TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Amendment Description Table A: Limits and Other Requirements

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2 TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Amendment Description Table A: Limits and Other Requirements GP 001 Mobile Sources GP 002 Emission Units Subject to Taconite MACT GP 003 Ore Crushing & Handling GP 004 Finished Pellet Handling GP 005 Waste Rock Handling GP 006 Fugitive Sources GP 007 Baghouses with Leak Detection GP 008 Bag Houses Subject to Taconite MACT GP 009 EAF Baghouses GP 010 Electric Arc Furnaces GP 011 Meltshop Enclosures GP 012 Cooling Towers GP 014 Flares GP 015 Tunnel Furnace GP 016 Material Loading Bin Sources GP 017 DRI Pellet Handling GP 018 Indurating Furnace GP 019 Boilers/Heaters Subject to Case-by-Case MACT GP 020 Wet Scrubbers Subject to Case-by-Case MACT GP 021 Emergency Generators and Fire Water Pumps GP 022 Stack/Vents with CEMS GP 023 EAF Ladle/Castle Area GP 024 DRI Top Gas Purification GP 025 DRI Water Blowdown Units GP 026 Ore Barns EU 165 Space Heaters FS 042 Slag Dumping Table B: Submittals Appendices Appendix A BACT Limits Appendix B Modeling Parameters Appendix C Green ball/dri Lead/Fluoride Concentration Monitoring 95% UCL Appendix D Visible Emissions Checklist Appendix E Test and Set for PM 2.5 Appendix F SAM Equations Appendix G Insignificant Activities Appendix H Process Flow Diagram

3 NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area Outside Metro Area TTY The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements.

4 FACILITY DESCRIPTION: Essar Steel Minnesota LLC (Essar) is currently in the process of constructing an approximately $1.6 billion mine mouth electric arc furnace steel mill. The Essar project is located in northern Minnesota, on the western end of the Biwabik Iron Formation (the Mesabi Range) near Nashwauk, at the site of the former Butler Taconite Mining Company operations. The project has secured the 1.4 billion (long) ton Mineral Resource of the Butler properties and seeks to capitalize on the unique mineralogical characteristics of the iron ore body by vertically integrating all mining and manufacturing processes to produce a finished steel product on one site. The processes involved will use proven technology and be the only fully integrated steelmaking facility in the United States. Essar will begin operations by mining a new pit, Pit 6, next to Pit 5 where Butler Taconite operations stopped. The mining of Pit 5 will resume after dewatering is completed. The key project features and their nominal capacities are: An open pit taconite mine capable of mining approximately 24,000,000 tonne/yr of ore. A crusher, concentrator with associated tailings basin, producing approximately 7,000,000 tonne/yr of concentrate. A pelletizer that can produce approximately 6,500,000 tonne/year of high flux oxide pellets or 7,000,000 tonne/yr of low flux oxide/ DRI grade pellets. A DRI facility producing approximately 1,800,000 tonne/yr of iron pellets for direct feed for steel production. An electric arc furnace, ladle metallurgy furnace, slag processing, and a caster to produce 1,500,000 tonne/yr of steel slabs for direct shipment or for onsite rolling to produce hot rolled coil. Essar plans to use natural gas as the process fuel for pelletizing, direct reduction, and steel making. Diesel fuel will be used to operate mining equipment. The project will demand 450 MW of electric power, which will be supplied by Nashwauk Public Utility. Essar plans to use ore concentrating and indurating processes common to existing taconite operations and to employ natural gas based direct iron reduction. The steel mill will use modern electric arc furnace (EAF) and metallurgy furnace technology to equip the melt shop. Unlike most other EAF-based steelmaking operations, Essar will use primarily DRI to charge the EAF. Scrap will only be used in the EAF for initial or post-maintenance startup. There will be no scrap charge to the EAFs at Essar other than internally-produced, virgin iron, "home scrap". AMENDMENT DESCRIPTION The proposed Essar Steel Minnesota Modifications (ESMM) project Master Development Agreement (MDA) Alternative would include all activities covered in the MSI project including mining, ore processing, direct reduced iron (DRI) production, and steel-making, but would entail higher taconite pellet production and associated mining and tailings generation rates. The project will increase production of taconite pellets from about 3.8 million (mm) metric ton (tonne) per year of low flux pellets suitable for DRI feed pellet to 7.0 mm tonne/yr of low flux pellets or 6.5 mm tonne/yr of high flux pellets suitable for blast furnace grade pellets or any combination in between. The blast furnace grade or high flux taconite pellets will be shipped to Essar Steel Algoma in Ste. St. Marie, Ontario Canada or sold on the open market. DRI grade or low flux pellets will be used as feed to the DRI process or sold on the open market. The MSI project was permitted for installation of two DRI lines and two steel lines. Essar is proposing at this time to permit one DRI line and one steel line to produce 1.8 mm tonne/yr of DRI and 1.5 mm tonne/yr of steel which is consistent with the Master Development Agreement (MDA) between Essar Steel Minnesota and the State of Minnesota. However, no physical changes to the DRI or steel mill are required to produce at these capacities.

5 The table below is provided to illustrate differences in capacities between the original MSI project and the proposed ESMM project MDA Alternative. Capacity Differences between the Original MSI Project and Proposed ESMM Project MDA Alternative Unit Operation Taconite Pelletizing Furnace Type of Pellet Original MSI Project Capacity (mm tonne/yr) Proposed ESMM Project MDA Alternative Capacity (mm tonne/yr) Low Flux (DRI feed grade) , 5 High Flux (blast furnace grade) , 5 DRI Not applicable Steel Making Pelletizing air emission calculations included a 10% safety factor to account for the level of detailed engineering that existed at the time of permitting. Actual capacity used for air emission calculations was 4.1 mm tonne/yr. 2 For the original MSI FEIS and Air Permit # , the capacity of the DRI modules was described as 2.8 mm tonne/yr. However, the MSI air emissions inventory used a value of 3.5 mm tonne/yr plus a 10% safety factor which equates to 3.85 mm tonne/yr. The MSI permit limits and BACT were based on 3.85 mm tonne/yr. The Essar emission inventory uses the capacity of 1.8 mm tonne/yr and the same hourly production rates as the MSI air emission calculations and limits. 3 Essar will make Low Flux, otherwise known as DRI feed grade pellets for on-site steel making or for sale on the open market. The quantity of this type of pellet to be produced on an annual basis will depend on internal manufacturing needs and on market conditions. 4 Essar will make High Flux, otherwise known as Blast Furnace grade pellets for Essar Steel Algoma or for sale on the open market. The quantity of this type of pellet to be produced on an annual basis will depend on internal manufacturing needs and on market conditions. 5 An air emission inventory was prepared for both types of pellets to be produced. The maximum value from either inventory for a given pollutant was used in air dispersion modeling assessments. 6 There are no physical changes to the DRI proposed and there are no changes to the hourly production rates. 7 There are no physical changes to the steel mill proposed and there are no changes to the hourly production rates. The proposed action modifies the indurating furnace where taconite (oxide) pellets are produced. The DRI process is separate from the indurating furnace. The oxide pellets would be transported to an off-site blast furnace or on-site DRI process. In the DRI process the oxide pellets are converted to DRI pellets. There would be no physical change to the DRI process or the steel mill that were previously permitted. With regard to analysis of the DRI process, Essar is not proposing any physical change or change to the hourly capacity of the DRI units as described in the MSI FEIS and Air Permit # Essar began construction on the originally permitted MSI project in October, Construction began with earthwork and rock excavation for all facility building and concrete foundations for primary crushing, mill bay tunnels, slurry tanks and balling discs and filters as well as infrastructure for the project. No construction activities associated with the 4 th secondary crushing unit, 3 rd autogenous grinding mill or the firing zone of the indurating furnace or any emission units that were not previously permitted has begun. The overall project timeline includes the following milestones: Finalize the Supplemental Environmental Impact Statement late 2011 Obtain environmental and mining permit for modification and obtain financial close for equipment required for increase pelletizing capacity 2012 Finish construction through taconite pellet plant and start taconite pellet production 2013 Start construction of one DRI line and steel mill 2013 Start steel production 2015

6 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-1 05/10/12 Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do The construction authorization expires 18 months after permit issuance. The Permittee must keep a record of the dates of installation and start-up on site. The Permittee may apply for an extension of the construction authorization deadline by following the Administrative Amendment provisions in Minn. R The facility currently uses ozone-depleting substances as defined in 40 CFR pt. 82. Sections of the 1990 Clean Air Act Amendments and 40 CFR pt. 82 may apply to your facility. Read Sections and 40 CFR pt. 82 to determine all the requirements that apply to your facility. Definition. Facility includes all emission units at the stationary source. This permit contains appendices as listed in the Table of Contents. The Permittee shall comply with all requirements contained in appendices. Modeling parameters in appendices are enforceable and compliance with these parameters is achieved through meeting the requirements that reference appendices. OPERATIONAL REQUIREMENTS Maintain records of the tons of oxide pellets, tons of DRI, and tons of liquid steel produced, on a per 8-hour shift basis. These production numbers shall be used in compliance emission limits that are based on production. At all times, including periods of startup, shutdown, and malfunction (SSM), the Permittee shall, to the extent practicable, maintain and operate any emissions unit including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R to Compliance shall be demonstrated upon written request by the MPCA. Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Operation and Maintenance (O&M) Plan: Retain at the stationary source an O&M plan for all air pollution control equipment. At a minimum, the O&M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. The O&M Plan shall include and maintain the operating ranges for each piece of control equipment as established in the most recent compliant performance test. Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Comply with Fugitive Emission Control Plan: The Permittee shall follow the actions and recordkeeping specified in the control plan. The plan may be amended by the Permittee with the Commissioner's approval. If the Commissioner determines the Permittee is out of compliance with Minn. R or the fugitive control plan, then the Permittee may be required to amend the control plan and/or to install and operate particulate matter ambient monitors as requested by the Commissioner. Why to do it 40 CFR 52.21(r)(2) and Minn. R CFR pt. 82 Title I Condition: 40 CFR 52.21(p); Minn. R and Minn. R , subp. 2 Minn. R , subp CFR pt. 50; Minn. Stat. Section , subds. 4a & 9; Minn. R , subps. 7A, 7L & 7M; Minn. R , subps. 1, 2 & 4; Minn. R Minn. R Minn. R , subps. 2 & 16(J) Minn. R , subps. 14 & 16(J) Minn. R , subp. 4 Minn. Stat. Section , subd. 4a; Minn. R ; Minn. R , subp. 2; Minn. R ; Minn. R

7 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-2 05/10/12 Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. Retired Acid Rain or CAIR/CASPR allowances used for visibility offsets may not be used by the Permittee or another regulated entity for any offset, banking, selling or trading program. PERFORMANCE TESTING Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Table A. Performance Test Notifications and Submittals: Performance Tests are due as outlined in Table A of the permit. Performance Test Notification: due 60* days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - CD Copy: due 105 days after each Performance Test Minn. R Minn. R Minn. R , subp. 9(A) Minn. R , subp. 16 Title I Condition: 40 CFR 52.21(p); Minn. R Minn. R. ch CFR 63.7(b)(1), (c)(2)(iv), & (g)(1); 40 CFR 63.9(e); 40 CFR (d); Minn. R , subp. 2; Minn. R , subp. 3; Minn. R ; Minn. R , subps. 1-4; Minn. R , subps. 1-2 *30 days for those tests that do not support MACT limits. The Notification, Test Plan, and Test Report may be submitted in alternative format as allowed by Minn. R Limits set as a result of a performance test apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R , subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. Within 15 days of the actual startup of that emission unit, the Permittee shall notify the MPCA of the initial startup of any emission unit for which the permit requires an initial performance test for which the date of testing depends on the date of initial startup. The initial performance test requirements are listed at the GP level. MONITORING Monitoring Equipment Calibration: Annually calibrate all required monitoring equipment (any requirements applying to CEMS are listed separately in this permit). Unless otherwise noted in Table A, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. RECORDKEEPING Recordkeeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R , subp. 2), including records of the emissions resulting from those changes. If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R These records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the office of the stationary source for all other years. The records may be maintained in either electronic or paper format. Minn. R , subp. 3 Minn. R , subp. 4 Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. R , subp. 5(C) Minn. R , subp. 5(B) Minn. R , subp. 4

8 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-3 05/10/12 Contractors: The Permittee shall retain records on site of each contractor that is allowed on site to operate any crushers, screens and conveyors. The records for each contractor shall consist of the contractor's company name, MPCA air emissions permit number (if any), short description of on-site activities undertaken by the contractor, estimate materials handled and the dates the contractor was on site. The records shall be updated quarterly. This is a state-only requirement and is not enforceable by the EPA administrator or citizens under the Clean Air Act. REPORTING/SUBMITTALS Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the Permittee does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. Minn. R , subp. 2 Minn. R , subp. 3 At the time of notification, the Permittee shall inform the Commissioner of the cause of the shutdown and the estimated duration. The Permittee shall notify the Commissioner when the shutdown is over. Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of >1 hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the Permittee. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. Minn. R , subp. 2 At the time of notification or as soon as possible thereafter, the Permittee shall inform the Commissioner of the cause of the breakdown and the estimated duration. The Permittee shall notify the Commissioner when the breakdown is over. Notification of Deviations Endangering Human Health or the Environment: Minn. R , subp. 1 As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Notification of Deviations Endangering Human Health or the Environment Report: Minn. R , subp. 1 Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. The cause of the deviation; 2. The exact dates of the period of the deviation, if the deviation has been corrected; 3. Whether or not the deviation has been corrected; 4. The anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Excess Emissions and Continuous Monitoring System Report: The Permittee shall Minn. R , subp. 2 submit an excess emissions and continuous monitoring system performance report and/or a summary report to the Commissioner by the 30th day following the end of each calendar half. The report(s) shall include all the information required and in accordance with 40 CFR Section 63.10(e)(3). Application for Permit Amendment: If a permit amendment is needed, submit an Minn. R application in accordance with the requirements of Minn. R Submittal dates vary, depending on the type of amendment needed. Extension Requests: The Permittee may apply for an Administrative Amendment Minn. R , subp. 1(H) to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pts. 60 & 63 are examples of deadlines the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R , subp. 1(H). Emission Inventory Report: due on or before April 1 of each calendar year following Minn. R permit issuance. To be submitted on a form approved by the Commissioner. Emission Fees: due 60 days after receipt of an MPCA bill. Minn. R INAPPLICABLE REQUIREMENTS 40 CFR 60 Subpart AAa does not apply to the electric arc furnace(s) (EU 125). It does apply to the vacuum degasser unit(s) and, therefore, to SV CFR a; Minn. R CFR 63 Subpart FFFFF does not apply anywhere at this facility. 40 CFR ; Minn. R

9 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-4 05/10/12 DETERMINING IF A PROJECT/MODIFICATION IS SUBJECT TO NSR These requirements apply if a reasonable possibility (RP), as defined in 40 CFR Section 52.21(r)(6)(vi), exists that a proposed project, analyzed using the actual-toprojected-actual (ATPA) test (either by itself or as part of the hybrid test at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may result in a significant emissions increase (SEI). If the ATPA test is not used for the project, or if there is no RP that the proposed project could result in a SEI, these requirements do not apply to that project. The Permittee is only subject to the Preconstruction Documentation requirement for a project where a RP occurs only within the meaning of Section 52.2(r)(6)(vi)(a). Even though a particular modification is not subject to New Source Review (NSR), or where there isn't a RP that a proposed project could result in a SEI, a permit amendment, recordkeeping, or notification may still be required by Minn. R Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following: 1. Project description 2. Identification of any emission unit (EU) whose emissions of an NSR pollutant could be affected 3. Pre-change potential emissions of any affected existing EU, and the projected post-change potential emissions of any affected existing or new EU. 4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the EU could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination. The Permittee shall maintain records of this documentation. The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the ATPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. The Permittee must submit a report to the Agency if the annual summed (actual, plus potential if used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain: 1. The name and ID number of the facility, and the name and telephone number of the facility contact person 2. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions increase are exceeded. 3. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. "TEST AND SET" PROVISIONS FOR PM2.5 This permit sets PM2.5 emission limits for Emission Units/Stacks that emit PM. The Permittee shall demonstrate compliance with these limits as required in the provisions for each emission unit/stack. The Permittee shall conduct performance testing for these stacks in accordance with Appendix E. The data collected during these tests shall be used to support the development of more refined PM2.5 emission limits for the emission units. Within 15 days of project startup, the Permittee shall notify the MPCA of the date of project startup. Project startup is defined in Appendices E. The Permittee shall submit an application for a major permit amendment within 910 days of project start up, it shall contain all data required by Appendix E. Title I Condition: 40 CFR 52.21(r)(6); Minn. R ; Minn. R , subp. 2 Title I Condition: 40 CFR 52.21(r)(6); Minn. R ; Minn. R , subp. 4; Minn. R , subps. 4 & 5 (continued) Title I Condition: 40 CFR 52.21(r)(6); Minn. R ; Minn. R , subp. 4; Minn. R , subps. 4 & 5 Title I Condition: 40 CFR 52.21(r)(6); Minn. R ; Minn. R , subps. 4 & 5 Title I Condition: 40 CFR 52.21(r)(6); Minn. R ; Minn. R , subps. 4 & 5

10 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: Essar Steel Minnesota LLC TOTAL FACILITY MERCURY EMISSION LIMITS Referred to as the Total Mercury Emission Limit, the total facility mercury emissions shall be less than or equal to 77 lbs/year using a rolling 12 month sum. This limit applies upon initial startup of the facility. For the first 11 months of operation, mercury emissions are limited as determined by the following equation: Hg = * M Where: Hg = mercury emissions in pounds since initial startup of the pellet plant; M = number of months after initial startup (i.e., for the first month, M = 0) As provided in the Implementation Plan for Minnesota's Statewide Mercury Total Maximum Daily Load - October 2009, by June 30, 2016, or a date established by the MPCA Rule, the MPCA will require submittal of a schedule for reducing mercury emissions from the ferrous mining and processing industry sector by 75% from the levels listed in the plan by Mercury Calculation and Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the monthly mercury emissions for the previous 12 calendar months. The Permittee shall maintain a written record of the monthly mercury emission calculations. AMBIENT AIR MODELING Parameters Used in Modeling: The stack heights, emission rates, and other parameters used in the modeling 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. The information submitted must include, at a minimum, the locations, heights and diameters of the stacks, locations and dimensions of nearby buildings, the velocity, temperatures, moisture content, and pressures of the gases emitted, and the emission rates. The plume dispersion characteristics due to the revisions of the information must be equivalent to or better than the dispersion characteristics modeled. The Permittee shall demonstrate this equivalency in the proposal. If the information does not demonstrate equivalent or better dispersion characteristics, or if a conclusion cannot readily be made about the dispersion, the Permittee must remodel. For changes that do not require a permit amendment or require a minor permit amendment, the proposal must be submitted as soon as practicable, but no less than 60 days before beginning actual construction of the stack or associated EU. For changes that require a permit amendment other than a minor amendment, the modeling protocol must be approved prior to submittal of the permit application. LEAD AND FLUORIDE SAMPLING METHODOLOGY Sample and analyze for each lead or fluoride limit in listed Table A using: 1. EPA Method 6010B for lead; and 2. EPA Method 9056 for fluoride. Lead and Fluoride Concentration: For the first 12 consecutive months after initial start-up, the Permittee shall sample and analyze weekly. 1. If, after 12 consecutive months, each sample is less than the concentration limit or if the 95% UCL of all samples taken in the previous 12 month period is less than the concentration limit, the sampling frequency may be reduced to monthly. 2. If, thereafter, the 95% UCL of all samples taken in the previous 12 month period is greater than the limit, the Permittee shall sample and analyze weekly until the 95% UCL of all samples taken in a continuous 12 month period is less than the limit. The Permittee may then reduce the sampling frequency to monthly. 95% Upper Confidence Level (UCL): The Permittee shall use the following method for calculating the 95% UCL of feed material lead or fluoride concentration: - For samples for which the lead or fluoride (as applicable) is less than the detection limit, the Permittee shall assume a concentration of lead or fluoride equal to one-half the detection limit. - The Permittee shall calculate the 95% UCL using the EPA ProUCL (Version 3.0 or higher) software or using an Excel spreadsheet as illustrated in Appendix C. PERMIT ORGANIZATION Requirements listed at the group level apply individually to each associated item listed for the group, unless otherwise specified by a specific section header or requirement. A-5 Minn. R , subps. 2, 4, 5 & 16(J) Minn. R , subps. 2, 4, 5 & 16(J) Minn. R , subp. 2 & 6 Minn. R , subps. 2, 4, 5, 14 & 16(J) Title I Condition: 40 CFR 52.21(k); Minn. R Title I Condition: 40 CFR 52.21(k); Minn. R ; Minn. R , subp. 4 Minn. R , subp. 2 05/10/12

11 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-6 05/10/12 NESHAP GENERAL PROVISIONS - 40 CFR pt. 63, subp. A Each EU and FS at the facility is subject to NESHAPs, except for EUs 026, 049, 050, 067, 068, 084, 085, 110, 111, 113, 143, 144, and Prior to construction or reconstruction of an affected source under the promulgated MACT standards, the Permittee must apply for and obtain an air emission permit. Proper Operation and Maintenance: At all times, including periods of SSM, the Permittee shall operate and maintain the emission unit(s) subject to the MACT standard and its associated air pollution control and monitoring equipment in a manner consistent with safety and good air pollution control practices for minimizing emissions at least to the levels required by all relevant standards. Malfunctions: Malfunctions shall be corrected as soon as practicable after their occurrence. Prepare a written Startup, Shutdown, and Malfunction Plan (SSMP) for each of the emission units, including associated control and monitoring equipment, subject to MACT by the applicable MACT standard compliance date. The SSMP shall be prepared in accordance with 40 CFR Section 63.6(e)(3) and include requirements specified therein. The SSMP must be located at the plant site and must be kept updated. When the SSMP is updated, all previous versions of the SSMP shall be kept for a period of 5 years. The Permittee must submit the SSMP when required. When actions taken during a SSM event (including actions taken to correct a malfunction) are consistent with the procedures specified in the SSMP, keep records for that event which demonstrate that the procedures specified in the plan were followed. These records may take the form of a checklist, or other effective form of recordkeeping that shows conformance with the SSMP for that event. Also keep records of these events as specified in 40 CFR 63.10(b). Confirm that actions taken during the relevant reporting period during periods of SSM were consistent with the SSMP in the Semi-Annual SSM report required in 40 CFR 63.10(d)(5). NESHAP GENERAL PROVISIONS - MONITORING Operation and maintenance of CMS. Operate and maintain each CMS in a manner consistent with good air pollution control practices. The owner or operator must: - Maintain and operate each CMS as specified in section 63.6(e)(1); - Keep the necessary parts for routine repairs readily available; and - Develop a written SSMP for CMS as specified in section 63.6(e)(3). All CMS must be installed such that representative measures of emissions or process parameters from the affected source are obtained. In addition, CEMS must be located as specified in the applicable performance specification(s). The read out, or other indication of operation, from any CMS required for compliance with the emission standard must be readily accessible on site for operational control or inspection by the operator of the equipment. All CMS shall be installed, operational, and the data verified prior to or in conjunction with conducting performance tests under section Except for system breakdowns, out-of-control periods, repairs, maintenance periods, calibration checks, and zero (low-level) and high-level calibration drift adjustments, all CMS, including COMS and CEMS, shall be in continuous operation and shall complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period. Check the zero (low-level) and high-level calibration drifts at least once daily in accordance with the written procedure specified in the performance evaluation plan developed under 40 CFR 63.8(e)(3)(i)&(ii) for each installed CMS. The zero (lowlevel) and high-level calibration drifts must be adjusted, at a minimum, whenever the 24-hour zero (low-level) drift exceeds two times the limits of the applicable performance specification(s) specified in the relevant standard. The system shall allow the amount of excess zero (low-level) and high-level drift measured at the 24-hour interval checks to be recorded and quantified whenever specified. Develop and submit a site-specific performance evaluation test plan to the Commissioner for approval upon request in accordance with 40 CFR 63.8(e)(3)(i). The quality control program shall include, at a minimum, a written protocol that describes procedures for each of the following operations: 1. Initial and any subsequent calibration of the CMS; 2. Determination and adjustment of the calibration drift of the CMS; 3. Preventive maintenance of the CMS, including spare parts inventory; 4. Data recording, calculations, and reporting; 5. Accuracy audit procedures, including sampling and analysis methods; and 6. Program of corrective action for a malfunctioning CMS. Keep these written procedures on record for the life of the affected source or until the affected source is no longer subject to the provisions of this part. 40 CFR 63.1; Minn. R CFR 63.5(b)(3); Minn. R CFR 63.6(e)(1)(i); Minn. R CFR 63.6(e)(1)(ii); Minn. R CFR 63.6(e)(3)(i) & (v); Minn. R CFR 63.6(e)(3)(iii); Minn. R CFR 63.8(c)(1); Minn. R , subp CFR 63.8(c)(2); Minn. R , subp CFR 63.8(c)(3) & (4); Minn. R , subp CFR 63.8(c)(6); Minn. R , subp CFR 63.8(d)(2) & (3), and (e)(3)(i); Minn. R , subp. 2

12 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-7 05/10/12 Notification of performance evaluation. The Permittee shall notify the Commissioner in writing of the date of the performance evaluation simultaneously with the notification of the performance test date required under 40 CFR Section 63.7(b) or at least 60 days prior to the date the performance evaluation is scheduled to begin if no performance test is required. The Permittee shall conduct a performance evaluation of a required CMS during any performance test required under 40 CFR Section 63.7 in accordance with the applicable performance specification as specified in the relevant standard. If a performance test is not required, or the requirement for a performance test has been waived under 40 CFR 63.7(h), the Permittee shall conduct the performance evaluation not later than 180 days after the appropriate compliance date. The Permittee shall submit to the Commissioner a copy of a written report of the results of the performance evaluation simultaneously with the results of the performance test required under 40 CFR Section 63.7 or within 60 days of completion of the performance evaluation if no test is required. Reduction of monitoring data. The Permittee must reduce the monitoring data as specified in 40 CFR Section 63.8(g). NESHAP GENERAL PROVISIONS - RECORDKEEPING Recordkeeping: The Permittee shall maintain files of all information required by 40 CFR part 63 in a form suitable and readily available for expeditious inspection and review. The files should be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Only the most recent two years of information must be kept on site. The Permittee shall maintain, at a minimum, the following information in the files: 1. The occurrence and duration of each startup, shutdown, or malfunction of operation; 2. The occurrence and duration of each malfunction of the air pollution control equipment; 3. All maintenance performed on the pollution control equipment; 4. Actions taken during periods of SSM when such actions are different from the procedures specified in the affected source's SSMP. In this case, the Permittee shall report this action within 2 days of occurrence and follow by a written notification within 7 days of occurrence. 5. All information necessary to demonstrate conformance with the affected source's SSMP and actions taken in accordance with SSMP; 6. Each period during which a CMS is malfunctioning or inoperative; 7. All required measurements needed to demonstrate compliance with a relevant standard; 8. All results of performance test, CMS performance evaluations, and opacity and visible emission observations; 9. All measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 10. All CMS calibration checks; 11. All adjustments and maintenance performed on CMS; 12. Any information demonstrating whether a source is meeting the requirements for a waiver of record keeping or reporting requirements under this part; 13. All documents supporting initial notifications and notifications of compliance status. The Permittee shall maintain the following records for each CMS: 1. All required CMS measurements; 2. The date and time identifying each period during which the CMS was inoperative except for zero (low-level) and high-level checks; 3. The date and time identifying each period during which the CMS was out of control; 4. The specific identification (i.e., the date and time of commencement and completion) of each period of excess emissions and parameter monitoring exceedances, that occurs during startups, shutdowns, and malfunctions of the affected source; 5. The specific identification (i.e., the date and time of commencement and completion) of each time period of excess emissions and parameter monitoring exceedances that occurs during periods other than SSM of the affected source; 6. The nature and cause of any malfunction; 7. The corrective action taken or preventive measures adopted; 8. The nature of the repairs or adjustments to the CMS that was inoperative or out of control; 9. The total process operating time during the reporting period; and 10. All procedures that are part of a quality control program developed and implemented for CMS under 40 CFR Section 63.8(d). 40 CFR 63.8(e)(2); Minn. R , subp CFR 63.8(e)(4); Minn. R , subp CFR 63.8(e)(5); 40 CFR 63.10(e)(2); Minn. R , subp. 2; Minn. R , subp CFR 63.8(g); Minn. R , subp CFR 63.10(b)(1); Minn. R , subp CFR 63.10(b)(2); Minn. R , subp. 2 (continued) 40 CFR 63.10(b)(2); Minn. R , subp CFR 63.10(c); Minn. R , subp. 2 (continued) 40 CFR 63.10(c); Minn. R , subp. 2

13 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-8 05/10/12 NESHAP GENERAL PROVISIONS - NOTIFICATIONS Submit notifications required under 40 CFR part 63 to the Commissioner. In addition, send a copy of each notification to the appropriate Region V contact. Notification of the Actual Date of Initial Startup: due 15 days after initial startup. Submit the name and number of each unit and the actual date of initial startup of each unit. The Permittee shall submit a written notification of the date the CMS performance evaluation under 40 CFR Section 63.8(e) is scheduled to begin, submitted simultaneously with the notification of the performance test date required under 40 CFR Section 63.7(b). If no performance test is required, the Permittee shall submit a written notification of the date of the performance evaluation at least 60 calendar days before the evaluation is scheduled to begin. The Permittee shall submit a notification of compliance status to the Commissioner following completion of the relevant compliance demonstration activity specified in the relevant standard. The Permittee shall submit actual HAP emissions data and other information to verify that information submitted as part of the permit application is correct as soon as available but no later than with the initial notification of compliance. Change in information already provided. Any change in the information already provided under this 40 CFR Section 63.9 shall be provided to the Commissioner in writing within 15 calendar days after the change. Excess Emissions and CMS Report. The Permittee shall submit an excess emissions and continuous monitoring system performance report and/or a summary report to the Commissioner by the 30th day following the end of each calendar half. The report(s) shall include all the information required and in accordance with 40 CFR Section 63.10(e)(3). Immediate SSM reports: Any time an action taken by the Permittee during a startup or shutdown or malfunction (that caused the source to exceed any applicable emission limitation in the relevant emission standards), that is not consistent with the procedures specified in the affected source's SSMP, the Permittee shall report the actions taken for that event within 2 working days after commencing the actions followed by a letter within 7 working days after the end of the event. The reports must be in accordance with 40 CFR Section 63.10(d)(5)(ii). 40 CFR 63.9(a); Minn. R , subp CFR 63.9(b)(4)(v); Minn. R , subp CFR 63.9(g)(1); Minn. R , subp CFR 63.9(h)(3); Minn. R , subp CFR 63.9(h)(5); Minn. R , subp CFR 63.9(j); Minn. R , subp CFR 63.10(e)(3)(i) & (v); Minn. R , subp CFR 63.10(d)(5)(ii); 40 CFR 63.6(e)(3)(iv); Minn. R ; Minn. R , subp. 2

14 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-9 05/10/12 Subject Item: GP 001 Mobile Sources What to do OPERATIONAL REQUIREMENTS AND LIMITS Mobile Sources. The mobile sources affected by the requirements of this part are the following emission sources modeled as part of the visibility demonstration: 1. Diesel-driven Haul Trucks; 2. Diesel-driven Mining Shovels; 3. Diesel-driven Locomotives; 4. Diesel-driven Front-End Loaders. Fuel Usage for Haul Trucks and Mining Equipment: Diesel Fuel only. Fuel Usage: less than or equal to 4.3 million gallons/year for all haul trucks and mining equipment combined. Sulfur Content of Fuel: less than or equal to 15 ppm in diesel fuel. The Permittee may use fuel supplier certification to demonstrate compliance with this requirement. Permitted number of mobile sources prior to startup of DRI & Steel Mill: The diesel driven mobile sources at the facility prior to the startup of the DRI & Steel Mill shall be certified Tier 2 or higher, at quantities at any one time not to exceed: - 8 Haul Trucks - 3 Mining Shovels - 2 Blast-hole Drills - 13 Total Front-End Loaders, Dozers, Graders, Locomotives, Sand&Water Trucks Permitted number of mobile sources after startup of the DRI & Steel Mill: The diesel driven mobile sources at the facility after startup of the DRI & Steel Mill shall be certified Tier 4, at quantities at any one time not to exceed: - 9 Haul Trucks - 4 Mining Shovels - 3 Blast-hole Drills - 14 Total Front-End Loaders, Dozers, Graders, Locomotives, Sand&Water Trucks There shall be no non-certified Tier 4 mobile sources after DRI & Steel Mill startup. Compliance certification requirements for Tier 2 mobile sources: Steady-State exhaust emissions from non-road diesel engines may not exceed: PM: <= 0.15 g/hp-hr CO: <= 2.6 g/hp-hr NOx: <= 4.9 g/hp-hr for rated engine power >= 175 hp but < 300 hp; NOx: <= 4.8 g/hp-hr for rated engine power >= 300 hp Compliance certification requirements for Tier 4 mobile sources: Steady-State exhaust emissions from non-road diesel engines may not exceed: CO: <= 2.6 g/bhp-hr NMHC: <= 0.14 g/bhp-hr For maximum engine power >= 175 hp and <= 750 hp: PM: <= g/bhp-hr NOx: <= 0.30 g/bhp-hr For maximum engine power > 750 hp: PM: <= g/bhp-hr NOx: <= 2.6 g/bhp-hr Operate and maintain the mobile sources in accordance to a written O&M Plan at all times. Keep copies of the O&M Plan onsite and available for inspection upon request. RECORDKEEPING The Permittee shall obtain and maintain a record of the monthly fuel supplier certification for diesel fuel, certifying that the sulfur content does not exceed 15ppm. The Permittee shall obtain and maintain a record of the fuel supplier receipt for the volume of fuel delivered for each shipment of diesel fuel to demonstrate compliance with the diesel fuel use limitation. The Permittee shall certify that the mobile sources in the group were operated and maintained in compliance with the manufacturers recommended maintenance procedures, practices, and schedules. The Permittee shall retain all documents pertaining to purchasing, operations, and required maintenance to Tier 4 mobile sources. Why to do it Title I Condition: 40 CFR 52.21(p); Minn. R Minn. R , subp. 35a Title I Condition: 40 CFR 52.21(p); Minn. R ; Minn. R , subp CFR (b) Title I Condition: 40 CFR 52.21(p); Minn. R ; Minn. R , subp. 2 Title I Condition: 40 CFR 52.21(p); Minn. R ; Minn. R , subp. 2 Title I Condition: 40 CFR 52.21(p); Minn. R ; 40 CFR (a); Minn. R , subp. 2 Title I Condition: 40 CFR 52.21(p); Minn. R ; 40 CFR (b); Minn. R , subp. 2 Minn. R , subps. 4 & 16(J) Minn. R , subps. 4 & 5 Minn. R , subps. 4 & 5 Minn. R subp. 4 Minn. R subp. 5

15 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-10 05/10/12 Subject Item: Associated Items: GP 002 Emission Units Subject to Taconite MACT and NSPS LL EU 002 Primary Ore Crusher EU 004 Grizzly Screening Building EU 013 Coarse Ore Storage Conveyor EU 014 Fine Ore Storage Conveyor EU 015 Coarse Ore Conveyor Gallery EU 018 Fine Ore Conveyor Gallery EU 022 Primary Grinding Mill Line 1 EU 024 Primary Grinding Mill Line 2 EU 036 Hearth Layer Bin EU 037 Hearth Layer Feed EU 038 Indurating Furnace, Hood Exhaust EU 039 Indurating Furnace, Furnace Waste Gas EU 040 Pellet Discharge EU 041 Pellet Screening and Handling EU 042 Pellet Screenings to Regrind Conveyors EU 048 Oxide Pellet Stockpile Conveyor Gallery EU 054 DRI Oxide Pellet Screening and Handling Line 1 EU 060 DRI Pellet Silos Line 1 EU 063 DRI Oxide Charging Area Line 1 EU 106 Oxides Pellet Transfer to Hearth Layer Bin EU 170 Grizzly Transfer Tower EU 171 Non-Magnetic Cobber Rejects Transfer Tower EU 172 Secondary Screening Crusher/Cobber Line 1 EU 173 Secondary Screening Crusher/Cobber Line 2 EU 174 Secondary Screening Crusher/Cobber Line 3 EU 175 Secondary Screening Crusher/Cobber Line 4 EU 176 Primary Grinding Mill Line 3 OPERATIONAL REQUIREMENTS What to do No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. At all times, including periods of SSM, owners and operators shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions, in accordance with 40 CFR 60.11(d). MONITORING Operate and maintain each source, including air pollution control and monitoring equipment, in a manner consistent with good air pollution control practices for minimizing emissions at least to the levels required by Taconite MACT. O&M Plan: The plan shall meet the requirements of 40 CFR (b)(1)-(4), a current copy of the O&M plan maintained onsite, and available for inspection upon request. Keep the plan for the life of the affected source or until the affected source is no longer subject to the requirements of 40 CFR part 63, subpart RRRRR. The Permittee shall monitor continuously (or collect data at all required intervals) at all times an affected source is operating except for monitoring malfunctions, associated repairs, and required quality assurance or control activities (including as applicable, calibration checks and required zero and span adjustments). 40 CFR CFR 60.11(d) 40 CFR (a); Minn. R CFR (b); 40 CFR (b); Minn. R CFR (a); Minn. R Why to do it

