Request to Provide Information Pursuant to the Clean Air Act

1. (Subpart 1) For the time period from January 1, 2004, to the date of your receipt of this Request, for each taconite iron ore pellet manufacturing facility you assisted or provided consulting services to regarding the cost effectiveness threshold appropriate for use in a Best Available Retrofit Technology (BART) analysis, identify the BART cost effectivene ss threshold amount or range you determined for each facility, and the basis for your determination.

Barr Engineering Company completed BART analyses for the following facilities:

 U.S. Steel Corporation’s Keewatin Taconite Operations (Keetac)

 U.S. Steel Corporation’s Minnesota Ore Operations (Minntac)

 Northshore Mining Company (NMC)

 Hibbing Taconite Company (Hibbtac)

 United Taconite (Utac)

 Mittal Steel USA – Minorca Mine (Mittal Steel)

For all analyses listed above, the BART Cost Effec tiveness Thresholds ($/ton removed) were as follows:

Pollutant BART Cost Effectiveness Threshold ($/ton removed) Sulfur Dioxide $1,000-1,300/ton Nitrogen Oxides $1,300-1,800/ton

The basis of this threshold was desc ribed in the BART reports as follows:

“Based on the BART final rule, court cases on cost-e ffectiveness, guidance from other regulatory bodies, and other similar regulatory programs like Clean Air Interstate Rule (CAIR), cost-effective air pollution controls in the electric utility industry for large power plants are in the range of [$1,000 to $1,300 per ton

SO 2 removed][$1,300 to $1,800 per ton NOx removed] as illustrated in Attachment A, Summary of Relevant Economic Feasibility Control Costs (included on the CD as a separate file). This cost-effective

threshold is also an indirect measure of affordab ility for the electric utility industry used by USEPA to support the BART rulemaking process.

For the purpose of the taconite BART an alyses, the [$1,000 to $1,300 per ton SO 2 removed][$1,300 to $1,800 per ton NOx removed] cost effectiveness thres hold is used as the cutoff in proposing BART. The taconite industry is not afforded the same market stab ility or guaranteed cost recovery mechanisms that are afforded to the electric utility industry. Therefore, the [$1,000 to $1,300 per ton SO 2 removed][$1,300 to $1,800 per ton NOx removed] is c onsidered a greater business risk to the taconite industry. Thus it is

reasonable to use it as a cost effective threshold fo r proposing BART in lieu of developing industry and site specific data.”

(Subpart 2) Provide citations for all sources used and/or consulted in maki ng your determination.

The following citations are included in Attachment A, Summary of Relevant Economic Feasibility ($/ton)

Control Costs:

 Midwest Regional Planning Organization (RPO), Interim White Paper – Midwest RPO Candidate Control Measures (Midwest RPO Report Re ferencing CAIR), Jaunuary 14, 2005. U.S. Environmental Protection Agency, Kammer Power Plant; West Virginia; Stack Height Infeasibility Analysis (Kammer EPA Decision); Federal Register: Augus t 19, 1998 (Volume 63, Number 160), Page 44434-44436.

 MACTEC Federal Programs/MACTEC Engineerin g and Consulting, Inc., Midwest Regional Planning Organization (RPO) Boiler Best Availa ble Retrofit Technology (BART) Engineering Analysis (LADCO Midwest RPO Boiler Analysis ), Prepared for The Lake Michigan Air Directors Consortium (LADCO), March 30, 2005.

 Northeast States for Coordinated Air Use Ma nagement In Partnership with The MidAtlantic/Northeast Visibility Union, Assessmentof Control Technology Options for BARTEligible Sources, Steam Electric Boilers, Industria l Boilers, Cement Plants and Paper and Pulp Facilities (MANE-VU BART Control Assessment), March 2005.

 Gregory H. Bowers, Appellant, v. Southwest Air Pollution Control Authority, Pacificorp, Washington Water Power Company, City of Seattle, City of Tacoma, PUD #1 of Snohomish County, Puget Sound Energy, PUD # of Grays Harbor County and Portland General Electric/Enron Corporation, Respondents, Finding s of Fact, Conclusions of Law, PCHB 98-3 &

31.

