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 at the stationary source 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 Amendment 10/09/2007 

Major Amendment 10/14/2011 

This permit supersedes Air Emission Permit No. 06100067-003 and authorizes the Permittee to operate 

and construct the stationary source at the address l!sted above. The Permittee must comply with all the 

conditions of the permit. Any changes or modifications to the stationary source must be performed in 

compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state 

air pollution control rules unless the term is explicitly defined in the permit. 

Unless otherwise indicated, all the Minnesota rules cited as the origin of t he permit terms are 

incorporated into the SIP under 40 CFR § 52.1220 and as such as are enforceable by U.S. Environmental 

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

Permit Type: Federal; Part 70/Major for NSR; 

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;DO'kt M/2J 

Don Smith, P.E., Manager 

Air Quality Permits Section 

Industrial Division 

for John Stine 

Commissioner 

Minnesota Pollution Control Agency 

TDD (for hearing and speech impaired only): 651-282-5332 

Printed on recycled paper containing at least 10% fibers from paper recycled by consumers 
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/Fluoride Concentration Monitoring – 95% UCL 

Appendix D – Visible Emissions Checklist 

Appendix E – Test and Set for PM2.5

Appendix F – SAM Equations 

Appendix G – Insignificant Activities 

Appendix H – Process Flow Diagram 
NOTICE TO THE PERMITTEE: 

Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency’s 

(MPCA) solid waste, hazardous waste, and water quality 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 Lafayette 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, compliance 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 limitations 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) may also use other credible evidence to establish 

compliance or noncompliance with applicable requirements. 
FACILITY DESCRIPTION: 

Essar Steel Minnesota LLC (Essar) is currently in the process 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 Nashwauk, at the site of the former 

Butler Taconite Mining Company operations. 

The project has secured the 1.4 billion (long) ton Mineral 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 integrated 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 dewatering 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. The project will demand 450 MW of electric power, which 

will be supplied by Nashwauk Public Utility. Essar plans to use ore concentrating and indurating processes 

common to existing taconite operations and to employ natural gas based direct iron reduction. The steel 

mill will use modern electric 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 charge to the 

EAFs at Essar other than internally-produced, virgin iron, "home scrap". 

AMENDMENT DESCRIPTION

The proposed Essar Steel Minnesota Modifications (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 combination in between. The blast furnace grade or high 

flux taconite pellets will be shipped to Essar Steel Algoma in Ste. St. Marie, Ontario Canada 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 

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. However, 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 Project 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) 3.81 7.03, 5 

High Flux (blast furnace grade) 0 6.54, 5 

DRI Not applicable 2.82 1.86 

Steel Making 2.57 1.57

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 capacity 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 tonne/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 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 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 used in air dispersion modeling assessments. 

6 There are no physical changes to the DRI proposed and there are no changes to the hourly production rates. 

7 There are no physical changes to the steel mill proposed and there are no changes to the hourly production rates. 

The proposed action modifies the indurating furnace where 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 on-site 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 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 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 4th secondary crushing unit, 3rd autogenous 

grinding mill or the firing zone of the indurating furnace 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 modification and obtain financial close for 

equipment required for increase pelletizing capacity – 2012 

• Finish construction through taconite pellet plant 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:

A-1 05/10/12

Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of

the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you 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 total 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

At 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

Air 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:

A-2 05/10/12

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:

A-3 05/10/12

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.

At 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 breakdown

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.

At 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:

As 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

Application 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:

A-4 05/10/12

DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NSR hdr

These requirements apply if a reasonable possibility (RP), as defined in 40 CFR

Section 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

ATPA 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

Agency 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:

A-5 05/10/12

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)

As 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)

AMBIENT 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:

A-6 05/10/12

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

All 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

All 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 plan

developed 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:

A-7 05/10/12

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:

A-8 05/10/12

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:

A-9 05/10/12

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 & Steel

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:

A-10 05/10/12

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

At 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:

A-11 05/10/12

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:

A-12 05/10/12

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:

A-13 05/10/12

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:

A-14 05/10/12

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:

A-15 05/10/12

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:

A-16 05/10/12

Subject Item: GP 006 Fugitive Sources

What to do Why to do it

Associated 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 determines

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:

A-17 05/10/12

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:

A-18 05/10/12

 ii. Sealing off defective bags or filter media.

 iii. Replacing defective bags or filter media or otherwise repairing the control device

 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:

A-19 05/10/12

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

Appendix 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:

A-20 05/10/12

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:

A-21 05/10/12

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

Appendix 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:

A-22 05/10/12

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:

A-23 05/10/12

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

Allowed 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:

A-24 05/10/12

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

Annual 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:

A-25 05/10/12

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:

A-26 05/10/12

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

Appendix 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:

A-27 05/10/12

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

Appendix 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:

A-28 05/10/12

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

Appendix 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

Additive 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:

A-29 05/10/12

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:

A-30 05/10/12

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

Appendix 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:

A-31 05/10/12

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:

A-32 05/10/12

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

Appendix 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:

A-33 05/10/12

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 limits

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:

A-34 05/10/12

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:

A-35 05/10/12

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

All 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:

A-36 05/10/12

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

At 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

Appendix 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:

A-37 05/10/12

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:

A-38 05/10/12

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 specified

 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:

A-39 05/10/12

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:

A-40 05/10/12

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:

A-41 05/10/12

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:

A-42 05/10/12

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 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

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:

A-43 05/10/12

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:

A-44 05/10/12

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.

Any 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:

A-45 05/10/12

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:

A-46 05/10/12

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:

A-47 05/10/12

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:

A-48 05/10/12

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

Appendix 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:

A-49 05/10/12

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

Appendix 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:

A-50 05/10/12

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:

A-51 05/10/12

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:

A-52 05/10/12

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

B-1 05/10/12

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 parts

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 separately 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

B-2 05/10/12

What to send When to send Portion of Facility Affected

Application 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

B-3 05/10/12

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

B-4 05/10/12

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

B-5 05/10/12

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

B-6 05/10/12

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

Annual 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, PM10, PM2.5, 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 PM10 PM2.5 Lead Fluoride PM PM10 PM2.5 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 Grinding 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 Grinding 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 Pellet 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 Grinding 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% O2. 

**DRI Process Gas Heater performance standards shall be on a lb/mmBtu basis. 

***Lead and Fluoride incoming material concentration limits are listed in Table A of the permit. 
For each pollutant, a performance standard (Table 2) and mass emission limit (Table 3) is presented. Where applicable, a 

startup, shutdown, malfunction (SSM) limit (Table 3) is also included. 

Table 2 – SO2, NOx, CO, VOC, SAM, H2S, and CO2e Not to Exceed Performance Standard Limits 

SO2 NOx CO VOC SAM H2S 

SV 018 EU 038 GP 018 Furnace Hood Exhaust 6.8 ppmv wet 

@15% O2

0.25 lb/mmBtu 1.9 ppmv wet 

@15% O2

0.60 ppmv wet 

@15% O2

0.0040 ppmv 

wet@15% O2

SV 019 EU 039 GP 018 Furnace Waste Gas 5.0 ppmv wet 

@15% O2

0.25 lb/mmBtu 7.4 ppmv wet 

@15% O2

2.3 ppmv wet 

@15% O2

0.029 ppmv 

wet@15% O2

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 – SO2, NOx, CO, VOC, SAM, H2S, and CO2e Not to Exceed Mass Emission Limits 

SO2 NOx CO VOC SAM H2S CO2e 

(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 8.2 
APPENDIX B 

Modeling Parameters Facility Name: Essar Steel Minnesota LLC Permit Number: 06100067-004 Summary of Stack Vent Parameters and Emission Rates used for Class I and Class II modeling 

Stack 

ID No. Description 

UTM: Zone 15 (NAD83) LCC: 47N 93W (30,60N) (5) Base 

Elevation

(m)

Exit Flow 

Rate

(acfm) 

Exit Height

from Base

(m)

Inside 

Diameter

(m)

Exit Flow

Velocity

(m/s)

Exit 

Temp

(K)

Easting

(m) 

Northing

(m)

X

(m)

Y

(m)

PM10 PM2.5 CO 

Hourly Annual Hourly Annual Hourly Hou

SV 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-01 SV 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-02 SV 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 -18427.76 38503.42 484.6 5,000 33.0 0.45 15.2 298.2 1.9E-02 1.1E-02 1.9E-02 1.1E-02 SV 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-02 SV 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-03 SV 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-02 SV 010 Primary Grinding Mill Line 1 481019.35 5245024.38 (1) 466.6 14,767 37.2 1.22 6.0 302.6 4.3E-02 3.3E-02 4.3E-02 3.3E-02 SV 011 Primary Grinding Mill Line 2 481019.35 5245024.38 (1) 466.6 14,767 37.2 1.22 6.0 302.6 4.3E-02 3.3E-02 4.3E-02 3.3E-02 SV 014 Limestone Handling System 483160.70 5247363.13 -16276.32 40783.92 469.2 1,090 61.5 0.21 14.40 298.2 2.7E-03 2.7E-03 2.7E-03 2.7E-03 SV 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-03 SV 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-01 SV 017 Hearth Layer Feed 483059.96 5247470.28 -16373.71 40887.48 469.2 7,689 40.6 0.55 15.36 298.2 1.5E-02 1.4E-02 1.5E-02 1.4E-02 SV 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 SV 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 1SV 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-01 SV 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-01 SV 022 Pellet Screenings to Regrind Conveyors 483273.41 5247570.03 -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-03 SV 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-02 SV 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 24.15 319.3 1.9E-01 1.7E-01 1.9E-01 1.7E-01 SV 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 SV 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-02 1.0E-01 9.0E-02 SV 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 SV 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-03 SV 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-03 SV 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-03 SV 042 Fluorspar Handling System 483732.70 5247474.57 -15723.46 40891.68 472.5 363 20.0 0.12 14.40 298.2 9.0E-04 8.9E-04 9.0E-04 8.9E-04 SV 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-03 SV 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+00 5.1E+01 1SV 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 SV 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-03 SV 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-02 SV 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 SV 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 SV 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-02 SV 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-02 SV 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-04 8.0E-04 8.9E-04 SV 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 1.5SV 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 1.5SV 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-02 5.5E-02 6.6E-02 5.5E-02 SV 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-01 SV 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-04 SV 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-02 SV 075 DRI Process Water Blowdown Line 1 483568.18 5247879.13 -15882.51 41282.69 472.5 7 25.0 0.61 0.01 358.2 3.4E-01SV 076 DRI Quench Cooling Water Blowdown Line 1 483577.44 5247874.65 -15873.56 41278.37 472.5 47 22.0 0.76 0.05 333.2 8.0E-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) 484.6 0 228.60 298.2SV 083 Fine Ore Barn Perimeter 480973.08 5245072.61 (3) 484.6 0 259.08 298.2SV 084 Primary Grinding Mill Line 3 481019.35 5245024.38 (1) 466.6 14,767 37.2 1.22 5.97 302.6 2.9E-02 2.6E-02 2.9E-02 2.6E-02 SV 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-03 SV 086 Non-Magnetic Cobber Rejects Transfer Tower 480841.62 5244854.10 -18517.65 38358.60 467.7 5,000 14.1 0.45 15.18 298.2 1.6E-02 9.2E-03 1.6E-02 9.2E-03 SV 087 Secondary Screening Crusher/Cobber Line 1 480835.83 5244765.92 -18523.24 38273.37 468.5 25,000 53.2 1.01 14.86 298.2 5.6E-02 4.6E-02 5.6E-02 4.6E-02 SV 088 Secondary Screening Crusher/Cobber Line 2 480837.18 5244773.06 -18521.94 38280.27 468.5 25,000 53.2 1.01 14.86 298.2 5.6E-02 4.6E-02 5.6E-02 4.6E-02 SV 089 Secondary Screening Crusher/Cobber Line 3 480838.34 5244779.43 -18520.82 38286.43 468.5 25,000 53.2 1.01 14.86 298.2 5.6E-02 4.6E-02 5.6E-02 4.6E-02 SV 090 Secondary Screening Crusher/Cobber Line 4 480839.43 5244786.49 -18519.76 38293.26 468.5 25,000 53.2 1.01 14.86 298.2 5.6E-02 4.6E-02 5.6E-02 4.6E-02 SV 091 Carbon Bin for Mercury Control 483169.09 5247544.04 468.8 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-03 
Stack 