16 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-11 05/10/12 Data recorded during monitoring malfunctions, associated repairs, and required QA/QC activities shall not be used in data averages and calculations used to report emission or operating levels, or to fulfill a minimum data availability requirement. Use all data collected during all other periods in assessing compliance. If the daily average operating parameter value for an emission unit or group of similar emission units does not meet the corresponding established operating limit, the Permittee must then follow the following procedures: 40 CFR (b); Minn. R CFR (j); Minn. R The Permittee must initiate and complete initial corrective action within 10 calendar days and demonstrate that the initial corrective action was successful. During any period of corrective action, the Permittee must continue to monitor and record all required operating parameters for equipment that remains in operation. After 10 calendar days, measure and record the daily average operating parameter value for the emission unit or group of similar emission units on which corrective action was taken. 2. If the initial corrective action required in (1) was not successful, then the Permittee must complete additional corrective action within 10 calendar days and demonstrate that the subsequent corrective action was successful. After the second set of 10 calendar days allowed to implement corrective action, the Permittee must again measure and record the daily average operating parameter value for the emission unit or group of similar emission units. 3. If the second attempt at corrective action required in paragraph (2) was not successful, then the Permittee must repeat the procedures until the corrective action is successful. If the third attempt at corrective action is unsuccessful, the Permittee must conduct another performance test in accordance with the procedures in 40 CFR Section (f) and report to the Commissioner as a deviation the third unsuccessful attempt at corrective action. 4. After the third unsuccessful attempt at corrective action, the Permittee must submit the written report required in (3) within 5 calendar days after the third unsuccessful attempt at corrective action. This report must notify the Commissioner that a deviation has occurred and document the types of corrective measures taken to address the problem that resulted in the deviation of established operating parameters and the resulting operating limits. Deviations. The Permittee must report each instance in which an emission limitation was not met. This includes periods of SSM. The Permittee must report each instance in which a work practice standard in 40 CFR was not met. The Permittee must report each instance in which an applicable operation and maintenance requirement in 40 CFR was not met. These deviations must be reported in accordance with the requirements in 40 CFR During periods of SSM, the Permittee must operate in accordance with the SSMP and the requirements in 40 CFR Section (b)(1)&(2). RECORDKEEPING The Permittee shall keep the following records: - A copy of each notification and report that you submitted to comply with 40 CFR part 63, subpart RRRRR. - The records in 40 CFR Section 63.6(e)(3)(iii)-(v) related to SSM. - Records of performance tests and performance evaluations as required in Section 63.10(b)(2)(viii). The Permittee shall also keep the records required in 40 CFR Sections through to show continuous compliance with each emission limitation, work practice standard, and operation and maintenance requirement that apply. Each record shall be kept for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Each record shall be kept on site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record. Maintain records of the occurrence and duration of any SSM event in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a CMS or monitoring device is inoperative. REPORTING Notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. Submit all notifications of compliance status to the Commissioner following completion of the specified compliance demonstration activity. (continued) 40 CFR (j); Minn. R (continued) 40 CFR (j); Minn. R CFR (a); Minn. R CFR (b); Minn. R CFR (a)&(c); 40 CFR (b)&(c); Minn. R ; 40 CFR 60.7(f); Minn. R , subp CFR 60.7(b); Minn. R , subp CFR 60.7(a)(4); Minn. R , subp CFR 63.9(h)(3); Minn. R , subp. 2 Meet the notification and schedule requirements in 40 CFR Section CFR ; Minn. R

17 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: Essar Steel Minnesota LLC Submit the initial notification of compliance status (including the performance test results) for each emission limitation and operating limit by the following dates: 1. Before the close of business on the 30th calendar day following completion of the initial compliance demonstration that does not include a performance test; 2. Before the close of business on the 60th calendar day following completion of the initial compliance demonstration that does include a performance test. Immediate SSM reports. Any time an action taken by the Permittee during a startup or shutdown or malfunction (that caused the source to exceed any applicable emission limitation in the relevant emission standards), that is not consistent with the procedures specified in the affected source's SSMP, the Permittee shall report the actions taken for that event within 2 working days after commencing the actions followed by a letter within 7 working days after the end of the event. The reports must be in accordance with 40 CFR Section 63.10(d)(5)(ii). Immediate corrective action report. The Permittee shall submit an immediate corrective action report if three unsuccessful attempts of applying corrective action as described in 40 CFR Section (j) were made on an emission unit or group of emission units. Also, within 5 calendar days after the third unsuccessful attempt at corrective action, the Permittee shall submit to the Commissioner a written report in accordance with 40 CFR Section (j)(3)&(4). Compliance Report Contents. Each compliance report must include the information in paragraphs (1)-(3) and, as applicable, in paragraphs (4)-(8). 1. Company name and address. 2. Statement by a responsible official, with the official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report. 3. Date of report and beginning and ending dates of the reporting period. 4. If you had a startup, shutdown, or malfunction during the reporting period and you took actions consistent with your SSMP, the compliance report must include the information in Section 63.10(d)(5)(i). 5. If there were no deviations from the continuous compliance requirements in Sections that apply to you, then provide a statement that there were no deviations from the emission limitations, work practice standards, or operation and maintenance requirements during the reporting period. 6. If there were no periods during which a CMS (including a CPMS) was out-ofcontrol as specified in Section 63.8(c)(7), then provide a statement that there were no periods that a CMS was out-of-control during the reporting period. 7. For each deviation from an emission limitation in Table 1 to this subpart that occurs at an affected source where you are not using a CMS (including a CPMS) to comply with an emission limitation, the compliance report must contain the information in paragraphs (1)-(4) of this section and the information in paragraphs (7)(i)&(ii). This includes periods of SSM. i. The total operating time of each affected source during the reporting period. ii. Information on the number, duration, and cause of deviations (including unknown cause) as applicable, and the corrective action taken. 8. For each deviation from an emission limitation occurring at an affected source a CMS (including a CPMS) is used to comply with the emission limitation, the Permittee must include the information in paragraphs (1)-(4) and the information in paragraphs (8)(i)-(xi). This includes periods of SSM. i. The date and time that each malfunction started and stopped. ii. The date and time that each CMS was inoperative, except for zero (low-level) and high-level checks. iii. The date, time, and duration that each CMS was out-of-control, including the information in Section 63.8(c)(8). iv. The date and time that each deviation started and stopped, and whether each deviation occurred during a period of startup, shutdown, or malfunction or during another period. v. A summary of the total duration of the deviation during the reporting period and the total duration as a percent of the total source operating time during that reporting period. vi. A breakdown of the total duration of the deviations during the reporting period including those that are due to startup, shutdown, control equipment problems, process problems, other known causes, and other unknown causes. vii. A summary of the total duration of CMS downtime during the reporting period and the total duration of CMS downtime as a percent of the total source operating time during the reporting period. viii. A brief description of the process units. ix. A brief description of the CMS. x. The date of the latest CMS certification or audit. xi. A description of any changes in continuous monitoring systems, processes, or controls since the last reporting period. 40 CFR (e); 40 CFR (c); 40 CFR 63.9(h)(2)(ii); Minn. R CFR 63.10(d)(5)(ii); 40 CFR (c); Minn. R , subp. 2; Minn. R CFR (e); Minn. R CFR (b); Minn. R (continued) 40 CFR (b); Minn. R (continued) 40 CFR (b); Minn. R (continued) 40 CFR (b); Minn. R A-12 05/10/12

18 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-13 05/10/12 Subject Item: Associated Items: GP 003 Ore Crushing & Handling EU 002 Primary Ore Crusher EU 004 Grizzly Screening Building EU 013 Coarse Ore Storage Conveyor EU 014 Fine Ore Storage Conveyor EU 015 Coarse Ore Conveyor Gallery EU 018 Fine Ore Conveyor Gallery EU 022 Primary Grinding Mill Line 1 EU 024 Primary Grinding Mill Line 2 EU 170 Grizzly Transfer Tower EU 171 Non-Magnetic Cobber Rejects Transfer Tower EU 172 Secondary Screening Crusher/Cobber Line 1 EU 173 Secondary Screening Crusher/Cobber Line 2 EU 174 Secondary Screening Crusher/Cobber Line 3 EU 175 Secondary Screening Crusher/Cobber Line 4 EU 176 Primary Grinding Mill Line 3 BACT LIMITS What to do Crude Ore Lead Concentration: less than or equal to 12 mg/kg using 12-month rolling average lead concentration of crude ore handled by the sources listed in this group. Crude Ore Fluoride Concentration: less than or equal to 1.0 mg/kg using 12-month rolling average fluoride concentration of crude ore handled by the sources listed in this group. MONITORING AND RECORDKEEPING Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. Crude Ore Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the crude ore lead and/or fluoride concentration. MACT LIMITS See GP 008 for MACT emission limits for these units. PERFORMANCE TESTING See GP 008 for Performance Testing requirements for these units. Why to do it Title I Condition: 40 CFR 52.21(j) & (k): ; Minn. R , subp. 5

19 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-14 05/10/12 Subject Item: Associated Items: GP 004 Finished Pellet Handling EU 036 Hearth Layer Bin EU 037 Hearth Layer Feed EU 040 Pellet Discharge EU 041 Pellet Screening and Handling EU 042 Pellet Screenings to Regrind Conveyors EU 048 Oxide Pellet Stockpile Conveyor Gallery EU 054 DRI Oxide Pellet Screening and Handling Line 1 EU 060 DRI Pellet Silos Line 1 EU 063 DRI Oxide Charging Area Line 1 EU 106 Oxides Pellet Transfer to Hearth Layer Bin BACT LIMITS What to do Oxide Pellet Lead Concentration: less than or equal to 2.0 mg/kg using 12-month rolling average lead concentration of oxide pellets handled by the sources listed in this group. Oxide Pellet Fluoride Concentration: less than or equal to 50. mg/kg using 12-month rolling average fluoride concentration of oxide pellets handled by the sources listed in this group. MONITORING AND RECORDKEEPING Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. Oxide Pellet Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the oxide pellet lead and/or fluoride concentration. MACT LIMITS See GP 008 for MACT emission limits for these units. PERFORMANCE TESTING See GP 008 for Performance Testing requirements for these units. Why to do it Title I Condition: 40 CFR 52.21(j) & (k): ; Minn. R , subp. 5

20 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-15 05/10/12 Subject Item: Associated Items: GP 005 Waste Rock Handling FS 004 Waste Rock Loadout FS 005 Waste Rock Unloading (Truck) FS 009 Overburden / Waste Rock Area Wind Erosion BACT LIMITS What to do Waste Rock Lead Concentration: less than or equal to 8.4 mg/kg using 12-month rolling average lead concentration of waste rock handled by the sources listed in this group. Waste Rock Fluoride Concentration: less than or equal to 0.7 mg/kg using 12-month rolling average fluoride concentration of waste rock handled by the sources listed in this group. MONITORING AND RECORDKEEPING Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. Waste Rock Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the waste rock lead and/or fluoride concentration. Why to do it Title I Condition: 40 CFR 52.21(j) & (k): ; Minn. R , subp. 5

21 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-16 05/10/12 Subject Item: GP 006 Fugitive Sources What to do Why to do it Associated items for this group consist of all the fugitive sources at the facility. Minn. R , subp. 2 The following regulations apply to the following fugitive sources at the facility: Taconite MACT - FS , and Case-by-Case MACT - FS , and NSPS LL - FS , and EMISSION LIMITS Opacity: less than 5 percent opacity using 6-minute Average Opacity: less than 10 percent opacity using 6-minute Average FUGITIVE CONTROL PLAN The Permittee shall prepare and at all times operate according to, a fugitive dust emissions control plan that describes in detail the measures that will be put in place to control fugitive dust emissions from: 1. Stockpiles; 2. Material transfer points; 3. Material handling; 4. Plant roadways; 5. Tailings basin; 6. Pellet/DRI/Slag loading areas; and 7. Yard areas. The Permittee shall maintain a current copy of the fugitive dust emissions control plan onsite, and it must be available for inspection upon request. The plan must be kept for the life of the affected source. Submit a fugitive emissions control plan before startup for review and approval by the Commissioner (see Table B). The plan shall identify all fugitive emission sources, primary and contingent control measures, and recordkeeping. Follow the actions and recordkeeping specified in the control plan. The plan may be amended by the Permittee with the Commissioner's approval. If the Commissioner determines the Permittee is out of compliance with Minn. R or the fugitive emission control plan, then the Permittee may be required to amend the control plan and/or to install and operate particulate matter ambient monitors. VISIBLE EMISSION CHECKS Check for Visible Emissions (VEs) daily (during daylight hours) from fugitive emission sources while in operation. Corrective Actions: If visible emissions are observed, determine the cause and take corrective actions as soon as possible to eliminate the VEs. Recordkeeping: Record the time and date of each VE inspection and whether or not any VEs were observed. If VEs were observed, also record a brief description of the corrective action taken, and the date the action was taken. PERFORMANCE TESTING Opacity Compliance: Demonstrate compliance with opacity standards using Reference Method 9, and only when emissions are clearly identified as emanating solely from the source being observed. 40 CFR (b) and Minn. R ; 40 CFR 63.43(g)(2): MACT and Minn. R CFR (b); Minn. R CFR (a) & (d); 40 CFR ; 40 CFR 63.43(g)(2): MACT and Minn. R Minn. R , subp. 2 Minn. R , subp. 4 Minn. R , subp. 2 Minn. R , subp CFR (b)(2); 40 CFR 60.11; Minn. R Initial Performance Test: due 180 days after Initial Startup for opacity from FS CFR (b)(2) and Minn. R Initial Performance Test: due 180 days after Initial Startup for opacity from FS CFR (b)(2) and Minn. R Initial Performance Test: due 180 days after Initial Startup for opacity from FS CFR (b)(2) and Minn. R Initial Performance Test: due 180 days after Initial Startup for opacity from FS CFR (b)(2) and Minn. R Initial Performance Test: due 180 days after Initial Startup for opacity from FS CFR (b)(2) and Minn. R Initial Performance Test: due 180 days after Initial Startup for opacity from FS CFR (b)(2) and Minn. R Initial Performance Test: due 180 days after Initial Startup for opacity from FS CFR (b)(2) and Minn. R Initial Performance Test: due 180 days after Initial Startup for opacity from FS CFR (b)(2) and Minn. R Initial Performance Test: due 180 days after Initial Startup for opacity from FS CFR (b)(2) and Minn. R

22 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-17 05/10/12 Subject Item: Associated Items: GP 007 Baghouses with Leak Detection CE 001 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 002 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 006 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 007 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 008 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 009 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 010 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 011 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 014 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 015 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 016 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 019 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 021 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 022 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 023 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 024 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 025 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 040 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 093 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 097 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 110 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 111 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 112 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 113 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 114 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 115 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 116 Fabric Filter - Low Temperature, i.e., T<180 Degrees F What to do Stacks associated with each baghouse are shown in the following pairs: Why to do it CE 001/SV 001 CE 011/SV 011 CE 023/SV 022 CE 111/SV 087 CE 002/SV 002 CE 014/SV 016 CE 024/SV 023 CE 112/SV 088 CE 006/SV 006 CE 015/SV 017 CE 025/SV 027 CE 113/SV 089 CE 007/SV 007 CE 016/SV 018 CE 040/SV 044 CE 114/SV 090 CE 008/SV 008 CE 019/SV 019 CE 093/SV 073 CE 115/SV 085 CE 009/SV 009 CE 021/SV 020 CE 097/SV 031 CE 116/SV 084 CE 010/SV 010 CE 022/SV 021 CE 110/SV 086 Install, operate, and maintain a bag leak detection system according to the requirements in 40 CFR Section (a) for each CE listed in this group. The Permittee shall identify and implement a set of site-specific preventative maintenance and corrective action plan including the following: 40 CFR (a); 40 CFR 64.7(a) & (c): CAM and Minn. R CFR (b)(1) & (2); 40 CFR 64.7(a) & (c): CAM and Minn. R Preventative maintenance for each control device, including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance. 2. Corrective action procedures for bag leak detection systems. In the event a bag leak detection system alarm is triggered, the Permittee shall initiate corrective action to determine the cause of the alarm within 1 hour of the alarm, initiate corrective action to correct the cause of the problem within 24 hours of the alarm, and complete the corrective action as soon as practicable. Corrective actions may include, but are not limited to: i. Inspecting the baghouse for air leaks, torn or broken bags or filter media, or any other condition that may cause an increase in emissions.

23 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-18 05/10/12 ii. Sealing off defective bags or filter media. iii. Replacing defective bags or filter media or otherwise repairing the control device iv. Sealing off a defective baghouse compartment. v. Cleaning the bag leak detection system probe, or otherwise repairing the bag leak detection system. vi. Adjusting the process operation producing the particulate emissions. The Permittee shall conduct inspections to: 1. Monitor the pressure drop across each baghouse cell each day to ensure pressure drop is within the normal operating range. 2. Confirm that dust is being removed from hoppers through weekly visual inspections or other means of ensuring the proper functioning of removal mechanisms. 3. Check the compressed air supply of pulse-jet baghouses each day. 4. Monitor cleaning cycles to ensure proper operation using an appropriate methodolgy. 5. Check bag cleaning mechanisms for proper functioning through monthly visual inspections or equivalent means. 6. Make monthly visual checks of bag tension on reverse air and shaker-type baghouses. 7. Confirm the physical integrity of the baghouse through quarterly visual inspections of the baghouse interior for air leaks. 8. Inspect fans for wear, material buildup, and corrosion through quarterly visual inspections, vibration detectors, or equivalent means. Maintain records of the time corrective action is initiated in the event of a bag leak detection system alarm, the corrective action(s) taken, and the date on which corrective action was completed. Inspect and maintain each baghouse according to the requirements in 40 CFR Section (a)(1)-(8) and record all the information needed to document conformance with these requirements. (continued) 40 CFR (b)(1) & (2); 40 CFR 64.7(a) & (c): CAM and Minn. R CFR (a); 40 CFR 64.7(a) & (c): CAM and Minn. R CFR (d); 40 CFR 64.7(a) & (c): CAM and Minn. R If the Permittee increases or decreases the sensitivity of the bag leak detection system beyond the limits specified in the site-specific monitoring plan, the Permittee shall include a copy of the required written certification by a responsible official in the next semiannual compliance report. The Permittee shall: 1. Perform preventative maintenance for each control device in accordance with a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance and record all information needed to document conformance with these requirements; and 2. Initiate and complete corrective action for a bag leak detection system alarm in accordance with 40 CFR (b)(2) and record all information needed to document conformance with these requirements. Operating limits may be changed for any air pollution control device if the Permittee: 1. Submits a written notification to the Commissioner requesting to conduct a new performance test to revise the operating limit. 2. Conducts a performance test to demonstrate compliance with the applicable emission limitation. 3. Establishes revised operating limits according to the applicable procedures in 40 CFR Section (a). 40 CFR (a)(1) & (2); 40 CFR 64.7(a) & (c): CAM and Minn. R CFR (f); Minn. R

24 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-19 05/10/12 Subject Item: Associated Items: GP 008 Baghouses Subject to Taconite MACT SV 001 Primary Ore Crusher SV 002 Grizzly Screening Building SV 006 Coarse Ore Storage Conveyor SV 007 Fine Ore Storage Conveyor SV 008 Coarse Ore Conveyor Gallery SV 009 Fine Ore Conveyor Gallery SV 010 Primary Grinding Mill Line 1 SV 011 Primary Grinding Mill Line 2 SV 016 Hearth Layer Bin SV 017 Hearth Layer Feed SV 020 Pellet Discharge SV 021 Pellet Screening and Handling SV 022 Pellet Screenings to Regrind Conveyors SV 023 Oxide Pellet Stockpile Conveyor Gallery SV 027 DRI Oxide Pellet Screening and Handling System Line 1 SV 031 DRI Oxide Charging Area Line 1 SV 073 DRI Pellet Silos Line 1 SV 084 Primary Grinding Mill Line 3 SV 085 Grizzly Transfer Tower SV 086 Non-Magnetic Cobber Rejects Transfer Tower SV 087 Secondary Screening Crusher/Cobber Line 1 SV 088 Secondary Screening Crusher/Cobber Line 2 SV 089 Secondary Screening Crusher/Cobber Line 3 SV 090 Secondary Screening Crusher/Cobber Line 4 BACT LIMITS What to do Appendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Total PM: comply with the Total PM limits on a gr/dscf and lb/hr basis using a 3-hour average. PM < 10 micron: comply with the PM10 limits on a gr/dscf and lb/hr basis using a 3-hour average. PM < 2.5 micron: comply with the PM2.5 limits on a gr/dscf and lb/hr basis using a 3-hour average. Lead: comply with the lead limits on a lb/hr basis using a 3-hour average. Fluorides: comply with the fluoride limits on a lb/hr basis using a 3-hour average. Opacity: less than or equal to 5 percent opacity using 6-minute Average OTHER EMISSION LIMITS Emission limits listed in this section apply individually to each stack, however compliance with the above limits will demonstrate compliance with these limits. Total PM: less than or equal to gr/dscf using 3-hour average and on the basis of a flow-weighted mean concentration. Determine the flow-weighted mean concentration of Total PM emissions from all SVs in this group as described in 40 CFR (b)(3)(i) or (ii). Total PM: less than 0.02 gr/dscf using 3-hour average. Why to do it Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Minn. R , subp CFR (a); 40 CFR (b); 40 CFR (a)(1); Minn. R CFR (a)(1); Minn. R Opacity: less than or equal to 7 percent opacity using 6-minute Average 40 CFR (a)(2) and Minn. R

25 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: PERFORMANCE TESTING Essar Steel Minnesota LLC The Source Groups referenced by the following testing requirements are as defined in Appendix E, which also describes testing requirements for PM2.5. Notification of Anticipated Date for Conducting Opacity Observations: due 30 day prior to observation date Demonstrate compliance with opacity standards using Reference Method 9. The opacity standards apply at all times except during periods of SSM. For the purpose of demonstrating initial compliance, conduct opacity observations concurrently with the initial performance test and include the results in the test report, pursuant to the conditions described in 40 CFR 60.11(e)(1)-(3). The test plan (see Table B) for the initial PM tests shall contain the following: 1. A list of all emission units. This list must clearly identify all emission units that have been grouped together as similar emission units. Within each group of emission units, the Permittee must identify the emission unit that will be the representative unit for that group and subject to initial performance testing. 2. A list of the process type and type of air pollution control device on each emission unit. 3. A schedule indicating when an initial performance test for PM, PM10, PM2.5, and opacity for each representative emission unit will be conducted. Initial Performance Test: due 180 days after Initial Startup to measure Total PM, PM10, and opacity from one stack from each of the following: Group A, Group B, Group C, and Group D sources. The PM performance test shall also demonstrate compliance with the MACT limit on a flow-weighted mean concentration basis. Initial Performance Test: due 180 days after Initial Startup to measure PM2.5 from two stacks from each of the following: Group A, Group B, Group C, and Group D sources. Performance Test: due before end of each calendar 24 months following Initial Performance Test to measure Total PM, PM10, PM2.5, and opacity from one stack from each of the following: Group A, Group B, Group C, and Group D sources. To the extent practicable, the performance tests shall cycle through each member of each group. The PM performance test shall also demonstrate compliance with the MACT limit on a flow-weighted mean concentration basis. The site-specific operating limits established for the emission unit selected as representative of a group of similar emission units will be used as the operating limit for each emission unit within the group. The operating limit established for the representative unit must be met by each emission unit within the group. For emission units not selected for initial performance testing and defined within a group of similar emission units in accordance with 40 CFR Section (e), the Permittee shall calculate the daily average value of each operating parameter for the similar air pollution control device applied to each similar emission unit within a defined group using the following equation. Pk = (sum of all Pi)/n 40 CFR 60.7(a)(4); Minn. R , subp CFR 60.11; Minn. R CFR 60.11(e)(1)-(3) 40 CFR 9620(g); Minn. R A-20 Title I Condition: 40 CFR 52.21(j) & (k): ; 40 CFR (a), (c), & (e); Minn. R ; Minn. R , subp. 1 Title I Condition: 40 CFR 52.21(j) & (k): ; 40 CFR (a), (c), & (e); Minn. R ; Minn. R , subp. 1 ; 40 CFR (a) & (c); 40 CFR (e); Minn. R ; Minn. R , subp CFR (f)(3); Minn. R CFR (b); Minn. R /10/12 Where: Pk = Daily average operating parameter value for all emission units within group k; Pi = Daily average parametric monitoring parameter value corresponding to emission unit i within the group; and n = Total number of emission units within the group. Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. MONITORING See GP 007 for Bag Leak Detection systems required for baghouses. Title I Condition: 40 CFR 52.21(j) & (k): 40 CFR (a); Minn. R ; 40 CFR 64.7(a) & (c): CAM and Minn. R

26 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-21 05/10/12 Subject Item: Associated Items: GP 009 EAF Baghouses CE 040 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 043 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 044 EAF Baghouse Line 1 SV 047 EAF Baghouse Dust Transfer Line 1 BACT LIMITS What to do Appendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Total PM: comply with the Total PM limits on a gr/dscf and lb/hr basis using a 3-hour average. PM < 10 micron: comply with the PM10 limits on a gr/dscf and lb/hr basis using a 3-hour average. PM < 2.5 micron: comply with the PM2.5 limits on a gr/dscf and lb/hr basis using a 3-hour average. Lead: comply with the lead limits on a lb/hr basis using a 3-hour average. Fluorides: comply with the fluoride limits on a lb/hr basis using a 3-hour average. Sulfur Dioxide: comply with the SO2 limits on a lb/ton of steel produced and lb/hr basis using a 1-hour average from SV 044. Sulfuric Acid Mist: comply with the SAM limits on a lb/ton of liquid steel produced and lb/hr basis using a 3-hour average from SV 044. Nitrogen Oxides: comply with the NOx limits on a lb/ton liquid steel produced on a 30-day rolling average and lb/hr using 24-hour rolling average basis from SV 044. Nitrogen Oxides: comply with the NOx SSM limits using 1-hour rolling average from SV 044. This limit applies during periods of startup (for no longer than 36 hours) and shutdown (for no longer than 28 hours). Carbon Monoxide: comply with the CO limits on a lb/ton of liquid steel produced and lb/hr basis using a 1-hour Rolling Average from SV 044. Volatile Organic Compounds: comply with the VOC limits on a lb/ton of liquid steel produced and lb/hr basis using a 3-hour average from SV 044. Opacity: less than 3 percent opacity using 6-minute Average from SV 044. This also demonstrates compliance with Minn. R , subp. 1(B). Opacity: less than or equal to 5 percent opacity using 6-minute Average from SV 047. This also demonstrates compliance with 40 CFR (a)(2). OTHER EMISSION LIMITS Why to do it Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): ; 40 CFR 63.43(g)(1): MACT and Minn. R ; 40 CFR a(a)(2); Minn. R , subp. D; Minn. R , subp. 1(B) ; 40 CFR (a)(2); Minn. R Emission limits listed in this section apply individually to each stack, however Minn. R , subp. 2 compliance with the above limits will demonstrate compliance with these limits. Total PM: less than gr/dscf using 3-hour average from SV CFR a(a)(1); Minn. R , subp. D; Minn. R , subps. 1(A) & 3 Total PM: less than 0.02 gr/dscf using 3-hour average from SV CFR (a)(1); Minn. R Total PM: less than or equal to gr/dscf using 3-hour average and on the basis of a flow-weighted mean concentration. Determine the flow-weighted mean concentration of Total PM emissions from all SVs in this group as described in 40 CFR (b)(3)(i) or (ii). EAF BAGHOUSE DUST TRANSFER LIMITS (SV 047 only) EAF Baghouse Dust Lead Concentration: less than or equal to 8000 mg/kg using 12-month rolling average lead concentration of EAF baghouse dust handled by the dust transfer baghouses listed in this group. EAF Baghouse Dust Fluoride Concentration: less than or equal to 4600 mg/kg using 12-month rolling average fluoride concentration of EAF baghouse dust handled by the dust transfer baghouses listed in this group. 40 CFR (a); 40 CFR (b); 40 CFR (a)(1); Minn. R

27 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-22 05/10/12 PERFORMANCE TESTING Initial Performance Test: due 180 days after Initial Startup of EU 125 for Total PM, PM10, and PM2.5 emissions from SV 044. The PM test shall also demonstrate compliance with the MACT limit on a flow-weighted mean concentration basis. Initial Performance Test: due 180 days after Initial Startup of EU 125 for opacity from SV 044. Initial Performance Test: due 180 days after Initial Startup of EU 125 for VOC emissions from SV 044. Initial Performance Test: due 180 days after Initial Startup of EU 125 for sulfuric acid mist from SV 044. Initial Performance Test: due 180 days after Initial Startup of EU 125 for lead from SV 044. Three 3-hour tests may be performed rather than three 1-hour tests because a low concentration of lead in the stack gases is anticipated. Initial Performance Test: due 180 days after Initial Startup of EU 125 for mercury from SV 044. The Permittee shall speciate the mercury emitted. Initial Performance Test: due 180 days after Initial Startup of EU 125 for PCDD/PCDF from SV 044. Performance Test: due before end of each year following Initial Performance Test to measure mercury emissions from SV 044. Shall be performed no sooner than 30 days from any other mercury test. Performance Test: due before end of each year following Initial Performance Test to measure PCDD/PCDF emissions from SV 044. Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. STACKS WITH CEMS - EAF BAGHOUSE (SV 044) Install, operate, and maintain bag leak detection systems according to the requirements in GP 007 (CE 040). Install, operate, and maintain CEMS, as specified in GP 022, to measure SO2, NOx, CO, and oxygen emissions from SV 044. Oxygen CEMS data is required for correction of concentrations of emissions of SO2, NOx, and CO. The Permittee shall continuously monitor sulfuric acid mist emissions (SAM) using SO2 CEMS and estimating an emission rate using the following equations: SAM (ppm) = K x F1 x F2 x SO2 (ppm) SAM (lb/hr) = See Appendix F Where: K = Molecular weight and units conversion from SO2 to H2SO4; F1 = Fuel Factor; F2 = Technology Factor VISIBLE EMISSION CHECKS - EAF BAGHOUSE DUST TRANSFER (SV 047) Visible Emissions: The Permittee shall check the fabric filter stacks for any visible emissions, using the Visible Emissions Check List included in Appendix D of this permit, once each day of operation during daylight hours. Recordkeeping of Visible Emissions. Record the time and date of each visible emission inspection and whether or not any visible emissions were observed. Corrective Action: If visible emissions are observed, the Permittee shall follow the O&M Plan for the fabric filter and take corrective actions as soon as possible to eliminate the visible emissions. The Permittee shall keep a record of the type and date of all corrective actions taken. RECORDKEEPING AND REPORTING EAF Baghouse Dust Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the EAF baghouse dust lead and fluoride concentration. No NOx emission data have been collected from an EAF using DRI to make high quality slab steel. Within 13 months of initial start-up, the Permittee shall submit CEM data for the first 12 months of operation. A copy of the data shall also be sent to the Manager of the Metallic Mining Sector. The Permittee shall submit an application for a PSD permit modification to amend the NOx limit and update the BACT analysis based on the actual level of emissions. Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R & 3010; 40 CFR 60.8 ; 40 CFR 60.8 Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 1 Title I Condition: 40 CFR 52.21(j) & (k): 40 CFR (a); 40 CFR 64.7(a) & (c): CAM and Minn. R ; 40 CFR 64.7(a): CAM and Minn. R ; Minn. R ; Minn. R , subp. 4 ; Minn. R , subp. 4 ; Minn. R , subp. 4 ; Minn. R , subp. 5 ; Minn. R , subps. 4 & 5 ; Minn. R , subp. 5 ; Minn. R , subp. 6

28 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: Essar Steel Minnesota LLC Subject Item: GP 010 Electric Arc Furnaces Associated Items: EU 125 Electric Arc Furnace Line 1 A-23 05/10/12 OPERATIONAL REQUIREMENTS What to do Material Usage: less than or equal to 30,313 tons/year using 12-month Rolling Sum of clean external market scrap steel in the EAF units in total. (27,500 tonnes/yr) Clean external scrap means scrap that has non-detectable concentrations of mercury, lead and polyvinylchloride and includes Special Plate Punchings, No.3 Steel (Prepared Bushling), No.1 Shredded Steel, or No.1 Bundles or any scrap that does not originate from automobile or white good shredding. External scrap from automobile or white good shredding may only be used if certified by the supplier to be free of mercury, lead and polyvinylchloride. Allowed External Scrap Steel Types: All Steel Mill Scrap grades are based on prepared mill specification grades in minimum truck-lot-load quantities (20 Ton). Special Plate Punchings: Special Plate Punchings shall include clean, dry, uniform plate punchings suitable for ballast material or high density furnaces charging. Material must be free flowing and no piece shall be larger than 2" in any direction and a minimum of 1/4" in any direction. May be any shape provided that there are no protruding edges. No.3 Steel (Prepared Bushling): No.3 Steel (Prepared Bushling) shall consist of clean, uncoated free flowing steel clippings, stampings & sheet skeletons under 1/8" thick and not exceeding 12" length or width. No.1 Shredded Steel: No.1 Shredded Steel shall consist of fresh shredded clean, bushling & shredder clips, suitable as charge stock for coreless induction melting with a minimum weight density of 50 lb/cubic foot. No.1 Bundles: No.1 Bundles shall consist of clean steel compressed into chargeage bundles with a minimum weight density of 75 lb/cubic foot. This grade would typically contain baled bushling. BACT REQUIREMENTS Oxy-fuel burners: The Permittee shall install and operate Oxy-fuel burners in the EAF units. Sulfur Content of Carbon Additive: less than or equal to 1.0% by weight. Fluorspar Usage Limit: less than or equal to 25 tons/hr of Fluorspar introduced to the Electric Arc Furnace (EU 125). Record the quantity of Fluorspar added to each heat and the time of the introduction. DRI Lead Concentration: less than or equal to 20 mg/kg using 12-month rolling average lead concentration of DRI introduced to the Electric Arc Furnace (EU 125). DRI Fluoride Concentration: less than or equal to 50 mg/kg using 12-month rolling average lead concentration of DRI introduced to the Electric Arc Furnace (EU 125). MONITORING The Permittee shall conduct monthly monitoring of the sulfur content of the carbon additives to the EAF. The Permittee shall, using ASTM sampling and analysis methods, by the 15th of each month use ASTM measure and record the sulfur content. In lieu of monthly sampling and analyzing the sulfur content of the carbon, the Permittee may obtain and maintain a record of monthly vendor certifications of the sulfur content of the carbon. RECORDKEEPING Feed Material Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the feed material lead and/or fluoride concentration. The Permittee shall daily record the quantity and type of external scrap charged to the EAFs. The Permittee shall also record if the material is certified by the supplier to have non-detectable concentrations of mercury, lead and polyvinylchloride and shall maintain a copy of the supplier's certification. The Permittee shall by the 16th of each month calculate and record the 12-month rolling sum of external scrap charged to the EAFs. Why to do it Title I Condition: 40 CFR 63.43(g): MACT and Minn. R ; Minn. R , subp. 2 Title I Condition: 40 CFR 63.43(g): MACT and Minn. R ; Minn. R , subp. 2 (continued) Title I Condition: 40 CFR 63.43(g): MACT and Minn. R ; Minn. R , subp. 2 Title I Condition: 40 CFR 52.21(j) & (k): ; Minn. R , subps. 4 & 5 Title I Condition: 40 CFR 52.21(j) & (k): ; Minn. R , subps. 4 & 5 ; Minn. R , subp. 5 Title I Condition: 40 CFR 63.43(g): MACT and Minn. R ; Minn. R , subps. 4 & 5

29 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: Subject Item: GP 011 Meltshop Enclosures Associated Items: BG 012 EAF Area & Furnace Shop Line 1 BG 014 Ladle Metallurgy Furnaces Line 1 A-24 05/10/12 BUILDING REQUIREMENTS What to do Design the meltshop buildings to operate at a negative gauge pressure. All air vented from the building shall be sent through air pollution control equipment. Annual certification. The Permittee shall annually certify that the building has been evaluated by qualified personnel and that the building conforms to the design and operating practices recommended in the "Industrial Ventilation - A Manual of Recommended Practice, American Conference of Governmental Industrial Hygienists." The building evaluation shall include consideration of building dimensions, design capture velocity, minimum recommended air flow, face, slot, plenum or duct velocity as applicable and fan rotation speed or fan power draw compared to design values. The number of doors open at any given time will be a function of the overall volumetric flow of air to the baghouse. The Permittee shall post signs on all non-alarmed doors and windows leading to the outside that state that the doors and windows must remain closed while the facility is in operation except for normal access and egress. Why to do it Minn. R , subps. 4 & 5 Minn. R , subps. 4 & 5 The Permittee shall conduct inspections at least once each calendar week to determine if the doors and windows are closed as required by this permit. The Permittee shall maintain a written record of the inspections and any corrective action taken. PERFORMANCE TESTING The Permittee shall perform an annual performance test to demonstrate that a negative pressure is achieved in the building under normal operating conditions. MONITORING The Permittee shall continuously monitor the flowrate to the baghouse and maintain it at a rate consistent with the flowrate measured during the last annual performance test shown to produce a negative pressure in the building. REPORTING Prior to initial start-up of the facility, a report shall be submitted to the agency, based on the final facility design, which will be used to determine the number of doors that can be open during specific operating scenarios and the required air flow to the baghouse. The number of doors that can be open at any one time will be based on the criteria established in this report. This will be considered normal operating conditions. Minn. R , subps. 4 & 5 Minn. R , subps. 4 & 5 Minn. R , subps. 4 & 5

30 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: Subject Item: GP 012 Cooling Towers Associated Items: EU 012 DRI Cooling Tower Line 1 EU 132 EAF Indirect Cooling Tower Line 1 EU 141 Direct Cooling Tower EU 142 Laminar Cooling Tower SV 005 DRI Cooling Tower Line 1 SV 048 EAF Indirect Cooling Tower Line 1 SV 054 Direct Cooling Tower SV 055 Laminar Cooling Tower A-25 05/10/12 OPERATIONAL REQUIREMENTS What to do The Permittee shall not use chromium-based water treatment chemicals in any affected industrial process cooling tower. The Permittee shall conduct water sample analyses in accordance with Method 7196, Chromium, Hexavalent (Colorimetric), contained in the Third Edition of Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW-846, (November 1986) and its Revision I, (December 1987), 40 CFR ; Minn. R CFR ; Minn. R Why to do it In lieu of the water sample analysis, the Permittee may maintain records of water treatment chemical purchases, including invoices and other documentation that includes invoices and other documentation that includes date(s) of purchase or shipment, trade name or other information to identify composition of the product, and quantity of the product. Maintain copies of the initial notification and the notification of compliance status as required by 40 CFR Section for a period of at least 5 years onsite. Drift Rate: The Permittee shall install and operate cooling towers with a drift rate less than or equal to percent. Opacity: less than or equal to 20 percent opacity using 6-minute Average MONITORING Continuously monitor the liquid flowrate through each cooling tower, and, by the 15th of each month, monitor the water quality of each of the cooling towers for total dissolved solids and the liquid flowrate through the cooling tower. RECORDKEEPING Recordkeeping: The Permittee shall maintain a record of the monthly TDS, and the flowrate through each cooling tower. REPORTING Notification of Compliance status shall meet the following requirements: 1. Be signed by a responsible official who also certifies the accuracy of the report; 2. Certify that source has complied with 40 CFR Section ; and 3. A description of the type of water treatment program used in EU 012, including the chemical name of each corrosion inhibitor ingredient used; the average concentration of those corrosion inhibitor ingredients maintained in the cooling water; and the material safety data sheet for each water treatment chemical or chemical compound used. 4. Include the following statement: I certify that no chromium-based water treatment chemicals have been introduced since (the initial compliance date) into any IPCT located within the facility for any purpose. PERFORMANCE TESTING Initial Performance Test: due 180 days after Initial Startup for opacity from SV 005. Initial Performance Test: due 180 days after Initial Startup for opacity from SV 048. Initial Performance Test: due 180 days after Initial Startup for opacity from SV 054. Initial Performance Test: due 180 days after Initial Startup for opacity from SV CFR ; Minn. R ; Minn. R , subp. 4 ; Minn. R , subp CFR ; Minn. R

