# CLIFFS

TILDEN MINING COMPANY L.C

. Managed by The Cleveland
-Cliffs Iron Company PO Box 2000, Ishpeming, Ml 49849
-0901 P 906 475

.3600 F 906.475 3777 cliffsnaturalresources

.com

May 25, 2012 

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# 8NJ Attn: Compliance Tracker, AE-171 AirEnforcement and Compliance Assurance Branch U.S. EnvironmentalProtectionAgency Region 5 77 W. Jackson Boulevard Chicago, Illinois 60604 AIRENFORCEMENTBRANCH U.S. EPA REGION 5

Re: Tilden Mining Company, L.C. Response to Clean Air Act Section 114 Request to Provide Information Regarding Best Available Retrofit Technology (BART) Compliance This letterand the enclosed data disks are the response ofTildenMining CompanyL.C. (referred to herein as "Tilden" or "we") to the "Request to Provide Information Requested Pursuant to the Clean Air Act" (the "Request"), regarding the iron ore processing facility located at 1 Tilden Mine Road, which we received on April 26, 2012

. The Request required a response within 15 days of receipt. Upon receipt of the Request, Tilden requested separate response dates for Questions 1-16 and Questions 17-25 to enable the facility to most effectively respond to the Request. Separate response dates were approved by Molly DeSalle and the response date for Questions 1-16 was set for May 25, 2012. Tilden hereby provides this timely response to the Request, withthe understandings and clarifications noted herein. Tilden has given careful consideration to this Request and each ofits questions to ensure that its response is accurate and properly tailored to the information EPA has requested. Most ofthe information requested is public information that has been submitted previously to a regulatory agency, so Tilden is not requesting that any portion ofthis response be considered Confidential Business Information. This response restates each ofthe questions in the Request and provides a narrative explanation of the r esponsive information. Responsive documents are referenced in the narrative and included onthe data disks enclosed withthis letter. The disks are organizedbynumberedfolders that correspond to the questions below

. Each disk is labeled with the company name, folders containedonthat disk, and the date ofresponse. Documents responsive to multiple questions are identified in the narrative response to each question, and are included on the disks under the question to which the documents are most responsive. The documents provided have been scanned for viruses using McAfee software. Ifyou have any questions or concerns about theinformation provided, please direct your questions to Tilden's counsel, Douglas McWilliams, at Douglas.McWilliams@squiresanders.com. 1. 

### Provide processflow diagramsfor both the taconite iron ore mining and the taconite pelletmanufacturingprocesses. Include in the description, ata minimum, information on thefollowing: mining operations, ore transfer andstorage, coarse ore crushing,fine ore crushing, ore classification screens, ore storage bins, grinding rod/ball mills, separation, thickeners, balling drums/pellet formation, indurating furnace,pellet cooling andstorage, and theprocess boilers. Include a detailed narrativeprocess description andphotographs to explain the indurating furnace process (separately for each furnace). For each photograph,provide a coded diagram/map to clearly identifY the location of the image in thephotograph. Photographs mustcorrespondto each of theprocess stages described. Responsive documents are included inFolder 1:

• Document 1-1 contains process flow diagrams depicting the processing ofmagnetite and hematite and the pelletproductionprocess. Iron ore mining operations include the removal of overburden material, removal of waste rock material, and mining ofore. The ore is loaded onto trucks, hauled to the primary crusher, crushed and conveyed to the Crude Ore Bam. A tripper conveyor system in the peak ofthe bam distributes the ore among 11 Primary Grinding Mills. A twelfth mill is used to grind the limestone required for producing flux pellets. Ore from the ore bam is ground by 11 autogenous primary mills and then proceeds throughpebble mills. Magnetic separators are used during magnetite production to remove magnetite ore from the tailings. The hematite process uses a series ofthickening and flotation steps to separate the iron particles from the tailings. Processes performed in the concentrator are wet operations, and several small wet scrubbers are used to control dust generated at concentrate conveyor transfer points. Tailings are pumped in a slurry form to the tailings basin. Concentrate is dewatered using steam filtration, steam is required to reduce the viscosity ofthe intergranular water and attain proper moisture content. Tilden operates three natural gas-fired process boilers to provide steam for production processes such as filtering and chemical processing, in addition to comfort heating and domestic hot water. After filtration the concentrate is conveyed to the dryers and the concentrate bins onthe balling floor. Green pellets are produced in balling drums and conveyed to one of two AllisChalmers grate-kiln systems, described in greater detail below. Emissions from each grate-kiln are controlled by 3 dry electrostatic precipitators. Fired pellets are conveyed to the pellet stock pile or railroad loadout bin for direct loading into rail cars. Once loadedinto rail cars pellets are transported from the facility.

