# Results of April 19-20, 2005Performance Tests on the Step III

# AgglomeratorLine 

# 6 Waste GasStack (SV144) andLine 7 

# Waste Gas Stack (SV151)for ParticulateMatter and Visible Emissions, Fluorides, SulfurDioxide, Carbon Monoxide, and Volatile Organic Compounds at the U.S. Steel Facility Locatedin Mt. Iron, Minnesota MPCA AQD File No. 26A AirEmissions PermitNo. 13700005-003/004 BarrProjectNo. 23/69-927002 Prepared for 

# u.s. Steel Corporation

- Minnesota Ore Operations Mt. Iron, Minnesota
June 2005



# BARR

# Results of April19-20, 2005Performance Tests on the Step IIIAgglomeratorLine 6 

# Waste GasStack (SV144) andLine 7 

# Waste Gas Stack (SV151)for ParticulateMatter and Visible Emissions, Fluorides, SulfurDioxide, Carbon Monoxide, and Volatile Organic Compounds at the U.S. Steel FacilityLocatedin Mt. Iron, Minnesota MPCA AQD FileNo. 26A AirEmissions PermitNo. 13

## 700005-003/004 BarrProjectNo. 23/69-927002 Prepared for 

# u.s. Steel Corporation

- Minnesota Ore Operations Mt. Iron, Minnesota
June 2005



# BARR 4700 West 77thStreet Minneapolis, MN55435 Phone: (952) 832-2600 Fax: (952) 832-2601

## Results of 

## April 19-20, 2005 Performance Tests on the Step 

## 1\1 Agglomerator Line 6 Waste Gas Stack (SV144) and Line 7 Waste Gas Stack (SV151) for Particulate Matter and Visible Emissions, Fluorides, Sulfur Dioxide, Carbon Monoxide, and Volatile Organic Compounds at the U.S. Steel Facility Located in Mt. Iron, Minnesota Table of Contents Report Certification iii Certification ofSampling Procedures: iii Certification ofAnalytical Procedures: iii Certification ofTest Report by Testing Company: iii Certification ofTest Report by Owner or OperatorofEmission Facility: iv Executive Summary v Introduction 1 Results Summary 3 AgglomeratorLine 6 (SY144) 3 AgglomeratorLine 7 (SY15l) 3 StackTestProcedures andMethods 6

2369927001Table I Table 2 Table 3 Table 4 Table 5 Table 6
Table 7

Figure I Figure 2 Figure 3 Figure 4 List of Tables Particulate Test Results - Line 6 Waste Gas Stack (SYI44) Particulate Test Results - Line 7 Waste Gas Stack (SYI51) Fluoride Test Results - Line 6 Waste Gas Stack (SYI44) Fluoride Test Results - Line 7 Waste Gas Stack (SYI51) Sulfur Dioxide, Carbon Monoxide, and Volatile Organic Compounds Test Results - Line 6 Waste Gas Stack(SYI44) Sulfur Dioxide, Carbon Monoxide, and Volatile Organic Compounds Test Results - Line 7 Waste Gas Stack (SYI51) Summary ofProcess Data Collected During Stack Testing

- Agglomerator Line 6 and Line 7 - April 19 & 20,2005
List of Figures Test Port Locations - Step III Line 6 Waste Gas Stack (SY144) Traverse Point Locations - Step III Line 6 Waste Gas Stack (SY144) Test Port Locations - Step III Line 7 Waste Gas Stack (SY151) Traverse Point Locations - Step III Line 7 Waste Gas Stack (SY151)

Appendix A AppendixB Appendix C AppendixD AppendixE AppendixF Appendix G AppendixH Appendix I Appendix J

#2369927001 List of Appendices Report Calculations and Nomenclature FieldData Sheets Laboratory Reports and Sample Chain ofCustody Instrument Output Calibration Data Cylinder Gas Certifications Visible Emissions Evaluator Certifications Process Operating Data Stack Test Plan Proj ect Participants

ii

# Report Certification
Certification of Sampling Procedures: I certify under penalty oflaw that the sampling procedures were performed in accordance with the approved test plan and that the data presented in this test report are, to the best of my knowledge and belief, true, accurate, and complete. All exceptions are listed and explained below. Exceptions: 1. SV054, the 078-01-2501 dust collector, could not be testedbecause full capacity cannot be reached un/irs to one li serve,?7,the collector are completed.

