
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:
March 20, 2023
Subject:
Minutes of the March 20, 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 March 20, 2023. The purpose of the meeting was to present the anticipated work practice and emissions standards 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
Julianne Kurdila, Cleveland Cliffs
Brett Tunno, U.S. Steel
Chris Hardin U.S. Steel
David Hacker, U.S. Steel
Coleen Davis, U.S. Steel
Alexis Piscitelli, U.S. Steel
Chuck Knauss, Hunton Andrews Kurth LLP
Shannon Broome, Hunton Andrews Kurth LLP
Phil Mulrine, EPA/OAQPS
Chuck French, EPA/OAQPS
Kevin McGinn, EPA/OAQPS
Katie Boaggio, EPA/OAQPS
Steve Fruh, EPA/OAQPS
Haley Key, RTI International

III.	Discussion
For blast furnace casthouse fugitives, a 5 percent opacity limit based on 6-minute-averages is anticipated based on 2022 and 2011 opacity data. This limit was based on maximum averages for the best performing facilities. Opacity testing is anticipated to be required twice monthly during a cast. AISI expressed concern that this limit may not be achievable and that the limit was calculated based on limited data. EPA indicated that industry may send in additional data if the data used for a facility was not representative data.
For basic oxygen process furnace shop fugitives, a 5 percent opacity limit based on 6-minute averages is anticipated, as well as work practice standards. Opacity testing is anticipated to be required twice monthly during a furnace cycle. AISI expressed concerns that the anticipated work practice requirements may not be applicable to every facility.
For planned bleeder valves openings, an 8 percent opacity limit based on 6-minute averages is anticipated. This limit was calculated by averaging the opacity values for the top 5 performing facilities. AISI expressed concern that planned bleeder events vary in length and it may not be possible to get a reader for opacity testing. AISI also recommended opacity testing requirements for a representative sample instead of requiring opacity testing for every event.
For unplanned bleeder valves openings, several work practice requirements are anticipated, including installing stockline monitors at 3 different locations with an alarm, installing instruments to monitor the temperature and pressure, raw material screening, and submitting a slip avoidance plan. AISI noted that stockline monitors only show when a slip has already happened and are not helpful in reducing slips. AISI suggested that monitoring temperature and pressure should be adequate, and that slip avoidance plans could include stockline monitor data if a monitor is already installed in a furnace.
For beaching, full or partial enclosure or the use carbon dioxide to suppress fumes are anticipated requirements, as well as minimizing the height and slope of beaching.
For large bell leaks, visible emission tests are anticipated to be required, as well as opacity testing if visible emissions are positive. If opacity exceeds the 10 percent anticipated limit based on 3-minute averages, facilities are anticipated to be required to replace or repair the large bell seal within 4 months. For the small bell, facilities are anticipated to be required to repair or replace the seal every 8 weeks or at a frequency or throughput that has been proven to achieve zero opacity. AISI expressed concern that the throughput value that would denote a bell seal change would be too variable.
For slag handling and storage, the maximum achievable control technology (MACT) opacity limit would be 9 percent based on an average of the opacities of the top 5 performing facilities. The beyond-the-floor opacity limit would be 5 percent.
EPA presented the anticipated MACT emission limits for points sources. Emissions testing for point sources is anticipated to be required once every 5 years.
EPA is reconsidering the oil content limit for sinter plants and is now considering dioxin/furan and polycyclic aromatic hydrocarbon limits in place of an oil content limit. Emissions testing for these compounds would be required once every 5 years if limits are set in place.
