# Results of May 17-18, 

# 2005 Performance Tests on the Step IAgglomeratorLine 3 

# Waste GasStack (SV103) andStep IIAgglomeratorLine 5 

# Waste GasStack (SV127)for ParticulateMatter and Visible Emissions, Fluorides, SulfurDioxide, Carbon Monoxide, and Volatile Organic Compounds at the U.S. SteelFacilityLocatedin Mountain Iron, Minnesota MPCA AQD File No. 26A AirEmissions PermitNo. 13

## 700005-003/004 BarrProjectNo. 23/69-927003 Prepared for 

# u.s. Steel Corporation

- Minnesota Ore Operations Mountain Iron, Minnesota July 2005



# BARR

# Results of May 17-18,2005Performance Tests on the Step IAgglomeratorLine 3 

# Waste GasStack (SV103) andStep IIAgglomeratorLine 5 

# Waste GasStack (SV127)forParticulate Matter and Visible Emissions, Fluorides, SulfurDioxide, Carbon Monoxide, and Volatile Organic Compounds at the U.S. SteelFacility Locatedin Mountain Iron, Minnesota MPCA AQD File No. 26A AirEmissions PermitNo. 13700005-003/004 BarrProjectNo. 23/69-927003 Prepared for 

# u.s. Steel Corporation

- Minnesota Ore Operations Mountain Iron, Minnesota July 2005



# BARR 4700 West 77th Street Minneapolis, MN55435 Phon., (952) 832-2600 Fax' (952) 832-2601

### Results of May 17-18, 2005 Performance Tests on the Step I Agglomerator Line 3 Waste Gas Stack (SV103) and Step II Agglomerator Line 5 Waste Gas Stack (SV127) for Particulate Matter and Visible Emissions, Fluorides, Sulfur Dioxide, Carbon Monoxide,

and Volatile Organic Compounds at the U.S. Steel Facility Located in Mountain Iron, Minnesota Table of Contents Report Certification iii Certification ofSampling Procedures: iii Certification ofAnalyticalProcedures: iii Certification ofTestReportby Testing Company: iv Certification ofTestReportby Owner or Operator ofEmission Facility: .iv Executive Summary '" '" v Introduction .i Results Summary 1 AgglomeratorLine 3 (SYI03) 1 AgglomeratorLine 5 (SYI27) 2 Process Description 3 Stack TestProcedures and Methods .4

2369927003Table I Table 2
Table 3 Table 4 Table 5 Table 6 Table 7
Table 8
Table 9

Figure I Figure 2 Figure 3 Figure 4 List of Tables Particulate Test Results - Line 3 Waste Gas Stack (SVI03) Visual Determination ofOpacity ofEmissions Results - Line 3 Waste Gas Stack (SVI03) PM IO Test Results- Line 3 Waste Gas Stack (SVI03) Particulate Test Results - Line 5 Waste Gas Stack (SVI27) Fluoride Test Results - Line 3 Waste Gas Stack (SVI03) Fluoride Test Results - Line 5 Waste Gas Stack (SVI27) Sulfur Dioxide, Carbon Monoxide, and Volatile Organic Compounds Test Results - Line 3 Waste Gas Stack (SVI03) Sulfur Dioxide, Carbon Monoxide, and Volatile Organic Compounds Test Results - Line 5 Waste Gas Stack (SVI27) Summary ofProcess Data Collected During Stack Testing

- Agglomerator Line 3 and Line 5 -May 17 & 18, 2005 List of Figures Test PortLocations - Step II Line 3 Waste Gas Stack (SVI03) Traverse Point Locations - Step II Line 3 Waste Gas Stack (SV I03) Test Port Locations - Step II Line 5 Waste Gas Stack (SVI27) Traverse Point Locations - Step II Line 5 Waste Gas Stack (SVI27)
List of Appendices Appendix A AppendixB Appendix C AppendixD Appendix E Appendix F Appendix G AppendixH Appendix I Appendix 