31 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-26 05/10/12 Subject Item: Associated Items: GP 014 Flares CE 042 Flaring CE 099 Flaring EU 068 DRI Flare Line 1 EU 129 EAF Vacuum Degasser Line 1 SV 045 EAF Vacuum Degasser Line 1 SV 061 DRI Flare Line 1 BACT LIMITS What to do Appendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Carbon Monoxide: comply with the CO limits on a ppm and lb/hr basis using a 1-hour average from SV Opacity: less than or equal to 3 percent opacity using 6-minute Average from SV 045. OPERATIONAL REQUIREMENTS Flares must be designed for and operated with no visible emissions except for a period not to exceed a total of 5 minutes during any 2 consecutive hours. Each flare shall be operated with a flame present at any time that the associated emission unit is in operation. Flares must be used only if the combustion gas has a heating value of 300 Btu/scf or greater. Steam assisted flares designed and operated with an exit velocity less than Vmax (as determined by 40 CFR 60.18(f)(5)) and less than 400 ft/sec are allowed. Flares used to comply with this section shall be steam assisted, air assisted, or nonassisted. Flares shall be monitored to ensure that they are operated and maintained in conformance with their design. Flares shall be operated at all times when emissions may be vented to them. Flame presence shall be monitored using a thermocouple or any other equivalent device. RECORDKEEPING Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. Maintain a file of all measurements, maintenance, reports and records for at least five years. VISIBLE EMISSION CHECKS Reference Method 22 shall be used to determined the compliance of flares with the visible emissions provisions. Visible emissions check: the Permittee shall check visible emissions daily when the flare is operating. A checklist meeting the requirements in Appendix D shall be used to indicate whether the control equipment requires attention. In the event the Permittee makes a finding that attention is required, the Permittee shall investigate the control equipment performance and implement corrective action if necessary. Visible emissions checklist: The Permittee shall use a checklist that contains at a minimum the information contained in Appendix D. MACT REQUIREMENTS The approval of the case-by-case MACT determinations for the members of this group under 40 CFR 63 Subp. B shall expire if construction of any of the members of this group has not commenced within the continuous construction of the facility. Why to do it Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R & Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R & 3010 ; 40 CFR 60.18(f)(2); Minn. R Minn. R , subp. 4 Minn. R , subp. 5 Title I Condition: 40 CFR 63.43(g)(4): MACT and Minn. R

32 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-27 05/10/12 Subject Item: Associated Items: GP 015 Tunnel Furnace EU 138 Tunnel Furnace SV 051 Tunnel Furnace What to do Low NOx Burners: The Permittee shall install and operate Low NOx burners or similar equipment designed to meet the NOx emission limits for EU 138/SV 051. Fuel Usage: Natural Gas Only BACT LIMITS Appendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Total PM: comply with the Total PM limits on a gr/dscf and lb/hr basis using a 3-hour average. PM < 10 micron: comply with the PM10 limits on a gr/dscf and lb/hr basis using a 3-hour average. PM < 2.5 micron: comply with the PM2.5 limits on a gr/dscf and lb/hr basis using a 3-hour average. Sulfur Dioxide: comply with the SO2 limits on a ppm and lb/hr basis using a 1-hour average. Nitrogen Oxides: comply with the NOx limits on a lb/ton steel produced and lb/hr basis using a 1-hour average. Carbon Monoxide: comply with the CO limits on a lb/mmbtu heat input and lb/hr basis using a 1-hour average. Volatile Organic Compounds: comply with the VOC limits on a lb/mmbtu heat input and lb/hr basis using a 3-hour average. Opacity: less than or equal to 3 percent opacity using 6-minute Average OTHER EMISSION LIMITS Emission limits listed in this section apply individually to each stack, however compliance with the above limits will demonstrate compliance with these limits. Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 20 percent opacity PERFORMANCE TESTING Initial Performance Test: due 180 days after Initial Startup for total PM, PM10, PM 2.5, and opacity from SV 051. Initial Performance Test: due 180 days after Initial Startup for NOx from SV 051. Initial Performance Test: due 180 days after Initial Startup for SO2 from SV 051. Initial Performance Test: due 180 days after Initial Startup for CO from SV 051. Initial Performance Test: due 180 days after Initial Startup for VOC from SV 051. MACT REQUIREMENTS The approval of the case-by-case MACT determinations for the members of this group under 40 CFR 63 Subp. B shall expire if construction of any of the members of this group has not commenced within the continuous construction of the facility. Why to do it Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R & 3010 Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R & 3010 Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R & 3010 Minn. R , subp. 2 Minn. R , subp. 1(A)(1) Minn. R , subp. 1(A)(2) Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R & 3010; Minn. R , subp. 1 ; Minn. R , subp. 1 ; Minn. R , subp. 1 Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R & 3010; Minn. R , subp. 1 Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R & 3010; Minn. R , subp. 1 Title I Condition: 40 CFR 63.43(g)(4): MACT and Minn. R

33 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-28 05/10/12 Subject Item: Associated Items: GP 016 Material Loading Bin Sources SV 014 Limestone Handling System SV 015 Binder Handling System SV 039 Hydrated Lime Handling System SV 040 Calcined Limestone Handling System SV 041 Carbon Handling System SV 042 Fluorspar Handling System SV 043 Bauxite Handling System SV 059 Pellet Plant - Powder Coating Handling SV 072 DRI Powder Coating Handling SV 091 Carbon Bin for Mercury Control SV 092 Lime Bin for Scrubber BACT LIMITS What to do Appendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Total PM: comply with the Total PM limits on a gr/dscf and lb/hr basis using a 3-hour average. PM < 10 micron: comply with the PM10 limits on a gr/dscf and lb/hr basis using a 3-hour average. PM < 2.5 micron: comply with the PM2.5 limits on a gr/dscf and lb/hr basis using a 3-hour average. Lead: comply with the lead limits on a lb/hr basis using a 3-hour average. Fluorides: comply with the fluoride limits on a lb/hr basis using a 3-hour average. Opacity: less than or equal to 5 percent opacity using 6-minute Average OTHER EMISSION LIMITS Emission limits listed in this section apply individually to each stack, however compliance with the above limits will demonstrate compliance with these limits. Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 20 percent opacity using 6-minute Average MATERIAL HANDLING LIMITS (SV 014, 015, 042, 059, and 072) Additive Material Lead Concentration: less than or equal to 2.3 mg/kg using 12-month rolling average lead concentration of the additive material handled by SV 014, 015, 059, and 072. RECORDKEEPING Feed Material Lead Concentration Recordkeeping: The Permittee shall by the 15th of each month record the feed material lead concentration for each unit with a lead concentration limit. VISIBLE EMISSION CHECKS Visible Emissions: The Permittee shall check the fabric filter stacks for any visible emissions, using the Visible Emissions Check List included in Appendix D of this permit, once each day of operation during daylight hours. Recordkeeping of Visible Emissions. The Permittee shall record the time and date of each visible emission inspection and whether or not any visible emissions were observed. Corrective Action: If visible emissions are observed, the Permittee shall follow the Operation and Maintenance Plan for the fabric filter and take corrective actions as soon as possible to eliminate the visible emissions. The Permittee shall keep a record of the type and date of all corrective actions taken. Why to do it Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R & 3010 Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Minn. R , subp. 2 Minn. R , subps. 1(A) & 3 Minn. R , subp. 1(B) ; Minn. R , subp. 5 Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R & 3010; Minn. R , subp. 4 ; Minn. R , subp. 5 ; Minn. R , subps. 4 & 5

34 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-29 05/10/12 MACT REQUIREMENTS The approval of the case-by-case MACT determinations for the members of this group under 40 CFR 63 Subp. B shall expire if construction of any of the members of this group has not commenced within the continuous construction of the facility. PERFORMANCE TESTING The performance testing requirements under this part apply to each stack listed in this group. The compliance status of each group member with its individual limit for a pollutant will be determined by performance testing conducted on one member of the group for that pollutant. Initial Performance Test: due 180 days after Initial Startup to measure Total PM, PM-10, PM2.5, and opacity from any one member of this group. Performance Test: due before end of each year following Initial Performance Test to measure PM, PM10, PM2.5, and opacity on at least one member of this group. To the extent practicable, the annual performance tests shall cycle through all members of this group. Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. Title I Condition: 40 CFR 63.43(g)(4): MACT and Minn. R Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R & 3010; Minn. R , subp. 1 Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R & 3010; Minn. R , subp. 1 Title I Condition: 40 CFR 52.21(j) & (k):

35 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: Subject Item: GP 017 DRI Pellet Handling Associated Items: EU 064 DRI Depressurizing Scrubber Line 1 EU 070 DRI P.T.S. Depressurizing Scrubber Line 1 EU 088 DRI Screening and Handling Line 1 SV 029 DRI Depressurizing Scrubber Line 1 SV 063 DRI P.T.S. Depressurizing Scrubber Line 1 SV 070 DRI Screening & Handling Line 1 A-30 05/10/12 BACT LIMITS What to do Appendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Total PM: comply with the Total PM limits on a gr/dscf and lb/hr basis using a 3-hour average. PM < 10 micron: comply with the PM10 limits on a gr/dscf and lb/hr basis using a 3-hour average. PM < 2.5 micron: comply with the PM2.5 limits on a gr/dscf and lb/hr basis using a 3-hour average. Lead: comply with the lead limits on a lb/hr basis using a 3-hour average. Fluorides: comply with the fluoride limits on a lb/hr basis using a 3-hour average. DRI Pellet Lead Concentration: less than or equal to 20. mg/kg using 12-month rolling average lead concentration of DRI pellets handled by the sources in this group. DRI Pellet Fluoride Concentration: less than or equal to 50. mg/kg using 12-month rolling average fluoride concentration of DRI pellets handled by the sources listed in this group. Opacity: less than 5 percent opacity using 6-minute Average OTHER EMISSION LIMITS Emission limits listed in this section apply individually to each stack, however compliance with the above limits will demonstrate compliance with these limits. Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Opacity: less than or equal to 20 percent opacity using 6-minute Average RECORDKEEPING DRI Pellet Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the DRI pellet lead and/or fluoride concentration. PERFORMANCE TESTING Initial Performance Test: due 180 days after Initial Startup to measure Total PM, PM10, PM2.5, and Opacity from SV 029. Initial Performance Test: due 180 days after Initial Startup to measure Total PM, PM10, PM2.5, and Opacity from SV 063. Initial Performance Test: due 180 days after Initial Startup to measure Total PM, PM10, PM2.5, and Opacity from SV 070. Performance Test: due before end of each calendar 36 months following Initial Performance Test to measure Total PM emissions from SV 070. Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. Why to do it Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R & 3010 Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Minn. R , subp. 2 Minn. R , subps. 1(A) & 3 Minn. R , subp. 1(B) ; Minn. R , subp. 5 Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R & 3010; Minn. R , subp. 1 Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R & 3010; Minn. R , subp. 1 Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R & 3010; Minn. R , subp. 1 Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R & 3010; Minn. R , subp. 1 Title I Condition: 40 CFR 52.21(j) & (k):

36 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-31 05/10/12 MACT REQUIREMENTS The approval of the case-by-case MACT determinations for the members of this group under 40 CFR 63 Subp. B shall expire if construction of any of the members of this group has not commenced within the continuous construction of the facility. VISIBLE EMISSION CHECKS Visible Emissions: The Permittee shall check the fabric filter stacks for any visible emissions once each day of operation during daylight hours, or the pressure drop across the fabric filter once each day of operation if inclement weather prohibits a visible emissions check. Recordkeeping of Visible Emissions and Pressure Drop. The Permittee shall record the time and date of each visible emission inspection and pressure drop reading, and whether or not any visible emissions were observed, and whether or not the observed pressure drop was within the range specified in this permit. Corrective Action: If visible emissions are observed, and/or if the pressure drop is outside the permitted range specified in this subject item, the Permittee shall follow the Operation and Maintenance Plan for the fabric filter and take corrective actions as soon as possible to eliminate the visible emissions and/or return the pressure drop to within the permitted range. The Permittee shall keep a record of the type and date of all corrective actions taken. Title I Condition: 40 CFR 63.43(g)(4): MACT and Minn. R Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R & 3010; Minn. R , subp. 4 ; Minn. R , subp. 5 ; Minn. R , subp. 4

37 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-32 05/10/12 Subject Item: Associated Items: GP 018 Indurating Furnace CE 016 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 018 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones CE 019 Fabric Filter - Low Temperature, i.e., T<180 Degrees F CE 020 Low NOx Burners CE 117 Gas Scrubber (General, Not Classified) CE 118 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones EU 038 Indurating Furnace, Hood Exhaust EU 039 Indurating Furnace, Furnace Waste Gas SV 018 Furnace Hood Exhaust SV 019 Furnace Waste Gas Fuel Usage : Natural Gas Only SV 018 vents CE 016 and 118 SV 019 vents CE 018, 019, and 117 What to do CE 020 are the Low NOx burners that fire the furnace. BACT LIMITS Appendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Carbon Dioxide equivalent (CO2e): comply with the CO2e limit on a ton/yr basis using a 12-month rolling sum from the pellet furnace (SV 018 and 019 combined). Total PM: comply with the Total PM limits on a gr/dscf and lb/hr basis using a 3-hour average. PM < 10 micron: comply with the PM10 limits on a gr/dscf and lb/hr basis using a 3-hour average. PM < 2.5 micron: comply with the PM2.5 limits on a gr/dscf and lb/hr basis using a 3-hour average. Sulfur Dioxide: comply with the SO2 limits on a ppm measured at 15% oxygen and lb/hr basis using a 1-hour rolling average. Sulfuric Acid Mist: comply with the SAM limits on a ppm measured at 15% oxygen and lb/hr basis using a 3-hour rolling average. Nitrogen Oxides: comply with the NOx limits on a lb/mmbtu heat input and lb/hr using a 1-hour rolling average basis from the pellet furnace (SV 018 and 019 combined). Carbon Monoxide: comply with the CO limits on a ppm measured at 15% oxygen and lb/hr basis using a 1-hour rolling average. Volatile Organic Compounds: comply with the VOC limits on a ppm measured at 15% oxygen and lb/hr basis using a 3-hour rolling average. Lead: comply with the lead limits on a gr/dscf and lb/hr basis using a 3-hour average. Fluorides: comply with the fluoride limits on a gr/dscf and lb/hr basis using a 3-hour average. Opacity: less than or equal to 5 percent opacity using 6-minute Average OTHER EMISSION LIMITS Emission limits listed in this section apply individually to each stack, however compliance with the above limits will demonstrate compliance with these limits. Total PM: less than or equal to gr/dscf using 3-hour average and on the basis of a flow-weighted mean concentration of both stacks. Demonstrate compliance during the Total PM performance test, as described by 40 CFR (c). Total PM: less than 0.02 gr/dscf using 3-hour average. Why to do it Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R & 3010 Title I Condition: 40 CFR 52.21(j) & (k): Minn. R , subp CFR (a); 40 CFR (a)(2); 40 CFR (c); Minn. R CFR (a)(1); Minn. R

38 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-33 05/10/12 OPERATIONAL REQUIREMENTS Good combustion practices (GCP) for indurating furnaces: Identify and implement a set of site-specific GCP for the indurating furnace. These GCP shall correspond to standard operating procedures for maintaining the proper and efficient combustion within the indurating furnace. GCP include, but are not limited to the following: 1. Proper operating conditions for each indurating furnace (e.g., minimum combustion temperature, maximum carbon monoxide concentration in the furnace exhaust gases, burner alignment, or proper fuel-air distribution/mixing). 2. Routine inspection and preventative maintenance and corresponding schedules. 3. Performance analyses. 4. Keeping applicable operator logs. 5. Keeping applicable records to document compliance with each element. The Permittee shall: - Perform preventative maintenance for each control device in accordance with 40 CFR (b)(1) and record all information needed to document conformance with these requirements. - Implement and maintain site-specific GCP for the indurating furnace in accordance with 40 CFR (b)(4) and record all information needed to document conformance with these requirements. Install and begin operation of an Activated Carbon Injection (ACI) system for reduction of mercury emissions within 365 days after initial startup of pellet plant. Once installed, operate and maintain the ACI system in accordance to a written O&M Plan any time the associated process equipment is in operation. Document periods of non-operation of the reduction equipment. Keep copies of the O&M Plan available onsite and available for inspection upon request. Install, operate, and maintain each CPMS and monitor the daily average of the operating parameter(s) identified in the MRTDR (Mercury Reduction Technology Demonstration Report) at all times that the associated Hg reduction technology is in operation. Keep records of the daily average operating parameter(s). Each CPMS must complete a minimum of one cycle of operation for each successive 15-minute period and determines and records valid data for at least 95% of every daily averaging period. Each CPMS must also determine and record the daily average of all recorded readings. Operate and maintain each CPMS and conduct a performance evaluation of each CPMS in accordance with the site-specific monitoring plan. 40 CFR (b)(4); 40 CFR (a)(4) 40 CFR (a)(1) & (4); 40 CFR 64.7(b) & (d): CAM and Minn. R Minn. R , subps. 2, 14 & 16(J) Minn. R , subps. 2, 4, 14 & 16(J) Minn. R , subps. 4, 5, 14 & 16(J) Minn. R , subps. 4, 5, 14 & 16(J) Minn. R , subps. 4, 5, 14 & 16(J) Establish and maintain the daily average site-specific operating parameters upon Minn. R , subps. 2, 4, 5, 14 & 16(J) MPCA approval of the MRTDR. Measure and record the parameters specified in the MRTDR during each of the runs of the Hg performance test. The operating limits are established as the lowest average of the specified parameters corresponding to any of the test runs that demonstrate compliance with the Hg emission limit. Maintain a record of the established operating parameter(s) measured during the Minn. R , subps. 4 & 5 performance test. The Permittee may change the site specific operating limits if the Permittee: Minn. R , subps. 2, 4, 5, 14 & 16(J) 1. Submits a written notification to the MPCA requesting to conduct a new performance test to revise the operating limit; 2. Conduct a performance test to demonstrate compliance with the applicable emission limitation; and 3. Establishes revised operating limits according to the method in 2. Initiate and complete corrective action as soon as practicable for a CPMS as Minn. R , subps. 5, 14 & 16(J) specified in the site-specific monitoring plan when an established operating limit for the mercury reduction technology is exceeded. Keep records of all information needed to document conformance with these requirements. Develop and make available for inspection, a site-specific monitoring plan that Minn. R , subps. 4, 5, 6, 14 & 16(J) addresses the following: 1. Installation of the CPMS sampling probe or other interface at a measurement location representative of reduction of the exhaust emissions. The CPMS shall be installed and operational prior to startup of the ACI system. 2. Performance and equipment specifications for the sample interface, the parametric signal analyzer, and the data collection and reduction system. 3. Performance evaluation procedures and acceptance criteria. 4. Ongoing operation and maintenance procedures. 5. Ongoing data quality assurance procedures. 6. Ongoing recordkeeping and reporting procedures. 7. Corrective action procedures to be followed in the event an air pollution reduction device exceeds an operating limit. In the event that an exceedance of an established operating limit for an air pollution 40 CFR (b)(3) control device occurs, except for a baghouse, initiate corrective action to determine the cause of the exceedance and complete the corrective action within 10 days.

39 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-34 05/10/12 PERFORMANCE TESTING Performance test methods and other procedures: Conduct each performance test 40 CFR (a) for PM according to the requirements of 40 CFR 63.7(e)(1) and (c). The Permittee shall speciate the mercury emitted for performance tests for mercury. Minn. R , subp. 2 Initial Performance Test: due 180 days after Initial Startup to measure Total PM emissions from SV 018 and SV 019 individually. Calculate the flow-weighted mean concentration of PM for both stacks using the methods of 40 CFR (c). Initial Performance Test: due 180 days after Initial Startup to measure PM10, PM2.5, Lead, and Fluoride emissions from SV 018 and 019 individually. Initial Performance Test: due 180 days after Initial Startup to measure VOCs and Sulfuric Acid Mist emissions from SV 018 and 019 individually. Initial Performance Test: due 180 days after Initial Startup to measure opacity from SV 018 and 019 individually. Initial Performance Test: due 180 days after Initial Startup to measure mercury emissions from SV 018 and 019 individually. Initial Performance Test: due 180 days after Initial Startup to measure PCDD/PCDF emissions from SV 018 and 019 individually. Performance Test: due before end of each calendar 24 months following Initial Performance Test to measure Total PM emissions from SV 018 & 019 individually. Calculate the flow-weighted mean concentration of PM for both stacks using the methods of 40 CFR (c). Performance Test: due 120 days after Initial Performance Test to measure mercury emissions from SV 018 and 019. Shall be performed no sooner than 30 days from any other mercury test. Performance Test: due 240 days after Initial Performance Test to measure mercury emissions from SV 018 and 019. Shall be performed no sooner than 30 days from any other mercury test. Performance Test: due before end of each year following Initial Performance Test to measure mercury emissions from SV 018 and 019. Shall be performed no sooner than 30 days from any other mercury test. Performance Test: due before end of each year following Initial Performance Test to measure PCDD/PCDF emissions from SV 018 and 019 individually. Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. MONITORING Install, operate, and maintain bag leak detection systems according to the requirements in GP 007 (CE 016 and 019). Install and operate a natural gas flow meter to measure the volume of natural gas used in the pellet furnace. Monitor and record the monthly natural gas use in the furnace. Obtain information on a semiannual basis from the natural gas vendor for the molecular weight, molar conversion factor, and carbon content of the gas to be used in the calculation of CO2 emissions. Install and operate a flue gas flow monitor to measure offgas flow rate from SV 018 and 019, to be used to convert concentration measurements to mass. Install, operate, and maintain CEMS, as specified in GP 022, to measure SO2, NOx, CO, and oxygen emissions from SV 018 and 019. Oxygen CEMS data is required for correction of concentrations of emissions of SO2, NOx, and CO. The Permittee shall continuously monitor sulfuric acid mist emissions (SAM) using SO2 CEMS and estimating an emission rate using the following equations: SAM (ppm) = K x F1 x F2 x SO2 (ppm) SAM (lb/hr) = See Appendix F Where: K = Molecular weight and units conversion from SO2 to H2SO4; F1 = Fuel Factor; F2 = Technology Factor = 0.1 for SV 018; 1.0 for SV 019 ; 40 CFR (b) & (c); Minn. R , subp. 1 ; Minn. R , subp. 1 ; Minn. R , subp. 1 ; Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp CFR (b) & (c); 40 CFR 64.7(a): CAM and Minn. R ; Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 1 Minn. R , subp. 1 Title I Condition: 40 CFR 52.21(j) & (k): 40 CFR (a); 40 CFR 64.7(a) & (c): CAM and Minn. R ; Minn. R , subp. 4; Minn. R ; 40 CFR 64.7(a): CAM and Minn. R ; Minn. R ; Minn. R , subp. 4 ; Minn. R , subp. 4

40 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: RECORDKEEPING Essar Steel Minnesota LLC Monitoring and recordkeeping: By the 28th of each month, calculate and record CO2-e emissions from the pellet furnace for the previous calendar month and the 12-month rolling sum fuel CO2-e emissions for the previous 12-month period. Global Warming Potentials (GWPs) are listed in Table A-1 to Subpart A of Part CFR pt. 98, subp. A, Table A-1 Calculate monthly fuel CO2-e emissions using the following: CO2-e = SUM(GWPi * Mi) for i = CO2, CH4, N2O Where: CO2-e = mass of carbon dioxide equivalent (ton); GWPi = GWP for component i; Mi = mass emissions of component i (ton), as calculated below Mi = Vng * HHVng * EFi / for i = CH4, N2O; and Mi = 44/12 * [Vng * Cng * MW / MCF + SUM(Mj * Cj) - Mk * Ck] for i = CO2 Where: Mi/j/k = Mass of component i/j/k (ton); Cj/k = Carbon content of component j/k (mass fraction); Vng = Volume of natural gas used in the previous month (mmscf); HHVng = Higher heating value of natural gas (btu/scf); EFi = Emission factor of component i (kg/mmbtu) from 40 CFR pt. 98, subp. C, Table C2; k = fired pellets produced; j = concentrate processed, powder coating used, limestone used, soda ash used, dolomite used; MW/MCF = Molecular Weight/Molar Conversion Factor for natural gas; 44/12 = molecular weight conversion from carbon to CO2; = conversion from kg to ton Maintain records of the annual pellet production rate (ton/year) and the annual and monthly mercury emissions. Recordkeeping: Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction or period of non-operation of the air pollution reduction equipment; or any periods during which a CPMS or monitoring device is inoperative. Feed Material Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the feed material lead and/or fluoride concentration. REPORTING (continued) Minn. R , subps. 4 & 5 Minn. R , subp. 5 ; Minn. R , subp. 5 Include the monthly mercury emission calculations in the emission inventory report. Minn. R , subp. 6 All deviations, including deviations from the rolling 12 month mercury emission limit shall be reported in the semiannual deviations report. GSA design specifications report (see Table B). The specifications shall identify the parameters and conditions used for system design such as: - Design conditions and parameters of the scrubber, including scrubber chemistry, range of chemical and physical characteristics allowed in the reagent selected; - Operating conditions (e.g. furnace production level, flue gas flow rate, inlet SO2 levels, temperature); and - Selection of reagent (lime, limestone), reagent purity, calcium content, physical characteristics (e.g. pebble size, available surface area) Scrubber Evaluation Study (see Table B): The study shall include: - The impact of ore sulfur content and fuel sulfur content on the level of SO2 emissions control; - SO2 scrubber response time to changes in SO2 loading and the impact the scrubber response time has on meeting a 3-hour average SO2 limit; - The impact of lime addition rates on SO2 control and the feasibility of meeting the proposed SO2 limits; - The impact scrubber operating parameters (e.g. water and steam injection rates) have on SO2 control and the feasibility of meeting the proposed SO2 limits; and - The plan shall specify the records that will be maintained so that the MPCA can determine whether the measures are being followed and whether the plant's operating parameters are consistent with the control system design. Plan Approvals and Amendments. a. If the MPCA does not provide written approval or written comments to the facility on the proposed scrubber evaluation plan within 30 days of receipt of the plan, the facility may implement the plan as proposed. b. The facility may amend the scrubber evaluation plan 30 days after submitting a notification of the proposed changes to the MPCA. The notification will include a list of the proposed changes, the rationale for the proposed changes, and any change to monitoring or recordkeeping that will occur. Minn. R , subp. 6 A-35 05/10/12

41 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: Subject Item: GP 019 Boilers/Heaters Subject to Case-by-Case MACT Associated Items: EU 065 DRI Package Boiler Line 1 EU 066 DRI Process Gas Heater Line 1 EU 069 DRI P.T.S. Heater Line 1 EU 137 Vacuum Degasser Boiler SV 028 DRI Package Boiler Line 1 SV 030 DRI Process Gas Heater Line 1 SV 050 Vacuum Degasser Boiler SV 062 DRI P.T.S. Heater Line 1 A-36 05/10/12 What to do Each emission unit in this group must individually comply with the requirements of this group upon startup of the unit. Ultra Low NOx Burners: The Permittee shall install and operate Ultra Low NOx burners or similar equipment designed to meet the NOx emission limits below. OPERATING LIMITS Fuel Usage: Natural Gas only At all times operate and maintain each emission unit and its associated air pollution control equipment in a manner consistent with good air pollution control practices for minimizing emissions at least to the levels required by all relevant standards, as described at 40 CFR Section 63.6(e)(1)(i). BACT LIMITS Appendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Total PM: comply with the Total PM limits on a lb/mmbtu and lb/hr basis using a 3-hour average from SV 030. PM < 10 micron: comply with the PM10 limits on a lb/mmbtu and lb/hr basis using a 3-hour average from SV 030. PM < 2.5 micron: comply with the PM2.5 limits on a lb/mmbtu and lb/hr basis using a 3-hour average from SV 030. Lead: comply with the lead limits on a lb/hr basis using a 3-hour average from SV 030. Fluorides: comply with the fluoride limits on a lb/hr basis using a 3-hour average from SV 030. Sulfur Dioxide: comply with the SO2 limits on a lb/ton of DRI produced and lb/hr basis using a 1-hour average from SV 030. Nitrogen Oxides: comply with the NOx limits on a lb/mmbtu heat input and lb/hr using 3-hour rolling average basis, except that SV 030 shall comply using 24-hour rolling average basis. Nitrogen Oxides: comply with the NOx SSM limits using 1-hour rolling average. This limit applies during periods of startup and shutdown for no longer than 24 hours per startup or shutdown. Carbon Monoxide: comply with the CO limits on a lb/mmbtu heat input and lb/hr basis using a 1-hour Rolling Average. The lb/mmbtu limit applies at all times except periods of SSM and when EU 066 operates at < 50% of rated capacity. Deviations that occur during a period of SSM are not violations if the Permittee demonstrates to the EPA Administrator's satisfaction that the EU was operated in accordance with the SSMP. The Administrator will determine whether deviations that occur during a period of SSM are violations, according to Section 63.6(e). Opacity: less than or equal to 3 percent opacity Oxide Pellet Lead Concentration: less than or equal to 2.0 mg/kg using 12-month rolling average lead concentration of oxide pellets introduced to the DRI Process Heater(s) (EU 066). Oxide Pellet Fluoride Concentration: less than or equal to 1.0 mg/kg using 12-month rolling average fluoride concentration of oxide pellets introduced to the DRI Process Heater(s) (EU 066). Why to do it Title I Condition: 40 CFR 63.43(g) & 40 CFR 63.6(b): MACT and Minn. R Title I Condition: 40 CFR 63.43(g): MACT and Minn. R ; 40 CFR 63.6(e)(1)(i) and Minn. R ; Minn. R , subp. 16(J) Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & (k): Title I Condition: 40 CFR 52.21(j) & 63.43(g)(1): BACT & MACT and Minn. R & 3010; 40 CFR 63.6(f)(1)

42 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-37 05/10/12 MACT REQUIREMENTS The approval of the case-by-case MACT determinations for the members of this group under 40 CFR 63 Subp. B shall expire if construction of any of the members of this group has not commenced within the continuous construction of the facility. NSPS LIMITS (SV 028, 050, and 062 only) Total Particulate Matter: less than lbs/million Btu heat input. This limit applies at all times on or after the date of the initial performance test is completed or is required to be completed under 40 CFR 60.8 except during periods of SSM. STARTUP, SHUTDOWN, AND MALFUNCTIONS The Permittee shall develop, implement, and maintain a written SSMP according to all of the provisions in 40 CFR Section 63.6(e)(3). The plan must be available for inspection and copying by the Administrator upon request. During periods of SSM, operate and maintain the emission unit(s) (including associated control and monitoring equipment) in accordance with the procedures specified in the SSMP developed under 40 CFR Section 63.6(e)(3). When actions taken during SSM (including actions taken to correct a malfunction) are consistent with the procedures specified in the SSMP, keep records for that event which demonstrate that the procedures specified in the plan were followed. These records may take the form of a checklist, or other effective form of record keeping that confirms conformance with the SSMP for that event. In addition, keep records of these events as specified in 40 CFR 63.10(b). Confirm that actions taken during the relevant reporting period during periods of SSM were consistent with the SSMP in the Semi-Annual SSM report required in 40 CFR 63.10(d)(5). If an action taken during SSM (including an action taken to correct a malfunction) is not consistent with the procedures specified in the SSMP, and the EU exceeds any applicable emission limitation in the relevant emission standard, then record the actions taken for that event and report such actions within 2 working days after commencing actions inconsistent with the plan, followed by a letter within 7 working days after the end of the event, in accordance with 40 CFR 63.10(d)(5). Perform an annual tune-up procedure on each unit, include the following: 1. Inspect the burner, and clean or replace any components of the burner as necessary (burner inspection may be delayed until the next scheduled unit shutdown, but inspect each burner at least once every 36 months); 2. Inspect the flame pattern, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available; 3. Inspect the system controlling the air-to-fuel ratio, and ensure that it is correctly calibrated and functioning properly; 4. Optimize total emissions of carbon monoxide. This optimization should be consistent with the manufacturer's specifications, if available; 5. Measure the concentrations in the effluent stream of carbon monoxide in ppmv, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made); and 6. Maintain on-site and submit, if requested by the Administrator, an annual report containing the following information: i. The concentrations of CO in the effluent stream in ppmv, and oxygen in volume percent, measured before and after the adjustments of the boiler; ii. A description of any corrective actions taken as a part of the combustion adjustment; and iii. The type and amount of fuel used over the 12 months prior to the annual adjustment, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel use by each unit. RECORDKEEPING Recordkeeping: By the last day of each calendar month, record the amount of gas combusted in each boiler/heater during the previous calendar month. These records shall consist of purchase records, receipts, or fuel meter readings. Gaseous Fuel Supplier Certification (EU 065, 069, and 137 only): The Permittee shall maintain fuel supplier certifications of the sulfur content of the fuels burned in each unit listed to show the potential sulfur dioxide emission rate is less than or equal to 0.32 lb/mmbtu heat input. This certification is considered to be the sulfur dioxide performance test required under 40 CFR Section 60.43c(e)(1). Feed Material Lead and Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the feed material lead and/or fluoride concentration. Title I Condition: 40 CFR 63.43(g)(4): MACT and Minn. R CFR 60.43c(e)(1) & (d); Minn. R Title I Condition: 40 CFR 63.43(g): MACT and Minn. R ; 40 CFR 63.6(e)(3)(i) & (v)-(viii); Minn. R CFR 63.6(e)(1) & (3)(ii); Minn. R CFR 63.6(e)(3)(iii); Minn. R CFR 63.6(e)(3)(iv); Minn. R CFR (a)(10); Minn. R CFR (a)(10); Minn. R CFR 60.48c(g); Minn. R CFR 60.45c(c); 40 CFR 60.47c(c); 40 CFR 60.48c(g); Minn. R ; Minn. R , subp. 5

43 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: Essar Steel Minnesota LLC The Permittee shall maintain relevant records of: 1. The occurrence and duration of each startup, shutdown, or malfunction of operation (i.e., process equipment); 2. The occurrence and duration of each malfunction of the required air pollution control and monitoring equipment; 3. All required maintenance performed on the air pollution control and monitoring equipment; 4. Actions taken during periods of SSM (including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation) when such actions are different from the procedures specified in the SSMP; 5. All information necessary to demonstrate conformance with the SSMP when all actions taken during periods of SSM (including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation) are consistent with the procedures specified in such plan. (The information needed to demonstrate conformance with the SSMP may be recorded using a checklist, or some other effective form of recordkeeping, to minimize the recordkeeping burden for conforming events); 6. All required measurements needed to demonstrate compliance with a relevant standard (including, but not limited to and raw performance testing measurements that support data that the source is required to report); 7. All results of performance tests; 8. All measurements as may be necessary to determine the conditions of performance tests; and 9. All documentation supporting initial notifications and notifications of compliance status under 40 CFR Section The Permittee shall keep the following records: 1. A copy of each notification and report that was submitted to comply with this group, including all documentation supporting any Initial Notification or Notification of Compliance Status or Semi-Annual Compliance Report that was submitted, according to the requirements in 40 CFR Section 63.10(b)(2)(xiv); 2. The records in 40 CFR Section 63.6(e)(3)(iii)-(v) related to SSM; and 3. Records of performance tests, fuel analyses, or other performance evaluations, compliance demonstrations and opacity observations required by 63.10(b)(2)(viii) Keep records which include monitoring data and calculated averages for applicable operating limits such as opacity and CO, to show continuous compliance with each emission limit, operating limit, and work practice standard that is applicable. The records must be in a form suitable and readily available for expeditious review. Records must be kept for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record, and must be kept on site for the first 2 of those years. Such files may be maintained on microfilm, on a computer, on computer floppy disks, on magnetic tape disks, or on microfiche. REPORTING Submittals and notifications under this group shall be sent to both the MPCA and EPA contacts listed on Page B-1 of this permit, unless otherwise noted. The Permittee shall submit all of the notifications in 40 CFR Sections 63.7(b) & (c), 63.8(e), (f)(4) & (6), and 63.9(b)-(h) that apply by the dates specified. Report each deviation from an applicable emission limit, operating limit, and work practice standard. Also, report each instance during a SSM when each applicable emission limit, operating limit, and work practice standard was not met. These instances are deviations from the emission limits and work practice standards. Deviations Report. The Permittee must report all deviations with the Notifications of Deviations Endangering Human Health or the Environment or in the Semi-Annual Deviations Report required elsewhere in this permit, whichever is applicable. Immediate SSM Report: The Permittee shall submit an immediate SSM Report if any unit had a startup, shutdown, or malfunction during the reporting period that is not consistent with the Permittee's SSMP, and the boiler/process heater exceeded any applicable emission limitation in this group. The report must contain: 1. Actions taken for the event; 2. The name, title, and signature of a responsible official who certifies its accuracy, 3. An explanation of the circumstances of the event; 4. The reasons for not following the SSMP; and 5. Whether any excess emissions and/or parameter monitoring exceedances are believed to have occurred. The Permittee must submit the report: 1. By fax or telephone within 2 working days after starting actions inconsistent with the plan; and 2. By letter within 7 working days after the end of the event unless the Permittee has made alternative arrangements with the Administrator. 40 CFR 63.10(b)(2); Minn. R , subp. 2 (continued) 40 CFR 63.10(b)(2); Minn. R , subp. 2 (continued) 40 CFR 63.10(b)(2); Minn. R , subp. 2 Title I Condition: 40 CFR 63.43(g): MACT and Minn. R Title I Condition: 40 CFR 63.43(g): MACT and Minn. R Title I Condition: 40 CFR 63.43(g): MACT and Minn. R Minn. R , subp. 2 Title I Condition: 40 CFR 63.43(g): MACT and Minn. R Title I Condition: 40 CFR 63.43(g): MACT and Minn. R Title I Condition: 40 CFR 63.43(g): MACT and Minn. R Title I Condition: 40 CFR 63.43(g): MACT and Minn. R ; 40 CFR 63.6(e)(3)(iv); 40 CFR 63.10(d)(5)(ii); Minn. R A-38 05/10/12

