VIA OVERNIGHT DELIVERY 

United States Steel Corporation 

l_aw Department 

600 ()rant Street 

Pittsburqh, PA 152192800 

Tel: 412A33.2919 

Fax: 412.433.2fl64 

E-mail: · dwhacker@uss.com 

April 24, 2012 

Attn: Compliance Tracker, AE-17J 

Air Enforcement and Compliance Assurance Branch 

U.S. Environmental Protection Agency- Region 5 

77 West Jackson Boulevard 

Chicago, IL 60604 

Re: United States Steel Corporation- Minntac 

Response to Section 114 Information Collection Request 

Dear U. S. EPA Region V Representative: 

David W. Hacker 

General Attorney-Environmental 

On or about April 5, 2012, United States Steel Corporation (U. S. Steel) received 

a Clean Air Act Section 114 Request for Information regarding its Minntac facility. In 

response to that request, U. S. Steel is providing the requested information, as explained 

below and in the attached disc. 

Since receiving the Request, U. S. Steel and U. S. EPA have had a 

teleconference and exchanged telephone calls. On April 9th, Chrissy Bartovich of U. S. 

Steel had a call with Patrick Miller and Bill Wagner from U. S. EPA During that call, 

among other things, U. S. EPA agreed to have the start date be concurrent for both the 

Keetac and Minntac facilities so although the Request to Minntac was received on or 

about April 5th, the time accural for the response started on April 9th; i.e., responses for 

both facilities, if submitted on or before April 24th, would be considerd timely. In addition 

and most significantly, U. S. EPA representatives visited U. S. Steel's Minntac facility on 

April 18, 2012 to review the facility's compliance with the taconite MACT standards as 

well as the application of BART at the facility. During the visit, U. S. Steel provided an 

overview of the Minntac operations, and addressed U. S. EPA's questions. many relating 

to burners. After the overview was discussed, U. S. EPA toured the Step 3 

Agglomerator, including the process equipment, low NOx burner and ancillary 

equipment. In sum, it was a comprehensive tour discussing how the facility operates. 

During the tour, U. S. EPA took 70 photographs. U. S. Steel respectfully requests that 

all such photographs taken during the tour be treated as Confidential Business 

Information (CBI), as they include proprietary information and provide insight to Minntac 

operations that is not publicly available. U. S. Steel takes reasonable measures to 

protect the confidentiality of such pictures and continues to do so, and any such 

photographs of equipment and processes are proprietary in nature and such 

photographs are not and have not been reasonably obtainable by legitimate means 

without U. S. Steel's consent. 
Attn: Compliance Tracker, AE-17 J 

Air Enforcement and Compliance Assurance Branch 

April 24, 2012 

Page 2 

The responses provided herein and in the attached discs are consistent with our 

discussions with U. S. EPA and the instructions provided in the Section 114 inquiry. For 

ease of review, U. S. Steel has provided the response to each request in a separate 

subfolder in the attached disc. In the disc, the inquiries as numbered and provided in the 

request along with U. S. Steel's responses are provided along with attachments that are 

responsive to the corresponding request. Please note that two discs with responsive 

information are being provided. The first disc contains information that is not considered 

CBI, while the second disc contains all responsive information that is deemed CBI. In 

particular, the responses to Items 1 and 11 of the Request sent to Minntac include such 

CBI. 

While U. S. Steel appreciates the Agency's consideration of accepting responses 

regarding a more limited scope and/or of time period, U. S. Steel believes that the 

Requests are unduly burdensome and overly broad, especially to the time frame to which 

the Requests pertain and the time frame or schedule in which responses were 

requested. U. S. Steel specifically objects to any definition or Request that can be 

interpreted to impose on U. S. Steel an obligation to collect or create information greater 

than that imposed by §114 of the Clean Air Act. Furthermore, U. S. Steel questions the 

relevance and probative value of some of these Requests, and by providing a response, 

U. S. Steel does not concede to the relevance or materiality of the information sought by 

any request or subject matter to which they refer, nor does U. S. Steel waive any such 

objections. Please note that the responses provided herein or attached shall not 

constitute any admission of liability on the part of U. S. Steel for any alleged violations. 

