Results ofApril 19-20, 2005 Performance Tests on

the Step IIIAgglomerator 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

MPCA AQD File No. 26A

Air Emissions Permit No. 13700005-003/004

Barr Project No. 23/69-927002

Preparedfor

u.s. Steel Corporation - Minnesota Ore Operations

Mt. Iron, Minnesota

June 2005

BARR

Results ofApril 19-20, 2005 Performance Tests on

the Step III 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

MPCA AQD File No. 26A

Air Emissions Permit No. 13700005-003/004

Barr Project No. 23/69-927002

Preparedfor

u.s. Steel Corporation - Minnesota Ore Operations

Mt. Iron, Minnesota

June 2005

BARR

4700 West 77th Street

Minneapolis, MN 55435

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 of Sampling Procedures: iii

Certification ofAnalytical Procedures: iii

Certification ofTest Report by Testing Company: iii

Certification ofTest Report by Owner or Operator ofEmission Facility: iv

Executive Summary v

Introduction 1

Results Summary 3

Agglomerator Line 6 (SY144) 3

Agglomerator Line 7 (SY15l) 3

Stack Test Procedures and Methods 6

2369927001
Table 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 of Process 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

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List of Appendices

Report Calculations and Nomenclature

Field Data 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 tested because full capacity cannot be

reached un/irsto 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:

ichard Berg Date

Sr. Air Quality Technician

Barr Engineering Co.

I certify under penalty oflaw that the analytical procedures were performed in accordance

with the requirements of the 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 of law that this test report and all attachments were prepared under 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 of my 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.

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111
Certification of Test Report by Owner or Operator of Emission

Facility:

I certify under penalty 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 of all 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 of the person or persons who performed the operational and

maintenance activities, the information submitted in this test report is, to the best of my

knowledge and belief, true, accurate, and complete. All exceptions are listed and explained

below.

Signature:

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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 of U.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

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v

TEST 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, Iblhr 2 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

Sulfur Dioxide 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.

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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 of total particulate matter

(PM), particulate matter less than 10 microns (PMIO) , visible emissions (VE), fluoride (P-), sulfur

dioxide (S02), carbon monoxide (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 a pretest meeting held

on April 11. The test plan and the approval letter dated April 11, 2005 from Andy Place of the

Minnesota Pollution Control Agency are provided in Appendix 1.

The test plan included Crusher dust collector SV054, which had been rescheduled for testing because

one of the 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 mobilization but the line is not yet

repaired. The equipment problems were discussed in a telephone conversation between Andy Place

ofthe MPCA and Ray Potts on February 18 and U. S. Steel subsequently submitted an administrative

amendment to allow time to accomplish the testing.

Applicable emissions limits for Group 011 Agglomerator Lines 6 & 7 are determined by 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.

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1
Mark Petersen led the Barr test team. Chrissy Bartovich and Ron Braski of U.S. Steel provided test

coordination with facility operations. The performance tests were not witnessed by the MPCA. A list

of project participants is provided in Appendix J.

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2
Results Summary

Results of the 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) limit in the Minnesota Rules. Emissions of

particulate matter less 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 of the Line 6 waste gas stack tests performed on April 19 are presented in 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 of 376,000 dry standard cubic

feet per minute (dscfm), and from Minn. Rules 7011.0730 at the average green ball feed rate of 546

long tons per hour (LTPH). Fluoride emissions were 1.0 pounds 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 permit based on previous test

data. Emissions of the gaseous pollutants; sulfur dioxide (S02), carbon monoxide (CO) and volatile

organic compounds (yOC) met the limits in the Title V1PSD permit.

Fluoride and gaseous pollutant emissions test runs were begun to coincide with PM test run 2.

Opacity of visible emissions observations were conducted concurrently with PM test run 2. The

opacity observation results are not summarized because all observations were zero. The opacity data

is included in Appendix B.

Agglomerator Line 7 (SV151)

Results of the Line 7 waste gas stack tests 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 of 358,000 dscfm, and from

Minn. Rules 7011.0730 at the average green ball feed rate of 548 LTPH. Fluoride emissions were 1.2

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3
lblhr, above the current proposed limit in the pending Title V/PSD permit. However, U. S. Steel has

submitted comments requesting a higher fluoride limit in the pending PSD permit based on previous

test data. Emissions of the 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 of visible emissions observations were conducted concurrently with PM test run 2.

The opacity observation results 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.

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4
Process Description

The Agglomerator grate-kiln systems consist offour 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 passed through the bed of green 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 slotted traveling pallets. Ambient air is passed through the bed of pellets

in the cooler to cool the pellets and recover heat.

The waste gas stacks are controlled for particulates by intermediate drop-out boxes, impingement

plates, and cyclones. In addition, Line 6 and Line 7 stacks are controlled by 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 production rate (LTPH), scrubber pressure drop (in H20 ) and

scrubber water flow (gpm). Summaries of the 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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5
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 point detail are

provided in Figures 1-4.

Volumetric airflow determinations were performed in accordance with Method 2 using an S-type

pitot tube. Airflows were determined in conjunction with the Method 5 and Method l3B performance

tests.

Stack gas compositions were determined by Method 3A. Stack gas moisture content was determined

by the performance of EPA Method 4, in conjunction with the Method 5 and Method 13B

performance tests.

Particulate concentrations and emission rates were determined in accordance with Method 5.

Particulate concentrations include condensible particulate matter collected in the back half of the

sample train. Condensible particulate matter was determined using Method 202. The impinger

contents were purged with nitrogen gas in the field and titrated in the lab to neutralize acids.

Minnesota total particulate matter (PM) was determined from the sum of filterable and condensible

organic particulate. Particulate matter less than 10 microns (PMlO) was determined by adding

inorganic condensible particulate to the filterable plus organic particulate. Determination of opacity of

visible emissions was made by Method 9.

Fluoride emissions were determined by Method 13B with filtration occurring after the liquid

condensation. Gaseous pollutant emissions were determined by 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 USEPA performance 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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6
Project Participants

Minnesota Pollution Control Agency

Andrew Place - Performance Test Coordinator

Hongming Jiang - Permit Engineer

U.S. Steel Corporation - Minnesota Ore Operations

Larry Salmela - Department Manager Environmental Control

Chrissy Bartovich - Environmental Control Engineer

Ron Braski - Agglomerator Coordination

Barr Engineering Company

Tim Russell - Vice President/Chemical Engineer

Mark Petersen - Senior Air Quality TechnicianlTeam Leader

Dan Koschak - Environmental Engineering Technician

Richard Berg - Senior Air Quality Technician

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J-l

Tables