Results ofJuly 12,2005 Performance Tests on the

Step II Agglomerator Line 4 Waste Gas Stack

(SV118) for Particulate Matter, Visible Emissions,

Fluoride, Sulfur Dioxide, Carbon Monoxide, and

Volatile Organic Compounds at the U.S. Steel

Facility Located in Mt. Iron, Minnesota

MPCA AQD File No. 26A

Air Emissions Permit No. 13700005-003/004

Barr Project No. 23/69-927005

Preparedfor

u.s. Steel Corporation - Minnesota Ore Operations

Mt. [ron, Minnesota

August 2005

BARR

Results ofJuly 12, 2005 Performance Tests on the

Step IIAgglomerator Line 4 Waste Gas Stack

(SV118) for Particulate Matter, Visible Emissions,

Fluoride, Sulfur Dioxide, Carbon Monoxide, and

Volatile Organic Compounds at the U.S. Steel

Facility Located in Mt. Iron, Minnesota

MPCA AQD File No. 26A

Air Emissions Permit No. 13700005-003/004

Barr Project No. 23/69-927005

Preparedfor

u.s. Steel Corporation - Minnesota Ore Operations

Mt. Iron, Minnesota

August 2005

BARR

4700 West 77th Street

Minneapolis, MN 55435

Ph••., (952) 832-2600

Fox: (952) 832-2601
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Results of July 12,2005 Performance Test on the Step II

Agglomerator Line 4 Waste Gas Stack (SV118) for Particulate

Matter, Visible Emissions, Fluoride, Sulfur Dioxide, Carbon

Monoxide, and Volatile Organic Compounds at the U.S. Steel

Facility Located in Mt. Iron, Minnesota

Table of Contents

Report Certification iii

Certification of Sampling Procedures: iii

Certification of Analytical Procedures: iii

Certification ofTest Report by Testing Company: iii

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

Executive Surmnary v

Introduction I

Results Surmnary 2

Agglomerator Line 4 (SVI18) 2

Process Description 3

Stack Test Procedures and Methods .4

2369927005
Table I

Table 2

Table 3

Table 4

Figure I

Figure 2

List of Tables

Particulate Test Results - Line 4 Waste Gas Stack (SYI18)

Fluoride Test Results - Line 4 Waste Gas Stack (SYI18)

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

Line 4 Waste Gas Stack (SYI18)

Summary ofData Collected During Stack Testing

List of Figures

Test Port Locations - Step II Line 4 Waste Gas Stack (SYl18)

Traverse Point Locations - Step II Line 4 Waste Gas Stack (SYl18)

List of Appendices

Appendix A

AppendixB

Appendix C

AppendixD

Appendix E

AppendixF

Appendix G

AppendixH

Appendix I

Appendix J

#2369927005

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

Stack Test Plan

Proj ect Participants

ii
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.

Date

1. Testing was not conducted as scheduled during the May mobilization due to process

problems. ./ //./. /

Signature: /~n A'<--C-'~ Tom Kuch(nski

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 of my knowledge and belief, true, accurate, and complete. All exceptions are

listed and explained below.

ichard Berg

Sr. Air Quality Technician

Barr Engineering Co.

Signa

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 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.

Signature:

Tom KuchinSki

Sr. Air Quality Technician

Barr Engineering Co.

#2369927005

iii
Certification of Test Report by Owner or Operator of Emission

Facility:

I certify under penalty of law 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 ofthe person or persons who performed the operational and

maintenance activities, 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.

Signature:

#2369927005

i1

!)l~-Iu'1Ai

Chrissy Bartovich

Environmental Control Engineer

U.S. Steel Corporation/ Minnesota Ore Operations

IV

Date
Executive Summary

Barr Engineering Company performed emissions tests at U.S. Steel Corporation Minnesota Ore

Operations' Step II Agglomerator facility located in Mt. Iron, Minnesota. Tests were performed on

the Line 4 waste gas stack (SVI18) for determination of total particulate matter, particulate matter

less than 10 microns, visible emissions, fluoride, sulfur dioxide, carbon monoxide and total volatile

organic compounds. The purpose ofthe testing was 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 in the test plan.

#2369927005

v
EXECUTIVE SUMMARY TABLE

TESTPARAMETER

EPA Methods 1·5, and 202,

EPA Method 9, Method 6C, Method 10,

Method 13B, Method 25A AVERAGE TESTRESULTS

Test Location Line 4 Waste Gas (SV118)

Test Date 7/12/05

Particulate Concentration, gr/dscf

Dry Catch Only (Filterable) 0.0084

Dry Catch Plus Organic Condensibles 0.0085

Dry Catch Plus Organic Plus Aqueous Phase 0.0173

Condensibies

Particulate Emissions Limit, grldscf 1.3 0.026

Particulate Emissions Rate, Ib/hr

Dry Catch Only (Filterable) 31

Dry Catch Plus Organic Condensibles 31

Dry Plus Organic Plus Aqueous Phase 63

Condensibles

Particulate Emissions Limit, Iblhr 2,3 47

Visible Emissions, % Opacity 0

Visible Emissions Limit, % Opacity 3 <20

Fluoride

Concentration, Ib/dscf 2.9E-08

Emissions Rate, ib/hr 0.78

Sulfur Dioxide

Concentration, ppm 30

Emissions Rate, Ib/MMBtu 0.66

Sulfur Dioxide Emissions Limit, IblMMBtu 3 4

Carbon Monoxide

Concentration, ppm 6.5

Emissions Rate, Ib/hr 13

Volatile Organic Compounds

Concentration, ppm 2.6

VOC Emissions Rate, Ib/hr 3.1

Line 4 waste gas stack meets the total particulate compliance concentration limit determined

from Minn. Rules 7011.0735 Tabie 2. Determinations are made using the sum of filterable and

organic condensibles measured in the stack gas.

2 Total particulate compliance emissions limit calculated from Minn. Rules 7011.0730.

Determinations are made using the sum of fiiterable and organic condensibles measured in the stack

gas.

3 Emissions limits are in Minntac's Title V permit 13700005-003.

#2369927005

VI
Introduction

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

Operations' Agglomerator facilities located in Mt. Iron, Minnesota. The testing was performed on the

Step II Line 4 waste gas stack (SYI18) for the determination of total particulate matter (PM),

particulate matter less than 10 microns (PM]o), visible emissions (YE), fluoride (F), sulfur dioxide

(S02), carbon monoxide (CO) and total volatile organic compounds (YOC).

Source Equipment Permit Permit Green Ball

Type Group Stack Feed Rates

Number Vent LTPH

Number

Line 4 Waste Wet GRP010 SV118 525 to 625

Gas Stack scrubber

The tests were performed to demonstrate compliance with the facility's Minnesota Air Emissions

Permit 1370005-003 and pending Title Y/PSD Permit 1370005-004. The Line 4 testing was

originally scheduled for the week ofMay 16, 2005. The test was rescheduled to July 12 due to

process operation difficulties, tester availability and scheduled down time for the process line. The

MPCA was notified by email about the testing delay. Communications documenting the delay along

with a copy of the March 8, 2005 test plan and MPCA approval letter are located in Appendix I.

Applicable emissions limits for Group 010 Agglomerator Lines 4-5 are determined by Minn. Rule

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

Subp.I(A)(2) for visible emissions under permit 1370005-003.

Tom Kuchinski led the Barr test team. Chrissy Bartovich, Ray Potts 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.

#2369927005

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Results Summary

Results ofthe emissions performance test 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. Emissions of

particulate matter less than 10 microns (PM,o) are determined using the filterable plus organic and

inorganic condensible particulates. The exhaust from the scrubbers is too wet to allow PMl o

determination by Method 201A.

Agglomerator Line 4 (SV118)

Results ofthe Line 4 waste gas stack tests performed on July 12 are presented in Table I for

particulate matter, Table 2 for fluoride and Table 3 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 425,000 dry standard cubic

feet per minute (dscfm), and from Minn. Rules 7011.0730 at the average fired pellet production rate

of 464 long tons per hour (LTPH). Fluoride emissions were 0.78 pounds per hour (lb/hr). Emissions

ofthe gaseous pollutants; sulfur dioxide (S02), carbon monoxide (CO) and volatile organic

compounds (VOe) met the proposed limits in the Title VIPSD permit.

Opacity of visible emissions observations were conducted concurrently with PM test run 1. The

opacity observation results are not summarized because all observations were zero. The opacity data

is included in Appendix B.

Run 1 ofthe fluoride and run 3 ofthe particulate testing were invalidated due to sample problems

which introduced unrepresentative particulate into the sample train. The problem was recognized at

the time of sample collection and a fourth run was performed for each pollutant to replace the

invalidated run. The result of the runs in question are provided in the appendices to demonstrate the

inconsistency ofloading and justification for not including the run in the reported averages.

#2369927005

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, Line 4 waste gas emissions are controlled by wet scrubbers 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 inches of water

column (in. wc.) and scrubber water flow gallons per minute (gpm). Summaries ofthe process

operating data are provided Table 4 and in Appendix H. The kiln was fired on a combination of gas

and wood. The line was producing acid pellets. Fuel analysis data is provided in appendix H.

#2369927005

3
Stack Test Procedures and Methods

Testing was performed from ports meeting USEPA Method 1 criteria. A 24-point traverse was

performed on the Line 4 (SVI18) waste gas stack. The traverses were performed from four ports for

particulate and fluoride measurements. Sample port location and traverse point detail are provided in

Figures 1-2.

Volumetric airflow determinations were performed in accordance with Method 2 using an Svtype

pitot tube. Airflows were determined in conjunction with the Method 5 and Method l3B 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 and Method l3B

performance tests.

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

Particulate concentrations include condensible particulate matter collected in the back half ofthe

sample train. Condensible particulate matter was determined using Method 202. The impinger

contents were purged with nitrogen gas in the field and titrated with ammonia hydorxide 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

adding inorganic condensible particulate to the filterable plus organic particulate. Determination of

opacity of visible emissions was made by Method 9. Opacity reader certification documentation is

provided in Appendix G.

Fluoride emissions were determined by Method l3B 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 l3B airflows.

The USEPA performance test methods cited in this report are found in 40 CFR Part 60, Appendix A,

except for Method 202, which is found in 40 CFR Part 51, Appendix M.

#2369927005

4
Tables

U. S. Steel

Minnesota Ore Operations

Mt. Iron, Minnesota

TABLE 1

PARTICULATE TEST RESULTS

Line 4 Waste Gas Stack (SV118)

Barr Engineering Co.

August 22, 2005

Parameter Run 1 Run 2 Run 4 Averaae

Test Date 7/12/2005 7/12/2005 7/12/2005 ...

Test Period 1000·1109 1155·1305 1925 - 2021 ._-

Test Duration, min. 60 60 45 55

Avg. Stack Temperature, deg.F 125 124 124 124

Avg. Moisture Content, %VN 13.6 13.3 13.6 13.5

Particulate Loading, g

Dry Catch 0.0246 0.0237 0.0174 0.0219

Organic Condensibles 0.0003 0.0001 0.0006 0.0003

Aqueous Phase Condensibles 0.0180 0.0160 0.0299 0.0211

Total 0.0429 0.0398 0.0479 0.0493

Air Flow Rate

acfm 589,000 582,000 557,000 576,000

scfm 502,000 497,000 475,000 491,000

dscfm 433,000 431,000 410,000 425,000

Sample Volume

acf 48.63 48.77 35.43 44.28

dscf 44.42 43.98 32.00 40.13

Isokinetic Variation, % I 101.5 101.1 103.0 101.9

Particulate Concentration, gr/dscf

Dry Catch Only (Filterable) 0.0085 0.0083 0.0084 0.0084

Dry Catch + Organic Condensibles 0.0086 0.0083 0.0087 0.0085

Dry Catch Only + Organic Condensibles + 0.0149 0.0140 0.0231 0.0173

Aqueous Phase Condensibles (Total)

Particulate Emission Rate, Ib/hr

Dry Catch Only (Filterable) 32.0 31.0 30.0 31.0

Dry Catch + Organic Condensibles 32.0 31.0 30.0 31.0

Dry Catch + Organic Condensibles + 55.0 52.0 81.0 62.7

Aqueous Phase Condensibles

Greenball Feed Rate, LTPH 588 584 588 587

Fired Pellet Production Rate, LTPH 465 463 463 464

Total Particulate Emission Rate, Ib/LT Greenball 0.09 0.09 0.14 0.11

Total Particulate Emission Rate, Ib/LT Fired Pellet 0.12 0.11 0.17 0.14

Note: Run 3 omitted due to sampling error.

Note: Run 4 shortened run time due to process upset
U.S. Steel

Minnesota Ore Operations

Mt. Iron, Minnesota

TABLE 2

FLUORIDE TEST RESULTS

Line 4 Waste Gas Stack (SV118)

Barr Engineering Co.

Augus122,2005

Parameter Run 2 Run 3 Run 4 Average

Test Date 7/12/2005 7/12/2005 7/12/2005 -- Test Period 1155·1306 1600 - 1716 1755 - 1905 --- Test Duration, min. 60 60 60 60

Avg. Stack Temperature, deg.F 120 121 119 120

Avg. Moisture Content, %VN 11.9 11.5 11.9 11.7

Fluoride Sample Loading, ug (as F") 408 418 315 380

Air Flow Rate

acfm 594,000 591,000 590,000 592,000

scfm 511,000 508,000 507,000 509,000

dscfm 450,000 449,000 447,000 449,000

Sample Volume

acf 32.66 32.13 32.68 32.49

dscf 29.16 28.67 29.16 29.00

Isokinetic Variation, % 99.6 98.1 100.3 99.3

Fluoride Concentration, Ib/dscf 3.1E-08 3.2E-08 2.4E-08 2.9E-08

Fluoride Emission Rate, Ib/hr 0.83 0.87 0.64 0.78

Greenball Feed Rate, LTPH 584 595 594 591

Fired Pellet Production Rate, LTPH 463 472 471 469

Fluoride Emission Rate, (lb/LT, Green ball Feed) 0.0014 0.0015 0.0011 0.0013

Fluoride Emission Rate, (lb/LT, Fired Pellets) 0.0018 0.0018 0.0014 0.0017

Note: Run 1 omitted due to sampling error
U.S. Steel

Minnesota Ore Operations

Mt. Iron, Minnesota

TABLE 3

Barr Engineering Co.

August 22, 2005

SULFUR DIOXIDE, CARBON MONOXIDE AND VOLATILE ORGANIC COMPOUNDS TEST RESULTS

Line 4 Waste Gas Stack (SV118)

Parameter Run 1 Run 2 Run 3 Averaae

Test Date 7/12/2005 7/12/2005 7/12/2005 --

Test Period 1000-1108 1155-1305 1601-1716 --

Air Flow Rate

ACFM 585,000 594,000 591,000 590,000

SCFM 502,000 511,000 508,000 507,000

DSCFM 440,000 450,000 449,000 446,000

EPA Method 6C Results

S02 Concentration, PPM 33 25 32 30

S02 Emission Rate, Ib/hr 144 111 144 133

S02 Emission Rate, Ib/MMBtu 0.67 0.60 0.70 0.66

EPA Method 10 Results

CO Concentration, PPM 6.2 5.7 7.8 6.5

CO Emission Rate, Ib/hr 11.8 11.1 15.3 12.7

EPA Method 25A Results

VOC Concentration, PPM (wet) as propane 3.9 2.6 1.4 2.6

VOC Emission Rate, Ib/hr as propane 4.4 3.0 1.7 3.0

Heat Input, MMBtu/hr 214 184 206 202
TABLE 4

DATA COLLECTED DURING STACK TESTING

line 4 July 12, 2005

Acid Pellet Production

Waste Gas Stack line 4

Feed Rates Fired Pellet Fuel Data Wet Scrubber

Start End To DrumsITo Grate Production Wood I Gas MBTUH I Total

Run/Pollutant Date Time Time LTPH LTPH LTPH MBTUH I Grate I Kiln I MBTUH DP I GPM

PM - gases 12-Jul 10:00 11:09 588 522 465 90.61 0.00 123.88 214.49 11.09 2985

PM - gases 12-Jul 11:55 13:06 584 520 463 85.83 0.00 98.29 184.12 11.20 2991

PM - gases 12-Jul 16:00 17:16 595 531 472 94.91 0.00 111.38 206.29 11.21 2985

PM 12-Jul 19:25 20:21 588 520 463 93.36 0.00 102.09 195.45 11.00 2987

Fluoride 12-Jul 17:55 19:05 594 529 471 95.22 0.00 95.76 190.98 11.23 2985

Average 590 524 467 90.5 0.0 106.3 201.6 11.15 2987

Based on 10-minute averages that approximately align with the test times.

Note: Gas meter was in error - read 17.67% low. Corrected values are shown
Figures

4 TEST PORTS

@ 90 DEGREES

114.0' ID I

I

34'

o

5' _ - ROOF LINE

_ -+~-=t-- - -

NOT TO SCALE

FAN

- --

i

~52'

TEST PORT LOCATIONS

US STEEL MINNESOTA ORE OPERATIONS

MOUNTAIN IRON, MN

STEP 2 AGGLOMERATOR LINE 4

WASTE GAS STACK (SV118)

FIGURE 1
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•

•

•

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•

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• • • •••

NO. OF TEST PORTS

PORT LENGTH

PORT DIAMETER

NO. OF TRAVERSE POINTS

DUCT DIAMETER

4

22.0"

6.0"

24

168.0"

POINT INSERTION

DEPTH IN ..

1 3.58

2 11.25

3 19.84

4 29.78

5 42.00

6 59.75

NOT TO SCALE

TRAVERSE POINT LOCATIONS

US STEEL MINNESOTA ORE OPERATIONS

MOUNTAIN IRON, MN

STEP 2 AGGLOMERATOR LINE 4

WASTE GAS STACK (SV118)

FIGURE 2
Appendices

Appendix A

Report Calculations and Nomenclature

Calculation Equations - EPA Methods 3A, 6C, 7E, and 10

System bias adjustment on source concentration indicated by the analyzer.

where:

CmA

is the adjusted source concentration, ppm(dry)

is the average concentration indicated by the analyzer, ppm(dry)

is the average of the initial and final system calibration responses of the zero

gas, ppm

is the average ofthe initial and fmal system calibration responses of the upscale

gas, ppm

is the certified concentration ofthe upscale calibration gas, ppm

Convert source concentration into emission rate(lb/br).

C _MWxCppm

(

-!"L)- 24.04

dscm

where:

C(.!"1LJ dscm

MW

24.04

E(lblhr)

6.242xI0-8

Qd

60

amount of compound, by weight(mg), per dry standard cubic meter of air

is the molecular weight of the gaseous compound

where Mw >

64 SO,

46 NO,

28 CO

34 TRS (Assume H,S Molecular Weight)

is the molar volume of gas at 68 OF and 29.92 in Hg, L'g-mole

emissionrate of gaseouscompound inpounds perhour

is the conversion factor from mg/m' to Ib/ft'

flow rate ofdry gas at standard conditions in cubic feet per minute, dscfrn

is the conversion factorfrom minutes to hours

P:\Z AIRSAMPLING\TempJates\Reports\Equations\analyzereq.doc
Emission rate of pounds per MMBtu heat input.

E(lblh')

Heat Input(MMBtu/hr) E(lbl MMBtu) =-----'=='----

Heat Input from operating data summary

P:\ZAIRSAMPLING\Templates\Reports\Equations\analyzereq.doc
Calculation Equations - EPA Method 25A

System bias adjustment on source concentration indicated by the analyzer.

where:

CmA

is the adjusted source concentration, ppm(dry)

is the average concentration indicated by the analyzer, pprn(dry)

is the average ofthe initial and final system calibration responses of the zero

gas, ppm

is the average ofthe initial and fmal system calibration responses of the upscale

gas, ppm

is the certified concentration ofthe upscale calibration gas, ppm

Couvert source concentration into emission rate(lblbr).

C =MWxCppm

(~~) 24.04

EOb1h' ) =(6.242 X 10·8)xC(mg) x60 xQs

.em

where:

C(!!!K) .em

MW

24.04

E(lb/hr)

6.242xlO·8

Qs

60

amount of compound, by weight(mg), per standard cubic meter of air

the molecular weight of carbon (x) the uumber of carbons in calibration gas used

whereMW=

12 carbon

24 ethane

44 propane (C3H8)

is the molar volume of gas at 68 'F and 29.92 in Hg, L'g-mole

emission rate of gaseous compound in pounds per hour

is the conversion factor from mg/nr' to lb/tt'

flow rate of gas at standard conditions in cubic feet per minute, scfin

is the conversion factorfromminutes to hours

P:\ZAIRSAMPLING\Templates\Reports\Equations\analyzereq.doc