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Technical Support Document, Permit Number: 13700113-102 Page 1 of 21 Technical Support Document for Draft Air Emission Permit No. 13700113-102 This technical support document (TSD) is intended for all parties interested in the draft permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft permit. 1. General information 1.1 Applicant and stationary source location Table 1. Applicant and source address Applicant/Address Stationary source/Address (SIC Code: 1011 - Iron Ores) United Taconite LLC 8470 Townline Rd. Forbes, Minnesota 55378-0180 United Taconite LLC - Fairlane Plant 8470 Townline Rd. Forbes, Minnesota 55378-0180 Contact: Candice Maxwell Phone: 218-744-7879 1.2 Facility description United Taconite LLC - Fairlane Plant (United Taconite) is a taconite processing and pellet production facility located near Forbes, Minnesota. Crude taconite ore is supplied from United Taconite LLC - Thunderbird Mine (Air Emission Permit No. 13700011-001) via a third party-owned and operated rail link. Crushed ore is unloaded in a covered building then transferred by a covered conveyor to the fines crusher building where it is immediately crushed at the third-stage crusher or sent to the coarse ore surge pile. The coarse ore surge pile is used to store ore between train shipments or during times when the crusher is down. Ore is returned from the coarse ore surge pile and fed into one of the five third-stage crushers. Particulate emissions from the third-stage crushers are controlled by wet scrubbers or fabric filters. The oversize material is conveyed to one of eight fourth-stage crushers. Each fourth-stage crusher has a dedicated wet scrubber or fabric filter to control particulate emissions. Undersize material is transferred to the fine ore surge building. Oversize material is recirculated to the fourth-stage crushers. Five concentrator lines receive ore from the fine ore surge building. Particulate emissions from the transfer of fine ore to the concentrator lines are controlled using wet scrubbers or fabric filters. Here ore is ground and magnetic separators remove the magnetite ore from the gangue to produce concentrate. Low-magnetic coarse tailings are transported by truck for use as construction material for tailing basin sidewalls. Fine tailings are pumped in slurry form to the tailings basin. The processes performed in the concentrator area are wet operations. Concentrate is piped as a slurry to the pelletizing plant where the slurry is dewatered with filters. Here additives are introduced and green pellets are produced in balling drums. The green pellets are conveyed to one of two traveling grate-kiln indurating furnaces where it is thermally hardened to produce fired pellets. The grate feed, grate discharge, kiln induration, and kiln cooler emissions are controlled with wet scrubbers. Fired pellets are conveyed to pellet storage silos. Pellets are then loaded into rail cars and transported from the facility. Particulate emissions from the pellets are controlled with wet scrubbers and dust suppressants.

Technical Support Document for Draft Air Emission Permit ... · Technical Support Document, Permit Number: 13700113-102 Page 2 of 21 Intermediate products and byproducts, including

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    Technical Support Document, Permit Number: 13700113-102 Page 1 of 21  

    Technical Support Document for

    Draft Air Emission Permit No. 13700113-102 

     This technical support document (TSD) is intended for all parties interested in the draft permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft permit.

    1. General information 1.1 Applicant and stationary source location

    Table 1. Applicant and source address

    Applicant/Address Stationary source/Address (SIC Code: 1011 - Iron Ores)

    United Taconite LLC 8470 Townline Rd. Forbes, Minnesota 55378-0180

    United Taconite LLC - Fairlane Plant 8470 Townline Rd. Forbes, Minnesota 55378-0180

    Contact: Candice Maxwell Phone: 218-744-7879

    1.2 Facility description

    United Taconite LLC - Fairlane Plant (United Taconite) is a taconite processing and pellet production facility located near Forbes, Minnesota. Crude taconite ore is supplied from United Taconite LLC - Thunderbird Mine (Air Emission Permit No. 13700011-001) via a third party-owned and operated rail link. Crushed ore is unloaded in a covered building then transferred by a covered conveyor to the fines crusher building where it is immediately crushed at the third-stage crusher or sent to the coarse ore surge pile. The coarse ore surge pile is used to store ore between train shipments or during times when the crusher is down. Ore is returned from the coarse ore surge pile and fed into one of the five third-stage crushers. Particulate emissions from the third-stage crushers are controlled by wet scrubbers or fabric filters. The oversize material is conveyed to one of eight fourth-stage crushers. Each fourth-stage crusher has a dedicated wet scrubber or fabric filter to control particulate emissions. Undersize material is transferred to the fine ore surge building. Oversize material is recirculated to the fourth-stage crushers. Five concentrator lines receive ore from the fine ore surge building. Particulate emissions from the transfer of fine ore to the concentrator lines are controlled using wet scrubbers or fabric filters. Here ore is ground and magnetic separators remove the magnetite ore from the gangue to produce concentrate. Low-magnetic coarse tailings are transported by truck for use as construction material for tailing basin sidewalls. Fine tailings are pumped in slurry form to the tailings basin. The processes performed in the concentrator area are wet operations. Concentrate is piped as a slurry to the pelletizing plant where the slurry is dewatered with filters. Here additives are introduced and green pellets are produced in balling drums. The green pellets are conveyed to one of two traveling grate-kiln indurating furnaces where it is thermally hardened to produce fired pellets. The grate feed, grate discharge, kiln induration, and kiln cooler emissions are controlled with wet scrubbers. Fired pellets are conveyed to pellet storage silos. Pellets are then loaded into rail cars and transported from the facility. Particulate emissions from the pellets are controlled with wet scrubbers and dust suppressants.

  • Technical Support Document, Permit Number: 13700113-102 Page 2 of 21

    Intermediate products and byproducts, including but not limited to rocks, tailings, and concentrate, are also sold by United Taconite. Supporting activities at the Fairlane Plant include maintenance shops and offices. The United Taconite facility is a major source under the Prevention of Significant Deterioration (PSD) program, a major source under the Part 70 program, and a major source of hazardous air pollutants (HAPs). Attachment 1 to this TSD contains the subject item inventory and Attachment 2 contains the requirements summary.

    1.3 Description of the activities allowed by this permit action This permit action incorporates two major amendments, one reopening, and one notification. The MPCA has a combined operating and construction permitting program under Minn. R. ch. 7007, and under Minn. R. 7007.0800. Under that authority, this permit action authorizes construction. The MPCA acknowledges that the expiration date of United Taconite’s Title V permit (February 23, 2005) has passed. Because United Taconite submitted its reissuance application in a timely manner on August 27, 2004, the Title V permit remains in effect per Minn. R. 7007.0450, subp. 3 and the MPCA may issue amendments to the permit. The MPCA discussed the possibility of reissuing the Title V permit in conjunction with this permit amendment with United Taconite. However, the MPCA has determined that it cannot reissue the Title V permit in time to meet United Taconite’s desired operation and outage schedule. Since United Taconite’s Title V reissuance application is outdated, this permit action incorporates a requirement for United Taconite to submit a complete updated Title V reissuance application within 30 days of the major amendment issuance date. This requirement will ensure that the MPCA receives the information that it requires to expeditiously reissue the Title V permit.

    1.3.1 Reopening The permit action incorporates an MPCA-initiated reopening to reset operating parameters for five wet scrubbers based on operation during performance tests. Firstly, a Notice of Compliance (NOC) dated August 31, 2017 resets the pressure drops for TREA 89 and TREA 90 for compliance with 40 CFR pt. 63, subp. RRRRR (NESHAP RRRRR). Secondly, an NOC dated March 26, 2018 resets the pressure drops and water flow rates for TREA 49 and TREA 50 for NESHAP RRRRR compliance. (United Taconite conducted the performance test on only the emission unit controlled by TREA 49: EQUI 20. However, United Taconite can reset operating parameters on other similar control equipment as allowed by NESHAP RRRRR.) Finally, an NOC dated April 18, 2018 resets the TREA 91 water flow rate for both NESHAP RRRRR and Title V compliance. These NOCs are included as Attachment 3 to this TSD.

    1.3.2 Furnace limit change major amendment United Taconite submitted a major amendment application on April 16, 2019 proposing to change limits to avoid a major PSD modification that were originally incorporated into Air Emission Permit No. 13700113-005. Amongst other emission and operational limits to avoid PSD, that permit action established PM, PM10, and PM2.5 grain-loading emission limits and annual hours-of-operation limits of 7,992 hr/yr for each the Line 1 (EQUI 45) and Line 2 (EQUI 47) induration furnaces. In its application, United Taconite proposed to remove the annual operating-hour limits and grain-loading emission limits and replace them with the 12-month rolling sum emission limits shown in Table 2 below. This change would allow United Taconite greater operational flexibility concerning regularly scheduled outages. Table 2. Proposed induration furnace emission limits

    Pollutant EQUI 45 emission limits (tpy)

    EQUI 47 emission limits (tpy)

    PM 72.1 317.6

  • Technical Support Document, Permit Number: 13700113-102 Page 3 of 21

    Pollutant EQUI 45 emission limits (tpy)

    EQUI 47 emission limits (tpy)

    PM10 143.0 382.2 PM2.5 143.0 382.2

    The PSD rules contain clarifications on certain changes that are not considered changes in the method of operation. Under 40 CFR § 52.21(b)(2)(iii)(f), an increase in the hours of operation of a source is not considered a change in the method of operation unless that increase would have been prohibited by an enforceable permit condition. Because United Taconite is proposing to replace the enforceable operating hour restrictions on its furnaces, this exclusion from the change in method of operation does not apply. Therefore, the proposed changes to enforceable permit limits is considered a change in the method of operation under PSD. While this permit action increases the allowed annual number of hours that the indurating furnaces are permitted to operate, the new 12-month rolling emissions limits ensure that the emissions increase remain below the levels projected in Air Emission Permit No. 13700113-005. This permit action removes the operating hour limits, replaces the emission limits, and incorporates the necessary monitoring and recordkeeping needed to adequately demonstrate compliance with the new limits.