44 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-39 05/10/12 Periodic SSM Reports. The Permittee shall submit SSM Reports only if there is an occurrence of any SSM event during the reporting period and shall be delivered or postmarked by the 30th day following the end of each calendar half year. The content of the report shall be as required by 40 CFR 63.10(d)(5)(i). PERFORMANCE TESTING Initial Performance Test: due 180 days after Initial Startup for Total PM, NOx, CO, and opacity from SV 028. Initial Performance Test: due 180 days after Initial Startup for Total PM, NOx, CO, and opacity from SV 050. Initial Performance Test: due 180 days after Initial Startup for Total PM, NOx, CO, and opacity from SV 062. Initial Performance Test: due 180 days after Initial Startup for Total PM, PM10, PM2.5, SO2, and opacity from SV 030. Performance Test: due before end of each calendar year following Permit Issuance to measure CO emissions from SV 028, to be conducted no sooner than 10 months after the previous performance test. Performance Test: due before end of each calendar year following Permit Issuance to measure CO emissions from SV 050, to be conducted no sooner than 10 months after the previous performance test. Performance Test: due before end of each calendar year following Permit Issuance to measure CO emissions from SV 062, to be conducted no sooner than 10 months after the previous performance test. Emission units (EU 065, 069, and 137) are limited to burning gaseous fuels only with potential SO2 emission rates of 230 ng/j (0.54 lb/mmbtu) heat input or less, therefore emissions monitoring is not required to be conducted under 40 CFR Section 60.43c(e)(1) for SO2 as long as fuel supplier certifications of the sulfur content of the fuels burned are maintained Compliance with the lead/fluoride emission limits will be determined by comparing the lead/fluoride emission limits to the product of the PM mass emission rate (in lb/hr) and the 12-month rolling average lead/fluoride concentration (determined as described on page A-5). This determination will be made for each PM test. CEMS REQUIREMENTS - DRI PROCESS GAS HEATER (EU 066/SV 030) Install, operate, and maintain a CEMS to measure NOx emissions from SV 030. Monitoring requirements are located under the subject item GP 022. Install, operate, and maintain a CEMS to measure oxygen for correction of concentrations of emissions of NOx and CO from SV 030. Monitoring requirements are located under the subject item GP 022. Install, operate, and maintain a CEMS for carbon monoxide and oxygen according to the following procedures upon startup of EU 066. Additional monitoring requirements are located under the subject item GP 022. The CO and oxygen shall be monitored at the same location at the outlet of the process heater: 1. Each CEMS must be installed, operated, and maintained according to the applicable procedures under Performance Specification (PS) 3 or 4A of 40 CFR part 60, appendix B, and according to the site-specific monitoring plan. 2. Conduct a performance evaluation of each CEMS according to the requirements in 40 CFR 63.8 and according to PS 4A of 40 CFR part 60, appendix B. 3. Each CEMS must complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period. 4. The CEMS data must be reduced as specified in 40 CFR 63.8(g)(2). 5. Calculate and record a 30-day rolling average emission rate of CO in ppmvd at 3% O2 on a daily basis. 6. For purposes of calculating data averages, data shall not be used that was recorded during periods of monitoring malfunctions, associated repairs, out-of-control periods, required quality assurance or control activities, or when the unit is operating at less than 50% of its rated capacity. Use all the data collected during all other periods in assessing compliance. Any period for which the monitoring system is out of control and data are not available for required calculations constitutes a deviation from the monitoring requirements. 40 CFR 63.10(d)(5)(i) Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; Minn. R , subp. 1; 40 CFR 63.7 Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; Minn. R , subp. 1; 40 CFR 63.7 Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; Minn. R , subp. 1; 40 CFR 63.7 Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; Minn. R , subp. 1; 40 CFR 63.7 Title I Condition: 40 CFR 63.43(g): MACT and Minn. R ; Minn. R , subp. 1 Title I Condition: 40 CFR 63.43(g): MACT and Minn. R ; Minn. R , subp. 1 Title I Condition: 40 CFR 63.43(g): MACT and Minn. R ; Minn. R , subp CFR 60.45c(c); Minn. R Title I Condition: 40 CFR 52.21(j) & (k): ; Minn. R ; Minn. R , subp. 4 ; Minn. R ; Minn. R , subp. 4 Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R & 3010; Minn. R ; Minn. R , subp. 4 (continued) Title I Condition: 40 CFR 52.21(j) & 63.43(g)(2): BACT & MACT and Minn. R & 3010; Minn. R ; Minn. R , subp. 4

45 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-40 05/10/12 Site-specific monitoring plan. Develop a site-specific monitoring plan according to the following: 1. Develop and submit to the EPA Administrator for approval a site-specific monitoring plan for each CMS required for units in this section that addresses the following. Submit this site-specific monitoring plan at least 60 days before the initial performance evaluation of your CMS. i. Installation of the CMS sampling probe or other interface at a measurement location relative to each affected process unit such that the measurement is representative of control of the exhaust emissions; ii. Performance and equipment specifications for the sample interface, the pollutant concentration or parametric signal analyzer, and the data collection and reduction systems; and iii. Performance evaluation procedures and acceptance criteria (e.g., calibrations). 2. The site-specific monitoring plan shall also address the following: i. Ongoing O&M procedures in accordance with the general requirements of 40 CFR 63.8(c)(1), (c)(3), and (c)(4)(ii); ii. Ongoing data quality assurance procedures in accordance with the general requirements of 40 CFR 63.8(d); and iii. Ongoing recordkeeping and reporting procedures in accordance with the general requirements of 40 CFR 63.10(c), (e)(1), and (e)(2)(i). 3. Conduct a performance evaluation of each CMS in accordance with the site-specific monitoring plan. 4. Operate and maintain the CMS in continuous operation according to the site-specific monitoring plan. Monitoring and data collection requirements. 1. Monitor CO and oxygen continuously (or collect data at all required intervals) at all times that the affected source is operating in according to the CEMS requirements, except for monitor malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments); 2. Maintain CO emissions below the CO work practice standard at all times except during periods of SSM, and when the unit is operating at less than 50% of rated capacity; and 3. Keep records of CO and oxygen levels for each CEMS according to the following: i. Records described in 40 CFR 63.10(b)(2)(vi)-(xi). ii. Previous (i.e., superseded) versions of the performance evaluation plan as required in 40 CFR 63.8(d)(3). iii. Request for alternatives to relative accuracy test for CEMS as required in 40 CFR 63.8(f)(6)(i). iv. Records of the date and time that each deviation started and stopped, and whether the deviation occurred during a period of startup, shutdown, or malfunction or during another period. The Permittee shall furnish the Administrator a copy of a written report of the results of the CO CEMS performance evaluation, as required under Section 63.8(e). Notify the Administrator in writing of the date of the performance evaluation at least 60 days prior to the date the performance evaluation is scheduled to begin. Submit a site-specific performance evaluation test plan to the Administrator for approval, due 45 days before conducting the CO CEMS performance evaluation. The plan shall meet the requirements of 40 CFR Section 63.8(e)(3). In addition to complying with the requirements specified in 40 CFR 63.10(b)(1)&(2), also keep the following records for the CO CEMS required by Section 63.10(c): 1. All required CEMS measurements; 2. The date and time identifying each period during which the CMS was inoperative except for zero (low-level) and high-level checks; 3. The date and time identifying each period during which the CMS was out of control; 4. The specific identification of each period of excess emissions and parameter monitoring exceedances that occurs during SSMs; 5. The specific identification of each period of excess emissions and parameter monitoring exceedances that occurs during periods other than SSMs; 6. The nature and cause of any malfunction (if known); 7. The corrective action taken or preventative measures adopted; 8. The nature of the repairs or adjustments to the CMS that was inoperative or out of control. 9. The total process operating time during the reporting period; and 10. All procedures that are part of a quality control program developed and implemented for the CMS. Records for items 6-8 may be the same records used to satisfy the SSMP, provided that such plan and records adequately address items CFR 63.43(g)(2): MACT and Minn. R (continued) 40 CFR 63.43(g)(2): MACT and Minn. R CFR 63.43(g)(2): MACT and Minn. R (continued) 40 CFR 63.43(g)(2): MACT and Minn. R CFR 63.43(g)(2): MACT and Minn. R ; 40 CFR 63.10(e)(2) 40 CFR 63.43(g)(2): MACT and Minn. R ; 40 CFR 63.8(e)(2) Minn. R , subps. 1 & 2; meets requirements of 40 CFR 63.8(e)(3) 40 CFR 63.43(g)(2): MACT and Minn. R ; 40 CFR 63.10(c) (continued) 40 CFR 63.43(g)(2): MACT and Minn. R ; 40 CFR 63.10(c)

46 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-41 05/10/12 Subject Item: Associated Items: GP 020 Wet Scrubbers Subject to Case-by-Case MACT CE 095 Wet Scrubber - High Efficiency CE 101 Wet Scrubber - High Efficiency CE 105 Wet Scrubber - High Efficiency What to do Stacks associated with each wet scrubber are shown in the following pairs: Why to do it CE 095/SV 029 CE 101/SV 063 CE 105/SV 070 Install, calibrate, maintain, and operate monitoring devices to continuously measure pressure drop across each scrubber. The monitoring device shall be certified by the manufacturer to be accurate within ±1 inch water gauge pressure and must be calibrated on an annual basis in accordance with manufacturer's instructions. Install, calibrate, maintain, and operate monitoring devices to continuously measure scrubbing liquid flow rate. The monitoring device shall be certified by the manufacturer to be accurate within ±5 percent of design scrubbing liquid flow rate and must be calibrated on at least an annual basis in accordance with manufacturer's instructions. Continuous Parameter Monitoring System (CPMS) Monitoring Plan: The Permittee shall develop and make available for inspection a site-specific monitoring plan that addresses the requirements in paragraphs (1)-(7): 1. Installation of the CPMS sampling probe or other interface at a measurement location relative to each affected emission unit such that the measurement is representative of control of the exhaust emissions (e.g., on or downstream of the last control device). 2. Performance and equipment specifications for the sample interface, the parametric signal analyzer, and the data collection and reduction system. 3. Performance evaluation procedures and acceptance criteria (e.g., calibrations). 4. Ongoing operation and maintenance procedures in accordance with 40 CFR Section 63.8(c)(1), (3), (4)(ii), (7), & (8). 5. Ongoing data quality assurance procedures in accordance with 40 CFR Section 63.8(d). 6. Ongoing recordkeeping and reporting procedures in accordance with 40 CFR Section 63.10(c), (e)(1), & (e)(2)(i). 7. Corrective action procedures that will be followed in the event a wet scrubber exceeds an established operating limit. The corrective actions must be completed within 10 calendar days. Install and operate each CPMS such that the CPMS completes a minimum of one cycle of operation for each successive 15-minute period and determines and records valid data for at least 95 percent of every daily averaging period. Each CPMS must also determine and record the daily average of all recorded readings. Operate and maintain each CPMS and conduct a performance evaluation of each CPMS in accordance with the site-specific monitoring plan. The Permittee shall establish site-specific operating limits: 1. Measure and record the pressure drop and scrubber water flow rate every 15 minutes during each run of the PM performance test using the CPMS. 2. Calculate and record the average pressure drop and scrubber water flow rate for each individual test run. Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; 40 CFR (a) and Minn. R ; Minn. R , subp. 4 Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; 40 CFR (b) and Minn. R ; Minn. R , subp. 4 Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; 40 CFR (b); Minn. R , subp. 4 (continued) Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; 40 CFR (b); Minn. R , subp. 4 Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; 40 CFR (c)-(e); Minn. R , subp. 4 Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; 40 CFR (a)&(f); Minn. R , subp. 4 The operating limits shall be established as the lowest average pressure drop and the lowest average scrubber water flow rate corresponding to any of the test runs, except that the established operating limits may be changed if the Permittee: 1. Submits a written notification to the Commissioner requesting to conduct a new performance test to revise the operating limit; 2. Conducts a performance test to demonstrate compliance with the applicable emission limitation; and 3. Establishes revised operating limits.

47 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-42 05/10/12 Maintain the daily average pressure drop and daily average scrubber water flow rate at or above the minimum levels established during the initial or subsequent performance test. If the daily average pressure drop or daily average scrubber water flow rate is below the operating limits established for a corresponding emission unit, then follow the corrective action procedures in paragraphs (1)-(4) below: 1. Initiate and complete initial corrective action within 10 calendar days and demonstrate that the initial corrective action was successful. During any period of corrective action, continue to monitor and record all required operating parameters for equipment that remains in operation. After 10 calendar days, measure and record the daily average operating parameter value for the emission unit on which corrective action was taken. After the initial corrective action, if the daily average operating parameter value for the emission unit meets the operating limit established for the corresponding unit, then the corrective action was successful and the emission unit is in compliance with the established operating limits. 2. If the initial corrective action required in paragraph (1) was not successful, then complete additional corrective action within 10 calendar days and demonstrate that the subsequent corrective action was successful. During any period of corrective action, continue to monitor and record all required operating parameters for equipment that remains in operation. After the second set of 10 calendar days allowed to implement corrective action, measure and record the daily average operating parameter value for the emission unit. If the daily average operating parameter value for the emission unit meets the operating limit established for the corresponding unit, then the corrective action was successful and the emission unit is in compliance with the established operating limits. 3. If the second attempt at corrective action required in paragraph (2) was not successful, then repeat the procedures of paragraph (2) until the corrective action is successful. If the third attempt at corrective action is unsuccessful, then conduct another performance test in accordance with the procedures in 40 CFR (f) and report to the Administrator as a deviation the third unsuccessful attempt at corrective action. 4. After the third unsuccessful attempt at corrective action, submit to the Administrator the written report required in paragraph (3) within 5 calendar days after the third unsuccessful attempt at corrective action. This report must notify the Administrator that a deviation has occurred and document the types of corrective measures taken to address the problem that resulted in the deviation of established operating parameters and the resulting operating limits. Operate and maintain each wet scrubber CPMS and record all the information needed to document conformance with these requirements. Collect and reduce monitoring data for pressure drop and scrubber water flow rate and record all the information needed to document conformance with these requirements. O&M Plan: Prepare, and at all times operate according to a written O&M plan. Maintain a current copy of the O&M plan onsite, and it must be available for inspection upon request. The plan must be kept for the life of the affected source. The plan must address the following elements: 1. The plan shall address preventative maintenance for each scrubber, including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance. 2. In the event that an exceedance of an established operating limit for a scrubber occurs, then initiate corrective action to determine the cause of the operating limit exceedance and complete the corrective action within 10 calendar days. The corrective action procedures taken must be consistent with the installation, operation, and maintenance procedures listed in the site-specific CPMS monitoring plan. Recordkeeping: During the initial performance test of a wet scrubber, and at least weekly thereafter, the measure and record the pressure drop across the scrubber and the scrubbing liquid flow rate. Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; 40 CFR (e)&(j); Minn. R , subp. 4 (continued) Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; 40 CFR (j); Minn. R , subp. 4 (continued) Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; 40 CFR (j); Minn. R , subp. 4 (continued) Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; 40 CFR (j); Minn. R , subp. 4 Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; 40 CFR (b); Minn. R , subp. 4 Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; 40 CFR (b); Minn. R , subp. 4 (continued) Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; 40 CFR (b); Minn. R , subp. 4 Title I Condition: 40 CFR 52.21(j) & 63.43(g): BACT & MACT and Minn. R & 3010; 40 CFR (b) and Minn. R ; Minn. R , subp. 4

48 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-43 05/10/12 Subject Item: Associated Items: GP 021 Emergency Generators and Fire Water Pumps EU 026 Fire Water Supply Pump - Concentrator EU 027 Emergency Power Generator - Concentrator EU 049 Fire Water Booster Pump - Pellet Plant EU 050 Fire Water Supply Pump - Pellet Plant EU 051 Emergency Power Generator - Pellet Plant EU 110 Fire Water Booster Pump - DRI EU 111 Fire Water Supply Pump - DRI EU 112 Emergency Power Generator - DRI EU 113 Fire Water Booster Pump - Offices EU 114 Emergency Power Generator - Offices EU 143 Fire Water Booster Pump - Steel Mill EU 144 Fire Water Supply Pump - Steel Mill EU 145 Emergency Power Generator - Steel Mill EMISSION LIMITS What to do Opacity: less than or equal to 5 percent opacity using 6-minute Average once operating temperatures have been attained. This also demonstrates compliance with Minn. R , subp. 1. Why to do it ; Minn. R. 7011, 2300, subp. 1 Sulfur Dioxide: less than or equal to 0.5 lbs/million Btu heat input Minn. R , subp. 2 EMISSION LIMITS - EMERGENCY GENERATORS (EU 027, 051, 112, 114, and 145) (SV 013, 026, 036, 038, and 058) NMHC + NOx: Less than or equal to 6.4 grams per Kilowatt-hour. 40 CFR (b) and Minn. R CO: Less than or equal to 3.5 grams per Kilowatt-hour. 40 CFR (b) and Minn. R PM: Less than or equal to 0.20 grams per Kilowatt-hour. 40 CFR (b) and Minn. R EMISSION LIMITS - FIRE WATER SUPPLY PUMPS (EU 026, 050, 111, and 144) (SV 012, 025, 035, and 057) NMHC + NOx: Less than or equal to 4.0 grams per Kilowatt-hour. 40 CFR (c) and Minn. R CO: Less than or equal to 5.0 grams per kilowatt-hour. 40 CFR (c) and Minn. R PM: Less than or equal to 0.30 grams per Kilowatt-hour. 40 CFR (c) and Minn. R EMISSION LIMITS - FIRE WATER BOOSTER PUMPS (EU 049, 110, 113, and 143) (SV 024, 034, 037, and 056) NMHC + NOx: Less than or equal to 4.7 grams per Kilowatt-hour. 40 CFR (c) and Minn. R CO: Less than or equal to 5.0 grams per kilowatt-hour. 40 CFR (c) and Minn. R PM: Less than or equal to 0.40 grams per Kilowatt-hour. 40 CFR (c) and Minn. R OPERATING REQUIREMENTS Low Sulfur Fuel: The Permittee shall use only fuel with a maximum sulfur content of % by weight. Operating Hours: less than 500 hours per year based on a 12-month rolling sum to be calculated by the 15th day of each month. RECORDKEEPING Hours of Operation: On a daily basis, the Permittee shall record the daily hours of operation of each emission unit of this group. ; 40 CFR (b) Minn. R , subp. 2 Minn. R , subps. 4 & 5 The Permittee shall retain these records for five years. Fuel Supplier Certification: The Permittee shall obtain and maintain a fuel supplier certification for each shipment of No. 2 fuel oil, certifying that the sulfur content does not exceed % by weight. Minn. R , subps. 4 & 5

49 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-44 05/10/12 PERFORMANCE TESTING Performance Test: Upon the request of the Commissioner, the Permittee shall conduct a performance test for any or all of the following pollutants: PM, PM10, NOx, CO, VOC, and opacity. NSPS REQUIREMENTS Minn. R , subp. 1 Operate and maintain the stationary engine according to the manufacturer's written 40 CFR and Minn. R instructions or procedures developed by the owner or operator and approved by the engine manufacturer, over the entire life of the engine. Use diesel fuel that meets the requirements of 40 CFR Section (b) for 40 CFR (b) and Minn. R nonroad diesel fuel. Install a non-resettable hour meter on each engine prior to startup of the engine. 40 CFR (a) and Minn. R Comply with the emission standards specified in 40 CFR Sections (b)&(c) by purchasing an engine certified to the emission standards in 40 CFR Section (b) or (c), as applicable, for the same model year and maximum engine power. The engine must be installed and configured according to the manufacturer's specifications. Establish operating parameters to be monitored continuously to ensure the stationary internal combustion engine continues to meet the emission standards. The emergency stationary ICE may be operated for the purpose of maintenance checks and readiness testing. Maintenance checks and readiness testing of such units is limited to 100 hours per year for each unit. 40 CFR (c) and Minn. R CFR (d) and Minn. R CFR (e) and Minn. R Any operation other than emergency operation, and maintenance and testing, is prohibited. MACT REQUIREMENTS - EMERGENCY GENERATORS (EU 027, 051, 112, 114, and 145) The Permittee shall submit to the Commissioner in accordance 40 CFR Section (b) an Initial Notification including the information in 40 CFR Section 63.9(b)(2)(i)-(v), and a statement that the RICE has no additional requirements and explain the basis of the exclusion. 40 CFR (d) and Minn. R

50 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-45 05/10/12 Subject Item: Associated Items: GP 022 Stack/Vents with CEMS MR 019 O2 CEM MR 020 CO CEM MR 021 NOx CEM MR 022 SO2 CEM MR 025 O2 CEM MR 026 CO CEM MR 027 NOx CEM MR 028 SO2 CEM MR 045 O2 CEM MR 046 CO CEM MR 047 NOx CEM MR 056 O2 CEM MR 057 CO CEM MR 058 NOx CEM MR 059 SO2 CEM SV 018 Furnace Hood Exhaust SV 019 Furnace Waste Gas SV 030 DRI Process Gas Heater Line 1 SV 044 EAF Baghouse Line 1 What to do CONTINUOUS EMISSION MONITORING SYSTEMS (CEMS) Requirements apply individually to each monitor listed in this group. The Permittee shall use a CEMS to measure emissions from each stack listed in this group, as indicated in the next requirement. The CEMS are labeled as follows: SV 030: MR 045 for O2, MR 046 for CO, MR 047 for NOx SV 018: MR 019 for O2, MR 020 for CO, MR 021 for NOx, MR 022 for SO2 SV 019: MR 025 for O2, MR 026 for CO, MR 027 for NOx, MR 028 for SO2 SV 044: MR 056 for O2, MR 057 for CO, MR 058 for NOx, MR 059 for SO2 Initial Notification: due 60 days before installing each CEMS. The Notification shall include plans and drawings of the proposed system which show the configuration of the monitoring system including any monitor bypass routes. CEMS Certification Test (CT) Plan: due 30 days before each CEMS CT CEMS CT Pretest Meeting: due 7 days before each CEMS CT CEMS CT Report: due 45 days after each CEMS CT CEMS CT Report - Microfiche Copy: due 105 days after each CEMS CT The Notification, Test Plan, and Test Report may be submitted in alternate format as allowed by Minn. R , subp. 2. Continuous Operation: Each CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. 4 data points, equally spaced, if the emission unit operated during the entire hour; B. 2 data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. 1 data point if the emission unit operated for 15 minutes or less during the hour. Minn. R CEMS Why to do it 40 CFR 64.9(a); Minn. R ; Minn. R , subp. 1 Minn. R , subps. 1-3; Minn. R , subps. 1-4 Minn. R Minn. R , subps. 1 & 2

51 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-46 05/10/12 QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. CEMS Daily Calibration Drift (CD) Test: The CD shall be quantified and recorded at zero (low-level) and upscale (high-level) gas concentrations at least once daily according to the procedures listed in Minn. R , subp. 3 and 40 CFR Section 60.13(d)(1) for each pollutant concentration, each diluent monitor, and for each monitor range. The CEMS shall be adjusted whenever the CD exceeds twice the specification of 40 CFR pt. 60, Appendix B. If no span value is specified in the applicable requirement or in a compliance document, the Permittee shall use a span value equivalent to 1.5 times the emission limit. 40 CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for CEMS. Follow the procedures in 40 CFR pt. 60, Appendix F. CEM Certification Test: due 90 days after Excess Emissions/Downtime Reports (EER's) are first required for the CEMS. The first EER is due 30 days after the end of the calendar quarter following permit issuance. Follow the Performance Specifications listed in 40 CFR pt. 60, Appendix B. Cylinder Gas Audit: due before end of each calendar half-year following CEM Certification Test, except that a CGA is not required during any calendar half year in which a RATA was performed. The initial CGA must be performed within 80 days following certification of the CEMS. The CGAs shall be conducted at least three months apart but no more than eight months apart. A CGA shall be conducted according to the procedures in 40 CFR pt. 60, Appendix F, section If the monitored emission unit was operated for less than 24 hours during the calendar half year, a CGA is not required for that calendar half year. CEMS Relative Accuracy Test Audit (RATA): due before end of each year following CEM Certification Test. A RATA is not required in any calendar year if a RATA conducted in the previous year demonstrated a relative accuracy value of less than 15 percent or if the associated emissions unit operated less than 48 hours during the calendar year. If the exception is used, the next RATA shall be conducted during the first half of the following calendar year. RATAs shall be conducted at least 3 months apart according to 40 CFR pt. 60, Appendix F, section Recordkeeping: The Permittee shall retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. Minn. R , subp. 2 Minn. R , subp. 3 Minn. R , subp. 1 Minn. R , subp. 4 Minn. R , subp. 5 Minn. R

52 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: Subject Item: GP 023 EAF Ladle/Castle Area Associated Items: EU 126 EAF Ladle Metallurgy Furnace Line 1 EU 127 EAF Casting Area Line 1 EU 128 EAF Ladle/Tundish Pre-Heaters Line 1 SV 044 EAF Baghouse Line 1 A-47 05/10/12 OPERATING LIMITS What to do Fuel Usage: Natural Gas Only burned in the EAF Ladle Units. (EU 126 and 128) Low NOx burners: The Permittee shall install and operate Low NOx burners in the EAF Ladle/Tundish Pre-Heaters (EU 128). EMISSION LIMITS Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Because it has been shown that the facility does not cause a violation of ambient air quality standards, and is located outside the Mpls/St Paul air quality control region and city of Duluth, and is located at least ¼ mile from any residence or public roadway, and the associated emission unit are controlled by control equipment which has a collection efficiency of 85% by weight, the associated emission units are considered to be in compliance with this requirement. Opacity: less than or equal to 20 percent opacity using 6-minute Average. Compliance with the opacity limit of associated stacks is considered to be compliance with this requirement. MACT REQUIREMENTS See GP 009 for MACT emission limits for these units. The approval of the case-by-case MACT determinations for the members of this group under 40 CFR 63 Subp. B shall expire if construction of any of the members of this group has not commenced within the continuous construction of the facility. Why to do it Minn. R , subps. 1(A) & 3 Minn. R , subp. 1(B) Title I Condition: 40 CFR 63.43(g)(4): MACT and Minn. R

53 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: Subject Item: GP 024 DRI Top Gas Purification Associated Items: EU 067 DRI Top Gas Purification Line 1 SV 078 DRI Top Gas Purification Line 1 A-48 05/10/12 BACT LIMITS What to do Appendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Hydrogen Sulfide: comply with the H2S limits on a ppm and lb/hr basis using a 3-hour average. OPERATING LIMITS The Permittee shall inject into the top gas DiMethyl-DiSulfide (DMDS) at a rate less than or equal to 11.1 lb/hr using a 3-hour average. PERFORMANCE TESTING Initial Performance Test: due 180 days after Initial Startup to measure H2S and TRS emissions. MONITORING The Permittee shall directly monitor the DMDS injection rate or a DMDS injection system operating parameter that can be used to calculate injection rate (for example, screw feeder speed). The Permittee shall also establish a relationship between the operating parameter and the DMDS injection rate in order to calculate the injection rate based on the operating parameter level. Why to do it ; Minn. R , subp. 4 Minn. R , subp. 4 The Permittee shall continuously monitor the DMDS injection rate or operating parameter during all periods when the DRI unit is operating, and calculate the 3-hour average DMDS injection rate in pounds per hour. When calculating the 3-hour average, the Permittee shall exclude hours when the unit is not operating and include hours when unit is operating but the injection system is not working correctly. RECORDKEEPING The Permittee shall record and maintain records of the average DMDS injection rate for each hour of operation and the 3-hour average injection rate. Minn. R , subps. 4 & 5 If the required 3-hour average DMDS injection operating parameter is not maintained, the Permittee shall record reasons for not maintaining the operating parameter and the corrective actions taken.

54 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: Subject Item: GP 025 DRI Water Blowdown Units Associated Items: EU 161 DRI Quench Cooling Water Blowdown Line 1 EU 162 DRI Process Water Blowdown Line 1 SV 075 DRI Process Water Blowdown Line 1 SV 076 DRI Quench Cooling Water Blowdown Line 1 A-49 05/10/12 BACT LIMITS What to do Appendix A contains the numerical limits that are referenced in this section. Each limit must be complied with separately for each basis specified. Carbon Monoxide: comply with the CO limits on a percent by volume and lb/hr basis using a 1-hour average. PERFORMANCE TESTING Initial Performance Test: due 180 days after Initial Startup to measure CO emissions from SV 075. Initial Performance Test: due 180 days after Initial Startup to measure CO emissions from SV 076. Why to do it

55 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Essar Steel Minnesota LLC Permit Number: A-50 05/10/12 Subject Item: Associated Items: GP 026 Ore Barns CE 108 Enclosure - Coarse Ore Storage CE 109 Enclosure - Fine Ore Storage EU 168 Coarse Ore Barn EU 169 Fine Ore Barn SV 082 Coarse Ore Barn Perimeter SV 083 Fine Ore Barn Perimeter MINNESOTA RULES What to do Total Particulate Matter: less than or equal to 0.3 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Total Particulate Matter PTE is 0.04 lb/hr and 0.14 lb/hr through SV 082 and SV 083 respectively. Opacity: less than or equal to 20 percent opacity using 6-minute Average CONTROL EQUIPMENT REQUIREMENTS The Permittee shall maintain the enclosure at a negative gauge pressure. All air vented from the enclosure shall be sent through air pollution control equipment; all doors and windows leading to the outside air shall be kept closed when the facility is in operation. The Permittee shall install, operate and record the output of differential pressure gauge. The gauge shall be located at a point in the structure that will experience the least draw from the baghouse fan. The Permittee shall collect and record, at a minimum rate of one reading every 15 minutes, the differential pressure between the enclosure and the atmosphere. Signage and Inspection of Enclosure Openings: The Permittee shall post signs on all non-alarmed doors and windows leading to the outside from that state that the doors and windows must remain closed while the facility is in operation. Why to do it Minn. R , subp. 1(A) Minn. R , subp. 1(B) Minn. R , subps. 4 & 5 Minn. R , subps. 4 & 5 Minn. R , subps. 4 & 5 The Permittee shall conduct inspections at least once each calendar week to determine if the doors and windows are closed as required by this permit. The Permittee shall maintain a written record of the inspections and any corrective action taken.

56 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: Essar Steel Minnesota LLC Subject Item: EU 165 Space Heaters A-51 05/10/12 What to do Why to do it Fuel Usage : Natural Gas Only Total Particulate Matter: less than or equal to 0.4 lbs/million Btu heat input Minn. R , subp. 1 Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity Minn. R , subp. 2

57 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: Permit Number: Essar Steel Minnesota LLC Subject Item: FS 042 Slag Dumping A-52 05/10/12 Associated Items: CE 068 Dust Suppression What to do Slag Fluoride Concentration: less than or equal to 10% by weight in the slag. Sample and analyze the fluoride content of the slag in accordance with EPA Method Fluoride Concentration Recordkeeping: The Permittee shall by the 15th of each month record the slag fluoride concentration. Why to do it ; Minn. R , subp. 5

58 TABLE B: SUBMITTALS Facility Name: Essar Steel Minnesota LLC Permit Number: Unless another person is identified in the applicable Table, send all other submittals to: AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota B-1 05/10/12 Send submittals that are required to be submitted to the U.S. EPA regional office to: Mr. George Czerniak Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by parts to must be certified by a responsible official, defined in Minn. R , subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition. Send submittals that are required by the Acid Rain Program to: U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C Send any application for a permit or permit amendment to: AQ Permit Document Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of: - accumulated insignificant activities, - installation of control equipment, - replacement of an emissions unit, and - changes that contravene a permit term. Table B lists most of the submittals required by this permit. Please note that some submittal requirements may appear in Table A or, if applicable, within a compliance schedule located in Table C. Table B is divided into two sections in order to separately list one-time only and recurrent submittal requirements.

59 TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS Facility Name: Essar Steel Minnesota LLC Permit Number: B-2 05/10/12 What to send When to send Portion of Facility Affected Application for Permit Reissuance due 180 days before expiration of Existing Total Facility Permit Fugitive Emissions Control Plan due before Initial Startup. The Permittee shall submit a copy of the fugitive dust emissions control plan to the Commissioner. GP006 The Permittee shall incorporate the fugitive dust control plan for sources subject to Case-by-Case MACT into the fugitive dust control plan required under 40 CFR part 63, subp RRRRR. Notification of compliance status due 60 days after Initial Performance Test EU065, EU066, EU069, EU137 Notification of compliance status due 60 days after Initial Startup of the DRI Facility. Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of ACI system. Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of each unit. Submit the name and number of each unit and the date operation of each unit began. Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of Mining Operations. Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of the DRI Facility. Notification of the Actual Date of Initial Startup due 15 days after Initial Startup of the Pelletizing Facility. Notification of the Date Construction Began due 30 days after Start Of Construction. Submit the name and number of each unit and the date construction of each unit began. Notification due 60 days before Install of CEMS. The Notification shall include plans and drawings of the proposed system which show the configuration of the monitoring system including any monitor bypass routes. Notification due 7 days after Initial Startup of the ACI System. Operation and Maintenance Plan due 180 days after Initial Startup. Prepare and submit to the Commissioner an O&M plan for each control device. Operation and Maintenance Plan due 90 days before Initial Startup of the ACI system. The plan shall specify the operating parameters to be monitored to ensure proper operation of the mercury reduction technology. The plan shall also include, at a minimum technical specifications for any oxidizing and adsorption agents to be used, as allowed by the equipment vendor considering any patented or proprietary information, target injection rates, routine and long-term maintenance and inspection requirements that are consistent with the manufacturers specifications. Operation and Maintenance Plan due before Initial Startup of Mining Operations. Prepare, submit and maintain a current copy of the O&M plan onsite incorporating operating parameters to be monitored to ensure proper operation of the mobile sources, maintenance and inspection requirements consistent with the manufacturers specifications, and records of urea use. The plan must be available for inspection upon request. GP012 GP018 GP002 GP001 Total Facility Total Facility GP002 MR019, MR020, MR021, MR022, MR025, MR026, MR027, MR028, MR045, MR046, MR047, MR056, MR057, MR058, MR059 GP018 GP020 GP018 GP001

60 TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS Facility Name: Essar Steel Minnesota LLC Permit Number: B-3 05/10/12 Operation and Maintenance Plan due before Initial Startup of Pelletizing GP002 Facility. Prepare, submit and maintain a current copy of the O&M plan onsite incorporating operating parameters to be monitored to ensure proper operation of the affected sources. The plan must be available for inspection upon request. Operation and Maintenance Plan due before Initial Startup. Prepare, submit GP007 and maintain a current copy of the O&M plan onsite incorporating preventative maintenance and leak detection requirements. The plan must be available for inspection upon request. Operation and Maintenance Plan due before Initial Startup. Prepare, submit GP018 and maintain a current copy of the O&M plan onsite incorporating the requirements of GCP for the indurating furnace. The plan must be available for inspection upon request. Performance Test Plan due 90 days before Initial Performance Test. GP008 Relative Accuracy Test Audit (RATA) Notification Relative Accuracy Test Audit (RATA) Results Summary due 30 days before CEMS Relative Accuracy Test Audit (RATA). due 45 days after CEMS Relative Accuracy Test Audit (RATA) Report due 60 days before Initial Startup of the Pelletizer, plans for a Scrubber Evaluation Study which addresses issues related to optimizing SO2 control. (See GP 018). Report due 90 days before Initial Startup of the pelletizer, design specifications from the pelletizer furnace and GSA vendors, which indicate that the system has been designed to achieve a SO2 emission rate of 5.0 ppm (wet basis) on a 24-hour rolling average. (See GP 018). Testing Frequency Plan due 60 days after Initial Performance Test for CO. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. Testing Frequency Plan due 60 days after Initial Performance Test for H2S. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. Testing Frequency Plan due 60 days after Initial Performance Test for NOx. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. Testing Frequency Plan due 60 days after Initial Performance Test for opacity. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. MR019, MR020, MR021, MR022, MR025, MR026, MR027, MR028, MR045, MR046, MR047, MR056, MR057, MR058, MR059 MR019, MR020, MR021, MR022, MR025, MR026, MR027, MR028, MR045, MR046, MR047, MR056, MR057, MR058, MR059 GP018 GP018 SV051, SV075, SV076 SV078 SV028, SV050, SV051, SV062 SV005, SV018, SV019, SV028, SV029, SV030, SV044, SV048, SV050, SV051, SV054, SV055, SV062, SV063, SV070

61 TABLE B: ONE TIME SUBMITTALS OR NOTIFICATIONS Facility Name: Essar Steel Minnesota LLC Permit Number: B-4 05/10/12 Testing Frequency Plan due 60 days after Initial Performance Test for PM. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. Testing Frequency Plan due 60 days after Initial Performance Test for PM10. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. Testing Frequency Plan due 60 days after Initial Performance Test for PM2.5. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. Testing Frequency Plan due 60 days after Initial Performance Test for SO2. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. Testing Frequency Plan due 60 days after Initial Performance Test for sulfuric acid mist. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. Testing Frequency Plan due 60 days after Initial Performance Test for VOCs. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12 month, 36 month, and 60 month intervals, or as applicable, shall be required upon written approval of the MPCA. Testing Frequency Plan due 60 days after Performance Test (4th) for mercury. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on quarterly, semiannually, yearly, or other intervals, shall be required upon written approval of the MPCA. SV028, SV029, SV030, SV044, SV050, SV051, SV062, SV063 SV018, SV019, SV029, SV030, SV044, SV051, SV063, SV070 SV018, SV019, SV029, SV030, SV044, SV051, SV063, SV070 SV030, SV051 SV018, SV019, SV044 SV018, SV019, SV044, SV051 SV018, SV019