 Western Regional Air Partnership Regional Haze BART (Trading Program Option)(WRAP Trading Program Methodology), DRAFT July 16, 1999.

Person providing information: Chandler Taylor, in consultation with Er ik Bolemen, Tony Shoberg, Jack Kennedy, Teresa Kinder, George Pruchnofsk i, Beth Havlik, and Lori Stegink.

2. (Subpart 1) For the time period from January 1, 2004, to the date of your receipt of this Request, for each taconite iron ore pellet manufacturing facility you assisted or provided consulting services to regarding the annualized pollution control cost valu e appropriate for use in a BART analysis, identify the annualized pollution control cost value you det ermined for each facility, and the basis for your

determination.

The general approach for determining the annualized pollution control cost values for each facility is

described herein. The control cost tables that were included as Appendix A of the BART reports included specific references for control cost methods and op erating costs for consumable materials such as electricity, water, and chemicals. These cost tables are included in Attachments B through F as described in the cover letter Table of Contents to this response. Page 1 of each of the control cost tables includes a Pollution Control Cost, in $/ton, by pollutant, by control technology, and by unit, as applicable.

In general, the control cost summary tables include the following components:

Cost Summary – This table lists each control t echnology, control efficiency, controlled emissions, emission reduction, installed capital cost , total annual cost, and pollution control cost.

Summary of Utility, Chemical and Supply Costs – This table includes a list of consumable

materials 1 such as electricity, water, and chemicals as well as labor, sales tax, and interest rate. Also included are design information such as fl ow rate and temperature for each stack. The

source of information for each item is listed in this table. This information is used throughout the remaining control cost worksheets.

1 Note that links in the tables to the Energy Information Administration website are no longer valid.Control Cost Worksheets – The control cost worksheets are ge nerally divided into three pages. The first page includes a summary of the cost information as well as notes and assumptions. The second page includes the calculation of capital and operating costs following the methods

outlined in EPA’s Air Pollution Control Cost Manual. The third page includes more detailed calculations relating to operating costs. Additi onal references are noted throughout the control cost worksheets to clarify sources of informati on. In the case of Selective Catalytic Reduction (SCF) with Reheat, there are three pages for calcu lations related to the SCR portion of the control technology as well as an additional four pages sp ecific to the reheat portion of the control technology. This was done to account for the reheating of gases up to SCR operating temperatures for application of a “clean side” SCR system downstream of SO 2 and particulate removal equipment. In this case, the summary page that includes the emission control cost calculation pulls in information from both the SCR and Reheat calculation pages.

Unless otherwise noted in the control cost spread sheets, equipment design was based on the maximum 24-hour emissions, vendor estimates, and U.S. EPA cost models for all six taconite facilities. Capital costs were based on vendor quotations or costs of si milar projects. The cost for each specific unit was scaled to each stack’s flow rate using the 6/10 power law 2 as shown in the following equation:

Cost of equipment A = Cost of equipment B * (capacity of A/capacity of B) 0.6

Direct and indirect costs were estimated as a percentage of the fixed capital investment using U.S. EPA models and factors. Operating costs were based on 93% utilization and site specific operating hours per year. Operating costs of consumable materials were established based on the U.S. EPA control cost manual and engineering experience, and were adju sted for the specific flow rates and pollutant

concentrations.

For some control equipment additional costs were adde d to account for a retrofit installation. Due to space considerations, 60% 3 of the total capital investment was origin ally included in the costs to account for a

retrofit installation. After discussions with each facili ty’s staff and/or management, it was determined the plot space surrounding the furnaces is congested, and the area surrounding the building supports vehicle traffic to transport materials to and from the buildi ng and maintenance access to the large equipment. Additionally, the structural design of the existing building would not support additional equipment on the roof. Therefore, the cost estimates provide for additional site-work and construction costs to accommodate the new equipment within the facility. A site-specific estimate for site work, foundations,

and structural steel was added to arrive at the total retrofit installed cost of the control technology. The site specific estimate was based on Barr’s experience with similar projects.

(Subpart 2) Provide citations for all sources used and/or consulted in maki ng your determination.