    1.3.3 Baghouse installation major amendment This major amendment application is for the installation of a new baghouse in the additive handling area of the United Taconite facility. In a July 15, 2014 notification for baghouse replacement, United Taconite proposed to replace TREA 13 with a new baghouse — TREA 11 — to control PM, PM10, and PM2.5 emissions from EQUI 37 and EQUI 55. This replacement was incorporated into Air Emissions Permit No. 13700113-006 in May 2015 with the removal of TREA 13 and the addition of TREA 11. As part of a larger permit action, the MPCA incorporated an insignificant modification for the installation of EQUI 170 into the Air Emissions Permit No. 13700113-007 in January 2017. Emissions from EQUI 170 were to be controlled by TREA 11. The relationships for these emission units as permitted by Air Emissions Permit No. 13700113-007 are: EQUI 37 is controlled in parallel by TREA 11 and TREA 63; EQUI 55 is controlled by TREA 11; and EQUI 170 is controlled by TREA 11. After reviewing its facility, United Taconite determined that the information it provided in its July 2014 notification was incorrect. The notification should have stated that the replacement baghouse was to replace TREA 63, not TREA 13. Additionally, United Taconite identified incorrect control equipment relationships for EQUI 37 and EQUI 55. The actual control equipment relationships at the facility for these emission units as of permit issuance are: EQUI 37 is controlled by TREA 11; EQUI 55 is controlled by TREA 13; and EQUI 170 is controlled by TREA 11. In its June 5, 2019 major amendment application, United Taconite proposed to install a new baghouse TREA 92 to independently control EQUI 170. United Taconite also proposed to correct the past errors previously identified. This permit action removes TREA 63 from the permit and reincorporates TREA 13 back into the permit. The control equipment relationships upon issuance of this permit action will be: EQUI 37 is controlled by TREA 11; EQUI 55 is controlled by TREA 13; and

  • Technical Support Document, Permit Number: 13700113-102 Page 4 of 21

    EQUI 170 is controlled by TREA 92.

    1.3.4 Notification In the November 20, 2019 notification, United Taconite proposes to replace two 4.06-MMBtu/hr space heaters with two identical 3.63-MMBtu/hr space heaters. The removed space heaters were previously listed as insignificant activities in Appendix A of the permit identified as EU 222 and EU 322, where EU 222 combusted natural gas and #2 fuel oil while EU 322 combusted only natural gas. The new space heaters are identified as EQUI 208 and EQUI 209 and are both designed to burn only natural gas. Since the new space heaters will not increase emissions of any regulated pollutant and the replacement does not constitute a Title I modification or other type of modification, United Taconite can make the replacement under the notification provisions of Minn. R. 7007.1150(C)(2).

    1.4 Description of notifications and applications included in this action Table 3 below lists the activities incorporated into this permit action. Table 3. Notifications and applications included in this action

    Date received Application/Notification type and description August 31, 2017 Reopening (IND20170003) April 16, 2019 (supplemental information January 22, 2020)

    Major Amendment (IND20190001) (furnace limit change)

    June 5, 2019 (supplemental information December 17, 2019)

    Major Amendment (IND20190002) (baghouse installation)

    November 20, 2019 Notification of Replacement of Unit (IND20190003) Due to the close proximity in the timing of application submittal dates, the MPCA determined if the major amendments and notification should be considered one project. Since the sources included in the project scopes do not overlap and there is no functional interrelatedness between the in-scope sources — the control equipment operation in the additive handling area does not affect the operation of the indurating furnaces nor do space heaters affect operation of any other sources — the MPCA does not consider the projects to be substantially related. Therefore, the MPCA performed its review of the applications and emission increase calculations as individual projects.

    1.5 Facility emissions

    1.5.1 Furnace limit change major amendment For the change in method of operation for the furnace limit change major amendment, United Taconite performed the actual-to-projected-actual emissions increase test found in 40 CFR § 52.21(a)(2)(iv)(c) to determine the emission increases looking forward from the application date. These increases are summarized in Table 4, which shows that the change in method of operation is not a major modification. Table 4. Forward-looking Title I emissions increase summary

    Pollutant

    Projected actual emissions* (tpy)

    Baseline actual emissions† (tpy)

    Projected emissions increase prior to excludables (tpy)

    Excludable emissions‡ (tpy)

    Projected emissions increase including excludables (tpy)

    NSR significant thresholds for major sources (tpy)

    NSR review required? (Yes/No)

    PM 262 177 84.5 85.2 0.50 25 No PM10 403 256 148 146 1.36 15 No

  • Technical Support Document, Permit Number: 13700113-102 Page 5 of 21

    Pollutant

    Projected actual emissions* (tpy)

    Baseline actual emissions† (tpy)

    Projected emissions increase prior to excludables (tpy)

    Excludable emissions‡ (tpy)

    Projected emissions increase including excludables (tpy)

    NSR significant thresholds for major sources (tpy)

    NSR review required? (Yes/No)

    PM2.5 403 256 148 146 1.36 10 No

    NOx 5,347 2,249 3,098 3,098 0 40 No

    SO2 2,710 1,218 1,492 1,617 0 40 No

    CO 142 73.5 68.7 23.5 45.1 100 No

    Ozone (VOC)

    76.8 43.9 32.8 11.5 21.3 40 No

    Lead 0.278 0.230 0.0480 0.139 0 0.6 No

    Fluorides 14.5 11.7 2.80 2.59 0.59 3 No

    Sulfuric acid mist

    103 89.8 13.7 22.4 0 7 No

    CO2e§ 866,008 403,863 462,145 109,612 352,533 75,000 No *Projected actual emissions as defined in 40 CFR § 52.21(b)(41). †Baseline actual emissions as defined in 40 CFR § 52.21(b)(48). ‡Emissions that can be excluded as detailed in 40 CFR § 52.21(b)(41)(ii)(c). §Carbon dioxide equivalents as defined in Minn. R. 7007.0100. Because the proposed change is a change to an enforceable limit previously take to avoid a major PSD modification, United Taconite also performed backward-looking emission increase calculations to determine in the proposed change would trigger 40 CFR § 52.21(r)(4). United Taconite recalculated the actual-to-projected-actual emissions increases originally calculated for Air Emissions Permit No. 13700113-005 assuming the proposed emission limits in place of the previous limits. These increases are summarized in Table 5 and show that the change does not trigger 40 CFR § 52.21(r)(4). The emission increases are discussed further in Section 3.1 of this TSD. Table 5. Backward-looking Title I emissions summary

    Pollutant*

    Projected actual emissions† (tpy)

    Baseline actual emissions‡ (tpy)

    Projected emissions increase (tpy)

    Source-wide contemporaneous increases and decreases§ (tpy)

    Net emissions increase (tpy)

    NSR significant thresholds for major sources (tpy)

    NSR review required? (Yes/No)

    PM 1164.9 1096.7 256.2 -232.1 24.1 25 No PM10 959.5 909.4 240.5 -250.7 -10.2 15 No PM2.5 923.3 855.4 240.5 -231.6 8.9 10 No NOx 5,346.1 5,311.1 1,266.2 -1,231.2 35.0 40 No SO2 3,687.2 3,652.2 1,275.9 -1,240.9 35.0 40 No CO 140.6 151.5 20.5 - 20.5 100 No Ozone (VOC)

    69.8 60.9 16.2 - 16.2 40 No

    Lead 0.2200 0.1242 0.0958 - 0.0958 0.6 No Fluorides 12.1 14.5 0 - 0 3 No

  • Technical Support Document, Permit Number: 13700113-102 Page 6 of 21

    Pollutant*

    Projected actual emissions† (tpy)

    Baseline actual emissions‡ (tpy)

    Projected emissions increase (tpy)

    Source-wide contemporaneous increases and decreases§ (tpy)

    Net emissions increase (tpy)

    NSR significant thresholds for major sources (tpy)

    NSR review required? (Yes/No)

    Sulfuric acid mist

    262.9 260.5 67.3 -64.9 2.4 7 No

    *At the time of issuance for Air Emission Permit No. 13700113-005, the MPCA still operated its PSD under delegated authority from the EPA. Concerning which pollutants were regulated under 40 CFR § 52.21, the EPA followed the guidance presented in the December 18, 2008 memo from Administrator Stephen Johnson titled, “EPA’s Interpretation of Regulations that Determine Pollutants Covered By Federal Prevention of Significant Deterioration (PSD) Permit Program.” This memo determined that carbon dioxide and other greenhouses gases were not subject to regulation under the NSR program. Therefore, greenhouse gas emissions increases were not analyzed for Air Emission Permit No. 13700113-005 and are not included here for the lookback analysis. †Projected actual emissions as defined in 40 CFR § 52.21(b)(41). ‡Baseline actual emissions as defined in 40 CFR § 52.21(b)(48). §Other emission changes during the contemporaneous period as defined by 40 CFR § 52.21, 40 CFR § 52.24, or 40 CFR pt. 51.

    1.5.2 Space heater notification emissions increases United Taconite conducted to baseline-to-potential emissions increase test for new sources under 40 CFR § 52.21(a)(2)(iv)(d). United Taconite did not consider the new space heaters to be “replacement units” as defined in 40 CFR § 52.21(b)(33) for the Title I emissions increase calculations. The Title I emission increases are summarized in Table 6, which shows that the project is not a major PSD modification. The non-Title I calculations are summarized in Table 7, which shows that the project does not require a minor or moderate amendment. Table 6. Notification Title I emissions summary

    Pollutant

    Emissions increase from the modification (tpy)

    Limited emissions increase from the modification (tpy)

    Net emissions increase (tpy)

    NSR/112(g) significant thresholds for major sources (tpy)

    NSR/112(g) review required? (Yes/No)

    PM 0.237 0.237 0.237 25 No PM10 0.237 0.237 0.237 15 No PM2.5 0.237 0.237 0.237 10 No NOx 3.12 3.12 3.12 40 No SO2 0.0187 0.0187 0.0187 40 No CO 2.62 2.62 2.62 100 No Ozone (VOC) 0.171 0.171 0.171 40 No Lead 0.0000156 0.0000156 0.0000156 0.6 No CO2e* 3,763 3,763 3,763 75,000 No Maximum individual HAP†

    0.0128 0.0128 0.0128 10 No

    Total HAPs 0.0589 0.0589 0.0589 25 No *Carbon dioxide equivalents as defined in Minn. R. 7007.0100. †Hexane

  • Technical Support Document, Permit Number: 13700113-102 Page 7 of 21

    Table 7. Notification non-Title I emissions increase summary

    Pollutant After change (lb/hr)

    Before change (lb/hr)

    Net change* (lb/hr)

    Insignificant modification thresholds (lb/hr )

    Type of amendment (minor or moderate)

    PM10 0.0541 0.0990 -0.0748 0.855 3.42 None NOx 0.712 0.996 -0.284 2.28 9.13 None SO2 0.00427 0.214 -0.210 2.28 9.13 None CO 0.598 0.669 -0.0712 5.70 22.80 None VOC 0.0391 0.0438 -0.00466 2.28 9.13 None Lead 0.00000356 0.0000386 -0.0000350 0.025 0.11 None

    *The term ‘Net Change’ is not equivalent to ‘Net Emissions Increase’ as defined at 40 CFR § 52.21(b)(3).