ID No. Description 

UTM: Zone 15 (NAD83) LCC: 47N 93W (30,60N) (5) Base 

Elevation

(m)

Exit Flow 

Rate

(acfm) 

Exit Height

from Base

(m)

Inside 

Diameter

(m)

Exit Flow

Velocity

(m/s)

Exit 

Temp

(K)

Easting

(m) 

Northing

(m)

X

(m)

Y

(m)

PM10 PM2.5 CO 

Hourly Annual Hourly Annual Hourly Hou

(6) 

SV 012 Fire Water Supply Pump - Concentrator 481005.98 5244953.24 -18358.80 38454.44 466.6 400 5.0 0.06 64.71 477.6 9.1E-04 1.1E-04 9.1E-04 1.1E-04 1.3

2.2E-02 2.6E-03 2.2E-02 2.6E-03 7.0E-02 3.1

SV 013 Emergency Power Generator - Concentrator 481009.70 5244974.32 -18355.21 38474.81 466.6 9,000 9.0 0.30 58.24 588.7 3.0E-03 3.4E-04 3.0E-03 3.4E-04 1.0

7.1E-02 8.1E-03 7.1E-02 8.1E-03 5.6E-01 2.4

SV 024 Fire Water Booster Pump - Pellet Plant 483103.07 5247272.26 -16332.02 40696.08 469.2 400 5.0 0.06 64.71 422.0 6.0E-04 5.3E-05 6.0E-04 5.3E-05 6.7

1.4E-02 1.3E-03 1.4E-02 1.3E-03 3.4E-02 1.6

SV 025 Fire Water Supply Pump - Pellet Plant 483101.32 5247267.92 -16333.72 40691.88 469.2 400 5.0 0.06 64.71 477.6 9.1E-04 1.1E-04 9.1E-04 1.1E-04 1.3

2.2E-02 2.6E-03 2.2E-02 2.6E-03 7.0E-02 3.1

SV 026 Emergency Power Generator - Pellet Plant 483168.44 5247402.02 -16268.85 40821.50 469.2 9,000 50.1 0.30 58.24 588.7 3.0E-03 3.4E-04 3.0E-03 3.4E-04 1.0

7.1E-02 8.1E-03 7.1E-02 8.1E-03 5.6E-01 2.4

SV 034 Fire Water Booster Pump - Furnace 483779.05 5247795.00 -15678.68 41201.39 472.5 400 23.0 0.06 64.71 422.0 6.0E-04 5.3E-05 6.0E-04 5.3E-05 6.7

1.4E-02 1.3E-03 1.4E-02 1.3E-03 3.4E-02 1.6

SV 035 Fire Water Supply Pump - DRI 483788.41 5247789.36 -15669.64 41195.95 472.5 400 23.0 0.06 64.71 477.6 9.1E-04 1.1E-04 9.1E-04 1.1E-04 1.3

2.2E-02 2.6E-03 2.2E-02 2.6E-03 7.0E-02 3.1

SV 036 Emergency Power Generator - DRI 483500.15 5247719.40 -15948.25 41128.30 472.5 9,000 34.4 0.30 58.24 588.7 3.0E-03 3.4E-04 3.0E-03 3.4E-04 1.0

7.1E-02 8.1E-03 7.1E-02 8.1E-03 5.6E-01 2.4

SV 037 Fire Water Booster Pump - Offices 483800.27 5247787.53 -15658.17 41194.18 472.5 400 23.0 0.06 64.71 422.0 6.0E-04 5.3E-05 6.0E-04 5.3E-05 6.7

1.4E-02 1.3E-03 1.4E-02 1.3E-03 3.4E-02 1.6

SV 038 Emergency Power Generator - Offices 483505.38 5247730.51 -15943.20 41139.03 472.5 3,750 34.4 0.30 24.27 588.7 1.4E-03 1.5E-04 1.4E-03 1.5E-04 4.2

3.3E-02 3.5E-03 3.3E-02 3.5E-03 2.4E-01 1.0

SV 056 Fire Water Booster Pump - Steel Mill 483880.64 5247765.00 -15580.48 41172.41 472.5 400 28.0 0.06 64.71 422.0 6.0E-04 5.3E-05 6.0E-04 5.3E-05 6.7

1.4E-02 1.3E-03 1.4E-02 1.3E-03 3.4E-02 1.6

SV 057 Fire Water Supply Pump - Steel Mill 483872.60 5247768.62 -15588.25 41175.90 472.5 400 28.0 0.06 64.71 477.6 9.1E-04 1.1E-04 9.1E-04 1.1E-04 1.3

2.2E-02 2.6E-03 2.2E-02 2.6E-03 7.0E-02 3.1

SV 058 Emergency Power Generator - Steel Mill 483889.76 5247772.28 -15571.68 41179.44 472.5 9,000 28.0 0.30 58.24 588.7 3.0E-03 3.4E-04 3.0E-03 3.4E-04 1.0

7.1E-02 8.1E-03 7.1E-02 8.1E-03 5.6E-01 2.4

(5) Rel. Hght Sigma Y Sigma Z 

SVCONC 481019.35 5245024.38 -18345.90 38523.20 466.6 17.6 23.3 16.33 1.2E-01 1.2E-01 1.2E-01 1.2E-01 5.0

SH400 483543.52 5247727.82 -15906.30 41136.40 472.5 7.6 98.8 7.09 1.9E-02 1.9E-02 1.9E-02 1.9E-02 2.0SH200 483117.58 5247512.11 -16318.00 40927.90 468.8 25.0 40.3 22.56 2.4E-03 2.4E-03 2.4E-03 2.4E-03 2.5SH000 480824.98 5244783.03 -18533.70 38289.90 471.6 24.2 5.9 8.41 2.4E-03 2.4E-03 2.4E-03 2.4E-03 2.5

MDS001 -15576.00 41038.00 455.4 3.3 293.2 3.08 2.2E-02 2.2E-02 1.2MDS002 -18070.00 37273.00 434.4 3.3 1105.8 3.08 1.1E-01 1.1E-01 3.7

MDS002b -16638.00 38493.00 443.8 3.3 1443.0 3.08 1.1E-01 1.1E-01 3.7

MDS003 -18070.00 37273.00 434.4 3.3 1105.8 3.08 3.9E-02 3.9E-02 1.3

MDS003b -16638.00 38493.00 443.8 3.3 1443.0 3.08 3.9E-02 3.9E-02 1.3

(1) These sources are all vented out of the concentrator building. See SVCONC in next table. 

(2) Building Vent, modeled as volume sources. See SV008/SV009 in next table (3) Ore barn vents, modeled as volume sources. 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 full operation and these units running (one per area) tests of no more than 30 m

Modeling files stored at MPCA at: X:\Agency_Files\Outcomes\Risk_Eval_Air_Mod\Air_Modeling 
Summary of Modeled Volume, Area, and Open Pit Source Parameters 

Source ID Source Description Source Type Release Height (m) SXINIT (m) SYINIT (m) SZINIT (m) AREA (m2) Angle (deg) PM10 (g/s) PM2.5 (g/s) 

Hourly Annual Hourly Annual Hou

SV008 Coarse Ore Conveyor Gallery VOLUME 14 10 13 1.43E-02 1.43E-02 1.43E-02 1.43E-02SV009 Fine Ore Conveyor Gallery VOLUME 14 10 13 6.50E-02 6.50E-02 6.50E-02 6.50E-02SVCONC Line 1, 2, and 3 Primary Grinding Mill and Space Heaters (4) VOLUME 18 23 16 1.19E-01 1.19E-01 1.19E-01 1.19E-01 5.05SH400 Area 400 Space Heaters (16) VOLUME 8 99 7.1 1.92E-02 1.92E-02 1.92E-02 1.92E-02 2.02SH200 Area 200 Space Heaters (2) VOLUME 25 40 23 2.40E-03 2.40E-03 2.40E-03 2.40E-03 2.52SH000 Area 000 Space Heaters(2) VOLUME 24 6 8.4 2.40E-03 2.40E-03 2.40E-03 2.40E-03 2.52CONCPILE Concentrate Stockpile VOLUME 5 15 4.7 7.68E-02 7.68E-02 1.59E-02 1.59E-02CONCWE Concentrate Stockpile Wind Erosions VOLUME 5 15 4.7 1.10E+00 1.10E+00 1.00E+00 1.00E+00OXPILE Oxides Stockpile VOLUME 5 9.3 4.7 1.14E-01 1.14E-01 1.47E-02 1.47E-02OXPILEWE Oxides Stockpile Wind Erosion VOLUME 5 9.3 4.7 1.10E+00 1.10E+00 1.00E+00 1.00E+00COBB Cobber Stockpile VOLUME 5 14 4.7 2.96E-01 2.96E-01 4.07E-02 4.07E-02COBBWE Cobber Stockpile Wind Erosion VOLUME 5 14 4.7 1.10E+00 1.10E+00 1.00E+00 1.00E+00OREBARN Orebarn Vents (fine and coarse) VOLUME 18 57 16 2.14E-02 2.14E-02 2.14E-02 2.14E-02OBA Overburden Stockpile A VOLUME 9 1.4 4.3 1.13E-01 1.13E-01 1.99E-02 1.99E-02OBAWE Overburden Stockpile A Wind Erosion VOLUME 9 1.4 4.3 1.10E+00 1.10E+00 1.00E+00 1.00E+00STATE Waste Rock Stockpile State VOLUME 9 1.4 4.3 3.59E-02 3.59E-02 4.51E-03 4.51E-03STATEWE Waste Rock Stockpile State Wind Erosion VOLUME 9 1.4 4.3 1.10E+00 1.10E+00 1.00E+00 1.00E+00LANGDON Waste Rock Stockpile Langdon VOLUME 9 1.4 4.3 3.63E-02 3.63E-02 4.55E-03 4.55E-03LGDNWE Waste Rock Stockpile Langdon Wind Erosion VOLUME 9 1.4 4.3 1.10E+00 1.10E+00 1.00E+00 1.00E+00GNIOP Waste Rock Stockpile GNIOP VOLUME 9 1.4 4.3 2.33E-02 2.33E-02 2.88E-03 2.88E-03GNIOPWE Waste Rock Stockpile GNIOP Wind Erosion VOLUME 9 1.4 4.3 1.10E+00 1.10E+00 1.00E+00 1.00E+00SHARE Waste Rock Stockpile Share VOLUME 9 1.4 4.3 3.34E-02 3.34E-02 4.18E-03 4.18E-03SHAREWE Waste Rock Stockpile Share Wind Erosion VOLUME 9 1.4 4.3 1.10E+00 1.10E+00 1.00E+00 1.00E+00FS400 Area 400 Lump Lime/Carbon Unloading and conveyor drop VOLUME 5 8.3 4.7 1.49E-02 1.49E-02 2.25E-03 2.25E-03FS500 Steel Plant Stockpile VOLUME 5 25 4.7 9.37E-01 9.37E-01 2.58E-01 2.58E-01FS500WE Steel Plant Stockpile Wind Erosion VOLUME 5 25 4.7 1.00E+00 1.00E+00 1.00E+00 1.00E+00FS314 Building Vent VOLUME 5 5.8 4.7 4.68E-01 4.68E-01 7.87E-02 7.87E-02FS526 Locomotive VOLUME 5 8.1 8.1 6.68E-02 6.68E-02 1.55E-02 1.55E-02PR001 Paved Road VOLUME 2 4.7 1.7 2.32E-01 2.32E-01 6.36E-02 6.36E-02FS037 CDRI Drop into Line I EAF Feed Collection Chute VOLUME 40 0.2 0.5 5.16E-02 5.16E-02 1.41E-02 1.41E-02SRVRD1 - 97 Service Road VOLUME 2 4.7 1.9 7.80E-01 7.80E-01 7.09E-02 7.09E-02COB05 - 09 Cobber Rejects Haul Road to Cobber Rejects Stockpile VOLUME 5 14 4.7 4.02E-02 4.02E-02 3.65E-03 3.65E-03OBA001 - 044 206 P05 OB - Stockpile A VOLUME 5 14 4.7 1.32E+00 1.32E+00 1.21E-01 1.21E-01WRT001 - 009 328 P06 Waste - Langdon ex-pit and 107 P07 Ore VOLUME 5 14 4.7 8.73E-01 8.73E-01 7.98E-02 7.98E-02TAC001 - 005 107 P07 Ore VOLUME 5 14 4.7 4.35E-01 4.35E-01 3.98E-02 3.98E-02WGLS001 - 023 328 P06 Waste - Langdon, GNIOP, Share, and State Piles VOLUME 5 14 4.7 5.60E-01 5.60E-01 5.11E-02 5.11E-02WST001 - 028 327 P06 Waste - State ex-pit VOLUME 5 14 4.7 2.05E-01 2.05E-01 1.87E-02 1.87E-02WRL001 - 018 328 P06 Waste - Langdon ex-pit VOLUME 5 14 4.7 1.34E-01 1.34E-01 1.22E-02 1.22E-02WGS001 - 025 326 P06 Waste - Share and GNIOP ex-pit VOLUME 5 14 4.7 2.40E-01 2.40E-01 2.19E-02 2.19E-02WRG001 - 008 325 P06 Waste - GNIOP ex-pit VOLUME 5 14 4.7 2.50E-02 2.50E-02 2.28E-03 2.28E-03WSH001 - 027 326 P06 Waste - Share ex-pit VOLUME 5 14 4.7 1.75E-01 1.75E-01 1.60E-02 1.60E-02PL024 - 045 & TB001 - 121 Tailings Basin Truck Traffic VOLUME 2 4.7 1.9 1.78E-01 1.78E-01 1.62E-02 1.62E-02PIT Mining Pit OPEN PIT 10 4070 1280 5.21E+06 335 1.90E-06 1.90E-06 2.21E-07 2.21E-07TBNE Tailings Basin Wind Erosion AREA 0 200 800 1.60E+05 0 1.10E+00 1.10E+00 1.00E+00 1.00E+00TBSW Tailings Basin Wind Erosion AREA 0 200 800 1.60E+05 -30 1.10E+00 1.10E+00 1.00E+00 1.00E+00TBNEDOZE Tailings Basin Dozer Activities AREA 2 200 800 1.60E+05 0 8.72E-06 8.72E-06 7.62E-07 7.62E-07TBSWDOZE Tailings Basin Dozer Activities AREA 2 200 800 1.60E+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 detection 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: 