62 TABLE B: RECURRENT SUBMITTALS Facility Name: Essar Steel Minnesota LLC Permit Number: B-5 05/10/12 What to send When to send Portion of Facility Affected Cylinder Gas Audit (CGA) Results Summary due 30 days after end of each calendar quarter following end of the calendar quarter in which the Audit was performed. Excess Emissions/Downtime Reports (EER's) due 30 days after end of each calendar quarter following Initial Startup of the Monitor. Submit DRF-1, as amended. The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard. The EER must be submitted even if there were no excess emissions, downtime or bypasses during the quarter. Report due 30 days after end of each calendar half-year following Initial Performance Test of the wet scrubber, the Permittee shall submit a report to the Commissioner of occurrences when the measurements of the scrubber pressure loss (or gain) or liquid flow rate differ by more than ±30% from the average from the most recent performance test. Report due 30 days after end of each half-year following Initial Startup. If actions taken by the Permittee during a startup or shutdown (and the startup or shutdown causes the source to exceed any applicable emission limitation in the relevant emission standards), or malfunction (including actions taken to correct a malfunction) are consistent with the procedures specified in the source's SSMP, the Permittee shall state such information in a SSM report. The report shall include: actions taken to minimize emissions, the number, duration, and a brief description for each type of malfunction and which caused or may have caused any applicable emission limitation to be exceeded. The report shall consist of a letter, containing the name, title, and signature of the responsible official. Semiannual Compliance Report due 31 days after end of each calendar half-year following Initial Startup. The first compliance report is due no later than January 31st or July 31st, whichever date is the first date following the end of the first calendar half after Initial Startup of the process heater. The Semi-Annual Compliance Report must contain the following: 1. Information required in 40 CFR Section (c)(1)-(11); 2. If there are no deviations from the requirements for work practice standards that apply, a statement that there were no deviations from the work practice standards during the reporting period; 3. If the Permittee has a deviation from the work practice standard during the reporting period, the report must contain the information in 40 CFR Section (d); and 4. If the process heater had a startup, shutdown, or malfunction during the reporting period and the Permittee took actions consistent with the SSMP the compliance report must include the information in 40 CFR Section 63.10(d)(5)(i). MR019, MR020, MR021, MR022, MR025, MR026, MR027, MR028, MR045, MR046, MR047, MR056, MR057, MR058, MR059 MR019, MR020, MR021, MR022, MR025, MR026, MR027, MR028, MR045, MR046, MR047, MR056, MR057, MR058, MR059 CE095, CE101, CE105 Total Facility GP019

63 TABLE B: RECURRENT SUBMITTALS Facility Name: Essar Steel Minnesota LLC Permit Number: Semiannual Deviations Report due 30 days after end of each calendar half-year following Initial Startup. The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occurred, the Permittee shall submit the report stating no deviations. Annual Report due 30 days after end of each calendar year following Initial Startup. The Permittee shall submit a report to the Commissioner due 30 days after end of each calendar year. The report covers January 1 - December 31, which is due by January 30 of each year. The report shall contain for each certified and non-certified mobile source the operating hours and gallons of fuel used. Compliance Certification due 30 days after end of each calendar year following Initial Startup (for the previous calendar year). To be submitted on a form approved by the Commissioner, both to the Commissioner and to the US EPA regional office in Chicago. This report covers all deviations experienced during the calendar year. Compliance Certification due 30 days after end of each calendar year following Initial Startup for mobile sources. Include a certification from the equipment manufacturer that the haul trucks in use at the facility have emissions less than or equal to the required Tier level. Total Facility GP001 Total Facility GP001 B-6 05/10/12

64 APPENDIX A Limits Table Facility Name: Essar Steel Minnesota LLC Permit Number: Table 1 PM, PM 10, PM 2.5, Lead, and Fluoride Not to Exceed Limits Stack ID EU ID GP ID Description Permitted Performance Standard*** Permitted Mass Emission Limits (gr/dscf) (ppmv)* (lb/hr) PM PM 10 PM 2.5 Lead Fluoride PM PM 10 PM 2.5 Lead Fluoride SV 001 EU 002 GP 008 Primary Ore Crusher E E E E E-06 SV 002 EU 004 GP 008 Grizzly Screening Building E E E E E-07 SV 006 EU 013 GP 008 Coarse Ore Storage Conveyor E E E E E-08 SV 007 EU 014 GP 008 Fine Ore Storage Conveyor E E E E E-08 SV 008 EU 015 GP 008 Coarse Ore Conveyor Gallery E E E E E-08 SV 009 EU 018 GP 008 Fine Ore Conveyor Gallery E E E E E-07 SV 010 EU 022 GP 008 Primary Grinding Mill Line E E E E E-07 SV 011 EU 024 GP 016 Primary Grinding Mill Line E E E E E-07 SV 014 EU 028 GP 016 Limestone Handling System E E E E-08 SV 015 EU 030 GP 008 Binder Handling System E E E E-07 SV 016 EU 036 GP 008 Hearth Layer Bin E E E E E-05 SV 017 EU 037 EU 106 GP 018 Hearth Layer Feed E E E E E-06 SV 018 EU 038 GP 018 Furnace Hood Exhaust E E E E E+00 SV 019 EU 039 GP 008 Furnace Waste Gas E E E E E+01 SV 020 EU 040 GP 008 Pellet Discharge E E E E E-04 SV 021 EU 041 GP 008 Pellet Screening and Handling E E E E E-04 SV 022 EU 042 GP 008 Pellet Screenings to Regrind Conveyors E E E E E-06 SV 023 EU 048 GP 008 Oxide Pellet Stockpile Conveyor Gallery E E E E E-05 SV 027 EU 054 GP 017 DRI Oxide Pellet Screening and Handling System Line E E E E E-05 SV 029 EU 064 GP 019 DRI Depressurizing Scrubber Line E E E E E-05 SV 030 EU 066 GP 008 DRI Process Gas Heater Line ** 0.015** 0.015** 7.3E E E E E-06 SV 031 EU 063 GP 016 DRI Oxide Charging Area Line E E E E E-06 SV 039 EU 115 GP 016 Hydrated Lime Handling System E E E-02 SV 040 EU 117 GP 016 Calcined Limestone Handling System E E E-02 SV 041 EU 119 GP 016 Carbon Handling System E E E-02 SV 042 EU 121 GP 016 Fluorspar Handling System E E E E-03 SV 043 EU 123 GP 009 Bauxite Handling System E E E-02 SV 044 EU 125 GP 009 EAF Baghouse Line E E E E E-04 SV 047 EU 131 GP 015 EAF Baghouse Dust Transfer Line E E E E E-05 SV 051 EU 138 GP 016 Tunnel Furnace E E E+00 SV 059 EU 044 GP 017 Pellet Plant - Powder Coating Handling E E E E-08 SV 063 EU 070 GP 017 DRI P.T.S. Depressurizing Scrubber Line E E E E E-05 SV 070 EU 088 GP 016 DRI Screening & Handling Line E E E E E-05 SV 072 EU 052 GP 008 DRI Powder Coating Handling E E E E-08 SV 073 EU 060 GP 008 DRI Pellet Silos Line E E E E E-05 SV 084 EU 176 GP 008 Primary Grinding Mill Line E E E E E-07 SV 085 EU 170 GP 008 Grizzly Transfer Tower E E E E E-08 SV 086 EU 171 GP 008 Non-Magnetic Cobber Rejects Transfer Tower E E E E E-08 SV 087 EU 172 GP 008 Secondary Screening Crusher/Cobber Line E E E E E-07 SV 088 EU 173 GP 008 Secondary Screening Crusher/Cobber Line E E E E E-07 SV 089 EU 174 GP 008 Secondary Screening Crusher/Cobber Line E E E E E-07 SV 090 EU 175 GP 016 Secondary Screening Crusher/Cobber Line E E E E E-07 SV 091 EU 177 GP 016 Carbon Bin for Mercury Control E E E-02 SV 092 EU 178 GP 008 Lime Bin for Scrubber E E E-02 *Fluoride performance standard shall be measured at ppmv wet corrected to 15% O 2. **DRI Process Gas Heater performance standards shall be on a lb/mmbtu basis. ***Lead and Fluoride incoming material concentration limits are listed in Table A of the permit.

65 For each pollutant, a performance standard (Table 2) and mass emission limit (Table 3) is presented. Where applicable, a startup, shutdown, malfunction (SSM) limit (Table 3) is also included. Table 2 SO 2, NO x, CO, VOC, SAM, H 2 S, and CO 2 e Not to Exceed Performance Standard Limits SO 2 NOx CO VOC SAM H 2 S SV 018 EU 038 GP 018 Furnace Hood Exhaust 6.8 ppmv wet ppmv wet ppmv wet ppmv 0.25 lb/mmbtu O O O 2 wet@15% O 2 SV 019 EU 039 GP 018 Furnace Waste Gas 5.0 ppmv wet ppmv wet ppmv wet ppmv 0.25 lb/mmbtu O O O 2 wet@15% O 2 SV 028 EU 065 GP 019 DRI Package Boiler Line lb/mmbtu lb/mmbtu SV 030 EU 066 GP 019 DRI Process Gas Heater Line lb/ton DRI produced lb/mmbtu lb/mmbtu SV 044 EU 125 GP 009 EAF Baghouse Line lb/ton steel lb/ton of liquid lb/ton of liquid lb/ton of liquid lb/ton of liquid produced steel produced steel produced steel produced steel produced SV 045 EU 129 GP 014 EAF Vacuum Degasser Line 1 53 ppm SV 050 EU 137 GP 019 Vacuum Degasser Boiler lb/mmbtu lb/mmbtu SV 051 EU 138 GP 015 Tunnel Furnace 1.0 ppm lb/ton steel produced lb/mmbtu lb/mmbtu SV 062 EU 069 GP 019 DRI P.T.S. Heater Line lb/mmbtu lb/mmbtu SV 075 EU 162 GP 025 DRI Process Water Blowdown Line % by volume SV 076 EU 161 GP 025 DRI Quench Cooling Water Blowdown Line % by volume SV 078 EU 067 GP 024 DRI Top Gas Purification Line 1 65 ppm Table 3 SO 2, NO x, CO, VOC, SAM, H 2 S, and CO 2 e Not to Exceed Mass Emission Limits SO 2 NO x CO VOC SAM H 2 S CO 2 e (lb/hr) (lb/hr) SSM (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (ton/yr) SV 018 EU 038 GP 018 Furnace Hood Exhaust SV 019 EU 039 GP 018 Furnace Waste Gas ,000 SV 028 EU 065 GP 019 DRI Package Boiler Line SV 030 EU 066 GP 019 DRI Process Gas Heater Line SV 044 EU 125 GP 009 EAF Baghouse Line SV 045 EU 129 GP 014 EAF Vacuum Degasser Line SV 050 EU 137 GP 019 Vacuum Degasser Boiler SV 051 EU 138 GP 015 Tunnel Furnace SV 062 EU 069 GP 019 DRI P.T.S. Heater Line SV 075 EU 162 GP 025 DRI Process Water Blowdown Line SV 076 EU 161 GP 025 DRI Quench Cooling Water Blowdown Line SV 078 EU 067 GP 024 DRI Top Gas Purification Line 1 8.2

66 APPENDIX B Modeling Parameters Facility Name: Essar Steel Minnesota LLC Permit Number: Summary of Stack Vent Parameters and Emission Rates used for Class I and Class II modeling Stack ID No. Description UTM: Zone 15 (NAD83) LCC: 47N 93W (30,60N) (5) Base Easting (m) Northing (m) X (m) Y (m) Elevation (m) Exit Flow Rate (acfm) Exit Height from Base (m) Inside Diameter (m) Exit Flow Velocity (m/s) Exit Temp (K) Emission Rates (g/s) PM 10 PM 2.5 CO NO x SO 2 SO 4 (5) PMC (5) PMF (5) SOA (5) EC (5) Pb (4) Hourly Annual Hourly Annual Hourly Hourly Annual Hourly Annual Hourly Annual Hourly Hourly Hourly Hourly Hourly SV 001 Primary Ore Crusher , E E E E E-01 SV 002 Grizzly Screening Building , E E E E E-02 SV 005 DRI Cooling Tower Line ,475, E E E E-01 SV 006 Coarse Ore Storage Conveyor , E E E E E-02 SV 007 Fine Ore Storage Conveyor , E E E E E-02 SV 008 Coarse Ore Conveyor Gallery (2) , E E E E E-02 SV 009 Fine Ore Conveyor Gallery (2) , E E E E E-02 SV 010 Primary Grinding Mill Line (1) , E E E E E-02 SV 011 Primary Grinding Mill Line (1) , E E E E E-02 SV 014 Limestone Handling System , E E E E E-03 SV 015 Binder Handling System , E E E E E-02 SV 016 Hearth Layer Bin , E E E E E-01 SV 017 Hearth Layer Feed , E E E E E-02 SV 018 Furnace Hood Exhaust , E E E E E E E E E E E E-03 SV 019 Furnace Waste Gas , E E E E E E E E E E E E-03 SV 020 Pellet Discharge , E E E E E-01 SV 021 Pellet Screening and Handling , E E E E E-01 SV 022 Pellet Screenings to Regrind Conveyors , E E E E E-03 SV 023 Oxide Pellet Stockpile Conveyor Gallery , E E E E E-01 SV 027 DRI Oxide Pellet Screening and Handling System Line , E E E E E-01 SV 028 DRI Package Boiler Line , E E E E E E E E E E E-02 SV 029 DRI Depressurizing Scrubber Line , E E E E E-01 SV 030 DRI Process Gas Heater Line , E E E E E E E E E E E-05 SV 031 DRI Oxide Charging Area Line , E E E E-02 SV 039 Hydrated Lime Handling System , E E E E E-03 SV 040 Calcined Limestone Handling System , E E E E E-03 SV 041 Carbon Handling System , E E E E E-03 SV 042 Fluorspar Handling System E E E E E-04 SV 043 Bauxite Handling System , E E E E E-02 SV 044 EAF Baghouse Line , E E E E E E E E E E E E-02 SV 045 EAF Vacuum Degasser Line , E E E E E E E E E E E-02 SV 047 EAF Baghouse Dust Transfer Line E E E E E-03 SV 048 EAF Indirect Cooling Tower Line ,318, E E E E E-02 SV 050 Vacuum Degasser Boiler , E E E E E E E E E E E-02 SV 051 Tunnel Furnace , E E E E E E E E E E-02 SV 054 Direct Cooling Tower ,020, E E E E E-02 SV 055 Laminar Cooling Tower ,291, E E E E E-02 SV 059 Pellet Plant - Powder Coating Handling E E E E E-04 SV 061 DRI Flare Line E E E E E E E E E E E E E-04 SV 062 DRI P.T.S. Heater Line , E E E E E E E E E E E E E-03 SV 063 DRI P.T.S. Depressurizing Scrubber Line , E E E E E-02 SV 070 DRI Screening & Handling Line , E E E E E-01 SV 072 DRI Powder Coating Handling E E E E E-04 SV 073 DRI Pellet Silos Line , E E E E E-02 SV 075 DRI Process Water Blowdown Line E-01 SV 076 DRI Quench Cooling Water Blowdown Line E-01 SV 078 DRI Top Gas Purification Line , SV 082 Coarse Ore Barn Perimeter (3) SV 083 Fine Ore Barn Perimeter (3) SV 084 Primary Grinding Mill Line (1) , E E E E E-02 SV 085 Grizzly Transfer Tower , E E E E E-02 SV 086 Non-Magnetic Cobber Rejects Transfer Tower , E E E E E-02 SV 087 Secondary Screening Crusher/Cobber Line , E E E E E-02 SV 088 Secondary Screening Crusher/Cobber Line , E E E E E-02 SV 089 Secondary Screening Crusher/Cobber Line , E E E E E-02 SV 090 Secondary Screening Crusher/Cobber Line , E E E E E-02 SV 091 Carbon Bin for Mercury Control , SV 092 Lime Bin for Scrubber , E E E E E-03

67 UTM: Zone 15 (NAD83) LCC: 47N 93W (30,60N) (5) Base Exit Flow Exit Height Inside Exit Flow Exit Emission Rates (g/s) Stack Description Easting Northing X Y Elevation Rate from Base Diameter Velocity Temp PM ID No. 10 PM 2.5 CO NO x SO 2 SO 4 (5) PMC (5) PMF (5) SOA (5) EC (5) (m) (m) (m) (m) (m) (acfm) (m) (m) (m/s) (K) Hourly Annual Hourly Annual Hourly Hourly Annual Hourly Annual Hourly Annual Hourly Hourly Hourly Hourly (6) SV 012 Fire Water Supply Pump - Concentrator E E E E E E E E E E E E-04 Class I 2.2E E E E E E E E E-03 Class II SV 013 Emergency Power Generator - Concentrator , E E E E E E E E E E E-03 Class I 7.1E E E E E E E E E-03 Class II SV 024 Fire Water Booster Pump - Pellet Plant E E E E E E E E E E E-04 Class I 1.4E E E E E E E E E-03 Class II SV 025 Fire Water Supply Pump - Pellet Plant E E E E E E E E E E E E-04 Class I 2.2E E E E E E E E E-03 Class II SV 026 Emergency Power Generator - Pellet Plant , E E E E E E E E E E E-03 Class I 7.1E E E E E E E E E-03 Class II SV 034 Fire Water Booster Pump - Furnace E E E E E E E E E E E-04 Class I 1.4E E E E E E E E E-03 Class II SV 035 Fire Water Supply Pump - DRI E E E E E E E E E E E E-04 Class I 2.2E E E E E E E E E-03 Class II SV 036 Emergency Power Generator - DRI , E E E E E E E E E E E-03 Class I 7.1E E E E E E E E E-03 Class II SV 037 Fire Water Booster Pump - Offices E E E E E E E E E E E-04 Class I 1.4E E E E E E E E E-03 Class II SV 038 Emergency Power Generator - Offices , E E E E E E E E E E E E-04 Class I 3.3E E E E E E E E E-03 Class II SV 056 Fire Water Booster Pump - Steel Mill E E E E E E E E E E E-04 Class I 1.4E E E E E E E E E-03 Class II SV 057 Fire Water Supply Pump - Steel Mill E E E E E E E E E E E E-04 Class I 2.2E E E E E E E E E-03 Class II SV 058 Emergency Power Generator - Steel Mill , E E E E E E E E E E E-03 Class I 7.1E E E E E E E E E-03 Class II (5) Rel. Hght Sigma Y Sigma Z SVCONC E E E E E E E E E E E E-02 SH E E E E E E E E E E E E-03 SH E E E E E E E E E E E E-04 SH E E E E E E E E E E E E-04 MDS E E E E E E E E-03 MDS E E E E E E E E-02 MDS002b E E E E E E E E-02 MDS E E E E E E E E-02 MDS003b E E E E E E E E-02 (1) These sources are all vented out of the concentrator building. See SVCONC in next table. (2) Building Vent, modeled as volume sources. See SV008/SV009 in next table (3) Ore barn vents, modeled as volume sources. See OREBARN in next table (4) Only used for Class II modeling (5) Only used for Class I modeling (6) Emergency Generators and Fire Water Pumps were modeled for Class I based on the worst case scenario of the facility in full operation and these units running (one per area) tests of no more than 30 minutes per day. Modeling files stored at MPCA at: X:\Agency_Files\Outcomes\Risk_Eval_Air_Mod\Air_Modeling

68 Summary of Modeled Volume, Area, and Open Pit Source Parameters Source ID Source Description Source Type Release Height (m) S XINIT (m) S YINIT (m) S ZINIT (m) AREA (m 2 ) Angle (deg) PM 10 (g/s) PM 2.5 (g/s) NO X (g/s) CO (g/s) SO 2 (g/s) Hourly Annual Hourly Annual Hourly Annual Hourly Hourly Annual SV008 Coarse Ore Conveyor Gallery VOLUME E E E E-02 SV009 Fine Ore Conveyor Gallery VOLUME E E E E-02 SVCONC Line 1, 2, and 3 Primary Grinding Mill and Space Heaters (4) VOLUME E E E E E E E E E-04 SH400 Area 400 Space Heaters (16) VOLUME E E E E E E E E E-03 SH200 Area 200 Space Heaters (2) VOLUME E E E E E E E E E-04 SH000 Area 000 Space Heaters(2) VOLUME E E E E E E E E E-04 CONCPILE Concentrate Stockpile VOLUME E E E E-02 CONCWE Concentrate Stockpile Wind Erosions VOLUME E E E E+00 OXPILE Oxides Stockpile VOLUME E E E E-02 OXPILEWE Oxides Stockpile Wind Erosion VOLUME E E E E+00 COBB Cobber Stockpile VOLUME E E E E-02 COBBWE Cobber Stockpile Wind Erosion VOLUME E E E E+00 OREBARN Orebarn Vents (fine and coarse) VOLUME E E E E-02 OBA Overburden Stockpile A VOLUME E E E E-02 OBAWE Overburden Stockpile A Wind Erosion VOLUME E E E E+00 STATE Waste Rock Stockpile State VOLUME E E E E-03 STATEWE Waste Rock Stockpile State Wind Erosion VOLUME E E E E+00 LANGDON Waste Rock Stockpile Langdon VOLUME E E E E-03 LGDNWE Waste Rock Stockpile Langdon Wind Erosion VOLUME E E E E+00 GNIOP Waste Rock Stockpile GNIOP VOLUME E E E E-03 GNIOPWE Waste Rock Stockpile GNIOP Wind Erosion VOLUME E E E E+00 SHARE Waste Rock Stockpile Share VOLUME E E E E-03 SHAREWE Waste Rock Stockpile Share Wind Erosion VOLUME E E E E+00 FS400 Area 400 Lump Lime/Carbon Unloading and conveyor drop VOLUME E E E E-03 FS500 Steel Plant Stockpile VOLUME E E E E-01 FS500WE Steel Plant Stockpile Wind Erosion VOLUME E E E E+00 FS314 Building Vent VOLUME E E E E-02 FS526 Locomotive VOLUME E E E E-02 PR001 Paved Road VOLUME E E E E-02 FS037 CDRI Drop into Line I EAF Feed Collection Chute VOLUME E E E E-02 SRVRD1-97 Service Road VOLUME E E E E-02 COB05-09 Cobber Rejects Haul Road to Cobber Rejects Stockpile VOLUME E E E E-03 OBA P05 OB - Stockpile A VOLUME E E E E-01 WRT P06 Waste - Langdon ex-pit and 107 P07 Ore VOLUME E E E E-02 TAC P07 Ore VOLUME E E E E-02 WGLS P06 Waste - Langdon, GNIOP, Share, and State Piles VOLUME E E E E-02 WST P06 Waste - State ex-pit VOLUME E E E E-02 WRL P06 Waste - Langdon ex-pit VOLUME E E E E-02 WGS P06 Waste - Share and GNIOP ex-pit VOLUME E E E E-02 WRG P06 Waste - GNIOP ex-pit VOLUME E E E E-03 WSH P06 Waste - Share ex-pit VOLUME E E E E-02 PL & TB Tailings Basin Truck Traffic VOLUME E E E E-02 PIT Mining Pit OPEN PIT E E E E E-07 TBNE Tailings Basin Wind Erosion AREA E E E E E+00 TBSW Tailings Basin Wind Erosion AREA E E E E E+00 TBNEDOZE Tailings Basin Dozer Activities AREA E E E E E-07 TBSWDOZE Tailings Basin Dozer Activities AREA E E E E E-07

69 APPENDIX C Greenball/ DRI Lead/Fluoride Concentration Monitoring 95% UCL Facility Name: Essar Steel Minnesota LLC Permit Number: The proposed lead content limit in greenball is 11 mg/kg. For compliance purpose, a sample when found below detection level is to be assigned one half of that detection level reported by the laboratory. An EPA software, ProUCL (Version 3.0), can be run to give a one-tailed 95% upper confidence level for compliance determination. Table 1. A hypothetical set of lead content data from green ball Pb content in GB, mg/kg Box-Whisker Plot Compliance determination Upper confidence level: 9.64 mg/kg Pb in GB, mg/kg The upper confidence level for a one-tailed analysis can also be calculated in Excel as follows: =average(a2:a14)+tinv(0.1,rows(a2:a14)-1)*stdev(a2:a14)/sqrt(rows(a2:a14)) Where cells a2:a14 hold the 13 values shown in Table 1. The Excel formula above carries out the following algebraic expression, which can be found in a statistics textbook: x + t α s n [1], n 1 n 1 Where x is the average; s n-1 is the sample standard deviation; n is the number of observations; t is the value found in Table 2 or directly calculated in Excel for given values of α and n - 1. Table 2. t value Confidence 90% 95% 99% Two tailed, α One tailed, α/ n - 1 =

70 APPENDIX D Visible Emissions Checklist Facility Name: Essar Steel Minnesota LLC Permit Number: Visible Emissions Checklist(s) Requirements Emission Units and Stack/Vents: Visible Emissions Checklist(s): The checklist or checklists must contain the following: 1) Printed name of observer; 2) Signature of observer; 3) Date and time of observation; 4) Indication of process and control equipment performance, either "requires attention", or "does not require attention". This determination is based upon an observed change in visible emission characteristics from that observed when this source and its pollution control equipment are properly operated and maintained. A change in visible emission characteristics will be indicative of "requires attention"; 5) Description of investigation and corrective actions completed for each requires attention observation; 6) Weather conditions (temperature, cloud cover, wind, precipitation); 7) Indication if plume were limited by visible moisture in the plume; 8) Emission unit (EU) and Stack/Vent (SV) ID number(s); and 9) Short description of emission unit.

71 APPENDIX E Test-and-Set Methodology for PM 2.5 Facility Name: Essar Steel Minnesota LLC Permit Number: Table of Contents 1.0 Test-and-Set Nomenclature 1.1 General Information 1.2 Source Groups 1.3 PM 2.5 Test Groups and Individual Stacks 2.0 Test and Set Procedure 2.1 Sampling Events 2.2 Test and Set Statistical Analysis Calculation of 95% UCL Two-Sample t-test Review of Initial Statistical Analysis Threshold for Initial Statistics Statistical Analysis Based on Two-Sampling Events Review Results of Statistical Analysis Based on Three Sampling Events 3.0 Reporting 4.0 Sampling Event Scheduling Figure 1 Test-and-Set Flowchart

72 1.0 Test and Set Nomenclature Acceptable data set For the data collected during the PM 2.5 testing for an emission unit to be included in a statistical analysis to develop a PM 2.5 emission limit, the emission unit must meet the following conditions: The measured PM 10 emissions from the emission unit must be at or below the PM 10 stack limit in the most recent PM 10 performance test conducted pursuant to Minn. R. ch The Permittee must demonstrate that the operation and maintenance requirements imposed by this permit have been applied to the emission units for at least the previous six months. The emission units must be in compliance with the operation and maintenance requirements at the time of testing. Emission Limit The allowable emission rate authorized by a permit or a rule for a pollutant emitted from a process or stack. Event Indicates a set of stack gas sampling test runs associated with a specific stack or specific group of stacks conducted on a particular date. The runs in an event may be data submittal engineering tests as defined in Minn. R , subp. 2a. Fuel Type The indurating furnace is authorized to burn natural gas only. Group For statistical purposes, test data are aggregated by parameters into groups to determine if statistical differences exist. Specific data groups (i.e., parameters) addressed in this appendix are Event and Fuel Type. However, a data group is a general term and could be used to evaluate the effect of other parameters on PM 2.5 emissions. Performance Test As defined in Minn. R , subp. 4. Performance Test Method The process by which a pollutant emitted from a stack is captured and measured is the stack test method. Source Groups A strategy of grouping similar material handling stacks as described in the Taconite MACT (40 CFR Part 63 Subp. RRRRR, GP 008 of the permit) which provides particulate matter emission limits for material handling sources and allowable groupings of similar stacks. A description of the source groupings is given in section 1.2. Test Run As defined in Minn. R , subp. 6. For statistical purposes, each test run is an individual sample data point.

73 1.1 General Information The Permittee shall conduct test-and-set testing in compliance with all applicable provisions of Minn. R. ch The stack test method that will be used in a specific stack test shall be selected in a pretest meeting between the company and the MPCA s stack test coordinator. (Pre-test meeting requirements are described in Minn. R , subp. 4.) Air Emission Permit No contains both an initial PM 2.5 concentration (gr/dscf) limit and an initial PM 2.5 mass emission rate limit (lb/hr) for each emission unit capable of emitting PM 2.5. The test-andset testing will be used to set more refined concentration and mass emission rate limits for each emission unit addressed in this appendix. The statistical analysis of the test-and-set testing will be used to determine a concentration limit as PM 2.5 concentrations are not expected to vary with flow rate. Mass emission rate limits will be determined by multiplying the maximum flow rate times the concentration developed using the test-and-set procedure. Currently, the solid, filterable fraction of PM 10 is typically measured using EPA Method 201A, while the condensable fraction of PM 10 is usually measured using EPA Method 202. Method 201A uses a cyclone to separate particles with a diameter of 10 microns or less from the larger particles. However, when the gas being tested contains entrained water droplets, Method 201A cannot be used. Instead, EPA Method 5 is often used; this method captures all filterable particulates. On March 25, 2009, US EPA proposed a modification to Method 201A to measure filterable PM 2.5. Though this modified method has not been promulgated by EPA, it has been used in Minnesota to measure PM 2.5. It is anticipated that Methods 201A and 202 will be the primary stack test methods used to develop PM 2.5 emission limits using the test-and-set process. However, when the gas being tested contained entrained water droplets, it is likely that EPA Method 5 will be used to measure the filterable portion of the particulate matter. The selection of the test method is subject to review and change. The test methods that will be used in these tests will be set pursuant to Minn. R. ch (See the first bullet in this section.) The Permittee may group test data by event to analyze statistical variability between events. The application for a major permit amendment shall contain proposed PM 2.5 emission limits for all units identified in Table 1, as applicable based on construction process. DRI and Steelmaking units will need to be tested once in operation as specified in the permit. Stack test reports and data analysis reports shall be prepared after each stack test mobilization effort such that multiple testing events conducted during the same mobilization effort (typically 1-2 weeks) would be combined into a single report. The reports shall include data on process operating conditions, CEMS data, ore analysis, and other data to assist in interpretation of the stack test results and statistical calculations as appropriate. The statistical analyses and proposed PM 2.5 emission limits shall be reviewed with MPCA prior to submitting an application for a major permit amendment to incorporate the limits.

74 1.2 Source Groups In Lieu of performing stack tests on all of the material handling sources, the Permittee has elected to define source groups for the stacks listed in GP 008 of this permit, as allowed by 40 CFR (e), each group may contain no more than 6 stacks. A group of material loading sources is also identified for the stacks listed in GP 016. Each source that is part of a group is controlled by a baghouse. The following groups have been identified. Group A/B/C Ore Crushing, Grinding and Handling Crushing, grinding and handling or ore and concentrate will be included in Groups A-C. The material handled by these sources contains a higher amount of fine material. However, there are no expected condensables and the discharge from the control equipment is expected to be primarily PM 2.5. Group D Finished Pellet Handling Finished pellet handling units from pellet reclaim through pellet loading will be included in Group D. The composition of particulate handled in these processes is expected to be fairly similar. No condensables are expected. Group E Material Loading Bins Storage, loading, and unloading for units which store materials used at the facility. 1.3 PM 2.5 Test Groups and Individual Stacks Table 1 PM 2.5 Test-and-Set Stacks/Groups Group ID Description EU IDs SV IDs Group A EU 002, 004, 013, 014, 015, 018, 167 SV 001, 002, 006, 007, 008, 009 Ore Crushing, Grinding, Group B EU 022, 024, 036, 037, 042, 106, 176 SV 010, 011, 016, 017, 022, 084 and Handling Group C EU 170, 171, 172, 173, 174, 175 SV 085, 086, 087, 088, 089, 090 Group D Finished Pellet Handling EU 040, 041, 048, 054, 060, 063 SV 020, 021, 023, 027, 031, 073 Group E Material Loading Bins EU , 044, 045, 052, 053, SV 014, 015, 039, 040, 041, 042, , 177, , 059, 072, 091, 092 Individual Stacks Furnace Hood Exhaust EU 038 SV 018 Furnace Waste Gas EU 039 SV 019 DRI Depressurizing Scrubber EU 064 SV 029 DRI Process Gas Heater EU 066 SV 030 EAF Baghouse EU SV 044 Tunnel Furnace EU 138 SV 051 DRI PTS Depressurizing Scrubber EU 070 SV 063 DRI Screening & Handling EU 088 SV 070

75 2.0 Test-and-Set Procedure Concentration emission limits shall be set for each source group and individual stack identified in Section 1.3. If PM 2.5 concentrations are found to be similar across source groups, the Permittee may propose to combine source groups for the purpose of establishing PM 2.5 concentration limits. Initially, two test events shall be completed for each group/individual stack identified in Table 1. For each group, more than one stack shall be tested for each of the two separate tests. The goal of the testing is to conduct a sufficient number of sample runs to obtain enough samples to capture the variability in emissions associated with properly operated equipment. From these data, an emission limit can be established. Figure 1 is a decision flow chart for determining the number of test events to be conducted for establishing the PM 2.5 emission limits. As shown in Figure 1, Event 1 and Event 2 shall consist of six runs per stack. The six runs shall be conducted during the same stack test mobilization period (i.e. event). Completion of six runs will require a minimum of two days to complete. Additional testing events indicated in Figure 1 shall consist of three runs per event. The outcome of the statistical analysis of the initial stack testing will be a determination of the variability of the test results. If the variability of the data from the initial stack testing meets certain statistical conditions (described below), no further testing is necessary before proposing the PM 2.5 emission limit. Test results with variability above these criteria indicate that more testing is necessary before proposing the PM 2.5 emission limit. Prior to accepting the stack test results as indicative of in-control operations, the performance of the control equipment and other operating metrics shall be verified. For the filterable component of PM 2.5, the PM 10 performance criteria will be used to determine the in-control condition for PM 2.5. Specifically, all manufacturer recommendations for PM 10 control will be verified. For those individual stacks where condensable PM 2.5 emissions are expected to be present, CEMS data shall be used to determine the efficacy of SO 2 control equipment operations at the stack outlets. NO x control shall be optimized through burner technology. 2.1 Sampling Events The Permittee shall conduct a minimum of six runs per event for at least two events for each group/individual stack subject to the test and set requirements, resulting in a minimum of six sample runs. The stack test mobilizations may be different for the different groups. Two stacks from each group shall be tested on different days during the same test event (i.e. within approximately one week). The test events on the furnace stacks (SV 018 and SV 019) shall be conducted simultaneously. Conduct two sampling events (Events 1 and 2). Calculate the 95% UCL (Upper Confidence Limit for the mean) to establish the PM 2.5 concentration limit. Conduct two-sample t-test (see Section 2.2.2) to determine if there are significant differences between events. Determine acceptability of results for setting PM 2.5 emission limits. If the statistical analysis indicates that an additional sampling event is required (see Section ), stacks shall be tested as described in the first two bullets in this section as applicable. This third event only requires three sample runs.

76 2.2 Test-and-Set Statistical Analysis Calculation of 95% UCL t( n 1,1 α ) s UCL = μ + n Where: UCL = Upper Confidence Level for the mean concentration μ = average concentration for n samples α = confidence level (= 0.05 for 95%) n = number of samples (12 for 2 events) s = sample standard deviation t (n-1, 1-α) = t-statistic for given n, α (note: this is a one-tailed t-statistic) = for n = 6, α = 0.05 = for n = 12, α = Two-sample t-test The two-sample t-test shall be used to determine if there is a statistically significant difference in the mean PM 2.5 concentration between stacks within the same group, or between two sampling events. The two-sample t-test is based on the pooled estimate of the standard deviation. The t-statistic shall be calculated and compared to the tabulated t-value for the appropriate significance level and degrees of freedom. If the calculated t-statistic is greater than the tabulated t-value, then it shall be concluded that there is a statistically significant difference between the mean concentrations. Calculation of two-sample t-test: t ( calculated ) X = s p A X B Δ n n A B s p = ( n A 1) s n 2 A A + ( nb 1) s + n 2 B 2 B Where: X A = mean (average) concentration for Event 1 samples X B = mean (average) concentration for Event 2 samples Δ = hypothesized difference between the means = 0 n A = number of samples from Event 1 = 6 n B = number of samples from Event 2 = 6 s p = Pooled Standard Deviation s A = standard deviation of Event 1 samples s B = standard deviation of Event 2 samples If t (calculated) > t ( n A + n B 2,1 α / 2), then the means of the events are significantly different. Where: t = for n A + n B - 2 = 4, α = 0.05 ( n A + n B 2,1 α / 2)

77 2.2.3 Review of Initial Statistical Analysis There are two components to determining if the initial statistical analysis results are acceptable for setting a PM 2.5 emission limit: 1. The PM 2.5 limit should be less than the PM 10 limit, and 2. There should be no statistically significant differences in PM 2.5 concentrations for sources within the same group. If after two sampling events the variability of the test results exceeds the acceptable threshold, one additional sampling event shall be conducted. If, after the third sampling event, the variability of the test exceeds the acceptable threshold, the Permittee shall submit a plan to the MPCA for establishing the PM 2.5 emission limits Threshold for Initial Statistics If 95% UCL < PM 10 limit and the two-sample t-test shows no significant difference between events, the statistical results shall be deemed acceptable for setting a PM 2.5 emission limit. For each group/stack that meets these criteria, the application to the MPCA for a major permit amendment shall include a proposal of a PM 2.5 limit = 95% UCL. If 95% UCL < PM 10 limit and the two-sample t-test exceeds the threshold for a significant difference between events, the Permittee shall conduct a third sampling event Statistical Analysis Based on Two Sampling Events If 95% UCL > PM 10, then conduct a two-sample t-test. If the two-sample t-test shows no significant difference between stacks (or events), the Permittee shall conduct a third sampling event. Following completion of the third event, recalculate 95% UCL (Section 2.2.1), with the following adjustments: n = number of samples for 3 events t (n-1, 1-α) = for n = 9, α = 0.05 = for n = 18, α = 0.05, or adjusted as appropriate Also, conduct two two-sample t-tests. In test one, compare Event 1 (Stack 1 and 2 combined) to Event 2 (Stack 1 and 2 combined). In test two, compare Stack 1 (Event 1 and 2 combined) to Stack 2 (Event 1 and 2 combined). Reevaluate statistics (Section ) Review Results of Statistical Analysis Based on Three Sampling Events The Permittee shall prepare and submit a major amendment application to propose PM 2.5 limits as follows: 1. For each group/stack in which the 95% UCL < PM 10 limit: a. Propose a limit of PM 2.5 = 95% UCL (all tests combined) if the two-sample t-test shows: i. There is no significant differences between events or groups/stacks; or ii. Significant differences exist between events but not between groups/stacks. b. Propose a limit for each group/stack of PM 2.5 = 95% UCL (using only test runs on the group/stack) if the two-sample t-test shows significant differences exist between groups/stacks. 2. For each group/stack in which the 95% UCL > PM 10 limit, determine the average emission rate for each set of three sampling runs (i.e., for each group, average sampling runs 1, 2 & 3; 4, 5 & 6; 7, 8 & 9; etc.). Compare the average emission rate for each three-run set to the PM 10 emission limit. Propose PM 2.5 limits as follows: a. Propose a limit of PM 2.5 = initial PM 10 if the average of each three-run set PM 10 limit; or b. Propose an increased PM 2.5 limit based on the test results if the average of each three-run set > PM 10 limit. The Permittee shall submit all test data collected in the test-and-set testing required in this appendix in the application to the MPCA for a major permit amendment.