### J

#2369927003 Report Calculations and Nomenclature Field Data Sheets Laboratory Reports and Sample Chain ofCustody Instrument Output Calibration Data Cylinder Gas Certifications Visible Emissions Evaluator Certifications Process Operating Data StackTestPlan Project Participants

iiDate 

# Report Certification
Certification of Sampling Procedures: I certify underpenalty oflaw that the sampling procedures were performedin accordance with the approved test plan and that the data presented in this testreport are, to the best of my knowledge and belief, true, accurate, and complete. All exceptions are listed and explained below. 1. SV1l8, the Line 4 waste gas stack, could notbe tested because ofaprocess upset. 2. Sample volume oftwo Line 3 PM IO test runs are slightly below 32 dscf. 

# :,,:::0':2'"'**~"do ~,,,,,,,blo**  limits 

# <»:;'" oSTom KuchinSki Date Sr. Air Quality Technician Barr Engineering Co. 

## Certification of Analytical Procedures: I certify underpenalty oflaw that the analytical procedures were performed in accordance with the requirements ofthe test methods and that the data presented for use in the test report were, to the best ofmy knowledge and belief, true, accurate, and complete. All exceptions are listed and explainedbelow. 1. Laboratory analysis for fluorides was performedby Oxford Laboratories. A signed lab report is provided.**/~--)I** 

# c/( .: Signature: Richard Berg Sr. Air Quality Technician Barr Engineering Co.

#2369927003
111

### Certification of Test Report by Testing Company: I certify under penalty oflaw that this test report and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the test information submitted. Based on my inquiry ofthe person or persons who performed sampling and analysis relating to the performance test, the information submitted in this test report is, to the best ofmy knowledge and belief, true, accurate, and complete. All exceptions are listed and explainedbelow.

# /y'/~~ Signature:

## ~~**G~"36-** u5 Tom Kuchinski Date Sf. Air Quality Technician Barr Engineering Co. 

### Certification of Test Report by Owner or Operator of Emission Facility: I certify under penalty oflaw that the information submitted in this test report accurately reflects the operating conditions at the emission facility during this performance test and describes the date and nature ofall operational and maintenance activities that were performed on the process and control equipment during the month prior to the performance test. Based on my inquiry ofthe person or persons who performed the operational and maintenance activities, the information submitted in this test report is, to the best of my knowledge and belief, true, accurate, and complete. All exceptions are listed and explained below.
Signature:

#2369927003 Chrissy Bartovich Environmental Control Engineer U.S. Steel Corporation! Minnesota Ore Operations

!v Date

# Executive Summary

Barr Engineering Company performed emissions tests on two stacks at U.S. Steel Corporation Minnesota Ore Operations' Step I and II Agglomerator facility located in Mountain Iron, Minnesota. Tests were performed for determination oftotal particulate matter, particulate matter less than 10 microns, visible emissions, fluoride, sulfur dioxide, carbon monoxide and total volatile organic compounds to satisfy requirements ofU.S. Steel's MinnesotaAir Emissions Permit 13700005-003 and pending Permit 13700005-004.
Test dates, results and emissions limits are presented in the Executive Summary Table. Process rates for all tests were within the process rates set out in the test plan. The lines were tested while producing acid pellets. The furnaces were fired with a combination ofbiomass andnatural gas.
EXECUTIVE SUMMARY TABLE TEST PARAMETER EPA Methods 1-5, 201A and 202, EPA Method 9, Method 6C, Method 10, Method 13B, Method 25A AVERAGE TEST RESULTS Line 3 Line 5 Test Location Waste Gas Waste Gas (SV103) (SV127) Test Date 5/17/05 5/18/05 Particulate Concentration (PM), gr/dscf Dry Catch Only (Filterable) 0.76 0.023 Dry Catch Plus Organic Condensibles 0.76 0.024 Dry Catch Plus Organic Plus Aqueous Phase 0.78 0.029 Condensibles Particulate Emissions Limit, gr/dscf 1