x + tα, n −1 sn −1 n [1] 

Where x is the average; sn-1 is the sample standard deviation; n is the number of observations; t is the value 

found in Table 2 or directly calculated 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 observed change in visible emission characteristics from 

that observed when this source and its pollution control 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 PM2.5

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 PM2.5 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 PM2.5 testing for an emission unit to be included in a 

statistical analysis to develop a PM2.5 emission limit, the emission unit must meet the following conditions: 

• The measured PM10 emissions from the emission unit must be at or below the PM10 stack limit in the most 

recent PM10 performance test conducted pursuant to Minn. R. ch. 7017. 

• The Permittee must demonstrate that the operation 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 associated 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 groups (i.e., parameters) addressed in this appendix are Event and Fuel Type. 

However, a data group is a general term and could be used to evaluate the effect of other parameters on PM2.5

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 handling stacks as described in the Taconite MACT (40 

CFR Part 63 Subp. RRRRR, GP 008 of the permit) which provides 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 statistical purposes, each test run is an individual 

sample data point. 
1.1 General Information

• The Permittee shall conduct test-and-set testing in compliance with all applicable provisions of Minn. R. ch 

7017. The stack test method that will be used in a specific 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 PM2.5 concentration (gr/dscf) limit and an 

initial PM2.5 mass emission rate limit (lb/hr) for each emission unit capable of emitting PM2.5. The test-andset testing will be used to set more refined concentration and mass emission rate limits for each emission 

unit addressed in this appendix. The statistical analysis of the test-and-set testing will be used to 

determine a concentration limit as PM2.5 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 PM10 is typically measured using EPA Method 201A, while the 

condensable fraction of PM10 is usually measured using EPA Method 202. Method 201A uses a cyclone to 

separate particles with a diameter of 10 microns or less from the larger particles. However, when the gas 

being tested contains entrained water droplets, Method 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 modification to Method 201A to measure filterable PM2.5. Though 

this modified method has not been promulgated by EPA, it has been used in Minnesota to measure PM2.5. 

It is anticipated that Methods 201A and 202 will be the primary stack test methods used to develop PM2.5

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 PM2.5 emission limits for all units 

identified in Table 1, as applicable based on construction 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 prepared 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 PM2.5 emission limits shall be reviewed with MPCA prior to 

submitting an application for a major permit 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 loading 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 Handling – Crushing, grinding and handling or ore and 

concentrate will be included in Groups A-C. The material 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 PM2.5. 

• 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 PM2.5 Test Groups and Individual Stacks 

Table 1 – PM2.5 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 PM2.5 concentrations are found to be similar across source groups, the Permittee may propose to combine 

source groups for the purpose of establishing PM2.5 concentration limits. 

Initially, two test events shall be completed for each group/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 number of test events to be conducted for establishing the 

PM2.5 emission limits. As shown in Figure 1, Event 1 and Event 2 shall consist of six runs per stack. The six runs 

shall be conducted during the same stack test mobilization period (i.e. event). Completion of six runs will require 

a minimum of two days to complete. Additional testing events indicated in Figure 1 shall consist of three runs 

per event. 

The outcome of the statistical analysis of the initial stack testing will be a determination of the variability of the 

test results. If the variability of the data from the initial stack testing meets certain statistical conditions (described 

below), no further testing is necessary before proposing the PM2.5 emission limit. Test results with variability 

above these criteria indicate that more testing is necessary before proposing the PM2.5 emission limit. 

Prior to accepting the stack test results as indicative of ‘in-control’ operations, the performance of the control 

equipment and other operating metrics shall be verified. For the filterable component of PM2.5, the PM10

performance criteria will be used to determine the ‘in-control’ condition for PM2.5. Specifically, all manufacturer 

recommendations for PM10 control will be verified. 

For those individual stacks where condensable PM2.5 emissions are expected to be present, CEMS data shall be 

used to determine the efficacy of SO2 control equipment operations at the stack outlets. NOx control shall be 

optimized through burner technology. 

2.1 Sampling Events 

The Permittee shall conduct a minimum of six runs per event 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 different 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 PM2.5 concentration limit. 

• Conduct two-sample t-test (see Section 2.2.2) to determine if there are significant differences between 

events. 

• Determine acceptability of results for setting PM2.5 emission limits. 

• If the statistical analysis indicates that an additional sampling event is required (see Section 2.2.3.2), 

stacks shall be tested as described in the first two bullets 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

t s

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 there is a statistically significant difference in the mean PM2.5

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 and degrees of freedom. If the calculated t-statistic is 

greater than the tabulated t-value, then it shall be concluded that there is a statistically significant difference 

between the mean concentrations. 

• Calculation of two-sample t-test: 

A B

p

A B

calculated

n n

s

X X

t

1 1 ( )

⋅ +

− − Δ =

2

( 1) ( 1) 2 2

+ −

− ⋅ + − ⋅ =

A B

A A B B

p n n

n s n s

s

Where: 

XA = mean (average) concentration for Event 1 samples 

XB = mean (average) concentration for Event 2 samples 

Δ = hypothesized difference between the means = 0 

nA = number of samples from Event 1 = 6 

nB = number of samples from Event 2 = 6 

sp = Pooled Standard Deviation 

sA = standard deviation of Event 1 samples 

sB = standard deviation of Event 2 samples 

• If t(calculated) > ( + −2,1−α / 2) nA nB t , then the means of the events are significantly different. 

Where: 

( + −2,1−α / 2) nA nB t = 2.776 for nA + nB - 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 

PM2.5 emission limit: 

1. The PM2.5 limit should be less than the PM10 limit, and 

2. There should be no statistically significant differences in PM2.5 concentrations for sources within the same group. 

If after two sampling events the variability of the test results exceeds the acceptable threshold, one additional 

sampling event shall be conducted. If, after the third sampling event, the variability of the test exceeds the 

acceptable threshold, the Permittee shall submit a plan to the MPCA for establishing the PM2.5 emission limits. 

2.2.3.1 Threshold for Initial Statistics 

If 95% UCL < PM10 limit and the two-sample t-test shows no significant difference between events, the statistical 

results shall be deemed acceptable for setting a PM2.5 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 PM2.5 limit = 95% UCL. 

If 95% UCL < PM10 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 > PM10, then conduct a two-sample t-test. If the two-sample t-test shows no significant difference 

between stacks (or events), the Permittee 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, compare 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 Analysis Based on Three Sampling Events 

The Permittee shall prepare and submit a major amendment application to propose PM2.5 limits as follows: 

1. For each group/stack in which the 95% UCL < PM10 limit: 

a. Propose a limit of PM2.5 = 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 PM2.5 = 95% UCL (using only test runs on the group/stack) if the 

two-sample t-test shows significant differences exist between groups/stacks. 

2. For each group/stack in which the 95% UCL > PM10 limit, determine the average emission rate for each set of 

three sampling runs (i.e., for each group, 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 PM10 emission limit. Propose PM2.5 limits as follows: 

a. Propose a limit of PM2.5 = initial PM10 if the average of each three-run set ≤ PM10 limit; or 

b. Propose an increased PM2.5 limit based on the test results if the average of each three-run set > PM10 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 contain an update to the BACT analysis and the proposed 

PM2.5 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 prepared 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 to assist in interpretation of 

the stack test results and statistical calculations. 

The statistical analyses and proposed PM2.5 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 between events to account for seasonality effects. Time is also required to 

conduct the analytical components of the stack test, conduct the statistical analysis, and prepare the stack test 

report. In addition, the currently proposed stack test method for PM2.5 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., Event 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 PM2.5 emission limit shall be 

determined by conducting either a PM2.5 performance test or a PM10 performance test to demonstrate 

compliance with the initial PM2.5 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 3.75 10− = ⋅ ⋅ j ⋅ × i

i i V

V

MW E c

Where: 

Ei = Emission Rate of pollutant i, lb/hr 

ci = Emission Rate of pollutant i, ppm 

Vj = Gas flow rate in stack j, dsfcm 

MWi = Molecular weight of pollutant i, g/mol 

V = 24.04 g/mol 

3.75x10-6 = combined conversion factor: ⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛ ⎟

⎠

⎞ ⎜

⎝

⎛

⋅

3

/ 453592.4 3.2808 min 60

m

ft

lb

mg

hr

V

MW

c i

i ⋅ computed as specified above has units of mg/m3
APPENDIX G 

Insignificant Activities 

Facility Name: Essar Steel Minnesota LLC 

Permit Number: 06100067-004 

The table below lists the insignificant activities at the facility 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, pressing, 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 storage 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 hydraulic 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 exclusively for bonding lining to brake shoes; and 

(7) Cleaning operations: alkaline/phosphate cleaners, associated cleaners, and associated burners. 

