EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

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SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

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U.S. ENVIRONMENTAL PROTECTION AGENCY

PUBLIC HEARING

Proposed Federal Implementation Plan for Taconite 

Facilities in Minnesota and Michigan

MINNESOTA DOCKET NO. EPA-R05-OAR-2010-0037

MICHIGAN DOCKET NO. EPA-R05-OAR-2010-0954

Citizens Board Hearing Room

Minnesota Pollution Control Agency

520 Lafayette Road

St. Paul, Minnesota

Met, pursuant to notice, at 10:00 in the

 morning on August 29, 2012.

COURT REPORTER: Angie D. Threlkeld

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SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

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I N D E X

SPEAKER PAGE

Bob Tammen 10

Brian Gordon 12

Wayne Rohde 15

Kevin Reuther 18

Wayne Dupuis 22

Scott Gischia 26

Mike Mlinar

Douglas McWilliams

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 34

George Pruchnofski 41

Allen Miller 46

Carol Overland 51

Matthew Dinslage 53

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1 M R . L E O N : G o o d m o r n in g . W e 'll g o a h e a d 

2 a n d g e t s ta r te d . G o o d m o rn in g . C a n e v e r y b o d y h e a r

3 m e ? Y e s ? A ll rig h t . G o o d m o rn in g a n d th a n k y o u 

4 fo r a t te n d in g th is p u b lic h e a rin g o n th e U .S . 

5 E n v ir o n m e n ta l P r o te c tio n A g e n c y 's p r o p o s e d fe d e r a l 

6 im p le m e n ta tio n p la n fo r ta c o n it e fa c ilitie s in 

7 M in n e s o ta a n d M ic h ig a n . 

8 M y n a m e 's H e rib e r to L e o n , a n d I a m th e 

9 c o m m u n ity in v o lv e m e n t c o o rd in a to r w ith th e U S E P A 

10 R e g io n 5 o f fic e in C h ic a g o . T o d a y I w ill b e s e r v in g 

11 a s th e h e a rin g o f fic e r , a n d w h a t th a t m e a n s is I 

12 w ill b a s ic a lly d ir e c t th e p r o c e d u r e s a n d th e tim in g

13 o f th e h e a rin g . I'll g iv e s o m e m o r e in s t ru c tio n s in 

14 a m o m e n t . 

15 Jo in in g m e a r e D o u g la s A b u r a n o , w h o is 

16 c h ie f o f th e a t ta in m e n t p la n n in g a n d m a in te n a n c e 

17 s e c tio n w ith E P A 's R e g io n 5 o f fic e ; S te v e R o s e n th a l, 

18 th e e n v ir o n m e n ta l e n g in e e r a ls o in th e s a m e o f fic e ;

19 a n d B ill W a g n e r f ro m th e O f fic e o f R e g io n a l C o u n s e l

20 E P A R e g io n 5 . 

21 I'll g o o v e r s o m e p ro c e d u r e s to 

22 fa c ilita te e v e r y o n e 's c o m m e n t s a t t o d a y 's h e a rin g in 

23 a m o m e n t , b u t fir s t I'd lik e to tu rn it o v e r to 

24 D o u g la s A b u r a n o w h o w ill p ro v id e u s w ith a b rie f 

25 s u m m a ry o f th is p r o p o s e d ru le . 

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1 D o u g . 

2 M R . A B U R A N O : T h a n k y o u . E P A a n d o th e r 

3 a g e n c ie s h a v e b e e n m o n ito rin g v is ib ility in n a tio n a l 

4 p a r k s a n d w ild e rn e s s a r e a s s in c e 1 9 8 8 . In 1 9 9 9 th e

5 U .S . E n v ir o n m e n ta l P r o te c tio n A g e n c y a n n o u n c e d a 

6 m a jo r e f fo r t to im p r o v e o u r q u a lity in n a tu ra l p a r k s 

7 a n d w ild e rn e s s a r e a s . T h e r e g io n a l h a z e ru le s c a ll

8 fo r s ta te a n d f e d e ra l a g e n c ie s to w o r k to g e th e r to 

9 im p r o v e v is ib ility in 1 5 6 n a tio n a l p a r k s a n d 

10 w ild e rn e s s a r e a s s u c h a s V o y a g e u r s N a tio n a l P a r k , 

11 th e B o u n d a r y W a te r C a n o e A r e a , th e I s le R o y a le 

12 N a tio n a l P a r k , a n d th e S e n e y N a tio n a l W ild lif e 

13 R e fu g e . T h e s e a r e a s a r e a ls o k n o w n a s C la s s I 

14 a r e a s . 

15 O n D e c e m b e r 3 0 th , 2 0 0 9 M in n e s o ta 

16 s u b m it te d a r e g io n a l h a z e p la n w h ic h in c lu d e d lim its 

17 o n ta c o n ite fa c ilit ie s to E P A fo r a p p r o v a l. 

18 M in n e s o ta s u b m it te d a s u p p le m e n t to it s o rig in a l 

19 s u b m it ta l o n M a y 1 8 th , 2 0 1 2 . O n N o v e m b e r 5 th , 2 0 1 0

20 M ic h ig a n s u b m it te d it s o rig in a l h a z e p la n , w h ic h 

21 in c lu d e d lim it s o n ta c o n ite fa c ilitie s in M ic h ig a n 

22 to E P A fo r a p p r o v a l. 

23 O n J u n e 1 2 th , 2 0 1 2 E P A a p p r o v e d m o s t o f 

24 M in n e s o ta 's r e g io n a l h a z e p la n , e x c e p t fo r th e 

25 lim it s fo r ta c o n ite f a c ilitie s . S im ila rly , o n 

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EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

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1 August 6th, 2012 EPA proposed approval of Michigan's 

2 regional haze plan, but that approval did not 

3 address the taconite facility when it's found in the 

4 Michigan plan. 

5 On August 15th, 2012 EPA published in the 

6 Federal Register proposed limits for the taconite 

7 facility in both Minnesota and Michigan. 

8 Today we are here to listen to your 

9 comments on all aspects of EPA's proposed limits on

10 taconite facilities. The proposed regulation 

11 contains nitrogen oxide and sulfur dioxide limits at 

12 all affected taconite facilities. These limits are

13 intended to require nitrogen oxide production at all 

14 facilities and additional sulfur dioxide production

15 at two of these facilities, namely United Taconite 

16 and Tilden Mine. These limits will dramatically cut 

17 emissions and effluents from the affected taconite 

18 process facilities. The emission productions will 

19 reduce the amount of regional haze and improve 

20 visibility in downwind areas. 

21 Section 169A of the Clean Air Act directs 

22 states or EPA, if implementing the federal 

23 implementation plan, or FIP, to evaluate the use of

24 retrofit controls at certain larger, often 

25 uncontrolled, older stationary sources in order to 

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1 address visibility impacts from these sources. 

2 Specifically Section 169A(b)(2)(A) of the 

3 Clean Air Act requires EPA to implement a FIP to 

4 contain such measures as may be necessary to make 

5 reasonable progress toward the national visibility 

6 goal, including a requirement that certain 

7 categories of existing major stationary sources 

8 built between 1962 and 1977 procure, install, and 

9 operate the best-available retrofit technology, or 

10 BART, as determined by EPA. 

11 Under the regional haze rule EPA is 

12 directed to conduct BART determinations for such 

13 BART-eligible sources that may be anticipated to 

14 cause or contribute to any visibility impairment in

15 a Class I area. The proposed limits found in the 

16 August 15th, 2012 Federal Register notice reflect 

17 best available retrofit technology, or BART, for the 

18 affected taconite facilities. 

19 Today we are here to listen to your 

20 comments on all aspects of EPA's proposed limits on

21 these facilities. 

22 I'll turn it back to Heriberto to go over 

23 the ground rules today. 

24 MR. LEON: Thank you, Doug. 

25 I would like to draw your attention to 

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1 the September 28th, 2012 deadline for submitting 

2 written comments on this proposal. This will hold 

3 the hearing record open for an additional 30 days 

4 beyond today's hearing to allow people to submit 

5 supplemental or rebuttal information that is related 

6 to testimony at today's hearing. So, again, you 

7 have until September 28th, 2012 to submit your 

8 comments and information. 

9 There are handouts in the registration 

10 area that have instructions for submitting the 

11 written comments. EPA will carefully consider your

12 comments from today's hearing, along with written 

13 comments received, in order to move ahead with the 

14 completion of this rule. Under a settlement 

15 agreement, EPA would take final action on this 

16 proposal by November 15th, 2012. 

17 You will notice that we have a court 

18 reporter at today's hearing. Her job is to listen 

19 to all of us speak in order to be able to create a 

20 written transcript of today's hearing. The 

21 transcript will become part of the official record 

22 on this rule and will be available to the public. 

23 Now let me describe the procedure for 

24 today's hearing. I will call scheduled speakers to

25 the table in pairs. When it is your turn to speak,

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1 please state your name and your affiliation before 

2 you begin your testimony. Please also spell out 

3 your name and talk clearly, because that will ensure 

4 that our court reporter captures your name and your

5 comments accurately. 

6 In order to be fair to everyone, we will 

7 limit testimony to five minutes each. Please remain 

8 seated at the table until both speakers have 

9 finished. After you've finished your testimony, 

10 members of the panel may ask clarifying questions. 

11 If you have a written version of your comments that

12 you would like to have entered in the docket, please 

13 give a copy to Sarah Cervak, who is sitting by the 

14 registration table over by the door. 

15 We have a timekeeping system consisting 

16 of green, yellow, and red sheets of paper. This is

17 to help us keep track of time and the five-minute 

18 limit that we have set. You may begin speaking when 

19 I hold up a green sheet. At four minutes I will 

20 bring up the yellow sheet, and this is to indicate 

21 that it is -- you have about one minute to wrap up. 

22 In the event that I notice that your eyes are 

23 looking at a paper and not looking up here, I may 

24 just say the word yellow. And when we have 

25 15 seconds to the 5 minutes, I will raise the red 

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1 sheet of paper to indicate that you're coming close

2 to your 5 minutes. And when your time is up at five 

3 minutes, I will ask you to stop your testimony. I 

4 will, however, exercise some discretion and offer 

5 additional time either immediately after your 

6 elapsed time or later, depending on the line of 

7 speakers that we have. 

8 Today's hearing will conclude at 

9 2:00 p.m. We will extend the session reasonably if

10 necessary to accommodate speakers who have signed up 

11 by noon today. If you would like to speak but have

12 not yet registered to do so, please sign at the 

13 registration table with Sarah Cervak. 

14 We ask for your patience as we proceed 

15 through the list of speakers. We may need to make 

16 some adjustments as the day progresses. 

17 Before we begin, I would like to 

18 acknowledge Brian Gordon from the office of 

19 Congressman Chip Cravaack, who is here today and 

20 will participate in the hearing and provide some 

21 comments. Thank you, Mr. Gordon. 

22 And also I would like to acknowledge Al 

23 Juhnke from the office of Senator Al Franken, who is 

24 also here. Thank you. 

25 Finally, if you have any questions during 

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1 the hearing, please see Sarah, who is sitting at the 

2 registration table over by the door, for any 

3 assistance. 

4 And thank you all for coming out and 

5 participating in today's proceeding. 

6 So we'll go ahead and get started by 

7 calling the first couple of attendees whose names I

8 have up here, and that would be Bob Tammen and Brian 

9 Gordon. 

10 All right. Mr. Tammen, go ahead. 

11 MR. TAMMEN: Thank you. I'm Bob Tammen 

12 from Soudan, Minnesota. B-O-B. T-A-M-M-E-N. 