78 3.0 Reporting The application for a major permit amendment shall contain an update to the BACT analysis and the proposed PM 2.5 emission limits for all units identified in Table 1, as applicable based on the stage of construction. The amendment will be processed as a PSD permit modification. Stack test reports and data analysis reports shall be prepared after each stack test mobilization effort such that multiple testing events conducted during the same mobilization effort (typically 1-2 weeks) would be combined into a single report. The reports shall include data on process operating conditions to assist in interpretation of the stack test results and statistical calculations. The statistical analyses and proposed PM 2.5 emission limits shall be reviewed with MPCA prior to submitting an application for a major permit amendment to incorporate the limits. 4.0 Sampling Event Scheduling Stack sampling events require time between events to account for seasonality effects. Time is also required to conduct the analytical components of the stack test, conduct the statistical analysis, and prepare the stack test report. In addition, the currently proposed stack test method for PM 2.5 cannot reliably be conducted during very cold weather. Other factors which may influence the timing of stack tests include market forces (i.e., production). In general, the stack testing schedule shall be as follows: If necessary, conduct each additional event (e.g., Event 2 for Groups A, B, C and D) no less than 120 days and no more than 240 days after Event 1. Maintain a similar schedule between stack tests for additional sampling events as necessary. While the test-and-set program is in progress, compliance with the initial PM 2.5 emission limit shall be determined by conducting either a PM 2.5 performance test or a PM 10 performance test to demonstrate compliance with the initial PM 2.5 emission limit.

79 Figure 1 Test-and-Set Flowchart

80 APPENDIX F Calculation Facility Name: Essar Steel Minnesota LLC Permit Number: Converting ppm to lb/hr E i MWi = ci V j V Where: E i = Emission Rate of pollutant i, lb/hr c i = Emission Rate of pollutant i, ppm V j = Gas flow rate in stack j, dsfcm MW i = Molecular weight of pollutant i, g/mol V = g/mol min 3.75x10-6 = combined conversion factor: mg 60 / hr lb MWi ci computed as specified above has units of mg/m 3 V ft m 3

81 APPENDIX G Insignificant Activities Facility Name: Essar Steel Minnesota LLC Permit Number: The table below lists the insignificant activities at the facility and their associated general applicable requirements. Minn. R Description of Activities at the Facility Applicable Requirement subp. 3(C) Fabrication operations: equipment used exclusively for forging, pressing, drawing, spinning, or extruding hot metals. Minn. R subp. 3(E) Storage tanks: (1) Gasoline storage tanks with a combined total tankage capacity of not more than 10,000 gallons; and (2) Nonhazardous air pollutant VOC storage tanks with a combined total tankage capacity of not more than 10,000 gallons of nonhazardous air pollutant VOCs and with a vapor pressure of not more than 1.0 psia at 60 F. subp. 3(H) Miscellaneous: Minn. R (1) Equipment used exclusively for packaging lubricants or greases; (2) Equipment used for hydraulic or hydrostatic testing; (3) Brazing, soldering, or welding equipment; (4) Blueprint copiers and photographic processes; (5) Equipment used exclusively for melting or application of wax; (6) Nonasbestos equipment used exclusively for bonding lining to brake shoes; and (7) Cleaning operations: alkaline/phosphate cleaners, associated cleaners, and associated burners. subp. 3(I) Individual emission units at a stationary source, each of which have a potential to emit the following pollutants in amounts less than: Minn. R Minn. R (1) 4,000 lb/yr of CO; and (2) 2,000 lb/yr each of NO x, SO 2, PM, PM 10, VOCs (including hazardous air pollutant-containing VOCs), and ozone. subp. 3(J) Fugitive dust emissions from unpaved entrance roads and parking lots. subp. 3(K) Infrequent use of spray paint equipment for routine housekeeping or plant upkeep activities not associated with primary production processes at the stationary source, such as spray painting of buildings, machinery, vehicles, and other supporting equipment. subp.4 Individual sources at the facility which has potential emissions below the following: A. 5.7 lb/hr CO B lb/hr PM, PM 10, NO x, SO 2, and VOCs C. 1.0 tpy combined HAPs D. 10,000 tpy CO 2 e Minn. R FS Drilling FS Overburden Loadout FS Overburden Unloading (Truck) FS Waste Rock Loadout FS Waste Rock Unloading (Truck) FS Drop onto Cobber Rejects Pile FS Cobber Rejects Pile Wind Erosion FS Cobber Rejects Pile Loadout FS Cobber Rejects Unloading (Truck) FS Cobber Rejects Stockpile Wind Erosion FS K ton Concentrate Stockpile Loading FS K ton Concentrate Stockpile Wind Erosion FS K ton Concentrate Stockpile Loadout FS DRI Stockpile Stacking Conveyor FS DRI Stockpile Wind Erosion FS Oxide Product Stockpile Stacking Conveyor FS Oxide Fines Bin Discharge FS Oxide Fines Return to Regrind Mill FS DRI Drop into Remet Bunker FS DRI Remet Bunker Wind Erosion FS DRI Remet Return to DRI Reclaim Hooper FS Oversize CDRI Drop Into Bunker FS Oversize CDRI Bunker Wind Erosion FS Oversize CDRI To EAF By Scrap Bucket FS DRI Railcar Loading FS CDRI Drop Into EAF Feed Collection Chute Line 1 FS Lump Lime / Carbon Unloading FS Lime / Carbon Bucket Elevator FS Lime / Carbon Tripper Conveyor Drop FS Slag Dumping FS Digging Pits / Breaking Slag FS Grizzly Stockpile Loading FS Grizzly Stockpile Wind Erosion FS Grizzly Stockpile Loadout FS Grizzly Loading FS Grizzly Oversize to Slag Dumping FS Grizzly / Feeder FS Slag Transfer Conveyor FS Screened Slag Conveyor FS Screened Slag Cobber FS Non-Metallics Stacker 1 FS Non-Metallics Stacker 2 FS Metallics Stacker 1 FS Metallics Stacker 2 FS Crusher FS Crusher By-pass Conveyor FS Crushed Slag Cobber FS Crushed Metallics Stacker FS Crushed Non-Metallics Screen FS Crushed Non-Metallics Stacker 1 FS Crushed Non-Metallics Stacker 2 FS Metallics Return to EAF FS Processed Slag Piles Wind Erosion FS Non-Metallics Slag Stockpile Wind Erosion TK Off-Road Diesel Fuel (900,000 gallons) TK Off-Road Diesel Fuel (900,000 gallons)

82 APPENDIX H Process Flow Diagram Facility Name: Essar Steel Minnesota LLC Permit Number:

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90 TECHNICAL SUPPORT DOCUMENT For AIR EMISSION PERMIT NO This technical support document (TSD) is intended for all parties interested in the 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 , 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 determination to issue the permit. 1. General Information 1.1 Applicant and Stationary Source Location Table 1. Applicant and Source Address Stationary Source/Address Applicant/Address (SIC Code: 3312) Essar Steel Minnesota, LLC Essar Steel Minnesota, LLC 555 W 27 th St County Road 58 Hibbing, MN Nashwauk, Itasca County Contact: Bradley Anderson Phone: Facility Description Essar Steel Minnesota LLC (Essar) is currently in the process of constructing an approximately $1.6 billion mine mouth electric arc furnace steel mill. The Essar project is located in northern Minnesota, on the western end of the Biwabik Iron Formation (the Mesabi Range) near Nashwauk, at the site of the former Butler Taconite Mining Company operations. The project has secured the 1.4 billion (long) ton Mineral Resource of the Butler properties and seeks to capitalize on the unique mineralogical characteristics of the iron ore body by vertically integrating all mining and manufacturing processes to produce a finished steel product on one site. The processes involved will use proven technology and be the only fully integrated steelmaking facility in the United States. Essar will begin operations by mining a new pit, Pit 6, next to Pit 5 where Butler Taconite operations stopped. The mining of Pit 5 will resume after dewatering is completed. The key project features and their nominal capacities are: An open pit taconite mine capable of mining approximately 24,000,000 tonne/yr of ore. A crusher, concentrator with associated tailings basin, producing approximately 7,000,000 tonne/yr of concentrate. A pelletizer that can produce approximately 6,500,000 tonne/year of high flux oxide pellets or 7,000,000 tonne/yr of low flux oxide/ DRI grade pellets. A DRI facility producing approximately 1,800,000 tonne/yr of iron pellets for direct feed for steel production. An Electric Arc Furnace (EAF), ladle metallurgy furnace, slag processing, and a caster to produce 1,500,000 tonne/yr of steel slabs for direct shipment or for onsite rolling to produce hot rolled coil. Essar plans to use natural gas as the process fuel for pelletizing, direct reduction, and steel making. Diesel fuel will be used to operate mining equipment. The project will demand 450 MW of electric power, which will be supplied by Nashwauk Public Utility. Essar plans to use ore concentrating and indurating processes common to existing taconite operations and to employ natural gas based direct iron reduction. The steel mill will use modern electric Technical Support Document, Permit Action Number: Page 1 of 22 Date: 5/10/2012

91 arc furnace (EAF) and metallurgy furnace technology to equip the melt shop. Unlike most other EAF-based steelmaking operations, Essar will use primarily DRI to charge the EAF. Scrap will only be used in the EAF for initial or post-maintenance startup. There will be no scrap charge to the EAFs at Essar other than internally-produced, virgin iron, "home scrap". 1.3 Description of the Activities Allowed by this Permit Action The proposed Essar Steel Minnesota Modifications (ESMM) project would include all activities covered in the MSI project including mining, ore processing, direct reduced iron (DRI) production, and steel-making, but would entail higher taconite pellet production and associated mining and tailings generation rates. The project will increase production of taconite pellets from about 3.8 million (mm) metric ton (tonne) per year of low flux pellets suitable for DRI feed pellet to 7.0 mm tonne/yr of low flux pellets or 6.5 mm tonne/yr of high flux pellets suitable for blast furnace grade pellets or any combination in between. The blast furnace grade or high flux taconite pellets will be shipped to Essar Steel Algoma in Ste. St. Marie, Ontario Canada or sold on the open market. DRI grade or low flux pellets will be used as feed to the DRI process or sold on the open market. The MSI project was permitted for installation of two DRI lines and two steel lines. Essar is proposing at this time to permit one DRI line and one steel line to produce 1.8 mm tonne/yr of DRI and 1.5 mm tonne/yr of steel which is consistent with the Master Development Agreement (MDA) between Essar Steel Minnesota and the State of Minnesota. However, no physical changes to the DRI or steel mill are required to produce at these capacities. The table below is provided to illustrate differences in capacities between the original MSI project and the proposed ESMM project MDA Alternative. Capacity Differences between the Original MSI Project and Proposed ESMM Project MDA Alternative Unit Operation Type of Pellet Original MSI Project Capacity (mm tonne/yr) Proposed ESMM Project MDA Alternative Capacity (mm tonne/yr) Low Flux (DRI feed grade) , 5 Taconite Pelletizing Furnace High Flux (blast furnace grade) , 5 DRI Not applicable Steel Making Pelletizing air emission calculations included a 10% safety factor to account for the level of detailed engineering that existed at the time of permitting. Actual capacity used for air emission calculations was 4.1 mm tonne/yr. 2 For the original MSI FEIS and Air Permit # , the capacity of the DRI modules was described as 2.8 mm tonne/yr. However, the MSI air emissions inventory used a value of 3.5 mm tonne/yr plus a 10% safety factor which equates to 3.85 mm tonne/yr. The MSI permit limits and BACT were based on 3.85 mm tonne/yr. The Essar emission inventory uses the capacity of 1.8 mm tonne/yr and the same hourly production rates as the MSI air emission calculations and limits. 3 Essar will make Low Flux, otherwise known as DRI feed grade pellets for on-site steel making or for sale on the open market. The quantity of this type of pellet to be produced on an annual basis will depend on internal manufacturing needs and on market conditions. 4 Essar will make High Flux, otherwise known as Blast Furnace grade pellets for Essar Steel Algoma or for sale on the open market. The quantity of this type of pellet to be produced on an annual basis will depend on internal manufacturing needs and on market conditions. 5 An air emission inventory was prepared for both types of pellets to be produced. The maximum value from either inventory for a given pollutant was used in air dispersion modeling assessments. 6 There are no physical changes to the DRI proposed and there are no changes to the hourly production rates. 7 There are no physical changes to the steel mill proposed and there are no changes to the hourly production rates. Technical Support Document, Permit Action Number: Page 2 of 22 Date: 5/10/2012

92 The proposed action modifies the indurating furnace where taconite (oxide) pellets are produced. The DRI process is separate from the indurating furnace. The oxide pellets would be transported to an off-site blast furnace or onsite DRI process. In the DRI process the oxide pellets are converted to DRI pellets. There would be no physical change to the DRI process or the steel mill that were previously permitted. With regard to analysis of the DRI process, Essar is not proposing any physical change or change to the hourly capacity of the DRI units as described in the MSI FEIS and Air Permit # Essar began construction on the originally permitted MSI project in October, Construction began with earthwork and rock excavation for all facility building and concrete foundations for primary crushing, mill bay tunnels, slurry tanks and balling discs and filters as well as infrastructure for the project. No construction activities associated with the 4 th secondary crushing unit, 3 rd autogenous grinding mill or the firing zone of the indurating furnace or any emission units that were not previously permitted has begun. The overall project timeline includes the following milestones: Finalize the Supplemental Environmental Impact Statement late 2011 Obtain environmental and mining permit for modification and obtain financial close for equipment required for increase pelletizing capacity 2012 Finish construction through taconite pellet plant and start taconite pellet production 2013 Start construction of one DRI line and steel mill 2013 Start steel production Facility Emissions Table 2. Title I Emissions Increase Summary (tpy) Pollutant Emissions Increase from modified units* Emissions Increase from new units Total Emissions Increase NSR/112(g) Significant Thresholds for major sources NSR/ 112(g) Review Required? (Yes/No) PM Yes PM Yes PM Yes NO x Yes SO Yes CO Yes Ozone (VOC) Yes Lead No Fluorides Yes Sulfuric Acid Mist 7 No (SAM) Hydrogen Sulfide (H 2 S) 10 No CO 2 e* 576,000 75,000 Yes *Modified units are units that have been modified since original permitting, however since they have not yet been constructed, the emissions increase is equal to the controlled PTE of each unit, i.e. no credit is taken for the change from the original unit (either increase or decrease in emissions). **Carbon dioxide equivalents as defined in Minn. R Technical Support Document, Permit Action Number: Page 3 of 22 Date: 5/10/2012

93 Table 3. Total Facility Potential to Emit Summary (tpy) Single PM PM 10 PM 2.5 SO 2 NO x CO VOC Pb F** H 2 S H 2 SO 4 CO 2 e HAP Original Project PTE* 2,667 1,332 N/A 420 1,462 3, N/A 13 Hexane Proposed Project PTE 2,301 1, , ,662,000 *Original PTE corrected based on corrected throughput for DRI facility. **Original PTE based on production of Low Flux pellets only. The Greenball fluoride concentration used to make High Flux pellets has higher fluoride contents. Table 4. Facility Classification 26.1 HF All HAPs Classification Major/Affected Source Synthetic Minor/Area Minor/Area PSD X Part 70 Permit Program X Part 63 NESHAP X 2. Regulatory and/or Statutory Basis New Source Review (NSR) The facility is an existing major source under NSR regulations. The proposed modification is subject to NSR regulations. One part of the NSR Review process is the review of the project s potential for impact on endangered species (a Section 7 review). The U.S. Fish and Wildlife service evaluated the need for this review and determined that it was not necessary. A letter from the U.S. Fish and Wildlife Service addressing the Endangered Species Act (ESA) consultation for the permit is found in Attachment 3. Part 70 Permit Program The facility is a major source under the Part 70 permit program. New Source Performance Standards (NSPS) The following NSPS are applicable to various operations at the facility: 40 CFR pt. 60, subp. LL NSPS for Metallic Mineral Processing Plants 40 CFR pt. 60, subp. AAa NSPS for Steel Plants: Electric Arc Furnaces and Argon-Oxygen Decarburization Vessels Constructed After August 7, CFR pt. 60, subp. Dc NSPS for Small Industrial Commercial Institutional Steam Generating Units 40 CFR pt. 60, subp. IIII NSPS for Stationary Compression Ignition Internal Combustion Engines National Emission Standards for Hazardous Air Pollutants (NESHAP) The facility is a major source of HAPs. The following NESHAPs are applicable to various operations at the facility: 40 CFR pt. 63, subp. B Case-by-Case MACT determinations made under permit action CFR pt. 63, subp. Q NESHAPs for Industrial Process Cooling Towers 40 CFR pt. 63, subp. ZZZZ NESHAPs for Stationary Reciprocating Internal Combustion Engines 40 CFR pt. 63, subp. RRRRR NESHAPs for Taconite Ore Processing Technical Support Document, Permit Action Number: Page 4 of 22 Date: 5/10/2012

94 Compliance Assurance Monitoring (CAM) 40 CFR pt. 64, CAM addresses monitoring for emission sources having major emissions of regulated air pollutants under Title V at major Title V sources. Since the facility is a major source under Part 70, CAM applies at the facility. 40 CFR pt. 64.5(a)&(b) establishes that CAM applies only to Large Pollutant-Specific Emission Units (PSEUs) as part of an application for a significant permit revision under Part 70. A large PSEU is an emission unit that has a PTE greater than the major source threshold after taking into account control equipment. Other PSEUs subject to CAM are required to address CAM at the time of permit renewal. For the proposed modification of the facility, this means that CAM is required under this permit for the indurating furnace. At the time of reissuance, CAM will be addressed for other PSEUs subject to the CAM requirements. Environmental Review The Minnesota Department of Natural Resources (DNR) conducted a Supplement Environmental Impact Statement (SEIS) to evaluate the proposed ESMM project in accordance with EIS preparation requirements of the National Environmental Policy Act (NEPA), 42 U.S.C and the Minnesota Environmental Policy Act (MEPA), Minnesota Statute 116D. The air emission permit for the project could not be issued until the SEIS was deemed adequate. On December 29, 2011, the MNDNR determined that the SEIS was adequate pursuant to MEPA. More information is available at Minnesota State Rules Portions of the facility are subject to the following Minnesota Standards of Performance: Minn. R Standards of Performance for Preventing Particulate Emissions from Becoming Airborne Minn. R Standards of Performance for New Indirect Heating Equipment Minn. R Standards of Performance for Fossil-Fuel-Burning Direct Heating Equipment Minn. R Standards of Performance for Post-1969 Industrial Process Equipment Minn. R Standards of Performance for Stationary Internal Combustion Engines Table 5. Regulatory Overview of Units at the Facility Level* Applicable Regulations Comments Total Facility Title I BACT limits for PM 2.5 The permit contains PM 2.5 Test-and-Set provisions which describe the requirements for the facility to test to determine an updated PM 2.5 emission limit, as well as the requirement to submit a major amendment application to incorporate those limits into the permit. Appendix E contains the full methodology. MN Mercury TMDL The permit contains total facility mercury emission limits, calculation methods, and recordkeeping. It also contains a requirement for the facility to comply with the Implementation Plan for Minnesota s Statewide Mercury Total Maximum Daily Load (TMDL), published October The plan requires the facility to submit a plan by 2016 which will contain a schedule for how the facility, or the taconite sector as a whole, will meet 75% reduction goals from the levels listed in the plan, by CFR pt. 63, subp. A NESHAP general requirements apply to all the emission units and fugitive sources at the facility except for a short list, which is defined in the permit. Technical Support Document, Permit Action Number: Page 5 of 22 Date: 5/10/2012

95 Level* Applicable Regulations Comments GP 001 Title I limits to avoid modeled adverse impacts in Class I areas Mobile sources at the facility were found to affect Class I modeling, and were also based on whether the DRI and Steel Mill had begun operation. The facility has accepted limits on the number of Tier 2 mobile sources at the facility prior to the startup of the DRI and Steel Mill. After startup of the DRI and Steel Mill, the facility has accepted limits to ensure that all mobile sources at the facility will be Tier 4 certified and at the quantities listed in GP 001. GP CFR pt. 63, subp. RRRRR Emission units subject to Taconite MACT. This group contains the general compliance requirements for these units required by this MACT. Emission limits and performance testing for these units are located in GP 008 or GP 018. The requirements specific to bag leak detectors required by this MACT are located in GP 007. GP 003 Title I BACT limits Ore Crushing and Handling emission units subject to BACT limits for Crude Ore Lead and Fluoride Concentration. GP 004 Title I BACT limits Finished Pellet Handling emission units subject to BACT limits for Oxide Pellet Lead and Fluoride Concentration. GP 005 Title I BACT limits Waste Rock Handling fugitive sources subject to BACT limits for Waste Rock Lead and Fluoride Concentration. GP 006 Taconite MACT, Case-by-Case MACT, and NSPS LL for fugitive sources All fugitive sources at the facility are subject to MACT, either via Taconite MACT or Case-by-Case MACT, and subject to the same requirements. Taconite MACT sources are also subject to Metallic Mineral Processing Plants NSPS. This group has requirements for a fugitive emissions control plan and visible emissions (VE) checks for each fugitive source at the facility. Visible emissions checks are a more stringent measure of compliance than one time performance tests, so the list of sources which require a performance test was reduced in lieu of more stringent VE requirements. GP CFR pt. 63, subp. RRRRR Bag Leak Detection requirements for baghouses controlling units subject to Taconite MACT. GP CFR pt. 63, subp. RRRRR Limits and performance testing requirements for units subject to Taconite MACT, except for the indurating furnace. GP 009 Title I BACT limits Case-by-Case MACT Limits, performance testing, VE checks, and CEMS requirements for baghouse stacks on the EAF. 40 CFR pt. 60, subp. LL GP 010 Title I BACT limits Material usage limits, monitoring, and recordkeeping for the EAF. Case-by-Case MACT GP 011 Title I BACT limits Operational requirements and compliance measures for the buildings for the Meltshop. GP 012 Title I BACT limits Operational requirements and compliance measures for the Cooling Towers. 40 CFR pt. 63, subp. Q GP 014 Title I BACT limits Case-by-Case MACT Operating requirements, limits, and compliance measures for Flares required by Case-by-Case MACT determinations. GP 015 Title I BACT limits Operating requirements, limits, and performance testing for the tunnel furnace. Case-by-Case MACT Minn. R GP 016 Title I BACT limits Minn. R Emission limits, material lead and fluoride limits, performance testing and VE checks for the Material Loading Bin Sources. GP 017 Title I BACT limits Case-by-Case MACT Minn. R Emission limits, material lead and fluoride limits, performance testing and VE checks for the DRI Pellet Handling units. Technical Support Document, Permit Action Number: Page 6 of 22 Date: 5/10/2012

96 Level* Applicable Regulations Comments GP 018 Title I BACT limits Operational requirements, limits, performance testing, compliance measures, and 40 CFR pt. 63, subp. RRRRR CEMS requirements for the indurating furnace. This also requires the installation of an activated carbon injection (ACI) system to control mercury emissions, as well as performance testing requirements for mercury to require testing at least 4 times in the first year of operation to verify ACI performance. Requirements were also added to calculate and record CO 2 e emissions from the furnace. GP 019 Case-by-Case MACT 40 CFR pt. 60, subp. Dc Limits, compliance measures and CEMS requirements for Boilers & Heaters subject to Case-by-Case MACT and NSPS. GP 020 Case-by-Case MACT Installation of monitoring devices and compliance measures for Wet Scrubbers as determined by Case-by-Case MACT. GP 021 Title I BACT limits 40 CFR pt. 63, subp. ZZZZ 40 CFR pt. 60, subp. IIII Minn. R CFR pt. 64, CAM Minn. R Title I BACT limits Minn. R Operating requirements, limits, and compliance measures for Emergency Generators and Fire Water Pumps at the facility. GP 022 Operational requirements and testing applying to all CEMS required at the facility. GP 023 Operating requirements and emission limits on emission units in the EAF Ladle/Casting area. Emission limits are complied with by complying with the requirements of GP 009. GP 024 Title I BACT limits Operating requirements, limits, performance testing, and other compliance requirements for the DRI Top Gas Purification system. GP 025 Title I BACT limits Emission limits and performance testing for the DRI water blowdown units. GP 026 Title I BACT limits Minn. R Operating requirements, emission limits, and control equipment requirements for the Ore Barns. EU 165 Title I BACT limits Minn. R Fuel usage and emission limits for the space heaters at the facility. There are 24 space heaters to be located as follows: 2 Mining and Crushing 4 Concentrator 2 Pelletizer 16 DRI and Steel Mill FS 042 Title I BACT limits Limits on the concentration of Fluoride in the slag, sampling methods, and recordkeeping requirements. Appendix A Title I BACT limits Appendix A lists all of the Title I BACT limits at the facility. References throughout Table A of the permit give the citation for the rule for each limit listed. Appendix A provides one location which stores all the BACT limits for all the stacks at the facility. Compliance with the BACT limits in Appendix A will generally demonstrate compliance with other less stringent limits that also apply. No limits in Table A are more stringent than any of the BACT limits. *Where the requirement appears in the permit (e.g., EU, SV, GP, etc.). Technical Support Document, Permit Action Number: Page 7 of 22 Date: 5/10/2012

97 3. Technical Information 3.1 Prevention of Significant Deterioration (PSD) PSD requirements apply to the modifications proposed by the facility. These requirements include the determination of Best Available Control Technology (BACT) for individual units, air quality modeling to demonstrate compliance with National Ambient Air Quality Standards (NAAQS), Minnesota Ambient Air Quality Standards (MAAQS) and Class I and Class II PSD Increments, and demonstrations of protection of Class I Air Quality Related Values (AQRVs), including visibility BACT A BACT analysis must be performed for each unit that is part of the proposed modification, for each pollutant that it emits. The table below summarizes the units evaluated for BACT and the pollutants they emit. A summary of the results of the BACT analysis is included as Attachment 1 to the TSD. Many of the units only have particulate emissions, and the choice for BACT was the highest rated control technology, and therefore a cost analysis was not required. A cost analysis was done for the indurating furnace for some pollutants and demonstrated that further controls would not be cost effective. Table 6. Units Evaluated for BACT Analysis Stack Vent Emission Unit Description Pollutants Emitted SV 018 EU 038 PM, PM Indurating Furnace 10, PM 2.5, Pb, F, CO, SV 019 EU 039 SO 2, NO x, VOC, GHG SV 016 EU 036 Hearth Layer Bin PM, PM 10, PM 2.5, Pb, F SV 017 EU 037 Hearth Layer Feed EU 106 Oxides Pellet Transfer to Hearth Layer Bin SV 020 EU 040 Pellet Discharge SV 021 EU 041 Pellet Screening and Handling SV 022 EU 042 Pellet Screenings to Regrind Conveyors SV 023 EU 048 Oxide Pellet Stockpile Conveyor Gallery SV 084 EU 176 Primary Grinding Mill Line 3 SV 085 EU 170 Grizzly Transfer Tower SV 086 EU 171 Non-Magnetic Cobber Rejects Transfer Tower SV EU Secondary Screening Crusher/Cobber Lines 1-4 SV 091 EU 177 Carbon Bin for Hg Control SV 092 EU 178 Lime Bin for Scrubber FS 017 Dozer Activity at Tailings Basin FS 018 Grading at Tailings Basin FS K ton Concentrate Stockpile Loading FS K ton Concentrate Stockpile Loadout FS 027 Oxide Product Loadout to Railcars Technical Support Document, Permit Action Number: Page 8 of 22 Date: 5/10/2012

98 GHG BACT GHG BACT was required to be analyzed for the Indurating Furnace stacks. Table 1-10 of Attachment 1 gives a summary of the BACT process for GHGs Carbon Capture and Sequestration The March 2011, PSD and Title V Permitting Guidance for Greenhouse Gases document states the following in regards to Carbon Capture and Sequestration (CCS): "... EPA generally considers CCS to be an available add-on pollution control technology for facilities emitting CO 2 in large amounts and industrial facilities with high-purity CO 2 streams...." "... CCS is composed of three main components: CO 2 capture and/or compression, transport, and storage. CCS may be eliminated from a BACT analysis in Step 2 if it can be shown that there are significant differences pertinent to the successful operation for each of these three main components from what has already been applied to a differing source type...." The BACT report addresses the three main components of CCS, as well as the integration of the three main components. Capture and/or Compression The BACT report evaluates several options for collection of CO 2 gas in Sections and The capture options evaluated were Post-Combustion CO 2 capture for normal combustion, Post-Combustion CO 2 capture for combustion using pure Oxygen rather than air, and Pre-Combustion CO 2 capture through gasification and converting the fuel to pure hydrogen prior to combustion. The first option is technically infeasible based on the low concentration of CO 2 in the exhaust stream. The other two options are technically infeasible for the indurating furnace due to the chemistry and thermodynamic properties required. Transport Transportation options for CO 2 vary depending on whether it is in gaseous form or as a solid or liquid. As a solid or liquid, transportation of CO 2 is feasible. CO 2 in a gaseous form is considered technically infeasible due to the location of the nearest storage facility (in central North Dakota) and the significant logistical hurdles to install a pipeline to transport the CO 2, such as the successful receipt of permitting, right-of-way, and other environmental considerations necessary to establish a pipeline to reach a sequestration site. Storage The BACT report evaluates several options for sequestration of CO 2 gas in Sections and The sequestration options evaluated in these sections were Deep Saline Aquifers, Oil/Gas Reserves, and Un-Mineable Coal Seams. There are processes under development to react CO 2 to form a solid by-product, known as CO 2 mineralization, discussed in Sections and of the BACT report. CO 2 mineralization is a kinetically slow process which requires large amounts of energy. Several demonstration projects are either underway or planned for these technologies, but they have not yet been demonstrated at a commercial scale. Integration of CCS Components CCS may also be eliminated in step 2 due to logistical barriers that make the integration of the three components technically infeasible. As noted further in EPA s Guidance... CCS may be eliminated from a BACT analysis in Step 2 if the three components working together are deemed technically infeasible for the proposed source, taking into account the integration of the CCS components with the base facility and site-specific considerations (e.g., space for CO 2 capture equipment at an existing facility, right-of-ways to build a pipeline or access to an existing pipeline, access to suitable geologic reservoirs for sequestration, or other storage options)... EPA recognizes the significant logistical hurdles that the installation and operation of a CCS system presents and that sets it apart from other Technical Support Document, Permit Action Number: Page 9 of 22 Date: 5/10/2012

99 add-on controls that are typically used to reduce emissions of other regulated pollutants and already have an existing reasonably accessible infrastructure in place to address waste disposal and other offsite needs. Logistical hurdles for CCS may include obtaining contracts for offsite land acquisition (including the availability of land), the need for funding (including, for example, government subsidies), timing of available transportation infrastructure, and developing a site for secure long term storage. Not every source has the resources to overcome the offsite logistical barriers necessary to apply CCS technology to its operations, and smaller sources will likely be more constrained in this regard. Based on these considerations, a permitting authority may conclude that CCS is not applicable to a particular source, and consequently not technically feasible, even if the type of equipment needed to accomplish the compression, capture, and storage of GHGs are determined to be generally available from commercial vendors. ( Many of the add-on technologies were eliminated in Step 2 of the BACT analysis as technically infeasible options based on the guidance that the three components of CCS working together were not technically feasible, most notably the logistical hurdles described in the transport section and the difficulties of CO 2 capture described above Energy Efficiency Energy Efficiency measures (Sections and of the BACT report) are being taken by Essar in an effort to minimize GHG emissions by both ensuring high levels of energy and production efficiency for the project. Heat recovery will be utilized in the indurating process in order to minimize fuel usage and separate recuperative heat recovery loops are planned which will maximize heat recovery. The Essar furnace will have up and down draft drying zones which use recuperative heat from the second pellet cooler for pellet drying. Recuperative heat is also used to preheat pellets in the down draft drying and preheat windbox and firing sections of the furnace using heat recovered from the first pellet cooler. A portion of the hot air coming off the first pellet cooler will be used as combustion air in the firing section of the straight grate furnace. Because the combustion air is hot, less fuel is necessary to heat the combustion air and more of the fuel energy can be directed into the production process. As noted in the NO x control analysis in Section 6.3 of the BACT report, the amount of preheated combustion air is limited in order to control NO x emissions in the low NO x LE Burners. Through these energy efficiency measures, the Essar project is expected to achieve thermal consumption levels consistent with a modern well designed energy efficient straight grate furnace Other BACT Considerations Lower Emitting Processes Sections and of the BACT report discuss the use of lower emitting processes which involves the use of different sorbents in the flue gas desulfurization (FGD) units, however none of the different sorbents are more efficient when considering GHG emissions, and therefore the choice of lime is BACT. Good Design Practices / Good Operating Practices Sections and of the BACT report discusses good design/operating practices for the furnace. Good design includes process and mechanical equipment designs which are either inherently lower polluting or are designed to minimize emissions. Good operating practices include operating methods, procedures and selection of raw materials (i.e., additives and control reagents) to minimize emissions. Fuels Section of the BACT report discusses fuels. Natural gas has the lowest GHG emissions of the fossil fuels when the biogenic nature of biomass is not considered, the choice of natural gas is the top choice for BACT. Technical Support Document, Permit Action Number: Page 10 of 22 Date: 5/10/2012

100 3.1.2 NAAQS Under the federal Clean Air Act and the Prevention of Significant Deterioration (PSD) regulation, a Class II area is a geographic area other than national parks, monuments and wilderness areas that are classified as Class I. Most of Minnesota is Class II. To receive a PSD permit in a Class II area, the Permittee must demonstrate that the NAAQS and MAAQS are protected, but somewhat more deterioration of air quality is allowed in a Class II area than a Class I area. A Class II air quality analysis was completed for the project as part of the air permit application. The Class II air quality analysis demonstrated that PM 10, PM 2.5, NO x, SO 2, Pb, and CO emissions would meet the NAAQS and MAAQS. An ozone impacts analysis is also required of any major PSD modification where there is an increase in NO x emissions which exceeds the significance threshold for ozone (40 tpy) because NO x and VOCs are precursors to ozone. A quantitative modeling analysis has not yet been developed to be used for this permit. With consultation with the U.S. EPA, a qualitative analysis was decided to be used. In this analysis, data from the only existing year-round ozone monitoring station in northern Minnesota was used, located at Voyageurs National Park, approximately 80 miles north of Essar. This data shows that the monitoring station has recorded average ozone concentrations at or below 78% of the NAAQS standard during NO x and VOC emissions from Essar account for less than 0.7% of the stationary source emissions, and less than 0.2% of the total emissions in the state. This data indicates there is no reason to expect emissions from the ESMM project would alter the compliance status with respect to the ozone standard. Additional details are included in a technical memorandum included as Attachment 4. Table 7. Maximum Predicted Ambient Air Concentrations Near the Essar Facility Pollutant Averaging Period Modeled Impact* (μg/m 3 ) Background Concentration (μg/m 3 ) Predicted Ambient Air Concentration (μg/m 3 ) MAAQS (μg/m 3 ) NAAQS (μg/m 3 ) PM Hour Annual PM Hour Annual SO 2 1-Hour , Hour Hour Annual NO x 1-Hour Annual CO 1-Hour ,000 40,000 8-Hour ,000 10,000 Lead (Pb)** Quarterly Not Available *For averaging periods shorter than annual, one exceedance is allowed per location per year. Therefore, for the short term averaging periods, the highest concentration per year per location is not considered and the high second high is presented. The highest CO concentrations are given since the concentrations are well below the standards. **Ambient air quality modeling for lead was completed as part of the Screening Level Ecological Risk Assessment (SLERA) Technical Support Document, Permit Action Number: Page 11 of 22 Date: 5/10/2012

101 3.1.3 PSD Increments PSD allows facilities to construct emission units, but restricts the amount of additional pollution an area can receive. It does this by imposing PSD increments, or limits on the concentration of air pollution since a certain date. There are increments that apply in normal (or Class II) areas as well as increments for protected (Class I) areas such as National Parks and Wilderness areas. The allowed increase in a concentration of a pollutant is lower in a Class I area than in a Class II area Class I Increment Analysis An increment analysis is required of any major PSD source for which the modeled Class I area impacts of that Essar s emissions alone are above the Significant Impact Levels (SILs). The SILs are values at or below 5% of the standard and represent a level where further analysis is not required to ensure compliance. Modeling of Essar s facility showed that its impacts are above the SILs for 24-hour PM 10, and 24-hour and annual PM 2.5 (Table 8); therefore an analysis of the cumulative impact from all sources of PM 10 and PM 2.5 (past and present, increases and decreases) on the Class I areas was prepared. The emission inventory for the Essar Steel Increment analysis included modifications to existing sources, new facilities that have been permitted or submitted permit applications prior to Essar Steel and increases in actual emissions from existing facilities. Additional details of each are presented in the permit application and the technical memorandum for PM 2.5 included as Attachment 5. Modeled air concentrations for the Class I PSD increments are presented in Table 8 along with the Class I increment standards. The CALPUFF modeling indicates that the emissions associated with the ESML project will not significantly deteriorate the air quality in the Class I areas. Table 8. Class I Modeling Results Model Run Pollutant Averaging Period Standard (μg/m 3 ) U.S. EPA SIL (μg/m 3 ) Facility Only Modeled Concentration (μg/m 3 ) Total Modeled Concentration (μg/m 3 ) Percent of Standard PSD Increment PM hour % Annual PM hour % Annual % SO 2 3-hour hour Annual NO x Annual Technical Support Document, Permit Action Number: Page 12 of 22 Date: 5/10/2012

