Technical Support Document, Permit Action Number: 13700005

‐ 006

Page 1 of 10

Date: 6/5/2013 TECHNICAL SUPPORT DOCUMENT

For

DRAFT/PROPOSED AIR EMISSION PERMIT NO. 13700005

‐ 006

This technical support document (TSD) is intended for all parties interested in the draft/proposed permit

and to meet the requirements that have been set forth by the federal and state regulations (40 CFR §

70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and

factual justification for each applicable requirement or policy decision considered in the preliminary

determination to issue the draft/proposed permit.

1. General Information

1.1 Applicant and Stationary Source Location:

Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address

(SIC Code: 1011 )



### U.S. Steel Corp. Minnesota Ore Operations

P.O. Box 417

Mountain Iron, MN 55768 Minntac

8819 Old Highway 169

Mountain Iron

St. Louis County

Contact: Chrissy Bartovich

Director Environmental Control

Phone: 218

‐ 749

‐ 7364

1.2 Facility Description

The Permittee owns and operates a taconite mine and processing facility, known as Minntac, at County
Highway 102, on the Mesabi Range north of the City of Mountain Iron, St. Louis County, Minnesota.

Taconite is a rock bearing from 15 to 30 percent magnetic iron particles (magnetite). The iron ore is

mined in an open pit, and reduced in size by a series of crushers until it has a powdery consistency. Iron

oxide concentrate is separated magnetically, while the remaining portion of the mined ore (tailings) is

sent to a tailings disposal basin. Limestone and/or dolomite (fluxstone) and bentonite (binder) are

added to the concentrate and the mixture is formed into round “green balls (pellets)” in a balling drum.

The green balls are heat hardened in an indurating process (agglomerator or grate

‐ kiln) line, which

consists of a traveling grate, a rotary kiln, and a horizontal rotary hearth (commonly called annular
cooler). Finished taconite pellets are stored for transport to blast iron furnaces. While the main product

of the Minntac facility is fluxed pellets which are used in blast furnaces to make molten iron, other
products such as iron ore concentrate, blast furnace trim, and railroad ballast are made for special

customers.Technical Support Document, Permit Action Number: 13700005

‐ 006

Page 2 of 10

Date: 6/5/2013 The Minntac facility was built in three successive stages or steps. The first taconite pellets were produced by the Step I facility in 1967. When Step II (1972) and Step III (1978) were added, the facility’s
pellet

‐ making capacity was tripled.

1.3 Description of the Activities Allowed by this Permit Action

This Major Amendment permit action authorizes the replacement of the existing main kiln burners with

Low NOx Main Burners on the facility’s induration lines 4 and 5 (adding CE 181 and CE 182, which vent through SV118 and SV 127; respectively).This project will reduce NOx emissions from baseline emission

rates. Remaining pollutants will remain at previously calculated rates. This amendment is processed as a Major Amendment due to the requirements located at the Total Facility Level indicating such.

This permit action also removes language from the Total Facility level identified as “F. Retroactive PSD
Permitting Requirements

– Tasks, Reports and CEMS related to language requesting a Computational

Fluid Dynamics (CFD) modeling report and installation of LowNox Burners at the traveling grate preheat

zones of the Agglomerator Lines 3 ‐ 7. Minntac completed conditions related to CFD modeling as well as
installed the traveling grate preheat Low NOx burners in 2009.

Requiring installation of control equipment to reduce NOx emissions was a component of the previous

Permit Action for this Facility (Permit Action 13700005

‐ 005, issued 12/22/2008). Further discussion of

this and the previous permit action can be found in Section 3 of this TSD.

1.4. Facility Emissions:

Table 2. PSD Applicability Emissions Summary

Pollutant Projected

Actual

Emissions*

(tpy) Baseline

Actual

Emissions**

(tpy) Emissions

Increase

Prior to

Excludable

(tpy) Excludable

Emissions ***

(tpy) Emissions

Increase

(tpy) NSR

Significant

Thresholds for

major sources
(tpy) NSR

Review

Required ?

(Yes/No)

PM 274.9 461.7 0 0 0 25 No

PM 10 328.5 668.0 0 0 0 15 No

PM 2.5 328.5 668.0 0 0 0 10 No

NO

x 2511.6 5010.5 0 0 0 40 No

SO 2 896.4 957.9 0 39.1 0 40 No

CO 448.4 402.6 45.9 42.7 3.2 100 No

Ozone

(VOC) 58.1 52.2 6.0 5.3 0.7 40 No

Lead 0.4 0.4 0 0 0 0.6 No

Fluorides 12.6 11.6 0.9 1.1 0 3 No

CO 2 e**** 747,121 674,354 72,767 58,657 15,049 75,000 No

*Projected Actual Emissions as defined in 40 CFR § 52.21(b)(41).Technical Support Document, Permit Action Number: 13700005

‐ 006

Page 3 of 10

Date: 6/5/2013 **Baseline Actual Emissions as defined in 40 CFR § 52.21(b)(48).

***Emissions that can be excluded as detailed in 40 CFR § 52.21(b)(41(ii)(c).

****Carbon dioxide equivalents as defined in Minn. R. 7007.0100.

Table 5. Facility Classification

Classification Major/Affected

Source Synthetic Minor/Area Minor/Area

PSD X

Part 70 Permit Program X

Part 63 NESHAP X

2. Regulatory and/or Statutory Basis

New Source Review

The facility is an existing major source under New Source Review regulations.

Part 70 Permit Program

The facility is a major source under the Part 70 permit program.

New Source Performance Standards (NSPS)

Portions of the facility are subject to 40 CFR pt. 60, subpart Y, “Standards of Performance for Coal

Preparation Plants,” and 40 CFR pt. 60, subpart LL “Standards of Performance for Metallic Mineral

Processing Plants,” are relevant to the Minntac facility, but not to the indurating process modification.

National Emission Standards for Hazardous Air Pollutants (NESHAP)

The facility is a major source of HAPs. The facility is subject to the following NESHAPs:

 Taconite and Iron Ore Processing (40 CFR Part 63 subpart RRRRR)

 Reciprocating Internal Combustion Engines (40 CFR Part 63 subpart ZZZZ)

Compliance Assurance Monitoring (CAM)

CAM does not apply to the modification allowed in this permit amendment, since the units added are

control equipment and do not meet the three

‐ part test for CAM applicability.

Environmental Review & AERA

No changes in this permitting action trigger Environmental Review or AERA requirements.

Environmental Justice

Environmental Justice (EJ) is the fair treatment and meaningful involvement of all people regardless of

race, color, national origin, or income with respect to the development, implementation, and the

enforcement of environmental laws, regulations, and policies. EPA has this goal for all communities and

persons across the U.S.A. It will be achieved when everyone enjoys the same degree of protection fromTechnical Support Document, Permit Action Number: 13700005

‐ 006

Page 4 of 10

Date: 6/5/2013 environmental and health hazards and equal access to the decision

‐ making process to have a healthy

environment in which to live, learn, and work.

As part of this permitting process, the MPCA contacts US E.P.A. Region 5 staff to verify if there are any
possible EJ issues for the facility location that need to be addressed in the permit action. For this project,

MCPA staff contacted EPA Region 5 staff who used the draft Environmental Justice Strategic

Enforcement Assessment Tool (EJSEAT) that identified the facility location did not potentially have EJ

concerns.

Minnesota State Rules

Portions of the facility are subject to the following Minnesota Standards of Performance. This permit

action does not change the list below.

The Minntac facility is subject to the following state standards for stationary sources:

• Minn. R. 7011.0150: Preventing avoidable amounts of fugitive particulate matter emissions from
becoming airborne.

• Minn. R. 7011.0510: Standards of performance for existing indirect heating equipment.

• Minn. R. 7011.0515: Standards of performance for new indirect heating equipment. (It means that

construction, modification, or reconstruction of the indirect heating equipment commenced after

January 31, 1977.)

• Minn. R. 7011.0610: Standards of performance for fossil

‐ fuel

‐ burning direct heating equipment.

• Minn. R. 7011.0710: Standards of performance for pre

‐ 1969 industrial process equipment.

• Minn. R. 7011.0715: Standards of performance for post

‐ 1969 industrial process equipment.

• Minn. R. 7011.1150: Standards of coal preparation plants.

• Minn. R. 7011.2300: Standards of performance for stationary internal combustion engines.

• Minn. R. 7011.2700: Standards of performance for new metallic mineral processing plants (which

incorporates the federal NSPS by reference).

Table 6. Regulatory Overview of Units Affected by the Modification/Permit Amendment

The table reflects regulatory overview of those conditions related to the Low NOx burners (CE 181 and

182) as well as those conditions related to visibility mitigation strategies implemented in Permit Action ‐

005.

Level * Applicable
Regulations Comments:

Facility 40 CFR pt. 50; Minn.

Stat. Section 116.07,

subds. 4a & 9; Minn. Ambient Air Quality Standards. Language added to require Minntac

to make any necessary changes to their permit to ensure
compliance with the 1

‐ hour SO2 and 1

‐ hour NO2 NAAQS.Technical Support Document, Permit Action Number: 13700005

‐ 006

Page 5 of 10

Date: 6/5/2013 R. 7007.0100, subp.

7(A), 7(L), & 7(M);

Minn. R. 7007.0800,

subps. 1, 2 & 4;

Minn. R. 7009.0010

‐

7009.0080

3. Technical Information

3.1 Calculations of Potential to Emit and Emissions Increase Analysis

Attachment 1 to this TSD contains PSD summary spreadsheets prepared by the Permittee and the

MPCA.

3.1.1 Baseline Actual Emissions:

The Permittee used a baseline period from January 2006

– December 2007 for SO2, a baseline

period of January 2007

– December 2008 to determine baseline emissions for PM, PM10,

PM2.5, NOx, and Lead and a baseline emission period of January 2010

– December 2011 for CO,

VOC, and F. Emissions were determined by CEMS for NOx and by fuel usage and emission

factors for SO2, CO, PM, PM10, PM2.5, VOC, Fluorides, Lead, and greenhouse gases.

Projected Actual Emissions : Future actual emissions were calculated using supporting CEMS

information for NOx and by fuel usage and emission factors for SO2, CO, PM, PM10, PM2.5,

VOC, Fluorides, Lead, and greenhouse gases.

Emissions of PM10 and PM2.5 have decreased from baseline rates due to implementation of the

Taconite MACT (Taconite and Iron Ore Processing, 40 CFR Part 63 subpart RRRRR). This NESHAP

regulates PM as a surrogate for HAPs and does not directly regulate PM10 and PM2.5. As such,

permit conditions have been added to explicitly require use of control equipment for emission

units affected by this permit action because these emission characteristics were relied upon for

the calculations of this permit action. While the multi

‐ cyclones (CE 102 and CE 112) are listed in

the facility description as control equipment, the purpose of this equipment is to remove the

very large particles out of the process equipment in order to prevent damage to the preheat

fans. These units are not relied upon for control of PM10 or PM2.5.

3.1.2 Excludable Emissions: The excludable emissions calculations made under 40 CFR

52.21(b)(41(ii)(c)must account for post

‐ change emissions:

i. That the unit was capable of emitting prior to the proposed change, and

ii. That is unrelated to the proposed change (including increased utilization due to demand

growth).

The excludable emission calculations made by the Permittee addresses both points.Technical Support Document, Permit Action Number: 13700005

‐ 006

Page 6 of 10

Date: 6/5/2013 Note that the BAE 24

‐ month period must be the same for a specific pollutant for all emission

units (if there are multiple emissions units in the applicability analysis that emit that pollutant).

However the BAE 24

‐ month period may differ for each PSD pollutant.

3.2 Visibility Mitigation Strategies Implemented in Permit Action ‐ 005

During Permit Action ‐ 005, the MCPA chose to set forth NOx emission limits pursuant to the

requirements for addressing impact to federal Class I areas in PSD regulations, 40 CFR 52.21 (p). This

resulted in an aggressive schedule of activities intended to achieve significant reductions in NOx

emission. The goal is to reduce the long

‐ term NOx emission limit by at least 70% from the initial limit at

Permit Issuance (13,300 ton/yr, in Permit: 13700005

‐ 005). Because it was not known at that time

whether any of the available identified add

‐ on technologies would be acceptable under the criteria set

forth in the previous permit action, the permit did not establish a final NOx emission limit.

To date, Minntac has fulfilled several of those activities, including: a CFD study of indurating NOx

formation and grate pre

‐ heat Low NOx burners, as well as pilot testing a NOx control technology. Pilot

testing has occurred with Low NOx burners installed on Line 7 in May 2010 and Line 6 in April 2011.

These lines have certified CEMS installed and with the emissions data provided by the CEMS, the low

NOx main burners were able to be evaluated and optimized. Installation of Low NOx burners on Line 4

and Line 5 (EU 261 and EU 282, respectively) continues this plan for reduction of NOx emissions as laid

out in Permit Action ‐ 005.

Permit conditions related to the visibility strategy remain within the permit with the exception of those

conditions which have been satisfied.

The Permittee will install Low NOx burners on Lines 4 and 5 which will be considered the ‘full

‐ scale’

demonstration of the control technology as discussed in Permit Action ‐ 005. As the permit conditions

indicate, Minntac will submit an engineering analysis to summarize a number of operating parameters

and their outcomes. If determined to be successful, Minntac will submit a major amendment to propose

to install Low NOx burner on Line 3 (the final furnace located at the facility to not have Low NOx burner

control technology). The remaining steps for this visibility mitigation strategy are located at the Total

Facility Level of this permit action.

3.3 New and Revised 1

‐ hour NAAQS

In 2010, the U. S .Environmental Protection Agency (EPA) promulgated the new National Ambient Air

Quality Standards (NAAQS) for sulfur dioxide (SO 2 ) and nitrogen dioxide (NO 2 ) averaged over one hour.

The attainment dates (the date by which the state must be able to demonstrate compliance with the

applicable standard) are five years after EPA publishes Minnesota’s attainment designation in the

Federal Register.Technical Support Document, Permit Action Number: 13700005

‐ 006

Page 7 of 10

Date: 6/5/2013 3.3.1 1

‐ hour NAAQS for Sulfur Dioxide

In June 2010, the new one

‐ hour NAAQS for SO 2 was set at 75 ppb. Minnesota has no monitored

violations of the standard. When EPA promulgates a new standard an infrastructure SIP is due within

three years; for SO 2 , this is June 2013. EPA initially indicated that all states, even those without

monitored violations, would need to demonstrate in the infrastructure SIP that sufficient emission limits

would be in place to model compliance with the SO 2 standard. These emission limits were to be in place
by the attainment date

– five years after promulgation of designations under the new standard. (See 75

FR 35573).

As indicated in a letter to the MPCA dated April 12, 2012, EPA acknowledged that it has not issued
implementation guidance for this standard. EPA indicated that stakeholders, including states, have
responded to EPA’s implementation proposal by identifying a number of concerns. EPA also indicated

that it no longer expects Minnesota’s infrastructure SIP submittal for the one

‐ hour SO 2 NAAQS to

include modeling demonstrations showing attainment of the standard in unclassifiable areas.

Previously, the MPCA completed the following steps in the SO 2 SIP process:

• In the spring of 2011, the MPCA identified key sources. MPCA staff requested modeling

parameters from 65 sources that met a certain emissions threshold or otherwise were

considered to potentially cause or contribute to a violation of the SO 2 standard.

• During the summer of 2011, key sources submitted SO 2 modeling parameters. All facilities

submitted modeling parameters by the end of July 2011.

• In fall 2011, the MPCA completed the initial round of baseline modeling of 75 sources and

identified sources that modeled an exceedance of the standard. The MPCA developed model

input files based on the modeling parameters received from the facilities or information

available in house.

After receiving the April 12, 2012 letter from EPA, the MPCA suspended these efforts.

Minntac was modeled during the MPCA’s baseline modeling. This modeling showed that Minntac’s

emissions led to a predicted maximum ambient concentration that may exceed the one

‐ hour SO 2 NAAQS. Minntac was also modeled for Polymet Mining, Inc.’s Northmet Project, a proposed neighboring
facility. Polymet’s modeling also predicted that Minntac’s emissions may contribute to a modeled

exceedance of the 1

‐ hour SO 2 NAAQS.

Since Minntac is not increasing its hourly SO 2 emissions in this permitting action, the MPCA is not
requiring Minntac to conduct its own SO 2 modeling demonstration prior to permit issuance. The draft

permit requires Minntac to submit a permit application, as applicable, to incorporate limits and other

conditions into an enforceable document, if such limits and/or conditions are necessary to achieve
compliance with the 1

‐ hour NAAQS for SO 2 by: the 1

‐ hour SO2 NAAQS attainment date established by

EPA; the Regional Haze State Implementation Plan Revision date which is currently, 2018; or as required
by any other applicable federal law, whichever is earliest.

Minntac is one of a number of facilities which are currently involved in an overall modeling effort to

address their ambient impacts for Minnesota’s Regional Haze State Implementation Plan (“Regional

Haze SIP”). Each of those facilities must submit dispersion modeling to the MPCA. The initial modeling is

limited to the facility itself (plus an ambient background); this modeling must demonstrate complianceTechnical Support Document, Permit Action Number: 13700005

‐ 006

Page 8 of 10

Date: 6/5/2013 with the SO 2 NAAQS. The MPCA will combine the inputs from those submittals with those from other

SO 2 ‐ emitting facilities in the area, including the emissions from Minntac. If modeled exceedances

remain, the MPCA will work with the facilities in the area to reduce emissions so that the one

‐ hour SO 2 NAAQS is protected.

3.3.2 1

‐ hour NAAQS for Nitrogen Dioxide

On February 9, 2010, EPA established the new one

‐ hour NAAQS for NO 2 at an ambient concentration of

100 ppb. Monitoring data indicates that Minnesota meets the one

‐ hour standard. EPA has indicated that
they intend to designate Minnesota counties as attainment or as unclassifiable with the one

‐ hour NO 2 standard.

Minntac was also modeled for Polymet Mining, Inc.’s Northmet Project, a proposed neighboring facility.
Polymet’s modeling also predicted that Minntac’s emissions may contribute to a modeled exceedance of

the 1

‐ hour NO 2 NAAQS.

Since Minntac is not increasing its hourly NO 2 emissions in this permitting action, the MPCA is not
requiring Minntac to conduct its own NO 2 modeling demonstration prior to permit issuance. The draft

permit required Minntac to submit a permit application, as applicable to incorporate limits and other

conditions into an enforceable document, if such limits and/or conditions are necessary to achieve
compliance with the 1

‐ hour NAAQS forNO 2 by: the 1

‐ hour NO2 NAAQS attainment date established by

EPA; the Regional Haze State Implementation Plan Revision date, which is currently 2018; or as required
by any other applicable federal law, whichever is earliest.

3.4 Periodic Monitoring

In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have

sufficient knowledge of the facility to certify that the facility is in compliance with all applicable

requirements.

In evaluating the monitoring included in the permit, the MPCA considered the following:

 The likelihood of the facility violating the applicable requirements;

 Whether add

‐ on controls are necessary to meet the emission limits;

 The variability of emissions over time;

 The type of monitoring, process, maintenance, or control equipment data already available for

the emission unit;

 The technical and economic feasibility of possible periodic monitoring methods; and

 The kind of monitoring found on similar units elsewhere.