13 Soudan is an old mining town. I'm a retired 

14 electrician. My wife, Pat, elementary teacher for 

15 many years, retired. We live on the range as our 

16 home. I worked in several of the taconite plants in 

17 my younger days. And of course you probably know 

18 that we have elevated levels of mesothelioma in 

19 northern Minnesota. I imagine you have the numbers, 

20 but I go to the funerals. 

21 A couple of months ago a report came out 

22 that many of the babies born in the Lake Superior 

23 drainage, northern Minnesota are born with elevated

24 levels of mercury. I'm sure you have the numbers, 

25 but my wife and I watch those children grow up in 

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1 our communities. 

2 A week ago a film company came to 

3 northern Minnesota. They wanted to go up in an 

4 airplane and get some videos of mining country. 

5 They asked me to go along because I know which mine

6 is which; I have some history of the taconite 

7 industry. It was a great flight. We left at 5:00 

8 in the afternoon, because they wanted the sun just 

9 right for their filming. And we were about 

10 800 feet. It was an impressive day, but it was a 

11 little hazy. And I don't know if that haze was 

12 natural haze or taconite haze. You know, you have 

13 the numbers, but my wife and I live in a world of 

14 death and toxicity and haze, and we'd like to see it 

15 cleaned up. 

16 Now we're sitting here in the Minnesota 

17 Pollution Control Agency building, and I know 

18 there's a lot of good people working in this 

19 building. They want to take care of our natural 

20 resources. And I also know that a previous 

21 commissioner of this agency went to work for the 

22 mining industry. 

23 The Department of Natural Resources 

24 routinely has their heads of the Land and Mineral 

25 Department retire young and go to work for the 

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1 mining industry. There is a revolving door at the 

2 top. I know that the people in the middle went to 

3 work here because they love our natural resources 

4 and they want to do their jobs. And so I hope that

5 the Environmental Protection Agency will enforce the 

6 regulations that we have and encourage our 

7 regulators and our legislators in Minnesota to clean 

8 up northern Minnesota. 

9 Thank you. 

10 MR. ABURANO: Thank you. 

11 MR. GORDON: Brian, B-R-I-A-N, last name 

12 Gordon, G-O-R-D-O-N, with Chip Cravaack's office, 

13 C-R-A-V-A-A-C-K. I have a written statement from 

14 the congressman dated August 27th, 2012 to 

15 Administrator Jackson, the EPA agency in Washington, 

16 D.C. 

17 Dear Administrator Jackson, On behalf of 

18 3,900 constituents of the Eighth District of 

19 Minnesota who are directly employed by the mining 

20 industry and the over 40,000 constituents that 

21 depend on the mining industry for their livelihood,

22 I am writing to express my concern with the recent 

23 proposed rule published in the Federal Register on 

24 August 15th, 2012. 

25 I request that the EPA reconsider its 

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1 rejection of the state implementation plan for 

2 upgrading taconite facilities. The Minnesota 

3 Pollution Control Agency has carefully examined the

4 feasibility of best-available retrofit technology, 

5 the time it would take to implement, and the 

6 potential operating risk it presents to taconite 

7 mines in northeastern Minnesota. 

8 I request that EPA work with the state to 

9 continue improving visibility in protected areas 

10 while allowing taconite plants to obtain flexibility 

11 needed to cost effectively update their furnaces on

12 a feasible time frame without endangering the 

13 stability of these operations. 

14 In an August of 2012 opinion EME Homer 

15 City Generation versus EPA, the DC Circuit of the 

16 U.S. Court of Appeals wrote, I quote: To deal with

17 the complex regulatory challenge, Congress did not 

18 authorize EPA to simply adopt limits on emissions as 

19 the EPA deemed reasonable; rather, Congress set up a 

20 federalism-based system of air pollution control. 

21 Under this cooperative federalism approach, both the 

22 federal government and the state play significant 

23 roles. The federal government sets air quality 

24 standards for pollutants. The states have the 

25 primary responsibility for determining how to meet 

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1 those standards and regulating resources within 

2 their borders, unquote. 

3 I request that EPA work with the state to 

4 effectively address the needs of Minnesotans. EPA's 

5 proposed federal implementation plan contains the 

6 timeline that is not technically and economically 

7 feasible for some plants and could negatively impact 

8 thousands of jobs at a time when Minnesota is 

9 meeting its regional haze reasonable progress goal. 

10 Minnesota taconite mining provides 

11 tremendous benefits to our entire state with nearly

12 $1.8 billion annual benefit to our economy. 

13 According to a University of Minnesota-Duluth study, 

14 2.5 ancillary jobs are produced for every mining 

15 job. In times of such high unemployment, these are

16 good-paying jobs we cannot jeopardize. 

17 I am happy to be of any assistance in 

18 moving forward with this effort. Sincerely, Chip 

19 Cravaack. 

20 MR. ABURANO: Thank you. 

21 MR. LEON: Thank you very much. We'll 

22 move on to the next couple of speakers. Thank you. 

23 MR. ABURANO: What I should say, if you 

24 have written copies of your testimony that you would 

25 like to submit to us today, we're more than happy to 

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1 take them. 

2 MR. LEON: Wayne Rohde and Kevin Reuther. 

3 Sorry. 

4 Mr. Rohde. 

5 MR. ROHDE: Good morning. My name is 

6 Wayne Rohde, and I'm a resident of Woodbury, 

7 Minnesota. I'm here to comment on the potential for 

8 other emissions increasing as a result of this rule. 

9 First, we want to commend the EPA for 

10 their efforts to improve air quality in Minnesota. 

11 Given the widespread use of natural gas by the iron

12 ore industry on the Iron Range for processing 

13 taconite, this proposed rule should increase 

14 positive impacts on air quality while minimizing 

15 economic impacts, since the price of natural gas has 

16 steadily dropped as new reserves have been 

17 developed. 

18 Second, reducing sulfates and nitrous 

19 oxide emissions produced by furnaces during taconite 

20 processing to improve visibility beyond the state 

21 proposal will not only further improve overall 

22 visibility in the region, it would also help reduce

23 the amount of respiratory and cardiovascular health

24 impacting pollution, impairing our local air 

25 quality, and reducing potentials for acid rain. 

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1 However, that said, the proposed changes 

2 to improve visibility may result in unanticipated 

3 changes in the HAP emissions. Our concerns relate 

4 to the increased temperature that will be created by 

5 the improvements in combustion and resulting effects 

6 on the amount of mercury and other HAPs these plants 

7 will emit. As the process temperatures increase due 

8 to greater efficiencies proposed, the potential from 

9 increased volatilization and changes in combustion 

10 chemistry could result in increased HAP emissions. 

11 We believe localized impacts due to 

12 hazardous air pollutants emissions from these 

13 facilities already exist. Recently the Minnesota 

14 Department of Health indicated infants born to 

15 people in the vicinity of the Iron Range and North 

16 Shore of Lake Superior have greater mercury burdens

17 in their bodies than residents in other areas of the 

18 state. This may be the result of low-level local 

19 mercury emissions already coming from taconite 

20 processing. 

21 We encourage the industry, the State of 

22 Minnesota, and the EPA to undertake further 

23 research. Answers are needed about the associated 

24 impacts that will occur as a result of the proposed

25 rules effects on HAPs emissions to ensure continuous 

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1 improvement in local public health and reduction of

2 toxic pollution downwind and downstream from the 

3 taconite and iron ore industry. 

4 In closing, while we welcome the changes 

5 being proposed here, we're also -- we also note that 

6 there is sufficient evidence to require further 

7 investigation into the potentials for HAP emission 

8 increases and the need to address these as well. 

9 We will submit further documentation if 

10 needed on the issues related to impacts of mercury 

11 on the Iron Range and North Shore as well as other 

12 related information about our concerns. 

13 Thank you, and I appreciate this 

14 opportunity to speak. 

15 MR. ABURANO: Just a clarifying question. 

16 Do you have any -- I understand you'd be willing to

17 share information about the effects of mercury that

18 are currently found there. Do you have anything 

19 supporting what you said about the increase in 

20 temperature increasing the HAPs that would be 

21 emitted? Are there any studies or things you could

22 share with us? 

23 MR. ROHDE: Yes. We can -- I don't have 

24 them with me. I would be more than happy to submit

25 those to you before the deadline. 

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1 MR. ABURANO: That would be great. Thank 

2 you. Appreciate that.

3 MR. WAGNER: Could you identify the 

4 organization you represent? 

5 MR. ROHDE: Yes. The Canary Party and 

6 also Safe Mines Institute. 

7 MR. LEON: Mr. Reuther. 

8 MR. REUTHER: Yeah. Thank you. Good 

9 morning. Is this on? 

10 MR. ABURANO: If a red light is on, then 

11 you're muted. So if you press the button and it is

12 not lit, then you should be on.

13 MR. REUTHER: I think it's on now? 

14 MR. ABURANO: Yep.

15 MR. REUTHER: Okay. Great. I'm Kevin 

16 Reuther. K-E-V-I-N. R-E-U-T-H-E-R. I'm the legal

17 director for the Minnesota Center for Environmental

18 Advocacy, MCEA. We, along with a number of other 

19 conservation and public health organizations, 

20 submitted lengthy comments in the technical review 

21 to you in response to the proposed rule. Those 

22 groups include the National Parks Conservation 

23 Association, Voyageurs Park -- Voyageurs National 

24 Park Association, the Friends of the Boundary Waters 

25 Wilderness, Fresh Energy, and also the Sierra Club. 

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1 Our organizations represent thousands of 

2 members here in Minnesota. And we thank you, EPA, 

3 for rejecting MPCA's haze SIP. We value cleaner air 

4 and also clearer air. And the haze rule, of course, 

5 is primarily about scenic views and ridding our 

6 national treasures of the visibility impairments 

7 that they now suffer, but it's also about public 

8 health and the benefits that will be gained by 

9 reducing emissions. These same pollutants cause --

10 that cause haze cause well-documented diseases, lung 

11 diseases, heart attacks. You're very familiar with

12 that, as are we. 

13 Minnesota's Class I areas are iconic 

14 places, and they belong to everyone; and the 

15 taconite industry has for decades been polluting 

16 these areas. The data in your record developed by 

17 the MPCA show that Minntac, for example, just one of 

18 these plants alone, affects visibility in the 

19 Voyageurs National Park more than 50 percent of the

20 days of the year. There are clearly cost-effective

21 controls that can eliminate some of that smog; and 

22 taconite has for decades evaded control, while other 

23 industries have made great progress on pollution 

24 reduction. It's time now for the taconite industry

25 to invest in modern controls and stop polluting the

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1 public's air and the public's parks. 

2 In fact, there isn't really anything that 

3 aggressive or novel about EPA's action here. If 

4 anything, it is long overdue. So we thank you for 

5 rejecting the MPCA plan, which required nothing at 

6 all of this industry. 

7 Now that being said, we believe there are 

8 additional cost-effective technologies that could 

9 reduce pollution further. And we will be submitting 

10 comments to you by the comment deadline in mid 

11 September, but I'll just summarize the two main ones 

12 that we see in the proposed rule. 

13 First, with regard to SO2, EPA did not 

14 evaluate alternative fuels; and, instead, the 

15 proposed rule seems to defer to industry's view that 

16 BART doesn't include fuel switching. But that's not 

17 the case. And, in fact, EPA has in a number of 

18 other instances required fuel switching as BART. So 

19 we will develop that argument in our written 

20 comments. 

21 With regard to NOx, EPA did not evaluate 

22 SCRs, and the proposed rule cites to U.S. Steel as 

23 having demonstrated that SCRs are infeasible. 