102 Class II Increment Analysis The increment standards, which apply to PM 10, PM 2.5, NO x and SO 2, are the maximum increase in air quality concentrations of pollutants that are allowed. Essar examined the impacts of its emission on the PSD Class II Increment Standards for the area within 50 kilometers (31 miles) of the facility. Additional details are presented in the permit application and the technical memorandum for PM 2.5 Increment included as Attachment 6. The proposed project includes both fugitive sources and stacks, as well as nearby large industrial background sources. The modeled fugitive sources include mining activities, dust generation from traffic within the mine and plant site, and a number of smaller stockpiles in the plant areas. The facility stacks include the crushing process stacks through the steel production stacks. Backup generators and stacks used only during plant upset were not included in the modeling. Air pollution control equipment efficiencies and proposed air permit limits are included in the air emission estimates that were used in the modeling. The AERMOD air dispersion model was used to estimate Class II ambient air concentrations. The USEPA recommends AERMOD as a Preferred Model for Class II air quality analyses. Building downwash was predicted for the facility stacks using the BPIP-PRIME downwash model. Both AERMOD and BPIP-PRIME were developed by USEPA. The predicted change in concentrations is presented below in Table 9 along with the Class II increment standards. Table 9. Class II Modeling Results Model Run Pollutant Averaging Period Standard (μg/m 3 ) Facility Only Maximum Modeled Concentration* (μg/m 3 ) Background (μg/m 3 ) Total Modeled Concentration** (μg/m 3 ) Percent of Standard PSD Increment PM hour % Annual % PM hour % Annual % SO 2 3-hour % 24-hour % Annual % NO 2 Annual % NAAQS/MAAQS PM hour % Annual % PM hour % Annual % SO 2 1-hour % 3-hour % 24-hour % Annual % NO 2 1-hour % Annual % CO 1-hour % 8-hour % Lead Quarterly % *For averaging periods shorter than annual, one exceedance is allowed per location per year. Therefore, for the short term averaging periods, the highest concentration per year per location is not considered and the high second high is presented. **Total Modeled Concentration is the sum of the Facility Only Maximum Modeled Concentration and the Background. Technical Support Document, Permit Action Number: Page 13 of 22 Date: 5/10/2012

103 3.1.4 Class I AQRVs Four Class I areas (the Boundary Waters Canoe Area Wilderness (BWCAW), Isle Royale National Park (IRNP), Rainbow Lake Wilderness (RLW), and Voyageurs National Park (VNP)) are located within 300 km of the project. PSD regulations require that these four areas be assessed for potential impacts on Air Quality Related Values (AQRVs) from the project em4issions. These assessments are typically conducted using the CALPUFF modeling system. AQRVs are features or properties of Class I areas that could be adversely affected by air pollution. The Clean Air Act requires that potential AQRV impacts be reviewed for all major sources near Class I areas. A Class I air quality analysis was prepared for the proposed project as part of the PSD air permit application. The Class I modeling demonstrates that the project would not likely have an adverse effect on flora and fauna or terrestrial or aquatic ecosystems. The CALPUFF Modeling System was used to model visual impacts on the Class I areas from the project. The analysis of impacts on the Class I areas, contained in Appendix F of the permit application, indicates that the project may have an adverse impact on visibility. A discussion of the results and potential mitigation measures (if needed) follows Flora and Fauna Table 10 below compares the sum of background SO 2 concentrations plus modeled ambient air SO 2 concentrations resulting from the project emissions at the four Class I areas. In evaluating potential adverse effects to flora and fauna, lichen species are generally used as a threshold indicator of potential air pollution damage because they are especially susceptible to air pollution and show adverse effects before other plant species and animal species. If pollutant concentrations are sufficiently low that no damage occurs to native lichens, then it can reasonably be concluded that all other flora and fauna species are protected. The most sensitive lichen species are only present when annual average SO 2 concentrations are less than 40 μg/m3. As can be seen in Table 10, all estimated SO 2 ambient air concentrations are lower than 40 μg/m3. The Federal Land Managers have set a screening level concentration referred to as the Green Line Concentration. All modeled concentrations are also below the Green Line Concentration of 5 μg/m3, indicating that there should be no adverse effects from the project emissions on flora or fauna in the Class I areas. Table 10. Class I Screening Analysis for Effects on Flora and Fauna From SO 2 Total Annual Average Ambient Air Concentrations Final Proposed Project Location Background Air Concentration 1 (μg/m 3 ) Modeled Project Contribution 2 (μg/m 3 ) Total Projected Air Concentration (μg/m 3 ) Green Line Concentration 3 (μg/m 3 ) BWCAW Isle Royale National Park Rainbow Lake Wilderness Voyageurs National Park Mean annual SO 2 concentrations (ug/m 3 ) 2 Modeled ambient air concentration in Class 1 area using the CALPUFF modeling system. 3 Green line concentration from Adams et al., Screening Procedures to Evaluate Effects of Air Pollution on Eastern Wildernesses Cited as Class I Air Quality Areas, USDA, Forest Service, Northeast Forest Experiment Station, Generator Technical Report NE-151, September Technical Support Document, Permit Action Number: Page 14 of 22 Date: 5/10/2012

104 Acid Deposition Adverse effects to terrestrial and aquatic ecosystems are evaluated slightly differently by the National Park Service and the US Forest Service. The acid deposition impact analysis for the BWCAW and Rainbow Lake Wilderness area considers the total concentration or deposition including background. The acid deposition impact on terrestrial and aquatic ecosystems is judged to be acceptable if ambient air concentrations and/or deposition is below the respective green line. For Voyageurs National Park and Isle Royale National Park, the Deposition Analysis Thresholds (DATs) were calculated for total sulfur and total nitrogen. DATs have been developed by the National Park Service and US Fish and Wildlife Service (USFWS) to evaluate the contribution of additional nitrogen (N) or sulfur (S) to deposition within Class I areas. The DATs are intended to distinguish where deposition increases may result in potentially adverse ecosystem stresses, as well as where the deposition increases are like to have a negligible impact on AQRVs. Project-related deposition was estimated using the CALPUFF modeling system and results are presented in Table 11. SO 2 and NO x emissions from the project are not expected to have an adverse effect on terrestrial or aquatic ecosystems in the Class I areas. Table 11. Class I Area Screening Analysis Results For Potential Terrestrial Impacts Final Proposed Project Location 2 Pollutant Background Data 1 Model Air Concentration or Calculated Project- Related Deposition 3 Total Concentration or Deposition Green Line Value or Deposition Analysis Threshold 4 BWCAW - Ely Annual Ave SO 2 (μg/m 3 ) μg/m 3 3-hour max SO 2 (μg/m 3 ) μg/m 3 Total Sulfur (kg/ha/yr) kg/ha/yr S Total Nitrogen (kg/ha/yr) kg/ha/yr N Isle Royale National Park Rainbow Lake Wilderness Voyageurs National Park Annual Ave SO 2 (μg/m 3 ) μg/m 3 3-hour max SO 2 (μg/m 3 ) μg/m 3 Total Sulfur (kg/ha/yr) NA 0.01 kg/ha/yr S Total Nitrogen (kg/ha/yr) NA 0.01kg/ha/yr N Annual Ave SO 2 (μg/m 3 ) μg/m 3 3-hour max SO 2 (μg/m 3 ) μg/m 3 Total Sulfur (kg/ha/yr) kg/ha/yr S Total Nitrogen (kg/ha/yr) kg/ha/yr N Annual Ave SO 2 (μg/m 3 ) μg/m 3 3-hour max SO 2 (μg/m 3 ) μg/m 3 Total Sulfur (kg/ha/yr) NA 0.01 kg/ha/yr S Total Nitrogen (kg/ha/yr) NA 0.01 kg/ha/yr N 1 Mean annual SO 2 concentrations (ug/m 3 ) 2 Modeled air concentration in each Class I area. 3 Model estimated ambient air concentrations using the CALPUFF modeling system. 4 Green line concentration. DAT is based on National Park Service Guidance for the Eastern U.S. 5 Majority of total concentration or deposition is due to background. The modeled air concentration contributes little to the total concentration. 6 The concentration from the proposed project scenario is less than the DAT. Technical Support Document, Permit Action Number: Page 15 of 22 Date: 5/10/2012

105 Visibility The potential visibility impacts associated with the proposed Essar Steel project were evaluated based on currently accepted guidance from the Federal Land Managers (FLMs). The guidance is known as FLAG (Federal Land Managers Air Quality Related Values Workgroup). Previous visibility impact modeling used FLAG 2000 guidance which uses the CALPUFF/CALPOST model with CALPOST Method 2 processing. FLAG 2010 uses CALPOST Method 8 processing. Results from both FLAG 2000 and FLAG 2010 are given in the table below. Potential changes in the visibility were expressed in terms of an extinction coefficient (b ext ). Three Class I areas were included in the visibility analysis for the project: the BWCAW (located 80 km from Essar s facility), Voyageurs National Park (100 km), and Isle Royale National Park (280 km). The BWCAW falls under the jurisdiction of the U.S. Department of Agriculture (U.S. Forest Service) whereas the national parks fall under the jurisdiction of the U.S. Department of the Interior (National Park Service and U.S. Fish and Wildlife Service). Visibility has not been established as an AQRV for the Rainbow Lakes Wilderness, so visibility impacts were not modeled for that area. Table 12. Class I Visibility Modeling Results For the Project Compared to Natural Background (NH 3 1 ppb) Location Parameter FLAG 2000 FLAG 2010 BWCAW Maximum Δb ext (%) Days with Δb ext 5% Days with Δb ext 10% Isle Royale Maximum Δb ext (%) Days with Δb ext 5% 0 0 Days with Δb ext 10% 0 0 Voyageurs Maximum Δb ext (%) Days with Δb ext 5% Days with Δb ext 10% *Maximum changes in the daily extinction coefficients compared to natural background and the number of days per year for the three years modeled (i.e., 2002, 2003 and 2004) in which the increase in the daily extinction coefficient exceed 5 and 10 percent due to Essar Steel emissions Mercury Total facility Mercury emissions from the original Minnesota Steel project were listed at 77 lb/yr in the Implementation Plan for Minnesota s Statewide Mercury Total Maximum Daily Load (TMDL) October The ESML project proposes installation of an activated carbon injection system on the waste gas stack (SV 019) of the indurating furnace to control Mercury emissions so that the entire facility emits less than 77 lb/yr. The permit requires performance testing for mercury from the furnace stacks quarterly for the first year, and annually, at a minimum, for subsequent years. The Mercury TMDL requires that the Taconite industry achieves a 75% reduction in Mercury emissions from the levels presented in the Plan by the year The Taconite industry is also required to submit a plan, due in the year 2016, which details how the sector will attain the 75% reduction goal. Further technology advancement will occur by then which will help in determining the technologies that will be required in order to meet the goals. Technical Support Document, Permit Action Number: Page 16 of 22 Date: 5/10/2012

106 3.1.6 Additional Impacts Analysis The additional impacts analysis submitted by the applicant considers the effect of project-related air emission on visibility, soils, and vegetation. It also addresses air quality impacts from regional growth related to the project. The assessment for Class II visibility focused on a number of Essar Steel stacks that are likely to have a water vapor plume due to their high moisture content. While such a plume dissipates fairly quickly, the plume would be visible to an observer looking toward the Essar Steel facility from Hill Annex State Park when the wind is D stability class and the wind speed is roughly 10 miles per hour (4.6 m/s) or less. An observer at McCarthy Beach State Park could see a plume from Essar Steel only when the wind is F stability class and the wind speed is less than about 2.5 miles per hour (1 m/s). Because northeastern Minnesota is generally heavily forested and lakes are surrounded by trees, the potential for seeing the plume from McCarthy Beach State Park is low under typical meteorological conditions. The analysis of the project s impact on soils found them to be far below the state acid deposition standard. The project s damage to vegetation was determined to be small, due in part to the control of SO 2 emissions with scrubbers and control of fugitive dust with a fugitive dust control plan. Construction employment at the Essar Steel site is expected to peak at about 2000 persons. After startup, about 700 people are expected to be employed at the site. This is roughly double the number employed at Butler Taconite. Because, however, the infrastructure of the Iron Range is generally capable of handling many more people than currently reside there, it is expected that the growth from this project will not have significant impacts beyond those experienced previously. 3.2 Case-by-Case Maximum Achievable Control Technology (MACT) There are two units proposed as part of the modification for which a MACT standard has not been promulgated. These are EU 177 and 178, the carbon bin and lime bin respectively. These store the materials used in the proposed Activated Carbon Injection and GSA Dry Scrubber controls on the furnace. These units have been determined to meet the same MACT standards as the other material loading bin sources at the facility. 3.3 Calculations of Potential to Emit (PTE) PTE calculations are summarized in Table 3. Detailed calculation spreadsheets are available electronically, however they are too large to be included with the TSD. The calculation spreadsheets show PTE calculations for both Low Flux and High Flux acid pellet production scenarios. The total facility PTE is based on the highest pollutant specific PTE between the scenarios. Production of High Flux pellets requires a different chemical composition of the greenballs as they enter into the furnace. Data from Hibbing Taconite Co was used to determine an emission factor for Fluorides emitted from a taconite furnace producing high flux pellets. 3.4 Periodic Monitoring and CAM 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. The Permittee submitted a CAM proposal as required by 40 CFR It can be found in Attachment 2 to this TSD. 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; Technical Support Document, Permit Action Number: Page 17 of 22 Date: 5/10/2012

107 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. The table below summarizes the periodic monitoring requirements for those emission units for which the monitoring required by the applicable requirement is nonexistent or inadequate or where CAM applies. Table 13. Periodic Monitoring Level* Requirement Additional Monitoring Discussion TF Hg 77 lb/yr on a 12- month rolling sum basis Monthly calculation and recordkeeping Limits to define a Total Facility Mercury Emission Limit and to show no net increase in potential emissions as compared to the value listed in the Mercury TMDL. GP 001 GP 002 GP 003 GP 004 GP 005 Material Pb and F concentrations Tier 2 and Tier 4 mobile sources General Conditions of Taconite MACT Material Pb and F concentrations Sampling and calculations Recordkeeping O&M Plan N/A Testing and Recordkeeping GP 006 Opacity < 5% Visible Emission (VE) Checks and Method 9 performance tests. GP 007 Baghouse requirements from Taconite MACT Monitoring Monthly calculations and recordkeeping of mercury emissions are required to document compliance with this limit. Sampling methodology and calculation methods for lead and fluoride concentration of materials to comply with limits listed throughout Table A. Calculation methods for determining 95% Upper Confidence Levels (UCL) of feed material are listed. Frequency of ongoing sampling is based on 95% UCL. The facility will be phasing in Tier 4 mobile sources as they become available from the manufacturers. Initial mobile sources are required to be certified at Tier 2 or higher. The entire fleet of mobile sources is required to be certified Tier 4 compliant upon startup of the DRI and Steel Mill. Records will be kept to document fuel use, sulfur content of fuel, proper operation, and purchasing and maintenance of the sources. In addition, an O&M plan is required to be submitted and approved and include tracking information for urea use. Monitoring, recordkeeping and reporting requirements as required by Taconite MACT and NSPS LL. Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit. Daily VE Checks are required on all fugitive sources at the facility with associated corrective actions and recordkeeping. In addition, method 9 testing is used to document initial compliance for those sources that are subject to the NSPS and not insignificant activities. Daily VE checks have been deemed to be more stringent than method 9 testing and sufficient to satisfy the requirements of the NSPS for the insignificant activities. Bag Leak Detection requirements for baghouse subject to Taconite MACT. Technical Support Document, Permit Action Number: Page 18 of 22 Date: 5/10/2012

108 Level* Requirement Additional Monitoring Discussion GP 008 PM, PM 10, PM 2.5, Pb, F, and Opacity limits for each stack. Material Pb and F concentrations Performance testing Recordkeeping The stacks in this group have been sorted into source groups for the purposes of testing as allowed by Taconite MACT. In addition, PM 2.5 tests require 2 stacks from each group in order to comply with the Test-and- Set methods listed in Appendix E. GP 009 PM, PM 10, PM 2.5, Pb, F, SO 2, SAM, NO x, CO, VOC, and Opacity limits for each stack. Pb and F material concentration limits GP 010 Fluorspar usage, sulfur content of carbon additive limit, and Pb and F material concentration limits Performance testing Recordkeeping Monitoring and Recordkeeping GP 011 Negative pressure building Monitoring and Performance testing GP 012 Drift rate and opacity Monitoring, Reporting and Performance testing GP 014 CO and opacity limits Monitoring, recordkeeping, operational requirements and VE checks GP 015 PM, PM 10, PM 2.5, SO 2, NO x, CO, VOC, and Opacity limits GP 016 PM, PM 10, PM 2.5, Pb, F, and Opacity limits and Pb material concentration limits GP 017 PM, PM 10, PM 2.5, Pb, F, and Opacity limits and Pb and F material concentration limits Performance testing Recordkeeping, Performance testing, VE Checks Recordkeeping, Performance testing, VE Checks Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit. Initial Performance tests and recurring performance tests and CEMS for SO 2, NO x, CO, and O 2 from SV 044. SV 047 is only a PM source and compliance is demonstrated through daily VE checks. Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit. Monthly monitoring and recordkeeping of sulfur content of the carbon additives. Recordkeeping of Fluorspar use required for each use. Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit. Continuous monitoring and annual performance testing to verify a negative pressure in the buildings. Continuous monitoring of liquid flowrate, and monthly monitoring of total dissolved solids Initial and recurring performance testing for opacity. Annual notice of compliance as required by MACT Q. Continuous monitoring of flame presence. Operational requirements to ensure proper operation of the flares and compliance with the CO limits. Daily VE Checks for opacity. Initial and recurring performance tests to document compliance with each limit. Yearly performance testing on one stack in the group. Annual test to cycle through each stack. Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit Initial and recurring performance testing to document compliance with emission units for each stack. Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit Technical Support Document, Permit Action Number: Page 19 of 22 Date: 5/10/2012

109 Level* Requirement Additional Monitoring Discussion GP 018 PM, PM 10, PM 2.5, Pb, F, Operating requirements, SO 2, SAM, NO x, CO, VOC, performance testing, CO 2 e and Opacity limits. Pb and F material monitoring, recordkeeping, reporting concentration limits GP 019 PM, PM 10, PM 2.5, Pb, F, SO 2, NO x, CO, and Opacity limits. Pb and F material concentration limits GP 020 GP 021 Wet Scrubber requirements from Case-by-Case MACT Fuel use, sulfur content of fuel, hours of operation CAM Operating requirements, monitoring, performance testing, recordkeeping Monitoring Monitoring and recordkeeping GP 022 CEMS Requirements Monitoring and recordkeeping GP 023 GP 024 PM and opacity (Minn. R ) H 2 S Limits DMDS injection rate Operating requirements Monitoring and performance testing CEMS are required to show compliance with the NO x, SO 2, and CO limits. Initial and recurring performance tests are required to show compliance with PM, PM 10, PM 2.5, Pb, F, VOCs, and opacity. Performance testing for mercury emissions will occur 4 times in the first year of operation and at least annually in subsequent years. Natural gas usage will be measured and vendor information will be used to calculate and record CO 2 emissions on a monthly basis. The required CAM plan is included as Attachment 2. Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit CEMS are required on the Process Gas Heater to document compliance with NO x and CO limits. Performance tests are required to document compliance with all other limits. Monthly recordkeeping of material lead and fluoride concentration as determined using the methods provided on page A-5 of the permit Monitoring devices to measure pressure drop and liquid flow rates in the scrubbers. Operational requirements and recordkeeping for each scrubber. Each engine requires a non-resettable hour meter to track operating hours. Recordkeeping is required to document sulfur content of fuel and operating hours. Monitoring and recordkeeping requirements that apply to all CEMS to be installed. This includes all required certification testing. Requires the installation of Low NO x burners in the Ladle/Tundish Pre-heaters. Compliance with emission limits will be demonstrated through compliance with the limits in GP 009. Initial and recurring performance tests to document compliance with H 2 S emissions. Monitoring and recordkeeping to document compliance with the DMDS injection rate. GP 025 CO Limits Performance testing Initial and recurring performance tests to document compliance with CO emissions. GP 026 PM and opacity (Minn. R ) Monitoring and recordkeeping *Where the requirement appears in the permit (e.g., EU, SV, GP, etc.). Monitoring and recordkeeping to document operation of the buildings at a negative gauge pressure. This will ensure compliance with the emission limits. Technical Support Document, Permit Action Number: Page 20 of 22 Date: 5/10/2012

110 3.5 Insignificant Activities Essar has several operations which are classified as insignificant activities under the MPCA s permitting rules. These are listed in Appendix G to the permit. 3.6 Permit Organization In general, the permit meets the MPCA Delta Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Delta guidance is in the use of appendices. Appendix A of the permit was created as a central location to store all of the most stringent BACT emission limits. This method provides one simple table which contains all the limits. This allows for great confidence in the accuracy of the limits, and will allow for simplified use of the permit. Requirements to comply with Appendix A are listed throughout the permit along with the rule basis for each limit. All other requirements are listed in Table A and B of the permit for tracking purposes (e.g. performance tests, recordkeeping, submittals, etc.) 3.7 Comments Received Public Notice Period: January 23, 2012 February 22, 2012 EPA Construction Permit Review Period: January 23, 2012 February 22, 2012 The MPCA received 6 comments during the public notice period. Attachment 8 of the TSD contains the comments received and the response to comments. The regulations provide EPA opportunities to comment on both the construction and operating provisions of the permit. EPA s review of the construction provisions coincided with the Public Notice Period. The 45-day review period (also known as EPA s operating permit review period ) was originally scheduled to run for 45 days beginning January 23, The EPA 45-day review period was restarted because there were comments on the permit. EAB Appeal Period: April 6, 2012 May 9, 2012 EPA Operating Permit Review Period: April 6, 2012 May 9, 2012 EPA notified the MPCA that the response to Comment 6-6 needed to be adjusted to include NO x SSM limits. These SSM limits are found for stacks in GP 009 and 019 only. As a result, NO x modeling was updated to include NO x SSM rates for the 1-hour NO 2 NAAQS. The updated rates and modeling results are included in Attachment 7 of the TSD. There was no change to the maximum modeled concentrations as a result of this update. In addition, the permit limits for NO x SSM rates were updated to a 1-hour averaging time to match the modeled rates, and the normal NO x emission limits averaging times were changed back to what was listed in the draft permit because these limits were not relied on for modeling compliance with the 1-hour standard. The normal NO x emission limits were used for modeling compliance with the annual standard, and therefore the original averaging times are appropriate. EPA notified the MPCA in an on May 9, 2012 that all of their comments had been addressed appropriately and that they would have no further comments, thereby ending their 45 day review period on that day, May 9 th, Permit Fee Assessment Attachment 9 to this TSD refers to the worksheet which contains the MPCA s assessment of Application and Additional Points used to determine the permit application fee for this permit action as required by Minn. R The permit action includes one permit application, which includes the incorporation of new units into NESHAP RRRRR and NSPS LL, air dispersion modeling, as well as BACT analysis for 10 pollutants (PM, PM 10, PM 2.5, Pb, F, SO 2, NO x, CO, VOC, and GHG). This equates to an additional 185 points to be added to the permit application. These fees were paid on May 4, Technical Support Document, Permit Action Number: Page 21 of 22 Date: 5/10/2012

111 5. Conclusion Based on the information provided by Essar, the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff Members on Permit Team: Trevor Shearen (permit writer/engineer) Steve Palzkill (enforcement) Andrew Place (stack testing) Dave Beil (peer reviewer) AQ File No. 3784B; DQ 2789 (pre-application), 3704 (application received 10/14/2011) Attachments: 1. BACT Summary 2. CAM Plan 3. ESA Determination 4. Ozone Impact Analysis Technical Memorandum 5. PM 2.5 Class I Increment Technical Memorandum 6. PM 2.5 Class II Increment Technical Memorandum 7. NO x Class II Modeling Technical Memorandum 8. Comments Received 8.1. Comments Received 8.2. Response to Comments 9. Points Calculator 10. Facility Description (in Delta) 11. Emissions Calculation Spreadsheets (Electronic only) Technical Support Document, Permit Action Number: Page 22 of 22 Date: 5/10/2012

112 Attachment 1 BACT Summary The proposed modification is a major modification for PM, PM 10, PM 2.5, SO 2, NO x, CO, VOC, F, Pb, and GHG. Any new major stationary source or major modification subject to a Prevention of Significant Deterioration (PSD) review must conduct an analysis to ensure the application of the Best Available Control Technology (BACT). The results of the BACT analysis for the proposed modifications project at Essar Steel Minnesota LLC form the basis for the selection of control technology and the resulting emission limitations at each emissions unit. The BACT analysis in this report followed EPA s five step top down approach: Step 1 Identify All Control Technologies Step 2 Eliminate Technically Infeasible Options Step 3 Rank Remaining Control Technologies by Control Effectiveness Step 4 Evaluate Most Effective Control Technologies and Document Results Step 5 Select BACT A summary of each of these steps for each pollutant is provided in Tables 1-1 through Tables 1-12 and 1-13 presents a summary of the BACT emission limits and control technologies.

113 Identify All Technologies Fabric Filter (Baghouse) Table 1-1: Taconite Pellet Indurating Furnace: Hood Exhaust & Waste Gas Stack; PM/PM 10 /PM 2.5 Step 1 Step 2 Step 3 Step 4 Step 5 Eliminate Technically Rank Remaining Infeasible Options Technologies Evaluate Most Effective Technologies Select and Document Results BACT Clean Fuels (Natural Gas) Good Design and Operating Practices Dry Electrostatic Precipitator (Dry ESP) Wet Electrostatic Precipitator (Wet ESP) Feasible? Basis for Determination of Infeasibility Rank Yes 1 Yes 5 Yes 5 Yes 2 Yes 2 Wet Scrubber Yes 2 Centrifugal Separation (e.g. Cyclones) Inertial Separators (Drop Out Box) Yes 3 Yes 4 Basis Outlet Conc. (gr/dscf) PM More effective at capturing fine particulate matter. PM 10 Uses less electricity No wastewater generated. PM 2.5 Inherent to Design Inherent to Design PM PM 10 PM PM PM 10 PM PM PM 10 PM PM PM 10 PM PM 0.20 PM 10 PM Project is designed and permitted to only use natural gas which produces the least amount of PM/PM 10 /PM 2.5. X X X

114 Identify All Technologies Table 1-2: Taconite Pellet Indurating Furnace: Waste Gas Stack; SO 2 Step 1 Step 2 Step 3 Step 4 Step 5 Eliminate Technically Rank Remaining Infeasible Options Technologies Evaluate Most Effective Technologies Select and Document Results BACT Gas Suspension Absorber (GSA) Clean Fuels (Natural Gas) Good Design and Operating Practices Spray Dryer Absorption Absorber (Single High Pressure Wet Scrubber) Absorber (Low Pressure Wet Scrubber) + Wet Electrostatic Precipitator Dry Sorbent Injection Feasible? Basis for Determination of Infeasibility Rank Yes 1 5 ppm Yes 4 Yes 4 Basis Outlet Conc. Inherent to Design Inherent to Design Yes 1 5 ppm Yes 1 5 ppm Yes 2 5 ppm Yes 3 10 ppm No wastewater generated. Uses 50% less water than a wet scrubber. Compatible with activated carbon injection for mercury control. Project is designed and permitted to only use natural gas which produces the least amount of SO 2. No wastewater generated. Uses 50% less water than a wet scrubber. Compatible with activated carbon injection for mercury control. Generates wastewater that requires treatment. Additional processing equipment is needed to convert the sulfates generated by absorption to a solid waste (gypsum). Absorption produces a visible plume due to the water condensation in absorber exhaust plume. X X X

115 Identify All Technologies Table 1-3: Taconite Pellet Indurating Furnace: Hood Exhaust; SO 2 Step 1 Step 2 Step 3 Step 4 Step 5 Eliminate Technically Rank Remaining Infeasible Options Technologies Evaluate Most Effective Technologies Select and Document Results BACT Clean Fuels (Natural Gas) Good Design and Operating Practices Gas Suspension Absorber (GSA) Spray Dryer Absorption Absorber (Single High Pressure Wet Scrubber) Absorber (Low Pressure Wet Scrubber) + Wet Electrostatic Precipitator Dry Sorbent Injection Feasible? Basis for Determination of Infeasibility Rank Yes 3 Yes 3 Basis Outlet Conc. Inherent to Design Inherent to Design Yes 1 5 ppm Yes 1 5 ppm Yes 1 5 ppm Yes 2 5 ppm Yes 2 6 ppm Project is designed and permitted to only use natural gas which produces the least amount of SO 2. Not cost effective at $134,000/ton of SO 2 removed. Not cost effective at $139,000/ton of SO 2 removed. Not cost effective at $97,000/ton of SO 2 removed. Not cost effective at $429,000/ton of SO 2 removed. Not cost effective at $207,000/ton of SO 2 removed. X X

116 Identify All Technologies Table 1-4: Taconite Pellet Indurating Furnace: Waste Gas Stack; NO x Step 1 Step 2 Step 3 Step 4 Step 5 Eliminate Technically Rank Remaining Infeasible Options Technologies Evaluate Most Effective Technologies Select and Document Results BACT New Natural Gas Combustion Chamber and LE Burners Good Design and Operating Practices Selective Catalytic Reduction (SCR) + Reheat Regenerative Selective Catalytic Reduction (RSCR) + Reheat Low Temperature Oxidation (LoTOx) Non Selective Catalytic Reduction (NSCR) Selective Non- Catalytic Reduction (SNCR) + Reheat Low NO x /Ultra Low NO x Burners Induced Flue Gas Recirculation External Flue Gas Recirculation Low Excess Air (LEA) Clean Fuels (Solid Fuels) Feasible? Basis for Determination of Infeasibility Rank Basis Outlet Conc. Yes 4 28 ppm X Yes 5 Inherent to Design Not cost effective at $40,000/ton of NO x removed. Technology transfer would require pilot testing before Yes 1 4 ppm implementation. An additional 1,200 MMcf/yr of natural gas would be required which would result in an additional 72,400 tpy of GHG emissions. Not cost effective at $22,000/ton of NO x removed. Technology transfer would require pilot testing before Yes 2 6 ppm implementation. An additional 30.1 MMcf/yr of natural gas would be required which would result in an additional 1,800 tpy of GHG emissions. Not cost effective at $86,000/ton of NO x removed. Yes ppm Technology transfer would require pilot testing before implementation. Generates wastewater which requires treatment. Sulfur content of waste gas stream is too high for NSCR. The NSCR catalyst is very sensitive to No poisoning by sulfur compounds. Applications to date limited primarily to natural gas fired combustion turbines. No location in the flue gas circuit where the temperatures are suitable. No Conc. in waste gas (37 ppm) is lower than SNCR floor of 100 ppm. 2-3 times more gas than SCR + reheat would be needed to reach SNCR operating temperatures. Without special combustion chamber design oxygen concentrations at burner are 15-20% No oxygen. This is too high for a low NO x burner to operate properly. Combustion air is very hot (1,500-1,600 F). This further degrades burner performance. No Not compatible with pellet furnace oxygen requirements. No No No Not compatible with pellet furnace oxygen requirements. Not compatible with pellet furnace oxygen requirements. Furnace is not designed to use solid fuel. Solid fuels have lower NO x emissions but higher emissions of all other pollutants. X

117 Identify All Technologies Table 1-5: Taconite Pellet Indurating Furnace: Hood Exhaust; NO x Step 1 Step 2 Step 3 Step 4 Step 5 Eliminate Technically Rank Remaining Infeasible Options Technologies Evaluate Most Effective Technologies Select and Document Results BACT New Natural Gas Combustion Chamber and LE Burners Good Design and Operating Practices Selective Catalytic Reduction (SCR) + Reheat Regenerative Selective Catalytic Reduction (RSCR) + Reheat Non Selective Catalytic Reduction (NSCR) Selective Non- Catalytic Reduction (SNCR) + Reheat Low NO x /Ultra Low NO x Burners Low Temperature Oxidation (LoTOx) Induced Flue Gas Recirculation External Flue Gas Recirculation Low Excess Air (LEA) Clean Fuels (Solid Fuels) Feasible? Basis for Determination of Infeasibility Rank Basis Outlet Conc. Yes 2 7 ppm X Yes 3 Inherent to Design Not cost effective at $140,000/ton of NO x removed. Technology transfer would require pilot testing before Yes ppm implementation. An additional 1,300 MMcf/yr of natural gas would be required which would result in an additional 77,300 tpy of GHG emissions. Not cost effective at $85,000/ton of NO x removed. Technology transfer would require pilot testing before Yes ppm implementation. An additional 41.1 MMcf/yr of natural gas would be required which would result in an additional 2,500 tpy of GHG emissions. Sulfur content of hood exhaust gas stream is too high for NSCR. The NSCR catalyst is very No sensitive to poisoning by sulfur compounds. Applications to date limited primarily to natural gas fired combustion turbines. No location in the flue gas circuit where the temperatures are suitable. No Conc. in waste gas (37 ppm) is lower than SNCR floor of 100 ppm. 2-3 times more gas than SCR + reheat would be needed to reach SNCR operating temperatures. Without special combustion chamber design oxygen concentrations at burner are 15-20% No oxygen. This is too high for a low NO x burner to operate properly. Combustion air is very hot (1,500-1,600 F). This further degrades burner performance. No Concentration in stream (10 ppm) is less than can be achieved by LoTOx (15 25 ppm). No No No No Not compatible with pellet furnace oxygen requirements. Not compatible with pellet furnace oxygen requirements. Not compatible with pellet furnace oxygen requirements. Furnace is not designed to use solid fuel. Solid fuels have lower NO x emissions but higher emissions of all other pollutants. X

118 Identify All Technologies Table 1-6: Taconite Pellet Indurating Furnace: Hood Exhaust & Waste Gas Stack; CO & VOC Step 1 Step 2 Step 3 Step 4 Step 5 Eliminate Technically Rank Remaining Infeasible Options Technologies Evaluate Most Effective Technologies Select and Document Results BACT Good Design and Operating Practices Clean Fuels (Natural Gas) Thermal Oxidation (TO) Catalytic Incineration Feasible? Basis for Determination of Infeasibility Rank Basis Control Efficiency Yes 1 Inherent to Design CO & VOC Yes 2 emissions are insignificant. No Thermal Oxidation not effective below 100 pmm. Concentration in streams <10 ppm. No Catalytic Incineration not effective below 100 pmm. Concentration in streams <10 ppm. X X

119 Identify All Technologies Table 1-7: Taconite Pellet Indurating Furnace: Waste Gas Stack; Fluoride Step 1 Step 2 Step 3 Step 4 Step 5 Eliminate Technically Rank Remaining Infeasible Options Technologies Evaluate Most Effective Technologies Select and Document Results BACT Gas Suspension Absorber (GSA) Clean Fuels (Natural Gas) Good Design and Operating Practices Absorber (Wet Scrubber) Wet Electrostatic Precipitator Spray Dryer Absorption Dry Sorbent Injection Feasible? Basis for Determination of Infeasibility Rank Basis Control Efficiency Yes % Yes 3 Yes 3 Inherent to Design Inherent to Design Yes % Yes % Yes % Yes % No wastewater generated. Uses 50% less water than a wet scrubber. Same technology chosen for SO 2 control. Compatible with activated carbon injection for mercury control. Project is designed and permitted to only use natural gas which generates the least amount of F. Generates wastewater that requires treatment. Additional processing equipment is needed to convert the sulfates generated by absorption to a solid waste (gypsum). Absorption produces a visible plume due to the water condensation in absorber exhaust plume. Generates wastewater that requires treatment. Additional processing equipment is needed to convert the sulfates generated to a solid waste (gypsum). X X X

120 Identify All Technologies Table 1-8: Taconite Pellet Indurating Furnace: Hood Exhaust; Fluoride Step 1 Step 2 Step 3 Step 4 Step 5 Eliminate Technically Rank Remaining Infeasible Options Technologies Evaluate Most Effective Technologies Select and Document Results BACT Clean Fuels (Natural Gas) Good Design and Operating Practices Gas Suspension Absorber (GSA) Absorber (Wet Scrubber) Wet Electrostatic Precipitator Spray Dryer Absorption Dry Sorbent Injection Feasible? Basis for Determination of Infeasibility Rank Yes 6 Yes 6 Basis Control Efficiency Inherent to Design Inherent to Design Yes % Yes % Yes % Yes % Yes % Project is designed and permitted to only use natural gas which generates the least amount of F. Uncontrolled F conc. = 1.8 ppm. Based on SO 2 control equipment not cost effective. X X

121 Identify All Technologies Fabric Filter (Baghouse) Table 1-9: Taconite Pellet Indurating Furnace: Hood Exhaust & Waste Gas Stack; Lead Step 1 Step 2 Step 3 Step 4 Step 5 Eliminate Technically Rank Remaining Infeasible Options Technologies Evaluate Most Effective Technologies Select and Document Results BACT Feasible? Basis for Determination of Infeasibility Rank Basis Control Efficiency Yes % Clean Fuels Inherent to Yes 4 (Natural Gas) Design Good Design and Inherent to Yes 4 Operating Practices Design Dry Electrostatic Precipitator Yes % (Dry ESP) Wet Electrostatic Precipitator Yes % (Wet ESP) Wet Scrubber Yes % Centrifugal Separation Yes % (e.g. Cyclones) Inertial Separators (Drop Out Box) Yes 3 <50% More effective at capturing fine particulate matter. Uses less electricity. No wastewater generated. Same technology selected for particulate control. Project is designed and permitted to only use natural gas which generates the least amount of Pb. More effective at capturing fine particulate matter. Uses less electricity. No wastewater generated. Able to remove other pollutants (SO 2, NO x, acid gases). Generates wastewater that must be treated. Uses more electricity. X X X