The table below documents the periodic monitoring requirements for control of particulate matter for

the wet scrubbers (CE 103 and CE 113).Technical Support Document, Permit Action Number: 13700005

‐ 006

Page 9 of 10

Date: 6/5/2013 Table 7. Periodic Monitoring

Level* Requirement

(rule basis) Additional

Monitoring Discussion

GP 010

CE 103

CE 113 Total Particulate

Matter: < 0.3

gr/dscf Recordkeeping:

Daily records of Gas

Stream Pressure

Drop, O & M Plan Records are generated on a daily basis of gas

stream pressure drop for compliance with PM

limits. These records can be used to

demonstrate reasonable assurance of operation

and maintenance of the wet scrubbers.

GP 010

CE 103

CE 113 Total Particulate

Matter: < 0.3

gr/dscf Recordkeeping:

Daily records of

Liquid Flow Rate, O

& M Plan Records are generated on a daily basis of liquid

flow rates for compliance with PM limits. These

records can be used to demonstrate reasonable

assurance of operation and maintenance of the

wet scrubbers.

3.5 Permit Organization

In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One

area where this permit deviates slightly from Delta guidance is in the use of appendices. While
appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks

should be electronically tracked (e.g., limits, submittals, etc.), should be in Table A or B of the permit.

The main reason is that the appendices are word processing sections and are not part of the electronic
tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these.

This permit action has generated reserved numbering for CE 145

‐ 180. This deviates from typical MPCA
practice.

Comments Received

Public Notice Period: <start date>
‐ <end date>

EPA 45

‐ day Review Period: <start date>
‐ <end date>

4. Permit Fee Assessment

Attachment 3 to this TSD contains the MPCA’s assessment of Application and Additional Points used to

determine the permit application fee for this permit action as required by Minn. R. 7002.0019. The

permit action includes one permit application received after the effective date of the rule (July 1, 2009).

5. Conclusion

Based on the information provided by Minntac, the MPCA has reasonable assurance that the proposed

operation of the emission facility, as described in the Air Emission Permit No. 13700005

‐ 006 and this

TSD, as well as requirement to address potential NAAQS standards will not cause or contribute to a

violation of applicable federal regulations and Minnesota Rules.Technical Support Document, Permit Action Number: 13700005

‐ 006

Page 10 of 10

Date: 6/5/2013 Staff Members on Permit Team: Sarah Seelen (permit writer/engineer)

Steve Palzkill (enforcement)

Andrew Place (stack testing)

Joe Miller (peer reviewer)

AQ File No. 26A; DQ 4078

Attachments: 1. PTE Summary Calculation Spreadsheets

2. Facility Description and CD

‐ 01 Forms

3. Points Calculator

# Attachment One:
PTE SummaryBaseline Years 2007/2008 2007/2008 2007/2008 2007/2008 2006/2007 2010/2011 2010/2011 2010/2011 2010/2011 2004/2005

PM PM 10 PM 2.5 NO

x SO 2 CO VOC F Lead GHG Baseline Emissions (TPY) 121.3 246.6 246.6 2664.1 536.1 286.0 28.45 5.35 0.19 323,163 Baseline Bypass Emissions 1.9 1.3 1.3 181.2 1.3 6.3 0.4 0.33 1.5E-05 8,734

Baseline Total 123.2 247.9 247.9 2845.3 537.5 292.3 28.9 5.7 0.2 331,897 Projected Actual (TPY) 46.5 67.9 67.9 1255.8 452.9 320.4 31.9 6.00 0.20 367,904 Projected Actual Bypass Emissions 1.9 1.3 1.3 N/A 1.3 6.3 0.4 0.33 1.5E-05 8,734 Total Projected Actual 48.4 69.3 69.3 1255.8 454.2 326.7 32.3 6.3 0.2 376,638

Low NOx - Excluded Emissions 0.0 0.0 0.0 0.0 16.4 34.4 3.4 0.6 0.0 29,692 Project Emission Increases/Decreases -74.8 -178.6 -178.6 -1589.5 -99.7 0.0 0.0 0.0 0.0 15,049 PSD Significance Threshold 25 15 10 40 40 100 40 3 0.6 75,000

Projected Actual - Baseline - Excluded -74.8 -178.6 -178.6 -1589.5 -99.7 0.0 0.0 0.0 0.0 15,049

PM PM 10 PM 2.5 NO

x SO 2 CO VOC F Lead GHG Baseline Emissions (TPY) 336.6 418.8 418.8 2011.7 419.0 103.3 22.83 5.61 0.17 332,092 Baseline Bypass Emissions 1.9 1.4 1.4 153.5 1.3 7.0 0.5 0.33 1.9E-05 10,366

Baseline Total 338.5 420.1 420.1 2165.2 420.4 110.3 23.3 5.9 0.2 342,458 Projected Actual (TPY) 224.6 257.8 257.8 1255.8 440.8 114.8 25.4 6.24 0.19 360,117 Projected Actual Bypass Emissions 1.9 1.4 1.4 N/A 1.3 7.0 0.5 0.33 1.9E-05 10,366 Total Projected Actual 226.5 259.2 259.2 1255.8 442.1 121.8 25.8 6.2 0.2 370,483

Low NOx - Excluded Emissions 0.0 0.0 0.0 0.0 22.6 8.3 1.8 0.5 0.0 28,965 Project Emission Increases/Decreases -338.5 -420.1 -420.1 -2165.2 -397.7 -102.0 -21.5 -5.5 -0.17 -939 PSD Significance Threshold 25 15 10 40 40 100 40 3 0.6 75,000

Projected Actual - Baseline - Excluded -112.0 -160.9 -160.9 -909.4 -0.9 3.2 0.7 -0.2 0.0 -939

PM PM 10 PM 2.5 NO

x SO 2 CO VOC F Lead GHG

Line 4 Emissions Increase/Decrease -74.8 -178.6 -178.6 -1589.5 -99.7 0.0 0.0 0.0 0.0 15,049

Line 5 Emissions Increase/Decrease -112.0 -160.9 -160.9 -909.4 -0.9 3.2 0.7 -0.2 0.0 -939

Total -186.8 -339.6 -339.6 -2499.0 -100.6 3.2 0.7 -0.2 0.0 14,110 PSD Significance Threshold 25 15 10 40 40 100 40 3 0.6 75,000

Baseline Emissions 461.7 668.0 668.0 5010.5 957.9 402.6 52.2 11.6 0.4 674,355

Projected Actual 274.9 328.5 328.5 2511.6 896.4 448.4 58.1 12.6 0.4 747,121

Excluded Emissions 0.0 0.0 0.0 0.0 39.1 42.7 5.3 1.1 0.0 58,657

difference without excludables -186.8 -339.6 -339.6 -2499.0 -61.5 45.9 6.0 0.9 0.0 72,767 difference including excludables -186.8 -339.6 -339.6 -2499.0 -100.6 3.2 0.7 -0.2 0.0 14,110 Line 5 (EU 282) Low NOx PSD/NSR Emissions Evaluation

Line 4 & 5 Project Summary TSD Attachment 1: Summary of Calculations

Line 4 (EU 261) Low NOx PSD/NSR Emissions Evaluation

# Attachment Two: Facility Description and CD

- 01 FormsMINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 1 of 69

Subject Item: Total Facility

NC/

CA Type Citation Requirement

CD hdr A . OPERATIONAL REQUIREMENTS 1.0

CD 40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R.

7009.0010-7009.0080 The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated upon written request by the MPCA. 2.0

CD 40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R.

7009.0010-7009.0080 The Permittee shall submit limits and other conditions, if necessary, to be incorporated into an enforceable document by: the 1-hour SO2 NAAQS attainment date established by EPA; the Regional Haze State Implementation Plan Revision date which is currently, 2018; or as required by any other applicable federal law,

whichever is earliest. 3.0

CD 40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M); Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R.

7009.0010-7009.0080 The Permittee shall submit limits and other conditions, if necessary, to be incorporated into an enforceable document by: the 1-hour NO2 NAAQS attainment date established by EPA; the Regional Haze State Implementation Plan Revision date which is currently, 2018; or as required by any other applicable federal law,

whichever is earliest. 4.0

S/A Minn. R. 7007.0080 A mbient Air Monitoring Report: due 45 days after end of each calendar quarter following Effective Date of Permit: total suspended particulate matter (TSP) monitoring reports to determine compliance with the Minnesota Ambient Air Quality Standards for TSP. Ambient monitoring will be conducted for a 3 year period, as provided by Attachment B to the September 17, 1999, Stipulation Agreement. Monitoring may be extended if violations occur. 5.0

CD Minn. R. 7011.0150 Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in

Minn. R. 7011.0150. 6.0

S/A Minn. Stat. Section 116.07, subd. 4a; Minn. R. 7007.0800, subp. 2 Fugitive Emissions Control Plan: due 60 days after 02/26/2003 for approval by the commissioner. The plan shall identify all fugitive emission sources, primary and contingent control measures, and record keeping. The Permittee shall follow the actions and record keeping specified in the control plan. The commissioner may require additions or changes to the O&M plan when granting approval. The Permittee will be given an opportunity to comment on any required additions or changes to the plan before the commissioner grants approval of the plan. The plan may be amended by the Permittee with the Commissioner's approval. If the Commissioner determines the permittee is out of compliance with Minn. R. 7011.0150 or the fugitive emission control plan, then the permittee may be required to amend the control plan and/or to install and operate particulate matter ambient

monitors.

The plan shall incorporate tailings basin emissions control measures required by the September 17, 1999, Stipulation Agreement, with changes approved by the

Commissioner. 7.0

CD Minn. Stat. Section 116.07, subd. 4a; Minn. R. 7007.0800, subp. 2 Comply with Fugitive Emission Control Plan: The Permittee shall follow the actions and record keeping specified in the control plan. The plan will include a statement of objectives, listing and daily observation of major fugitive emission sources, operating and control measures, dust suppressant application description, corrective actions, training and records. The plan may be amended by the Permittee with the Commissioner's approval. If the Commissioner determines the Permittee is out of compliance with Minn. R. 7011.0150 or the fugitive control plan, then the Permittee may be required to amend the control plan and/or to install and operate particulate matter ambient monitors as requested by the Commissioner. 8.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 2 of 69

S/A Minn. R. 7007.0800, subp. 14 and Minn. R. 7007.0800, subp. 16(J) Operation and Maintenance Plan: due 120 days after 02/26/2003 for review and approval by the commissioner. The O&M plan shall identify all air pollution control equipment, a preventative maintenance program for that equipment, description of corrective actions to be taken in the event of a malfunction or breakdown, description of the employee training program, and the records kept to demonstrate plan implementation. The commissioner may require additions or changes to the O&M plan when granting approval. The Permittee will be given an opportunity to comment on any required additions or changes to the plan before the commissioner grants approval of the plan. 9.0

S/A Minn. R. 7007.0800, subp. 14 and Minn. R. 7007.0800, subp. 16(J) Submittal of Permit Application: due 360 days after Effective Date of Permit the Permittee shall submit parameter ranges, along with rationale for their development, in a permit amendment application, to incorporate the air pollution control equipment parameter ranges (scrubber water flow and/or pressure drop) into this permit. The rationale for choosing these ranges shall include the control equipment manufacturer's suggested ranges and any reasons for deviating from the recommended ranges. 10.0

CD Minn. R. 7007.0800, subp. 14 and Minn. R. 7007.0800, subp. 16(J) Comply with the O & M Plan: Follow the actions and recordkeeping specified in the O & M plan. The plan may be amended by the Commissioners written approval. 11.0

CD Minn. R. 7030.0010 - 7030.0080 Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or

citizens under the Clean Air Act. 12.0

CD Minn. R. 7007.0800, subp. 2; Minn. R. 7007.0800, subp. 16(J) A ir Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless

otherwise noted in Table A. 13.0

CD hdr B. PERFORMANCE TESTING REQUIREMENTS 14.0

CD Minn. R. ch. 7017 Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in Tables A, B, and/or C. 15.0

CD Minn. R. 7017.2025 Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as specified by Minn. R. 7017.2025 following formal review of a subsequent performance test on the same unit. 16.0

CD hdr C. MONITORING REQUIREMENTS 17.0

CD Minn. R. 7007.0800, subp. 4(D) Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment (any requirements applying to continuous emission monitors are listed separately in this permit - Subject Item: Total Facility, Section F; Subject Items MR1 through MR5). 18.0

CD Minn. R. 7007.0800, subp. 4(D) Monitoring Equipment: Install or make needed repairs to monitoring equipment within 180 days of issuance of the permit if monitoring equipment is not installed and operational on the date the permit is issued. 19.0

CD Minn. R. 7007.0800, subp. 4(D) Monitoring Equipment Debugging, Troubleshooting, and Establishment of Parameter Ranges: Complete within 180 days of installation or of completion of needed repair of all monitoring equipment, including the air pollution control equipment operating at the time of Permit Issuance. 20.0

CD Minn. R. 7007.0800, subp. 4(D) Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. 21.0

CD Minn. R. 7007.0800, subp. 4(D); Minn. R. 7007.0800, subp. 14; Minn. R. 7007.0800, subp. 16(J) Visible Emissions Check: The Permittee shall check visible emissions from the 26 selected stacks/vents, which are specified else where in this permit, once daily when in operation during daylight hours. A form meeting the requirements of

A ppendix B shall be used to indicate whether process or control equipment requires attention. In the event the Permittee makes a finding that attention is required, the Permittee shall investigate the process and control equipment performance and implement appropriate corrective action, if necessary.

Upon approval of the O&M Plan, the Permittee shall check visible emissions from {SVs} once daily when in operation during daylight hours. The Permittee shall used

the visible emissions checklists in the O&M Plan as a means to indicate when appropriate corrective actions in the O&M Plan should be taken. 22.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 3 of 69

CD Minn. R. 7007.0800, subp. 4(D); Minn. R. 7007.0800, subp. 14; Minn. R. 7007.0800, subp. 16(J) Fugitive Dust Observations: Prior to the approval of the Fugitive Control Plan, the Permittee shall observe fugitive dust sources {FS} once daily during daylight hours. In the event the Permittee makes a finding that attention to fugitive dust sources is required, the Permittee shall investigate the fugitive dust sources and implement corrective action, if necessary. For unpaved haul roads, the Permittee may use the existing Unpaved Haul Road Fugitive Control Plan and may submit this plan for approval as part of the overall fugitive control plan.

Upon approval of the Fugitive Control Plan, the Permittee shall observe fugitive dust sources {FS} once daily during daylight hours in accordance with the approved plan. 23.0

CD Minn. R. 7007.0800, subp. 4(D); Minn. R. 7007.0800, subp. 14; Minn. R. 7007.0800, subp. 16(J) Visible Emissions Training: The Permittee shall (1) ensure that one plant employee obtain an initial EPA Method 9 certification and be recertified every three years or (2) employ a similarly certified contractor. This person will train other plant employees to perform the daily visible emissions check as detailed in the O&M Plan and Fugitive Control Plan. 24.0

CD hdr D. RECORD KEEPING REQUIREMENTS 25.0

CD Minn. R. 7007. 0800, subp. 5(B) Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007. 1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350 subp. 2), including records of the emissions resulting from those changes. 26.0

CD Minn. R. 7007.0800, subp. 5(C) Record keeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). Computerized formats can be used, provided that the Permittee maintains reliable backup for data retrieval. 27.0

CD Minn. R. 7007.0800, subp. 2 Contractors: The Permittee shall retain records on site of all contractors that are allowed on site that include any crushers, screens and conveyors. The Permittee shall also retain records on site of all contractors whose operations would require

an Air Emission Permit from the MPCA. The records shall include the contractor's company name, MPCA air emission permit number, short description of activities undertaken by the contractor, estimate of emissions or materials handled and the dates the contractor was on site. The record shall be updated at least monthly.

The Permittee shall evaluate if the activities of any contractor required NSR permitting prior to the contractor performing such activities. If a contractor has its own permit, but it is determined that the contractor is under the common control of the taconite plant then the contractor's permit does not shield the taconite plant or the contractor from the NSR & Part 70 modification regulations or enforcement

actions. 28.0

CD hdr E. REPORTING REQUIREMENTS 29.0

CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger

human health or the environment. 30.0

CD Minn. R. 7019.1000, subp. 1 Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected ; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the

deviation. 31.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 4 of 69

CD Minn. R. 7019.1000, subp. 2 Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2.

A t the time of notification or as soon as possible thereafter, the owner or operator

shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the

breakdown is over. 32.0

CD Minn. R. 7019.1000, subp. 3 Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 3.

A t the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. 33.0

CD Minn. R. 7002.0005 through Minn.

R. 7002.0095 Emission Fees: due 60 days after receipt of an MPCA bill. 34.0

CD hdr F. Retroactive PSD Permitting Requirements - Tasks, Reports and CEMS (Table A under Subject Item: MR 001 through MR 005, and Table B have additional CEMS requirements) 35.0

CD Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 The Permittee shall commence pilot testing of selected NOx control technologies, upon receipt of written MPCA approval of the selection and the test schedule and receipt of permit(s) as needed. The Permittee shall collect data to be used for evaluation of control technology success. Pilot tests shall be completed by 12/31/2009, or as outlined in MPCA approved schedule, whichever is later.

MPCA will evaluate the control technology using the following criteria at a minimum: 1. technical feasibility or impact to pellet quality; 2. significant NOx reduction; 3. cross media impacts; 4. multi-pollutant co-control benefits; 5. energy efficiency or consumption impact; and 6. economic feasibility. 36.0

CD Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 No more than 60 days after pilot test completion, submit Pilot Test Results of NOx control technologies for MPCA's approval. The Pilot Test Results submittal shall include, at a minimum, a technical description of each control technology tested, and a summary of major physical and chemical data obtained that are important for deciding whether or not the technology should be demonstrated. With the Pilot Test Results, the Permittee shall propose one control technology for full scale demonstration on one Agglomerator line and shall rank the other control technologies that have been pilot tested for potential demonstration. 37.0

S/A Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 Submittal of Permit Application: due 60 days after receipt of written MPCA approval of NOx emission control pilot testing results, for a major permit amendment to install a control technology at one Agglomerator line for a full scale demonstration.

The Permittee shall submit a schedule of equipment installation, anticipated startup, and final reporting of the demonstration within 60 days of receipt of the

Permit from the MPCA. 38.0

CD Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 The Permittee shall submit a schedule of equipment installation and anticipated startup of the full - scale demonstration on Line 4 (EU 261) Line 5 (EU 282) within 60 days of Permit Issuance. { This is a reminder; the requirement can also be found in Table B. } 39.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 5 of 69

CD Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 The Permittee shall commence full scale demonstration of the selected NOx control technology at one Agglomerator line, upon receipt of MPCA permit(s). This includes, but is not limited to the following tasks: 1) compiling emission monitoring and stack testing data that were generated before installing the control technology; 2) installing and operating the control technology; 3) monitoring emissions and conducting stack testing with the control technology operating; 4) collect capital and operating cost data. The goal is to have the demonstration completed by 2/1/2011.

