### AIR EMISSION PERMIT NO. 06100067-004 Major Amendment

IS ISSUED TO

Essar Steel Minnesota LLC

Essar Steel Minnesota LLC

17113 County Road 58 Nashwauk
, Itasca County, MN 55769

The emission units, control equipment and emission stacks a t the stationary s ource authorized in this permit amendment are as described in the following permit applications :

Permit Type Application Date

Total Facility Operating Permit 

### 05/04/2007 Major Ame ndment 

### 10/09/2007 Major Amendment 

### 10/14/2011



### This permit supe rsedes Air Emission Permit No

. 06100067

- 003 and authorizes the Permittee to operate and construct the s tationary source at the address l! sted a bove

. The Permittee must comply with all the condition s of the permit. Any c hanges or modifications to the stationary sou r ce must be performe d in compliance with Minn. R. 7007.1150 to 7007.1500. Terms u s ed in the permit are as defined in the s tate air pollution control rules unless the term is explicitly defined in the permit.

Unless otherwise indi cat ed, all the Minn esota rule s cited as the origin of t he permit terms 

### are incorporated into the SIP under 40 CFR 

### § 52.1220 and as suc h as are enforceable by U.S

. Environm e ntal Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Permit Type: Federal; Part 70/Major for N SR; Operating Permit Issue Date: September 7
, 2007 Major Amendment Issue Date: April 6, 2012 Major Amendment Effective Date: May 10
, 2012 

### Expiration Date' September 7, 2012 -Title I Conditions do no;D O'kt 

# M/2J

Don Smith, P .E., Manager Air Quality Permits Section Industrial Division

for John Stine Commissioner Minnesota Pollution Control Agency

TDD (for h ear ing a nd speec h impaired on ly) : 651

- 282-5332 Printed on recycled paper containi n g at lea s t 10 % fibers fro m paper recycled by cons um ers

### TABLE OF CONTENTS
Notice to the Permittee
Permit Shield Facility Description Amendment Description Table A: Limits and Other Requirements
GP 001 – Mobile Sources GP 002 – Emission Units Subject to Taconite MACT GP 003 – Ore Crushing & Handling GP 004 – Finished Pellet Handling GP 005 – Waste Rock Handling GP 006 – Fugitive Sources GP 007 – Baghouses with Leak Detection GP 008 – Bag Houses Subject to Taconite MACT GP 009 – EAF Baghouses GP 010 – Electric Arc Furnaces GP 011 – Meltshop Enclosures GP 012 – Cooling Towers GP 014 – Flares GP 015 – Tunnel Furnace GP 016 – Material Loading Bin Sources GP 017 – DRI Pellet Handling GP 018 – Indurating Furnace GP 019 – Boilers/Heaters Subject to Case-by-Case MACT GP 020 – Wet Scrubbers Subject to Case-by-Case MACT GP 021 – Emergency Generators and Fire Water Pumps GP 022 – Stack/Vents with CEMS GP 023 – EAF Ladle/Castle Area GP 024 – DRI Top Gas Purification GP 025 – DRI Water Blowdown Units GP 026 – Ore Barns EU 165 – Space Heaters FS 042 – Slag Dumping


### Table B: Submittals Appendices Appendix A – BACT Limits Appendix B – Modeling Parameters Appendix C – Green ball/DRI Lead/Fluorid e Concentration Monitoring – 95% UCL Appendix D – Visible Emissions Checklist Appendix E – Test and Set for PM 2.5 

### Appendix F – SAM Equations Appendix G – Insignificant Activities Appendix H – Process Flow Diagram

### NOTICE TO THE PERMITTEE: Your stationary source may be s ubject to the requirements of the Mi nnesota Pollution Control Agency’s (MPCA) solid waste, hazardous waste, and water qualit y programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at:
Metro Area 651-296-6300

Outside Metro Area 1-800-657-3864

TTY 651-282-5332 The rules governing these programs are contained in Minn. R. chs. 7000-7105. Written questions may be sent to: Minnesota Pollution Control Agency, 520 La fayette Road North, St. Paul, Minnesota 55155-4194. Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above.

PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, complia nce with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the lim itations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) ma y also use other credible evidence to establish compliance or noncompliance with applicable requirements.

### FACILITY DESCRIPTION: Essar Steel Minnesota LLC (Essar) is currently in th e process of constructing an approximately $1.6 billion mine mouth electric arc furnace steel mill. The Essa r project is located in northern Minnesota, on the western end of the Biwabik Iron Formation (the Mesabi Range) near Nashwauk, at the site of the former Butler Taconite Mining Company operations. The project has secured the 1.4 billion (long) ton Minera l Resource of the Butler properties and seeks to capitalize on the unique mineralogical characteristics of the iron ore body by vertically integrating all mining and manufacturing processes to produce a finished steel product on one site. The processes involved will use proven technology and be the only fully integr ated steelmaking facility in the United States. Essar will begin operations by mining a new pit, Pit 6, next to Pit 5 where Butler Taconite operations stopped. The mining of Pit 5 will resume after dewa tering is completed. The key project features and their nominal capacities are: • An open pit taconite mine capable of mining approximately 24,000,000 tonne/yr of ore. • A crusher, concentrator with associated tailings basin, producing approximately 7,000,000 tonne/yr of concentrate. • A pelletizer that can produce approximately 6, 500,000 tonne/year of high flux oxide pellets or 7,000,000 tonne/yr of low flux oxide/ DRI grade pellets. • A DRI facility producing approximately 1,800,000 tonne /yr of iron pellets for direct feed for steel production. • An electric arc furnace, ladle metallurgy furnace, slag processing, and a caster to produce 1,500,000 tonne/yr of steel slabs for direct shipment or for onsite rolling to produce hot rolled coil. Essar plans to use natural gas as the process fuel for pelletizing, direct reduction, and steel making. Diesel fuel will be used to operate mining equipment. Th e project will demand 450 MW of electric power, which will be supplied by Nashwauk Public Utility. Essar pl ans to use ore concentrating and indurating processes common to existing taconite operatio ns and to employ natural gas based direct iron reduction. The steel mill will use modern electric arc furnace (EAF) and meta llurgy furnace technology to equip the melt shop. Unlike most other EAF-based steelmaking operations, Essa r will use primarily DRI to charge the EAF. Scrap will only be used in the EAF for initial or post-mainten ance startup. There will be no scrap charge to the EAFs at Essar other than internally -produced, virgin iron, "home scrap".

AMENDMENT DESCRIPTION The proposed Essar Steel Minnesota Modification s (ESMM) project Master Development Agreement (MDA) Alternative would include all activities covered in the MSI project including mining, ore processing, direct reduced iron (DRI) production, and steel-making, but would entail higher taconite pellet production and associated mining and tailings generation rates. The project will increase production of taconite pellets from about 3.8 million ( mm) metric ton (tonne) per year of low flux pellets suitable for DRI feed pellet to 7.0 mm tonne/yr of low flux pellets or 6.5 mm tonne/yr of high flux pellets suitable for blast furnace grade pellets or any comb ination in between. The blast furnace grade or high flux taconite pellets will be shipped to Essar Steel Algo ma in Ste. St. Marie, Ontario Canada or sold on the open market. DRI grade or low flux pellets will be us ed as feed to the DRI process or sold on the open market. The MSI project was permitted for installati on of two DRI lines and two steel lines. Essar is proposing at this time to permit one DRI line and one steel line to produce 1.8 mm tonne/yr of DRI and 1.5 mm tonne/yr of steel which is consistent with the Master Development Agreement (MDA) between Essar Steel Minnesota and the State of Minnesota. Ho wever, no physical changes to the DRI or steel mill are required to produce at these capacities.

### The table below is provided to illustrate differences in capacities between the original MSI project and the proposed ESMM project MDA Alternative. Capacity Differences between the Original MSI Pr oject and Proposed ESMM Project MDA Alternative

Unit Operation Type of Pellet Original MSI Project Capacity (mm tonne/yr) Proposed ESMM Project MDA Alternative Capacity (mm tonne/yr) Taconite Pelletizing Furnace Low Flux (DRI feed grade) 3.8 1 

### 7.0 3, 5 

### High Flux (blast furnace grade) 0 6.5 4, 5 

### DRI Not applicable 2.8 2 

### 1.8 6 

### Steel Making 2.5 7 

### 1.5 7

1 

### Pelletizing air emission calculations included a 10% safety factor to account for the level of detailed engineering

that existed at the time of permitting. Actual capaci ty used for air emission calculations was 4.1 mm tonne/yr. 2 

### For the original MSI FEIS and Air Permit #06100067, the capacity of the DRI modules was described as 2.8 mm

tonne/yr. However, the MSI air emissions inventory used a value of 3.5 mm tonne/yr plus a 10% safety factor which equates to 3.85 mm tonne/yr. The MSI permit limits and BACT were based on 3.85 mm tonne/yr. The Essar emission inventory uses the capacity of 1.8 mm to nne/yr and the same hourly production rates as the MSI air emission calculations and limits. 3 

### Essar will make Low Flux, otherwise known as DRI feed gr ade pellets for on-site steel making or for sale on the open market. The quantity of this type of pellet to be produced on an annual basis will depend on internal manufacturing needs and on market conditions. 4 

### Essar will make High Flux, otherwise known as Blast Furnace grade pellets for Essar Steel Algoma or for sale on

the open market. The quantity of this type of pellet to be produced on an annual basis will depend on internal manufacturing needs and on market conditions. 5 

### An air emission inventory was prepared for both types of pellets to be produced. The maximum value from either inventory for a given pollutant was us ed in air dispersion modeling assessments. 6 

### There are no physical changes to the DRI proposed and th ere are no changes to the hourly production rates. 7 

### There are no physical changes to the steel mill proposed a nd there are no changes to the hourly production rates. 

### The proposed action modifies the indurating furnace wh ere taconite (oxide) pellets are produced. The DRI process is separate from the indurating furnace. Th e oxide pellets would be transported to an off-site blast furnace or on-site DRI process. In the DRI pr ocess the oxide pellets are converted to DRI pellets. There would be no physical change to the DRI process or the steel mill that were previously permitted. With regard to analysis of the DRI process, Essar is not proposing any physical change or change to the hourly capacity of the DRI units as described in the MSI FEIS and Air Permit #06100067-001. Essar began construction on the originally permitte d MSI project in October, 2008. Construction began with earthwork and rock excavation for all fac ility building and concrete foundations for primary crushing, mill bay tunnels, slurry tanks and balling di scs and filters as well as infrastructure for the project. No construction acti vities associated with the 4 th



### secondary crushing unit, 3 rd 

### autogenous grinding mill or the firing zone of the indurating furnac e or any emission units that were not previously permitted has begun. The overall project timeline includes the following milestones:

• Finalize the Supplemental Environmental Impact Statement – late 2011

• Obtain environmental and mining permit for mo dification and obtain financial close for equipment required for increase pelletizing capacity – 2012

• Finish construction through taconite pellet pl ant and start taconite pellet production – 2013

• Start construction of one DRI line and steel mill – 2013

• Start steel production – 2015

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-1

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first colum n of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that y ou must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under tota l facility requirements.

Subject Item: Total Facility

What to do Why to do it The construction authorization expires 18 months after permit issuance. The Permittee must keep a record of the dates of installation and start-up on site. The Permittee may apply for an extension of the construction authorization deadline by following the Administrative Amendment provisions in Minn. R. 7007.1400. 40 CFR 52.21(r)(2) and Minn. R. 7007.3000

The facility currently uses ozone-depleting substances as defined in 40 CFR pt. 82. Sections 601-618 of the 1990 Clean Air Act Amendments and 40 CFR pt. 82 may apply to your facility. Read Sections 601-618 and 40 CFR pt. 82 to determine all the requirements that apply to your facility. 40 CFR pt. 82

Definition. Facility includes all emission units at the stationary source. Title I Condition: 40 CFR 52.21(p); Minn. R. 7007.3000 and Minn. R. 7007.0800, subp. 2 This permit contains appendices as listed in the Table of Contents. The Permittee shall comply with all requirements contained in appendices. Modeling parameters in appendices are enforceable and compliance with these parameters is achieved through meeting the requirements that reference appendices. Minn. R. 7007.0800, subp. 2

OPERATIONAL REQUIREMENTS hdr Maintain records of the tons of oxide pellets, tons of DRI, and tons of liquid steel produced, on a per 8-hour shift basis. These production numbers shall be used in compliance emission limits that are based on production. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

A t all times, including periods of startup, shutdown, and malfunction (SSM), the Permittee shall, to the extent practicable, maintain and operate any emissions unit including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated upon written request by the MPCA. 40 CFR pt. 50; Minn. Stat. Section 116.07, subds. 4a & 9; Minn. R. 7007.0100, subps. 7A, 7L & 7M; Minn. R. 7007.0800, subps. 1, 2 & 4; Minn. R. 7009.0010 - 7009.0080
Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Minn. R. 7011.0020

A ir Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Minn. R. 7007.0800, subps. 2 & 16(J)

Operation and Maintenance (O&M) Plan: Retain at the stationary source an O&M plan for all air pollution control equipment. At a minimum, the O&M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation.
The O&M Plan shall include and maintain the operating ranges for each piece of control equipment as established in the most recent compliant performance test. Minn. R. 7007.0800, subps. 14 & 16(J)

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Minn. R. 7019.1000, subp. 4

Comply with Fugitive Emission Control Plan: The Permittee shall follow the actions and recordkeeping specified in the control plan. The plan may be amended by the Permittee with the Commissioner's approval. If the Commissioner determines the Permittee is out of compliance with Minn. R. 7011.0150 or the fugitive control plan, then the Permittee may be required to amend the control plan and/or to install and operate particulate matter ambient monitors as requested by the Commissioner. Minn. Stat. Section 116.07, subd. 4a; Minn. R. 7007.0100; Minn. R. 7007.0800, subp. 2; Minn. R. 7011.0150; Minn. R. 7009.0020

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-2

Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150. Minn. R. 7011.0150

Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Minn. R. 7030.0010 - 7030.0080

Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A). Minn. R. 7007.0800, subp. 9(A)

The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. Minn. R. 7007.0800, subp. 16

Retired Acid Rain or CAIR/CASPR allowances used for visibility offsets may not be used by the Permittee or another regulated entity for any offset, banking, selling or trading program. Title I Condition: 40 CFR 52.21(p); Minn. R. 7007.3000

PERFORMANCE TESTING hdr Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in Table A. Minn. R. ch. 7017

Performance Test Notifications and Submittals:
Performance Tests are due as outlined in Table A of the permit. Performance Test Notification: due 60* days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - CD Copy: due 105 days after each Performance Test
*30 days for those tests that do not support MACT limits. The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R. 7017.2018. 40 CFR 63.7(b)(1), (c)(2)(iv), & (g)(1); 40 CFR 63.9(e); 40 CFR 63.9640(d); Minn. R. 7019.0100, subp. 2; Minn. R. 7017.2015, subp. 3; Minn. R. 7017.2018; Minn. R. 7017.2030, subps. 1-4; Minn. R. 7017.2035, subps. 1-2

Limits set as a result of a performance test apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. Minn. R. 7017.2025, subp. 3

Within 15 days of the actual startup of that emission unit, the Permittee shall notify the MPCA of the initial startup of any emission unit for which the permit requires an initial performance test for which the date of testing depends on the date of initial startup. The initial performance test requirements are listed at the GP level. Minn. R. 7007.0800, subp. 4

MONITORING hdr Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment (any requirements applying to CEMS are listed separately in this permit). Minn. R. 7007.0800, subp. 4(D)

Unless otherwise noted in Table A, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. Minn. R. 7007.0800, subp. 4(D)

RECORDKEEPING hdr Recordkeeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). Minn. R. 7007.0800, subp. 5(C)

Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. Minn. R. 7007.0800, subp. 5(B)

If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. These records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the office of the stationary source for all other years. The records may be maintained in either electronic or paper format. Minn. R. 7007.1200, subp. 4

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-3

Contractors: The Permittee shall retain records on site of each contractor that is allowed on site to operate any crushers, screens and conveyors. The records for each contractor shall consist of the contractor's company name, MPCA air emissions permit number (if any), short description of on-site activities undertaken by the contractor, estimate materials handled and the dates the contractor was on site. The records shall be updated quarterly. This is a state-only requirement and is not enforceable by the EPA administrator or citizens under the Clean Air Act. Minn. R. 7007.0800, subp. 2

REPORTING/SUBMITTALS hdr Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the Permittee does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 3.

A t the time of notification, the Permittee shall inform the Commissioner of the cause of the shutdown and the estimated duration. The Permittee shall notify the Commissioner when the shutdown is over. Minn. R. 7019.1000, subp. 3

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of >1 hour duration of any control equipment or process equipment if the breakdow n causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the Permittee. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2.

A t the time of notification or as soon as possible thereafter, the Permittee shall inform the Commissioner of the cause of the breakdown and the estimated duration

. The Permittee shall notify the Commissioner when the breakdown is over. Minn. R. 7019.1000, subp. 2

Notification of Deviations Endangering Human Health or the Environment: A s soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Minn. R. 7019.1000, subp. 1

Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. The cause of the deviation; 2. The exact dates of the period of the deviation, if the deviation has been corrected; 3. Whether or not the deviation has been corrected; 4. The anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Minn. R. 7019.1000, subp. 1

Excess Emissions and Continuous Monitoring System Report: The Permittee shall submit an excess emissions and continuous monitoring system performance report and/or a summary report to the Commissioner by the 30th day following the end of each calendar half. The report(s) shall include all the information required and in accordance with 40 CFR Section 63.10(e)(3). Minn. R. 7019.0100, subp. 2

A pplication for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150-7007.1500. Submittal dates vary, depending on the type of amendment needed. Minn. R. 7007.1150 - 7007.1500

Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pts. 60 & 63 are examples of deadlines the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R. 7007.1400, subp. 1(H). Minn. R. 7007.1400, subp. 1(H)

Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance. To be submitted on a form approved by the Commissioner. Minn. R. 7019.3000 - 7019.3100

Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R. 7002.0005 - 7002.0095
INAPPLICABLE REQUIREMENTS hdr 40 CFR 60 Subpart AAa does not apply to the electric arc furnace(s) (EU 125). It does apply to the vacuum degasser unit(s) and, therefore, to SV 044. 40 CFR 60.270a; Minn. R. 7007.1800 40 CFR 63 Subpart FFFFF does not apply anywhere at this facility. 40 CFR 63.7782; Minn. R. 7007.1800

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-4

DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NSR hdr These requirements apply if a reasonable possibility (RP), as defined in 40 CFRSection 52.21(r)(6)(vi), exists that a proposed project, analyzed using the actual-toprojected-actual (ATPA) test (either by itself or as part of the hybrid test at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may result in a significant emissions increase (SEI). If the ATPA test is not used for the project, or if there is no RP that the proposed project could result in a SEI, these requirements do not apply to that project. The Permittee is only subject to the Preconstruction Documentation requirement for a project where a RP occurs only within the meaning of Section 52.2(r)(6)(vi)(a).
Even though a particular modification is not subject to New Source Review (NSR), or where there isn't a RP that a proposed project could result in a SEI, a permit amendment, recordkeeping, or notification may still be required by Minn. R. 7007.1150 - 7007.1500. Title I Condition: 40 CFR 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 2

Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following:
1. Project description 2. Identification of any emission unit (EU) whose emissions of an NSR pollutant could be affected 3. Pre-change potential emissions of any affected existing EU, and the projected post-change potential emissions of any affected existing or new EU. Title I Condition: 40 CFR 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.1200, subp. 4; Minn. R. 7007.0800, subps. 4 & 5

4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the EU could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination.

The Permittee shall maintain records of this documentation. (continued) Title I Condition: 40 CFR 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.1200, subp. 4; Minn. R. 7007.0800, subps. 4 & 5

The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the A TPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. Title I Condition: 40 CFR 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

The Permittee must submit a report to the Agency if the annual summed (actual, plus potential if used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the A gency within 60 days after the end of the year in which the exceedances occur.
The report shall contain: 1. The name and ID number of the facility, and the name and telephone number of the facility contact person 2. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions increase are exceeded. 3. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. Title I Condition: 40 CFR 52.21(r)(6); Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

"TEST AND SET" PROVISIONS FOR PM2.5 hdr This permit sets PM2.5 emission limits for Emission Units/Stacks that emit PM. The Permittee shall demonstrate compliance with these limits as required in the provisions for each emission unit/stack.
The Permittee shall conduct performance testing for these stacks in accordance with Appendix E. The data collected during these tests shall be used to support the development of more refined PM2.5 emission limits for the emission units. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Within 15 days of project startup, the Permittee shall notify the MPCA of the date of project startup. Project startup is defined in Appendices E. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 The Permittee shall submit an application for a major permit amendment within 910 days of project start up, it shall contain all data required by Appendix E. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-5

TOTAL FACILITY MERCURY EMISSION LIMITS hdr Referred to as the Total Mercury Emission Limit, the total facility mercury emissions shall be less than or equal to 77 lbs/year using a rolling 12 month sum. This limit applies upon initial startup of the facility. Minn. R. 7007.0800, subps. 2, 4, 5 & 16(J)

For the first 11 months of operation, mercury emissions are limited as determined by the following equation:
Hg = 6.60 + 6.40 * M

Where: Hg = mercury emissions in pounds since initial startup of the pellet plant; M = number of months after initial startup (i.e., for the first month, M = 0) Minn. R. 7007.0800, subps. 2, 4, 5 & 16(J)

A s provided in the Implementation Plan for Minnesota's Statewide Mercury Total Maximum Daily Load - October 2009, by June 30, 2016, or a date established by the MPCA Rule, the MPCA will require submittal of a schedule for reducing mercury emissions from the ferrous mining and processing industry sector by 75% from the levels listed in the plan by 2025. Minn. R. 7007.0800, subp. 2 & 6

Mercury Calculation and Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the monthly mercury emissions for the previous 12 calendar months. The Permittee shall maintain a written record of the monthly mercury emission calculations. Minn. R. 7007.0800, subps. 2, 4, 5, 14 & 16(J)

A MBIENT AIR MODELING hdr Parameters Used in Modeling: The stack heights, emission rates, and other parameters used in the modeling are listed in Appendix B of this permit. The Permittee must submit to the Commissioner for approval any revisions of these parameters and must wait for a written approval before making such changes. The information submitted must include, at a minimum, the locations, heights and diameters of the stacks, locations and dimensions of nearby buildings, the velocity, temperatures, moisture content, and pressures of the gases emitted, and the emission rates. The plume dispersion characteristics due to the revisions of the information must be equivalent to or better than the dispersion characteristics modeled. The Permittee shall demonstrate this equivalency in the proposal. If the information does not demonstrate equivalent or better dispersion characteristics, or if a conclusion cannot readily be made about the dispersion, the Permittee must remodel. Title I Condition: 40 CFR 52.21(k); Minn. R. 7007.3000

For changes that do not require a permit amendment or require a minor permit amendment, the proposal must be submitted as soon as practicable, but no less than 60 days before beginning actual construction of the stack or associated EU.
For changes that require a permit amendment other than a minor amendment, the modeling protocol must be approved prior to submittal of the permit application. Title I Condition: 40 CFR 52.21(k); Minn. R. 7007.3000

LEAD AND FLUORIDE SAMPLING METHODOLOGY hdr Sample and analyze for each lead or fluoride limit in listed Table A using: 1. EPA Method 6010B for lead; and 2. EPA Method 9056 for fluoride. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Lead and Fluoride Concentration: For the first 12 consecutive months after initial start-up, the Permittee shall sample and analyze weekly.
1. If, after 12 consecutive months, each sample is less than the concentration limit or if the 95% UCL of all samples taken in the previous 12 month period is less than the concentration limit, the sampling frequency may be reduced to monthly. 2. If, thereafter, the 95% UCL of all samples taken in the previous 12 month period is greater than the limit, the Permittee shall sample and analyze weekly until the 95% UCL of all samples taken in a continuous 12 month period is less than the limit. The Permittee may then reduce the sampling frequency to monthly. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4

95% Upper Confidence Level (UCL): The Permittee shall use the following method for calculating the 95% UCL of feed material lead or fluoride concentration:
- For samples for which the lead or fluoride (as applicable) is less than the detection limit, the Permittee shall assume a concentration of lead or fluoride equal to one-half the detection limit. - The Permittee shall calculate the 95% UCL using the EPA ProUCL (Version 3.0 or higher) software or using an Excel spreadsheet as illustrated in Appendix C. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

PERMIT ORGANIZATION hdr Requirements listed at the group level apply individually to each associated item listed for the group, unless otherwise specified by a specific section header or requirement. Minn. R. 7007.0800, subp. 2

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-6

NESHAP GENERAL PROVISIONS - 40 CFR pt. 63, subp. A hdr Each EU and FS at the facility is subject to NESHAPs, except for EUs 026, 049, 050, 067, 068, 084, 085, 110, 111, 113, 143, 144, and 161-169. 40 CFR 63.1; Minn. R. 7011.7000 Prior to construction or reconstruction of an affected source under the promulgated MACT standards, the Permittee must apply for and obtain an air emission permit. 40 CFR 63.5(b)(3); Minn. R. 7011.7000 Proper Operation and Maintenance: At all times, including periods of SSM, the Permittee shall operate and maintain the emission unit(s) subject to the MACT standard and its associated air pollution control and monitoring equipment in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels required by all relevant standards. 40 CFR 63.6(e)(1)(i); Minn. R. 7011.7000

Malfunctions: Malfunctions shall be corrected as soon as practicable after their
occurrence. 40 CFR 63.6(e)(1)(ii); Minn. R. 7011.7000 Prepare a written Startup, Shutdown, and Malfunction Plan (SSMP) for each of the emission units, including associated control and monitoring equipment, subject to MACT by the applicable MACT standard compliance date. The SSMP shall be prepared in accordance with 40 CFR Section 63.6(e)(3) and include requirements specified therein. The SSMP must be located at the plant site and must be kept updated. When the SSMP is updated, all previous versions of the SSMP shall be kept for a period of 5 years. The Permittee must submit the SSMP when required. 40 CFR 63.6(e)(3)(i) & (v); Minn. R. 7011.7000

When actions taken during a SSM event (including actions taken to correct a malfunction) are consistent with the procedures specified in the SSMP, keep records for that event which demonstrate that the procedures specified in the plan were followed. These records may take the form of a checklist, or other effective form of recordkeeping that shows conformance with the SSMP for that event. Also keep records of these events as specified in 40 CFR 63.10(b). Confirm that actions taken during the relevant reporting period during periods of SSM were consistent with the SSMP in the Semi-Annual SSM report required in 40 CFR 63.10(d)(5). 40 CFR 63.6(e)(3)(iii); Minn. R. 7011.7000

NESHAP GENERAL PROVISIONS - MONITORING hdr Operation and maintenance of CMS. Operate and maintain each CMS in a manner consistent with good air pollution control practices. The owner or operator must: - Maintain and operate each CMS as specified in section 63.6(e)(1); - Keep the necessary parts for routine repairs readily available; and - Develop a written SSMP for CMS as specified in section 63.6(e)(3). 40 CFR 63.8(c)(1); Minn. R. 7017.1010, subp. 2

A ll CMS must be installed such that representative measures of emissions or process parameters from the affected source are obtained. In addition, CEMS must be located as specified in the applicable performance specification(s).
The read out, or other indication of operation, from any CMS required for compliance with the emission standard must be readily accessible on site for operational control or inspection by the operator of the equipment. 40 CFR 63.8(c)(2); Minn. R. 7017.1010, subp. 2

A ll CMS shall be installed, operational, and the data verified prior to or in conjunction with conducting performance tests under section 63.7.
Except for system breakdowns, out-of-control periods, repairs, maintenance periods, calibration checks, and zero (low-level) and high-level calibration drift adjustments, all CMS, including COMS and CEMS, shall be in continuous operation and shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period. 40 CFR 63.8(c)(3) & (4); Minn. R. 7017.1010, subp. 2

Check the zero (low-level) and high-level calibration drifts at least once daily in accordance with the written procedure specified in the performance evaluation plandeveloped under 40 CFR 63.8(e)(3)(i)&(ii) for each installed CMS. The zero (lowlevel) and high-level calibration drifts must be adjusted, at a minimum, whenever the 24-hour zero (low-level) drift exceeds two times the limits of the applicable performance specification(s) specified in the relevant standard. The system shall allow the amount of excess zero (low-level) and high-level drift measured at the 24-hour interval checks to be recorded and quantified whenever specified. 40 CFR 63.8(c)(6); Minn. R. 7017.1010, subp. 2

Develop and submit a site-specific performance evaluation test plan to the Commissioner for approval upon request in accordance with 40 CFR 63.8(e)(3)(i). The quality control program shall include, at a minimum, a written protocol that describes procedures for each of the following operations: 1. Initial and any subsequent calibration of the CMS; 2. Determination and adjustment of the calibration drift of the CMS; 3. Preventive maintenance of the CMS, including spare parts inventory; 4. Data recording, calculations, and reporting; 5. Accuracy audit procedures, including sampling and analysis methods; and 6. Program of corrective action for a malfunctioning CMS. Keep these written procedures on record for the life of the affected source or until the affected source is no longer subject to the provisions of this part. 40 CFR 63.8(d)(2) & (3), and (e)(3)(i); Minn. R. 7017.1010, subp. 2

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-7

Notification of performance evaluation. The Permittee shall notify the Commissioner in writing of the date of the performance evaluation simultaneously with the notification of the performance test date required under 40 CFR Section 63.7(b) or at least 60 days prior to the date the performance evaluation is scheduled to begin if no performance test is required. 40 CFR 63.8(e)(2); Minn. R. 7017.1010, subp. 2

The Permittee shall conduct a performance evaluation of a required CMS during any performance test required under 40 CFR Section 63.7 in accordance with the applicable performance specification as specified in the relevant standard. If a performance test is not required, or the requirement for a performance test has been waived under 40 CFR 63.7(h), the Permittee shall conduct the performance evaluation not later than 180 days after the appropriate compliance date. 40 CFR 63.8(e)(4); Minn. R. 7017.1010, subp. 2

The Permittee shall submit to the Commissioner a copy of a written report of the results of the performance evaluation simultaneously with the results of the performance test required under 40 CFR Section 63.7 or within 60 days of completion of the performance evaluation if no test is required. 40 CFR 63.8(e)(5); 40 CFR 63.10(e)(2); Minn. R. 7017.1010, subp. 2; Minn. R. 7019.0100, subp. 2 Reduction of monitoring data. The Permittee must reduce the monitoring data as specified in 40 CFR Section 63.8(g). 40 CFR 63.8(g); Minn. R. 7017.1010, subp. 2
NESHAP GENERAL PROVISIONS - RECORDKEEPING hdr Recordkeeping: The Permittee shall maintain files of all information required by 40 CFR part 63 in a form suitable and readily available for expeditious inspection and review. The files should be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Only the most recent two years of information must be kept on site. 40 CFR 63.10(b)(1); Minn. R. 7019.0100, subp. 2

The Permittee shall maintain, at a minimum, the following information in the files:
1. The occurrence and duration of each startup, shutdown, or malfunction of operation; 2. The occurrence and duration of each malfunction of the air pollution control equipment; 3. All maintenance performed on the pollution control equipment; 4. Actions taken during periods of SSM when such actions are different from the procedures specified in the affected source's SSMP. In this case, the Permittee shall report this action within 2 days of occurrence and follow by a written notification within 7 days of occurrence. 5. All information necessary to demonstrate conformance with the affected source's SSMP and actions taken in accordance with SSMP; 40 CFR 63.10(b)(2); Minn. R. 7019.0100, subp. 2

6. Each period during which a CMS is malfunctioning or inoperative; 7. All required measurements needed to demonstrate compliance with a relevant standard; 8. All results of performance test, CMS performance evaluations, and opacity and visible emission observations; 9. All measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 10. All CMS calibration checks; 11. All adjustments and maintenance performed on CMS; 12. Any information demonstrating whether a source is meeting the requirements for a waiver of record keeping or reporting requirements under this part; 13. All documents supporting initial notifications and notifications of compliance status. (continued) 40 CFR 63.10(b)(2); Minn. R. 7019.0100, subp. 2

The Permittee shall maintain the following records for each CMS:
1. All required CMS measurements; 2. The date and time identifying each period during which the CMS was inoperative except for zero (low-level) and high-level checks; 3. The date and time identifying each period during which the CMS was out of control; 4. The specific identification (i.e., the date and time of commencement and completion) of each period of excess emissions and parameter monitoring exceedances, that occurs during startups, shutdowns, and malfunctions of the affected source; 5. The specific identification (i.e., the date and time of commencement and completion) of each time period of excess emissions and parameter monitoring exceedances that occurs during periods other than SSM of the affected source; 40 CFR 63.10(c); Minn. R. 7019.0100, subp. 2

6. The nature and cause of any malfunction; 7. The corrective action taken or preventive measures adopted; 8. The nature of the repairs or adjustments to the CMS that was inoperative or out of control; 9. The total process operating time during the reporting period; and 10. All procedures that are part of a quality control program developed and implemented for CMS under 40 CFR Section 63.8(d). (continued) 40 CFR 63.10(c); Minn. R. 7019.0100, subp. 2

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-8

NESHAP GENERAL PROVISIONS - NOTIFICATIONS hdr Submit notifications required under 40 CFR part 63 to the Commissioner. In addition, send a copy of each notification to the appropriate Region V contact. 40 CFR 63.9(a); Minn. R. 7019.0100, subp. 2 Notification of the Actual Date of Initial Startup: due 15 days after initial startup. Submit the name and number of each unit and the actual date of initial startup of each unit. 40 CFR 63.9(b)(4)(v); Minn. R. 7019.0100, subp. 2

The Permittee shall submit a written notification of the date the CMS performance evaluation under 40 CFR Section 63.8(e) is scheduled to begin, submitted simultaneously with the notification of the performance test date required under 40 CFR Section 63.7(b). If no performance test is required, the Permittee shall submit a written notification of the date of the performance evaluation at least 60 calendar days before the evaluation is scheduled to begin. 40 CFR 63.9(g)(1); Minn. R. 7019.0100, subp. 2

The Permittee shall submit a notification of compliance status to the Commissioner following completion of the relevant compliance demonstration activity specified in the relevant standard. 40 CFR 63.9(h)(3); Minn. R. 7019.0100, subp. 2

The Permittee shall submit actual HAP emissions data and other information to verify that information submitted as part of the permit application is correct as soon as available but no later than with the initial notification of compliance. 40 CFR 63.9(h)(5); Minn. R. 7019.0100, subp. 2

Change in information already provided. Any change in the information already provided under this 40 CFR Section 63.9 shall be provided to the Commissioner in writing within 15 calendar days after the change. 40 CFR 63.9(j); Minn. R. 7019.0100, subp. 2

Excess Emissions and CMS Report. The Permittee shall submit an excess emissions and continuous monitoring system performance report and/or a summary report to the Commissioner by the 30th day following the end of each calendar half. The report(s) shall include all the information required and in accordance with 40 CFR Section 63.10(e)(3). 40 CFR 63.10(e)(3)(i) & (v); Minn. R. 7019.0100, subp. 2

Immediate SSM reports: Any time an action taken by the Permittee during a startup or shutdown or malfunction (that caused the source to exceed any applicable emission limitation in the relevant emission standards), that is not consistent with the procedures specified in the affected source's SSMP, the Permittee shall report the actions taken for that event within 2 working days after commencing the actions followed by a letter within 7 working days after the end of the event. The reports must be in accordance with 40 CFR Section 63.10(d)(5)(ii). 40 CFR 63.10(d)(5)(ii); 40 CFR 63.6(e)(3)(iv); Minn. R. 7011.7000; Minn. R. 7019.0100, subp. 2

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-9

Subject Item: GP 001 Mobile Sources

What to do Why to do it OPERATIONAL REQUIREMENTS AND LIMITS hdr Mobile Sources. The mobile sources affected by the requirements of this part are the following emission sources modeled as part of the visibility demonstration: 1. Diesel-driven Haul Trucks; 2. Diesel-driven Mining Shovels; 3. Diesel-driven Locomotives; 4. Diesel-driven Front-End Loaders. Title I Condition: 40 CFR 52.21(p); Minn. R. 7007.3000

Fuel Usage for Haul Trucks and Mining Equipment: Diesel Fuel only. Minn. R. 7007.0100, subp. 35a Fuel Usage: less than or equal to 4.3 million gallons/year for all haul trucks and mining equipment combined. Title I Condition: 40 CFR 52.21(p); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 2 Sulfur Content of Fuel: less than or equal to 15 ppm in diesel fuel. The Permittee may use fuel supplier certification to demonstrate compliance with this requirement. 40 CFR 80.510(b)

Permitted number of mobile sources prior to startup of DRI & Steel Mill: The diesel driven mobile sources at the facility prior to the startup of the DRI & Stee l Mill shall be certified Tier 2 or higher, at quantities at any one time not to exceed: - 8 Haul Trucks - 3 Mining Shovels - 2 Blast-hole Drills - 13 Total Front-End Loaders, Dozers, Graders, Locomotives, Sand&Water Trucks Title I Condition: 40 CFR 52.21(p); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 2

Permitted number of mobile sources after startup of the DRI & Steel Mill: The diesel driven mobile sources at the facility after startup of the DRI & Steel Mill shall be certified Tier 4, at quantities at any one time not to exceed: - 9 Haul Trucks - 4 Mining Shovels - 3 Blast-hole Drills - 14 Total Front-End Loaders, Dozers, Graders, Locomotives, Sand&Water Trucks
There shall be no non-certified Tier 4 mobile sources after DRI & Steel Mill startup. Title I Condition: 40 CFR 52.21(p); Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 2

Compliance certification requirements for Tier 2 mobile sources: Steady-State exhaust emissions from non-road diesel engines may not exceed: PM: <= 0.15 g/hp-hr CO: <= 2.6 g/hp-hr NOx: <= 4.9 g/hp-hr for rated engine power >= 175 hp but < 300 hp; NOx: <= 4.8 g/hp-hr for rated engine power >= 300 hp Title I Condition: 40 CFR 52.21(p); Minn. R. 7007.3000; 40 CFR 89.112(a); Minn. R. 7007.0800, subp. 2

Compliance certification requirements for Tier 4 mobile sources: Steady-State exhaust emissions from non-road diesel engines may not exceed: CO: <= 2.6 g/bhp-hr NMHC: <= 0.14 g/bhp-hr For maximum engine power >= 175 hp and <= 750 hp: PM: <= 0.015 g/bhp-hr NOx: <= 0.30 g/bhp-hr For maximum engine power > 750 hp: PM: <= 0.030 g/bhp-hr NOx: <= 2.6 g/bhp-hr Title I Condition: 40 CFR 52.21(p); Minn. R. 7007.3000; 40 CFR 1039.101(b); Minn. R. 7007.0800, subp. 2

Operate and maintain the mobile sources in accordance to a written O&M Plan at all times. Keep copies of the O&M Plan onsite and available for inspection upon request. Minn. R. 7007.0800, subps. 4 & 16(J)

RECORDKEEPING hdr The Permittee shall obtain and maintain a record of the monthly fuel supplier certification for diesel fuel, certifying that the sulfur content does not exceed 15ppm. Minn. R. 7007.0800, subps. 4 & 5

The Permittee shall obtain and maintain a record of the fuel supplier receipt for the volume of fuel delivered for each shipment of diesel fuel to demonstrate compliance with the diesel fuel use limitation. Minn. R. 7007.0800, subps. 4 & 5

The Permittee shall certify that the mobile sources in the group were operated and maintained in compliance with the manufacturers recommended maintenance procedures, practices, and schedules. Minn. R. 7007.0800 subp. 4

The Permittee shall retain all documents pertaining to purchasing, operations, and required maintenance to Tier 4 mobile sources. Minn. R. 7007.0800 subp. 5

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-10

Subject Item: GP 002 Emission Units Subject to Taconite MACT and NSPS LL
Associated Items: EU 002 Primary Ore Crusher EU 004 Grizzly Screening Building EU 013 Coarse Ore Storage Conveyor EU 014 Fine Ore Storage Conveyor EU 015 Coarse Ore Conveyor Gallery EU 018 Fine Ore Conveyor Gallery EU 022 Primary Grinding Mill Line 1 EU 024 Primary Grinding Mill Line 2 EU 036 Hearth Layer Bin EU 037 Hearth Layer Feed EU 038 Indurating Furnace, Hood Exhaust EU 039 Indurating Furnace, Furnace Waste Gas EU 040 Pellet Discharge EU 041 Pellet Screening and Handling EU 042 Pellet Screenings to Regrind Conveyors EU 048 Oxide Pellet Stockpile Conveyor Gallery EU 054 DRI Oxide Pellet Screening and Handling Line 1
EU 060 DRI Pellet Silos Line 1 EU 063 DRI Oxide Charging Area Line 1 EU 106 Oxides Pellet Transfer to Hearth Layer Bin EU 170 Grizzly Transfer Tower EU 171 Non-Magnetic Cobber Rejects Transfer Tower EU 172 Secondary Screening Crusher/Cobber Line 1 EU 173 Secondary Screening Crusher/Cobber Line 2 EU 174 Secondary Screening Crusher/Cobber Line 3 EU 175 Secondary Screening Crusher/Cobber Line 4 EU 176 Primary Grinding Mill Line 3

What to do Why to do it OPERATIONAL REQUIREMENTS hdr No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. 40 CFR 60.12

A t all times, including periods of SSM, owners and operators shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions, in accordance with 40 CFR 60.11(d). 40 CFR 60.11(d)

MONITORING hdr Operate and maintain each source, including air pollution control and monitoring equipment, in a manner consistent with good air pollution control practices for minimizing emissions at least to the levels required by Taconite MACT. 40 CFR 63.9600(a); Minn. R. 7011.8030

O&M Plan: The plan shall meet the requirements of 40 CFR 63.9600(b)(1)-(4), a current copy of the O&M plan maintained onsite, and available for inspection upon request. Keep the plan for the life of the affected source or until the affected source is no longer subject to the requirements of 40 CFR part 63, subpart RRRRR. 40 CFR 63.9600(b); 40 CFR 63.9636(b); Minn. R. 7011.8030

The Permittee shall monitor continuously (or collect data at all required intervals) at all times an affected source is operating except for monitoring malfunctions, associated repairs, and required quality assurance or control activities (including as applicable, calibration checks and required zero and span adjustments). 40 CFR 63.9633(a); Minn. R. 7011.8030

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-11

Data recorded during monitoring malfunctions, associated repairs, and required QA/QC activities shall not be used in data averages and calculations used to report emission or operating levels, or to fulfill a minimum data availability requirement. Use all data collected during all other periods in assessing compliance. 40 CFR 63.9633(b); Minn. R. 7011.8030

If the daily average operating parameter value for an emission unit or group of similar emission units does not meet the corresponding established operating limit, the Permittee must then follow the following procedures:
1. The Permittee must initiate and complete initial corrective action within 10 calendar days and demonstrate that the initial corrective action was successful. During any period of corrective action, the Permittee must continue to monitor and record all required operating parameters for equipment that remains in operation. After 10 calendar days, measure and record the daily average operating parameter value for the emission unit or group of similar emission units on which corrective action was taken. 40 CFR 63.9634(j); Minn. R. 7011.8030

2. If the initial corrective action required in (1) was not successful, then the Permittee must complete additional corrective action within 10 calendar days and demonstrate that the subsequent corrective action was successful. After the second set of 10 calendar days allowed to implement corrective action, the Permittee must again measure and record the daily average operating parameter value for the emission unit or group of similar emission units. 3. If the second attempt at corrective action required in paragraph (2) was not successful, then the Permittee must repeat the procedures until the corrective action is successful. If the third attempt at corrective action is unsuccessful, the Permittee must conduct another performance test in accordance with the procedures in 40 CFR Section 63.9622(f) and report to the Commissioner as a deviation the third unsuccessful attempt at corrective action. (continued) 40 CFR 63.9634(j); Minn. R. 7011.8030

4. After the third unsuccessful attempt at corrective action, the Permittee must submit the written report required in (3) within 5 calendar days after the third unsuccessful attempt at corrective action. This report must notify the Commissioner that a deviation has occurred and document the types of corrective measures taken to address the problem that resulted in the deviation of established operating parameters and the resulting operating limits. (continued) 40 CFR 63.9634(j); Minn. R. 7011.8030

Deviations. The Permittee must report each instance in which an emission limitation was not met. This includes periods of SSM. The Permittee must report each instance in which a work practice standard in 40 CFR 63.9591 was not met. The Permittee must report each instance in which an applicable operation and maintenance requirement in 40 CFR 63.9600 was not met. These deviations must be reported in accordance with the requirements in 40 CFR 63.9641. 40 CFR 63.9637(a); Minn. R. 7011.8030

During periods of SSM, the Permittee must operate in accordance with the SSMP and the requirements in 40 CFR Section 63.9637(b)(1)&(2). 40 CFR 63.9637(b); Minn. R. 7011.8030
RECORDKEEPING hdr The Permittee shall keep the following records:
- A copy of each notification and report that you submitted to comply with 40 CFR part 63, subpart RRRRR. - The records in 40 CFR Section 63.6(e)(3)(iii)-(v) related to SSM. - Records of performance tests and performance evaluations as required in Section 63.10(b)(2)(viii).
The Permittee shall also keep the records required in 40 CFR Sections 63.9634 through 63.9636 to show continuous compliance with each emission limitation, work practice standard, and operation and maintenance requirement that apply.
Each record shall be kept for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Each record shall be kept on site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record. 40 CFR 63.9642(a)&(c); 40 CFR 63.9643(b)&(c); Minn. R. 7011.8030; 40 CFR 60.7(f); Minn. R. 7019.0100, subp. 1

Maintain records of the occurrence and duration of any SSM event in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a CMS or monitoring device is inoperative. 40 CFR 60.7(b); Minn. R. 7019.0100, subp. 1

REPORTING hdr Notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. 40 CFR 60.7(a)(4); Minn. R. 7019.0100, subp. 1 Submit all notifications of compliance status to the Commissioner following completion of the specified compliance demonstration activity. 40 CFR 63.9(h)(3); Minn. R. 7019.0100, subp. 2 Meet the notification and schedule requirements in 40 CFR Section 63.9640. 40 CFR 63.9583; Minn. R. 7011.8030

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-12

Submit the initial notification of compliance status (including the performance test results) for each emission limitation and operating limit by the following dates: 1. Before the close of business on the 30th calendar day following completion of the initial compliance demonstration that does not include a performance test; 2. Before the close of business on the 60th calendar day following completion of the initial compliance demonstration that does include a performance test. 40 CFR 63.9640(e); 40 CFR 63.9623(c); 40 CFR 63.9(h)(2)(ii); Minn. R. 7011.8030

Immediate SSM reports. Any time an action taken by the Permittee during a startup or shutdown or malfunction (that caused the source to exceed any applicable emission limitation in the relevant emission standards), that is not consistent with the procedures specified in the affected source's SSMP, the Permittee shall report the actions taken for that event within 2 working days after commencing the actions followed by a letter within 7 working days after the end of the event. The reports must be in accordance with 40 CFR Section 63.10(d)(5)(ii). 40 CFR 63.10(d)(5)(ii); 40 CFR 63.9641(c); Minn. R. 7019.0100, subp. 2; Minn. R. 7011.8030

Immediate corrective action report. The Permittee shall submit an immediate corrective action report if three unsuccessful attempts of applying corrective action as described in 40 CFR Section 63.9634(j) were made on an emission unit or group of emission units. Also, within 5 calendar days after the third unsuccessful attempt at corrective action, the Permittee shall submit to the Commissioner a written report in accordance with 40 CFR Section 63.9634(j)(3)&(4). 40 CFR 63.9641(e); Minn. R. 7011.8030

Compliance Report Contents. Each compliance report must include the information in paragraphs (1)-(3) and, as applicable, in paragraphs (4)-(8). 1. Company name and address. 2. Statement by a responsible official, with the official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report. 3. Date of report and beginning and ending dates of the reporting period. 4. If you had a startup, shutdown, or malfunction during the reporting period and you took actions consistent with your SSMP, the compliance report must include the information in Section 63.10(d)(5)(i). 5. If there were no deviations from the continuous compliance requirements in Sections 63.9634-63.9636 that apply to you, then provide a statement that there were no deviations from the emission limitations, work practice standards, or operation and maintenance requirements during the reporting period. 40 CFR 63.9641(b); Minn. R. 7011.8030

6. If there were no periods during which a CMS (including a CPMS) was out-of- control as specified in Section 63.8(c)(7), then provide a statement that there were no periods that a CMS was out-of-control during the reporting period. 7. For each deviation from an emission limitation in Table 1 to this subpart that occurs at an affected source where you are not using a CMS (including a CPMS) to comply with an emission limitation, the compliance report must contain the information in paragraphs (1)-(4) of this section and the information in paragraphs (7)(i)&(ii). This includes periods of SSM. i. The total operating time of each affected source during the reporting period. ii. Information on the number, duration, and cause of deviations (including unknown cause) as applicable, and the corrective action taken. (continued) 40 CFR 63.9641(b); Minn. R. 7011.8030

8. For each deviation from an emission limitation occurring at an affected source a CMS (including a CPMS) is used to comply with the emission limitation, the Permittee must include the information in paragraphs (1)-(4) and the information in paragraphs (8)(i)-(xi). This includes periods of SSM. i. The date and time that each malfunction started and stopped. ii. The date and time that each CMS was inoperative, except for zero (low-level) and high-level checks. iii. The date, time, and duration that each CMS was out-of-control, including the information in Section 63.8(c)(8). iv. The date and time that each deviation started and stopped, and whether each deviation occurred during a period of startup, shutdown, or malfunction or during another period. (continued) 40 CFR 63.9641(b); Minn. R. 7011.8030

v. A summary of the total duration of the deviation during the reporting period and the total duration as a percent of the total source operating time during that reporting period. vi. A breakdown of the total duration of the deviations during the reporting period including those that are due to startup, shutdown, control equipment problems, process problems, other known causes, and other unknown causes. vii. A summary of the total duration of CMS downtime during the reporting period and the total duration of CMS downtime as a percent of the total source operating time during the reporting period. viii. A brief description of the process units. ix. A brief description of the CMS. x. The date of the latest CMS certification or audit. xi. A description of any changes in continuous monitoring systems, processes, or controls since the last reporting period. (continued) 40 CFR 63.9641(b); Minn. R. 7011.8030

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-13

Subject Item: GP 003 Ore Crushing & Handling
Associated Items: EU 002 Primary Ore Crusher EU 004 Grizzly Screening Building EU 013 Coarse Ore Storage Conveyor EU 014 Fine Ore Storage Conveyor EU 015 Coarse Ore Conveyor Gallery EU 018 Fine Ore Conveyor Gallery EU 022 Primary Grinding Mill Line 1 EU 024 Primary Grinding Mill Line 2 EU 170 Grizzly Transfer Tower EU 171 Non-Magnetic Cobber Rejects Transfer Tower EU 172 Secondary Screening Crusher/Cobber Line 1 EU 173 Secondary Screening Crusher/Cobber Line 2 EU 174 Secondary Screening Crusher/Cobber Line 3 EU 175 Secondary Screening Crusher/Cobber Line 4 EU 176 Primary Grinding Mill Line 3

What to do Why to do it
BACT LIMITS hdr Crude Ore Lead Concentration: less than or equal to 12 mg/kg using 12-month rolling average lead concentration of crude ore handled by the sources listed in this group. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Crude Ore Fluoride Concentration: less than or equal to 1.0 mg/kg using 12-month rolling average fluoride concentration of crude ore handled by the sources listed in this group. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

MONITORING AND RECORDKEEPING hdr Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000

Crude Ore Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the crude ore lead and/or fluoride concentration. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 5
MACT LIMITS See GP 008 for MACT emission limits for these units. hdr

PERFORMANCE TESTING See GP 008 for Performance Testing requirements for these units. hdr

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-14

Subject Item: GP 004 Finished Pellet Handling
Associated Items: EU 036 Hearth Layer Bin EU 037 Hearth Layer Feed EU 040 Pellet Discharge EU 041 Pellet Screening and Handling EU 042 Pellet Screenings to Regrind Conveyors EU 048 Oxide Pellet Stockpile Conveyor Gallery EU 054 DRI Oxide Pellet Screening and Handling Line 1
EU 060 DRI Pellet Silos Line 1 EU 063 DRI Oxide Charging Area Line 1 EU 106 Oxides Pellet Transfer to Hearth Layer Bin

What to do Why to do it
BACT LIMITS hdr Oxide Pellet Lead Concentration: less than or equal to 2.0 mg/kg using 12-month rolling average lead concentration of oxide pellets handled by the sources listed in this group. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Oxide Pellet Fluoride Concentration: less than or equal to 50. mg/kg using 12-month rolling average fluoride concentration of oxide pellets handled by the sources listed in this group. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

