
had
tested
for
acid
gases,
formaldehyde
and
PM
in
May
of
1999,
and
PM
in
May
2002,
and
will
provide
EPA
with
the
data.
