Explore, enjoy and protect the planet

Mining without Harm - Mesabi Nugget Draft Air Permit - Comments

Mining Without Harm Campaign
Sierra Club North Star Chapter
c/o Clyde Hanson
4038 Cascade Beach Road
Lutsen, MN 55612
(218) 387-9081

June 13, 2005

Commissioner Sheryl Corrigan
c/o Mr. Dick Cordes
Minnesota Pollution Control Agency
520 Lafayette Rd. North
St. Paul, MN 55155
Via Fax and email only

Re: PSD/Title V Permit MN13700318-001, Mesabi Nugget, LLC Erie Nugget Plant
Petition for MPCA Citizens' Board Review and withdrawal, modification and
re-notice of draft permit

Dear Commissioner Corrigan,

Here are the official comments of the Sierra Club's 20,000 Minnesota members on the proposed Mesabi Nugget rotary furnace iron making facility in Hoyt Lakes. We would like the MPCA to respond specifically and in detail to each comment and to make significant changes in the draft permit to assure the air emission do not harm workers, neighbors, people downwind and the natural environment including the BWCAW and Voyagers and Isle Royale National Parks. In light of the significant changes needed to the permit and supporting analysis, the Sierra Club requests that the permit be withdrawn, modified and re-noticed with a new public comment period. This would be faster for the project proposer than a potential administrative appeal to the EPA Environmental Appeal Board.

We formally request that the Minnesota Pollution Control Agency (MPCA) Citizens' Board hold a hearing to address the concerns raised during the public comment period on the Mesabi Nugget, LLC Erie Nugget facility (herein, "Mesabi Nugget"), adopt the changes to the draft air permit and address the concerns weve highlighted in our comments. The significant potential environmental impacts of this facility warrant a Citizens' Board meeting. The month-long comment period has not been sufficient to address concerns that will have lasting impacts on Minnesota's environment and quality of life.

Our Mining With Out Harm Campaign has the goal of protecting the health of people and the quality of our state's lakes, streams and wildlife from mining pollution. Dangerous types of mining and mineral processing new to Minnesota are proposed in the Superior National Forest south of Ely. Theyll spew acid, toxic metals and mercury into our clean air and waters. Habitats vital to fishing, hunting, Duluth's water supply and Lake Superior fisheries would be at risk. Arrowhead citizens are working together to protect the headwaters of the St. Louis River and the people at risk of pollution caused- sickness by asking the government and industry for Mining Without Harm.

For the record, the Sierra Club objects to the waiver by special legislation of an otherwise mandatory environmental impact statement for this new, unproven technology at a site in an area of pristine air and water quality. This is exactly the type of project for which science should be husbanded to inform decision-makers of the broad impacts of the project before specific permit decisions are made. New pollutants for which government has not adopted specific laws or rules are examples of information which the public will now not know because of the waiver. Now every new polluting facility will buy a waiver of an EIS with high priced lobbyists, campaign contributions, and donations to local communities.

The legislative exemption for the environmental review process does not change the responsibility of the Minnesota Pollution Control Agency to realize its mission: "The mission of the Minnesota Pollution Control Agency (MPCA) is to protect Minnesota's environment to secure the quality of life of its citizens. To accomplish this mission, the agency works to provide: clean and clear air, fishable and swimmable lakes and rivers, uncontaminated ground water and land, and sustainable ecosystems."[1]

General Comments

Environmental Review — What impact would have environmental review (an EIS) uncovered about this project? Related expansions at power plants and taconite plants (North Shore Mining)? Alternative sites, technologies, modified designs, modified scale, and alternatives incorporating reasonable mitigation measures identified from public comments? Social, environmental, economic, employment impacts? Community and land use impacts? Wildlife and ecological baselines? Please summarize the environmental impacts not analyzed by the air and water permits process.
MPCA Commitment to Legislature for a 45 Day Public Review Period Violated — During the legislative hearings for Mesabi Nugget, the MPCA staff tempered legislators' concerns regarding the pollution from this facility with a promise of a full 45-day public comment period; however, in reality, the MPCA chose to offer only 30 days, and denied several extension requests. This facility is legislatively exempted from formal environmental review, and utilizes a new technology which has not been proven in full-scale. In addition, it has the potential to be the 8^th largest mercury emitter in the state, has virtually no controls for nitrogen oxide, and due to the nature of the combustion process produces large amounts of other pollution. In the public meeting, MPCA staff soothed the public by highlighting a decrease in pollution compared to the former site occupant. What MPCA failed to add is that during legislative hearings MPCA staff called LTV one of the dirtiest facilities in Minnesota. LTV also employed significantly more people and produced more output. All of this is to say, the fast track provided to Mesabi Nugget did not deny the public the full comment period needed to address the reality of Mesabi Nugget's impact on the environment and public health. The administrative record was very large, the limited time to made technical analysis a challenge, and we only had two weeks after the public meeting to prepare our comments. The agency has had months to review the complex application for a new technology.
Financial Assurance — $5 million letter of credit (LOC) is not enough to operate the wastewater treatment plant for decades, clean up toxic waste on-site, and reclaim the tailings ponds to their post-mining use. LTV went bankrupt on same site with no LOC in force and the taxpayers of Minnesota had to pay dearly. DNR dropped the ball. The Financial assurance should be increased to $10 million and an inflation clause added to the permit. This is a risky new venture that is undercapitalized and as a separate LLC will not be backed by the assets of its owners. The water discharge from the tailings ponds will exceed water pollution standards if the wastewater treatment plant is not operating.
Required Expertise Lacking in MPCA — A retired MPCA employee has informed the Sierra Club that the MPCA does not currently employ any engineers certified in metallurgy. Yet there is no evidence that any outside consulting engineers with the necessary specialized credentials reviewed the process design and RHF emissions. The permit must not be issued until qualified experts review the pollution potential of the project and their findings made public and public comments received and reviewed. Not to do so would violate professional standards and the public interest.
Environmental Justice — The permit and its record do not show any analysis of environmental justice issues for this permit. Please document that low income or minority communities are not going to be disproportionately impacted by the pollution of the proposed plant. This includes wild rice lakes, subsistence fishing and hunting in areas where Native American Tribes have retained such rights.
Agency Pre-Decisional Bias Demonstrated — The agency has demonstrated a pre-decisional bias in favor of the project proposer in publications such as its magazine. MPCA: "What looks like a satellite from a science fiction movie is really Mesabi Nugget's new rotary hearth furnace. Capable of churning out high-quality iron nuggets at less cost and with fewer air emissions, this technology is a good example of an innovation that is good for the environment as well as helping a company compete in the global economy." (Minnesota Environment, Winter 2004) In light of this bias, the EPA should be making this permit decision.
Key Engineering Data Withheld from Public — The scale up and lack of analysis risks not adequately determining the pollution from the facility because turbulence (one of the three Ts for combustion) is variable in an RHF of any size and there are problems with scale up and turbulence. Incomplete combustion could result in increased pollution including VOCs, PMs, dioxins, etc. The worst case scenarios of pollution potential are being kept from the public as "proprietary information." We cannot comment adequately on this permit without access to the engineering analysis of the RHF. We requested this data but it was not made available.
Best Available Control Technologies (BACT) Required for More Toxic Emissions — The permit and permit record do not address the Great Lakes Toxic Substances Control Agreement and how the draft permit follows its terms and conditions. A copy is attached. Minnesota is a signatory. The agreement regulates and requires BACT for mercury, alkylated lead compounds, total polychlorinated Biphenyl, heachlorobenzene, benzo-a-prene, 2,3,7,8-terachlordibenzo-p-dioxin, and 2,3,7,8 tetrachlordibernofuran in all new air permits. It applies to the Mesabi Nugget permit and the draft permit does not have BACT for several of these toxic pollutants. The agreement is also available at: http://www.sagady.com/stuff/GLStateAirPermittingAgreement.pdf
Asbestos-like Fiber Controls Needed — The permit and permit record do not address the asbestos-like fibers in taconite concentrate which would be emitted into the air through shipping and handling and processing in the pulverizer. The permit seems to be applying only visual standards to fugitive dust, when in fact this dust has significant health risks related to lung disease of workers, neighbors and down wind communities. The permit needs to control mineral fibers in transport and during processing.
Best Available Control Technology — The BACT analysis for Mesabi Nugget is insufficient and must be reevaluated before issuing an air permit.

