Need to return call by / at/between and

. Signature: Project No.: 

### 0 317.0 2 .005.520 Page 1 of 4

Project Name: 

### DMR20 1 3 

## CBI?

Yes

No TELEPHONE CALL RECOR D Incoming Outgoing Date: 

### 6/9 /15 Time: 

### 4 :00 am

pm

Company Name: 

### Cliffs Natural Resources ERG Staff Name: 

### Kimberly Bartell

Contact Name: 

### Brent Ketzenberger Contact Phone Number: 

### (906) 475

- 3792

General Subject: 

### 2013 DMR Selenium Discharges for Tilden Mine , Ishpeming, MI



## TOPICS DISCUSSED AND ACTION TAKEN

On June 9, I called and left a message at the facility (voicemail was for Chris Shear (sp?) )

. (906) 475

- 3812

On June 15, Brent Ketzenberger returned my call and left a message. He is the environmental manager for Cliffs Mining for Michigan and is reachable at 906

- 475

- 3792. I returned his call on June 17 and left a message.

On June 19, I spoke with Mr. Ketzenberger. He stated that the facility’s selenium issues should b e ending in the near future. The facility’s current permit includes a schedule of compliance for selenium discharges.

 (Mass balances and ecological studies were completed initially)

 August 2013: feasibility study of treatment options complete

 May 2015: st atus report on pilot studies for the selected treatment options complete (public document)

 January 2016: report that includes final treatment strategy based on evaluation of pilot studies

 November 2017: implementation complete, facility should be meeting p ermit limits

The facility has gone through several steps of investigation and taken thousands of samples. They have done ecological studies for baseline data and submit annual mass balances to MIDEQ. They have also met with MI DEQ on a weekly basis. They have already started construction to meet their compliance schedule of meeting 5ppm limits from outfall 002A by November 1, 2017.

The mine is very large and the tailings basin is 30,000 acres. The tailings basin is bright red due to the hematite productio n. The water from the tailings basin is sent through a series of clarifiers and then is discharged to Goose Lake outfall. The facility has determined that the selenium concentrations are from mining processes and moving overburden. They do not have correla tions in the data to easily determine what is causing the flux in selenium concentrations. The facility believes the flux is a result of the source rock and varies based on which

area of rock is mined.

A hematite process is used at the mine, resulting in the red water (hematite particles are very small and do not easily settle out). The mine has found concentrations of selenite and selenate. Selenite is easier to treat, while selenate is much harder. The facility has looked at many different treatment tec hnologies, including biological chemical reactors (horse manure, wood chips, etc

. ), reverse osmosis, and pH reduction. Details on treatment options reviewed can be found in the status report from May 2015. The facility has determined that RO would

work to treat the selenium, but it is cost prohibitive. Additionally, they have found that the biological chemical reactors will not work for their mine. The mine is leaning toward reducing the pH in the tailings basin (from 8

- 9 to less than 5), which would allow the selenite to be removed . The mine is currently performing full scale testing on pH reduction. If needed, new clarifiers could be implemented that use ferric chloride to remove

additional selenium.Need to return call by / at/between and

. Signature: 

### Cliffs Natural Resources owns two mines that are back t o back. The Tilden mine is on the west side and uses the Hematite process (red in color). The Empire mine is on the east side and uses the magnetite process (grey in color). The Empire mine has a series of settling ponds prior to discharge. Each mine has i ts own tailings basin.

Per his request, I emailed Brent a summary of the write up for the section for his review.

Brent: brent.ketzenberger@cliffsnr.com

I also spoke with Jay Parent from MI DEQ in June 2015 about the selenium discharges for the mine, see notes

below.

On June 11, I called Jay Parent and left a message.

Email: parentj@michigan.gov

Mr. Parent returned my call on June 11. He stated that selenium discharges have been an issue at the facility and the state is working with them to implement a 60 million dollar treatment plan for selenium. The facility discharges only part of the year and it can differ from year to year. The discharges are dependent on the amount of water that the mine recycles and is directly related to TDS in the water.

