MEMORANDUM
DATE: April 3, 2023
TO: Phil Mulrine, EPA/OAQPS/SPPD
FROM: Jeremy Kaelin, Ricky Strott, Haley Key, and Gabrielle Raymond, RTI International 
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SUBJECT: Point Source Data Summary for Integrated Iron and Steel Facilities under 40 CFR Part 63, Subpart FFFFF
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1.0	INTRODUCTION 
      This memorandum describes the data collected from Integrated Iron and Steel Manufacturing (II&S) facilities regarding emissions of hazardous air pollutants (HAP) and other related information from II&S facilities, pursuant to our authority under Section 114 of the Clean Air Act (CAA) (42 U.S.C. § 7414). These data were collected to inform the development of amendments of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for II&S facilities under 40 CFR part 63, subpart FFFFF to address unregulated pollutants emitted by this source category pursuant to the decision issued in Louisiana Environmental Action Network, et al., Petitioners v. EPA (2020), also known as the "LEAN Decision." These data supported the development of a Maximum Achievable Control Technology (MACT) floor, as required by CAA section 112, and the determination of beyond-the-floor (BTF) control options. 
      The purpose of this memorandum is to describe the point source emissions and related data obtained from II&S facilities as compiled into the II&S Emissions Database (Appendix A).
2.0	INTEGRATED IRON & STEEL FACILITIES
	Emissions testing and submissions of other recent test reports was required as part of a collection request sent to integrated iron and steel facilities under the authority of section 114 of the CAA (42 U.S.C. 7414). The section 114 requests were sent to two companies: Cleveland Cliffs and US Steel. Cleveland Cliffs had six facilities from which information was requested, and US Steel had three facilities from which information was requested. A summary of the companies, facilities, and locations included in the section 114 request is provided in Table 1.
            Table 1: II&S Facilities, Companies, and Locations
                                 Company Name
                                 Facility Name
                                 Abbreviation
                                     City
                                     State
Cleveland-Cliffs, Inc.
Cleveland-Cliffs Burns Harbor
CC-BurnsHarbor-IN
Burns Harbor
IN
Cleveland-Cliffs, Inc
Cleveland-Cliffs Cleveland Works
CC-Cleveland-OH
Cleveland
OH
Cleveland-Cliffs, Inc
Cleveland-Cliffs Dearborn Works
CC-Dearborn-MI
Dearborn
MI
Cleveland-Cliffs, Inc.
Cleveland-Cliffs Indiana Harbor East
CC-IndianaHarbor-IN-E
East Chicago
IN
Cleveland-Cliffs, Inc.
Cleveland-Cliffs Indiana Harbor West
CC-IndianaHarbor-IN-W
East Chicago
IN
Cleveland-Cliffs, Inc.
Cleveland Cliffs Middletown
CC-Middletown-OH
Middletown
OH
US Steel Corporation
US Steel Braddock
USS-Braddock-PA
Braddock
PA
US Steel Corporation
US Steel Gary
USS-Gary-IN
Gary
IN
US Steel Corporation
US Steel Granite City
USS-GraniteCity-IL
Granite City
IL

      Table 2 lists the quantity of stack tests that were conducted in response to the section 114 request ("new" stack tests) and stack tests that were conducted between 2015 and the date the section 114 request was received ("previous" stack tests) and submitted by each facility.
Table 2: II&S Facilities Quantity of Submitted New and Previous Stack Tests
                                   Facility
                                  Stack Tests

                                      New
                                   Previous
CC-BurnsHarbor-IN
                                       4
                                       -
CC-Cleveland-OH
                                       1
                                      18
CC-Dearborn-MI
                                       -
                                      11
CC-IndianaHarbor-IN
                                       -
                                       -
CC-Middletown-OH
                                       -
                                       -
USS-Braddock-PA
                                       -
                                       2
USS-Gary-IN
                                       1
                                       1
USS-GraniteCity-IL
                                       2
                                       -

