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Minnesota Pollution Control Agency 

520 Lafayette Road North I St. Pa ul, MN 55155-4194 I 651-296-6300 I 800-657-3864 I 651-282-5332 TTY I www.pca.state.mn.us 

January 18, 2011 

Ms. Chrissy Bartovich 

U.S. Steel Corporation 

Minnesota Ore Operations- Minntac 

P.O. Box 417 

Mountain lron, MN 55768 

RE: Nitrogen Oxides Control Technology Pilot Testing 

Dear Ms. Bartovich: 

This letter is in response to the October 22, 2010, report from U.S. Steel Corporation Minnesota 

Ore Operations- Minntac (Minntac) to the Minnesota Pollution Control Agency (MPCA) 

regarding nitrogen oxides (NOx) control technology pilot test requirements contained in Air 

Emissions Permit No. 13700005-005. The air emissions permit for the facility contains stepwise 

requirements to test NOx control technologies with the goal of achieving greater than 70 percent 

NOx emissions control from the initial permit limit of 13,300 tons per year NOx. 

In the October report Minntac provided preliminary pilot test results from the low NOx main 

burner installed on Line 7, a schedule for continued pilot testing on Line 7, and a schedule for 

installation and pilot testing on Line 6. The MPCA, Federal Land Managers, and Minntac met on 

December 13 , 2010, to discuss the effort to date. During the meeting several follow-up items were 

identified. This letter responds to the October 22, 2010, report and provides direction to U.S. Steel 

Corporation for future testing, including approximate permitting timelines for major permit 

modifications. 

Line 7 Low NOx Main Burner Pilot Test 

Minntac installed a low NOx main burner on Line 7 in May 2010. Minntac has provided information 

demonstrating continued achievement of excellent NOx control efficiencies while combusting 

natural gas. Despite redesigning the burner tip twice, Minntac stated that it has not been able to 

achieve the same level of emissions reductions when combusting coal and biomass. Minntac stated 

that while combusting coal, the Line 7 burner has continued to produce a short, bushy flame which 

results in reduced NOx control efficiency and warps the kiln refractory. 

In September 2010, the MPCA requested that Minntac submit the results ofthe pilot test results 

conducted to date including technical feasibility and impact to pellet quality, significant NOx 

reduction, cross media impacts, multi-pollutant co-control benefits, energy efficiency or 

consumption impact, and economic feasibility . The MPCA is required, per Minntac's air permit, 

to evaluate the pilot test results using that data. In the October 22,2010, report Minntac provided 

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 
Ms. Chrissy Bartovich 

Page 2 

brief descriptions regarding the above items, but because it had not yet installed the second 

redesigned burner tip or completed pilot testing while combusting biomass, any report provided 

at that time would've been incomplete. Instead Minntac submitted an amended schedule for 

providing the final results of the Line 7 pilot testing. The MPCA approves the schedule proposed 

in the October report, pending the inclusion of quarterly updates to the MPCA. The quarterly 

update can be as simple as an e-mail to the MPCA contacts, but should provide information so 

that the MPCA can track the status of the effort; including the installation dates and the other 

measures used as milestones in the proposed schedule. 

Per the schedule provided, Minntac will be submitting the final report on the Line 7 low NOx 

main burner pilot testing approximately in June 2011. The MPCA expects that the final report 

will contain data in greater detail than the brief descriptions provided in the October preliminary 

report so that the MPCA can use the data provided to evaluate the control technology. When 

submitting the final report, if Minntac intends to submit protected data, please be mindful of the 

MPCA's confidentiality requirements; including submittal of justification for confidentiality and 

providing two copies of the report, one confidential and one with the protected data redacted. 

Line 6 Low NOx Main Burner Pilot Test 

Despite its efforts to redesign the Line 7 low NOx main burner tip, Minntac stated that it has 

achieved limited improvements to NOx control efficiency while combusting coal. It also stated 

that it was having biomass delivery problems; the burner isn't able to feed biomass into the 

burner at an adequate rate for production. 