24 However, in our original comments -- and this will 

25 be developed further -- we detailed the 

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1 insufficiencies of the study relied on in 

2 disregarding SCRs. And so we would challenge EPA to 

3 take another look at SCRs and the feasibility of 

4 SCRs in this context. 

5 In summary, our organizations and our 

6 members fully support EPA's action to require 

7 taconite to reduce its pollution of Voyageurs 

8 National Park and the Boundary Waters wilderness, 

9 and we find that these minimal controls are long 

10 overdue. Thank you.

11 MR. LEON: Thank you very much. 

12 MR. ABURANO: Just a reminder to any 

13 subsequent speakers, please remember to state your 

14 name and spell out your name for the court reporter. 

15 And also I know that, you know, a lot of people 

16 talking about government regulations also have a lot 

17 of acronyms. So if you're going to use an acronym 

18 like BART or SCR, you know, best-available retrofit

19 technology or selected catalytic reduction, please,

20 for the court reporter's benefit, spell out the 

21 acronym or define the acronym that you're using, 

22 just for the people that aren't involved in 

23 government as much as some of us are on a day-to-day 

24 basis. Thank you. 

25 MR. LEON: All right. I'd like to call 

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1 up the next two speakers. Wayne Dupuis and Scott 

2 Gischia. 

3 Wayne Dupuis, go ahead. 

4 MR. DUPUIS: Good morning. My name is 

5 Wayne Dupuis. It's W-A-Y-N-E, D-U-P-U-I-S. I am 

6 from the Fond Du Lac Reservation. I'm an 

7 environmental program manager there. And appreciate 

8 your time this morning. I'd like to read what we've 

9 -- we're submitting. 

10 The Fond Du Lac Band has been involved 

11 for the past several years in working towards the 

12 implementation of the requirements of the regional 

13 haze rule, which was promulgated in 1999. The Band

14 was a member of the Central Regional Air 

15 Partnership, CENRAP, Coalition in nine states, 

16 federal land managers, industry groups, and several

17 tribes for a number of years, the staff serving as 

18 the secretary/treasurer of this organization. 

19 During the time that CENRAP was active, staff 

20 participated in numerous face-to-face meetings and 

21 conference calls on this topic. 

22 We appreciate the time and effort that 

23 Region 5 has put into reviewing the regional haze 

24 state implementation plan submitted by the Minnesota 

25 Pollution Control Agency and the Michigan Department 

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1 of Environmental Quality and in subsequently issuing 

2 a federal implementation plan that replaces the 

3 portion of these SIPs that were found to be 

4 inadequate. 

5 Regional haze is a matter of concern to 

6 the Band because two of the areas affected by the 

7 regional haze rule, the Boundary Waters Canoe Area 

8 and the Wilderness Area and Voyageurs National Park

9 lie within the Band's treaty-ceded territories. 

10 Treaty-ceded territories consist of roughly 8 

11 million acres in the arrowhead portion of Minnesota

12 that were ceded by the Band and other Lake Superior

13 Chippewa bands, the United States Government, and 

14 the 1854 Treaty of La Pointe, together with the 

15 territory ceded to the United States Government in 

16 the 1837 Treaty of St. Peters where the Band retains 

17 usufructuary rights, including hunting, fishing, and 

18 gathering. The Band believes that the application 

19 of the requirements of the regional haze rule will 

20 protect these lands not only from visual degradation 

21 but also from additional effects of haze-causing 

22 pollutants such as the potential acidification and 

23 nitrification of the water resources as well as 

24 deleterious effects on soil, plants, and wildlife. 

25 For the following four reasons the Band 

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1 strongly supports the FIP proposed by Region 5, 

2 particularly with regard to Region 5's determination 

3 that low NOx burners are best-available retrofit 

4 technology for taconite facilities. 

5 First, Region 5's analysis shows that 

6 this option is technically feasible as these burners 

7 have already been installed on U.S. Steel Minntac's

8 grate kiln furnaces and are being installed on 

9 Essar's straight-grate kiln furnaces. While some 

10 taconite facilities utilizing straight-grate kiln 

11 furnaces are concerned about how this technology 

12 will translate to these furnaces, the bench scale 

13 pilot study performed at SR, as well as SR's 

14 willingness to move ahead with full-scale 

15 construction of this technology, demonstrates this 

16 should not be a problem. The vendors who design and 

17 install low NOx burners also do not anticipate 

18 problems in installing their product in 

19 straight-grate kiln furnaces. 

20 Second, low NOx burners have been shown 

21 to be affordable with control costs estimated at 

22 roughly $500 per ton, which is well within the range 

23 of costs that have been deemed affordable for BART 

24 by both the states and the EPA. 

25 Third, low NOx burners are a wise control 

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1 choice because they prevent NOx from being formed in 

2 the first place, rather than just collecting the 

3 pollutant after it has been produced, which is a key 

4 concept in pollution prevention. Selection and 

5 disposal of pollutants can lead to secondary 

6 environmental problems as well as increased energy 

7 consumption by the control device. It is also 

8 advantageous that low NOx burners do not lead to 

9 increased use of fuel whereby additional pollutants

10 could be generated, including greenhouse gas 

11 pollutants. 

12 Fourth, in addition to the compelling 

13 results of the BART determination, the Band contends 

14 that installation of these burners is an equity. 

15 Based on the fact that U.S. Steel Minntac and SR 

16 have already made the commitment to low NOx burners

17 and have taken the majority of the burden of 

18 demonstration upon themselves, it would be unfair to 

19 allow other facilities to upgrade without having to

20 install this technology. 

21 The Band also supports the installation 

22 schedule that Region 5 has proposed. It is our 

23 understanding that product vendors anticipate 

24 roughly a six-month design time for each line and an 

25 installation time of about a week per line. With 

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1 the numerous delays that have been encountered in 

2 implementing the regional haze rule, we believe it 

3 is reasonable and desirable to require installation

4 of low NOx burners on the schedule that is being 

5 proposed. 

6 We want to thank you for your careful 

7 review of regional haze in northeastern Minnesota. 

8 We appreciate the time you've given us. 

9 MR. ABURANO: Thank you. 

10 MR. LEON: Thank you. 

11 Scott Gischia. 

12 MR. GISCHIA: Morning. My name is Scott 

13 Gischia. S-C-O-T-T. G-I-S-C-H-I-A. I'm the 

14 director of environmental compliance for Cliffs 

15 Natural Resources U.S. iron ore operation. 

16 My comments here today will be expanded 

17 upon by several others and ultimately supported by 

18 written comments by Cliffs, but Cliffs believes it 

19 important to briefly highlight some of the terms 

20 here today and appreciate the opportunity. 

21 By way of introduction, Cliffs Natural 

22 Resources is a 160-year old U.S. company whose goal

23 is responsible mining of products that support the 

24 steel industry. Iron ore is the key ingredient to 

25 making steel. And the whole of the United States' 

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1 domestic iron ore reserves originate from only eight 

2 facilities in the entire country. Cliffs' three 

3 Minnesota and two Michigan operations represent the

4 backbone of our company, rated to produce 32 million 

5 tons of iron ore annually, which represents nearly 

6 two-thirds of the entire domestic supply of iron 

7 ore. 

8 Cliffs employs nearly 6,000 men and women 

9 across the U.S., with both direct and indirect 

10 impact on the economies in these areas of roughly $2 

11 billion annually. 

12 First and foremost I'd like to emphasize 

13 that emissions reduction are an important part of 

14 Cliffs overall business strategy, whether to pave 

15 the way for future expansion opportunities because 

16 of the recently updated national ambient air quality 

17 standards or in recognition of concerns from a 

18 variety of stakeholders. Emissions reductions 

19 simply make good business sense. And in that light

20 Cliffs has similar goals as many others interested 

21 in this issue. 

22 Cliffs' concerns, however, with the 

23 reductions approach presented by the draft regional

24 haze federal implementation plan that is based on 

25 serious technical flaws fails to recognize the 

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1 complexities involved with each unique taconite 

2 furnace, departs from EPA's own guidance for 

3 implementation of BART, bypasses due process at a 

4 number of stages, most significantly presents a 

5 serious risk to Cliffs' product quality which is 

6 central to the sustainability of any producer like 

7 Cliffs that must sell product to the open market, 

8 and all under a time frame that fails to recognize 

9 the necessary design and engineering steps required

10 to develop well thought out sustainable approaches 

11 for this industry. 

12 You recall that BART is designed as the 

13 first step of a 60-year program to improve 

14 visibility. It's not a health-related standard. It 

15 secured a quick available retrofit to subject 

16 facilities. To the extent that the proposed FIP 

17 suggests technologies that inherently challenge the

18 viability of the business, it is outside the scope 

19 and intent of BART. 

20 While Cliffs presents these concerns as 

21 facility operators, they are equally echoed by the 

22 designers of the underwriting processes whom Cliffs

23 would call upon to attempt to effect the changes 

24 considered by the FIP. The technology simply is not 

25 available to the industry at this point in time; and 

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1 the timeframes proposed by EPA are, quite simply, 

2 unrealistic. Emissions reductions of some scale, 

3 however, are always possible; and Cliffs embraces 

4 that idea as part of its current and future 

5 operations, but it is irresponsible of EPA to 

6 promote expectations that are not based on the 

7 available technical and knowledge base, especially 

8 when those expectations could negatively impact the

9 quality and marketability of the product. 

10 The Clean Air Act designates the states 

11 as the primary responsibility for determination of 

12 BART. Cliffs requests that EPA recognize the time,

13 energy, and ultimately the reasonable approaches put 

14 forward by both Michigan Department of Environmental 

15 Quality and Minnesota Pollution Control Agency as 

16 the first steps of the regional haze plan and that 

17 EPA validates those state implementation plans. 

18 This concludes my comments here today. 

19 Thank you for the opportunity to enter this into the 

20 record. 

21 MR. ABURANO: Thank you. 

22 MR. LEON: Thank you very much. 

23 I'd like to call up the next couple of 

24 speakers, Mike -- is it -- 

25 MR. MLINAR: Mike Mlinar.

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1 MR. LEON: -- Mike Mlinar, okay, and Doug 

2 Williams. 

3 MR. MLINAR: Good morning and thank you 

4 for the opportunity to speak this morning. My name

5 is Mike Mlinar. That's M-I-K-E, M-L-I-N-A-R. And 

6 I'm vice president for Cliffs Natural Resources 

7 North America Iron Ore Initiatives, and in this 

8 position I have responsibility for the U.S. iron ore 

9 and eastern Canadian operations initiative endeavors 

10 to improve efficiency, look at alternative products, 

11 and improve overall performance. 

12 Before this position I was the vice 

13 president and general manager for the North Shore 

14 Mining Company, the Hibbing Taconite Company, the 

15 United Taconite Company in Minnesota, and prior to 

16 that was the vice president and general manager for

17 the two Michigan mines, the Tilden Empire and 

18 Michigan's Upper Peninsula. Therefore, with over 

19 35 years of experience as a professional engineer 

20 and manager of iron ore mining and taconite 

21 processing facilities, I have a thorough 

22 understanding of the process technology that's used

23 to convert iron-ore-bearing rock into higher 

24 iron-bearing pellets needed for our customers' 

25 fuel-making facilities. 