2• Document 1-2 contains a schematic drawing of the indurating furnace. This schematic is being provided in lieu ofphotographs because Tilden does not possess current photographs ofthe indurating furnaces that would be useful in this context. Both furnaces are ofthe same design and therefore the diagram and description below are equally applicable to both Line 1 and Line 2. Only Line 1 is subject to BART, and therefore the process description below includes the dimensions for the Line 1 furnace. The schematic includes labeling identifying the processes described below. As stated above, the Tilden Mine owns and operates two Allis-Chalmers grate-kiln systems. Each unit consists ofa three pass traveling grate, rotary kiln, and annular cooler. The traveling grate is a metal casting conveyor which is subdivided into 3.5 bays of updraft drying, 7.5 bays of downdraft drying and 8 bays of downdraft preheating for drying and preheating the green balls. The grate is 18'7" wide and 210'8" long, and has three natural gas-fired preheat burners. A heat recuperation system is utilized. The grate empties into a refractory lined rotary kiln with a 25' inside shell diameter that is 160' long. Each kiln is equipped with two main burners, one for natural gas and one for coal. The kilns are supplied with diesel powered emergency drives. The pellets travel through the kiln into a refractory lined annular cooler (66' mean diameter x 10'2" W), which incorporates both primary and secondary heat recuperation. As the annulus cooler rotates, air is directed to heat recuperation ducts and is delivered to the drying zone ofthe grate. Incorporated in each unit are three dry electrostatic precipitators. Exhaust gases from downdraft drying are cleaned by two electrostatic precipitators. The exhaust gases from updraft are cleanedby a third electrostatic precipitator. Thomas O'Brien (Environmental Engineer) and Scott Rasmussen (Area Manager Metallurgical Processing) ofTildenMiningprovided information for this response. 2. 

### For the time period January 1, 2010, to December 31, 2011, provide manufacturing specifications and operating data to demonstrate operatingparametersfor each ofthe facility's indurating furnaces and dryers. Operatingparameters and data must include, at a minimum:fluegas composition, entrance air temperature, exitair temperature,preheat zone temperature, burnertemperature,pellet residence time, andair flow rate. Responsive information is included in Folder 2, Document 2-1. Tilden does not have operating data for flue gas composition, entrance air temperature, burner temperature, air flow rate or residence time for the indurating furnaces for the requested time period. Residence time is estimated to be between 37-87 minutes from the time the pellets enter the grate to the time they exit the cooler. This estimate was derived by dividing the total length ofthe grate, kiln, and cooler by the expected low and high speeds for each device. Kiln speed was assumed to be the same as the grate speed in this estimate. The remaining requested data has been provided for the indurating furnaces. Burner temperature and outlet



### 3temperature are included for the dryer. To the extent estimated normal operational parameters are available, these have also beenincluded inDocument 2-1. Thomas O'Brien (Environmental Engineer) and Jeremy Pletka (Senior Mineral Processing Engineer) ofTilden Miningprovided information for this response. 3. 

### For the timeperiodJanuary 1, 2007, to December31, 2011,provide records of thenatural gas usedbyeach specific indurating furnace anddryer at the facility. Monthlynatural gas usage is included inFolder3 as Document 3-1. Thomas O'Brien (Environmental Engineer) and Jeremy Pletka (Senior Mineral Processing Engineer) ofTilden Miningprovided information for this response. 4. 

### For the timeperiod January 1, 2007, to December 31, 2011, 

### ifcoal was used as afuel source at thefacility, provide documentation ofthe average sulfur contentfor coal used by each specific indurating furnace anddryer atthe facility. Sulfur data for coal usedbythe indurating furnaces is included inFolder4 as Document4-1. Tilden has composite monthly samples tested aud records the results in Excel format for reporting purposes. Coal is not tested separately for each indurating furnace. Coal is not combusted inthe thermal dryer. Thomas O'Brien (Environmental Engineer) ofTilden Mining provided information for this response. 5. 