MONITORING AND RECORDKEEPING hdr Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000

Oxide Pellet Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the oxide pellet lead and/or fluoride concentration. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 5
MACT LIMITS See GP 008 for MACT emission limits for these units. hdr

PERFORMANCE TESTING See GP 008 for Performance Testing requirements for these units. hdr

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-15

Subject Item: GP 005 Waste Rock Handling
Associated Items: FS 004 Waste Rock Loadout FS 005 Waste Rock Unloading (Truck)
FS 009 Overburden / Waste Rock Area Wind Erosion

What to do Why to do it
BACT LIMITS hdr Waste Rock Lead Concentration: less than or equal to 8.4 mg/kg using 12-month rolling average lead concentration of waste rock handled by the sources listed in this group. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Waste Rock Fluoride Concentration: less than or equal to 0.7 mg/kg using 12-month rolling average fluoride concentration of waste rock handled by the sources listed in this group. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

MONITORING AND RECORDKEEPING hdr Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000

Waste Rock Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the waste rock lead and/or fluoride concentration. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 5

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-16

Subject Item: GP 006 Fugitive Sources

What to do Why to do it
A ssociated items for this group consist of all the fugitive sources at the facility. Minn. R. 7007.0800, subp. 2 The following regulations apply to the following fugitive sources at the facility: Taconite MACT - FS 001-021, and 025-029 Case-by-Case MACT - FS 022-024, and 030-070 NSPS LL - FS 002-006, and 009-036 40 CFR 63.9582(b) and Minn. R. 7011.8030; 40 CFR 63.43(g)(2): MACT and Minn. R. 7007.3010

EMISSION LIMITS hdr Opacity: less than 5 percent opacity using 6-minute Average Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Opacity: less than 10 percent opacity using 6-minute Average 40 CFR 60.382(b); Minn. R. 7011.2700
FUGITIVE CONTROL PLAN hdr The Permittee shall prepare and at all times operate according to, a fugitive dust emissions control plan that describes in detail the measures that will be put in place to control fugitive dust emissions from: 1. Stockpiles; 2. Material transfer points; 3. Material handling; 4. Plant roadways; 5. Tailings basin; 6. Pellet/DRI/Slag loading areas; and 7. Yard areas.
The Permittee shall maintain a current copy of the fugitive dust emissions control plan onsite, and it must be available for inspection upon request. The plan must be kept for the life of the affected source. 40 CFR 63.9591(a) & (d); 40 CFR 63.9635; 40 CFR 63.43(g)(2): MACT and Minn. R. 7007.3010

Submit a fugitive emissions control plan before startup for review and approval by the Commissioner (see Table B). The plan shall identify all fugitive emission sources, primary and contingent control measures, and recordkeeping. Follow the actions and recordkeeping specified in the control plan. The plan may be amended by the Permittee with the Commissioner's approval. If the Commissioner determine s the Permittee is out of compliance with Minn. R. 7011.0150 or the fugitive emission control plan, then the Permittee may be required to amend the control plan and/or to install and operate particulate matter ambient monitors. Minn. R. 7007.0800, subp. 2

VISIBLE EMISSION CHECKS hdr Check for Visible Emissions (VEs) daily (during daylight hours) from fugitive emission sources while in operation. Minn. R. 7007.0800, subp. 4

Corrective Actions: If visible emissions are observed, determine the cause and take corrective actions as soon as possible to eliminate the VEs. Minn. R. 7007.0800, subp. 2

Recordkeeping: Record the time and date of each VE inspection and whether or not any VEs were observed. If VEs were observed, also record a brief description of the corrective action taken, and the date the action was taken. Minn. R. 7007.0800, subp. 5

PERFORMANCE TESTING hdr Opacity Compliance: Demonstrate compliance with opacity standards using Reference Method 9, and only when emissions are clearly identified as emanating solely from the source being observed. 40 CFR 60.386(b)(2); 40 CFR 60.11; Minn. R. 7017.2015

Initial Performance Test: due 180 days after Initial Startup for opacity from FS 006. 40 CFR 60.386(b)(2) and Minn. R. 7011.2700 Initial Performance Test: due 180 days after Initial Startup for opacity from FS 009. 40 CFR 60.386(b)(2) and Minn. R. 7011.2700 Initial Performance Test: due 180 days after Initial Startup for opacity from FS 010. 40 CFR 60.386(b)(2) and Minn. R. 7011.2700 Initial Performance Test: due 180 days after Initial Startup for opacity from FS 016. 40 CFR 60.386(b)(2) and Minn. R. 7011.2700 Initial Performance Test: due 180 days after Initial Startup for opacity from FS 017. 40 CFR 60.386(b)(2) and Minn. R. 7011.2700 Initial Performance Test: due 180 days after Initial Startup for opacity from FS 018. 40 CFR 60.386(b)(2) and Minn. R. 7011.2700 Initial Performance Test: due 180 days after Initial Startup for opacity from FS 024. 40 CFR 60.386(b)(2) and Minn. R. 7011.2700 Initial Performance Test: due 180 days after Initial Startup for opacity from FS 025. 40 CFR 60.386(b)(2) and Minn. R. 7011.2700 Initial Performance Test: due 180 days after Initial Startup for opacity from FS 027. 40 CFR 60.386(b)(2) and Minn. R. 7011.2700

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-17

Subject Item: GP 007 Baghouses with Leak Detection
Associated Items: CE 001 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 006 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 007 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 008 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 009 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 010 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 011 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 014 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 015 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 016 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 019 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 021 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 022 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 023 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 024 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 025 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 040 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 093 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 097 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 110 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 111 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 112 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 113 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 114 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 115 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 116 Fabric Filter - Low Temperature, i.e., T<180 Degrees F

What to do Why to do it Stacks associated with each baghouse are shown in the following pairs:
CE 001/SV 001 | CE 011/SV 011 | CE 023/SV 022 | CE 111/SV 087 CE 002/SV 002 | CE 014/SV 016 | CE 024/SV 023 | CE 112/SV 088 CE 006/SV 006 | CE 015/SV 017 | CE 025/SV 027 | CE 113/SV 089 CE 007/SV 007 | CE 016/SV 018 | CE 040/SV 044 | CE 114/SV 090 CE 008/SV 008 | CE 019/SV 019 | CE 093/SV 073 | CE 115/SV 085 CE 009/SV 009 | CE 021/SV 020 | CE 097/SV 031 | CE 116/SV 084 CE 010/SV 010 | CE 022/SV 021 | CE 110/SV 086 hdr

Install, operate, and maintain a bag leak detection system according to the requirements in 40 CFR Section 63.9632(a) for each CE listed in this group. 40 CFR 63.9631(a); 40 CFR 64.7(a) & (c): CAM and Minn. R. 7017.0200 The Permittee shall identify and implement a set of site-specific preventative maintenance and corrective action plan including the following:
1. Preventative maintenance for each control device, including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance. 2. Corrective action procedures for bag leak detection systems. In the event a bag leak detection system alarm is triggered, the Permittee shall initiate corrective action to determine the cause of the alarm within 1 hour of the alarm, initiate corrective action to correct the cause of the problem within 24 hours of the alarm, and complete the corrective action as soon as practicable. Corrective actions may include, but are not limited to: i. Inspecting the baghouse for air leaks, torn or broken bags or filter media, or any other condition that may cause an increase in emissions. 40 CFR 63.9600(b)(1) & (2); 40 CFR 64.7(a) & (c): CAM and Minn. R. 7017.0200

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-18

ii. Sealing off defective bags or filter media. iii. Replacing defective bags or filter media or otherwise repairing the control devic e iv. Sealing off a defective baghouse compartment. v. Cleaning the bag leak detection system probe, or otherwise repairing the bag leak detection system. vi. Adjusting the process operation producing the particulate emissions. (continued) 40 CFR 63.9600(b)(1) & (2); 40 CFR 64.7(a) & (c): CAM and Minn. R. 7017.0200

The Permittee shall conduct inspections to:
1. Monitor the pressure drop across each baghouse cell each day to ensure pressure drop is within the normal operating range. 2. Confirm that dust is being removed from hoppers through weekly visual inspections or other means of ensuring the proper functioning of removal mechanisms. 3. Check the compressed air supply of pulse-jet baghouses each day. 4. Monitor cleaning cycles to ensure proper operation using an appropriate methodolgy. 5. Check bag cleaning mechanisms for proper functioning through monthly visual inspections or equivalent means. 6. Make monthly visual checks of bag tension on reverse air and shaker-type baghouses. 7. Confirm the physical integrity of the baghouse through quarterly visual inspections of the baghouse interior for air leaks. 8. Inspect fans for wear, material buildup, and corrosion through quarterly visual inspections, vibration detectors, or equivalent means. 40 CFR 63.9631(a); 40 CFR 64.7(a) & (c): CAM and Minn. R. 7017.0200

Maintain records of the time corrective action is initiated in the event of a bag leak detection system alarm, the corrective action(s) taken, and the date on which corrective action was completed.
Inspect and maintain each baghouse according to the requirements in 40 CFR Section 63.9631(a)(1)-(8) and record all the information needed to document conformance with these requirements.
If the Permittee increases or decreases the sensitivity of the bag leak detection system beyond the limits specified in the site-specific monitoring plan, the Permittee shall include a copy of the required written certification by a responsible official in the next semiannual compliance report. 40 CFR 63.9634(d); 40 CFR 64.7(a) & (c): CAM and Minn. R. 7017.0200

The Permittee shall:
1. Perform preventative maintenance for each control device in accordance with a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance and record all information needed to document conformance with these requirements; and 2. Initiate and complete corrective action for a bag leak detection system alarm in accordance with 40 CFR 63.9600(b)(2) and record all information needed to document conformance with these requirements. 40 CFR 63.9636(a)(1) & (2); 40 CFR 64.7(a) & (c): CAM and Minn. R. 7017.0200

Operating limits may be changed for any air pollution control device if the Permittee: 1. Submits a written notification to the Commissioner requesting to conduct a new performance test to revise the operating limit. 2. Conducts a performance test to demonstrate compliance with the applicable emission limitation. 3. Establishes revised operating limits according to the applicable procedures in 40 CFR Section 63.9622(a). 40 CFR 63.9622(f); Minn. R. 7011.8030

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-19

Subject Item: GP 008 Baghouses Subject to Taconite MACT
Associated Items: SV 001 Primary Ore Crusher SV 002 Grizzly Screening Building SV 006 Coarse Ore Storage Conveyor SV 007 Fine Ore Storage Conveyor SV 008 Coarse Ore Conveyor Gallery SV 009 Fine Ore Conveyor Gallery SV 010 Primary Grinding Mill Line 1 SV 011 Primary Grinding Mill Line 2 SV 016 Hearth Layer Bin SV 017 Hearth Layer Feed SV 020 Pellet Discharge SV 021 Pellet Screening and Handling SV 022 Pellet Screenings to Regrind Conveyors SV 023 Oxide Pellet Stockpile Conveyor Gallery SV 027 DRI Oxide Pellet Screening and Handling System Line 1 SV 031 DRI Oxide Charging Area Line 1
SV 073 DRI Pellet Silos Line 1 SV 084 Primary Grinding Mill Line 3 SV 085 Grizzly Transfer Tower SV 086 Non-Magnetic Cobber Rejects Transfer Tower SV 087 Secondary Screening Crusher/Cobber Line 1 SV 088 Secondary Screening Crusher/Cobber Line 2 SV 089 Secondary Screening Crusher/Cobber Line 3 SV 090 Secondary Screening Crusher/Cobber Line 4

What to do Why to do it
BACT LIMITS hdr
A ppendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Total PM: comply with the Total PM limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 PM < 10 micron: comply with the PM10 limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 PM < 2.5 micron: comply with the PM2.5 limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Lead: comply with the lead limits on a lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Fluorides: comply with the fluoride limits on a lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Opacity: less than or equal to 5 percent opacity using 6-minute Average Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
OTHER EMISSION LIMITS hdr Emission limits listed in this section apply individually to each stack, however compliance with the above limits will demonstrate compliance with these limits. Minn. R. 7007.0800, subp. 2

Total PM: less than or equal to 0.005 gr/dscf using 3-hour average and on the basis of a flow-weighted mean concentration. Determine the flow-weighted mean concentration of Total PM emissions from all SVs in this group as described in 40 CFR 63.9621(b)(3)(i) or (ii). 40 CFR 63.9590(a); 40 CFR 63.9621(b); 40 CFR 63.9623(a)(1); Minn. R. 7011.8030 Total PM: less than 0.02 gr/dscf using 3-hour average. 40 CFR 60.382(a)(1); Minn. R. 7011.2700 Opacity: less than or equal to 7 percent opacity using 6-minute Average 40 CFR 60.382(a)(2) and Minn. R. 7011.2700

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-20

PERFORMANCE TESTING hdr The Source Groups referenced by the following testing requirements are as defined in Appendix E, which also describes testing requirements for PM2.5. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Notification of Anticipated Date for Conducting Opacity Observations: due 30 day prior to observation date 40 CFR 60.7(a)(4); Minn. R. 7019.0100, subp. 1 Demonstrate compliance with opacity standards using Reference Method 9. The opacity standards apply at all times except during periods of SSM. 40 CFR 60.11; Minn. R. 7017.2015 For the purpose of demonstrating initial compliance, conduct opacity observations concurrently with the initial performance test and include the results in the test report, pursuant to the conditions described in 40 CFR 60.11(e)(1)-(3). 40 CFR 60.11(e)(1)-(3)

The test plan (see Table B) for the initial PM tests shall contain the following: 1. A list of all emission units. This list must clearly identify all emission units that have been grouped together as similar emission units. Within each group of emission units, the Permittee must identify the emission unit that will be the representative unit for that group and subject to initial performance testing. 2. A list of the process type and type of air pollution control device on each emission unit. 3. A schedule indicating when an initial performance test for PM, PM10, PM2.5, and opacity for each representative emission unit will be conducted. 40 CFR 9620(g); Minn. R. 7011.8030

Initial Performance Test: due 180 days after Initial Startup to measure Total PM, PM10, and opacity from one stack from each of the following: Group A, Group B, Group C, and Group D sources. The PM performance test shall also demonstrate compliance with the MACT limit on a flow-weighted mean concentration basis. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000; 40 CFR 63.9620(a), (c), & (e); Minn. R. 7011.8030; Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 180 days after Initial Startup to measure PM2.5 from two stacks from each of the following: Group A, Group B, Group C, and Group D
sources. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000; 40 CFR 63.9620(a), (c), & (e); Minn. R. 7011.8030; Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each calendar 24 months following Initial Performance Test to measure Total PM, PM10, PM2.5, and opacity from one stack from each of the following: Group A, Group B, Group C, and Group D sources. To the extent practicable, the performance tests shall cycle through each member of each group. The PM performance test shall also demonstrate compliance with the MACT limit on a flow-weighted mean concentration basis. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; 40 CFR 63.9630(a) & (c); 40 CFR 63.9620(e); Minn. R. 7911.8030; Minn. R. 7017.2020, subp. 1 The site-specific operating limits established for the emission unit selected as representative of a group of similar emission units will be used as the operating limit for each emission unit within the group. The operating limit established for the representative unit must be met by each emission unit within the group. 40 CFR 63.9620(f)(3); Minn. R. 7011.8030

For emission units not selected for initial performance testing and defined within a group of similar emission units in accordance with 40 CFR Section 63.9620(e), the Permittee shall calculate the daily average value of each operating parameter for the similar air pollution control device applied to each similar emission unit within a defined group using the following equation.
Pk = (sum of all Pi)/n

Where: Pk = Daily average operating parameter value for all emission units within group k; Pi = Daily average parametric monitoring parameter value corresponding to emission unit i within the group; and n = Total number of emission units within the group. 40 CFR 63.9634(b); Minn. R. 7011.8030

Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000

MONITORING hdr See GP 007 for Bag Leak Detection systems required for baghouses. 40 CFR 63.9631(a); Minn. R. 7011.8030; 40 CFR 64.7(a) & (c): CAM and Minn. R. 7017.0200

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-21

Subject Item: GP 009 EAF Baghouses
Associated Items: CE 040 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 043 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 044 EAF Baghouse Line 1 SV 047 EAF Baghouse Dust Transfer Line 1

What to do Why to do it
BACT LIMITS hdr
A ppendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Total PM: comply with the Total PM limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 PM < 10 micron: comply with the PM10 limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 PM < 2.5 micron: comply with the PM2.5 limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Lead: comply with the lead limits on a lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Fluorides: comply with the fluoride limits on a lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Sulfur Dioxide: comply with the SO2 limits on a lb/ton of steel produced and lb/hr basis using a 1-hour average from SV 044. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Sulfuric Acid Mist: comply with the SAM limits on a lb/ton of liquid steel produced and lb/hr basis using a 3-hour average from SV 044. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Nitrogen Oxides: comply with the NOx limits on a lb/ton liquid steel produced on a 30-day rolling average and lb/hr using 24-hour rolling average basis from SV 044. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Nitrogen Oxides: comply with the NOx SSM limits using 1-hour rolling average from SV 044. This limit applies during periods of startup (for no longer than 36 hours) and shutdown (for no longer than 28 hours). Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000

Carbon Monoxide: comply with the CO limits on a lb/ton of liquid steel produced and lb/hr basis using a 1-hour Rolling Average from SV 044. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; 40 CFR 63.43(g)(1): MACT and Minn. R. 7007.3010 Volatile Organic Compounds: comply with the VOC limits on a lb/ton of liquid steel produced and lb/hr basis using a 3-hour average from SV 044. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Opacity: less than 3 percent opacity using 6-minute Average from SV 044. This also demonstrates compliance with Minn. R. 7011.0715, subp. 1(B). Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; 40 CFR 60.272a(a)(2); Minn. R. 7011.2020, subp. D; Minn. R. 7011.0715, subp. 1(B) Opacity: less than or equal to 5 percent opacity using 6-minute Average from SV 047. This also demonstrates compliance with 40 CFR 60.382(a)(2). Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; 40 CFR 60.382(a)(2); Minn. R. 7011.2700
OTHER EMISSION LIMITS hdr Emission limits listed in this section apply individually to each stack, however compliance with the above limits will demonstrate compliance with these limits. Minn. R. 7007.0800, subp. 2

Total PM: less than 0.0052 gr/dscf using 3-hour average from SV 044. 40 CFR 60.272a(a)(1); Minn. R. 7011.2020, subp. D; Minn. R. 7011.0715, subps. 1(A) & 3 Total PM: less than 0.02 gr/dscf using 3-hour average from SV 047. 40 CFR 60.382(a)(1); Minn. R. 7011.2700 Total PM: less than or equal to 0.005 gr/dscf using 3-hour average and on the basis of a flow-weighted mean concentration. Determine the flow-weighted mean concentration of Total PM emissions from all SVs in this group as described in 40 CFR 63.9621(b)(3)(i) or (ii). 40 CFR 63.9590(a); 40 CFR 63.9621(b); 40 CFR 63.9623(a)(1); Minn. R. 7011.8030
EAF BAGHOUSE DUST TRANSFER LIMITS (SV 047 only) hdr

EAF Baghouse Dust Lead Concentration: less than or equal to 8000 mg/kg using 12-month rolling average lead concentration of EAF baghouse dust handled by the dust transfer baghouses listed in this group. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

EAF Baghouse Dust Fluoride Concentration: less than or equal to 4600 mg/kg using 12-month rolling average fluoride concentration of EAF baghouse dust handled by the dust transfer baghouses listed in this group. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-22

PERFORMANCE TESTING hdr Initial Performance Test: due 180 days after Initial Startup of EU 125 for Total PM, PM10, and PM2.5 emissions from SV 044. The PM test shall also demonstrate compliance with the MACT limit on a flow-weighted mean concentration basis. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 60.8 Initial Performance Test: due 180 days after Initial Startup of EU 125 for opacity from SV 044. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; 40 CFR 60.8 Initial Performance Test: due 180 days after Initial Startup of EU 125 for VOC emissions from SV 044. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Initial Performance Test: due 180 days after Initial Startup of EU 125 for sulfuric acid mist from SV 044. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Initial Performance Test: due 180 days after Initial Startup of EU 125 for lead from SV 044. Three 3-hour tests may be performed rather than three 1-hour tests because a low concentration of lead in the stack gases is anticipated. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Initial Performance Test: due 180 days after Initial Startup of EU 125 for mercury from SV 044. The Permittee shall speciate the mercury emitted. Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Initial Startup of EU 125 for PCDD/PCDF from SV 044. Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each year following Initial Performance Test to measure mercury emissions from SV 044. Shall be performed no sooner than 30 days from any other mercury test. Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each year following Initial Performance Test to measure PCDD/PCDF emissions from SV 044. Minn. R. 7017.2020, subp. 1

Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000

STACKS WITH CEMS - EAF BAGHOUSE (SV 044) hdr

Install, operate, and maintain bag leak detection systems according to the requirements in GP 007 (CE 040). 40 CFR 63.9631(a); 40 CFR 64.7(a) & (c): CAM and Minn. R. 7017.0200 Install, operate, and maintain CEMS, as specified in GP 022, to measure SO2, NOx, CO, and oxygen emissions from SV 044. Oxygen CEMS data is required for correction of concentrations of emissions of SO2, NOx, and CO. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; 40 CFR 64.7(a): CAM and Minn. R. 7017.0200; Minn. R. 7017.1006; Minn. R. 7007.0800, subp. 4 The Permittee shall continuously monitor sulfuric acid mist emissions (SAM) using SO2 CEMS and estimating an emission rate using the following equations: SAM (ppm) = K x F1 x F2 x SO2 (ppm) SAM (lb/hr) = See Appendix F Where: K = 1.53 - Molecular weight and units conversion from SO2 to H2SO4; F1 = 0.0038 - Fuel Factor; F2 = 0.1 - Technology Factor Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4

VISIBLE EMISSION CHECKS - EAF BAGHOUSE DUST TRANSFER (SV 047) hdr

Visible Emissions: The Permittee shall check the fabric filter stacks for any visible emissions, using the Visible Emissions Check List included in Appendix D of this permit, once each day of operation during daylight hours. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4 Recordkeeping of Visible Emissions. Record the time and date of each visible emission inspection and whether or not any visible emissions were observed. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 5 Corrective Action: If visible emissions are observed, the Permittee shall follow the O&M Plan for the fabric filter and take corrective actions as soon as possible to eliminate the visible emissions. The Permittee shall keep a record of the type and date of all corrective actions taken. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

RECORDKEEPING AND REPORTING hdr EAF Baghouse Dust Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the EAF baghouse dust lead and fluoride concentration. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 5 No NOx emission data have been collected from an EAF using DRI to make high quality slab steel. Within 13 months of initial start-up, the Permittee shall submit CEM data for the first 12 months of operation. A copy of the data shall also be sent to the Manager of the Metallic Mining Sector. The Permittee shall submit an application for a PSD permit modification to amend the NOx limit and update the BACT analysis based on the actual level of emissions. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 6

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-23

Subject Item: GP 010 Electric Arc Furnaces
Associated Items: EU 125 Electric Arc Furnace Line 1

What to do Why to do it OPERATIONAL REQUIREMENTS hdr Material Usage: less than or equal to 30,313 tons/year using 12-month Rolling Sum of clean external market scrap steel in the EAF units in total. (27,500 tonnes/yr)
Clean external scrap means scrap that has non-detectable concentrations of mercury, lead and polyvinylchloride and includes Special Plate Punchings, No.3 Steel (Prepared Bushling), No.1 Shredded Steel, or No.1 Bundles or any scrap that does not originate from automobile or white good shredding. External scrap from automobile or white good shredding may only be used if certified by the supplier to be free of mercury, lead and polyvinylchloride. Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010; Minn. R. 7007.0800, subp. 2

A llowed External Scrap Steel Types: All Steel Mill Scrap grades are based on prepared mill specification grades in minimum truck-lot-load quantities (20 Ton). Special Plate Punchings: Special Plate Punchings shall include clean, dry, uniform plate punchings suitable for ballast material or high density furnaces charging. Material must be free flowing and no piece shall be larger than 2" in any direction and a minimum of 1/4" in any direction. May be any shape provided that there are no protruding edges. No.3 Steel (Prepared Bushling): No.3 Steel (Prepared Bushling) shall consist of clean, uncoated free flowing steel clippings, stampings & sheet skeletons under 1/8" thick and not exceeding 12" length or width. Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010; Minn. R. 7007.0800, subp. 2

No.1 Shredded Steel: No.1 Shredded Steel shall consist of fresh shredded clean, bushling & shredder clips, suitable as charge stock for coreless induction melting with a minimum weight density of 50 lb/cubic foot. No.1 Bundles: No.1 Bundles shall consist of clean steel compressed into chargeage bundles with a minimum weight density of 75 lb/cubic foot. This grade would typically contain baled bushling. (continued) Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010; Minn. R. 7007.0800, subp. 2

BACT REQUIREMENTS hdr Oxy-fuel burners: The Permittee shall install and operate Oxy-fuel burners in the EAF units. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Sulfur Content of Carbon Additive: less than or equal to 1.0% by weight. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Fluorspar Usage Limit: less than or equal to 25 tons/hr of Fluorspar introduced to the Electric Arc Furnace (EU 125). Record the quantity of Fluorspar added to each heat and the time of the introduction. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5 DRI Lead Concentration: less than or equal to 20 mg/kg using 12-month rolling average lead concentration of DRI introduced to the Electric Arc Furnace (EU 125). Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 DRI Fluoride Concentration: less than or equal to 50 mg/kg using 12-month rolling average lead concentration of DRI introduced to the Electric Arc Furnace (EU 125). Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
MONITORING hdr The Permittee shall conduct monthly monitoring of the sulfur content of the carbon additives to the EAF. The Permittee shall, using ASTM sampling and analysis methods, by the 15th of each month use ASTM measure and record the sulfur content. In lieu of monthly sampling and analyzing the sulfur content of the carbon, the Permittee may obtain and maintain a record of monthly vendor certifications of the sulfur content of the carbon. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

RECORDKEEPING hdr Feed Material Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the feed material lead and/or fluoride concentration. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 5 The Permittee shall daily record the quantity and type of external scrap charged to the EAFs. The Permittee shall also record if the material is certified by the supplier to have non-detectable concentrations of mercury, lead and polyvinylchloride and shall maintain a copy of the supplier's certification.
The Permittee shall by the 16th of each month calculate and record the 12-month rolling sum of external scrap charged to the EAFs. Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010; Minn. R. 7007.0800, subps. 4 & 5

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-24

Subject Item: GP 011 Meltshop Enclosures
Associated Items: BG 012 EAF Area & Furnace Shop Line 1 BG 014 Ladle Metallurgy Furnaces Line 1

What to do Why to do it BUILDING REQUIREMENTS hdr Design the meltshop buildings to operate at a negative gauge pressure. All air vented from the building shall be sent through air pollution control equipment. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
A nnual certification.
The Permittee shall annually certify that the building has been evaluated by qualified personnel and that the building conforms to the design and operating practices recommended in the "Industrial Ventilation - A Manual of Recommended Practice, American Conference of Governmental Industrial Hygienists." The building evaluation shall include consideration of building dimensions, design capture velocity, minimum recommended air flow, face, slot, plenum or duct velocity as applicable and fan rotation speed or fan power draw compared to design values. The number of doors open at any given time will be a function of the overall volumetric flow of air to the baghouse. Minn. R. 7007.0800, subps. 4 & 5

The Permittee shall post signs on all non-alarmed doors and windows leading to the outside that state that the doors and windows must remain closed while the facility is in operation except for normal access and egress.
The Permittee shall conduct inspections at least once each calendar week to determine if the doors and windows are closed as required by this permit. The Permittee shall maintain a written record of the inspections and any corrective action taken. Minn. R. 7007.0800, subps. 4 & 5

PERFORMANCE TESTING hdr The Permittee shall perform an annual performance test to demonstrate that a negative pressure is achieved in the building under normal operating conditions. Minn. R. 7007.0800, subps. 4 & 5

MONITORING hdr The Permittee shall continuously monitor the flowrate to the baghouse and maintain it at a rate consistent with the flowrate measured during the last annual performance test shown to produce a negative pressure in the building. Minn. R. 7007.0800, subps. 4 & 5

REPORTING hdr Prior to initial start-up of the facility, a report shall be submitted to the agency, based on the final facility design, which will be used to determine the number of doors that can be open during specific operating scenarios and the required air flow to the baghouse. The number of doors that can be open at any one time will be based on the criteria established in this report. This will be considered normal operating conditions. Minn. R. 7007.0800, subps. 4 & 5

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-25

Subject Item: GP 012 Cooling Towers
Associated Items: EU 012 DRI Cooling Tower Line 1 EU 132 EAF Indirect Cooling Tower Line 1 EU 141 Direct Cooling Tower EU 142 Laminar Cooling Tower SV 005 DRI Cooling Tower Line 1 SV 048 EAF Indirect Cooling Tower Line 1 SV 054 Direct Cooling Tower SV 055 Laminar Cooling Tower

What to do Why to do it OPERATIONAL REQUIREMENTS hdr The Permittee shall not use chromium-based water treatment chemicals in any affected industrial process cooling tower. 40 CFR 63.402; Minn. R. 7011.7160 The Permittee shall conduct water sample analyses in accordance with Method 7196, Chromium, Hexavalent (Colorimetric), contained in the Third Edition of Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW-846, (November 1986) and its Revision I, (December 1987),
In lieu of the water sample analysis, the Permittee may maintain records of water treatment chemical purchases, including invoices and other documentation that includes invoices and other documentation that includes date(s) of purchase or shipment, trade name or other information to identify composition of the product, and quantity of the product. 40 CFR 63.404; Minn. R. 7011.7160

Maintain copies of the initial notification and the notification of compliance status as required by 40 CFR Section 63.405 for a period of at least 5 years onsite. 40 CFR 63.406; Minn. R. 7011.7160 Drift Rate: The Permittee shall install and operate cooling towers with a drift rate less than or equal to 0.005 percent. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Opacity: less than or equal to 20 percent opacity using 6-minute Average Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
MONITORING hdr Continuously monitor the liquid flowrate through each cooling tower, and, by the 15th of each month, monitor the water quality of each of the cooling towers for total dissolved solids and the liquid flowrate through the cooling tower. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4
RECORDKEEPING hdr Recordkeeping: The Permittee shall maintain a record of the monthly TDS, and the flowrate through each cooling tower. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4
REPORTING hdr Notification of Compliance status shall meet the following requirements: 1. Be signed by a responsible official who also certifies the accuracy of the report; 2. Certify that source has complied with 40 CFR Section 63.402; and 3. A description of the type of water treatment program used in EU 012, including the chemical name of each corrosion inhibitor ingredient used; the average concentration of those corrosion inhibitor ingredients maintained in the cooling water; and the material safety data sheet for each water treatment chemical or chemical compound used. 4. Include the following statement: I certify that no chromium-based water treatment chemicals have been introduced since (the initial compliance date) into any IPCT located within the facility for any purpose. 40 CFR 63.405; Minn. R. 7011.7160

PERFORMANCE TESTING hdr Initial Performance Test: due 180 days after Initial Startup for opacity from SV 005. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Initial Performance Test: due 180 days after Initial Startup for opacity from SV 048. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Initial Performance Test: due 180 days after Initial Startup for opacity from SV 054. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Initial Performance Test: due 180 days after Initial Startup for opacity from SV 055. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-26

Subject Item: GP 014 Flares
Associated Items: CE 042 Flaring CE 099 Flaring
EU 068 DRI Flare Line 1 EU 129 EAF Vacuum Degasser Line 1 SV 045 EAF Vacuum Degasser Line 1
SV 061 DRI Flare Line 1

What to do Why to do it
BACT LIMITS hdr
A ppendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Carbon Monoxide: comply with the CO limits on a ppm and lb/hr basis using a 1-hour average from SV 045. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R. 7007.3000 & 3010
1 2 1

Opacity: less than or equal to 3 percent opacity using 6-minute Average from SV 045. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 OPERATIONAL REQUIREMENTS hdr Flares must be designed for and operated with no visible emissions except for a period not to exceed a total of 5 minutes during any 2 consecutive hours. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Each flare shall be operated with a flame present at any time that the associated emission unit is in operation. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R. 7007.3000 & 3010 Flares must be used only if the combustion gas has a heating value of 300 Btu/scf or greater. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Steam assisted flares designed and operated with an exit velocity less than Vmax (as determined by 40 CFR 60.18(f)(5)) and less than 400 ft/sec are allowed. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Flares used to comply with this section shall be steam assisted, air assisted, or nonassisted. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Flares shall be monitored to ensure that they are operated and maintained in conformance with their design. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Flares shall be operated at all times when emissions may be vented to them. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Flame presence shall be monitored using a thermocouple or any other equivalent device. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; 40 CFR 60.18(f)(2); Minn. R. 7011.0050
RECORDKEEPING hdr Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Maintain a file of all measurements, maintenance, reports and records for at least five years. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
VISIBLE EMISSION CHECKS hdr Reference Method 22 shall be used to determined the compliance of flares with the visible emissions provisions. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Visible emissions check: the Permittee shall check visible emissions daily when the flare is operating. A checklist meeting the requirements in Appendix D shall be used to indicate whether the control equipment requires attention. In the event the Permittee makes a finding that attention is required, the Permittee shall investigate the control equipment performance and implement corrective action if necessary. Minn. R. 7007.0800, subp. 4

Visible emissions checklist: The Permittee shall use a checklist that contains at a minimum the information contained in Appendix D. Minn. R. 7007.0800, subp. 5

MACT REQUIREMENTS hdr The approval of the case-by-case MACT determinations for the members of this group under 40 CFR 63 Subp. B shall expire if construction of any of the members of this group has not commenced within the continuous construction of the facility. Title I Condition: 40 CFR 63.43(g)(4): MACT and Minn. R. 7007.3010

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-27

Subject Item: GP 015 Tunnel Furnace
Associated Items: EU 138 Tunnel Furnace
SV 051 Tunnel Furnace

What to do Why to do it Low NOx Burners: The Permittee shall install and operate Low NOx burners or similar equipment designed to meet the NOx emission limits for EU 138/SV 051. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Fuel Usage: Natural Gas Only Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
BACT LIMITS hdr
A ppendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Total PM: comply with the Total PM limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R. 7007.3000 & 3010 PM < 10 micron: comply with the PM10 limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 PM < 2.5 micron: comply with the PM2.5 limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Sulfur Dioxide: comply with the SO2 limits on a ppm and lb/hr basis using a 1-hour average. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Nitrogen Oxides: comply with the NOx limits on a lb/ton steel produced and lb/hr basis using a 1-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Carbon Monoxide: comply with the CO limits on a lb/mmBtu heat input and lb/hr basis using a 1-hour average. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R. 7007.3000 & 3010 Volatile Organic Compounds: comply with the VOC limits on a lb/mmBtu heat input and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R. 7007.3000 & 3010 Opacity: less than or equal to 3 percent opacity using 6-minute Average Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
OTHER EMISSION LIMITS hdr Emission limits listed in this section apply individually to each stack, however compliance with the above limits will demonstrate compliance with these limits. Minn. R. 7007.0800, subp. 2

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011. 0735. Minn. R. 7011.0610, subp. 1(A)(1)

Opacity: less than or equal to 20 percent opacity Minn. R. 7011.0610, subp. 1(A)(2)
PERFORMANCE TESTING hdr Initial Performance Test: due 180 days after Initial Startup for total PM, PM10, PM 2.5, and opacity from SV 051. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 180 days after Initial Startup for NOx from SV 051. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 180 days after Initial Startup for SO2 from SV 051. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 180 days after Initial Startup for CO from SV 051. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 180 days after Initial Startup for VOC from SV 051. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7017.2020, subp. 1 MACT REQUIREMENTS hdr The approval of the case-by-case MACT determinations for the members of this group under 40 CFR 63 Subp. B shall expire if construction of any of the members of this group has not commenced within the continuous construction of the facility. Title I Condition: 40 CFR 63.43(g)(4): MACT and Minn. R. 7007.3010

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-28

Subject Item: GP 016 Material Loading Bin Sources
Associated Items: SV 014 Limestone Handling System SV 015 Binder Handling System SV 039 Hydrated Lime Handling System SV 040 Calcined Limestone Handling System SV 041 Carbon Handling System SV 042 Fluorspar Handling System SV 043 Bauxite Handling System SV 059 Pellet Plant - Powder Coating Handling SV 072 DRI Powder Coating Handling SV 091 Carbon Bin for Mercury Control
SV 092 Lime Bin for Scrubber

What to do Why to do it
BACT LIMITS hdr
A ppendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Total PM: comply with the Total PM limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R. 7007.3000 & 3010 PM < 10 micron: comply with the PM10 limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 PM < 2.5 micron: comply with the PM2.5 limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Lead: comply with the lead limits on a lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Fluorides: comply with the fluoride limits on a lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Opacity: less than or equal to 5 percent opacity using 6-minute Average Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
OTHER EMISSION LIMITS hdr Emission limits listed in this section apply individually to each stack, however compliance with the above limits will demonstrate compliance with these limits. Minn. R. 7007.0800, subp. 2

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0715, subps. 1(A) & 3

Opacity: less than or equal to 20 percent opacity using 6-minute Average Minn. R. 7011.0715, subp. 1(B)
MATERIAL HANDLING LIMITS (SV 014, 015, 042, 059, and 072) hdr

A dditive Material Lead Concentration: less than or equal to 2.3 mg/kg using 12-month rolling average lead concentration of the additive material handled by SV 014, 015, 059, and 072. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

RECORDKEEPING hdr Feed Material Lead Concentration Recordkeeping: The Permittee shall by the 15th of each month record the feed material lead concentration for each unit with a lead concentration limit. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 5
VISIBLE EMISSION CHECKS hdr Visible Emissions: The Permittee shall check the fabric filter stacks for any visible emissions, using the Visible Emissions Check List included in Appendix D of this permit, once each day of operation during daylight hours. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7007.0800, subp. 4 Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection and whether or not any visible emissions were observed. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 5 Corrective Action: If visible emissions are observed, the Permittee shall follow the Operation and Maintenance Plan for the fabric filter and take corrective actions as soon as possible to eliminate the visible emissions. The Permittee shall keep a record of the type and date of all corrective actions taken. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subps. 4 & 5

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-29

MACT REQUIREMENTS hdr The approval of the case-by-case MACT determinations for the members of this group under 40 CFR 63 Subp. B shall expire if construction of any of the members of this group has not commenced within the continuous construction of the facility. Title I Condition: 40 CFR 63.43(g)(4): MACT and Minn. R. 7007.3010

PERFORMANCE TESTING hdr The performance testing requirements under this part apply to each stack listed in this group. The compliance status of each group member with its individual limit for a pollutant will be determined by performance testing conducted on one member of the group for that pollutant. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Initial Performance Test: due 180 days after Initial Startup to measure Total PM, PM-10, PM2.5, and opacity from any one member of this group. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each year following Initial Performance Test to measure PM, PM10, PM2.5, and opacity on at least one member of this group.
To the extent practicable, the annual performance tests shall cycle through all members of this group. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7017.2020, subp. 1

Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-30

Subject Item: GP 017 DRI Pellet Handling
Associated Items: EU 064 DRI Depressurizing Scrubber Line 1 EU 070 DRI P.T.S. Depressurizing Scrubber Line 1 EU 088 DRI Screening and Handling Line 1 SV 029 DRI Depressurizing Scrubber Line 1 SV 063 DRI P.T.S. Depressurizing Scrubber Line 1 SV 070 DRI Screening & Handling Line 1

What to do Why to do it
BACT LIMITS hdr
A ppendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Total PM: comply with the Total PM limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R. 7007.3000 & 3010 PM < 10 micron: comply with the PM10 limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 PM < 2.5 micron: comply with the PM2.5 limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Lead: comply with the lead limits on a lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Fluorides: comply with the fluoride limits on a lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 DRI Pellet Lead Concentration: less than or equal to 20. mg/kg using 12-month rolling average lead concentration of DRI pellets handled by the sources in this group. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

DRI Pellet Fluoride Concentration: less than or equal to 50. mg/kg using 12-month rolling average fluoride concentration of DRI pellets handled by the sources listed in this group. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Opacity: less than 5 percent opacity using 6-minute Average Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
OTHER EMISSION LIMITS hdr Emission limits listed in this section apply individually to each stack, however compliance with the above limits will demonstrate compliance with these limits. Minn. R. 7007.0800, subp. 2

Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Minn. R. 7011.0715, subps. 1(A) & 3

Opacity: less than or equal to 20 percent opacity using 6-minute Average Minn. R. 7011.0715, subp. 1(B)
RECORDKEEPING hdr DRI Pellet Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the DRI pellet lead and/or fluoride concentration. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 5
PERFORMANCE TESTING hdr Initial Performance Test: due 180 days after Initial Startup to measure Total PM, PM10, PM2.5, and Opacity from SV 029. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 180 days after Initial Startup to measure Total PM, PM10, PM2.5, and Opacity from SV 063. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 180 days after Initial Startup to measure Total PM, PM10, PM2.5, and Opacity from SV 070. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each calendar 36 months following Initial Performance Test to measure Total PM emissions from SV 070. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7017.2020, subp. 1 Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-31

MACT REQUIREMENTS hdr The approval of the case-by-case MACT determinations for the members of this group under 40 CFR 63 Subp. B shall expire if construction of any of the members of this group has not commenced within the continuous construction of the facility. Title I Condition: 40 CFR 63.43(g)(4): MACT and Minn. R. 7007.3010

VISIBLE EMISSION CHECKS hdr Visible Emissions: The Permittee shall check the fabric filter stacks for any visible emissions once each day of operation during daylight hours, or the pressure drop across the fabric filter once each day of operation if inclement weather prohibits a visible emissions check. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7007.0800, subp. 4

Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 5

Corrective Action: If visible emissions are observed, and/or if the pressure drop is outside the permitted range specified in this subject item, the Permittee shall follow the Operation and Maintenance Plan for the fabric filter and take corrective actions as soon as possible to eliminate the visible emissions and/or return the pressure drop to within the permitted range. The Permittee shall keep a record of the type and date of all corrective actions taken. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-32

Subject Item: GP 018 Indurating Furnace
Associated Items: CE 016 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 018 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones CE 019 Fabric Filter - Low Temperature, i.e., T<180 Degrees F
CE 020 Low NOx Burners CE 117 Gas Scrubber (General, Not Classified) CE 118 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones EU 038 Indurating Furnace, Hood Exhaust EU 039 Indurating Furnace, Furnace Waste Gas
SV 018 Furnace Hood Exhaust
SV 019 Furnace Waste Gas

What to do Why to do it Fuel Usage : Natural Gas Only Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
SV 018 vents CE 016 and 118 SV 019 vents CE 018, 019, and 117

CE 020 are the Low NOx burners that fire the furnace. hdr

BACT LIMITS hdr
A ppendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Carbon Dioxide equivalent (CO2e): comply with the CO2e limit on a ton/yr basis using a 12-month rolling sum from the pellet furnace (SV 018 and 019 combined). Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Total PM: comply with the Total PM limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 PM < 10 micron: comply with the PM10 limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 PM < 2.5 micron: comply with the PM2.5 limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Sulfur Dioxide: comply with the SO2 limits on a ppm measured at 15% oxygen and lb/hr basis using a 1-hour rolling average. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Sulfuric Acid Mist: comply with the SAM limits on a ppm measured at 15% oxygen and lb/hr basis using a 3-hour rolling average. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Nitrogen Oxides: comply with the NOx limits on a lb/mmBtu heat input and lb/hr using a 1-hour rolling average basis from the pellet furnace (SV 018 and 019 combined). Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000

Carbon Monoxide: comply with the CO limits on a ppm measured at 15% oxygen and lb/hr basis using a 1-hour rolling average. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R. 7007.3000 & 3010 Volatile Organic Compounds: comply with the VOC limits on a ppm measured at 15% oxygen and lb/hr basis using a 3-hour rolling average. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Lead: comply with the lead limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Fluorides: comply with the fluoride limits on a gr/dscf and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Opacity: less than or equal to 5 percent opacity using 6-minute Average Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
OTHER EMISSION LIMITS hdr Emission limits listed in this section apply individually to each stack, however compliance with the above limits will demonstrate compliance with these limits. Minn. R. 7007.0800, subp. 2

Total PM: less than or equal to 0.006 gr/dscf using 3-hour average and on the basis of a flow-weighted mean concentration of both stacks. Demonstrate compliance during the Total PM performance test, as described by 40 CFR 63.9621(c). 40 CFR 63.9590(a); 40 CFR 63.9623(a)(2); 40 CFR 63.9621(c); Minn. R. 7011.8030 Total PM: less than 0.02 gr/dscf using 3-hour average. 40 CFR 60.382(a)(1); Minn. R. 7011.2700

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-33

OPERATIONAL REQUIREMENTS hdr Good combustion practices (GCP) for indurating furnaces: Identify and implement a set of site-specific GCP for the indurating furnace. These GCP shall correspond to standard operating procedures for maintaining the proper and efficient combustion within the indurating furnace. GCP include, but are not limited to the following: 1. Proper operating conditions for each indurating furnace (e.g., minimum combustion temperature, maximum carbon monoxide concentration in the furnace exhaust gases, burner alignment, or proper fuel-air distribution/mixing). 2. Routine inspection and preventative maintenance and corresponding schedules. 3. Performance analyses. 4. Keeping applicable operator logs. 5. Keeping applicable records to document compliance with each element. 40 CFR 63.9600(b)(4); 40 CFR 63.9636(a)(4)

The Permittee shall: - Perform preventative maintenance for each control device in accordance with 40 CFR 63.9600(b)(1) and record all information needed to document conformance with these requirements. - Implement and maintain site-specific GCP for the indurating furnace in accordance with 40 CFR 63.9600(b)(4) and record all information needed to document conformance with these requirements. 40 CFR 63.9636(a)(1) & (4); 40 CFR 64.7(b) & (d): CAM and Minn. R. 7017.0200

Install and begin operation of an Activated Carbon Injection (ACI) system for reduction of mercury emissions within 365 days after initial startup of pellet plant. Minn. R. 7007.0800, subps. 2, 14 & 16(J)

Once installed, operate and maintain the ACI system in accordance to a written O&M Plan any time the associated process equipment is in operation. Document periods of non-operation of the reduction equipment. Keep copies of the O&M Plan available onsite and available for inspection upon request. Minn. R. 7007.0800, subps. 2, 4, 14 & 16(J)

Install, operate, and maintain each CPMS and monitor the daily average of the operating parameter(s) identified in the MRTDR (Mercury Reduction Technology Demonstration Report) at all times that the associated Hg reduction technology is in operation. Keep records of the daily average operating parameter(s). Minn. R. 7007.0800, subps. 4, 5, 14 & 16(J)

Each CPMS must complete a minimum of one cycle of operation for each successive 15-minute period and determines and records valid data for at least 95% of every daily averaging period. Each CPMS must also determine and record the daily average of all recorded readings. Minn. R. 7007.0800, subps. 4, 5, 14 & 16(J)

Operate and maintain each CPMS and conduct a performance evaluation of each CPMS in accordance with the site-specific monitoring plan. Minn. R. 7007.0800, subps. 4, 5, 14 & 16(J)

Establish and maintain the daily average site-specific operating parameters upon MPCA approval of the MRTDR. Measure and record the parameters specified in the MRTDR during each of the runs of the Hg performance test. The operating limit s are established as the lowest average of the specified parameters corresponding to any of the test runs that demonstrate compliance with the Hg emission limit. Minn. R. 7007.0800, subps. 2, 4, 5, 14 & 16(J)

Maintain a record of the established operating parameter(s) measured during the performance test. Minn. R. 7007.0800, subps. 4 & 5

The Permittee may change the site specific operating limits if the Permittee: 1. Submits a written notification to the MPCA requesting to conduct a new performance test to revise the operating limit; 2. Conduct a performance test to demonstrate compliance with the applicable emission limitation; and 3. Establishes revised operating limits according to the method in 2. Minn. R. 7007.0800, subps. 2, 4, 5, 14 & 16(J)

Initiate and complete corrective action as soon as practicable for a CPMS as specified in the site-specific monitoring plan when an established operating limit for the mercury reduction technology is exceeded. Keep records of all information needed to document conformance with these requirements. Minn. R. 7007.0800, subps. 5, 14 & 16(J)

Develop and make available for inspection, a site-specific monitoring plan that addresses the following: 1. Installation of the CPMS sampling probe or other interface at a measurement location representative of reduction of the exhaust emissions. The CPMS shall be installed and operational prior to startup of the ACI system. 2. Performance and equipment specifications for the sample interface, the parametric signal analyzer, and the data collection and reduction system. 3. Performance evaluation procedures and acceptance criteria. 4. Ongoing operation and maintenance procedures. 5. Ongoing data quality assurance procedures. 6. Ongoing recordkeeping and reporting procedures. 7. Corrective action procedures to be followed in the event an air pollution reduction device exceeds an operating limit. Minn. R. 7007.0800, subps. 4, 5, 6, 14 & 16(J)

In the event that an exceedance of an established operating limit for an air pollution control device occurs, except for a baghouse, initiate corrective action to determine the cause of the exceedance and complete the corrective action within 10 days. 40 CFR 63.9600(b)(3)

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-34

PERFORMANCE TESTING hdr Performance test methods and other procedures: Conduct each performance test for PM according to the requirements of 40 CFR 63.7(e)(1) and 63.9621(c). 40 CFR 63.9621(a)

The Permittee shall speciate the mercury emitted for performance tests for mercury. Minn. R. 7007.0800, subp. 2 Initial Performance Test: due 180 days after Initial Startup to measure Total PM emissions from SV 018 and SV 019 individually. Calculate the flow-weighted mean concentration of PM for both stacks using the methods of 40 CFR 63.9621(c). Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; 40 CFR 63.9620(b) & 63.9621(c); Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 180 days after Initial Startup to measure PM10, PM2.5, Lead, and Fluoride emissions from SV 018 and 019 individually. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 180 days after Initial Startup to measure VOCs and Sulfuric Acid Mist emissions from SV 018 and 019 individually. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 180 days after Initial Startup to measure opacity from SV 018 and 019 individually. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7017.2020, subp. 1 Initial Performance Test: due 180 days after Initial Startup to measure mercury emissions from SV 018 and 019 individually. Minn. R. 7017.2020, subp. 1

Initial Performance Test: due 180 days after Initial Startup to measure PCDD/PCDF emissions from SV 018 and 019 individually. Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each calendar 24 months following Initial Performance Test to measure Total PM emissions from SV 018 & 019 individually. Calculate the flow-weighted mean concentration of PM for both stacks using the methods of 40 CFR 63.9621(c). 40 CFR 63.9630(b) & 63.9621(c); 40 CFR 64.7(a): CAM and Minn. R. 7017.0200; Minn. R. 7017.2020, subp. 1

Performance Test: due 120 days after Initial Performance Test to measure mercury emissions from SV 018 and 019. Shall be performed no sooner than 30 days from any other mercury test. Minn. R. 7017.2020, subp. 1

Performance Test: due 240 days after Initial Performance Test to measure mercury emissions from SV 018 and 019. Shall be performed no sooner than 30 days from any other mercury test. Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each year following Initial Performance Test to measure mercury emissions from SV 018 and 019. Shall be performed no sooner than 30 days from any other mercury test. Minn. R. 7017.2020, subp. 1

Performance Test: due before end of each year following Initial Performance Test to measure PCDD/PCDF emissions from SV 018 and 019 individually. Minn. R. 7017.2020, subp. 1

Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000

MONITORING hdr Install, operate, and maintain bag leak detection systems according to the requirements in GP 007 (CE 016 and 019). 40 CFR 63.9631(a); 40 CFR 64.7(a) & (c): CAM and Minn. R. 7017.0200 Install and operate a natural gas flow meter to measure the volume of natural gas used in the pellet furnace. Monitor and record the monthly natural gas use in the furnace. Obtain information on a semiannual basis from the natural gas vendor for the molecular weight, molar conversion factor, and carbon content of the gas to be used in the calculation of CO2 emissions. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Install and operate a flue gas flow monitor to measure offgas flow rate from SV 018 and 019, to be used to convert concentration measurements to mass. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4; Minn. R. 7017.1006 Install, operate, and maintain CEMS, as specified in GP 022, to measure SO2, NOx, CO, and oxygen emissions from SV 018 and 019. Oxygen CEMS data is required for correction of concentrations of emissions of SO2, NOx, and CO. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; 40 CFR 64.7(a): CAM and Minn. R. 7017.0200; Minn. R. 7017.1006; Minn. R. 7007.0800, subp. 4 The Permittee shall continuously monitor sulfuric acid mist emissions (SAM) using SO2 CEMS and estimating an emission rate using the following equations: SAM (ppm) = K x F1 x F2 x SO2 (ppm) SAM (lb/hr) = See Appendix F Where: K = 1.53 - Molecular weight and units conversion from SO2 to H2SO4; F1 = 0.0038 - Fuel Factor; F2 = Technology Factor = 0.1 for SV 018; 1.0 for SV 019 Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-35

