1
Date:
May
15,
2003
Subject:
Telephone
Conference
Meeting
­
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.

II.
Date
May
9,
2003
III.
Attendees
U.
S.
Environmental
Protection
Agency
Steve
Fruh,
OAQPS/
ESD/
MG
Conrad
Chin,
OAQPS/
ESD/
MG
Taconite
industry
representatives
Rhonda
Ross,
Warner
Norcross
&
Judd
Leonard
Parker,
Tilden
Mining
John
Meier,
Cleveland­
Cliffs
Gus
Josephson,
Ispat
Inland
Mining
Nancy
Smith,
Northshore
Mining
Brad
Anderson,
EVTAC
Bill
Kubiak,
U.
S.
Steel
LaTisha
Gietzen,
National
Steel
Raymond
Potts,
U.
S.
Steel
Larry
Salmela,
U.
S.
Steel
Alpha­
Gamma
Technologies
Chuck
Zukor
Chris
Sarsony
OAR­
2002­
0039
IV­
E­
5
2
IV.
Discussion
Fugitives
Dust
Emissions
Control
Plan
°
Some
industry
representatives
commented
that
the
fugitives
dust
plan
should
be
deleted
to
avoid
duplication
and
potential
conflicts
with
existing
Tile
V
permits.
The
EPA
explained
that
the
plants
can
use
their
existing
approved
fugitives
dust
emissions
control
plan
for
the
Title
V
permit
to
comply
with
the
NESHAP
requirements.

Stack
Testing
for
Indurating
Furnaces
°
Industry
commented
that
the
proposed
requirement
of
simultaneous
testing
of
multiple
stacks
from
an
indurating
furnace
is
costly,
unpractical,
and
possibly
infeasible.
EPA
will
consider
the
above
comments
when
reviewing
the
test
protocol
for
sampling
furnace
stacks
to
demonstrate
compliance
with
the
emission
limits
for
indurating
furnaces.

°
Industry
believes
that
testing
twice
per
permit
term
is
too
expensive
($
10,000
per
test/
stack).
Industry
recommended
testing
once
per
permit
term
as
is
currently
required
in
existing
Title
V
permits.
EPA
explained
that
it
is
typical
for
MACT
rules
to
require
testing
twice
within
the
five
year
permit
term.
In
addition,
the
taconite
MACT
has
a
more
stringent
emission
limit
than
the
existing
state
permits,
and
therefore,
it
may
be
necessary
to
have
more
stringent
testing
requirements
for
compliance
assurance.

Operating
Limits
for
Rod­
Deck
Scrubbers
°
Industry
clarified
their
issue
as
follows:
Their
rod­
deck
scrubbers
are
fixed­
throat
scrubbers
whose
volumetric
flow
rate
is
dependant
on
the
production
mass
flow
rate.
Therefore,
they
cannot
directly
control
the
pressure
drop
because
the
pressure
drop
fluctuates
with
changes
in
production
rates.
They
requested
that
the
rule
allow
a
range
of
pressure
drops,
one
for
maximum
production
and
another
for
reduced
production.
EPA
will
review
the
pressure
drop
and
water
flow
data
from
tests
provided
by
industry
and
consider
that
information
when
developing
the
final
requirements.

Baseline
Emissions
and
Emission
Reductions
°
Industry
indicated
that
EPA
should
incorporate
new
baseline
emissions
estimates
calculated
by
the
state
of
Minnesota
for
formaldehyde
and
acid
gases.
Industry
believes
current
baseline
emissions
of
formaldehyde
and
acid
gases
are
overestimated,
thus
EPA's
emissions
reduction
estimate
is
too
high.
Industry
also
indicated
that
the
emission
reductions
of
acid
gases
are
overestimated
because
EPA
assumed
that
wet
scrubbers
would
be
installed
to
meet
MACT
requirements
even
though
other
controls
could
be
used
to
meet
the
MACT
limits
without
reducing
emissions
of
acid
gases.
EPA
will
consider
various
control
strategies
to
demonstrate
compliance
with
the
final
rule
when
estimating
environmental
impacts
of
the
final
rule.