    1.5.3 Total facility emissions and classification Table 8 below summarizes United Taconite’s potential emissions and annual actual emissions. Table 8. Total facility potential to emit summary

    Pollutant

    Total facility limited potential emissions (tpy)

    Total facility actual emissions (2018) (tpy)

    PM 3,073 519 PM10 2,359 592 PM2.5 663 409 NOx 5,410 4,789 SO2 3,791 365 CO 324 64.7 VOC 151 42.6 Fluorides 26.3 *

    Lead 1.31 0.137 Sulfuric acid mist 266 *

    CO2e 1,310,557 *

    Maximum single HAP† 119 *

    Total HAPs 173 * *Not reported in Minnesota emission inventory. †Hydrochloric acid Table 9 below summarizes the program classifications for United Taconite. Table 9. Facility classification

    Classification Major Synthetic minor/area Minor/Area New Source Review X Part 70 X Part 63 X

  • Technical Support Document, Permit Number: 13700113-102 Page 8 of 21

    1.6 Changes to permit The MPCA has a combined operating and construction permitting program under Minn. R. ch. 7007, and under Minn. R. 7007.0800, the MPCA has authority to include additional requirements in a permit. Under that authority, the following changes to the permit are also made through this permit action: Updated the draft permit to reflect current MPCA templates and standard citation formatting. Completed requirements and the requirements for equipment that has been removed have been

    deleted. Added TREA 91 to COMG 16 (NESHAP RRRRR wet scrubber requirements). Removed outdated EQUI 169 requirements relating to the May 1, 2016 D.C. Circuit Court’s vacatur of

    requirements regarding nonemergency use of emergency engines in 40 CFR pt. 60, subp. IIII and 40 CFR pt. 63, subp. ZZZZ.

    Removed the requirement to submit an annual report comparing the assumptions made while determining PSD applicability for Air Emissions Permit No. 13700113-005 to actual observed data along with Appendix D of the former permit, which contained these assumptions. The 5-year projection period for that project has lapsed. Therefore, the recordkeeping required by 40 CFR § 52.21(r)(6) for sources with a reasonable possibility to result in a significant emissions increase is no longer necessary.

    2. Regulatory and/or statutory basis

    2.1 New Source Review (NSR)

    As one of the listed sources under the Prevention of Significant Deterioration (PSD) regulation under 40 CFR § 52.21(b)(1)(a) with potential emissions exceeding 100 tpy, the United Taconite facility is an existing major source under New Source Review regulations. This permit action changes existing limits previously taken to avoid a major modification under PSD for Air Emission Permit No. 13700113-005 in 2010. The newly proposed limits maintain that the 2010 modification would not have been a major modification if these proposed limits were taken in at that time and United Taconite does not trigger the PSD process as otherwise required by 40 CFR § 52.21(r)(4). This action is not a major modification for the change in method of operation for the changes to permit limits.

    2.2 Part 70 permit program Because potential criteria emissions from the United Taconite facility exceed 100 tpy, it is a major source under the Part 70 permit program. No changes to Part 70 applicability were made as part of this permit action.

    2.3 New Source Performance Standards (NSPS) No NSPS standards apply to the changes in the draft permit.

    2.4 National Emission Standards for Hazardous Air Pollutants (NESHAP) No NESHAP standards apply to the changes in the draft permit.

    2.5 Compliance Assurance Monitoring (CAM) For EQUI 170, the pre-control potential emissions exceed the Part 70 major source threshold for PM, it is subject to an emission limit or standard for PM from Minn. R. 7011.0715, subp. 1(A), and its control equipment, TREA 92, is necessary for compliance with the emission limit. By meeting these criteria and having post-control potential emissions below the Part 70 major source threshold for PM, EQUI 170 is an other PSEU under CAM. United Taconite is not required to submit the monitoring plan required under 40 CFR § 64.4 at this time. Under 40 CFR § 64.5(b), the CAM rules require submittals for other PSEUs as part of an application for the reissuance of a Part 70 permit. Therefore, United Taconite does not need to submit the CAM plan for TREA 92 for this permit action.

  • Technical Support Document, Permit Number: 13700113-102 Page 9 of 21

    2.6 Regulatory overview

    Table 10 below provides the regulatory overview of the project. Table 10. Regulatory overview of facility

    Subject item* Applicable regulations Rationale TFAC 1 (United Taconite LLC - Fairlane Plant)

    Minn. R. 7007.0800, subp. 2(A) & (B); Minn. R. 7009.0020–7009.0090; Minn. Stat. 116.07, subd. 4a(a)

    National Ambient Air Quality Standards and Minnesota Ambient Air Quality Standards. The draft permit contains requirements for United Taconite to conduct PM10, PM2.5, SO2, and NO2 dispersion modeling.

    Minn. R. 7007.0502 Mercury Reduction Rule. The draft permit contains certain requirements from Minn. R. 7007.0502 that apply to United Taconite regardless of the approval status of its mercury reduction plan.

    EQUI 45 (Line 1 Pellet Induration)

    Title I Condition: Avoid major modification under 40 CFR § 52.21(b)(3)(netting) and Minn. R. 7007.3000

    Prevention of Significant Deterioration. The draft permit revises limits previously taken to avoid a major modification under PSD. The change maintains the previous modification as a synthetic minor modification under PSD.

    EQUI 47 (Line 2 Pellet Induration)

    Title I Condition: Avoid major modification under 40 CFR § 52.21(b)(3)(netting) and Minn. R. 7007.3000

    Prevention of Significant Deterioration. The draft permit revises limits previously taken to avoid a major modification under PSD. The change maintains the previous modification as a synthetic minor modification under PSD.

    EQUI 208 (Space Heater (Pellet Plant, Conv 21A Head))

    Minn. R. 7011.0600–7011.0625

    Standards of Performance for Direct Heating Equipment. • Construction of the unit was on or after July 9, 1969; • The unit burns gaseous fuel; and • The facility is located outside of the Twin Cities.

    Minn. R. 7005.0100, subp. 35a Requirements for allowable fuels. Allowable fuel types that can be combusted are restricted to natural gas only, by design.

    EQUI 209 (Space Heater (Line 1, Plant, Col B1-22 Grade))

    Minn. R. 7011.0600–7011.0625

    Standards of Performance for Direct Heating Equipment. • Construction of the unit was on or after July 9, 1969; • The unit burns gaseous fuel; and • The facility is located outside of the Twin Cities.

    Minn. R. 7005.0100, subp. 35a Requirements for allowable fuels. Allowable fuel types that can be combusted are restricted to natural gas only, by design.

    TREA 13 (Fabric Filter - Donaldson-Torit)

    Title I Condition: Avoid major modification under 40 CFR § 52.21(b)(2)(i); Minn. R. 7011.0060–7011.0080

    Prevention of Significant Deterioration and Standard of Performance for Control Equipment. The draft permit contains control efficiency and other operating parameter requirements to limit PM, PM10, and PM2.5 emissions to avoid major modification classification under PSD. These limits reflect that the units have total enclosures. The draft permit specifies that replacement baghouses must meet the TREA 13 requirements.

    TREA 49 (Wet Scrubber - AAF Type N Rotoclone)

    40 CFR pt. 63, subp. RRRRR; Minn. R. 7011.8030

    National Emission Standards for Hazardous Air Pollutants: Taconite Iron Ore Processing: The draft permit resets the scrubber pressure drop and water flow rate operating parameters that United Taconite must monitor for NESHAP RRRRR.

  • Technical Support Document, Permit Number: 13700113-102 Page 10 of 21

    Subject item* Applicable regulations Rationale TREA 50 (Wet Scrubber - AAF Type N Rotoclone)

    40 CFR pt. 63, subp. RRRRR; Minn. R. 7011.8030

    National Emission Standards for Hazardous Air Pollutants: Taconite Iron Ore Processing: The draft permit resets the scrubber pressure drop and water flow rate operating parameters that United Taconite must monitor for NESHAP RRRRR.

    TREA 89 (Wet Scrubber - Ducon VV-O)

    40 CFR pt. 63, subp. RRRRR; Minn. R. 7011.8030

    National Emission Standards for Hazardous Air Pollutants: Taconite Iron Ore Processing: The draft permit resets the scrubber pressure drop operating parameter that United Taconite must monitor for NESHAP RRRRR.

    TREA 90 (Wet Scrubber - Ducon VV-O)

    40 CFR pt. 63, subp. RRRRR; Minn. R. 7011.8030

    National Emission Standards for Hazardous Air Pollutants: Taconite Iron Ore Processing: The draft permit resets the scrubber pressure drop operating parameter that United Taconite must monitor for NESHAP RRRRR.

    TREA 91 (Wet Scrubber - Ducon VV-O)

    40 CFR pt. 63, subp. RRRRR; Minn. R. 7011.8030; Minn. R. 7007.0800

    National Emission Standards for Hazardous Air Pollutants: Taconite Iron Ore Processing and Title V: The draft permit resets the scrubber pressure drop operating parameter that United Taconite must monitor for NESHAP RRRRR and Title V compliance.

    TREA 92 (Binder Unloading (Truck to Bin) Baghouse)

    Title I Condition: Avoid major modification under 40 CFR § 52.21(b)(2)(i); Minn. R. 7011.0060–7011.0080

    Prevention of Significant Deterioration and Standard of Performance for Control Equipment. The draft permit contains control efficiency and other operating parameter requirements to limit PM, PM10, and PM2.5 emissions to avoid major modification classification under PSD. These limits reflect that the units have total enclosures. The draft permit specifies that replacement baghouses must meet the TREA 92 requirements.

