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 Agreementthat 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 forthose emission reductions. This agreement does notrelieve U.S. Steel from the continuing obligation to comply with requirements ofapplicable Federal and StateregUlations, constmction or operating permits, and other applicablerequirements to control emissions.

1. Enhancements to 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 forparticUlate 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 ofoperating parameters thatreliably indicate and

ensure adequate capture ofemissions by each existing hood. b. Within 3 months ofbeginning opemtion ofany additionalnew 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 usedto establish values ofoperating 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 leastfive (5) days out ofevery seven (7). A day is defmed as any day when a BOF is in operationfor a minimum offour hours during conditions that are acceptable for Method 9 readings. A minimum of60 consecutive minutes ofopacity readings mustbe obtained and must encompass at least one steel production cycle. A productioncycle 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 lEP A. d. U.S. Steel may, at some later date, submit a formal requestto 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 wouldbe measuredby 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 exitfrom the electrostatic precipitator stackmustnot 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 stackmustnot 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 of March 3 1,2013, 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. Emissions that exitfrom this baghouse stack mustnot 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 orpermits to incorporate the requirements ofSections 1 atld 2 above. The federally eliforceable permit or permits 

### shall include the requirements imposedby Sections 1 and 2 md appropriate requirements for emission testing, monitoring, recordkeeping and reporting associatedwiththese 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 completebasic engineering ofsteam rings for the oxygen lances in the BOP shop.

### ii. U. S. Steel 

### will submit a constructionpermit 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 ofa final constructionpermit, assuming that

no appeal(s) or Challenge(s) ofthe Permit or the requirements therein have been filed 

### with the Pollution Control Board or Federal Courtwithin 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 providedthat the required constructionpermit 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 dedicatedtapping 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 ofescaping to the atmosphere from the BOPF building. The airpollution 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,
atthe stack. 

### iii. Within 30 days ofthe completion ofthe basic engineering for the new control system, U. S. Steel will submit a constructionpermit application for the new system to the IEPA that contains a schedule for the design engineering, construction and initial startup 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 constructionpermit, assuming that no appeal(s) or challenge(s) ofthe Permit

orthe requirements therein have been filed withthe Pollution Control Board or Federal Courtwithinthat 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 improwmffits to 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 fortapping or another new baghouse. ii. Ifthe evaluation compkted in paragraph 

### 4(d)(i) does
not support implemffiting additional projtlcts to reduCtJ particulattl emission fi'om charging, U. S. Sttlel will submit within 9 months ofthe tlffectivtl dare ofthe Agreemoot, an tlvaluation reportthat includes a summary ofthtl evaluation, statem()fit on decision criteria for pottlntial projects, and incremental costper ton ofpollutantreduction analysis. iii. Ifthe tlvaluation complered in paragraph 4(d)(i) does supportimpltlmenting additional projects to reduce particulare emissions from charging, U. S. Steel 

### will complere within 

### 9 months ofthe effectivtl date ofthtl agretlmtlntthe basic tlnginetlring forinstallation and operation ofan upgradtl to thtl existing charging control syst()ffi. Future submittals will coincidtJ withthe tapping hood schedule identifitldin paragraph 4(c

### )(iii)

- 4(c)(v).

5. Rtlgu1atory Uses ofEmission Reductions

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

### in the MOU will btl incorporated into thtl Illinois 1997 PM 2.5National Ambitlnt Air Quality Standard Stattl Implemtlntation Plan (NAAQS SlP) submittedto 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 :reprtlSffitthatthe requir=ents ofthis MOU satisfy U. S. Sttlel's obligations towards Illinois EPA's requirementto demonstrattl complianctl with thtl 1997 PM 2.5 NAAQS.c. IEPA will provide U. S. Steel with an opportunity to review and provide comments on the 1997 

### PM 

### z

. 5modeled attainment demonstration. d. U. S. Steel 

### and IEP A 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 thatthey canbe incorporated into the Illinois 1997 

### PMzs SlP.

e. U. S. Steel's commi1Jnents and obligations underthis MOU are subject to and conditionedupon: 1) the issuance and sustained validity ofa federally enforceable pennit or permits containing the particulate matter emissionreductions requirements set forth in the MOU; 2) IEPA's approval thatthe particulate
matter etnissionreductions satisfy U. S. Steel's requirement for the 1997 

### PMz.5 NAAQS SIP; and 3) IEPA notpursuing a regulation pursuantto the 1997 PM2.5 NAAQS containing additional restrictions for the Granite City Works BOP. U. S. Steel and IEP A shall mutually support and use best efforts to obtainthe appropriate permits and SIP approvals based on this agreement. f. In developing rules, regulations, or state implementationplan revisions designed to comply with the 

### PMZ.5 NAAQS, IEPA, taldng into account all emissionreduction efforts and other appropriate factors, will use best efforts to seek 

### PM 

### z

.5 reductions inregards to future NAAQS from other sources before seeking additional emissionreductions 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 whichperformance obligations are scheduledto be met will be extended for aperiod oftime equal to the time lost due to any delay so caused.

### For Illinois EPA For United States Steel Corporation



# M.s**1.J~ClMA.** 'S
Michael S. Williams Senior Vice President

- North American FlatRoll Operations

Date: 

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