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1 I'm here today to provide a perspective 

2 on the operation on pellet product quality impacts 

3 of USEPA's proposed regional haze federal 

4 implementation plan for the taconite industry. As 

5 Scott Gischia explained, Cliffs understands and we 

6 accept our role and the important objective to 

7 reduce regional haze impacts, and we have 

8 contributed significantly to the gradual reduction 

9 in these emissions. We remain committed to further

10 reducing emissions that contribute to the formation

11 of regional haze. We do have a strategic plan that

12 meets the state's long-term strategy outlined in the 

13 state implementation plan to reduce implementations

14 that contribute to regional haze and request that 

15 the USEPA respect the confidence plan developed in 

16 the SIPs that establish BART and demonstrate 

17 reasonable and significant further progress towards

18 reducing haze emissions and impacts. 

19 We have serious concerns that USEPA's 

20 federal implementation plan concludes that taconite

21 furnaces can successfully be retrofitted to deploy a 

22 pilot technology and achieve emissions limits 

23 without conducting any engineering to determine if 

24 the technology is technically or economically 

25 feasible. This one size-fits-all assumption ignores 

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1 the comprehensive technical evaluations performed by 

2 engineers specializing in the taconite industry and

3 the conclusions independently reached by the states

4 of Minnesota and Michigan which follow the USEPA's 

5 guidance in conducting their technology 

6 determinations. 

7 Even more perplexing, EPA ignored the 

8 Minnesota Pollution Control Agency's firsthand 

9 knowledge of the readiness of this pilot technology

10 and surprisingly determined after years of study by

11 the mining industry and the state agencies that the

12 technology was viable, based upon the opinion of 

13 equipment vendors and others unfamiliar with 

14 potential impacts to the unique heat balance and 

15 product quality aspects. 

16 Finally, the OEM technical resources that 

17 were responsible for designing the heat balance 

18 process are a part of SIP and are the only ones 

19 fully knowledgeable of the unique indurating heat 

20 balance design. None of them were asked to conduct

21 any engineering evaluation for the EPA to assess the 

22 feasibility that validates this one-size-fits-all 

23 conclusion. 

24 Each of our taconite indurating furnaces 

25 are unique. None are the same. Each furnace is 

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1 engineered to process its unique iron ore bodies to

2 meet its customers' specifications that are all 

3 dependent on a carefully engineered, heat balanced 

4 distribution. 

5 Retrofitting existing burners from a low 

6 stoic design to a high stoic design, which is the 

7 current generation being pilot trialed at 1 grate 

8 kiln process, requires more primary combustion air 

9 to be introduced into the burner to cool the plane 

10 and reduce NOx emissions. This early generation of

11 low NOx burner pilot is being developed to resolve a 

12 singularly-focused NOx compliance issue at one 

13 taconite facility and creates other potential 

14 negative consequences that have not been evaluated 

15 by the USEPA and would not satisfy BART criteria. 

16 For example, according to the OEM 

17 engineers that are expert in the grate-kiln heat 

18 balance design, the NOx FIP would have a couple of 

19 detrimental impacts. First, the increase of fuel 

20 switching by up to 60 percent would lead to 

21 collateral increase in related combustion emissions; 

22 and, secondly, they would produce an altered flame 

23 temperature profile, which has negative collateral 

24 impacts on our quality process. 

25 In conclusion, we ask that the EPA 

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1 withdraw the proposed FIP for the taconite 

2 facilities in Minnesota and Michigan and approve the 

3 state SIPs which establish legitimate BART 

4 determinations, and of course the reasonable further 

5 progress to limit emissions that reduce visibility 

6 impacts. 

7 Thank you for the opportunity to listen. 

8 MR. ABURANO: Thank you. 

9 MR. LEON: Mr. McWilliams. 

10 MR. MCWILLIAMS: Thank you. My name is 

11 Douglas McWilliams. D-O-U-G-L-A-S. McWilliams, 

12 M-C-W-I-L-L-I-A-M-S. And I'm outside counsel -- 

13 outside environmental counsel, Squire Sanders U.S.,

14 and Cliffs Natural Resources has asked that I 

15 provide some comments for the record on the proposed 

16 regional haze federal implementation plan and to 

17 encourage USEPA to withdraw its FIP and, instead, 

18 approve the state implementation plans for the 

19 taconite industry. 

20 The Clean Air Act establishes different 

21 rules for USEPA and states. The DC Circuit Court of 

22 Appeals recently described the relationship as 

23 follows, and I quote: Under the Clean Air Act the 

24 federal government sets air quality standards, but 

25 states retain the primary responsibility if the 

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1 states want it for choosing how to attain those 

2 standards within their borders. The act, thus, 

3 leaves it to the individual states to determine in 

4 the first instance the particular restrictions that

5 will be imposed on the particular emitters within 

6 their borders. If a state refuses to participate, 

7 the federal government regulates the sources 

8 directly, closed quote. 

9 Minnesota and Michigan did not refuse to 

10 participate; and, to the contrary, these states 

11 invested significant resources over many years to 

12 develop their regional haze state implementation 

13 plans for the taconite industry, demonstrating 

14 clearly that they were willing to exercise their 

15 primary responsibility to develop valid state plans. 

16 The primary role for states is very clear 

17 in the regional haze provisions of the Clean Air Act 

18 as well. In 1977 Congress added visibility 

19 protection in Section 169A of the act. Congress 

20 actively debated whether to place EPA or the states

21 in charge of implementing the regional haze program, 

22 and Congress chose the states. The DC Circuit Court 

23 recently reviewed the legislative history of the 

24 visibility protection provisions of the act and 

25 concluded, again I quote: Congress intended the 

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1 states to decide which sources impaired visibility 

2 and what BART controls should apply to those 

3 sources, closed quote. 

4 The Court then decided that EPA's 1999 

5 regulations, regional haze rules, were invalid 

6 because they deprived the states of some of the that 

7 statutory authority. EPA's proposed FIP is another

8 attempt to deprive states of their statutory 

9 authority and the primary role in choosing how to 

10 achieve the regional haze goals within their 

11 borders. This time EPA is second-guessing the 

12 best-available retrofit technology determinations, 

13 or BART determinations, submitted by Minnesota and 

14 Michigan for taconite furnaces not because the 

15 states did something wrong, but because new 

16 information has been presented that was not 

17 available when the states arrived at their BART 

18 technology determinations and which still has not 

19 been peer reviewed or subject to evaluation by the 

20 affected stakeholders. 

21 EPA reviews SIPs to determine if they 

22 meet clean air criteria. And if the state process 

23 fails to produce a compliant SIP, EPA can produce a

24 FIP. That's not what happened here. EPA had 

25 proposed approving the Minnesota SIP for taconite 

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1 furnaces on January 25th of 2012. EPA changed 

2 directions and is proposing a FIP because it thinks

3 it has a better idea for BART that is based on newer 

4 data that it believes will reduce emissions and 

5 reach regional haze goals faster than the state's 

6 plan. 

7 Based on our preliminary review, it is 

8 premature to make any regulatory decisions based on

9 this new information, as others have indicated. 

10 But, more importantly, EPA's limited authority under 

11 the Clean Air Act does not authorize it to impose a

12 FIP because it thinks it has a better idea. That 

13 undercuts Congress' decision to give states the 

14 primary role in determining BART for sources within

15 their borders. 

16 EPA cannot rely on new information as the 

17 basis for claiming that the SIP is deficient. EPA's 

18 own guidelines, Part 51, Appendix Y, directs states

19 to stop considering the evolution of available 

20 technologies after they close public comment on 

21 their state's BART determination. Minnesota's BART

22 determination for taconite furnaces closed in 2009,

23 and Michigan's closed in 2010. EPA's proposed BART

24 FIP is based on questionable new information that 

25 was submitted for consideration in 2011 and 2012. 

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1 EPA cannot fault the states for following federal 

2 guidance, particularly when that guidance promotes 

3 the common sense position that states must be able 

4 to choose an endpoint for finalizing their BART 

5 determination to ensure there is an end to the 

6 regulatory process. 

7 May I ask for your discretion to have a 

8 few more minutes to complete my comments? 

9 MR. ABURANO: Sure, go ahead. 

10 MR. MCWILLIAMS: Thank you. The proposed 

11 FIP also approves -- or proves, rather, the wisdom 

12 of Congress' decision to leave BART determinations 

13 in state hands. The taconite industry is unique to

14 the Iron Range that extends across northern 

15 Minnesota and into the upper peninsula of Michigan. 

16 These two states, Michigan and Minnesota, have 

17 decades of direct experience regulating taconite 

18 compliance and pelletizing furnaces that EPA 

19 cannot -- cannot hope to replicate. 

20 Minnesota and Michigan are in a better 

21 position to assess the time and resources that it 

22 will take to evaluate the next generation of 

23 emission controls for this industry. The states 

24 appropriately chose a more conservative and measured 

25 approach to the initial BART determination. EPA has 

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1 a statutory obligation to approve these legitimate 

2 state decisions and should withdraw its proposed 

3 FIP. 

4 Importantly, though, Minnesota's approach 

5 does not foreclose additional NOx reductions in the

6 future as part of the state's long-range regional 

7 haze strategy. In fact, Minnesota has required 

8 these taconite furnaces by the end of this year to 

9 offer NO2 modeling and offer NOx emission controls 

10 as necessary to meeting ambient concentrations of 

11 NO2. 

12 To the extent that NOx emission reduction 

13 strategies are necessary to achieve these 

14 health-based national standards, the reductions are

15 also expected to help meet the regional haze goals 

16 of the Clean Air Act. This approach allows the 

17 industry and its vendors more time to evaluate 

18 emission control options and their effect on health

19 quality, preserving energy efficiencies, and 

20 sustaining pellet production at economically-viable

21 levels. 

22 EPA's FIP usurps the state's reasoned and 

23 measured path forward and replaces it with a frenzy

24 federal plan with inadequate support, and we have 

25 just 44 days on which to comment. Vendors are 

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1 telling us that they need more time. Vendors are 

2 telling us they need months to design a burner 

3 system that might work for each furnace, more months 

4 to determine the rate of emission reduction that 

5 that is likely to achieve, and even more months to 

6 assess the true cost of retrofit emission controls. 

7 Modelers are telling us they need more time than 

8 remains in the comment period to perform the 

9 visibility analysis that EPA should have done to 

10 support its BART FIP determination. EPA should 

11 extend the comment period to ensure that it will get 

12 the quality of information necessary to critically 

13 evaluate the proposed control technology. 

14 To close, we ask that EPA approve the 

15 SIPs, withdraw the proposed federal implementation 

16 plan for the taconite facilities in both Minnesota 

17 and Michigan. 

18 Thank you for your time. 

19 MR. ABURANO: Thank you. One clarifying 

20 question. At the beginning of your statement you 

21 talked about a court ruling -- 

22 MR. MCWILLIAMS: Yes.

23 MR. ABURANO: -- that you quoted from. 

24 Can you tell us which court ruling it was? 

25 MR. MCWILLIAMS: The first one was EME 

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1 Homer versus EPA, DC Circuit 2012 vacating the 

2 cross-state air pollution rule. There was a brief 

3 second quote, and that is from American Corn Growers 

4 versus USEPA, 291 F.3d 1, DC Circuit 2002. 

5 MR. ABURANO: Thank you. 

6 MR. LEON: Thank you. 

7 I'd like to call up George Pruchnofski 

8 and Allen Miller.

9 Go ahead, Mr. Pruchnofski. 

10 MR. PRUCHNOFSKI: Is it working? Oh, the 

11 red light should be on for it to be working? 

12 Good day. My name is George Pruchnofski. 

13 My last name is spelled P-R-U-C-H-N-O-F-S-K-I. I'm

14 a principal engineer with Barr Engineering Company. 

15 Barr has a unique and long-term perspective on the 

16 regional haze SIP BART implementation plans -- BART

17 is the best-available retrofit technology -- that 

18 was developed for the taconite industry in Minnesota 

19 and Michigan. 