    *Location of the requirement in the draft permit (e.g., EQUI 1, STRU 2, etc.).

    3. Technical information 3.1 Emissions increase analysis

    3.1.1 Furnace limit change major amendment emission increases

    Attachment 4 of this TSD contains the revised Title I emissions increase calculations for the furnace limit change major amendment. These calculations show that proposed project is not a major modification under PSD. These calculations are further discussed in Section 3.1.1.1. Attachment 5 of this TSD contains the revised Title I net emissions increase lookback calculations for the furnace limit change major amendment. These calculations show that the 2010 production increase and fuel blending modification approved by Air Emission Permit No. 13700113-005 would not have been a major modification at the time if assuming the limits proposed in this permit action. These calculations are further discussed in Section 3.1.1.2

    3.1.1.1 Forward-looking emissions increases To determine the emissions increase from proposed project, United Taconite used the actual-to-projected-actual emissions increase test found in 40 CFR § 52.21(a)(2)(iv)(c). Table 4 above shows the total project emissions increase compared to the PSD significant emission rates. The baseline period for the emissions increase calculations is any consecutive 24-month period within the 10-year period immediately preceding either the date the owner or operator begins

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    actual construction of the project or the date a complete permit application is received by the MPCA, whichever is earlier. The MPCA received the initial application for this project on March 5, 2019. Upon review, the MPCA determined that the application was incomplete. United Taconite resubmitted the application, which was received by the MPCA on April 16, 2019. The MPCA determined that this application was complete. Therefore, the MPCA considers that as the date a complete permit application was received and the end of the 10-year baseline period. The baseline dates utilized for each pollutant in this permit action are shown below in Table 11. Table 11. Baseline dates

    Pollutant Baseline period PM July 2009–June 2011 PM10 July 2009–June 2011 PM2.5 July 2009–June 2011 CO March 2012–February 2014 NOx January 2016–December 2017 SO2 November 2011–October 2013 VOC December 2011–November 2013 Lead January 2011–December 2012 Fluorides October 2011–September 2013 Sulfuric acid mist November 2011–October 2013 CO2e October 2011–September 2013

    The overall approach to calculating the project emissions increase is to calculate the baseline actual emissions (BAE) using the emissions data from the 24-month periods in Table 11 above and the projected actual emissions (PAE) that are projected to be emitted in any 12-month period in the five years following the project. In the PAE calculation, emissions can be excluded as allowed by 40 CFR § 52.21(b)(41)(ii)(c). The BAE is subtracted from the PAE to determine the emission increase from the project. To calculate BAE for PM, PM10, PM2.5, CO, NOx, SO2, VOC, and lead, United Taconite used annual average emission factors applied to each calendar year for each pollutant, which are based on annual emissions inventory data. The NOx and SO2 annual emission factors were based on continuous emissions monitoring system (CEMS) data for the portion of the 10-year baseline period after installation and certification of the CEMSs. For fluorides and sulfuric acid mist, United Taconite used results of recent performance tests to establish emission factors. For greenhouse gases, United Taconite relied on published emission factors and carbon balances. These emission factors are constant throughout the entire baseline period. United Taconite calculated its PAE for this project utilizing the same set of long-term assumptions that it has for previous permit actions: one scenario of 100% annual standard pellet production split between EQUI 45 and EQUI 47 at 1,950,000 LT/yr and 4,050,000 LT/yr, respectively and another scenario of 100% flux pellet production split between EQUI 45 and EQUI 47 at 1,500,000 LT/yr and 3,511,059 LT/yr, respectively. The maximum calculated PAE for this project is associate with the 100% flux pellet production scenario. The projected operation for United Taconite has not changed since the previous permit actions so it remains an appropriate projection. United Taconite established CO, NOx, SO2, VOC, and lead PAE emission factors by scaling-up past annual average emission factors. United Taconite also ensured that the NOx and SO2 PAE did not

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    exceed the levels established by existing permit limits. For PM, PM10, and PM2.5, United Taconite took the highest 3-hour average from performance tests conducted within the baseline period. For fluorides and sulfuric acid mist, United Taconite used results of recent performance tests to establish emission factors and, for greenhouse gases, United Taconite relied on published emission factors and carbon balances. United Taconite also excluded certain emissions from its PAE determination as allowed by 40 CFR § 52.21(b)(41)(ii)(c). These excludable emissions are the portion of the PAE that an existing source could have accommodated during the 24-month period baseline period and that are unrelated to the particular project. The calculations of excludable emissions must account for permitted emission and operational limits and maximum design capacity of the existing units. For United Taconite, that means that it cannot exclude emissions attributed to pellet production that would exceed the 6,000,000-LT/yr total facility pellet production limit or the maximum annual operational capacities for either of the furnaces. To calculate the excludable emissions, United Taconite utilized pellet production records (for PM, PM10, PM2.5, and lead), heat input records (for CO and VOC), or CEMS emissions records (for NOx and SO2) for a high production month (or 30-day rolling sum in the case of NOx) within the 24-month baseline period. For all PSD pollutants, United Taconite annualized the resultant calculated maximum monthly emissions (or simply maximum emissions observed for SO2 and NOx) to represent the emissions that furnaces could have produced in a year if it were to operate at that high emission level year-round. With the restrictions on excludable emissions discussed above, United Taconite ensured that the annualized pellet production represented by these emissions did not exceed the 6,000,000 LT/yr permit limit or the maximum annual operating capacities of the furnaces. The emissions calculated from this hypothetical operation are considered could-have-accommodated emissions (CHAE). The portion of CHAE that exceeds the calculated BAE are the excludable emissions and can be subtracted from the PAE calculation. For emission factors, United Taconite utilized the same 2009–2018 emissions inventory data as it did for the BAE emission factor calculations to establish CO, NOx, SO2, VOC, and lead emission factors by conducting a statistical analysis of the annual average emission factors. For PM, PM10, and PM2.5, United Taconite utilized the same performance-test-based emission factors as it did for the PAE calculations. Fluorides, sulfuric acid mist, and greenhouse gas emission factors are the same as for the BAE calculations. United Taconite applied these emission factors over the entire baseline period when calculating CHAE. After subtracting the BAE for each pollutant from the PAE while accounting for excludable emissions, the Title I emission increase calculations summarized in Table 4 demonstrate that emissions increases from the proposed project would be below the significant emission rates (SERs) in 40 CFR § 52.21(b)(23)(i) without the need for any enforceable permit limits.

    3.1.1.2 Backward-looking emissions increases Under 40 CFR § 52.21(r)(4), the PSD rules state that any modification that would become a major modification solely due to the relaxation of an enforceable limit taken to avoid a major modification must follow the requirements found in 40 CFR § 52.21(j) through (s). In this case, United Taconite is proposing to remove the EQUI 45 and EQUI 47 operating-hour limits and PM, PM10, and PM2.5 grain-loading emission limits it assumed in 2010 to avoid a major modification and replace them with annual PM, PM10, and PM2.5 emission limits. The MPCA determined that the change needed to be evaluated under 40 CFR § 52.21(r)(4) as a potential relaxation of a limit taken to avoid a major modification under PSD. For this project,

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    United Taconite recalculated the actual-to-projected-actual emissions increase analysis it previously conducted for the 2010 project while incorporating the newly proposed limits to determine if the 2010 project would have been a major modification at that time and if it triggers 40 CFR § 52.21(r)(4). The proposed change does not affect any emission units other than EQUI 45 and EQUI 47 so those sources are not discussed in this TSD. Additionally, the proposed project only affects PM, PM10, and PM2.5 emissions so other pollutants are also not discussed in this TSD. For the 2016 project authorized by Air Emissions Permit No. 13700113-007, United Taconite calculated emission increases as part of a change in the method of operation for its two furnaces. Those PAE calculations did not rely on the operating-hour limits that are being removed in this permit action. Therefore, there is no need to conduct any backward-looking emission increase calculations for that project.

    3.1.1.2.1 2010 emissions increase at the time of Air Emission Permit No. 13700113-005 The emissions increase calculations United Taconite conducted for the 2010 project included actual-to-projected-actual emissions increases under 40 CFR § 52.21(a)(2)(iv)(c) for several existing emission units, including EQUI 45 and EQUI 47. The PAE calculations consisted of two discrete operating scenarios: Case A for 29% natural gas usage in the furnaces and Case B for no natural gas combustion in the furnaces. For both cases, the balance of the heat input would come from solid fuels. (The solid fuels allowed by the permit are coal and petroleum coke.) These two cases maximize projected emission increases and represent the projected endpoints of natural gas usage in the furnaces while maintaining annual pellet production below the 6,000,000 LT/yr-limit and all other emission increases below the respective SERs. For the EQUI 45 and EQUI 47 PAE calculations, United Taconite proposed PM, PM10, and PM2.5 grain-loading emission factors for both natural gas and solid fuel combustion, which it established based on results of past performance tests. Table 12 presents these emission factors. Table 12. 2010 project furnace emission factors

    Pollutant

    EQUI 45 emission factors (gr/dscf)

    EQUI 47 emission factors (gr/dscf)

    Solid fuel Natural gas Solid fuel Natural gas PM 0.0070 0.0041 0.0157 0.0078 PM10 0.0139 0.0082 0.0189 0.0136 PM2.5 0.0139 0.0082 0.0189 0.0136

    Using the emission factors in Table 12, the maximum stack gas flow rates for each furnace – 300,000 dscfm for the EQUI 45 stack STRU 53 and 590,000 dscfm for the combined EQUI 47 stacks STRU 15 and STRU 16 – and the 7,992-hr/yr operating-hour limits for each furnace, United Taconite calculated the PAE for each furnace, as summarized in Table 13. Table 13. 2010 project furnace PAE

    Pollutant

    EQUI 45 PAE* (tpy)

    EQUI 47 PAE* (tpy)

    Case A Case B Case A Case B PM 63.4 72.1 271.1 317.6

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    Pollutant

    EQUI 45 PAE* (tpy)

    EQUI 47 PAE* (tpy)

    Case A Case B Case A Case B PM10 125.9 143.0 351.1 382.2 PM2.5 125.9 143.0 351.1 382.2