### - 0.026 Particulate Emissions Rate (PM), Ib/hr Dry Catch Only (Filterable) 1580 84 Dry Catch Plus Organic Condenslbles 1580 86 Dry Plus Organic Plus Aqueous Phase 1620 107 Condensibles Particulate Emissions Limit, /b/hr 2 

### - 47 Particulate Less Than 10 Microns (PM,,), Concentration, gr/dscf 0.13

- Emissions Rate, Ib/hr 273



### -

#2369927003

vTEST PARAMETER EPA Methods 1-5, 201A and 202, EPA Method 9, Method 6C, Method 10, Method 138, Method 25A AVERAGE TEST RESULTS Line 3 Line 5 Test Location Waste Gas Waste Gas (SV103) (SV127) Test Date 5/17/05 5/18/05 Visible Emissions, % Opacity 33 0 Visible Emissions Limit, % Opacity 3,4 <40 <20 Fluoride Concentration, Ibldscf 1,6E-06 5AE-8 Emissions Rate, Iblhr 22 1.3 Sulfur Dioxide Concentration, ppm 55 23 Emissions Rate, Ib/MMBtu 1.02 0.35 Carbon Monoxide Concentration, ppm 13 9 Emissions Rate, Iblhr 13 16 Volatile Organic Compounds Concentration, ppm 2,1 2,1 

### vac Emissions Rate, Iblhr 1.3 2,2
Total particulate compliance concentration limit determined from Minn. Rules 7011.0735 Table 2. Determinations are made using the sum of filterable and organic. Line 3 is not evaluated because of pending scrubber installation. 2 Total particulate compliance emissions limit calculated from Minn. Rules 7011.0730. Determinations are made using the sum of filterable and organic condensibles. Line 3 is not evaluated because of pending scrubber installation. 3 Emissions limits are in Minntac's Title V permit 13700005-003, 4 Line 5 visible emissions were observed on June 10, 2005.

#2369927003
V1

# Introduction

Barr Engineering Co. performed emissions tests at U.S. Steel Corporation

- Minnesota Ore Operations' Agglomerator facilities located in Mountain Iron, Minnesota. Tests were conducted on the Agglomerator Step I and Step II waste gas stacks listed below for the determination oftotal particulate matter (PM), particulate matter less than 10 microns (PM lO) , visible emissions (YE), fluoride (F), sulfur dioxide (S02), carbon monoxide (CO) and total volatile organic compounds (YOC). The stacks are listed below, along with pertinentinformation from the test plan.
Source Equipment Permit Permit Green Ball Type Group Stack Feed Rate Number Vent Range Number LTPH Step I Line 3 Wet GRP009 SV103 280 to 350 Waste Gas Stack scrubber Step II Line 5 Wet GRP010 SV127 525 to 625 Waste Gas Stack scrubber

The tests were performedto demonstrate compliance with the facility's Minnesota Air Emissions Permit 1370005-003 and to provide baseline data for the pending Title Y/PSD Permit 1370005-004. A test plan dated April 15,2005 was submittedto the MinnesotaPollution Control Agency. The test plan was reviewed at apretestmeeting held on May II. The test plan and the approval letter dated May 11, 2005 from Andy Place ofthe MPCA areprovidedin Appendix 1. Line 4 testing was postponedbecause ofdifficulties in operating the line. Chrissy Bartovichnotified the MPCA of the postponement in an e-mail on May 19. That e-mail and the response from Andy Place are also provided in Appendix 1. Applicable emissions limits for Group 010 Agglomerator Line 5 are determinedby Minn. Rule 7011.0610 Subp.l(A)(I) for particulate matter concentration and Minn. Rule 7011.0610 Subp.l(A)(2) for visible emissions underpermit 1370005-003. Since the issuance of air emissions permit 1370005, Minntac has demonstrated compliance ofGroup 009 Agglomerator Line 3 stack (SYI03) using the 85% collection efficiency rule described in Minn. Rule 7011.0710, subp. 3. Because the purpose of this testing was to provide baseline data for permit 1370005-004, data to determine the collection efficiency was not gathered and, as aresult, no determination ofcompliance can be made from the testing.

