United States Steel Corporation

– Minntac

Response to U. S. EPA Section 114 Request April 24, 2012

**Item 17** What is the Total Capital Investment, the Total Annual Cost (including Total Indirect Annual Cost and Direct Annual Cost), annual emission reduction, and average cost effectiveness ($/ton)? Total Capital Cost and Total Annual Cost are as defined in EPA's Air Pollution Control Cost Manual (EPA/45 2/B

- 02

- 001, January 2002). Also, to what extent would the costs, and $/ton, be lower for a subsequent Low NO X main burner because much of the engineering/design work on the low NO X burners on Line 6 and 7 wo uld not need to be repeated? **Person(s) that provided information used or considered in responding to the question , or**  **consulted in preparation of the response :**  Rob Wilmunen, Darren Gietzen (Hatch Engineering), Mike Dzurinko, Victoria Morton, Stephani Campbell, Teresa Simetkosky , Chriss y Bartovich, Jacly n Brooks, Richard Deloria
**Answer:** The total capital investment, total annual cost, annual emission reduction, and average cost effectiveness for the Line 6 low NOx main burner is detailed in the attached s preadsheet. There are comments included on the spreadsheet that outline assumptions made and how some of the numbers were originated. Ty pically low NOx burners increase fuel usage by approximately

10% in industry

. This was initially experienced with the Minntac burners as well. After tes ting and process optimization, the fuel penalt y was mitigated on the Li ne 6 low NOx main burner when running natural gas or a combination of natural gas and coal. Therefore, a fuel penalty was not included in the spread sheet as an annual cost

. As for the change in costs when installing future burners, the capital costs to procure and install a low NOx main burner on L ine 4 or 5 would be comparable to the values provided for Line 6. However, there are several items th at will need to be considered with additional burners. The items include, but may

not be limited to, the following:

 Engineering: The fuels utilized by the Step 2 lines, and by

the Keetac Phase II line, are different than that of the Minntac Step 3 lin es. Step 2 is permitted to burn biomass, gas and fuel oil, Step 3 burns th e se fuels and also coal. The Phase II line at Keetac can utilize gas, coal and fuel oil. Th e Keetac line is also larger than an y of the Minntac lines. Therefore, the design would not be identical to burners currentl y installed and additional design engineering would need to be completed. Also, a location for the combustion air fans would need identified and a possible addition would need to be put on the building to accommodate the fans.

 Fan sizing/lead time: Detailed engineering would indicate if new fans were needed in order to remove the additional combustion air from the sy stem to avoid the safet y and quality issues initially

experienced with the Step 3 burners. Fan lead t ime has been quoted as an ywh ere from 26

- 52 weeks depending on the vendor. This can complicateUnited States Steel Corporation

– Minntac

Response to U. S. EPA Section 114 Request April 24, 2012 installation schedules when trying to coordinate with major production outages

.

 Troubleshooting: As seen with the Step 3 burners, a significant amount of plant personnel time was dedicated to the start up and optimization of the burners. This includes the work conducted to alleviate the fuel penalty

. D ue to being unable to complete testing on Line 6 using biomass, there may be a fuel penalt y when using biomass with the low NOx burners. If fuel did increase when running biomass , the $/ton of NOx removed would also increase.