    *The PAE calculations included a component that accounts for 200 hr/yr of natural gas combustion while the furnace grate is not moving. This amount is 0.14 tpy for EQUI 45 and 0.30 tpy for EQUI 47. United Taconite determined the BAE from emissions data in the 10-year period preceding the 2010 project. For PM, the 24-month baseline period spanned the calendar months of August 1998 through July 2000 and for PM10 and PM2.5, it spanned from October 1998 through September 2000. United Taconite also conducted a netting analysis for PM, PM10, PM2.5 emissions, which reduced the net emissions increase. The Case B emissions increases were greater for PM, PM10, PM2.5 and are summarized below in Table 14. This table shows that the PM, PM10, PM2.5 net emissions increases for the 2010 project were less than the applicable SERs. (See the TSD for Air Emission Permit No. 13700113-005 for more information on these calculations.) Table 14. 2010 project Title I emissions increase analysis

    Pollutant

    Projected actual emissions* (tpy)

    Baseline actual emissions† (tpy)

    Projected emissions increase (tpy)

    Source-wide contemporaneous increases and decreases‡ (tpy)

    Net emissions increase (tpy)

    PM 1,164.9 1,096.7 256.2 -232.1 24.1 PM10 959.5 909.4 240.5 -250.7 -10.2 PM2.5 923.3 855.4 240.5 -231.6 8.9

    *Projected actual emissions as defined in 40 CFR § 52.21(b)(41). †Baseline actual emissions as defined in 40 CFR § 52.21(b)(48). ‡Other emission changes during the contemporaneous period as defined by 40 CFR § 52.21, 40 CFR § 52.24, or 40 CFR pt. 51. For United Taconite to avoid a major modification, the MPCA set conditions in Air Emission Permit No. 13700113-005 for each furnace to operate less than or equal to 7,992 hr/yr along with emission limits set equal to the solid fuel grain-loading emission factors from Table 12. The combination of these limits restricted the furnace PAE to the Case B values in Table 13. Since the issuance of Air Emission Permit No. 13700113-005, United Taconite has conducted several performance tests on EQUI 45 and EQUI 47 that all showed compliance with these PM, PM10, and PM2.5 emission limits. United Taconite has also maintained its 12-month rolling operation below the limited number of hours for each furnace.

    3.1.1.2.2 Lookback emission increase with newly proposed limits In its 2019 major amendment application, United Taconite proposes the new PM, PM10, and PM2.5 emissions limits to be equal to the Case B PAE values shown in Table 13. Equating the newly proposed emission limits with the previously calculated PAE simplifies the lookback emissions increase analysis. The PAE for all other sources are unchanged. Because the BAE are determined from actual emissions in the 10-year period preceding the 2010 project and not the period preceding this project, the BAE are unchanged for the lookback analysis from those previously discussed. This is the case for all pollutants and

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    emission sources. Additionally, the MPCA re-analyzed the PM, PM10, and PM2.5 netting analyses conducted in 2010. Also, the baseline emissions and creditable contemporaneous emissions decreases used in the 2010 netting analysis are unchanged for the lookback analysis. The proposal does not affect the other netting analyses. The lookback emission increases and net emission increases are identical to those originally calculated for the 2010 project. The lookback net emissions increases remain less than applicable SERs had the newly proposed limits been proposed for the 2010 project. Therefore, the provisions of 40 CFR § 52.21(r)(4) do not apply. Table 5 above summarizes the lookback emissions increases calculations.

    3.1.2 Space heater replacement notification emissions increase Attachment 6 of this TSD contains the revised emission increase calculations for the space heater notification. These calculations show that proposed project is not a major modification under PSD and that the proposed project does not require a minor or moderate amendment. To calculate emissions from the new space heaters, United Taconite utilized emission factors from AP-42 Table 1.4-1 for NOx and CO from small boilers; Table 1.4-2 for PM, PM10, PM2.5, SO2, VOC, CO2, CH4, N2O, and lead; Table 1.4-3 for organic HAPs; and Table 1.4-4 for metallic HAPs. Printouts of these calculations are found in Attachment 6 of this TSD.

    3.2 Compliance with new PM, PM10, and PM2.5 emission limits

    3.2.1 Calculation method and Initial emission factors To demonstrate compliance with the proposed emission limits, United Taconite will maintain daily records of pellet production and fuel usage for each induration furnace. United Taconite will utilize these daily records to calculate monthly PM, PM10, and PM2.5 emissions according to the equation in Appendix H of the draft permit. United Taconite will use these monthly emission values to calculate the 12-month rolling sum for comparison to the permit limits. The draft permit requires United Taconite to perform this calculation by the end of each month for emissions from the previous calendar month. Generally, the MPCA will require this type of calculation to be conducted earlier in the month. However, United Taconite must take weekly fuel samples that are sent to an off-site lab to determine the fuel’s heat content among other properties. This lab analysis has an up to 3-week turnaround time so United Taconite will likely need an entire month to ensure that it has the necessary information to perform the emissions calculations. The monthly calculations in Appendix H of the draft permit allocate a percentage of the monthly pellet production to each allowed fuel type based on the monthly percent of heat input that is supplied by that fuel type. These calculations also specify different emission factors to be used depending on the fuel combusted in the furnace. In general, particulate emissions are greater when firing solid fuels than when firing natural gas. The emission factors specified in Appendix H of the draft permit are established from the results of recent performance tests for each furnace depending on fuel use. Using fuel-specific performance test results to establish emission factors produces a compliance demonstration method that will most accurately compare actual emissions to the emission limits. For EQUI 45, the natural gas PM, PM10, and PM2.5 emission factors are the 3-hour average results from the February 2019 performance test. For solid fuels, the emission factors are the 3-hour average results from the February 2018 performance test, conducted while firing a mix of coal and natural gas. Similarly, for EQUI 47 the natural gas emission factors are the 3-hour average results from the PM, PM10, and PM2.5 performance test United Taconite conducted in May 2017. For solid fuels, the PM emission factor is the 3-hour average from the most recent performance test while firing a mix of coal

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    and natural gas conducted March 2019. This test did not include condensable particulate. The PM10 and PM2.5 emission factors are the 3-hour averages from results of the April 2017 performance test, which is the most recent test to include condensable particulate while firing a mix of coal and natural gas. Because distillate oil remains an allowable fuel for the furnaces, United Taconite must account for the possibility of its use. United Taconite does not have any site-specific emissions data for firing its furnaces with distillate oil so it is unable to establish oil-specific emission factors. United Taconite intends to only burn distillate oil during times of other fuel shortages so conducting a performance test while burning only distillate oil to establish distillate oil-specific emission factors is infeasible. To be conservative, United Taconite will assume that distillate oil emission factors are equal to the solid fuel emission factors. The emission factors are shown in Table 15 below. Table 15. Furnace emission factors for compliance

    Pollutant

    EQUI 45 emission factors (lb/LT)

    EQUI 47 emission factors (lb/LT)

    Solid fuel Distillate oil Natural gas Solid fuel Distillate oil Natural gas PM 0.0573 0.0573 0.0357 0.0767 0.0767 0.0616 PM10 0.1101 0.1101 0.0631 0.1009 0.1009 0.0939 PM2.5 0.1101 0.1101 0.0631 0.1009 0.1009 0.0939

    3.2.2 Resetting emission factors

    Initially, United Taconite will use the Table 15 emission factors to calculate the PM, PM10, and PM2.5 12-month rolling sum emissions to demonstrate compliance with the proposed emission limits. However, the draft permit contains language that requires United Taconite to reset these emission factors based on the results of future performance tests. This process of resetting emission factors is considered approved replicable methodology (ARM) as defined in 40 CFR § 70.2 and Minn. R. 7007.0100, subp. 6b. The ARM language will require United Taconite to reset the emission factors after each performance test to the 3-hour average emission rate as measured during that most recent MPCA-approved performance test. Utilizing the most recent performance test results to reset the emission factors is consistent with the method used to establish the initial emission factors in Table 15. Updating the emission factors with recurring performance tests will ensure that the emissions calculations remain representative of the actual furnace emissions. The draft permit adds new requirements for United Taconite to conduct fuel-specific emission factor performance tests every three years. For each EQUI 45 and EQUI 47, United Taconite will be required to conduct PM, PM10, and PM2.5 emission factor tests while firing only natural gas every three years. United Taconite will also be required to conduct PM, PM10, and PM2.5 emission factor tests while maximizing solid fuel firing. The heat input supplied by firing only solid fuels is insufficient to operate either of the furnaces at maximum capacity so United Taconite supplies the necessary remaining heat input with natural gas. Since it is infeasible to conduct a performance test at worst-case conditions with only solid fuels, the draft permit requires United Taconite to maximize its solid fuel use during the performance test. Doing so would cause emissions that are most representative of emissions from only solid fuel firing. United Taconite is already required to conduct PM performance tests on the furnaces twice every five years by NESHAP RRRRR. United Taconite may fulfill both the newly required emission factor and NESHAP RRRRR testing requirements with a single performance test. United Taconite may do this as long as the performance test satisfies the individual obligations of both testing requirements.

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    3.3 Dispersion modeling As applicable requirements under Minn. R. 7007.0100, subp. 7(L) and 7(M), United Taconite must comply with the National Ambient Air Quality Standards (NAAQS) and Minnesota Ambient Air Quality Standards (MAAQS). In practice, the MPCA does not require a site-specific compliance demonstration of the NAAQS and MAAQS for all facilities. However, the MPCA has the authority to require a compliance demonstration such as air dispersion modeling to show that a source does not contribute to any NAAQS and/or MAAQS violations. United Taconite most recently conducted facility-wide modeling for the NAAQS and MAAQS in 2001 where it modeled PM10, NO2, and SO2 compared against the standards in place at that time. Because of this and the fact that United Taconite has significant emissions with the potential to contribute to adverse ambient air quality impacts, the MPCA is now requiring United Taconite to perform dispersion modeling. The draft permit includes requirements that address NAAQS and MAAQS modeling for the 1-hour SO2, 24-hr PM10, 24-hour and annual PM2.5, and 1-hour NO2 standards. The draft permit requires United Taconite to submit a modeling pre-protocol 45 days after the major amendment issuance, a modeling protocol 120 days after major amendment issuance, and a modeling report 60 days after MPCA approval of the modeling protocol. The pre-protocol submittal will include information on nearby sources, receptor grid placement, meteorology data, and deposition assumptions. This information submittal is intended to promote progress on the dispersion modeling demonstration and aid in developing a high quality modeling protocol. The deadline of 120 days after major amendment issuance for the modeling protocol submittal is shorter than what the MPCA generally requires. The shorter submittal deadline will ensure that the air dispersion modeling process will begin in an expeditious manner and it is important for a facility with significant stakeholder interest. The submittal deadline is also long enough to ensure that United Taconite will have adequate time to complete the modeling protocol. The results of this modeling demonstration will be incorporated into the reissued Title V permit.

