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 effectiveness 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 Effectiveness 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 described in the BART reports as follows: 

“Based on the BART final rule, court cases on cost-effectiveness, 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 

SO2 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 affordability for the electric utility industry used by USEPA to 

support the BART rulemaking process. 

For the purpose of the taconite BART analyses, the [$1,000 to $1,300 per ton SO2 removed][$1,300 to 

$1,800 per ton NOx removed] cost effectiveness threshold is used as the cutoff in proposing BART. The 

taconite industry is not afforded the same market stability or guaranteed cost recovery mechanisms that 

are afforded to the electric utility industry. Therefore, the [$1,000 to $1,300 per ton SO2 removed][$1,300 

to $1,800 per ton NOx removed] is considered a greater business risk to the taconite industry. Thus it is 

reasonable to use it as a cost effective threshold for proposing BART in lieu of developing industry and 

site specific data.” 

(Subpart 2) Provide citations for all sources used and/or consulted in making 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 Referencing CAIR), Jaunuary 14, 2005. 
 U.S. Environmental Protection Agency, Kammer Power Plant; West Virginia; Stack Height 

Infeasibility Analysis (Kammer EPA Decision); Federal Register: August 19, 1998 (Volume 63, 

Number 160), Page 44434-44436. 

 MACTEC Federal Programs/MACTEC Engineering and Consulting, Inc., Midwest Regional 

Planning Organization (RPO) Boiler Best Available 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 Management In Partnership with The MidAtlantic/Northeast Visibility Union, Assessment of Control Technology Options for BARTEligible Sources, Steam Electric Boilers, Industrial 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, Findings 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 Erik Bolemen, Tony Shoberg, Jack 

Kennedy, Teresa Kinder, George Pruchnofski, 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 value appropriate for use in a BART analysis, identify 

the annualized pollution control cost value you determined 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 operating 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 technology, 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 

materials1

 such as electricity, water, and chemicals as well as labor, sales tax, and interest rate. 

Also included are design information such as flow 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 generally 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. Additional references are noted throughout the control 

cost worksheets to clarify sources of information. In the case of Selective Catalytic Reduction 

(SCF) with Reheat, there are three pages for calculations related to the SCR portion of the control 

technology as well as an additional four pages specific 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 SO2 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 spreadsheets, 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 similar projects. The cost for each specific unit was 

scaled to each stack’s flow rate using the 6/10 power law2

 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 adjusted for the specific flow rates and pollutant 

concentrations. 

For some control equipment additional costs were added to account for a retrofit installation. Due to space 

considerations, 60%3

 of the total capital investment was originally included in the costs to account for a 

retrofit installation. After discussions with each facility’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 building 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 making your determination. 

Citations are included in the cost tables. 

Person providing information: Tony Shoberg, in consultation 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 date of your receipt of this Request, for each 

taconite iron ore pellet manufacturing facility you assisted or provided consulting services to 

 

2

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

Inc. 

3

 U.S. EPA, CUE Cost Workbook 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 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 identify the individuals whom you 

contacted or consulted with 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 consultation with Teresa Kinder, Erik Boleman, Tony 

Shoberg and Jack Kennedy. 

4. 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 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 identify the individuals whom 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 consultation with Teresa Kinder, Erik Boleman, Tony 

Shoberg and Jack Kennedy. 
5. For the time period from January 1, 2004, to the date of your receipt of this Request, provide all 

technical or economic feasibility reports or studies you prepared regarding the application of Low 

NOx burner technology for use at taconite iron ore pellet manufacturing facilities. 

The following four reports or studies 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, Prepared 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 Evaluation and Mitigation, Proposal for Keetac Expansion, February 

10, 2010 

Person providing information: Chandler Taylor, in consultation with Erik Bolemen, Jack Kennedy, Teresa 

Kinder, George Pruchnofski, Beth Havlik, Lori Stegink, and Mike Hansel.