### For the timeperiod January 1, 2005, to December 31, 2011, provide copies ofall stack tests conducted on any emissions unit for any reason, and include all test runs, even 

### if a full test series was not completed. IdentifY the emissions unit; specifY the date of the test, test method used, and thefilter temperature during the time ofthe test, 

### ifapplicable. Provide all calculations relative to the stack test, and provide copies of the full test report, including the section describing the process parameters andproduction or processing rates at the time of the test, as well as copies ofany reports ofvisible emission observations conducted during each test. For each test during which the source was not operating at maximum design capacity, provide an explanation why production was limited. US EPA's request letter states that US EPA is "requesting information on the facility's furnaces, dryers, and other nitrogen oxide (NOx) and sulfur dioxide (S02) emitting units." Consistent with the scope ofthe request, Tilden is providing stack test informationrelated to NOx and SOz emissions at the facility during this time. Tilden did not operate continuous opacity monitors at the time oftesting and therefore does not have any independent opacity data for the testprovided. A stacktest report measuring S02 from the indurating furnaces in 2005 is included inFolder 5 as Document 5-1. This testwas run undernormal operating conditions.

4Thomas O'Brien (Enviromnental Engineer) ofTilden Mining provided information for this response. 6. Provide an electronic Excel workbook with the complete nitrogen oxide (NO,J and sulfur dioxide (SOl)facility-widepotentialto emit calculations. Include in the response a written description of howeach column in theExcelworkbook isgenerated. Tilden's potential to emit calculations for NOx and S02 are in Folder 6, Document 6-1. References are within the spreadsheet and give an explanation ofhow each calculation was conducted. The potential to emit calculations may change when BART limits for NOx and S02 become effective. PTE calculations do not include emissions from insignificant sources. Thomas O'Brien (Environmental Engineer) of Tilden Mining and Teresa Kinder (Barr Engineering) provided information for this response. 7-9. Questions 7 through 9 request specific informationrelatedto the BART report submittedby Tilden in 2006 (hereinafter "TildenBART Report"). The following information is provided as common background for Questions 7, 8, and 9 ofthe Request. Additional information specific to each Question is further included in each section as appropriate. As indicated in EPA's Section 114 Request, the Tilden BART Report was developed in 2006 using control technology that was considered available and technically feasible at that time. In preparing the report, two guidance documents were relied on to establish the process and methodology. These were:

• MPCA's "Guidance for Facilities Conducting a BART Analysis"; and

• EPA's "Regional Haze Regulations and Guidelines for Best Available Retrofit Technology (BART) Determinations," 70 Fed. Reg. 39164, 39164-70 (July 6, 2005). EPA's "Regional Haze Regulations and Guidelines" document provided the five step BART review process, as supported by MPCA's "Guidance for Facilities Conducting a BART Analysis." In addition, Tilden's BART report followed the MPCA guidance document in considering the Taconite MACT to be equivalent to BART for particulate sources subject to bothrules. These documents are included inFolder 7-9_Background Documents. The Michigan Department ofEnvironmental Quality did not provide state-specific BART guidance, butinstead relieduponthatpublishedbythe state ofMinnesota. Although MPCA guidance and data on the taconite industry in Minnesota was considered for purposes of Tilden's BART report, Tilden's BART is a facility-specific evaluation and the BART determination is based onfacility-specific considerations.

57. 

### Thefacility's BestAvailable Retrofit Technology report ("BART report") discusses the low efficiency ofthefacility's wet scrubbers on the Line 1 dryerfor S02• 

### Provide all documentation, including reports andstudies, to determine the current S02 

### efficiency of all water scrubbers at thefacility. Additionally,provide all documents, including reports and studies, completed for the technical feasibility ofefficiency upgrades for each scrubber. Documents regarding wet scrubber S02 removal efficiency are included in Folder 7. This folder includes documents specific to Tilden as well as documents on the taconite industry generallythat informedthe BART report.

• Document 7-1 contains internal correspondence from Barr Engineering discussing potential costs and control potential of installing a second scrubber at Tilden. As explained inthe Tilden BART Report, installation ofa second scrubber at this unit is not cost effective and was not evaluated further.

• Document 7-2 estimates potential S02 control efficiencies ifa second scrubber was installed at Tilden. As explained in the Tilden BART Report, installation of a second scrubber at this unit is not cost effective and was not evaluated further.