20 In 2006 Barr helped the taconite industry 

21 respond to the original state's request for BART 

22 technology determinations. In 2003 Barr provided a

23 report to MPCA, the Minnesota Pollution Control 

24 Agency, on the state of retrofit technology for the

25 taconite industry. The MPCA attached that report to 

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1 their BART determinations in 2009 when they 

2 concluded that good combustion practices constituted 

3 BART from NOx submissions and existing controls 

4 constituted BART for SO2 emissions. 

5 Michigan relied on Barr's work for 

6 Minnesota to render its BART determination in 2010 

7 for the lone taconite furnace that is subject to 

8 regional haze regulation emission. Barr also 

9 provided support to the state process in 2011-2012 

10 that converted the state technology determinations 

11 into enforceable numerical limits using available 

12 test data. 

13 Throughout this process we witnessed the 

14 Minnesota Pollution Control Agency proceeding 

15 through a complete, lengthy, and legitimate SIP 

16 development process consistent with state and 

17 federal regional haze guidance. This includes the 

18 federal BART guidance published at 40 CFR Part 51, 

19 Appendix Y, and the Minnesota guidance that adopts 

20 the Appendix Y criteria and is called Guidance For 

21 Facilities Conducting a BART Analysis, March 2006. 

22 We are not aware of any errors or flaws in 

23 Minnesota's BART SIP process, and USEPA does not 

24 claim in its proposed federal implementation plan 

25 that Minnesota made errors or flaws leading up to 

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1 its emission of its regional haze state 

2 implementation plan in December 2009. 

3 USEPA points to new information made 

4 available to USEPA in the comment period on its 

5 proposed approval of the Minnesota SIP in January of 

6 2012. This new information was not available to 

7 Barr when we were preparing the BART SIP technology

8 reviews for taconite facilities. 

9 According to USEPA's own guidance, 

10 Minnesota was allowed to close this review of BART 

11 technologies when it closed public comment on the 

12 December 2009 SIP because -- to quote, Because a new 

13 technology may become available at various points in 

14 time during the BART analysis process, we believe 

15 that guidelines are needed on when the technology 

16 must be considered. In order to provide certainty 

17 to the process, all technologies should be 

18 considered, if available, before the close of the 

19 state's public comment period. You need not 

20 consider technologies that become available after 

21 this date, end quote. 

22 MPCA reasonably followed federal 

23 guidelines to develop its SIP based on the 

24 information available at the time. It would be 

25 inconsistent with federal guidance to require that 

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1 the SIP be reopened to consider this new 

2 information. But USEPA seems to be willing to 

3 propose a FIP based solely on this new information. 

4 That doesn't make sense to me. 

5 After thorough, intense, and lengthy 

6 reviews and additional evaluations required by the 

7 states, BART for nitrogen oxides controls was 

8 determined to be good operating practices for 

9 furnaces as determined on a furnace-specific basis. 

10 Now USEPA's proposed FIP relies on technologies that 

11 were not available, demonstrated, or were not 

12 permitted when the BART SIPs were submitted to USEPA 

13 in 2009 and 2010 for Minnesota and Michigan 

14 respectively. 

15 After similarly thorough, intense, and 

16 lengthy reviews and additional evaluations required

17 by the states, the SIPs determined that BART for 

18 sulfur dioxide control was existing controls without 

19 additional add-on emissions controls, in large part

20 based on cost considerations. The cost evaluations

21 were completed by professionals with experience in 

22 cost estimating for iron industry furnaces and 

23 emissions controls. These cost evaluations factored 

24 in the significant cost of ancillary changes that 

25 would need -- would be needed at the existing 

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1 facilities through use of a retrofit factor based on 

2 a professional's experience. However, for the 

3 proposed FIP USEPA has disregarded these evaluations 

4 and decided to complete the new cost evaluations 

5 that are currently incomplete and significantly 

6 underestimate the cost of installing the controls at 

7 an existing facility. 

8 May I have one more minute, please, sir? 

9 Thank you. 

10 USEPA is now asking that any objections 

11 to this incomplete cost evaluation be supported by 

12 vendor information. EPA should have fully completed 

13 its cost effectiveness analysis prior to making its

14 proposed determinations of BART in its proposed FIP. 

15 Our experience is that it will take months to gather 

16 the vendor information and complete the evaluations

17 USEPA is requesting at the detail they want. For 

18 new technologies applied to complex furnaces, the 

19 time to conduct the demonstrations needed for 

20 clients to get guaranteed emission rates and 

21 determine true costs could take considerably more 

22 time. 

23 My last two comments are very brief. One 

24 is that our preliminary review of the FIP appears -- 

25 our preliminary review of the FIP, it appears that 

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1 USEPA is making several optimistic assumptions that

2 are underestimating the dollar-per-ton reduction 

3 improvement costs and also the dollar-per-deciview 

4 cost and will take time to get this sorted out. 

5 We'll be providing those comments for our clients 

6 for inclusion in their comments. 

7 And finally we have a final concern that 

8 in some cases USEPA may be establishing its proposed 

9 BART emission limits in the FIP based on average 

10 emissions, which means that roughly half the time 

11 actual emissions would be greater than the limit, 

12 resulting in noncompliance. Technology-based 

13 emission limits always includes some margin of 

14 safety to ensure that operations will achieve 

15 continuous compliance. We are concerned that the 

16 proposed FIP does not fully take this consideration

17 into account. 

18 Thank you so much for your time, allowing 

19 me to finish the comments into the record. 

20 MR. LEON: Thank you, Mr. Pruchnofski. 

21 Mr. Miller. 

22 MR. MILLER: Good morning. My name is 

23 Allen Miller. I live at 1110 West Avenue in 

24 Red Wing, Minnesota. I previously submitted some 

25 comments in this proceeding in the form of a letter

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1 to Administrator Jackson dated February 24th, 2012; 

2 and I'd like that to be included in the docket, if 

3 it isn't already. 

4 I think that anyone who's watched this 

5 proceeding, which has dragged out, in effect, for 

6 many years, and looked at it objectively would have

7 to recognize that what's fundamentally going on here 

8 is that the political influence of the mining 

9 industry in Minnesota has outweighed the integrity 

10 of the regulatory process in Minnesota. And 

11 although it's not pleasant to say this, in effect 

12 the MPCA is fronting for the industry rather than 

13 carrying out its responsibilities, particularly 

14 those responsibilities delegated to it by the region 

15 and the agency. 

16 So I want to thank you for being here 

17 today, for bringing forward the federal 

18 implementation plan. I think we're all aware that 

19 this is not something that is done commonly or 

20 lightly by EPA, but the need for it in this case in

21 my opinion is indisputable. And that's very clearly 

22 shown by the testimony on both sides that we've 

23 heard so far this morning. 

24 So I support the FIP, as you have brought 

25 it forward; but it also seems to me, as Mr. Reuther

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1 suggested, that it is a very conservative, 

2 unaggressive document and there are many places in 

3 which one could arguably push for more aggressive 

4 reductions and stricter limits. And I can submit 

5 written comments on that, those points. But I'll 

6 just mention a couple of them. 

7 You know, you identified the cost per ton 

8 of NOx reductions from the Minntac heating boilers 

9 was 6- to $8,000 a ton. But then for the North 

10 Shore boilers it came out to $723 a ton. Obviously

11 boilers aren't all the same, and the engineering 

12 upgrades can vary quite a bit. But that's the 

13 difference of an order of magnitude in a 

14 fundamentally-similar device, and I would take a 

15 look at that. 

16 I'm concerned about the discussion of 

17 fuel switching and the implications of that. For 

18 example, there have been representations that 

19 burning wood is environmentally beneficial when, in

20 fact, the overall ecological impact of massive 

21 industrial steel wood burning is, in many respects,

22 very negative, and it shouldn't be lightly factored

23 in. 

24 Similarly, the MPCA seems to have been 

25 persuaded in some proceedings that the fuel 

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1 switching to coal was an emissions reduction measure 

2 in which it's argued that lower flame temperatures 

3 of coal reduce NOx emissions. But if one can make 

4 that argument at all, one can do it only by 

5 comparing coal to extremely-poorly-designed gas 

6 burners. And it seems to have been done without 

7 much regard for increased emissions of sulfur 

8 oxides. So, again, I think that is a subject that 

9 could use a little bit more exploration. 

10 I am concerned that some of the limits in 

11 the FIP seem to exclude oil burning. I won't go on

12 to specific cites, but one says these limits do not

13 apply when burning fuel oil. And that might seem 

14 fairly innocuous because of today's prices, nobody's 

15 going to burn much fuel when they have access to 

16 natural gas. But anybody who's been alive for more

17 than a few minutes knows that none of us really know 

18 where energy prices are going. So I'm concerned 

19 about setting limits that don't include limits 

20 during periods of gas burning. 

21 Similarly, there are references in the 

22 FIP to the burning of oil with sulfur concentrations 

23 by weight of over 1 percent. That doesn't seem 

24 appropriate to me. Every operating refinery in the

25 world now knows how to desulfurize fuel oil, and 

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50

1 we're seeing a broad movement across sectors and 

2 industries towards much lower levels of sulfur in 

3 fuel oil. So I think that's something that ought to 

4 be looked at if you're going to allow fuel oil. 

5 Burning -- particularly if you're going to exempt 

6 fuel oil burning periods from regulatory limits, you 

7 ought to specify clean fuel oil. 

8 And I'll just wind up then with this 

9 comment: That I am reasonably satisfied, based on 

10 the amount of time I've been able to spend on this,

11 that low NOx burners are appropriately identified as 

12 BART for the control of nitrogen oxide emissions. 

13 And when we look at a reduction in baseline levels 

14 from something like 4 pounds per million and BTUs to 

15 1.2, that looks pretty good. But when we look at 

16 the work that's been done on the reduction of sulfur 

17 oxide emissions, I'm less well satisfied. It's not

18 apparent that SCR and SNCR have been adequately 

19 evaluated. It's not clear to me that the use of 

20 spray dryers has been adequately considered. I see

21 that in one place that was found by one operator to

22 be technically feasible and by others not. I would

23 like to see a little bit more information on why 

24 that and other types of scrubbing aren't, in fact, 

25 cost effective. 

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1 So, with that, I'll just close by saying 

2 please go ahead with the FIP; please take a look at

3 opportunities for tightening it up a bit. Thank 

4 you. 

5 MR. ABURANO: Thank you. 

6 MR. LEON: We have -- well, I have one 

7 more name up here. Carol Overland. 

8 MS. OVERLAND: Good morning. My name is 

9 Carol Overland. I'm here on behalf of my company, 

10 Legalectric, l-e-g-a-l-e-c-t-r-i-c. 1110 West 

11 Avenue, Red Wing. And that is a -- I'm an attorney

12 working primarily in transmission issues, so I 

13 haven't had much time to look at this. This is not

14 my specialty. But a few things I wanted to note. 

15 First, I want to thank you for the 

16 opportunity to make comments on this. I've been 

17 peripherally involved in some issues regarding the 

18 Minnesota Pollution Control Agency, and the agency 

19 has consistently taken no action in this specific 

20 case over many, many years. And what I would like 

21 you to consider is that what you're seeing here is 

22 just the tip of the iceberg, and this is a pattern 

23 of behavior on behalf of the Minnesota Pollution 

24 Control Agency. And I'm glad to see the EPA taking

25 action here, and I hope you look further at what's 

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1 happening at the MPCA. 

