VIA OVERNIGHT DELIVERY 

Sponse to United States Steel 

Corporation 

Law Departrnent 

600 Grant Street 

Pittsburgh, F'A 15219-2800 

Tel 4 '12 .4332919 

Fax: 4'12-433.2964 

E-mai!: 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- Keetac 

Response to Section 114 Information Collection Request 

Dear U. S. EPA Region V Representative: 

David W. Hacker 

General Attorney-Environmental 

On or about April 9, 2012, United States Steel Corporation (U. S. Steel) received 

a Clean Air Act Section 114 Request for Information regarding its Keetac 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. In addition and most significantly, U. S. 

EPA representatives visited U. S. Steel's Keetac facility on April 17, 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 a tour and an overview of the 

Keetac operations, and addressed U. S. EPA's questions, many relating to burners and 

fuel choice. U. S. EPA toured the mine, crusher, concentrator and pellet plants. In sum, 

it was a comprehensive tour discussing how the facility operates. While Keetac was not 

operating at the time of the tour- as it was down for its annual maintenance and repairU. S. EPA was able to view certain equipment that is not typically able to be viewed in 

this manner when the facility is operating. During the tour, U. S. EPA took 94 

photographs. U. S. Steel respectfully requests that all such photographs taken during 

the tour be treated as Confidential Business Information, as they include proprietary 

information and provide insight to Keetac 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. 

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

discussions with U. S. EPA and the instructions provided in the Section 114 inquiry. For 
Attn: Compliance Tracker, AE-17 J 

Air Enforcement and Compliance Assurance Branch 

April 24, 2012 

Page 2 

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. 

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 Keetac on or about April 9, 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 disk in the 

subfolder- Item 1. As noted above, U. S. EPA collected information 

that is responsive to this Request when it visited the facility on 

April 17, 2012. Also as noted above, 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 
Attn : Compliance Tracker, AE-17 J 

Air Enforcement and Compliance Assurance Branch 

April 24, 2012 

Page 3 

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 

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. 
Attn: Compliance Tracker, AE-17 J 

Air Enforcement and Compliance Assurance Branch 

April 24, 2012 

Page 4 

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 

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 1 0. 

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 
Attn: Compliance Tracker, AE-17 J 

Air Enforcement and Compliance Assurance Branch 

April 24, 2012 

Page 5 

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

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

subfolder- Item 11. 

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

following information from the NOx and/or S02 continuous emissions 

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

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

The Excel workbook must include the following: 

a. GEMS identifying name or marker; 

b. GEMS 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. 

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

documents of how the facility could use NOx GEMs 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. 
Attn: Compliance Tracker, AE-17 J 

Air Enforcement and Compliance Assurance Branch 

April 24, 2012 

Page 6 

15. U.S. EPA REQUEST: Identify all 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. 

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 

(418001 ) 

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

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

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

M. Dzurinko (USS) (w/enclosures) 

David W. Hacker 
CERTIFICATION 

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

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

individuals with primary responsibility 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. 

United States Steel Corporation 

Manager Minnesota Ore Operations 

Date