PUBLIC PARTICIPATION DOCUMENTS For United States Steel Corporation Ecorse, Wayne County SRN: A7809

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1 STATE OF MICHIGAN Rick Snyder, Governor DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION CONSTITUTION HALL 525 WEST ALLEGAN STREET P.O. BOX LANSING, MICHIGAN PUBLIC PARTICIPATION DOCUMENTS For Ecorse, Wayne County SRN: A7809 PROPOSED STIPULATION FOR ENTRY OF FINAL ORDER BY CONSENT (CONSENT ORDER) AQD No Albert B. Buday Civic Center 3869 West Jefferson Avenue, Ecorse, Michigan City Council Chambers 2nd Floor Informational Session: 6:00 p.m. Public Hearing: 7:00 p.m.

2 Public Participation Page 2 FREQUENTLY ASKED QUESTIONS The Michigan Department of Environmental Quality (MDEQ), Air Quality Division (AQD) is seeking the proposed entry of a Stipulation for Entry of Final Order by Consent (Consent Order) with United States Steel Corporation (Company) for the noncompliant operation of their facility located at No.1 Quality Drive in Ecorse, Michigan. The AQD is accepting public comments until the close of the public hearing on, which will be held at the Albert B. Buday Civic Center, 3869 West Jefferson Avenue, 2nd Floor, City Council Chambers in Ecorse, Michigan. Prior to the public hearing, an informational session will be held from 6:00 p.m. to 7:00 p.m. where staff will be available to answer questions. The public hearing will immediately follow. All comments will be reviewed by the decision-maker prior to the final decision and entry of the proposed Consent Order. What is a Stipulation for Entry of Final Order by Consent? The Stipulation for Entry of Final Order by Consent is known as a Consent Order Order. A Consent Order is a settlement agreement, which is a legally enforceable document that binds the MDEQ and the Company for the purpose of resolving the alleged violations of laws or regulations administered by the MDEQ. A settlement agreement normally incorporates a compliance program for resolving the alleged violations and ensuring the violations are not repeated, a monetary settlement, and provisions for stipulated penalties for failure to comply with the terms and conditions of the proposed Consent Order. The purpose of monetary sanctions is to provide an incentive for achieving and maintaining compliance. What is the purpose of this proposed Consent Order? The Company operates a steel pickling line (No. 5 Pickle Line) at the main plant in Ecorse, Michigan. The steel pickling is performed to remove oxides (rust) from the surface of the steel. This is done by submerging the steel strip in several heated tanks containing mostly water and some hydrogen chloride/hydrochloric acid. The tanks are completely covered and hydrogen chloride fumes are sent to a wet scrubber. The Company performed a test of the No. 5 Pickle Line wet scrubber exhaust stack in August of 2015 to measure hydrogen chloride. They are permitted to emit 18 parts per million by volume (ppmv) and 1.64 pounds per hour from the pickle line wet scrubber. The result of the testing was 19.6 ppmv of hydrogen chloride which is above the emission limit. The pounds per hour test result was 1.36 pounds, which was in compliance with the hourly limit. The proposed Consent Order requires the Company to perform a second test and submit an enhanced maintenance plan for the scrubber and associated maintenance and inspection records. It also includes a monetary settlement amount of $49, By law, this settlement must go to the State of Michigan general fund. What is a wet scrubber? A wet scrubber is an air pollution control devices for removing particles and/or gases from industrial exhaust. A wet scrubber operates by mixing the dirty gas stream with a scrubbing liquid usually water. Particulate or gases are collected in the scrubbing liquid. How was the penalty amount determined? The initial penalty offer is calculated using the United States Environmental Protection Agency Clean Air Act Stationary Source Civil Penalty Policy. This Policy takes into account several factors, including: the actual or possible harm of the violation, the length of time of the violation, the sensitivity to the environment, importance to the regulatory scheme, and the size of the violator.

3 Public Participation Page 3 What happens if is found in violation of this Consent Order? In order to discourage non-compliance the proposed Consent Order requires the Company to pay up to $5, per violation per day for any violations of this Consent Order. How might this violation impact people s health? Health problems are not expected to have occurred due to this alleged violation. Although hydrogen chloride can irritate the eyes, nose and throat, the exposure levels were not high enough to be harmful. What is known about possible health impacts besides the time period of this stack test? During time periods outside of the stack test, the facility is required to continuously monitor scrubber operations such as water flow rate, recirculation water flow rate, and pressure drop and perform inspections and repairs to the scrubber every three months. The acceptable minimum flow rates and pressure drop range were set during a prior test when the scrubber was in compliance with the emission limits. The scrubber is required to operate within these values at all times and the Company must maintain a written record to show compliance. While the company has certified that the scrubber has been operating in compliance with these set values, there is not enough information to know when the violation started and if the emissions may have exceeded health-protective benchmarks and reached levels that may have caused health concerns. The scrubber passed the prior stack test in Based on the scrubber operational records and additional maintenance performed after the failed stack test, it is not expected that the emission rates have increased beyond the tested levels since the failed test. Although the facility is still considered to be out of compliance until another stack test is performed, adverse health effects are not expected to occur because of the violation. How do the public comment period and public hearing work? The law requires the AQD to hold a public comment period and accept comments on proposed Consent Orders. The public comment period allows people to review and comment on the AQD s proposed Consent Orders. The AQD reviews all comments before the final decision is made. Based on comments received during the public comment period and during the public hearing, the AQD may issue the Consent Order as proposed or attempt to reach agreement with the Company regarding a revised Consent Order. Prior to the public hearing, an informational session is held where staff will be made available to answer questions concerning the proposed Consent Order. Comments regarding the proposed Consent Order that the AQD staff can consider include: Technical or mathematical mistakes. Why the proposed compliance plan is not adequate. Why the proposed settlement amount is not appropriate. Why the proposed Consent Order should include additional requirements.