2 For example, one that I was involved in 

3 was the MPCA did not weigh in on Excelsior Energy's

4 coal gasification project proposed for the Range 

5 near the plants that you're considering here until 

6 my clients had made a motion to drag them into the 

7 proceeding. And at that point they did, after the 

8 instance the pollution -- I mean, the Public 

9 Utilities Commission made a request that they do 

10 participate. And when -- in that case, where the 

11 MPCA saw no problem with haze potential, the EPA did 

12 weigh in. They were concerned about the haze and 

13 the potential for the Mesaba project to increase 

14 haze in the area. So this is another area that's 

15 related where the MPCA is not acting regarding haze

16 and it's not acting generally. 

17 And I ask that you do increase the haze 

18 regulation; and, as Mr. Miller said, tighten it up 

19 and that you go forward with this FIP. 

20 And I ask that the EPA look at the MPCA's 

21 failure to regulate in its delegated role. You 

22 heard a lot from Cliffs about the state's authority, 

23 but that authority has been delegated by the EPA, as 

24 you well know, and the MPCA is not doing its job. 

25 And I -- also, as a process issue I note 

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1 that, you know, look at the time. This is a time 

2 when most people work. And when you have a meeting

3 at this time, what you're going to get is five, six

4 Cliffs people and very few members of the public. 

5 And it does not work for the public. And the EPA 

6 does have a public participation component, and it 

7 would have helped to have at least another session 

8 in the evening so that people could attend, regular

9 people and not paid lobbyists. 

10 And I will submit more detailed comments 

11 by the deadline. And thank you for taking this 

12 action, and thank you for holding this hearing. 

13 MR. ABURANO: Thank you. 

14 MR. LEON: Thank you. 

15 Just a general announcement, if there's 

16 anybody else who would like to make a comment, I'd 

17 like to invite you to come up. 

18 MR. ABURANO: Because I don't think we 

19 have any additional speakers at this point, so 

20 we're -- okay. 

21 MR. LEON: So please state your name and 

22 affiliation, if you have one, and you have five 

23 minutes. 

24 MR. DINSLAGE: All right. Thanks. My 

25 name is Matthew Dinslage. I live in Lakeville, 

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1 Minnesota. 

2 COURT REPORTER: Could you spell that, 

3 please?

4 MR. DINSLAGE: D-I-N, S as in Sam, 

5 L-A-G-E.

6 COURT REPORTER: Thank you.

7 MR. DINSLAGE: And so, yes, I am just a 

8 general constituent of the area, so -- and important 

9 topics, so I made a time out in my schedule to 

10 attend this public hearing, so... 

11 I've listened to a lot of the comments 

12 from a technology standpoint, from an air quality 

13 standpoint. My family and I, we camp quite a bit 

14 all throughout Minnesota. My goal over the years is 

15 to have my kids attend and camp at all the state 

16 parks through the next 18 years, and I think we've 

17 accomplished getting to about 22 of them today. 

18 But I'm also a mechanical engineer. My 

19 wife is a chemical engineer. And we look at things

20 from a very process-oriented and technical 

21 standpoint. If you look at the ways that the EPA 

22 and the emission reductions have taken place on 

23 highway diesel engines globally, from a marine 

24 shipping standpoint and then also just from the 

25 power production plants throughout the United 

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1 States, the number of OEMs and the number of 

2 analysis and data analysis that has gone into those

3 emission reduction standards over the years is quite 

4 dramatic. When you look at the on-highway diesel 

5 engine market, you have probably seven to ten large

6 OEMs who have input -- or invested millions and 

7 millions of dollars at looking at different 

8 technologies to get to the point where we are today

9 in terms of particulate matter reduction and SOx and 

10 NOx emissions. 

11 If you look at the marine industry for 

12 the numbers of ships throughout the globe, again, 

13 the numbers of OEMs and the dollars spent and the 

14 amount of fuel used in that industry is staggering,

15 much higher than the CVL on highway industry. 

16 When you look at the number of power 

17 plants in the United States, the over 16 million 

18 gigawatts of power generated and the numbers of OEMs 

19 that put in millions and billions of dollars of 

20 research to get to the emission reductions we are 

21 today is staggering as well. 

22 When you look at the taconite industries, 

23 there are just a handful of OEMs that are in this 

24 job. And when you look at the taconite industry or

25 iron ore industry from a global standpoint, most of

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1 the iron ore developed throughout the U.S. -- 

2 throughout the world is dug out of the ground and 

3 put right into the mill -- or right into the 

4 steel-making process. Here we have to go through a

5 taconite process to refine and to purify that to a 

6 much greater concentration of ore, which there is 

7 very few OEMs and very few people invested into that 

8 industry. 

9 So the amount -- when I hear a lot of the 

10 research that has started to go out there in terms 

11 of reduction in some of these furnaces, these 

12 furnaces are very unique from one another. Just 

13 like God created each of us as unique individuals 

14 with an individual plan, each one of these 

15 indurating furnaces are very unique in their own 

16 processes. And to apply a standard thought process

17 like is done in the CVL on highway or marine 

18 industry or the power production standpoint, you 

19 can't just brushstroke that across and say if we can 

20 do it here, we should be able to do it here. That's 

21 not going to take. We have to have a very 

22 disciplined approach to meet these next guidelines. 

23 I agree that there should be a guideline, 

24 but I think this FIP should be pushed off and then 

25 looked at and really researched and looked at how 

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1 m u ch m o n e y c a n b e s p e n t o n d e v e lo p in g th is 

2 te ch n o lo g y , w h a t te c h n o lo g y is g o o d , b e c a u s e ju s t 

3 ta kin g o n e -o f f te c h n o lo g y th a t h a s n o t b e e n 

4 im plem e n te d o r re s e a r ch e d o r v e t te d p ro p e rly is n o t

5 g o o d fo r th e in d u s try . 

6 T h a n k y o u fo r y o u r tim e . 

7 M R . A B U R A N O : T h a n k y o u . 

8 M R . L E O N : Is th e re a n y b o d y e ls e 

9 in te re s te d in m a k in g a c om m e n t? 

10 M R . A B U R A N O : W e c o u ld p ro b a b ly ta k e a 

11 1 5 -m in u te b re a k th e n . A n d if a n y o n e e ls e w o u ld like 

12 to g iv e te s tim o n y , p le a s e s e e S a ra h to g e t o n th e 

13 s p e a k e r lis t o r ju s t le t u s k n ow in th e n e x t 

14 1 5 m in u te s a n d y o u c a n h a v e th e o p p o r tu n ity to 

15 s p e a k . 

16 T h a n k y o u . 

17 (B re a k from 1 1 :1 1 to 1 1 :2 9 .) 

18 M R . A B U R A N O : I'd lik e to re o p e n th e 

19 p u b lic h e a rin g a t th is p o in t. T h e 1 5 -m in u te b re a k 

20 is o v e r . S o if p e o p le c o u ld ta k e th e ir s e a t s , w e 'd

21 lik e to re s ta rt th e p u b lic h e a rin g . 

22 A g a in , if th e re a re p e o p le th a t w o u ld 

23 lik e to g iv e te s tim o n y to d a y th a t h a v e n o t sig n e d up 

24 to d o s o , p le a s e s ig n u p a t th e re g is tra tio n d e s k at 

25 th e d o o r . 

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1 H e rib e r to w ill g o o v e r th e k in d o f g ro u n d 

2 ru le s th a t w e 're p ro c e e d in g to d a y in giv in g p u b lic 

3 te s tim o n y . 

4 M R . L E O N : S o , a g a in , if y o u 're 

5 in te re s te d in g iv in g c om m e n ts th is m o rn in g , w e a s k 

6 th a t y o u ch e c k in w ith th e re g is tra tio n . S a ra h 

7 C e rv a k is a t th e -- b y th e d o o r . A n d w e a s k th a t 

8 w h e n y o u c om e u p th a t y o u m a k e su re th a t y o u s ta te 

9 y o u r n am e a n d s p e ll it o u t fo r u s s o th a t w e c a n g et 

10 a n a c cu ra te tra n s c rip tio n o f th a t in fo rm a tio n , a s 

11 w e ll a s a n y a f filia tio n th a t y o u h a v e . 

12 A n d w e h a v e a c o lo r s ch em e h e re to 

13 in d ic a te th a t y o u m a y b e g in y o u r fiv e -m in u te 

14 te s tim o n y . A t fo u r m in u te s w e h a v e a y e llo w sh e e t 

15 o f p a p e r to in d ic a te th a t y o u h a v e o n e m o re m in u te 

16 to w ra p u p . A n d th e n 1 5 s e c o n d s to 5 m in u te s w e 

17 h a v e th e re d s h e e t o f p a p e r to in d ic a te th a t y o u 

18 sh o u ld b e w ra p p in g u p . S o .. . 

19 M R . A B U R A N O : It lo o k s lik e w e d o n 't h a v e 

20 a n y m o re p e o p le c u rre n tly sla te d to g iv e te s tim o n y . 

21 S o I th in k w e 're g o in g to sit h e re . W e 're re q u ire d

22 to b e h e re u n til 2 :0 0 . T h a t's h o w lo n g th e p u b lic 

23 h e a rin g is g o in g to b e . S o w e w ill w a it fo r 

24 a d d itio n a l s p e a k e rs to sh o w u p . A g a in , w e a re 

25 a c c e p tin g w rit te n c om m e n t s o n th is u n til 

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1 S e p tem b e r 2 8 th . S o th is is n o t th e la s t tim e y o u 'll 

2 b e o f fe re d to - - y o u 'll h a v e a n o p p o rtu n ity to g iv e

3 c om m e n ts . Y o u c a n g iv e it to d a y o ra lly o r w e a re 

4 a c c e p tin g w ritte n c om m e n t s u n til S e p tem b e r 2 8 th . 

5 S o u n til s o m e o n e w a n ts to c om e u p a n d 

6 ta lk , y o u c a n lo o k a t u s . 

7 (B re a k fro m 1 1 :3 2 to 1 2 :0 8 .) 

8 M R . A B U R A N O : B e in g w e h a v e n o s p e a k e rs 

9 a t th e m om e n t, I th in k I'm g oin g to a llo w o u rs e lv e s

10 a 2 0 -m in u te lu n ch b re a k . S o w e w ill b e re c o n v e n in g

11 a t 1 2 :3 0 , I g u e s s . S o if a n y o n e w o u ld lik e to o ffer 

12 te s tim o n y , y o u c a n d o s o a t 1 2 :3 0 o r la te r . T h a n k 

13 y o u . W e 're g o in g to ta k e a lit tle b re a k rig h t n o w .

14 (B re a k fro m 1 2 :0 8 to 1 :4 6 .) 

15 M R . A B U R A N O : W e 're fo rm a lly clo sin g th is 

16 m e e tin g b e c a u s e n o o n e els e is h e re to p re s e n t 

17 te s tim o n y . U n le s s s om e o n e sh o w s u p in th e la s t five 

18 m in u te s , w e a re o f fic ia lly d o n e a c c e p tin g c om m e n ts 

19 a t to d a y 's h e a rin g . 

20 (P ro c e e d in g s c o n clu d e d a t 2 :0 0 p .m .) 

21

22

23

24

25

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1 S T A T E O F M IN N E S O T A )

 ) s s .

2 C O U N T Y O F D A K O T A )

3

4

5 R E P O R T E R 'S C E R T I F IC A T E

6

7

8 I , A n g ie D . T h re lk e ld , d o h e re b y

9 c e rtify th a t th e a b o v e a n d fo re g o in g tra n s c rip t,

10 c o n sis tin g o f th e p re c e d in g 5 9 p a g e s is a 

11 c o rre c t tra n s c rip t o f m y s ten o g ra p h ic n o te s , a n d is

12 a fu ll, tru e a n d c om ple te tra n s c rip t o f th e 

13 p ro c e e d in g s to th e b e s t o f m y a b ility .