RECORDKEEPING hdr Monitoring and recordkeeping: By the 28th of each month, calculate and record CO2-e emissions from the pellet furnace for the previous calendar month and the 12-month rolling sum fuel CO2-e emissions for the previous 12-month period. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Global Warming Potentials (GWPs) are listed in Table A-1 to Subpart A of Part 98. 40 CFR pt. 98, subp. A, Table A-1 Calculate monthly fuel CO2-e emissions using the following: CO2-e = SUM(GWPi * Mi) for i = CO2, CH4, N2O Where: CO2-e = mass of carbon dioxide equivalent (ton); GWPi = GWP for component i; Mi = mass emissions of component i (ton), as calculated below Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Mi = Vng * HHVng * EFi / 907.18474 for i = CH4, N2O; and Mi = 44/12 * [Vng * Cng * MW / MCF + SUM(Mj * Cj) - Mk * Ck] for i = CO2 Where: Mi/j/k = Mass of component i/j/k (ton); Cj/k = Carbon content of component j/k (mass fraction); Vng = Volume of natural gas used in the previous month (mmscf); HHVng = Higher heating value of natural gas (btu/scf); EFi = Emission factor of component i (kg/mmBtu) from 40 CFR pt. 98, subp. C, Table C2; k = fired pellets produced; j = concentrate processed, powder coating used, limestone used, soda ash used, dolomite used; MW/MCF = Molecular Weight/Molar Conversion Factor for natural gas; 44/12 = molecular weight conversion from carbon to CO2; 907.18474 = conversion from kg to ton (continued) Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Maintain records of the annual pellet production rate (ton/year) and the annual and monthly mercury emissions. Minn. R. 7007.0800, subps. 4 & 5

Recordkeeping: Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction or period of non-operation of the air pollution reduction equipment; or any periods during which a CPMS or monitoring device is inoperative. Minn. R. 7007.0800, subp. 5

Feed Material Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the feed material lead and/or fluoride concentration. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 5
REPORTING hdr Include the monthly mercury emission calculations in the emission inventory report. Minn. R. 7007.0800, subp. 6
A ll deviations, including deviations from the rolling 12 month mercury emission limit shall be reported in the semiannual deviations report. Minn. R. 7007.0800, subp. 6

GSA design specifications report (see Table B). The specifications shall identify the parameters and conditions used for system design such as: - Design conditions and parameters of the scrubber, including scrubber chemistry, range of chemical and physical characteristics allowed in the reagent selected; - Operating conditions (e.g. furnace production level, flue gas flow rate, inlet SO2 levels, temperature); and - Selection of reagent (lime, limestone), reagent purity, calcium content, physical characteristics (e.g. pebble size, available surface area) Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Scrubber Evaluation Study (see Table B): The study shall include: - The impact of ore sulfur content and fuel sulfur content on the level of SO2 emissions control; - SO2 scrubber response time to changes in SO2 loading and the impact the scrubber response time has on meeting a 3-hour average SO2 limit; - The impact of lime addition rates on SO2 control and the feasibility of meeting the proposed SO2 limits; - The impact scrubber operating parameters (e.g. water and steam injection rates) have on SO2 control and the feasibility of meeting the proposed SO2 limits; and - The plan shall specify the records that will be maintained so that the MPCA can determine whether the measures are being followed and whether the plant's operating parameters are consistent with the control system design. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Plan Approvals and Amendments. a. If the MPCA does not provide written approval or written comments to the facility on the proposed scrubber evaluation plan within 30 days of receipt of the plan, the facility may implement the plan as proposed. b. The facility may amend the scrubber evaluation plan 30 days after submitting a notification of the proposed changes to the MPCA. The notification will include a list of the proposed changes, the rationale for the proposed changes, and any change to monitoring or recordkeeping that will occur. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-36

Subject Item: GP 019 Boilers/Heaters Subject to Case-by-Case MACT
Associated Items: EU 065 DRI Package Boiler Line 1
EU 066 DRI Process Gas Heater Line 1
EU 069 DRI P.T.S. Heater Line 1 EU 137 Vacuum Degasser Boiler SV 028 DRI Package Boiler Line 1
SV 030 DRI Process Gas Heater Line 1 SV 050 Vacuum Degasser Boiler
SV 062 DRI P.T.S. Heater Line 1

What to do Why to do it Each emission unit in this group must individually comply with the requirements of this group upon startup of the unit. Title I Condition: 40 CFR 63.43(g) & 40 CFR 63.6(b): MACT and Minn. R. 7007.3010 Ultra Low NOx Burners: The Permittee shall install and operate Ultra Low NOx burners or similar equipment designed to meet the NOx emission limits below. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
OPERATING LIMITS hdr Fuel Usage: Natural Gas only Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
A t all times operate and maintain each emission unit and its associated air pollution control equipment in a manner consistent with good air pollution control practices for minimizing emissions at least to the levels required by all relevant standards, as described at 40 CFR Section 63.6(e)(1)(i). Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010; 40 CFR 63.6(e)(1)(i) and Minn. R. 7011.7000; Minn. R. 7007.0800, subp. 16(J)
BACT LIMITS hdr
A ppendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Total PM: comply with the Total PM limits on a lb/mmBtu and lb/hr basis using a 3-hour average from SV 030. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 PM < 10 micron: comply with the PM10 limits on a lb/mmBtu and lb/hr basis using a 3-hour average from SV 030. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 PM < 2.5 micron: comply with the PM2.5 limits on a lb/mmBtu and lb/hr basis using a 3-hour average from SV 030. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Lead: comply with the lead limits on a lb/hr basis using a 3-hour average from SV 030. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000 Fluorides: comply with the fluoride limits on a lb/hr basis using a 3-hour average from SV 030. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Sulfur Dioxide: comply with the SO2 limits on a lb/ton of DRI produced and lb/hr basis using a 1-hour average from SV 030. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Nitrogen Oxides: comply with the NOx limits on a lb/mmBtu heat input and lb/hr using 3-hour rolling average basis, except that SV 030 shall comply using 24-hour rolling average basis. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000

Nitrogen Oxides: comply with the NOx SSM limits using 1-hour rolling average. This limit applies during periods of startup and shutdown for no longer than 24 hours per startup or shutdown. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000

Carbon Monoxide: comply with the CO limits on a lb/mmBtu heat input and lb/hr basis using a 1-hour Rolling Average. The lb/mmBtu limit applies at all times except periods of SSM and when EU 066 operates at < 50% of rated capacity.
Deviations that occur during a period of SSM are not violations if the Permittee demonstrates to the EPA Administrator's satisfaction that the EU was operated in accordance with the SSMP. The Administrator will determine whether deviations that occur during a period of SSM are violations, according to Section 63.6(e). Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 63.6(f)(1)

Opacity: less than or equal to 3 percent opacity Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Oxide Pellet Lead Concentration: less than or equal to 2.0 mg/kg using 12-month rolling average lead concentration of oxide pellets introduced to the DRI Process Heater(s) (EU 066). Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Oxide Pellet Fluoride Concentration: less than or equal to 1.0 mg/kg using 12-month rolling average fluoride concentration of oxide pellets introduced to the DRI Process Heater(s) (EU 066). Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-37

MACT REQUIREMENTS hdr The approval of the case-by-case MACT determinations for the members of this group under 40 CFR 63 Subp. B shall expire if construction of any of the members of this group has not commenced within the continuous construction of the facility. Title I Condition: 40 CFR 63.43(g)(4): MACT and Minn. R. 7007.3010

NSPS LIMITS (SV 028, 050, and 062 only) hdr

Total Particulate Matter: less than 0.030 lbs/million Btu heat input . This limit applies at all times on or after the date of the initial performance test is completed or is required to be completed under 40 CFR 60.8 except during periods of SSM. 40 CFR 60.43c(e)(1) & (d); Minn. R. 7011.0570

STARTUP, SHUTDOWN, AND MALFUNCTIONS hdr The Permittee shall develop, implement, and maintain a written SSMP according to all of the provisions in 40 CFR Section 63.6(e)(3). The plan must be available for inspection and copying by the Administrator upon request. Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010; 40 CFR 63.6(e)(3)(i) & (v)-(viii); Minn. R. 7011.7000 During periods of SSM, operate and maintain the emission unit(s) (including associated control and monitoring equipment) in accordance with the procedures specified in the SSMP developed under 40 CFR Section 63.6(e)(3). 40 CFR 63.6(e)(1) & (3)(ii); Minn. R. 7011.7000

When actions taken during SSM (including actions taken to correct a malfunction) are consistent with the procedures specified in the SSMP, keep records for that event which demonstrate that the procedures specified in the plan were followed. These records may take the form of a checklist, or other effective form of record keeping that confirms conformance with the SSMP for that event. In addition, keep records of these events as specified in 40 CFR 63.10(b). Confirm that actions taken during the relevant reporting period during periods of SSM were consistent with the SSMP in the Semi-Annual SSM report required in 40 CFR 63.10(d)(5). 40 CFR 63.6(e)(3)(iii); Minn. R. 7011.7000

If an action taken during SSM (including an action taken to correct a malfunction) is not consistent with the procedures specified in the SSMP, and the EU exceeds any applicable emission limitation in the relevant emission standard, then record the actions taken for that event and report such actions within 2 working days after commencing actions inconsistent with the plan, followed by a letter within 7 working days after the end of the event, in accordance with 40 CFR 63.10(d)(5). 40 CFR 63.6(e)(3)(iv); Minn. R. 7011.7000

Perform an annual tune-up procedure on each unit, include the following: 1. Inspect the burner, and clean or replace any components of the burner as necessary (burner inspection may be delayed until the next scheduled unit shutdown, but inspect each burner at least once every 36 months); 2. Inspect the flame pattern, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available; 3. Inspect the system controlling the air-to-fuel ratio, and ensure that it is correctly calibrated and functioning properly; 4. Optimize total emissions of carbon monoxide. This optimization should be consistent with the manufacturer's specifications, if available; 40 CFR 63.7540(a)(10); Minn. R. 7011.7000

5. Measure the concentrations in the effluent stream of carbon monoxide in ppmv, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made); and 6. Maintain on-site and submit, if requested by the Administrator, an annual report containing the following information: i. The concentrations of CO in the effluent stream in ppmv, and oxygen in volume percent, measured before and after the adjustments of the boiler; ii. A description of any corrective actions taken as a part of the combustion adjustment; and iii. The type and amount of fuel used over the 12 months prior to the annual adjustment, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel use by each unit. 40 CFR 63.7540(a)(10); Minn. R. 7011.7000

RECORDKEEPING hdr Recordkeeping: By the last day of each calendar month, record the amount of gas combusted in each boiler/heater during the previous calendar month. These records shall consist of purchase records, receipts, or fuel meter readings. 40 CFR 60.48c(g); Minn. R. 7011.0570

Gaseous Fuel Supplier Certification (EU 065, 069, and 137 only): The Permittee shall maintain fuel supplier certifications of the sulfur content of the fuels burned in each unit listed to show the potential sulfur dioxide emission rate is less than or equal to 0.32 lb/MMBtu heat input. This certification is considered to be the sulfur dioxide performance test required under 40 CFR Section 60.43c(e)(1). 40 CFR 60.45c(c); 40 CFR 60.47c(c); 40 CFR 60.48c(g); Minn. R. 7011.0570

Feed Material Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the feed material lead and/or fluoride concentration. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 5

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-38

The Permittee shall maintain relevant records of: 1. The occurrence and duration of each startup, shutdown, or malfunction of operation (i.e., process equipment); 2. The occurrence and duration of each malfunction of the required air pollution control and monitoring equipment; 3. All required maintenance performed on the air pollution control and monitoring equipment; 4. Actions taken during periods of SSM (including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation) when such actions are different from the procedures specified in the SSMP; 40 CFR 63.10(b)(2); Minn. R. 7019.0100, subp. 2

5. All information necessary to demonstrate conformance with the SSMP when all actions taken during periods of SSM (including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation) are consistent with the procedures specifie d in such plan. (The information needed to demonstrate conformance with the SSMP may be recorded using a checklist, or some other effective form of recordkeeping, to minimize the recordkeeping burden for conforming events); 6. All required measurements needed to demonstrate compliance with a relevant standard (including, but not limited to and raw performance testing measurements that support data that the source is required to report); (continued) 40 CFR 63.10(b)(2); Minn. R. 7019.0100, subp. 2

7. All results of performance tests; 8. All measurements as may be necessary to determine the conditions of performance tests; and 9. All documentation supporting initial notifications and notifications of compliance status under 40 CFR Section 63.9. (continued) 40 CFR 63.10(b)(2); Minn. R. 7019.0100, subp. 2

The Permittee shall keep the following records: 1. A copy of each notification and report that was submitted to comply with this group, including all documentation supporting any Initial Notification or Notification of Compliance Status or Semi-Annual Compliance Report that was submitted, according to the requirements in 40 CFR Section 63.10(b)(2)(xiv); 2. The records in 40 CFR Section 63.6(e)(3)(iii)-(v) related to SSM; and 3. Records of performance tests, fuel analyses, or other performance evaluations, compliance demonstrations and opacity observations required by 63.10(b)(2)(viii) Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010

Keep records which include monitoring data and calculated averages for applicable operating limits such as opacity and CO, to show continuous compliance with each emission limit, operating limit, and work practice standard that is applicable. Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010

The records must be in a form suitable and readily available for expeditious review. Records must be kept for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record, and must be kept on site for the first 2 of those years. Such files may be maintained on microfilm, on a computer, on computer floppy disks, on magnetic tape disks, or on microfiche. Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010

REPORTING hdr Submittals and notifications under this group shall be sent to both the MPCA and EPA contacts listed on Page B-1 of this permit, unless otherwise noted. Minn. R. 7007.0800, subp. 2

The Permittee shall submit all of the notifications in 40 CFR Sections 63.7(b) & (c), 63.8(e), (f)(4) & (6), and 63.9(b)-(h) that apply by the dates specified. Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010 Report each deviation from an applicable emission limit, operating limit, and work practice standard. Also, report each instance during a SSM when each applicable emission limit, operating limit, and work practice standard was not met. These instances are deviations from the emission limits and work practice standards. Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010

Deviations Report. The Permittee must report all deviations with the Notifications of Deviations Endangering Human Health or the Environment or in the Semi-Annual Deviations Report required elsewhere in this permit, whichever is applicable. Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010

Immediate SSM Report: The Permittee shall submit an immediate SSM Report if any unit had a startup, shutdown, or malfunction during the reporting period that is not consistent with the Permittee's SSMP, and the boiler/process heater exceeded any applicable emission limitation in this group. The report must contain: 1. Actions taken for the event; 2. The name, title, and signature of a responsible official who certifies its accuracy, 3. An explanation of the circumstances of the event; 4. The reasons for not following the SSMP; and 5. Whether any excess emissions and/or parameter monitoring exceedances are believed to have occurred. The Permittee must submit the report: 1. By fax or telephone within 2 working days after starting actions inconsistent with the plan; and 2. By letter within 7 working days after the end of the event unless the Permittee has made alternative arrangements with the Administrator. Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010; 40 CFR 63.6(e)(3)(iv); 40 CFR 63.10(d)(5)(ii); Minn. R. 7011.7000

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-39

Periodic SSM Reports. The Permittee shall submit SSM Reports only if there is an occurrence of any SSM event during the reporting period and shall be delivered or postmarked by the 30th day following the end of each calendar half year. The content of the report shall be as required by 40 CFR 63.10(d)(5)(i). 40 CFR 63.10(d)(5)(i)

PERFORMANCE TESTING hdr Initial Performance Test: due 180 days after Initial Startup for Total PM, NOx, CO, and opacity from SV 028. Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7017.2020, subp. 1; 40 CFR 63.7 Initial Performance Test: due 180 days after Initial Startup for Total PM, NOx, CO, and opacity from SV 050. Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7017.2020, subp. 1; 40 CFR 63.7 Initial Performance Test: due 180 days after Initial Startup for Total PM, NOx, CO, and opacity from SV 062. Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7017.2020, subp. 1; 40 CFR 63.7 Initial Performance Test: due 180 days after Initial Startup for Total PM, PM10, PM2.5, SO2, and opacity from SV 030. Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7017.2020, subp. 1; 40 CFR 63.7 Performance Test: due before end of each calendar year following Permit Issuance to measure CO emissions from SV 028, to be conducted no sooner than 10 months after the previous performance test. Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010; Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each calendar year following Permit Issuance to measure CO emissions from SV 050, to be conducted no sooner than 10 months after the previous performance test. Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010; Minn. R. 7017.2020, subp. 1 Performance Test: due before end of each calendar year following Permit Issuance to measure CO emissions from SV 062, to be conducted no sooner than 10 months after the previous performance test. Title I Condition: 40 CFR 63.43(g): MACT and Minn. R. 7007.3010; Minn. R. 7017.2020, subp. 1 Emission units (EU 065, 069, and 137) are limited to burning gaseous fuels only with potential SO2 emission rates of 230 ng/J (0.54 lb/mmBtu) heat input or less, therefore emissions monitoring is not required to be conducted under 40 CFR Section 60.43c(e)(1) for SO2 as long as fuel supplier certifications of the sulfur content of the fuels burned are maintained 40 CFR 60.45c(c); Minn. R. 7011.0570

Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. Title I Condition: 40 CFR 52.21(j) & (k): BACT and Minn. R. 7007.3000

CEMS REQUIREMENTS - DRI PROCESS GAS HEATER (EU 066/SV 030) hdr

Install, operate, and maintain a CEMS to measure NOx emissions from SV 030. Monitoring requirements are located under the subject item GP 022. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7017.1006; Minn. R. 7007.0800, subp. 4 Install, operate, and maintain a CEMS to measure oxygen for correction of concentrations of emissions of NOx and CO from SV 030. Monitoring requirements are located under the subject item GP 022. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7017.1006; Minn. R. 7007.0800, subp. 4 Install, operate, and maintain a CEMS for carbon monoxide and oxygen according to the following procedures upon startup of EU 066. Additional monitoring requirements are located under the subject item GP 022. The CO and oxygen shall be monitored at the same location at the outlet of the process heater: 1. Each CEMS must be installed, operated, and maintained according to the applicable procedures under Performance Specification (PS) 3 or 4A of 40 CFR part 60, appendix B, and according to the site-specific monitoring plan. 2. Conduct a performance evaluation of each CEMS according to the requirements in 40 CFR 63.8 and according to PS 4A of 40 CFR part 60, appendix B. 3. Each CEMS must complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7017.1006; Minn. R. 7007.0800, subp. 4

4. The CEMS data must be reduced as specified in 40 CFR 63.8(g)(2). 5. Calculate and record a 30-day rolling average emission rate of CO in ppmvd at 3% O2 on a daily basis. 6. For purposes of calculating data averages, data shall not be used that was recorded during periods of monitoring malfunctions, associated repairs, out-of-control periods, required quality assurance or control activities, or when the unit is operating at less than 50% of its rated capacity. Use all the data collected during all other periods in assessing compliance. Any period for which the monitoring system is out of control and data are not available for required calculations constitutes a deviation from the monitoring requirements. (continued) Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R. 7007.3000 & 3010; Minn. R. 7017.1006; Minn. R. 7007.0800, subp. 4

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-40

Site-specific monitoring plan. Develop a site-specific monitoring plan according to the following: 1. Develop and submit to the EPA Administrator for approval a site-specific monitoring plan for each CMS required for units in this section that addresses the following. Submit this site-specific monitoring plan at least 60 days before the initial performance evaluation of your CMS. i. Installation of the CMS sampling probe or other interface at a measurement location relative to each affected process unit such that the measurement is representative of control of the exhaust emissions; ii. Performance and equipment specifications for the sample interface, the pollutant concentration or parametric signal analyzer, and the data collection and reduction systems; and iii. Performance evaluation procedures and acceptance criteria (e.g., calibrations). 40 CFR 63.43(g)(2): MACT and Minn. R. 7007.3010

2. The site-specific monitoring plan shall also address the following: i. Ongoing O&M procedures in accordance with the general requirements of 40 CFR 63.8(c)(1), (c)(3), and (c)(4)(ii); ii. Ongoing data quality assurance procedures in accordance with the general requirements of 40 CFR 63.8(d); and iii. Ongoing recordkeeping and reporting procedures in accordance with the general requirements of 40 CFR 63.10(c), (e)(1), and (e)(2)(i). 3. Conduct a performance evaluation of each CMS in accordance with the site-specific monitoring plan. 4. Operate and maintain the CMS in continuous operation according to the site-specific monitoring plan. (continued) 40 CFR 63.43(g)(2): MACT and Minn. R. 7007.3010

Monitoring and data collection requirements. 1. Monitor CO and oxygen continuously (or collect data at all required intervals) at all times that the affected source is operating in according to the CEMS requirements, except for monitor malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments); 2. Maintain CO emissions below the CO work practice standard at all times except during periods of SSM, and when the unit is operating at less than 50% of rated capacity; and 40 CFR 63.43(g)(2): MACT and Minn. R. 7007.3010

3. Keep records of CO and oxygen levels for each CEMS according to the following : i. Records described in 40 CFR 63.10(b)(2)(vi)-(xi). ii. Previous (i.e., superseded) versions of the performance evaluation plan as required in 40 CFR 63.8(d)(3). iii. Request for alternatives to relative accuracy test for CEMS as required in 40 CFR 63.8(f)(6)(i). iv. Records of the date and time that each deviation started and stopped, and whether the deviation occurred during a period of startup, shutdown, or malfunction or during another period. (continued) 40 CFR 63.43(g)(2): MACT and Minn. R. 7007.3010

The Permittee shall furnish the Administrator a copy of a written report of the results of the CO CEMS performance evaluation, as required under Section 63.8(e)

. 40 CFR 63.43(g)(2): MACT and Minn. R. 7007.3010; 40 CFR 63.10(e)(2) Notify the Administrator in writing of the date of the performance evaluation at least 60 days prior to the date the performance evaluation is scheduled to begin. 40 CFR 63.43(g)(2): MACT and Minn. R. 7007.3010; 40 CFR 63.8(e)(2) Submit a site-specific performance evaluation test plan to the Administrator for approval, due 45 days before conducting the CO CEMS performance evaluation. The plan shall meet the requirements of 40 CFR Section 63.8(e)(3). Minn. R. 7017.1060, subps. 1 & 2; meets requirements of 40 CFR 63.8(e)(3)

In addition to complying with the requirements specified in 40 CFR 63.10(b)(1)&(2), also keep the following records for the CO CEMS required by Section 63.10(c): 1. All required CEMS measurements; 2. The date and time identifying each period during which the CMS was inoperative except for zero (low-level) and high-level checks; 3. The date and time identifying each period during which the CMS was out of control; 4. The specific identification of each period of excess emissions and parameter monitoring exceedances that occurs during SSMs; 5. The specific identification of each period of excess emissions and parameter monitoring exceedances that occurs during periods other than SSMs; 6. The nature and cause of any malfunction (if known); 40 CFR 63.43(g)(2): MACT and Minn. R. 7007.3010; 40 CFR 63.10(c)

7. The corrective action taken or preventative measures adopted; 8. The nature of the repairs or adjustments to the CMS that was inoperative or out of control. 9. The total process operating time during the reporting period; and 10. All procedures that are part of a quality control program developed and implemented for the CMS. Records for items 6-8 may be the same records used to satisfy the SSMP, provided that such plan and records adequately address items 6-8. (continued) 40 CFR 63.43(g)(2): MACT and Minn. R. 7007.3010; 40 CFR 63.10(c)

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-41

Subject Item: GP 020 Wet Scrubbers Subject to Case-by-Case MACT
Associated Items: CE 095 Wet Scrubber - High Efficiency CE 101 Wet Scrubber - High Efficiency CE 105 Wet Scrubber - High Efficiency

What to do Why to do it Stacks associated with each wet scrubber are shown in the following pairs:
CE 095/SV 029 | CE 101/SV 063 | CE 105/SV 070 hdr

Install, calibrate, maintain, and operate monitoring devices to continuously measure pressure drop across each scrubber. The monitoring device shall be certified by the manufacturer to be accurate within ±1 inch water gauge pressure and must be calibrated on an annual basis in accordance with manufacturer's instructions. Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 60.384(a) and Minn. R. 7011.2700; Minn. R. 7007.0800, subp. 4 Install, calibrate, maintain, and operate monitoring devices to continuously measure scrubbing liquid flow rate. The monitoring device shall be certified by the manufacturer to be accurate within ±5 percent of design scrubbing liquid flow rate and must be calibrated on at least an annual basis in accordance with manufacturer's instructions. Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 60.384(b) and Minn. R. 7011.2700; Minn. R. 7007.0800, subp. 4

Continuous Parameter Monitoring System (CPMS) Monitoring Plan:
The Permittee shall develop and make available for inspection a site-specific monitoring plan that addresses the requirements in paragraphs (1)-(7):
1. Installation of the CPMS sampling probe or other interface at a measurement location relative to each affected emission unit such that the measurement is representative of control of the exhaust emissions (e.g., on or downstream of the last control device). 2. Performance and equipment specifications for the sample interface, the parametric signal analyzer, and the data collection and reduction system. 3. Performance evaluation procedures and acceptance criteria (e.g., calibrations). Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 63.9632(b); Minn. R. 7007.0800, subp. 4

4. Ongoing operation and maintenance procedures in accordance with 40 CFR Section 63.8(c)(1), (3), (4)(ii), (7), & (8). 5. Ongoing data quality assurance procedures in accordance with 40 CFR Section 63.8(d). 6. Ongoing recordkeeping and reporting procedures in accordance with 40 CFR Section 63.10(c), (e)(1), & (e)(2)(i). 7. Corrective action procedures that will be followed in the event a wet scrubber exceeds an established operating limit. The corrective actions must be completed within 10 calendar days. (continued) Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 63.9632(b); Minn. R. 7007.0800, subp. 4

Install and operate each CPMS such that the CPMS completes a minimum of one cycle of operation for each successive 15-minute period and determines and records valid data for at least 95 percent of every daily averaging period. Each CPMS must also determine and record the daily average of all recorded readings.
Operate and maintain each CPMS and conduct a performance evaluation of each CPMS in accordance with the site-specific monitoring plan. Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 63.9632(c)-(e); Minn. R. 7007.0800, subp. 4

The Permittee shall establish site-specific operating limits:
1. Measure and record the pressure drop and scrubber water flow rate every 15 minutes during each run of the PM performance test using the CPMS. 2. Calculate and record the average pressure drop and scrubber water flow rate for each individual test run.
The operating limits shall be established as the lowest average pressure drop and the lowest average scrubber water flow rate corresponding to any of the test runs, except that the established operating limits may be changed if the Permittee:
1. Submits a written notification to the Commissioner requesting to conduct a new performance test to revise the operating limit; 2. Conducts a performance test to demonstrate compliance with the applicable emission limitation; and 3. Establishes revised operating limits. Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 63.9622(a)&(f); Minn. R. 7007.0800, subp. 4

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-42

Maintain the daily average pressure drop and daily average scrubber water flow rate at or above the minimum levels established during the initial or subsequent performance test.
If the daily average pressure drop or daily average scrubber water flow rate is below the operating limits established for a corresponding emission unit, then follow the corrective action procedures in paragraphs (1)-(4) below: Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 63.9634(e)&(j); Minn. R. 7007.0800, subp. 4

1. Initiate and complete initial corrective action within 10 calendar days and demonstrate that the initial corrective action was successful. During any period of corrective action, continue to monitor and record all required operating parameters for equipment that remains in operation. After 10 calendar days, measure and record the daily average operating parameter value for the emission unit on which corrective action was taken. After the initial corrective action, if the daily average operating parameter value for the emission unit meets the operating limit established for the corresponding unit, then the corrective action was successful and the emission unit is in compliance with the established operating limits. (continued) Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 63.9634(j); Minn. R. 7007.0800, subp. 4

2. If the initial corrective action required in paragraph (1) was not successful, then complete additional corrective action within 10 calendar days and demonstrate that the subsequent corrective action was successful. During any period of corrective action, continue to monitor and record all required operating parameters for equipment that remains in operation. After the second set of 10 calendar days allowed to implement corrective action, measure and record the daily average operating parameter value for the emission unit. If the daily averag e operating parameter value for the emission unit meets the operating limit established for the corresponding unit, then the corrective action was successful and the emission unit is in compliance with the established operating limits. (continued) Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 63.9634(j); Minn. R. 7007.0800, subp. 4

3. If the second attempt at corrective action required in paragraph (2) was not successful, then repeat the procedures of paragraph (2) until the corrective action is successful. If the third attempt at corrective action is unsuccessful, then conduct another performance test in accordance with the procedures in 40 CFR 63.9622(f) and report to the Administrator as a deviation the third unsuccessful attempt at corrective action. 4. After the third unsuccessful attempt at corrective action, submit to the Administrator the written report required in paragraph (3) within 5 calendar days after the third unsuccessful attempt at corrective action. This report must notify the Administrator that a deviation has occurred and document the types of corrective measures taken to address the problem that resulted in the deviation of established operating parameters and the resulting operating limits. (continued) Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 63.9634(j); Minn. R. 7007.0800, subp. 4

Operate and maintain each wet scrubber CPMS and record all the information needed to document conformance with these requirements. Collect and reduce monitoring data for pressure drop and scrubber water flow rate and record all the information needed to document conformance with these requirements. Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 63.9631(b); Minn. R. 7007.0800, subp. 4 O&M Plan: Prepare, and at all times operate according to a written O&M plan. Maintain a current copy of the O&M plan onsite, and it must be available for inspection upon request. The plan must be kept for the life of the affected source. The plan must address the following elements: 1. The plan shall address preventative maintenance for each scrubber, including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance. Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 63.9600(b); Minn. R. 7007.0800, subp. 4

2. In the event that an exceedance of an established operating limit for a scrubber occurs, then initiate corrective action to determine the cause of the operating limit exceedance and complete the corrective action within 10 calendar days. The corrective action procedures taken must be consistent with the installation, operation, and maintenance procedures listed in the site-specific CPMS monitoring plan. (continued) Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 63.9600(b); Minn. R. 7007.0800, subp. 4

Recordkeeping: During the initial performance test of a wet scrubber, and at least weekly thereafter, the measure and record the pressure drop across the scrubber and the scrubbing liquid flow rate. Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R. 7007.3000 & 3010; 40 CFR 60.385(b) and Minn. R. 7011.2700; Minn. R. 7007.0800, subp. 4

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-43

Subject Item: GP 021 Emergency Generators and Fire Water Pumps
Associated Items: EU 026 Fire Water Supply Pump - Concentrator EU 027 Emergency Power Generator - Concentrator EU 049 Fire Water Booster Pump - Pellet Plant EU 050 Fire Water Supply Pump - Pellet Plant EU 051 Emergency Power Generator - Pellet Plant EU 110 Fire Water Booster Pump - DRI EU 111 Fire Water Supply Pump - DRI EU 112 Emergency Power Generator - DRI EU 113 Fire Water Booster Pump - Offices EU 114 Emergency Power Generator - Offices EU 143 Fire Water Booster Pump - Steel Mill EU 144 Fire Water Supply Pump - Steel Mill EU 145 Emergency Power Generator - Steel Mill

What to do Why to do it
EMISSION LIMITS hdr Opacity: less than or equal to 5 percent opacity using 6-minute Average once operating temperatures have been attained. This also demonstrates compliance with Minn. R. 7011.2300, subp. 1. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7011, 2300, subp. 1 Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input Minn. R. 7011.2300, subp. 2
EMISSION LIMITS - EMERGENCY GENERATORS (EU 027, 051, 112, 114, and 145) (SV 013, 026, 036, 038, and 058) hdr

NMHC + NOx: Less than or equal to 6.4 grams per Kilowatt-hour. 40 CFR 60.4205(b) and Minn. R. 7011.3520 CO: Less than or equal to 3.5 grams per Kilowatt-hour. 40 CFR 60.4205(b) and Minn. R. 7011.3520 PM: Less than or equal to 0.20 grams per Kilowatt-hour. 40 CFR 60.4205(b) and Minn. R. 7011.3520
EMISSION LIMITS - FIRE WATER SUPPLY PUMPS (EU 026, 050, 111, and 144) (SV 012, 025, 035, and 057) hdr

NMHC + NOx: Less than or equal to 4.0 grams per Kilowatt-hour. 40 CFR 60.4205(c) and Minn. R. 7011.3520 CO: Less than or equal to 5.0 grams per kilowatt-hour. 40 CFR 60.4205(c) and Minn. R. 7011.3520 PM: Less than or equal to 0.30 grams per Kilowatt-hour. 40 CFR 60.4205(c) and Minn. R. 7011.3520
EMISSION LIMITS - FIRE WATER BOOSTER PUMPS (EU 049, 110, 113, and 143) (SV 024, 034, 037, and 056) hdr

NMHC + NOx: Less than or equal to 4.7 grams per Kilowatt-hour. 40 CFR 60.4205(c) and Minn. R. 7011.3520 CO: Less than or equal to 5.0 grams per kilowatt-hour. 40 CFR 60.4205(c) and Minn. R. 7011.3520 PM: Less than or equal to 0.40 grams per Kilowatt-hour. 40 CFR 60.4205(c) and Minn. R. 7011.3520
OPERATING REQUIREMENTS hdr Low Sulfur Fuel: The Permittee shall use only fuel with a maximum sulfur content of 0.0015% by weight. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; 40 CFR 80.510(b) Operating Hours: less than 500 hours per year based on a 12-month rolling sum to be calculated by the 15th day of each month. Minn. R. 7007.0800, subp. 2

RECORDKEEPING hdr Hours of Operation: On a daily basis, the Permittee shall record the daily hours of operation of each emission unit of this group.
The Permittee shall retain these records for five years. Minn. R. 7007.0800, subps. 4 & 5

Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel supplier certification for each shipment of No. 2 fuel oil, certifying that the sulfur content does not exceed 0.0015% by weight. Minn. R. 7007.0800, subps. 4 & 5

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-44

PERFORMANCE TESTING hdr Performance Test: Upon the request of the Commissioner, the Permittee shall conduct a performance test for any or all of the following pollutants: PM, PM10, NOx, CO, VOC, and opacity. Minn. R. 7017.2020, subp. 1

NSPS REQUIREMENTS hdr Operate and maintain the stationary engine according to the manufacturer's written instructions or procedures developed by the owner or operator and approved by the engine manufacturer, over the entire life of the engine. 40 CFR 60.4206 and Minn. R. 7011.3520

Use diesel fuel that meets the requirements of 40 CFR Section 80.510(b) for nonroad diesel fuel. 40 CFR 60.4207(b) and Minn. R. 7011.3520

Install a non-resettable hour meter on each engine prior to startup of the engine. 40 CFR 60.4209(a) and Minn. R. 7011.3520 Comply with the emission standards specified in 40 CFR Sections 60.4205(b)&(c) by purchasing an engine certified to the emission standards in 40 CFR Section 60.4205(b) or (c), as applicable, for the same model year and maximum engine power. The engine must be installed and configured according to the manufacturer's specifications. 40 CFR 60.4211(c) and Minn. R. 7011.3520

Establish operating parameters to be monitored continuously to ensure the stationary internal combustion engine continues to meet the emission standards. 40 CFR 60.4211(d) and Minn. R. 7011.3520

The emergency stationary ICE may be operated for the purpose of maintenance checks and readiness testing. Maintenance checks and readiness testing of such units is limited to 100 hours per year for each unit.

A ny operation other than emergency operation, and maintenance and testing, is prohibited. 40 CFR 60.4211(e) and Minn. R. 7011.3520

MACT REQUIREMENTS - EMERGENCY GENERATORS (EU 027, 051, 112, 114, and 145) hdr

The Permittee shall submit to the Commissioner in accordance 40 CFR Section 63.6590(b) an Initial Notification including the information in 40 CFR Section 63.9(b)(2)(i)-(v), and a statement that the RICE has no additional requirements and explain the basis of the exclusion. 40 CFR 63.6645(d) and Minn. R. 7011.8150

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-45

Subject Item: GP 022 Stack/Vents with CEMS
Associated Items: MR 019 O2 CEM
MR 020 CO CEM
MR 021 NOx CEM
MR 022 SO2 CEM
MR 025 O2 CEM
MR 026 CO CEM
MR 027 NOx CEM
MR 028 SO2 CEM
MR 045 O2 CEM
MR 046 CO CEM
MR 047 NOx CEM
MR 056 O2 CEM
MR 057 CO CEM
MR 058 NOx CEM
MR 059 SO2 CEM
SV 018 Furnace Hood Exhaust
SV 019 Furnace Waste Gas
SV 030 DRI Process Gas Heater Line 1 SV 044 EAF Baghouse Line 1

What to do Why to do it CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements apply individually to each monitor listed in this group. hdr

The Permittee shall use a CEMS to measure emissions from each stack listed in this group, as indicated in the next requirement. Minn. R. 7017.1006

The CEMS are labeled as follows: SV 030: MR 045 for O2, MR 046 for CO, MR 047 for NOx SV 018: MR 019 for O2, MR 020 for CO, MR 021 for NOx, MR 022 for SO2 SV 019: MR 025 for O2, MR 026 for CO, MR 027 for NOx, MR 028 for SO2 SV 044: MR 056 for O2, MR 057 for CO, MR 058 for NOx, MR 059 for SO2 CEMS

Initial Notification: due 60 days before installing each CEMS. The Notification shall include plans and drawings of the proposed system which show the configuration of the monitoring system including any monitor bypass routes. 40 CFR 64.9(a); Minn. R. 7017.0200; Minn. R. 7017.1040, subp. 1 CEMS Certification Test (CT) Plan: due 30 days before each CEMS CT CEMS CT Pretest Meeting: due 7 days before each CEMS CT CEMS CT Report: due 45 days after each CEMS CT CEMS CT Report - Microfiche Copy: due 105 days after each CEMS CT
The Notification, Test Plan, and Test Report may be submitted in alternate format as allowed by Minn. R. 7017.1120, subp. 2. Minn. R. 7017.1060, subps. 1-3; Minn. R. 7017.1080, subps. 1-4

Continuous Operation: Each CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. Minn. R. 7017.1090

Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A . 4 data points, equally spaced, if the emission unit operated during the entire hour; B. 2 data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. 1 data point if the emission unit operated for 15 minutes or less during the hour. Minn. R. 7017.1160, subps. 1 & 2

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-46

QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. Minn. R. 7017.1170, subp. 2

CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified and recorded at zero (low-level) and upscale (high-level) gas concentrations at least once daily according to the procedures listed in Minn. R. 7017.1170, subp. 3 and 40 CFR Section 60.13(d)(1) for each pollutant concentration, each diluent monitor, and for each monitor range. The CEMS shall be adjusted whenever the CD exceeds twice the specification of 40 CFR pt. 60, Appendix B. If no span value is specified in the applicable requirement or in a compliance document, the Permittee shall use a span value equivalent to 1.5 times the emission limit. 40 CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for CEMS. Follow the procedures in 40 CFR pt. 60, Appendix F. Minn. R. 7017.1170, subp. 3

CEM Certification Test: due 90 days after Excess Emissions/Downtime Reports (EER's) are first required for the CEMS. The first EER is due 30 days after the end of the calendar quarter following permit issuance. Follow the Performance Specifications listed in 40 CFR pt. 60, Appendix B. Minn. R. 7017.1050, subp. 1

Cylinder Gas Audit: due before end of each calendar half-year following CEM Certification Test, except that a CGA is not required during any calendar half year in which a RATA was performed. The initial CGA must be performed within 80 days following certification of the CEMS. The CGAs shall be conducted at least three months apart but no more than eight months apart. A CGA shall be conducted according to the procedures in 40 CFR pt. 60, Appendix F, section 5.1.2. If the monitored emission unit was operated for less than 24 hours during the calendar half year, a CGA is not required for that calendar half year. Minn. R. 7017.1170, subp. 4

CEMS Relative Accuracy Test Audit (RATA): due before end of each year following CEM Certification Test. A RATA is not required in any calendar year if a RATA conducted in the previous year demonstrated a relative accuracy value of less than 15 percent or if the associated emissions unit operated less than 48 hours during the calendar year. If the exception is used, the next RATA shall be conducted during the first half of the following calendar year. RATAs shall be conducted at least 3 months apart according to 40 CFR pt. 60, Appendix F, section 5.1.1. Minn. R. 7017.1170, subp. 5

Recordkeeping: The Permittee shall retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. Minn. R. 7017.1130

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-47

Subject Item: GP 023 EAF Ladle/Castle Area
Associated Items: EU 126 EAF Ladle Metallurgy Furnace Line 1 EU 127 EAF Casting Area Line 1
EU 128 EAF Ladle/Tundish Pre-Heaters Line 1 SV 044 EAF Baghouse Line 1

What to do Why to do it
OPERATING LIMITS hdr Fuel Usage: Natural Gas Only burned in the EAF Ladle Units. (EU 126 and 128) Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Low NOx burners: The Permittee shall install and operate Low NOx burners in the EAF Ladle/Tundish Pre-Heaters (EU 128). Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
EMISSION LIMITS hdr Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. Because it has been shown that the facility does not cause a violation of ambient air quality standards, and is located outside the Mpls/St Paul air quality control region and city of Duluth, and is located at least 1⁄4 mile from any residence or public roadway, and the associated emission unit are controlled by control equipment which has a collection efficiency of 85% by weight, the associated emission units are considered to be in compliance with this requirement. Minn. R. 7011.0715, subps. 1(A) & 3

Opacity: less than or equal to 20 percent opacity using 6-minute Average . Compliance with the opacity limit of associated stacks is considered to be compliance with this requirement. Minn. R. 7011.0715, subp. 1(B)

MACT REQUIREMENTS See GP 009 for MACT emission limits for these units. hdr

The approval of the case-by-case MACT determinations for the members of this group under 40 CFR 63 Subp. B shall expire if construction of any of the members of this group has not commenced within the continuous construction of the facility. Title I Condition: 40 CFR 63.43(g)(4): MACT and Minn. R. 7007.3010

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-48

Subject Item: GP 024 DRI Top Gas Purification
Associated Items: EU 067 DRI Top Gas Purification Line 1 SV 078 DRI Top Gas Purification Line 1

What to do Why to do it
BACT LIMITS hdr
A ppendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Hydrogen Sulfide: comply with the H2S limits on a ppm and lb/hr basis using a 3-hour average. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
OPERATING LIMITS hdr The Permittee shall inject into the top gas DiMethyl-DiSulfide (DMDS) at a rate less than or equal to 11.1 lb/hr using a 3-hour average. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 4
PERFORMANCE TESTING hdr Initial Performance Test: due 180 days after Initial Startup to measure H2S and TRS emissions. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
MONITORING hdr The Permittee shall directly monitor the DMDS injection rate or a DMDS injection system operating parameter that can be used to calculate injection rate (for example, screw feeder speed). The Permittee shall also establish a relationship between the operating parameter and the DMDS injection rate in order to calculate the injection rate based on the operating parameter level.
The Permittee shall continuously monitor the DMDS injection rate or operating parameter during all periods when the DRI unit is operating, and calculate the 3-hour average DMDS injection rate in pounds per hour.
When calculating the 3-hour average, the Permittee shall exclude hours when the unit is not operating and include hours when unit is operating but the injection system is not working correctly. Minn. R. 7007.0800, subp. 4

RECORDKEEPING hdr The Permittee shall record and maintain records of the average DMDS injection rate for each hour of operation and the 3-hour average injection rate.
If the required 3-hour average DMDS injection operating parameter is not maintained, the Permittee shall record reasons for not maintaining the operating parameter and the corrective actions taken. Minn. R. 7007.0800, subps. 4 & 5

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-49

Subject Item: GP 025 DRI Water Blowdown Units
Associated Items: EU 161 DRI Quench Cooling Water Blowdown Line 1
EU 162 DRI Process Water Blowdown Line 1
SV 075 DRI Process Water Blowdown Line 1 SV 076 DRI Quench Cooling Water Blowdown Line 1

What to do Why to do it
BACT LIMITS hdr
A ppendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Carbon Monoxide: comply with the CO limits on a percent by volume and lb/hr basis using a 1-hour average. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000
PERFORMANCE TESTING hdr Initial Performance Test: due 180 days after Initial Startup to measure CO emissions from SV 075. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Initial Performance Test: due 180 days after Initial Startup to measure CO emissions from SV 076. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-50

Subject Item: GP 026 Ore Barns
Associated Items: CE 108 Enclosure - Coarse Ore Storage CE 109 Enclosure - Fine Ore Storage
EU 168 Coarse Ore Barn
EU 169 Fine Ore Barn
SV 082 Coarse Ore Barn Perimeter
SV 083 Fine Ore Barn Perimeter

What to do Why to do it
MINNESOTA RULES hdr Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735.
Total Particulate Matter PTE is 0.04 lb/hr and 0.14 lb/hr through SV 082 and SV 083 respectively. Minn. R. 7011.0715, subp. 1(A)

Opacity: less than or equal to 20 percent opacity using 6-minute Average Minn. R. 7011.0715, subp. 1(B)
CONTROL EQUIPMENT REQUIREMENTS hdr The Permittee shall maintain the enclosure at a negative gauge pressure. All air vented from the enclosure shall be sent through air pollution control equipment; all doors and windows leading to the outside air shall be kept closed when the facility is in operation. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

The Permittee shall install, operate and record the output of differential pressure gauge. The gauge shall be located at a point in the structure that will experience the least draw from the baghouse fan. Minn. R. 7007.0800, subps. 4 & 5

The Permittee shall collect and record, at a minimum rate of one reading every 15 minutes, the differential pressure between the enclosure and the atmosphere. Minn. R. 7007.0800, subps. 4 & 5

Signage and Inspection of Enclosure Openings: The Permittee shall post signs on all non-alarmed doors and windows leading to the outside from that state that the doors and windows must remain closed while the facility is in operation.
The Permittee shall conduct inspections at least once each calendar week to determine if the doors and windows are closed as required by this permit. The Permittee shall maintain a written record of the inspections and any corrective action taken. Minn. R. 7007.0800, subps. 4 & 5

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-51

Subject Item: EU 165 Space Heaters

What to do Why to do it Fuel Usage : Natural Gas Only Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000 Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input Minn. R. 7011.0515, subp. 1 Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity Minn. R. 7011.0515, subp. 2

### TABLE A: LIMITS AND OTHER REQUIREMENTS
Essar Steel Minnesota LLC

06100067 - 004 Facility Name:
Permit Number: 05/10/12 A-52

Subject Item: FS 042 Slag Dumping
Associated Items: CE 068 Dust Suppression

What to do Why to do it Slag Fluoride Concentration: less than or equal to 10% by weight in the slag. Sample and analyze the fluoride content of the slag in accordance with EPA Method 9056. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000

Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the slag fluoride concentration. Title I Condition: 40 CFR 52.21(j): BACT and Minn. R. 7007.3000; Minn. R. 7007.0800, subp. 5

### TABLE B: SUBMITTALS Facility Name: Essar Steel Minnesota LLC
Permit Number: 06100067 - 004 05/10/12 B-1

Unless another person is identified in the applicable Table, send all other submittals to:
AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Send submittals that are required to be submitted to the U.S. EPA regional office to:
Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by part s 7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition.

Send submittals that are required by the Acid Rain Program to:
U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460 Send any application for a permit or permit amendment to:

AQ Permit Document Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term.

Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separatel y list one-time only and recurrent submittal requirements.

### TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS Facility Name: Essar Steel Minnesota LLC
Permit Number: 06100067 - 004 05/10/12 B-2

What to send When to send Portion of Facility Affected
A pplication for Permit Reissuance due 180 days before expiration of Existing Permit Total Facility

Fugitive Emissions Control Plan due before Initial Startup. The Permittee shall submit a copy of the fugitive dust emissions control plan to the Commissioner.
The Permittee shall incorporate the fugitive dust control plan for sources subject to Case-by-Case MACT into the fugitive dust control plan required under 40 CFR part 63, subp RRRRR. GP006

Notification of compliance status due 60 days after Initial Performance Test EU065, EU066, EU069, EU137 Notification of compliance status due 60 days after Initial Startup of the DRI Facility. GP012

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of ACI system. GP018

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of each unit. Submit the name and number of each unit and the date operation of each unit began. GP002

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of Mining Operations. GP001

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of the DRI Facility. Total Facility

Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of the Pelletizing Facility. Total Facility

Notification of the Date Construction Began due 30 days after Start Of Construction. Submit the name and number of each unit and the date construction of each unit began. GP002

Notification due 60 days before Install of CEMS. The Notification shall include plans and drawings of the proposed system which show the configuration of the monitoring system including any monitor bypass routes. MR019, MR020, MR021, MR022, MR025, MR026, MR027, MR028, MR045, MR046, MR047, MR056, MR057, MR058, MR059

Notification due 7 days after Initial Startup of the ACI System. GP018

Operation and Maintenance Plan due 180 days after Initial Startup. Prepare and submit to the Commissioner an O&M plan for each control device. GP020

Operation and Maintenance Plan due 90 days before Initial Startup of the ACI system. The plan shall specify the operating parameters to be monitored to ensure proper operation of the mercury reduction technology. The plan shall also include, at a minimum technical specifications for any oxidizing and adsorption agents to be used, as allowed by the equipment vendor considering any patented or proprietary information, target injection rates, routine and long-term maintenance and inspection requirements that are consistent with the manufacturers specifications. GP018

Operation and Maintenance Plan due before Initial Startup of Mining Operations. Prepare, submit and maintain a current copy of the O&M plan onsite incorporating operating parameters to be monitored to ensure proper operation of the mobile sources, maintenance and inspection requirements consistent with the manufacturers specifications, and records of urea use. The plan must be available for inspection upon request. GP001

### TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS Facility Name: Essar Steel Minnesota LLC
Permit Number: 06100067 - 004 05/10/12 B-3

Operation and Maintenance Plan due before Initial Startup of Pelletizing Facility. Prepare, submit and maintain a current copy of the O&M plan onsite incorporating operating parameters to be monitored to ensure proper operation of the affected sources. The plan must be available for inspection upon request. GP002

Operation and Maintenance Plan due before Initial Startup. Prepare, submit and maintain a current copy of the O&M plan onsite incorporating preventative maintenance and leak detection requirements. The plan must be available for inspection upon request. GP007

Operation and Maintenance Plan due before Initial Startup. Prepare, submit and maintain a current copy of the O&M plan onsite incorporating the requirements of GCP for the indurating furnace. The plan must be available for inspection upon request. GP018

Performance Test Plan due 90 days before Initial Performance Test. GP008 Relative Accuracy Test Audit (RATA) Notification due 30 days before CEMS Relative Accuracy Test Audit (RATA). MR019, MR020, MR021, MR022, MR025, MR026, MR027, MR028, MR045, MR046, MR047, MR056, MR057, MR058, MR059 Relative Accuracy Test Audit (RATA) Results Summary due 45 days after CEMS Relative Accuracy Test Audit (RATA) MR019, MR020, MR021, MR022, MR025, MR026, MR027, MR028, MR045, MR046, MR047, MR056, MR057, MR058, MR059 Report due 60 days before Initial Startup of the Pelletizer, plans for a Scrubber Evaluation Study which addresses issues related to optimizing SO2 control. (See GP 018). GP018

Report due 90 days before Initial Startup of the pelletizer, design specifications from the pelletizer furnace and GSA vendors, which indicate that the system has been designed to achieve a SO2 emission rate of 5.0 ppm (wet basis) on a 24-hour rolling average. (See GP 018). GP018

Testing Frequency Plan due 60 days after Initial Performance Test for CO. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. SV051, SV075, SV076

Testing Frequency Plan due 60 days after Initial Performance Test for H2S. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. SV078

Testing Frequency Plan due 60 days after Initial Performance Test for NOx. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. SV028, SV050, SV051, SV062

Testing Frequency Plan due 60 days after Initial Performance Test for opacity. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. SV005, SV018, SV019, SV028, SV029, SV030, SV044, SV048, SV050, SV051, SV054, SV055, SV062, SV063, SV070

### TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS Facility Name: Essar Steel Minnesota LLC
Permit Number: 06100067 - 004 05/10/12 B-4

Testing Frequency Plan due 60 days after Initial Performance Test for PM. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. SV028, SV029, SV030, SV044, SV050, SV051, SV062, SV063

Testing Frequency Plan due 60 days after Initial Performance Test for PM10. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. SV018, SV019, SV029, SV030, SV044, SV051, SV063, SV070

Testing Frequency Plan due 60 days after Initial Performance Test for PM2.5. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. SV018, SV019, SV029, SV030, SV044, SV051, SV063, SV070

Testing Frequency Plan due 60 days after Initial Performance Test for SO2. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. SV030, SV051

Testing Frequency Plan due 60 days after Initial Performance Test for sulfuric acid mist. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. SV018, SV019, SV044

Testing Frequency Plan due 60 days after Initial Performance Test for VOCs. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. SV018, SV019, SV044, SV051

Testing Frequency Plan due 60 days after Performance Test (4th) for mercury. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on quarterly, semiannually, yearly, or other intervals, shall be required upon written approval of the MPCA. SV018, SV019

### TABLE B: RECURRENT SUBMITTALS Facility Name: Essar Steel Minnesota LLC
Permit Number: 06100067 - 004 05/10/12 B-5

What to send When to send Portion of Facility Affected Cylinder Gas Audit (CGA) Results Summary due 30 days after end of each calendar quarter following end of the calendar quarter in which the Audit was performed. MR019, MR020, MR021, MR022, MR025, MR026, MR027, MR028, MR045, MR046, MR047, MR056, MR057, MR058, MR059 Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar quarter following Initial Startup of the Monitor. Submit DRF-1, as amended. The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard. The EER must be submitted even if there were no excess emissions, downtime or bypasses during the quarter. MR019, MR020, MR021, MR022, MR025, MR026, MR027, MR028, MR045, MR046, MR047, MR056, MR057, MR058, MR059

Report due 30 days after end of each calendar half-year following Initial Performance Test of the wet scrubber, the Permittee shall submit a report to the Commissioner of occurrences when the measurements of the scrubber pressure loss (or gain) or liquid flow rate differ by more than ±30% from the average from the most recent performance test. CE095, CE101, CE105

Report due 30 days after end of each half-year following Initial Startup. If actions taken by the Permittee during a startup or shutdown (and the startup or shutdown causes the source to exceed any applicable emission limitation in the relevant emission standards), or malfunction (including actions taken to correct a malfunction) are consistent with the procedures specified in the source's SSMP, the Permittee shall state such information in a SSM report. The report shall include: actions taken to minimize emissions, the number, duration, and a brief description for each type of malfunction and which caused or may have caused any applicable emission limitation to be exceeded. The report shall consist of a letter, containing the name, title, and signature of the responsible official. Total Facility

Semiannual Compliance Report due 31 days after end of each calendar half-year following Initial Startup. The first compliance report is due no later than January 31st or July 31st, whichever date is the first date following the end of the first calendar half after Initial Startup of the process heater.
The Semi-Annual Compliance Report must contain the following: 1. Information required in 40 CFR Section 63.7550(c)(1)-(11); 2. If there are no deviations from the requirements for work practice standards that apply, a statement that there were no deviations from the work practice standards during the reporting period; 3. If the Permittee has a deviation from the work practice standard during the reporting period, the report must contain the information in 40 CFR Section 63.7550(d); and 4. If the process heater had a startup, shutdown, or malfunction during the reporting period and the Permittee took actions consistent with the SSMP the compliance report must include the information in 40 CFR Section 63.10(d)(5)(i). GP019

### TABLE B: RECURRENT SUBMITTALS Facility Name: Essar Steel Minnesota LLC
Permit Number: 06100067 - 004 05/10/12 B-6

Semiannual Deviations Report due 30 days after end of each calendar half-year following Initial Startup. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations. Total Facility

A nnual Report due 30 days after end of each calendar year following Initial Startup. The Permittee shall submit a report to the Commissioner due 30 days after end of each calendar year. The report covers January 1 - December 31, which is due by January 30 of each year. The report shall contain for each certified and non-certified mobile source the operating hours and gallons of fuel used. GP001

Compliance Certification due 30 days after end of each calendar year following Initial Startup (for the previous calendar year). To be submitted on a form approved by the Commissioner, both to the Commissioner and to the US EPA regional office in Chicago. This report covers all deviations experienced during the calendar year. Total Facility

Compliance Certification due 30 days after end of each calendar year following Initial Startup for mobile sources. Include a certification from the equipment manufacturer that the haul trucks in use at the facility have emissions less than or equal to the required Tier level. GP001

### APPENDIX A Limits Table Facility Name: Essar Steel Minnesota LLC Permit Number: 06100067-004

Table 1 – PM, PM 10 

### , PM 2.5 

### , Lead, and Fluoride Not to Exceed Limits

Stack

ID EU ID GP ID Description Permitted Performance Standard*** Permitted Mass Emission Limits (gr/dscf) (ppmv)* (lb/hr) PM PM 10 PM 2.5 Lead Fluoride PM PM 10 PM 2.5 Lead Fluoride SV 001 EU 002 GP 008 Primary Ore Crusher 0.0025 0.0025 0.0025 1.1E+00 1.1E+00 1.1E+00 1.3E-05 1.1E-06 SV 002 EU 004 GP 008 Grizzly Screening Building 0.0025 0.0025 0.0025 4.7E-01 4.7E-01 4.7E-01 5.7E-06 4.7E-07 SV 006 EU 013 GP 008 Coarse Ore Storage Conveyor 0.0025 0.0025 0.0025 9.8E-02 9.8E-02 9.8E-02 1.2E-06 9.8E-08 SV 007 EU 014 GP 008 Fine Ore Storage Conveyor 0.0025 0.0025 0.0025 9.8E-02 9.8E-02 9.8E-02 1.2E-06 9.8E-08 SV 008 EU 015 GP 008 Coarse Ore Conveyor Gallery 0.0025 0.0025 0.0025 6.3E-02 6.3E-02 6.3E-02 7.6E-07 6.3E-08 SV 009 EU 018 GP 008 Fine Ore Conveyor Gallery 0.0025 0.0025 0.0025 4.6E-01 4.6E-01 4.6E-01 5.6E-06 4.6E-07 SV 010 EU 022 GP 008 Primary Gri nding Mill Line 1 0.0025 0.0025 0.0025 2.9E-01 2.9E-01 2.9E-01 3.4E-06 2.9E-07 SV 011 EU 024 GP 016 Primary Gri nding Mill Line 2 0.0025 0.0025 0.0025 2.9E-01 2.9E-01 2.9E-01 3.4E-06 2.9E-07 SV 014 EU 028 GP 016 Limestone Handling System 0.0025 0.0025 0.0025 2.1E-02 2.1E-02 2.1E-02 4.9E-08 SV 015 EU 030 GP 008 Binder Handling System 0.0025 0.0025 0.0025 5.0E-02 5.0E-02 5.0E-02 1.2E-07 SV 016 EU 036 GP 008 Hearth Layer Bin 0.0020 0.0020 0.0020 1.4E+00 1.4E+00 1.4E+00 2.8E-06 7.0E-05

SV 017 EU 037 EU 106 GP 018 Hearth Layer Feed 0.0020 0.0020 0.0020 1.2E-01 1.2E-01 1.2E-01 2.4E-07 6.0E-06

SV 018 EU 038 GP 018 Furnace Hood Exhaust 0.0040 0.0080 0. 0080 0.0040 1.8 2.7E+01 5.4E+01 5.4E+01 2.1E-02 4.4E+00 SV 019 EU 039 GP 008 Furnace Waste Gas 0.0040 0.0080 0.0080 0.0040 11.5 1.8E+01 3.7E+01 3.7E+01 2.1E-02 2.0E+01 SV 020 EU 040 GP 008 Pellet Discharge 0.0020 0.0020 0.0020 3.3E+00 3.3E+00 3.3E+00 6.7E-06 1.7E-04 SV 021 EU 041 GP 008 Pellet Screening and Handling 0.0020 0.0020 0.0020 2.9E+00 2.9E+00 2.9E+00 5.8E-06 1.4E-04 SV 022 EU 042 GP 008 Pellet Screenings to Regrind Conveyors 0.0020 0.0020 0.0020 2.4E-02 2.4E-02 2.4E-02 4.7E-08 1.2E-06 SV 023 EU 048 GP 008 Oxide Pellet Stockpile Conveyor Gallery 0.0020 0.0020 0.0020 7.7E-01 7.7E-01 7.7E-01 1.5E-06 3.8E-05 SV 027 EU 054 GP 017 DRI Oxide Pellet Screening and Handling System Line 1 0.0025 0.0025 0.0025 1.6E+00 1.6E+00 1.6E+00 3.2E-06 7.9E-05 SV 029 EU 064 GP 019 DRI Depressurizing Scrubber Line 1 0.0050 0.0050 0.0050 7.8E-01 7.8E-01 7.8E-01 1.6E-05 3.9E-05 SV 030 EU 066 GP 008 DRI Process Gas Heater Line 1 0.015** 0.015** 0.015** 7.3E+00 7.3E+00 7.3E+00 1.5E-05 7.3E-06 SV 031 EU 063 GP 016 DRI Oxide Charging Area Line 1 0.0025 0.0025 0.0025 1.0E-01 1.0E-01 1.0E-01 2.0E-07 5.0E-06 SV 039 EU 115 GP 016 Hydrated Lime Handling System 0.0025 0.0025 0.0025 2.1E-02 2.1E-02 2.1E-02 SV 040 EU 117 GP 016 Calcined Limestone Handling System 0.0025 0.0025 0.0025 2.1E-02 2.1E-02 2.1E-02 SV 041 EU 119 GP 016 Carbon Handling System 0.0025 0.0025 0.0025 2.1E-02 2.1E-02 2.1E-02 SV 042 EU 121 GP 016 Fluorspar Handling System 0.0025 0.0025 0.0025 7.1E-03 7.1E-03 7.1E-03 3.4E-03 SV 043 EU 123 GP 009 Bauxite Handling System 0.0025 0.0025 0.0025 6.6E-02 6.6E-02 6.6E-02 SV 044 EU 125 GP 009 EAF Baghouse Line 1 0.0018 0.0030 0.0030 9.1E+00 1.5E+01 1.5E+01 3.0E-04 7.6E-04 SV 047 EU 131 GP 015 EAF Baghouse Dust Transfer Line 1 0.0025 0.0025 0.0025 9.0E-03 9.0E-03 9.0E-03 7.2E-05 4.1E-05 SV 051 EU 138 GP 016 Tunnel Furnace 0.0060 0.0060 0.0060 1.0E+00 1.0E+00 1.0E+00 SV 059 EU 044 GP 017 Pellet Plant - Powder Coating Handling 0.0025 0.0025 0.0025 6.3E-03 6.3E-03 6.3E-03 1.5E-08 SV 063 EU 070 GP 017 DRI P.T.S. Depressurizing Scrubber Line 1 0.0050 0.0050 0.0050 4.7E-01 4.7E-01 4.7E-01 9.5E-06 2.4E-05 SV 070 EU 088 GP 016 DRI Screening & Handling Line 1 0.0050 0.0050 0.0050 1.6E+00 1.6E+00 1.6E+00 3.1E-05 7.8E-05 SV 072 EU 052 GP 008 DRI Powder Coating Handling 0.0025 0.0025 0.0025 6.3E-03 6.3E-03 6.3E-03 1.5E-08 SV 073 EU 060 GP 008 DRI Pelle t Silos Line 1 0.0025 0.0025 0.0025 2.9E-01 2.9E-01 2.9E-01 5.8E-07 1.5E-05 SV 084 EU 176 GP 008 Primary Gri nding Mill Line 3 0.0020 0.0020 0.0020 2.3E-01 2.3E-01 2.3E-01 2.8E-06 2.3E-07 SV 085 EU 170 GP 008 Grizzly Transfer Tower 0.0020 0.0020 0.0020 7.9E-02 7.9E-02 7.9E-02 9.5E-07 7.9E-08 SV 086 EU 171 GP 008 Non-Magnetic Cobber Rejects Transfer Tower 0.0020 0.0020 0.0020 7.9E-02 7.9E-02 7.9E-02 9.5E-07 7.9E-08 SV 087 EU 172 GP 008 Secondary Screening Crusher/Cobber Line 1 0.0020 0.0020 0.0020 3.9E-01 3.9E-01 3.9E-01 4.7E-06 3.9E-07 SV 088 EU 173 GP 008 Secondary Screening Crusher/Cobber Line 2 0.0020 0.0020 0.0020 3.9E-01 3.9E-01 3.9E-01 4.7E-06 3.9E-07 SV 089 EU 174 GP 008 Secondary Screening Crusher/Cobber Line 3 0.0020 0.0020 0.0020 3.9E-01 3.9E-01 3.9E-01 4.7E-06 3.9E-07 SV 090 EU 175 GP 016 Secondary Screening Crusher/Cobber Line 4 0.0020 0.0020 0.0020 3.9E-01 3.9E-01 3.9E-01 4.7E-06 3.9E-07 SV 091 EU 177 GP 016 Carbon Bin for Mercury Control 0.0020 0.0020 0.0020 1.7E-02 1.7E-02 1.7E-02 SV 092 EU 178 GP 008 Lime Bin for Scrubber 0.0020 0.0020 0.0020 1.7E-02 1.7E-02 1.7E-02



### *Fluoride performance standard shall be measured at ppmv wet corrected to 15% O 2 

### . **DRI Process Gas Heater performance st andards shall be on a lb/mmBtu basis. ***Lead and Fluoride incoming material concentrat ion limits are listed in Table A of the permit.

### For each pollutant, a performance standard (Table 2) and ma ss emission limit (Table 3) is presented. Where applicable, a startup, shutdown, malfunction (SSM) limit (Table 3) is also included.


### Table 2 – SO 2 

### , NO x 

### , CO, VOC, SAM, H 2 

### S, and CO 2 

### e Not to Exceed Performance Standard Limits

SO 2

NOx CO VOC SAM H 2 S

SV 018 EU 038 GP 018 Furnace Hood Exhaust 6.8 ppmv wet @15% O 2 0.25 lb/mmBtu 1.9 ppmv wet @15% O 2 0.60 ppmv wet @15% O 2 0.0040 ppmv wet@15% O 2
SV 019 EU 039 GP 018 Furnace Waste Gas 5.0 ppmv wet @15% O 2 0.25 lb/mmBtu 7.4 ppmv wet @15% O 2 2.3 ppmv wet @15% O 2 0.029 ppmv wet@15% O 2 SV 028 EU 065 GP 019 DRI Package Boiler Line 1 0.035 lb/mmBtu 0.080 lb/mmBtu

SV 030 EU 066 GP 019 DRI Process Gas Heater Line 1 0.0029 lb/ton DRI produced 0.040 lb/mmBtu 0.080 lb/mmBtu

SV 044 EU 125 GP 009 EAF Baghouse Line 1 0.15 lb/ton steel produced 0.30 lb/ton of liquid steel produced 2.0 lb/ton of liquid steel produced 0.13 lb/ton of liquid steel produced 0.0052 lb/ton of liquid steel produced SV 045 EU 129 GP 014 EAF Vacuum Degasser Line 1 53 ppm SV 050 EU 137 GP 019 Vacuum Degasser Boiler 0.035 lb/mmBtu 0.080 lb/mmBtu SV 051 EU 138 GP 015 Tunnel Furnace 1.0 ppm 0.024 lb/ton steel produced 0.080 lb/mmBtu 0.0060 lb/mmBtu

SV 062 EU 069 GP 019 DRI P.T.S. Heater Line 1 0.035 lb/mmBtu 0.080 lb/mmBtu SV 075 EU 162 GP 025 DRI Process Water Blowdown Line 1 10.3 % by volume SV 076 EU 161 GP 025 DRI Quench Cooling Water Blowdown Line 1 3.5 % by volume SV 078 EU 067 GP 024 DRI Top Gas Purification Line 1 65 ppm



### Table 3 – SO 2 

### , NO x 

### , CO, VOC, SAM, H 2 

### S, and CO 2 

### e Not to Exceed Mass Emission Limits

SO 2

NO x CO VOC SAM H 2 S CO 2 e (lb/hr) (lb/hr) SSM (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (ton/yr) SV 018 EU 038 GP 018 Furnace Hood Exhaust 55.7 135 6.8 3.3 0.15 710,000 SV 019 EU 039 GP 018 Furnace Waste Gas 29.9 19.3 9.3 0.15 SV 028 EU 065 GP 019 DRI Package Boiler Line 1 3.5 10 8.2 SV 030 EU 066 GP 019 DRI Process Gas Heater Line 1 1.0 21.2 60.6 50 SV 044 EU 125 GP 009 EAF Baghouse Line 1 33 53 110 410 27 0.0070 SV 045 EU 129 GP 014 EAF Vacuum Degasser Line 1 7.8 SV 050 EU 137 GP 019 Vacuum Degasser Boiler 3.5 10 8.2 SV 051 EU 138 GP 015 Tunnel Furnace 0.10 4.9 1.9 0.50 SV 062 EU 069 GP 019 DRI P.T.S. Heater Line 1 0.32 1.2 0.74 SV 075 EU 162 GP 025 DRI Process Water Blowdown Line 1 2.7 SV 076 EU 161 GP 025 DRI Quench Cooling Water Blowdown Line 1 6.3 SV 078 EU 067 GP 024 DRI Top Gas Purification Line 1 8.2APPENDIX BModeling ParametersFacility Name: Essar Steel Minnesota LLCPermit Number: 06100067-004Summary of Stack Vent Parameters and Emission Rates used for Class I and Class II modelingStackID No.DescriptionUTM: Zone 15 (NAD83) LCC: 47N 93W (30,60N)(5)BaseElevation(m)Exit FlowRate(acfm)Exit Heightfrom Base(m)InsideDiameter(m)Exit FlowVelocity(m/s)ExitTemp(K)Emission Rates(g/s)Easting(m)Northing(m)X(m)Y(m)PM10PM2.5CONOxSO2SO4(5)PMC(5)PMF(5)SOA(5)EC(5)Pb(4)Hourly Annual Hourly Annual Hourly Hourly Annual Hourly Annual Hourly Annual Hourly Hourly Hourly Hourly HourlySV 001 Primary Ore Crusher 481220.43 5244543.86 -18151.49 38058.77 457.2 54,000 26.6 1.46 15.2 298.2 1.4E-01 1.2E-01 1.4E-01 1.2E-011.4E-01SV 002 Grizzly Screening Building 481120.39 5244718.42 -18248.19 38227.48 457.4 24,000 39.9 0.98 15.2 298.2 6.6E-02 5.6E-02 6.6E-02 5.6E-026.6E-02SV 005 DRI Cooling Tower Line 1 483527.10 5247799.57 -15922.20 41205.79 472.5 5,475,555 20.0 19.57 8.6 301.2 1.4E-01 1.4E-01 1.4E-01 1.4E-01SV 006 Coarse Ore Storage Conveyor 480934.64 5245003.92 -18427.7638503.42 484.6 5,000 33.0 0.45 15.2 298.2 1.9E-02 1.1E-02 1.9E-02 1.1E-021.9E-02SV 007 Fine Ore Storage Conveyor 480869.11 5244997.21 -18491.09 38496.93 484.6 5,000 33.0 0.45 15.2 298.2 1.9E-02 1.1E-02 1.9E-02 1.1E-021.9E-02SV 008 Coarse Ore Conveyor Gallery 480944.69 5245060.87 (2) 484.6 3,270 29.3 1.22 1.3 302.6 1.4E-02 7.3E-03 1.4E-02 7.3E-031.4E-02SV 009 Fine Ore Conveyor Gallery 480884.08 5245071.55 (2) 484.6 23,909 29.3 1.22 9.7 302.6 6.5E-02 5.3E-02 6.5E-02 5.3E-026.5E-02SV 010 Primary Grinding Mill Line1 481019.35 5245024.38 (1) 466.6 14,76737.2 1.22 6.0 302.6 4.3E-02 3.3E-02 4.3E-02 3.3E-024.3E-02SV 011 Primary Grinding Mill Line2 481019.35 5245024.38 (1) 466.6 14,76737.2 1.22 6.0 302.6 4.3E-02 3.3E-02 4.3E-02 3.3E-024.3E-02SV 014 Limestone Handling System 483160.70 5247363.13 -16276.32 40783.92469.2 1,090 61.5 0.21 14.40 298.2 2.7E-03 2.7E-03 2.7E-03 2.7E-032.7E-03SV 015 Binder Handling System 483164.03 5247372.03 -16273.10 40792.51 469.2 2,545 61.5 0.30 16.47 298.2 1.3E-02 6.0E-03 1.3E-02 6.0E-031.3E-02SV 016 Hearth Layer Bin 483049.00 5247474.39 -16384.30 40891.45 469.2 90,315 40.6 1.89 15.20 298.2 1.8E-01 1.7E-01 1.8E-01 1.7E-011.8E-01SV 017 Hearth Layer Feed 483059.96 5247470.28 -16373.71 40887.48 469.27,689 40.6 0.55 15.36 298.2 1.5E-02 1.4E-02 1.5E-02 1.4E-021.5E-02SV 018 Furnace Hood Exhaust 483198.20 5247456.08 -16262.48 40876.37 468.8 905,062 100.0 5.79 14.72 318.2 6.9E+00 5.6E+00 6.9E+00 5.6E+00 8.6E-01 4.44 3.65 7.02 5.77 1.0E-01 2.4E-02 2.4E-16 6.2E+00 6.0E-01 3.6E-03 2.63E-03SV 019 Furnace Waste Gas 483204.40 5247453.73 -16251.23 40905.81 468.8 658,695 100.0 5.00 14.38 318.2 4.7E+00 3.8E+00 4.7E+00 3.8E+00 2.4E+00 12.63 10.38 3.77 3.41 5.9E-02 1.4E-02 6.1E-16 4.2E+00 4.1E-01 1.0E-02 2.63E-03SV 020 Pellet Discharge 483127.60 5247660.05 -16308.34 41070.90 469.2 213,816 40.6 2.90 15.33 298.2 4.2E-01 3.9E-01 4.2E-01 3.9E-014.2E-01SV 021 Pellet Screening and Handling 483262.30 5247612.78 -16178.14 41025.23 469.2 185,000 34.5 2.71 15.11 298.2 3.7E-01 3.4E-01 3.7E-01 3.4E-013.7E-01SV 022 Pellet Screenings to Regrind Conveyors 483273.415247570.03 -16167.40 40983.90 468.8 1,500 29.5 0.24 15.17 298.2 3.0E-03 2.9E-03 3.0E-03 2.9E-033.0E-03SV 023 Oxide Pellet Stockpile Conveyor Gallery 483303.93 5247714.23 -16137.91 41123.29 469.2 52,263 18.9 0.76 54.11 319.3 1.0E-01 9.1E-02 1.0E-01 9.1E-021.0E-01SV 027 DRI Oxide Pellet Screening and Handling System Line 1 483456.43 5247542.29 -15990.50 40957.11 472.5 85,966 23.3 1.46 24.15319.3 1.9E-01 1.7E-01 1.9E-01 1.7E-011.9E-01SV 028 DRI Package Boiler Line 1 483961.99 5247838.70 -15501.86 41243.64 472.5 34,268 35.0 0.61 55.44 453.2 9.3E-02 7.9E-02 9.3E-02 7.9E-02 1.0E+00 1.26 0.37 1.4E-02 6.4E-03-6.9E-18 2.4E-03 6.7E-02 2.3E-02SV 029 DRI Depressurizing Scrubber Line 1 483512.13 5247674.10-15936.67 41084.51 472.5 22,556 93.0 0.61 36.49 319.3 1.0E-01 9.0E-021.0E-01 9.0E-021.0E-01SV 030 DRI Process Gas Heater Line 1 483506.56 5247677.04 -15942.05 41087.36 472.5 197,199 100.0 2.04 28.43 448.2 1.1E+00 9.4E-01 1.1E+00 9.4E-01 6.3E+00 7.64 2.67 1.0E-01 8.3E-021.6E-01 8.0E-01 1.4E-01 3.96E-05SV 031 DRI Oxide Charging Area Line 1 483578.86 5247791.74 -15872.17 41198.23 472.5 5,056 100.0 0.45 15.35 298.2 1.9E-02 1.2E-02 1.9E-02 1.2E-02SV 039 Hydrated Lime Handling System 483662.99 5247481.28 -15790.84 40898.16 472.5 1,090 20.0 0.21 14.40 298.2 2.7E-03 2.7E-03 2.7E-03 2.7E-032.7E-03SV 040 Calcined Limestone Handling System 483672.31 5247477.63 -15781.83 40894.62 472.5 1,090 20.0 0.21 14.40 298.2 2.7E-03 2.7E-03 2.7E-03 2.7E-032.7E-03SV 041 Carbon Handling System 483593.09 5247664.38 -15858.41 41075.13 472.5 1,090 44.9 0.21 14.40 298.2 2.7E-03 2.7E-03 2.7E-03 2.7E-032.7E-03SV 042 Fluorspar Handling System 483732.70 5247474.57 -15723.46 40891.68472.5 363 20.0 0.12 14.40 298.2 9.0E-04 8.9E-04 9.0E-04 8.9E-049.0E-04SV 043 Bauxite Handling System 483728.81 5247464.20 -15727.22 40881.65 472.5 3,330 20.0 0.37 14.97 298.2 1.5E-02 8.4E-03 1.5E-02 8.4E-031.5E-02SV 044 EAF Baghouse Line 1 483716.98 5247601.13 -15738.66 41014.00 472.5 847,008 30.0 4.51 25.02 393.2 2.0E+00 1.8E+00 2.0E+00 1.8E+005.1E+01 13.86 6.18 4.11 3.78 4.2E-03 9.7E-04 1.7E-16 1.7E+00 2.7E-01 6.7E-03 2.95E-02SV 045 EAF Vacuum Degasser Line 1 483528.95 5247603.17 -15920.40 41015.96 472.5 55,736 44.9 1.71 11.50 449.8 6.7E-02 1.6E-02 6.7E-02 1.6E-02 2.9E-01 0.81 0.20 4.8E-03 1.2E-036.9E-18 1.8E-03 4.9E-02 1.7E-02SV 047 EAF Baghouse Dust Transfer Line 1 483620.08 5247577.48 -15832.32 40991.13 472.5 436 22.0 0.12 17.63 298.2 1.1E-03 1.2E-03 1.1E-03 1.2E-031.1E-03SV 048 EAF Indirect Cooling Tower Line 1 483533.11 5247579.89 -15916.38 40993.46 472.5 8,318,750 12.5 24.14 8.58 301.2 9.3E-02 8.7E-02 9.3E-02 8.7E-029.3E-02SV 050 Vacuum Degasser Boiler 483955.71 5247844.28 -15507.94 41249.03 472.5 31,393 17.2 1.28 11.52 449.8 9.3E-02 2.6E-02 9.3E-02 2.6E-02 1.0E+00 1.26 0.12 1.4E-02 2.0E-03-6.9E-18 2.4E-03 6.7E-02 2.3E-02SV 051 Tunnel Furnace 483789.47 5247650.90 -15668.60 41062.11 472.5 67,111 47.5 1.86 11.67 903.2 1.3E-01 1.2E-01 1.3E-01 1.2E-01 2.4E-01 0.61 0.56 1.4E-02 7.3E-033.4E-03 9.4E-02 3.3E-02SV 054 Direct Cooling Tower 483526.18 5247865.58 -15923.11 41269.60 472.5 8,020,833 12.5 23.71 8.58 301.2 5.7E-02 5.0E-02 5.7E-02 5.0E-025.7E-02SV 055 Laminar Cooling Tower 483842.24 5247628.86 -15617.59 41040.81 472.5 2,291,666 12.5 12.68 8.57 301.2 1.4E-02 1.5E-02 1.4E-02 1.5E-021.4E-02SV 059 Pellet Plant - Powder Coating Handling 483043.85 5247418.54 -16389.27 40837.46 469.2 327 42.7 0.24 3.31 303.2 8.0E-04 8.9E-048.0E-04 8.9E-048.0E-04SV 061 DRI Flare Line 1 483501.83 5247806.22 -15946.63 41212.22 472.5 165 45.0 0.61 0.27 408.2 1.0E-03 8.9E-04 1.0E-03 8.9E-04 2.1E-03 1.5E-02 7.8E-03 1.5E-04 1.3E-04-5.4E-20 2.8E-05 7.6E-04 2.6E-04SV 062 DRI P.T.S. Heater Line 1 483530.03 5247664.01 -15919.37 41074.77 472.5 4,530 65.0 0.43 14.96 558.2 1.7E-02 1.1E-02 1.7E-02 1.1E-02 1.2E-01 1.5E-01 5.1E-02 8.5E-04 1.0E-03-8.7E-19 4.5E-04 1.2E-02 4.3E-03SV 063 DRI P.T.S. Depressurizing Scrubber Line 1 483564.65 5247698.29 -15885.91 41107.90 472.5 13,706 93.0 0.61 22.17 319.3 6.6E-025.5E-02 6.6E-02 5.5E-026.6E-02SV 070 DRI Screening & Handling Line 1 483597.56 5247673.01 -15854.10 41083.47 472.5 42,308 44.9 0.61 68.45 319.3 1.8E-01 1.7E-01 1.8E-01 1.7E-011.8E-01SV 072 DRI Powder Coating Handling 483652.81 5247484.04 -15800.67 40900.82 472.5 327 21.0 0.24 3.31 303.2 8.0E-04 8.7E-04 8.0E-04 8.7E-048.0E-04SV 073 DRI Pellet Silos Line 1 483453.67 5247573.03 -15993.17 40986.82 472.5 15,819 23.3 0.61 25.59 319.3 4.0E-02 3.1E-02 4.0E-02 3.1E-024.0E-02SV 075 DRI Process Water Blowdown Line 1 483568.18 5247879.13 -15882.51 41282.69 472.5 7 25.0 0.61 0.01 358.23.4E-01SV 076 DRI Quench Cooling Water Blowdown Line 1 483577.44 5247874.65 -15873.56 41278.37 472.5 47 22.0 0.76 0.05 333.28.0E-01SV 078 DRI Top Gas Purification Line 1 483547.27 5247705.49 -15902.71 41114.85 472.5 23,704 100.0 1.22 9.59 322.0SV 082 Coarse Ore Barn Perimeter 480973.08 5245072.61 (3) 484.60 228.60298.2SV 083 Fine Ore Barn Perimeter 480973.08 5245072.61 (3) 484.60 259.08298.2SV 084 Primary Grinding Mill Line3 481019.35 5245024.38 (1) 466.6 14,76737.2 1.22 5.97 302.6 2.9E-022.6E-02 2.9E-02 2.6E-022.9E-02SV 085 Grizzly Transfer Tower 480896.25 5244765.41 -18464.84 38272.88 468.5 5,000 14.4 0.45 15.18 298.2 1.6E-02 9.2E-03 1.6E-02 9.2E-031.6E-02SV 086 Non-Magnetic Cobber Rejects Transfer Tower480841.62 5244854.10 -18517.65 38358.60 467.7 5,000 14.1 0.45 15.18 298.2 1.6E-029.2E-03 1.6E-02 9.2E-031.6E-02SV 087 Secondary Screening Crusher/Cobber Line 1480835.83 5244765.92 -18523.24 38273.37 468.5 25,000 53.2 1.01 14.86 298.2 5.6E-024.6E-02 5.6E-02 4.6E-025.6E-02SV 088 Secondary Screening Crusher/Cobber Line 2480837.18 5244773.06 -18521.94 38280.27 468.5 25,000 53.2 1.01 14.86 298.2 5.6E-024.6E-02 5.6E-02 4.6E-025.6E-02SV 089 Secondary Screening Crusher/Cobber Line 3480838.34 5244779.43 -18520.82 38286.43 468.5 25,000 53.2 1.01 14.86 298.2 5.6E-024.6E-02 5.6E-02 4.6E-025.6E-02SV 090 Secondary Screening Crusher/Cobber Line 4480839.43 5244786.49 -18519.76 38293.26 468.5 25,000 53.2 1.01 14.86 298.2 5.6E-024.6E-02 5.6E-02 4.6E-025.6E-02SV 091 Carbon Bin for Mercury Control 483169.09 5247544.04468.8 1,090 35.6 0.61 1.76 298.2SV 092 Lime Bin for Scrubber 483187.04 5247528.70 -16268.23 40958.78 468.8 1,090 35.6 0.61 1.76 298.2 2.2E-03 2.0E-03 2.2E-03 2.0E-032.2E-03StackID No.DescriptionUTM: Zone 15 (NAD83) LCC: 47N 93W (30,60N)(5)BaseElevation(m)Exit FlowRate(acfm)Exit Heightfrom Base(m)InsideDiameter(m)Exit FlowVelocity(m/s)ExitTemp(K)Emission Rates(g/s)Easting(m)Northing(m)X(m)Y(m)PM10PM2.5CONOxSO2SO4(5)PMC(5)PMF(5)SOA(5)EC(5)Hourly Annual Hourly Annual Hourly Hourly Annual Hourly Annual Hourly Annual Hourly Hourly Hourly Hourly(6)SV 012 Fire Water Supply Pump - Concentrator 481005.98 5244953.24 -18358.80 38454.44 466.6 400 5.0 0.06 64.71 477.69.1E-04 1.1E-04 9.1E-04 1.1E-041.3E-02 1.5E-03 8.5E-04 9.7E-05-5.4E-20 3.3E-04 1.9E-04 4.0E-04 Class I2.2E-02 2.6E-03 2.2E-02 2.6E-03 7.0E-02 3.1E-01 3.5E-02 2.0E-02 2.3E-03Class IISV 013 Emergency Power Generator - Concentrator 481009.70 5244974.32 -18355.21 38474.81 466.6 9,000 9.0 0.30 58.24 588.73.0E-03 3.4E-04 3.0E-03 3.4E-041.0E-01 1.2E-02 1.8E-03 2.0E-041.1E-03 6.2E-04 1.3E-03 Class I7.1E-02 8.1E-03 7.1E-02 8.1E-03 5.6E-01 2.4E+00 2.8E-01 4.4E-02 4.7E-03Class IISV 024 Fire Water Booster Pump - Pellet Plant 483103.07 5247272.26 -16332.02 40696.08 469.2 400 5.0 0.06 64.71 422.06.0E-04 5.3E-05 6.0E-04 5.3E-056.7E-03 7.5E-04 5.6E-04 4.9E-052.1E-04 1.2E-04 2.6E-04 Class I1.4E-02 1.3E-03 1.4E-02 1.3E-03 3.4E-02 1.6E-01 1.8E-02 1.4E-02 1.2E-03Class IISV 025 Fire Water Supply Pump - Pellet Plant 483101.32 5247267.92 -16333.72 40691.88 469.2 400 5.0 0.06 64.71 477.69.1E-04 1.1E-04 9.1E-04 1.1E-041.3E-02 1.5E-03 8.5E-04 9.7E-05-5.4E-20 3.3E-04 1.9E-04 4.0E-04 Class I2.2E-02 2.6E-03 2.2E-02 2.6E-03 7.0E-02 3.1E-01 3.5E-02 2.0E-02 2.3E-03Class IISV 026 Emergency Power Generator - Pellet Plant 483168.44 5247402.02 -16268.85 40821.50 469.2 9,000 50.1 0.30 58.24 588.73.0E-03 3.4E-04 3.0E-03 3.4E-041.0E-01 1.2E-02 1.7E-03 1.9E-041.1E-03 6.2E-04 1.3E-03 Class I7.1E-02 8.1E-03 7.1E-02 8.1E-03 5.6E-01 2.4E+00 2.8E-01 4.1E-02 4.6E-03Class IISV 034 Fire Water Booster Pump - Furnace 483779.05 5247795.00 -15678.68 41201.39 472.5 400 23.0 0.06 64.71 422.06.0E-04 5.3E-05 6.0E-04 5.3E-056.7E-03 7.5E-04 5.6E-04 4.9E-052.1E-04 1.2E-04 2.6E-04 Class I1.4E-02 1.3E-03 1.4E-02 1.3E-03 3.4E-02 1.6E-01 1.8E-02 1.4E-02 1.2E-03Class IISV 035 Fire Water Supply Pump - DRI 483788.41 5247789.36 -15669.64 41195.95 472.5 400 23.0 0.06 64.71 477.69.1E-04 1.1E-04 9.1E-04 1.1E-041.3E-02 1.5E-03 8.5E-04 9.7E-05-5.4E-20 3.3E-04 1.9E-04 4.0E-04 Class I2.2E-02 2.6E-03 2.2E-02 2.6E-03 7.0E-02 3.1E-01 3.5E-02 2.0E-02 2.3E-03Class IISV 036 Emergency Power Generator - DRI 483500.15 5247719.40 -15948.25 41128.30 472.5 9,000 34.4 0.30 58.24 588.73.0E-03 3.4E-04 3.0E-03 3.4E-041.0E-01 1.2E-02 1.8E-03 2.0E-041.1E-03 6.2E-04 1.3E-03 Class I7.1E-02 8.1E-03 7.1E-02 8.1E-03 5.6E-01 2.4E+00 2.8E-01 4.4E-02 4.7E-03Class IISV 037 Fire Water Booster Pump - Offices 483800.27 5247787.53 -15658.17 41194.18 472.5 400 23.0 0.06 64.71 422.06.0E-04 5.3E-05 6.0E-04 5.3E-056.7E-03 7.5E-04 5.6E-04 4.9E-052.1E-04 1.2E-04 2.6E-04 Class I1.4E-02 1.3E-03 1.4E-02 1.3E-03 3.4E-02 1.6E-01 1.8E-02 1.4E-02 1.2E-03Class IISV 038 Emergency Power Generator - Offices 483505.38 5247730.51 -15943.20 41139.03 472.5 3,750 34.4 0.30 24.27 588.71.4E-03 1.5E-04 1.4E-03 1.5E-044.2E-02 4.8E-03 8.4E-04 8.7E-05-1.1E-19 4.9E-04 2.8E-04 5.9E-04 Class I3.3E-02 3.5E-03 3.3E-02 3.5E-03 2.4E-01 1.0E+00 1.2E-01 2.0E-02 2.1E-03Class IISV 056 Fire Water Booster Pump - Steel Mill483880.64 5247765.00 -15580.48 41172.41 472.5 400 28.0 0.06 64.71 422.06.0E-04 5.3E-05 6.0E-04 5.3E-056.7E-03 7.5E-04 5.6E-04 4.9E-052.1E-04 1.2E-04 2.6E-04 Class I1.4E-02 1.3E-03 1.4E-02 1.3E-03 3.4E-02 1.6E-01 1.8E-02 1.4E-02 1.2E-03Class IISV 057 Fire Water Supply Pump - Steel Mill483872.60 5247768.62 -15588.25 41175.90 472.5 400 28.0 0.06 64.71 477.69.1E-04 1.1E-04 9.1E-04 1.1E-041.3E-02 1.5E-03 8.5E-04 9.7E-05-5.4E-20 3.3E-04 1.9E-04 4.0E-04 Class I2.2E-02 2.6E-03 2.2E-02 2.6E-03 7.0E-02 3.1E-01 3.5E-02 2.0E-02 2.3E-03Class IISV 058 Emergency Power Generator - Steel Mill483889.76 5247772.28 -15571.68 41179.44 472.5 9,000 28.0 0.30 58.24 588.73.0E-03 3.4E-04 3.0E-03 3.4E-041.0E-01 1.2E-02 1.8E-03 2.0E-041.1E-03 6.2E-04 1.3E-03 Class I7.1E-02 8.1E-03 7.1E-02 8.1E-03 5.6E-01 2.4E+00 2.8E-01 4.4E-02 4.7E-03Class II(5)Rel. Hght Sigma Y Sigma ZSVCONC 481019.35 5245024.38 -18345.90 38523.20 466.617.6 23.3 16.331.2E-01 1.2E-01 1.2E-01 1.2E-015.0E-02 5.0E-02 3.0E-04 3.0E-04-3.5E-18 3.1E-03 8.6E-02 3.0E-02SH400 483543.52 5247727.82 -15906.30 41136.40 472.57.6 98.8 7.091.9E-02 1.9E-02 1.9E-02 1.9E-022.0E-01 2.0E-01 1.2E-03 1.2E-030.0E+00 5.1E-04 1.4E-02 4.8E-03SH200 483117.58 5247512.11 -16318.00 40927.90 468.825.0 40.3 22.562.4E-03 2.4E-03 2.4E-03 2.4E-032.5E-02 2.5E-02 1.5E-04 1.5E-040.0E+00 6.3E-05 1.7E-03 6.0E-04SH000 480824.98 5244783.03 -18533.70 38289.90 471.624.2 5.9 8.412.4E-03 2.4E-03 2.4E-03 2.4E-032.5E-02 2.5E-02 1.5E-04 1.5E-040.0E+00 6.3E-05 1.7E-03 6.0E-04MDS001-15576.00 41038.00 455.43.3 293.2 3.082.2E-022.2E-021.2E+004.1E-040.0E+00 7.8E-03 4.6E-03 9.5E-03MDS002-18070.00 37273.00 434.43.3 1105.8 3.081.1E-011.1E-013.7E+004.8E-030.0E+00 3.8E-02 2.2E-02 4.6E-02MDS002b-16638.00 38493.00 443.83.3 1443.0 3.081.1E-011.1E-013.7E+004.8E-030.0E+00 3.8E-02 2.2E-02 4.6E-02MDS003-18070.00 37273.00 434.43.3 1105.8 3.083.9E-023.9E-021.3E+002.2E-033.5E-18 1.4E-02 8.1E-03 1.7E-02MDS003b-16638.00 38493.00 443.83.3 1443.0 3.083.9E-023.9E-021.3E+002.2E-033.5E-18 1.4E-02 8.1E-03 1.7E-02(1)These sources are all vented out of the concentrator building. See SVCONC in next table.(2) Building Vent, modeled as volumesources. See SV008/SV009 in next table(3) Ore barn vents, modeled as volumesources. See OREBARN in next table(4) Only used for Class II modeling(5) Only used for Class I modeling(6) Emergency Generators and Fire Water Pumps were modeled for Class I based on the worst case scenario of the facility in fulloperation and these units running (one per area) tests of no more than 30 minutes per day.Modeling files stored at MPCA at: X:\Agency_Files\Outcomes\Risk_Eval_Air_Mod\Air_ModelingSummary of Modeled Volume, Area,and Open Pit Source ParametersSource ID Source DescriptionSourceTypeReleaseHeight(m)SXINIT(m)SYINIT(m)SZINIT(m)AREA(m2)Angle(deg)PM10(g/s)PM2.5(g/s)NOX(g/s)CO(g/s)SO2(g/s)Hourly Annual Hourly Annual Hourly Annual Hourly Hourly AnnualSV008 Coarse Ore Conveyor Gallery VOLUME 1410 131.43E-02 1.43E-02 1.43E-02 1.43E-02SV009 Fine Ore Conveyor Gallery VOLUME 1410 136.50E-02 6.50E-02 6.50E-02 6.50E-02SVCONC Line 1, 2, and 3 Primary Grinding Mill and Space Heaters (4) VOLUME 1823 161.19E-01 1.19E-01 1.19E-01 1.19E-01 5.05E-02 5.10E-02 4.26E-02 2.96E-04 2.96E-04SH400 Area 400 Space Heaters (16) VOLUME 899 7.11.92E-02 1.92E-02 1.92E-02 1.92E-02 2.02E-01 2.02E-01 1.70E-01 1.19E-03 1.19E-03SH200 Area 200 Space Heaters (2) VOLUME 2540 232.40E-03 2.40E-03 2.40E-03 2.40E-03 2.52E-02 2.60E-02 2.13E-02 1.48E-04 1.48E-04SH000 Area 000 Space Heaters(2) VOLUME 246 8.42.40E-03 2.40E-03 2.40E-03 2.40E-03 2.52E-02 2.60E-02 2.13E-02 1.48E-04 1.48E-04CONCPILE Concentrate Stockpile VOLUME 515 4.77.68E-02 7.68E-02 1.59E-02 1.59E-02CONCWE Concentrate Stockpile Wind Erosions VOLUME 515 4.71.10E+00 1.10E+00 1.00E+00 1.00E+00OXPILE Oxides Stockpile VOLUME 59.3 4.71.14E-01 1.14E-01 1.47E-02 1.47E-02OXPILEWE Oxides Stockpile Wind Erosion VOLUME 59.3 4.71.10E+00 1.10E+00 1.00E+00 1.00E+00COBB Cobber Stockpile VOLUME 514 4.72.96E-01 2.96E-01 4.07E-02 4.07E-02COBBWE Cobber Stockpile Wind Erosion VOLUME 514 4.71.10E+00 1.10E+00 1.00E+00 1.00E+00OREBARN Orebarn Vents (fine and coarse) VOLUME 1857 162.14E-02 2.14E-02 2.14E-02 2.14E-02OBA Overburden Stockpile A VOLUME 91.4 4.31.13E-01 1.13E-01 1.99E-02 1.99E-02OBAWE Overburden Stockpile A Wind Erosion VOLUME 91.4 4.31.10E+00 1.10E+00 1.00E+00 1.00E+00STATE Waste Rock Stockpile State VOLUME 91.4 4.33.59E-02 3.59E-02 4.51E-03 4.51E-03STATEWE Waste Rock Stockpile State Wind Erosion VOLUME 91.4 4.31.10E+00 1.10E+00 1.00E+00 1.00E+00LANGDON Waste Rock Stockpile Langdon VOLUME 91.4 4.33.63E-02 3.63E-02 4.55E-03 4.55E-03LGDNWE Waste Rock Stockpile Langdon Wind Erosion VOLUME 91.4 4.31.10E+00 1.10E+00 1.00E+00 1.00E+00GNIOP Waste Rock Stockpile GNIOP VOLUME 91.4 4.32.33E-02 2.33E-02 2.88E-03 2.88E-03GNIOPWE Waste Rock Stockpile GNIOP Wind Erosion VOLUME 91.4 4.31.10E+00 1.10E+00 1.00E+00 1.00E+00SHARE Waste Rock Stockpile Share VOLUME 91.4 4.33.34E-02 3.34E-02 4.18E-03 4.18E-03SHAREWE Waste Rock Stockpile Share Wind Erosion VOLUME 91.4 4.31.10E+00 1.10E+00 1.00E+00 1.00E+00FS400 Area 400 Lump Lime/Carbon Unloading and conveyor drop VOLUME 58.3 4.71.49E-02 1.49E-02 2.25E-03 2.25E-03FS500 Steel Plant Stockpile VOLUME 525 4.79.37E-01 9.37E-01 2.58E-01 2.58E-01FS500WE Steel Plant Stockpile Wind Erosion VOLUME 525 4.71.00E+00 1.00E+00 1.00E+00 1.00E+00FS314 Building Vent VOLUME 55.8 4.74.68E-01 4.68E-01 7.87E-02 7.87E-02FS526 Locomotive VOLUME 58.1 8.16.68E-02 6.68E-02 1.55E-02 1.55E-02PR001 Paved Road VOLUME 24.7 1.72.32E-01 2.32E-01 6.36E-02 6.36E-02FS037 CDRI Drop into Line I EAF Feed Collection Chute VOLUME 400.2 0.55.16E-02 5.16E-02 1.41E-02 1.41E-02SRVRD1 - 97 Service Road VOLUME 24.7 1.97.80E-01 7.80E-01 7.09E-02 7.09E-02COB05 - 09 Cobber Rejects Haul Road to Cobber Rejects Stockpile VOLUME 514 4.74.02E-02 4.02E-02 3.65E-03 3.65E-03OBA001 - 044 206 P05 OB - Stockpile A VOLUME 514 4.71.32E+00 1.32E+00 1.21E-01 1.21E-01WRT001 - 009 328 P06 Waste - Langdon ex-pit and 107 P07 Ore VOLUME 514 4.78.73E-01 8.73E-01 7.98E-02 7.98E-02TAC001 - 005 107 P07 Ore VOLUME 514 4.74.35E-01 4.35E-01 3.98E-02 3.98E-02WGLS001 - 023 328 P06 Waste - Langdon, GNIOP, Share, and State Piles VOLUME 514 4.75.60E-01 5.60E-01 5.11E-02 5.11E-02WST001 - 028 327 P06 Waste - State ex-pit VOLUME 514 4.72.05E-01 2.05E-01 1.87E-02 1.87E-02WRL001 - 018 328 P06 Waste - Langdon ex-pit VOLUME 514 4.71.34E-01 1.34E-01 1.22E-02 1.22E-02WGS001 - 025 326 P06 Waste - Share and GNIOP ex-pit VOLUME 514 4.72.40E-01 2.40E-01 2.19E-02 2.19E-02WRG001 - 008 325 P06 Waste - GNIOP ex-pit VOLUME 514 4.72.50E-02 2.50E-02 2.28E-03 2.28E-03WSH001 - 027 326 P06 Waste - Share ex-pit VOLUME 514 4.71.75E-01 1.75E-01 1.60E-02 1.60E-02PL024 - 045 &TB001 - 121Tailings Basin Truck Traffic VOLUME 24.7 1.91.78E-01 1.78E-01 1.62E-02 1.62E-02PIT Mining Pit OPEN PIT 10 4070 12805.21E+06 335 1.90E-06 1.90E-06 2.21E-07 2.21E-07TBNE Tailings Basin Wind Erosion AREA 0 200 8001.60E+05 0 1.10E+00 1.10E+00 1.00E+00 1.00E+00TBSW Tailings Basin Wind Erosion AREA 0 200 8001.60E+05 -30 1.10E+00 1.10E+00 1.00E+00 1.00E+00TBNEDOZE Tailings Basin Dozer Activities AREA 2 200 8001.60E+05 0 8.72E-06 8.72E-06 7.62E-07 7.62E-07TBSWDOZE Tailings Basin Dozer Activities AREA 2 200 8001.60E+05 -30 8.72E-06 8.72E-06 7.62E-07 7.62E-07

### APPENDIX C Greenball/ DRI Lead/Fluoride Concentration Monitoring – 95% UCL 

### Facility Name: Essar Steel Minnesota LLC Permit Number: 06100067-004

The proposed lead content limit in greenball is 11 mg/kg. For compliance purpose, a sample when found below detection level is to be assigned one half of that detecti on level reported by the laboratory. An EPA software, ProUCL (Version 3.0), can be run to give a one-tailed 95% upper confidence level for compliance determination.

Table 1 . A hypothetical set of lead content data from green ball 

### Pb content in GB, mg/kg 6.12 7.05 3.63 2.20 11.8 4.22 8.14 7.77 11.2 12.6 3.37 9.21 13.7

Box-Whisker Plot ►
Compliance determination Upper confidence level: 9.64 mg/kg 0 2 4 6 8 10 12 14

Pb in GB, mg/kg



### The upper confidence level for a one-tailed analysis can also be calculated in Excel as follows:
=average(a2:a14)+tinv(0.1,rows(a2:a14 )-1)*stdev(a2:a14)/sqrt(rows(a2:a14))

Where cells a2:a14 hold the 13 values shown in Table 1. The Excel formula above carries out the following algebraic expression, which can be found in a statistics textbook:



## n s t x n n 1

1
, −

− 

## + α 

### [1]

Where 

## x is the average; s n-1 

### is the sample standard deviation; n is t he number of observations; t is the value found in Table 2 or directly calculat ed in Excel – for given values of α and n - 1.



### Table 2. t value Confidence 90% 95% 99% Two tailed, α 0.10 0.05 0.01 One tailed, α /2 0.05 0.025 0.005 n - 1 = 1 6.31 12.7 63.7 2 2.92 4.30 9.92 3 2.35 3.18 5.84 4 2.13 2.78 4.60 11 1.80 2.20 3.11 51 1.68 2.01 2.68

### APPENDIX D Visible Emissions Checklist Facility Name: Essar Steel Minnesota LLC Permit Number: 06100067-004

Visible Emissions Checklist(s) Requirements

Emission Units and Stack/Vents: Visible Emissions Checklist(s): The checklist or checklists must contain the following:
1) Printed name of observer; 2) Signature of observer; 3) Date and time of observation; 4) Indication of process and control equipment performance, either "requires attention", or "does not require attention". This determination is based upon an observ ed change in visible emission characteristics from that observed when this source and its pollution c ontrol equipment are properly operated and maintained. A change in visible emission characteristics will be indicative of "requires attention"; 5) Description of investigation and corrective actions completed for each “requires attention” observation; 6) Weather conditions (temperature, cloud cover, wind, precipitation); 7) Indication if plume were limited by visible moisture in the plume; 8) Emission unit (EU) and Stack/Vent (SV) ID number(s); and 9) Short description of emission unit.