4 Public Participation Page 4 Purpose FACT SHEET The Michigan Department of Environmental Quality, Air Quality Division is seeking the proposed entry of a Consent Order with for the noncompliant operation of their facility located at No.1 Quality Drive in Ecorse, Michigan; with State Registration Number (SRN) A7809. On October 14, 2015, the AQD staff received the stack test report for the No. 5 Pickle Line scrubber. A review of the report revealed that the pickle line scrubber emissions exceeded the 18 ppmv hydrogen chloride (HCl) limit in the Company s Renewable Operating Permit No and in Title 40 CFR Part 63 Subpart CCC (Steel Pickling MACT). The stack test result was 19.6 ppmv. The results of two prior stack tests performed in 2013 and 2010 were 0.2 ppmv and 0.3 ppmv, respectively. The proposed Consent Order requires the Company to perform a stack test to ensure compliance with the No. 5 Pickle Line scrubber HCl emission limits, submit a revised preventative maintenance plan for the No. 5 Pickle Line scrubber, and submit No. 5 Pickle Line scrubber maintenance records each quarter the Consent Order is effective. Prior to acting on this Consent Order, the Air Quality Division is holding a public comment period and a public hearing to allow all interested parties the opportunity to comment on the proposed Consent Order. All relevant information received during the comment period and hearing will be considered by the decision-maker prior to taking final action on the Consent Order. Background and Location The Company operates an integrated steel mill that has been in operation since August It is located just south of the City of Detroit. The site consists of approximately 1,100 acres that span along the Detroit River through the cities of Ecorse and River Rouge. The facility includes the Main Plant Area, the 80-inch Hot Strip Mill, and the iron making and coke making operations on Zug Island. The plant produces flat-rolled steel products for the automotive, appliance, container, service center, and piping and tubing industries. The primary iron producing facility is located on Zug Island, City of River Rouge, which is bordered by the Rouge River on the north, south, and west sides and the Detroit River on the east side. The Zug Island facility includes, but is not limited to, two operating blast furnaces, one coke oven, one coke byproducts recovery plant, and three boiler houses. The Zug Island site is zoned heavy industrial. The nearest residential area is approximately 0.1 miles from the facility. The 80-inch Hot Strip Mill (HSM) facility is located in the City of River Rouge between the Zug Island and the Main Plant. This Mill facility includes the hot strip finishing and shipping building, scale pit, coil storage and shipping building, slab yard, and 80 hot strip mill. The HSM site is zoned heavy industrial. The nearest residential area is approximately 0.5 miles from the facility. The Main Plant is located on a 682 acre site in the City of Ecorse. It is bordered by the Detroit River to the east, the 80-inch Hot Mill Strip facility to the north, Edward C. Levy Plant No. 3 to the south, and Jefferson Avenue to the west. The following steel making operations are located at the Main Plant: No. 2 Basic Oxygen Process (#2 BOP), Vacuum Degasser, Ladle Metallurgical Facility (LMF), No. 1 and No. 2 Argon Stir, No. 5 Pickle Line, Electrogalvanizing Line, No. 4 Tandem Cold Mill, Continuous Annealing Line, and Boiler House. The Main Plant site is zoned heavy industrial. The nearest residential area is approximately 0.25 miles from the facility.

5 Public Participation Page 5 The facility operates 24 hours per day, 7 days per week, and 52 weeks per year. Many process units are equipped with control devices. The No. 5 pickle line is controlled by a scrubber. Compliance Issues On August 11, 2015, testing was performed by the Company for HCl from the No. 5 Pickle Line scrubber. The test report received on October 14, 2015, documented the HCl emission limit exceedance. The HCl emission limit is 18 ppmv and the test result was 19.6 ppmv. Compliance Program The proposed Consent Order requires the Company to perform a stack test to ensure compliance with the No. 5 Pickle Line HCl emission limits, submit a revised preventative maintenance plan for the No. 5 Pickle Line scrubber, and submit No. 5 Pickle Line scrubber maintenance records each quarter the Consent Order is effective. The proposed Consent Order requires that a monetary settlement amount of $49, be made to the State of Michigan general fund. Failure to comply with the terms and conditions of the proposed Consent Order could result in a maximum stipulated penalty of $5, per violation per day. Present Air Quality The Company s facility is located in a part of Wayne County, which is meeting the National Ambient Air Quality Standards (NAAQS) for all criteria pollutants, except for sulfur dioxide. Recommendation The AQD staff believes that the proposed Consent Order, as drafted, contains an appropriate compliance program for resolution of the federal and state air quality violations at the Company s facility. The AQD staff recommends that the proposed Consent Order be entered, unless substantive adverse comments are received during the public comment period. If you would like additional information about the proposed Consent Order, please contact Mr. Jason Wolf, Air Quality Division, at