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Minnesota Pollution Control Agency

520 Lafayett e Road North I St. Paul, MN 55155-4194 I 651-296-6300 I 800-657-3864 I 651-282-5332 TTY I www.pca.state.mn.us

January 18, 2011

Ms. Chrissy Bartovich

U.S. Steel Corporation

Minnesota Ore Operations - Minntac

P.O. Box 417

Mountain Iron, MN 55768

RE: Nitrogen Oxides Control Technology Pilot Testing

Dear Ms. Bartovich:

This letter is in response to the October 22, 20 I0, report from U.S . Steel Corporation Minnesota

Ore Operations - Minntac (Minntac) to the Minnesota Pollution Control Agency (MPCA)

regarding nitrogen oxides (NOx) control technology pilot test requirements contained in Air

Emissions Permit No. 13700005-005. The air emissions permit for the facility contains stepwise

requirements to test NO x control technologies with the goal of achieving greater than 70 percent

NO x emissions control from the initial permit limit of 13,300 tons per year NO x.

In the October report Minntac provided preliminary pilot test results from the low NO x main

burner installed on Line 7, a schedule for continued pilot testing on Line 7, and a schedule for

installation and pilot testing on Line 6. The MPCA, Federal Land Managers, and Minntac met on

December 13,20 I0, to discuss the effort to date. During the meeting several follow-up items were

identified. This letter responds to the October 22,20 I0, report and provides direction to U.S. Steel

Corporation for future testing, including approximate permitting timelines for major permit

modifications.

Line 7 Low NOx Main Burner Pilot Test

Minntac inst alled a low NO x main burner on Line 7 in May 20 IO. Minntac has provided information

demonstrating continued achievement of excellent NO x control efficiencies while combusting

natural gas. Despite redesigning the burner tip twice, Minntac stated that it has not been able to

achieve the same level of emissions reductions when combusting coal and biomass. Minntac stated

that while combusting coal, the Line 7 burner has continued to produce a short, bushy flame which

results in reduced NOx control efficiency and warps the kiln refractory.

In September 20 I0, the MPCA requested that Minntac submit the results ofthe pilot test results

conducted to date including technical feasibility and impact to pellet quality, significant NO x

reduction, cro ss media impacts, multi-pollutant co-control benefits, energy efficiency or

consumption impact, and economic feasibility . The MPCA is required, per Minntac's air permit,

to evaluate the pilot test results using that data. In the October 22, 20 I0, report Minntac provided

St. Paul I Brainerd I Detroit Lakes I Duluth I Mankato I Marshall I Rochester I Willmar I Printed on 100% post-consumer recycled paper
Ms. Chrissy Bartovich

Page 2

brief descriptions regarding the above items, but because it had not yet installed the second

redesigned burner tip or completed pilot testing while combusting biomass, any report provided

at that time would've been incomplete. Instead Minntac submitted an amended schedule for

providing the final results ofthe Line 7 pilot testing. The MPCA approves the schedule proposed

in the October report, pending the inclusion of quarterly updates to the MPCA. The quarterly

update can be as simple as an e-mail to the MPCA contacts, but should provide information so

that the MPCA can track the status ofthe effort; including the installation dates and the other

measures used as milestones in the proposed schedule.

Per the schedule provided, Minntac will be submitting the final report on the Line 7 low NOx

main burner pilot testing approximately in June 20 I I. The MPCA expects that the final report

will contain data in greater detail than the brief descriptions provided in the October preliminary

report so that the MPCA can use the data provided to evaluate the control technology. When

submitting the final report, if Minntac intends to submit protected data, please be mindful of the

MPCA's confidentiality requirements; including submittal ofjustification for confidentiality and

providing two copies ofthe report, one confidential and one with the protected data redacted.

Line 6 Low NOx Main Burner Pilot Test

Despite its efforts to redesign the Line 7 low NO x main burner tip, Minntac stated that it has

achieved limited improvements to NO x control efficiency while combusting coal. It also stated

that it was having biomass delivery problems; the burner isn't able to feed biomass into the

burner at an adequate rate for production.