_ Signature: 

# 6 r:6 O,J Mark Peters n Sr. Air Quality Technician Barr Engineering Co. Date



### Certification of Analytical Procedures:

Date ichard Berg Sr. Air Quality Technician Barr Engineering Co. I certify under penalty oflaw that the analytical procedures were performed in accordance with the requirements ofthe test methods and that the data presented for use in the test report were, to the best of m knowledge and belief, true, accurate, and complete. All exceptions are listed and ex .ned bel



### Certification of Test Report by Testing Company: I certify under penalty oflaw that this test report and all attachments were preparedunder my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the test information submitted. Based on my inquiry ofthe person or persons who performed sampling and analysis relating to the performance test, the information submitted in this test report is, to the best ofmy knowledge and belief, true, accurate, and complete. All exceptions are listed and explained below. Signature:.£ 

# Ld cP-6-ct:;;- Tom Kuchin&i Date Sr. Air Quality Technician Barr Engineering Co.

#236992700I
111

## Certification of Test Report by Owner or Operator of Emission Facility: I certify underpenalty oflaw that the information submitted in this test report accurately reflects the operating conditions at the emission facility during this performance test and describes the date and nature ofall operational and maintenance activities that were performed on the process and control equipment during the month prior to the performance test. Based on my inquiry ofthe person or persons who performed the operational and maintenance activities, the information submitted in this test report is, to the best ofmy knowledge and belief, true, accurate, and complete. All exceptions are listed and explained below.

Signature:

#2369927001 Chrissy Bartovich Environmental Control Engineer U.S. Steel Corporation/Minnesota Ore Operations

IV Date

# Executive Summary

Barr Engineering Company performed emissions tests on two stacks at U.S. Steel Corporation Minnesota Ore Operations' Step III Agglomerator facility located in Mt. Iron, Minnesota. Tests were performed for determination oftotal particulate matter, particulate matter less than 10 microns, visible emissions, fluoride, sulfur dioxide, carbon monoxide and total volatile organic compounds to satisfy requirements ofU.S. Steel's Minnesota Air Emissions Permit 13700005-003 and pending Permit 13700005-004.
Test dates, results and emissions limits are presented in the Executive Summary Table. Process rates for all tests were within the process rates set out in the test plan. Emission limits were met for the existing permit.
EXECUTIVE SUMMARY TABLE (REVISED 2/7/06) TEST PARAMETER EPA Methods 1-5, and 202, EPA Method 9, Method 6C, Method 10, Method 13B, Method 25A AVERAGE TEST RESULTS Line 6 Line 7 Test Location Waste Gas Waste Gas (SV144) (SV151) Test Date 4/19/05 4/20/05 Particulate Concentration, gr/dscf Dry Catch Only (Filterable) 0.019 0.020 Dry Catch Plus Organic Condensibles 0.019 0.021 Dry Catch Plus Organic Plus Aqueous Phase 0.025 0.027 Condensibles Particulate Emissions Limit, grldscf 1 0.027 0.028

#2369927001
vTEST PARAMETER EPA Methods 1-5, and 202, EPA Method 9, Method 6C, Method 10, Method 138, Method 25A AVERAGE TEST RESULTS Line 6 Line 7 Test Location Waste Gas Waste Gas (SV144) (SV151 ) Test Date 4/19/05 4/20/05 Particulate Emissions Rate, Ib/hr Dry Catch Only (Filterable) 60 62 Dry Catch Plus Organic Condensibles 61 64 Dry Plus Organic Plus Aqueous Phase 81 82 Condensibles Particulate Emissions Limit, Iblhr2 46 46 Visible Emissions, % Opacity 0 0 Visible Emissions Limit, % Opacity 3 <20 <20 Fluoride Concentration, Ib/dscf 4.5E-08 3.9E-8 4 Emissions Rate, Ib/hr 1.0 0.85 4 Sulfur Dioxide Concentration, ppm 30 21 Emissions Rate, Ib/MMBtu 0.45 0.29 SulfurDioxide Emissions Limit, IblMMBtu 3 4 4 Carbon Monoxide Concentration, ppm 30 44 Emissions Rate, Ib/hr 48 70 Volatile Organic Compounds Concentration, ppm 1.9 1.4 VOC Emissions Rate, Ib/hr 5.6 5 3.8 Both Line 6 and Line 7 waste gas stacks meet the total particulate compliance concentration limit determined from Minn. Rules 7011.0735 Table 2. Determinations are made using the sum of filterable and organic condensibles measured in the stack gas. 2 Total particulate compliance emissions limit calculated from Minn. Rules 7011.0730. Determinations are made using the sum of filterable and organic condensibles measured in the stack gas. 3 Emissions limits are in Minntac's Title V permit 13700005-003. 4 Line 7 fluoride concentration and emissions rate corrected 2/7/06. 5 VOC emissions rate corrected 2/7/06.

