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/452/B-02-001, January 2002). Also, to what 

extent would the costs, and $/ton, be lower for a subsequent Low NOX main

burner because much of the engineering/design work on the low NOX burners on Line

6 and 7 would 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, Chrissy Bartovich, Jaclyn 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 spreadsheet. There 

are comments included on the spreadsheet that outline assumptions made and how some of the 

numbers were originated. Typically low NOx burners increase fuel usage by approximately 10% 

in industry. This was initially experienced with the Minntac burners as well. After testing and 

process optimization, the fuel penalty was mitigated on the Line 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 spreadsheet 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 Line 4 or 5 would be comparable to the values provided for Line 6. 

However, there are several items that 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 lines. Step 2 is permitted to burn biomass, gas 

and fuel oil, Step 3 burns these fuels and also coal. The Phase II line at Keetac can utilize 

gas, coal and fuel oil. The Keetac line is also larger than any of the Minntac lines. 

Therefore, the design would not be identical to burners currently 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 system to avoid the safety and 

quality issues initially experienced with the Step 3 burners. Fan lead time has been 

quoted as anywhere from 26-52 weeks depending on the vendor. This can complicate 
United 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. Due to being unable to 

complete testing on Line 6 using biomass, there may be a fuel penalty when using 

biomass with the low NOx burners. If fuel did increase when running biomass, the $/ton 

of NOx removed would also increase.