Taconite Risk and Technology Review (RTR) - Meeting Agenda
Date: Tuesday, 10/11/2016
Time: 10:00 AM EST
Call-in number:	(919) 541-1590
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Participants:
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EPA:	David Putney, OAQPS/SPPD/MICG
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Contractor:	Mark Bahner, RTI
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Industry:
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      Name	Company/Facility(ies)	Contact Info.
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      Kelsey Johnson	Iron Mining Association	info@taconite.org
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      Candice Maxwell	Cliffs Natural Resources	Candice.Maxwell@CliffsNR.com
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      Tasha Niemi	Cliffs Natural Resources	Tasha.Nieme@CliffsNR.com
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      Michael Long	Cliffs Natural Resources	Michael.Long@CliffsNR.com
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      Jennifer Ramsdell	Cliffs Natural Resources	Jennifer.Ramsdell@CliffsNR.com
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      Brent Ketzenberger	Cliffs Natural Resources	Brent.Ketzenberger@CliffsNR.com
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      Julie Lucas	Cliffs Natural Resources	Julie.Lucas@CliffsNR.com
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      Jason Aagenes	Cliffs Natural Resources	Jason.Aagenes@CliffsNR.com
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      Chrissy Bartovich	US Steel	clbartovich@USS.com
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      Julianne Kurdila	ArcelorMittal	julianne.kurdila@Arcelormittal.com
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      Jaime Johnson	ArcelorMittal	Jaime.Johnson@Arcelormittal.com
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      Rich Zavoda	ArcelorMittal	Rich.Zavoda@arcelormittal.com
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      David Vidmar	Magnetation	david.vidmar@magnetation.com
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      Kevin Petz	Steel Dynamics	kevin.petz@steeldynamics.com
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General:
 Industry universe - Are there any taconite iron ore processing facilities that are not members of the MN Iron Mining Association (e.g., Michigan facilities or perhaps the facilities owned by Magnetation, Inc., since it is a newer company?)
 Contact info - Preferred contact information (names, phone numbers, email address, etc.) for the taconite iron ore processing facilities in general and Northshore, Minntac, and Magnetation Plant in particular.
 Site visits - EPA would like to visit some of the facilities as to familiarize itself with the operations of the taconite iron ore processing facilities. Specifically, EPA would like to visit the Northshore facility (this facility is of particular interest due to the presence of amphibole fibers), the Minntac facility (this facility is of particular interest as it is the largest operation and, presumably, would have more operations to view), and the Magnetation Plant 1 facility (this facility is of particular interest due to the use of a new technology to concentrate iron ore).
 Risk Review:
 General info  -  In order to better inform the residual risk modeling input file, we will be collecting general information regarding emissions of HAP, emission point locations, and stack parameters.
 Fuel types - According to the background information documents associated with the initial taconite iron ore processing NESHAP, the indurating furnaces at these facilities can burn natural gas, coal, oil, and a variety of other fuels. In order to develop the upcoming testing requirements (see "Testing" below) we will need to know what fuel(s) each facility's indurating furnace(s) burn(s). That is, which fuels is it capable of burning and which fuels does it typically (i.e., over the last couple of years of operation) burn?
 Temporal variations - EPA would like to discuss the temporal variation in emissions at these facilities. During the risk assessment for these facilities we will need to estimate how much higher peak emissions are than normal emissions. The default multiplier we use is 10  -  that is, we estimate that peak emissions are 10 times higher than normal emissions. However, for some industries (e.g., those with processes that do not vary much over time but rather operate at a much more steady state) that multiplier is a lower number. This may well be the case for taconite iron ore processing facilities.
 HAP concentrations - We would also like to discuss the variations (or relative lack thereof, as the case may be) in concentrations of metal hazardous air pollutants (e.g., arsenic, manganese, nickel, etc.) in the taconite iron processed by your member companies. That is, do they have reason to believe that concentrations of these impurities in the ore vary significantly over time, or that they vary very little? This is of particular interest in the case of mercury.
 Startup, Shutdown, and Malfunction (SSM) - In response to recent court decisions, we may be required to remove any exemptions to compliance with the emissions standards included in 40 CFR part 63, subpart RRRRR (subpart 5R) during periods of SSM. This is often an item of interest on the part of industry and we are soliciting any input the facilities might have on this issue. For example, do they have reason to believe (e.g., any parametric monitoring or emission data obtained during periods of SSM) that they could (or could not, as the case may be) comply with the emission standards already in subpart 5R during periods of SSM?
         
         
 Technology Review:
 New developments and/or improvements  -  EPA will be soliciting information on any new developments and/or improvements in practices, processes and control technologies to reduce emissions of hazardous air pollutants (HAP) considering cost and feasibility that have been put into practice at the taconite iron ore processing facilities since promulgation of subpart 5R.