BACT Not Required For SO2 Emissions From The RHF
The permit limits SO2 emissions from the RHF to 123 lbs/hr based on a 3-hr block average. The BACT analysis concluded this emission limit was BACT by evaluating four technologies scrubbers, wet electrostatic precipitator ("wet ESP"), spray dryer absorption, and sorbent injection. The SO2 BACT analysis is flawed because it failed to evaluate all SO2 control technologies, failed to evaluate combinations of technologies, failed to evaluate the highest removal efficiency, failed to conduct an environmental impacts analysis, and failed to include a percent reduction. These issues are discussed below.
1. SO2 BACT Analysis Failed To Evaluate All Control Technologies
  The BACT analysis evaluated a generic "wet scrubber" that was reported to be capable of 90% to 95% SO2 control. The BACT analysis selected the lower end of this control range based on pilot plant tests because the nugget process is a new technology. However, while the iron making process itself may be relatively new, the flues gases and proposed control technologies are not. Thus, deference should not be accorded to the lower end of the control range. Also, the record is silent on whether the pilot plant scrubber was selected to meet a target SO2 reduction of 90%, as suggested by the record, or whether the pilot plant scrubber was optimized to achieve the emission limit based on the maximum degree of reduction, as required for BACT. Finally, the MPCA should analyze requiring Mesabi Nugget to decrease the sulfur content in their coal. The current commitment by Mesabi Nugget to use 1.0% sulfur content coal does not do enough to reduce SO2 in light of the fact that Weston coal plant in north central Wisconsin utilitizes .3% and other coals have .19% sulfur content.
  
  There are a number of different SO2 scrubbing technologies, each of which is a distinct technology with its own SO2 removal range. The BACT analysis does not identify the specific technology assumed.[2]
  The first step in the top-down BACT process is to identify all available control options. NSR Manual, Sec. III.A. The applicant identified four SO₂control technologies which it ranked according to control efficiency for the class. However, these classes contain a number of separate and distinguishable control technologies that are individually able to achieve higher SO₂ removal efficiencies than 95%, the upper end of the range that was evaluated.
  
  Wet flue gas desulfurization ("WFGD") or "scrubbing" is a term of art for a class of SO₂ control technologies that scrubs the flue gas with a slurry of lime or limestone. This class includes a number of processes, some of which have SO₂ removal efficiencies of over 95% for similar flue gases. The processes that have demonstrated greater than 95% SO₂ removal are the magnesium enhanced lime ("MEL") FGD process[3] and the Chiyoda CT-121 bubbling jet reactor.[4]^,[5] Further, design enhancements and additives are available that can increase removal efficiencies above 98% for other technologies within this general class. [6]
2. Combinations Of Control Technologies Not Evaluated
  The NSR Manual notes that "combinations of techniques should be considered to the extent they result in more effective means of achieving stringent emissions levels represented by the 'top' alternative, particularly if the 'top' alternative is eliminated." (NSR Manual, p. B.17.) Similarly, the NSR Manual notes that "[c]ombinations of inherently lower-polluting processes/practices (or a process made to be inherently less polluting) and add-on controls are likely to yield more effective means of emissions control than either approach alone… These combinations should be identified in step 1 of the top down process for evaluation in subsequent steps." (NSR Manual, p. B.14.)
  
  The BACT analysis for SO₂, sulfuric acid mist, and PM/PM10 did not identify combinations of techniques to control these pollutants. Much lower emission limits and higher control efficiencies could be met by using combinations of the four control technologies that were evaluated for these pollutants. For example, the use of a wet scrubber followed by a wet FGD would remove far more of the SO2, sulfuric acid mist, and PM/PM10 than the wet FGD selected as BACT. This combination has been selected as BACT for two coal-fired power plants fired with high sulfur bituminous coals with similar flue gas composition, Prairie State, Illinois and Thoroughbred, Kentucky.
3. Control Efficiency Not Stated In Permit
  The BACT limit must be met continuously at all levels of operation. NSR Manual, p. B.56. The proposed limit was based on a scrubber SO2 control efficiency of 90%. BACT Analysis, p. 21, Table 3. The TSD acknowledges that the scrubber should be operated well at all times. TSD, p. 15. However, the draft permit defers establishing the scrubber control efficiency to a future optimization study. TSD, p. 16, Permit, p. A-26. Because the optimization study will set part of the BACT limit, it is subject to the public notice, review, and appeal provisions of the PSD program. The permit should be revised to clarify this point.
BACT Not Required For NOx Emissions From The RHF
The most effective control technology, post-scrubber SCR, was eliminated as not cost effective at about $11,000 per ton because it exceeded the MN cost guidelines. TSD, p. 18. The MPCA does not point to any specific guidance on cost effectiveness. However, in another case, the MPCA states that costs less than $8000/ton were not cost prohibitive, anything between $8000/ton to $12,000/ton was to be decided on a case by case basis, and anything greater than $12,000 was cost prohibitive.[7] The MPCA does not explain why a cost effectiveness of about $11,000/ton in the Mesabi case is not cost effective. The applicants BACT analysis argues that it would result in an adverse economic impact on the applicant, i.e., make the cost of iron nugget uncompetitive. BACT Analysis, pp. 61-62. However, this is not a valid reason to reject the top technology. The MPCA should explain why in this case about $11,000/ton is not cost effective within the framework of BACT, which requires consideration of the cost per ton of pollution removed, not economic impact on the applicant, or require post scrubber SCR as BACT.

