May 4, 2012 

VIA FEDERAL EXPRESS 

Attn : Compliance Tracker, AE-17J 

Air Enforcement and Compliance Assurance Branch 

U.S. Environmental Protection Agency 

Region 5 

77 W. Jackson Boulevard 

Chicago, Illinois 60604 

HIBBING TACONITE COMPANY 

Managed by Cliffs Mining Company 

CLIFFS 

4950 County Highway 5 North, PO Box 589, Hibbing, MN 55746-0589 

P 218 262.5950 cliffsnaturalresources.com 

Re: Request to Hibbing Taconite Company for Information Pursuant to Clean Air Act Section 114 

Dear Mr. Czerniak: 

This letter and the enclosed information are the response of Hibbing Taconite Company (referred to 

herein as "HTC" or "Hibbing") to Appendix C of the U.S. EPA Region V Clean Air Act Section 114 Information 

Request (the "Request"), regarding the facility located at 4950 County Road 5N in Hibbing, Minnesota, which was 

received on April 6, 2012. The Request originally required a response within 15 days of receipt, but subsequent 

conversation and correspondence with Ms. Molly DeSalle of EPA staff on April 20, 2012 extended the deadline for 

submittal to May 7, 2012. HTC hereby provides this timely response to the Request, with the understandings and 

clarifications noted herein. 

HTC has given careful consideration to this Request and each of its questions to ensure that its response is 

properly tailored to the information EPA has requested HTC has made a good faith effort to respond to this 

Request in the time allotted. To the extent that the response does not include all of the information anticipated by 

your request, we ask that EPA first consider the information attached hereto and evaluate what, if anything, may 

U.S. Environmental Protection Agency 

Attn: Compliance Tracker, AE-17J 

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still be reasonably required under Clean Air Act Section 114(a). To the extent that EPA identifies continuing needs 

for information, please contact us to discuss how we may further assist you. 

This response restates each of the questions in the Request and provides a narrative explanation of the 

responsive information as necessary. Responsive documents are referenced in the narrative and included with this 

letter. The attachments are organized by numeric references that correspond to the questions below. Documents 

responsive to multiple questions are identified in the narrative response to each question, and are included under 

the question to which the documents are most responsive. The documents provided have been scanned for 

viruses using Symantec Endpoint Protection Version 11. 

For the record, HTC notes that while it has made a good faith effort to respond to the Information 

Request, it does not waive any of its rights to object to the form and content of the Information Request or any 

legal defenses that it might have to this Information Request or its admissibility in any administrative or judicial 

proceeding. To the extent, this Information Request is overly broad and unduly burdensome; it seeks information 

that is not relevant to the compliance status of its facility; it is vague and ambiguous, and requires that legal 

conclusions be made to it, HTC objects to the Information Request on the grounds that it exceeds U.S. EPA's 

authority under Section 114 of the Clean Air Act. HTC also objects to the Information Request to the extent that it 

requests information that is subject to attorney-client privilege or other applicable privilege, or that constitutes 

attorney work product or is otherwise not discoverable. Finally, to the extent that the questions are vague, 

ambiguous, overly broad or otherwise exceed U.S. EPA's authority under Section 114(a), HTC has made 

appropriate and reasonable efforts to respond to the questions to the best of its ability, and has made reasonable 

interpretations of the questions. 

If you have any questions regarding this information, please contact Ms. Julie Lucas of my staff at 

(218) 262-68S6. 

U.S. Environmental Protection Agency 

Attn: Compliance Tracker, AE-17J 

Page 2 
Certification 

I certify under penalty of law that I have examined and am familiar with the information in the enclosed 

documents, including all attachments. Based on my inquiry of those individuals with primary responsibility for 

obtaining the information, I certify that the statements and information are, to the best of my knowledge and 

belief, true and complete. I am aware that there are significant penalties for knowingly submitting false statements 

and information, including the possibility of fines or imprisonment pursuant to section 113(c)(2) of the Act, and 18 

U.S.C. §§ 1001 and 1341. 

Sincerely, 

Edward M. LaTendresse 

General Manager 

Enclosure 

cc: Jeff T. Connell, Manager 

Air Quality Division 

Minnesota Pollution Control Agency 

520 Lafayette Road North 

St. Paul, Minnesota 55155 

Ms. Mary Gade, Gade Environmental Group LLC 

Mr. Michael Long, Cliffs Natural Resources 

Mr. Scott Gischia, Cliffs Natural Resources 

U.S. Environmental Protection Agency 

Attn: Compliance Tracker, AE-17J 

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