From: McWilliams, Douglas A. [ mailto:douglas.mcwilliams@squirepb.com ]

Sent: Wednesday, May 27, 2015 3:17 PM

To: Greenberg, Alan (ENRD)

Subject: BART FIP Rulemaking Record CBI Response [I

‐ AMS.FID1382176]

Alan,

This is Cliffs’ response to your three requests for additional information for the rulemaking record as set forth in your May 20,

2015 e

‐ mail.

1) The redacted Metso reports provide the requested information. However, regarding the January 13, 2015 Metso report

(re Tilden), EPA previously requested an explanation of what constitutes the Phase I, Phase II and Phase III studies. EPA

also sought clarification whether only simulations 8 through 11 as part of the Phase III study are relevant and that these

results supersede the earlier simulations.

The Metso work was implemented in three phases. Each phase provided information on a more refined set of

simulations. Phase I was simulations 1

‐ 3, Phase II was simulations 4

‐ 7, and Phase III was simulations 8

‐ 11. As

indicated in the table of simulations on pp 1

‐ 2 of the Metso Phase III report, Phase I established baseline

operating conditions and then simulated the 100 and 115% stoichiometric primary combustion air conditions

introduced with the high stoich LNB option proposed by Coen’s technology for a furnace maintaining the

recoup air temperature. Phase II simulated changes intended to mitigate air flow, temperature and fuel

efficiency disruptions caused by the high stoich LNB technology. Phase III refined the simulations with better

input data. Two new baselines were simulated, one on 100% gas and one with a gas/coal mix, which were

conditions for which we had measured data that could be used to verify and validate the simulation. Metso

then simulated the effect of Coen LNB technology (using updated inputs from Coen) added to these two

baseline simulations. The Phase III simulations supersede the old baseline simulation (1) and the Coen

simulations (2

‐ 7) because Metso introduced new and more refined information from the facility and from

Coen for simulations 8

‐ 11.

2) The redacted versions of the SO2 cost

‐ effectiveness calculations are helpful but the following information must be

provided through removal of redactions: (1) purchase price of controls (2) acfm (3) emission rate and (4) cost of

materials. In addition, either through redactions or through other documents, EPA needs Tilden’s maximum annual

emission rate.

Revised versions of the SO2 Emission Control Cost Analysis for Tilden and United Taconite are attached to

address your request for additional non

‐ confidential information. These documents with their redactions are

released from our claim of confidential business information. The changes are summarized below:

 The SO2 Cost Effectiveness documents include the purchase price of controls in the Tilden Report at p.3

(Table 1), and Appendix A (Tables 1, 3). Purchase price of controls can be found in the United Report

at p.3 (Table 1), and Appendix A (Table 3).

 To address emission rate and flow rate, we removed redactions for inlet gas flow and inlet SO2 in gas

from the Tilden Report and the United Report. See e.g., Tilden Report at p.8 (Table 2) and United

Report at p.8 (Table 3).

 To address cost of materials, we removed redactions for categories of costs. The unit costs (e.g.,

$/Kwh) and the total amount of material to be consumed remain redacted to protect the negotiated

unit cost as confidential business information.

 Tilden’s maximum uncontrolled annual SO2 emission rate (1,153 tons/year) is included in the Tilden

Report at Appendix A, Table 1, Note c.

 The list of edits to the redaction are listed below for each report:

o Utac

 Page 8: Removed redaction from the Inlet Gas Flow and Inlet Gas SO2 figures (Table

3)

 Appendix A, Page 1: Removed redaction from the Standard Flow Rates in the

“Calculation Inputs” table Appendix A, Page 2: Removed redaction from the SO2 emission rates

 Appendix A, Pages 3, 6, 9, 12, 15, 18, 21, 24, 33, 36, 39, 42, 45, 48, 51: Removed

redaction from actual, standardized, and dry flow rate (Tables 3, 4, 5, 6, 7, 8, 9, 10, 15,

16, 17, 18, 19, 20, 21, 22)

 Appendix A, Pages

4,5,7,8,10,11,13,14,16, 17,19,20,22,23,25,26,34,35,37, 38,40,41,43,44,46,47,49,50: Rem

oved redaction from total line item O&M costs (Tables 3, 4, 5, 6, 7, 8, 9, 10, 15, 16, 17,

18, 19, 20, 21, 22)

 Appendix C, Pages 14, 17: Removed redaction from total line item O&M costs (Table

3.2, Table 3.4)

 Appendix E, Page 6: Removed redaction from Inlet Gas Flow and Inlet Gas SO2

o Tilden

 Page 8: Removed redaction from the Inlet Gas Flow and Inlet Gas SO2 figures (Table

2)

 Page 9: Removed redaction of the total flow rate in the first line

 Appendix A, Page 2: Removed redaction from the SO2 emission rates and the air flow

rates in the footnotes (Table 2)

 Appendix A, Pages 3,6,11,14: Removed redaction from actual, standardized, and dry

flow rate (Tables 3,4,7,8)

 Appendix A, Pages 4,5,7,8,10,12,13,15.16: Removed redaction from total line item

O&M costs (Tables 3, 4, 6, 7,8)

 Appendix C, Pages 14,17: Removed redaction from total line item O&M costs (Tables

3.2, 3.4)

 Appendix E, Page 5: Removed redaction from Inlet Gas Flow and Inlet Gas SO2

3) You declined to withdraw your CBI claims associated with the COEN reports, and offered to generate an alternative

source for the information that EPA needs to support the proposed rulemaking. EPA requests that Cliffs submit an

alternative source for the uncontrolled emission rates provided in the COEN reports. Two other components of the

Metso report need independent support. The January 13, 2015 Tilden Metso report states “The purpose of this analysis

(is) to use current operating data and apply it using the latest COEN LNB design conditions required for NOx

reduction.” The August 7, 2014 UTAC Metso report states “Simulation 5 conditions were used to simulate a

stoichiometric primary combustion air rate representing updated COEN LNB technology while trying to unsuccessfully

balance fuel requirements and pellet quality issues.” Cliffs needs to provide some discussion of what constitutes “COEN

LNB design conditions” and “COEN LNB technology.”

We are proposing draft language to provide uncontrolled NOx rates for United and Tilden as well as a

discussion of the Coen LNB technology and associated design conditions. After EPA technical review to

confirm this language provides sufficient support for EPA’s rule

‐ making record, we will provide a formal

alternative source document that EPA can submit into the rule record:

Cliffs hired the John Zink Company LLC (Coen Division) (“Coen”) to conduct a Phase I Engineering Study of the

suitability of its Low NOx Burner (LNB) technology for the Unit 1 Furnace at Tilden Mining and at United

Taconite. Coen LNB technology had been used at the Minntac furnace operated by U. S. Steel to reduce NOx

emissions, so Coen had some experience with piloting LNB technology on “ported kiln” taconite grate kiln

furnaces. Coen found that the ported kiln indurating furnaces differ in many ways from the Tilden and United

applications. “At the previous sites, the solid fuel fired was different, the firing rate was much lower, the kilns

were different and the solid fuel had a substantial amount of natural gas to support in close proximity to the

coal.” The baseline NOx emission rates also varied substantially. The furnace

‐ specific range and baseline NOx

emission rate on natural gas are included in the table below:

Furnace Reported NOx Range Baseline NOx Rate

United Line 2 5.5 to 6.0 lbs/MMBtu 5.5 lbs/MMBtu

Tilden Unit 1 4.0 to 6.0 lbs/MMBtu 5.5 lbs/MMBtuFor Tilden and United, the Coen Engineering Studies cautiously proposed the following:

“The addition of cold combustion air is being proposed to reduce peak flame temperatures and as a

result, lower thermal NOx formation. Usually without some change in the process that may or may

not be possible, the addition of high EA [excess air] will negatively impact kiln efficiency likely

requiring higher fuel usage and higher mass emission rates.”

“To achieve the [NOx] reduction it will be necessary to displace the high secondary air temperature

and substitute cold air in the burner zone to dilute the flame.”

“The addition of EA and displaced hot air will also result in reduced flame radiation and potential

thermal efficiency losses as well that could create production issues.”

“Reduction in flame temperature will reduce peak radiation from flame to product in the main flame

zone. This reduction could range from 50 to 70% and will likely shift the radiant load further away

from the kiln product exit. The impact on kiln operation needs to be carefully evaluated. The kiln

process needs to be simulated to determine the impact on production.“

Metso Engineering conducted the simulations of the kiln process to determine potential impacts on pellet

quality, fuel efficiency, and mass emission rates when using the Coen technology at Tilden and United

furnaces. The Coen LNB technology would substantially increase the range of excess air from 10

‐ 15% baseline

stoichiometric ratio at the existing burners to the 100

‐ 115% stoichiometric ratio design condition for the Coen

burners. This increase in cool air must be balanced to avoid pressure increases in the furnace that can damage

pellets and create unsafe conditions. The cool air also requires a corresponding increase in Btus of fuel to

maintain furnace temperature. The Metso simulations are included in the record and explained in the August

8, 2014 correspondence from Squire Patton Boggs to Alan Greenberg and Matthew Marks.

Please call me to discuss.

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the co rrect file and location. Douglas A. McWilliams

Partner

Squire Patton Boggs (US) LLP

4900 Key Tower

127 Public Square

Cleveland, Ohio 44114

T +1 216 479 8332

O +1 216 479 8500

F +1 216 479 8780

M +1 216 407 4968

Douglas.McWilliams@squirepb.com | squirepattonboggs.com



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