Citations are included in the cost tables.

Person providing information: Tony Shoberg, in cons ultation with Erik Bolemen, Jack Kennedy, Teresa Kinder, George Pruchnofski, Beth Havlik , Lori Stegink and Chandler Taylor.

3. For the time period from January 1, 2004, to the da te of your receipt of this Request, for each taconite iron ore pellet manufacturing facility y ou assisted or provided consulting services to

2 Peters, M.S. and Timmerhaus, K.D. 1968. Plant Design and Econom ics for Chemical Engineers, Second Edition. McGraw Hill,

Inc.

3 U.S. EPA, CUE Cost Wor kbook Version 1.0. Page 2.regarding a BART analysis, for which you determined the technical and economic feasibility of the use of any low nitrogen oxides (NOx) burner t echnology, provide a list of the manufacturers, distributors, and agents or representatives thereof, you contacted or consulted with in making your determination. Provide the address of each entity listed, and identify the individuals whom you

contacted or consulted w ith at each listed entity.

Kenneth Gardner Jan Weckes Metso Corporation Outokumpu Technology GmbH 350 Railroad Street Eschweiler StaBe 101-109, D-52477 Alsdorf Danville, PA 17821-2048 Germany

570-271-7637 +49 240 467 08 0 Kenneth.gardner@metso.com Jan.Weckes@outokumpu.com

Peter Zonneveld Koen Meijer

Danieli Corus Danieli Corus

P.O. Box 10000 P.O. Box 10000

1970 CA Umuiden 1970 CA Umuiden

The Netherlands The Netherlands +39 (0432) 597821 +31 (6513) 93458

Peter.Zonneveld@danieli-corus.com Koen.Meijer@danieli-corus.com

Person providing information: Chandler Taylor, in co nsultation with Teresa Kinder, Erik Boleman, Tony Shoberg and Jack Kennedy.

4. For the time period from January 1, 2004, to the da te of your receipt of this Request, for each taconite iron ore pellet manufacturing facility y ou assisted or provided consulting services to regarding a BART analysis, for which you determined the technical and economic feasibility of the use of any selective catalytic reduction technology, provide a list of the manufacturers, distributors, and agents or representatives thereof, you contacted or consulted with in making your determination. Provide the address of each entity listed, and id entify the individuals w hom you contacted or consulted with at each listed entity.

Bob Schreiber Bob Harold Schreiber, Yonley &ssociates Babcock Power 16252 Westwoods Business Park Drive 5 Neponset Street Ellisville, MO 63021 PO Box 15040 636-256-7200 Worcester, MA 01615-0040

508-854-3941 BHarold@babcockpower.com

Elizabeth Govey Cormetech, Inc. Treyburn Corporate Park

5000 International Drive Durham, NC 27712

919-620-3000 GoveyEM@Cormetech.com

Person providing information: Chandler Taylor, in co nsultation with Teresa Kinder, Erik Boleman, Tony Shoberg and Jack Kennedy.5. For the time period from January 1, 2004, to the da te of your receipt of this Request, provide all technical or economic feasibility re ports or studies you prepared re garding the application of Low NOx burner technology for use at taconite iron ore pellet manufacturing facilities.

The following four reports or studi es are included on the compact disc:

1. Application for a Permit to Construct and Operate an Integrated Steel Plant, Volume II, Appendix C Best Available Control Technology Review, Prepared for Minnesota Steel Industries, LLC, May 2007

2. Best Available Control Technology Analysis, Pr epared for Essar Steel Minnesota LLC, October

2011

3. Air Emissions Permit Application for the Furnace 5 Reactivation Project, Volume I, Permit Application Forms, Regulatory Applicability Summary and BACT Analysis, Prepared for Northshore Mining Company, May 2, 2005

4. NOx Reduction Technology Evaluati on and Mitigation, Proposal fo r Keetac Expansion, February 10, 2010

Person providing information: Chandler Taylor, in consultation with Erik Bolemen, Jack Kennedy, Teresa Kinder, George Pruchnofski, Beth Hav lik, Lori Stegink, and Mike Hansel.