Recommended Scope of Analysis for Endangered Species

Gateway Energy and Coke Company, LLC

Granite City, Illinois

August 24, 2006

[Purpose of analysis]{.underline}:

The analysis is intended to determine whether the proposed construction
of the Gateway Energy and Coke Company, LLC and the accompanying
improvements at US Steel's Granite City Works (GCW) are likely to
directly or indirectly adversely affect federally listed species. This
recommended scope of analysis or roadmap recommends using USEPA's
ecological risk assessment process to inform the decision points in
section 7 of the Endangered Species Act. Portions of the USEPA's draft
Screening Level Ecological Risk Assessment Protocol for Hazardous Waste
Combustion Facilities (EPA 530-D-99-001A) provides useful guidance for
this analysis. Although this guidance was designed specifically to
assess the impact of hazardous waste combustion facilities, it offers
general approaches for assessing the fate of chemicals released to the
air that can be applied to all types of industrial facilities.

Overall, the evaluation should focus on emissions from the facilities.
To complete this analysis we need an understanding of the background
concentrations and deposition patterns. The anticipated emissions from
permitted but not yet operational facilities should be included in
background. The anticipated concentration in air or deposition at sites
supporting listed species should be compared against NOEL (No observed
effects level) benchmarks thought to be protective of the appropriate
group (e.g., plants). The evaluation should look at the incremental
addition in the context of background concentrations.

[Benchmarks]{.underline}:

For these analyses, commonly accepted NOEL (no observed effects levels)
benchmarks should be used. Where more than one benchmark can be found,
the most conservative value should be used, unless an explanation is
given to justify a less conservative benchmark. When there is no
commonly accepted benchmark, there should be a search of the scientific
literature for relevant toxicity information to provide a basis for risk
assessment for the species of concern.

[Modeling protocol]{.underline}:

Modeling should follow the general guidance provided in Chapter 3 of
USEPA's SLERA protocol for assessing chemical fate and transport. The
modeling should show air concentrations and deposition rates for all
pollutants (where appropriate). The air emissions resulting from the
project should be modeled at the facility level, not on a unit basis.
Total impacts should be evaluated looking at the combined effects of the
vapor phase, particle phase and particle-bound phase of pollutants.
ISCST3 is an acceptable model for this analysis. For chemicals amenable
to deposition, models in the SLERA guidance should be used to estimate
concentrations in soil, surface water, and sediment in conjunction with
relevant fate and transport parameters.

[Background Levels]{.underline}:

Site specific background concentrations in air, soil, water and sediment
should be considered in the effects analysis.

S[uite of pollutants to consider]{.underline}:

The assessment should cover all air pollutants emitted from the facility
including ozone, sulfur compounds, oxides of nitrogen, carbon monoxide,
particulates, and hazardous air pollutants. USEPA will provide the
analysis for ozone for this project.

[Types of impact to consider]{.underline}:

> 1\) Long term, depending upon pollutant. Compare the worst year of
> concentrations in air or deposition on soil (over the last 5 years)
> with appropriate bench marks for chronic effects.
>
> 2 ) Direct effects to listed plants and animals from exposure to the
> vapor phase, particle phase and particle-bound phase of pollutants.
>
> 3\) The indirect effects to animals from ingestion of plants, fish,
> and invertebrates that have accumulated these pollutants.

[Listed Species]{.underline}:

The species that should be evaluated for impacts from the project are
the Bald Eagle, Indiana Bat, Decurrent False Aster, Gray Bat, Pallid
Sturgeon and Least Interior Tern.