    3.4 Mercury reduction plan On September 22, 2014, the MPCA adopted rules concerning mercury emissions in Minn. R. 7007.0502. These rules establish how the MPCA will achieve its mercury air emissions goal of less than 789 lb/yr from all Minnesota sources by December 31, 2025. As part of this rule, ferrous mining sources must submit a mercury reduction plan that describes how the source will reduce mercury emissions by 72%. Under Minn. R. 7007.0502, subp. 4(B), ferrous mining or processing facilities must submit this plan by December 30, 2018. United Taconite submitted its mercury reduction plan on time on December 21, 2018 and, to date, the MPCA has not yet approved the plan. The MPCA may have additional comments or questions because of reviewing the mercury reduction plan. The draft permit contemplates a need for the MPCA to request information from United Taconite to complete or supplement the mercury reduction plan under review. The draft permit requires United Taconite to respond to such information requests in the timelines provided by the MPCA within the request or within the timeframe extended in agreement with the MPCA. The contents of the approved mercury reduction plan will be included into United Taconite’s permit after MPCA approval of the plan. However, the rule in Minn. R. 7007.0502, subp. 8 which states that the owner or operator must implement the mercury reduction plan as approved by the MPCA requires United Taconite to follow its mercury reduction plan before the contents of the plan are included in the permit. Additionally, the draft permit contains certain requirements from the mercury reduction rule that United Taconite must comply with. These requirements include complying with the mercury reduction plan as approved by the MPCA by January 1, 2025, submitting annual reports, and requesting modifications to the plan.

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    3.5 Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. In evaluating the monitoring included in the permit, the MPCA considered the following:

    the likelihood of the facility violating the applicable requirements; whether add-on controls are necessary to meet the emission limits; the variability of emissions over time; the type of monitoring, process, maintenance, or control equipment data already available for the

    emission unit; the technical and economic feasibility of possible periodic monitoring methods; and the kind of monitoring found on similar units elsewhere.

    Table 16 summarizes the monitoring requirements. Table 16. Monitoring

    Subject Item* Requirement (basis)

    What is the monitoring?

    Why is this monitoring adequate?

    EQUI 45 (Line 1 Pellet Induration)

    PM ≤ 72.1 ton/yr, 12-month rolling sum PM10 ≤ 143.0 ton/yr, 12-month rolling sum PM2.5 ≤ 143.0 ton/yr, 12-month rolling sum (Title I Condition: Netting limit to avoid major PSD modification)

    Recordkeeping: daily records of pellet production and fuel usage by type; monthly emissions calculations; performance tests

    Records can be generated on a daily basis with a combination of daily manual logs and electronic monitors. A 12-month rolling sum is adequate to ensure that United Taconite remains below the limits. United Taconite will reset the emission factors used in the compliance calculations based on performance test results according to the ARM requirements in the draft permit.

    EQUI 47 (Line 2 Pellet Induration)

    PM ≤ 317.6 ton/yr, 12-month rolling sum PM10 ≤ 382.2 ton/yr, 12-month rolling sum PM2.5 ≤ 382.2 ton/yr, 12-month rolling sum (Title I Condition: Netting limit to avoid major PSD modification)

    Recordkeeping: daily records of pellet production and fuel usage by type; monthly emissions calculations; performance tests

    Records can be generated on a daily basis with a combination of daily manual logs and electronic monitors. A 12-month rolling sum is adequate to ensure that United Taconite remains below the limits. United Taconite will reset the emission factors used in the compliance calculations based on performance test results according to the ARM requirements in the draft permit.

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    Subject Item* Requirement (basis)

    What is the monitoring?

    Why is this monitoring adequate?

    EQUI 208 (Space Heater (Pellet Plant, Conv 21A Head))

    PM ≤ 0.30 gr/dscf, unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735 Opacity ≤ 20% opacity, except for one six-minute period per hour of not more than 60% opacity (MN Direct Heating Equipment Rule)

    Recordkeeping: monthly fuel records

    This unit uses natural gas only; therefore, the likelihood of violating either of the emission limits is very small. United Taconite can demonstrate that this unit will continue to operate such that emissions are well below the emission limits by only burning natural gas.

    EQUI 209 (Space Heater (Line 1, Plant, Col B1-22 Grade))

    PM ≤ 0.30 gr/dscf, unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735 Opacity ≤ 20% opacity, except for one six-minute period per hour of not more than 60% opacity (MN Direct Heating Equipment Rule)

    Recordkeeping: monthly fuel records

    This unit uses natural gas only; therefore, the likelihood of violating either of the emission limits is very small. United Taconite can demonstrate that this unit will continue to operate such that emissions are well below the emission limits by only burning natural gas.

    TREA 13 (Fabric Filter - Donaldson-Torit)

    PM ≥ 99% control efficiency PM10 ≥ 93% control efficiency Pressure Drop ≥ 0.5 and ≤ 10 in. H2O (Title I Condition: Limit to avoid major PSD modification; MN Control Equipment Rule)

    Daily and periodic inspections, pressure drop, operation and maintenance, corrective actions, and recordkeeping

    Monitoring required by the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance for both the Control Equipment Rule limits and the site-specific limit for PM2.5.

    PM2.5 ≥ 93% control efficiency (Title I Condition: Limit to avoid major PSD modification)

    TREA 49 (Wet Scrubber - AAF Type N Rotoclone)

    Pressure Drop ≥ 11.2 in. H2O, 24-hour block average Water Flow Rate ≥ 32.7 gal/min, 24-hour block average (NESHAP RRRRR)

    Performance tests, continuous pressure drop and flow rate monitoring, operation and maintenance, corrective actions, and recordkeeping

    Monitoring required by NESHAP RRRRR is adequate to demonstrate compliance with the operating limits.

    TREA 50 (Wet Scrubber - AAF Type N Rotoclone)

    Pressure Drop ≥ 11.2 in. H2O, 24-hour block average Water Flow Rate ≥ 32.7 gal/min, 24-hour block average (NESHAP RRRRR)

    Performance tests, continuous pressure drop and flow rate monitoring, operation and maintenance, corrective actions, and recordkeeping

    Monitoring required by NESHAP RRRRR is adequate to demonstrate compliance with the operating limits.

    TREA 89 (Wet Scrubber - Ducon VV-O)

    Pressure Drop ≥ 7.4 in. H2O, 24-hour block average (NESHAP RRRRR)

    Performance tests, continuous pressure drop monitoring, operation and maintenance, corrective actions, and recordkeeping

    Monitoring required by NESHAP RRRRR is adequate to demonstrate compliance with the operating limit.

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    Subject Item* Requirement (basis)

    What is the monitoring?

    Why is this monitoring adequate?

    TREA 90 (Wet Scrubber - Ducon VV-O)

    Pressure Drop ≥ 7.5 in. H2O, 24-hour block average (NESHAP RRRRR)

    Performance tests, continuous pressure drop monitoring, operation and maintenance, corrective actions, and recordkeeping

    Monitoring required by NESHAP RRRRR is adequate to demonstrate compliance with the operating limit.

    TREA 91 (Wet Scrubber - Ducon VV-O)

    Water Flow Rate ≥ 3,614 gal/min, 24-hour block average (NESHAP RRRRR)

    Performance tests, continuous flow rate monitoring, operation and maintenance, corrective actions, and recordkeeping

    Monitoring required by NESHAP RRRRR and additional monitoring based on the Minnesota Performance Standard for Control Equipment is adequate to demonstrate compliance with the operating limits.

    Water Flow Rate ≥ 3,614 gal/min, 24-hour block average (Title V)

    TREA 92 (Binder Unloading (Truck to Bin) Baghouse)

    PM ≥ 99% control efficiency PM10 ≥ 93% control efficiency Pressure Drop ≥ 0.5 and ≤ 10 in. H2O (Title I Condition: Limit to avoid major PSD modification; MN Control Equipment Rule)

    Daily and periodic inspections, pressure drop, operation and maintenance, corrective actions, and recordkeeping

    Monitoring required by the Minnesota Performance Standard for Control Equipment is adequate to have a reasonable assurance of compliance for both the Control Equipment Rule limits and the site-specific limit for PM2.5.

    PM2.5 ≥ 93% control efficiency (Title I Condition: Limit to avoid major PSD modification)

    *Location of the requirement in the draft permit (e.g., EQUI 1, STRU 2, etc.).

    3.6 Insignificant activities United Taconite has several operations that are classified as insignificant activities under the MPCA’s permitting rules. These are listed in Appendix A to the draft permit, which reflects revisions made to Minn. R. 7007.1300 promulgated since the issuance of Air Emissions Permit No. 137001137-007. This permit action removes the space heaters identified as EU 220 and EU 322 from the insignificant activity list because they have been removed from the facility. No other changes to insignificant activities were made in this permit action.

    3.7 Permit organization This permit action adds a new enforceable appendix to the draft permit that specifies the equations and values that United Taconite is to use to demonstrate compliance with the proposed EQUI 45 and EQUI 47 emission limits. These equations appear in Appendix H rather than the body of the draft permit to promote clarity as requirements in the body of the permit lack formatting ability.

    3.8 Comments received Public Notice Period: [start date]–[end date] EPA Review Period: [start date]–[end date] This section will be completed upon the conclusion of the public notice and EPA review periods.