### APPENDIX E Test-and-Set Methodology for PM 2.5 

### Facility Name: Essar Steel Minnesota LLC Permit Number: 06100067-004

Table of Contents

1.0 Test-and-Set Nomenclature

1.1 General Information

1.2 Source Groups

1.3 PM 2.5 

### Test Groups and Individual Stacks

2.0 Test and Set Procedure

2.1 Sampling Events

2.2 Test and Set Statistical Analysis

2.2.1 Calculation of 95% UCL

2.2.2 Two-Sample t-test

2.2.3 Review of Initial Statistical Analysis

2.2.3.1 Threshold for Initial Statistics

2.2.3.2 Statistical Analysis Based on Two-Sampling Events

2.2.3.3 Review Results of Statistical Analysis Based on Three Sampling Events

3.0 Reporting

4.0 Sampling Event Scheduling Figure 1 – Test-and-Set Flowchart

### 1.0 Test and Set Nomenclature
Acceptable data set – For the data collected during the PM 2.5 

### testing for an emission unit to be included in a statistical analysis to develop a PM 2.5 

### emission limit, the emission unit must meet the following conditions:

• The measured PM 10 

### emissions from the emission unit must be at or below the PM 10 

### stack limit in the most recent PM 10 

### performance test conducted pursuant to Minn. R. ch. 7017.

• The Permittee must demonstrate that the operatio n and maintenance requirements imposed by this permit have been applied to the emission units for at least the previous six months. The emission units must be in compliance with the operation and maintenance requirements at the time of testing.
Emission Limit – The allowable emission rate authorized by a permit or a rule for a pollutant emitted from a process or stack.
Event – Indicates a set of stack gas sampling test runs associat ed with a specific stack or specific group of stacks conducted on a particular date. The runs in an event may be data submittal engineering tests as defined in Minn. R. 7017.2005, subp. 2a. Fuel Type – The indurating furnace is authorized to burn natural gas only. Group – For statistical purposes, test data are aggregated by parameters into groups to determine if statistical differences exist. Specific data gro ups (i.e., parameters) addressed in th is appendix are Event and Fuel Type. However, a data group is a general term and could be us ed to evaluate the effect of other parameters on PM 2.5 

### emissions.
Performance Test – As defined in Minn. R. 7017.2005, subp. 4.
Performance Test Method – The process by which a pollutant emitted from a stack is captured and measured is the stack test method. Source Groups – A strategy of grouping similar material handli ng stacks as described in the Taconite MACT (40 CFR Part 63 Subp. RRRRR, GP 008 of the permit) which prov ides particulate matter emission limits for material handling sources and allowable groupings of similar stacks . A description of the source groupings is given in section 1.2.
Test Run – As defined in Minn. R. 7017.2005, subp. 6. For stat istical purposes, each test run is an individual sample data point.

### 1.1 General Information

• The Permittee shall conduct test-and-set testing in complia nce with all applicable provisions of Minn. R. ch 7017. The stack test method that will be used in a specif ic stack test shall be selected in a pretest meeting between the company and the MPCA’s stack test coordinator. (Pre-test meeting requirements are described in Minn. R. 7017.2030, subp. 4.)

• Air Emission Permit No. 06100067-004 contains both an initial PM 2.5 

### concentration (gr/dscf) limit and an initial PM 2.5 

### mass emission rate limit (lb/hr) for each emission unit capable of emitting PM 2.5 

### . The test-andset testing will be used to set more refined concentr ation and mass emission rate limits for each emission unit addressed in this appendix. The statistical anal ysis of the test-and-set testing will be used to determine a concentration limit as PM 2.5 

### concentrations are not expected to vary with flow rate. Mass emission rate limits will be determined by multiplying the maximum flow rate times the concentration developed using the test-and-set procedure.

• Currently, the solid, filterable fraction of PM 10 

### is typically measured using EPA Method 201A, while the condensable fraction of PM 10 

### is usually measured using EPA Method 202. Method 201A uses a cyclone to separate particles with a diameter of 10 microns or le ss from the larger particles. However, when the gas being tested contains entrained water droplets, Meth od 201A cannot be used. Instead, EPA Method 5 is often used; this method captures all filterable particulates. On March 25, 2009, US EPA proposed a modificati on to Method 201A to measure filterable PM 2.5 

### . Though this modified method has not been promulgated by EPA, it has been used in Minnesota to measure PM 2.5 

### . It is anticipated that Methods 201A and 202 will be the primary stack test methods used to develop PM 2.5 

### emission limits using the test-and-set process. However, when the gas being tested contained entrained water droplets, it is likely that EPA Method 5 will be used to measure the filterable portion of the particulate matter. The selection of the test method is subject to review and change. The test methods that will be used in these tests will be set pursuant to Minn. R. ch. 7017. (See the first bullet in this section.)

• The Permittee may group test data by event to analyze statistical variability between events.

• The application for a major permit amendment shall contain proposed PM 2.5 

### emission limits for all units identified in Table 1, as applicable based on constr uction process. DRI and Steelmaking units will need to be tested once in operation as specified in the permit.

• Stack test reports and data analysis reports shall be pr epared after each stack test mobilization effort such that multiple testing events conducted during the same mobilization effort (typically 1-2 weeks) would be combined into a single report. The reports shall include data on process operating conditions, CEMS data, ore analysis, and other data to assist in interpretation of the stack test results and statistical calculations as appropriate.

• The statistical analyses and proposed PM 2.5 

### emission limits shall be reviewed with MPCA prior to submitting an application for a major perm it amendment to incorporate the limits.

### 1.2 Source Groups

In Lieu of performing stack tests on all of the material handling sources, the Permittee has elected to define source groups for the stacks listed in GP 008 of this permit, as allowed by 40 CFR 63.920(e), each group may contain no more than 6 stacks. A group of material load ing sources is also identified for the stacks listed in GP 016. Each source that is part of a group is controlled by a baghouse. The following groups have been identified.

• Group A/B/C – Ore Crushing, Grinding and Handli ng – Crushing, grinding and handling or ore and concentrate will be included in Groups A-C. The ma terial handled by these sources contains a higher amount of fine material. However, there are no expected condensables and the discharge from the control equipment is expected to be primarily PM 2.5 

### .

• Group D – Finished Pellet Handling – Finished pellet handling units from pellet reclaim through pellet loading will be included in Group D. The composition of particulate handled in these processes is expected to be fairly similar. No condensables are expected.

• Group E – Material Loading Bins – Storage, loading, and unloading for units which store materials used at the facility.

1.3 PM 2.5 

### Test Groups and Individual Stacks

Table 1 – PM 2.5 

### Test-and-Set Stacks/Groups Group ID Description EU IDs SV IDs Group A Ore Crushing , Grinding, and Handling EU 002, 004, 013, 014, 015, 018, 167 SV 001, 002, 006, 007, 008, 009 Group B EU 022, 024, 036, 037, 042, 106, 176 SV 010, 011, 016, 017, 022, 084 Group C EU 170, 171, 172, 173, 174, 175 SV 085, 086, 087, 088, 089, 090 Group D Finished Pellet Handling EU 040, 041, 048, 054, 060, 063 SV 020, 021, 023, 027, 031, 073 Group E Material Loading Bins EU 028-35, 044, 045, 052, 053, 115-124, 177, 178 SV 014, 015, 039, 040, 041, 042, 043, 059, 072, 091, 092 Individual Stacks

Furnace Hood Exhaust EU 038 SV 018 Furnace Waste Gas EU 039 SV 019 DRI Depressurizing Scrubber EU 064 SV 029 DRI Process Gas Heater EU 066 SV 030 EAF Baghouse EU 125-129 SV 044 Tunnel Furnace EU 138 SV 051 DRI PTS Depressurizing Scrubber EU 070 SV 063 DRI Screening & Handling EU 088 SV 070

### 2.0 Test-and-Set Procedure

Concentration emission limits shall be set for each source group and individual stack identified in Section 1.3. If PM 2.5 

### concentrations are found to be similar across sour ce groups, the Permittee may propose to combine source groups for the pur pose of establishing PM 2.5 

### concentration limits. Initially, two test events shall be completed for each gro up/individual stack identified in Table 1. For each group, more than one stack shall be tested for each of the two separate tests. The goal of the testing is to conduct a sufficient number of sample runs to obtain enough samples to capture the variability in emissions associated with properly operated equipment. From these data, an emission limit can be established. Figure 1 is a decision flow chart for determining the num ber of test events to be conducted for establishing the PM 2.5 

### emission limits. As shown in Figure 1, Event 1 and Even t 2 shall consist of six runs per stack. The six runs shall be conducted during the same stack test mobilization pe riod (i.e. event). Completion of six runs will require a minimum of two days to complete. Additional testing ev ents indicated in Figure 1 sh all consist of three runs per event. The outcome of the statistical analysis of the initial stac k testing will be a determination of the variability of the test results. If the variability of the data from the initia l stack testing meets certain statistical conditions (described below), no further testing is necessary before proposing the PM 2.5 

### emission limit. Test results with variability above these criteria indicate that more te sting is necessary before proposing the PM 2.5 

### emission limit. Prior to accepting the stack test results as indicative of ‘in-control’ operations, th e performance of the control equipment and other operating metrics shall be verified. For the filterable component of PM 2.5 

### , the PM 10 

### performance criteria will be used to de termine the ‘in-control’ condition for PM 2.5 

### . Specifically, all manufacturer recommendations for PM 10 

### control will be verified.
For those individual stacks where condensable PM 2.5 

### emissions are expected to be present, CEMS data shall be used to determine the efficacy of SO 2 

### control equipment operations at the stack outlets. NO x 

### control shall be optimized through burner technology.
2.1 Sampling Events

The Permittee shall conduct a minimum of six runs per ev ent for at least two events for each group/individual stack subject to the test and set requirements, resulting in a minimum of six sample runs. The stack test mobilizations may be different for the different groups.

• Two stacks from each group shall be tested on diffe rent days during the same test event (i.e. within approximately one week).

• The test events on the furnace stacks (SV 018 and SV 019) shall be conducted simultaneously.

• Conduct two sampling events (Events 1 and 2).

• Calculate the 95% UCL (Upper Confidence Limit for the mean) to establish the PM 2.5 

### concentration limit.

• Conduct two-sample t-test (see Section 2.2.2) to dete rmine if there are significant differences between events.

• Determine acceptability of results for setting PM 2.5 

### emission limits.

• If the statistical analysis indicates that an additi onal sampling event is required (see Section 2.2.3.2), stacks shall be tested as described in the first two bulle ts in this section as applicable. This third event only requires three sample runs.

### 2.2 Test-and-Set Statistical Analysis

2.2.1 Calculation of 95% UCL



## n s t UCL n 

## ⋅ + = − − )

1
, 1 ( α 

## μ

Where: UCL = Upper Confidence Level for the mean concentration μ = average concentration for n samples

α = confidence level (= 0.05 for 95%) n = number of samples (12 for 2 events) s = sample standard deviation t (n-1, 1- α ) 

### = t-statistic for given n, α (note: this is a one-tailed t-statistic) = 2.015 for n = 6, α = 0.05 = 1.796 for n = 12, α = 0.05
2.2.2 Two-sample t-test

The two-sample t-test shall be used to determine if ther e is a statistically significant difference in the mean PM 2.5 

### concentration between stacks within the same group, or between two sampling events. The two-sample t-test is based on the pooled estimate of the standard deviation. The t-statistic shall be calculated and compared to the tabulated t-value for the appropriate significance level a nd degrees of freedom. If the calculated t-statistic is greater than the tabulated t-value, then it shall be conc luded that there is a statistically significant difference between the mean concentrations.

• Calculation of two-sample t-test:

B A p B A calculated



## n n s X X t 1 1 ) ( 

## +
⋅ Δ

− −
=



## 2 ) 1 ( ) 1 ( 2 2



## − + ⋅ − +
⋅ −
=

B A B B A A p 

## n n s n s n s

Where: X A 

### = mean (average) concentration for Event 1 samples X B 

### = mean (average) concentration for Event 2 samples Δ = hypothesized difference between the means = 0

n A 

### = number of samples from Event 1 = 6

n B 

### = number of samples from Event 2 = 6

s p 

### = Pooled Standard Deviation

s A 

### = standard deviation of Event 1 samples

s B 

### = standard deviation of Event 2 samples

• If t (calculated) 

### > ) 2 / 1
, 2 ( α

− − + B A n n 

## t , then the means of the events are significantly different.

Where:

) 2 / 1
, 2 ( α

− − + B A n n 

## t = 2.776 for n A 

### + n B 

### - 2 = 4, α = 0.05

### 2.2.3 Review of Initial Statistical Analysis

There are two components to determining if the initial statistical analysis results are acceptable for setting a PM 2.5 

### emission limit:
1. The PM 2.5 

### limit should be less than the PM 10 

### limit, and 2. There should be no statistically significant differences in PM 2.5 

### concentrations for sources within the same group. If after two sampling events the variability of the test re sults exceeds the acceptable threshold, one additional sampling event shall be conducted. If, after the third sa mpling event, the variability of the test exceeds the acceptable threshold, the Permittee shall subm it a plan to the MPCA for establishing the PM 2.5 

### emission limits.

2.2.3.1 Threshold for Initial Statistics
If 95% UCL < PM 10 

### limit and the two-sample t-test shows no signi ficant difference between events, the statistical results shall be deemed acceptable for setting a PM 2.5 

### emission limit. For each group/stack that meets these criteria, the application to the MPCA for a major permit amendment shall include a proposal of a PM 2.5 

### limit = 95% UCL.
If 95% UCL < PM 10 

### limit and the two-sample t-test exceeds the threshold for a significant difference between events, the Permittee shall conduct a third sampling event.
2.2.3.2 Statistical Analysis Based on Two Sampling Events
If 95% UCL > PM 10 

### , then conduct a two-sample t-test. If the two-sample t-test shows no significant difference between stacks (or events), the Permi ttee shall conduct a third sampling event. Following completion of the third event, recalculate 95% UCL (Section 2.2.1), with the following adjustments: n = number of samples for 3 events
t (n-1, 1- α ) 

### = 1.860 for n = 9, α = 0.05 = 1.740 for n = 18, α = 0.05, or adjusted as appropriate Also, conduct two two-sample t-tests. In test one, compar e Event 1 (Stack 1 and 2 combined) to Event 2 (Stack 1 and 2 combined). In test two, compare Stack 1 (Event 1 and 2 combined) to Stack 2 (Event 1 and 2 combined). Reevaluate statistics (Section 2.2.3.3)

2.2.3.3 Review Results of Statistical An alysis Based on Three Sampling Events The Permittee shall prepare and submit a major amendment application to propose PM 2.5 

### limits as follows: 1. For each group/stack in which the 95% UCL < PM 10 

### limit: a. Propose a limit of PM 2.5 

### = 95% UCL (all tests combined) if the two-sample t-test shows: i. There is no significant differences between events or groups/stacks; or ii. Significant differences exist between events but not between groups/stacks. b. Propose a limit for each group/stack of PM 2.5 

### = 95% UCL (using only test runs on the group/stack) if the two-sample t-test shows significant di fferences exist between groups/stacks. 2. For each group/stack in which the 95% UCL > PM 10 

### limit, determine the average emission rate for each set of three sampling runs (i.e., for each gro up, average sampling runs 1, 2 & 3; 4, 5 & 6; 7, 8 & 9; etc.). Compare the average emission rate for each three-run set to the PM 10 

### emission limit. Propose PM 2.5 

### limits as follows: a. Propose a limit of PM 2.5 

### = initial PM 10 

### if the average of each three-run set ≤ PM 10 

### limit; or b. Propose an increased PM 2.5 

### limit based on the test results if the average of each three-run set > PM 10 

### limit.
The Permittee shall submit all test data collected in the test-and-set testing required in this appendix in the application to the MPCA for a major permit amendment.

### 3.0 Reporting

The application for a major permit amendment shall cont ain an update to the BACT analysis and the proposed PM 2.5 

### emission limits for all units identified in Table 1, as applicable based on the stage of construction. The amendment will be processed as a PSD permit modification. Stack test reports and data analysis reports shall be prep ared after each stack test mobilization effort such that multiple testing events conducted during the same mobilizat ion effort (typically 1-2 weeks) would be combined into a single report. The reports shall include data on proc ess operating conditions to assist in interpretation of the stack test results and statistical calculations. The statistical analyses and proposed PM 2.5 

### emission limits shall be reviewed with MPCA prior to submitting an application for a major permit amendment to incorporate the limits.
4.0 Sampling Event Scheduling

Stack sampling events require time betw een events to account for seasonality effects. Time is also required to conduct the analytical components of the stack test, conduc t the statistical analysis, and prepare the stack test report. In addition, the currently proposed stack test method for PM 2.5 

### cannot reliably be conducted during very cold weather. Other factors which may influence the timing of stack tests include market forces (i.e., production). In general, the stack testing schedule shall be as follows:

• If necessary, conduct each additional event (e.g., Even t 2 for Groups A, B, C and D) no less than 120 days and no more than 240 days after Event 1.

• Maintain a similar schedule between stack tests for additional sampling events as necessary. While the test-and-set program is in progress, compliance with the initial PM 2.5 

### emission limit shall be determined by conducting either a PM 2.5 

### performance test or a PM 10 

### performance test to demonstrate compliance with the initial PM 2.5 

### emission limit.

### Figure 1 – Test-and-Set Flowchart

### APPENDIX F Calculation Facility Name: Essar Steel Minnesota LLC Permit Number: 06100067-004

Converting ppm to lb/hr

6 

## 10 75

. 3 − 

## × ⋅ ⋅ ⋅ = j i i i 

## V V MW c E

Where: E i 

### = Emission Rate of pollutant i, lb/hr

c i 

### = Emission Rate of pollutant i, ppm V j 

### = Gas flow rate in stack j, dsfcm MW i 

### = Molecular weight of pollutant i, g/mol 

## V = 24.04 g/mol

3.75x10 -6 

### = combined conversion factor: 

## ⎟ ⎟ ⎠ ⎞ ⎜ ⎜ ⎝ ⎛ ⎟ ⎠ ⎞ ⎜ ⎝ ⎛



## ⋅ 3 

## 2808

. 3 4

. 453592 / min 60


## m ft lb mg hr

V MW c i

i 

## ⋅ computed as specified above has units of mg/m 3

### APPENDIX G Insignificant Activities Facility Name: Essar Steel Minnesota LLC Permit Number: 06100067-004

The table below lists the insignificant activities at the fa cility and their associated general applicable requirements.

Minn. R. 7007.1300 Description of Activities at the Facility Applicable Requirement subp. 3(C) Fabrication operations : equipment used exclusively for forging, pressi ng, drawing, spinning, or extruding hot metals . Minn. R. 7011.0715 subp. 3(E) Storage tanks: (1) Gasoline storage tanks with a combined total tankage capacity of not more than 10,000 gallons; and (2) Nonhazardous air pollutant VOC stor age tanks with a combined total tankage capacity of not more than

10,000 gallons of nonhazardous air pollutant VOCs and with a vapor pressure of not more than 1.0 psia at 60°F. subp. 3(H) Miscellaneous: (1) Equipment used exclusively for packaging lubricants or greases; (2) Equipment used for hydrau lic or hydrostatic testing; (3) Brazing, soldering, or welding equipment; (4) Blueprint copiers and photographic processes; (5) Equipment used exclusively for melting or application of wax; (6) Nonasbestos equipment used exclusivel y for bonding lining to brake shoes; and (7) Cleaning operations: alkaline/ phosphate cleaners, associated cl eaners, and associated burners. Minn. R. 7011.0110

subp. 3(I) Individual emission uni ts at a stationary source, each of which have a potential to emit the following pollutants in amounts less than:

(1) 4,000 lb/yr of CO; and (2) 2,000 lb/yr each of NO x , SO 2 , PM, PM 10 , VOCs (including hazardous air pollu tant-containing VOCs), and ozone. Minn. R. 7011.0715 Minn. R. 7011.2300

subp. 3(J) Fugitive dust emissions from unpaved entrance roads and parking lots. subp. 3(K) Infrequent use of spray paint equipment for routine housekeeping or plan t upkeep activities not associated with primary production processes at the stationary source, such as spray pain ting of buildings, machinery, vehicles, and other supporting equipment. subp.4 Individual sources at the facility which has potential emissions below the following: A. 5.7 lb/hr CO B. 2.28 lb/hr PM, PM 10 , NO x , SO 2 , and VOCs C. 1.0 tpy combined HAPs D. 10,000 tpy CO 2 e Minn. R. 7011.0715

FS 001 - Drilling FS 002 - Overburden Loadout FS 003 - Overburden Unloading (Truck) FS 004 - Waste Rock Loadout FS 005 - Waste Rock Unloading (Truck) FS 011 - Drop onto Cobber Rejects Pile FS 012 - Cobber Rejects Pile Wind Erosion FS 013 - Cobber Rejects Pile Loadout FS 014 - Cobber Rejects Unloading (Truck) FS 015 - Cobber Rejects Stockpile Wind Erosion FS 019 - 120K ton Concentrate Stockpile Loading FS 020 - 120K ton Concentrate Stockpile Wind Erosion FS 021 - 120K ton Concentrate Stockpile Loadout FS 022 - DRI Stockpile Stacking Conveyor FS 023 - DRI Stockpile Wind Erosion FS 026 - Oxide Product Stockpile Stacking Conveyor FS 028 - Oxide Fines Bin Discharge FS 029 - Oxide Fines Return to Regrind Mill FS 030 - DRI Drop into Remet Bunker FS 031 - DRI Remet Bunker Wind Erosion FS 032 - DRI Remet Return to DRI Reclaim Hooper FS 033 - Oversize CDRI Drop Into Bunker FS 034 - Oversize CDRI Bunker Wind Erosion FS 035 - Oversize CDRI To EAF By Scrap Bucket FS 036 - DRI Railcar Loading FS 037 - CDRI Drop Into EAF Feed Collection Chute Line 1 FS 039 - Lump Lime / Carbon Unloading FS 040 - Lime / Carbon Bucket Elevator FS 041 - Lime / Carbon Tripper Conveyor Drop FS 042 - Slag Dumping FS 043 - Digging Pits / Breaking Slag FS 044 - Grizzly Stockpile Loading FS 045 - Grizzly Stockpile Wind Erosion FS 046 - Grizzly Stockpile Loadout FS 047 - Grizzly Loading FS 048 - Grizzly Oversize to Slag Dumping FS 049 - Grizzly / Feeder FS 050 - Slag Transfer Conveyor FS 052 - Screened Slag Conveyor FS 053 - Screened Slag Cobber FS 054 - Non-Metallics Stacker 1 FS 055 - Non-Metallics Stacker 2 FS 056 - Metallics Stacker 1 FS 057 - Metallics Stacker 2 FS 058 - Crusher FS 059 - Crusher By-pass Conveyor FS 060 - Crushed Slag Cobber FS 061 - Crushed Metallics Stacker FS 062 - Crushed Non-Metallics Screen FS 063 - Crushed Non-Metallics Stacker 1 FS 064 - Crushed Non-Metallics Stacker 2 FS 065 - Metallics Return to EAF FS 067 - Processed Slag Piles Wind Erosion FS 069 - Non-Metallics Slag Stockpile Wind Erosion TK 001 - Off-Road Diesel Fuel (900,000 gallons) TK 002 - Off-Road Diesel Fuel (900,000 gallons)

### APPENDIX H Process Flow Diagram Facility Name: Essar Steel Minnesota LLC Permit Number: 06100067-0040 0 n: LEGEND

,----------, I DUST I CONTROL I

I BOUNDARIES 1 L

____ _j

SVOOB OPTIONAL MAGS

NON-MAGS**~U013---------------­**

I SV006

## :a::::::==~==~:_-=:=:::rq==Df**~----------------------_j**

# L()----~1 

# =-1 L=

.. ---

PLANT FEED CONVEYORS 2 1 I
I I I

I EUO 15 COARSE ORE CONVEYOR GALLERY I**L_--------------------------~**

TO PRIMARY GRINDING MILLS (3) SV002

,-------------------------**----~**

EU004 GRIZZLY SCREENING BUILDING

SV085 I I I I I
I I I I I I
I

L

___________________________**~**

## [~**r~ [~** **[~**

## ccr>::::::::::::::~~) () ()

SV009

EU018 FINE ORE CONVEYOR GALLERY L

____________________________ _

-

## Pro~~ff~GINEERING CO. Scale NONE Date 01/28/11 

# BARR 4700 WEST 77TH SlREET Drown RLG MINNEAPOLIS, MN. 55435-4803 Checked 3 Corporate Headquarters: Ph: 1-800-632-2277 Designed Minneapolis, Minnesota Fax: (612) 832-2601 Ph: 1-800-632-2277 www.barr.com Approved**~** 1-N-0-t. -BY--t-H-K-tN'-P+--DI\-:rE-+----R-EVI_S_IO_N_D_E_S_C_R_IPTI_O_N----1 DATE

___ REG. " 0 '----- I I I EXTERNAL ROOF

ORE DUMPING TO CRUSHER



### --, I I
: · . :. I LOADING & HAULING

DRILLING OVERBURDEN LOADOUT OVERBURDEN UNLOADING (TRUCK) WASTE ROCK LOADOUT WASTE ROCK UNLOADING (TRUCK) CRUDE ORE LOADOUT HAUL ROAD EMISSIONS SERVICE ROAD EMISSIONS OVERBURDEN/WASTE ROCK AREA WIND EROSION OVERBURDEN/WASTE ROCK DOZER ACTIVITY PAVED ROADS I I I I I I /r-------------------------------l

L

__________ _j / / /

BIN

EU172 SECONDARY SCREENING CRUSHER/COBBLER LINE 1 EU173 SECONDARY SCREENING

CRUSHER/COBBLER LINE 2 EU174 SECONDARY SCREENING

CRUSHER/COBBLER LINE 3 EU175 SECONDARY SCREENING

CRUSHER/COBBLER LINE 4 BLASTING

FS001 FS002 FS003 FS004 FS005 FS006 FS007, CE057 FSOOB, CE058 FS009

FS010 FS070, CE051

SV087, SVOBB, SV089, SV090 DRILLING**L--------------------------------------------------~** SV086

r--- ------, I EU171 I
I WEAK OR I

I NON-MAGNETIC 1 

# !

_____ 

# ,:::_+f--l

__ _j

TRUCKTO**~ ~STEROCK** 

# ~-ST_O_C_KP_IL-E**_lJ~LL_l.l.l_...:;..~="::~L._** __

COBBER REJECTS LOADING & HAULING FS013 COBBER REJECTS UNLOADING FS014 STOCKPILE WIND EROSION FS015



# &

· · . ·

. ·

. ·

.**··.~**

COBBER REJECTS STOCKPILE

DWG. No. REV. No. 

### A= OPTIONAL



### ,----, I DUST I I CONTROL I I BOUNDARIES I

L_

____ _j

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1Eua22 L:1NE: -,-PRiMARY 8RINoiN8 -MTLC ' 1 I EU024 LINE 2 PRIMARY GRINDING MILL IEU176 LINE 3 PRIMARY GRINDING MILL I WATER FROM -f----------, PLANT HEAD TANK I I I
MILL I DISCHARGE!

I I I I

I I I I I

I I I I

I I SV010 SV011 SV084

/**~----_j** I #1 ROUGHER {13) {MAGNETIC SEPARATION) L

___________ _j

PRIMARY MILL DISCHARGE SUMP {2) SV012

EU026

FIRE WATER

PUMP

SV013

EU027 FINISHER FEED DISTRIBUTOR FLOTATION CHEMICAL---- WATER----- FLOTATION CHEMICAL

,------- WATER



# ,,,-{]

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0 c: CYCLONE FEED SUMP EMERGENCY POWER GENERATOR

TAILINGS BASIN BULLDOZING GRADING

TAILINGS BASIN FINISHER CONCENTRATE SUMP
SCREEN UNDERSIZE SUMP

THICKENED TAILINGS CONCENTRATE SUMP

FROM CONCENTRATE THICKENER OVERFLOW

### ~,**t--,::+=+:=+=~==========~;-;;;;;;;;:;-;;;;;:::;;-;;;:;;,;;;;-Jmr:::::::::r:::r::::r:::::r:::::ll=l:::r::::Jiiiiiiiii.-;;;;-;;;;;:;--~~~~---------r-~~~~~~-;:;:;:;:------y'BiiR'R'PiWJECTi~---i ~**  J-- I HEREBY CERTIFY THAT THIS PLAN WAS PREPARED CUENT 

### IRON ORE PROCESSING PLANT BARR PROJECT No. 

# :**1-1-=~~=~~==~::t:::::t::::::::::::::::::::::::::::~ ~A~EA** **o~u~~o~:G,~~~oE';R~~~~:,~~~ ~g,J:~** **~~~~;Nsjimji;u;;;ci;TIO~N~==~~::t::~==~~::t::~::~** ESSAR STEEL MIN N ESQTA LLC 23311 0 13.0 1 -

## Pco~~ff~~GINEERING CO. Scale NONE

UNDER THE LAWS OF THE STATE OFMINNESOTA.r I, .__ _______ N_a_s_h_w_a_u_k_,_M_in_n_e_s_o_t_a

______ --ICLIENT PROJECT No.

### ~ t--tr---11--t--t--t------------1

### l==:::t~kk:k:t:;::t;:t:::;::l~;:~~~ FIGURE 3 r PREUMINARY PROCESS FLOW DIAGRAM**~r-t--r_,--t----i------------------------~ R~m** **~A~~B~C~~O~~~~~** " NO. BY HK APP DAlE REVISION DESCRIPTION DATE

___ REG. No•----- TO/FOR DAlE RELEASm FIGURE 3

- SHEET 2 Date 01/28/11 

# BARR 4700 WEST 77TH SlREET Drawn RLG MINNEAPOUS, MN. 55435-4803 Checked 2 3 Corporate Headquarters: Ph: 1-800-632-2277 Designed Minneapolis, Minnesota Fox: (612) 832-2601 Ph: 1-800-632-2277 www.barr.com Approved REV. No. 

### A DWG. No.E**~** 0



# . 0 c:**~** I SV092 SV091

SV019 WASTE GAS

STACK DUST**COLLECTOR~----------------------------------------~**

GREEN BALLS (WET) FROM BALLING DRUMS

SV022

L--- MULTI CLONE

WINDBOX EXHAUST FAN

SV017

DUST COLLECTOR

TD INDURATION THICKENER SV016

DUST COLLECTOR

CE014



## ,- ------,**~** FROM SCREENING

EU106 OXIDE PELLETS TRANSFER

EU036 DUST COLLECTOR

CE016

HOOD EXHAUST FAN

EU038 COLLOCATED STACKS

SV018 HOOD EXHAUST STACK

EXHAUST GAS MAIN DUG

DUST COLLECTOR CE027

EU044 PELLET PLANT COATING POWDER STORAGE BIN

BLOWER

1-N-0-t. -BY-;-H-K-tAP-P+--DA-:rE-+----R-EVI_S_IO_N_D_E_S_C_R_IP_TI_O_N

__ --1 DATE

___ REG. " 0 '----- 2 3 COATING POWDER DAY BIN ROOF B006

EU039

-

## Pm~~ff~~GINEERING CO. COATING SLURRY TANK

Scale
Date 

# BARR 4700 WEST 77TH STREET Drawn MINNE'APOUS, MN. 55435-4803 Checked Corporate Headquarters: Ph: 1-800-632-2277 Designed Minneapolis, Minnesota Fox: (612) 832-2601 Ph: 1-800-632-2277 www.borr.com Approved AMBIENT AIR

SCREENINGS TO REGRIND

- CONVEYER 1

PELLET COATING SPRAY

NONE 01/28/11

RLG SV024 

# """ {J

EU049

FIREWATER BOOSTER

PUMP

SV025

mcm 

# {J

EU050

FIREWATER

PUMP

SV026

mmc 

# {J

EU051

EMERGENCY

POWER GENERATOR

PELLET DISCHARGE EU040 

### ,------, I DUST I I CONTROL I I BOUNDARIES I L

____ _j

SV020

SV021



# ---,

TO HEARTH LAYER**d====~~** FEED BIN

I I I I I I I EU041 PELLET SCREENING AND HANDLING I L

_______________________**~** OPTIONAL FLOW PATH

OXIDE PELLETS TO STOCKPILE FS026

DWG. No. REV. No. 

### A0 0 a: .-------------------------------, I I I I I I

DRI AREA COATING POWDER STORAGE BIN DRI AREA COATING POWDER DAY BIN I I

,---------------------, FROM OXIDE PELLET STOCKPILE 

# t

I .-+----_j CONVEYOR GALLERY 

### ho-------t:-----_,(._..)**6~~5E4 ~E~L~NE**  1 SCREENING & HANDLING

SV023 FS032

FROM REMET BUNKER'\ SV073

EU060 DRI LINE 1 PELLET SILOS**;~R~~g~CTION** I**,..---------------<r,_-_-_-_-~--E-;;-0~3- -----~**  I I**-------------------------~** I I

OXIDE PELLETS FROM PELLET PLANT I I I L

_______ _

PELLET COATING DRI RECLAIM HOPPER

-------------- 

# -----, J I 

### () lXI 

# q

I I I I I I I I I I

### '-L-r-----~-------~~OL-----~(>t : SV070 

# I

BIN AREA WET SCRUBBER CE105 

# t 01

OXIDE PRODUCT STOCKPILE 

# j L----- _'-_L-_-_-_-_-_-_-_-,------loo.(

# ~ I I**,---------------------------~** STACKING CONVEYOR FS026, CE066 STOCKPILE WIND EROSION FS025, CE065



# ,-----

1 I I L

____ --,

TO OXIDE II (

.... ).__

_________**~** DAY BINS

- ' PELLET I SCREENING I I I I EU048 OXIDE PELLET STOCKPILE CONVEYOR GALLERY I L

_______________________**~** I FS027, CE067 1 I

LOADING FINES TO REGRIND MILL FS029 I I I

COLD

# DRI['(-~~~-~;2;2=====================================:t=:FS:0~3=~=-=-=-=-=-=_:1t_:FS:_:O-;-:O:_:_=_:_=_=_:_D_-- t**~ ~%J:s~CK~** **~ ~** **FS024~** DRI RECLAIM TO MELT SHOP

## ~ "FS035 OVERSIZE REMET

## BUNKER~ FS034 FS031 RETURN TO DRI RECLAIM HOPPER FS032

SV075 illEtill

----------- = OPTIONAL**r-;;c-ST---~** I CONTROL I

### ~~~~~sj FROM DRI EXTERNAL COOLER AND PTS -----1 SCRUBBER EU162

- Project Office: Scale NONE BARR ENGINEERING CO. Dote 09/13/11 

# BARR 4700 WEST 77TH STREET Drawn RLG MINNEAPOLIS, MN. 55435-4803 Checked 3 Corporate Headquarters: Ph: 1-800-632-2277 Designed Minneapolis, Minnesota Fax: (612) 832-2601 Ph: 1-800-632-2277 www.barr.com Approved I l

_______________________ j

I I

SV076

EU161

HOT WATIER RETURN**FROM-~-----~**

DRI PLANT COOLING TOWER TO DRI PLANT SV005

COOLING TOWER

CE005

MAKEUP WATER FROM DRI CLARIFIER SV063

EU012

SLOWDOWN TO INDURATION

THICKENER TO ELIECTRIC ARC FURNACE PTS GAS COMPRESSOR SV031

SV030

SV034

4EU110

FIREWATIER BOOSTER PUMP DRI AREA

SV035

# ~ru"' FIREWATER SUPPLY PUMP

SV036 

# ---{]rum

EMERGENCY POWER GENERATOR

SV037

# ~rum FIREWATER BOOSTER PUMP DRI AREA OFIFICES

DWG. No. REV. No. 

### A0 c: CARBON DAY BIN EU120 SV041 FS041 TRIPPER CONVEYOR

CALCINED LIMESTONE (CaD) STORAGE BIN

SLAG/USED REFACTORY STOCKPILE SV040

EU117 QUICKLIME DAY BIN EU116

# ~D~**~~~~ ~n**  nn

# FS0471LK~~**////\\~** c5Q_():j

FS045 FS044 CE071 CE070 SLAG DUMPING FS042, CE068 DIGGING PITS/BREAKING SLAG GRIZZLY RETURN TO FS043, CE069 SLAG DUMPING FS048, CE073

# ~FS050,**~S051,** CE076 CE075

FS052, CE077

# l~SCREEN
FS062 

# n

CE087**~** 

# I

# ~~ CE089 CE088 EXTERNAL SCRAP FOR PERIODIC COLD ------1 START-UPS

L_

__________

## ~---------**~------~~~0 ~** **1_5\;,:)·-''\~.:J** METALLIC

FS068 TO OFF SITE SALE OR STOCKPILING 

# l**~~~· ~**  :______:/"'<..../ '<.;../ FS066, CE091 NON METALLIC SLAG STOCKPILE/WIND OR STOCKPILING FS069 METALLIC STOCKPILE RETURN PROCESSED SLAG PILE/WIND EROSION TO EAF FS067, CE092

LEGEND

·------------ OPTIONAL FLOW PATH**D~s~---~** I CONTROL I I BOUNDARIES I L

_____ _j SV043 SV039

AIR RELEASE SV042

LUMP ADDITIVE DELIVERY FS039

HYDRATED LIME [Ca(OH),] STORAGE BIN BAUXITE STORAGE

BIN

'EU124 L ()I

___ 

## j

PNUEMATIC ADDITION OF SLAG ADDITIVES

ALLOYS
O+N+Ar 2 2
NATURAL GAS

WATER
SCRAP/ SLAG METALLICS VIA SCRAP BUCKET

SLAG TO SLAG PROCESSING

MAKEUP WATER COMPRESSED AIR

NEW REFRACTORY LINING
SLAG TO SLAG POT

SV048

WATER TREATMENT

PLANT INDIRECT COOLING TOWER CE044

EU132

SV054 BLOWDOWN TO SUMP FLUORSPAR STORAGE

BIN

HOT WATER RETURN

COOLING WATER TO EAFs, LADLES, CASTERS AND MILL

LADLE/ TUNDISH PREHEATERS (20 BURNERS) EU128 WATER COOLED DUCT

DROP OUT SLAG TO SLAG PROCESSING

Fe ALLOYS & LANCE COMPRESSED AIR NATURAL GAS COOLIING WATER NEW REFRACTORY

LADLE SKULL**~--NATURAL** GAS CE041 LOW NOx BURNER**TR~i~~NT ~go~~~E~~TER**  -------------1....

2 3 MAKEUP WATER PLANT DIRECT COOLING TOWER HOT WATER RETURN**~-----------I-..-** CE055

EU141 

## y

BLOWDOWN
TO SUMP

-Project Office: Scale BARR ENGINEERING CO. Date 

# BARR 4700 WEST 77TH STREET Drawn MINNEAPOUS, MN. 55435-4803 Checked Corporate Headquarters: Ph: 1-800-632-2277 Designed Minneapolis, Minnesota Fox: (612) 832-2601 Ph: 1-800-632-2277 www.borr.com Approved NONE 09/13/11

RLG HEAT EXCHANGER

TUNDISH SKULL DUST & GASES BAGHOUSE CE040

CASTING POWDERS
COMPRESSED AIR
NATURAL GAS
COOLING WATER
GREASE Ar, 0 2 WATER

ROTARY SV044

RECYCLE TO EAF

OR LANDFILL

EU127 LINE 1 CASTING AREA

USED REFRACTORY

RETURN WATER TO
WATER TREATMENT PLANT (WTP)

DWG. Na. SV047

SV045

NATURAL GAS

REV. Na.



### A**~** NO. BY CHK fof'P DATE LUBE AND HYDRAULIC OIL COMPRESSED AIR
NATURAL GAS

RETURN WATER TO WATER TREATMENT PLANT (WTP)

SCALE TO GROUND SV051

SCALE SCALE SCALE 

# s

LUBE AND HYDRAULIC OIL COMPRESSED AIR
ROLLING OIL
COOLING WATER ROOF VENT 

# 2

GREASE & OILS TO MANAGED DISPOSAL

SCALE, GREASE AND OIL

TRANSFER TO GREASE & OILS

COMPRESSED AIR
COOLING WATER

BANDING/MARKING

# ~~~"'''**~** RETURN WATER TO

WATER TREATMENT PLANT (WTP)

SCALE PIT

SCRAP SCRAP IN-HOUSE**~----------------------------------------------~--~~~**

SCRAP SV056 

# "5a-D
EU143

FIREWATER BOOSTER

PUMP

SV057 

# "5a-D
EU144

FIREWATER SUPPLY PUMP

SV05B 

# "5a-D
EU145

EMERGENCY

POWER GENERATOR

2 3 DATE

_______ REG. NOI

__________ _ REVISION DESCRIPTION**R~ED ~A~~B~C~~O~~~~~**  TO/FOR DATE RELEASED OFFSITE LANDFILL

SV055 

### 1
HOT WATER FROM WATER ROLLING MILL TREATMENT

PLANT COOLING WATER LAMINAR TO ROLLING MILL MAKEUP WATER**~** COOLING

NA 

# "'CAAC-0 EU165

GAS

SPACE HEATERS

-

### Pco~~ff~~GINEERING CO. 

# BARR 4700 WEST 77TH SlREET MINNEAPOLIS, loiN. 55435-4803 Corporate Headquarters: Ph: 1-800-632-2277 Minneapolis, l.olinnesotc Fax: (612) 832-2601 Ph: 1-800-632-2277 www.borr.com Scale

Date
Drawn

Checked
Designed Approved NONE 01/28/11

RLG TOWER
CE056
EU142 

### 1
BLOW DOWN TO SUMP CRANE

# ~**~** STRAPS 

# I

COIL/SLAB STORAGE RAILROAD SHIPPING (90%)

, ______ j
, 

# A Jd

TRUCK/HIGHWAY SHIPPING (10%)

LEGEND**~--------1**
I DUST : I CONTROL

: BOUNDARIES : l

________ l OPTIONAL FLOW PATH

DWG. No. REV. No. 

### A

### Technical Support Document, Permit Action Number: 06100067-004 Page 1 of 22 Date: 5/10/2012 

### TECHNICAL SUPPORT DOCUMENT For AIR EMISSION PERMIT NO. 06100067-004

This technical support document (TSD ) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit.

1. General Information
1.1 Applicant and Stationary Source Location Table 1. Applicant and Source Address

Applicant/Address Stationary Source/Address (SIC Code: 3312 ) Essar Steel Minnesota, LLC 555 W 27 th 

### St Hibbing, MN 55746 Essar Steel Minnesota, LLC 17113 County Road 58 Nashwauk, Itasca County Contact: Bradley Anderson Phone: 218-312-1436


### 1.2 Facility Description Essar Steel Minnesota LLC (Essar) is currently in the pr ocess of constructing an approximately $1.6 billion mine mouth electric arc furnace steel mill. The Essar project is located in northern Minnesota, on the western end of the Biwabik Iron Formation (the Mesabi Range) near Nashwa uk, at the site of the former Butler Taconite Mining Company operations. The project has secured the 1.4 billion (long) ton Minera l Resource of the Butler properties and seeks to capitalize on the unique mineralogical characteristics of the iron ore body by vertically integrating all mining and manufacturing processes to produce a finished steel product on one site. The processes involved will use proven technology and be the only fully integr ated steelmaking facility in the United States. Essar will begin operations by mining a new pit, Pit 6, ne xt to Pit 5 where Butler Taconite operations stopped. The mining of Pit 5 will resume after dewatering is co mpleted. The key project features and their nominal capacities are: • An open pit taconite mine capable of mining approximately 24,000,000 tonne/yr of ore. • A crusher, concentrator with associated tailings basin, producing approximately 7,000,000 tonne/yr of
concentrate. • A pelletizer that can produce approximately 6, 500,000 tonne/year of high flux oxide pellets or 7,000,000 tonne/yr of low flux oxide/ DRI grade pellets. • A DRI facility producing approximately 1,800,000 tonne /yr of iron pellets for direct feed for steel production. • An Electric Arc Furnace (EAF), ladle metallurgy fu rnace, slag processing, and a caster to produce 1,500,000 tonne/yr of steel slabs for direct shipment or for onsite rolling to produce hot rolled coil. Essar plans to use natural gas as the process fuel for pelle tizing, direct reduction, and steel making. Diesel fuel will be used to operate mining equipment. The project will demand 450 MW of electric power, which will be supplied by Nashwauk Public Utility. Essar plans to use ore co ncentrating and indurating processes common to existing taconite operations and to employ na tural gas based direct iron reduction. The steel mill will use modern electric

### Technical Support Document, Permit Action Number: 06100067-004 Page 2 of 22 Date: 5/10/2012 

### arc furnace (EAF) and metallurgy furnace technology to equip the melt shop. Unlike most other EAF-based steelmaking operations, Essar will use primarily DRI to charge the EAF. Scrap will only be used in the EAF for initial or post-maintenance startup. There will be no scrap char ge to the EAFs at Essar other than internally-produced, virgin iron, "home scrap".
1.3 Description of the Activities Allowed by this Permit Action The proposed Essar Steel Minnesota Modifications (ESMM) project would include all activities covered in the MSI project including mining, ore processing, direct reduced ir on (DRI) production, and steel-making, but would entail higher taconite pellet production and associated mining a nd tailings generation rates. The project will increase production of taconite pellets from about 3.8 million (mm) metric ton (tonne) per year of low flux pellets suitable for DRI feed pellet to 7.0 mm tonne/yr of low flux pellets or 6.5 mm tonne/yr of high flux pellets suitable for blast furnace grade pellets or any combination in between. The bl ast furnace grade or high flux taconite pellets will be shipped to Essar Steel Algoma in Ste. St. Marie, Ontario Ca nada or sold on the open market. DRI grade or low flux pellets will be used as feed to the DRI process or sold on the open market. The MSI project was permitted for installation of two DRI lines and two steel lines. Essar is pr oposing at this time to permit one DRI line and one steel line to produce 1.8 mm tonne/yr of DRI and 1.5 mm tonne/y r of steel which is consistent with the Master Development Agreement (MDA) between Essar Steel Mi nnesota and the State of Minnesota. However, no physical changes to the DRI or steel mill ar e required to produce at these capacities. The table below is provided to illustrate differences in capacities between the original MSI project and the proposed ESMM project MDA Alternative. Capacity Differences between the Original MSI Pr oject and Proposed ESMM Project MDA Alternative

Unit Operation Type of Pellet Original MSI Project Capacity (mm tonne/yr) Proposed ESMM Project MDA Alternative Capacity (mm tonne/yr)
Taconite Pelletizing Furnace Low Flux (DRI feed grade) 3.8 1 

### 7.0 3, 5 

### High Flux (blast furnace grade) 0 6.5 4, 5


### DRI Not applicable 2.8 2 

### 1.8 6 

### Steel Making 2.5 7 

### 1.5 7

1 

### Pelletizing air emission calculations included a 10% safety fact or to account for the level of detailed engineering that

existed at the time of permitting. Actual capacity used for air emission calculations was 4.1 mm tonne/yr.
2 

### For the original MSI FEIS and Air Permit # 06100067-001, the capa city of the DRI modules was described as 2.8 mm tonne/yr.

However, the MSI air emissions inventory used a value of 3.5 mm tonne/yr plus a 10% safety factor which equates to 3.85 mm tonne/yr. The MSI permit limits and BACT were based on 3.85 mm tonne/yr. The Essar emission inventory uses the capacity of 1.8 mm tonne/yr and the same hourly producti on rates as the MSI air emission calculations and limits.
3 

### Essar will make Low Flux, otherwise known as DRI feed grade pellets for on-site steel making or for sale on the open

market. The quantity of this type of pellet to be produced on an annual basis will depend on internal manufacturing needs and on market conditions.
4 

### Essar will make High Flux, otherwise know n as Blast Furnace grade pellets for Essar Steel Algoma or for sale on the open

market. The quantity of this type of pellet to be produced on an annual basis will depend on internal manufacturing needs and on market conditions.
5 

### An air emission inventory was prepared for both types of pellets to be produced. The maximum value from either

inventory for a given pollutant was used in air dispersion modeling assessments.
6 

### There are no physical changes to the DRI proposed and th ere are no changes to the hourly production rates.
7 

### There are no physical changes to the steel mill proposed a nd there are no changes to the hourly production rates.

### Technical Support Document, Permit Action Number: 06100067-004 Page 3 of 22 Date: 5/10/2012 

### The proposed action modifies the indurating furnace wher e taconite (oxide) pellets are produced. The DRI process is separate from the indurating furnace. The oxide pellets would be transported to an off-site blast furnace or onsite DRI process. In the DRI process the oxide pellets are converted to DRI pellets. There would be no physical change to the DRI process or the steel mill that were prev iously permitted. With regard to analysis of the DRI process, Essar is not proposing any physical change or cha nge to the hourly capacity of the DRI units as described in the MSI FEIS and Air Permit # 06100067-001. Essar began construction on the originally permitted MSI project in October, 2008. Construction began with earthwork and rock excavation for all facility building and concrete foundations for primary crushing, mill bay tunnels, slurry tanks and balling discs and filters as well as infrastructure for the project. No construction activities associated with the 4 th 

### secondary crushing unit, 3 rd 

### autogenous grinding mill or the firing zone of the indurating furnace or any emission units that were no t previously permitted has begun. The overall project timeline includes the following milestones:

• Finalize the Supplemental Environmental Impact Statement – late 2011

• Obtain environmental and mining permit for modifi cation and obtain financial close for equipment required for increase pelletizing capacity – 2012

• Finish construction through taconite pellet pl ant and start taconite pellet production – 2013

• Start construction of one DRI line and steel mill – 2013

• Start steel production – 2015

1.4 Facility Emissions Table 2. Title I Emissions Increase Summary (tpy)

Pollutant Emissions Increase from modified units* Emissions Increase from

new units Total Emissions Increase NSR/112(g) Significant Thresholds for major
sources NSR/ 112(g) Review Required? (Yes/No)
PM 2157 8.13 2165 25 Yes PM 10 

### 994 8.13 1002 15 Yes PM 2.5 

### 458 8.13 466 10 Yes NO x 

### 488 488 40 Yes SO 2 

### 319 319 40 Yes CO 94 94 100 Yes Ozone (VOC) 45 45 40 Yes Lead 0.15 0.15 0.6 No Fluorides 89 89 3 Yes Sulfuric Acid Mist (SAM) 7 No

Hydrogen Sulfide (H 2 

### S) 10 No CO 2 

### e* 576,000 75,000 Yes
*Modified units are units that have been modified since or iginal permitting, however since they have not yet been

constructed, the emissions increase is equal to the controlled PTE of each unit, i.e. no credit is taken for the change from the original unit (either increase or decrease in emissions). **Carbon dioxide equivalents as defined in Minn. R. 7007.0100.

### Technical Support Document, Permit Action Number: 06100067-004 Page 4 of 22 Date: 5/10/2012 

### Table 3. Total Facility Potent ial to Emit Summary (tpy)

PM PM 10 

### PM 2.5 

### SO 2 

### NO x 

### CO VOC Pb F** H 2 

### S H 2 

### SO 4 

### CO 2 

### e Single HAP All HAPs Original Project PTE* 2,667 1,332 N/A 420 1,462 3,586 258 1.5 2.7 65.2 0.91 N/A 13 Hexane 54.6 Proposed Project PTE 2,301 1,152 608 455 905 2,071 175 0.91 92 30.8 1.3 1,662,000 26.1 HF 43.3
*Original PTE corrected based on corrected throughput for DRI facility. **Original PTE based on production of Low Flux pellets on ly. The Greenball fluoride concentration used to make

High Flux pellets has higher fluoride contents. 

### Table 4. Facility Classification Classification Major/Affected Source Synthetic Minor/Area Minor/Area
PSD X Part 70 Permit Program X Part 63 NESHAP X


### 2. Regulatory and/or Statutory Basis New Source Review (NSR) The facility is an existing major source under NSR regulations. The proposed modification is subject to NSR regulations. One part of the NSR Review process is the review of the project’s potential for impact on endangered species (a Section 7 review). The U.S. Fish and Wildlife service e valuated the need for this review and determined that it was not necessary. A letter from the U.S. Fish and Wild life Service addressing the Endangered Species Act (ESA) consultation for the permit is found in Attachment 3. Part 70 Permit Program The facility is a major source under the Part 70 permit program. New Source Performance Standards (NSPS) The following NSPS are applicable to various operations at the facility:

• 40 CFR pt. 60, subp. LL – NSPS for Metallic Mineral Processing Plants

• 40 CFR pt. 60, subp. AAa – NSPS for Steel Plants: Elec tric Arc Furnaces and Argon-Oxygen Decarburization Vessels Constructed After August 7, 1983

• 40 CFR pt. 60, subp. Dc – NSPS for Small Industrial – Commercial – Institutional Steam Generating Units

• 40 CFR pt. 60, subp. IIII – NSPS for Stationary Comp ression Ignition Internal Combustion Engines National Emission Standards for Hazardous Air Pollutants (NESHAP) The facility is a major source of HAPs. The following NESHAP s are applicable to various operations at the facility:

• 40 CFR pt. 63, subp. B – Case-by-Case MACT determinations – made under permit action 001.