#2369927001

VI

# Introduction

Barr Engineering Co. performed emissions tests at U.S. Steel Corporation - Minnesota Ore Operations' Agglomerator facilities located in Mt. Iron, Minnesota. Tests were conducted on the two Agglomerator Step III waste gas stacks listed below for the determination oftotal particulate matter (PM), particulate matter less than 10 microns (PMIO) , visible emissions (VE), fluoride (P-), sulfur dioxide (S02), carbonmonoxide (CO) and total volatile organic compounds (VOC). Source Equipment Permit Permit Green Ball Type Group Stack Feed Rates Number Vent LTPH Number Line 6 Waste Wet GRP011 SV144 525 to 600 Gas Stack scrubber Line 7 Waste Wet GRP001 SV151 525 to 600 Gas Stack scrubber

The tests were performed to demonstrate compliance with the facility's Minnesota Air Emissions Permit 1370005-003 and pending Title V/PSD Permit 1370005-004. A test plan was submitted on March 18, 2005. The test plan was reviewed at apretestmeeting held on April 11. The test plan and the approval letter dated April 11, 2005 from Andy Place ofthe Minnesota Pollution Control Agency are provided in Appendix 1. The test plan included Crusher dust collector SV054, which had been rescheduled fortesting because one ofthe lines the collector serves was down and the collector could not be tested at worst case conditions. The collector was included in the test plan for this mobilizationbut the line is not yet repaired. The equipmentproblems were discussed in atelephone conversation between Andy Place ofthe MPCA and Ray Potts on February 18 and U. S. Steel subsequently submitted an administrative amendmentto allow time to accomplishthe testing. Applicable emissions limits for Group 011 Agglomerator Lines 6 & 7 are determinedby Minn. Rule 7011.0610 Subp.l(A)(I) for particulate matter concentration and Minn. Rule 7011.0610 Subp.l(A)(2) for visible emissions under permit 1370005-003.

#2369927001 1MarkPetersen led the Barr testteam. Chrissy Bartovich and Ron Braski ofU.S. Steel provided test coordination with facility operations. The performance tests were not witnessedby the MPCA. A list ofproject participants is provided in Appendix J.

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# Results Summary

Results ofthe emissions performance tests are summarized in the Executive Summary Tables. The particulate emissions results are presented for filterable particulate emissions, filterable plus organic particulate emissions, and total particulate emissions-filterable, organic condensibles, and inorganic condensibles. Filterable plus organic particulate emissions results are used when determining compliance with the particulate emissions (PM) limitin the Minnesota Rules. Emissions of particulate matterless than 10 microns (PM lO) are determined using the filterable plus organic and inorganic condensible particulates. The exhaust from these scrubbers is too wet to allow PMlO determination by Method 20 IA. 

### Agglomerator Line 6 (SV144) Results ofthe Line 6 waste gas stacktests performed on April 19 are presentedin Table I for particulate matter, Table 3 for fluoride and Table 5 for gaseous pollutants. The stack complies with the Minn. Rules 7011.0715 Subp. I(A) for particulate matter emissions. Emissions limits were determined from Minn. Rules 7011.0735 at an average airflow rate of376,000 dry standard cubic feet per minute (dscfm), and fromMinn. Rules 7011.0730 at the average greenball feed rate of546 long tons per hour (LTPH). Fluoride emissions were 1.0pounds per hour (lb/hr), above the current proposed limit in the pending Title V/PSD permit 1370005-004. However, U. S. Steel has submitted permit comments requesting a higher fluoride limit in the pending PSD permitbased on previous test data. Emissions ofthe gaseous pollutants; sulfur dioxide (S02), carbon monoxide (CO) and volatile organic compounds (yOC) metthe limits in the Title V1PSDpermit.
Fluoride and gaseous pollutant emissions test runs were begun to coincide with PM test run 2. Opacity ofvisible emissions observations were conducted concurrently with PM testrun 2. The opacity observation results are not summarizedbecause all observations were zero. The opacity data is included in Appendix B. 