• Document 7-3 is an "Evaluation ofMinnesota Taconite Wet Scrubbers at Minntac, Keetac, HibTac, and UTac" by John Engesser (Minnesota Department of Natural Resources). This report does not discuss Tilden's scrubbers specifically, but information on the S02 removal efficiency of scrubbers in the taconite industry generallywas considered in preparing Tilden's BART Report.

• Document 7-4 is a report prepared by Barr Engineering in 2003 for the Minnesota Pollution Control Agency entitled "Potential Impacts ofthe Federal Regional Haze and Best Available Retrofit Technology Rules on the Taconite Industry in Minnesota." This report discusses the potential removal efficiencies of wet scrubbers for the taconite industry beginning at pages 46 and 66. This report does not discuss Tilden's scrubbers specifically, but information on the S02 removal efficiency ofscrubbers in the taconite industry generally was considered in preparing Tilden's BART Report.

• Document 7-5 contains the BACT analysis performed for the Northshore facility's restart ofLine 5. Information on the expected control efficiency ofwet scrubbers is included on page A-5-17. This document does not discuss Tilden's scrubbers specifically, but information on S02 removal efficiency at other taconite facilities was consideredinpreparing Tilden's BART Report. George Pruchnofski, Beth Havlik, Jack Kennedy, Erik Boleman, and Teresa Kinder ofBarr Engineeringprovided information for this response under the direction ofThomas O'Brien.

68. 

### The BART report discusses the technical feasibly oflow NOx burners, a variety of selective catalytic reduction (SCRs) systems andselective non-catalytic reduction (SNCRs) systems. Provide all documentation, including reports and studies, to determine the technicalfeasibility oflow NOx burners, SCRs and SNCRs at the facility's Line 1 indurating furnace andLine 1 dryer. Responsive documents are included inFolder 8:

• Document 8-1 contains emails discussing the low-NOx burner retrofit recently completed by Dauieli-Corus at a straight-grate taconite induration furnace in the Netherlands. At the time ofthis email (2006), this technology was determined to be "not available" for taconite indurating furnaces because only one facility used the technology audithadnotbeen sold outside ofthe compauy.
• Document 8-2 contains emails between personnel from Barr Engineering, Tilden, and an equipment vendor discussing the option of low-NOx burners in the preheat section ofthe furnace at Tilden. Low NOx burners cannot be used in the indurating zone ofthe furnace because the reduced flame temperatures associated with lowNOx burners would adversely affectproduct quality.

• Document 8-3 contains an email from Teresa Kinder at Barr Engineering to Brent Ketzenberger and Tom O'Brien at Tilden explaining why SNCR technology is not technically feasible and how high temperatures reduce control efficiency for ultra low-NOx burnertechnology at taconite facilities.

• Document 8-4 contains a Barr Engineering memorandum evaluating the technical feasibility of SNCR technology for an indurating furnace and concluding that the technology is not feasible due to high process temperatures aud chemical reactions withthe taconite greenball.

• Document 8-5 discusses the different control technologies that could be considered for a taconite facility aud potential difficulties unique to Tilden's equipment.

• Document 8-6 is Tilden's response to MDEQ's request for additional information relatedto Tilden's BARTReport from 2006.

• Document 8-7 contains a 2010 Barr Engineering memoraudum to MDEQ recommending BART for the Tilden facility.

• Documents 8-8a and 8-8b contain internal Barr Engineering emails discussing a recent SCR pilot study and potential problems for taconite facilities and an Excel spreadsheet summarizing data from the pilot study. This document does not discuss Tilden specifically, but information on this technology as it applies to taconite facilities was considered inpreparing Tilden's BARTReport.

• Document 8-9 contains internal Barr Engineering emails discussing potential difficulties with applying RSCR technology to taconite facilities. This document

7does not discuss Tilden specifically, but information on this technology as it applies to taconite facilities was considered inpreparing Tilden's BARTReport. Responsive information is also included in Folder 7, Document 7-4 and Document 7-5. These reports do not discuss Tilden's operations specifically, but information on the applicability of these technologies to the taconite industry generally was considered in preparing the BART report for Tilden. In Document 7-5, the information most relevant to low NO, burners, SCR and SNCR is located at pages 45-47 and 62-65. In Document 7-6, information most relevantto these technologies is located at pages A-5-26 to A-5-27 and A5-31 to A-5-33. George Pruchnofski, Beth Havlik, Jack Kennedy, Erik Boleman, and Teresa Kinder ofBarr Engineeringprovided information for this response underthe direction ofTom O'Brien. 9. 