A goal is a target for the Permittee but is not intended to be an enforceable permit

condition. 40.0

CD Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 Within 60 days following completion of the full scale demonstration, submit a Full Scale Demonstration Report for MPCA approval. At a minimum, the report shall include a summary of: 1) mass rate (lb/hr) and concentration (ppmv, dry) of NOx, SO2, CO, and mercury entering and exiting each demonstrated control technology; 2) control efficiencies and emission factors in lb/dry, long ton of pellets made and in lb/million Btu total heat input for NOx, SO2, CO, and mercury, based on statistical analyses of hourly continuous emission and process monitoring results and, if necessary, additional stack testing results; and 3) cross-media quantification for scrubbing and/or plant process water.

(To be continued in the next box) 41.0

CD Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 (Continued from the box above)

MPCA will evaluate the full scale technology demonstration using the criteria specified to evaluate the pilot testing at a minimum. The goal is to have NOx control technology installation completed for all operating lines by 2/1/2014, or as outlined in MPCA approved schedule, whichever is later. A goal is a target for the Permittee but is not intended to be an enforceable permit condition. 42.0

S/A Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 Submittal of Permit Application: due 60 days after receipt of written MPCA approval of the final report on control technology demonstration on Line 4 (EU 261) and Line 5 (EU 282) for a major permit amendment to install the demonstrated control technology on the remaining Agglomerator lines.

The Permittee shall submit a schedule of equipment installation and anticipated startup of individual lines within 60 days of receipt of the Permit from the MPCA. 43.0

CD Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 If the MPCA determines that the demonstrated control technology should not be installed on the remaining lines in operation, the Permittee shall commence demonstration of the next-ranked control technology option that was submitted with the Pilot Test Results and shall submit a Full Scale Demonstration report as required above. The Permittee shall continue this process until either the MPCA approves a control technology for installation on the remaining lines in operation or all of the ranked technology options have been exhausted. If all of the ranked technology options are exhausted and the MPCA has not approved a technology for installation on the remaining lines in operation, the Permittee shall propose a schedule for completion of a Supplemental Engineering Analysis that at a minimum identifies any previously unidentified NOx control technologies, NOx reduction strategies or then current industry practices. (To be continued in the next box) 44.0

CD Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 (Continued from the box above) The specific provisions of the Supplemental Engineering Analysis shall be incorporated into the permit through the submission of a major permit amendment.

The Supplemental Engineering Analysis shall be submitted to the MPCA no later than 60 days after written notification from the MPCA that none of the pilot tested technologies are approvable for installation on all lines in operation. The Supplemental Engineering Analysis will identify new potentially feasible control technologies, based on previously identified criteria, and propose a schedule, for MPCA approval, of supplemental pilot tests, pilot test reports, installation of technology for a full scale demonstration, demonstration project reports, and full installation of control technology at remaining operating Agglomerator lines.

(To be continued in the next box) 45.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 6 of 69

CD Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 (Continued from the box above)

If the Supplemental Engineering Analysis concludes that no technologies are currently feasible, based on previously identified criteria, and MPCA approves, another Supplemental Engineering Analysis will be submitted by the Permittee within 1095 days of last Supplement Engineering Analysis submittal, with all of the procedures that the MPCA has previously approved, with the exception that the Permittee need not obtain a major permit amendment to implement additional Supplemental Engineering Analyses. The Permittee shall continue to submit Supplemental Engineering Analyses every 1095 days until NOx control technologies have been installed on all operating Agglomerator lines.

(To be continued in the next box) 46.0

CD Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 (Continued from the box above)

If, after initial engineering analyses, pilot testing, demonstration projects, and an initial Supplemental Engineering Analysis, no control technologies are approved for full installation and significant NOx emission reductions have been achieved without full installation of control technologies on all operating Agglomerator lines, the Permittee may submit a request, in the form of a major permit amendment, to cease trials of NOx emissions control technologies.

(End of the requirement that takes 4 boxes to hold) 47.0

CD Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 If the MPCA approves a demonstrated control technology for installation at the remaining lines in operation, the Permittee shall commence installation upon receipt of MPCA permits(s). If a non-operating line recommences operation, the Permittee shall install the approved NOx control technology before the line resumes operation. Installation includes, but is not limited to: 1) installing and operating the control technology; 2) monitoring emissions and conducting stack testing with the control technology operating and setting emission limits; and 3) collect capital and operating cost data. 48.0

CD Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 Within 60 days after completion of full scale installation, submit a Final NOx Reduction Report for MPCA approval to document the NOx reduction process and major findings. At a minimum, the Final Report shall include a summary of: 1) demonstrated control efficiency of the control technology installed at each line and the emission factors (lb/LT pellets; lb/million Btu of total heat input) for each pollutant determined during the full scale demonstration; 2) associated cross-media impacts assessed and mitigation measures; 3) annualized cost of NOx control for the control technology installed (of captial cost for equipment and operation cost) per ton of NOx removed; 4) Low NOx burners, CFD work, the benefit of CEMS application, and other measures taken that contribute to reduction in induration

NOx formation. 49.0

CD Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1006 Emission Monitoring: The owner or operator shall use a CEMS to measure mass emissions of NOx and SO2 from each of the following stacks: SV 103 (GP 009), SV 118 & SV 127 (GP 010), and SV 144 & SV 151 (GP 011). Monitoring requirements are located under the associated subject items (MR 001 through MR 005). 50.0

CD Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1090. Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. 51.0

CD Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1160, subp. 1 and 2. Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emssion averages unless another applicable requirement or compliance document requires more frequent averaging. Each hourly average starts at the beginning of the hour and ends at the beginning of the following hour. In order for an hour of data to be considered, it must contain the following minimum number of data points: a) four data points, equally spaced, if the emission unit operated during the entire hour; b) two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; and c) one data point, if the emission unit operated for 15 minutes or less during the hour. 52.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 7 of 69

CD Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1170, subp. 2. QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR 60, Appendix F, section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the

list. 53.0

CD Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1170, subp. 3. CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified and recorded at zero (low-level) and upscale (high-level) gas concentrations at least once daily according to the procedures listed in Minn. R. 7017.1170, subp. 3 and 40 CFR 60.13(d)(1) for each pollutant concentration, each diluent monitor, and for each monitor range. The CEMS shall be adjusted whenever the CD exceeds twice the specification of 40 CFR 60, Appendix B. If no span value is specified in the applicable requirement or in a compliance document, the Permittee shall use a span value equivalent to 1.5 times the emission limit. 40 CFR 60, Appendix F, shall be used to determine out-of-control periods for CEMS. Follow the procedures in 40 CFR 60, Appendix F. 54.0

CD Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1180, subp. 2. Relative Accuracy Test Audit (RATA) Notification: due 30 days before CEMS Relative Accuracy Test Audit (RATA). 55.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1110, subp. 1 and 2. Excess Emissions/Downtime Reports (EER's): due 30 days after end of each calendar quarter following Initial Startup of the Monitor. Submit Deviations Reporting Form DRF-1 as amended. The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e., during starup, shutdown, and malfunctions. The EER must be submitted even if there were no excess emissions, downtime or bypass during the quarter. 56.0

CD hdr G. MISCELLANEOUS 57.0

CD Minn. R. 7007.1400, subp. 1(H) Extension Requests: Except for Title I Conditions, the Permittee may apply for an

A dministrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). 58.0

CD Minn. R. 7007.1150 through Minn.

R. 7007.1500 A pplication for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment

needed. 59.0

CD Minn. R. 7007.0800, subp. 9(A) Inspections: Upon presentation of credentials and other documents as may be required by law, allow the Agency, or its representative, to enter the Permittee's premises to have access to and copy any records required by this permit, to inspect at reasonable times (which include any time the source is operating) any facilities, equipment, practices or operations, and to sample or monitor any substances or parameters at any location. 60.0

CD Minn. R. 7011.0020 Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. 61.0

CD Minn. R. 7019.1000, subp. 4 Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. 62.0

S/A Minn. R. 7007.0400, subp. 3 A pplication for Permit Reissuance: due 180 days before expiration of Existing

Permit 63.0

S/A Minn. R. 7007.0800, subp. 6(A)(2) Semiannual Deviations Report: due 30 days after end of each calendar half-year starting 02/26/2003 . The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. 64.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 8 of 69

S/A Minn. R. 7007.0800, subp. 6(C) Compliance Certification: due 31 days after end of each calendar year starting 02/26/2003 (for the previous calendar year). To be submitted on a form approved by the Commissioner <, both to the Commissioner, and to the U.S. EPA regional office in Chicago>. This report covers all deviations experienced during the calendar year. < The EPA copy shall be sent to: Mr. George Czerniak, Chief, Air Enforcement and Compliance Assurance Branch, Air and Radiation Division, EPA Region V, 77 West Jackson Boulevard, Chicago, Illinois 60604> 65.0

CD Minn. R. 7007.0800, subp. 16 The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. 66.0

S/A Minn. R. 7019.3000 through Minn.

R. 7019.3010 Emissions Inventory Report: due 91 days after end of each calendar year starting 02/26/2003 (April 1). To be submitted on a form approved by the Commissioner. 67.0

S/A Minn. R. 7007.0800, subp. 2 Submittal: due 1096 days after 02/26/2003 to provide modeling data as specified in MPCA Guidance for Modeling Information Request. The modeling information is for data collection purposes, no modeling analysis is required at this time. This is a state only requirement and is not enforceable by the EPA Administrator or citizens

under the Clean Air Act. 68.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 9 of 69

Subject Item: GP 001 Pre-1977 heating boilers

Associated Items: EU 001 SI 104 MMBtu Heating Boiler

EU 002 SI 104 MMBtu Heating Boiler

EU 003 SII 125 MMBtu Heating Boiler

EU 010 24.6 MMBtu Boiler

EU 011 24.6 MMBtu Boiler

SV 001 SI 104 MMBtu Boiler

SV 002 SI 104 MMBtu Boiler

SV 003 SII 125 MMBtu Boiler

SV 010 24.6 MMBtu Boiler

SV 011 24.6 MMBtu Boiler

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0510, subp. 1 Total Particulate Matter: less than or equal to 0.6 lbs/million Btu heat input 2.0

LIMIT Minn. R. 7011.0510, subp. 1 Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input 3.0

LIMIT Minn. R. 7011.0510, subp. 2 Opacity: less than or equal to 20 percent opacity , except for one six-minute period per hour of not more than 60 percent opacity. 4.0

CD hdr B. OPERATION REQUIREMENTS 5.0

CD Minn. R. 7007.0800, subp. 4(B) The Permittee shall record the amount of fuel oil burned each month. The Permittee shall obtain and maintain a fuel supplier certification of the sulfur weight percent for each shipment of fuel oil. If supplier certification is not available, the Permittee shall sample the fuel oil from multiple the tank(s) after each delivery but not more than once each calendar week when multiple deliveries are made. The Permittee shall analyze the oil sample to determine sulfur content of the fuel oil in pcercent by weight in accordance with the current ASTM method. The Permittee shall maintain records of the fuel deliveries and results of the fuel analysis. 6.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 10 of 69

Subject Item: GP 002 Post-1977 heating boilers

Associated Items: EU 004 SIII 153 MMBtu Heating Boiler

EU 005 SIII 153 MMBtu Heating Boiler

SV 004 SIII 153 MMBtu Boiler

SV 005 SIII 153 MMBtu Boiler

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0515, subp. 1 Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input 2.0

LIMIT Minn. R. 7011.0515, subp. 1 Sulfur Dioxide: less than or equal to 2.0 lbs/million Btu heat input 3.0

LIMIT Minn. R. 7011.0515, subp. 2 Opacity: less than or equal to 20 percent opacity , except for one six-minute period per hour of not more than 60 percent opacity. 4.0

CD hdr B. OPERATION REQUIREMENTS 5.0

CD Minn. R. 7007.0800, subp. 4(B) The Permittee shall record the amount of fuel oil burned each month. The Permittee shall obtain and maintain a fuel supplier certification of the sulfur weight percent for each shipment of fuel oil. If supplier certification is not available, the Permittee shall sample the fuel oil from multiple the tank(s) after each delivery but not more than once each calendar week when multiple deliveries are made. The Permittee shall analyze the oil sample to determine sulfur content of the fuel oil in pcercent by weight in accordance with the current ASTM method. The Permittee shall maintain records of the fuel deliveries and results of the fuel analysis. 6.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 11 of 69

Subject Item: GP 003 Panfeeders (Pre-1969)

Associated Items: CE 004 Wet Scrubber-High Efficiency w/o Lime

CE 005 Wet Scrubber-High Efficiency w/o Lime

EU 022 Step I Coarse Crusher Pan Feeders

EU 023 Step I Coarse Crusher Pan Feeders

EU 024 Step II Coarse Crusher Pan Feeders

EU 025 Step II Coarse Crusher Pan Feeders

SV 016 Step I Coarse Crusher Pan Feeders

SV 017 Step II Coarse Crusher Pan Feeders

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0710, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 2.0

LIMIT Minn. R. 7011.0710, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 3.0

LIMIT Minn. R. 7011.0710, subp. 1(B) Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. 4.0

CD hdr B. CONTROL EQUIPMENT MONITORING 5.0

CD Minn. R. 7007.0800, subp. 4(D); 14; 16(J) Gas Stream Pressure Drop: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 6.0

CD Minn. R. 7007.0800, subp. 4(D); 14; 16(J) Liquid Flow Rate: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 7.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 8.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 730 days after 02/26/2003 on one stack to measure

PM emission. 9.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 60 months following Initial Performance Test on one stack that was not tested in the previous 60-month period to measure

PM emission. 10.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 11.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 12.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 13.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 14.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 15.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 12 of 69

Subject Item: GP 004 Zinc furnaces & miscellaneous ovens

Associated Items: EU 028 Zinc Melt Furnace

EU 031 Zinc Melt Furnace

EU 032 Zinc Melt Furnace

EU 142 Zinc Melt Furnace

EU 143 Zinc Melt Furnace

EU 389 Electric Shop Curing Oven (new)

EU 390 Burnout Oven

SV 019 Zinc Melt Furnace

SV 020 Zinc Melt Furnace

SV 086 Zinc Melt Furnace

SV 189 Electric Shop Curing Oven

SV 190 Burnout Oven

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0610, subp. 1(A)(1) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. 2.0

LIMIT Minn. R. 7011.0610, subp. 2(B)(1) Sulfur Dioxide: less than or equal to 2 lbs/million Btu heat input 3.0

LIMIT Minn. R. 7011.0610, subp. 1(A)(2) Opacity: less than or equal to 20 percent opacity , except for one six-minute period per hour of not more than 60 percent opacity. 4.0

CD hdr B. OPERATION REQUIREMENTS 5.0

CD Minn. R. 7007.0800, subp. 4(B) The Permittee shall record the amount of fuel oil burned each month. The Permittee shall obtain and maintain a fuel supplier certification of the sulfur weight percent for each shipment of fuel oil. If supplier certification is not available, the Permittee shall sample the fuel oil from multiple the tank(s) after each delivery but not more than once each calendar week when multiple deliveries are made. The Permittee shall analyze the oil sample to determine sulfur content of the fuel oil in pcercent by weight in accordance with the current ASTM method. The Permittee shall maintain records of the fuel deliveries and results of the fuel analysis. 6.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 13 of 69

Subject Item: GP 005 Conveyor transfer points (26A-91-I/O-1)

Associated Items: CE 014 Wet Scrubber-High Efficiency w/o Lime

CE 015 Wet Scrubber-High Efficiency w/o Lime

EU 049 Conveyor Transfer 005 Feed

EU 050 Conveyor Transfer 005 Discharge

SV 027 Conveyor Transfer 005 Feed

SV 028 Conveyor Transfer 005 Discharge

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Title I Condition: a 1991 action that avoided major classification

under 40 CFR 52.21 Total Particulate Matter: less than or equal to 0.02 grains/dry standard cubic foot 2.0

LIMIT Title I Condition: a 1991 action that avoided major classification

under 40 CFR 52.21 Particulate Matter < 10 micron: less than or equal to 0.01 grains/dry standard cubic

foot 3.0

CD hdr B. CONTROL EQUIPMENT MONITORING 4.0

CD Minn. R. 7007.0800, subp. 4(D); 14; 16(J) Gas Stream Pressure Drop: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 5.0

CD Minn. R. 7007.0800, subps. 4(D); 14; 16(J) Liquid Flow Rate: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 6.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 7.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 730 days after 11/30/2004 on one stack to measure

PM and PM10 emissions. 8.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 60 months following Initial Performance Test on the stack that was not tested in the previous 60-month period to measure

PM and PM10 emissions. 9.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 10.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 11.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 12.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 13.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 14.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 14 of 69

Subject Item: GP 006 Stationary internal combustion engines

Associated Items: EU 006 Diesel Generator

EU 008 Diesel Generator

EU 009 Diesel Fire Pump

EU 012 Diesel Generator

EU 051 Diesel Generator

EU 215 Diesel Generator

EU 216 Diesel Generator

EU 383 Diesel Generator

EU 384 Diesel Generator

EU 385 Diesel Generator

EU 386 Diesel Generator

EU 387 Air Compressor

SV 006 Diesel Generator

SV 009 Diesel Fire Pump

SV 012 Diesel Generator

SV 029 Diesel Generator

SV 098 Diesel Generator

SV 099 Diesel Generator

SV 183 Diesel Generator

SV 184 Diesel Generator

SV 185 Diesel Generator

SV 186 Diesel Generator

SV 187 Diesel Air Compressor

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.2300, subp. 2 Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input 2.0

LIMIT Minn. R. 7011.2300, subp. 1 Opacity: less than or equal to 20 percent opacity once operating temperatures have

been attained. 3.0

CD hdr B. OPERATION REQUIREMENTS 4.0

CD Minn. R. 7007.0800, subp. 4(B) The Permittee shall record the amount of diesel fuel consumed each calendar quarter. The Permittee shall obtain and maintain a fuel supplier certification of the sulfur weight percent for each shipment of diesel fuel. If supplier certification is not available, the Permittee shall sample diesel fuel from multiple the tank(s) after each delivery but not more than once each calendar week when multiple deliveries are made. The Permittee shall analyze the fuel sample to determine sulfur content of diesel fuel in pcercent by weight in accordance with the current ASTM method.

The Permittee shall maintain records of the fuel deliveries and results of the fuel analysis. 5.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 15 of 69

Subject Item: GP 007 Coal handling sources

Associated Items: CE 139 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 140 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

EU 367 Coal Unloading Silo

EU 368 Coal Unloading Silo

EU 369 Coal Unloading Silo

EU 370 Coal Unloading Silo

EU 371 Coal Unloading Silo

EU 372 Coal Unloading Silo

EU 373 Coal Unloading Silo

EU 374 Coal Day Bin/Conveyor Transfer

EU 375 Coal Day Bin/Conveyor Transfer

EU 376 Coal Day Bin/Conveyor Transfer

EU 377 Coal Day Bin/Conveyor Transfer

EU 378 Coal Day Bin/Conveyor Transfer

EU 379 Coal Day Bin/Conveyor Transfer

EU 380 Coal Day Bin/Conveyor Transfer

EU 381 Coal Day Bin/Conveyor Transfer

EU 382 Coal Day Bin/Conveyor Transfer

SV 181 Coal Unloading Silo

SV 182 Coal Day Bin/Conveyor Transfer

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT 40 CFR 60.252(c); Minn. R.