### Agglomerator Line 7 (SV151) Results ofthe Line 7 waste gas stacktests performed on April 20 are presented in Table 2 for particulate matter, Table 4 for fluoride and Table 6 for gaseous pollutants. The stack complies with the Minn. Rules 7011.0715 Subp. l(A) for particulate matter emissions. Emissions limits were determined from Minn. Rules 7011.0735 at an average airflow rate of358,000 dscfm, and from Minn. Rules 7011.0730 at the average green ball feed rate of548 LTPH. Fluoride emissions were 1.2 #2369927001 3lblhr, above the currentproposed limit in the pending Title V/PSD permit. However, U. S. Steel has submitted comments requesting a higher fluoride limit in the pending PSD permitbased onprevious test data. Emissions ofthe gaseous pollutants; sulfur dioxide, carbon monoxide and volatile organic compounds (VOC) met the limits in the Title VIPSD permit. PM, fluoride and gaseous pollutant emissions tests runs were conducted concurrently for all runs on Line 7. Opacity ofvisible emissions observations were conducted concurrently with PM test run 2. The opacity observationresults are not summarized because all observations were zero. The opacity data is included in Appendix B. Table 7 provides information on the Agglomerator process rates and control equipment operating parameters collected during all tests.

#2369927001 4

# Process Description

The Agglomerator grate-kiln systems consistoffour primary components; the dryer, preheat furnace, kiln and cooler. Green pellets from the balling drums enter the grate, supported by a slotted grate. The grate is divided into three sections: two for drying and one for preheating the pellets. Hot process gases are passedthroughthe bed ofgreen pellets on the grate in order to first dry and then preheat them. The grate then transports the pellets into the rotary kiln. In the kiln the pellets are tumbled and indurated (heat hardened) by heating them to 2450 'F. The pellets are then discharged into an annular cooler with slottedtraveling pallets. Ambient air is passed through the bed of pellets in the coolerto cool the pellets andrecover heat. The waste gas stacks are controlled for particulates by intermediate drop-outboxes, impingement plates, and cyclones. In addition, Line 6 and Line 7 stacks are controlledby wet scrubbers for particulate emissions. Sampling was performed at the rooflevel and after all control equipment. Operating parameters were recorded for each test run. The parameters included fuel usage, green pellet feed rate (LTPH), fired pellet productionrate (LTPH), scrubber pressure drop (in H20 ) and scrubber water flow (gpm). Summaries ofthe process operating data are provided Table 7 and in Appendix H. Fuel analysis data for coal are provided in Table 8.

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# Stack Test Procedures and Methods
Testing was performed from ports meeting USEPA Method 1 criteria. A 24-point traverse was performed on the Line 6 (SVI44) and the Line 7 (SVI51) waste gas stacks. The traverses were performed from four ports on each stack for particulate and fluoride measurements. Historical measurements were referenced for cyclonic flow. Sample port location and traverse pointdetail are providedin Figures 1-4. Volumetric airflow determinations were performed in accordance with Method 2 using an S-type pitottube. Airflows were determined in conjunction with the Method 5 and Method l3B performance tests. Stack gas compositions were determinedby Method 3A. Stack gas moisture contentwas determined by the performance ofEPA Method 4, in conjunction withthe Method 5 and Method 13B performance tests. Particulate concentrations and emissionrates were determined in accordance withMethod 5. Particulate concentrations include condensible particulate matter collectedin the back halfofthe sample train. Condensible particulate matter was determinedusing Method 202. The impinger contents were purged with nitrogen gas in the field and titratedin the lab to neutralize acids. Minnesotatotal particulate matter (PM) was determined from the sum offilterable and condensible organic particulate. Particulate matter less than 10microns (PMlO) was determinedby adding inorganic condensible particulate to the filterable plus organic particulate. Determination ofopacity of visible emissions was made by Method 9. Fluoride emissions were determinedby Method 13B with filtration occurring after the liquid condensation. Gaseous pollutant emissions were determinedby Method 6C for sulfur dioxide, Method 10 for carbon monoxide, and Method 25A for volatile organic compounds. Gaseous emissions rates were determined in conjunction with Method 13B airflows. The USEPAperformance test methods cited in this report are found in 40 CFR Part 60, Appendix A, except for Method 202, which is found in 40 CFR Part 51, Appendix M.

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# Project Participants

Minnesota Pollution Control Agency Andrew Place - Performance Test Coordinator Hongming Jiang - Permit Engineer
U.S. Steel Corporation - Minnesota Ore Operations Larry Salmela

- DepartmentManager Environmental Control Chrissy Bartovich

- Environmental Control Engineer Ron Braski

- Agglomerator Coordination
Barr Engineering Company TimRussell - Vice President/Chemical Engineer MarkPetersen - Senior Air Quality TechnicianlTeamLeader Dan Koschak

- Environmental Engineering Technician Richard Berg - Senior Air Quality Technician

#2369927001 J-l

# Tables