Subject: Discussion of Testing, Monitoring, Recordkeeping and 

Reporting Requirements

To: Minnesota and Michigan Taconite FIP Docket

From: Steven Rosenthal

The following discussion explains the basis for the testing 

and monitoring, recordkeeping, and reporting requirements that 

are needed to ensure compliance with the proposed BART limits in 

the FIP.

1. Testing and Monitoring

EPA is requiring the seven taconite facilities, Keetac, 

Hibbing, Minntac, United Taconite, ArcelorMittal, Northshore, 

and Tilden, to use CEMS, continuous diluent monitors (O2 or CO2), 

and continuous flow rate monitors on their indurating furnaces

to measure NOx emissions. EPA selected CEMS as the method for

determining compliance instead of performance testing because of 

the variability in indurating furnace operations and emissions. 

CEMS provide more dependable data for determining ongoing 

compliance for continuously varying operations because CEMS will 

eliminate the need to extrapolate emissions under varying 

operational conditions. The taconite facilities will operate 

the CEMS, in accordance with 40 CFR 63.8, and Appendices B and F 

of Part 60, which provide the concentration of emissions -

typically in parts per million. The data collected from the 

continuous diluent and flow rate monitors is used in conjunction 
with an emission factor to convert NOx concentrations to units 

of the standard (lbs/MMBtu). EPA is also requiring Northshore

to conduct performance testing on its process boiler units in 

accordance with the requirements of 40 CFR 60.8, 40 CFR 60.11, 

and Appendix A of Part 60 to determine the NOx emissions.

The seven taconite facilities also need to operate CEMS,

continuous diluent monitors (O2 or CO2), and continuous flow rate 

monitors to measure SO2 from their indurating furnaces. Data 

from the monitors are used to calculate the SO2 emissions in ppmv

and pounds per hour, the units of the standard. Performance 

testing for demonstrating compliance with the SO2 removal 

efficiency standard requires measuring the SO2 concentrations at 

the inlet to the control device and after emissions exit the 

control device.

The seven taconite facilities are required to conduct 

initial performance testing for NOx and SO2, in accordance with 

the requirements of 40 CFR 63.7 and Appendix A of Part 60 to 

determine initial compliance with applicable emission limits. 

The general reference methods to be used for initial testing 

include Methods 1-4, 6-6C, and 7-7E.

Keetac is also required to continuously monitor the 

hydrogen ion concentration (pH) in its scrubber. Keetac will 

operate the pH monitor in accordance with the requirements of 40 

CFR 163.3, using EPA method 150.2. A pH level at or above the 
standard, 7.5, indicates that the control device will remove 

sufficient SO2 from the exhaust. Performance of the control will 

decline if the water is more acidic.

2. Recordkeeping Requirements

EPA is proposing standard recordkeeping requirements for 

the taconite facilities. Facilities are required to keep a 

number of records such as performance test results, maintenance 

records, malfunction records, and copies of submitted reports 

for at least five years. Details of the recordkeeping 

requirements can be found below in the proposed 40 CFR part 52 

language.

3. Reporting Requirements

EPA provides the facilities with details on what it must 

report in the proposed rule language. The deadlines for the 

reporting are also provided. The reporting requirements specify

that a source must provide at least 60 days notification of an 

initial performance test and then submit the results within 60

days following completion of initial performance testing. 

Sources are to report non-continuous performance test results 

within 90 days of completing the test. The content of 

semiannual compliance reports is listed. Sources are to submit 

the semiannual reports no later than January 31 and July 31 each 

year for the preceding July to December or January to June time 

period. A source is required to submit its site-specific 
performance evaluation test plan at least 60 days prior to 

conducting a CEMS performance test.