2369927003The tests were performed during acid pellets production at both lines. The furnaces were fired on a combination ofbiomass and natural gas. Tom Kuchinski led the Barr test team. Chrissy Bartovich and Ron Braski ofU.S. Steel provided test coordination with facility operations. The performance tests were not witnessed by the MPCA. A list ofproject participants is provided in Appendix J.

#2369927003

11

# Results Summary

Results ofthe emissions performance tests are summarized in the Executive Summary Tables. The particulate emissions results arepresented for filterable particulate emissions, filterable plus organic particulate emissions, and total particulate emissions-filterable, organic condensibles, and inorganic condensibles. Filterable plus organic particulate emissions results are used when determining compliance with the particulate emissions (PM) limitin the Minnesota Rules. 

## Agglomerator Line 3 (SV103) Results of the Line 3 waste gas stack tests performed on May 17 and May 18 arepresentedin Table 1 for particulate matter (PM), Table 2 for opacity ofvisible emissions, Table 3 for particulate matter less than 10 microns (PMlO) , Table 4 for fluoride, and Table 6 for gaseous pollutants. Emissions limits are omitted from the reportbecause the latest draft of the pending PSD permit does notrequire initial performance testing ofSV103 until after installation of the wet scrubber.
Fluoride emissions test runs coincided with the PM test runs. Opacity ofvisible emissions observations were conducted concurrently with PM test run 1. The highest average 6-minute period opacity was 33%. This result meets the 40% adjusted opacity limit applied for by U. S. Steel.
Gaseous pollutanttest runs coincided with PM test runs 2 and 3, and PM 10 test run 1. Loss ofpower during run 1 preventedpost test calibrations ofthe gaseous pollutant analyzers, so the gaseous pollutanttest run had to be repeated. The loss ofpower also resulted in a 25 minute delay ofthe PM and fluoride tests which were completed when power was restored. A 45 minute process upset interrupted testing 35 minutes into PM test run 3 (gaseous pollutanttest run 2). The run was continuedto completion when the line was restarted. The PMlO test run 1 was performed in the evening on May 17 and the remaining two runs were conducted in the morning of May 18, within the 24-hourtime period.
The first attempt at PMlO test run 1 was aborted due to a process upset (fines to the grate). Sample volumes for PMlO test runs 2 and 3 were slightly below the required 32 dscf. Field observation of the less than 10 micron catch showed significant loading such that a slightly low sample volume would not compromise the detection limit.

#2369927003 1

### Agglomerator Line 5 (SV127) Results ofthe Line 5 waste gas stacktests performed on May 18 are presented in Table 4 for particulate matter, Table 6 for fluoride and Table 8 for gaseous pollutants. The stackcomplies with the Minn. Rules 7011.0715 Subp. I(A) for particulate matter emissions. Emissions limits were determined from Minn. Rules 7011.0735 at an average airflow rate of426,000 dscfm, and from Minn. Rules 7011.0730 at the average fired pelletproductionrate of485 LTPH. PM emissions met the limit for PM concentration. Emissions ofparticulate matter less than 10 microns (PM IO) are determined using the filterable plus organic and inorganic condensible particulates. The exhaust from this scrubber is too wet to allow PM IO determination by EPA Method 20 IA. PM, fluoride and gaseous pollutant emissions tests runs were conducted concurrently for all runs on Line 5. A low isokinetic variation outcome (86.8%) occurred on the Method l3B fluoride test run I because offilterplugging. The problem was remedied by changing nozzles before the start ofrun 2 resulting in a smaller sample volume so that plugging did not occur and isokinetic sampling couldbe maintained. All samples were above the laboratory detection limit. The result for test run I is the mid range value for the three runs. The average result for the three runs is 1.32 Ib/hr compared to 1.36 Ib/hr for runs 2 and 3.
Visible emissions observations were postponed because ofrain. The visible emissions tests were conducted on June 10,2005. The run was terminated at 45 

### Yz minutes when the line experienced an upset and it was determined that the situation could not be resolved in a timely manner. The opacity observationresults are not summarizedbecause all observations were zero. The opacity data is included in Appendix B.
Table 9 provides information on the Agglomerator process rates and control equipment operating parameters collected during all tests.

