
To:
Integrated Iron and Steel (II&S) Response to Louisiana Environmental Action Network (LEAN) Decision Project File
From:
Phil Mulrine and Chuck French, OAQPS/EPA
Date:
January 17, 2023
Subject:
Minutes of the January 17, 2023 Conference Call with the American Iron and Steel Institute
NESHAP for Integrated Iron and Steel Manufacturing

I.	Introduction
A conference call between the U.S. Environmental Protection Agency (EPA) and the American Iron and Steel Institute (AISI) was held on January 17, 2023. The purpose of the meeting was to discuss potential work practice and opacity requirements for the national emission standards for hazardous air pollutants (NESHAP) for the integrated iron and steel (II&S) manufacturing industry. This memorandum summarizes the major topics discussed during the meeting. 

II.	Attendees and Affiliations
Paul Balserak, AISI
Rich Zavoda, Cleveland Cliffs
Rob Beranek, Cleveland Cliffs
Julianne Kurdila, Cleveland Cliffs
Michael Long, Cleveland Cliffs
Brett Tunno, U.S. Steel
Chris Hardin U.S. Steel
David Hacker, U.S. Steel
Alexander Epsy, U.S. Steel
Joseph Hanning, U.S. Steel
Coleen Davis, U.S. Steel
Krista Armentrout, U.S. Steel
Nicole Heinichen, U.S. Steel
Chuck Knauss, Hunton Andrews Kurth LLP
Shannon Broome, Hunton Andrews Kurth LLP
Erin Grisby, Hunton Andrews Kurth LLP
Mary Kaplan, AECOM
Phil Mulrine, EPA/OAQPS
Chuck French, EPA/OAQPS
Kevin McGinn, EPA/OAQPS
Katie Boaggio, EPA/OAQPS
Steve Fruh, EPA/OAQPS
Brian Dickens, EPA Region V
Haley Key, RTI International

III.	Discussion
Planned Bleeder Valve Openings
EPA indicated that a 5 or 10 percent opacity limit is being considered for planned bleeder valve openings, and that the limit is based on facility responses to the section 114 questionnaire as well as input from EPA staff. Hunton expressed concern that this opacity limit may not be achievable. Hunton suggested that a work practice standard would be better suited for this source than an opacity limit. An opacity limit could lead to safety concerns. If a work practice action plan would be required, flexibility would be needed to tailor the plan to each facility due to variation in technology and the size and type of blast furnace. Hunton recommended that EPA define the difference between planned and unplanned openings.

Unplanned Bleeder Valve Openings
EPA indicated that a limit of 1-2 unplanned openings and a requirements to install stockline monitors and conduct raw material screening are being considered for unplanned bleeder valve openings. Hunton suggested that EPA should set guidelines to reduce slips instead of limiting the number of unplanned openings. Hunton indicated that stockline monitors don't prevent slips or unplanned openings. EPA indicated that stockline monitors would inform operators of a hang, and the operator can then reduce wind and take measures to avoid large slips that would lead to unplanned openings. Hunton recommended that rule language clarify what EPA means by raw material screening, and that the rule language remain flexible since different facilities use different techniques to manage raw materials.

Slag Handling and Storage
EPA indicated that an opacity limit and a requirement to install fog systems are being considered for slag handling and storage sources. Hunton recommended that a work practice standard be required in place of an opacity limit. Hunton expressed safety concerns regarding the use of fog systems. EPA will conduct additional research on fog systems.
