As memorialized in the attached Consent Decree Modification and discussed in greater detail below, when it owned Dearborn Works, AK Steel agreed to undertake an ESP Project to provide significantly more effective pollution control than the existing ESP. The cost of the ESP Project is estimated at $105,000,000. While Cliffs has now completed the ESP Project, the Consent Decree Modification requires a series of successive performance tests over a several-year period to demonstrate continuing compliance under different operating scenarios. Additional injunctive relief measures are discussed below.
The core of the Consent Decree Modification is the ESP Project. It consists of: 1) replacing the four existing ESP casings (each of which contains eight fields) with four new casings (each of which contains ten fields); and 2) installing one new, fifth casing that has the same air handling capacity and pollution control efficiency as each of the new ESP casings (ten equivalent fields). The ESP project was designed to be carried out in five phases, one for each casing. The new ESP casing was scheduled to be installed not later than June 24, 2021, with the last casing replacement to be finished not later than March 31, 2023. Cliffs has represented that it has now completed installation of all five casings.
As a result, the rebuilt ESP contains a total of 46 discharge electrode fields, comprised of five fields in each compartment of the four replaced casings (for a total of