• 40 CFR pt. 63, subp. Q – NESHAPs for Industrial Process Cooling Towers

• 40 CFR pt. 63, subp. ZZZZ – NESHAPs for Stationary Reciprocating Internal Combustion Engines

• 40 CFR pt. 63, subp. RRRRR – NESHAPs for Taconite Ore Processing

### Technical Support Document, Permit Action Number: 06100067-004 Page 5 of 22 Date: 5/10/2012 

### Compliance Assurance Monitoring (CAM) 40 CFR pt. 64, CAM addresses monitoring for emission sour ces having major emissions of regulated air pollutants under Title V at major Title V sources. Since the facility is a major source under Part 70, CAM applies at the facility. 40 CFR pt. 64.5(a)&(b) establishes that CAM applies only to Large Pollutant-Specific Emission Units (PSEUs) as part of an application for a significant permit revision under Part 70. A large PSEU is an emission unit that has a PTE greater than the major source threshold after taking into account control equipmen t. Other PSEUs subject to CAM are required to address CAM at the time of permit renewal. For the proposed modification of the facility, this mean s that CAM is required under this permit for the indurating furnace. At the time of reissuance, CAM will be addressed for other PSEUs subject to the CAM requirements.
Environmental Review The Minnesota Department of Natural Resources (DNR) conducted a Supplement Environmental Impact Statement (SEIS) to evaluate the proposed ESMM projec t in accordance with EIS preparation requirements of the National Environmental Policy Act (NEPA), 42 U. S.C. §§ 4321-4347 and the Minnesota Environmental Policy Act (MEPA), Minnesota Statute §116D. The air emission perm it for the project could not be issued until the SEIS was deemed adequate. On December 29, 2011, the MNDNR determined that the SEIS was adequate pursuant to MEPA. More information is available at http://files.dnr.state.mn. us/input/environmentalreview/essar/essar_final_seis.pdf

. Minnesota State Rules Portions of the facility are subject to the following Minnesota Standards of Performance:

• Minn. R. 7011. 0150 – Standards of Performance for Preventing Particulate Emissions from Becoming Airborne

• Minn. R. 7011.0515 – Standards of Performance for New Indirect Heating Equipment

• Minn. R. 7011.0610 – Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment

• Minn. R. 7011.0715 – Standards of Performance for Post-1969 Industrial Process Equipment

• Minn. R. 7011.2300 – Standards of Performance fo r Stationary Internal Combustion Engines Table 5. Regulatory Overview of Units at the Facility Level* Applicable Regulations Comments Total Facility Title I BACT limits for PM 2.5 

### The permit contains PM 2.5 

### Test-and-Set provisions which describe the requirements for the facility to test to determine an updated PM 2.5 

### emission limit, as well as the requirement to submit a major amendment application to incorporate those limits into the permit. Appendix E contains the full methodology. MN Mercury TMDL The permit contains total fac ility mercury emission limits, calculation methods, and recordkeeping. It also contains a requirement for the facility to comply with the Implementation Plan for Minnesota’s Statewide Mercury Total Maximum Daily Load (TMDL), published October 2009. The plan requires the facility to submit a plan by 2016 which will contain a schedule for how the facility, or the taconite sector as a whole, will meet 75% reduction goals from the levels listed in the plan, by 2025. 40 CFR pt. 63, subp. A NESHAP general requirements a pply to all the emission units and fugitive sources at the facility except for a short list, which is defined in the permit.

### Technical Support Document, Permit Action Number: 06100067-004 Page 6 of 22 Date: 5/10/2012 Level* Applicable Regulations Comments GP 001 Title I limits to avoid modeled adverse impacts in Class I areas Mobile sources at the facility were found to affect Class I modeling, and were also based on whether the DRI and Steel Mill had begun operation. The facility has accepted limits on the number of Tier 2 mobile sources at the facility prior to the startup of the DRI and Steel Mill. After startup of the DRI and Steel Mill, the facility has accepted limits to ensure that all mobile sources at the facility will be Tier 4 certified and at the quantities listed in GP 001. GP 002 40 CFR pt. 63, subp. RRRRR Emission units subject to Taconite MACT. This group contains the general compliance requirements for these units required by this MACT. Emission limits and performance testing for these units are located in GP 008 or GP 018. The requirements specific to bag leak detectors required by this MACT are located in GP 007. GP 003 Title I BACT limits Ore Crushing and Handling emission units subject to BACT limits for Crude Ore Lead and Fluoride Concentration. GP 004 Title I BACT limits Finished Pellet Handling em ission units subject to BACT limits for Oxide Pellet Lead and Fluoride Concentration. GP 005 Title I BACT limits Waste Rock Handling fugitive sources subject to BACT limits for Waste Rock Lead and Fluoride Concentration. GP 006 Taconite MACT, Case-by-Case MACT, and NSPS LL for fugitive sources All fugitive sources at the facility are s ubject to MACT, either via Taconite MACT or Case-by-Case MACT, and subject to the same requirements. Taconite MACT sources are also subject to Metallic Mineral Processing Plants NSPS. This group has requirements for a fugitive emissions control plan and visible emissions (VE) checks for each fugitive source at the facility. Visible emissions checks are a more stringent measure of compliance than one ti me performance tests, so the list of sources which require a performance test was reduced in lieu of more stringent VE requirements. GP 007 40 CFR pt. 63, subp. RRRRR Bag Leak Detection requi rements for baghouses controlling units subject to Taconite MACT. GP 008 40 CFR pt. 63, subp. RRRRR Limits and performance test ing requirements for units subject to Taconite MACT, except for the indurating furnace. GP 009 Title I BACT limits Case-by-Case MACT 40 CFR pt. 60, subp. LL Limits, performance testing, VE checks, and CEMS requirements for baghouse stacks on the EAF.

GP 010 Title I BACT limits Case-by-Case MACT Material usage limits, monitoring, and recordkeeping for the EAF.

GP 011 Title I BACT limits Operational requirements and compliance measures for the buildings for the Meltshop. GP 012 Title I BACT limits 40 CFR pt. 63, subp. Q Operational requirements and compliance measures for the Cooling Towers.

GP 014 Title I BACT limits Case-by-Case MACT Operating requirements, limits, and comp liance measures for Flares required by Case-by-Case MACT determinations. GP 015 Title I BACT limits Case-by-Case MACT Minn. R. 7011.0610 Operating requirements, limits, and perfor mance testing for the tunnel furnace.

GP 016 Title I BACT limits Minn. R. 7011.0715 Emission limits, material lead and fluoride limits, performance testing and VE checks for the Material Loading Bin Sources. GP 017 Title I BACT limits Case-by-Case MACT Minn. R. 7011.0715 Emission limits, material lead and fluoride limits, performance testing and VE checks for the DRI Pellet Handling units.

### Technical Support Document, Permit Action Number: 06100067-004 Page 7 of 22 Date: 5/10/2012 Level* Applicable Regulations Comments GP 018 Title I BACT limits 40 CFR pt. 63, subp. RRRRR Operational requirements, limits, performance testing, compliance measures, and CEMS requirements for the indurating furnace. This also requires the installation of an activated carbon injection (ACI) system to control mercury emissions, as well as performance testing requirements for mercury to require testing at least 4 times in the first year of operation to verify ACI performance. Requirements were also added to calculate and record CO 2 

### e emissions from the furnace. GP 019 Case-by-Case MACT 40 CFR pt. 60, subp. Dc Limits, compliance measures and CEMS requirements for Boilers & Heaters subject to Case-by-Case MACT and NSPS. GP 020 Case-by-Case MACT Installation of monitoring devices and compliance measures for Wet Scrubbers as determined by Case-by-Case MACT. GP 021 Title I BACT limits 40 CFR pt. 63, subp. ZZZZ 40 CFR pt. 60, subp. IIII Minn. R. 7011.2300 Operating requirements, limits, and compliance measures for Emergency Generators and Fire Water Pumps at the facility.

GP 022 40 CFR pt. 64, CAM Minn. R. 7017.1004-1090 Operational requirements and testing applying to all CEMS required at the facility. GP 023 Title I BACT limits Minn. R. 7011.0715 Operating requirements and emission limits on emission units in the EAF Ladle/Casting area. Emission limits are co mplied with by complying with the requirements of GP 009. GP 024 Title I BACT limits Operating requirements, lim its, performance testing, and other compliance requirements for the DRI Top Gas Purification system. GP 025 Title I BACT limits Emission limits and perfor mance testing for the DRI water blowdown units. GP 026 Title I BACT limits Minn. R. 7011.0715 Operating requirements, emission limits, and control equipment requirements for the Ore Barns. EU 165 Title I BACT limits Minn. R. 7011.0515 Fuel usage and emission limits for the space heaters at the facility. There are 24 space heaters to be located as follows:

2 – Mining and Crushing 4 – Concentrator 2 – Pelletizer 16 – DRI and Steel Mill FS 042 Title I BACT limits Limits on the concentratio n of Fluoride in the slag, sampling methods, and recordkeeping requirements. Appendix A Title I BACT limits Appendix A lists all of the Title I BA CT limits at the facility. References throughout Table A of the permit give the citation for the rule for each limit listed. Appendix A provides one location which stores all the BACT limits for all the stacks at the facility. Compliance with the BACT limits in Appendix A will generally demonstrate compliance with other less stringent limits that also apply. No limits in Table A are more stringent than any of the BACT limits. *Where the requirement appears in the permit (e.g., EU, SV, GP, etc.).

### Technical Support Document, Permit Action Number: 06100067-004 Page 8 of 22 Date: 5/10/2012 

### 3. Technical Information

3.1 Prevention of Significant Deterioration (PSD) PSD requirements apply to the modifications proposed by the facility. These requirements include the determination of Best Available Control Technology (BACT) for individual units, air quality modeling to demonstrate compliance with National Ambient Air Qua lity Standards (NAAQS), Minnesota Ambient Air Quality Standards (MAAQS) and Class I and Class II PSD Increments, a nd demonstrations of protection of Class I Air Quality Related Values (AQRVs), including visibility.
3.1.1 BACT A BACT analysis must be performed for each unit that is part of the proposed modification, for each pollutant that it emits. The table below summarizes the units evaluated for BACT and the pollutants they emit. A summary of the results of the BACT analysis is include d as Attachment 1 to the TSD. Many of the units only have particulate emissions, and the choice for BACT wa s the highest rated control technology, and therefore a cost analysis was not required. A cost analysis was done for the indurating furnace for some pollutants and demonstrated that further controls would not be cost effective. Table 6. Units Evaluated for BACT Analysis Stack Vent Emission Unit Description Pollutants Emitted
SV 018 EU 038 Indurating Furnace PM, PM 10 

### , PM 2.5 

### , Pb, F, CO, SO 2 

### , NO x 

### , VOC, GHG SV 019 EU 039 SV 016 EU 036 Hearth Layer Bin PM, PM 10 

### , PM 2.5 

### , Pb, F

SV 017 EU 037 Hearth Layer Feed EU 106 Oxides Pellet Transfer to Hearth Layer Bin SV 020 EU 040 Pellet Discharge SV 021 EU 041 Pellet Screening and Handling SV 022 EU 042 Pellet Screenings to Regrind Conveyors SV 023 EU 048 Oxide Pellet Stockpile Conveyor Gallery SV 084 EU 176 Primary Grinding Mill Line 3 SV 085 EU 170 Grizzly Transfer Tower SV 086 EU 171 Non-Magnetic Cobber Rejects Transfer Tower SV 087-090 EU 172-175 Secondary Scr eening Crusher/Cobber Lines 1-4 SV 091 EU 177 Carbon Bin for Hg Control SV 092 EU 178 Lime Bin for Scrubber FS 017 Dozer Activity at Tailings Basin FS 018 Grading at Tailings Basin FS 019 120K ton Concentrate Stockpile Loading FS 021 120K ton Concentrate Stockpile Loadout FS 027 Oxide Product Loadout to Railcars

### Technical Support Document, Permit Action Number: 06100067-004 Page 9 of 22 Date: 5/10/2012 

### 3.1.1.1 GHG BACT GHG BACT was required to be analyzed for the Indurating Furnace stacks. Table 1-10 of Attachment 1 gives a summary of the BACT process for GHGs.
3.1.1.1.1 Carbon Capture and Sequestration The March 2011, PSD and Title V Permitting Guidance fo r Greenhouse Gases document states the following in regards to Carbon Capture and Sequestration (CCS): "... EPA generally considers CCS to be an “available” add-on pollution contro l technology for facilities emitting CO 2 

### in large amounts and industrial facilities with high-purity CO 2 

### streams. ..." "... CCS is composed of three main components: CO 2 

### capture and/or compression, transport, and storage. CCS may be eliminated from a BACT analysis in Step 2 if it can be shown that there are signi ficant differences pertinent to the successful operation for each of these three main components from what has alre ady been applied to a differing source type. ..." The BACT report addresses the three main components of CCS, as well as the integration of the three main components. Capture and/or Compression The BACT report evaluates several options for collection of CO 2 

### gas in Sections 5.6.1 and 6.7.1.1. The capture options evaluated were Post-Combustion CO 2 

### capture for normal combustion, Post-Combustion CO 2 

### capture for combustion using pure Oxygen rather than air, and Pre-Combustion CO 2 

### capture through gasification and converting the fuel to pure hydrogen pr ior to combustion. The first option is technically infeasible based on the low concentration of CO 2 

### in the exhaust stream. The other two options are technically infeasible for the indurating furnace due to the chemistry and thermodynamic properties required.
Transport Transportation options for CO 2 

### vary depending on whether it is in gaseous form or as a solid or liquid. As a solid or liquid, transportation of CO 2 

### is feasible. CO 2 

### in a gaseous form is considered technically infeasible due to the location of the nearest storage facility (in central North Da kota) and the significant logi stical hurdles to install a pipeline to transport the CO 2 

### , such as the successful receipt of permitting, right-of-way, and other environmental considerations necessary to establish a pipeline to reach a sequestration site. Storage The BACT report evaluates several options for sequestration of CO 2 

### gas in Sections 5.6.3 and 6.7.1.3.The sequestration options evaluated in these sections were Deep Saline A quifers, Oil/Gas Reserves, and Un-Mineable Coal Seams. There are processes under development to react CO 2 

### to form a solid by-product, known as CO 2 

### mineralization, discussed in Sections 5.6.2 and 6.7.1.2 of the BACT report. CO 2 

### mineralization is a kinetically slow process which requires large amounts of energy. Several demonstratio n projects are either underway or planned for these technologies, but they have not yet been demonstrated at a commercial scale. Integration of CCS Components CCS may also be eliminated in step 2 due to logistical barriers that make the integration of the three components technically infeasible. As noted further in EPA’s Guidance “... CCS may be elim inated from a BACT analysis in Step 2 if the three components working together are deemed technically infe asible for the proposed sour ce, taking into account the integration of the CCS components with the base facilit y and site-specific considerations (e.g., space for CO 2 

### capture equipment at an existing facility, right-of-ways to build a pipeline or access to an existing pipeline, access to suitable geologic reservoirs for sequestration, or other storage options) ... EPA recognizes the significant logistical hurdles that the installation and operation of a CCS system presents and that sets it apart from other

### Technical Support Document, Permit Action Number: 06100067-004 Page 10 of 22 Date: 5/10/2012 

### add-on controls that are typically us ed to reduce emissions of other regulated pollutants and already have an existing reasonably accessible infrastructure in place to a ddress waste disposal and other offsite needs. Logistical hurdles for CCS may include obtaining contracts for offsit e land acquisition (including the availability of land), the need for funding (including, for example, government subs idies), timing of available transportation infrastructure, and developing a site for secure long term storage. Not every source has the resource s to overcome the offsite logistical barriers necessary to apply CCS technology to its operations, and smaller sources will likely be more constrained in this regard. Based on these considerations, a permitting auth ority may conclude that CCS is not applicable to a particular source, and consequently not technically feasible, ev en if the type of equipment needed to accomplish the compression, capture, and storage of GHGs are determined to be generally available from commercial vendors.” (http://www.epa.gov/region4/ air/permits/GHGPermittingGuidance%20_March2011.pdf ) Many of the add-on technologies were eliminated in Step 2 of the BACT analysis as technically infeasible options based on the guidance that the three components of CCS working together were not technically feasible, most notably the logistical hurdles described in the transport section and the difficulties of CO 2 

### capture described above.
3.1.1.1.2 Energy Efficiency Energy Efficiency measures (Sections 5.6.5 and 6.7.1.4 of the BACT report) are being taken by Essar in an effort to minimize GHG emissions by both ensuring high levels of energy and production efficiency for the project. Heat recovery will be utilized in the indurating process in order to minimize fuel usage and separate recuperative heat recovery loops are planned which will maximize heat re covery. The Essar furnace will have up and down draft drying zones which use recuperative heat from the second pellet cooler for pellet drying. Recuperative heat is also used to preheat pellets in the down draft dryi ng and preheat windbox and firing sections of the furnace using heat recovered from the first pellet cooler. A portio n of the hot air coming off the first pellet cooler will be used as combustion air in the firing section of the strai ght grate furnace. Because the combustion air is hot, less fuel is necessary to heat the combustion air and more of the fuel energy can be directed into the production process. As noted in the NO x 

### control analysis in Section 6.3 of th e BACT report, the amount of preheated combustion air is limited in order to control NO x 

### emissions in the low NO x 

### LE Burners. Through these energy efficiency measures, the Essar project is expected to achieve thermal consumption levels consistent with a modern well designed energy efficient straight grate furnace.
3.1.1.1.3 Other BACT Considerations Lower Emitting Processes Sections 5.6.7 and 6.7.1.5 of the BACT report discuss th e use of lower emitting processes which involves the use of different sorbents in the flue gas desulfurization (FGD ) units, however none of the different sorbents are more efficient when considering GHG emissions, and therefore the choice of lime is BACT. Good Design Practices / Good Operating Practices Sections 5.6.6 and 6.7.1.4 of the BACT report discusse s good design/operating practices for the furnace. Good design includes process and mechanical equipment designs which are either inherently lower polluting or are designed to minimize emissions. Good operating practices include operating methods, procedures and selection of raw materials (i.e., additives and control reagents) to minimize emissions.
Fuels Section 5.6.4 of the BACT report discusses fuels. Natu ral gas has the lowest GHG emissions of the fossil fuels when the biogenic nature of biomass is not considered, the choice of natural gas is the top choice for BACT.

### Technical Support Document, Permit Action Number: 06100067-004 Page 11 of 22 Date: 5/10/2012 

### 3.1.2 NAAQS Under the federal Clean Air Act and the Prevention of Signifi cant Deterioration (PSD) regulation, a Class II area is a geographic area other than national parks, monuments and w ilderness areas that are classified as Class I. Most of Minnesota is Class II. To receive a PSD permit in a Class II area, the Permittee must demonstrate that the NAAQS and MAAQS are protected, but somewhat more deterioration of ai r quality is allowed in a Class II area than a Class I area. A Class II air quality analysis was completed for the project as part of the air permit application. The Class II air quality analysis demonstrated that PM 10 

### , PM 2.5 

### , NO x 

### , SO 2 

### , Pb, and CO emissions would meet the NAAQS and MAAQS. An ozone impacts analysis is also required of any majo r PSD modification where there is an increase in NO x 

### emissions which exceeds the significance threshold for ozone (40 tpy) because NO x 

### and VOCs are precursors to ozone. A quantitative modeling analysis has not yet b een developed to be used for this permit. With consultation with the U.S. EPA, a qualit ative analysis was decided to be used. In this analysis, data from the only existing year-round ozone monitoring station in northern Minnesota was used, located at Voyageurs National Park, approximately 80 miles north of Essar. This data shows that the monitoring station has recorded average ozone concentrations at or below 78% of the NAAQS standard during 2008-2010. NO x 

### and VOC emissions from Essar account for less than 0.7% of the stationary source emissions, and less than 0.2% of the total emissions in the state. This data indicates there is no reason to expect emissions from the ESMM project would alter the compliance status with respect to the ozone standa rd. Additional details are included in a technical memorandum included as Attachment 4. Table 7. Maximum Predicted Ambient Air Concentrations Near the Essar Facility

Pollutant Averaging Period Modeled Impact * ( μ g/m 3 

### ) Background Concentration ( μ g/m 3 

### ) Predicted Ambient Air Concentration ( μ g/m 3 

### ) MAAQS ( μ g/m 3 

### ) NAAQS ( μ g/m 3 

### )

PM 10 

### 24-Hour 27 30 57 150 150 Annual 5.8 11 17 50 - PM 2.5 

### 24-Hour 15 15.7 31 65 35 Annual 1.5 5.6 7.1 15 15 SO 2 

### 1-Hour 163 7.7 171 1,300 197 3-Hour 108 10 118 915 1300 24-Hour 30 4 34 365 365 Annual 3.0 2 5.0 60 80 NO x 

### 1-Hour 138 28 166 - 188 Annual 13 7 20 100 100 CO 1-Hour 229 575 804 35,000 40,000 8-Hour 85 345 430 10,000 10,000 Lead (Pb)** Quarterly 0.0018 Not Available 0.0018 1.5 0.15 *For averaging periods shorter than annual, one exceedance is allowed per location per year. Therefore, for the short term

averaging periods, the highest concentration per year pe r location is not considered and the high second high is presented. The highest CO concentrations are given sin ce the concentrations are well below the standards. **Ambient air quality modeling for lead was completed as part of the Screening Level Ecolog ical Risk Assessment (SLERA)

### Technical Support Document, Permit Action Number: 06100067-004 Page 12 of 22 Date: 5/10/2012 

### 3.1.3 PSD Increments PSD allows facilities to construct emission units, but restrict s the amount of additional pollution an area can receive. It does this by imposing “PSD increm ents,” or limits on the concentration of air pollution since a certain date. There are increments that apply in normal (or Class II) areas as well as increments for protected (Class I) areas such as National Parks and Wilderness areas. The allowed in crease in a concentration of a pollutant is lower in a Class I area than in a Class II area.
3.1.3.1 Class I Increment Analysis An increment analysis is required of any major PSD source for which the modeled Class I area impacts of that Essar’s emissions alone are above the Significant Impact Levels (SIL s). The SILs are values at or below 5% of the standard and represent a level where further analysis is not requi red to ensure compliance. Modeling of Essar’s facility showed that its impacts are above the SILs for 24-hour PM 10 

### , and 24-hour and annual PM 2.5 

### (Table 8); therefore an analysis of the cumulative impact from all sources of PM 10 

### and PM 2.5 

### (past and present, increases and decreases) on the Class I areas was prepared. The emission inventory for the Essar Steel Increment an alysis included modifications to existing sources, new facilities that have been permitted or submitted permit a pplications prior to Essar Steel and increases in actual emissions from existing facilities. Additional details of each are presented in the permit application and the technical memorandum for PM 2.5 

### included as Attachment 5.
Modeled air concentrations for the Class I PSD increments are presented in Table 8 along with the Class I increment standards. The CALPUFF modeling indicates that the em issions associated with the ESML project will not significantly deteriorate the air quality in the Class I areas. Table 8. Class I Modeling Results

Model Run Pollutant Averaging Period Standard ( μ g/m 3 

### ) U.S. EPA SIL ( μ g/m 3 

### ) Facility Only Modeled Concentration ( μ g/m 3 

### ) Total Modeled Concentration ( μ g/m 3 

### ) Percent of Standard

PSD Increment PM 10 

### 24-hour 8 0.3 0.377 3.0 38% Annual 4 0.2 0.017 -- -- PM 2.5 

### 24-hour 2 0.07 -- 0.458 23% Annual 1 0.06 -- 0.043 4% SO 2 

### 3-hour 25 1 0.484 -- -- 24-hour 5 0.2 0.191 -- -- Annual 2 0.1 0.006 -- -- NO x 

### Annual 2.5 0.1 0.016 -- --

### Technical Support Document, Permit Action Number: 06100067-004 Page 13 of 22 Date: 5/10/2012 

### 3.1.3.2 Class II Increment Analysis The increment standards, which apply to PM 10 

### , PM 2.5 

### , NO x 

### and SO 2 

### , are the maximum increase in air quality concentrations of pollutants that are allowed. Essar ex amined the impacts of its emission on the PSD Class II Increment Standards for the area within 50 kilometers (31 miles) of the facility. Additional details are presented in the permit application and the technical memorandum for PM 2.5 

### Increment included as Attachment 6. The proposed project includes both fugitive sources a nd stacks, as well as nearby large industrial background sources. The modeled fugitive sources include mining activi ties, dust generation from traffic within the mine and plant site, and a number of smaller stockpiles in the plan t areas. The facility stacks include the crushing process stacks through the steel production stacks. Backup generato rs and stacks used only during plant upset were not included in the modeling. Air pollution control equipm ent efficiencies and proposed air permit limits are included in the air emission estimates that were used in the modeling. The AERMOD air dispersion model was used to estimate Class II ambient air concentrations. The USEPA recommends AERMOD as a “Preferred Model” for Class II air quality an alyses. Building downwash was predicted for the facility stacks using the BPIP-PRIME downwash model. Both AERMOD and BPIP-PRIME were developed by USEPA. The predicted change in concentrations is presented below in Table 9 along with the Class II increment standards. Table 9. Class II Modeling Results

Model Run Pollutant Averaging Period Standard ( μ g/m 3 

### ) Facility Only Maximum Modeled Concentration* ( μ g/m 3 

### ) Background ( μ g/m 3 

### ) Total Modeled Concentration** ( μ g/m 3 

### ) Percent of Standard
PSD Increment PM 10 

### 24-hour 30 25 -- 25 84% Annual 17 3.6 -- 3.6 21% PM 2.5 

### 24-hour 9 7.1 -- 7.1 79% Annual 4 1.3 -- 1.3 33% SO 2 

### 3-hour 512 41 -- 41 8% 24-hour 91 12 -- 12 13% Annual 20 1.6 -- 1.6 8% NO 2 

### Annual 25 3.9 -- 3.9 16% NAAQS/MAAQS PM 10 

### 24-hour 150 27 30 57 38% Annual 50 5.8 11 17 34% PM 2.5 

### 24-hour 35 15 15.7 31 89% Annual 15 1.5 5.6 7.1 48% SO 2 

### 1-hour 197 163 7.7 171 87% 3-hour 915 108 10 118 13% 24-hour 365 30 4 34 9% Annual 60 3.0 2 5.0 8% NO 2 

### 1-hour 188 138 28 166 89% Annual 100 13 7 20 20% CO 1-hour 35000 229 575 804 2% 8-hour 10000 85 345 430 4% Lead Quarterly 0.15 0.0018 -- 0.0018 1% *For averaging periods shorter than annual, one exceedance is allowed per location per year. Therefore, for the short term

averaging periods, the highest concentration per year per loca tion is not considered and the high second high is presented. **Total Modeled Concentration is the sum of the Facility Only Maximum Modeled Concentration and the Background.

### Technical Support Document, Permit Action Number: 06100067-004 Page 14 of 22 Date: 5/10/2012 

### 3.1.4 Class I AQRVs Four Class I areas (the Boundary Waters Canoe Area W ilderness (BWCAW), Isle Royale National Park (IRNP), Rainbow Lake Wilderness (RLW), and Voyageurs National Park (VNP)) are located within 300 km of the project. PSD regulations require that these four areas be assesse d for potential impacts on Air Quality Related Values (AQRVs) from the project em4issions. These assessmen ts are typically conducted using the CALPUFF modeling system. AQRVs are features or properties of Class I area s that could be adversely affected by air pollution. The Clean Air Act requires that potential AQRV impacts be reviewed for all major sources near Class I areas. A Class I air quality analysis was prepared for the proposed project as part of the PSD air permit application. The Class I modeling demonstrates that th e project would not likely have an adverse effect on flora and fauna or terrestrial or aquatic ecosystems. The CALPUFF Modeling System was used to model visual impact s on the Class I areas from the project. The analysis of impacts on the Class I areas, contained in Appendix F of the permit application, indicates that the project may have an adverse impact on visibility. A discussion of the result s and potential mitigation me asures (if needed) follows.
3.1.4.1 Flora and Fauna Table 10 below compares the sum of background SO 2 

### concentrations plus modeled ambient air SO 2 

### concentrations resulting from the project emissions at the four Class I areas. In evaluating potential adverse effects to flora and fauna, lichen species are generally us ed as a threshold indicator of potential air pollution damage because they are especially susceptible to air pollution and show adverse effects before other plant species and animal species. If pollutant concentrations are sufficiently low that no damage occurs to native lichens, then it can reasonably be concluded that all other flora and fauna species are protected. The most sensitive lichen species are only present when annual average SO 2 

### concentrations are less than 40 μ g/m3. As can be seen in Table 10, all estimated SO 2 

### ambient air concentrations are lower than 40 μ g/m3. The Federal Land Managers have set a screening level concentration referre d to as the “Green Line Concentration”. All modeled concentrations are also below the “Green Line Concentration” of 5 μ g/m3, indicating that there should be no adverse effects from the project emissions on flora or fauna in the Class I areas. Table 10. Class I Screening Analysis for Effects on Flora and Fauna From SO 2 

### Total Annual Average Ambient Air Concen trations – Final Proposed Project

Location Background Air Concentration 1 

### ( μ g/m 3 

### ) Modeled Project Contribution 2 

### ( μ g/m 3 

### ) Total Projected Air Concentration ( μ g/m 3 

### ) Green Line Concentration 3 

### ( μ g/m 3 

### )
BWCAW 1.2 0.006 1.2 5 Isle Royale National Park 2.0 0.001 2.0 5 Rainbow Lake Wilderness 1.6 0.003 1.6 5 Voyageurs National Park 0.7 0.006 0.7 5

1 

### Mean annual SO 2 

### concentrations (ug/m 3 

### )
2 

### Modeled ambient air concentration in Class 1 area using the CALPUFF modeling system.
3 

### Green line concentration from Adams et al., “Screening Proc edures to Evaluate Effects of Air Pollution on Eastern

Wildernesses Cited as Class I Air Quality Areas”, USDA, Forest Service, Northeast Forest Experiment Station, Generator Technical Report NE-151, September 1991

.

### Technical Support Document, Permit Action Number: 06100067-004 Page 15 of 22 Date: 5/10/2012 

### 3.1.4.2 Acid Deposition Adverse effects to terrestrial and aquatic ecosystems ar e evaluated slightly differently by the National Park Service and the US Forest Service. The acid depositi on impact analysis for the BWCAW and Rainbow Lake Wilderness area considers the total concentration or deposition including background. The acid deposition impact on terrestrial and aquatic ecos ystems is judged to be acceptable if ambient air concentrations and/or deposition is below the respective “green line”. For Voyageurs National Park and Isle Royale National Park, the Deposition Analysis Thresholds (DATs) were calculated for total sulfur and total nitrogen. DATs have been develo ped by the National Park Service and US Fish and Wildlife Service (USFWS) to evaluate the contributio n of additional nitrogen (N) or sulfur (S) to deposition within Class I areas. The DATs are intended to distinguish where deposition increases may result in potentially adverse ecosystem stresses, as well as where the deposition increases are like to have a negligible impact on AQRVs. Project-related deposition was estimated using the CA LPUFF modeling system and results are presented in Table 11. SO 2 

### and NO x 

### emissions from the project are not expected to have an adverse effect on terrestrial or aquatic ecosystems in the Class I areas. Table 11. Class I Area Screening Analysis Results For Potential Terrestrial Impacts – Final Proposed Project

Location 2 

### Pollutant Background Data 1 

### Model Air Concentration orCalculated ProjectRelated Deposition 3 

### Total Concentration or Deposition Green Line Value or Deposition Analysis Threshold 4


### BWCAW - Ely Annual Ave SO 2 

### ( μ g/m 3 

### ) 1.2 0.006 1.2 5 μ g/m 3 

### 3-hour max SO 2 

### ( μ g/m 3 

### ) 10.8 0.484 11.3 100 μ g/m 3 

### Total Sulfur (kg/ha/yr) 2.85 0.004 2.85 5-7 kg/ha/yr S Total Nitrogen (kg/ha/yr) 4.75 0.005 4.76 5-8 kg/ha/yr N Isle Royale National Park Annual Ave SO 2 

### ( μ g/m 3 

### ) 2.0 0.001 2.0 5 μ g/m 3 

### 3-hour max SO 2 

### ( μ g/m 3 

### ) 18 0.074 18.1 100 μ g/m 3 

### Total Sulfur (kg/ha/yr) 2.15 0.001 NA 0.01 kg/ha/yr S Total Nitrogen (kg/ha/yr) 3.85 0.001 NA 0.01kg/ha/yr N Rainbow Lake Wilderness Annual Ave SO 2 

### ( μ g/m 3 

### ) 1.6 0.003 1.6 5 μ g/m 3 

### 3-hour max SO 2 

### ( μ g/m 3 

### ) 14.4 0.183 14.6 100 μ g/m 3 

### Total Sulfur (kg/ha/yr) 2.98 0.002 2.98 5-7 kg/ha/yr S Total Nitrogen (kg/ha/yr) 5.88 0.002 5.88 5 

### 5-8 kg/ha/yr N Voyageurs National Park Annual Ave SO 2 

### ( μ g/m 3 

### ) 0.7 0.006 0.7 5 μ g/m 3 

### 3-hour max SO 2 

### ( μ g/m 3 

### ) 6.3 0.324 6.6 100 μ g/m 3 

### Total Sulfur (kg/ha/yr) 1.84 0.005 NA 0.01 kg/ha/yr S Total Nitrogen (kg/ha/yr) 3.87 0.005 6 

### NA 0.01 kg/ha/yr N

1 

### Mean annual SO 2 

### concentrations (ug/m 3 

### )
2 

### Modeled air concentration in each Class I area.
3 

### Model estimated ambient air concentratio ns using the CALPUFF modeling system.
4 

### Green line concentration. DAT is based on Nation al Park Service Guidance for the Eastern U.S.
5 

### Majority of total concentration or deposition is due to backgr ound. The modeled air concentration contributes little to the

total concentration.
6 

### The concentration from the proposed project scenario is less than the DAT.

### Technical Support Document, Permit Action Number: 06100067-004 Page 16 of 22 Date: 5/10/2012 

### 3.1.4.3 Visibility The potential visibility impacts associated with the pr oposed Essar Steel project were evaluated based on currently accepted guidance from the Federal Land Manage rs (FLMs). The guidance is known as FLAG (Federal Land Managers Air Quality Related Va lues Workgroup). Previous visib ility impact modeling used FLAG 2000 guidance which uses the CALPUFF/CALPOST model wi th CALPOST Method 2 processing. FLAG 2010 uses CALPOST Method 8 processing. Results from both FLAG 2000 and FLAG 2010 are given in the table below. Potential changes in the visibility were expressed in terms of an extinction coefficient (b ext 

### ). Three Class I areas were included in the visibility analysis for the project: th e BWCAW (located 80 km from Essar’s facility), Voyageurs National Park (100 km), and Isle Royale National Park (280 km). The BWCAW falls under the jurisdiction of the U.S. Department of Agriculture (U.S. Forest Service) whereas the national parks fall under the jurisdiction of the U.S. Department of the Interior (National Park Service and U.S. Fish and Wildlife Service). Visibility has not been established as an AQRV for the Rainbow Lakes Wilderness, so visibility impacts were not modeled for that area. Table 12. Class I Visibility Modeling Results For the Project Compared to Natural Background (NH 3 

### 1 ppb)

Location Parameter FLAG 2000 FLAG 2010
BWCAW Maximum Δ b ext 

### (%) 5.15 – 12.79 5.47 – 10.62 Days with Δ b ext 

### ≥ 5% 1 – 10 1 – 4 Days with Δ b ext 

### ≥ 10% 0 – 1 0 – 1 Isle Royale Maximum Δ b ext 

### (%) 2.88 – 4.49 1.42 – 2.9 Days with Δ b ext 

### ≥ 5% 0 0 Days with Δ b ext 

### ≥ 10% 0 0 Voyageurs Maximum Δ b ext 

### (%) 6.63 – 13.52 4.31 – 7.94 Days with Δ b ext 

### ≥ 5% 3 – 6 0 – 2 Days with Δ b ext 

### ≥ 10% 0 – 1 0 *Maximum changes in the daily extinction coefficients compared to natural back ground and the number of days per year

for the three years modeled (i.e., 2002, 2003 and 2004) in which the increase in the daily extinction coefficient exceed 5 and 10 percent due to Essar Steel emissions.


### 3.1.5 Mercury Total facility Mercury emissions from the original Mi nnesota Steel project were listed at 77 lb/yr in the Implementation Plan for Minnesota’s Statewide Mercur y Total Maximum Daily Load (TMDL) – October 2009. The ESML project proposes installation of an activated carbon injection system on the waste gas stack (SV 019) of the indurating furnace to control Mercury emissions so that the entire facility emits less than 77 lb/yr. The permit requires performance testing for mercury from the furnace stacks quarterly for the first year, and annually, at a minimum, for subsequent years. The Mercury TMDL requires that the Taconite industry achieves a 75% reduction in Mercury emissions from the levels presented in the Plan by the year 2025. The Taconite industry is also required to submit a plan, due in the year 2016, which details how the sector will attain the 75% reduction goal. Further technology advancement will occur by then which will help in determining the technolo gies that will be required in order to meet the goals.

### Technical Support Document, Permit Action Number: 06100067-004 Page 17 of 22 Date: 5/10/2012 

### 3.1.6 Additional Impacts Analysis The additional impacts analysis submitted by the applicant considers the effect of project-related air emission on visibility, soils, and vegetation. It also addresses air qualit y impacts from regional growth related to the project. The assessment for Class II visibility focused on a number of Essar Steel stacks that are likely to have a water vapor plume due to their high moisture content. While such a plume dissipates fairly quickly, the plume would be visible to an observer looking toward the Essar Steel facility from Hill Annex State Park when the wind is ‘D’ stability class and the wind speed is roughly 10 miles per hour (4.6 m/s) or less. An observer at McCarthy Beach State Park could see a plume from Essar Steel only when the wind is ‘F’ stability class and the wind speed is less than about 2.5 miles per hour (1 m/s). Because northeas tern Minnesota is generally heavily forested and lakes are surrounded by trees, the potential for seeing the plume from McCarthy Beach State Park is low under typical meteorological conditions. The analysis of the project’s impact on soils found them to be far below the state acid deposition standard. The project’s damage to vegetation was determined to be small, due in part to the control of SO 2 

### emissions with scrubbers and control of fugitive dus t with a fugitive dust control plan. Construction employment at the Essar Steel site is expe cted to peak at about 2000 persons. After startup, about 700 people are expected to be employed at the site. This is roughly double the number employed at Butler Taconite. Because, however, the infras tructure of the Iron Range is gene rally capable of handling many more people than currently reside there, it is expected that the growth from this project will not have significant impacts beyond those experienced previously.

3.2 Case-by-Case Maximum Achievable Control Technology (MACT) There are two units proposed as part of the modification for which a MACT standard has not been promulgated. These are EU 177 and 178, the carbon bin and lime bin re spectively. These store the materials used in the proposed Activated Carbon Injection and GSA Dry Scrubbe r controls on the furnace. These units have been determined to meet the same MACT standards as the other material loading bin sources at the facility.

3.3 Calculations of Potential to Emit (PTE)

PTE calculations are summarized in Table 3. Detailed calculation spreadsheets are available electronically, however they are too large to be included with the TSD. The calculation spreadsheets show PTE calculations for both Low Flux and High Flux acid pellet production scen arios. The total facility PTE is based on the highest pollutant specific PTE between the scenarios. Production of High Flux pellets requires a different chemic al composition of the greenba lls as they enter into the furnace. Data from Hibbing Taconite Co was used to determine an emission factor for Fluorides emitted from a taconite furnace producing high flux pellets.

3.4 Periodic Monitoring and CAM In accordance with the Clean Air Act, it is the respon sibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the fa cility is in compliance with all applicable requirements. The Permittee submitted a CAM proposal as required by 40 CF R § 64.3. It can be found in Attachment 2 to this TSD. In evaluating the monitoring included in the permit, the MPCA considered the following:

• The likelihood of the facility violating the applicable requirements;

• Whether add-on controls are necessary to meet the emission limits;

• The variability of emissions over time;

### Technical Support Document, Permit Action Number: 06100067-004 Page 18 of 22 Date: 5/10/2012 

### • The type of monitoring, process, maintenance, or control equipment data already available for the emission unit;

• The technical and economic feasibility of possible periodic monitoring methods; and

• The kind of monitoring found on similar units elsewhere. The table below summarizes the periodic monitoring re quirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate or where CAM applies. Table 13. Periodic Monitoring Level* Requirement Additional Monitoring Discussion TF Hg ≤ 77 lb/yr on a 12- month rolling sum basis Monthly calculation and recordkeeping Limits to define a Total Facility Mercury Emission Limit and to show no net increase in potential emissions as compared to the value listed in the Mercury TMDL. Monthly calculations and recordkeeping of mercury emissions are required to document compliance with this limit. Material Pb and F concentrations Sampling and calculations Sampling methodology and calculation methods for lead and fluoride concentration of materials to comply with limits listed throughout Table A. Calculation methods for determining 95% Upper Confidence Levels (UCL) of feed material are listed. Frequency of ongoing sampling is based on 95% UCL. GP 001 Tier 2 and Tier 4 mobile

sources Recordkeeping O&M Plan The facility will be phasing in Tier 4 mobile sources as they become available from the manufacturers. Initial mobile sources are required to be certified at Tier 2 or higher. The entire fleet of mobile sources is required to be certified Tier 4 compliant upon startup of the DRI and Steel Mill. Records will be kept to document fuel use, sulfur content of fuel, proper operation, and purchasing and maintenance of the sources. In addition, an O&M plan is required to be submitted and approved and include tracking information for urea use. GP 002 General Conditions of Taconite MACT N/A Monitoring, recordkeeping and reporting requirements as required by Taconite MACT and NSPS LL. GP 003 GP 004 GP 005 Material Pb and F concentrations Testing and Recordkeeping Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit. GP 006 Opacity < 5% Visible Emission (VE) Checks and Method 9 performance tests. Daily VE Checks are required on all fugitive sources at the facility with associated corrective actions and recordkeeping. In addition, method 9 testing is used to document initial compliance for those sources that are subject to the NSPS and not insignificant activities. Daily VE checks have been deemed to be more stringent than method 9 testing and sufficient to satisfy the requirements of the NSPS for the insignificant activities. GP 007 Baghouse requirements from Taconite MACT Monitoring Bag Leak Detection requirements for baghouse subject to Taconite MACT.

### Technical Support Document, Permit Action Number: 06100067-004 Page 19 of 22 Date: 5/10/2012 Level* Requirement Additional Monitoring Discussion GP 008 PM, PM 10 

### , PM 2.5 

### , Pb, F, and Opacity limits for each stack. Material Pb and F concentrations Performance testing Recordkeeping The stacks in this group have been sorted into source groups for the purposes of testing as allowed by Taconite MACT. In addition, PM 2.5 

### tests require 2 stacksfrom each group in order to comply with the Test-andSet methods listed in Appendix E. Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit. GP 009 PM, PM 10 

### , PM 2.5 

### , Pb, F, SO 2 

### , SAM, NO x 

### , CO, VOC, and Opacity limits for each stack. Pb and F material concentration limits Performance testing Recordkeeping Initial Performance tests and recurring performance tests and CEMS for SO 2 

### , NO x 

### , CO, and O 2 

### from SV 044. SV 047 is only a PM source and compliance is demonstrated through daily VE checks. Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit. GP 010 Fluorspar usage, sulfur content of carbon additive limit, and Pb and F material concentration limits Monitoring and Recordkeeping Monthly monitoring and recordkeeping of sulfur content of the carbon additives. Recordkeeping of Fluorspar use required for each use. Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit. GP 011 Negative pressure building Monitoring and Performance testing Continuous monitoring and annual performance testing to verify a negative pressure in the buildings. GP 012 Drift rate and opacity Monitoring, Reporting and Performance testing Continuous monitoring of liquid flowrate, and monthly monitoring of total dissolved solids Initial and recurring performance testing for opacity. Annual notice of compliance as required by MACT Q. GP 014 CO and opacity limits Monitoring, recordkeeping, operational requirements and VE checks Continuous monitoring of flame presence. Operational requirements to ensure proper operation of the flares and compliance with the CO limits. Daily VE Checks for opacity. GP 015 PM, PM 10 

### , PM 2.5 

### , SO 2 

### , NO x 

### , CO, VOC, and Opacity limits Performance testing Initial and recurring performance tests to document compliance with each limit.

GP 016 PM, PM 10 

### , PM 2.5 

### , Pb, F, and Opacity limits and Pb material concentration limits Recordkeeping, Performance testing, VE Checks Yearly performance testing on one stack in the group. Annual test to cycle through each stack. Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit GP 017 PM, PM 10 

### , PM 2.5 

### , Pb, F, and Opacity limits and Pb and F material concentration limits Recordkeeping, Performance testing, VE Checks Initial and recurring performance testing to document compliance with emission units for each stack. Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit

### Technical Support Document, Permit Action Number: 06100067-004 Page 20 of 22 Date: 5/10/2012 Level* Requirement Additional Monitoring Discussion GP 018 PM, PM 10 

### , PM 2.5 

### , Pb, F, SO 2 

### , SAM, NO x 

### , CO, VOC, CO 2 

### e and Opacity limits. Pb and F material concentration limits Operating requirements, performance testing, monitoring, recordkeeping, reporting

CAM CEMS are required to show compliance with the NO x 

### , SO 2 

### , and CO limits. Initial and recurring performance tests are required to show compliance with PM, PM 10 

### , PM 2.5 

### , Pb, F, VOCs, and opacity. Performance testing for mercury emissions will occur 4 times in the first year of operation and at least annually in subsequent years. Natural gas usage will be measured and vendor information will be used to calculate and record CO 2 

### emissions on a monthly basis. The required CAM plan is included as Attachment 2. Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit GP 019 PM, PM 10 

### , PM 2.5 

### , Pb, F, SO 2 

### , NO x 

### , CO, and Opacity limits. Pb and F material concentration limits Operating requirements, monitoring, performance testing, recordkeeping CEMS are required on the Process Gas Heater to document compliance with NO x 

### and CO limits. Performance tests are required to document compliance with all other limits. Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit GP 020 Wet Scrubber requirements from Case-by-Case MACT Monitoring Monitoring devices to measure pressure drop and liquid flow rates in the scrubbers. Operational requirements and recordkeeping for each scrubber. GP 021 Fuel use, sulfur content of fuel, hours of operation Monitoring and recordkeeping Each engine requires a non-resettable hour meter to track operating hours. Recordkeeping is required to document sulfur content of fuel and operating hours. GP 022 CEMS Requirements Monitoring and recordkeeping Monitoring and recordkeeping requirements that apply to all CEMS to be installed. This includes all required certification testing. GP 023 PM and opacity (Minn. R. 7011.0715) Operating requirements Requires the installation of Low NO x 

### burners in the Ladle/Tundish Pre-heaters. Compliance with emission limits will be demonstrated through compliance with the limits in GP 009. GP 024 H 2 

### S Limits DMDS injection rate Monitoring and performance testing Initial and recurring performance tests to document compliance with H 2 

### S emissions. Monitoring and recordkeeping to document compliance with the DMDS injection rate. GP 025 CO Limits Performance testing Initial and recurring performance tests to document compliance with CO emissions. GP 026 PM and opacity (Minn. R. 7011.0715) Monitoring and recordkeeping Monitoring and recordkeeping to document operation of the buildings at a negative gauge pressure. This will ensure compliance with the emission limits. *Where the requirement appears in the permit (e.g., EU, SV, GP, etc.).

### Technical Support Document, Permit Action Number: 06100067-004 Page 21 of 22 Date: 5/10/2012 

### 3.5 Insignificant Activities Essar has several operations which are classified as in significant activities under the MPCA’s permitting rules. These are listed in Appendix G to the permit.

3.6 Permit Organization In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. Appendix A of the permit was created as a central location to store all of the most stringent BACT emission limits. This method provides one simple table which contains all the limits. This allows for great confidence in the accuracy of the limits, and will allow for simplified use of the permit. Requirement s to comply with Appendix A are listed throughout the permit along with the rule basis for each limit. All other requirements are listed in Table A and B of the permit for tracking purposes (e.g. performance te sts, recordkeeping, submittals, etc.)

3.7 Comments Received Public Notice Period: January 23, 2012 – February 22, 2012 EPA Construction Permit Review Period: January 23, 2012 – February 22, 2012 The MPCA received 6 comments during the public notice period. Attachment 8 of the TSD contains the comments received and the response to comments. The regulations provide EPA oppo rtunities to comment on both the construction and operating provisions of the permit. EPA’s revi ew of the construction provisions coincided with the Public Notice Period. The 45-day re view period (also known as “EPA’s operating permit review period”) was originally scheduled to run for 45 days beginning January 23, 2012. The EPA 45-day review period was restarted because there were comments on the permit. EAB Appeal Period: April 6, 2012 – May 9, 2012 EPA Operating Permit Review Period: April 6, 2012 – May 9, 2012 EPA notified the MPCA that the response to Co mment 6-6 needed to be adjusted to include NO x 

### SSM limits. These SSM limits are found for stacks in GP 009 and 019 only. As a result, NO x 

### modeling was updated to include NO x 

### SSM rates for the 1-hour NO 2 

### NAAQS. The updated rates and modeling results are included in Attachment 7 of the TSD. There was no change to the maximum mo deled concentrations as a result of this update. In addition, the permit limits for NO x 

### SSM rates were updated to a 1-hour averaging time to match the modeled rates, and the normal NO x 

### emission limits averaging times were changed back to what was listed in the draft permit because these limits were not relied on for modeling compliance with the 1-hour standard. The normal NO x 

### emission limits were used for modeling compliance with the annual standard, and ther efore the original averaging times are appropriate. EPA notified the MPCA in an email on May 9, 2012 that a ll of their comments had been addressed appropriately and that they would have no further comments, thereby e nding their 45 day review period on that day, May 9 th 

### , 2012.

4. Permit Fee Assessment
Attachment 9 to this TSD refers to the worksheet wh ich contains the MPCA’s assessment of Application and Additional Points used to determine the permit applicat ion fee for this permit action as required by Minn. R. 7002.0019. The permit action includes one permit applicatio n, which includes the incorporation of new units into NESHAP RRRRR and NSPS LL, air dispersion modeling, as well as BACT analysis for 10 pollutants (PM, PM 10 

### , PM 2.5 

### , Pb, F, SO 2 

### , NO x 

### , CO, VOC, and GHG). This equates to an additional 185 points to be added to the permit application. These fees were paid on May 4, 2012.

### Technical Support Document, Permit Action Number: 06100067-004 Page 22 of 22 Date: 5/10/2012 

### 5. Conclusion Based on the information provided by Essar, the MPCA ha s reasonable assurance that the proposed operation of the emission facility, as described in the Air Emissi on Permit No. 06100067-004 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Trevor Shearen (permit writer/engineer) Steve Palzkill (enforcement) Andrew Place (stack testing) Dave Beil (peer reviewer) AQ File No. 3784B; DQ 2789 (pre-applicatio n), 3704 (application received 10/14/2011) Attachments: 1. BACT Summary 2. CAM Plan 3. ESA Determination 4. Ozone Impact Analysis Technical Memorandum 5. PM 2.5 

### Class I Increment Technical Memorandum 6. PM 2.5 

### Class II Increment Technical Memorandum 7. NO x 

### Class II Modeling Technical Memorandum 8. Comments Received 8.1. Comments Received 8.2. Response to Comments 9. Points Calculator 10. Facility Description (in Delta) 11. Emissions Calculation Spreadsheets (Electronic only)

### Attachment 1 – BACT Summary
The proposed modification is a major modification for PM, PM 10 

### , PM 2.5 

### , SO 2 

### , NO x 

### , CO, VOC, F, Pb, and GHG. Any new major stationary source or major modification subj ect to a Prevention of Significant Deterioration (PSD) review must conduct an analysis to ensure the application of the Best A vailable Control Technology (BACT). The results of the BACT analysis for the proposed modificati ons project at Essar Steel Minnesota LLC form the basis for the selection of control technology and the resulting emission limitation s at each emissions unit. The BACT analysis in this report followed EP A’s five step top down approach:
Step 1 – Identify All Control Technologies Step 2 – Eliminate Technically Infeasible Options Step 3 – Rank Remaining Control Tech nologies by Control Effectiveness Step 4 – Evaluate Most Effective Cont rol Technologies and Document Results Step 5 – Select BACT
A summary of each of these steps for each pollutant is provided in Tables 1-1 through 1-11. Tables 1-12 and 1-13 presents a summary of the BACT emission limits and control technologies.