For these reasons, Minntac has proposed to redesign and reconfigure a new low NO x main

burner to try to eliminate the flame shape problems occurring during coal combustion on Line 7.

To this end, Minntac submitted to the MPCA a schedule for installing and pilot testing a

redesigned burner on Line 6.

Per our request in the September 20 I0 letter, the MPCA approves the proposed Line 6 pilot test

schedule pending inclusion of a quarterly update so that the MPCA can track the status ofthe

pilot testing effort.

Permitting Timelines to meet February 1,2014, Full Scale Installation Goal

Sixty days after the MPCA approves the final NO x emission control pilot testing results, Minntac

is required to submit a major permit amendment for "full scale demonstration;" installation ofthe

chosen technology on a single agglomerating line. Following full scale demonstration, the permit

requires a major permit amendment for "full scale installation;" installation ofthe chosen

technology on all operating agglomerating lines at the plant. The major permit amendment is an

important part ofthe process because it allows for public participation and provides some level of

regulatory certainty for Minntac.
Ms. Chrissy Bartovich

Page 3

Because there is no way-to pilot test a low NOx main burner without full scale installation, the line

between a pilot testing and full scale demonstration is blurred. But the MPCA believes that

Minntac will have sufficiently refined the technology during the Line 6 low NOx main burner pilot

testing, so that any future proposed low NOx main burner installations can no longer be considered

pilot tests and will trigger require major permit amendment requirements prior to installation.

Minntac's air emissions permit contains a goal of installation ofNOx controls on all agglomerating

lines by February 1,2014. The major amendment process can require a significant amount oftime.

In addition to drafting the permit language, there are numerous administrative requirements that

add time to permitting. In order to meet the February 1, 2014, installation goal it is important that

Minntac consider the timing ofthe major permit amendment submittal. The time required to issue

the permit is dependent on a number of factors, including the completeness ofthe application, the

number and complexity of comments received, etc. So, the following are rough estimates for some

ofthe major steps in the major amendment process:

Major Modification Milestones Time Estimates

1. MPCA reviews the application submitted by Minntac and determines that it Start

is complete

2. MPCA drafts permit and discusses the permit terms Varies

3. MPCA internal peer review 14 days

4. MPCA seeks feedback from Minntac, tribes and FLMs 15 days

5. MPCA receives feedback, adjusts the language, and finalizes the permit Varies, generally

approx. 30 days

6. Minntac submits permit application reflecting the final permit language, if 45 days _

significant changes have occurred since the application was submitted.

Concurrently, MPCA prepares permit for public notice.

7. Public notice 30 days

8. EPA 45 day review period. In some cases it is possible for this review to be 45 days

concurrent with the public notice.

9. Ifrequested to come before the MPCA Citizen's Board for issuance, MPCA 45-60 days

prepared responses to comments and prepares for the board meeting.

10. Permit issued 5 days after Citizen's

Board Meeting

11. EAB Appeal Period (PSD permits only) 45 days

Please be cognizant ofthe above time requirements when submitting permit amendment

applications to comply with the February 1, 2014, control installation goal.
Ms. Chrissy Bartovich

Page 4

The MPCA looks forward to continuing to work with U.S. Steel Corporation on achieving the

NOx emission reductions required by its permit. If you have any questions or concerns, please

contact me at 651-757-2603 .

Sincerely,

Christopher J. Nelson, P.E., Manager

Strategic Projects Sector

Industrial Division

CJN/SLB :lao

cc: Trent Wickman, US Forest Service

Don Shepherd, National Park Service

David Pohlman, National Park Service

Tishie Woodwell, U.S. Steel Corporation

Mike Dzurinko, U.S. Steel Corporation

James Jarvi, U.S. Steel Corporation

Suzanne Baumann, MPCA