Regardless, the applicant overestimated the cost effectiveness of a post-scrubber SCR, which is outside of the range of costs of an SCR system. The MPCA should carefully scrutinize the proffered costs. Some of the items that appear to be overstated include:
1. The cost of reheating the gas stream appears to be overstated but cannot be verified as the BACT analysis does not contain adequate support, including vendor quotes and design basis (e.g., specific reheat device that would be used, increase in gas temperature assumed, firing rate of reheat device). Further, the latent heat of the gas stream upstream of the scrubber can be used for reheat. This option does not appear to have been evaluated.
2. The cost effectiveness analysis estimates sales taxes as 6.5% of the purchased equipment (PE) cost. Pollution control systems are normally exempt from sales taxes.
3. There is no disposal costs for spent SCR catalyst, as the catalyst is returned to the vendor.
4. Overhead is estimated as 60% of maintenance parts and labor costs. However, SCR systems are comparatively simple pollution control systems consisting of few components and moving parts that require maintenance. Therefore, they require very little maintenance. Based on discussions with SCR vendors, overhead should be nominal, no more than 10% of maintenance parts and labor.
5. The engineering/supervision and construction/field expenses are both estimated as 10% of the PE, based on the OAQPS Manual. However, as noted above, SCR systems are relatively simple compared to most pollution control systems. Thus, they are inexpensive to engineer and build. Costs to design and construct an SCR is typically no more than 5% of the PEC each.
6. Piping is estimated as 4% of the PE. The OAQPS Manual that the applicant relied on indicates piping for every pollution control system except gas absorbers ranges from 1% to 2% of the PE. [8] Because very little piping is required for an SCR system, piping should be estimated at no more than 1% of the PE.
7. The life of the SCR catalyst is assumed to be 3 years, which is a typical guaranteed lifetime. The service life, not the guarantee life, should be used in cost-effectiveness analyses. It is well known that SCR catalysts last substantially longer then the vendor guarantee. SCR catalyst life at coal-fired boilers ranges from 8 to 14 years and averages about 9 years. The high particulate and sulfur loading in coal-fired boilers is similar to or more severe than conditions present in reheat furnace exhaust.
8. Indirect operating costs were estimated as a percent of the capital costs, comprising 1% for taxes, 1% for insurance, and 2% for administration. This is excessive for the proposed SCR system. Administration costs for ductwork and a stationary steel frame filled with blocks of catalyst is very small. There is simply nothing to administer. These costs are more commonly estimated as 20% to 30% of operating labor for all three combined. (Peters and Timmerhaus 1991, pp. 206-207.) Property taxes vary by location, and, normally, pollution control equipment is exempt.
BACT Not Required For PM/PM10 Emissions From The RHF
The BACT analysis concluded that the wet scrubber and wet ESP could both remove 98% of the PM/PM10 emissions. The wet scrubber was selected because its cost effectiveness was lower, $671/ton compared to $1717/ton. BACT Review 5/05, p. 86. However, the BACT analysis failed to evaluate environmental impacts of these two options, as required in the top down process. NSR Manual, Sec. IV.D.3. The BACT analysis did not evaluate the environmental impacts of the wet scrubber for SO2, sulfuric acid mist or PM/PM10. The scrubber generates waste streams that require disposal, requires import of raw materials, lime or limestone, and produces a wet, visible plume. Mining of the lime or limestone, for example, may adversely impact sensitive species, and emits diesel exhaust, a potent carcinogen. These adverse impacts associated with the scrubber support the selection of wet ESP.
BACT Not Required For PM/PM10 Emissions From The Cooling Tower
The BACT emission limit for the cooling tower is based on a drift rate of 0.001% and circulating water TDS of 194,000 ppm. Permit, p. A-7. Cooling towers are routinely permitted to achieve a drift rate 0.0005%.

Staff at Brentwood Industries, a major supplier of drift eliminators for cooling towers, stated that single layers of drift eliminators typically achieve drift rates of 0.001% and 0.005% for cellular and blade type designs, respectively. Lower drift rates require the in-series installation of two layers of drift eliminators, usually of the cellular type. The double layer type tower is routinely guaranteed to achieve drift rates as low as 0.0005%.

The BACT analysis also did not establish a limit for PM/PM10 emissions from the cooling tower, but rather a technology standard. This is not consistent with the definition of BACT, which is an "emissions limitation" unless there are "technological or economic limitations on the application of measurement methodology to a particular emissions unit" that "would make the imposition of an emissions standard infeasible." (40 C.F.R 52.21(b)(12).)

This is not the case here. PM/PM10 emission limits are routinely specified in BACT analyses and permits for cooling towers. The Permit should be modified to establish an emission limit for PM/PM10 from the cooling tower and to require compliance testing, to include TDS in the circulating water, circulating water flow rate, and drift rate.
The Permit Does Not Assure Continuous Compliance and Protect Short-Term Ambient Air Quality Standards
BACT emission limits must be met on a continual basis at all levels of operation and protect short-term ambient air quality standards. NSR Manual, p. B.56. This requires that the BACT emission limits be expressed two ways as a concentration (ppm, gr/dscf, lb/MMBtu) and as a mass emission rate (lb/hr, ton/yr). See also NSR Manual at at H.5 ("it is best to express the emission limits in two different ways, with one value serving as an emissions cap (e.g., lbs/hr) and the other ensuring continuous compliance at any operating capacity (e.g., lbs/MMBtu). The permit writer should keep in mind that the source must comply with both values to demonstrate compliance."); H.10, I.2,I.4.

The BACT limits in the draft permit are expressed only one way, either as a concentration or an emission rate but not both. For example, the PM10 BACT limit for the RHF is 0.015 gr/dscf at 7% oxygen. The permit does not contain an emission rate in lbs/hr. Similarly, the fluoride and sulfuric acid mist BACT limits for the RHF are expressed only in lbs/hr and thus do not require continuous compliance.
BACT Limits Not Set For All Emission Units And Pollutants
The permit does not establish BACT limits for the following: (1) NOx, CO, VOC, and SO2 emissions from the three green ball dryers; (2) NOx, CO, VOC, and SO2 emissions from the product separator/dryer; (3) NOx, CO, VOC, and SO2 emissions for the coal pulverizer and flux pulverizer dryers; (4) PM/PM10, NOx, CO, VOC, and SO2 emissions from the ore dryer; (5) PM/PM10 emissions from the cooling tower.

