Minnesota Pollution Control Agency 

520 lafayette Road North I St. Paul, MN 55155-4194 I 651-296-6300 I 800-675-3843 I 651-282-5332 TTY I www.pca.state.mn.us 

November 20, 2009 

Mr. Scott Coleman 

General Manager 

US Steel Corp - Minntac 

8819 Old Highway 169 

Mt. Iron, MN 55768 

RE: Request for the Approval of Pilot Testing and Installation of a Low Nitrogen Oxides Main Burner on 

Agglomeration Line 7 at the US Steel- Minnesota Ore Operations Minntac Facility 

Dear Mr. Coleman: 

This letter is in response to your July 15, 2009, letier to the Minnesota Pollution Control Agency (MPCA) 

regarding the proposed installation and pilot testing of a low Nitrogen Oxides (NOx) main burner on 

Agglomeration Line 7 at the Minntac facility in Mountain Iron, Minnesota. In the letter, US Steel CorpMinnesota Ore Operations Minntac (Minntac) requested the MPCA concurrence with its determination 

that the facility does not need an air emissions permit amendment (administrative, minor, moderate, or 

major) to install and pilot test a low NOx main burner on Agglomeration line 7 at Minntac. 

Minn. R. 7007.1150 dictates when an air permit amendment is needed based on several criteria. The 

MPCA does not exempt specific activities from the need to obtain a petmit or permit amendment, other 

than what is listed in Minn. R. 7007. In order to evaluate those criteria the MPCA requested additional 

information from Minntac on possible air emission impacts that could result from the burner replacement. 

This information request was fulfilled with a supplemental letter from Minntac dated November 12, 2009. 

The November 12, 2009, letter contained statements on behalf of the vendors selected to design the low 

NOx main burner, Hatch Associates Consultants, Inc. and COEN Company, Inc. These statements 

addressed possible changes to fuel use rates, fuel mixes, and pollutant emissions that could result from the 

burner replacement. The information submitted byMinntac in the July 15,2009, letter and subsequent 

November 12, 2009, letter were used for the evaluation of the criteria in Minn. R. 7007.1150. 

Generally, when a reduction in NOx emissions from fuel combustion is proposed the pollutant of concern 

for potential increase is carbon monoxide (CO). However, due to the design of the proposed low NOx 

main burner, CO emissions are not anticipated to increase. Furthermore, as explained in the 

manufacturers' letters dated November 3, 2009, and November 6, 2009, and submitted to the MPCA via 

Minntac's November 12,2009, letter, due to the design and operation of the proposed burner, CO 

emissions are expected to decrease. An analysis of the CO emissions fi·om the pilot test should be 

included in the Pilot Test Results submittal as required by the Pern1ittee's Air Emission Permit 

No. 13700005-005. 

Based on the information provided in the July 15,2009, and November 12,2009, letters, the MPCA 

concurs with Minntac's determination that an air emissions permit amendment (administrative, minor, 

moderate, or major) is not required for replacement and pilot testing of a low NOx main burner on 

Minntac's Agglomeration line 7. The MPCA staff based this conclusion on the following assumptions: 

• The change does not increase emissions of any regulated air pollutant. 

• The change does not allow for an increase in fuel consumption or production rates. 

• Cunent monitoring, recordkeeping and reporting practices are sufficient to demonstrate 

compliance with the applicable requirements. 

St. Paul I Brainerd I Detroit Lakes I Duluth I Mankato I Marshall I Rochester I Willmar I Printed on 100% post-consumer recycled paper 
Mr. Scott Coleman 

Page2 

The cmTent Air Emission Pem1it No. 13700005-005 in which Minntac operates under, for purposes of the 

Retroactive Prevention of Significant Deterioration Program (PSD) Petmitting Requirements, requires the 

Permittee to commence pilot testing of selected NOx control technologies, upon written MPCA approval 

of the NOx control technology selection and test schedule as submitted in an Engineering Analysis Report 

as well as receipt of permit(s) as needed. 

Based on the above concunence with Minntac's detennination that the facility does not need an air 

emissions permit amendment (administrative, minor, moderate, or major) to install and pilot test a low 

NOx main burner on Agglomeration line 7, and a letter dated April16, 2009, from the MPCA approving a 

Febmary 27, 2009, Engineering Analysis Report for the selection and test schedule of the proposed NOx 

control technologies, Minntac has final approval from the MPCA to install and pilot test a low NOx main 

burner on Agglomeration line 7. The low NOx main burner installation, pilot testing, as well as the 

associated monitoring, recordkeeping and reporting shall be conducted in accordance with the 

aforementioned documents and the Permittee's Air Emission Permit No. 13700005-005. Additionally, the 

MPCA requests a notification of the burner replacement within 15 days after the installation. 

Furthennore, Air Emission Pennit No. 13700005-005 (pages A-3- A-6) contains Retroactive PSD 

Petmitting Requirements, which requires the pilot testing ofNOx control technologies, and the 

requirements for full scale demonstrations and incorporation of selected technologies into the remaining 

Agglomeration lines at Minntac. If the low NOx main burner approved in this letter for installation and 

pilot testing on Agglomeration line 7 is selected for full scale demonstration or installation on the 

remaining four Agglomeration lines at Minntac, the Permittee must submit the required amendment(s) in 

accordance with Air Emission Permit No. 13700005-005. 

Please be aware that new permit application fees, including fees for applicability determination requests, 

will be effective retroactively to July 1, 2009. Applicability determination requests received by the MPCA 

after July 1, 2009, and before implementation of the tule, are subject to the new fees and will be charged 

retroactive fees as necessary. For infonnation, see the MPCA's website regarding the new fee mle: 

www.pca.state.mn.us/petmits/airwaterfees.html. 

If you have any questions, please feel free to contact me at 651-757-2713. Your cooperation and 

compliance with environmental regulations are appreciated. 

Sincerely, 

OwenSeltz 

(};;; ~ ~ 

Engineer 

Metallic Mining Sector 

Industrial Division 

OS:rm 

cc: Chrissy Bartovich, U. S. Steel 

Tishie WoodwelL U. S. Steel 

Ryan Siats, U. S. Steel 

Mike Dzurinko, U. S. Steel 

Chris Nelson, MPCA 

Hongming Jiang, MPCA 

Suzanne Baumann, MPCA 

AQ File No. 26A