14 D a te d S e p tem b e r 1 3 , 2 0 1 2 .

15

16

17

18

 

19 A N G IE D . T H R E LK E LD

 C o u rt R e p o rte r

20

21

22

23

24

25

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$

$500 [1] - 24:22

$723 [1] - 48:10

$8,000 [1] - 48:9

1

1 [3] - 33:7, 41:4, 

49:23

1.2 [1] - 50:15

1.8 [1] - 14:12

10 [1] - 2:2

10:00 [1] - 1:15

1110 [2] - 46:23, 

51:10

11:11 [1] - 57:17

11:29 [1] - 57:17

11:32 [1] - 59:7

12 [1] - 2:3

12:08 [2] - 59:7, 

59:14

12:30 [2] - 59:11, 

59:12

12th [1] - 4:23

13 [1] - 60:14

15 [4] - 2:4, 8:25, 

57:14, 58:16

15-minute [2] - 

57:11, 57:19

156 [1] - 4:9

15th [4] - 5:5, 

6:16, 7:16, 

12:24

16 [1] - 55:17

160-year [1] - 

26:22

169A [2] - 5:21, 

35:19

169A(b)(2)(A [1] - 

6:2

18 [2] - 2:5, 54:16

1837 [1] - 23:16

1854 [1] - 23:14

18th [1] - 4:19

1962 [1] - 6:8

1977 [2] - 6:8, 

35:18

1988 [1] - 4:4

1999 [3] - 4:4, 

22:13, 36:4

1:46 [1] - 59:14

2

2 [1] - 27:10

2.5 [1] - 14:14

20-minute [1] - 

59:10

2002 [1] - 41:4

2003 [1] - 41:22

2006 [2] - 41:20, 

42:21

2009 [6] - 4:15, 

37:22, 42:1, 

43:2, 43:12, 

44:13

2010 [4] - 4:19, 

37:23, 42:6, 

44:13

2011 [1] - 37:25

2011-2012 [1] - 

42:9

2012 [18] - 1:17, 

4:19, 4:23, 5:1, 

5:5, 6:16, 7:1, 

7:7, 7:16, 12:14, 

12:24, 13:14, 

37:1, 37:25, 

41:1, 43:6, 47:1, 

60:14

22 [2] - 2:6, 54:17

24th [1] - 47:1

25th [1] - 37:1

26 [1] - 2:7

27th [1] - 12:14

28th [4] - 7:1, 7:7, 

59:1, 59:4

29 [1] - 1:17

291 [1] - 41:4

2:00 [3] - 9:9, 

58:22, 59:20

3

3,900 [1] - 12:18

30 [2] - 2:8, 7:3

30th [1] - 4:15

32 [1] - 27:4

34 [1] - 2:9

35 [1] - 30:19

4

4 [1] - 50:14

40 [1] - 42:18

40,000 [1] - 12:20

41 [1] - 2:10

44 [1] - 39:25

46 [1] - 2:11

5

5 [9] - 3:10, 3:17, 

3:20, 8:25, 9:2, 

22:23, 24:1, 

25:22, 58:16

5's [2] - 24:2, 24:5

50 [1] - 19:19

51 [3] - 2:12, 

37:18, 42:18

520 [1] - 1:12

53 [1] - 2:13

59 [1] - 60:10

5:00 [1] - 11:7

5th [1] - 4:19

6

6 [1] - 48:9

6,000 [1] - 27:8

60 [1] - 33:20

60-year [1] - 28:13

6th [1] - 5:1

8

8 [1] - 23:10

800 [1] - 11:10

A

ability [1] - 60:13

able [4] - 7:19, 

38:3, 50:10, 

56:20

ABURANO [25] - 

4:2, 12:10, 

14:20, 14:23, 

17:15, 18:1, 

18:10, 18:14, 

21:12, 26:9, 

29:21, 34:8, 

38:9, 40:19, 

40:23, 41:5, 

51:5, 53:13, 

53:18, 57:7, 

57:10, 57:18, 

58:19, 59:8, 

59:15

Aburano [2] - 

3:15, 3:24

accept [1] - 31:6

accepting [3] - 

58:25, 59:4, 

59:18

access [1] - 49:15

accommodate [1]

- 9:10

accomplished [1]

- 54:17

according [3] - 

14:13, 33:16, 

43:9

account [1] - 

46:17

accurate [1] - 

58:10

accurately [1] - 

8:5

achieve [5] - 

31:22, 36:10, 

39:13, 40:5, 

46:14

acid [1] - 15:25

acidification [1] - 

23:22

acknowledge [2] - 

9:18, 9:22

acres [1] - 23:11

acronym [3] - 

21:17, 21:21

acronyms [1] - 

21:17

act [3] - 35:2, 

35:19, 35:24

Act [8] - 5:21, 6:3, 

29:10, 34:20, 

34:23, 35:17, 

37:11, 39:16

acting [2] - 52:15, 

52:16

action [6] - 7:15, 

20:3, 21:6, 

51:19, 51:25, 

53:12

active [1] - 22:19

actively [1] - 35:20

actual [1] - 46:11

add [1] - 44:19

add-on [1] - 44:19

added [1] - 35:18

addition [1] - 

25:12

additional [12] - 

5:14, 7:3, 9:5, 

20:8, 23:21, 

25:9, 39:5, 44:6, 

44:16, 44:19, 

53:19, 58:24

address [4] - 5:3, 

6:1, 14:4, 17:8

adequately [2] - 

50:18, 50:20

adjustments [1] - 

9:16

Administrator [3]

- 12:15, 12:17, 

47:1

adopt [1] - 13:18

adopts [1] - 42:19

advantageous [1]

- 25:8

SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

1

Advocacy [1] - 

18:18

affected [5] - 5:12, 

5:17, 6:18, 23:6, 

36:20

affects [1] - 19:18

affiliation [3] - 

8:1, 53:22, 

58:11

affordable [2] - 

24:21, 24:23

afternoon [1] - 

11:8

agencies [3] - 4:3, 

4:8, 32:11

AGENCY [1] - 1:1

agency [4] - 

11:21, 12:15, 

47:15, 51:18

Agency [11] - 

1:11, 4:5, 11:17, 

12:5, 13:3, 

22:25, 29:15, 

41:24, 42:14, 

51:18, 51:24

Agency's [2] - 3:5, 

32:8

aggressive [2] - 

20:3, 48:3

ago [2] - 10:21, 

11:2

agree [1] - 56:23

agreement [1] - 

7:15

ahead [9] - 3:1, 

7:13, 10:6, 

10:10, 22:3, 

24:14, 38:9, 

41:9, 51:2

Air [9] - 5:21, 6:3, 

22:14, 29:10, 

34:20, 34:23, 

35:17, 37:11, 

39:16

air [15] - 13:20, 

13:23, 15:10, 

15:14, 15:24, 

16:12, 19:3, 

19:4, 20:1, 

27:16, 33:8, 

34:24, 36:22, 

41:2, 54:12

airplane [1] - 11:4

Al [2] - 9:22, 9:23

alive [1] - 49:16

Allen [3] - 2:11, 

41:8, 46:23

allow [4] - 7:4, 

25:19, 50:4, 

59:9
EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

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allowed [1] - 

43:10

allowing [2] - 

13:10, 46:18

allows [1] - 39:16

alone [1] - 19:18

altered [1] - 33:22

alternative [2] - 

20:14, 30:10

ambient [2] - 

27:16, 39:10

America [1] - 30:7

American [1] - 

41:3

amount [6] - 5:19, 

15:23, 16:6, 

50:10, 55:14, 

56:9

analysis [6] - 

24:5, 40:9, 

43:14, 45:13, 

55:2

Analysis [1] - 

42:21

ancillary [2] - 

14:14, 44:24

angie [1] - 1:20

Angie [1] - 60:8

ANGIE [1] - 60:19

announced [1] - 

4:5

announcement

[1] - 53:15

annual [1] - 14:12

annually [2] - 

27:5, 27:11

answers [1] - 

16:23

anticipate [2] - 

24:17, 25:23

anticipated [1] - 

6:13

apparent [1] - 

50:18

Appeals [2] - 

13:16, 34:22

Appendix [3] - 

37:18, 42:19, 

42:20

application [1] - 

23:18

applied [1] - 45:18

apply [3] - 36:2, 

49:13, 56:16

appreciate [6] - 

17:13, 18:2, 

22:7, 22:22, 

26:8, 26:20

approach [6] - 

13:21, 27:23, 

38:25, 39:4, 

39:16, 56:22

approaches [2] - 

28:10, 29:13

appropriate [1] - 

49:24

appropriately [2] - 

38:24, 50:11

approval [5] - 

4:17, 4:22, 5:1, 

5:2, 43:5

approve [4] - 34:2, 

34:18, 39:1, 

40:14

approved [1] - 

4:23

approves [1] - 

38:11

approving [1] - 

36:25

area [5] - 6:15, 

7:10, 52:14, 

54:8

Area [3] - 4:11, 

23:7, 23:8

areas [12] - 4:4, 

4:7, 4:10, 4:13, 

4:14, 5:20, 13:9, 

16:17, 19:13, 

19:16, 23:6, 

27:10

arguably [1] - 48:3

argued [1] - 49:2

argument [2] - 

20:19, 49:4

arrived [1] - 36:17

arrowhead [1] - 

23:11

aspects [3] - 5:9, 

6:20, 32:15

assess [3] - 32:21, 

38:21, 40:6

assistance [2] - 

10:3, 14:17

associated [1] - 

16:23

Association [2] - 

18:23, 18:24

assumption [1] - 

31:25

assumptions [1] - 

46:1

attached [1] - 

41:25

attacks [1] - 19:11

attain [1] - 35:1

attainment [1] - 

3:16

attempt [2] - 

28:23, 36:8

attend [3] - 53:8, 

54:10, 54:15

attendees [1] - 

10:7

attending [1] - 3:4

attention [1] - 

6:25

attorney [1] - 

51:11

August [7] - 1:17, 

5:1, 5:5, 6:16, 

12:14, 12:24, 

13:14

authority [5] - 

36:7, 36:9, 

37:10, 52:22, 

52:23

authorize [2] - 

13:18, 37:11

available [21] - 

6:9, 6:17, 7:22, 

13:4, 21:18, 

24:3, 28:15, 

28:25, 29:7, 

36:12, 36:17, 

37:19, 41:17, 

42:11, 43:4, 

43:6, 43:13, 

43:18, 43:20, 

43:24, 44:11

Avenue [2] - 

46:23, 51:11

average [1] - 46:9

aware [2] - 42:22, 

47:18

B

B-O-B [1] - 10:12

babies [1] - 10:22

backbone [1] - 

27:4

balance [4] - 

32:14, 32:17, 

32:20, 33:18

balanced [1] - 

33:3

Band [9] - 22:10, 

22:13, 23:6, 

23:12, 23:16, 

23:18, 23:25, 

25:13, 25:21

Band's [1] - 23:9

bands [1] - 23:13

Barr [6] - 41:14, 

41:15, 41:20, 

41:22, 42:8, 

43:7

Barr's [1] - 42:5

BART [47] - 6:10, 

6:12, 6:13, 6:17, 

20:16, 20:18, 

21:18, 24:23, 

25:13, 28:3, 

28:12, 28:19, 

29:12, 31:16, 

33:15, 34:3, 

36:2, 36:13, 

36:17, 37:3, 

37:14, 37:21, 

37:23, 38:4, 

38:12, 38:25, 

40:10, 41:16, 

41:21, 42:1, 

42:3, 42:4, 42:6, 

42:18, 42:21, 

42:23, 43:7, 

43:10, 43:14, 

44:7, 44:12, 

44:17, 45:14, 

46:9, 50:12

BART-eligible [1]