#2369927003 2

# Process Description

The Agglomerator grate-kiln systems consist offour primary components; the dryer, preheat furnace, kiln and cooler. Green pellets from the balling drums enterthe grate, supported by a slotted grate. The grate is divided into three sections: two for drying and one for preheating the pellets. Hot process gases are passed through the bed ofgreen pellets on the grate in order to first dry and then preheatthem. The grate then transports the pellets into the rotary kiln. In the kiln the pellets are tumbled and indurated (heathardened) by heating them to 2450 OF. The pellets are then discharged into an annular cooler with slotted traveling pallets. Ambient air is passed through the bed ofpellets in the cooler to cool the pellets and recover heat.
The waste gas stacks are controlled for particulates by intermediate drop-out boxes, impingement plates, and cyclones. In addition, the Line 5 stackis controlled by a wet scrubber for particulate emissions. Sampling was performed at the rooflevel and after all control equipment. Operating parameters were recorded for each test run. The parameters included fuel usage, green pelletfeed rate (LTPH), fired pelletproduction rate (LTPH), scrubberpressure drop (in H20 ) and scrubber water flow (gpm), Summaries ofthe process operating data are provided Table 9 and in Appendix H. Fuel analysis data for wood are also provided in Appendix H.

#2369927003 3

# Stack Test Procedures and Methods
Testing was performed from ports meeting USEPA Method 1 criteria. A 12-point traverse was performed from two ports on the Line 3 (SVI03) waste gas stack and a 24-pointtraverse was performed from four ports on the Line 5 (SVI27) waste gas stack. The traverses were performed on each stack for particulate and fluoride measurements. Historical measurements were referenced for cyclonic flow. Sample port location and traverse point detail are provided in Figures 1-4.
Volumetric airflow determinations were performed in accordance with Method 2 using an S-type pitot tube. Airflows were determined in conjunction with the Method 5 and Method 13B performance tests. Stack gas compositions were determinedby Method 3A. Stack gas moisture content was determined by the performance ofEPA Method 4, in conjunction with the Method 5, Method 20lA and Method 13B performance tests. Particulate concentrations and emissionrates were determined in accordance with Method 5 for both stacks. Particulate concentrations include condensible particulate matter collected in the back halfof the sample train. Condensible particulate matter was determined using Method 202. The impinger contents were purged with nitrogen gas in the field and titrated in the lab to neutralize acids. Minnesota total particulate matter (PM) was determined from the sum offilterable and condensible organic particulate. Particulate matter less than 10 microns (PM lO) was determined by Method 20lA for Line 3 and by adding inorganic condensible particulate to the filterable plus organic particulate for Line 5. Determination ofopacity ofvisible emissions was made by Method 9.
Fluoride emissions were determined by Method 13B with filtration occurring after the liquid condensation.
Gaseous pollutant emissions were determinedby Method 6C for sulfur dioxide, Method 10 for carbon monoxide, and Method 25A for volatile organic compounds. Gaseous emissions rates were determined in conjunction with Method 13B airflows. Methane calibrations standards were used to calibrate the hydrocarbon analyzer. Hydrocarbon results are reported as propane. The USEPA performance test methods cited in this report are found in 40 CFRPart 60, Appendix A, except for Method 201A and Method 202, which are found in 40 CFR Part 51, Appendix M.

#2369927003 4

# Tables