### TheBARTreport discusses the technicalfeasibly of induced fluegas technology. Provide all documentation, including reports andstudies, to determine the technicalfeasibility of induced fluegas technologyatthe facility's Line 1 dryer. As provided on page 64 of Tilden's BART Report, process knowledge was used to determine that the configuration of the dryer and the operating parameters of the drying process were compatible with IFGR technology. This assessment was based on engineering judgmentand did notrely onexistingreports or studies. George Pruchnofski, Beth Havlik, Jack Kennedy, Erik Boleman, and Teresa Kinder ofBarr Engineering provided information for this response underthe direction ofTom O'Brien. 10. 

### IdentifY the manufacturer, including contact information,for all low NOx burners, SCR, SNCR, scrubber, and induced fluegas technologies consideredtechnically feasiblefor use atthe facility. The manufacturer company names, contacts, email addresses, and phone numbers are provided below for low NOx burners (LNB), SCR, induced flue gas recirculation/ultra-low NOx burner technology (IFGR-ULNB), wet scrubbers, and wet electrostatic precipitators (Wet ESP). Tilden's BART Report also discussed dry sorbent injection (DSI) and spray dryer absorption (SDA) technologies, but specific manufacturers were not identified for these technologies.
Control Company Contact Email Phone

LNB Metso Kenneth kenneth.gardner@metso.com 570.271.7637 IFGR-ULNB Gardner LNB Outokumpu Jan Weekes Jan.Weckes@outokumpu.com LNB Danieli Peter Peter.Zonneveld@danieli-corus.com +39 (0432) Zonneveld 597821 LNB Danieli KoenMeijer Koen.Meijer@danieli-corus.com +31(6513) 93458 LNB Joho Zink Jason Jason.McAdams@johnzink.com 918.234.2728 IFGR-ULNB McAdams

8Control Company Contact Email Phone LNB Fives Jack Jack.Cochenour@fivesgroup.com 216.271.6000 Cochenour Schreiber, Bob SCR Yonley, and Schreiber Assoc. SCR Babcock Bob Harold BHarold@babcockpower.com 508.854.3941 Power SCR Cormetech Elizabeth GoveyEM@Carmetech.com 919.620.3000 Govey Wet Scrubber STS Hal Taylor taylor@stsconsultants.com 847.279.2541 Consultants Wet ESP Durr Rodney Rodeny.Pennington@durrusa.com 407.822.9203 Pennington George Pruchnofski, Beth Havlik, Jack Kennedy, Erik Boleman, and Teresa Kinder ofBarr Engineering provided information for this response underthe direction ofTom O'Brien. 11. For the timeperiod January 1, 2002, to the date ofthis information request, provide all documentation, including engineering studies or mass balance studies, conducted to determine emissions of NOxfrom each waste-gas stack at all induratingfurnaces and dryers atthe facility. Tilden has not performed any mass balance studies to determine NOx emissions from each waste gas stack atthe facility. AvailableNOx testing data is includedinFolder 11:

• Document 11-1 contains 2004 NOx test results for the North and South stacks at the Line 1 furnace. The test was conductedusing Method 7E.

• Document 11-2 contains NOx testing data from 2012 for the North and South stacks atthe Line 1 furnace. The testwas conductedusingMethod 7E. Thomas O'Brien (Environmental Engineer) and Marty Hanninen (retired employee) of TildenMining provided informationfor this response. 12. Provide an electronic Excel workbook listing thefollowing information from the NOx and/or S02 continuous emissions monitoring system (CEMS)from the date the CEMS were installed to the date ofthis information request. Provide the information on an hourlybasis, whereapplicable. TheExcelworkbookmustincludethe following:

a. CEMSidentijjlingnameormarker; b. CEMSlocation; 

### c. Pollutantmonitored; d. Date andtime; e. NO,/S02 emissions rate inpoundspermillion British thermal units (1b/mmBtu); f. RawNO,/S0 2inppm; g. NO,/S02emissions rate inpoundsperhour;

9h. 