Minn. R. 7011.0110

subp. 3(I) Individual emission units 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 NOx, SO2, PM, PM10, VOCs (including hazardous air pollutant-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 plant upkeep activities not associated with 

primary production processes at the stationary source, such as spray painting 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, PM10, NOx, SO2, and VOCs 

C. 1.0 tpy combined HAPs 

D. 10,000 tpy CO2e 

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: 06100067-004 
0 

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 

~STEROCK TRUCKTO ~ 

~-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 

FROM PLANT FEED CONVEYORS {2) 

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 

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WATER-----

FLOTATION CHEMICAL 

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0 

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FINISHER 

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SCREEN 

UNDERSIZE 

SUMP 

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CONCENTRATE 

SUMP 

FROM CONCENTRATE 

THICKENER OVERFLOW 

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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. 

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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) 

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DRUMS 

SV022 

L---

MULTI 

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WINDBOX 

EXHAUST 

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SV017 

DUST 

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SV016 

DUST 

COLLECTOR 

CE014 

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PELLETS 

TRANSFER 

EU036 

DUST 

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CE016 

HOOD 

EXHAUST FAN 

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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 

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I 

I 

I 

I 

EU041 PELLET SCREENING AND HANDLING I L _______________________ ~ 

OPTIONAL FLOW PATH 

OXIDE PELLETS 

TO STOCKPILE 

FS026 

DWG. No. REV. No. 

A 
0 

0 

a: 

.-------------------------------, 

I I I I I I 

DRI 

AREA 

COATING 

POWDER 

STORAGE BIN 

DRI AREA 

COATING 

POWDER 

DAY BIN 

I 

I 

,---------------------, 

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CONVEYOR GALLERY ho-------t:-----_,(._..) 6~~5E4 ~E~L~NE 1 

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SV023 

FS032 

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SV073 

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;~R~~g~CTION I 

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FS025, CE065 

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I 

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I 

FS027, CE067 1 

I 

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TO REGRIND MILL 

FS029 

I 

I 

I 

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SV075 

illEtill 

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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-~-----~ 

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COOLING TOWER 

TO DRI PLANT 

SV005 

COOLING 

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CE005 

MAKEUP 

WATER FROM 

DRI CLARIFIER 

SV063 

EU012 

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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 

FIREWATER 

~rum BOOSTER PUMP 

DRI AREA OFIFICES 

DWG. No. REV. No. 

A 
0 

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 27th 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 process 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 Nashwauk, at the site of the former Butler Taconite Mining 

Company operations. 

The project has secured the 1.4 billion (long) ton Mineral 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 integrated 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 dewatering 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 (EAF), 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. The project will demand 450 MW of electric power, which will be supplied 

by Nashwauk Public Utility. Essar plans to use ore concentrating and indurating processes common to existing 

taconite operations and to employ natural 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 charge 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 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 combination in between. The blast furnace grade or high flux taconite pellets will be 

shipped to Essar Steel Algoma in Ste. St. Marie, Ontario Canada 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 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. However, 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 Project 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) 3.81 7.03, 5

High Flux (blast furnace grade) 0 6.54, 5

DRI Not applicable 2.82 1.86 

Steel Making 2.57 1.57

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 capacity used for air emission calculations was 4.1 mm tonne/yr. 2

 For the original MSI FEIS and Air Permit # 06100067-001, 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 tonne/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 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 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 used in air dispersion modeling assessments. 

6 There are no physical changes to the DRI proposed and there are no changes to the hourly production rates. 7 There are no physical changes to the steel mill proposed and 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 where 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 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 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 4th secondary crushing unit, 3rd autogenous grinding mill or the firing zone of the 

indurating furnace 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 modification and obtain financial close for equipment 

required for increase pelletizing capacity – 2012 

• Finish construction through taconite pellet plant 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 

PM10 994 8.13 1002 15 Yes 

PM2.5 458 8.13 466 10 Yes 

NOx 488 488 40 Yes 

SO2 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 (H2S) 10 No 

CO2e* 576,000 75,000 Yes 

*Modified units are units that have been modified since original 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 Potential to Emit Summary (tpy) 

PM PM10 PM2.5 SO2 NOx CO VOC Pb F** H2S H2SO4 CO2e 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 26.1HF 43.3 

*Original PTE corrected based on corrected throughput for DRI facility. 

**Original PTE based on production of Low Flux pellets only. 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 evaluated the need for this review and determined that it 

was not necessary. A letter from the U.S. Fish and Wildlife 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: Electric 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 Compression Ignition Internal Combustion Engines 

National Emission Standards for Hazardous Air Pollutants (NESHAP)

The facility is a major source of HAPs. The following NESHAPs 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 sources 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 equipment. Other PSEUs subject to 

CAM are required to address CAM at the time of permit renewal. 

For the proposed modification of the facility, this means 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 project 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 permit 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 for Stationary Internal Combustion Engines 

Table 5. Regulatory Overview of Units at the Facility 

Level* Applicable Regulations Comments 

Total 

Facility 

Title I BACT limits for PM2.5 The permit contains PM2.5 Test-and-Set provisions which describe the requirements 

for the facility to test to determine an updated PM2.5 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 facility 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 apply 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 emission 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 subject 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 time 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 requirements for baghouses controlling units subject to 

Taconite MACT. 

GP 008 40 CFR pt. 63, subp. RRRRR Limits and performance testing 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 compliance 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 performance 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 CO2e 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 complied with by complying with the 

requirements of GP 009. 

GP 024 Title I BACT limits Operating requirements, limits, performance testing, and other compliance 

requirements for the DRI Top Gas Purification system. 

GP 025 Title I BACT limits Emission limits and performance 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 concentration of Fluoride in the slag, sampling methods, and 

recordkeeping requirements. 

Appendix 

A 

Title I BACT limits Appendix A lists all of the Title I BACT 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 Quality Standards (NAAQS), Minnesota Ambient Air Quality 

Standards (MAAQS) and Class I and Class II PSD Increments, and 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 included as Attachment 1 to the TSD. Many of the units only 

have particulate emissions, and the choice for BACT was 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, PM10, PM2.5, Pb, F, CO, 

SO2, NOx SV 019 EU 039 , VOC, GHG 

SV 016 EU 036 Hearth Layer Bin PM, PM10, PM2.5, 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 Screening 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 

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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 for 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 control technology for facilities emitting CO2

in large amounts and industrial facilities with high-purity CO2 streams. ..." "... CCS is composed of three main 

components: CO2 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 significant differences pertinent to the successful operation for 

each of these three main components from what has already 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 CO2 gas in Sections 5.6.1 and 6.7.1.1. The capture 

options evaluated were Post-Combustion CO2 capture for normal combustion, Post-Combustion CO2 capture for 

combustion using pure Oxygen rather than air, and Pre-Combustion CO2 capture through gasification and 

converting the fuel to pure hydrogen prior to combustion. The first option is technically infeasible based on the 

low concentration of CO2 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 CO2 vary depending on whether it is in gaseous form or as a solid or liquid. As a solid 

or liquid, transportation of CO2 is feasible. CO2 in a gaseous form is considered technically infeasible due to the 

location of the nearest storage facility (in central North Dakota) and the significant logistical hurdles to install a 

pipeline to transport the CO2, 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 CO2 gas in Sections 5.6.3 and 6.7.1.3.The sequestration 

options evaluated in these sections were Deep Saline Aquifers, Oil/Gas Reserves, and Un-Mineable Coal Seams. 

There are processes under development to react CO2 to form a solid by-product, known as CO2 mineralization, 

discussed in Sections 5.6.2 and 6.7.1.2 of the BACT report. CO2 mineralization is a kinetically slow process which 

requires large amounts of energy. Several demonstration 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 eliminated from a BACT analysis in Step 2 if the three 

components working together are deemed technically infeasible for the proposed source, taking into account the 

integration of the CCS components with the base facility and site-specific considerations (e.g., space for CO2

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 

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Date: 5/10/2012 

add-on controls that are typically used to reduce emissions of other regulated pollutants and already have an 

existing reasonably accessible infrastructure in place to address waste disposal and other offsite needs. Logistical 

hurdles for CCS may include obtaining contracts for offsite land acquisition (including the availability of land), the 

need for funding (including, for example, government subsidies), timing of available transportation infrastructure, 

and developing a site for secure long term storage. Not every source has the resources 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 authority may conclude that CCS is not 

applicable to a particular source, and consequently not technically feasible, even 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 CO2 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 recovery. 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 drying and preheat windbox and firing sections of the furnace 

using heat recovered from the first pellet cooler. A portion of the hot air coming off the first pellet cooler will be 

used as combustion air in the firing section of the straight 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 NOx control analysis in Section 6.3 of the BACT report, the amount of preheated 

combustion air is limited in order to control NOx emissions in the low NOx 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 the 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 discusses 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. Natural 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 

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Date: 5/10/2012 

3.1.2 NAAQS

Under the federal Clean Air Act and the Prevention of Significant Deterioration (PSD) regulation, a Class II area is a 

geographic area other than national parks, monuments and wilderness 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 air 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 PM10, PM2.5, NOx, SO2, Pb, and CO emissions would meet the NAAQS and MAAQS. 

An ozone impacts analysis is also required of any major PSD modification where there is an increase in NOx

emissions which exceeds the significance threshold for ozone (40 tpy) because NOx and VOCs are precursors to 

ozone. A quantitative modeling analysis has not yet been developed to be used for this permit. With 

consultation with the U.S. EPA, a qualitative 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. NOx 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 standard. 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*

(μg/m3

)

Background 

Concentration 

(μg/m3

)

Predicted Ambient Air 

Concentration (μg/m3

)

MAAQS 

(μg/m3)

NAAQS 

(μg/m3)

PM10 24-Hour 27 30 57 150 150 

Annual 5.8 11 17 50 - 

PM2.5 24-Hour 15 15.7 31 65 35 

Annual 1.5 5.6 7.1 15 15 

SO2 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 

NOx 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 per location is not considered and the high second high is 

presented. The highest CO concentrations are given since the concentrations are well below the standards. 

**Ambient air quality modeling for lead was completed as part of the Screening Level Ecological Risk Assessment (SLERA) 
Technical Support Document, Permit Action Number: 06100067-004 

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Date: 5/10/2012 

3.1.3 PSD Increments

PSD allows facilities to construct emission units, but restricts the amount of additional pollution an area can receive. 

It does this by imposing “PSD increments,” 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 increase 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 (SILs). The SILs are values at or below 5% of the standard 

and represent a level where further analysis is not required to ensure compliance. Modeling of Essar’s facility 

showed that its impacts are above the SILs for 24-hour PM10, and 24-hour and annual PM2.5 (Table 8); therefore an 

analysis of the cumulative impact from all sources of PM10 and PM2.5 (past and present, increases and decreases) on 

the Class I areas was prepared. 

The emission inventory for the Essar Steel Increment analysis included modifications to existing sources, new 

facilities that have been permitted or submitted permit applications 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 PM2.5 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 emissions 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

(μg/m3

) 

U.S. EPA

SIL 

(μg/m3

) 

Facility Only Modeled 

Concentration 

(μg/m3) 

Total Modeled 

Concentration

(μg/m3) 

Percent of 

Standard 

PSD Increment PM10 24-hour 8 0.3 0.377 3.0 38% 

Annual 4 0.2 0.017 -- -- 

PM2.5 24-hour 2 0.07 -- 0.458 23% 

Annual 1 0.06 -- 0.043 4% 

SO2 3-hour 25 1 0.484 -- -- 

24-hour 5 0.2 0.191 -- -- 

Annual 2 0.1 0.006 -- -- 

NOx 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 PM10, PM2.5, NOx and SO2, are the maximum increase in air quality 

concentrations of pollutants that are allowed. Essar examined 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 PM2.5 Increment included as Attachment 6. 