### Table 1-1: Taconite Pellet Indurating Furnace: Hood Exhaust & Waste Gas Stack; PM/PM 10 

### /PM 2.5 Step 1 Step 2 Step 3 Step 4 Step 5

Identify All Technologies Eliminate Technically Infeasible Options Rank Remaining Technologies Evaluate Most Effective Technologies and Document Results Select BACT Feasible? Basis for Determination of Infeasibility Rank Basis Outlet Conc.

(gr/dscf)

Fabric Filter (Baghouse) Yes 1 PM 0.0040 • More effective at capturing fine particulate matter. • Uses less electricity. • No wastewater generated. X PM 10 0.0080 PM 2.5 Clean Fuels (Natural Gas) Yes 5 Inherent to Design Project is designed and permitted to only use natural gas which produces the least amount of PM/PM 10 /PM 2.5 . X
Good Design and Operating Practices Yes 5 Inherent to Design X Dry Electrostatic Precipitator (Dry ESP) Yes 2 PM 0.0060 PM 10 0.012 PM 2.5 Wet Electrostatic Precipitator (Wet ESP) Yes 2 PM 0.0060 PM 10 0.012 PM 2.5

Wet Scrubber Yes 2 PM 0.0060 PM 10 0.012 PM 2.5 Centrifugal Separation (e.g. Cyclones) Yes 3 PM 0.080 PM 10 0.16 PM 2.5 Inertial Separators (Drop Out Box) Yes 4 PM 0.20 PM 10 0.40 PM 2.5

### Table 1-2: Taconite Pellet Indurating Furnace: Waste Gas Stack; SO 2 Step 1 Step 2 Step 3 Step 4 Step 5

Identify All Technologies Eliminate Technically Infeasible Options Rank Remaining Technologies Evaluate Most Effective Technologies and Document Results Select BACT Feasible? Basis for Determination of Infeasibility Rank Basis Outlet Conc.

Gas Suspension Absorber (GSA) Yes 1 5 ppm • No wastewater generated. • Uses 50% less water than a wet scrubber. • Compatible with activated carbon injection for

mercury control. X

Clean Fuels (Natural Gas) Yes 4 Inherent to Design Project is designed and permitted to only use natural gas which produces the least amount of SO 2 . X Good Design and Operating Practices Yes 4 Inherent to Design X

Spray Dryer Absorption Yes 1 5 ppm • No wastewater generated. • Uses 50% less water than a wet scrubber. • Compatible with activated carbon injection for

mercury control.

Absorber (Single High Pressure Wet Scrubber) Yes 1 5 ppm • Generates wastewater that requires treatment. • Additional processing equi pment is needed to convert

the sulfates generated by absorption to a solid waste (gypsum). • Absorption produces a visi ble plume due to the water

condensation in absorber exhaust plume. Absorber (Low Pressure Wet Scrubber) + Wet Electrostatic Precipitator Yes 2 5 ppm

Dry Sorbent Injection Yes 3 10 ppm

### Table 1-3: Taconite Pellet Indurating Furnace: Hood Exhaust; SO 2 Step 1 Step 2 Step 3 Step 4 Step 5

Identify All Technologies Eliminate Technically Infeasible Options Rank Remaining Technologies Evaluate Most Effective Technologies and Document Results Select BACT Feasible? Basis for Determination of Infeasibility Rank Basis Outlet Conc. Clean Fuels (Natural Gas) Yes 3 Inherent to Design Project is designed and permitted to only use natural gas which produces the least amount of SO 2 . X Good Design and Operating Practices Yes 3 Inherent to Design X Gas Suspension Absorber (GSA) Yes 1 5 ppm Not cost effective at $134,000/ton of SO 2 removed.

Spray Dryer Absorption Yes 1 5 ppm Not cost effective at $139,000/ton of SO 2 removed.

Absorber (Single High Pressure Wet Scrubber) Yes 1 5 ppm Not cost effective at $97,000/ton of SO 2 removed.

Absorber (Low Pressure Wet Scrubber) + Wet Electrostatic Precipitator Yes 2 5 ppm Not cost effective at $429,000/ton of SO 2 removed.

Dry Sorbent Injection Yes 2 6 ppm Not cost effective at $207,000/ton of SO 2 removed.

### Table 1-4: Taconite Pellet Indurating Furnace: Waste Gas Stack; NO x Step 1 Step 2 Step 3 Step 4 Step 5

Identify All Technologies Eliminate Technically Infeasible Options Rank Remaining Technologies Evaluate Most Effective Technologies and Document Results Select BACT Feasible? Basis for Determination of Infeasibility Rank Basis Outlet Conc. New Natural Gas Combustion Chamber and LE Burners Yes 4 28 ppm X

Good Design and Operating Practices Yes 5 Inherent to Design X

Selective Catalytic Reduction (SCR) + Reheat Yes 1 4 ppm • Not cost effective at $40,000/ton of NO x removed. • Technology transfer would require pilot testing before

implementation. • An additional 1,200 MMcf/yr of natural gas would

be required which would result in an additional 72,400 tpy of GHG emissions.

Regenerative Selective Catalytic Reduction (RSCR) + Reheat Yes 2 6 ppm • Not cost effective at $22,000/ton of NO x removed. • Technology transfer would require pilot testing before

implementation. • An additional 30.1 MMcf/yr of natural gas would be

required which would result in an additional 1,800 tpy of GHG emissions.

Low Temperature Oxidation (LoTOx) Yes 3 15-25 ppm • Not cost effective at $86,000/ton of NO x removed. • Technology transfer would require pilot testing before

implementation. • Generates wastewater which requires treatment. Non Selective Catalytic Reduction (NSCR) No Sulfur content of waste gas stream is too high fo r NSCR. The NSCR catalyst is very sensitive to poisoning by sulfur compounds. Applications to date limited primarily to natural gas fired combustion turbines.
Selective NonCatalytic Reduction (SNCR) + Reheat No • No location in the flue gas circuit where the temperatures are suitable. • Conc. in waste gas (37 ppm) is lower than SNCR floor of 100 ppm. • 2 -3 times more gas than SCR + reheat would be needed to reach SNCR operating

temperatures.
Low NO x /Ultra Low NO x Burners No Without special combustion ch amber design oxygen concentrations at burner are 15 - 20% oxygen. This is too high for a low NO x burner to operate properly. Combustion air is very hot (1,500 - 1,600°F). This further degrades burner performance. Induced Flue Gas Recirculation No • Not compatible with pellet furnace oxygen requirements.

External Flue Gas Recirculation No • Not compatible with pellet furnace oxygen requirements.

Low Excess Air (LEA) No • Not compatible with pellet furnace oxygen requirements.

Clean Fuels (Solid Fuels) No • Furnace is not designed to use solid fuel. • Solid fuels have lower NO x emissions but higher emissi ons of all other pollutants.

### Table 1-5: Taconite Pellet Indurating Furnace: Hood Exhaust; NO x Step 1 Step 2 Step 3 Step 4 Step 5

Identify All Technologies Eliminate Technically Infeasible Options Rank Remaining Technologies Evaluate Most Effective Technologies and Document Results Select BACT Feasible? Basis for Determination of Infeasibility Rank Basis Outlet Conc. New Natural Gas Combustion Chamber and LE Burners Yes 2 7 ppm X

Good Design and Operating Practices Yes 3 Inherent to Design X

Selective Catalytic Reduction (SCR) + Reheat Yes 1 2-3 ppm • Not cost effective at $140,000/ton of NO x removed. • Technology transfer would require pilot testing before

implementation. • An additional 1,300 MMcf/yr of natural gas would

be required which would result in an additional 77,300 tpy of GHG emissions.

Regenerative Selective Catalytic Reduction (RSCR) + Reheat Yes 1 2-3 ppm • Not cost effective at $85,000/ton of NO x removed. • Technology transfer would require pilot testing before

implementation. • An additional 41.1 MMcf/yr of natural gas would be

required which would result in an additional 2,500 tpy of GHG emissions. Non Selective Catalytic Reduction (NSCR) No Sulfur content of hood exhaust gas stream is too high for NSCR. The NSCR catalyst is very sensitive to poisoning by sulfur compounds. Applic ations to date limited primarily to natural gas fired combustion turbines.Selective NonCatalytic Reduction (SNCR) + Reheat No • No location in the flue gas circuit where the temperatures are suitable. • Conc. in waste gas (37 ppm) is lower than SNCR floor of 100 ppm. • 2 -3 times more gas than SCR + reheat would be needed to reach SNCR operating temperatures.
Low NO x /Ultra Low NO x Burners No Without special combustion ch amber design oxygen concentrations at burner are 15 - 20% oxygen. This is too high for a low NO x burner to operate properly. Combustion air is very hot (1,500 - 1,600°F). This further degrades burner performance. Low Temperature Oxidation (LoTOx) No Concentration in stream (10 ppm) is less than can be achieved by LoTOx (15 – 25 ppm).

Induced Flue Gas Recirculation No • Not compatible with pellet furnace oxygen requirements.

External Flue Gas Recirculation No • Not compatible with pellet furnace oxygen requirements.

Low Excess Air (LEA) No • Not compatible with pellet furnace oxygen requirements.

Clean Fuels (Solid Fuels) No • Furnace is not designed to use solid fuel. • Solid fuels have lower NO x emissions but higher emissi ons of all other pollutants.

### Table 1-6: Taconite Pellet Indurating Furnace: Hood Exhaust & Waste Gas Stack; CO & VOC
Step 1 Step 2 Step 3 Step 4 Step 5

Identify All Technologies Eliminate Technically Infeasible Options Rank Remaining Technologies Evaluate Most Effective Technologies and Document Results Select BACT Feasible? Basis for Determination of Infeasibility Rank Basis Control Efficiency Good Design and Operating Practices Yes 1 Inherent to Design X

Clean Fuels (Natural Gas) Yes 2 CO & VOC emissions
are insignificant. X

Thermal Oxidation (TO) No • Thermal Oxidation not effective below 100 pmm. • Concentration in streams <10 ppm. Catalytic Incineration No • Catalytic Incineration not effective below 100 pmm. • Concentration in streams <10 ppm.

### Table 1-7: Taconite Pellet Indurating Furnace: Waste Gas Stack; Fluoride
Step 1 Step 2 Step 3 Step 4 Step 5

Identify All Technologies Eliminate Technically Infeasible Options Rank Remaining Technologies Evaluate Most Effective Technologies and Document Results Select BACT Feasible? Basis for Determination of Infeasibility Rank Basis Control Efficiency

Gas Suspension Absorber (GSA) Yes 1 70-85% • No wastewater generated. • Uses 50% less water than a wet scrubber. • Same technology chosen for SO 2 control. • Compatible with activated carbon injection for

mercury control. X

Clean Fuels (Natural Gas) Yes 3 Inherent to Design Project is designed and permitted to only use natural gas which generates the least amount of F. X Good Design and Operating Practices Yes 3 Inherent to Design X

Absorber (Wet Scrubber) Yes 1 70-85% • Generates wastewater that requires treatment. • Additional processing equi pment is needed to convert

the sulfates generated by absorption to a solid waste (gypsum). • Absorption produces a visi ble plume due to the water

condensation in absorber exhaust plume.
Wet Electrostatic Precipitator Yes 1 70-85% • Generates wastewater that requires treatment. • Additional processing equi pment is needed to convert

the sulfates generated to a solid waste (gypsum). Spray Dryer Absorption Yes 2 35-70% Dry Sorbent Injection Yes 2 35-70%

### Table 1-8: Taconite Pellet Indurating Furnace: Hood Exhaust; Fluoride
Step 1 Step 2 Step 3 Step 4 Step 5

Identify All Technologies Eliminate Technically Infeasible Options Rank Remaining Technologies Evaluate Most Effective Technologies and Document Results Select BACT Feasible? Basis for Determination of Infeasibility Rank Basis Control Efficiency Clean Fuels (Natural Gas) Yes 6 Inherent to Design Project is designed and permitted to only use natural gas which generates the least amount of F. X Good Design and Operating Practices Yes 6 Inherent to Design X Gas Suspension Absorber (GSA) Yes 1 40-70% Uncontrolled F conc. = 1.8 ppm. Based on SO 2 control equipment not cost effective. Absorber (Wet Scrubber) Yes 1 40-70%
Wet Electrostatic Precipitator Yes 1 40-70% Spray Dryer Absorption Yes 4 0-40% Dry Sorbent Injection Yes 4 0-40%

### Table 1-9: Taconite Pellet Indurating Furnace: Hood Exhaust & Waste Gas Stack; Lead
Step 1 Step 2 Step 3 Step 4 Step 5

Identify All Technologies Eliminate Technically Infeasible Options Rank Remaining Technologies Evaluate Most Effective Technologies and Document Results Select BACT Feasible? Basis for Determination of Infeasibility Rank Basis Control Efficiency

Fabric Filter (Baghouse) Yes 1 98-99+% • More effective at capturing fine particulate matter. • Uses less electricity. • No wastewater generated. • Same technology selected for particulate control. X

Clean Fuels (Natural Gas) Yes 4 Inherent to Design Project is designed and permitted to only use natural gas which generates the least amount of Pb. X Good Design and Operating Practices Yes 4 Inherent to Design X Dry Electrostatic Precipitator (Dry ESP) Yes 1 98-99+% • More effective at capturing fine particulate matter. • Uses less electricity. • No wastewater generated. Wet Electrostatic Precipitator (Wet ESP) Yes 1 98-99+% • Able to remove other pollutants (SO 2 , NO x , acid gases). • Generates wastewater that must be treated. • Uses more electricity. Wet Scrubber Yes 1 98-99+% Centrifugal Separation (e.g. Cyclones) Yes 2 50-80%

Inertial Separators (Drop Out Box) Yes 3 <50%

### Table 1-10: Taconite Pellet Indurating Fu rnace: Hood Exhaust & Waste Gas Stack; GHG
Step 1 Step 2 Step 3 Step 4 Step 5

Identify All Technologies Eliminate Technically Infeasible Options Rank Remaining Technologies Evaluate Most Effective Technologies and Document Results Select BACT Feasible? Basis for Determination of Infeasibility Rank Basis Control Efficiency Clean Fuels (Natural Gas) Yes 1 Inherent to Design Project is designed and permitted to only use natural gas which generates the least amount of CO 2 e. X Energy Efficiency Measures Yes 1 Inherent to Design X Lower Emitting Processes -- SO 2 removal reagent Yes 1 Inherent to Design X
Lower Emitting Processes -- Alternate pellet additives No • Limestone addition is necessary for pellet hardness and as a fluxing agent. • No alternatives available.

CO 2 Capture Technologies
Post Combustion CO 2 Capture No • Not demonstrated at commercial scale. • High energy demand. • No feasible sequestration location. Oxyfuel Combustion with CO 2 Capture No • Oxygen requirements of the furnace are not compat ible with technology. • Not demonstrated on a commercial scale. • No feasible sequestration location. Gasification and Pre-combustion CO 2 Capture No • Furnace is not designed to burn hydrogen pr oduced from gasification of solid fuels. • No feasible sequestration location.

CO 2 Mineralization No • Not demonstrated at commercial scale. • High energy demand. CO 2 Sequestration Locations Deep Saline Aquifers No • Closest location is 600 miles from project. • No CO 2 transportation pipelines in the region. • Not demonstrated at commercial scale.

Oil & Gas Reserve No • Closest location is 550 miles from project. • No CO 2 transportation pipelines in the region. • Not demonstrated at commercial scale.
Un-mineable Coal Seam No • Closest location is 550 miles from project. • No CO 2 transportation pipelines in the region. • Not demonstrated at commercial scale.

### Table 1-11: Material Handling; PM/PM 10 

### /PM 2.5 Step 1 Step 2 Step 3 Step 4 Step 5

Identify All Technologies Eliminate Technically Infeasible Options Rank Remaining Technologies Evaluate Most Effective Technologies and Document Results Select BACT Feasible? Basis for Determination of Infeasibility Rank Basis Outlet Conc.

(gr/dscf)

Fabric Filter (Baghouse) Yes 1 0.0020 • More effective at capturing fine particulate matter. • Uses less electricity. • No wastewater generated. X

Wet Electrostatic Precipitator (Wet ESP) Yes 2 0.0040

Dry Electrostatic Precipitator (Dry ESP) Yes 3 0.0050

Wet Scrubber Yes 3 0.0050 Centrifugal Separation (e.g. Cyclones) Yes 4 0.10

Inertial Separators (Drop Out Box) Yes 5 0.25Table 1-12: Summary of BACT Limits – Material Handling SourcesSV ID EU ID CE ID*Emission Unit DescriptionPerformance StandardMass Emission LimitPM/PM10/PM2.5(gr/dscf)Lead(mg/kg)Fluoride(mg/kg)PM/PM10/PM2.5(lb/hr)Lead(lb/hr)Fluoride(lb/hr)Opacity(%)SV 016 EU 036 CE 014 Hearth Layer Bin0.0020 2.0 50 1.4E+00 2.8E-06 7.0E-05 5SV 017EU 037EU 106CE 015 Hearth Layer Feed0.0020 2.0 50 1.2E-01 2.4E-07 6.0E-06 5SV 020 EU 040 CE 021 Pellet Discharge0.0020 2.0 50 3.3E+00 6.7E-06 1.7E-04 5SV 021 EU 041 CE 022 Pellet Screening and Handling 0.0020 2.0 50 2.9E+00 5.8E-06 1.4E-04 5SV 022 EU 042 CE 023 Pellet Screenings to RegrindConveyors 0.0020 2.0 50 2.4E-02 4.7E-08 1.2E-06 5SV 023 EU 048 CE 024 Oxide Pellet Stockpile ConveyorGallery0.0020 2.0 50 7.7E-01 1.5E-06 3.8E-05 5SV 084 EU 176 CE 116 Primary Grinding Mill Line 30.0020 12 1.0 2.3E-01 2.8E-06 2.3E-07 5SV 085 EU 170 CE 115 Grizzly Transfer Tower0.0020 12 1.0 7.9E-02 9.5E-07 7.9E-08 5SV 086 EU 171 CE 110 Non-Magnetic Cobber Rejects Transfer Tower 0.0020 12 1.0 7.9E-02 9.5E-07 7.9E-08 5SV 087 EU 172 CE 111 Secondary Screening Crusher/Cobber Line 1 0.0020 12 1.0 3.9E-01 4.7E-06 3.9E-07 5SV 088 EU 173 CE 112 Secondary Screening Crusher/Cobber Line 2 0.0020 12 1.0 3.9E-01 4.7E-06 3.9E-07 5SV 089 EU 174 CE 113 Secondary Screening Crusher/Cobber Line 3 0.0020 12 1.0 3.9E-01 4.7E-06 3.9E-07 5SV 090 EU 175 CE 114 Secondary Screening Crusher/Cobber Line 4 0.0020 12 1.0 3.9E-01 4.7E-06 3.9E-07 5SV 091 EU 177 CE 119 Carbon Bin for Mercury Control0.0020 --- --- 1.7E-02 --- --- 5SV 092 EU 178 CE 120 Lime Bin for Scrubber0.0020 --- --- 1.7E-02 --- --- 5NAFS 017NADozer Activity at Tailings BasinFugitive Dust Control Plan5FS 018Grading at Tailings Basin5FS 019120K ton Concentrate Stockpile Loading5FS 021120K ton Concentrate Stockpile Loadout5FS 027Oxide Product Loadout to Railcars5*Control Equipment chosen as BACT for each EU isa fabric filter (baghouse) with Leak Detection.Table 1-13: Summary of BACT Limits – Indurating FurnaceSV ID EU ID EU Description CE ID CE Description Pollutant Performance Standard Mass Emission Limit Averaging TimeSV 018 EU 038FurnaceHood ExhaustCE 016Fabric Filter (baghouse)with Leak DetectionPM 0.0040 gr/dscf 27 (lb/hr)3-hourPM100.0080 gr/dscf54 (lb/hr)PM2.50.0080 gr/dscf54 (lb/hr)Pb 0.0040 gr/dscf0.021 (lb/hr)NA NAF 1.8 ppmv wet @ 15% O24.4 (lb/hr)3-hour rollingSO26.8 ppmv wet @ 15% O255.7 (lb/hr)3-hour rollingNA Good Combustion PracticesCO 1.9 ppmv wet @ 15% O26.8 (lb/hr)1-hour rollingVOC 0.60 ppmv wet @ 15% O23.3 (lb/hr)3-hour rollingNA NA Opacity5% NA 6-minuteSV 018/019CombinedEU 038/039CombinedFurnaceCE 020 Low NOx burners NOx0.25 lb/mmBtu135 (lb/hr)3-hour rollingNA NA CO2e NA710,000 ton/yr 12-month rolling sumSV 019 EU 039FurnaceWaste GasCE 019Fabric Filter (baghouse)with Leak DetectionPM 0.0040 gr/dscf18 (lb/hr)3-hourPM100.0080 gr/dscf37 (lb/hr)PM2.50.0080 gr/dscf37 (lb/hr)Pb 0.0040 gr/dscf0.021 (lb/hr)CE 117 GSA Dry ScrubberF 11.5 ppmv wet @ 15% O220.4 (lb/hr)3-hour rollingSO25.0 ppmv wet @ 15% O229.9 (lb/hr)3-hour rollingNA Good Combustion PracticesCO 7.4 ppmv wet @ 15% O219.3 (lb/hr)1-hour rollingVOC 2.3 ppmv wet @ 15% O29.3 lb/hr3-hour rollingNA NA Opacity5% NA 6-minute

### Attachment 2 – CAM Plan


## Compliance Assurance Monitoring Plan GSA Dry Scrubber with Lime for SO 2 

## Emissions Control Furnace Waste Gas

I. Background

A. Source Information Facility: Essar Steel Minnesota, LLC State Hwy 58 Nashwauk, MN 55769 Emission Unit(s) Description: Furnace Waste Gas Emission Unit(s) ID: EU 039 Stack ID: SV 019 APCD ID: CE 117
B. Applicable Regulation, Emissions Limit, and Monitoring Requirements Regulation: BACT under PSD
Emissions Limit: 5.0 ppm; 29.9 lb/hr SO 2 

### Monitoring Requirements: SO 2 

### CEM and stack flow rate monitor
C. Control Technology : GSA dry scrubber with lime solution

### II. Monitoring Approach

I. Indicator SO 2 

### CEM, O 2 

### meter and stack flow rate meter. Measurement Approach: The SO 2 

### concentration in ppm and emission rate in lb/hr will be continually monitored via a CEM. II. Indicator Range An excursion is defined as SO 2 

### emissions in excess of 5 ppm, or 30 lb/hr on a three hour block average basis during normal production pe riods. Excursions trigger an inspection, corrective action as necessary, and a reporting requirement. The suggested SO 2 

### CEM measurement range is 0 to 100 ppm SO 2 

### . The suggested stack flow rate meter measurement range is 0 – 400,000 scfm III. Performance Criteria
A. Data Representativeness The SO 2 

### CEM will measure the SO 2 

### content at the scrubber outlet. The O 2 

### meter will be used to correct the SO 2 

### concentration to a 15% O 2 

### basis. A stack flow rate meter will measure the stack flow rate for determining the SO 2 

### mass emission rate. B. Verification of Operational Status NA.

C. QA/QC Practices and Criteria The CEM will be installed, certified, calibra ted, and operated according to procedures identified in Minn. R. 7017.1002-.1220. The quality assurance procedures include initial analyzer certification, daily calibration drif t assessment, quarterly calibration gas audits and relative accuracy test audits (RATA). Th e accuracy of the stack flow meter will be verified during RATAs. In calendar years wh en a RATA is not required, the stack flow meter calibration will be checked at leas t once per manufacturer’s procedures. D. Monitoring Frequency The SO 2 

### concentration and emission rate will be measured continuously by the CEM and stack flow rate monitor. Data Collection Procedures Data will be collected by el ectronic data acquisition equi pment. Data will be collected at a minimum rate of one reading every 15 minutes, and stored as 1-hour averages according to procedures identified in Minn. R. 7017.1002 -.1220. Procedures specified in Minn. R. 7017.1160 will be followed for data collection during periods of monitor maintenance, monitor quality assurance checks and operat ional periods of less than one hour. The stack moisture co ntent, if needed, will also be verified during RATAs. Averaging period 3-hour (block) period periods based on the hourly averages data collected by the CEMS data acquisition system.

### III. Monitoring Approach Justification
A. Background The pollutant-specific emission unit is the Furnace Waste Gas. The source is subject to BACT under PSD and is ther efore not subject to the Minnesota Industrial Process Equipment Rule. The source will be equipped with a GSA dry scrubber with lime to control SO 2 

### emissions.

B. Rationale for Selection of Performance Indicators
SO 2 

### measurement by CEM with O 2 

### correction and stack flow rate measurement were selected because they provide the most accurate means to ensure performance on a real-time basis.
C. Rationale for Selection of Indicator Ranges The indicator range is based on the expected quantity of SO 2 

### in the offgas stream.
D. Control device operating parameter data collect ed used to justify the proposed indicator range Not Applicable. A continuous emissions monitoring system will be used to demonstrate compliance.
E. Test plan and schedule for obtaining data if performance test data are not available
If SO 2 

### concentrations are measured on a dry basis, stack test data will be used to determine the moisture content of the stack for the SO 2 

### mass emission rate calculations (stack flow is measured on a wet basis). The moisture content of the waste gas stack will be measured during the initial performance test, and thereafter during the RATA. The initial performance test will be conducted according the schedule in the Essar Steel Minnesota LLC’s operating permit. Th e RATA will be schedul ed per Minn. R. 7017.1170 requirements. Test procedures will be specified in the pre-test plan as required by Minn. R. 7017.2030.
F. Implementation plan
The SO 2 

### CEM and stack flow rate monitor will be inst alled per the requirements of Minn. R. 7017.1040 and calibrated per manufacturer’s specifications. The monitoring system will be installed, calibrated and operational prior to commencing the initial performanc e test as specified in Es sar Steel Minnesota LLC’s operating permit. The SO 2 

### CEMS will be certified per Minn. R. 7017.1050. Certification testing will be done concurrently with the initial performance test.

## Compliance Assurance Monitoring Plan Baghouses for Particulate Matter (PM 10 

## ) Emissions Control Pelletizer Waste Gas Stack and Hood Exhaust Stack

I. Background

A. Source Information Facility: Essar Steel Minnesota, LLC State Hwy 58 Nashwauk, MN 55769 Emission Unit(s) Description: Pelletizer Emission Unit(s) ID: EU 038, 039 Stack ID: SV 018, 019 APCD ID: CE 016, 019, 118
B. Applicable Regulation, Emissions Limit, and Monitoring Requirements Regulation: BACT under PSD
Emissions Limit: 0.008 gr/dscf (filterable) Monitoring Requirements: Bag leak detection sy stem, pressure drop indicators and baghouse inspection and maintenance program
C. Control Technology : Baghouses (CE 016, CE 019) and Multiclone (CE 118)

### II. Monitoring Approach

I. Indicators Bag leak detection system Baghouse cell pressure drop Inspection and maintenance program Measurement Approach: A bag leak detector will be inst alled at the baghouse exhaust. An alarm will sound to indicate a broken filter bag. Pressure drop indicators will be installed on each baghouse cell. Low pressure drop across the baghouse will be an indicator of potential bag leaks. The inspection and maintenanc e program will include routine inspections to make sure baghouse equipment is functioning properly, and routine preventative maintenance to minimize equipment failures. II. Indicator Range A bag break indicator will define excursions. Excursions trigger an inspection, corrective action as necessary, and a reporting requirement. Abnormally low pressure drop across a baghouse cell will indi cate the potential for leaks and/or bag failures. Excursions trigger an in spection, corrective action as necessary, and a reporting requirement. Initia lly, manufacturer’s specifications for pressure drop will be followed. The pressure drop specification may be adjusted if operating data indicates a different range is appropriate. The inspection and maintenanc e program will trigger corrective action as necessary, and a reporting requirement if an inspection identifies equipment which is not operating within manufacturer’s specifications and/or normal operating ranges. III. Performance Criteria
A. Data Representativeness The bag leak detector will be placed in the ductwork do wnstream of the baghouse. The pressure drop indicators will measure the pressure drop be tween the inlet and outlet of each baghouse cell. The inspection and maintena nce program will be consistent with the requirements for baghouses in the Taconite MACT (40 CFR 63 Subpart RRRR). B. Verification of Operational Status NA.

C. QA/QC Practices and Criteria The leak detector will be calibrated and inspected per manufacturer’s specifications, and per the baghouse leak detector specifications in the Taconite MACT. The baghouse cell pressure drop indicators will be calibrated annually. Monitoring equipment and process down time will be recorded in a log. No QA/QC program is needed for the inspection and maintenance program. D. Monitoring Frequency Leak detector

– continuous Pressure drop – daily reading Inspection and mainte nance program – the frequency of inspections will be consistent with the requirements for baghouses in the Taconite MACT. Data Collection Procedures The bag leak detector indica tion will be recorded via the melt shop process data acquisition system. Baghouse pressure drop readings will be co llected manually at least once per day. Inspection and mainte nance program records will be re corded manually at a frequency specified by plan. Averaging period None.

### III. Monitoring Approach Justification

A. Background The pollutant-specific emission units are the pelletizer waste gas and hood exhaust systems. The sources are subject to BACT under PSD and therefore not subject to the Minnesota Industrial Process Equipment Rule. The sources will be equipped with a baghouse to control PM 10 

### emissions.

B. Rationale for Selection of Performance Indicators Bag leak detectors have demonstrat ed the ability to identify excess ive particulate matter bypassing the baghouse, which may indicate leaking or broken bags. Pressure drop is commonly used as an indicator for proper baghouse operation. A pressure drop is created as gas flows through the baghouse duct work and filter bags. If a leak develops in the baghouse tube sheet or filter bag, gases flowing through the leak face less resistance than normal conditions and the pressure drop across the baghouse is reduced. The inspection and maintenance program is designed to make sure that all equipment is operating correctly and is properly maintained. The Taconite MACT requirements for baghouses will be followed to ensure that the program is consistent with approved EPA methodology.
Performance indicators were chosen to be consistent with the requirements of the Taconite MACT, which will enable Essar to have a single program for baghouse monitoring across the facility.

C. Rationale for Selection of Indicator Ranges An excursion is defined as excessive particulate matter bypassing the baghouse, activating a leak detection alarm, or causing a low pressured drop indication. When an excu rsion occurs, corrective action will be initiated, beginning with an evaluation of the occurrence to determine the action required to correct the situation. All excursions will be do cumented and reported. The range selected will be based on both the recommendations from the baghouse supplier and observed operating parameters during initial performance testing. An excursion in the inspection and maintenance program is defined as an operating parameter which is outside of normal operating parameters (e.g. a high dust hopper level), or equipment which does not meet inspection criteria (e.g. ho les or tears in filter bags). When an excursion occurs, corrective action will be initiated, beginning with an evaluation of the occurrence to determine the action required to correct the situation.

D. Control device operating parameter data collected used to justify the proposed indicator range Not Applicable. A continuous emissions monitoring system will be used to demonstrate compliance.

E. Test plan and schedule for obtaining data if performance test data are not available Performance testing will be conducted according to the schedule in the Essar Steel operating permit.

F. Implementation plan The bag leak detectors and pressure drop indicators will be installed and calibrated per manufacturer’s specifications. They will be installed, calibrated and operational prior to commencing the initial performance test as specified in Essar Steel Minnesota LLC’s operating permit.

## Compliance Assurance Monitoring Plan Proposed LE Burner for NO x 

## Emissions Control Pelletizer Waste Gas Stack and Hood Exhaust Stack

I. Background

A. Source Information Facility: Essar Steel Minnesota, LLC State Hwy 58 Nashwauk, MN 55769 Emission Unit(s) Description: Pelletizer Emission Unit(s) ID: EU 038, 039 Stack ID: SV 018, 019 APCD ID: CE 020
B. Applicable Regulation, Emissions Limit, and Monitoring Requirements Regulation: BACT under PSD
Emissions Limit: 0.25 lb/mmBtu; 135 lb/hr NO x 

### (with LE Burner)
Other Limit: None Monitoring Requirements: NO x 

### CEM and stack flow rate monitor
C. Control Technology : LE Burner

### II. Monitoring Approach

I. Indicator NO x 

### CEM, O 2 

### meter and stack flow rate meter. Measurement Approach: The NO x 

### concentration and emission rate will be measured continuously by the CEM and stack flow rate monitor. II. Indicator Range An excursion is defined as NO x 

### emissions in excess of 0.25 lb /mmBtu or 135 lb/hr on a 24 hour block average basis during normal prod uction periods. Excursions trigger an inspection, corrective action as necessary , and a reporting requirement. The suggested NO x 

### CEM measurement range is 0-100 ppm NO x 

### for monitoring emissions after control by Low NO x 

### LE burners, and will convert the ppm measurement to lb/mmBtu. The suggested stack flow rate meter me asurement range is 0-400,000 scfm. III. Performance Criteria
A. Data Representativeness The NO x 

### CEM will measure the NO x 

### content at the scrubber outlet. The O 2 

### meter will be used to correct the NO x 

### concentration to a 15% O 2 

### basis. A stack flow rate meter will measure the stack flow rate for determining the NO x 

### mass emission rate. B. Verification of Operational Status NA.

C. QA/QC Practices and Criteria The CEM will be installed, certified, calibra ted, and operated according to procedures identified in Minn. R. 7017.1002-.1220. The quality assurance procedures include initial analyzer certification, daily calibration drif t assessment, quarterly calibration gas audits and RATAs. The accuracy of the stack flow meter will be verified during RATAs. In calendar years when a RATA is not required, the stack flow meter calibration will be checked at least once per manufacturer’s procedures. D. Monitoring Frequency The NO x 

### concentration and emission rate will be measured continuously by the CEM and stack flow rate monitor. Data Collection Procedures Data will be collected by el ectronic data acquisition equi pment. Data will be collected at a minimum rate of one reading every 15 minutes, and stored as 1 hour averages according to procedures identified in Minn. R. 7017.1002 -.1220. Procedures specified in Minn. R. 7017.1160 will be followed for data collection during periods of monitor maintenance, monitor quality assurance checks and operat ional periods of less than one hour. The stack moisture co ntent, if needed, will also be verified during RATAs. Averaging period 24-hour (block) period based on th e hourly averages data collected by the CEMS data acquisition system.

### III. Monitoring Approach Justification

A. Background The pollutant-specific emission unit is the Indurating Furnace. The source is subject to BACT under PSD and is ther efore not subject to the Minnesota Industrial Process Equipment Rule. The source will be equipped with Low NO x 

### burners to control NO x 

### emissions.

B. Rationale for Selection of Performance Indicators
The NO x 

### measurement by CEM with O 2 

### correction and stack flow rate measurement were selected because they provide the most accurate means to ensure performance on a real-time basis.

C. Rationale for Selection of Indicator Ranges The indicator range is based on the expected quantity of NO x 

### in the offgas stream.

D. Control device operating parameter data collected used to justify the proposed indicator range Not Applicable. A continuous emissions monitoring system will be used to demonstrate compliance.

E. Test plan and schedule for obtaining data if performance test data are not available
If NO x 

### concentrations are measured on a dry basis, stack test data will be used to determine the moisture content of the stack for the NO x 

### mass emission rate calculations (stack flow is measured on a wet basis). The moisture content of the waste gas stack will be measured during the initial performance test, and thereafter during the RATA. The initial performance test will be conducted according the schedule in the Essar Steel Minnesota LLC’s operating permit. The RATA will be sche dule per Minn. R. 7017.1170 requirements. Test procedures will be specified in the pre-test plan as required by Minn. R. 017.2030.

F. Implementation plan
The NO x 

### CEMS, O 2 

### meter and stack flow rate monitor will be installed per the requirements of Minn. R. 7017.1040 and calibrated per manufacturer’s specifications. The monitoring system will be installed, calibrated and operational prior to commen cing the initial performance test as specified in Essar Steel’s operating permit. The NO x 

### CEMS will be certified per Minn. R. 7017.1050. Certification testing will be done concurrently with the initial pe rformance test. Initial operation of the CEMS will be to demonstrate compliance with the interim NO x 

### BACT limit (no controls).

### Attachment 3 - ESA Determination

1 

## Shearen, Trevor (MPCA)

From: Nick_Rowse@fws.gov Sent: Wednesday, October 19, 2011 2:16 PM To: Kangas, Kevin - ESML - MN Cc: Todd Fasking M.; Shearen, Trevor (MPCA); daryl.w.wierzbinski@usace.army.mil; Margaret_Rheude@fws.gov; Tony_Sullins@fws.gov Subject: Re: Section 7 Consultation for Proposed Essa r Steel Minnesota Modifications Project

Kevin W. Kengas HSE Director Essar Steel Minnesota LLC. 555 West 27th Street Hibbing, MN 55746

Dear Mr. Kangas,
Trevor Shearen of the MN Pollution Control Agency and I ju st discussed your letter regarding need for a Section 7 consultation for the proposed Essar Steel Modifications Project in Nashwauk, Minnesota. Because there is no federal action (e.g. a revised Corps of Engineers section 404 permit) , there is no requirement for the Fish and Wildlife Service (Service) to concur with the proposed modifications to the mine proposal. As you know, in 2007 the Service concurred with the Corps determination t hat the proposed action was not likely to adv ersely affect the Canada lynx, a federally threatened species. Since that time in 2009, the gray wolf was reinstated as a federally threatened species. However, since there is no current federal action for this project, I do not see the need to concur with this action. The Service does not concur with any non-federal entity unless they sp ecifically are identified as a federal representative.

Please be aware that bald eagles ( Haliaeetus leucocephalus ) and their nests are protected under the Bald and Golden Eagle Protection Act of 1940, as amended. According to the Corps 2007 Biological Assessment, there were two known bald eagle nests within Essar’s permit to mine boundary at t he time. Both nests are located 0.25 miles from the tailing basin and you determined these nesting eagles would not be dist urbed by mining, construction, or operating activities. Essar will continue to survey all project construction ar eas to identify eagle nests and will ensure they will not be disturbed. We do recommend that Essar Steel conduct an eagle ne st survey within a half-mile of any mining activity and within 660-feet of any construction activity prior to any proposed construction. If any bal d eagle nests are found within these surveyed areas, please contact Mags Rheude in our office at (612) 725-3548, ext. 2202 or by email at margaret_rheude@fws.gov

.
Please let me know if I can be of further assistance . by calling me at 612-725-3548 x2210 or by email at nick_rowse@fws.gov

. Sincerely,

Nick Rowse

Nick Rowse Fish and Wildlife Biologist Twin Cities Field Office U.S. Fish and Wildlife Service 4101 American Blvd. E. Bloomington, MN 55425-1665

### Attachment 4 – Ozone Impact Analysis



# Technical Memorandum

To: 

### Trevor Shearen, Minnesota Pollution Control Agency

From: 

### Jennifer Koenen, Barr Engineering Company Subject: 

### Ozone Impact Analysis

Date: 

### March 21, 2012 Project: 

### Essar Steel Minnesota LLC Expansion Project

cc: 

### Joe Henderson, MPCA Kevin Kangas, Essar Lori Stegink, Barr

In response to the United States Environm ental Protection Agency Region V’s comment 1 

### on Essar Steel Minnesota LLC’s (Essar) draft Prevention of Significa nt Deterioration (PSD) and Title V permit, this memorandum presents an ozone impact analysis for the Essar Steel Minnesota Modification (ESMM) project.
Supplemental Environmental Impact Statement (SEIS)
The SEIS for the ESMM project presented an assessment of potential cumulative impacts to air quality resulting from the project. This ozone impact analysis follows the structure and intent of the SEIS in providing local and regional context to ESMM projec t emissions. Consequently, several of the data sources used in the SEIS cumulative air quality impacts are referenced in this analysis.
One of the primary differences in this ozone impact s analysis as compared to the other cumulative air quality impacts analyses is that modeling of ozone im pacts is not technically or practically feasible 2 

### for determining an individual source’s contribution to gr ound-level ozone concentrations either near the facility or at long distance from the facility.

1 

### Comment 1 in a letter from Genevieve Damico - Chief, Air Permits Section USEPA Region V to Joe Henderson,

Strategic Projects Sector – Minnesota Pollution Control Agency (MPCA) February 23, 2012. 2 

### 40 CFR Part 51 Appendix W – Guideline on Air Quality Models - Section 5.2.1.a.To: Trevor Shearen, Minnesota Pollution Control Agency
From: Jennifer Koenen, Barr Engineering Company Subject: Ozone Impact Analysis
Date: March 21, 2012

cc: Joe Henderson, MPCA; Kevin Kang as, Essar; Lori Stegink, Barr



### Ozone Formation, Fate and Transport
Ozone is formed through complex photochemical reactions between NO x 

### , VOC, other non-regulated compounds (e.g., OH - 

### ), sunlight, and meteorological cond itions of wind speed, wind direction, temperature, and humidity. Elevated ozone concentr ations occur primarily during stable / stagnant atmospheric conditions in urban airsheds. 3 

### Minnesota generally does not experience long duration stagnation periods due to its ge ographic location and climate.
Ozone transport can be an important contri butor to a region’s ozone concentrations 4 

### , however, due to its distance from metropolitan areas and prevailing winds, nor thern Minnesota is not typically affected by long range ozone transport.
Ozone concentrations from 2008-2010 for Voyageurs National Park (VNP) are shown below and are below the applicable standard. VNP is located appr oximately 80 miles north of ESMM and is the only year-round ozone monitoring station in northern Minnesota. 5


### Table 1: Voyageurs National Park 8 Hour Ozone NAAQS Monitor

Year 8 Hour High 4 th 

### High Concentration (ppm) NAAQS (ppm) NAAQS (%) Data Source

2008 0.059 0.08 74% EPA Airdata website
2009 0.062 0.08 77% EPA Airdata website
2010 0.067 0.08 84% EPA Airdata website Average 0.063 0.08 78%

To attain this standard, the 3-year average of the fourth-highe st daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.08 ppm (80 ppb).

3 

### MPCA, 2011. Air Quality in Minnesota. 2011 Report to the Legislature. Ozone concentrations tend to be highest

just outside urban areas, si nce other pollutants emitted in urban centers ac tually destroy ground level ozone. As a result, MPCA does not monitor ozone in urban centers such as Minneapolis and St. Paul, but does in surrounding suburban areas. 4 

### See for example the Clean Air Interstate Rule (CAIR) replacement, called the Transport Rule, modifying

40 CFR Parts 51, 72, 73, 74, 77, 78, 96. 5 

### The MPCA conducts ozone monitoring at other stations in northern Minnesota from April through September.To: Trevor Shearen, Minnesota Pollution Control Agency
From: Jennifer Koenen, Barr Engineering Company Subject: Ozone Impact Analysis
Date: March 21, 2012

cc: Joe Henderson, MPCA; Kevin Kang as, Essar; Lori Stegink, Barr



### Ozone Precursor Emission Levels

NO x 

### and VOC emissions are both ozone precursors. NO x 

### emissions are primarily anthropogenic, whereas VOCs are emitted both from biogenic and anthropogeni c sources. Figure 1 shows the primary emission source types for NO x 

### and VOCs in Minnesota.
Figure 1: Minnesota Ozone Precursor Emissions by Source Type 6

6 

### Source: MPCA. Air Quality in Minnesota: Emerging Trends. 2009 Report to the LegislatureTo: Trevor Shearen, Minnesota Pollution Control Agency
From: Jennifer Koenen, Barr Engineering Company Subject: Ozone Impact Analysis
Date: March 21, 2012

cc: Joe Henderson, MPCA; Kevin Kang as, Essar; Lori Stegink, Barr



### Essar Facility NO x 

### and VOC Emissions Analysis
The Facility Emissions Summary on Form GI-07 in the October 2011 Air Permit Application lists the total controlled VOC emissions for Essar Steel at 175 TPY and NO x 

### at 905 TPY.
Table 2 compares reported actual statewide emissions in 2008 with emissions increases that would result from changes associated with the proposed ESMM proj ect and with changes associated with reasonably foreseeable projects in northeastern Minnesota (as reported in SEIS Table 5.1-3). Statewide VOC emissions from 1999 are also included in Table 2 7 

### . The table illustrates that proposed ESMM project emissions would be negligible compared to statewide emissions.
Table 2. Statewide Actual Emissions Compared with

Proposed and Reasonably Foreseeable Emissions

NO x 

### 2008 Actuals Proposed ESMM Project Reasonably Foreseeable Changes in NE MN Stationary sources (tons/yr) 129,000 905 -15,000 All sources (tons/yr) 391,000 -- -- % 2008, stationary -- 0.7% -11.6% % 2008, total -- 0.2% -3.8%

VOC 1999 Actuals Proposed ESMM Project Reasonably Foreseeable Changes in NE MN Stationary sources (tons/yr) 32,500 175 -- All sources (tons/yr) 397,000 -- % 1999, stationary -- 0.5% -- % 1999, total -- 0.04% --



### Summary

In conclusion, while ozone formation is complex and not directly linear with respect to emissions, given the ESMM project’s low NO x 

### and VOC emissions relative to statewide emissions, as well as the generally uniform ozone concentrations in northern Minneso ta and its favorable location (relative to ozone formation), there is no reason to believe that the ESMM project would have an impact on ozone concentrations either near to or far from the facility . Since ozone concentrations at the nearest receptor (VNP) are currently 78% of the standard (Table 1) , there is no reason to expect emissions from the ESMM project would alter compliance status with respect to the ozone standard.

7 

### 1999 VOC emissions from MPCA we bsite. http://www.pca.state.mn.us/inde x.php/topics/environmental-data/edaenvironmental-data-access/eda-air-quality-search es/eda-air-quality-search-pollutant-data.html

### Attachment 5 – PM 2.5 

### Class I Increment



# Technical Memorandum

To: 

### Sarah Seelen, Minnesota Pollution Control Agency Ruth Roberson, Minnesota Pollution Control Agency

From: 

### Andrew Skoglund, Barr Engineering Company Subject: 

### PM 2.5 

### Increment Class I Modeling Results

Date: 

### March 6, 2012 Project: 

### Essar Steel Minnesota LLC Expansion Project

cc: 

### Joe Henderson, MPCA Kevin Kangas, Essar Lori Stegink, Barr

This memo summarizes Class I PM 2.5 

### Increment results for the Essar Expansion project. Comments received from EPA Region 5 requested that a PM 2.5 

### Increment modeling analysis be conducted.

PM 2.5 

### Increment Method The modeling analysis uses the PM 2.5 

### inventory provided by MPCA February 24, 2012, updated with current source emissions data (included for review). Consistent with the permit application modeling, the 2002-2004 4 km grid CALMET meteorological data was utilized. The PM 2.5 

### Increment trigger date was October 20, 2011. The nearby PM 2.5 

### Increment consumers included in the modeling analysis were the U. S. Steel Keewatin Expansion, Mesabi Mining, and PolyMet Mining. The modeling results table is included below along with the 24-hour PM 2.5 

### Increment Results figure. The modeling files and source inventory are submitted electronically with this memo.

PM 2.5 

### Increment Modeling Results
Table 1 below shows the modeled PM 2.5 

### Increment Results are below the 24-hour and Annual Increment standards, assuming approval of the inventory. The inventory is included as an attachment.

Table 1: PM 2.5 

### Class I Increment Modeling Results

PM 2.5 

### Increment 24-Hour High 2 nd 

### High Results (μg/m 3 

### ) Annual Results (μg/m 3 

### ) All (Essar, Keetac Expansion, Mesabi Mining, PolyMet) 0.458 0.043
Class I Increment 2 1
% Increment 23% 4%


### The general distribution of the 24-hour and annual m odeled results are similar. Figure 1 below shows the 24-hour PM 2.5 

### modeled results. Figure 2 below shows the Annual PM 2.5 

### modeled results.

### Attachment 6 – PM 2.5 

### Class II Increment



# Technical Memorandum

To: 

### Ruth Roberson, Minnesota Pollution Control Agency

From: 

### Jennifer Koenen, Barr Engineering Company Subject: 

### PM 2.5 

### Increment Class II Modeling Results

Date: 

### March 2, 2012 Project: 

### Essar Steel Minnesota LLC Expansion Project

cc: 

### Joe Henderson, MPCA Kevin Kangas, Essar Lori Stegink, Barr

This memo summarizes Class II PM 2.5 

### Increment results for the Essar Expansion project. Comments received from EPA Region 5 requested that a PM 2.5 

### Increment modeling analysis be conducted. This modeling was performed as a response to that request.

PM 2.5 

### Increment Method Inputs for the modeling analysis use the PM 2.5 

### NAAQS modeling files included with the Essar Expansion Air Permit Application. Consistent with the pe rmit application modeling, the 2001-2005 Hibbing meteorological data was modeled with AERMOD versi on 09292. As described in the EPA comments, the PM 2.5 

### Increment trigger date to be used was October 20, 2011. Therefore, nearby PM 2.5 

### Increment consumers to be used in the modeling analysis include the U. S. Steel Keewatin Expansion. The modeling files that include these inputs are submi tted electronically and accompany this memo.

PM 2.5 

### Increment Modeling Results The modeling results summary table is included below along with the 24-hour PM 2.5 

### Increment Results figure. Table 1 below shows the modeled PM 2.5 

### Increment Results are below both the 24-hour and Annual Increment standards.

Table 1: PM 2.5 

### Increment Modeling Results

PM 2.5 

### Increment 24-Hour High 2 nd 

### High Results (ug/m 3 

### ) Annual Results (ug/m 3 

### ) All (Essar & Keetac Expansion) 7.1 1.3
Increment 9 4
% Increment 79% 33%


### The general distribution of the 24-hour and annual mode led results are similar. The 24-hour results, which have the higher modeled concentrations, are include d to demonstrate the distribution of the modeled results. Figure 1 below shows the 24-hour PM 2.5 

### modeled results.

### Attachment 7 – NO x 

### Class II Modeling Update



# Technical Memorandum

To: 

### Ruth Roberson, Minnesota Pollution Control Agency

From: 

### Jennifer Koenen, Barr Engineering Company Subject: 

### 1-Hour NO 2 

### NAAQS Class II Modeling Results

Date: 

### April 26, 2012 Project: 

### Essar Steel Minnesota LLC Expansion Project

cc: 

### Joe Henderson, MPCA Trevor Shearen, MPCA Kevin Kangas, Essar Lori Stegink, Barr

This memo summarizes updates to the Class II 1-hour NO 2 

### NAAQS results for the Essar Expansion project. Comments received from EPA Region 5 requested that a revised 1-hour NO 2 

### NAAQS modeling analysis be conducted using the startup/shutdown NO x 

### emission limits for the DRI and Steel Area. This modeling was performed as a response to that request.

Revised 1-Hour NO x 

### Emission Rates
Table 1 below lists the sources identified as having a NO x 

### startup/shutdown short-term emission limit. It also lists the previously submitted model emissi on rate and the revised emission rate based on the startup/shutdown emission limits. Consistent w ith the permit application modeling, the 2001-2005 Hibbing meteorological data was modeled with AERMOD version 09292. The modeling files that include these inputs are submitted electronically and accompany this memo.

Table 1: NO x 

### Modeled Emission Rates

Stack Vent ID Emission Unit Description Submitted 1-Hour NO x 

### Startup/Shutdown 1-Hour NO x 

### (lb/hr) (g/s) (lb/hr) (g/s) SV 028 EU 065 Line 1 Package Boiler 3.5 0.4429 10 1.260

SV 030 EU 066 Line 1 DRI Process Heater 21.2 2.674 60.6 7.635

SV 044 EU 128 Line 1 Ladle/Tundish Preheaters Line 1 Electric Arc Furnace Line 1 Ladle Metallurgy Furnace Line 1 Casting Area 53.3 6.717 110 13.86

SV 050 EU 137 Vacuum Degasser Boiler 3.5 0.4429 10 1.260

SV 062 EU 069 Line 1 P.T.S Heater 0.4 0.05075 1.2 0.1512To: Ruth Roberson, Minnesota Pollution Control Agency
From: Jennifer Koenen, Barr Engineering Company Subject: 1-Hour NO 2 NAAQS Class II Modeling Results
Date: April 26, 2012

cc: Joe Henderson, MPCA Trevor Shearen, MPCA Kevin Kangas, Essar Lori Stegink, Barr



### 1-Hour NO 2 

### NAAQS Modeling Results
Table 2 shows the previous maximum modeled 1- hour NAAQS concentration and the new 1-hour NO 2 

### modeled concentration. The emission increases for the sources listed in Table 1 resulted in small changes in modeled concentration near the facility boundary . However, the modeling demonstration also shows that the emission increases do not have an impact on the maximum modeled concentrations, which are dominated by contributions from other sources.

