Results ofMay 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

MPCA AQD File No. 26A

Air Emissions Permit No. 13700005-003/004

Barr Project No. 23/69-927003

Preparedfor

u.s. Steel Corporation - Minnesota Ore Operations

Mountain Iron, Minnesota

July 2005

BARR

Results ofMay 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

MPCA AQD File No. 26A

Air Emissions Permit No. 13700005-003/004

Barr Project No. 23/69-927003

Preparedfor

u.s. Steel Corporation - Minnesota Ore Operations

Mountain Iron, Minnesota

July 2005

BARR

4700 West 77th Street

Minneapolis, MN 55435

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 of Sampling Procedures: iii

Certification of Analytical Procedures: iii

Certification ofTest Report by Testing Company: iv

Certification ofTest Report by Owner or Operator ofEmission Facility: .iv

Executive Summary '" '" v

Introduction .i

Results Summary 1

Agglomerator Line 3 (SYI03) 1

Agglomerator Line 5 (SYI27) 2

Process Description 3

Stack Test Procedures and Methods .4

2369927003
Table 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 of Opacity of Emissions Results - Line 3 Waste Gas Stack

(SVI03)

PMIO 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 (SVI 03)

Sulfur Dioxide, Carbon Monoxide, and Volatile Organic Compounds Test Results -

Line 5 Waste Gas Stack (SVI27)

Summary of Process Data Collected During Stack Testing - Agglomerator Line 3 and

Line 5 -May 17 & 18, 2005

List of Figures

Test Port Locations - 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

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Report Calculations and Nomenclature

Field Data Sheets

Laboratory Reports and Sample Chain of Custody

Instrument Output

Calibration Data

Cylinder Gas Certifications

Visible Emissions Evaluator Certifications

Process Operating Data

Stack Test Plan

Project Participants

ii
Date

Report Certification

Certification of Sampling Procedures:

I certify under penalty oflaw that the sampling procedures were performed in accordance

with the approved test plan and that the data presented in this test report 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 not be tested because of a process upset.

2. Sample volume of two Line 3 PMIO 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 under penalty 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 explained below.

1. Laboratory analysis for fluorides was performed by Oxford Laboratories. A signed lab

report is provided.

/~--)I c/( .:

Signature:

Richard Berg

Sr. Air Quality Technician

Barr Engineering Co.

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111
Certification of Test Report by Testing Company:

I certify under penalty of law 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 of the 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 explained below.

/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 of all 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 of the 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 of U.S. Steel's Minnesota Air 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 of biomass and natural 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 -

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v
TEST 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.

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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 (PMlO) , visible emissions (YE),

fluoride (F), sulfur dioxide (S02), carbon monoxide (CO) and total volatile organic compounds

(YOC). The stacks are listed below, along with pertinent information 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 performed to 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 submitted to the Minnesota Pollution Control Agency. The test

plan was reviewed at a pretest meeting held on May II. The test plan and the approval letter dated

May 11, 2005 from Andy Place ofthe MPCA are provided in Appendix 1. Line 4 testing was

postponed because of difficulties in operating the line. Chrissy Bartovich notified 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 determined by Minn. Rule

7011.0610 Subp.l (A)(I) for particulate matter concentration and Minn. Rule 7011.0610

Subp.l(A)(2) for visible emissions under permit 1370005-003. Since the issuance of air emissions

permit 1370005, Minntac has demonstrated compliance of Group 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 a result, no determination of compliance

can be made from the testing.

2369927003
The tests were performed during acid pellets production at both lines. The furnaces were fired on a

combination of biomass and natural gas.

Tom Kuchinski led the Barr test team. Chrissy Bartovich and Ron Braski of U.S. Steel provided test

coordination with facility operations. The performance tests were not witnessed by the MPCA. A list

of project participants is provided in Appendix J.

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11
Results Summary

Results ofthe emissions performance tests are summarized in the Executive Summary Tables. The

particulate emissions results are presented 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) limit in the Minnesota Rules.

Agglomerator Line 3 (SV103)

Results of the Line 3 waste gas stack tests performed on May 17 and May 18 are presented in Table 1

for particulate matter (PM), Table 2 for opacity of visible 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 report because the latest draft of the pending PSD permit does not require

initial performance testing of SV103 until after installation of the wet scrubber.

Fluoride emissions test runs coincided with the PM test runs. Opacity of visible 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 pollutant test runs coincided with PM test runs 2 and 3, and PM10 test run 1. Loss of power

during run 1 prevented post test calibrations of the gaseous pollutant analyzers, so the gaseous

pollutant test run had to be repeated. The loss ofpower also resulted in a 25 minute delay of the 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 pollutant test run 2). The run was

continued to 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-hour time 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.

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1
Agglomerator Line 5 (SV127)

Results of the Line 5 waste gas stack tests performed on May 18 are presented in Table 4 for

particulate matter, Table 6 for fluoride and Table 8 for gaseous pollutants. The stack complies 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 of 426,000 dscfm, and from

Minn. Rules 7011.0730 at the average fired pellet production rate of 485 LTPH. PM emissions met

the limit for PM concentration. Emissions of particulate matter less than 10 microns (PMIO) 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 offilter plugging. The problem was remedied by changing nozzles before the start of run 2

resulting in a smaller sample volume so that plugging did not occur and isokinetic sampling could be

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

observation results are not summarized because 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.

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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 enter the 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 of green pellets on the grate in order to first dry and then

preheat them. The grate then transports the pellets into the rotary kiln. In the kiln the pellets are

tumbled and indurated (heat hardened) 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 of pellets

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 stack is controlled by a wet scrubber for particulate

emissions. Sampling was performed at the roof level and after all control equipment.

Operating parameters were recorded for each test run. The parameters included fuel usage, green

pellet feed rate (LTPH), fired pellet production rate (LTPH), scrubber pressure 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.

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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-point traverse 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 determined by Method 3A. Stack gas moisture content was determined

by the performance of EPA Method 4, in conjunction with the Method 5, Method 20lA and Method

13B performance tests.

Particulate concentrations and emission rates were determined in accordance with Method 5 for both

stacks. Particulate concentrations include condensible particulate matter collected in the back half of

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 of filterable and condensible

organic particulate. Particulate matter less than 10 microns (PMlO) was determined by Method 20lA

for Line 3 and by adding inorganic condensible particulate to the filterable plus organic particulate for

Line 5. Determination of opacity of visible emissions was made by Method 9.

Fluoride emissions were determined by Method 13B with filtration occurring after the liquid

condensation.

Gaseous pollutant emissions were determined by 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 CFR Part 60, Appendix A,

except for Method 201A and Method 202, which are found in 40 CFR Part 51, Appendix M.

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4
Tables