The proposed project includes both fugitive sources and stacks, as well as nearby large industrial background 

sources. The modeled fugitive sources include mining activities, dust generation from traffic within the mine and 

plant site, and a number of smaller stockpiles in the plant areas. The facility stacks include the crushing process 

stacks through the steel production stacks. Backup generators and stacks used only during plant upset were not 

included in the modeling. Air pollution control equipment 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 analyses. 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

(μg/m3

) 

Facility Only Maximum 

Modeled Concentration*

(μg/m3

) 

Background 

(μg/m3

) 

Total Modeled 

Concentration**

(μg/m3

) 

Percent 

of 

Standard

PSD Increment PM10 24-hour 30 25 -- 25 84% 

Annual 17 3.6 -- 3.6 21% 

PM2.5 24-hour 9 7.1 -- 7.1 79% 

Annual 4 1.3 -- 1.3 33% 

SO2 3-hour 512 41 -- 41 8% 

24-hour 91 12 -- 12 13% 

Annual 20 1.6 -- 1.6 8% 

NO2 Annual 25 3.9 -- 3.9 16% 

NAAQS/MAAQS PM10 24-hour 150 27 30 57 38% 

Annual 50 5.8 11 17 34% 

PM2.5 24-hour 35 15 15.7 31 89% 

Annual 15 1.5 5.6 7.1 48% 

SO2 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% 

NO2 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 location 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.
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Date: 5/10/2012 

3.1.4 Class I AQRVs

Four Class I areas (the Boundary Waters Canoe Area Wilderness (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 assessed for potential impacts on Air Quality Related Values 

(AQRVs) from the project em4issions. These assessments are typically conducted using the CALPUFF modeling 

system. AQRVs are features or properties of Class I areas 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 the 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 impacts 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 results and potential mitigation measures (if needed) follows.

3.1.4.1 Flora and Fauna

Table 10 below compares the sum of background SO2 concentrations plus modeled ambient air SO2

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 used 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 SO2 concentrations are less than 40 μg/m3. As can 

be seen in Table 10, all estimated SO2 ambient air concentrations are lower than 40 μg/m3. The Federal Land 

Managers have set a screening level concentration referred to as the “Green Line Concentration”. All modeled 

concentrations are also below the “Green Line Concentration” of 5 μg/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 SO2

Total Annual Average Ambient Air Concentrations – Final Proposed Project 

Location 

Background Air 

Concentration1

(μg/m3

) 

Modeled Project 

Contribution2

(μg/m3

) 

Total Projected 

Air Concentration 

(μg/m3) 

Green Line 

Concentration3 

(μg/m3) 

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 SO2 concentrations (ug/m3) 2

Modeled ambient air concentration in Class 1 area using the CALPUFF modeling system. 3

Green line concentration from Adams et al., “Screening Procedures 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 are evaluated slightly differently by the National Park 

Service and the US Forest Service. The acid deposition 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 ecosystems 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 developed by the National Park Service and US Fish and Wildlife 

Service (USFWS) to evaluate the contribution 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 CALPUFF modeling system and results are presented in 

Table 11. SO2 and NOx 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 

Location2 Pollutant Background 

Data1

Model Air 

Concentration or 

Calculated ProjectRelated Deposition3

Total 

Concentration or 

Deposition 

Green Line Value or 

Deposition Analysis 

Threshold4

BWCAW - Ely Annual Ave SO2 (μg/m3

) 1.2 0.006 1.2 5 μg/m3

3-hour max SO2 (μg/m3) 10.8 0.484 11.3 100 μg/m3

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 SO2 (μg/m3

) 2.0 0.001 2.0 5 μg/m3

3-hour max SO2 (μg/m3) 18 0.074 18.1 100 μg/m3

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 SO2 (μg/m3

) 1.6 0.003 1.6 5 μg/m3

3-hour max SO2 (μg/m3) 14.4 0.183 14.6 100 μg/m3

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 SO2 (μg/m3

) 0.7 0.006 0.7 5 μg/m3

3-hour max SO2 (μg/m3) 6.3 0.324 6.6 100 μg/m3

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 SO2 concentrations (ug/m3) 2

Modeled air concentration in each Class I area. 

3

Model estimated ambient air concentrations using the CALPUFF modeling system. 4

Green line concentration. DAT is based on National Park Service Guidance for the Eastern U.S. 5

Majority of total concentration or deposition is due to background. 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 proposed Essar Steel project were evaluated based on 

currently accepted guidance from the Federal Land Managers (FLMs). The guidance is known as FLAG (Federal 

Land Managers Air Quality Related Values Workgroup). Previous visibility impact modeling used FLAG 2000 

guidance which uses the CALPUFF/CALPOST model with 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 (bext). Three Class I areas were 

included in the visibility analysis for the project: the 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 (NH3 1 ppb) 

Location Parameter FLAG 2000 FLAG 2010 

BWCAW Maximum Δbext (%) 5.15 – 12.79 5.47 – 10.62 

Days with Δbext ≥ 5% 1 – 10 1 – 4 

Days with Δbext ≥ 10% 0 – 1 0 – 1 

Isle Royale Maximum Δbext (%) 2.88 – 4.49 1.42 – 2.9

Days with Δbext ≥ 5% 0 0 

Days with Δbext ≥ 10% 0 0 

Voyageurs Maximum Δbext (%) 6.63 – 13.52 4.31 – 7.94

Days with Δbext ≥ 5% 3 – 6 0 – 2 

Days with Δbext ≥ 10% 0 – 1 0 

*Maximum changes in the daily extinction coefficients compared to natural background 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 Minnesota Steel project were listed at 77 lb/yr in the 

Implementation Plan for Minnesota’s Statewide Mercury 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 technologies 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 quality 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 northeastern 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 SO2 emissions with 

scrubbers and control of fugitive dust with a fugitive dust control plan. 

Construction employment at the Essar Steel site is expected 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 infrastructure of the Iron Range is generally 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 respectively. These store the materials used in the 

proposed Activated Carbon Injection and GSA Dry Scrubber 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 scenarios. The total facility PTE is based on the highest 

pollutant specific PTE between the scenarios. 

Production of High Flux pellets requires a different chemical composition of the greenballs 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 responsibility of the owner or operator of a facility to have 

sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. 

The Permittee submitted a CAM proposal as required by 40 CFR § 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 requirements 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, PM10, PM2.5, 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, PM2.5 tests require 2 stacks 

from 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, PM10, PM2.5, Pb, F, 

SO2, SAM, NOx, 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 SO2, NOx, CO, and O2 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, PM10, PM2.5, SO2, 

NOx, CO, VOC, and 

Opacity limits 

Performance testing Initial and recurring performance tests to document 

compliance with each limit. 

GP 016 PM, PM10, PM2.5, 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, PM10, PM2.5, 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, PM10, PM2.5, Pb, F, 

SO2, SAM, NOx, CO, VOC, 

CO2e 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 NOx, 

SO2, and CO limits. Initial and recurring performance 

tests are required to show compliance with PM, PM10, 

PM2.5, 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 CO2

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, PM10, PM2.5, Pb, F, 

SO2, NOx, 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 NOx 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 NOx burners in the 

Ladle/Tundish Pre-heaters. Compliance with emission 

limits will be demonstrated through compliance with the 

limits in GP 009. 

GP 024 H2S Limits 

DMDS injection rate 

Monitoring and 

performance testing 

Initial and recurring performance tests to document 

compliance with H2S 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 insignificant 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. Requirements 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 tests, 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 opportunities to comment on 

both the construction and operating provisions of the permit. EPA’s review of the construction provisions 

coincided with the Public Notice Period. The 45-day review 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 Comment 6-6 needed to be adjusted to include NOx SSM limits. These 

SSM limits are found for stacks in GP 009 and 019 only. As a result, NOx modeling was updated to include NOx SSM 

rates for the 1-hour NO2 NAAQS. The updated rates and modeling results are included in Attachment 7 of the TSD. 

There was no change to the maximum modeled concentrations as a result of this update. In addition, the permit 

limits for NOx SSM rates were updated to a 1-hour averaging time to match the modeled rates, and the normal NOx

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 NOx emission limits were used for 

modeling compliance with the annual standard, and therefore the original averaging times are appropriate. 

EPA notified the MPCA in an email on May 9, 2012 that all of their comments had been addressed appropriately and 

that they would have no further comments, thereby ending their 45 day review period on that day, May 9th, 2012. 

4. Permit Fee Assessment 

Attachment 9 to this TSD refers to the worksheet which contains the MPCA’s assessment of Application and 

Additional Points used to determine the permit application fee for this permit action as required by Minn. R. 

7002.0019. The permit action includes one permit application, 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, PM10, PM2.5, 

Pb, F, SO2, NOx, 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 has reasonable assurance that the proposed operation of 

the emission facility, as described in the Air Emission 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-application), 3704 (application received 10/14/2011) 

Attachments: 1. BACT Summary 

2. CAM Plan 

3. ESA Determination 

4. Ozone Impact Analysis Technical Memorandum 

5. PM2.5 Class I Increment Technical Memorandum 

6. PM2.5 Class II Increment Technical Memorandum 

7. NOx 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, PM10, PM2.5, SO2, NOx, CO, VOC, F, Pb, and GHG. Any 

new major stationary source or major modification subject to a Prevention of Significant Deterioration (PSD) 

review must conduct an analysis to ensure the application of the Best Available Control Technology (BACT). The 

results of the BACT analysis for the proposed modifications project at Essar Steel Minnesota LLC form the basis 

for the selection of control technology and the resulting emission limitations at each emissions unit. The BACT 

analysis in this report followed EPA’s five step top down approach: 

Step 1 – Identify All Control Technologies 

Step 2 – Eliminate Technically Infeasible Options 

Step 3 – Rank Remaining Control Technologies by Control Effectiveness 

Step 4 – Evaluate Most Effective Control 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/PM10/PM2.5

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. 

PM10 X 0.0080 PM2.5

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/PM10/PM2.5. 

X 

Good Design and 

Operating Practices Yes 5 Inherent to Design X 

Dry Electrostatic 

Precipitator 

(Dry ESP) 

Yes 2 

PM 0.0060 

PM10 0.012 PM2.5

Wet Electrostatic 

Precipitator 

(Wet ESP) 

Yes 2 

PM 0.0060 

PM10 0.012 PM2.5

Wet Scrubber Yes 2 

PM 0.0060 

PM10 0.012 PM2.5

Centrifugal 

Separation 

(e.g. Cyclones) 

Yes 3 

PM 0.080 

PM10 0.16 PM2.5

Inertial Separators 

(Drop Out Box) Yes 4 

PM 0.20 

PM10 0.40 PM2.5

 
Table 1-2: Taconite Pellet Indurating Furnace: Waste Gas Stack; 

SO2

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 SO2. 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 equipment is needed to convert 

the sulfates generated by absorption to a solid waste 

(gypsum). 

• Absorption produces a visible 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; 

SO2

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 SO2. 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 SO2 removed. 

Spray Dryer 

Absorption Yes 1 5 ppm Not cost effective at $139,000/ton of SO2 removed. 

Absorber 

(Single High 

Pressure Wet 

Scrubber) 

Yes 1 5 ppm 

Not cost effective at $97,000/ton of SO2 removed. 