Subject to the conditions noted above, enclosed herein, please find our responses 

to the Request received by Minntac on or about April 5, 2012. 

1. U.S. EPA REQUEST: Provide process flow diagrams for both the taconite 

iron ore mining and the taconite pellet manufacturing processes. Include in 

the description, at a minimum, information on the following : mining 

operations, ore transfer and storage, course ore crushing, fine ore 

crushing, ore classification screens, ore storage bins, grinding rod/ball 

mills, separation, thickeners , balling drums/pellet formation , indurating 

furnace, pellet cooling and storage, and the process boilers. Include a 

detailed narrative process description and photographs to explain the 

indurating furnace process (separately for each furnace). For each 

photograph, provide a coded diagram/map to clearly identify the location 

of the image in the photograph. Photographs must correspond to each of 

the process stages described. 

U. S. STEEL RESPONSE: Please see the attached two discs for 

information that is responsive to this request. The first disc contains 

information that is not considered CBI , while the second disc contains all 

responsive information that is CBI. Responsive information is included 

in the respective subfolders- identified as "Item 1" on each of the discs. 

As noted above, U. S. EPA collected information that is responsive to 
Attn: Compliance Tracker, AE-17 J 

Air Enforcement and Compliance Assurance Branch 

April 24, 2012 

Page 3 

this Request when it visited the facility on April 18, 2012. Also as noted 

above, in addition to the responses provided on the disc identified as 

CBI, U. S. Steel respectfully requests that all photographs taken during 

the site visit be treated as Confidential Business Information (CBI). 

2. U.S. EPA REQUEST: For the time period January 1, 2010 to 

December 31, 2011, provide manufacturing specifications and 

operating data to demonstrate operating parameters for each of 

the facility's indurating furnaces. Operating parameters and data 

must include, at a minimum: flue gas composition, entrance air 

temperature, exit air temperature, preheat zone temperature, 

burner temperature, pellet residence time, and air flow rate). 

U. S. STEEL RESPONSE: Please see the attached disk in the 

subfolder- Item 2. 

3. U.S. EPA REQUEST: For the time period January 1, 2007 to 

December 31, 2011, provide records of the natural gas used by each 

specific indurating furnace at the facility. 

U.S. STEEL RESPONSE: Please see the attached disk in the 

subfolder- Item 3. 

4. U.S. EPA REQUEST: For the time period January 1, 2007 to 

December 31, 2011, if coal was used as a fuel source at the facility, 

provide documentation of the average sulfur content for coal used by each 

specific indurating furnace at the facility. 

U. S. STEEL RESPONSE: Please see the attached disk in the subfolder 

- Item 4. 

5. U.S. EPA REQUEST: If not already included in the Section 114 

Information Request Response to be sent to EPA by April 18, 2010 

[sic], provide copies of all stack tests conducted on any emissions 

unit for any reason, and include all test runs, even if a full test series 

was not completed. Identify the emissions unit; specify the date of the 

test, test method used, and the filter temperature during the time of 

the test, if applicable. Provide all calculations relative to the stack test, 

and provide copies of the full test report, including the section 

describing the process parameters and production or processing rates 

at the time of the test as well as copies of any reports of visible 

emission observations conducted during each test. For each test 

during which the source was not operating at maximum design 
Attn: Compliance Tracker, AE-17 J 

Air Enforcement and Compliance Assurance Branch 

April 24, 2012 

Page 4 

capacity, provide an explanation why production was not operating at 

maximum design capacity. 

U. S. STEEL RESPONSE: Please see the attached disk in the 

subfolder- Item 5. 