7011.1150 Opacity: less than or equal to 20 percent opacity 2.0

CD hdr B. CONTROL EQUIPMENT MONITORING 3.0

CD Minn. R. 7007.0800, subp. 4(D); 14; 16(J) Gas Stream Pressure Drop: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 4.0

CD Minn. R. 7007.0800, subp. 4(D); 14; 16(J) Process Monitoring: the visual emissions observer in the facility staff shall check stack visible emissions (opacity) once daily using a checklist that at a minimum contains the information required in Appendix B. If the Permittee uses for a control device a broken bag detector approved by the MPCA, the Permittee does not need

to conduct visible emissions checks for the stack associated with the control device in this group. 5.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 6.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 180 days after 11/07/2003 on both stacks to measure Opacity emission. 7.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on one-year (12 month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. 8.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 9.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 10.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 11.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 12.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 13.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 16 of 69

Subject Item: GP 009 Agglomerator Line 3

Associated Items: CE 086 Other

CE 088 Gravity Collector - Low Efficiency

CE 145 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones

CE 146 Wet Scrubber-High Efficiency

EU 223 L3 Traveling Grate

EU 225 L3 Rotary Kiln

EU 226 L3 Pellet Cooler Secondary Air

MR 001 NOx & SO2 CEMS at Line 3 Waste Gas Stack (SV 103)

SV 103 L3 Waste Gas Stack

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 Nitrogen Oxides: less than or equal to 5000 lbs/hour using 24-hour Block Average from all five waste gas stacks combined (GP 009 through 011; SV 103, 118, 127, 144, and 151) at Permit Issuance. 2.0

LIMIT Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 Nitrogen Oxides: less than or equal to 13300 tons/year using 365-day Rolling Sum from all five waste gas stacks combined (GP 009 through 011; SV 103, 118, 127, 144, and 151) at Permit Issuance. Representative NOx emission data shall be used to demonstrate compliance for the first 365 days. 3.0

LIMIT Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 Nitrogen Oxides: less than or equal to 7300 tons/year using 365-day Rolling Sum from all five waste gas stacks combined (GP 009 through 011; SV 103, 118, 127, 144, and 151) no later than Feb. 1, 2010. 4.0

LIMIT Title I Condition: BACT emission limit, 40 CFR 52.21(j)(3); Minn. R.

7007.3000. Fluorides: less than or equal to 1.04 lbs/hour using 3-hour Average at Line 3 Waste Gas Stack (SV 103). 5.0

LIMIT Title I Condition: BACT emission limit, 40 CFR 52.21(j)(3); Minn. R.

7007.3000. Carbon Monoxide: less than or equal to 68.8 lbs/hour using 3-hour Average at Line 3 Waste Gas Stack (SV 103). 6.0

LIMIT Title I Condition: BACT emission limit, 40 CFR 52.21(j)(3); Minn. R.

7007.3000. Volatile Organic Compounds: less than or equal to 51.6 lbs/hour using 3-hour

A verage , as propane, at Line 3 Waste Gas Stack (SV 103). 7.0

LIMIT Minn. R. 7011.0610, subp. 1(A)(1) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. 8.0

LIMIT Minn. R. 7011.0610, subp. 2(B) Sulfur Dioxide: less than or equal to 2 lbs/million Btu heat input when liquid fuel is

combusted. 9.0

LIMIT Minn. R. 7011.0610, subp. 2(A)(2) Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. 10.0

CD hdr B. OPERATION REQUIREMENTS

(Note - CEMS requirements can be found in Table A under Subject Item: Total Facility, Section F, and Subject Items MR 001 through MR 005; and in Table B) 11.0

CD Title I Condition: To address fuel options for the indurating process modification of 1987-1989, 40 CFR 52.21(j)(3); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 2 Fuel Restrictions: The Permittee shall combust at the kiln burner natural gas, fuel oil, and/or types of biomass that are specified in Appendix 1 of this permit; and at the preheat burners natural gas. Other fuels may be combusted for a short period of time during a trial burn as approved by an amendment to this permit. 12.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 17 of 69

LIMIT Minn. R. 7007.0800, subp. 2 Material Usage: less than or equal to 3000 gallons/month of fuel additive for

A gglomerator Lines 3, 4, 5, 6, and 7 (Groups 9, 10, and 11) combined. The Permittee shall maintain for at least three years a monthly record of fuel additive usage including brands and suppliers. 13.0

LIMIT Minn. R. 7007.0800, subp. 2 Material Usage: less than or equal to 16000 gallons/month of slag inhibitor for

A gglomerator Lines 3, 4, 5, 6, and 7 (Groups 9, 10, and 11) combined. The Permittee shall maintain for at least three years a monthly record of slag inhibitor usage including brands and suppliers. 14.0

CD Minn. R. 7007.0800, subp. 4(B) Material/Fuel Usage and Sulfur Content: The Permittee shall 1) record the amount of materials and fuel consumed each day; 2) obtain and maintain a fuel supplier certification of the sulfur weight percent for each shipment of fuel, or sample the fuel oil from multiple the tank(s) after each delivery but not more than once each calendar week when multiple deliveries are made; 3) sample materials entering the grate-kiln once each calendar week; and 4) maintain records of the fuel deliveries, material usage, and analyses results. The Permittee shall analyze the fuel and material samples to determine their sulfur content in pcercent by weight and fuel heating value in accordance with the current ASTM method. 15.0

CD hdr C. CONTROL EQUIPMENT MONITORING 16.0

CD Title I Condition: Monitoring for fluoride BACT, 40 CFR 52.21(j)(3); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 17.0

CD Title I Condition: Monitoring for fluoride BACT, 40 CFR 52.21(j)(3); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Liquid Flow Rate: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 18.0

CD Title I Condition: Monitoring for CO & VOC BACT, 40 CFR 52.21(j)(3); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Waste Gas to Heat Input Ratio: The Permittee shall calculate and record, for each hour when valid data are available, the ratio of SV 103 gas flow, as measured by CEMS in cubic feet per hour in standard conditions (scfh), to total heat input at kiln and grate burners in British Thermal Units per hour (Btu/hr). This ratio will be used as an indicator to learn how complete CO & VOC are destroyed in the indurating

furnace. 19.0

CD hdr D. PERFORMANCE TESTING REQUIREMENTS 20.0

S/A Title I Condition: BACT emission limit, 40 CFR 52.21(j)(3); Minn. R.

7007.3000. Initial Performance Test: due 180 days after 12/22/2008 to measure Fluorides, CO, and VOC emissions at Line 3 Waste Gas Stack (SV 103). 21.0

S/A Title I Condition: BACT emission limit, 40 CFR 52.21(j)(3); Minn. R.

7007.3000. Testing Frequency Plan: due 60 days after Initial Performance Test. The plan shall specify a testing frequency for fluorides, CO, and VOC based on the test data and MPCA guidance. Future performance tests based on one-year (12-month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. 22.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 60 months starting 05/17/2005 to measure PM and Opacity emissions. 23.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 24.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 25.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 26.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 27.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 28.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 18 of 69

Subject Item: GP 010 Agglomeration Lines 4 & 5

Associated Items: CE 101 Other

CE 102 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones

CE 103 Wet Scrubber-High Efficiency w/o Lime

CE 111 Other

CE 112 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones

CE 113 Wet Scrubber-High Efficiency w/o Lime

CE 181 Line 4 Low NOx Main Burner

CE 182 Line 5 Low NOx Main Burner

EU 259 L4 Traveling Grate

EU 260 L4 Recoup System Air

EU 261 L4 Rotary Kiln

EU 262 L4 Pellet Cooler Secondary Air

EU 280 L5 Traveling Grate

EU 281 L5 Recoup System Air

EU 282 L5 Rotary Kiln

EU 283 L5 Pellet Cooler Secondary Air

MR 002 NOx & SO2 CEMS at Line 4 Waste Gas Stack (SV 118)

MR 003 NOx & SO2 CEMS at Line 5 Waste Gas Stack (SV 127)

SV 118 L4 Waste Gas Stack

SV 127 L5 Waste Gas Stack

NC/

CA Type Citation Requirement

CD hdr CONSTRUCTION AUTHORIZATION 1.0

CD Title I Condition: To avoid classification of changes as major

modifications under 40 CFR

Section 52.21 & Minn. R.

7007.3000 Construction Authorization for CE 181 and CE 182: The construction authorization expires 5 years after permit issuance. The Permittee must keep a record of the dates of installation and start-up on site. The Permittee may apply for an extension of the construction authorization deadline by following the Administrative

A mendment provisions in Minn. R. 7007.1400. 2.0

CD hdr A . POLLUTANT LIMITS 3.0

LIMIT Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 Nitrogen Oxides: less than or equal to 5000 lbs/hour using 24-hour Block Average from all five waste gas stacks combined (GP 009 through 011; SV 103, 118, 127, 144, and 151) at Permit Issuance. 4.0

LIMIT Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 Nitrogen Oxides: less than or equal to 13300 tons/year using 365-day Rolling Sum from all five waste gas stacks combined (GP 009 through 011; SV 103, 118, 127, 144, and 151) at Permit Issuance. Representative NOx emission data shall be used to demonstrate compliance for the first 365 days. 5.0

LIMIT Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 Nitrogen Oxides: less than or equal to 7300 tons/year using 365-day Rolling Sum from all five waste gas stacks combined (GP 009 through 011; SV 103, 118, 127, 144, and 151) no later than Feb. 1, 2010. 6.0

LIMIT Title I Condition: BACT emission limit, 40 CFR 52.21(j)(3); Minn. R.

7007.3000. Fluorides: less than or equal to 1.62 lbs/hour using 3-hour Average at Line 4 Waste Gas Stack (SV 118) and Line 5 Waste Gas Stack (SV 127), respectively. 7.0

LIMIT Title I Condition: BACT emission limit, 40 CFR 52.21(j)(3); Minn. R.

7007.3000. Carbon Monoxide: less than or equal to 98.6 lbs/hour using 3-hour Average at Line 4 Waste Gas Stack (SV 118) and Line 5 Waste Gas Stack (SV 127), respectively. 8.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 19 of 69

LIMIT Title I Condition: BACT emission limit, 40 CFR 52.21(j)(3); Minn. R.

7007.3000. Volatile Organic Compounds: less than or equal to 74.0 lbs/hour using 3-hour

A verage , as propane, at Line 4 Waste Gas Stack (SV 118) and Line 5 Waste Gas Stack (SV 127), respectively. 9.0

LIMIT Minn. R. 7011.0610, subp. 2(B)(1) Sulfur Dioxide: less than or equal to 2 lbs/million Btu heat input , if a liquid fossil

fuel is burned. 10.0

LIMIT Minn. R. 7011.0610, subp. 1(A)(1) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 11.0

LIMIT Minn. R. 7011.0610, subp. 1(A)(1); Minn. R. 7011.0715, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 12.0

LIMIT Minn. R. 7011.0610, subp. 1(A)(2) Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. 13.0

CD hdr B. OPERATION REQUIREMENTS

(Note - CEMS requirements can be found in Table A under Subject Item: Total Facility, Section F, and Subject Items MR 001 through MR 005; and in Table B) 14.0

CD Title I Condition: To address fuel options for the indurating process modification of 1987-1989, 40 CFR 52.21(j)(3); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 2 Fuel Restrictions: The Permittee shall combust at the kiln burner natural gas, fuel oil, and/or types of biomass that are specified in Appendix 1 of this permit; and at the preheat burners natural gas. Other fuels may be combusted for a short period of time during a trial burn as approved by an amendment to this permit. 15.0

LIMIT Minn. R. 7007.0800, subp. 2 Material Usage: less than or equal to 3000 gallons/month of fuel additive for

A gglomerator Lines 3, 4, 5, 6, and 7 (Groups 9, 10, and 11) combined. The Permittee shall maintain for at least three years a monthly record of fuel additive usage including brands and suppliers. 16.0

LIMIT Minn. R. 7007.0800, subp. 2 Material Usage: less than or equal to 16000 gallons/month of slag inhibitor for

A gglomerator Lines 3, 4, 5, 6, and 7 (Groups 9, 10, and 11) combined. The Permittee shall maintain for at least three years a monthly record of slag inhibitor usage including brands and suppliers. 17.0

CD Minn. R. 7007.0800, subp. 4(B) Material/Fuel Usage and Sulfur Content: The Permittee shall record the amount of materials and fuel consumed each day. The Permittee shall obtain and maintain a fuel supplier certification of the sulfur weight percent for each shipment of fuel or sample the fuel oil from multiple the tank(s) after each delivery but not more than once each calendar week when multiple deliveries are made. The Permittee shall sample materials entering the grate-kiln once each calendar week. The Permittee shall analyze the fuel and material samples to determine their sulfur content in pcercent by weight and fuel heating value in accordance with the current ASTM method. The Permittee shall maintain records of the fuel deliveries, material usage, and analyses results. 18.0

CD Title I Condition: To avoid classification as a major source

and modification under 40 CFR

Section 52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 and 14 The Permittee shall operate and maintain the scrubber (CE 103) at any time that the process equipment controlled by the scrubber (EU 261) is in operation. The Permittee shall document periods of non-operation of the control equipment. 19.0

CD Title I Condition: To avoid classification as a major source

and modification under 40 CFR

Section 52.21 and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 2 and 14 The Permittee shall operate and maintain the scrubber (CE 113) at any time that the process equipment controlled by the scrubber (EU 282) is in operation. The Permittee shall document periods of non-operation of the control equipment. 20.0

CD Minn. R. 7007.0800, subp. 14 The Permittee shall operate and maintain the scrubbers in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available for use by staff and MPCA staff. 21.0

CD hdr C. CONTROL EQUIPMENT MONITORING 22.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 20 of 69

CD Title I Condition: Monitoring for fluoride BACT, 40 CFR 52.21(j)(3); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 23.0

CD Title I Condition: Monitoring for fluoride BACT, 40 CFR 52.21(j)(3); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Liquid Flow Rate: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 24.0

CD Title I Condition: Monitoring for CO & VOC BACT, 40 CFR 52.21(j)(3); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Waste Gas to Heat Input Ratio: The Permittee shall calculate and record, for each hour when valid data are available, the ratio of SV 118 gas flow, as measured by CEMS in cubic feet per hour in standard conditions (scfh), to total heat input at kiln and grate burners of Line 4 in British Thermal Units per hour (Btu/hr); and, similarly, the ratio of SV 127 gas flow to total heat input of Line 5. The ratio will be used as an indicator to learn how complete CO & VOC are destroyed in each indurating

furnace. 25.0

CD hdr D. PERFORMANCE TESTING REQUIREMENTS 26.0

S/A Title I Condition: BACT emission limit, 40 CFR 52.21(j)(3); Minn. R.

7007.3000. Initial Performance Test: due 180 days after 12/22/2008 to measure Fluorides, CO, and VOC emissions at Line 4 Waste Gas Stack (SV 118) and Line 5 Waste Gas Stack (SV 127), respectively. 27.0

S/A Title I Condition: BACT emission limit, 40 CFR 52.21(j)(3); Minn. R.

7007.3000. Testing Frequency Plan: due 60 days after Initial Performance Test. For each of Lines 4 and 5, the plan shall specify a testing frequency for fluorides, CO, and VOC based on the test data and MPCA guidance. Future performance tests based on one-year (12-month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. 28.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 60 months starting 05/18/2005 on the stack that was not tested in the previous 60-month period to measure PM and Opacity emissions. 29.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 30.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 31.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 32.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 33.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 34.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 21 of 69

Subject Item: GP 011 Agglomeration Lines 6 & 7 (Action 007)

Associated Items: CE 123 Other

CE 124 Gravity Collector - High Efficiency

CE 125 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones

CE 126 Wet Scrubber-High Efficiency w/o Lime

CE 133 Other

CE 134 Gravity Collector - High Efficiency

CE 135 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones

CE 136 Wet Scrubber-High Efficiency w/o Lime

EU 313 L6 Traveling Grate

EU 314 L6 Recoup System Air

EU 315 L6 Rotary Kiln

EU 316 L6 Pellet Cooler Secondary Air

EU 332 L7 Traveling Grate

EU 333 L7 Recoup System Air

EU 334 L7 Rotary Kiln

EU 335 L7 Pellet Cooler Secondary Air

MR 004 NOx & SO2 CEMS at Line 6 Waste Gas Stack (SV 144)

MR 005 NOx & SO2 CEMS at Line 7 Waste Gas Stack (SV 151)

SV 144 L6 Waste Gas Stack

SV 151 L7 Waste Gas Stack

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 Nitrogen Oxides: less than or equal to 5000 lbs/hour using 24-hour Block Average from all five waste gas stacks combined (GP 009 through 011; SV 103, 118, 127, 144, and 151) at Permit Issuance. 2.0

LIMIT Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 Nitrogen Oxides: less than or equal to 13300 tons/year using 365-day Rolling Sum from all five waste gas stacks combined (GP 009 through 011; SV 103, 118, 127, 144, and 151) at Permit Issuance. Representative NOx emission data shall be used to demonstrate compliance for the first 365 days. 3.0

LIMIT Title I conditions: to mitigate adverse impacts on Class I areas visibility from pellet induration; 40 CFR 52.21 (p); Minn. R.

7007.3000 Nitrogen Oxides: less than or equal to 7300 tons/year using 365-day Rolling Sum from all five waste gas stacks combined (GP 009 through 011; SV 103, 118, 127, 144, and 151) no later than Feb. 1, 2010. 4.0

LIMIT Title I Condition: BACT emission limit, 40 CFR 52.21(j)(3); Minn. R.

7007.3000. Fluorides: less than or equal to 1.62 lbs/hour using 3-hour Average at Line 6 Waste Gas Stack (SV 144) and Line 7 Waste Gas Stack (SV 151), respectively. 5.0

LIMIT Title I Condition: BACT emission limit, 40 CFR 52.21(j)(3); Minn. R.

7007.3000. Carbon Monoxide: less than or equal to 74.0 lbs/hour using 3-hour Average at Line 6 Waste Gas Stack (SV 144) and Line 7 Waste Gas Stack (SV 151), respectively. 6.0

LIMIT Title I Condition: a 1997 action that avoided major classification

under 40 CFR 52.21 Carbon Monoxide: less than or equal to 99 tons/year using 12-month Rolling Sum for the combustion of wood waste (wood, wood bark, and sawdust) at Lines 6 and 7

combined. 7.0

LIMIT Title I Condition: BACT emission limit, 40 CFR 52.21(j)(3); Minn. R.