BACT Conclusion:

Class I Air (Pristine Air over National Parks and Wilderness Areas not protected — "The MPCA believes no further analysis is needed to ensure that the Class I PSD increments are protected." The U.S. Forest Service disagrees with this conclusion in their June 10, 2005 letter to MPCA which calls the impacts "adverse." The FLM goes on to propose acid rain emissions trading as a possible mitigation. Three pollutants exceed the thresholds including SO2 and PM10 SILs (significant impact levels) and significant visibility impacts of 5%-10% in the BWCAW. The excuse is that the LTV taconite plant has closed. P 29. The applicant performed the modeling. Following FLM guidance, the applicant modeled visibility impacts at the BWCAW, Voyageurs National Park, and Isle Royale National Park. Using the existing background, impacts surpassing the five percent level were noted at the BWCAW and at Voyageurs National Park.9 The maximum impact of ten percent was noted at the BWCA. The maximum impact at Voyageurs National Park was about five percent. P 30 The applicant also modeled using an estimate that represented a pristine background. As expected, these modeling results indicated more visibility impairment; impacts surpassing the five percent level were noted at all three Class I areas. Again, the maximum impact nearly thirty percent was identified at the BWCA. Yet no haze limits are mentioned in the technical supplement. Some intrastate agency is promising a plan by 2008. But haze limits are needed now for this new source.

Sulfur and nitrogen depositionagain the closing of LTV solves all problems (see 9 below) but it is not clear if the modeling was from the last regional actual study or the pristine baseline. P 30. Voyagers Park exceeds "green line limits." The analysis needs to be re-done and the permit changed to protect the Class I area air.
LTV plant closure incorrectly used to off-set new pollution from Mesabi Nugget — The state law exempting this proposed project from environmental review clearly states that, "The shutdown of these (LTV Taconite Furnaces) shall not be creditable in calculating the 'emissions increase' as defined in the Code of Federal Regulations, title 40, section 52.21, for this project" (MN session laws 2004, Chapter 220). The draft permit violates this state law by including off-sets of the closing of the LTV taconite plant in its analysis of Class I, Class II and criteria pollutant and BACT analyses.
Cumulative Air Pollution Impact Analysis — The Sierra Club agrees with the U.S. Forest Service that a NE Minnesota regional cumulative air pollution impact analysis is needed to prevent with future increment problems. The large number of major polluting industrial developments pending on the iron range multiplies the impact of this permit. This is important for both air quality and economic development decisions.
Minnesota Environmental Policy Act (MEPA) Violated — The draft permit should not be issued because it would violate the Minnesota Environmental Policy Act (MEPA), which states that no permit may be issued where such permit "is likely to cause pollution, impairment, or destruction of the air, water, land or other natural resources located within the state, so long as there is a feasible and prudent alternative consistent with the reasonable requirements of the public health, safety, and welfare and the state's paramount concern for the protection of its air, water, land and other natural resources from pollution, impairment, or destruction. Economic considerations alone shall not justify such conduct." Minn. Stat. 116D.04(6).[9] In this situation, both not permitting the plant and requiring the plant to treat its emissions to reduce NOX, SO2 and mercury are feasible and prudent alternatives that are "consistent with the reasonable requirements of the public health, safety, and welfare and the state's paramount concern for the protection of its air, water, land and other natural resources from pollution, impairment, or destruction."

Given MEPA's prohibition on justifying pollution based on "economic considerations alone," this attempt to transform an issue of economic feasibility into one of technical feasibility is not acceptable. In any event, even if treatment were technically infeasible, the permit and support documents provide little support for a determination that there is not a "feasible and prudent alternative consistent with the reasonable requirements of the public health, safety, and welfare and the state's paramount concern for the protection of its air, water, land and other natural resources from pollution, impairment, or destruction."

Permit Comments by Page in Draft Permit

Construction authorization in the permit should expire in six months, as this project was exempted from an EIS because it was being fast-tracked. If the project would be delayed any longer by the proposer, the permits must be terminated, as the reasons for the exemption would not longer apply. This would allow a more full and careful review of the environmental impacts of this novel facility. The state EIS exemption law is silent on the construction authorization schedule so the agency still has discretion in this matter.
Particulate matter ambient monitors must be required to be installed and operated for at least the first five years of operation. This needed to establish a solid baseline as this novel process is changed by the permittee and to prove to the breathing public that the plant is not harming them and that the plant is in compliance. The location and number of monitors should include nearby communities and the BWCAW. The monitors must be able to measure PM 2.5 on a continuous basis. Monitoring data should be published in real time on the AQI a public web site operated by the permittee or the PCA like http://aqi.pca.state.mn.us/hourly/index.cfm
Preconstruction monitoring should be required before the permit is issued. Without a local baseline, the impacts of the proposed plant on air quality cannot be accurately determined.
"Parameters Used in Modeling: Stack heights, emission rates, and other parameters used in the modeling for this permit (13700318-001) are listed in Appendix B of this permit. The Permittee must submit to the Commissioner for approval any revisions of these parameters and must wait for a written approval before making such changes." These proposed changes should be listed on the PCA web site as they are received for public notice and comment.
Clean Unit Status: The Sierra Club is opposed to granting the project proposer what is essentially a waiver (EXPAND)

"Notification of the Initial Performance Test Trigger Date: Not more than 15 days after the Initial Performance Test Trigger Date, the Permittee shall notify the Agency of the Initial Performance Test Trigger Date." The public and news media should be notified of this date and the permit should require such notification.

The public and media should be notified of pollution control equipment breakdowns and performance failures and the permit should require this disclosure as they happen.
"Deviations Endangering Human Health or the Environment" — the permit needs to list some examples of project specific deviations that would trigger this requirement. The permittee should be required to notify local public safety officials and the media immediately so action can be taken to minimize the health impacts.

Any future facility modifications that increase the product or pollution output of the proposed facility need full public notice and comment periods.
Mercury Reduction Efforts, pgs. A-4 - A-5: The Sierra Club requests the MPCA make a change on A-5 from "Conduct a performance test for mercury at least 60 days after but not more than 180 after implementing the selected option to achieve a 50% reduction in baseline mercury emissions." to "achieve at least 50% reductions in baseline mercury emissions."

[10]

A) The Sierra Club requests the MPCA require the best control process for Mesabi Nugget in establishing the baseline for achieving the mercury reductions or provide documentation of engineering analysis which rules out this option.

[11]

B) The Sierra Club requests the MPCA establishes an accountable and enforceable mercury reduction effort for Mesabi Nugget that includes an opportunity for public comment.

^th

[12]

[13]

[14]

C)Mercury emissions are subject to case-by-case Maximum Achievable Control Technology (MACT) limits and MACT analysis must be done before the permit is issued.

[15]

Maximum Achievable Control Technology Determination,

It is not reasonable to delay the mercury reduction feasibility report until 18 months after the plant has produced 200,000 tons of product. The state law on this project does not grant a delay in the delivery in the delivery of the lowest mercury emissions reasonably possible. The state law states: "(d) The Pollution Control Agency shall strive in the permitting process to assure the lowest mercury emissions reasonably possible." Months for the plant to get its first 200,000 tons produced, plus 18 months for planning (given in the draft permit) plus agency review time plus design and construction time, plus up 180 months for performance testing would add up to a four year delay. That is not a reasonable pace. A reasonable and lawful pace would be to have the report done before the air and water permits are issued. The law clearly states in the permitting process and does not allow any delays until after the permit is issued as asserted by the draft permit.