Table 2: NO 2 

### 1-Hour NAAQS Modeling Results

NO 2 

### NAAQS 1-Hour High 8th High Submitted Results (μg/m 3 

### ) 1-Hour High 8th High New Results (μg/m 3 

### ) Cumulative Modeling Results

w/o Background 138 138

Cumulative Modeling Results

w/ 28 μg/m 3 

### background 166 166

NAAQS 188 188

### Attachment 8.1 – Comments Received

On February 9, 2012 a public meeting on the Essar Steel Minnesota modification project draft air quality permit was held at the Nashwauk-Keewatin High Sc hool. As part of the meeting a video and audio recording was made and individuals were allowe d to speak and have comments recorded. Two individuals chose to speak and approximate transcri pts of their statements are below. Comments were taken from their statements and placed in th e MPCA response to comments document. These comments will be responded to. Additional information in each statement is noted for the record and will not be responded to in the response to comment document.

Comment 1 Chris Wright 31360 Rocky Shores Lane Pengilly, MN 55775 Snowball Lake [My question comes in the form of the monitoring. Who is supposed to be the ones doing this monitoring? I’ve sent pictures in. They’ve already failed in the fugitive dust control, and it’s just going to get worse when they start to mine. It’s affecting ever ybody in an adverse way. My kids can’t go out and build a snowman in our yard, how is that fair? This was supposed to be our dream home that we built, we live on a lake, it was supposed to be the best years of my life right now, and I feel like I’m living a nightmare. I don’t think it’s fair, they’re monitori ng themselves. How does that work, can somebody explain it? You have mentioned the modeling that was done. They bought three houses on our lake, because they are in the bad air and noise pollution zo ne. But yet there’s nothing between except for lake, and they left the rest of us. I don’t understand this . How is that air and noise not traveling across that lake? If you’ve ever been to a lake, you can yell acro ss the lake and you can hear it. My wife is now on a daily asthma treatment, for the first time in her life, she’s 39 years old. We couldn’t figure it out until my kids went out in December to make snowmen, they came in, they were red. I realize this is the stuff we are breathing. Are we going to wait until a bunch of people show up with cancer before something happens, before somebody helps us? I don’t think it is right. I would like to see some help here.]

Comment 2 Terry Thompson 17882 Little McCarthy Lake Road Nashwauk, MN 55769 Little McCarthy Lake [I’m a half mile through the woods from your entrance to your plant. And we get dust, only when the wind is out of the south. But the noise, every time you dump a pile of rocks on th at stockpile, it’s like it’s in our back yard. We can’t sit outside in the summer time. Now, nobody wants to buy our homes, because of the noise. I have a lot of lake shore, it should be easy to sell. And no help, I’ve called Essar, they’re going to have meetings, don’t hear anything. My yard in the wintertime is brown sometimes, just when the wind is out of the south where I live. But for me, it ’s the noise, and all this stuff tonight, you had all these other emissions, but no noise, the CATs, it’s lik e they’re in my back yard. You bought the land across the road from me, 800 feet away yo u bought the house, and then you st opped. In ’75 Hanna was going to mine the same body of ore, I have all the prints, they had a 3⁄4 mile “dead zone”. Essar has nothing.]

## February 17, 2012

VIA FEDEX and FACSIMILE
Trevor Shearen, PE, Stra tegic Projects Sector Industrial Division, Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, MN 55155
Fax: (651) 757-2717

Re: Comment on Draft Permit for Essar Steel Minnesota

These comments are submitted on behal f of the Minnesota Center for Environmental Advocacy and the Midwest En vironmental Defense Center and their members. We appreciate t he opportunity to provide th ese comments regarding the Essar Steel Minnesota Facility in Nash wauk, Itasca County, Minnesota.
Comment 1: MPCA must do an analysis of the facility’s compliance with the PM2.5 increment (Class I and Class 2).

EPA has established PM2.5 increments th at apply after the effective date of October 20, 2011. 75 Fed. Reg. 64,864. Si nce Essar Steel will receive its PSD permit after the effective date, it must show that its emissions will not cause or contribute to a violation of the increment. 75 FR at 64,899 ("each source that receives its PSD permit after the effective date of t he PM2.5 increments [Oct 20, 2011], regardless of when the application was submitted, to provide a demonstration that the source's proposed emissions increase, along with other increm ent-consuming emissions, will not cause or contribute to a violation of t he PM2.5 increments."). Howeve r, in the draft permit and

### 2 

## statement of basis it appears that MPCA has not undertaken this analysis. MPCA must correct this omission.
Comment 2: MPCA must make its analys is of the facility’s PM2.5 increment compliance available to the public fo r a period of public notice and comment. Section 165(a)(2) of the Act, 42 U.S.C. § 7475(a)(2), requires that “a public hearing [be] held with an opportunity for in terested persons... to appear and submit written or oral presentations on the air quality impact ...” Additionally, § 7475(a)(3) requires that the facility demons trate that it will not cause a violation of increment and § 7475(e)(3)(B) and (C) require the analysis of air quality impacts to be done and the results to “be available at the time of the public hearing on the application.” Furthermore, MPCA must specify its modelin g procedures with reas onable particularity” in the public notice. 42 U.S.C. § 7475(e)(3)(D). This was not done for any PM2.5 increment modeling. Ther efore, when MPCA corrects its omission noted above, and requires Essar to demonstrate that it will not cause or contribute to a violation of any PM2.5 increment, MPCA must undergo a new notice and comment period for the permit.
The applicable regulations provide that where additi ons to the record are “substantial,” the permitting aut hority must reopen the record in one of three ways: (1) by preparing a new draft permit subject to th e full public comment process; (2) preparing a revised statement of bas is and reopening the comment period; or (3) reopening or extending the comment period. 40 C.F.R. § 124.14(b). T here is no question that including an increment analysis that was not done prior to, and not included in the supporting documents available to the public for the original public notice and comment period, is a “substantial” additional to t he record. Merely in cluding an increment analysis in the final permit decision does not satisfy the Clean Air Act’s public notice and participation requirements.
Further still, 40 C.F.R. § 52. 21(q) requires MPCA to fo llow the procedures in 40 C.F.R. 52.21(r)(1979), whic h requires that the increment consumptio n be included in the public notice. 40 C.F.R. § 52.21(r)(2)(iii) (1979); see also, In re Hadson Power 14- Buena Vista , 4 E.A.D. 258, 272 (EAB 1992).
Comment 3: The Air Quality Impact Analysis Is Improperly Based On Background Concentrations That Are Not From Monitors That Meet The Applicable Requirements.
PSD permitting must include an analysis of the permittee’s air quality impacts, combined with the impacts from nearby sources and background concentrations. Background concentrations must be from eit her site-specific monitoring located in

### 3 

## specific places at the site of the proposed pr oject, or from existi ng monitors that meet specific requirements for location, data qua lity, and the currentne ss of the data. For example, if data from an existi ng off-site monitor is used, t he monitor must be located in the area of maximum concentration increas e from the proposed fa cility, the maximum concentration from existing sources, and t he area of maximum co mbined impact from existing and new sources. Generally, monitors located more than 10 km cannot be used for determining background concentrations for the propose PSD project analysis. This is especially true of a multi-source area like the one in which the permittee is constructing. 1 

## Moreover, the applicant and the permitting agency must provide a specific basis in the permit record fo r using off-site monitors for background concentrations.
The permit at issue here appears to use background data distant from the proposed project. (MPCA’s Te chnical Support Document does not identify the basis for the background concentrations, so we assume they are directly from page 64 of the application.) Not only do those data not meet the requirements for being representative of location, and not only are some not curr ent, but MPCA has not made the basis for using those data available in the public record.
Furthermore, it appears that the background concentrations do not even represent monitored concentra tions. For example, the PM 2.5 

## background concentrations are from Virginia, Mi nnesota, but reduced by 5%, the NOx concentrations are from Cloquet, Minnesot a, but reduced by 20%, and the SO 2 

## concentrations are from Rosemount, Minnesota, and also reduced by 20%. See Application at p. 64. There is no legal or factual basis for these made-up background concentrations.
The air impact analysis must be redone by using background data from sitespecific monitors or monitors that meet t he requirements to use substituted data from off-site monitors. If MPCA dec ides to use substituted data from off-site monitors, it must make sure the record is su fficient to demonstrate that th ose monitor data satisfy the applicable requirements in EPA’s Monitoring Gu idelines. MPCA mu st then make the new analysis available to the public in a new notice and provide a new public comment process.

1 

### Other emission sources in the area include U.S. Steel Keewatin, Hibbing Taconite, United Taconite Fairlane Plant Blandin Paper Co., Minntac, Hibbing Public Utility, and Minnesota Power Boswell Energy Center.

### 4 

## Comment 4: Adding A Monitored Desi gn Value to A Modeled Design Value Does Not Predict the Maximum Impact.
It is not clear whether the air quality anal ysis for this permit im properly combines a background and modeled value that are bot h expressed based on the form of the standard (i.e., as a 98 th 

## or 99 th 

## percentile of modeled or monito red values). Specifically, the analysis starts with a background concentra tion that represents the design value based on the form of the standard (i.e., 3-ye ar average H2H for PM2.5, 3-year average H8H for NOx, and 3-year average H4H for SO2). The facility’s impact is then modeled. It is not clear whether the modeled concentra tion for any of the po llutants is expressed as the design value based on the form of the standard (H2H, H8H or H4) or as the single maximum concentration, and whether two design values (each based on the % form of the standard) combined. At a minimum, MPCA should be clear in the record and the public documents how it determined the total modeled concentrations.
EPA guidance has explained that combining a 98 th 

## percentile monitored value with a 98 th 

## percentile of modeled values does not represent the maximum 98 th 

## percentile of total impacts and therefore not protective of the NAAQS. Theref ore, EPA has cautioned that if the 3-year 98 th 

## percentile design value is used as background, then the modeled concentration used in the cumulative im pact analysis should be the average of the highest modeled concentration—not the 98 th 

## percentile concentration. See e.g
., Memorandum from Stephen Page, Modeling Procedures for Determining Compliance with PM2.5 NAAQS at p. 8 (Marc h 23, 2010). Alternatively, if the modeled result is expressed based on the form of the standard (e.g., 98 th 

## percentile), then it should be added to the single highest m onitored value and not the 98 th 

## percentile of the monitored values. See Memorandum from Anna Marie W ood, EPA OAQPS, General Guidance for Implementing the 1-hour NO 2 National Ambient Air Qualit y Standard in Prevention of the Significant Deterioration Permits, Incl uding an Interim 1-hour NO2 Significant Impact Level at p. 18 (June 28, 2010)
Therefore, if any of MPCA’s air quality impact analyses fail to account for maximum possible ambient concentrations due to the form of the standard, the analysis must be redone. Once redone, the results mu st be included in a new public notice and MPCA must provide for a new public comment period.
Comment 5: Using SILs to Excuse M odeled NAAQS Violations Is Incorrect.

While the MPCA’s statement of basis and public notice documents fail to point it out, the air quality analysis done for this facilit y actually predicts NAAQS violations. However, the permittee appears to discard certain modeled violations based on a socalled “culpability analysis” by applying “SILs” to claim that where the facility’s impact is

### 5 

## below the SIL, its impact does not count towa rds a NAAQS violation. There is no lawful basis for this.
Moreover, to the extent that the a pplicant and MPCA claim that a “SIL” represents a de minimis air impact, there is no basis in the record for such a finding. To the extent that MPCA intends to rely on SILs based on a de minimis theory, it has a burden of creating a factual record sufficient to support that theory. It has not done so here.
Furthermore, even if the use of a SIL fo r a “culpability” anal ysis was legal, the applicant’s analysis is incomplete. In Tabl e 5 of Appendix E of t he Application, the applicant applies a “SIL” to discount the “M aximum Modeled Concent ration.” However, it fails to disclose whether the next-highest concentration was also discounted. In other words, the record is not clear as to how many modeled violations are ignored based on a “culpability” analysis. The applicant only appears to have disclosed the first maximum concentration that was ignored. All modeled violations should be disclosed and, for each, the basis for ignoring t hem in the PSD permit analysis.
For example, Appendix E, T able 5 of the Application notes that the highest 24- hour PM2.5 modeled impact was 31 ug/ m3, which was ignored based on the “culpability” analysis. However, in the MPCA’s Technical Support Document, the maximum modeled concentration used for the anal ysis was 15 ug/m3. It is unclear (at best): (a) whether there were any modeled concentrations between 15 and 31 ug/m3, (b) whether the applicant similarly ignored thos e results, and (c) if so, on what basis. If any modeled concentrations were ignored ba sed on a culpability analysis, other than the maximum modeled concentration, thos e must be disclosed and the basis for ignoring them must also be set forth in the public record. (A gain, of course, there is no legal or factual basis in the record fo r ignoring any, including the maximum modeled concentration).
Thank you for this opportunity to comm ent on the permit. Please let us know when MPCA decides to renotice a revised draft permit and extend the comment period to address the issues above. If MPCA doe s not extend the comment period, we request that you send notice of t he permit decision to us.

Regards,

Midwest Environmental Defense Center

Minnesota Center for Environmental Advocacy

# Minnesota Pollution Control Agency 

# COMMENT FORM

for the Essar Steel Minnesota Draft Air Permit Modifications



## NAME (please print) 

# J_ ii. 

# f2oy 

# P L """ <r

# ll'~©~ll\W~ 1W

# ~-~EB212012**~** BY:-------------

ADDRESS

__

# =tf~v~,~v~3~g_b 

# __________________________ _
STATE 

# /11/IJ ZIP 

# f{'·r'77 f

All comments must be received by the MPCA by 4:30p.m. on Feb. 22,2012.

This form may be dropped into the specially-marked comment form box at the February 9, 2012 informational meeting in Nashwauk, Minnesota or mailed to the attention of Trevor Shearen at MPCA, 520 Lafayette Road North, 

### St. Paul, MN 55155 or faxed to him at651-296-8683. Comments may also be emailed to trevor.shearen@state.mn.us.



### The following comments are about the proposed Essar Steel Minnesota air perm it modifications (attach additional pages as necessary):

## Shearen, Trevor (MPCA)

From: Mindy Thomsen-Tammi [mindy03@hotmail.com] Sent: Tuesday, February 21, 2012 6:02 PM To: Shearen, Trevor (MPCA) Subject: Essar Steel



## Trevor, I left you a voicemail requesting a petition to the Co mmissioner that the MPCA Citizen's Board consider the permit matter for Essar Steel Minnesota LLC. I am a concerned neighbor to this proposed facilit y and live only a half mile from the plant on Little McCarthy Lake. Currently there is damage to my house fr om the blasting at the Essar site. I am concerned it will only get worse from here. Given the lack of response of Essar to promised m eetings with me regarding the project and that many contractors are in court battles with Essar to receive pa yment for services, I have no confidence that Essar will adhere to or comply with the proposed air permit. I hope that the Citizen's Board will he ar my case that Essar should not be issued this permit since they do not follow through on commitments made to neighbors and hi red contractors. If they are not paying their bills now, why would they honor and comply with the proposed air permit? Please contact me with any questions you have and I would like the opportunity to make my case to the Board.
Thank you,
Terry Thomsen My email: tthomsen@mnpower.com House Phone: 218-885-3672

### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5



# FEB 2 

# 1 7012

Joe Henderson Strategic Projects Sector Industrial Division 77 WEST JACKSON BOULEVARD CHICAGO
, IL 60604-3590

REPLY TO THE ATIENTION OF :



## Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155

Dear Mr. Henderso n:

We have reviewed the Minneso ta Pollution Control Agency's (MPCA) draft prevention of significant deterioration (PSD) and Title V permit for Essar Steel Minnesota, LLC (Essar) in Nashwauk, Minnesota (permit number 061 00067-004) to modify a project already under construction for the previously permitted Minnesota Steel Industries (MSI)

. T h e p ropos ed Essar project modification encompasses activities covered in the MSI project includ ing mining, ore processing, direct reduced iron (DRI) production and steel-making
, but will also increase taconite pellet production and associated min ing and tailings generation rates. The proposed project is a major source of emissions of greenhouse gases (GHG)
, nitrogen oxides (NOx), sulfur dioxide (S0 2 ), 

## carbon monoxide (CO), volatile organic compounds, fluorides, and particulate matter (PM), including PM less than 10 microns in size (PM 10 ) 

## and less than 2.5 microns in size (PM 2 .s).

In order to ensure that the project meets Federal Clean Air Act (CAA) requirements, that the permit will provide necessary information so that th e basis for t he permit decision is transparen t and re adily accessible to the pub lic, and that the permit record provides adequate support for the decision, the U.S. Envi ronmen ta l Protection Agency has the following comments:

1. 

## The perm i t record does not appear to include any air quality analysis to show that this

source wi ll not cause a violation of the ozone national ambient a ir quality standards. 40 CFR 51.166(K); 40 CFR 51.166(m)

. EPA's 8-hour ozone implementation phase 2 rule (November 29, 2005; 70 FR 71612) requires that NOx be considered as an ozone precurso r under PSD. One of the elements of that rule is a requirement that the PSD program regula tions define the term "significant" for ozone to include 40 tons per year (tpy) ofNOx. See 40 CFR 51.166(b)(23)(i). In accordance with 40 CFR 51.166(m)(1)(a),

a permit application must contain an air qua l ity analysis for each pollutant that a new
source would have the potential t o emit in 

## significant amounts. Since the Es sar modification project has NOx emissions above this significance threshold for ozone, EPA regulations require that the r ecord contain an ozone impact ana l ysis for this source. A quantitative modeling analysis is not necessari l y required but MPCA sho uld consult wit h EPA Reg ion 5 regarding th e appropriate form fo r s u ch an ana l ysis in this case. 40 CFR Part 51
, Appendix W, 5.2.1.c.

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (50% Postconsumer)

## 2. The permit record does not include a PM2.s increment analysis. At 75 Fed. Reg. 64864, EPA establishes increments for PM 2

. 5 

## pursuant to the CAA. In the preamble to the 20 I 0 final rule promulgating the PM 2

. 5 

## increments, we indicated that we would require sources seeking a PSD permit under the Federal PSD program to complete an increment analysis

as a prerequisite to the permit being issued if the date of issuance will occur after the trigger date (October 20, 2011), when the PM 25 

## increments became effective under the Federal PSD program. Please require Essar to complete a PM2.s increment analysis and include it as part of the permit record.

3. The "Test & 

## Set "provisions for PM 2

. 5 

## include a requirement that the Pem1ittee shall submit an application for a major permit amendment within 910 days of project start up. Essar is a major source of PM 25 

## emissions. The permit initially establishes Best Available Control Technology (BACT) limits for PM 2.s that are equivalent to the PM10 BACT limits. When the PM 25 

## BACT limits are revised, in keeping with EPA policy, they must undergo a reopening of the BACT analysis and subsequently must give a new opportunity for public comment. The permit language should be clarified wherever the "Test and Set" provisions are mentioned, including the Appendices.

4. P. A-21, Group 009/SV047 contains a requirement to keep EAF baghouse dust lead and fluoride concentrations to below 8000 mg/kg and 4600 mg/kg, respectively, using a 12 month rolling average. The permit does not appear to require monitoring of these permit conditions. The previous permit for Essar required weekly sampling and analysis to monitor these permit conditions. Please include monitoring that effectively demonstrates compliance with these provisions.

5. P. A- 17 and A-21, contain requirements for fabric filters related to the Group 009 EAF baghouses. Please explain how monitoring for this group of emissions units adequately

ensures compliance (e.g., parametric monitoring of pressure drop across the baghouse) or add monitoring sufficient to ensure compliance to the permit.

6. Throughout the permit, limits for sulfur dioxide and nitrogen oxides are on alb/ton of liquid steel produced and lb/hour basis using a 3-hour average. Due to the I hour standards for sulfur dioxide and nitrogen oxides, limits for these pollutants should be on a similar short term basis, (i.e. on a 1 hour basis). Please revise this averaging period wherever it is appropriate in the permit.

7. P. A-22 contains a requirement for Group 009 emissions units under the Recordkeeping and Reporting Section that allows the Permittee to collect 12 months ofNOx continuous emission monitoring system (CEM) emissions data that can be submitted to the Commissioner ofMPCA who "shall establish a NOx limit and amend this permit to reflect the actual level of emissions". The NOx limits for Group 009 are BACT limits, and as such carmot be modified by the Commissioner without undergoing a BACT

### reopening or revision. In addition, a modification of a BACT limit cannot be established 

### with an administrative amendment.

8. The Technical Support Document (TSD) should include a more detailed discussion of the Modeled Class 1 Increment Concentrations (Table 7-3 in Essar's application) for the 24 hour PM 10 

### standard. Specifically, the TSD does not include this table and exact modeling concentrations do not appear to be mentioned in the narrative. The permit record should discuss results of the air quality modeling and typical procedures allowed by the PSD rules or EPA policy and guidance that impact permitting decisions.

9. In regard to the BACT analysis for GHGs, we have the following comments: 1) Table 1-10 is a summary chart for the steps involved in determining BACT control technology. However, the permit record does not explain why certain BACT technologies were eliminated. It 

### also lists "energy efficiency measures"

as inherent to the design of the indurating furnace, but it does not actually identify the energy efficiency measures or the degree to which the measures will reduce GHG emissions from the indurating furnace. Please revise the permit record to thoroughly explain all the decisions that were made in the BACT analysis, including justifications for rejecting control technologies that

were deemed not feasible.

2) Table 1-10 eliminates carbon capture and sequestration (CCS) as technically infeasible, without providing a basis for this statement. EPA generally considers CCS to be both commercially available and technically feasible for large carbon dioxide emitting facilities. (See EPA's permitting guidance at http:/ /www.epa.gov/nsr/ ghgdocs/ ghgpermittingguidance.pdf and control technology white paper at http:/ /www.epa.gov/nsr/ghgdocs/ironsteel.pdf). If MPCA cannot demonstrate why CCS is technically infeasible for the proposed project, then please revise Step 4 in the BACT analysis to include an evaluation of costs and other impacts of installing and operating CCS for this proposed project.

We appreciate the opportunity to provide comments on this draft permit. Please feel free to
contact me or have your staff contact.Tennifer Darrow, of my staff, at (312) 886-6315 if you have
any questions.
Sincerely, 

# ,; I

# v~~a;~ (}Genevieve Damico Chief Air Permits Section

### Attachment 8.2 – Response to Comments
Essar Steel Minnesota Modifications Project

Air Emissions Permit No. 06100067-004

RESPONSES TO COMMENTS ON THE DRAFT PERMIT
The Minnesota Pollution Control Agency (MPCA) has chosen to organize the responses to comments by name/date received/issue.
1. Comments by Chris Wright, Snow ball Lake. Comment recorded at public hearing, February 9, 2012, A video recording of Chris Wright’s complete statement is part of the permit file. Comments are paraphrased and responded to below. Additional stat ements which were made are noted in the record.

Comment 1-1: Commenter does not believe that the decision s on which properties Essar chose to buy

or not buy are fair and protective for all. Essar bought out three homes on Mr. Wright’s lake, but his home was not purchased by Essar. Response: Decisions on property acquisition are made by the project proposer. Each proposer must consider many things, including the requirement to control access to all land within the ambient air boundary and to model compliance with ambient ai r quality standards at that boundary. The MPCA does not set the ambient air boundary, rather the MPCA reviews modeling submitted by the proposer and the MPCA confirms whether the modeling result s demonstrate compliance with standards at the ambient boundary selected by the company. The ambient air boundary selected by Essar Steel has not changed since the Minnesota Steel Industries (M SI) Environmental Impact Statement (EIS) was completed in 2007. The three homes mentioned by the commenter are wi thin the ambient air boundary and therefore Essar needed to purchas e them. The commenter’s home is outside the ambient air boundary. The MSI EIS and the Essar Supplemental EIS were each deemed to be adequate and both concluded that the Air quality impacts of the projects would be below risk levels of significant concern to human health at the ambient air boundary.

Comment 1-2: Commenter questions who is supposed to be doing the monitoring. Commenter expresses concern that the facility is monitoring themselves. Response: The air permit requires multiple forms of moni toring to ensure compliance with the permit.

Forms of monitoring include visible emission checks on fugitive sources, bag leak detectors on baghouses, pressure drop readings on scrubbers, Continuous Emission Monitoring Systems (CEMS) on stacks to measure specific pollutant emissions, analysis of ore to comply with lead/fluoride feedrate limits, and stack testing. The permit also requires calibration and maintenance of monitoring equipment, recordkeeping to verify that the monitoring has been done proper ly, and scheduled reporting of many monitored parameters, exceedances, or deviat ions. Immediate reporting is also required for certain instances as outlined in rule and the facility permit. Records are kept and availabl e during inspections. Deviations reports are submitted to the agency and dealt with as needed. While the facility is required to perform all the mo nitoring on their own, the MPCA ensures compliance with the monitoring requirements through compliance inspections and reporting.

### Essar Steel Minnesota LLC Responses to Comments on the Nashwauk, Minnesota Draft Air Emission Permit

2 

### Comment 1-3: Commenter complained about the fugitive dust. He contends the dust issues will only get

worse when the facility begins to mine. He is co ncerned that his wife has developed asthma and his children are breathing the dust every day. He also ha s concerns that he does not want to wait until cancer appears before action is taken. He wo uld like to get help with his concerns now. Response: The facility is under construc tion. On December 2, 2011, a high velocity, shifting wind event occurred in the Nashwauk area, whic h resulted in a dusting event and complaints from residents. The MPCA followed up on the complaints and issued an enforcement action to Essar Steel on January 4, 2012. Corrective actions within the enforcement document required cha nges to better manage fugitive dust. Essar Steel made changes following the event a nd submitted final documentation of completion of all the enforcement action requirements on February 1, 2012. The required changes have been implemented. Any future fugitive dusting events or other environmental compliance complaints should be brought to the attention of MPCA enforcement staff using the Online Citizen Complaints Form (http://www.pca.st ate.mn.us/foyp21 ) or by calling 1-800-657-3864. Air pollutants, such as dust and the chemicals on dust, were estimated through modeling to assess potential human health impacts from the facility an d existing background. The comparisons that were done to estimate potential human health impacts were protective of public health including susceptible populations like children and the elderly. The comparis ons were also made in consideration of sensitive human health endpoints such as asthmatic episodes. The current fa cility operations environmental impacts, including potential human health impacts, were evaluated through the MSI EIS. The Essar Steel Modifications Project Supplemental EIS evaluated the environmental impacts of the changes proposed in the project and both demonstrated that health im pacts are unlikely, however this does not mean that all calculated or modeled impacts (risks) have been eliminated.

### Essar Steel Minnesota LLC Responses to Comments on the Nashwauk, Minnesota Draft Air Emission Permit

3 

### 2. Comments by Terry Thompson, Little McCarthy Lake, Nashwauk. Commen ts recorded at public hearing, February 9, 2012. A video recording of Terry Thompson’s complete stat ement is part of the permit file. Comments are paraphrased and responded to below. Additional stat ements which were made are noted in the record.

Comment 2-1: Commenter complained about the amount of noise generated by construction of the

facility. He believes that it has impacted his ability to sell his home. He feels that his lakeshore home should be easy to sell, but he claims that nobody wants to buy it. Response: The Minnesota Steel Industries (MSI) Environmental Impact Statement (EIS) addressed

whether or not potential noise from operation of th e facility would exceed the state noise standards. The assessment used daytime and nighttime standards for residential areas. Based on Minnesota Noise Standards and the total estimated no ise that would be generated at the plant facility, the facility would meet day and nighttime standards for the nearest residential receptors on the three nearby lakes (please see MSI EIS, Table 4.10.2 for applicable noise standards). The most restrictive state noise standard is the nighttime residential classification of 50 dB(A). Based on this analysis, the highest noise level at the nearest residential receptor is estimated to be 44 dB(A). Mitigation actions were identified in the MSI FEIS, and noise was not considered a chan ge in the project for the Essar Steel Minnesota Modification project. Therefore, no ise was adequately addressed. A copy of the MSI EIS can be found on the DNR’s web site at http:// www.dnr.state.mn.us/input/environme ntalreview/minnsteel/index.html

. Potential noise exceedances can be reported to th e MPCA using the Online Citizen Complaints Form (http://www.pca.st ate.mn.us/foyp21 ) or by calling 1-800-657-3864.

Comment 2-2: Commenter claims that the dust has made his yard brown in the winter and he claims

that Essar does not follow through on commitments made to meet with him. Response: The facility is under constructi on. On December 2, 2011, a high velocity, shifting wind event

occurred in the Nashwauk area, whic h resulted in a dusting event and complaints from residents. This dusting event resulted in a brown and red dust deposition on a number of residences surrounding Essar. The MPCA followed up on the complaints and issued an enforcement action to Essar on January 4, 2012. Corrective actions within the enforc ement document required changes to better manage fugitive dust. Essar made changes following the event and submitted final documentation of completion of all the enforcement action requirements on February 1, 201 2. The required changes have been implemented. Any future fugitive dusting events should be brough t to the attention of MPCA enforcement staff using the Online Citizen Complaints Form or by calling 1-800-657-3864. Following through on commitments to neighbors and pa ying local contractors in a timely manner is important, however it is not something the MPCA ha s information on nor is it regulated by the air quality permit. This issue is beyond the scope of this public notice and permitting action.

Comment 2-3: Commenter claims that Essar bought property directly across the road from his home and the home 800 feet away from his home and then stopped purchasing at his property line. He does not believe that this is fair. Response: Decisions on property acquisition are made by th e project proposer. Each proposer must consider

many things, including the requirement to control acce ss to all land within the ambient air boundary and to model compliance with ambient air quality standards at that boundary. The MPCA does not set the ambient air boundary, rather the MPCA reviews modeling subm itted by the proposer and the MPCA confirms whether the modeling results demonstrate compliance with standards at the ambient boundary selected by the company. The ambient air boundary selected by Essar has not changed since the MSI EIS was completed in 2007. The properties mentioned by the commenter are within the ambient air boundary and therefore Essar needed to purchase them. The comme nter’s home is outside the ambient air boundary.

### Essar Steel Minnesota LLC Responses to Comments on the Nashwauk, Minnesota Draft Air Emission Permit

4 

### 3. Comments by Midwest Environmental Defense Center and Minnesota Center for Environmental Advocacy. Letter received elec tronically February 17, 2012.

Comment 3-1 : MPCA must do an analysis of th e facility’s compliance with the PM 2.5 

### Increment (Class I and II). Response: The permit as placed on public notice January 23, 2012 recognized the need for PM 2.5 

### limits. Those limits were used in the modeling to show compliance with the PM 2.5 

### NAAQS as documented in the Technical Support Document (TSD). Based on this comment, a PM 2.5 

### Increment analysis was completed using the same permit limits. Compliance with the increment has also been demonstrated. Increment analysis has been conducted for Class I and Class II. Table 1 provides the results for the Class II PM 2.5 

### Increment modeling and Table 2 provides incremen t modeling results for Class I. The model results are below the increment for the 24-hour and Annual standard for both Class I and II.

Table 1: Class II PM 2.5 

### Increment Modeling Results.

PM 2.5 

### Increment 24-Hour High 2 nd 

### High Results (μg/m 3 

### ) Annual Results (μg/m 3 

### ) All (Essar & Keetac Expansion) 7.1 1.3 Class II Increment 9 4 % Increment 79% 33%



### Table 2: Class I PM 2.5 

### Increment Modeling Results.

PM 2.5 

### Increment 24-Hour High 2 nd 

### High Results (μg/m 3 

### ) Annual Results (μg/m 3 

### ) All (Essar, Keetac Expansion, Mesabi Mining, PolyMet) 0.458 0.043
Class I Increment 2 1 % Increment 23% 4%



### Comment 3-2: The MPCA must make its analysis of the facility’s PM 2.5 

### increment compliance available to the public for a period of public notice and comment. Response: The MPCA has performed an an alysis of the facility’s PM 2.5 

### Increment (Class I and II). The results of the increment analysis are provided in the response to comment 3-1 and demonstrate compliance with PM 2.5 

### Increment standards. Compliance wi th these standards was demonstrated based on the draft permit publically noticed on January 23 rd 

### , 2012, therefore no additional permit conditions were required to be added. The MPCA's anal ysis is included in the TSD in sections 3.1.3.1-2. The MPCA's analysis of the Facility's PM 2.5 

### Increment compliance is available to the public and the permit is subject to an Environmental Appeals Boar d (EAB) appeal period. The EAB appeal period is 33 days long and begins once the permit is issued by the MPCA. Petitions may be submitted during the EAB review period to the US EPA. As stated above, the PM 2.5 

### Increment analysis demonstrated compliance for both Class I and Class II, and did not raise any substantial new questions concerning the permit. Therefore, no additional conditions were added and the permit conditions have not changed since the permit was publically noticed on January 23, 2012. For these reasons the permit will not be re-noticed prior to the EAB appeal period.

### Essar Steel Minnesota LLC Responses to Comments on the Nashwauk, Minnesota Draft Air Emission Permit

5 

### Comment 3-3: The Air Quality analysis is improperly based on background concentrations that are not

from monitors that meet the applicable requirements. Response: Background concentrations were developed in accordance with U.S. Environmental

Protection Agency (EPA) 40 CFR pt. 51: § 8.2.2 Re commendations. Background concentrations were applied to the modeled concentrat ions conservatively with no temp oral or spatial pairing and in accordance with the rules and regulations outlin ed in EPA 40 CFR pt. 51: § 8.2.3 Recommendations (Multi-Source Areas) and a March 1, 2011, EPA me mo under the section Combining Modeled Results and Monitored Background to Determine Compliance. Nearby sources explicitly modeled in the Essar Class II NAAQS and Increment analysis included Minnesota Power Inc-Boswell Energy Center, Hawkinson Construction Co, Blandin Paper/Rapids En ergy Center, US Steel Keewatin Taconite, United Taconite Fairlane, Hibbing Public Utilitie s, Hibbing Taconite, US Steel Minntac. Other sources were represented by a regional background concentration developed from a representative monitoring site.

Comment 3-4: Adding a monitored design value to a modeled design value does not predict the

maximum impact. Response: The application of background values followe d the methodology referred to in a March 2011

EPA memo and that which was used in the recent Keetac permit modeling. Background concentrations were applied properly and conservatively without te mporal or spatial pairing. Typically a regional background concentration is developed when there is extensive and explicit modeling of nearby sources, this may consist of moni tored maximum concentrations adjusted for the influence of nearby sources. Additionally, in a March 1, 2011, memo EPA provides further clarification regarding 98th percent modeled plus 98th percent monitored und er the section Combining Modeled Results and Monitored Background to Determine Compliance: “Bas ed on these consideratio ns, we believe that a less conservative “first tier” for a uniform monito red background contribution based on the monitored design value from a representative monitor should be acceptable in most cases.” Table 4 in Appendix E of the Permit Application lists the representati ve monitored background concentrations and the modeled design values in footnote 2.

Comment 3-5: Using SILs to excuse modeled NAAQS violations is incorrect. Response: It appears that the commenter misread the tables in the permit application. The “Maximum

Modeled Concentrations” shown in the Permit Applicat ion, Appendix E, Table 5 are the “Total Modeled Concentration Results” shown in Table 4. These results are the modeled concentrations plus the background concentrations. There were no modeled ex ceedences of the NAAQS or Increment. Table 5 is a summary of Table 4 that attempts to show that the maximum impacts for the NAAQS and Increment are not influenced by the Essar fa cility, but rather by the other nearby explicitly modeled sources.

### Essar Steel Minnesota LLC Responses to Comments on the Nashwauk, Minnesota Draft Air Emission Permit

6 

### 4. Comments by LeRoy Flug, Pengilly. Letter received by mail on February 21, 2012.

Comment 4-1: Commenter questions why heavy dust is occurring 10 miles south on Twin Lakes Highway 65. Response: MPCA enforcement staff is currently investigat ing multiple potential sources of dust which

are close to the Twin Lakes area. The Essar dusting event of December 2, 2011, is believed to have impacted the Swan Lake and Highway 65 area which is approximately 2 – 3 miles from the Essar site. The MPCA will be closely monitoring both these ar eas to document any future dusting occurrences which, if connected to a business, are in violation of the Agency’s fugitive dust rule. Any future fugitive dusting events should be brought to the attention of MPCA enforcement staff using the Online Citizen Complaints Form (http://www.pca.state.mn.us/foyp21 ) or by calling 1-800-657-3864.

Comment 4-2: Commenter questions whether a study has been done on the dust to evaluate its

asbestos content. Response: The Minnesota Steel Industries (MSI), LLC Fi nal Environmental Impact Statement (FEIS)

(http://www.dnr.state.mn.us/input/environmentalreview/minnsteel/index.html ) addressed the potential for generation of asbestiform fibers, Sect ion 4.7.2.6. Ore analysis and tailings samples were looked at from several sources for taconite mining operations on the west end of the Mesabi Iron Range, none of the samples showed evidence of asbestos minerals or amphibole minerals.

### Essar Steel Minnesota LLC Responses to Comments on the Nashwauk, Minnesota Draft Air Emission Permit

7 

### 5. Comments by Terry Thompson, Li ttle McCarthy Lake, Nashwauk. Email received February 21, 2012.

Comment 5-1: The commenter contends that there is damage to his home from blasting and Essar’s response to promised meeting requests has been poor. Response: Blasting is not an activity regulated by the MPCA and is therefore not an activity within the air

quality permit modification project proposal. Compla ints concerning construction blasting should be raised with Jon Nisja at the MN Department of Public Safety (651-201-7204) and complaints concerning mining blasting activities should be rais ed with Julie Jordan at the Minnesota Department of Natural Resources, Lands and Minerals (218-231-8457).

Comment 5-2: Commenter contends that Essar does not follow through on commitments made to

neighbors and contractors. He alleges that they are not paying their bills and that they will not honor and comply with the proposed air permit. Response: Following through on commitments to neighbors and paying local contractors in a timely manner is important, however it is not something th e MCA has information on nor is it regulated by the air quality permit. This issue is beyond the scope of this public notice and permitting action. The Essar facility currently has an air quality permit which outlines specific operation and compliance requirements. The MPCA is not aware of any intent by the facility to not honor or comply with the current permit or the permit modifications proposed. The MPCA will use enforcement if needed to ensure that the Essar facility maintains compliance wi th all rules and permit requirements within their current permit as well as those pr oposed within this modification.

Comment 5-3: Commenter requests that the MPCA Citizen’s Board consider the permitting matter. Response: In accordance with Minnesota Statute § 116.02, Subd. 8 (2), the MPCA commissioner carefully

considered the petition to have the Essar permit modification decision be made by the MPCA Citizens’ Board. However, after a review of the request, issu es and comments, the MPCA will deny the request. As outlined in the response to comments 5-1 and 5-2 the commenter’s concerns are beyond the scope of this public notice and permitting action and outside the scope of the MPCA’s authority and that of the MPCA Citizens Board. Finally, pursuant to the Mi nnesota Statute § 116.02, subdivision 8(2), the MPCA commissioner will provide the commenter with a writ ten explanation of the reasons for denying the petition and he will also inform the MPCA Citizens’ Board of the decision as well as the reasoning.

### Essar Steel Minnesota LLC Responses to Comments on the Nashwauk, Minnesota Draft Air Emission Permit

8 

### 6. Comments by EPA, Region V Chicago. Lett er received electronic ally February 22, 2012.

Comment 6-1: The permit record does not appear to include any air quality analysis to show that this source will not cause a violation of the ozone nati onal ambient air quality st andards. 40 CFR 51.166(K); 50 CFR 51.166(m). EPA’s 8-hour ozone implementati on phase 2 rule (November 29, 2005; 70 FR 71612) requires that NO x 

### be considered as an ozone precursor under PSD. One of the elements of that rule is a requirement that the PSD program regulation define the term “significant” for ozone to include 40 tons per year (tpy) of NO x 

### . See 70 CFR 51.166(b)(23)(i). In acco rdance with 40 CFR 51.166(m)(1)(a), a permit application must contain an air quality analys is for each pollutant that a new source would have the potential to emit in significant amounts. Since the Essar modification project has NO x 

### emissions above this significance threshold for ozone, EPA re gulations require that the record contain an ozone impact analysis for this source. A quantitative mode ling analysis is not necessarily required but MPCA should consult with EPA Region 5 regarding the appropriate form for such an analysis in this case. 40 CFR Part 51, Appendix W, 5.2.1.c. Response: Section 3.1.2 of the Technical Support Document (TSD) was modified to include the outcome of a qualitative ozone impacts analysis which shows that the modification would not alter the compliance status with respect to the ozone standard.

Comment 6-2: The permit record does not include a PM 2.5 

### increment analysis. At 75 Fed. Reg. 64864, EPA establishes increments for PM 2.5 

### pursuant to the CAA. In the preamble to the 2010 final rule promulgating the PM 2.5 

### increments, we indicated that we would require sources seeking a PSD permit under the Federal PSD program to complete an increm ent analysis as a prerequisite to the permit being issued in the date of issuance will occur after the trigger date (October 20, 2011), when the PM 2.5 

### increments became effective under the Federal PS D program. Please require Essar to complete a PM 2.5 

### increment analysis and include it as part of the permit record. Response: Sections 3.1.3.1-2 of the TSD has been updated to include the results of the PM 2.5 

### increment analysis conducted for Class I and Class II. The mo deled results show impacts below the increment for the 24-hour and Annual PM 2.5 

### Increment standard for both Class I and II.

Comment 6-3: The “Test & Set” provisions for PM 2.5 

### include a requirement that the Permittee shall submit an application for a major permit amendment within 910 days of project start up. Essar is a major source of PM 2.5 

### emissions. The permit initially estab lishes Best Available Control Technology (BACT) limits for PM 2.5 

### that are equivalent to the PM 10 

### BACT limits. When the PM 2.5 

### BACT limits are revised, in keeping with EPA policy, they must undergo a reopening of the BACT analysis and subsequently must give a new opportunity for public comment. The permit language should be clarified wherever the “Test and Set” provisio ns are mentioned, including the Appendices. Response: Appendix E, Section 3.0: First Paragraph cha nged to: "The application for a major permit

amendment shall contain an update to the BACT analysis and the proposed PM 2.5 

### emission limits for all units identified in Table 1, as applicable based on the stage of construction. The amendment will be processed as a PSD permit modification." Page A-4 contains the following language: “major amendment with all data required by Appendix E”, with a BACT citation.

### Essar Steel Minnesota LLC Responses to Comments on the Nashwauk, Minnesota Draft Air Emission Permit

9 

### Comment 6-4: P. A-21, Group 009/SV 047 contains a require ment to keep EAF baghouse dust lead and

fluoride concentrations to below 8000 mg/kg and 4600 mg/kg, respectively, using a 12 month rolling average. The permit does not appear to require mo nitoring of these permit conditions. The previous permit for Essar required weekly sampling and analys is to monitor these permit conditions. Please include monitoring that effectively demons trates compliance with these provisions. Response: The monitoring requirements for Lead and Fluoride were consolidated and are listed on page A-5 of the permit. Page A-5 contains requirements to sample and analyze for each lead and fluoride limit in the permit, along with the required frequency and statistical analysis. No change was made to the permit.

Comment 6-5: P. A-17 and A-21, contain requirements for fabric filters related to the Group 009 EAF

baghouses. Please explain how monitoring for this group of emissions units adequately ensures compliance (e.g. parametric monitoring of pressu re drop across the baghouse) or add monitoring sufficient to ensure compliance to the permit. Response: Parametric monitoring requirements for these baghouse are listed in GP 007, p. A-17-18.

This group requires bag leak detection systems to be installed on these baghouses, preventative maintenance and corrective action plans, inspection s and monitoring (including pressure drop), records of the inspections and monitoring, continuous compliance requirements. These requirements are all based on Taconite MACT. Th is MACT explicitly excludes operating limits for Baghouses (see 40 CFR 63.9590, 63.9622, 63.9623, 63.9631, 63.9632, and 63.9634; 68 FR 61871). Compliance with emission limits under Taconite MACT are based on the use of bag leak detectors and the requirements for those. As a direct measure of particulates, broken bag leak detector is a more effective measure of compliance than pressure dr op, a surrogate parameter that measures pressure differential, not emissions. No change was made to the permit.

Comment 6-6: Throughout the permit, limits for sulfur dioxide and nitrogen oxides are on a lb/ton of

liquid steel produced and lb/hr basis using a 3-hour average. Due to the 1-hour standards for sulfur dioxide and nitrogen oxides, limits for these pollutants should be on a similar sh ort term basis (i.e. on a 1-hour basis). Please revise this averaging peri od wherever it is appr opriate in the permit. Response: These limits are listed in GPs 009, 015, 018, and 019. Limits for Sulfur Dioxide and Nitrogen

Oxides that were listed in the permit as 3-hour averaging times were changed to 1-hour averaging times, except for Startup, Shut down, Malfunction (SSM) limits.

Comment 6-7: P. A-22 contains a requirement for GP 009 em issions units under the Recordkeeping and

Reporting Section that allows the Pe rmittee to collect 12 months of NO x 

### continuous emission monitoring system (CEMS) emissions data that ca n be submitted to the Commissioner of the MPCA who “shall establish a NO x 

### limit and amend this permit to reflec t the actual level of emissions”. The NO x 

### limits for GP 009 are BACT limits, and as such cannot be modified by the Commissioner without undergoing a BACT reopening or revision. In addition, a modification of a BACT limit cannot be established with an admi nistrative amendment. Response: Language for this requirement was changed to the following:

"No NO x 

### emission data have been collected from an EAF using DRI to make high quality slab steel. Within 13 months of initial start-up, the Permittee shall submit CEM data for the first 12 months of operation. A copy of the data shall also be sent to the Manager of the Metallic Mining Sector. The Permittee shall submit an application for a PSD permit modification to amend the NO x 

### limit and update the BACT analysis based on the actual level of emissions.”

### Essar Steel Minnesota LLC Responses to Comments on the Nashwauk, Minnesota Draft Air Emission Permit

10 

### Comment 6-8: The TSD should include a more detailed di scussion of the Modeled Class I Increment

Concentrations (Table 7-3 in Essa r’s application) for the 24-hour PM 10 

### standard. Specifically, the TSD does not include this table and ex act modeling concentrations do not appear to be mentioned in the narrative. The permit record should discuss results of the air quality modeling and typical procedures allowed by the PSD rules or EPA policy and guidance that impact permitting decisions. Response: Section 3.1.3.1 of the Technical Support Document has been updated to include a discussion

of Significant Impact Levels (SILs) and their use to impact further analysis. Facility only modeled results were added as well as SILs to document the mode ling done. No changes were made to the permit.

Comment 6-9:

1.) Table 1-10 is a summary chart for the steps in volved in determining BACT control technology.

However, the permit record does not explain why ce rtain BACT technologies were eliminated. It also lists “energy efficiency measures” as inherent to th e design of the indurating furnace, but it does not actually identify the energy efficiency measures or the degree to which the measures will reduce GHG emissions from the indurating furnace. Please revise the permit record to thoroughly explain all the decisions that were made in the BACT analys is, including justifications for rejecting control technologies that were deemed not feasible. 2.) Table 1-10 eliminates carbon capture and sequ estration (CCS) as technically infeasible, without

providing basis for this statement. EPA generally co nsiders CCS to be both commercially available and technically feasible for large carb on dioxide emitting facilities. (See EPA’s permitting guidance at http://www.epa.gov/nsr/ghgdo cs/ghgpermittingguidance. pdf and control technology white paper at http://www.epa.gov/nsr/ghgdocs/ironst eel.pdf). If MPCA cannot demo nstrate why CCS is technically infeasible for the proposed project, the please re vise Step 4 in the BACT analysis to include an evaluation of costs and other impacts of installin g and operating CCS for this proposed project. Response: Section 3.1.1.1 of the TSD has been added to address each of these two comments. No changes were made to the permit.

# Minnesota Pollution Control Agency

52 0 La fayette Road North 

### I St

. Pau l, M i nne sota 5 5155-4194 

### I 6 51-2 96-6300
BQ0-657 3864 

### I 651·282 5332 TTY 

### I www.pca.state**mn.u~** 

### I**Equ~l** Opportun1ty Employer 

### April 6
, 2012

Mr

. Terry Thompson 17882 Little McCarthy Lake Nashwauk
, MN 57104

RE: Essar Steel Minnesota Draft Air Quality Permit No

. 061000067-004 Response to February 21, 2012, Request for Board Review of Essar Steel Minnesota Modifica t ion Perm i t

Dear Mr

. Thompson:

Thank you f or your electronic submittal dated February 21, 2012. In your submittal, you request that the Essar Steel Minnesota Modification Project air permit decision be considered by the Minnesota Pollution Control Agency (MPCA) Citizens' Board. You raise two issues in your petition to bring this decision before the MPCA Citizens' Board. First, you allege Essar's construction blasting has damaged your house

. Second, you indicate Essar's response to you has been Jacking and you allege that contractors

are in court battles with Essar over failure to receive payment for services. You are concerned that this indicates Essar will not honor and comply with the terms of its Minnesota Pollution Control Agency (MPCA) Air Permit.

In response to the first of these two comments the MPCA would point out that blasting is not an activity regulated by the MPCA and is therefore not an activity within the Essar Steel air quality permit modification proposal. Complaints concerning construction blasting should be raised with Jon Nisja at the Minnesota Department of Public Safety (65 1-2 01

- 7204) and complaints concerning mining blasting activities s hould be raised with Julie Jordan at the Minnesota Department of Natural Resources
, Lands and Minera l s (218-231-8457)

.

In r esponse to the second of two comments the MPCA would agree with you that following through on commitments to neighbors and paying loca l contractors in a timely manner is important
, however it i s not someth i ng the MPCA has information on no r i s i t regulated by the air quality permit. Th i s issue i s beyond the scope of this public notice and permitting action. The Essar facility currently has an air quality permit
, which outlines specific operation and compliance requirements. The MPCA is not aware of any i n tent by the facility to not honor or comply with the current perm i t or the permit modificat i ons proposed

. The MPCA will use enforcement i f needed to ensure that the Essar facility maintains compliance with all rules and permit requirements within their current permit as well as those proposed within this modification

.

I have carefully considered your petition and rev i ewed the issues you raised and the MPCA staff response to all comments received

. Based upon my review
, I must deny your request. I have concluded that the specific concerns you raise in your February 

### 21
, 2012, electronic submittal are beyond the scope of this public notice and permitting action and outside the scope of MPCA's authority and that of the MPCA Citizens Board.

In addition to providing you this written explanat i on of my reasons for denying your petition
, I will also inform the MPCA Citizens' Board of the same.

### Mr. Terry Thompson Page 2 April 6, 2012

Enclosed is the MPCA Response to Comments received on the Essar Steel Minnesota modification project draft air quality permit. Included in this document are detailed responses to your comments recorded at the public meeting held. at the Nashwauk-Keewatin High School on February 

### g<h, 2012 and your electronic submittal dated February 21, 2012 discussed above. The enclosed Response to Comments document describes in more detail and context how the agency reviewed, made changes as necessary, and addressed all comments received.

Although I cannot grant your petition in this matter, I do appreciate your interest and participation in the public notice and comment process.

Paul W. Aasen Commissioner

PWA/JH:rm

Enclosure

### Attachment 9 - Points Calculator

1) AQ Facility ID No.: 06100067 Total Points 210 2) Facility Name: Essar Steel Minnesota LLC 3) Small business? y/n? n 4) DQ Numbers (including all rolled) : 3704, 2789 (pre-application) 5) Date of each Application Received: 10/15/2011 6) Final Permit No. 0610006-004 7) Permit Staff Trevor Shearen 8) "Work completed" in which .xls file (i.e. unit 2b, unit 1a, biofuels)? SPS

Total Application Type DQ No. Qty. Points Points Details Administrative Amendment 1 0 Minor Amendment 4 0 Applicability Request 10 0 Moderate Amendment 15 0 Major Amendment 3704 1 25 25 Individual State Permit (not reissuance) 50 0 Individual Part 70 Permit (not reissuance) 75 0

Additional Points Modeling Review 3704 1 15 15

BACT Review 3704 10 15 150

LAER Review 15 0 CAIR/Part 75 CEM analysis 10 0 NSPS Review 3704 1 10 10 LL NESHAP Review 3704 1 10 10 RRRRR Case-by-case MACT Review 20 0 Netting 10 0 PM, PM 10 , PM 2.5 , Pb, F, SO 2 , NO x , CO, VOC, GHG

Limits to remain below threshold 10 0 Plantwide Applicability Limit (PAL) 20 0 AERA review 15 0 Variance request under 7000.7000 35 0 Confidentiality request under 7000.1300 2 0 EAW review Part 4410.4300, subparts 18, item A; and 29 15 0 Part 4410.4300, subparts 8, items A & B; 10, items A to C; 16, items A & D; 17, items A to C & E to G; and 18, items B & C 35 0

Part 4410.4300, subparts 4; 5 items A & B; 13; 15; 16, items B & C; and 17 item D 70 0

Add'l Points 185

NOTES: Additional Fees were paid on May 4, 2012.

(DQ 3704)