7007.3000. Volatile Organic Compounds: less than or equal to 54.3 lbs/hour using 3-hour

A verage , as propane, at Line 6 Waste Gas Stack (SV 144) and Line 7 Waste Gas Stack (SV 151), respectively. 8.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 22 of 69

LIMIT Title I Condition: a 1997 action that avoided major classification

under 40 CFR 52.21 Volatile Organic Compounds: less than or equal to 39 tons/year using 12-month Rolling Sum for the combustion of wood waste (wood, wood bark, and sawdust) at

Lines 6 and 7 combined. 9.0

LIMIT Minn. R. 7011.0610, subp. 1(A)(1) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 10.0

LIMIT Minn. R. 7011.0610, subp. 1(A)(1); Minn. R. 7011.0715, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 11.0

LIMIT Minn. R. 7011.0610, subp. 2(B)(1) Sulfur Dioxide: less than or equal to 2 lbs/million Btu heat input , if a liquid fossil fuel is burned; or less than or equal to 4 lbs/million Btu heat input, if a solid fossil

fuel is burned. 12.0

LIMIT Minn. R. 7011.0610, subp. 1(A)(2) Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. 13.0

CD hdr B. OPERATION REQUIREMENTS

(Note - CEMS requirements can be found in Table A under Subject Item: Total Facility, Section F, and Subject Items MR 001 through MR 005; and in Table B) 14.0

CD Title I Condition: To address fuel options for the indurating process modification of 1987-1989, 40 CFR 52.21(j)(3); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 2 Fuel Restrictions: The Permittee shall combust at the kiln burner natural gas, coal, fuel oil, and/or types of biomass that are specified in Appendix 1 of this permit; and at the preheat burners natural gas. Other fuels may be combusted for a short period of time during a trial burn as approved by an amendment to this permit. 15.0

CD Title I Condition: a 1997 action that avoided major classification

under 40 CFR 52.21 Heating Value and Usage of Wood Waste Fuel: a representative wood waste fuel sample shall be conllected and analyzed for heating value (Btu/lb) once each calendar quarter. The Permittee shall record, in tons/month, the amount of wood waste combusted in the kilns of this Group. 16.0

CD Title I Condition: a 1997 action that avoided major classification

under 40 CFR 52.21 CO and VOC Emission Factors: a performance test for CO and VOC shall be conducted, at either one or both kilns of this Group for at least once, to generate emission factors in lbs/million Btu for purpose of emission calculation for the combustion of wood waste (wood, wood bark, and sawdust). 17.0

LIMIT Minn. R. 7007.0800, subp. 2 Material Usage: less than or equal to 3000 gallons/month of fuel additive for

A gglomerator Lines 3, 4, 5, 6, and 7 (Groups 9, 10, and 11) combined. The Permittee shall maintain for at least three years a monthly record of fuel additive usage including brands and suppliers. 18.0

LIMIT Minn. R. 7007.0800, subp. 2 Material Usage: less than or equal to 16000 gallons/month of slag inhibitor for

A gglomerator Lines 3, 4, 5, 6, and 7 (Groups 9, 10, and 11) combined. The Permittee shall maintain for at least three years a monthly record of slag inhibitor usage including brands and suppliers. 19.0

CD Minn. R. 7007.0800, subp. 4(B) Material/Fuel Usage and Sulfur Content: The Permittee shall record the amount of materials and fuel consumed each day. The Permittee shall obtain and maintain a fuel supplier certification of the sulfur weight percent for each shipment of fuel or sample the fuel oil from multiple the tank(s) after each delivery but not more than once each calendar week when multiple deliveries are made. The Permittee shall sample other fuels and materials entering the grate-kiln once each calendar week. The Permittee shall analyze the fuel and material samples to determine their sulfur content in pcercent by weight and fuel heating value in accordance with the current

A STM method. The Permittee shall maintain records of the fuel deliveries, material usage, and analyses results. 20.0

CD hdr C. CONTROL EQUIPMENT MONITORING 21.0

CD Title I Condition: Monitoring for fluoride BACT, 40 CFR 52.21(j)(3); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 22.0

CD Title I Condition: Monitoring for fluoride BACT, 40 CFR 52.21(j)(3); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Liquid Flow Rate: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 23.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 23 of 69

CD Title I Condition: Monitoring for CO & VOC BACT, 40 CFR 52.21(j)(3); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Waste Gas to Heat Input Ratio: The Permittee shall calculate and record, for each hour when valid data are available, the ratio of SV 144 gas flow, as measured by CEMS in cubic feet per hour in standard conditions (scfh), to total heat input at kiln and grate burners of Line 6 in British Thermal Units per hour (Btu/hr); and, similarly, the ratio of SV 151 gas flow to total heat input of Line 7. The ratio will be used as an indicator to learn how complete CO & VOC are destroyed in each indurating

furnace. 24.0

CD hdr D. PERFORMANCE TESTING REQUIREMENTS 25.0

S/A Title I Condition: BACT emission limit, 40 CFR 52.21(j)(3); Minn. R.

7007.3000. Initial Performance Test: due 180 days after 12/22/2008 to measure Fluorides, CO, and VOC emissions at Line 6 Waste Gas Stack (SV 144) and Line 7 Waste Gas Stack (SV 151), respectively. 26.0

S/A Title I Condition: BACT emission limit, 40 CFR 52.21(j)(3); Minn. R.

7007.3000. Testing Frequency Plan: due 60 days after Initial Performance Test. For each of Lines 6 and 7, the plan shall specify a testing frequency for fluorides, CO, and VOC based on the test data and MPCA guidance. Future performance tests based on one-year (12-month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. 27.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 60 months starting 04/20/2005 on the stack that was not tested in the previous 60-month period to measure PM and Opacity emissions. 28.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 29.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 30.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 31.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 32.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 33.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 24 of 69

Subject Item: GP 012 Pre-1969 ore transfer points around crushers

Associated Items: CE 001 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 008 Wet Scrubber-High Efficiency w/o Lime

CE 010 Wet Scrubber-High Efficiency w/o Lime

CE 016 Wet Scrubber-High Efficiency w/o Lime

CE 021 Wet Scrubber-High Efficiency w/o Lime

CE 022 Wet Scrubber-High Efficiency w/o Lime

CE 047 Wet Scrubber-High Efficiency w/o Lime

EU 013 Step I Coarse Crusher

EU 014 Step I Coarse Crusher

EU 034 Conveyor Transfer 005-006

EU 035 Conveyor Transfer 005-006

EU 040 Conveyor Transfer 005-006

EU 052 Conveyor Transfer 008 to 009

EU 053 Conveyor Transfer 008 to 009

EU 058 Conveyor Transfer 005 to 006

EU 059 Conveyor Transfer 005 to 006

EU 060 Conveyor Transfer 005 to 006

EU 061 Conveyor Transfer 003 to 004

EU 062 Conveyor Transfer 003 to 004

EU 063 Conveyor Transfer 003 to 004

EU 064 Conveyor Transfer 003 to 004

EU 065 Tertiary Storage Bin 1-4

EU 066 Tertiary Storage Bin 1-4

EU 067 Tertiary Storage Bin 1-4

EU 102 Storage Bin 070-02

SV 013 Step I Coarse Crusher

SV 021 Conveyor Transfer 005-006

SV 023 Conveyor Transfer 005-006

SV 030 Conveyor Transfer 008-009

SV 035 Conveyor Transfer 005-006

SV 036 Conveyor Transfer 003-004

SV 037 Tertiary Storage Bins 1-4

SV 061 Storage Bin 070-02

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0710, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 2.0

LIMIT Minn. R. 7011.0710, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 3.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 25 of 69

LIMIT Minn. R. 7011.0710, subp. 1(B) Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. 4.0

CD hdr B. CONTROL EQUIPMENT MONITORING 5.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 6.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Liquid Flow Rate for Wet Scrubbers: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 7.0

CD Minn. R. 7007.0800, subp. 4(D); 14; 16(J) Process Monitoring: the visual emissions observer in the facility staff shall check stack visible emissions (opacity) for SV 013 (CE 001) once daily using a checklist that at a minimum contains the information required in Appendix B. If the Permittee uses for CE 001 a broken bag detector approved by the MPCA, the Permittee does

not need to conduct visible emissions checks for SV 013. 8.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 9.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 730 days after 12/22/2008 on one stack to measure

PM emission. 10.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 60 months following Initial Performance Test on one stack that was not tested in the previous 60-month period to measure

PM emission. 11.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 12.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 13.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 14.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 15.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 16.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 26 of 69

Subject Item: GP 013 Post-1969 ore transfer points around crushers

Associated Items: CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 003 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 006 Wet Scrubber-High Efficiency w/o Lime

CE 007 Wet Scrubber-High Efficiency w/o Lime

CE 009 Wet Scrubber-High Efficiency w/o Lime

CE 011 Wet Scrubber-High Efficiency w/o Lime

CE 012 Wet Scrubber-High Efficiency w/o Lime

CE 013 Wet Scrubber-High Efficiency w/o Lime

CE 023 Wet Scrubber-High Efficiency w/o Lime

CE 040 Wet Scrubber-High Efficiency w/o Lime

EU 015 Step II Coarse Crusher

EU 016 Step II Coarse Crusher

EU 017 Step III Coarse Crusher & Lime Dump

EU 018 Step III Coarse Crusher & Lime Dump

EU 019 Step III Coarse Crusher & Lime Dump

EU 020 Step III Coarse Crusher & Lime Dump

EU 026 Step III Coarse Crusher Pan Feeders & Lime Transfer

EU 027 Step III Coarse Crusher Pan Feeders & Lime Transfer

EU 036 Conveyor Transfer 010-01

EU 037 Conveyor Transfer 010-01

EU 038 Conveyor Transfer 010-01

EU 039 Conveyor Transfer 010-01

EU 041 Conveyor Transfer 004-005

EU 042 Conveyor Transfer 004-005

EU 043 Conveyor Transfer 004-005

EU 044 Conveyor Transfer 004-005

EU 045 Conveyor Transfer 004-005

EU 046 Conveyor Transfer 004-005

EU 047 Conveyor Transfer 011-02/03

EU 048 Surge Pile/Reclaim 011-01

EU 068 Tertiary Storage Bin 1-4

EU 085 Tertiary Crusher 080 Bins 5-8

EU 086 Tertiary Crusher 080 Bins 5-8

EU 087 Tertiary Crusher 080 Bins 5-8

EU 088 Tertiary Crusher 080 Bins 5-8

EU 089 Tertiary Crusher 080 Bins 5-8

EU 090 Tertiary Crusher 080 Bins 5-8

EU 091 Tertiary Crusher 080 Bins 5-8

EU 092 Tertiary Crusher 080 Bins 5-8

SV 014 Step II Coarse Crusher

SV 015 Step III Coarse Crusher

SV 018 Step III Coarse Crusher Pan Feeders

SV 022 Conveyor Transfer 010-01MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 27 of 69

Associated Items: SV 024 Conveyor Transfer 004-005

SV 025 Conveyor Transfer 011-02/03

SV 026 Surge Pile/Reclaim 011-01

SV 037 Tertiary Storage Bins 1-4

SV 054 Tertiary Crusher 080 5-8 Bins

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 2.0

LIMIT Minn. R. 7011.0715, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 3.0

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity 4.0

CD hdr B. CONTROL EQUIPMENT MONITORING 5.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 6.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Liquid Flow Rate for Wet Scrubbers: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 7.0

CD Minn. R. 7007.0800, subp. 4(D); 14; 16(J) Process Monitoring: the visual emissions observer in the facility staff shall check stack visible emissions (opacity) for SV 014 (CE 002) and SV 015 (CE 003) once daily using a checklist that at a minimum contains the information required in

A ppendix B. If the Permittee uses for a control device a broken bag detector approved by the MPCA, the Permittee does not need to conduct visible emissions checks for the stack associated with the control device in this group. 8.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 9.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 730 days after 11/30/2004 on SV 054 and another

stack to measure PM emission. 10.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 60 months following Initial Performance Test on one stack that was not tested in the previous 60-month period to measure

PM emission. 11.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 12.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 13.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 14.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 15.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 16.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 28 of 69

Subject Item: GP 014 Pre-1969 secondary crushers

Associated Items: CE 017 Wet Scrubber-High Efficiency w/o Lime

CE 018 Wet Scrubber-High Efficiency w/o Lime

CE 019 Wet Scrubber-High Efficiency w/o Lime

CE 020 Wet Scrubber-High Efficiency w/o Lime

EU 054 Secondary Crusher L1

EU 055 Secondary Crusher L2

EU 056 Secondary Crusher L3

EU 057 Secondary Crusher L4

SV 031 Secondary Crusher L1

SV 032 Secondary Crusher L2

SV 033 Secondary Crusher L3

SV 034 Secondary Crusher L4

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0710, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 2.0

LIMIT Minn. R. 7011.0710, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 3.0

LIMIT Minn. R. 7011.0710, subp. 1(B) Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. 4.0

CD hdr B. CONTROL EQUIPMENT MONITORING 5.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 6.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Liquid Flow Rate: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 7.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 8.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 180 days after 11/07/2003 on one stack to measure

PM emission. 9.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on one-year (12 month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. 10.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 11.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 12.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 13.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 14.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 15.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 29 of 69

Subject Item: GP 015 Pre-1969 tertiary crushers

Associated Items: CE 024 Wet Scrubber-High Efficiency w/o Lime

CE 025 Wet Scrubber-High Efficiency w/o Lime

CE 026 Wet Scrubber-High Efficiency w/o Lime

CE 027 Wet Scrubber-High Efficiency w/o Lime

CE 028 Wet Scrubber-High Efficiency w/o Lime

CE 029 Wet Scrubber-High Efficiency w/o Lime

EU 069 Tertiary Crusher L1

EU 070 Tertiary Crusher L2

EU 071 Tertiary Crusher L3

EU 072 Tertiary Crusher L4

EU 073 Tertiary Crusher L5

EU 074 Tertiary Crusher L6

SV 038 Tertiary Crusher L1

SV 039 Tertiary Crusher L2

SV 040 Tertiary Crusher L3

SV 041 Tertiary Crusher L4

SV 042 Tertiary Crusher L5

SV 043 Tertiary Crusher L6

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0710, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 2.0

LIMIT Minn. R. 7011.0710, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 3.0

LIMIT Minn. R. 7011.0710, subp. 1(B) Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. 4.0

CD hdr B. CONTROL EQUIPMENT MONITORING 5.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 6.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Liquid Flow Rate: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 7.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 8.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 365 days after 11/30/2004 on one stack to measure

PM emission. 9.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on one-year (12 month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. 10.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 11.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 12.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 30 of 69

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 13.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 14.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 15.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 31 of 69

Subject Item: GP 016 Post-1969 secondary crushers

Associated Items: CE 041 Wet Scrubber-High Efficiency w/o Lime

CE 042 Wet Scrubber-High Efficiency w/o Lime

CE 043 Wet Scrubber-High Efficiency w/o Lime

CE 044 Wet Scrubber-High Efficiency w/o Lime

CE 045 Wet Scrubber-High Efficiency w/o Lime

CE 048 Wet Scrubber-High Efficiency w/o Lime

CE 050 Wet Scrubber-High Efficiency w/o Lime

CE 051 Wet Scrubber-High Efficiency w/o Lime

CE 052 Wet Scrubber-High Efficiency w/o Lime

CE 053 Wet Scrubber-High Efficiency w/o Lime

CE 054 Wet Scrubber-High Efficiency w/o Lime

EU 093 Secondary Crusher L6

EU 094 Secondary Crusher L7

EU 095 Secondary Crusher L8

EU 096 Secondary Crusher L9

EU 097 Secondary Crusher L10

EU 103 Secondary Crusher L5

EU 106 Secondary Crusher L11

EU 107 Secondary Crusher L12

EU 108 Secondary Crusher L13

EU 109 Secondary Crusher L14

EU 110 Secondary Crusher L15

SV 055 Secondary Crusher L6

SV 056 Secondary Crusher L7

SV 057 Secondary Crusher L8

SV 058 Secondary Crusher L9

SV 059 Secondary Crusher L10

SV 062 Secondary Crusher L5

SV 064 Secondary Crusher L11

SV 065 Secondary Crusher L12

SV 066 Secondary Crusher L13

SV 067 Secondary Crusher L14

SV 068 Secondary Crusher L15

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 2.0

LIMIT Minn. R. 7011.0715, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 3.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 32 of 69

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity 4.0

CD hdr B. CONTROL EQUIPMENT MONITORING 5.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: M Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 6.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Liquid Flow Rate: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 7.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 8.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 730 days after 11/07/2003 on one stack to measure

PM emission. 9.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on one-year (12 month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. 10.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 11.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 12.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 13.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 14.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 15.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 33 of 69

Subject Item: GP 017 Post-1969 ore transfer for fine crushers

Associated Items: CE 046 Wet Scrubber-High Efficiency w/o Lime

CE 049 Wet Scrubber-High Efficiency w/o Lime

CE 055 Wet Scrubber-High Efficiency w/o Lime

CE 056 Wet Scrubber-High Efficiency w/o Lime

CE 057 Wet Scrubber-High Efficiency w/o Lime

CE 058 Wet Scrubber-High Efficiency w/o Lime

CE 071 Wet Scrubber-High Efficiency w/o Lime

EU 098 Conveyor Transfer 008 to 009

EU 099 Conveyor Transfer 008 to 009

EU 100 Conveyor Transfer 008 to 009

EU 101 Conveyor Transfer 008 to 009

EU 104 Conveyor Transfer 008-009

EU 105 Conveyor Transfer 008-009

EU 111 Conveyor Transfer 001-070 Bin

EU 112 Conveyor Transfer 003

EU 113 Conveyor Transfer 003

EU 114 Conveyor Transfer 003-004

EU 115 Conveyor Transfer 003-004

EU 116 Tertiary Storage 006-080 Bin

EU 117 Tertiary Storage 006-080 Bin

EU 118 Tertiary Storage 006-080 Bin

EU 119 Tertiary Storage 006-080 Bin

EU 120 Tertiary Storage 006-080 Bin

EU 121 Tertiary Storage 006-080 Bin

EU 122 Tertiary Storage 006-080 Bin

EU 123 Tertiary Storage 006-080 Bin

EU 124 Tertiary Storage 006-080 Bin

EU 125 Tertiary Storage 006-080 Bin

EU 126 Tertiary Storage 006-080 Bin

EU 127 Tertiary Storage 006-080 Bin

EU 140 Conveyor Transfer 005-006

EU 141 Conveyor Transfer 005-006

SV 060 Conveyor Transfer 008-009

SV 063 Conveyor Transfer 008-009

SV 069 Conveyor Transfer 001-070 Bin

SV 070 Conveyor Transfer 003

SV 071 Conveyor Transfer 003-004

SV 072 Tertiary Storage 006-080 Bins

SV 085 Conveyor Transfer 005-006

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 34 of 69

LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 2.0

LIMIT Minn. R. 7011.0715, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 3.0

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity 4.0

CD hdr B. CONTROL EQUIPMENT MONITORING 5.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: Monitor and record as least once every day when in operation, once the pressure gauge is installed for each piece of control equipment in this group. Complete pressure drop monitoring equipment debugging, trouble-shooting, and establishment of parameter range within 180 days of

installation. 6.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Liquid Flow Rate: Monitor and record as least once every day when in operation, once the monitoring equipment is installed for each piece of wet scrubbers in this group. Complete monitoring equipment debugging, trouble-shooting, and establishment of parameter range within 180 days of installation. 7.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 8.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 730 days after 11/30/2004 on two stacks to measure

PM emission. 9.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 60 months following Initial Performance Test on two stacks that were not tested in the previous 60-month period to measure

PM emission. 10.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 11.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 12.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 13.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 14.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 15.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 35 of 69