The permit must be revised to provide for public notice and comment on the mercury report as it is a major revision of the air permit. The State on Indiana provided for public participation in permit modifications for the iron nugget plant proposed for Auburn Nugget in Butler Indiana. (the Indiana permit can be found at: http://oaqpermits.in.gov/19475p.pdf.)

The pressure drop calibration range of 2X the performance standard is too wide. The calibration range must always accurately measure the pollution criteria.

The permit should specify that at least once a year a simultaneous sampling of all pollutants at all locations should be made and reported, so that there is clear evidence that the permittee is not manipulating the sampling to optimize reduction of one pollutant at a time through operational or input changes that are not part of normal operations. This is especially critical for new technologies like this proposed iron furnace.
Optimization study of wet scrubbers gives MPCA another opportunity to change the permit without public comment. This applies to fluoride and sulfuric acid mist, removal too. The results of the optimization study should be put on public notice and public comments accepted. And there should be a set emission limit for scrubber performance under which the limits will not be lowered.

Fugitive dust emission standards need to include a) tighter standards off-site, b) off-site monitoring locations, c) rail and trucking corridor standards and monitoring, and d) standards for mineral fibers that may cause cancer and e) standards for PM 2.5 small particles. The large quantities of materials moving through the proposed facility require tighter standards to maintain public and environmental health. The permit and its backup lack documentation of the content of fugitive emissions and possible unknowns discovered after operations being justify post-startup measurement and refinement of standards.
The checklist for the substance of the fugitive dust emissions control plan was not provided the public in the pdf file on the PCA website.

Storage pile fugitive dust can harm worker and community health. The standards need to be more specific than a general visibility standard. Content of the dust and cumulative limits must also be regulated.

There was very limited analysis of dioxin and other pollutants associated with incomplete combustion in the permit and associated documents that we reviewed. The final permit and substantiation must deal with this in more detail and there must be a no-discharge dioxin limit in the permit. There must be continuous monitoring for dioxin until the plant has stabilized its operations and no dangers are measured.
There needs to be continuous monitoring of VOCs at the top of the stack in order to project the public from harm. This is especially true for an unproven iron making process and new facility design. The expected variation in inputs and modifications to operating process make continuous monitoring even more important. Continuous emission monitoring of VOCs are required by the Indiana nugget plant permit to establish a baseline to determine whether CO monitoring can be used as a surrogate for VOCs. P 129 of comments on the Indiana permit by project proposer.

Particulate Matter on A-24:

MPCA should remove the administrative process detailed on A-24 for increasing PM and PM10 permit limits by 25% and 20% respectively.

MPCA should deny the permit unless new modeling is done showing the facility will not cause or contribute to PSD Increment or NAAQS violations. New modeling must consider the current permit levels and the potential increases noted on A-24.

The Sierra Club opposes approving both the permit and the Clean Unit status designation without first establishing that the plant will not cause or contribute to any PSD increment or NAAQS violation, based upon modeling considering the existing air quality and existing polluters, to which Mesabi's pollution would be added. This modeling must include both the current permitted PM and PM10 levels; as well as, the proposed increased levels permitted for MPCA administrative approval on page A-24.

As noted above, it appears the Class I analysis did not consider the existing level of pollution in the area and whether or not the Mesabi plant will cause or contribute to violations of the increment, or bring air quality close to the increment, in light of the pollution already existing in the area. This analysis must be done to determine if the Mesabi plant will be consistent with air quality standards. MPCA seems to be asserting no increment violation will occur because the LTV plant was closed. The Sierra Club is unaware of any offsetting program that allows a facility that will cause or contribute to a violation of an air quality standard in Minnesota to receive a permit because another polluting facility has been shut down. The Sierra Club would oppose issuing an air permit to a facility that will harm air quality simply because it emits less of most pollutants than another facility that used to exist. If there is some program in Minnesota that authorizes this type of offsetting, please identify it so the Sierra Club can familiarize itself with the program and assess the issue in the context of the offsetting program.

Cumulative analysis must be done in particular because of several types of emissions which, according to the air modeling, are large and therefore have more potential to cause or contribute to increment violations. For example, the Air Dispersion Report, Table 2, states PM10 will be 20 when the increment is 30. These are significant emissions. Given the large amount of emissions, it is critical to determine the background level of PM10 in the area to determine if an increment violation will occur. Further, it is unclear from the modeling if MPCA used the current permitted PM10 level, or the level to which MPCA can administratively raise the emissions limits. If this is the current permit limit, then additional analysis needs to be done to determine if the increment will be violated if MPCA does the administrative upward limit adjustment. This is needed now particularly because the use of an administrative adjustment, in our understanding, means there will be no public participation process if MPCA decides to raise the amount of PM emissions allowed from the plant.

The Sierra Club also objects to the determination that the green line values will not be violated only because the LTV plant was shut-down. Again, if there is an offsetting program in Minnesota that allows this type of trading, please identify it so the Sierra Club can analyze the issue in the context of such a program.

There doesn't appear to be any modeling for the 8-hour ozone or PM2.5. Until such modeling is done and shows there is no violation of PSD increment or NAAQs, the MPCA must not approve the permit. The Clean Air Act states that, in order to procure a permit, the owner or operator of a major emitting facility must demonstrate that "emissions from construction or operation of [the] facility will not cause, or contribute to, air pollution in excess of any . . . national ambient air quality standard for any pollutant in any area to which this part applies…" 42 U.S.C. 7475(a)(3). See also 40 C.F.R. 52.21(k) ("The owner or operator of the proposed source shall demonstrate that the allowable emissions increases from the proposed source… would not cause or contribute to air pollution in violation of: (1) Any national ambient air quality standard in any air quality control region…").

MPCA has failed to make that showing with regard to two air quality standards: the 8-hour ozone standard, and the fine-particulate standard. That failure precludes issuance of the permit. 42 U.S.C. 7475(a) ("No major emitting facility may be constructed in any area to which this part applies" unless owner has demonstrated that facility will not result in violation of air quality standards).
The sulfur dioxide emission limit should be reduced substantially from the 123/bs/hour in the draft permit. The pilot nugget plant at North Shore Mining produced 0.24 lbs/hour of SO2. Why is the limit over 500 times that of the pilots actual emissions went the plant capacity is only 24 times larger? (Source EPA comments on the Butler, Indiana iron nugget plant draft permit, p 139 of at http://oaqpermits.in.gov/19475p.pdf) Usually pilot plants create more pollutants per hour per ton than full size plants, as they are more unstable to operate and the engineering not yet optimized to reduce pollution. The EPA also recommended an emission reduction percentage so if different coal is used or the hourly tonnage rate of the RFH is lower that maximum control is maintained. The proposed limit is almost three times the emission rates of the SDI/Iron Dynamics RHF in Indiana. We were not able to find any documentation (engineering analysis) of the calculation of uncontrolled SO2 emissions from the RHF in the project record so we reserve the right to comment again when this information is made public. This is very important to a quality permit and the public should be able to review the calculation in light of the wide range of coal that might be used in the RHF. The impact of sulfur deposition on mercury methylation and uptake by fish is a serious concern of the Sierra Club.