 Hg emissions reduction - Through discussions with staff in the Minnesota Pollution Control Agency EPA has learned that taconite iron ore processing facilities located in Minnesota are required to reduce their mercury (Hg) emissions by 75% by 2020. This could impact the technology review portion of the RTR project. EPA would like to get information from companies as to the methods they are proposing to use to achieve the required reductions in Hg emissions and any data (e.g., emissions testing) obtained to date that would suggest that the proposed methods will achieve those reductions.
 Testing:
 Operational status - Based on Internet information about the taconite iron ore processing source category we noticed that, as with many metals industries, some facilities may well be currently idled due to unfavorable economic conditions. Information on this (i.e., which facilities are currently operating and which ones are not) would be very helpful as we develop a testing plan for the industry. This testing plan will be sent out (probably later this year) in an information request under the authority of section 114 of the Clean Air Act (CAA) and is also often an item of intense interest on the part of industry. We will be soliciting input from companies during the development of this information request. Our current understanding about the operational status is as presented in the table below. Please inform us of any errors in the table and any expected near-term changes in the operational status of these facilities.
Parent Company
Facility
Subpart RRRRR?
Operating Status
US Steel  -  Minnesota Ore Operations
Keetac
1 Mine Road
Keewatin, MN 55753
Yes
Idle
US Steel
Minntac
8819 Old Hwy 169
Moutain Iron, MN 55768
Yes
Operational
Cliffs
United Taconite - Fairlane Plant
8479 Townline Road
Forbes, MN 55738
Yes
Idle
Cliffs
Northshore - Silver Bay Plant
10 Outer Drive
Silver Bay, MN 55614
Yes
Idle
Cliffs (USS 14%)
Hibbing Minnesota Taconite Plant
4950 County Hwy 5 North
Hibbing, MN 55746
Yes
Operational
Cliffs Erie/Steel Dynamics
Mesabi Nugget
Hoyt Lakes Mining Area
Hoyt Lakes, MN
Yes
Idle
ArcelorMittal
Minorca Mine
5950 Old Hwy 53 North
Virginia, MN 55792
Yes
Operational
Essar Steel
Essar Steel Minnesota
17113 County Road 58
Nashwauk, MN 55769
Yes
Construction not occurring
Cliffs (USS 15%)
Tilden Mining Company
1 Tilden Mine Road
Ishpeming, MI 49849
Yes
Operational
Cliffs
Empire Mine
101 Empire Mine Road
Palmer, MI 49871
Yes
Shut down August 2016
Magnetation
Magnetation - Plant 1
35001 County Road 571
Keewatin, MN 55753
No
Idle
Magnetation
Magnetation - Plant 2
27692 County Road 10
Bovey, MN 55709
No
Idle
Magnetation/Steel Dynamics/Mining Resources LLC
Magnetation - Plant 3
11050 US Hwy 169
Chisholm, MN 55719
No
Idle
Magnetation - Mag Mining
Magnetation - Plant 4
28754 County Road 61
Grand Rapids, MN 55744
No
Idle
Magnetation
Magnetation Pellet Plant
64 East 100 North
Reynolds, IN 47980Reynolds
No
Operational
 Emission sources - According to the preamble for the initial 40 CFR part 63, subpart RRRRR, most of the hazardous air pollutant emissions from these taconite iron ore processing facilities are emitted from the indurating furnaces. Therefore, any new testing required via the upcoming information request will likely focus on the indurating furnaces. To that end, it would be very helpful to collect information on the amount of organic material is included in the feed materials to those furnaces - or evidence to show that organic material is not included in the feed materials, as the case may be.
 Test submission years - Through the section 114 information request mentioned above, we will be requesting copies of recent tests conducted on subject emission sources from member companies. Typically, "recent" is defined as within the last 3 years. However, member companies may have strong compelling interest in increasing this window to 4 or 5 years. If this is the case, we would like to discuss that possibility.
 Test result units - The test results are all required to be reported in lb/ton of taconite pellets produced. That's different from the existing standard, which is concentration-based. This may cause problems if there are confidentiality claims regarding production rate. Therefore we wanted to discuss that with the industry before sending the section 114 testing plan to industry.
 New testing - In response to recent court decisions, we may be required to gather emissions data for HAP not currently regulated under subpart 5R (e.g., for dioxins/furans, mercury and asbestos) via the section 114 testing plan.
 Asbestos fibers - Also through the section 114 information request mentioned above, we will be seeking information on emissions data and/or fence line concentrations of amphibole fibers such as those emitted from the Northshore facility. Do any other member companies have reason to believe that the taconite ore they process (and therefore their emissions) include amphibole fibers? Or evidence to suggest that they do not?