    4. Permit fee assessment The permit action incorporates two major amendments to which fees may apply. The furnace limit change major amendment application was received on April 16, 2019 and the baghouse installation major amendment was

  • Technical Support Document, Permit Number: 13700113-102 Page 21 of 21

    received on June 5, 2019, both of which are after the effective date of the rule: July 1, 2009. Attachment 7 to this TSD contains the MPCA’s additional points calculator used to determine the permit application fee as required by Minn. R. 7002.0019. In total, the MPCA assessed an additional 40 points for this permit action. The MPCA assesses 10 additional points for limits established in the same permit action to avoid programmatic thresholds regardless of the number pollutants, the number and types of units involved and the number or types of limits imposed. This permit action changes previously existing limits to avoid a major modification under PSD from an operational basis to an emission basis. The MPCA assessed 10 points for the limits to avoid a major PSD modification. The MPCA assesses 10 additional points for each PSD pollutant for which netting analysis is conducted in one permit action, regardless of the number and types of units involved. For this permit action, the revised limits necessitated a re-evaluation of the previously conducted PM, PM10, and PM2.5 netting analyses that were performed for Air Emission Permit No. 13700113-005. The MPCA assessed a total of 30 points for the netting reviews.

    5. Conclusion Based on the information provided by United Taconite LLC - Fairlane Plant the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 13700113-102 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff members on permit team: Benjamin Wenkel, P.E. (permit engineer)

    Richard Cordes, P.E. (peer reviewer) Andy Place (compliance) Steve Palzkill (enforcement) Sarah Seelen (project manager) Beckie Olson (permit writing assistant) Joe Handtmann (administrative support)

    TEMPO360 Activities: Major Amendment (IND20190001), Major Amendment (IND20190002), Notification of Replacement of Unit (IND20190003), Reopening (IND20170003)

    Attachments: 1. Subject item inventory 2. Requirements summary 3. Notifications of compliance 4. Furnace limit change major amendment forward-looking emissions increase calculations 5. Furnace limit change major amendment backward-looking emissions increase calculations 6. Space heater replacement emissions increase calculations 7. Additional points calculator

  • Attachment 1 – Subject item inventory 

  • Agency Interest Name Subject Item ID SI Designation and Description

    United Taconite LLC -Fairlane Plant

    ACTV1NullInsignificant Activities

    AISI140099NullNull

    COMG2GP007Pellet Loadout System for Line 2after 10/13/2000 fire

    COMG3GP010Taconite MACT All Affected Sources

    COMG4GP011Taconite MACT Existing OreCrushing and Handling

    COMG5GP012Taconite MACT Existing InduratingFurnaces

    COMG6GP013Taconite MACT Existing FinishedPellet Handling

    COMG8GP016Wet Scrubber (Title VRequirements)

    COMG15GP008Replacement Pellet ReclaimScreening System

    COMG16GP014Wet Scrubbers

    COMG17GP015Baghouses

    COMG19NullBaghouses (Subject to CAM)

    COMG20 NullFluxstone Storage Building SpaceHeaters

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    COMG19NullBaghouses (Subject to CAM)

    COMG20NullFluxstone Storage Building SpaceHeaters

    COMG21NullFourth Stage Crusher PerformanceTesting

    COMG22NullFluxstone Storage Building NSPSSubpart OOO Affected Facilities

    EQUI1EU108Make-up Heater - Prod Loadout

    EQUI6EU115Conveyor 16T Discharge TransferPoint

    EQUI7EU116Conveyor 16TA Discharge TransferPoint

    EQUI9EU002Crude Ore Unloading

    EQUI11EU005Third Stage Crusher 1

    EQUI12EU006Third Stage Crusher 2

    EQUI13EU007Third Stage Crusher 3

    EQUI14EU008Third Stage Crusher 4

    EQUI15EU009Third Stage Crusher 5

    EQUI17 EU011Fourth Stage Crusher 1

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    EQUI15EU009Third Stage Crusher 5

    EQUI17EU011Fourth Stage Crusher 1

    EQUI18EU012Fourth Stage Crusher 2

    EQUI19EU013Fourth Stage Crusher 3

    EQUI20EU014Fourth Stage Crusher 4

    EQUI21EU015Fourth Stage Crusher 5

    EQUI22EU016Fourth Stage Crusher 6

    EQUI23EU017Fourth Stage Crusher 7

    EQUI24EU018Fourth Stage Crusher 8

    EQUI26EU020Transfer House North

    EQUI27EU022Transfer House South

    EQUI33EU028Limestone Storage Bins

    EQUI34EU029Additive Rail Unloading

    EQUI35 EU030Line 2 Binder Storage Bins

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    EQUI34EU029Additive Rail Unloading

    EQUI35EU030Line 2 Binder Storage Bins

    EQUI37EU032Binder Storage Bins / AdditiveMixing

    EQUI41EU036Line 2 Pellet Cooler Exhaust

    EQUI45EU040Line 1 Pellet Induration

    EQUI46EU041Line 1 Pellet Cooler Exhaust

    EQUI47EU042Line 2 Pellet Induration

    EQUI49EU051Fairlane Truck Shop Boiler

    EQUI50EU052Fairlane New Shop Boiler

    EQUI51EU053Fuel Handling Boiler #1

    EQUI52EU054Fuel Handling Boiler #2

    EQUI53EU057"A" Binder Day Bin

    EQUI55EU062"B" Binder Day Bin

    EQUI62 EU104Prod Conveyor Transfer 22S

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    EQUI55EU062"B" Binder Day Bin

    EQUI62EU104Prod Conveyor Transfer 22S

    EQUI63EU105Prod Conveyor Transfer 22N

    EQUI64EU106Prod Conveyor Transfer 23S

    EQUI65EU107Prod Conveyor Transfer 23N

    EQUI68TK001Fuel Oil Storage Tank

    EQUI69TK004Waste Oil Storage Tank

    EQUI70TK005Fuel Oil Storage Tank

    EQUI71TK006Fuel Oil Storage Tank

    EQUI72TK008Gasoline Storage Tank

    EQUI73TK003Lube Oil Storage Tank

    EQUI74TK002Antifreeze Storage Tank

    EQUI75TK007Diesel Storage Tank

    EQUI117 EU001Crude Ore Unloading Pan Feeders

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    EQUI75TK007Diesel Storage Tank

    EQUI117EU001Crude Ore Unloading Pan Feeders

    EQUI118EU004Coarse Ore Surge

    EQUI119EU010Third Stage Bins Conveyor

    EQUI120EU019Fourth Stage Trip/Bin/Convey

    EQUI121EU023#1 Rod Mill Feed

    EQUI122EU024#2 Rod Mill Feed

    EQUI123EU025#3 Rod Mill Feed

    EQUI124EU026#4 Rod Mill Feed

    EQUI125EU027#5 Rod Mill Feed

    EQUI126EU031Line 2 Binder Addition

    EQUI127EU033Line 2 Grate Feed

    EQUI128EU034Line 2 Grate Discharge

    EQUI129 EU035Line 2 Kiln Cooler Discharge

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    EQUI128EU034Line 2 Grate Discharge

    EQUI129EU035Line 2 Kiln Cooler Discharge

    EQUI130EU037Line 1 Grate Feed

    EQUI131EU038Line 1 Grate Discharge

    EQUI132EU039Line 1 Kiln Cooler Discharge

    EQUI133EU058Binder Addition to ConcentrateConveyor

    EQUI134EU109Space Heater

    EQUI136EU110Space Heater

    EQUI137EU111Space Heater

    EQUI138EU112Space Heater

    EQUI142MR001Furnace 1 NOx CEMS

    EQUI143MR002Furnace 1 SO2 CEMS

    EQUI144MR003Furnace 1 Stack Air Flow

    EQUI145 MR004Furnace 2A NOx CEMS

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    EQUI144MR003Furnace 1 Stack Air Flow

    EQUI145MR004Furnace 2A NOx CEMS

    EQUI146MR005Furnace 2A SO2 CEMS

    EQUI147MR006Furnace 2A Stack Air Flow

    EQUI148MR007Furnace 2B NOx CEMS

    EQUI149MR008Furnace 2B SO2 CEMS

    EQUI150MR009Furnace 2B Stack Air Flow

    EQUI151DA001Environmental ManagementSystem

    EQUI152EU117Make-Up Heater 1 (Fine Crusher)

    EQUI153EU118Make-Up Heater 2 (Fine Crusher)

    EQUI154EU119Make-Up Heater 3 (Fine Crusher)

    EQUI155EU120Make-Up Heater 4 (Fine Crusher)

    EQUI158EU123Make-Up Heater (Fine Ore Surge -Conveyor 3)

    EQUI159 EU124Make-Up Heater (Fine Ore Surge -Conveyor 4)

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    EQUI158

    EU123Make-Up Heater (Fine Ore Surge -Conveyor 3)

    EQUI159EU124Make-Up Heater (Fine Ore Surge -Conveyor 4)

    EQUI160EU125Make-Up Heater (Fine Ore Surge -Conveyor 5)

    EQUI162EU127Space Heater (Pellet Plant NearLine 2 Chip Mill)

    EQUI164EU129Make-Up Heater 1 (Pellet Loadout)

    EQUI165EU130Make-Up Heater 2 (Pellet Loadout)

    EQUI166EU131Make-Up Heater 3 (Pellet Loadout)

    EQUI167EU132Make-Up Heater 1 (Transfer House)

    EQUI168EU133Make-Up Heater 2 (Transfer House)

    EQUI169EU134Line 1 Kiln Drive Emergency Engine

    EQUI170EU135Binder Unloading (Truck to Bin)

    EQUI171EU136Bentonite Unloading (Truck to Bin)

    EQUI172EU137Bentonite Conveying (Bin to #5Conveyor)

    EQUI173 EU138Fluxstone Railcar SummerUnloading (Bottom Dump to CV-00..

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    EQUI172

    EU137Bentonite Conveying (Bin to #5Conveyor)

    EQUI173EU138Fluxstone Railcar SummerUnloading (Bottom Dump to CV-00..

