United States Steel Corporation

Granite City Works and

IEPA Memorandum ofUnderstanding

The Memorandum ofUnderstanding (MOU or Agreement) is entered into by and

between United States Steel Corporation (0. S. Steel) and the Illinois Environmental

Protection Agency (!EPA), and is dated and effective as ofthe last date ofsignature in

the signature block.

U. S. Steel and IEPA have reached an Agreement that will achieve reductions in

emissions ofparticUlate matter from U. S. Steel's Granite City Works, with the specific

intent ofreducing the emissions ofparticulate matter2.5 (pM2.5). This MOU sets forth

the terms ofthe Agreement between U. S. Steel and IEPA and sets forth the intended

regulatory uses for those emission reductions. This agreement does not relieve U.S. Steel

from the continuing obligation to comply with requirements ofapplicable Federal and

State regUlations, constmction or operating permits, and other applicable requirementsto

control emissions.

1. Enhancementsto Compliance Procedures

a. Within 2 months ofthe effective date ofthis agreement, U. S. Steel shall

begin installation ofan enhanced operational monitoring system for the

capture systems for particUlate matter emissions from the Basic Oxygen

Furnaces (BOP), including installation, operation and maintenance of

monitoring devices to verify the performance ofeach capture system

during the various steps in the steelmaldng process. This will include

establishment ofvalues of operating parameters that reliably indicate and

ensure adequate capture ofemissions by each existing hood.

b. Within 3 months ofbeginning opemtion of any additional new pollution

control equipment at the BOF, as prescribed in this MOU, U. S. Steel shall

implement enhanced operational monitoring for such new capture system

for particulate matter. Such implementation will include installation,

operation and maintenance ofappropriate monitoring devices. These

devices will verify the performance ofthe new capture system. Such

monitoring devices will be used to establish values of operating

parameters that reliably indicate and ensure adequate capture ofemissions

by each new hood.

c. Within 2 months ofthe effective date ofthis agreement, U. S. Steel shall

conduct opacity readings ofemissions escaping from any openings in the

Basic Oxygen Process Furnace (BOPF) building in accordance with

USEPA Method 9 in 40 CPR Part 60, Appendix A. These readings shall

be performed for at least five (5) days out ofevery seven (7). A day is

defmed as any day when a BOF is in operation for a minimum offour

hours during conditions that are acceptable for Method 9 readings. A

minimum of 60 consecutive minutes of opacity readings must be obtained

and must encompass at least one steel production cycle. A production
cycle is defined as the beginning ofscrap charging to the completion of

deslagging ofthe steelmaking vessel. Results ofthese readings shall be

reduced to three (3) minute rolling averages. U.S. Steel shall maintain

appropriate records for all opacity measurements and these records shall

be made available upon request from the lEPA.

d. U.S. Steel may, at some later date, submit a formal request to lEPA to

streamline the monitoring requirements. This request shall be submitted

as an application for a significant modification to the CAAPP permit.

2. Emission Limits

a. All particulate matter emission limits in this MOU are expressed in terms

ofparticulate as would be measured by USEPA Methods 5, 5D or 17.

b. As ofJanuaryl, 2012, U. S. Steel shall comply with the following

requirements for particulate matter emissions:

i. Particulate matter emissions from the basic oxygen process (BOP)

that exit from the electrostatic precipitator stack must not exceed

om gr/dscf.

11. PmiicuIate matter emissions from hot metal desulfurization and

reladling (BOF Hot Metal Transfer and Desulfurization

Baghouse(s» that exit from the baghouse must not exceed 0.005

gr/dscf.

iii. Particulate matter emissions from slag skimming (BOF Slag

Skimming Baghouse(s» that exit from the baghouse stack must not

exceed 0.005 gr/dscf.

IV. Particulate matter emissions from ladle metallurgy operations

(LMF Baghouse) that exit from the baghouse stack must not

exceed 0.005 gr/dscf.

c. As ofMarch 31,2013, or such later date eslablished pursuant to paragraph

4(c)(v) below, U. S. Steel will comply with the following requirements for

particulate matter emissions fi'om tapping:

i. Emissions shall be controlled by a new baghouse.

11. Emissionsthat exit from this baghouse stack must not exceed

0.005 gr/dscf.

3. Within 2 months ofthe effective date ofthis Agreement U. S. Steel shall submit

an application for a federally errforceable permit or permits to incorporate the

requirements ofSections 1 atld 2 above. The federally eliforceable permit or

permits shall include the requirements imposed by Sections 1 and 2 md

appropriate requirements for emission testing, monitoring, recordkeeping and

reporting associated with these requirements.

4. Emission Reduction Projects

.a. Steam Rings for the Oxygen Lances

i. Within 6 months ofthe effective date ofthe Agreement,

U. S. Steel will complete basic engineering ofsteam

rings for the oxygen lances in the BOP shop.
ii. U. S. Steel will submit a construction permit application

and an installation schedule to IEPA within 30 days of

completion ofthe basic engineering. In consideration

ofthe need to begin operation ofthe steam rings by

October 31,2011, U. S. Steel shall commence

construction ofthe steam rings within 40-days of

issuance of a final construction permit, assuming that

no appeal(s) or Challenge(s) ofthe Permit or the

requirements therein have been filed with the Pollution

Control Board or Federal Court within that 40-day

period.

b. U. S. Steel will complete the installation and begin operation of

the steam rings no later than October 31, 2011 provided that

the required construction permit is obtained in a reasonable

time and not appealed.

c. Secondary Emission Control for Tapping

i. Within 9 months ofthe effective date ofthe Agreement,

U. S. Steel will complete the basic engineering for the

installation and operation ofa dedicated tapping

emission control system that includes a fabric filter

control device (bagbouse).