### Flow rate in actual cubic feetperminute (acfm); and i. 

### Furnace temperature in °F. Tilden does not own or operate continuous emissions monitors (CEMS) and therefore has no informationresponsive to this request. Thomas O'Brien (Environmental Engineer) ofTilden Mining provided information for this response. 13. 

### Describe how the NOx 

### CEMs located at yourfacility are used, or could be used, to optimizeyour taconitepelletmanufacturingprocess. Provide supportingdocumentation. Tilden has not evaluated how a NOx CEMS could be used for process optimization at Tilden, and any response to this request as it relates to Tilden's operations would be speculative. CEMS are intended for use as monitoring devices, not as process control tools. Temperature and other parameters that may be adjusted on boilers and other combustion devices to control NOx emissions are critical to pellet quality, and cannot necessarily be adjusted for NOx optimization at a taconite facility in the same way they can be adjusted at other facilities. Process optimization using NO, CEMS at taconite facilities is not a proven technology, nor is it commercially available as a method ofNOx control. NOx CEMS have not been documented as a NOx control technology at any taconite facilities and therefore are not "available" or "applicable" for BART purposes. Thomas O'Brien (Environmental Engineer) ofTilden Mining provided information for this response. 

### 14. For theperiod from January 1, 2002, to the date of this information request,provide NOx 

### emissions data on a daily basis and on a 30-day rolling basis for Line 1 and its correspondingdryer. Tilden does not own or operate continuous emissions monitors (CEMS) and therefore has no informationresponsive to this request. Thomas O'Brien (Environmental Engineer) ofTilden Mining provided information for this response. 15. 

### IdentifY all NOx 

### emlsswn sources andfactors contributing to NOx 

### emlsswns at the facility's indurating furnaces anddryers, includingbutnotlimitedto, the burners. Understanding of NOx generation in indurating taconite furnaces is relatively young as compared to more traditional burners in the power industry, but continues to evolve. The three mechanisms bywhichNOx production is believedto occur in an indurating furnace are thermal, fuel, and prompt NOx. Thermal NOx occurs when nitrogen contained in air oxidizes at high temperatures, and would primarily occur in the flame zone ofthe burners. Fuel NOx occurs when nitrogen contained in the fuel oxidizes during combustion. Prompt NOx occurs at the burners as turbulent diffusion mixes fuel and air and creates eddies ideal for NO formation.

10The amount ofNOx generated by each ofthese mechanisms is not well understood. NOx in a grate-kiln system is primarily influenced by flame temperature, turbulence in the flame, length of time in the flame, and oxygen content. Burning zone temperature, quantity of secondary air, and oxygen content are process driven and are difficult to adjust without affecting pellet quality. Anything that would significantly change the burner or burner performance cannot be completed without understanding the effects on pellet quality and production rates. Thomas O'Brien (Environmental Engineer) and Marty Hauninen (retired employee) of TildenMiningprovided information for this response. 

### 16. Identify all persons, including employees, consultants, representatives ofthe taconite industry, or representatives ofairpollution control manufacturers, who assisted in the preparation, or were consulted for thepurpose of preparing, theBARTreport. The following personnel at Barr Engineering contributed to the BART report:

• George Pruchnofski (Principle in Charge) • BethHavlik (Project Manager) • Jack Kennedy (Technical) • ErikBoleman (Technical) • KimAlfonsi • Teresa Kinder (Technical) The following employees of Tilden and Cliffs Natural Resources were consulted for purposes ofpreparingthe BART report:

• Thomas O'Brien (Environmental Engineer- Tilden) • Keri Schiferl (former employee

- Tilden) • Brent Ketzenberger (AreaManager, Environmental

- Tilden) • Leonard Parker (Director, Environmental Permitting, Michigan and Canada Iron Ore

- Cliffs Natural Resources) Manufacturers consulted for purposes ofpreparing the BART report are listed in response to Question 10. Thomas O'Brien (Environmental Engineer) of Tilden Mining and Teresa Kinder of Barr Engineering provided information for this response.

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# Since**~~**

# ~:a**var** Vice President- General Manager Empire Iron MiningPartnership by The Cl eveland

-Cliffs Iron Company as Managing Agent & Tilden Mining CompanyL.C. by The Cl eveland

-Cliffs Iron Company as Managing Agent

Enclosure

cc: Scott Gischia BrentKetzenberger Thomas O'Brien DouglasMe Williams

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