The 10% opacity limit is too high. The plume and haze impacts would be substantial and would harm the BWCAW and local recreation economy, not to mention the environment. Even polluter friendly Indiana has a 5% opacity limit in their permit, and they started at a 3% level in their draft permit, page 42 http://oaqpermits.in.gov/19475p.pdf. Opacity is noticeably visible over 2.5% according to the Class I analysis. A 3% limit is needed in the final permit. The air modeling used current conditions and not natural background as required for Class I pristine air areas.
If PM is a surrogate for the control of metal hazardous air particles, then the proposed standard of 0.015 grains/ dry standard cubic foot is too high. It should not exceed 0.010 grains/dscf. The PM should be lower to protect the Class I pristine air over the BWCAW and our national parks and to protect public health from toxic metals and PM2.5. The draft permit would significantly degrade the clarity of the Class 1 air in Minnesota at great loss to our quality of life and recreation economy. The U.S. Forest Service comments of December 13, 2004 also call for a 0.10 grain/dscf limit as achievable by modern bag house filters. The SDI/Iron Dynamics RHF produces only 0.0052 grains/dscf to the draft limit is three times higher that the SDI experience. This cannot meet the BACT test.
Is this good enough for public health? PM BACT stds can be lowered by MPCA in the draft permit based on what the wet scrubbers can actually do. This seems to give the proposer an incentive to fail the tests. Page 15 tech support doc for air permit.
We object to the draft permit condition allowing an administrative process, out of sight of the public, to increase the PM emission limit to 0.020 grains/dscf (a 33% increase) if the facility cannot meet the original level. This is bait and switch. This gives the project proposer every incentive to not reach the original limit. The State of Indiana provided for public participation in permit modifications for the iron nugget plant proposed for Auburn Nugget in Butler Indiana (http://oaqpermits.in.gov/19475p.pdf).
The 0.20 grains/dscf for particulate matter (PM) of less than 10 microns is too high and we object to the use of an administrative process (non-public) to increase the limit by 25% for the reasons noted above.
There needs to be a specific emission limit for Particulate Matter less than 2.5 microns in size in the permit due to the long-term residency of these particles in human lungs, the potential that they may be cancer-causing materials or shapes, and because of the documented public health impacts. Lumping large and small particles together is not good public policy or professional practice. As a new source, the MPCA should use its authority to set limits for these fine particles on a case-by-case basis until state-wide or national limits are set. We interpret MEPA to require action now to reduce this dangerous sub-set of PM.
There need to be specific emission limits for all types of hazardous air particles (HAPS) in the permit and direct monitoring of each. The use of PM or PM 10 limits as surrogates for HAPs hides the dangers, especially in a new process at a new scale.
The Volatile Organic Compounds standard must also include compound specific standards for benzene and dioxin and other hazardous materials. (See General Comments above on compliance with the Great Lakes Toxic Substances Control Agreement). VOC Volatile organic compounds — the draft permit took the proposers limit based on the pilot plant, no documentation. And the monitoring will be inferred from CO monitoringneeds to be tested directly, and continuously.
MPCA should require Nitrogen Oxide controls on the RHF and the Green Ball Dryer.

The Sierra Club questions the BACT determination for Nitrogen Oxides. The Sierra Club has questions about how certain technologies were eliminated as not technologically feasible, and objects to the determination that no external controls are required.

The Sierra Club is unable to determine exactly what MPCA and the applicant consider to be BACT for NOx control in the RHF. Page 18 of the TSD states that BACT is "no add-on controls" for this application. MPCA seems to be relying upon features (low NOx burners and RHF staged combustion) inherent in the RHF design for NOx control, resulting in permit limits of approximately 901.404 tons of NOx per year (calculated using the 205.8 lbs of NOx per hour limit stated on page 18 of the TSD and page A-24 of the permit), when uncontrolled the furnace is expected to generate 902 tons of NOx per year. It appears that MPCA is essentially accepting uncontrolled emissions as BACT. The Sierra Club objects to the BACT determination, but will need to obtain an expert to consider the technical BACT analysis and comparison of technologies in detail. Upon preliminary review, it appears to the Sierra Club that uncontrolled emissions are "Best Available Control Technology."

The BACT analysis notes on pages 55-56 that selective catalytic reduction is not feasible in part because the temperature range for SCR before wet scrubber is not workable, and that process temperatures downstream are too cold for SCR without reheating. However, it also states that there are available catalysts that can operate below 500 degrees. This option is eliminated because it would create problems if put before the wet scrubber. Could these technologies be used after the wet scrubber, where gases would otherwise be too cold for SCR? Would use of the SCR after the wet scrubber reduce catalyst poisoning problems, as PM is being addressed with a wet scrubber? What temperature is gas downstream from the scrubber, and at what temperatures can the recently developed catalyst technologies work? The analysis says that exhaust gas would have to be reheated downstream from the scrubber, but does not give the temperatures. The analysis also states the new technologies have lower removal efficiencies, and that is used as part of the reason they are infeasible. What are the removal efficiencies, and what would the total removal efficiency be coupled with the NOx reducing processes inherent in the RHF?

Similarly, why can't Selective Non-Catalytic reduction be used downstream from the wet scrubber? The BACT analysis states on page 57 that a wet scrubber would reduce the fouling problem, and concludes that the issues prior to the wet scrubber are insurmountable. Is use after the wet scrubber feasible?

It appears MPCA also accepts uncontrolled emissions as BACT for the diesel generator and the Green Ball Dryer. The Sierra Club also objects to uncontrolled emissions as BACT for these units. A BACT analysis for back up generator must include natural gas and ultra low sulfur diesel (ULSD) both readily available alternatives.

There is also no BACT analysis for NOx from the Green Ball Dryer, though the permit indicates the same practices were found to be BACT in the Green Ball Dryer as in the RHF. However, the BACT analysis for the Green Ball Dryer showed that BACT was different between the Green Ball Dryer and the RHF for some pollutants. The Sierra Club would like to know if control technologies eliminated in the RHF BACT analysis for NOx would not be eliminated in a BACT analysis for the Green Ball Dryer. For example, in the Green Ball Dryer analysis a bag house/fabric filter was chosen as BACT for PM, while in the RHF the same technology was not feasible due to pressure changes. Until a BACT analysis is conducted for the Green Ball Dryer, we cannot assess whether or not NOx controls are feasible for this source.
The NOx limits are too high. The MPCA has accepted the proposers NOx limits. 125 PPM ads up to tons of pollution at this big facility that would increase ozone which affects people, wildlife and vegetation. Nitrates also impact haze over the BWCAW. NOx controls should be required on the plant at start-up and the limits at least cut in half. SNCR is used at SDI, and proposed for the DRI plant in Silver Day, to reduce NOx and should be BACT for this permit. Mesabi permit is almost three times the emissions of the SDI plant.
Almost one pound of lead per hour is 24 pounds a day, 8,760 pounds per year of a toxic material harmful to child development. This is far too high a limit. No level of lead is safe. Set and lower the limit in the final permit.