	Detail on specific stack test reports requested from each facility is provided in section 3.0 of this memo.
3.0	STACK TEST DATA
	Stack tests were requested to compile data on various hazardous air pollutant (HAP) from integrated iron and steel sources. EPA requested data for some sources regardless of when the last testing was done and for other sources only if the data submitted for the 2011 section 114 collection request were no longer representative of current facility emissions. An amendment to the section 114 request was sent out to Cleveland Cliffs and US Steel at a later date requiring additional stack tests using Method 26A, Method 25A, and Other Test Method 46 for the Cleveland Cliffs Burns Harbor (IN) facility. New stacks tests for Method 26A and Other Test Method 46 were requested for the US Steel Granite City (IL) facility at that time. The US Steel Braddock (PA) facility submitted additional test reports that were not conducted as a requirement of the 2022 section 114 collection. The reports were previously conducted and voluntarily submitted by the facility. A summary of the stack tests, sources, facilities, and pollutants which were requested as part of the 2022 section 114 collection request is provided in Table 3. 
         Table 3: Summary of Stack Test Data Requested from Facilities
                                  Test Method
                                  Pollutants
                                    Sources
                                  Facilities
Method 26A
Hydrogen Fluoride;
Hydrochloric Acid
Sinter Plant Windboxes;
Basic Oxygen Process Furnace (BOPF) Primary Control Device;
Blast Furnace (BF) Stove;
BF Casthouse Baghouse
CC-BurnsHarbor-IN;
CC-IndianaHarbor-IN;
USS-Gary-IN;
USS-GraniteCity-IL;
USS-Braddock-PA[b]
Method 29
Antimony;
Arsenic; 
Beryllium;
Cadmium;
Chromium;
Cobalt;
Lead;
Manganese;
Mercury;
Nickel;
Selenium
BF Control Device[a];
BOPF Primary Control Device[a];
BOPF Secondary Control Device[a];
Sinter Plant Windboxes
CC-BurnsHarbor-IN;
CC-Cleveland-OH;
CC-Dearborn-MI;
CC-IndianaHarbor-IN;
CC-Middletown-OH;
USS-Braddock-PA;
USS-Gary-IN;
USS-GraniteCity-IL
Method 25A
Total Hydrocarbon
BF Stove;
BF Casthouse;
BOPF Primary Control Device
CC-BurnsHarbor-IN;
USS-Braddock-PA[b]
Other Test Method 46
Total Equivalency of Dioxin/Furan
BF Stove
BOPF Primary Control Device
CC-BurnsHarbor-IN;
USS-GraniteCity-IL
a  Only requested for which data submitted in 2011 are no longer representative of current emissions.
[b] Test report was not required by 114 collection and was voluntarily submitted by the facility.
	It should be noted that in response to the 2022 section 114 request for Method 29 testing for BF and BOPF control devices, CC-Cleveland-OH submitted new data for their BOPF primary control device, CC-Dearborn-MI submitted new data for their BF, BOPF primary, and BOPF secondary control devices, and USS-Gary-IN submitted data for their BF control device. This implies that the 2011 section 114 stack test data were still representative of current emissions from BF and BOPF control devices for a majority of the facilities. The 2011 section 114 stack test data is described in the memorandum Integrated Iron and Steel Risk and Technology Review: Point Source Data Summary. (EPA 2019). 
 3.1	PROCESS DATA SUBMITTED WITH II&S ICR TEST DATA 

From each II&S ICR test report submitted, from either II&S ICR tests or previous tests, the following testing information data and process parameters were compiled for each test run into the II&S Emissions Database:
       Testing Information
Test date, and if tested before or after MACT controls 
Exhaust gas flow rate, in actual cubic feet per minute (acfm) and dry standard cfm (dscfm)
Sample volume, in dry standard cubic feet (dscf) and dry standard cubic meters (dscm)
Stack moisture, in percent (%)
Stack gas temperature, in degrees Fahrenheit (˚F)
Sampling velocity, in feet per second (fps)
Isokinetic sampling percent (%)
Oxygen content of stack gas, in percent (%)
Carbon dioxide content of stack gas, in percent (%)
Reported pollutant concentration, in parts per million (ppm), milligrams per dry standard cubic meter (mg/dscm), or grains per dry standard cubic foot (gr/dscf), etc.
Reported pollutant emission rate, lb/hr
Data quality classifications, e.g., above detection limit (ADL), below detection limit (BDL), or detection level limited (DLL) 
Latitude and longitude of stack tested (decimal degrees, six decimal places)
       
       Process Parameters
Number of heats/process cycle(s) during each run
Production rate, e.g., steel, iron, or sinter, in tons per hour (tph)
         Total (raw) cast steel production from BOPF 
         Type of steel produced during testing, e.g., carbon steel, stainless steel, high alloy, as percent
         By-products from BF, type and quantity/rate, e.g., slag, BF gas, in scfm
Charge rates (tph)
         Inputs to the BF, e.g., fluxing agents, sinter, iron ore, coke, coal
         Hot metal charged to BOPF
         Scrap used in BOPF during tests, e.g. auto scrap, No. 2 heavy melting steel (ISRI codes 204-206), shredded scrap (ISRI Code 210), as a percent of total charge 
         Other inputs to BOPF, e.g., direct reduced iron, other ferrous materials, metallurgical coke, petroleum coke, coal, lime, alloys, tires, etc. 
         Sinter feed
4.0	REFERENCES
Jones, D.L. 2019. Integrated Iron and Steel Risk and Technology Review: Point Source Data Summary. Memorandum from Donna Lee Jones, EPA/OAQPS/SPPD, to Docket No. EPA-HQ-OAR-2002-0083-0955. May 1, 2019.


                                  APPENDIX A:
                  II&S EMISSIONS DATABASE (POINT SOURCES)

The point source test data from the II&S ICR test requests are provided in the accompanying Microsoft Excel[TM] file. This file includes the parameters and emission data compiled from each test report and the calculations conducted on the data. Also in this file are surrogate emissions data derived from II&S ICR source test data for units or HAP not tested in the II&S ICR test program.