    EQUI174EU139Fluxstone Summer Conveying(CV-001A to CV-002)

    EQUI175EU140Fluxstone Winter Conveying(CV-001B to CV-002)

    EQUI176EU141Fluxstone Conveying (CV-002 toCV-003)

    EQUI177EU142Fluxstone Transfer (CV-003 to Bin1)

    EQUI178EU143Fluxstone Transfer (CV-003 to Bin2)

    EQUI179EU144Fluxstone Transfer (Bin 1 toCV-005)

    EQUI181EU146Fluxstone Conveying (CV-003 toStockpile)

    EQUI183EU148Fluxstone Reclaiming (CV-004 toCV-005)

    EQUI184EU149Fluxstone Crusher (CV-005 to RollCrusher to CV-006)

    EQUI185EU150Space Heater 1 (Fluxstone StorageBuilding)

    EQUI186EU151Space Heater 2 (Fluxstone StorageBuilding)

    EQUI187 EU152Space Heater 3 (Fluxstone StorageBuilding)

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    EQUI186

    EU151Space Heater 2 (Fluxstone StorageBuilding)

    EQUI187EU152Space Heater 3 (Fluxstone StorageBuilding)

    EQUI188EU153Space Heater 4 (Fluxstone StorageBuilding)

    EQUI189EU154Space Heater 5 (Fluxstone StorageBuilding)

    EQUI190EU155Space Heater 6 (Fluxstone StorageBuilding)

    EQUI191EU156Space Heater 7 (Fluxstone StorageBuilding)

    EQUI192EU157Space Heater 8 (Fluxstone StorageBuilding)

    EQUI193EU158Space Heater 9 (Fluxstone StorageBuilding)

    EQUI194EU159Space Heater 10 (Fluxstone StorageBuilding)

    EQUI195EU160Space Heater 11 (Fluxstone StorageBuilding)

    EQUI196EU161Space Heater 12 (Fluxstone StorageBuilding)

    EQUI197EU162Space Heater 13 (Fluxstone StorageBuilding)

    EQUI198EU163Space Heater 14 (Fluxstone StorageBuilding)

    EQUI199 EU164Space Heater 15 (Fluxstone StorageBuilding)

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    EQUI198

    EU163Space Heater 14 (Fluxstone StorageBuilding)

    EQUI199EU164Space Heater 15 (Fluxstone StorageBuilding)

    EQUI200EU165Space Heater 16 (Fluxstone StorageBuilding)

    EQUI201EU166Space Heater 17 (Fluxstone StorageBuilding)

    EQUI202EU167Space Heater 18 (Fluxstone StorageBuilding)

    EQUI203EU168Space Heater 19 (Fluxstone StorageBuilding)

    EQUI204EU169Space Heater 20 (Fluxstone StorageBuilding)

    EQUI205EU145Fluxstone Transfer (Bin 2 toCV-005)

    EQUI206EU147Fluxstone Reclaiming (Loader toHopper)

    EQUI208NullSpace Heater (Pellet Plant, Conv21A Head)

    EQUI209NullSpace Heater (Line 1, Plant, ColB1-22 Grade)

    FUGI1FS005Coarse Ore Surge Dump

    FUGI3FS038Conveyor 3D Discharge TransferPoint

    FUGI4 FS037Conveyor 3C Discharge TransferPoint

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    FUGI3

    FS038Conveyor 3D Discharge TransferPoint

    FUGI4FS037Conveyor 3C Discharge TransferPoint

    FUGI5FS046Pellet Reclaim - Screen Prod to Belt22N/S via Belt 22X

    FUGI6FS031Line 1 Pellet Transfer (21 to 21B)

    FUGI7FS043Pellet Reclaim - Hopper/Grizzly toBelt 22Z via Hopper Conveyor Belt

    FUGI8FS041Pellet Reclaim - Pile 2 toHopper/Grizzly via Front End Load..

    FUGI9FS030Fine Ore Surge (10 to Pile Transfer)

    FUGI10FS044Pellet Reclaim - Hopper ConveyorBelt to Screen via Belt 22Z

    FUGI11FS039Conveyor 3E Discharge TransferPoint

    FUGI13FS042Pellet Reclaim - Hopper/GrizzlyOversize to Pile Transfer

    FUGI15FS032Pellet Loadout Conveyor N

    FUGI16FS040Conveyor 3F Discharge TransferPoint

    FUGI17FS014Pellet Reclaim - Screen to Belt 22(out after action)

    FUGI18 FS012Unpaved Roads - Light Truck TrafficAround Plant

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    FUGI17

    FS014Pellet Reclaim - Screen to Belt 22(out after action)

    FUGI18FS012Unpaved Roads - Light Truck TrafficAround Plant

    FUGI19FS001Unpaved Roads - Coarse Tailings toTailings Basin

    FUGI20FS033Pellet Loadout Railcar Loading

    FUGI21FS036Conveyor 3A Discharge TransferPoint

    FUGI22FS034Conveyor 2C Discharge TransferPoint

    FUGI23FS029Fine Ore Surge (9F to 10 Transfer)

    FUGI24FS002Wind Erosion - Tailings Basin(Active Area)

    FUGI25FS004Wind Erosion - ConcentrateStockpile

    FUGI26FS024Pellet Reclaim - Pocket to Pile 2(FEL)

    FUGI27FS035Conveyor 2D Discharge TransferPoint

    FUGI28FS045Pellet Reclaim - Screening

    FUGI29FS047Pellet Reclaim - Screen Fines toStockpile (via Belt 22Y) Transfer

    FUGI30 FS048Pellet Reclaim - Screen Oversize toStockpile (via Chute) Transfer

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    FUGI29

    FS047Pellet Reclaim - Screen Fines toStockpile (via Belt 22Y) Transfer

    FUGI30FS048Pellet Reclaim - Screen Oversize toStockpile (via Chute) Transfer

    FUGI31FS049Concentrate Reclaim - ScreenOversize to Stockpile (via Belt 31B..

    FUGI32FS050Wind Erosion - Concentrate ReclaimScreen Oversize Stockpile

    FUGI33FS051Line 1 Pellet Transfer (21B to22N/S)

    FUGI34FS052Unpaved Roads - Solid Fuel Trucks

    FUGI35FS053Fluxstone Railcar Winter Unloading(Railcar to Hopper)

    FUGI36FS054Fluxstone Railcar Winter Unloading(Hopper to CV-001B)

    FUGI37FS056Unpaved Roads - Trucks HaulingConcentrate

    FUGI38FS057Paved Roads - Trucks HaulingConcentrate

    STRU1SV117Fluxstone Railcar Unloading andConveying

    STRU2SV118Fluxstone Conveying (CV-005 toCrusher to CV-006)

    STRU4SV070Line 2 Cooler Discharge

    STRU6 SV097Line 1 Stack Cap

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    STRU4SV070Line 2 Cooler Discharge

    STRU6SV097Line 1 Stack Cap

    STRU7SV098Line 2 Stack Cap

    STRU8SV107Truck Shop Boiler

    STRU9SV108New Shop Boiler

    STRU10SV109Fuel Handling Boiler #1

    STRU11SV110Fuel Handling Boiler #2

    STRU12SV058"B" Binder Day Bin

    STRU13SV057"A" Binder Day Bin

    STRU14SV050Line 2 Cooler Discharge / VibratingFeeders

    STRU15SV049Line 2 Pellet Induration

    STRU16SV048Line 2 Pellet Induration

    STRU17SV044Line 1 Grate Discharge

    STRU18 SV043Line 1 Grate Feed

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    STRU17SV044Line 1 Grate Discharge

    STRU18SV043Line 1 Grate Feed

    STRU19SV042Line 2 Cooler Exhaust

    STRU20SV041Line 2 Cooler Discharge

    STRU21SV040Line 2 Grate Discharge

    STRU22SV039Line 2 Grate Feed

    STRU23SV037Line 2 Binder Addition

    STRU24SV036Line 2 Binder Storage Bins

    STRU25SV035Additive Rail Unloading

    STRU26SV033#5 Rod Mill Feed

    STRU27SV032#4 Rod Mill Feed

    STRU28SV031#3 Rod Mill Feed

    STRU29SV030#2 Rod Mill Feed

    STRU30 SV029#1 Rod Mill Feed

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    STRU29SV030#2 Rod Mill Feed

    STRU30SV029#1 Rod Mill Feed

    STRU31SV028Transfer House South

    STRU32SV026Transfer House North

    STRU33SV025Fourth Stage Trip/Bin/Convey

    STRU34SV024Fourth Stage Crusher 8

    STRU35SV023Fourth Stage Crusher 7

    STRU36SV022Fourth Stage Crusher 6

    STRU37SV020Fourth Stage Crusher 4

    STRU38SV019Fourth Stage Crusher 3

    STRU39SV018Fourth Stage Crusher 2

    STRU40SV017Fourth Stage Crusher 1

    STRU41SV016Third Stage Bins Conveyor

    STRU42 SV015Third Stage Crusher 5

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    STRU41SV016Third Stage Bins Conveyor

    STRU42SV015Third Stage Crusher 5

    STRU43SV014Third Stage Crusher 4

    STRU44SV013Third Stage Crusher 3

    STRU45SV011Third Stage Crusher 1

    STRU46SV010Coarse Ore Surge

    STRU47SV009Crude Ore Unloading

    STRU48SV008Crude Ore Unloading

    STRU49SV007Crude Ore Unloading Pan Feeders

    STRU50SV063Pellet Loadout Bin 3 Vent

    STRU51SV045Line 1 Cooler Exhaust - CE 055 only

    STRU52SV047Line 1 Cooler Exhaust

    STRU53SV046Line 1 Pellet Induration

    STRU57 SV021Fourth Stage Crusher 5

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    STRU53SV046Line 1 Pellet Induration

    STRU57SV021Fourth Stage Crusher 5

    STRU58SV012Third Stage Crusher 2

    STRU59SV116Cooler Dump Zone - CE 065 only

    STRU60SV114Space heater vent

    STRU61SV115Space heater vent

    STRU62SV111Pellet product bins

    STRU63SV112Space heater vent

    STRU64SV113Space heater vent

    STRU66BG001General Office

    STRU67BG002Crude Ore Unloading

    STRU68BG003Coarse Ore Surge

    STRU69BG004Truck Shop

    STRU70 BG005Fines Crushing (3rd & 4th StageCrushers)

    List of SIs

    Agency Interest: United Taconite LLC - Fairlane PlantAgency Interest ID: 140099Activity: IND20190002 (Major Amendment)

    Details for:SI Category: NoneSI Type: All

  • Agency Interest Name Subject Item ID SI Designation and DescriptionUnited Taconite LLC -Fairlane Plant

    STRU69BG004Truck Shop

    STRU70BG005Fines Crush