1
Date:
August
25,
2003
Subject:
Telephone
Conference
Summary
­
EPA
and
representatives
from
the
taconite
industry
From:
Conrad
Chin,
EPA
To:
Docket
OAR­
2002­
0039
I.
Purpose
EPA
and
Taconite
Industry
representatives
held
a
conference
call
on
July
17,
2003
to
discuss
comments
to
the
proposed
MACT
Rule.
EPA
is
considering
various
options
in
response
to
comments
it
received
on
the
proposed
rule.

II.
Date
July
17,
2003
III.
Conference
Call
Participants
Conrad
Chin
EPA
Brad
Anderson
EVTAC
Mining
LaTisha
Gietzen
Kewatin
Taconite
(
formerly
National
Steel
Pellet
Company)
Martin
Hanninen
Cliffs
Mining
Services
Company
John
Meier
Cliffs
Mining
Services
Company
Rhonda
Ross
Warner
Norcross
&
Judd
LLP
Larry
Salmela
US
Steel­
Minntac
Dave
Skolasinski
Northshore
Mining
Company
Tamra
Van
Til
Madison
Consulting
LLC
IV.
Discussion
General
Taconite
industry
representatives
had
requested
the
conference
call
to
receive
an
update
from
EPA
on
its
approach
to
the
proposed
rule
comments.
Industry
representatives
also
wanted
to
ensure
EPA
had
all
of
the
information
it
needed
to
make
appropriate
decisions
regarding
revisions
to
the
proposed
rule.
EPA
advised
that
there
were
comments
from
a
number
of
groups
on
emissions
of
formaldehyde,
acid
gases
(
hydrochloric
acid
and
hydrofluoric
acid),
mercury,
and
fibers.
Following
are
summaries
of
the
major
discussion
items:

Acid
Gases
 
EPA
stated
that
stack
tests
were
available
from
six
pellet
plants.
OAR­
2002­
0039
2
 
Several
of
the
industry
representatives
noted
that
while
the
stack
tests
had
been
conducted,
acid
gasses
had
never
been
a
primary
focus
of
EPA,
the
state
environmental
agencies,
or
the
industry.
As
a
result,
little
was
known
about
the
operating
conditions
and
other
factors
that
may
have
influenced
the
results
of
the
tests.
John
Meier
was
concerned
that
when
the
stack
tests
were
conducted
at
the
Michigan
operations
there
was
a
high
probability
that
natural
gas
was
being
burned
in
the
pellet
furnaces.
At
the
present
time
coal
is
the
primary
fuel
in
the
furnaces.
John
agreed
to
look
into
the
fuel
issue
and
provide
further
information
to
the
EPA.

 
It
is
generally
assumed
that
the
wet
scrubbers
used
by
most
of
the
pellet
plants
were
responsible
for
reductions
of
acid
gases
emissions.
However,
the
two
Michigan
plants
have
dry
electrostatic
precipitators
(
ESPs)
on
their
stacks.
The
ability
of
the
dry
ESPs
to
reduce
acid
gas
emissions
was
questioned
by
the
industry.
If
a
wet
scrubber
had
to
be
added
to
the
ESPs,
the
industry
asserted
that
economic
impact
of
this
would
be
significant.

 
EPA
noted
that
an
alternative
to
establishing
a
MACT
Floor
for
acid
gases
at
this
time
would
be
to
correlate
acid
gas
emissions
to
particulate
matter
(
PM)
emissions
and
use
the
PM
emissions
as
a
surrogate
for
acid
gas
emissions.
EPA
indicated
this
would
be
investigated.

Formaldehyde
 
Formaldehyde
is
the
product
of
incomplete
combustion
of
natural
gas.

 
EPA
stated
that
it
intends
to
require
the
industry
to
utilize
"
Good
Combustion
Practices"
in
operating
its
pellet
furnaces
to
minimize
formaldehyde
emissions.
There
is
precedent
for
this
in
other
MACT
rules
such
as
the
Industrial
Boiler
MACT.
Good
Combustion
Practices
would
have
to
be
addressed
in
each
pellet
plant's
Operations
and
Maintenance
Plan.

Mercury
 
The
primary
source
of
mercury
in
pellet
plant
emissions
is
small
amount
of
mercury
present
in
the
ore
bodies.
Because
the
mercury
content
varies
among
the
ore
bodies,
the
amount
of
mercury
emitted
varies
from
one
pellet
plant
to
the
next.

 
The
mercury
emissions
among
the
plants
is
highly
variable
and
there
is
no
mercury
emission
control
equipment
available
to
use
on
the
pellet
plant
stacks.

Fibers
 
EPA
stated
that
it
is
updating
the
IRIS
risk
number
for
asbestos.

Concluding
Discussion
EPA
asked
that
if
any
of
the
mines
had
additional
data
that
would
be
of
help
in
addressing
these
four
hazardous
air
pollutants,
the
information
should
be
brought
forward
within
the
next
few
days
to
allow
EPA
to
consider
it
and
yet
meet
its
promulgation
schedule
for
the
rule.