Flourides: lower the limit. 24.6 lbs per hour (108 tons/year) is too high.
Sulfuric acid mist: lower the limit. 25.6 lbs per hour is too high as this pollution will make the mercury emissions even more harmful to human health and increase the fish advisories and subsistence faming advisories.
The mercury emission limit is far too high. 75 lbs a year is enough to poison every lake in the state and for mothers to pass on to their developing fetuses. If this is to be a called a clean facility then it should be required to be one. It should also live up to the promises made by the advocates of waiving environmental review to speed up the process, who promised the lowest mercury emissions reasonably possible. The agency and the project proposer are promising a further 50% reduction from this level. If they really mean it they should put 37.5 lbs in the permit now and for day one operation.
We disagree with the air modeling assumptions that no elemental mercury is deposited locally. This is an extreme assumption that is not substantiated. This effectively removes most of the mercury emitted by the proposed furnace from the air health risks analysis. This is especially important as the voluntary mercury reduction program has failed to reduce industrial mercury emissions, per MPCA's own assessment in its January 2002 report to the legislature.
The mercury standard should also be set as per unit of product, so that lower levels of utilization do not increase the permitted discharge.
There need to be specific limits for and monitoring of metal, acid gas and volatile organic Hazardous Air Pollutants (HAPs) in the permit for each emission unit. These pollutants make people sick, cause suffering and shorter lives. Direction to operate an emission control system is not specific enough to guarantee compliance and to give the agency a cause of action to compel action from the permittee (Remember Reserve Mining).
Accepting coal sulfur analysis from the coal companies is not a credible source. Third party certification should be required to protect the environment, product quality and the facility.

The mercury certification test set at nine months before the application for permit renewal give the plant a four year pass at meeting any mercury standard. This is not acceptable. The mercury certification test must be within 10 days of the first 200,000 tons of production or 6 months from plant start-up, whichever comes first. This data is vital for evaluating the "mercury report" on further reductions and yet it won't be done in time if the schedule proposed in the permit is used.

Clean Unit Status:

MPCA should determine that this plant does not qualify for Clean Unit status.

The Sierra Club opposes a Clean Unit designation for any unit at the Mesabi plant because the plant will adversely affect Air Quality Related Values in Class I areas and because the plant may cause or contribute to PSD increment violations, and therefore does not qualify for clean unit status under federal regulations.

A. Clean Unit Qualification
The RHF has been given clean unit status for those pollutants controlled by materials questionably found to be BACT, namely SO2, PM, PM10, fluorides, lead, CO, VOCs and sulfuric acid. Also, each unit with a baghouse for PM is a clean unit for PM. We were unable to provide full technical and legal review of areas in the permit, such as this, due to the time constraints of a 30-day comment period with only two weeks after the public meeting. We question what test is applicable in determining if a unit qualifies a clean unit. Cited in the TSD is 67 FR 80185, announcing rules now published at 40 CFR Parts 51 and 52. On page A-26 the air emissions permit cites 40 CFR 52.21(x)(6) for the RHF clean unit designation for sulfur dioxide, PM, PM10, carbon monoxide, VOCs, lead, fluorides, sulfuric acid mist, and CO. The same section is cited for the clean unit designations for parts of the facility using a baghouse to control PM10.[16] Paragraph (x)(1), Applicability, states that the provisions of paragraph (x) apply to "any emissions unit for which the reviewing authority has issued a major NSR permit within the last 10 years" (emphasis added). We are uncertain of the precise meaning of this provision — it sounds like a permit must have issued for the unit within the last 10 years. To our knowledge Mesabi has had no permits at any time in the past, meaning it does not qualify as a Clean Unit under paragraph (x).

Facilities not qualifying under paragraph (x) can qualify under 40 CFR Part 52.21(y). In sum, parts (y)(3)(i) (ii) require that a "Clean Unit" meet the following requirements: 1) the owner or operator must demonstrate the unit's control technology is comparable to BACT according to paragraph (y)(4); 2) that the owner made an investment in the technology; and 3) "the Administrator must determine that the allowable emissions from the emissions unit will not cause or contribute to a violation of any national ambient air quality standard or PSD increment, or adversely impact an air quality related value (such as visibility) that has been identified for a Federal Class I area by a Federal Land Manager and for which information is available to the general public" (emphasis added).

B. Mesabi does not qualify.
Mesabi should have to qualify under paragraph (y) because it has not received a permit within the 10 years before the effective date of the rule. Therefore the Administrator must determine there are no adverse impacts on an AQRV, such as visibility, in a Class I area. The Sierra Club believes past findings by FLMs on similar projects suggest the unit will have an adverse effect. Mesabi will worsen visibility in Class I areas by 5 10%, as discussed at length in the Class I Area Air Modeling Report. The Sierra Club has not had sufficient time to fully evaluate the technical details of the report, however we have some comments based upon our initial review of the data. In addition, we're attaching U.S. Fish and Wildlife Services findings on adverse impacts on a Class I area in Illinois which had 5% - 10% reduction in visibility (see attachment.)

The Sierra Club asserts that 5% - 10% reductions in visibility in the Boundary Waters and other Class I areas impacted is adverse; however, a final conclusion cannot be reached until the visibility modeling is rerun consistent with what is called for by the Federal Land Manager, in this case the Forest Supervisors of Superior and Chequamegon-Nicolet National Forests. The Sierra Club agrees that comparison of impacts appears not to be compared with the natural background, as required by federal guidance. Further, the Sierra Club shares the concerns of the USFS that the air emissions could have negative impacts in Class I areas, which the Sierra Club asserts should be considered to be adverse impacts.

Further, due to the failure to consider existing pollution in the area to which Mesabi's pollution would be added, the Sierra Club asserts MPCA could not determine whether Mesabi would cause or contribute to violations of the PSD increment in Class I areas. In Class II areas, other facilities were excluded from the modeling. Again, in order to determine whether Mesabi will cause or contribute to a violation of the PSD increment, modeling must be done that considers the current air quality. Surely if the increment is close to being violated and pollution from Mesabi pushed total pollution over the increment it would cause or contribute to a violation of the PSD increment. We were unable to determine whether or not this was the scenario from the Class I and Class II modeling. MPCA should conduct this analysis before issuing a permit to Mesabi, and before determining Mesabi qualified for clean unit status.