Subject Item: GP 018 Post-1969 tertiary crushers

Associated Items: CE 030 Wet Scrubber-High Efficiency w/o Lime

CE 031 Wet Scrubber-High Efficiency w/o Lime

CE 032 Wet Scrubber-High Efficiency w/o Lime

CE 033 Wet Scrubber-High Efficiency w/o Lime

CE 034 Wet Scrubber-High Efficiency w/o Lime

CE 035 Wet Scrubber-High Efficiency w/o Lime

CE 036 Wet Scrubber-High Efficiency w/o Lime

CE 037 Wet Scrubber-High Efficiency w/o Lime

CE 038 Wet Scrubber-High Efficiency w/o Lime

CE 039 Wet Scrubber-High Efficiency w/o Lime

CE 059 Wet Scrubber-High Efficiency w/o Lime

CE 060 Wet Scrubber-High Efficiency w/o Lime

CE 061 Wet Scrubber-High Efficiency w/o Lime

CE 062 Wet Scrubber-High Efficiency w/o Lime

CE 063 Wet Scrubber-High Efficiency w/o Lime

CE 064 Wet Scrubber-High Efficiency w/o Lime

CE 065 Wet Scrubber-High Efficiency w/o Lime

CE 066 Wet Scrubber-High Efficiency w/o Lime

CE 067 Wet Scrubber-High Efficiency w/o Lime

CE 068 Wet Scrubber-High Efficiency w/o Lime

CE 069 Wet Scrubber-High Efficiency w/o Lime

EU 075 Tertiary Crusher L7

EU 076 Tertiary Crusher L8

EU 077 Tertiary Crusher L9

EU 078 Tertiary Crusher L10

EU 079 Tertiary Crusher L11

EU 080 Tertiary Crusher L12

EU 081 Tertiary Crusher L13

EU 082 Tertiary Crusher L14

EU 083 Tertiary Crusher L15

EU 084 Tertiary Crusher L16

EU 128 Tertiary Crusher L18

EU 129 Tertiary Crusher L19

EU 130 Tertiary Crusher L20

EU 131 Tertiary Crusher L21

EU 132 Tertiary Crusher L22

EU 133 Tertiary Crusher L23

EU 134 Tertiary Crusher L24

EU 135 Tertiary Crusher L25

EU 136 Tertiary Crusher L26

EU 137 Tertiary Crusher L27

EU 138 Tertiary Crusher L28

SV 044 Tertiary Crusher L7MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 36 of 69

Associated Items: SV 045 Tertiary Crusher L8

SV 046 Tertiary Crusher L9

SV 047 Tertiary Crusher L10

SV 048 Tertiary Crusher L11

SV 049 Tertiary Crusher L12

SV 050 Tertiary Crusher L13

SV 051 Tertiary Crusher L14

SV 052 Tertiary Crusher L15

SV 053 Tertiary Crusher L16

SV 073 Tertiary Crusher L18

SV 074 Tertiary Crusher L19

SV 075 Tertiary Crusher L20

SV 076 Tertiary Crusher L21

SV 077 Tertiary Crusher L22

SV 078 Tertiary Crusher L23

SV 079 Tertiary Crusher L24

SV 080 Tertiary Crusher L25

SV 081 Tertiary Crusher L26

SV 082 Tertiary Crusher L27

SV 083 Tertiary Crusher L28

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 2.0

LIMIT Minn. R. 7011.0715, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 3.0

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity 4.0

CD hdr B. CONTROL EQUIPMENT MONITORING 5.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 6.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Liquid Flow Rate: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 7.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 8.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 730 days after 11/30/2004 on three stacks to

measure PM emission. 9.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 60 months following Initial Performance Test on two stacks that were not tested in the previous 60-month period to measure

PM emission. 10.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 11.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 12.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 37 of 69

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 13.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 14.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 15.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 38 of 69

Subject Item: GP 019 Pre-1969 ore transfer to bins

Associated Items: CE 073 Wet Scrubber-High Efficiency w/o Lime

CE 074 Wet Scrubber-High Efficiency w/o Lime

CE 075 Wet Scrubber-High Efficiency w/o Lime

EU 144 Conveyor Transfer 009-020

EU 145 Conveyor Transfer 009-020

EU 148 Storage Bin L1,2

EU 149 Storage Bin L1,2

EU 150 Storage Bin L1,2

EU 151 Storage Bin L1,2

EU 152 Storage Bin L1,2

EU 153 Storage Bin L1,2

EU 154 Storage Bin L1,2

EU 155 Storage Bin L3,4

EU 156 Storage Bin L3,4

EU 157 Storage Bin L3,4

EU 158 Storage Bin L3,4

EU 159 Storage Bin L3,4

EU 160 Storage Bin L3,4

EU 161 Storage Bin L3,4

EU 162 Storage Bin L5,6

EU 163 Storage Bin L5,6

EU 164 Storage Bin L5,6

EU 165 Storage Bin L5,6

EU 166 Storage Bin L5,6

EU 167 Storage Bin L5,6

EU 168 Storage Bin L5,6

SV 088 Storage Bin L1, 2

SV 089 Storage Bin L3, 4

SV 090 Storage Bin L5, 6

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0710, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 2.0

LIMIT Minn. R. 7011.0710, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 3.0

LIMIT Minn. R. 7011.0710, subp. 1(B) Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. 4.0

CD hdr B. CONTROL EQUIPMENT MONITORING 5.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 39 of 69

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 6.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Liquid Flow Rate: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 7.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 8.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 180 days after 11/07/2003 on two stacks to measure PM emission, and on all stacks to measure Opacity emission. 9.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on one-year (12 month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. 10.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 11.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 12.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 13.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 14.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 15.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 40 of 69

Subject Item: GP 020 Post-1969 ore transfer to bins

Associated Items: CE 072 Wet Scrubber-High Efficiency w/o Lime

CE 076 Wet Scrubber-High Efficiency w/o Lime

CE 077 Wet Scrubber-High Efficiency w/o Lime

CE 078 Wet Scrubber-High Efficiency w/o Lime

CE 079 Wet Scrubber-High Efficiency w/o Lime

CE 080 Wet Scrubber-High Efficiency w/o Lime

CE 081 Wet Scrubber-High Efficiency w/o Lime

CE 082 Wet Scrubber-High Efficiency w/o Lime

EU 146 Conveyor Transfer 009-020

EU 147 Conveyor Transfer 009-020

EU 169 Storage Bin L7,8

EU 170 Storage Bin L7,8

EU 171 Storage Bin L7,8

EU 172 Storage Bin L7,8

EU 173 Storage Bin L7,8

EU 174 Storage Bin L7,8

EU 175 Storage Bin L7,8

EU 176 Storage Bin L9,10

EU 177 Storage Bin L9,10

EU 178 Storage Bin L9,10

EU 179 Storage Bin L9,10

EU 180 Storage Bin L9,10

EU 181 Storage Bin L9,10

EU 182 Storage Bin L9,10

EU 183 Storage Bin L11,12

EU 184 Storage Bin L11,12

EU 185 Storage Bin L11,12

EU 186 Storage Bin L11,12

EU 187 Storage Bin L11,12

EU 188 Storage Bin L11,12

EU 189 Storage Bin L11,12

EU 190 Conveyor Transfer 009-020

EU 191 Conveyor Transfer 009-020

EU 192 Conveyor Transfer 009-020

EU 193 Conveyor Transfer 009-020

EU 194 Storage Bin L13,14

EU 195 Storage Bin L13,14

EU 196 Storage Bin L13,14

EU 197 Storage Bin L13,14

EU 198 Storage Bin L13,14

EU 199 Storage Bin L13,14

EU 200 Storage Bin L13,14

EU 201 Storage Bin L15,16MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 41 of 69

Associated Items: EU 202 Storage Bin L15,16

EU 203 Storage Bin L15,16

EU 204 Storage Bin L15,16

EU 205 Storage Bin L15,16

EU 206 Storage Bin L15,16

EU 207 Storage Bin L15,16

EU 208 Storage Bin L17,18

EU 209 Storage Bin L17,18

EU 210 Storage Bin L17,18

EU 211 Storage Bin L17,18

EU 212 Storage Bin L17,18

EU 213 Storage Bin L17,18

EU 214 Storage Bin L17,18

SV 087 Conveyor Transfer 009-020

SV 091 Storage Bin L7, 8

SV 092 Storage Bin L9, 10

SV 093 Storage Bin L11, 12

SV 094 Conveyor Transfer 009-020

SV 095 Storage Bin L13, 14

SV 096 Storage Bin L15, 16

SV 097 Storage Bin L17, 18

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 2.0

LIMIT Minn. R. 7011.0715, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 3.0

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity 4.0

CD hdr B. CONTROL EQUIPMENT MONITORING 5.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 6.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Liquid Flow Rate: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 7.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 8.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 730 days after 11/30/2004 on two stacks to measure PM emission, and on all stacks to measure Opacity emission. 9.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each 60 months following Initial Performance Test on two stacks that were not tested in the previous 60-month period to measure PM emission, and on all stacks to measure Opacity emission. 10.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 11.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 42 of 69

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 12.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 13.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 14.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 15.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 43 of 69

Subject Item: GP 021 Pre-1969 mixing & pellet handling for Step I

Associated Items: CE 083 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 084 Wet Scrubber-High Efficiency w/o Lime

CE 085 Wet Scrubber-High Efficiency w/o Lime

CE 089 Wet Scrubber-High Efficiency w/o Lime

CE 090 Wet Scrubber-High Efficiency w/o Lime

CE 091 Wet Scrubber-High Efficiency w/o Lime

CE 092 Wet Scrubber-High Efficiency w/o Lime

EU 217 L3 Bentonite Blending

EU 218 L3 Bentonite Blending

EU 219 L3 Bentonite Blending

EU 220 L3 Bentonite Blending

EU 221 L3 Grate Feed

EU 222 L3 Grate Discharge

EU 228 L3 Cooler Discharge

EU 229 L3 Feeder 041/046 Belts

EU 230 L3 041/046 Conveyor Belt Vent

EU 231 L3 041/046 Conveyor Belt Vent

EU 232 S1 Conveyor Transfer 042-043

EU 233 S1 Conveyor Transfer 042-043

EU 234 L3 Conveyor Transfer 041-042

EU 235 L3 Conveyor Transfer 041-042

SV 101 L3 Grate Feed

SV 102 L3 Grate Discharge

SV 105 L3 Cooler Dump Zone

SV 106 L3 Feeder 041, 046 Belts

SV 107 L3 041/046 Conveyor Belt Vent

SV 108 S1 Conveyor Transfer 042-043

SV 109 L1 Conveyor Transfer 041-042

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0710, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 2.0

LIMIT Minn. R. 7011.0710, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 3.0

LIMIT Minn. R. 7011.0710, subp. 1(B) Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. 4.0

CD hdr B. CONTROL EQUIPMENT MONITORING 5.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 44 of 69

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: Monitor and record as least once every day when in operation, once the pressure gauge is installed for each piece of control equipment in this group. Complete pressure drop monitoring equipment debugging, trouble-shooting, and establishment of parameter range within 180 days of

installation. 6.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Liquid Flow Rate for Wet Scrubbers: Monitor and record as least once every day when in operation, once the monitoring equipment is installed for each piece of wet scrubbers in this group. Complete monitoring equipment debugging, trouble-shooting, and establishment of parameter range within 180 days of

installation. 7.0

CD Minn. R. 7007.0800, subp. 4(D); 14; 16(J) Process Monitoring: the visual emissions observer in the facility staff shall check stack visible emissions (opacity) for SV 100 (CE 083) once daily using a checklist that at a minimum contains the information required in Appendix B. If the Permittee uses for CE 083 a broken bag detector approved by the MPCA, the Permittee does

not need to conduct visible emissions checks for SV 100. 8.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 9.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 365 days after 11/07/2003 on SV 105 and another stack to measure PM and Opacity emissions. 10.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on one-year (12 month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. 11.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 12.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 13.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 14.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 15.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 16.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 45 of 69

Subject Item: GP 022 Post-1969 cooler vent stacks for Steps II & III

Associated Items: EU 263 L4 Pellet Cooler Vent Stack

EU 284 L5 Pellet Cooler Vent Stack

EU 397 L6 Pellet Cooler Vent Stack

EU 398 L7 Pellet Cooler Vent Stack

SV 119 L4 Cooler Vent Stack

SV 128 L5 Cooler Vent Stack

SV 196 L6 Pellet Cooler Stack

SV 197 L7 Pellet Cooler Stack

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735. 2.0

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity 3.0

CD hdr B. OPERATION REQUIREMENTS 4.0

CD Minn. R. 7007.0800, subp. 4(D); 14; 16(J) Process Monitoring: the visual emissions observer in the facility staff shall check stack visible emissions (opacity) once daily using a checklist that at a minimum contains the information required in Appendix B. 5.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 6.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 365 days after 11/30/2004 on all stacks to measure PM and Opacity emissions. 7.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each year following Initial Performance Test on all stacks to measure PM and Opacity emissions. After at least three years of performance testing data are submitted, the Permittee may request that future testing be scheduled according to a test frequency plan proposed based on submitted testing data. 8.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 9.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 10.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 11.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 12.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 13.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 46 of 69

Subject Item: GP 023 Pre-1969 bentonite equipment

Associated Items: CE 093 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 094 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 095 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

EU 236 S1 Bentonite Storage Bin

EU 237 S1 Bentonite Storage Bin

EU 238 S1 Bentonite Storage Bin

EU 239 L2,3 Bentonite Day Bin

EU 240 L2,3 Bentonite Day Bin

EU 241 L2,3 Bentonite Day Bin

EU 242 L2,3 Bentonite Day Bin

EU 243 S1,2 Bentonite Unloading

SV 110 S1 Bentonite Storage Bin

SV 111 L2, 3 Bentonite Day Bin

SV 112 S1, 2 Bentonite Unloading

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0710, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 2.0

LIMIT Minn. R. 7011.0710, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 3.0

LIMIT Minn. R. 7011.0710, subp. 1(B) Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. 4.0

CD hdr B. CONTROL EQUIPMENT MONITORING 5.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: Monitor and record as least once every day when in operation, once the pressure gauge is installed for each piece of control equipment in this group. Complete pressure drop monitoring equipment debugging, trouble-shooting, and establishment of parameter range within 180 days of

installation. 6.0

CD Minn. R. 7007.0800, subp. 4(D); 14; 16(J) Process Monitoring: the visual emissions observer in the facility staff shall check stack visible emissions (opacity) once daily using a checklist that at a minimum contains the information required in Appendix B. If the Permittee uses for a control device a broken bag detector approved by the MPCA, the Permittee does not need

to conduct visible emissions checks for the stack associated with the control device in this group. 7.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 8.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 730 days after 11/07/2003 on one stack to measure PM emission, and on all stacks to measure Opacity emission. 9.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on one-year (12 month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. 10.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 11.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 12.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 13.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 14.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 47 of 69

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 15.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 48 of 69

Subject Item: GP 024 Post-1969 bentonite equipment

Associated Items: CE 096 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 097 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 107 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 118 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 119 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 129 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 142 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

EU 244 S2 Bentonite Storage Bin

EU 245 S2 Bentonite Storage Bin

EU 246 S2 Bentonite Storage Bin

EU 247 L4 Bentonite Day Bins

EU 248 L4 Bentonite Day Bins

EU 249 L4 Bentonite Day Bins

EU 250 L4 Bentonite Day Bins

EU 251 L4 Bentonite Day Bins

EU 268 L5 Bentonite Day Bins

EU 269 L5 Bentonite Day Bins

EU 270 L5 Bentonite Day Bins

EU 271 L5 Bentonite Day Bins

EU 272 L5 Bentonite Day Bins

EU 297 S3 Bentonite Storage

EU 298 S3 Bentonite Storage

EU 299 S3 Bentonite Storage

EU 300 S3 Ben storage+unloading hopper

EU 301 L6 Bentonite Day Bin

EU 302 L6 Bentonite Day Bin

EU 303 L6 Bentonite Day Bin

EU 304 L6 Bentonite Day Bin

EU 305 L6 Bentonite Day Bin

EU 320 L7 Bentonite Day Bin

EU 321 L7 Bentonite Day Bin

EU 322 L7 Bentonite Day Bin

EU 323 L7 Bentonite Day Bin

EU 324 L7 Bentonite Day Bin

SV 113 S2 Bentonite Storage Bin

SV 114 L4 Bentonite Day Bin

SV 123 L5 Bentonite Day Bin

SV 139 S3 Bentonite Storage

SV 140 L6 Bentonite Day Bin

SV 147 L7 Bentonite Day Bin

SV 193 Step III Bentonite Storage BaghouseMINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 49 of 69

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 2.0

LIMIT Minn. R. 7011.0715, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 3.0

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity 4.0

CD hdr B. CONTROL EQUIPMENT MONITORING 5.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: Upon installation of monitoring equipment, monitor and record at least once every day when in operation. Once the operating range is established it becomes an enforceable part of this permit. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 6.0

CD Minn. R. 7007.0800, subp. 4(D); 14; 16(J) Process Monitoring: the visual emissions observer in the facility staff shall check stack visible emissions (opacity) once daily using a checklist that at a minimum contains the information required in Appendix B. If the Permittee uses for a control device a broken bag detector approved by the MPCA, the Permittee does not need

to conduct visible emissions checks for the stack associated with the control device in this group. 7.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 8.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 730 days after 11/07/2003 on one stack to measure PM emission, and on all stacks to measure Opacity emission. 9.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on one-year (12 month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. 10.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 11.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 12.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 13.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 14.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 15.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 50 of 69

Subject Item: GP 025 Post-1969 mixers for Steps II & III

Associated Items: CE 098 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 099 Wet Scrubber-High Efficiency w/o Lime

CE 100 Wet Scrubber-High Efficiency w/o Lime

CE 108 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 109 Wet Scrubber-High Efficiency w/o Lime

CE 110 Wet Scrubber-High Efficiency w/o Lime

CE 120 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 121 Wet Scrubber-High Efficiency w/o Lime

CE 122 Wet Scrubber-High Efficiency w/o Lime

CE 130 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

CE 131 Wet Scrubber-High Efficiency w/o Lime

CE 132 Wet Scrubber-High Efficiency w/o Lime

EU 252 L4 Bentonite Blending

EU 253 L4 Bentonite Blending

EU 254 L4 Bentonite Blending

EU 255 L4 Bentonite Blending

EU 256 L4 Bentonite Blending

EU 257 L4 Grate Feed

EU 258 L4 Grate Discharge

EU 273 L5 Bentonite Blending

EU 274 L5 Bentonite Blending

EU 275 L5 Bentonite Blending

EU 276 L5 Bentonite Blending

EU 277 L5 Bentonite Blending

EU 278 L5 Grate Feed

EU 279 L5 Grate Discharge

EU 306 L6 Bentonite Blending

EU 307 L6 Bentonite Blending

EU 308 L6 Bentonite Blending

EU 309 L6 Bentonite Blending

EU 310 L6 Bentonite Blending

EU 311 L6 Grate Feed

EU 312 L6 Grate Discharge

EU 325 L7 Bentonite Blending

EU 326 L7 Bentonite Blending

EU 327 L7 Bentonite Blending

EU 328 L7 Bentonite Blending

EU 329 L7 Bentonite Blending

EU 330 L7 Grate Feed

EU 331 L7 Grate Discharge

SV 115 L4 Bentonite Blending

SV 116 L4 Grate Feed

SV 117 L4 Grate DischargeMINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 51 of 69

Associated Items: SV 124 L5 Bentonite Blending

SV 125 L5 Grate Feed

SV 126 L5 Grate Discharge

SV 141 L6 Bentonite Blending

SV 142 L6 Grate Feed

SV 143 L6 Grate Discharge

SV 148 L7 Bentonite Blending

SV 149 L7 Grate Feed

SV 150 L7 Grate Discharge

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 2.0

LIMIT Minn. R. 7011.0715, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 3.0