ii. The tapping emission control system will be designed

for optimal capture to minimize emissions from

tapping, which have the potential of escaping to the

atmosphere from the BOPF building. The air pollution

control device for the captured emissions will be

designed to comply with a particulate matter emission

rate of0.005 grains per dry standard cubic feet exhaust,

at the stack.

iii. Within 30 days ofthe completion ofthe basic

engineering for the new control system, U. S. Steel will

submit a construction permit application for the new

system to the IEPA that contains a schedule for the

design engineering, construction and initial start up of

the new tapping emission control system.

iv. In. consideration ofthe need to begin operation ofthe

secondary emission controls for tapping by March 31,

2013, IEPA shall act on all required permit(s) within

three months ofreceipt ofpermit application(s) from U.

S. Steel. U. S. Steel shall commence construction of

the secondary emission controls for tapping within 40-

days ofissuance ofa final construction permit,

assuming that no appeal(s) or challenge(s) ofthe Permit

or the requirements therein have been filed with the

Pollution Control Board or Federal Court within that

40-day period.
v. U. S. Steel will begin operation ofthe new tapping

emission control system no later than March 31,2013

provided that required permits are obtained in a

reasonable time and not appealed.

d. Secondary Emission Control for Charging

I. As part ofthe engineering for the new tapping emission

control system, U. S. Steel will also evalilate the current

emission control system for charging and potential

projects to reduce particulate matter emissions from

charging. As part oftbis evaluation, U. S. Steel will

tlvaluattl improwmffitsto thtl capturtl efficifficy

achieved for charging ffilissions and ducting some or

all ofthe capturtld charging tlmissions, which currently

are controlled by the electrostatic precipitator, to thtl

new control dtlvire for tapping or another new

baghouse.

ii. Ifthe evaluation compkted in paragraph 4(d)(i) does

not support implemffiting additional projtlctsto reduCtJ

particulattl emission fi'om charging, U. S. Sttlel will

submit within 9 months ofthe tlffectivtl dare ofthe

Agreemoot, an tlvaluation report that includes a

summary ofthtl evaluation, statem()fit on decision

criteria for pottlntial projects, and incremental cost per

ton ofpollutant reduction analysis.

iii. Ifthe tlvaluation complered in paragraph 4(d)(i) does

supportimpltlmenting additional projectsto reduce

particulare emissions from charging, U. S. Steel will

complere within 9 months ofthe effectivtl date ofthtl

agretlmtlnt the basic tlnginetlring for installation and

operation of an upgradtl to thtl existing charging control

syst()ffi. Future submittals will coincidtJ with the

tapping hood schedule identifitld in paragraph 4(c)(iii) -

4(c)(v).

5. Rtlgu1atory Uses ofEmission Reductions

a. For thtl Gl'anite City BOP, thtl particulate emission reductions

set forth in the MOU will btl incorporated into thtl Illinois 1997

PM2.5National Ambitlnt Air Quality Standard Stattl

Implemtlntation Plan (NAAQS SlP) submitted to U. S. EPA in

accordance with 40 CFR §51.1001, et seq., and §§ 110 and 172

ofthe Clean Air Act

b. IEPA shall use its btlst efforts to support and :reprtlSffitthat the

requir=ents ofthis MOU satisfy U. S. Sttlel's obligations

towards Illinois EPA's requirement to demonstrattl complianctl

with thtl 1997 PM2.5 NAAQS.
c. IEPA will provide U. S. Steel with an opportunity to review

and provide comments on the 1997 PMz.5modeled attainment

demonstration.

d. U. S. Steel and IEPA shall mutually support and use best

efforts to obtain the appropriate pennits and approvals

incorporating the terms ofthis agreement to make the

reductions federally enforceable so that they can be

incorporated into the Illinois 1997 PMzs SlP.

e. U. S. Steel's commi1Jnents and obligations under this MOU are

subject to and conditioned upon: 1) the issuance and sustained

validity of a federally enforceable pennit or permits containing

the particulate matter emission reductions requirements set

forth in the MOU; 2) IEPA's approval that the particulate

matter etnission reductions satisfy U. S. Steel's requirement for

the 1997 PMz.5 NAAQS SIP; and 3) IEPA not pursuing a

regulation pursuant to the 1997 PM2.5 NAAQS containing

additional restrictions for the Granite City Works BOP. U. S.

Steel and IEPA shall mutually support and use best efforts to

obtain the appropriate permits and SIP approvals based on this

agreement.

f. In developing rules, regulations, or state implementation plan

revisions designed to comply with the PMZ.5 NAAQS, IEPA,

taldng into account all emission reduction efforts and other

appropriate factors, will use best efforts to seek PMz.5

reductions in regards to future NAAQS from other sources

before seeking additional emission reductions from the U. S.

Steel BOP.

6. Force Majeure

U. S. Steel shall not be liable for any failure or delay in performance under

this MOU (other than for delay for submitting a pennit application) to the

extent said failures or delays are caused by extraordinary circumstances

beyond U. S. Steers reasonable control and occurring without its fault or

negligence, provided that, U. S. Steel gives prompt written notice, with

full details following the occurrence ofthe cause relied upon. Dates by

which performance obligations are scheduled to be met will be extended

for a period oftime equal to the time lost due to any delay so caused.
For United States Steel Corporation For Illinois EPA

M.s 1.J~ClMA. 'S

Michael S. Williams

Senior Vice President - North American

Flat Roll Operations

Date: (P /30 / 2t:lj () Date: 7/_.:-1_/ ;;Lo 10