The Sierra Club asserts that Mesabi does not qualify for Clean Unit Status, and asserts that Mesabi appears to be causing adverse impacts to the AQRVs in Class I areas, and that upon this record the MPCA cannot determine whether or not Mesabi will cause or contribute to violatations of the PSD increment in Class I or Class II areas.

The opacity limit is too high. This would create a very visible plume and add to the region's haze, including the BWCAW.
The PM limit of 15 grains/dscf is to high. See comments above on RHF.
There needs to be a PM 2.5 limit and control system for the green ball dryer. These are the most deadly PM and there was no mention of them in the permit or technical support document. They need to be controlled directly by the permit and technology. It is critical to do it now as the bag house design needs to reflect the standard for fine particles.
Clean Unit Designation: We object to awarding Clean Unit designations for these pollutants because a) the emissions limits are still high and b) the plant should be required to upgrade pollution controls as better technology or tighter regulations are developed. This designation is misleading. It give a right to pollute and not to adapt best available control technologies are they are developed, it gives a decade long free pass at a cost of missed opportunities to protect the environment.
Why are there no criteria and HAP limits specifically for this emission unit?
Ambient impacts of the proposed project: the 1-hour std. for SO2 is violated. The MPCA blames it on a MN Power plant that has "proposed to bring their plant into compliance." This is different than actually emitting less. What if MN Power doesn't upgrade their pollution controls or they are not effective? The speculative actions of a third party should not affect the draft permit.
The applicant proposes a CO carbon monoxide limit of 70 ppm at three percent oxygen on a six-hour average as BACT. This reflects the results stack tests (18 ppm, according to the BACT analysis) performed at the pilot plant plus a safety factor. The MPCA will set a limit of 60 ppm (corrected to seven percent oxygen) on a three-hour average as BACT. This is a huge safety margin — or the proposer not breathers. The CO limit needs to be reduced significantly for the source.

The opacity limit is too high. This would create a very visible plume and add to the region's haze, including the BWCAW.
The PM limit of 15 grains/dscf is too high. See comments above on RHF.
There needs to be a PM 2.5 limit and control system for the green ball dryer. These are the most deadly size PM and there was no mention of them in the permit or technical support document. The need to be controlled directly by the permit and technology. It is critical to do it now as the bag house design needs to reflect the standard for fine particles.
Clean Unit Designation: We object to awarding Clean Unit designations for these pollutants because a) the emissions limits are still high and b) the plant should be required to upgrade pollution controls as better technology or tighter regulations are developed. This designation is misleading. It give a right to pollute and not to adapt best available control technologies are they are developed, it gives a decade long free pass at a cost of missed opportunities to protect the environment.

The PM limit of 15 grains/dscf is too high. The U.S. Forest Service comments of December 13, 2004 also call for a 0.10 grain/dscf limit as achievable by modern bag house filters. The proposed limit would allow 20% of emissions to escape to the air. Also see comments above on RHF.
There needs to be a PM 2.5 limit and control system for the green ball dryer. These are the most deadly size PM and there was no mention of them in the permit or technical support document. They need to be controlled directly by the permit and technology. It is critical to do it now as the bag house design needs to reflect the standard for fine particles.
Clean Unit Designation: We object to awarding Clean Unit designations for these pollutants because a) the emissions limits are still high and b) the plant should be required to upgrade pollution controls as better technology or tighter regulations are developed. This designation is misleading. It give a right to pollute and not to adapt best available control technologies are they are developed, it gives a decade long free pass at a cost of missed opportunities to protect the environment.

There is no mention of rail transport and associated air emissions of locomotives or the 1,000+ truckloads of materials to be brought to the plant each year or mention of dust of concentrate blowing off loaded cars or during unloading. This needs to be covered in the final permit. This may be a source of mineral fiber emissions for the communities along the rail line from the North Shore Mining taconite plant in Silver Bay. This needs to be analyzed and address in the final permit.

Great Lakes Toxic Substances Control Agreement (attached)

Via email only:

FWS Consultation on the Prairie State Generating Company power plant in Illinois

Support information for the DOI Adverse Impact Conclusion on AQRVs in the Mingo Wilderness Area from proposed emissions by the Prairie State Generating Station

[1] http://www.pca.state.mn.us/about/pubs/proreport98/index.html

[2] R.K. Srivastava and W. Jozewicz, Flue Gas Desulfurization: The State of the Art, Journal of the Air & Waste Management Association, v. 51, 2001, pp. 1676-1688.

[3] Lewis Benson, Kevin Smith, and Bob Roden, New Magnesium-Enhanced Lime FGD Process, The Mega Symposium, May 2003.

[4] Commercial Experience of CT-121 FGD Plant for 700 MW Electric Power Plant.

[5] http://www.bwe.dk/pdf/ref-11%20FGD.pdf.

[6] Paul S. Nolan, Flue Gas Desulfurization Technologies for Coal-Fired Power Plants, Coal-Tech 2000 International Conference, November 13-14, 2000.

[7] http://www.pca.state.mn.us/air/permits/issued/9100059-002-aqpermit.pdf

[8] See the OAQPS Manual, Table 3.9 for thermal and catalytic incinerators (2%), Table 4-4 for carbon adsorber systems (2%), Table 5.9 for fabric filter systems (1%), Table 6.10 for electrostatic precipitators (1%), Table 7.4 for flares (2%), and Table 8.3 for refrigerated condenser systems (2%).

[9] While special legislation exempts this facility from the environmental review provisions of MEPA, it does not exempt permits for the facility from this prohibition.

[10] 2005 Minn. Sess. Law Chapter 37, H.F. No. 1334 (Section 1, (4)(d))

[11] Appendix A to Form HG-2003, Analysis of Mercury Control Options, Mesabi Nugget Corporation LLC

[12] Reducing Mercury Pollution: Workable Solutions for Minnesota's Waters, Izaak Walton League, Table 2: Top 10 Mercury Emitters in Minnesota, pg. 8.

[13] Minn. Stat. 116.915.

[14] www.pca.state.mn.us/hot/legislature/reports/2002/mercury-02.pdf

[15] AERA Internal Form-03, Risk Analysis, pg. 4

[16] The designations are made for the green ball dryer (page A-29), product separator (page A-30), the coal 1 pulverizer (page A-32), the coal 2 pulverizer (page A-34), the flux 1 pulverizer (page A-35), the coal flux/unload baghouse (page A-36), the rail loadout baghouse/material transfer operations (page A-38), the material transfer operations (page A-40), and the flux 2 pulverizer (page A-42).


	About Us \| Newsletter & Action Alerts \| Groups \| Join! \| Volunteer \| Contact Us Copyright © 2003-2009 Sierra Club North Star Chapter. All Rights Reserved.

Upcoming Mining Events

Mining without Harm

Mining without Harm - Mesabi Nugget Draft Air Permit - Comments