6. U.S. EPA REQUEST: Provide an electronic Excel workbook with the 

complete nitrogen oxide (NOx) and sulfur dioxide (S02) facility-wide 

potential to emit calculations. Include in the response a written 

description of how each column in the Excel workbook is generated. 

U. S. STEEL RESPONSE: Please see the attached disk in the 

subfolder- Item 6. 

7. U.S. EPA REQUEST: The facility's Best Available Retrofit 

Technology report, available on the Minnesota Pollution Control 

Agency Regional Haze website ("BART report"), discusses the 

facility's wet scrubbers for S02. Provide all documentation, including 

reports and studies, to determine the current S02 efficiency of all 

water scrubbers at the facility. Additionally, provide all documents, 

including reports and studies, completed for the technical feasibility of 

efficiency upgrades for each scrubber. 

U. S. STEEL RESPONSE: Please see the attached disk in the 

subfolder- Item 7. 

8. U. S. EPA REQUEST: The BART report discusses the technical feasibly of 

low NOx burners and a variety of selective catalytic reduction (SCRs) 

systems. Provide all documentation , including reports and studies, to 

determine the technical feasibility of low NOx burners and SCRs at the 

facility's indurating furnaces . 

U. S. STEEL RESPONSE: Please see the attached disk in the 

subfolder- Item 8. 

9. U.S. EPA REQUEST: The BART report discusses the technical feasibly 

of overfire air and induced flue gas technology. Provide all documentation, 

including reports and studies, to determine the technical feasibility of 

overfire air and induced flue gas technology at the facility's indurating 

furnaces. 

U. S. STEEL RESPONSE: Please see the attached disk in the 

subfolder- Item 9. 

10. U. S. EPA REQUEST: Identify the manufacturer, including contact 
Attn: Compliance Tracker, AE-17J 

Air Enforcement and Compliance Assurance Branch 

April 24, 2012 

Page 5 

information, for all low NOx burners, SCR, scrubber, overfire air, and 

induced flue gas technologies considered technically feasible for use at the 

facility. 

U. S. STEEL RESPONSE: Please see the attached disk in the 

subfolder- Item 10. 

11 . U. S. EPA REQUEST: For the time period January 1, 2002, to the date of 

receipt of this letter, provide all documentation, including engineering 

studies or mass balance studies , conducted to determine emissions of NOx 

from each waste-gas stack at all indurating furnaces at the facility: 

U. S. STEEL RESPONSE: Please see the attached two discs for 

information that is responsive to this request. The first disc contains 

information that is not considered CBI, while the second disc contains all 

responsive information that is deemed CBI. Responsive information is 

included in the respective subfolders- identified as "Item 11" on each of 

the discs. 

12. U. S. EPA REQUEST: Provide an electronic Excel workbook listing the 

following information from the NOx and/or S02 continuous emissions 

monitoring system (CEMS) from the date the CEMS were installed to 

present. Provide the information on an hourly basis, where applicable. 

The Excel workbook must include the following : 

a. CEMS identifying name or marker; 

b. CEMS location; 

c. Pollutant monitored; 

d. Date and time; 

e. NOx/ S02 emissions rate in pounds per million British 

thermal units (lb/mmBtu); 

f. Raw NOx/ S02 in ppm; 

g. NOx/ S02 emissions rate in pounds per hour; 

h. Flow rate in actual cubic feet per minute (acfm); and 

i. Furnace temperature in F. 

U. S. STEEL RESPONSE: Please see the attached disk in the 

subfolder- Item 12. 
Attn : Compliance Tracker, AE-17 J 

Air Enforcement and Compliance Assurance Branch 

April 24, 2012 

Page 6 

13. U. S. EPA REQUEST: Provide written explanation and supporting 

documents of how the facility could use NOx CEMs for process optimization. 

U. S. STEEL RESPONSE: Please see the attached disk in the 

subfolder- Item 13. 