Absorber 

(Low Pressure 

Wet Scrubber) + 

Wet Electrostatic 

Precipitator 

Yes 2 5 ppm 

Not cost effective at $429,000/ton of SO2 removed. 

Dry Sorbent 

Injection Yes 2 6 ppm Not cost effective at $207,000/ton of SO2 removed. 

 
Table 1-4: Taconite Pellet Indurating Furnace: Waste Gas Stack; 

NOx

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 NOx 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 NOx 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 NOx 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 for 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 NOx/Ultra Low 

NOx Burners No 

Without special combustion chamber design oxygen concentrations at burner are 15 - 20% 

oxygen. This is too high for a low NOx 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 NOx emissions but higher emissions of all other pollutants. 

 
Table 1-5: Taconite Pellet Indurating Furnace: Hood Exhaust; 

NOx

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 NOx 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 NOx 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. 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 NOx/Ultra Low 

NOx Burners No 

Without special combustion chamber design oxygen concentrations at burner are 15 - 20% 

oxygen. This is too high for a low NOx 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 NOx emissions but higher emissions 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 SO2 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 equipment is needed to convert 

the sulfates generated by absorption to a solid waste 

(gypsum). 

• Absorption produces a visible plume due to the water 

condensation in absorber exhaust plume. 

Wet Electrostatic 

Precipitator Yes 1 70-85% 

• Generates wastewater that requires treatment. 

• Additional processing equipment 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 SO2 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 

(SO2, NOx , acid gases). 

• Generates wastewater that must be treated. 

Wet Scrubber Yes 1 98-99+% • Uses more electricity. 

Centrifugal 

Separation 

(e.g. Cyclones) 

Yes 2 50-80% 

Inertial Separators 

(Drop Out Box) Yes 3 <50% 

 
Table 1-10: Taconite Pellet Indurating Furnace: 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 CO2e. 

X 

Energy Efficiency 

Measures Yes 1 Inherent to Design X 

Lower Emitting 

Processes -- SO2

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. 

CO2 Capture Technologies 

Post Combustion 

CO2 Capture No 

• Not demonstrated at commercial scale. 

• High energy demand. 

• No feasible sequestration location. 

Oxyfuel 

Combustion with 

CO2 Capture 

No 

• Oxygen requirements of the furnace are not compatible with technology. 

• Not demonstrated on a commercial scale. 

• No feasible sequestration location. 

Gasification and 

Pre-combustion 

CO2 Capture 

No 

• Furnace is not designed to burn hydrogen produced from gasification of solid fuels. 

• No feasible sequestration location. 

CO2 Mineralization No • Not demonstrated at commercial scale. 

• High energy demand. 

CO2 Sequestration Locations 

Deep Saline 

Aquifers No 

• Closest location is 600 miles from project. 

• No CO2 transportation pipelines in the region. 

• Not demonstrated at commercial scale. 

Oil & Gas Reserve No 

• Closest location is 550 miles from project. 

• No CO2 transportation pipelines in the region. 

• Not demonstrated at commercial scale. 

Un-mineable 

Coal Seam No 

• Closest location is 550 miles from project. 

• No CO2 transportation pipelines in the region. 

• Not demonstrated at commercial scale. 

 
Table 1-11: Material Handling; 

PM/PM10/PM2.5

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 0.25 
Table 1-12: Summary of BACT Limits – Material Handling Sources

SV ID EU ID CE ID* Emission Unit Description 

Performance Standard Mass Emiss

PM/PM10/PM2.5

(gr/dscf) 

Lead 

(mg/kg) 

Fluoride

(mg/kg) 

PM/PM10/PM2.5

(lb/hr) 

(

SV 016 EU 036 CE 014 Hearth Layer Bin 0.0020 2.0 50 1.4E+00 2SV 017 EU 037 EU 106 CE 015 Hearth Layer Feed 0.0020 2.0 50 1.2E-01 2SV 020 EU 040 CE 021 Pellet Discharge 0.0020 2.0 50 3.3E+00 6SV 021 EU 041 CE 022 Pellet Screening and Handling 0.0020 2.0 50 2.9E+00 5SV 022 EU 042 CE 023 Pellet Screenings to Regrind Conveyors 0.0020 2.0 50 2.4E-02 4SV 023 EU 048 CE 024 Oxide Pellet Stockpile Conveyor Gallery 0.0020 2.0 50 7.7E-01 1SV 084 EU 176 CE 116 Primary Grinding Mill Line 3 0.0020 12 1.0 2.3E-01 2SV 085 EU 170 CE 115 Grizzly Transfer Tower 0.0020 12 1.0 7.9E-02 9SV 086 EU 171 CE 110 Non-Magnetic Cobber Rejects Transfer Tower 0.0020 12 1.0 7.9E-02 9SV 087 EU 172 CE 111 Secondary Screening Crusher/Cobber Line 1 0.0020 12 1.0 3.9E-01 4SV 088 EU 173 CE 112 Secondary Screening Crusher/Cobber Line 2 0.0020 12 1.0 3.9E-01 4SV 089 EU 174 CE 113 Secondary Screening Crusher/Cobber Line 3 0.0020 12 1.0 3.9E-01 4SV 090 EU 175 CE 114 Secondary Screening Crusher/Cobber Line 4 0.0020 12 1.0 3.9E-01 4SV 091 EU 177 CE 119 Carbon Bin for Mercury Control 0.0020 --- --- 1.7E-02 SV 092 EU 178 CE 120 Lime Bin for Scrubber 0.0020 --- --- 1.7E-02 

NA 

FS 017 

NA 

Dozer Activity at Tailings Basin 

Fugitive Dust Control Plan 

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 

*Control Equipment chosen as BACT for each EU is a fabric filter (baghouse) with Leak Detection.
Table 1-13: Summary of BACT Limits – Indurating Furnace

SV ID EU ID EU Description CE ID CE Description Pollutant Performance Standard Mass Emission 

SV 018 EU 038 Furnace Hood Exhaust 

CE 016 Fabric Filter (baghouse) with Leak Detection 

PM 0.0040 gr/dscf 27 (lb/hr) 

PM10 0.0080 gr/dscf 54 (lb/hr) PM2.5 0.0080 gr/dscf 54 (lb/hr) Pb 0.0040 gr/dscf 0.021 (lb/hr) 

NA NA F 1.8 ppmv wet @ 15% O2 4.4 (lb/hr) 

SO2 6.8 ppmv wet @ 15% O2 55.7 (lb/hr) 

NA Good Combustion Practices CO 1.9 ppmv wet @ 15% O2 6.8 (lb/hr) 

VOC 0.60 ppmv wet @ 15% O2 3.3 (lb/hr) 

NA NA Opacity 5% NA 

SV 018/019 

Combined 

EU 038/039 

Combined Furnace CE 020 Low NOx burners NOx 0.25 lb/mmBtu 135 (lb/hr) 

NA NA CO2e NA 710,000 ton/yr 

SV 019 EU 039 Furnace Waste Gas 

CE 019 Fabric Filter (baghouse) with Leak Detection 

PM 0.0040 gr/dscf 18 (lb/hr) 

PM10 0.0080 gr/dscf 37 (lb/hr) PM2.5 0.0080 gr/dscf 37 (lb/hr) Pb 0.0040 gr/dscf 0.021 (lb/hr) 

CE 117 GSA Dry Scrubber F 11.5 ppmv wet @ 15% O2 20.4 (lb/hr) 

SO2 5.0 ppmv wet @ 15% O2 29.9 (lb/hr) 

NA Good Combustion Practices CO 7.4 ppmv wet @ 15% O2 19.3 (lb/hr) 

VOC 2.3 ppmv wet @ 15% O2 9.3 lb/hr 

NA NA Opacity 5% NA 
Attachment 2 – CAM Plan 

Compliance Assurance Monitoring Plan 

GSA Dry Scrubber with Lime for SO2 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 SO2

Monitoring Requirements: SO2 CEM and stack flow rate monitor 

C. Control Technology: GSA dry scrubber with lime solution 

 
II. Monitoring Approach

I. Indicator SO2 CEM, O2 meter and stack flow rate meter.

Measurement Approach: The SO2 concentration in ppm and emission rate in lb/hr will be continually monitored 

via a CEM. 

II. Indicator Range An excursion is defined as SO2 emissions in excess of 5 ppm, or 30 lb/hr on a three hour 

block average basis during normal production periods. Excursions trigger an inspection, 

corrective action as necessary, and a reporting requirement. The suggested SO2 CEM 

measurement range is 0 to 100 ppm SO2. The suggested stack flow rate meter 

measurement range is 0 – 400,000 scfm 

III. Performance Criteria 

A. Data 

Representativeness 

The SO2 CEM will measure the SO2 content at the scrubber outlet. The O2 meter will be 

used to correct the SO2 concentration to a 15% O2 basis. A stack flow rate meter will 

measure the stack flow rate for determining the SO2 mass emission rate. 

B. Verification of 

Operational Status 

NA. 

C. QA/QC Practices and 

Criteria 

The CEM will be installed, certified, calibrated, and operated according to procedures 

identified in Minn. R. 7017.1002-.1220. The quality assurance procedures include initial 

analyzer certification, daily calibration drift assessment, quarterly calibration gas audits 

and relative accuracy test audits (RATA). 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 SO2 concentration and emission rate will be measured continuously by the CEM and 

stack flow rate monitor. 

Data Collection 

Procedures 

Data will be collected by electronic data acquisition equipment. 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 operational periods of less than 

one hour. The stack moisture content, 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 therefore not subject to the Minnesota Industrial Process 

Equipment Rule. The source will be equipped with a GSA dry scrubber with lime to control SO2 emissions. 

B. Rationale for Selection of Performance Indicators

SO2 measurement by CEM with O2 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 SO2 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 SO2 concentrations are measured on a dry basis, stack test data will be used to determine the moisture 

content of the stack for the SO2 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 scheduled 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 SO2 CEM 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 commencing the initial performance test as specified in Essar Steel Minnesota LLC’s 

operating permit. The SO2 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 (PM10) 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 system, 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 installed 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 maintenance 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 indicate the potential for leaks 

and/or bag failures. Excursions trigger an inspection, corrective action as necessary, and 

a reporting requirement. Initially, 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 maintenance 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 downstream of the baghouse. 

The pressure drop indicators will measure the pressure drop between the inlet and 

outlet of each baghouse cell. 

The inspection and maintenance 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 downtime 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 maintenance program – the frequency of inspections will be consistent 

with the requirements for baghouses in the Taconite MACT. 

Data Collection 

Procedures 

The bag leak detector indication will be recorded via the melt shop process data 

acquisition system. 

Baghouse pressure drop readings will be collected manually at least once per day. 

Inspection and maintenance program records will be recorded 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 PM10 emissions. 

B. Rationale for Selection of Performance Indicators

Bag leak detectors have demonstrated the ability to identify excessive 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 excursion 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 documented 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. holes 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 NOx 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 NOx (with LE Burner) 

Other Limit: None 

Monitoring Requirements: NOx CEM and stack flow rate monitor 

C. Control Technology: LE Burner 

 
II. Monitoring Approach 

I. Indicator NOx CEM, O2 meter and stack flow rate meter.

Measurement Approach: The NOx concentration and emission rate will be measured continuously by the CEM 

and stack flow rate monitor. 

II. Indicator Range An excursion is defined as NOx emissions in excess of 0.25 lb/mmBtu or 135 lb/hr on a 

24 hour block average basis during normal production periods. Excursions trigger an 

inspection, corrective action as necessary, and a reporting requirement. The suggested 

NOx CEM measurement range is 0-100 ppm NOx for monitoring emissions after control 

by Low NOx LE burners, and will convert the ppm measurement to lb/mmBtu. The 

suggested stack flow rate meter measurement range is 0-400,000 scfm. 