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity 4.0

CD hdr B. CONTROL EQUIPMENT MONITORING 5.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Gas Stream Pressure Drop: Monitor and record as least once every day when in operation, once the pressure gauge is installed for each piece of control equipment in this group. Complete pressure drop monitoring equipment debugging, trouble-shooting, and establishment of parameter range within 180 days of

installation. 6.0

CD Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J) Liquid Flow Rate for Wet Scrubbers: Monitor and record as least once every day when in operation, once the monitoring equipment is installed for each piece of wet scrubbers in this group. Complete monitoring equipment debugging, trouble-shooting, and establishment of parameter range within 180 days of

installation. 7.0

CD Minn. R. 7007.0800, subp. 4(D); 14; 16(J) Process Monitoring: the visual emissions observer in the facility staff shall check stack visible emissions (opacity) for SV 115, SV 124, SV 141, and SV 148 once daily using a checklist that at a minimum contains the information required in

A ppendix B. If the Permittee uses for a fabric filter (CE 098, CE 108, CE 120, or CE 130) a broken bag detector approved by the MPCA, the Permittee does not need to conduct visible emissions checks for the stack controlled by that fibric filter (SV 115, SV 124, SV 141, or SV 148, respectively). 8.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 9.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 730 days after 11/07/2003 on one stack from (SV 116, 117, 125, 126, 142, 143, 149, or 150) and another stack to measure PM and Opacity emissions. 10.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on one-year (12 month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. 11.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 12.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 13.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 14.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 15.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 16.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 52 of 69

Subject Item: GP 026 Post-1969 pellet handling for Steps II and III

Associated Items: CE 104 Wet Scrubber-High Efficiency w/o Lime

CE 105 Wet Scrubber-High Efficiency w/o Lime

CE 114 Wet Scrubber-High Efficiency w/o Lime

CE 115 Wet Scrubber-High Efficiency w/o Lime

CE 117 Wet Scrubber-High Efficiency w/o Lime

CE 127 Wet Scrubber-High Efficiency w/o Lime

CE 137 Wet Scrubber-High Efficiency w/o Lime

EU 265 L4 Cooler Discharge

EU 286 L5 Cooler Discharge

EU 295 S3 Conveyor Transfer

EU 296 S3 Conveyor Transfer

EU 317 L6 Cooler Dump zone

EU 336 L7 Cooler Dump Zone

EU 339 Step I 043/044 Conveyor Transfer

EU 340 Step I 043/044 Conveyor Transfer

SV 120 L4 Conveyor Transfer Feeder

SV 121 L4 Cooler Dump Zone

SV 129 L5 Conveyor Transfer Feeder

SV 130 L5 Cooler Dump Zone

SV 138 S3 Conveyor Transfer

SV 146 L6 Conveyor Transfer

SV 153 L7 Conveyor Transfer

SV 154 Step I 043/044 Conv. Trans

SV 155 Step I 043/044 Conv. Trans

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735; or, alternatively,

as below: 2.0

LIMIT Minn. R. 7011.0715, subp. 3 Total Particulate Matter: greater than or equal to 85 percent collection efficiency , provided that the entire emission facility is in compliance with NAAQS and MAAQS, and the emission facility is located not less than one-forth mile from any residence or public roadway. (This is an alternative demonstration of compliance to Total Particulate Matter Limit.) 3.0

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity 4.0

CD hdr B. CONTROL EQUIPMENT MONITORING 5.0

LIMIT Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J); 7017.2025, subp. 3 Pressure Drop: greater than or equal to 13.5 inches of water column using 8-hour Block Average on the gas stream. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 6.0

LIMIT Minn. R. 7007.0800, subp. 4(D); subp. 14; subp. 16(J); 7017.2025, subp. 3 Liquid Flow Rate: greater than or equal to 297 gallons/minute using 8-hour Block

A verage on the wet scrubber. A deviation from the established range shall trigger a corrective action as detailed in the O&M plan. 7.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 8.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 365 days after 11/07/2003 on one stack from (SV 121, 130, 146, or 153) and another stack to measure PM and Opacity emissions. 9.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 53 of 69

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on one-year (12 month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. 10.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 11.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 12.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 13.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 14.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 15.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 54 of 69

Subject Item: GP 027 Post-1969 conveyor transfer points without APCE

Associated Items: EU 289 Step I 043 Conveyor Vents

EU 290 Step I 043 Conveyor Vents

EU 291 Step I 043 Conveyor Vents

EU 292 Step I 043 Conveyor Vents

EU 293 Step I 043 Conveyor Vents

EU 294 Step I 043 Conveyor Vents

EU 318 L6 Conveyor Transfer

EU 319 L6 Conveyor Transfer

EU 337 L7 Conveyor Transfer

EU 338 L7 Conveyor Transfer

EU 341 Step III 042 Conveyor Vent

EU 342 Step III 042 Conveyor Vent

EU 343 Step III 043 Conveyor Vent

EU 344 Step III 043 Conveyor Vent

EU 345 Step III 044 Conveyor Vent

EU 346 Step III 044 Conveyor Vent

EU 347 Step III 044 Conveyor Vent

EU 348 Step III 044 Conveyor Vent

EU 349 Step III 044 Conveyor Vent

EU 350 Step III 044 Conveyor Vent

EU 351 Step III 044 Conveyor Vent

EU 352 Step III 044 Conveyor Vent

EU 353 Step III 044 Conveyor Vent

EU 354 Step III 044 Conveyor Vent

EU 355 Step III 044 Conveyor Vent

EU 356 Step III 044 Conveyor Vent

EU 357 Step III 044 Conveyor Vent

EU 358 Step III 044 Conveyor Vent

EU 359 Step III 043/044 Conveyor Transfer

EU 360 Step III 043/044 Conveyor Transfer

EU 361 Step III 043/044 Conveyor Transfer

EU 362 Step III 043/044 Conveyor Transfer

EU 363 Step III 044-6/044-7 Conveyor Transfer

EU 364 Step III 044-6/044-7 Conveyor Transfer

EU 365 Step III 044-6/044-7 Conveyor Transfer

EU 366 Step III Pellet Loadout

SV 132 Step I 043 Conveyor Vents

SV 133 Step I 043 Conveyor Vents

SV 134 Step I 043 Conveyor Vents

SV 135 Step I 043 Conveyor Vents

SV 136 Step I 043 Conveyor Vents

SV 137 Step I 043 Conveyor Vents

SV 156 Step III 042 Conveyor VentMINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 55 of 69

Associated Items: SV 157 Step III 042 Conveyor Vent

SV 158 Step III 043 Conveyor Vent

SV 159 Step III 043 Conveyor Vent

SV 160 Step III 044 Conveyor Vent

SV 161 Step III 044 Conveyor Vent

SV 162 Step III 044 Conveyor Vent

SV 163 Step III 044 Conveyor Vent

SV 164 Step III 044 Conveyor Vent

SV 165 Step III 044 Conveyor Vent

SV 166 Step III 044 Conveyor Vent

SV 167 Step III 044 Conveyor Vent

SV 168 Step III 044 Conveyor Vent

SV 169 Step III 044 Conveyor Vent

SV 170 Step III 044 Conveyor Vent

SV 171 Step III 044 Conveyor Vent

SV 172 Step III 044 Conveyor Vent

SV 173 Step III 044 Conveyor Vent

SV 174 Step III 043/044 Conveyor Transfer

SV 175 Step III 043/044 Conveyor Transfer

SV 176 Step III 043/044 Conveyor Transfer

SV 177 Step III 043/044 Conveyor Transfer

SV 178 Step III 044-6/044-7 Conveyor Transfer

SV 179 Step III 044-6/044-7 Conveyor Transfer

SV 180 Step III Pellet Loadout

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735. 2.0

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity 3.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 56 of 69

Subject Item: GP 028 Limestone handling (Actions 007 and 008)

Associated Items: CE 070 Wet Scrubber-High Efficiency w/o Lime

CE 143 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

EU 139 Tertiary Crusher L29

EU 393 Limestone Dump Pocket

EU 394 Limestone converyor trnsfr 1

EU 395 Limestone converyor trnsfr 2

SV 084 Tertiary Crusher L29

SV 194 Limestone Receiving System

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT 40 CFR 60.672(a)(1) Total Particulate Matter: less than or equal to 0.022 grains/dry standard cubic foot (0.05 grams per dry standard cubic meter). 2.0

LIMIT 40 CFR 60.672(a)(2) Opacity: less than or equal to 7 percent opacity for SV 194, which is controlled by CE 143 (the fabric filter for limestone receiving system dump pocket & transfer point no. 1). 3.0

CD hdr B. CONTROL EQUIPMENT REQUIREMENTS 4.0

LIMIT Title I Condition: a 1997&2000

action that avoided review under

CFR 52.21 set this Pressure Drop: greater than or equal to 3.2 inches of water column and less than or equal to 5.7 inches of water column for CE 070 (wet scrubber) that controls SV 084 for EU 395 (limestone receiving system transfer point no. 2). 5.0

LIMIT Title I Condition: a 1997&2000

action that avoided review under

CFR 52.21 set this Pressure Drop: greater than or equal to 0.5 inches of water column and less than or equal to 8.0 inches of water column for CE 143 (fabric filter) that controls SV 194 for EU 393 & EU 394 (limestone receiving system dump pocket & transfer point no. 1). 6.0

LIMIT Title I Condition: a 1997&2000

action that avoided review under

CFR 52.21 set this Liquid Flow Rate: greater than or equal to 25 gallons/minute and less than or equal to 45 gallons/minute for CE 070 (wet scrubber) that controls SV 084 for EU 395 (limestone receiving system transfer point no. 2). 7.0

S/A 40 CFR 60.676(d) Semiannual Deviations Report: due before end of each half-year following Initial Performance Test. The Permittee shall report occurrences when the measurements of gas stream pressure drop (or gain) and liquid flow rate of CE 070 differ by more than 30%, plus or minus, from the average obtained during the most recent performance test. 8.0

CD hdr C. CONTROL EQUIPMENT MONITORING 9.0

CD Title I Condition: a 1997&2000

action that avoided review under

CFR 52.21 set this Gas Stream Pressure Drop: Monitor and record as least once every day when in operation for CE 070 and CE 143. 10.0

CD Title I Condition: a 1997&2000

action that avoided review under

CFR 52.21 set this Liquid Flow Rate: Monitor and record as least once every day when in operation

for CE 070. 11.0

CD Minn. R. 7007.0800, subp. 4(D); 14; 16(J) Process Monitoring: the visual emissions observer in the facility staff shall check stack visible emissions (opacity) for SV 194 once daily using a checklist that at a minimum contains the information required in Appendix B. If the Permittee uses for CE 143 a broken bag detector approved by the MPCA, the Permittee does not

need to conduct visible emissions checks for SV 194. 12.0

CD hdr D. PERFORMANCE TESTING REQUIREMENTS 13.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 365 days after 11/30/2004 on one stack to measure PM and Opacity emissions. 14.0

S/A Minn. R. 7017.2020, subp. 1 Testing Frequency Plan: due 60 days after Initial Performance Test. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on one-year (12 month), 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. 15.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 16.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 17.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 57 of 69

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 18.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 19.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 20.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 58 of 69

Subject Item: SV 104 L3 Cooler Vent Stack

Associated Items: EU 227 L3 Cooler Vent Stack

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0710, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn R. 7011.0730 or Minn. R. 7011.0735. 2.0

LIMIT Minn. R. 7011.0710, subp. 1(B) Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. 3.0

CD hdr B. OPERATION REQUIREMENTS 4.0

CD Minn. R. 7007.0800, subp. 4(D); 14; 16(J) Process Monitoring: the visual emissions observer in the facility staff shall check stack visible emissions (opacity) once daily using a checklist that at a minimum contains the information required in Appendix B. 5.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 6.0

S/A Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 365 days after 11/30/2004 to measure PM and Opacity emissions. 7.0

S/A Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each year following Initial Performance Test to measure PM and Opacity, if Line 3 utilization for that 12-month period is 50% or higher. (Line 3 utilization is 100%, if its kiln burner is fired for 8760 hours in the 12-month period, regardless of the rate of heat input or the rate of green ball feed.) However, Performance Test must be conducted at least ONCE for each 60 month period following Initial Performance Test. 8.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 9.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 10.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test 11.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 12.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 13.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 59 of 69

Subject Item: SV 122 L4 Conveyor Transfer 041-046 to 042 Belts

Associated Items: EU 264 L4 Conveyor Transfer Feeder

EU 266 L4 Conveyor Transfer 041/046 to 042 Belts

EU 267 L4 Conveyor Transfer 041/046 to 042 Belts

EU 399 L4 Pellet Scrn Fine Belt

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT 40 CFR 60.382(a); Minn. R.

7011.2700 Total Particulate Matter: less than or equal to 0.05 grams/dry standard cubic meter (0.022 grains/dry standard cubic foot) of exhaust gas on and after the date on which the performance test required is completed. 2.0

LIMIT 40 CFR 60.382(b); Minn. R.

7011.2700 Opacity: less than or equal to 10 percent opacity using 6-minute average for any process fugitive emissions on and after the 60th day after achieving the maximum production rate at which EU 399 and the screen at EU 264 will be operated, but not later than 180 days after the initial startup of EU 399 and the screen at EU 264. 3.0

CD hdr B. POLLUTION CONTROL EQUIPMENT LIMITS 4.0

LIMIT Minn. R. 7017.2025, subp. 3 Liquid Flow Rate: greater than or equal to 240 gallons/minute using 24-hour Rolling

A verage . 5.0

CD hdr C. POLLUTION CONTROL EQUIPMENT REQUIREMENTS 6.0

CD 40 CFR 60.384(a); Minn. R.

7011.2700 Gas Stream Pressure Drop: The Permittee shall install, calibrate, maintain, and operate a monitoring device for the wet scrubber (CE 106) for the continuous measurement of the change in pressure of the gas stream through the wet scrubber. The monitoring device must be certified by the manufacturer to be accurate within 250 Pascals (1 inch water) gauge pressure, plus or minus; and

must be calibrated on an annual basis in accordance with manufacturer's

instructions. 7.0

CD Minn. R. 7011.0800 Record Gas Stream Pressure Drop and Liquid Flow Rate for CE 106 each day in operation. 8.0

CD 40 CFR 60.384(b); Minn. R.

7011.2700 Liquid Flow Rate: The Permittee shall install, calibrate, maintain, and operate a monitoring device for the wet scrubber (CE106) for the continuous measurement of the scrubbing liquid flow rate to the wet scrubber. The monitoring device must be certified by the manufacturer to be accurate within 5%, plus or minus, of design scrubbing liquid flow rate; and must be calibrated on an annual basis in accordance

with manufacturer's instructions. 9.0

CD hdr D. PERFORMANCE TESTING REQUIREMENTS 10.0

S/A 40 CFR 60.385(a); Minn. R.

7011.2700 Initial Performance Test: due 60 days after achieving maximum capacity but not later than 180 days after initial startup of the affected facility (EU 399 and the screen at EU 264) to determine Total Particulate Matter emissions. 11.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test. 12.0

CD 40 CFR 60.385(b); Minn. R.

7011.2700 The Permittee shall record the measurements of both the change in pressure of the gas stream across the wet scrubber (CE 106) and the scrubbing liquid flow rate during the Initial Performance Test of the wet scrubber and at least weekly

thereafter. 13.0

S/A 40 CFR 60.7(a)(1) Notification of the Date Construction Began: due 30 days after Start Of

Construction. Submit the name and number of each unit and the date construction of each unit began (EU 399 and the screen at EU 264). 14.0

S/A 40 CFR 60.7(a)(3) Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup of

EU 399 and the screen at EU 264. 15.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 16.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 17.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 18.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 19.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 60 of 69

S/A 40 CFR 60.385(c); Minn. R.

7011.2700 Semiannual Deviations Report: due 30 days after end of each calendar half-year following Initial Performance Test. The Permittee shall report occurrences when the measurements of the wet scrubber gas stream pressure drop (or gain) and scrubbing liquid flow differ by more than 30%, plus or minus, from the average obtained during the most recent performance test. 20.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 61 of 69

Subject Item: SV 131 L5 Conveyor Transfer 041-046 to 042 Belts

Associated Items: EU 285 L5 Conveyor Transfer Feeder (B4 L5 hygiene)

EU 287 L5 Conveyor Transfer 041/046 to 042 Belts

EU 288 L5 Conveyor Transfer 041/046 to 042 Belts

EU 400 L5 Pellet Scrn Fine Belt

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT 40 CFR 60.382(a); Minn. R.

7011.2700 Total Particulate Matter: less than or equal to 0.05 grams/dry standard cubic meter (0.022 grains/dry standard cubic foot) of exhaust gas on and after the date on which the performance test required is completed. 2.0

LIMIT 40 CFR 60.382(b); Minn. R.

7011.2700 Opacity: less than or equal to 10 percent opacity using 6-minute average for any process fugitive emissions on and after the 60th day after achieving the maximum production rate at which the screen at EU 285 will be operated, but not later than 180 days after the initial startup of the screen at EU 285. 3.0

CD hdr B. POLLUTION CONTROL EQUIPMENT REQUIREMENTS 4.0

CD 40 CFR 60.384(a); Minn. R.

7011.2700 Gas Stream Pressure Drop: The Permittee shall install, calibrate, maintain, and operate a monitoring device for the wet scrubber (CE 116) for the continuous measurement of the change in pressure of the gas stream through the wet scrubber. The monitoring device must be certified by the manufacturer to be accurate within 250 Pascals (1 inch water) gauge pressure, plus or minus; and

must be calibrated on an annual basis in accordance with manufacturer's

instructions. 5.0

CD 40 CFR 60.384(b); Minn. R.

7011.2700 Liquid Flow Rate: The Permittee shall install, calibrate, maintain, and operate a monitoring device for the wet scrubber (CE116) for the continuous measurement of the scrubbing liquid flow rate to the wet scrubber. The monitoring device must be certified by the manufacturer to be accurate within 5%, plus or minus, of design scrubbing liquid flow rate; and must be calibrated on an annual basis in accordance

with manufacturer's instructions. 6.0

CD Minn. R. 7011.0800 Record Gas Stream Pressure Drop and Liquid Flow Rate for CE 116 each day in operation. 7.0

CD hdr C. PERFORMANCE TESTING REQUIREMENTS 8.0

S/A 40 CFR 60.385(a); Minn. R.

7011.2700 Initial Performance Test: due 60 days after achieving maximum capacity, but not later than 180 days after initial startup of the affected facility (the screen at EU 285) to determine Total Particulate Matter emission. {Please Note: Air Emission Permit No. 13700005-013 has 2 Initial Performance Test requirements for SV 131 - one before the Industrial Hygiene Upgrade Project and the other after the Industrial Hygiene Upgrade Project.} 9.0

S/A Minn. R. 7017.2030, subp. 4 Performance Test Pre-test Meeting: due 7 days before Performance Test. 10.0

CD 40 CFR 60.385(b); Minn. R.