For these reasons, Minntac has proposed to redesign and reconfigure a new low NOx main 

burner to try to eliminate the flame shape problems occurring during coal combustion on Line 7. 

To this end, Minntac submitted to the MPCA a schedule for installing and pilot testing a 

redesigned burner on Line 6. 

Per our request in the September 2010 letter, the MPCA approves the proposed Line 6 pilot test 

schedule pending inclusion of a quarterly update so that the MPCA can track the status of the 

pi Jot testing effort. 

Permitting Timelines to meet February 1, 2014, Full Scale Installation Goal 

Sixty days after the MPCA approves the final NOx emission control pilot testing results, Minntac 

is required to submit a major permit amendment for "full scale demonstration;" installation of the 

chosen technology on a single agglomerating line. Following full scale demonstration, the permit 

requires a major permit amendment for "full scale installation;" installation of the chosen 

technology on all operating agglomerating lines at the plant. The major permit amendment is an 

important part of the process because it allows for public participation and provides some level of 

regulatory certainty for Minntac. 
Ms. Chrissy Bartovich 

Page 3 

Because there is no way to pilot test a low NOx main burner without full scale installation, the line 

between a pilot testing and full scale demonstration is blurred. But the MPCA believes that 

Minntac will have sufficiently refined the technology during the Line 6 low NOx main burner pilot 

testing, so that any future proposed low NOx main burner installations can no longer be considered 

pilot tests and will trigger require major permit amendment requirements prior to installation. 

Minntac' s air emissions permit contains a goal of installation ofNOx controls on all agglomerating 

lines by February 1, 2014. The major amendment process can require a significant amount of time. 

In addition to drafting the permit language, there are numerous administrative requirements that 

add time to permitting. In order to meet the February 1, 2014, installation goal it is important that 

Minntac consider the timing of the major permit amendment submittal. The time required to issue 

the permit is dependent on a number of factors, including the completeness of the application, the 

number and complexity of comments received, etc. So, the following are rough estimates for some 

of the major steps in the major amendment process: 

Major Modification Milestones Time Estimates 

1. MPCA reviews the application submitted by Minntac and determines that it Start 

is complete 

2. MPCA drafts permit and discusses the permit terms Varies 

3. MPCA internal peer review 14 days 

4. MPCA seeks feedback from Minntac, tribes and FLMs 15 days 

5. MPCA receives feedback, adjusts the language, and finalizes the permit Varies, generally 

approx. 30 days 

6. Minntac submits permit application reflecting the final permit language, if 45 days 

significant changes have occurred since the application was submitted. 

Concurrently, MPCA prepares permit for public notice. 

7. Public notice 30 days 

8. EPA 45 day review period. In some cases it is possible for this review to be 45 days 

concurrent with the public notice. 

9. If requested to come before the MPCA Citizen's Board for issuance, MPCA 45-60 days 

prepared responses to comments and prepares for the board meeting. 

10. Permit issued 5 days after Citizen's 

Board Meeting 

11. EAB Appeal Period (PSD permits only) 45 days 

Please be cognizant of the above time requirements when submitting permit amendment 

applications to comply with the February 1, 2014, control installation goal. 
Ms. Chrissy Bartovich 

Page 4 

The MPCA looks forward to continuing to work with U.S. Steel Corporation on achieving the 

NOx emission reductions required by its permit. If you have any questions or concerns, please 

contact me at 651-7 57-2603 . 

Sincerely, 

Christopher J. Nelson, P.E., Manager 

Strategic Projects Sector 

Industrial Division 

CJN/SLB:lao 

cc: Trent Wickman, US Forest Service 

Don Shepherd, National Park Service 

David Pohlman, National Park Service 

Tishie Woodwell, U.S. Steel Corporation 

Mike Dzurinko, U.S. Steel Corporation 

James Jarvi, U.S. Steel Corporation 

Suzanne Baumann, MPCA