III. Performance Criteria 

A. Data 

Representativeness 

The NOx CEM will measure the NOx content at the scrubber outlet. The O2 meter will be 

used to correct the NOx concentration to a 15% O2 basis. A stack flow rate meter will 

measure the stack flow rate for determining the NOx mass emission rate. 

B. Verification of 

Operational Status 

NA. 

C. QA/QC Practices and 

Criteria 

The CEM will be installed, certified, calibrated, and operated according to procedures 

identified in Minn. R. 7017.1002-.1220. The quality assurance procedures include initial 

analyzer certification, daily calibration drift 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 NOx concentration and emission rate will be measured continuously by the CEM 

and stack flow rate monitor. 

Data Collection 

Procedures 

Data will be collected by electronic data acquisition equipment. 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 operational periods of less than 

one hour. The stack moisture content, if needed, will also be verified during RATAs. 

Averaging period 24-hour (block) period 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 Indurating Furnace. 

The source is subject to BACT under PSD and is therefore not subject to the Minnesota Industrial Process 

Equipment Rule. The source will be equipped with Low NOx burners to control NOx emissions. 

B. Rationale for Selection of Performance Indicators

The NOx measurement by CEM with O2 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 NOx 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 NOx concentrations are measured on a dry basis, stack test data will be used to determine the moisture 

content of the stack for the NOx 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 schedule 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 NOx CEMS, O2 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 commencing the initial performance test as specified in 

Essar Steel’s operating permit. The NOx CEMS will be certified per Minn. R. 7017.1050. Certification 

testing will be done concurrently with the initial performance test. Initial operation of the CEMS will be 

to demonstrate compliance with the interim NOx 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 Essar 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 just 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 that the proposed action was not likely to adversely 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 specifically 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 the time. Both nests are located 0.25 miles from the tailing 

basin and you determined these nesting eagles would not be disturbed by mining, construction, or operating activities. 

 Essar will continue to survey all project construction areas to identify eagle nests and will ensure they will not be 

disturbed. We do recommend that Essar Steel conduct an eagle nest survey within a half-mile of any mining activity and 

within 660-feet of any construction activity prior to any proposed construction. If any bald 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 Environmental Protection Agency Region V’s comment1

 on Essar Steel 

Minnesota LLC’s (Essar) draft Prevention of Significant 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 project 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 impacts analysis as compared to the other cumulative air 

quality impacts analyses is that modeling of ozone impacts is not technically or practically feasible2

 for 

determining an individual source’s contribution to ground-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 Kangas, Essar; Lori Stegink, Barr 

Ozone Formation, Fate and Transport 

Ozone is formed through complex photochemical reactions between NOx, VOC, other non-regulated 

compounds (e.g., OH-

), sunlight, and meteorological conditions of wind speed, wind direction, 

temperature, and humidity. Elevated ozone concentrations occur primarily during stable / stagnant 

atmospheric conditions in urban airsheds.3

 Minnesota generally does not experience long duration 

stagnation periods due to its geographic location and climate. 

Ozone transport can be an important contributor to a region’s ozone concentrations4

, however, due to its 

distance from metropolitan areas and prevailing winds, northern 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 approximately 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 4th 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-highest 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, since other pollutants emitted in urban centers actually 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 Kangas, Essar; Lori Stegink, Barr 

Ozone Precursor Emission Levels 

NOx and VOC emissions are both ozone precursors. NOx emissions are primarily anthropogenic, whereas 

VOCs are emitted both from biogenic and anthropogenic sources. Figure 1 shows the primary emission 

source types for NOx and VOCs in Minnesota.

Figure 1: Minnesota Ozone Precursor Emissions by Source Type6

 

 

6

 Source: MPCA. Air Quality in Minnesota: Emerging Trends. 2009 Report to the Legislature 
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 Kangas, Essar; Lori Stegink, Barr 

Essar Facility NOx 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 NOx 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 project 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 27

. 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 

NOx 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 NOx and VOC emissions relative to statewide emissions, as well as the generally 

uniform ozone concentrations in northern Minnesota 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 website. http://www.pca.state.mn.us/index.php/topics/environmental-data/edaenvironmental-data-access/eda-air-quality-searches/eda-air-quality-search-pollutant-data.html 
Attachment 5 – PM2.5 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: PM2.5 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 PM2.5 Increment results for the Essar Expansion project. Comments 

received from EPA Region 5 requested that a PM2.5 Increment modeling analysis be conducted. 

PM2.5 Increment Method

The modeling analysis uses the PM2.5 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 PM2.5 Increment trigger date was 

October 20, 2011. The nearby PM2.5 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 PM2.5 Increment Results figure. The modeling files and source 

inventory are submitted electronically with this memo. 

PM2.5 Increment Modeling Results 

Table 1 below shows the modeled PM2.5 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: PM2.5 Class I Increment Modeling Results 

PM2.5 Increment 24-Hour High 2nd High Results 

(μg/m3) 

Annual Results

(μg/m3) 

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 modeled results are similar. Figure 1 below shows the 

24-hour PM2.5 modeled results. Figure 2 below shows the Annual PM2.5 modeled results. 
Attachment 6 – PM2.5 Class II Increment 

Technical Memorandum 

To: Ruth Roberson, Minnesota Pollution Control Agency 

From: Jennifer Koenen, Barr Engineering Company 

Subject: PM2.5 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 PM2.5 Increment results for the Essar Expansion project. Comments 

received from EPA Region 5 requested that a PM2.5 Increment modeling analysis be conducted. This 

modeling was performed as a response to that request. 

PM2.5 Increment Method 

Inputs for the modeling analysis use the PM2.5 NAAQS modeling files included with the Essar Expansion 

Air Permit Application. Consistent with the permit application modeling, the 2001-2005 Hibbing 

meteorological data was modeled with AERMOD version 09292. As described in the EPA comments, the 

PM2.5 Increment trigger date to be used was October 20, 2011. Therefore, nearby PM2.5 Increment 

consumers to be used in the modeling analysis include the U. S. Steel Keewatin Expansion. The modeling 

files that include these inputs are submitted electronically and accompany this memo.

PM2.5 Increment Modeling Results 

The modeling results summary table is included below along with the 24-hour PM2.5 Increment Results 

figure. Table 1 below shows the modeled PM2.5 Increment Results are below both the 24-hour and Annual 

Increment standards. 

Table 1: PM2.5 Increment Modeling Results 

PM2.5 Increment 24-Hour High 2nd High Results (ug/m3) Annual Results (ug/m3) 

All (Essar & Keetac Expansion) 7.1 1.3 

Increment 9 4 

% Increment 79% 33% 

The general distribution of the 24-hour and annual modeled results are similar. The 24-hour results, which 

have the higher modeled concentrations, are included to demonstrate the distribution of the modeled 

results. Figure 1 below shows the 24-hour PM2.5 modeled results. 
Attachment 7 – NOx Class II Modeling Update 

Technical Memorandum

To: Ruth Roberson, Minnesota Pollution Control Agency 

From: Jennifer Koenen, Barr Engineering Company 

Subject: 1-Hour NO2 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 NO2 NAAQS results for the Essar Expansion 

project. Comments received from EPA Region 5 requested that a revised 1-hour NO2 NAAQS modeling 

analysis be conducted using the startup/shutdown NOx emission limits for the DRI and Steel Area. This 

modeling was performed as a response to that request. 

Revised 1-Hour NOx Emission Rates 

Table 1 below lists the sources identified as having a NOx startup/shutdown short-term emission limit. 

It also lists the previously submitted model emission rate and the revised emission rate based on the 

startup/shutdown emission limits. Consistent with 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: NOx Modeled Emission Rates 

Stack 

Vent ID 

Emission 

Unit Description 

Submitted 

1-Hour NOx

Startup/Shutdown 

1-Hour NOx

(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 0.1512 

 
To: Ruth Roberson, Minnesota Pollution Control Agency 

From: Jennifer Koenen, Barr Engineering Company 

Subject: 1-Hour NO2 NAAQS Class II Modeling Results 

Date: April 26, 2012 

cc: Joe Henderson, MPCA Trevor Shearen, MPCA Kevin Kangas, Essar Lori Stegink, Barr 

1-Hour NO2 NAAQS Modeling Results 

Table 2 shows the previous maximum modeled 1-hour NAAQS concentration and the new 1-hour NO2

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: NO2 1-Hour NAAQS Modeling Results 

NO2 NAAQS 1-Hour High 8th High 

Submitted Results (μg/m3) 

1-Hour High 8th High 

New Results (μg/m3) 

Cumulative Modeling Results 

w/o Background 138 138 

Cumulative Modeling Results 

w/ 28 μg/m3

 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 School. As part of the meeting a video and audio 

recording was made and individuals were allowed to speak and have comments recorded. Two 

individuals chose to speak and approximate transcripts of their statements are below. Comments were 

taken from their statements and placed in the 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 everybody 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 monitoring 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 zone. 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 across 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 that stockpile, it’s like it’s 

in our back yard. We can’t sit outside in the summertime. 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 like they’re in my back yard. You bought the land across 

the road from me, 800 feet away you bought the house, and then you stopped. 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, Strategic 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 behalf of the Minnesota Center for 

Environmental Advocacy and the Midwest Environmental Defense Center and their 

members. We appreciate the opportunity to provide these comments regarding the 

Essar Steel Minnesota Facility in Nashwauk, 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 that apply after the effective date of 

October 20, 2011. 75 Fed. Reg. 64,864. Since 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 the 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 increment-consuming emissions, will not cause or 

contribute to a violation of the PM2.5 increments."). However, 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 analysis of the facility’s PM2.5 increment 

compliance available to the public for 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 interested persons... to appear and submit 

written or oral presentations on the air quality impact...” Additionally, § 7475(a)(3) 

requires that the facility demonstrate 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 modeling procedures with reasonable particularity” 

in the public notice. 42 U.S.C. § 7475(e)(3)(D). This was not done for any PM2.5 

increment modeling. Therefore, 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 additions to the record are 

“substantial,” the permitting authority must reopen the record in one of three ways: (1) 

by preparing a new draft permit subject to the full public comment process; (2) preparing 

a revised statement of basis and reopening the comment period; or (3) reopening or 

extending the comment period. 40 C.F.R. § 124.14(b). There 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 the record. Merely including 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 follow the procedures in 40 

C.F.R. 52.21(r)(1979), which requires that the increment consumption 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 either site-specific monitoring located in 
3

specific places at the site of the proposed project, or from existing monitors that meet 

specific requirements for location, data quality, and the currentness of the data. For 

example, if data from an existing off-site monitor is used, the monitor must be located in 

the area of maximum concentration increase from the proposed facility, the maximum 

concentration from existing sources, and the area of maximum combined 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 for using off-site monitors for background 

concentrations. 

 The permit at issue here appears to use background data distant from the 

proposed project. (MPCA’s Technical 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 current, 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 concentrations. For example, the PM2.5 background 

concentrations are from Virginia, Minnesota, but reduced by 5%, the NOx 

concentrations are from Cloquet, Minnesota, but reduced by 20%, and the SO2

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 the requirements to use substituted data from 

off-site monitors. If MPCA decides to use substituted data from off-site monitors, it must 

make sure the record is sufficient to demonstrate that those monitor data satisfy the 

applicable requirements in EPA’s Monitoring Guidelines. MPCA must 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 Design Value to A Modeled Design Value 

Does Not Predict the Maximum Impact. 

