Subject:  Discussion of Testing, Monitoring, Recordkeeping and Reporting Requirements
To:  Minnesota and Michigan Taconite FIP Docket
From: Steven Rosenthal
	The following discussion explains the basis for the testing and monitoring, recordkeeping, and reporting requirements that are needed to ensure compliance with the proposed BART limits in the FIP.
   1.  Testing and Monitoring
      EPA is requiring the seven taconite facilities, Keetac, Hibbing, Minntac, United Taconite, ArcelorMittal, Northshore, and Tilden, to use CEMS, continuous diluent monitors (O2 or CO2), and continuous flow rate monitors on their indurating furnaces to measure NOx emissions.  EPA selected CEMS as the method for determining compliance instead of performance testing because of the variability in indurating furnace operations and emissions.  CEMS provide more dependable data for determining ongoing compliance for continuously varying operations because CEMS will eliminate the need to extrapolate emissions under varying operational conditions.  The taconite facilities will operate the CEMS, in accordance with 40 CFR 63.8, and Appendices B and F of Part 60, which provide the concentration of emissions -typically in parts per million.  The data collected from the continuous diluent and flow rate monitors is used in conjunction with an emission factor to convert NOx concentrations to units of the standard (lbs/MMBtu).  EPA is also requiring Northshore to conduct performance testing on its process boiler units in accordance with the requirements of 40 CFR 60.8, 40 CFR 60.11, and Appendix A of Part 60 to determine the NOx emissions.
      The seven taconite facilities also need to operate CEMS, continuous diluent monitors (O2 or CO2), and continuous flow rate monitors to measure SO2 from their indurating furnaces.  Data from the monitors are used to calculate the SO2 emissions in ppmv and pounds per hour, the units of the standard.  Performance testing for demonstrating compliance with the SO2 removal efficiency standard requires measuring the SO2 concentrations at the inlet to the control device and after emissions exit the control device.
      The seven taconite facilities are required to conduct initial performance testing for NOx and SO2, in accordance with the requirements of 40 CFR 63.7 and Appendix A of Part 60 to determine initial compliance with applicable emission limits.  The general reference methods to be used for initial testing include Methods 1-4, 6-6C, and 7-7E.
      Keetac is also required to continuously monitor the hydrogen ion concentration (pH) in its scrubber.  Keetac will operate the pH monitor in accordance with the requirements of 40 CFR 163.3, using EPA method 150.2.  A pH level at or above the standard, 7.5, indicates that the control device will remove sufficient SO2 from the exhaust.  Performance of the control will decline if the water is more acidic.
   2. Recordkeeping Requirements
      EPA is proposing standard recordkeeping requirements for the taconite facilities.  Facilities are required to keep a number of records such as performance test results, maintenance records, malfunction records, and copies of submitted reports for at least five years.  Details of the recordkeeping requirements can be found below in the proposed 40 CFR part 52 language. 
   3. Reporting Requirements
      EPA provides the facilities with details on what it must report in the proposed rule language.  The deadlines for the reporting are also provided.  The reporting requirements specify that a source must provide at least 60 days notification of an initial performance test and then submit the results within 60 days following completion of initial performance testing.  Sources are to report non-continuous performance test results within 90 days of completing the test.  The content of semiannual compliance reports is listed.  Sources are to submit the semiannual reports no later than January 31 and July 31 each year for the preceding July to December or January to June time period.  A source is required to submit its site-specific performance evaluation test plan at least 60 days prior to conducting a CEMS performance test. 