7011.2700 The Permittee shall record the measurements of both the change in pressure of the gas stream across the wet scrubber (CE 116) and the scrubbing liquid flow rate during the Initial Performance Test of the wet scrubber and at least weekly

thereafter. 11.0

S/A 40 CFR 60.7(a)(1) Notification of the Date Construction Began: due 30 days after Start Of

Construction. Submit the name and number of each unit and the date construction of each unit began (the screen at EU 285). 12.0

S/A 40 CFR 60.7(a)(3) Notification of the Actual Date of Initial Startup: due 15 days after Initial Startup of

the screen at EU 285. 13.0

S/A Minn. R. 7017.2030, subp. 1 Performance Test Notification (written): due 30 days before Performance Test 14.0

S/A Minn. R. 7017.2030, subp. 2 and 3 Performance Test Plan: due 30 days before Performance Test 15.0

S/A Minn. R. 7017.2035, subp. 1 and 2 Performance Test Report: due 45 days after Performance Test 16.0

S/A Minn. R. 7017.2035, subp. 2 Performance Test Report - Microfiche Copy: due 105 days after Performance Test 17.0

S/A 40 CFR 60.385(c); Minn. R.

7011.2700 Semiannual Deviations Report: due 30 days after end of each calendar half-year following Initial Performance Test. The Permittee shall report occurrences when the measurements of the wet scrubber gas stream pressure drop (or gain) and scrubbing liquid flow differ by more than 30%, plus or minus, from the average obtained during the most recent performance test. 18.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 62 of 69

Subject Item: SV 191 Carpenters Shop

Associated Items: EU 391 Carpenters Shop

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. 2.0

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity 3.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 63 of 69

Subject Item: SV 192 Paint Shop Booth

Associated Items: EU 392 Paint Shop Booth

NC/

CA Type Citation Requirement

CD hdr A . POLLUTANT LIMITS 1.0

LIMIT Minn. R. 7011.0715, subp. 1(A) Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. 2.0

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity 3.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 64 of 69

Subject Item: SV 195 Hill Wood Products system

Associated Items: EU 396 Hill Wood Products system

NC/

CA Type Citation Requirement

LIMIT Title I Condition: Limit to avoid classification as a major modification under 40 CFR 52.21;

and Minn. R. 7007.3000 Process Throughput: less than or equal to 220,000 tons/year using 12-month Rolling Sum of wood waste. The amount of wood waste received shall be calculated by the 15th of each month for the previous 12-month period. A record of the amount of wood waste received shall be kept on a daily basis. 1.0

LIMIT Title I Condition: Limit to avoid classification as a major modification under 40 CFR 52.21;

and Minn. R. 7007.3000 Total Particulate Matter: greater than or equal to 90 percent capture efficiency and less than 0.54 lb/hr at SV 195 after control by CE 144 (fabric filter) 2.0

LIMIT Title I Condition: Limit to avoid classification as a major modification under 40 CFR 52.21;

and Minn. R. 7007.3000 Particulate Matter < 10 micron: greater than or equal to 90 percent capture efficiency and less than 0.32 lb/hr at SV 195 after control by CE 144 (fabric filter) 3.0

LIMIT Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 20 percent opacity 4.0

CD Minn. R. 7007.0800, subp. 4(D), 14, and 16(J) Monitoring: The visible emissions observer on the facility staff shall check stack visible emissions (opacity) once daily using a checklist that at a minimum contains the information required in Appendix B. 5.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 65 of 69

Subject Item: MR 001 NOx & SO2 CEMS at Line 3 Waste Gas Stack (SV 103)

Associated Items: CE 146 Wet Scrubber-High Efficiency

GP 009 Agglomerator Line 3

SV 103 L3 Waste Gas Stack

NC/

CA Type Citation Requirement

CD hdr CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements

(See additional CEMS requirements in Table A under Subject Item: Total Facility, Section F, and Subject Items MR 002 through MR 005; and in Table B) 1.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1006. Initial Startup of the Monitor: due 30 days after 12/22/2008 . Monitor is the continuous emission monitoring system (CEMS), which is defined as the total equipment used to sample, condition (if applicable), analyze, and provide a permanent record of emissions of NOx and SO2 in lb/hr. 2.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1050, subp. 1. CEM Certification Test: due 90 days after Excess Emissions/Downtime Reports (EER's) are first required. The first EER is due 30 days after the end of the calendar quarter following Permit Issuance. Follow the Performance Specifications listed in 40 CFR 60, Appendix B. Note that some changes that affect the CEMS may require recertification. 3.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1170, subp. 4. CEMS Cylinder Gas Audit (CGA): due before end of each calendar quarter following CEM Certification Test, except that a CGA is not required during any calendar half year in which a RATA was performed. The initial CGA must be performed within 80 days following certification of the CEMS. The CGAs shall be conducted at least three months apart but no more than eight months apart. A CGA shall be conducted according to the procedures in 40 CFR 60, Appendix F, section 5.1.2. If the monitored emission unit was operated for less than 24 hours during the calendar half year, a CGA is not required for that calendar half year. 4.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1170, subp. 5. CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar year following CEM Certification Test. A RATA is not required in any calendar year if a RATA conducted in the previous year demonstrated a relative accuracy value of less than 15 percent or if the associated emission unit operated less than 48 hours during the calendar year. If the exception is used, the next RATA shall be conducted during the first half of the following calendar year. RATAs shall be conducted at least 3 months apart according to 40 CFR 60, Appendix F, section

5.1.1. 5.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1180, subp. 1. Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter following end of the calendar quarter in which the Audit was performed. A CGA is not required during any calendar quarter in which a RATA was performed. 6.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1180, subp. 3. Relative Accuracy Test Audit (RATA) Results Summary: due 45 days after CEMS Relative Accuracy Test Audit (RATA). 7.0

CD Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1110, subp. 1 and 2. Excess Emissions/Downtime Reports (EER's): due 30 days after end of each calendar quarter following Initial Startup of the Monitor. Submit Deviations Reporting Form DRF-1 as amended. The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e., during starup, shutdown, and malfunctions. The EER must be submitted even if there were no excess emissions, downtime or bypass during the quarter. { This is a reminder; the same requirement can be found in Table B of this permit. } 8.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 66 of 69

Subject Item: MR 002 NOx & SO2 CEMS at Line 4 Waste Gas Stack (SV 118)

Associated Items: CE 103 Wet Scrubber-High Efficiency w/o Lime

GP 010 Agglomeration Lines 4 & 5

SV 118 L4 Waste Gas Stack

NC/

CA Type Citation Requirement

CD hdr CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements

(See additional CEMS requirements in Table A under Subject Item: Total Facility, Section F, and Subject Items MR 001, and MR 003 through MR 005; and in Table B) 1.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1006. Initial Startup of the Monitor: due 30 days after 12/22/2008 . Monitor is the continuous emission monitoring system (CEMS), which is defined as the total equipment used to sample, condition (if applicable), analyze, and provide a permanent record of emissions of NOx and SO2 in lb/hr. 2.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1050, subp. 1. CEM Certification Test: due 90 days after Excess Emissions/Downtime Reports (EER's) are first required. The first EER is due 30 days after the end of the calendar quarter following Permit Issuance. Follow the Performance Specifications listed in 40 CFR 60, Appendix B. Note that some changes that affect the CEMS may require recertification. 3.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1170, subp. 4. CEMS Cylinder Gas Audit (CGA): due before end of each calendar quarter following CEM Certification Test, except that a CGA is not required during any calendar half year in which a RATA was performed. The initial CGA must be performed within 80 days following certification of the CEMS. The CGAs shall be conducted at least three months apart but no more than eight months apart. A CGA shall be conducted according to the procedures in 40 CFR 60, Appendix F, section 5.1.2. If the monitored emission unit was operated for less than 24 hours during the calendar half year, a CGA is not required for that calendar half year. 4.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1170, subp. 5. CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar year following CEM Certification Test. A RATA is not required in any calendar year if a RATA conducted in the previous year demonstrated a relative accuracy value of less than 15 percent or if the associated emission unit operated less than 48 hours during the calendar year. If the exception is used, the next RATA shall be conducted during the first half of the following calendar year. RATAs shall be conducted at least 3 months apart according to 40 CFR 60, Appendix F, section

5.1.1. 5.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1180, subp. 1. Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter following end of the calendar quarter in which the Audit was performed. A CGA is not required during any calendar quarter in which a RATA was performed. 6.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1180, subp. 3. Relative Accuracy Test Audit (RATA) Results Summary: due 45 days after CEMS Relative Accuracy Test Audit (RATA). 7.0

CD Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1110, subp. 1 and 2. Excess Emissions/Downtime Reports (EER's): due 30 days after end of each calendar quarter following Initial Startup of the Monitor. Submit Deviations Reporting Form DRF-1 as amended. The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e., during starup, shutdown, and malfunctions. The EER must be submitted even if there were no excess emissions, downtime or bypass during the quarter. { This is a reminder; the same requirement can be found in Table B of this permit. } 8.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 67 of 69

Subject Item: MR 003 NOx & SO2 CEMS at Line 5 Waste Gas Stack (SV 127)

Associated Items: CE 113 Wet Scrubber-High Efficiency w/o Lime

GP 010 Agglomeration Lines 4 & 5

SV 127 L5 Waste Gas Stack

NC/

CA Type Citation Requirement

CD hdr CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements

(See additional CEMS requirements in Table A under Subject Item: Total Facility, Section F, and Subject Items MR 001, MR 002, MR 004, and MR 005; and in Table B) 1.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1006. Initial Startup of the Monitor: due 30 days after 12/22/2008 . Monitor is the continuous emission monitoring system (CEMS), which is defined as the total equipment used to sample, condition (if applicable), analyze, and provide a permanent record of emissions of NOx and SO2 in lb/hr. 2.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1050, subp. 1. CEM Certification Test: due 90 days after Excess Emissions/Downtime Reports (EER's) are first required. The first EER is due 30 days after the end of the calendar quarter following Permit Issuance. Follow the Performance Specifications listed in 40 CFR 60, Appendix B. Note that some changes that affect the CEMS may require recertification. 3.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1170, subp. 4. CEMS Cylinder Gas Audit (CGA): due before end of each calendar quarter following CEM Certification Test, except that a CGA is not required during any calendar half year in which a RATA was performed. The initial CGA must be performed within 80 days following certification of the CEMS. The CGAs shall be conducted at least three months apart but no more than eight months apart. A CGA shall be conducted according to the procedures in 40 CFR 60, Appendix F, section 5.1.2. If the monitored emission unit was operated for less than 24 hours during the calendar half year, a CGA is not required for that calendar half year. 4.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1170, subp. 5. CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar year following CEM Certification Test. A RATA is not required in any calendar year if a RATA conducted in the previous year demonstrated a relative accuracy value of less than 15 percent or if the associated emission unit operated less than 48 hours during the calendar year. If the exception is used, the next RATA shall be conducted during the first half of the following calendar year. RATAs shall be conducted at least 3 months apart according to 40 CFR 60, Appendix F, section

5.1.1. 5.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1180, subp. 1. Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter following end of the calendar quarter in which the Audit was performed. A CGA is not required during any calendar quarter in which a RATA was performed. 6.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1180, subp. 3. Relative Accuracy Test Audit (RATA) Results Summary: due 45 days after CEMS Relative Accuracy Test Audit (RATA). 7.0

CD Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1110, subp. 1 and 2. Excess Emissions/Downtime Reports (EER's): due 30 days after end of each calendar quarter following Initial Startup of the Monitor. Submit Deviations Reporting Form DRF-1 as amended. The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e., during starup, shutdown, and malfunctions. The EER must be submitted even if there were no excess emissions, downtime or bypass during the quarter. { This is a reminder; the same requirement can be found in Table B of this permit. } 8.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 68 of 69

Subject Item: MR 004 NOx & SO2 CEMS at Line 6 Waste Gas Stack (SV 144)

Associated Items: CE 126 Wet Scrubber-High Efficiency w/o Lime

GP 011 Agglomeration Lines 6 & 7 (Action 007)

SV 144 L6 Waste Gas Stack

NC/

CA Type Citation Requirement

CD hdr CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements

(See additional CEMS requirements in Table A under Subject Item: Total Facility, Section F, and Subject Items MR 001 through MR 003, and MR 005; and in Table B) 1.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1006. Initial Startup of the Monitor: due 30 days after 12/22/2008 . Monitor is the continuous emission monitoring system (CEMS), which is defined as the total equipment used to sample, condition (if applicable), analyze, and provide a permanent record of emissions of NOx and SO2 in lb/hr. 2.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1050, subp. 1. CEM Certification Test: due 90 days after Excess Emissions/Downtime Reports (EER's) are first required. The first EER is due 30 days after the end of the calendar quarter following Permit Issuance. Follow the Performance Specifications listed in 40 CFR 60, Appendix B. Note that some changes that affect the CEMS may require recertification. 3.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1170, subp. 4. CEMS Cylinder Gas Audit (CGA): due before end of each calendar quarter following CEM Certification Test, except that a CGA is not required during any calendar half year in which a RATA was performed. The initial CGA must be performed within 80 days following certification of the CEMS. The CGAs shall be conducted at least three months apart but no more than eight months apart. A CGA shall be conducted according to the procedures in 40 CFR 60, Appendix F, section 5.1.2. If the monitored emission unit was operated for less than 24 hours during the calendar half year, a CGA is not required for that calendar half year. 4.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1170, subp. 5. CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar year following CEM Certification Test. A RATA is not required in any calendar year if a RATA conducted in the previous year demonstrated a relative accuracy value of less than 15 percent or if the associated emission unit operated less than 48 hours during the calendar year. If the exception is used, the next RATA shall be conducted during the first half of the following calendar year. RATAs shall be conducted at least 3 months apart according to 40 CFR 60, Appendix F, section

5.1.1. 5.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1180, subp. 1. Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter following end of the calendar quarter in which the Audit was performed. A CGA is not required during any calendar quarter in which a RATA was performed. 6.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1180, subp. 3. Relative Accuracy Test Audit (RATA) Results Summary: due 45 days after CEMS Relative Accuracy Test Audit (RATA). 7.0

CD Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1110, subp. 1 and 2. Excess Emissions/Downtime Reports (EER's): due 30 days after end of each calendar quarter following Initial Startup of the Monitor. Submit Deviations Reporting Form DRF-1 as amended. The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e., during starup, shutdown, and malfunctions. The EER must be submitted even if there were no excess emissions, downtime or bypass during the quarter. { This is a reminder; the same requirement can be found in Table B of this permit. } 8.0MINNESOTA POLLUTION CONTROL AGENCY

AIR QUALITY

520 LAFAY ETTE ROAD

ST. PAUL, MN 55155-4194 

### COMPLIANCE PLAN 

# CD-01

Facility Name: US Steel Corp - Minntac

Permit Number: 13700005 - 006 30 May, 2013 13:58 Page 69 of 69

Subject Item: MR 005 NOx & SO2 CEMS at Line 7 Waste Gas Stack (SV 151)

Associated Items: CE 136 Wet Scrubber-High Efficiency w/o Lime

GP 011 Agglomeration Lines 6 & 7 (Action 007)

SV 151 L7 Waste Gas Stack

NC/

CA Type Citation Requirement

CD hdr CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements

(See additional CEMS requirements in Table A under Subject Item: Total Facility, Section F, and Subject Items MR 001 through MR 004; and in Table B) 1.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1006. Initial Startup of the Monitor: due 30 days after 12/22/2008 . Monitor is the continuous emission monitoring system (CEMS), which is defined as the total equipment used to sample, condition (if applicable), analyze, and provide a permanent record of emissions of NOx and SO2 in lb/hr. 2.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1050, subp. 1. CEM Certification Test: due 90 days after Excess Emissions/Downtime Reports (EER's) are first required. The first EER is due 30 days after the end of the calendar quarter following Permit Issuance. Follow the Performance Specifications listed in 40 CFR 60, Appendix B. Note that some changes that affect the CEMS may require recertification. 3.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1170, subp. 4. CEMS Cylinder Gas Audit (CGA): due before end of each calendar quarter following CEM Certification Test, except that a CGA is not required during any calendar half year in which a RATA was performed. The initial CGA must be performed within 80 days following certification of the CEMS. The CGAs shall be conducted at least three months apart but no more than eight months apart. A CGA shall be conducted according to the procedures in 40 CFR 60, Appendix F, section 5.1.2. If the monitored emission unit was operated for less than 24 hours during the calendar half year, a CGA is not required for that calendar half year. 4.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1170, subp. 5. CEMS Relative Accuracy Test Audit (RATA): due before end of each calendar year following CEM Certification Test. A RATA is not required in any calendar year if a RATA conducted in the previous year demonstrated a relative accuracy value of less than 15 percent or if the associated emission unit operated less than 48 hours during the calendar year. If the exception is used, the next RATA shall be conducted during the first half of the following calendar year. RATAs shall be conducted at least 3 months apart according to 40 CFR 60, Appendix F, section

5.1.1. 5.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1180, subp. 1. Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter following end of the calendar quarter in which the Audit was performed. A CGA is not required during any calendar quarter in which a RATA was performed. 6.0

S/A Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1180, subp. 3. Relative Accuracy Test Audit (RATA) Results Summary: due 45 days after CEMS Relative Accuracy Test Audit (RATA). 7.0

CD Title I Conditions: to monitor NOx mitigation for Class I visibility impacts from pellet induration; 40 CFR 52.21 (p); Minn. R. 7007.3000; Minn. R. 7017.1110, subp. 1 and 2. Excess Emissions/Downtime Reports (EER's): due 30 days after end of each calendar quarter following Initial Startup of the Monitor. Submit Deviations Reporting Form DRF-1 as amended. The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e., during starup, shutdown, and malfunctions. The EER must be submitted even if there were no excess emissions, downtime or bypass during the quarter. { This is a reminder; the same requirement can be found in Table B of this permit. } 8.0

# Attachment Three:

Points CalculatorPoints Calculator

(DQ DQ#) 1) AQ Facility ID No.: 13700005 Total Points 25
2) Facility Name: US Steel Corp - Minntac 3) Small business? y/n? N
4) DQ Numbers (including all rolled) : 4078 5) Date of each Application Received: August 01, 2012, updated application: 04/08/13
6) Final Permit No. 13700005-006
7) Permit Staff Sarah Seelen

8) "Work completed" in which .xls file (i.e. unit 2b, unit 1a, biofuels)?

Total
Application Type DQ No. Qty. Points Points Details

Administrative Amendment 1 0

Minor Amendment 4 0
Applicability Request 10 0

Moderate Amendment 15 0
Major Amendment 4078 1 25 25
Individual State Permit (not reissuance) 50 0
Individual Part 70 Permit (not reissuance) 75 0

Additional Points
Modeling Review 15 0

BACT Review 15 0

LAER Review 15 0
CAIR/Part 75 CEM analysis 10 0

NSPS Review 10 0

NESHAP Review 10 0
Case-by-case MACT Review 20 0
Netting 10 0

Limits to remain below threshold 10 0 Plantwide Applicability Limit (PAL) 20 0

AERA review 15 0
Variance request under 7000.7000 35 0
Confidentiality request under 7000.1300 2 0

EAW review

Part 4410.4300, subparts 18, item A; and 29 15 0

Part 4410.4300, subparts 8, items A & B; 10, items

A to C; 16, items A & D; 17, items A to C & E to G;

and 18, items B & C 35 0

Part 4410.4300, subparts 4; 5 items A & B; 13; 15;

16, items B & C; and 17 item D 70 0

Add'l Points 0

NOTES: