May 4, 2012 

VIA FEDERAL EXPRESS 

Attn: Compliance Tracker, AE-17J 

lo)!E ©~ow ~rm 0:~ lffi MAY 0 7 2012 l.!lJ ,;_J -- AIR ENFORCEMENT 

U.S. EPA REGION 

BRANCH 

5 ~ 

CUFFS NATURAL RESOURCES 

Nocthsho:e Minong Company 

10 Outo:o Drive, Silver Bay, ~ 55614 

CLIFFS 

P 8.226.~ 125 F 21S.22o.6037 cl ffsnatural!asources.com 

Air Enforcement and Compliance Assurance Branch 

U.S. Environmental Protection Agency 

Region 5 

77 W. Jackson Boulevard 

Chicago, Illinois 60604 

Re: Request to North shore Mining-Silver Bay, for Information Pursuant to Clean Air Act Section 114 

Dear Mr. Czerniak: 

This letter and the enclosed information are the response of Northshore Mining- Silver Bay (referred to 

herein as "NSM" or "Northshore") to Appendix C of the U.S. EPA Region V Clean Air Act Section 114 Information 

Request (the "Request"), regarding the facility located at 10 Outer Drive in Minnesota, which was received on April 

6, 2012. The Request originally required a response within 15 days of receipt, but subsequent conversation and 

correspondence with Ms. Molly DeSalie of EPA staff on April 20, 2012 extended the deadline for submittal to May 

7, 2012. NSM hereby provides this timely response to the Request, with the understandings and clarifications 

noted herein. 

NSM has given careful consideration to this Request and each of its questions to ensure that its response 

is· properly tailored to the information EPA has requested. NSM has made a good faith effort to respond to this 

Request in the time allotted. To the extent that the response does not include ali of the information anticipated by 

your request, we ask that EPA first consider the information attached hereto and evaluate what, if anything, may 

still be reasonably required under Clean Air Act Section 114(a). To the extent that EPA identifies continuing needs 

for information, please contact us to discuss how we may further assist you. 

This response restates each of the questions in the Request and provides a narrative explanation of the 

responsive information as necessary. Responsive documents are referenced in the narrative and included with this 

fetter. The attachments are organized by numeric references that correspond to the questions below. Documents 

responsive to multiple questions are identified in the narrative response to each question, and are included under 

the question to which the documents are most responsive. The documents provided have been scanned for 

viruses using McAfee software. 

Northshore Mining Company wishes to point out that it is the third in a sequence of three owners and 

operators of the Northshore iron ore mining and processing facilities. While the facility commenced operations in 

the late 1950s as Reserve Mining Company, Cyprus Minerals Company operated the facility during the early 1990s. 

Northshore Mining Company assumed ownership during October 1994 and has operated the facility since that 

time. In responding to the information request, w hen appropriate, Northshore has searched archived files from 

U.S. Environmental Protection Agency 

Attn: Compliance Tracker, AE-17J 

Page 1 
the previous owners for the requested information. It is impossible for Northshore to determine if these fi les are 

complete. Nevertheless, every attempt was made to provide a complete response to the inquiry. 

Additionally, it is Northshore's understanding that the information sought by EPA in this Request is 

focused on its taconite processing plant and, therefore, Northshore has prepared its responses with regards to 

those sources, rather than on the subsidiary power plant located on the NSM premises. 

For the record, NSM notes that while it has made a good faith effort to respond to the Information Request, it 

does not waive any of its rights to object to the form and content of the Information Request or any legal defenses 

that it might have to this Information Request or its admissibility in any administrative or judicial proceeding. To 

the extent, this Information Request is overly broad and unduly burdensome; it seeks information that is not 

relevant to the compliance status of its facility; it is vague and ambiguous, and requires that legal conclusions be 

made to it, NSM objects to the Information Request on the grounds that it exceeds U.S.EPA's authority under 

Section 114 of the Clean Air Act. NSM also objects to the Information Request to the extent that it requests 

information that is subject to attorney-client privilege or other applicable privilege, or that constitutes attorney 

work product or is otherwise not discoverable. Finally, to the extent that the questions are vague, ambiguous, 

overly broad or otherwise exceed U.S. EPA's authority under Section 114(a), NSM has made appropriate and 

reasonable efforts to respond to the questions to the best of its ability, and has made reasonable interpretations 

of the questions. 

If you have any questions regarding this information, please contact Ms. Andrea Hayden of my staff at 

(218) 226-6032. 

Certification 

I certify under penalty of law that I have examined and am familiar with the information in the enclosed 

documents, including all attachments. Based on my inquiry of those individuals with primary responsibility for 

obtaining the information, I certify that the statements and information are, to the best of my knowledge and 

belief, true and complete. I am aware that there are significant penalties for knowingly submitting false statements 

and information, including the possibility of fines or imprisonment pursuant to section 113(c)(2) of the Act, and 18 

u.s. c. §§ 1001 and 1341. 

Sincerely, 

1James Korpi 

VP/General Manager 

Enclosure 

cc: Jeff T. Connett,' Manager 

Air Quality Division 

Minnesota Pollution Control Agency 

S20 Lafayette Road North 

St. Paul, Minnesota 55155 

Ms. Mary Gade, Gade Law Group 

Mr. Michael Long, Cliffs Natural Resources 

Mr. Scott Gischia, Cliffs Natural Resources 

U.S. Environmental Protection Agency 

Attn: Compliance Tracker, AE-17J 

Page 2 
Narrative Response to Items Listed in Appendix C of EPA Request for 

Information Addressed to Northshore Mining- Silver Bay, Received April 6, 

2012 

Items from Appendix Care restated below in italic print with Northshore Mining- Silver Bay's response 

directly following each. 

1. Provide process flow diagrams for both the taconite iron ore mining and the taconite pellet 

manufacturing processes. Include in the description, at a minimum, information on the 

following: mining operations, ore transfer and storage, course ore crushing, fine ore crushing, 

ore classification screens, ore storage bins, grinding rod/ball mills, separation, thickeners, balling 

drums/pellet formation, indurating furnace, pellet cooling and storage, and the process boilers. 

Include a detailed narrative process description and photographs to explain the indurating 

furnace process (separately for each furnace]. For each photograph; provide o coded 

diagram/map to clearly identify the location of the image in the photograph. Photographs must 

correspond to each of the process stages described. 

The Adobe document titled "Question 1 Process Diagram.pdf" and Word document titled 

"Question 1 Process Pictures.docx" provided on the flash drive accompanying this Narrative 

Response includes a process flow diagram and related pictures for both the taconite iron ore 

mining and the taconite pellet manufacturing processes. 

The Word document titled "Question 1 Process Description.docx" provided on the flash drive 

accompanying this Narrative Response includes a description of mining operations, ore transfer 

and storage, coarse ore crushing, fine ore crushing, ore classification screens, ore storage bins, 

grinding rod/ball mills, separation, thickeners, balling drums/pellet formation, indurating 

furnaces, and pellet cooling and storage. 

The Word document titled "Question 1 Furnaces 11 and 12.doc" provided on the flash drive 

accompanying this Narrative Response is a detailed narrative process description with 

photographs for similar indurating furnaces number 11 and 12. The Word document titled 

"Question 1 Furnaces 5 and 6.doc" is a detailed narrative process description with photographs 

for similar indurating furnaces number 5 and 6. The Word document titled "Question 1 Furnace 

Diagram.docx" is a diagram that relates to the pictures in the furnace Word documents. 

Information that was used or considered in preparation of this response was provided by Ryan Siats and Jennifer 

Ramsdell of Northshore Mining. Scott Gischia of Cliffs and Counsel were also consulted. 

2. For the time period January 1, 2010 to December 31, 2011, provide manufacturing specification 

and operating data to demonstrate operating parameters for each of the facility's indurating 

furnaces. Operating parameters and data must include, at a minimum: flue gas composition, 

entrance air temperature, exit air temperature, preheat zone temperature, burner temperature, 

pellet residence time, and air flow rate. 

Response to Items listed in Appendix C of EPA Request for Information 

Addressed to Northshore Mining- Silver Bay, Received April 6, 2012 

Page 1 of 12 
The Excel workbook titled "Question 2.xslx" provided on the flash drive accompanying this Narrative 

Response includes daily average values of stack entrance air temperatures, stack exit air temperatures, 

furnace preheat zone temperature, furnace ignition zone (burner) temperature, and stack air flow rates 

for each specific indurating furnace at the Northshore Mining Silver Bay facility for the time period 

January 1, 2010 to December 31, 2011. Flue gas composition is derived from the most recent NOx or 

SOx stack test results and detailed in the same workbook. Residence time of pellets is not measured. 

However, for the time period January 1, 2010 to December 31, 2011, the average residence time for 

pellets during normal operation in Furnaces 11 and 12 was approximately 31-43 minutes, Furnace 5 

was approximately 28-39 minutes, and Furnace 6 was approximately 29-40 minutes. Northshore is 

unable to locate any documentation of the manufacturing specifications of the indurating furnaces. As 

stated in the cover letter, ownership of the facility by Cliffs was assumed in October 1994, and archived 

records of past owners are incomplete. 

Information that was used or considered in preparation of this response was provided by Ryan Siats and Jennifer 

Ramsdell of Northshore Mining. Scott Gischia of Cliffs and Counsel were also consulted. 

3. For the time period January 1, 2007 to December 31, 2011, provide records of the natural gas 

used by each specific indurating furnace at the facility. 

The Excel workbook titled "Question 3.xslx" provided on the flash drive accompanying this 

Narrative Response includes daily records of the natural gas used by each specific indurating 

furnace at the Northshore Mining- Silver Bay facility for the time period January 1, 2007 to 

December 31, 2011. The unit of measure is thousand cubic feet per hour, for the average of 

each day. 

Information that was used or considered in preparation of this response was provided by Ryan Siats and Jennifer 

Ramsdell of Northshore Mining. Scott Gischia of Cliffs and Counsel were also consulted. 

4. For the time period January 1, 2007 to December 31, 2011, provide documentation of the 

average sulfur content for caal used by each specific indurating furnace at the facility. 

Coal was not used as a fuel source by any of the specific indurating furnaces at the Northshore 

Mining- Silver Bay facility for the time period January 1, 2007 to December 31, 2011. The 

indurating furnaces at the Silver Bay facility are not permitted to burn coal. 

Information that was used or considered in preparation of this response was provided by Ryan Siats and, Jennifer 

Ramsdell of Cliffs. Scott Gischia of Cliffs and Counsel were also consulted. 

5. Provide copies of all stack tests conducted on any emissions unit for any reason, and include off 

test runs, even if a full test series was not completed. Identify the emissions unit; specify the 

date of the test, test method used, and the filter temperature during the time of the test, if 

applicable. Provide all calculations relative to the stack test, and provide copies of the full test 

report, including the section describing the process parameters and production or processing 

rates at the time of the test, as well as copies of any reports of visible emission observations 

Response to Items listed in Appendix C of EPA Request for Information 

Addressed to Northshore Mining- Silver Bay, Received April6, 2012 

Page 2 of 12 
conducted during each test. For each test during which the source was not operating at 

maximum design capacity, provide an explanation why production was limited. 

Page 2 of EPA's request letter states "We are requesting information on the facility's furnaces 

and other nitrogen oxide {NOx} and sulfur dioxide {502} emitting units at the facility." As such, 

the response to this question has been provided consistent with that request, and focuses on 

502 and NOx stack test information from the indurating furnaces at the facility. 

The table below is an index of attached OCR documents each of which is a complete stack test 

report. During each of the referenced stack tests, sources were not operating at maximum 

design capacity but rather within an acceptable range of the maximum practiced during the 

timeframe around which testing was conducted. 

Furnace 12 Hood Exhaust 

Furnace 12 Waste Gas 

Dec-00 Furnace 6 X NOx 2000 SV 262 SV 113 SV 

EU 104 SV 104 Furnace 11 Waste Gas 

NOx 2005 SV 104 SV 

X 

EU 104 SV 104 Furnace 11 Waste Gas 

EU 104 SV 104 Furnace 11 Waste Gas 

EU 114 SV 114 Furnace 12 Waste Gas 

Information that was used or considered in preparation of this response was provided by Ryan Siats and Jennifer 

Ramsdell of Northshore Mining. Scott Gischia of Cliffs and Counsel were also consulted. 

Response to Items listed in Appendix C of EPA Request for Information 

Addressed to Northshore Mining- Silver Bay, Received April 6, 2012 

Page 3 of 12 
6. Provide an electronic Excel workbook with the complete nitrogen oxide {NOx} and sulfur dioxide 

{502} facility-wide potential ta emit calculations. Include in the response a written description of 

how each column in the Excel workbook is generated. 

The Excel workbook titled "Question 6.xlsx" provided on the flash drive accompanying this 

Narrative Response includes complete nitrogen oxide (NOx) and sulfur dioxide (502 ) facility-wide 

potential to emit calculations. Each column that includes data generated is referenced by a 

unique footnote providing a written description of how the data was generated. 

Information that was used or considered in preparation of this response was provided by Ryan Siats and Jennifer 

Ramsdell of Northshore Mining and Paul Taylor of Barr Engineering. Scott Gischia of Cliffs and Counsel were also 

consulted. 

7-9. The following information is provided as common background for Questions 7, 8 and 9 of the 

Request. Additional information specific to each Question is further included in each section as 

appropriate. 

As indicated in EPA's Section 114 Request, the BART Reports were developed in 2006 using 

control technology that was considered available and technically feasible at that time. In 

preparing the BART Report referenced in EPA's Questions 7 through 9, two guidance documents 

were relied on to establish the process and methodology. These were: 

1. MPCA's 2006 "Guidance for Facilities Conducting a BART Analysis"; and 

2. EPA's "Regional Haze Regulations and Guidelines for Best Available Retrofit Technology 

(BART) Determinations", July 6, 2005, of70 Federal Register 391614 et seq., specifically 

pages 391614 to 39170. 

The 2003 document from MPCA entitled "Guidance for Facilities Conducting a BART Analysis" 

provided the basis and requirements for the BART reviews. This document specifies that the 

Taconite MACT is to be considered equivalent to BART for particulate sources subject to both 

rules. EPA's "Regional Haze Regulations and Guidelines for Best Available Retrofit Technology 

(BART) Determinations" in combination with MPCA's guidance provided the five step BART 

review process, which was followed for the BART analysis in the BART Reports. 

In addition to these guidance documents, the BART Report relied on Section 6 of MPCA's 

"Potential Impacts of the Federal Regional Haze and Best Available Retrofit Technology Rules on 

the Taconite Industry in Minnesota." This document established the control technology 

available and technically feasible for the taconite industry in Minnesota. It was developed 

through a stakeholder process, which included members of MPCA, representatives of the 

Minnesota taconite plants, representatives of Indian tribes and NGO's as well as other 

stakeholders. 

Cliffs' BART Reports also relied on the information contained in its Northshore Facility's permit 

for its 2005 Line 5 Reactivation Project. This project required Best Available Control Technology 

(BACT) analysis for control of nitrogen oxides and sulfur dioxide emissions as part of its PSD 

permit. This BACT analysis is considered more rigorous than BART analysis. 

Response to Items listed in Appendix C of EPA Request for Information 

Addressed to Northshore Mining- Silver Bay, Received April 6, 2012 

Page 4 of 12 
Each of the background documents referenced herein is contained on the flash drive 

accompanying this Narrative Response. 

Also provided on the flash drive accompanying this Narrative Response are an email and 

attachments in an Adobe document titled "9May2006 Barr to MPCA SOx NOx Control 

Technologies.pdf' that shared with MPCA the potential NOx and S02 technologies defined as 

available and applicable for further assessment in the facility-specific BART analyses. 

Information that was used or considered in preparation of this response was provided by Beth Havlik, Teresa Kinder 

and Jack Kennedy of Barr Engineering. Scott Gischia of Cliffs and Counsel were also consulted. 

7. The facility's Best Available Retrofit Technology report, available on the Minnesota Pollution 

Control Agency Regional Haze website ("BART report"), discusses the low efficiency of the 

facility's wet scrubbers for 502• Provide all documentation, including reports and studies, to 

determine the current 502 efficiency of all water scrubbers at the facility. Additionally, provide 

all documents, including reports and studies, completed for the technical feasibility of efficiency 

upgrades for each scrubber. 

Northshore's Silver Bay facility's current control for S02 is a wet electrostatic precipitator with a 

control efficiency of approximately 80%. Therefore, Northshore does not believe that this 

Question applies to it. Please refer to the Adobe document titled "Furnace 5 Restart BACT 

Analysis. pdf" and the electronic folder titled "BART NMC Furnaces PDF to MPCA" provided on 

the flash drive accompanying this Narrative Response for the background information. 

Also provided on the flash drive accompanying this Narrative Response is an Adobe document 

titled "10Jan2007 Barr S02 Scrubber Cost Adjustment. pdf" that includes an email from Barr 

Engineering summarizing some minor corrections to S02 scrubber cost estimates. 

Information that was used or considered in preparation of this response was provided by George Pruchnofski, Beth 

Havlik, Jack Kennedy, Erik Boleman, and Teresa Kinder of Barr Engineering. Scott Gischia of Cliffs and Counsel were 

also consulted. 

8. The BART report discusses the technical feasibility of low NOx burners and a variety of selective 

catalytic reduction (5CRs) systems. Provide all documentation, including reports and studies, to 

determine the technical feasibility of low NOx burners and 5CRs at the facility's indurating 

furnaces. 

The Adobe document titled "Potential Impacts ofthe Federal Regional Haze and BART Rules on 

the Taconite Industry in MN.pdf" provided on the flash drive accompanying this Narrative 

Response includes information regarding technical feasibility of low NOx burners. As described 

in the BART report on page 33, the indurating furnaces at Northshore Mining's Silver Bay facility 

Response to Items listed in Appendix C of EPA Request for Information 

Addressed to Northshore Mining- Silver Bay, Received April 6, 2012 

Page 5 of 12 
have a completely different combustion design compared to other furnaces. The indurating 

furnace design at Northshore Mining's Silver Bay facility do not separate the preheat zone from 

the combustion zone and temperature control is a controlling variable for operation. Because 

the temperature in the indurating zone is critical to product quality, and because this is 

dependent on the preheat zone operation, it is not practical to control the furnace conditions in 

the preheat zone adequately to make low NOx burners a feasible option at Northshore. 

The Adobe documents titled "Vogt Vendor Budget Estimate (redacted).pdf' and "Potential 

Impacts of the Federal Regional Haze and BART Rules on the Taconite Industry in MN.pdf" 

provided on the flash drive accompanying this Narrative Response include information regarding 

the technical feasibility of SCRs at the Northshore Mining- Silver Bay facility. 

The availability and technical feasibility of both Low NOx burners and SCR were discussed as 

presented in the Adobe documents titled "Agenda CCI BART Issues Meeting 08-09-06.pdf' 

provided on the flash drive accompanying this Narrative Response. 

Also provided on the flash drive accompanying this Narrative Response are Adobe documents 

titled "2Aug2006 Barr LNB Vendor Discussion.pdf" and "30Aug2006 Osmundson BART 

comments. pdf". The document titled "2Aug2006 Barr LNB Vendor Discussion. pdf" includes an 

email discussion outlining conversations with a Low-NOx burner vendor, and the document 

titled "30Aug2006 Osmundson BART comments.pdf" includes email correspondence from Mike 

Osmundson (Northshore Mining Company) discussing possible implications to furnace operation 

of temperature in preheat region of furnace. 

Information that was used or considered in preparation of this response was provided by George Pruchnofski, Beth 

Havlik, Jack Kennedy, Erik Bole man, and Teresa Kinder of Barr Engineering. Scott Gischia of Cliffs and Counsel were 

also consulted. 

9. The BART report discusses the technical feasibility of overfire air and induced flue gas 

technology. Provide all documentation, including reports and studies, to determine the technical 

feasibility of overfire air and induced flue gas technology at the facility's indurating furnaces. 

The Adobe documents titled "Furnace 5 Restart BACT Analysis. pdf" and "Metso representative 

e-mail dated July 18, 2006.pdf' provided on the flash drive accompanying this Narrative 

Response includes information to determine the technical feasibility of overfire air and induced 

flue gas technology at the Northshore Mining- Silver Bay facility. 

Information that was used or considered in preparation of this response was provided by George Pruchnofski, Beth 

Havlik, Jack Kennedy, Erik Boleman, and Teresa Kinder of Barr Engineering. Scott Gischia of Cliffs and Counsel were 

also consulted. 

10. Identify the manufacturer, including contact information, for all low NOx burners, SCR, scrubber, 

overfire air, and induced flue gas technologies considered technically feasible for use at the 

facility. 

Response to Items listed in Appendix C of EPA Request for Information 

Addressed to Northshore Mining- Silver Bay, Received April 6, 2012 

Page 6 of 12 
The Excel workbook titled "Manufacturers_contact_info(l).xlsx" provided on the flash drive 

accompanying this Narrative Response identifies the manufacturer, including contact 

information, for low NOx burners, SCR, scrubber, overfire air, and induced flue gas technologies 

considered technically feasible for use at the Northshore Mining- Silver Bay facility. 

Information that was used or considered in preparation of this response was provided by Ryan Siats and Jennifer 

Ramsdell of Northshore Mining. Scott Gischia of Cliffs and Counsel were also consulted. 

11. For the time period January 1, 2002, to the date of receipt of this fetter, provide all 

documentation, including engineering studies or mass balance studies, conducted to determine 

emissions of NOx from each waste-gas stack at all indurating furnaces at the facility. 

The Word document titled "NOx Generation in Northshore Mining Furnaces.doc" provided on 

the flash drive accompanying this Narrative Response includes information from engineering 

studies to determine emissions of NOx from the indurating furnaces at the Northshore MiningSilver Bay facility. 

Information that was used or considered in preparation of this response was provided by Ryan Siats and Jennifer 

Ramsdell of Northshore Mining. Scott Gischia of Cliffs and Counsel were also consulted. 

12. Provide an electronic Excel workbook listing the following information from the NOx and/or 502 

continuous emissions monitoring system (CEM5} from the date the CEM5 were installed to 

present. Provide the information on an hourly basis, where applicable. The Excel workbook must 

include the following: 

a. CEM5 identifying name or maker; 

b. CEMS location; 

c. Pollutant monitored; 

d. Date and time; 

e. NOx/502 emissions rate in pounds per million British thermal units (lb/mmBtu); 

f. Raw NOx/502 in ppm 

g. NOx/502 emissions rate in pounds per hour; 

h. Flow rate in actual cubic feet per minute (acfm); and 

i. Furnace temperature in °F. 

The Excel workbook titled "Question 12.xslx" provided on the flash drive accompanying this 

Narrative Response includes the requested information pertaining to the NOx continuous 

emissions monitoring system (CEMS) installed on Furnace 5 from December 29, 2010 to present. 

The CEMS were initially certified on December 29, 2010. CEMS are not installed on any of the 

other indurating furnaces at the Northshore Mining Silver Bay facility. 

Information that was used or considered in preparation of this response was provided by Ryan Siats and Jennifer 

Ramsdell of Northshore Mining. Scott Gischia of Cliffs and Counsel were also consulted. 

13. Provide written explanation and supporting documents of how the facility could use NOx CEM5 

for process optimization. 

Response to Items listed in Appendix C of EPA Request for Information 

Addressed to Northshore Mining- Silver Bay, Received April 6, 2012 

Page 7 of 12 
Discussion of this topic was included as part of Cliffs' Northshore 2006 BART report, and is 

reprinted here for reference. 

"Process Optimization with NOx CEMS or Other Parametric Monitoring" 

MPCA guidance lists "NOx CEMS" as a work practice/operational change for controlling NOx 

emissions. Parametric monitoring is a possible derivative of this alternative. 

Based on conversations with MPCA staff, this work practice would include process adjustments, 

or optimization, to minimize NOx emissions. The impact ofthe process adjustments would be 

measured using the NOx CEMS. This approach has been used in the electric utility industry to 

fine tune NOx emissions from boilers. 

One taconite plant has installed NOx CEMS to monitor emissions but not to optimize NOx 

emissions through process fine tuning. That plant has experienced some reduction in NOx 

emissions but these encompass multiple variables and are not directly attributed to process fine 

tuning with the NOx CEMS. Therefore, this alternative has not been demonstrated in the 

taconite industry. 

There are several concerns with utilizing process optimization as an available, applicable and 

technically feasible control option for the taconite industry: 

• 

• 

• 

Taconite furnaces are designed and operated to convert magnetite to hematite in the 

presence of excess oxygen and require heat input to initiate the reaction which is 

exothermic and releases heat once initiated. Fuel combustion is only part of the process and 

therefore this process is different from a boiler. 

The quality of the process feed material to the furnace is variable at some taconite 

operations and product quality may be compromised by attempting to fine tune heat input 

to minimize NOx formation. 

At some operations, the operating parameters which generally influence the rate of NOx 

generation such as flame temperature, fuel usage and excess air are relatively constant 

during operation of the furnace, independent of process operation variability. This indicates 

that NOx formation is not dependent upon controllable operating parameters. In the 

absence of controllable parameters, process optimization would not be effective at 

controlling NOx emissions. 

Based upon this information, there is no indication that further emission reductions would be 

achieved through the use ofthe process optimization, using NOx CEMS or other parametric 

monitoring, as a control technology. Therefore, process optimization as a control option will not 

be evaluated further in this report." (P35-36, NSM BART Report) 

The electronic folder titled "BART NMC Furnaces PDF to MPCA" provided on the flash drive 

accompanying this Narrative Response includes the Northshore Mining- Silver Bay facility's 

BART report in its entirety. 

Response to Items listed in Appendix C of EPA Request for Information 

Addressed to Northshore Mining -Silver Bay, Received April6, 2012 

Page 8 of 12 
Also provided on the flash drive accompanying this Narrative Response is an Adobe document 

titled "12Jul2006 Barr Discussion of Process optimization.pdf" consisting of an email from Barr 

Engineering outlining a discussion with regards to NOx generation and optimization with CEMS. 

Information that was used or considered in preparation of this response was provided by Ryan Siats and Jennifer 

Ramsdell of Northshore Mining. Scott Gischia of Cliffs and Counsel were also consulted. 

14. For the period from January 1, 2002, to the date of receipt of this letter, provide NOx emissions 

data from each indurating furnace for each day, and also for a thirty-day rolling average. 

The Excel workbook titled "Question 14.xslx" provided on the flash drive accompanying this 

Narrative Response includes daily and thirty-day rolling average NOx emissions data for Furnace 

5 from December 29, 2010 to the date of receipt of this letter. From January 1, 2002, to 

December 29, 2010, NOx emissions data for Furnace 5 is not available because CEMS were not 

installed during that time frame. NOx emissions data for the other indurating furnaces is not 

available because CEMS are not installed on them. 

Information that was used or considered in preparation of this response was provided by Ryan Siats and Jennifer 

Ramsdell of Northshore Mining. Scott Gischia of Cliffs and Counsel were also consulted. 

15. Identify all NOx emission sources and factors contributing ta NOx emissions at the facility's 

indurating furnaces, including but not limited to, the burners. 

The Word document titled "NOx Generation in Northshore Mining Furnaces.doc" and the Adobe 

document titled "Formation of NOx in Iron Oxide Pelletizing Furnaces.PDF" provided on the flash 

drive accompanying this Narrative Response, identify possible NOx emission sources and factors 

contributing to NOx emissions in the indurating furnaces at the Northshore Mining- Silver Bay 

facility. 

Also provided on the flash drive accompanying this Narrative Response is an Adobe document 

titled "12May2006 Barr Conference Call on Kiln NOx Emissions.pdf" consisting of a May 12, 2006 

email correspondence from Barr Engineering outlining a planned conference call to 'discuss NOx 

emissions data'. 

Information that was used or considered in preparation of this response was provided by Ryan Siats and Jennifer 

Ramsdell of Northshore Mining. Scott Gischia of Cliffs and Counsel were also consulted. 