14. U.S. EPA REQUEST: For the period from January 1, 2002, to the date of 

receipt of this letter, provide NOx emissions data from each indurating 

furnace for each day, and also for a thirty-day rolling average. 

U. S. STEEL RESPONSE: Please see the attached disk in the 

subfolder- Item 14. 

15. U. S. EPA REQUEST: Identify al l NOx emission sources and factors 

contributing to NOx emissions at the facility's indurating furnaces, including 

but not limited to, the burners. 

U. S. STEEL RESPONSE: Please see the attached disk in the 

subfolder- Item 15. 

16. U.S. EPA REQUEST: Identify all persons, including employees, 

consultants, representatives of the taconite industry, or representatives of 

air pollution control manufacturers, who assisted in the preparation, or were 

consulted for the purpose of preparing, the BART report. 

U. S. STEEL RESPONSE: Please see the attached disk in the 

subfolder- Item 16. 

The following requests and responses relate to the lowNOx burners on the facility's 

Line 6 indurating furnace. 

17. U.S. EPA REQUEST: What is the Total Capital Investment, the Total 

Annual Cost (including Total Indirect Annual Cost and Direct Annual Cost), 

annual emission reduction, and average cost effectiveness ($/ton)? Total 

Capital Cost and Total Annual Cost are as defined in EPA's Air Pollution 

Control Cost Manual (EPA/452/B-02-001, January 2002). Also, to what 

extent would the costs, and $/ton, be lower for a subsequent Low NOx 

main burner because much of the engineering/design work on the low NOx 

burners on Line 6 and 7 would not need to be repeated. 

U.S. STEEL RESPONSE: Please see the attached disk in the 

subfolder- Item 17. 

18. U. S. EPA REQUEST: Provide any test results and a description of any 

other work done to improve the performance of the Line 6 Low NOx Main 

Burner, especially for burning coal and natural gas or biomass, subsequent 
Attn: Compliance Tracker, AE-17 J 

Air Enforcement and Compliance Assurance Branch 

April 24, 2012 

Page 7 

to what was reported in the December 1, 2011, Line 6 Low NOx Main 

Burner Final Report. 

U. S. STEEL RESPONSE: Please see the attached disk in the 

subfolder - Item 18. 

A certification statement regarding this correspondence and all attachments is 

provided on the following page. The files in the attached disk, where appropriate, are 

provided as Word documents or in PDF format with Optical Character Recognition 

(OCR) capability. The files provided in the attached compact disk are virus free based 

upon U. S. Steel's virus protection software, Norton by Symantec®. 

Although U. S. Steel originally sought a USEPA extension to May 7, 2012 to 

supplement its response with information that it believed it would be unable to compile 

by April 24, 2012, U. S. Steel has expedited its review and believes it has satisfied the 

information request with the enclosed information. 

If any additional information is found prior to May 7 which is responsive to the 

request, a supplemental submittal will be made. If USEPA has any questions related to 

the information submitted, please feel free to contact Chrissy Bartovich at (218) 7 49-

7364. 

Enclosures 

cc: C. Bartovich (USS) (w/enclosures) 

S. Campbell (USS) (w/o enclosures) 

D. Smiga (USS) (w/o enclosures) 

(418004) 

T. Woodwell (USS) (w/o enclosures) 

M. Dzurinko (USS) (w/enclosures) 

sjJJ)j 

David W . Hacker 
CERTIFICATION 

I certify under penalty of law that I have examined and am familiar with the information in 

the enclosed documents, including all attachments. Based on my inquiry of those 

individuals with primary respon~ibility for obtaining the information, I certify that the 

statements and information are, to the best of my knowledge and belief, true and 

complete. I am aware that there are significant penalties for knowingly submitting false 

statements and information, including the possibility of fines or imprisonment pursuant to 

section 113(c)(2) of the Act, and 18 U.S.C. §§ 1001 and 1341. 

~ homas ~ Kelly, General Manager 

United States Steel Corporation 

Minnesota Ore Operations 

Date