
To:
Integrated Iron and Steel (II&S) Response to Louisiana Environmental Action Network (LEAN) Decision Project File
From:
Donna Lee Jones and Chuck French, OAQPS/EPA
Date:
December 14, 2021
Subject:
Minutes of the December 14, 2021 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 December 14, 2021. The purpose of the meeting was to discuss AISI's comments on the section 114 questionnaire and testing 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
Jason Aagenes, Cleveland Cliffs
Brett Tunno, U.S. Steel
Chris Hardin U.S. Steel
David Hacker, U.S. Steel
Chuck Knauss, Hunton Andrews Kurth LLP
Shannon Broome, Hunton Andrews Kurth LLP
Donna Lee Jones, EPA/OAQPS
Chuck French, EPA/OAQPS
Kevin McGinn, EPA/OAQPS
Ned Shappley, EPA/OAQPS
Matt Woody, EPA/OAQPS
Meredith Miller, EPA/OGC Air & Radiation Law Office
Andy Doyle, DOJ-ENRD
Haley Key, RTI International
Gabrielle Raymond, RTI International

III.	Discussion
EPA addressed some of AISI's previous comments on a draft of the section 114 collection request for II&S.
EPA had collected blast furnace emissions data in 2010. This information will be included in the section 114 mail outs and facilities will be asked whether it is still representative data. Method 29 testing for blast furnace HAP metal emissions will only be required if the data is no longer representative. Method 29 testing for sinter plant HAP metal emissions will be required for 3 units. Sinter plants will also be required to perform emissions testing for hydrogen fluoride (HF).
Fenceline monitoring will be required for lead and arsenic as part of the section 114 data collection. Up to 4 monitors will be required at or near the fenceline. Samples should be taken every 6 days for 6 to 12 months. Data will need to be submitted quarterly. Testing will not be required for unmeasured fugitive and intermittent particulate (UFIP) sources as that would be too costly and there are no established methods for testing these sources. The questionnaire will include questions regarding opacity data and work practices, estimated costs of work practices, and what equipment is needed for each work practice.
In response to AISI comments on the draft section 114 collection request, EPA revised some of the language for clarity. EPA also added specification that there will be 2010 data prepopulated in the Excel questionnaire file which facilities will be able to update if applicable. EPA extended the original deadlines. There will be 3 separate deadlines: the first for the questionnaire response, the second for sinter plant testing, and the third for fenceline monitoring. EPA aims to publish a proposed rule by the end of 2022.
AISI indicated that lead and arsenic emissions data collected in the past near the fenceline of some II&S facilities showed emissions low enough to not be of concern, and that data collected on ambient air validates that lead and arsenic emissions are low. AISI suggests that EPA use this previously collected data instead of requiring fenceline monitoring as part of the section 114 collection, and expressed concern that fenceline monitoring would be costly. EPA indicated that since there is uncertainty about emissions from UFIP sources, testing options such as fenceline monitoring would inform EPA about on-site fugitive emissions. EPA will follow up on the previous collected data AISI referenced.
EPA indicated that 4 facilities would be required to conduct fenceline monitoring, but the specific facilities have been selected yet. Hunton suggested that the facilities selected be representative of an average II&S facility. EPA indicated that a meterology component would be included in the fenceline monitoring.
EPA clarified that HF emissions testing was required to address LEAN gaps, since no HF data had been collected from sinter plants in the past. HAP metals emission testing would be to refine the assessment of potential impacts on environmental justice communities.
EPA indicated in response to AISI's previous comments that slag pit sources would still be addressed in the section 114 questionnaire since they are located on-site at II&S facilities. RTI clarified that past opacity data would be requested for some UFIP sources, and addition Method 9 testing would be required if no past opacity data exists for those sources.