16. Identify all persons, including employees, consultants, representatives of the taconite industry, or 

representatives of air pollution control manufacturers, who assisted in the preparation, or were 

consulted for the purpose of preparing, the BART report. 

Individuals who assisted in the preparation, or were consulted for the purpose of preparing, the 

BART report, included the following: 

Response to Items listed in Appendix C of EPA Request for Information 

Addressed to Northshore Mining- Silver Bay, Received April6, 2012 

Page 9 of 12 
Information that was used or considered in preparation of this response was provided by George Pruchnofski, Beth 

Havlik, Jack Kennedy, Erik Boleman, and Teresa Kinder of Barr Engineering. Scott Gischia of Cliffs and Counsel were 

also consulted. 

Response to Items listed in Appendix C of EPA Request for Information 

Addressed to Northshore Mining- Silver Bay, Received April 6, 2012 

Page 10 of 12 
Table of Contents: Accompanying Documentation for Narrative Response to 

Items Listed in Appendix C of EPA Request for Information Addressed to 

North shore Mining- Silver Bay 

Folder Title 

Question 1 

Question 2 

Question 3 

Question 4 

Question 5 

Question 6 

Question 7-9 

Question 7 

Question 8 

Question 9 

Contents 

Question 1 Furnace Diagram.docx 

Question 1 Furnaces 5 and 6.doc 

Question 1 Furnaces 11 and 12.doc 

Question 1 Process Description.docx 

Question 1 Process Diagram.PDF 

Question 1 Process Pictures.docx 

Question2.xlsx 

Question 3.xlsx 

No Documents Included 

NOx 2000 SV 262 SV 113 SV 114.pdf 

NOx 2005 SV 104 SV 261.pdf 

NOx 2006 SV 112 SV 114.pdf 

NOx 2007 July SV 104.pdf 

NOx 2007 SV March 104.pdf 

NOx 2009 SV 104 SV 114.pdf 

NOx 2010 EU 104 EU 114.pdf 

NOx 2011 EU 104 EU 114.pdf 

S02 2008 sv 266.pdf 

Question 6.xlsx 

9May2006 Barr to MPCA SOx NOx Control Technologies.pdf 

EPA's Regional Haze Regulations and Guidelines for Best Available 

Retrofit Technology (BART) Determinations.pdf 

Furnace 5 Restart BACT Analysis.pdf 

MPCA's 2006 Guidelines for Facilities Conducting a BART Analysis. pdf 

Potential Impacts of the Federal Regional Haze and Best Available 

Retrofit Technology Rules on the Taconite Industry in MN.pdf 

10Jan2007 Barr S02 Scrubber Cost Adjustment 

NMC Furnaces BART Report 

Furnace 5 Restart BACT Analysis. pdf 

2Aug2006 Barr LNB Vendor Discussion.pdf 

30Aug2006 Osmundson BART comments.pdf 

Agenda CCI BART Issues Meeting 08-09-06.pdf 

Potential Impacts of the Federal Regional Haze and Best Available 

Retrofit Technology Rules on the Taconite Industry in MN.pdf 

Vogt Vendor Budget Estimate (redacted).pdf 

Furnace 5 Restart BACT Analysis.pdf 

Response to Items Listed in Appendix C of EPA Request for Information 

Addressed to Northshore Mining- Silver Bay, Received April 6, 2012 

Page 11 of 12 
Question 10 

Question 11 

Question 12 

Question 13 

Question 14 

Question 15 

Question 16 

Metso representative e-mail dated July 18 2006 

Manufacturers contact info(1).xls 

NOx Generation in Northshore Mining Furnaces.doc 

Question 12.xlsx 

12Jul2006 Barr Discussion of Process optimization. pdf 

NMC Furnaces BART Report 

Question 14.xlsx 

12May2006 Barr Conference Call on Kiln NOx Emissions.pdf 

Formation of NOX in Iron Oxide Pelletizing Furnaces. pdf 

NOx Generation in Northshore Mining Furnaces.doc 

No Documents Included 

Response to Items listed in Appendix C of EPA Request for Information 

Addressed to Northshore Mining- Silver Bay, Received April 6, 2012 

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