 It is not clear whether the air quality analysis for this permit improperly combines 

a background and modeled value that are both expressed based on the form of the 

standard (i.e., as a 98th or 99th percentile of modeled or monitored values). Specifically, 

the analysis starts with a background concentration that represents the design value 

based on the form of the standard (i.e., 3-year 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 concentration for any of the pollutants 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 98th percentile monitored value with a 

98th percentile of modeled values does not represent the maximum 98th percentile of 

total impacts and therefore not protective of the NAAQS. Therefore, EPA has cautioned 

that if the 3-year 98th percentile design value is used as background, then the modeled 

concentration used in the cumulative impact analysis should be the average of the 

highest modeled concentration—not the 98th percentile concentration. See e.g., 

Memorandum from Stephen Page, Modeling Procedures for Determining Compliance 

with PM2.5 NAAQS at p. 8 (March 23, 2010). Alternatively, if the modeled result is 

expressed based on the form of the standard (e.g., 98th percentile), then it should be 

added to the single highest monitored value and not the 98th percentile of the monitored 

values. See Memorandum from Anna Marie Wood, EPA OAQPS, General Guidance 

for Implementing the 1-hour NO2 National Ambient Air Quality Standard in Prevention of 

the Significant Deterioration Permits, Including 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 must be included in a new public notice and 

MPCA must provide for a new public comment period. 

Comment 5: Using SILs to Excuse Modeled 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 facility 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 towards a NAAQS violation. There is no lawful 

basis for this. 

Moreover, to the extent that the applicant 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 for a “culpability” analysis was legal, the 

applicant’s analysis is incomplete. In Table 5 of Appendix E of the Application, the 

applicant applies a “SIL” to discount the “Maximum Modeled Concentration.” 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 them in the PSD permit analysis. 

For example, Appendix E, Table 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 analysis 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 those results, and (c) if so, on what basis. If 

any modeled concentrations were ignored based on a culpability analysis, other than 

the maximum modeled concentration, those must be disclosed and the basis for 

ignoring them must also be set forth in the public record. (Again, of course, there is no 

legal or factual basis in the record for ignoring any, including the maximum modeled 

concentration). 

 Thank you for this opportunity to comment 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 does not extend the comment period, we request 

that you send notice of the 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 Commissioner that the MPCA Citizen's Board consider the 

permit matter for Essar Steel Minnesota 

LLC. I am a concerned neighbor to this proposed facility and live only a half mile from the plant on Little 

McCarthy Lake. Currently there is damage to my house from 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 meetings with me regarding the project and that many 

contractors are in court battles with Essar to receive payment 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 hear my case that Essar should not be issued this permit since they do not 

follow through on commitments made to neighbors and hired 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. Henderson: 

We have reviewed the Minnesota 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). The proposed Essar 

project modification encompasses activities covered in the MSI project including mining, ore 

processing, direct reduced iron (DRI) production and steel-making, but will also increase 

taconite pellet production and associated mining and tailings generation rates. The proposed 

project is a major source of emissions of greenhouse gases (GHG), nitrogen oxides (NOx), sulfur 

dioxide (S02), carbon monoxide (CO), volatile organic compounds, fluorides, and particulate 

matter (PM), including PM less than 10 microns in size (PM10) and less than 2.5 microns in size 

(PM2.s). 

In order to ensure that the project meets Federal Clean Air Act (CAA) requirements, that the 

permit will provide necessary information so that the basis for the permit decision is transparent 

and readily accessible to the public, and that the permit record provides adequate support for the 

decision, the U.S. Environmental Protection Agency has the following comments: 

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 national ambient air 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 

precursor under PSD. One of the elements of that rule is a requirement that the PSD 

program regulations 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 quality analysis for each pollutant that a new 

source would have the potential to emit in significant amounts. Since the Essar 

modification project has NOx emissions above this significance threshold for ozone, EPA 

regulations require that the record contain an ozone impact analysis for this source. A 

quantitative modeling 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. 

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 PM2.5 pursuant to the CAA. In the preamble to the 20 I 0 

final rule promulgating the PM2.5 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 PM25 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 PM25 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 PM10 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, Snowball 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 statements which were made are noted in the record. 

Comment 1-1: Commenter does not believe that the decisions 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 air 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 results 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 (MSI) Environmental Impact Statement (EIS) was 

completed in 2007. The three homes mentioned by the commenter are within the ambient air 

boundary and therefore Essar needed to purchase 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 monitoring 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 properly, and scheduled reporting of many monitored 

parameters, exceedances, or deviations. Immediate reporting is also required for certain instances as 

outlined in rule and the facility permit. Records are kept and available during inspections. Deviations 

reports are submitted to the agency and dealt with as needed. 

While the facility is required to perform all the monitoring 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 concerned that his wife has developed asthma and his 

children are breathing the dust every day. He also has concerns that he does not want to wait until 

cancer appears before action is taken. He would like to get help with his concerns now. 

Response: The facility is under construction. On December 2, 2011, a high velocity, shifting wind event 

occurred in the Nashwauk area, which 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 changes to better manage fugitive 

dust. Essar Steel made changes following the event and 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.state.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 and 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 comparisons were also made in consideration of sensitive 

human health endpoints such as asthmatic episodes. The current facility 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 impacts 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. Comments recorded at public

hearing, February 9, 2012.

A video recording of Terry Thompson’s complete statement is part of the permit file. Comments are 

paraphrased and responded to below. Additional statements 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 the 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 noise 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 change in the project for the Essar Steel Minnesota 

Modification project. Therefore, noise 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/environmentalreview/minnsteel/index.html. 

Potential noise exceedances can be reported to the MPCA using the Online Citizen Complaints Form 

(http://www.pca.state.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 construction. On December 2, 2011, a high velocity, shifting wind event 

occurred in the Nashwauk area, which 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 enforcement 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, 2012. The required changes have been implemented. 

Any future fugitive dusting events should be brought 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 paying local contractors in a timely manner is 

important, however it is not something the MPCA 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. 

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 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 air 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 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 commenter’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 electronically February 17, 2012.

Comment 3-1: MPCA must do an analysis of the facility’s compliance with the PM2.5 Increment (Class I and II). 

Response: The permit as placed on public notice January 23, 2012 recognized the need for PM2.5 limits. 

Those limits were used in the modeling to show compliance with the PM2.5 NAAQS as documented in 

the Technical Support Document (TSD). Based on this comment, a PM2.5 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 

PM2.5 Increment modeling and Table 2 provides increment 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 PM2.5 Increment Modeling Results. 

PM2.5 Increment 24-Hour High 2nd High Results (μg/m3) Annual Results (μg/m3) 

All (Essar & Keetac Expansion) 7.1 1.3 

Class II Increment 9 4 

% Increment 79% 33% 

Table 2: Class I PM2.5 Increment Modeling Results. 

PM2.5 Increment 24-Hour High 2nd High Results (μg/m3) Annual Results (μg/m3) 

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 PM2.5 increment compliance available to 

the public for a period of public notice and comment. 

Response: The MPCA has performed an analysis of the facility’s PM2.5 Increment (Class I and II). The 

results of the increment analysis are provided in the response to comment 3-1 and demonstrate 

compliance with PM2.5 Increment standards. Compliance with these standards was demonstrated 

based on the draft permit publically noticed on January 23rd, 2012, therefore no additional permit 

conditions were required to be added. The MPCA's analysis is included in the TSD in sections 3.1.3.1-2. 

The MPCA's analysis of the Facility's PM2.5 Increment compliance is available to the public and the 

permit is subject to an Environmental Appeals Board (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 PM2.5 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 Recommendations. Background concentrations were 

applied to the modeled concentrations conservatively with no temporal or spatial pairing and in 

accordance with the rules and regulations outlined in EPA 40 CFR pt. 51: § 8.2.3 Recommendations 

(Multi-Source Areas) and a March 1, 2011, EPA memo 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 Energy Center, US Steel Keewatin Taconite, United 

Taconite Fairlane, Hibbing Public Utilities, 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 followed 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 temporal or spatial pairing. Typically a regional 

background concentration is developed when there is extensive and explicit modeling of nearby 

sources, this may consist of monitored 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 under the section Combining Modeled Results and 

Monitored Background to Determine Compliance: “Based on these considerations, we believe that a 

less conservative “first tier” for a uniform monitored 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 representative 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 Application, 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 exceedences 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 facility, 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 investigating 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 areas 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 Final Environmental Impact Statement (FEIS) 

(http://www.dnr.state.mn.us/input/environmentalreview/minnsteel/index.html) addressed the 

potential for generation of asbestiform fibers, Section 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, Little 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. Complaints 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 raised 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 the 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 with all rules and permit requirements within their 

current permit as well as those proposed 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, issues 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 Minnesota Statute § 116.02, subdivision 8(2), the MPCA 

commissioner will provide the commenter with a written 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. Letter received electronically 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 national ambient air quality standards. 40 CFR 51.166(K); 

50 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 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 NOx. See 70 CFR 51.166(b)(23)(i). In accordance with 40 CFR 51.166(m)(1)(a), a 

permit application must contain an air quality analysis for each pollutant that a new source would have 

the potential to emit in significant amounts. Since the Essar modification project has NOx emissions 

above this significance threshold for ozone, EPA regulations require that the record contain an ozone 

impact analysis for this source. A quantitative modeling 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 PM2.5 increment analysis. At 75 Fed. Reg. 64864, 

EPA establishes increments for PM2.5 pursuant to the CAA. In the preamble to the 2010 final rule 

promulgating the PM2.5 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 in the date of issuance will occur after the trigger date (October 20, 2011), when the 

PM2.5 increments became effective under the Federal PSD program. Please require Essar to complete a 

PM2.5 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 PM2.5 increment 

analysis conducted for Class I and Class II. The modeled results show impacts below the increment for 

the 24-hour and Annual PM2.5 Increment standard for both Class I and II. 

Comment 6-3: The “Test & Set” provisions for PM2.5 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 PM2.5 emissions. The permit initially establishes Best Available Control Technology 

(BACT) limits for PM2.5 that are equivalent to the PM10 BACT limits. When the PM2.5 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” provisions are mentioned, including the Appendices. 

Response: Appendix E, Section 3.0: First Paragraph changed to: "The application for a major permit 

amendment shall contain an update to the BACT analysis and the proposed PM2.5 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 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. 

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 pressure 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, inspections and monitoring (including pressure drop), records 

of the inspections and monitoring, continuous compliance requirements. 

These requirements are all based on Taconite MACT. This 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 drop, 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 short term basis (i.e. on 

a 1-hour basis). Please revise this averaging period wherever it is appropriate 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, Shutdown, Malfunction (SSM) limits. 

Comment 6-7: P. A-22 contains a requirement for GP 009 emissions units under the Recordkeeping and 

Reporting Section that allows the Permittee to collect 12 months of NOx continuous emission 

monitoring system (CEMS) emissions data that can be submitted to the Commissioner of the MPCA 

who “shall establish a NOx limit and amend this permit to reflect the actual level of emissions”. The 

NOx 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 administrative amendment. 

Response: Language for this requirement was changed to the following: 

"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.” 
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 discussion of the Modeled Class I Increment 

Concentrations (Table 7-3 in Essar’s application) for the 24-hour PM10 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. 

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 modeling done. No changes were made to the permit. 

Comment 6-9: 

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 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, the 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. 

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 

520 Lafayette Road North I St. Paul, Minnesota 55155-4194 I 651-296-6300 

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 Modification Permit 

Dear Mr. Thompson: 

Thank you for 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 (651-201-7204) and complaints concerning mining blasting 

activities should be raised with Julie Jordan at the Minnesota Department of Natural Resources, Lands 

and Minerals (218-231-8457). 

In response to the second of two comments the MPCA would agree with you that following through on 

commitments to neighbors and paying local contractors in a timely manner is important, however it is 

not something the MPCA 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 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 reviewed 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 explanation 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, PM10, PM2.5, Pb, F,

SO2, NOx, 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)