122 Identify All Technologies Table 1-10: Taconite Pellet Indurating Furnace: Hood Exhaust & Waste Gas Stack; GHG Step 1 Step 2 Step 3 Step 4 Step 5 Eliminate Technically Rank Remaining Infeasible Options Technologies Evaluate Most Effective Technologies Select and Document Results BACT Feasible? Basis for Determination of Infeasibility Rank Clean Fuels (Natural Gas) Yes 1 Energy Efficiency Measures Yes 1 Lower Emitting Processes -- SO 2 Yes 1 removal reagent Lower Emitting Processes -- Alternate pellet No additives CO 2 Capture Technologies Post Combustion CO 2 Capture Oxyfuel Combustion with CO 2 Capture Gasification and Pre-combustion CO 2 Capture CO 2 Mineralization No No No No CO 2 Sequestration Locations Deep Saline Aquifers Oil & Gas Reserve Un-mineable Coal Seam No No No Basis Control Efficiency Inherent to Design Inherent to Design Inherent to Design Project is designed and permitted to only use natural gas which generates the least amount of CO 2 e. Limestone addition is necessary for pellet hardness and as a fluxing agent. No alternatives available. Not demonstrated at commercial scale. High energy demand. No feasible sequestration location. Oxygen requirements of the furnace are not compatible with technology. Not demonstrated on a commercial scale. No feasible sequestration location. Furnace is not designed to burn hydrogen produced from gasification of solid fuels. No feasible sequestration location. Not demonstrated at commercial scale. High energy demand. Closest location is 600 miles from project. No CO 2 transportation pipelines in the region. Not demonstrated at commercial scale. Closest location is 550 miles from project. No CO 2 transportation pipelines in the region. Not demonstrated at commercial scale. Closest location is 550 miles from project. No CO 2 transportation pipelines in the region. Not demonstrated at commercial scale. X X X

123 Identify All Technologies Fabric Filter (Baghouse) Table 1-11: Material Handling; PM/PM 10 /PM 2.5 Step 1 Step 2 Step 3 Step 4 Step 5 Eliminate Technically Rank Remaining Infeasible Options Technologies Evaluate Most Effective Technologies Select and Document Results BACT Feasible? Basis for Determination of Infeasibility Rank Basis Outlet Conc. (gr/dscf) Yes Wet Electrostatic Precipitator Yes (Wet ESP) Dry Electrostatic Precipitator Yes (Dry ESP) Wet Scrubber Yes Centrifugal Separation Yes (e.g. Cyclones) Inertial Separators (Drop Out Box) Yes More effective at capturing fine particulate matter. Uses less electricity. No wastewater generated. X

124 Table 1-12: Summary of BACT Limits Material Handling Sources SV ID EU ID CE ID* Emission Unit Description Performance Standard Mass Emission Limit PM/PM 10 /PM 2.5 (gr/dscf) Lead (mg/kg) Fluoride (mg/kg) PM/PM 10 /PM 2.5 (lb/hr) Lead (lb/hr) SV 016 EU 036 CE 014 Hearth Layer Bin E E E-05 5 SV 017 EU 037 EU 106 CE 015 Hearth Layer Feed E E E-06 5 SV 020 EU 040 CE 021 Pellet Discharge E E E-04 5 SV 021 EU 041 CE 022 Pellet Screening and Handling E E E-04 5 SV 022 EU 042 CE 023 Pellet Screenings to Regrind Conveyors E E E-06 5 SV 023 EU 048 CE 024 Oxide Pellet Stockpile Conveyor Gallery E E E-05 5 SV 084 EU 176 CE 116 Primary Grinding Mill Line E E E-07 5 SV 085 EU 170 CE 115 Grizzly Transfer Tower E E E-08 5 SV 086 EU 171 CE 110 Non-Magnetic Cobber Rejects Transfer Tower E E E-08 5 SV 087 EU 172 CE 111 Secondary Screening Crusher/Cobber Line E E E-07 5 SV 088 EU 173 CE 112 Secondary Screening Crusher/Cobber Line E E E-07 5 SV 089 EU 174 CE 113 Secondary Screening Crusher/Cobber Line E E E-07 5 SV 090 EU 175 CE 114 Secondary Screening Crusher/Cobber Line E E E-07 5 SV 091 EU 177 CE 119 Carbon Bin for Mercury Control E SV 092 EU 178 CE 120 Lime Bin for Scrubber E FS 017 Dozer Activity at Tailings Basin 5 FS 018 Grading at Tailings Basin 5 NA FS 019 NA 120K ton Concentrate Stockpile Loading Fugitive Dust Control Plan 5 FS K ton Concentrate Stockpile Loadout 5 FS 027 Oxide Product Loadout to Railcars 5 *Control Equipment chosen as BACT for each EU is a fabric filter (baghouse) with Leak Detection. Fluoride (lb/hr) Opacity (%)

125 Table 1-13: Summary of BACT Limits Indurating Furnace SV ID EU ID EU Description CE ID CE Description Pollutant Performance Standard Mass Emission Limit Averaging Time PM gr/dscf 27 (lb/hr) CE 016 Fabric Filter (baghouse) PM gr/dscf 54 (lb/hr) with Leak Detection PM gr/dscf 54 (lb/hr) 3-hour SV 018 EU 038 SV 018/019 Combined EU 038/039 Combined SV 019 EU 039 Furnace Hood Exhaust Furnace Furnace Waste Gas Pb gr/dscf (lb/hr) NA NA F 1.8 ppmv 15% O (lb/hr) 3-hour rolling SO ppmv 15% O (lb/hr) 3-hour rolling NA Good Combustion Practices CO 1.9 ppmv 15% O (lb/hr) 1-hour rolling VOC 0.60 ppmv 15% O (lb/hr) 3-hour rolling NA NA Opacity 5% NA 6-minute CE 020 Low NOx burners NO x 0.25 lb/mmbtu 135 (lb/hr) 3-hour rolling NA NA CO 2 e NA 710,000 ton/yr 12-month rolling sum PM gr/dscf 18 (lb/hr) CE 019 Fabric Filter (baghouse) PM gr/dscf 37 (lb/hr) with Leak Detection PM gr/dscf 37 (lb/hr) 3-hour Pb gr/dscf (lb/hr) CE 117 GSA Dry Scrubber F 11.5 ppmv 15% O (lb/hr) 3-hour rolling SO ppmv 15% O (lb/hr) 3-hour rolling NA Good Combustion Practices CO 7.4 ppmv 15% O (lb/hr) 1-hour rolling VOC 2.3 ppmv 15% O lb/hr 3-hour rolling NA NA Opacity 5% NA 6-minute

126 Attachment 2 CAM Plan Compliance Assurance Monitoring Plan GSA Dry Scrubber with Lime for SO 2 Emissions Control Furnace Waste Gas I. Background A. Source Information Facility: Essar Steel Minnesota, LLC State Hwy 58 Nashwauk, MN Emission Unit(s) Description: Furnace Waste Gas Emission Unit(s) ID: EU 039 Stack ID: SV 019 APCD ID: CE 117 B. Applicable Regulation, Emissions Limit, and Monitoring Requirements Regulation: BACT under PSD Emissions Limit: 5.0 ppm; 29.9 lb/hr SO 2 Monitoring Requirements: SO 2 CEM and stack flow rate monitor C. Control Technology: GSA dry scrubber with lime solution

127 II. Monitoring Approach I. Indicator SO 2 CEM, O 2 meter and stack flow rate meter. Measurement Approach: The SO 2 concentration in ppm and emission rate in lb/hr will be continually monitored via a CEM. II. Indicator Range An excursion is defined as SO 2 emissions in excess of 5 ppm, or 30 lb/hr on a three hour block average basis during normal production periods. Excursions trigger an inspection, corrective action as necessary, and a reporting requirement. The suggested SO 2 CEM measurement range is 0 to 100 ppm SO 2. The suggested stack flow rate meter measurement range is 0 400,000 scfm III. Performance Criteria A. Data Representativeness B. Verification of Operational Status C. QA/QC Practices and Criteria The SO 2 CEM will measure the SO 2 content at the scrubber outlet. The O 2 meter will be used to correct the SO 2 concentration to a 15% O 2 basis. A stack flow rate meter will measure the stack flow rate for determining the SO 2 mass emission rate. NA. The CEM will be installed, certified, calibrated, and operated according to procedures identified in Minn. R The quality assurance procedures include initial analyzer certification, daily calibration drift assessment, quarterly calibration gas audits and relative accuracy test audits (RATA). The accuracy of the stack flow meter will be verified during RATAs. In calendar years when a RATA is not required, the stack flow meter calibration will be checked at least once per manufacturer s procedures. D. Monitoring Frequency The SO 2 concentration and emission rate will be measured continuously by the CEM and Data Collection Procedures Averaging period stack flow rate monitor. Data will be collected by electronic data acquisition equipment. Data will be collected at a minimum rate of one reading every 15 minutes, and stored as 1-hour averages according to procedures identified in Minn. R Procedures specified in Minn. R will be followed for data collection during periods of monitor maintenance, monitor quality assurance checks and operational periods of less than one hour. The stack moisture content, if needed, will also be verified during RATAs. 3-hour (block) period periods based on the hourly averages data collected by the CEMS data acquisition system.

128 III. Monitoring Approach Justification A. Background The pollutant-specific emission unit is the Furnace Waste Gas. The source is subject to BACT under PSD and is therefore not subject to the Minnesota Industrial Process Equipment Rule. The source will be equipped with a GSA dry scrubber with lime to control SO 2 emissions. B. Rationale for Selection of Performance Indicators SO 2 measurement by CEM with O 2 correction and stack flow rate measurement were selected because they provide the most accurate means to ensure performance on a real-time basis. C. Rationale for Selection of Indicator Ranges The indicator range is based on the expected quantity of SO 2 in the offgas stream. D. Control device operating parameter data collected used to justify the proposed indicator range Not Applicable. A continuous emissions monitoring system will be used to demonstrate compliance. E. Test plan and schedule for obtaining data if performance test data are not available If SO 2 concentrations are measured on a dry basis, stack test data will be used to determine the moisture content of the stack for the SO 2 mass emission rate calculations (stack flow is measured on a wet basis). The moisture content of the waste gas stack will be measured during the initial performance test, and thereafter during the RATA. The initial performance test will be conducted according the schedule in the Essar Steel Minnesota LLC s operating permit. The RATA will be scheduled per Minn. R requirements. Test procedures will be specified in the pre-test plan as required by Minn. R F. Implementation plan The SO 2 CEM and stack flow rate monitor will be installed per the requirements of Minn. R and calibrated per manufacturer s specifications. The monitoring system will be installed, calibrated and operational prior to commencing the initial performance test as specified in Essar Steel Minnesota LLC s operating permit. The SO 2 CEMS will be certified per Minn. R Certification testing will be done concurrently with the initial performance test.

129 Compliance Assurance Monitoring Plan Baghouses for Particulate Matter (PM 10 ) Emissions Control Pelletizer Waste Gas Stack and Hood Exhaust Stack I. Background A. Source Information Facility: Essar Steel Minnesota, LLC State Hwy 58 Nashwauk, MN Emission Unit(s) Description: Pelletizer Emission Unit(s) ID: EU 038, 039 Stack ID: SV 018, 019 APCD ID: CE 016, 019, 118 B. Applicable Regulation, Emissions Limit, and Monitoring Requirements Regulation: Emissions Limit: Monitoring Requirements: BACT under PSD gr/dscf (filterable) Bag leak detection system, pressure drop indicators and baghouse inspection and maintenance program C. Control Technology: Baghouses (CE 016, CE 019) and Multiclone (CE 118)

130 II. Monitoring Approach I. Indicators Bag leak detection system Baghouse cell pressure drop Inspection and maintenance program Measurement Approach: A bag leak detector will be installed at the baghouse exhaust. An alarm will sound to indicate a broken filter bag. Pressure drop indicators will be installed on each baghouse cell. Low pressure drop across the baghouse will be an indicator of potential bag leaks. The inspection and maintenance program will include routine inspections to make sure baghouse equipment is functioning properly, and routine preventative maintenance to minimize equipment failures. II. Indicator Range A bag break indicator will define excursions. Excursions trigger an inspection, corrective action as necessary, and a reporting requirement. Abnormally low pressure drop across a baghouse cell will indicate the potential for leaks and/or bag failures. Excursions trigger an inspection, corrective action as necessary, and a reporting requirement. Initially, manufacturer s specifications for pressure drop will be followed. The pressure drop specification may be adjusted if operating data indicates a different range is appropriate. The inspection and maintenance program will trigger corrective action as necessary, and a reporting requirement if an inspection identifies equipment which is not operating within manufacturer s specifications and/or normal operating ranges. III. Performance Criteria A. Data Representativeness B. Verification of Operational Status C. QA/QC Practices and Criteria The bag leak detector will be placed in the ductwork downstream of the baghouse. The pressure drop indicators will measure the pressure drop between the inlet and outlet of each baghouse cell. The inspection and maintenance program will be consistent with the requirements for baghouses in the Taconite MACT (40 CFR 63 Subpart RRRR). NA. The leak detector will be calibrated and inspected per manufacturer s specifications, and per the baghouse leak detector specifications in the Taconite MACT. The baghouse cell pressure drop indicators will be calibrated annually. Monitoring equipment and process downtime will be recorded in a log. No QA/QC program is needed for the inspection and maintenance program. D. Monitoring Frequency Leak detector continuous Pressure drop daily reading Inspection and maintenance program the frequency of inspections will be consistent with the requirements for baghouses in the Taconite MACT. Data Collection Procedures Averaging period The bag leak detector indication will be recorded via the melt shop process data acquisition system. Baghouse pressure drop readings will be collected manually at least once per day. Inspection and maintenance program records will be recorded manually at a frequency specified by plan. None.

131 III. Monitoring Approach Justification A. Background The pollutant-specific emission units are the pelletizer waste gas and hood exhaust systems. The sources are subject to BACT under PSD and therefore not subject to the Minnesota Industrial Process Equipment Rule. The sources will be equipped with a baghouse to control PM 10 emissions. B. Rationale for Selection of Performance Indicators Bag leak detectors have demonstrated the ability to identify excessive particulate matter bypassing the baghouse, which may indicate leaking or broken bags. Pressure drop is commonly used as an indicator for proper baghouse operation. A pressure drop is created as gas flows through the baghouse duct work and filter bags. If a leak develops in the baghouse tube sheet or filter bag, gases flowing through the leak face less resistance than normal conditions and the pressure drop across the baghouse is reduced. The inspection and maintenance program is designed to make sure that all equipment is operating correctly and is properly maintained. The Taconite MACT requirements for baghouses will be followed to ensure that the program is consistent with approved EPA methodology. Performance indicators were chosen to be consistent with the requirements of the Taconite MACT, which will enable Essar to have a single program for baghouse monitoring across the facility. C. Rationale for Selection of Indicator Ranges An excursion is defined as excessive particulate matter bypassing the baghouse, activating a leak detection alarm, or causing a low pressured drop indication. When an excursion occurs, corrective action will be initiated, beginning with an evaluation of the occurrence to determine the action required to correct the situation. All excursions will be documented and reported. The range selected will be based on both the recommendations from the baghouse supplier and observed operating parameters during initial performance testing. An excursion in the inspection and maintenance program is defined as an operating parameter which is outside of normal operating parameters (e.g. a high dust hopper level), or equipment which does not meet inspection criteria (e.g. holes or tears in filter bags). When an excursion occurs, corrective action will be initiated, beginning with an evaluation of the occurrence to determine the action required to correct the situation. D. Control device operating parameter data collected used to justify the proposed indicator range Not Applicable. A continuous emissions monitoring system will be used to demonstrate compliance. E. Test plan and schedule for obtaining data if performance test data are not available Performance testing will be conducted according to the schedule in the Essar Steel operating permit. F. Implementation plan The bag leak detectors and pressure drop indicators will be installed and calibrated per manufacturer s specifications. They will be installed, calibrated and operational prior to commencing the initial performance test as specified in Essar Steel Minnesota LLC s operating permit.

132 Compliance Assurance Monitoring Plan Proposed LE Burner for NO x Emissions Control Pelletizer Waste Gas Stack and Hood Exhaust Stack I. Background A. Source Information Facility: Emission Unit(s) Description: Pelletizer Emission Unit(s) ID: EU 038, 039 Stack ID: SV 018, 019 APCD ID: CE 020 Essar Steel Minnesota, LLC State Hwy 58 Nashwauk, MN B. Applicable Regulation, Emissions Limit, and Monitoring Requirements Regulation: Emissions Limit: Other Limit: Monitoring Requirements: BACT under PSD 0.25 lb/mmbtu; 135 lb/hr NO x (with LE Burner) None C. Control Technology: LE Burner NO x CEM and stack flow rate monitor

133 II. Monitoring Approach I. Indicator NO x CEM, O 2 meter and stack flow rate meter. Measurement Approach: The NO x concentration and emission rate will be measured continuously by the CEM and stack flow rate monitor. II. Indicator Range An excursion is defined as NO x emissions in excess of 0.25 lb/mmbtu or 135 lb/hr on a 24 hour block average basis during normal production periods. Excursions trigger an inspection, corrective action as necessary, and a reporting requirement. The suggested NO x CEM measurement range is ppm NO x for monitoring emissions after control by Low NO x LE burners, and will convert the ppm measurement to lb/mmbtu. The suggested stack flow rate meter measurement range is 0-400,000 scfm. III. Performance Criteria A. Data Representativeness B. Verification of Operational Status C. QA/QC Practices and Criteria The NO x CEM will measure the NO x content at the scrubber outlet. The O 2 meter will be used to correct the NO x concentration to a 15% O 2 basis. A stack flow rate meter will measure the stack flow rate for determining the NO x mass emission rate. NA. The CEM will be installed, certified, calibrated, and operated according to procedures identified in Minn. R The quality assurance procedures include initial analyzer certification, daily calibration drift assessment, quarterly calibration gas audits and RATAs. The accuracy of the stack flow meter will be verified during RATAs. In calendar years when a RATA is not required, the stack flow meter calibration will be checked at least once per manufacturer s procedures. D. Monitoring Frequency The NO x concentration and emission rate will be measured continuously by the CEM Data Collection Procedures Averaging period and stack flow rate monitor. Data will be collected by electronic data acquisition equipment. Data will be collected at a minimum rate of one reading every 15 minutes, and stored as 1 hour averages according to procedures identified in Minn. R Procedures specified in Minn. R will be followed for data collection during periods of monitor maintenance, monitor quality assurance checks and operational periods of less than one hour. The stack moisture content, if needed, will also be verified during RATAs. 24-hour (block) period based on the hourly averages data collected by the CEMS data acquisition system.

134 III. Monitoring Approach Justification A. Background The pollutant-specific emission unit is the Indurating Furnace. The source is subject to BACT under PSD and is therefore not subject to the Minnesota Industrial Process Equipment Rule. The source will be equipped with Low NO x burners to control NO x emissions. B. Rationale for Selection of Performance Indicators The NO x measurement by CEM with O 2 correction and stack flow rate measurement were selected because they provide the most accurate means to ensure performance on a real-time basis. C. Rationale for Selection of Indicator Ranges The indicator range is based on the expected quantity of NO x in the offgas stream. D. Control device operating parameter data collected used to justify the proposed indicator range Not Applicable. A continuous emissions monitoring system will be used to demonstrate compliance. E. Test plan and schedule for obtaining data if performance test data are not available If NO x concentrations are measured on a dry basis, stack test data will be used to determine the moisture content of the stack for the NO x mass emission rate calculations (stack flow is measured on a wet basis). The moisture content of the waste gas stack will be measured during the initial performance test, and thereafter during the RATA. The initial performance test will be conducted according the schedule in the Essar Steel Minnesota LLC s operating permit. The RATA will be schedule per Minn. R requirements. Test procedures will be specified in the pre-test plan as required by Minn. R F. Implementation plan The NO x CEMS, O 2 meter and stack flow rate monitor will be installed per the requirements of Minn. R and calibrated per manufacturer s specifications. The monitoring system will be installed, calibrated and operational prior to commencing the initial performance test as specified in Essar Steel s operating permit. The NO x CEMS will be certified per Minn. R Certification testing will be done concurrently with the initial performance test. Initial operation of the CEMS will be to demonstrate compliance with the interim NO x BACT limit (no controls).

135 Attachment 3 - ESA Determination Shearen, Trevor (MPCA) From: Sent: To: Cc: Subject: Nick_Rowse@fws.gov Wednesday, October 19, :16 PM Kangas, Kevin - ESML - MN Todd Fasking M.; Shearen, Trevor (MPCA); daryl.w.wierzbinski@usace.army.mil; Margaret_Rheude@fws.gov; Tony_Sullins@fws.gov Re: Section 7 Consultation for Proposed Essar Steel Minnesota Modifications Project Kevin W. Kengas HSE Director Essar Steel Minnesota LLC. 555 West 27th Street Hibbing, MN Dear Mr. Kangas, Trevor Shearen of the MN Pollution Control Agency and I just discussed your letter regarding need for a Section 7 consultation for the proposed Essar Steel Modifications Project in Nashwauk, Minnesota. Because there is no federal action (e.g. a revised Corps of Engineers section 404 permit), there is no requirement for the Fish and Wildlife Service (Service) to concur with the proposed modifications to the mine proposal. As you know, in 2007 the Service concurred with the Corps determination that the proposed action was not likely to adversely affect the Canada lynx, a federally threatened species. Since that time in 2009, the gray wolf was reinstated as a federally threatened species. However, since there is no current federal action for this project, I do not see the need to concur with this action. The Service does not concur with any non-federal entity unless they specifically are identified as a federal representative. Please be aware that bald eagles (Haliaeetus leucocephalus) and their nests are protected under the Bald and Golden Eagle Protection Act of 1940, as amended. According to the Corps 2007 Biological Assessment, there were two known bald eagle nests within Essar s permit to mine boundary at the time. Both nests are located 0.25 miles from the tailing basin and you determined these nesting eagles would not be disturbed by mining, construction, or operating activities. Essar will continue to survey all project construction areas to identify eagle nests and will ensure they will not be disturbed. We do recommend that Essar Steel conduct an eagle nest survey within a half-mile of any mining activity and within 660-feet of any construction activity prior to any proposed construction. If any bald eagle nests are found within these surveyed areas, please contact Mags Rheude in our office at (612) , ext or by at margaret_rheude@fws.gov. Please let me know if I can be of further assistance. by calling me at x2210 or by at nick_rowse@fws.gov. Sincerely, Nick Rowse Nick Rowse Fish and Wildlife Biologist Twin Cities Field Office U.S. Fish and Wildlife Service 4101 American Blvd. E. Bloomington, MN

136 Attachment 4 Ozone Impact Analysis Technical Memorandum To: From: Trevor Shearen, Minnesota Pollution Control Agency Jennifer Koenen, Barr Engineering Company Subject: Ozone Impact Analysis Date: March 21, 2012 Project: Essar Steel Minnesota LLC Expansion Project cc: Joe Henderson, MPCA Kevin Kangas, Essar Lori Stegink, Barr In response to the United States Environmental Protection Agency Region V s comment 1 on Essar Steel Minnesota LLC s (Essar) draft Prevention of Significant Deterioration (PSD) and Title V permit, this memorandum presents an ozone impact analysis for the Essar Steel Minnesota Modification (ESMM) project. Supplemental Environmental Impact Statement (SEIS) The SEIS for the ESMM project presented an assessment of potential cumulative impacts to air quality resulting from the project. This ozone impact analysis follows the structure and intent of the SEIS in providing local and regional context to ESMM project emissions. Consequently, several of the data sources used in the SEIS cumulative air quality impacts are referenced in this analysis. One of the primary differences in this ozone impacts analysis as compared to the other cumulative air quality impacts analyses is that modeling of ozone impacts is not technically or practically feasible 2 for determining an individual source s contribution to ground-level ozone concentrations either near the facility or at long distance from the facility. 1 Comment 1 in a letter from Genevieve Damico - Chief, Air Permits Section USEPA Region V to Joe Henderson, Strategic Projects Sector Minnesota Pollution Control Agency (MPCA) February 23, CFR Part 51 Appendix W Guideline on Air Quality Models - Section a.

137 To: Trevor Shearen, Minnesota Pollution Control Agency From: Jennifer Koenen, Barr Engineering Company Subject: Ozone Impact Analysis Date: March 21, 2012 cc: Joe Henderson, MPCA; Kevin Kangas, Essar; Lori Stegink, Barr Ozone Formation, Fate and Transport Ozone is formed through complex photochemical reactions between NO x, VOC, other non-regulated compounds (e.g., OH - ), sunlight, and meteorological conditions of wind speed, wind direction, temperature, and humidity. Elevated ozone concentrations occur primarily during stable / stagnant atmospheric conditions in urban airsheds. 3 Minnesota generally does not experience long duration stagnation periods due to its geographic location and climate. Ozone transport can be an important contributor to a region s ozone concentrations 4, however, due to its distance from metropolitan areas and prevailing winds, northern Minnesota is not typically affected by long range ozone transport. Ozone concentrations from for Voyageurs National Park (VNP) are shown below and are below the applicable standard. VNP is located approximately 80 miles north of ESMM and is the only year-round ozone monitoring station in northern Minnesota. 5 Table 1: Voyageurs National Park 8 Hour Ozone NAAQS Monitor Year 8 Hour High 4 th High Concentration (ppm) NAAQS (ppm) NAAQS (%) Data Source % EPA Airdata website % EPA Airdata website % EPA Airdata website Average % To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations measured at each monitor within an area over each year must not exceed 0.08 ppm (80 ppb). 3 MPCA, Air Quality in Minnesota Report to the Legislature. Ozone concentrations tend to be highest just outside urban areas, since other pollutants emitted in urban centers actually destroy ground level ozone. As a result, MPCA does not monitor ozone in urban centers such as Minneapolis and St. Paul, but does in surrounding suburban areas. 4 See for example the Clean Air Interstate Rule (CAIR) replacement, called the Transport Rule, modifying 40 CFR Parts 51, 72, 73, 74, 77, 78, The MPCA conducts ozone monitoring at other stations in northern Minnesota from April through September.

138 To: Trevor Shearen, Minnesota Pollution Control Agency From: Jennifer Koenen, Barr Engineering Company Subject: Ozone Impact Analysis Date: March 21, 2012 cc: Joe Henderson, MPCA; Kevin Kangas, Essar; Lori Stegink, Barr Ozone Precursor Emission Levels NO x and VOC emissions are both ozone precursors. NO x emissions are primarily anthropogenic, whereas VOCs are emitted both from biogenic and anthropogenic sources. Figure 1 shows the primary emission source types for NO x and VOCs in Minnesota. Figure 1: Minnesota Ozone Precursor Emissions by Source Type 6 6 Source: MPCA. Air Quality in Minnesota: Emerging Trends Report to the Legislature

139 To: Trevor Shearen, Minnesota Pollution Control Agency From: Jennifer Koenen, Barr Engineering Company Subject: Ozone Impact Analysis Date: March 21, 2012 cc: Joe Henderson, MPCA; Kevin Kangas, Essar; Lori Stegink, Barr Essar Facility NOx and VOC Emissions Analysis The Facility Emissions Summary on Form GI-07 in the October 2011 Air Permit Application lists the total controlled VOC emissions for Essar Steel at 175 TPY and NO x at 905 TPY. Table 2 compares reported actual statewide emissions in 2008 with emissions increases that would result from changes associated with the proposed ESMM project and with changes associated with reasonably foreseeable projects in northeastern Minnesota (as reported in SEIS Table 5.1-3). Statewide VOC emissions from 1999 are also included in Table 2 7. The table illustrates that proposed ESMM project emissions would be negligible compared to statewide emissions. NO x Table 2. Statewide Actual Emissions Compared with Proposed and Reasonably Foreseeable Emissions 2008 Actuals Proposed ESMM Project Reasonably Foreseeable Changes in NE MN Stationary sources (tons/yr) 129, ,000 All sources (tons/yr) 391, % 2008, stationary % -11.6% % 2008, total % -3.8% VOC 1999 Actuals Proposed ESMM Project Reasonably Foreseeable Changes in NE MN Stationary sources (tons/yr) 32, All sources (tons/yr) 397, % 1999, stationary % -- % 1999, total % -- Summary In conclusion, while ozone formation is complex and not directly linear with respect to emissions, given the ESMM project s low NO x and VOC emissions relative to statewide emissions, as well as the generally uniform ozone concentrations in northern Minnesota and its favorable location (relative to ozone formation), there is no reason to believe that the ESMM project would have an impact on ozone concentrations either near to or far from the facility. Since ozone concentrations at the nearest receptor (VNP) are currently 78% of the standard (Table 1), there is no reason to expect emissions from the ESMM project would alter compliance status with respect to the ozone standard VOC emissions from MPCA website.

140 Attachment 5 PM 2.5 Class I Increment Technical Memorandum To: From: Sarah Seelen, Minnesota Pollution Control Agency Ruth Roberson, Minnesota Pollution Control Agency Andrew Skoglund, Barr Engineering Company Subject: PM 2.5 Increment Class I Modeling Results Date: March 6, 2012 Project: Essar Steel Minnesota LLC Expansion Project cc: Joe Henderson, MPCA Kevin Kangas, Essar Lori Stegink, Barr This memo summarizes Class I PM 2.5 Increment results for the Essar Expansion project. Comments received from EPA Region 5 requested that a PM 2.5 Increment modeling analysis be conducted. PM2.5 Increment Method The modeling analysis uses the PM 2.5 inventory provided by MPCA February 24, 2012, updated with current source emissions data (included for review). Consistent with the permit application modeling, the km grid CALMET meteorological data was utilized. The PM 2.5 Increment trigger date was October 20, The nearby PM 2.5 Increment consumers included in the modeling analysis were the U. S. Steel Keewatin Expansion, Mesabi Mining, and PolyMet Mining. The modeling results table is included below along with the 24-hour PM 2.5 Increment Results figure. The modeling files and source inventory are submitted electronically with this memo. PM2.5 Increment Modeling Results Table 1 below shows the modeled PM 2.5 Increment Results are below the 24-hour and Annual Increment standards, assuming approval of the inventory. The inventory is included as an attachment. Table 1: PM2.5 Class I Increment Modeling Results PM 2.5 Increment 24-Hour High 2 nd High Results (µg/m 3 ) Annual Results (µg/m 3 ) All (Essar, Keetac Expansion, Mesabi Mining, PolyMet) Class I Increment 2 1 % Increment 23% 4% The general distribution of the 24-hour and annual modeled results are similar. Figure 1 below shows the 24-hour PM 2.5 modeled results. Figure 2 below shows the Annual PM 2.5 modeled results.

141 Attachment 6 PM 2.5 Class II Increment Technical Memorandum To: From: Ruth Roberson, Minnesota Pollution Control Agency Jennifer Koenen, Barr Engineering Company Subject: PM 2.5 Increment Class II Modeling Results Date: March 2, 2012 Project: Essar Steel Minnesota LLC Expansion Project cc: Joe Henderson, MPCA Kevin Kangas, Essar Lori Stegink, Barr This memo summarizes Class II PM 2.5 Increment results for the Essar Expansion project. Comments received from EPA Region 5 requested that a PM 2.5 Increment modeling analysis be conducted. This modeling was performed as a response to that request. PM2.5 Increment Method Inputs for the modeling analysis use the PM 2.5 NAAQS modeling files included with the Essar Expansion Air Permit Application. Consistent with the permit application modeling, the Hibbing meteorological data was modeled with AERMOD version As described in the EPA comments, the PM 2.5 Increment trigger date to be used was October 20, Therefore, nearby PM 2.5 Increment consumers to be used in the modeling analysis include the U. S. Steel Keewatin Expansion. The modeling files that include these inputs are submitted electronically and accompany this memo. PM2.5 Increment Modeling Results The modeling results summary table is included below along with the 24-hour PM 2.5 Increment Results figure. Table 1 below shows the modeled PM 2.5 Increment Results are below both the 24-hour and Annual Increment standards. Table 1: PM2.5 Increment Modeling Results PM 2.5 Increment 24-Hour High 2 nd High Results (ug/m 3 ) Annual Results (ug/m 3 ) All (Essar & Keetac Expansion) Increment 9 4 % Increment 79% 33% The general distribution of the 24-hour and annual modeled results are similar. The 24-hour results, which have the higher modeled concentrations, are included to demonstrate the distribution of the modeled results. Figure 1 below shows the 24-hour PM 2.5 modeled results.

142 Attachment 7 NO x Class II Modeling Update Technical Memorandum To: From: Ruth Roberson, Minnesota Pollution Control Agency Jennifer Koenen, Barr Engineering Company Subject: 1-Hour NO 2 NAAQS Class II Modeling Results Date: April 26, 2012 Project: Essar Steel Minnesota LLC Expansion Project cc: Joe Henderson, MPCA Trevor Shearen, MPCA Kevin Kangas, Essar Lori Stegink, Barr This memo summarizes updates to the Class II 1-hour NO 2 NAAQS results for the Essar Expansion project. Comments received from EPA Region 5 requested that a revised 1-hour NO 2 NAAQS modeling analysis be conducted using the startup/shutdown NO x emission limits for the DRI and Steel Area. This modeling was performed as a response to that request. Revised 1-Hour NOx Emission Rates Table 1 below lists the sources identified as having a NO x startup/shutdown short-term emission limit. It also lists the previously submitted model emission rate and the revised emission rate based on the startup/shutdown emission limits. Consistent with the permit application modeling, the Hibbing meteorological data was modeled with AERMOD version The modeling files that include these inputs are submitted electronically and accompany this memo. Table 1: NOx Modeled Emission Rates Stack Vent ID Emission Unit Description Submitted 1-Hour NO x Startup/Shutdown 1-Hour NO x (lb/hr) (g/s) (lb/hr) (g/s) SV 028 EU 065 Line 1 Package Boiler SV 030 EU 066 Line 1 DRI Process Heater SV 044 EU 128 Line 1 Ladle/Tundish Preheaters Line 1 Electric Arc Furnace Line 1 Ladle Metallurgy Furnace Line 1 Casting Area SV 050 EU 137 Vacuum Degasser Boiler SV 062 EU 069 Line 1 P.T.S Heater

143 To: Ruth Roberson, Minnesota Pollution Control Agency From: Jennifer Koenen, Barr Engineering Company Subject: 1-Hour NO2 NAAQS Class II Modeling Results Date: April 26, 2012 cc: Joe Henderson, MPCA Trevor Shearen, MPCA Kevin Kangas, Essar Lori Stegink, Barr 1-Hour NO2 NAAQS Modeling Results Table 2 shows the previous maximum modeled 1-hour NAAQS concentration and the new 1-hour NO 2 modeled concentration. The emission increases for the sources listed in Table 1 resulted in small changes in modeled concentration near the facility boundary. However, the modeling demonstration also shows that the emission increases do not have an impact on the maximum modeled concentrations, which are dominated by contributions from other sources. NO 2 NAAQS Cumulative Modeling Results w/o Background Cumulative Modeling Results w/ 28 µg/m 3 background Table 2: NO2 1-Hour NAAQS Modeling Results 1-Hour High 8th High Submitted Results (µg/m 3 ) 1-Hour High 8th High New Results (µg/m 3 ) NAAQS

144 Attachment 8.1 Comments Received On February 9, 2012 a public meeting on the Essar Steel Minnesota modification project draft air quality permit was held at the Nashwauk-Keewatin High School. As part of the meeting a video and audio recording was made and individuals were allowed to speak and have comments recorded. Two individuals chose to speak and approximate transcripts of their statements are below. Comments were taken from their statements and placed in the MPCA response to comments document. These comments will be responded to. Additional information in each statement is noted for the record and will not be responded to in the response to comment document. Comment 1 Chris Wright Rocky Shores Lane Pengilly, MN Snowball Lake [My question comes in the form of the monitoring. Who is supposed to be the ones doing this monitoring? I ve sent pictures in. They ve already failed in the fugitive dust control, and it s just going to get worse when they start to mine. It s affecting everybody in an adverse way. My kids can t go out and build a snowman in our yard, how is that fair? This was supposed to be our dream home that we built, we live on a lake, it was supposed to be the best years of my life right now, and I feel like I m living a nightmare. I don t think it s fair, they re monitoring themselves. How does that work, can somebody explain it? You have mentioned the modeling that was done. They bought three houses on our lake, because they are in the bad air and noise pollution zone. But yet there s nothing between except for lake, and they left the rest of us. I don t understand this. How is that air and noise not traveling across that lake? If you ve ever been to a lake, you can yell across the lake and you can hear it. My wife is now on a daily asthma treatment, for the first time in her life, she s 39 years old. We couldn t figure it out until my kids went out in December to make snowmen, they came in, they were red. I realize this is the stuff we are breathing. Are we going to wait until a bunch of people show up with cancer before something happens, before somebody helps us? I don t think it is right. I would like to see some help here.] Comment 2 Terry Thompson Little McCarthy Lake Road Nashwauk, MN Little McCarthy Lake [I m a half mile through the woods from your entrance to your plant. And we get dust, only when the wind is out of the south. But the noise, every time you dump a pile of rocks on that stockpile, it s like it s in our back yard. We can t sit outside in the summertime. Now, nobody wants to buy our homes, because of the noise. I have a lot of lake shore, it should be easy to sell. And no help, I ve called Essar, they re going to have meetings, don t hear anything. My yard in the wintertime is brown sometimes, just when the wind is out of the south where I live. But for me, it s the noise, and all this stuff tonight, you had all these other emissions, but no noise, the CATs, it s like they re in my back yard. You bought the land across the road from me, 800 feet away you bought the house, and then you stopped. In 75 Hanna was going to mine the same body of ore, I have all the prints, they had a ¾ mile dead zone. Essar has nothing.]

145 February 17, 2012 VIA FEDEX and FACSIMILE Trevor Shearen, PE, Strategic Projects Sector Industrial Division, Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, MN Fax: (651) Re: Comment on Draft Permit for Essar Steel Minnesota These comments are submitted on behalf of the Minnesota Center for Environmental Advocacy and the Midwest Environmental Defense Center and their members. We appreciate the opportunity to provide these comments regarding the Essar Steel Minnesota Facility in Nashwauk, Itasca County, Minnesota. Comment 1: MPCA must do an analysis of the facility s compliance with the PM2.5 increment (Class I and Class 2). EPA has established PM2.5 increments that apply after the effective date of October 20, Fed. Reg. 64,864. Since Essar Steel will receive its PSD permit after the effective date, it must show that its emissions will not cause or contribute to a violation of the increment. 75 FR at 64,899 ("each source that receives its PSD permit after the effective date of the PM2.5 increments [Oct 20, 2011], regardless of when the application was submitted, to provide a demonstration that the source's proposed emissions increase, along with other increment-consuming emissions, will not cause or contribute to a violation of the PM2.5 increments."). However, in the draft permit and