The facility uses fresh water from a reservoir for many operations at the mine, including washing ro ck. The

mine uses a low

- grade iron deposit to produce iron pellets. The mined ore is about 30% iron . The ore is crushed and ground into a paste. Then the iron is separated out and concentrated into about 70% iron in order to make iron pellets . The silica (waste rock) goes to the tailing basin. The facility collects water and recycles as much of it as possible. In recent years they have been able to recycle more than previous years. As they recycle water,

the selenium and salt increase in the w ater over time because no new fresh water is added. Mr. Parent said that this can lead to increased selenium discharges over time. The selenium discharges are a site

- wide problem at the mine. Mr. Parent is compiling the DMR data to send over. See attached email correspondence.

Total pounds of selenium discharged:

2010: 999 lbs

2011: 1009 lbs

2012: 695 lbs

2013: 717 lbsNeed to return call by / at/between and

. Signature: 

### Email Communication with MI DEQ for Cliffs Natural Resources

From: Jay Parent <parentj@michigan.gov> To: Kimberly Bartell

Date: 06/17/15 11:05 A M Subject: RE: 2013 DMR Clarification for Selenium Discharges

Kimberly,

As part of selenium management Cliffs submits a Selenium Mass Balance to the State. The numbers in the attached spreadsheet a re from that. Selenium Concentrations are measured weekly at the outfall. This changed from monthly in 2012 and that ma y be why you’re having an issue with the data submitted.

Cliffs is investigating a number of strategies to reduce Selenium in the discharge. Currently a pH reduction project is being implemented. By manipulating the pH in the tailings basin the hope is to reduce selenium in the discharge by 80 to 90 percent. In addition active treatment strategies have been evaluated. 27 different technologies were looked at with 5 progressing to benc h scale testing and 3 further evaluated with pilot scale testing in the f ield. The final treatment strategy is still being developed with implementation by 2017.

Thanks, hope this helps

Jay Parent, P.E. Environmental Engineer MDEQ

– WRD, UP District Office

906

- 236

- 9611

From: Kimberly Bartell

To: Jay Parent <parentj@michigan.gov>

Date: 06/11/15 4:15 PM Subject: 2013 DMR Clarification for Selenium Discharges

Mr. Parent:

Eastern Research Group, Inc. (ERG) under EPA Contract No. EP

- C

- 12

- 021, is e

- mailing you on EPA's behalf to request clarification of 2013 discharge monitoring reports for Tilden Mine in Ishpeming, MI (MI0038369). Some back ground on what the information is

used for is below.

EPA reviews publicly

- available DMR data to fulfill its review obligation under Section 304(b) of the Clean Water Act. The CWA requires EPA to annually review and, if appropriate, revise its water pollu tion control technology

- based regulations, called "effluent limitations guidelines" or "effluent guidelines," that limit the discharge of pollutants to waters of the U.S. from various c ategories of industrial facilities. EPA is currently conducting its 201 5 annual review of existing effluent guidelines and potential industrial guidelines which may need to be included (see http://www.epa.gov/guide/304m/ for further information). EPA will discuss this review and the results in its 2015 Effluent Guidelines Program Plan scheduled for publication in the Federal Register sometime in 20 15 or 2016. As part of the 2015 annual review, EPA is evaluating the data in discharge monitoring reports from 2013 and needs further information to complete the review.

We would like to obtain additional information on the following 2013 discharge data for Tilden Mine. Our records show that th e values in the table below were di scharged from outfall 002.

Date Selenium

Discharge (kg/d) Flow (MGD)

1/31/13 14.2 6.15

2/28/13 12.03 5.7

3/31/13 8.66 4.71

4/30/13 3.609 1.73

5/31/13 7.12 5.49

6/30/13 9.63 3.17Need to return call by / at/between and

. Signature: 7/31/13 14.6 9.1

8/31/13 14.8 4.19

9/30/13 5.65 2.35

10/31/13 0 0

11/30/13 5.44 3.37

12/31/13 12.6 6.7

We appreciate your help in confirming if the data are accurate, or if there are units errors in the DMR data.

Please call me at (517) 515

- 1721 if you have any questions. If you would like to speak directly with EPA regarding this request, you can contact William F. Swietlik of EPA's Office of Water/Engineering Analysis Division by phone at (202) 566

- 1129 or by email:

swietlik .william@epa.gov

.

Thank you, Kimberly

-------------------------------------- Kimberly D. Bartell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com

Phone: 517

- 515

- 1721