1
Date:
July
11,
2003
Subject:
Meeting
Minutes
on
Good
Combustion
Practices
with
Taconite
Industry
Representatives
From:
Chuck
Zukor,
Alpha­
Gamma
Technologies,
Inc
To:
Docket
OAR­
2002
 
0039
I.
Purpose
The
primary
purpose
of
the
telephone
conference
meeting
was
to
determine
if
the
taconite
industry
is
currently
using
good
combustion
practices
for
their
indurating
furnaces.

II.
Date
July
11,
2003
III.
Attendees
Northshore
Representatives
Gus
Josephson,
Ispat
Inland
Mining
Larry
Salmela,
U.
S.
Steel
Dave
Skolasinski,
Northshore
Mining
Dennis
Wagner,
Northshore
Mining
Alpha­
Gamma
Technologies
Chuck
Zukor
IV.
Discussion
°
Mr
Chuck
Zukor
of
Alpha­
Gamma
Technologies
arranged
this
telephone
conference
meeting
at
the
request
of
Mr.
Conrad
Chin
of
the
EPA
to
determine
whether
taconite
plants
were
implementing
good
combustion
practices
(
GCP)
on
their
indurating
furnaces
as
a
means
to
minimize
pollutants
of
incomplete
combustion
(
e.
g.,
formaldehyde)
emissions.
Also,
EPA
wanted
to
determine
whether
the
plants
are
required
to
implement
GCP
by
the
States
in
their
Title
V
or
other
operating
permits.
Mr
Zukor
provided
a
brief
explanation
of
GCP.
OAR­
2002­
0039
IV­
E­
10
2
°
Good
combustion
practices
typically
consist
of
work
practices
and
standard
operating
procedures
to
maintain
the
proper
operation
of
the
combustion
process,
routine
inspections
and
analyses
of
the
process
performance,
and
preventative
maintenance
activities.
Specific,
GCP
activities
may
include:
°
Maintenance
of
operator
logs;
°
Development
of
procedures
for
startup,
shutdown,
and
malfunction;
°
Performance
of
periodic
evaluations
or
inspections;
°
Performance
of
burner
or
control
adjustments/
tune­
ups;
°
Monitoring
and
maintenance
of
concentrations
of
carbon
monoxide
(
CO),
oxygen
(
O
2),
or
carbon
dioxide
(
CO
2)
in
compliance
with
site­
specific
concentration
limits
in
the
combustion
exhaust;
°
Monitoring
and
maintenance
of
combustion
temperatures
above
a
site­
specific
minimum
value;
°
Monitoring
of
fuel/
air
metering;
°
Compliance
with
a
CO
or
total
organic
carbon
(
TOC)
emission
limit;
°
Maintenance
of
proper
liquid
fuel
atomization;
°
Monitoring
of
fuel
quality
and
handling
procedures;
°
Maintenance
of
combustion
air
distribution;
and
°
Maintenance
of
fuel
dispersion.

°
The
industry
representatives
stated
that
they
are
not
required
to
implement
a
formal
GCP
program
as
part
of
their
State
operating
permits.
The
plants
stated
that
they
are
not
implementing
GCP
per
se,
however,
each
plant
has
certain
work
practices
or
standard
operating
procedures
in
place
to
maintain
the
proper
and
efficient
operation
of
each
furnace.
Since
the
operation
of
indurating
furnaces
is
highly
energy
intensive,
the
standard
operating
procedures
are
necessary
to
maintain
product
quality
and
fuel
efficiency.
The
plant
representatives
stated
that
many
of
their
work
practices
would
be
considered
GCP.

°
One
facility
stated
that
it
is
required
by
the
Minnesota
Pollution
Control
Agency
to
install
NO
X
emission
controls,
such
as
low
NO
X
burners,
on
its
indurating
furnaces.
The
basic
method
used
in
reducing
NO
X
emissions
is
a
reduction
in
combustion
temperature,
which
is
the
opposite
strategy
needed
for
minimizing
PIC
(
i.
e.,
increasing
combustion
temperature).
Thus,
the
operating
temperatures
for
a
furnace
with
NO
X
emission
controls
may
be
lower
than
another
furnace
without
NO
X
emission
controls.
Therefore,
industry
stated
that
EPA
should
not
control
formaldehyde
emissions
by
including
an
industry­
wide
minimum
operating
temperature
for
indurating
furnaces
in
the
taconite
NESHAP.

°
Due
to
differences
in
furnace
design,
operation,
firing
fuel,
process
controls,
and
air
pollution
control
equipment,
one
set
of
GCP
established
for
one
type
of
indurating
furnace
may
be
different
from
those
needed
for
another
type
of
indurating
furnace.
Therefore,
industry
stated
that
instead
of
prescribing
a
set
of
GCP
requirements
in
the
rule,
the
EPA
should
allow
the
GCP
to
be
established
on
a
site­
specific
basis.