- 6:13

base [1] - 29:7

based [17] - 13:20, 

25:15, 27:24, 

29:6, 32:12, 

37:3, 37:7, 37:8, 

37:24, 39:14, 

43:23, 44:3, 

44:20, 45:1, 

46:9, 46:12, 

50:9

baseline [1] - 

50:13

basis [3] - 21:24, 

37:17, 44:9

bearing [2] - 

30:23, 30:24

become [3] - 7:21, 

43:13, 43:20

begin [4] - 8:2, 

8:18, 9:17, 

58:13

beginning [1] - 

40:20

behalf [3] - 12:17, 

51:9, 51:23

behavior [1] - 

51:23

believes [3] - 

23:18, 26:18, 

37:4

belong [1] - 19:14

bench [1] - 24:12

beneficial [1] - 

48:19

benefit [2] - 14:12, 

21:20

SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

2

benefits [2] - 

14:11, 19:8

best [8] - 6:9, 

6:17, 13:4, 

21:18, 24:3, 

36:12, 41:17, 

60:13

best-available [6]

- 6:9, 13:4, 

21:18, 24:3, 

36:12, 41:17

better [3] - 37:3, 

37:12, 38:20

between [1] - 6:8

beyond [2] - 7:4, 

15:20

Bill [1] - 3:19

billion [2] - 14:12, 

27:11

billions [1] - 55:19

bit [5] - 48:12, 

49:9, 50:23, 

51:3, 54:13

Board [1] - 1:11

Bob [3] - 2:2, 

10:8, 10:11

bodies [2] - 16:17, 

33:1

boilers [3] - 48:8, 

48:10, 48:11

borders [5] - 14:2, 

35:2, 35:6, 

36:11, 37:15

born [3] - 10:22, 

10:23, 16:14

Boundary [4] - 

4:11, 18:24, 

21:8, 23:7

break [7] - 57:11, 

57:17, 57:19, 

59:7, 59:10, 

59:13, 59:14

BRIAN [1] - 12:11

Brian [4] - 2:3, 

9:18, 10:8, 

12:11

brief [3] - 3:24, 

41:2, 45:23

briefly [1] - 26:19

bring [1] - 8:20

bringing [1] - 

47:17

broad [1] - 50:1

brought [1] - 

47:24

brushstroke [1] - 

56:19

BTUs [1] - 50:14

building [2] - 

11:17, 11:19
EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

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built [1] - 6:8

burden [1] - 25:17

burdens [1] - 

16:16

burn [1] - 49:15

burner [3] - 33:9, 

33:11, 40:2

burners [12] - 

24:3, 24:6, 

24:17, 24:20, 

24:25, 25:8, 

25:14, 25:16, 

26:4, 33:5, 49:6, 

50:11

burning [8] - 

48:19, 48:21, 

49:11, 49:13, 

49:20, 49:22, 

50:5, 50:6

business [3] - 

27:14, 27:19, 

28:18

button [1] - 18:11

bypasses [1] - 

28:3

C

C-R-A-V-A-A-C-K

[1] - 12:13

camp [2] - 54:13, 

54:15

Canadian [1] - 

30:9

Canary [1] - 18:5

cannot [5] - 14:16, 

37:16, 38:1, 

38:19

Canoe [2] - 4:11, 

23:7

captures [1] - 8:4

cardiovascular

[1] - 15:23

care [1] - 11:19

careful [1] - 26:6

carefully [3] - 

7:11, 13:3, 33:3

Carol [3] - 2:12, 

51:7, 51:9

carrying [1] - 

47:13

case [4] - 20:17, 

47:20, 51:20, 

52:10

cases [1] - 46:8

catalytic [1] - 

21:19

categories [1] - 

6:7

causing [1] - 

23:21

ceded [4] - 23:9, 

23:10, 23:12, 

23:15

CENRAP [2] - 

22:15, 22:19

Center [1] - 18:17

central [1] - 28:6

Central [1] - 22:14

certain [2] - 5:24, 

6:6

certainty [1] - 

43:16

CERTIFICATE [1]

- 60:5

certify [1] - 60:9

Cervak [3] - 8:13, 

9:13, 58:7

CFR [1] - 42:18

challenge [3] - 

13:17, 21:2, 

28:17

changed [1] - 37:1

changes [6] - 

16:1, 16:3, 16:9, 

17:4, 28:23, 

44:24

charge [1] - 35:21

check [1] - 58:6

chemical [1] - 

54:19

chemistry [1] - 

16:10

Chicago [1] - 3:10

chief [1] - 3:16

children [1] - 

10:25

Chip [3] - 9:19, 

12:12, 14:18

Chippewa [1] - 

23:13

choice [1] - 25:1

choose [1] - 38:4

choosing [2] - 

35:1, 36:9

chose [2] - 35:22, 

38:24

Circuit [5] - 13:15, 

34:21, 35:22, 

41:1, 41:4

cites [2] - 20:22, 

49:12

Citizens [1] - 1:11

City [1] - 13:15

claim [1] - 42:24

claiming [1] - 

37:17

clarifying [3] - 

8:10, 17:15, 

40:19

Class [3] - 4:13, 

6:15, 19:13

clean [3] - 12:7, 

36:22, 50:7

Clean [8] - 5:21, 

6:3, 29:10, 

34:20, 34:23, 

35:17, 37:11, 

39:16

cleaned [1] - 

11:15

cleaner [1] - 19:3

clear [2] - 35:16, 

50:19

clearer [1] - 19:4

clearly [4] - 8:3, 

19:20, 35:14, 

47:21

clients [3] - 45:20, 

46:5, 52:6

Cliffs [17] - 26:14, 

26:18, 26:21, 

27:8, 27:14, 

27:20, 28:7, 

28:20, 28:22, 

29:3, 29:12, 

30:6, 31:5, 

34:14, 52:22, 

53:4

Cliffs' [3] - 27:2, 

27:22, 28:5

close [6] - 9:1, 

37:20, 40:14, 

43:10, 43:18, 

51:1

closed [5] - 35:8, 

36:3, 37:22, 

37:23, 43:11

closing [2] - 17:4, 

59:15

Club [1] - 18:25

coal [4] - 49:1, 

49:3, 49:5, 52:4

Coalition [1] - 

22:15

collateral [2] - 

33:21, 33:23

collecting [1] - 

25:2

color [1] - 58:12

combustion [5] - 

16:5, 16:9, 33:8, 

33:21, 42:2

coming [3] - 9:1, 

10:4, 16:19

commend [1] - 

15:9

comment [12] - 

15:7, 20:10, 

37:20, 39:25, 

40:8, 40:11, 

43:4, 43:11, 

43:19, 50:9, 

53:16, 57:9

comments [34] - 

3:22, 5:9, 6:20, 

7:2, 7:8, 7:11, 

7:12, 7:13, 8:5, 

8:11, 9:21, 

18:20, 20:10, 

20:20, 20:24, 

26:16, 26:18, 

29:18, 34:15, 

38:8, 45:23, 

46:5, 46:6, 

46:19, 46:25, 

48:5, 51:16, 

53:10, 54:11, 

58:5, 58:25, 

59:3, 59:4, 

59:18

Commission [1] - 

52:9

commissioner [1]

- 11:21

commitment [1] - 

25:16

committed [1] - 

31:9

common [1] - 38:3

commonly [1] - 

47:19

communities [1] - 

11:1

community [1] - 

3:9

Company [4] - 

30:14, 30:15, 

41:14

company [4] - 

11:2, 26:22, 

27:4, 51:9

comparing [1] - 

49:5

compelling [1] - 

25:12

complete [5] - 

38:8, 42:15, 

45:4, 45:16, 

60:12

completed [2] - 

44:21, 45:12

completion [1] - 

7:14

complex [2] - 

13:17, 45:18

complexities [1] - 

28:1

compliance [4] - 

SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

3

26:14, 33:12, 

38:18, 46:15

compliant [1] - 

36:23

component [1] - 

53:6

comprehensive

[1] - 32:1

concentration [1]

- 56:6

concentrations

[2] - 39:10, 49:22

concept [1] - 25:4

concern [3] - 

12:22, 23:5, 

46:7

concerned [6] - 

24:11, 46:15, 

48:16, 49:10, 

49:18, 52:12

concerns [6] - 

16:3, 17:12, 

27:17, 27:22, 

28:20, 31:19

conclude [1] - 9:8

concluded [3] - 

35:25, 42:2, 

59:20

concludes [2] - 

29:18, 31:20

conclusion [2] - 

32:23, 33:25

conclusions [1] - 

32:3

conduct [3] - 6:12, 

32:20, 45:19

Conducting [1] - 

42:21

conducting [2] - 

31:23, 32:5

conference [1] - 

22:21

confidence [1] - 

31:15

Congress [6] - 

13:17, 13:19, 

35:18, 35:19, 

35:22, 35:25

Congress' [2] - 

37:13, 38:12

congressman [1]

- 12:14

Congressman [1]

- 9:19

consequences [1]

- 33:14

conservation [1] - 

18:19

Conservation [1] - 

18:22
EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

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conservative [2] - 

38:24, 48:1

consider [4] - 

7:11, 43:20, 

44:1, 51:21

considerably [1] - 

45:21

consideration [2]

- 37:25, 46:16

considerations

[1] - 44:20

considered [4] - 

28:24, 43:16, 

43:18, 50:20

considering [2] - 

37:19, 52:5

consist [1] - 23:10

consistent [1] - 

42:16

consistently [1] - 

51:19

consisting [2] - 

8:15, 60:10

constituent [1] - 

54:8

constituents [2] - 

12:18, 12:20

constituted [2] - 

42:2, 42:4

construction [1] - 

24:15

consumption [1] - 

25:7

contain [1] - 6:4

contains [2] - 

5:11, 14:5

contends [1] - 

25:13

context [1] - 21:4

continue [1] - 13:9

continuous [2] - 

16:25, 46:15

contrary [1] - 

35:10

contribute [3] - 

6:14, 31:10, 

31:14

contributed [1] - 

31:8

Control [10] - 

1:11, 11:17, 

13:3, 22:25, 

29:15, 32:8, 

41:23, 42:14, 

51:18, 51:24

control [9] - 

13:20, 19:22, 

24:21, 24:25, 

25:7, 39:18, 

40:13, 44:18, 

50:12

controls [14] - 

5:24, 19:21, 

19:25, 21:9, 

36:2, 38:23, 

39:9, 40:6, 42:3, 

44:7, 44:18, 

44:19, 44:23, 

45:6

convert [1] - 30:23

converted [1] - 

42:10

cool [1] - 33:9

cooperative [1] - 

13:21

coordinator [1] - 

3:9

copies [1] - 14:24

copy [1] - 8:13

Corn [1] - 41:3

correct [1] - 60:11

cost [16] - 13:11, 

19:20, 20:8, 

40:6, 44:20, 

44:22, 44:23, 

44:24, 45:4, 

45:6, 45:11, 

45:13, 46:4, 

48:7, 50:25

cost-effective [2]

- 19:20, 20:8

costs [4] - 24:21, 

24:23, 45:21, 

46:3

counsel [2] - 

34:12, 34:13

Counsel [1] - 3:19

country [2] - 11:4, 

27:2

COUNTY [1] - 

60:2

couple [6] - 10:7, 

10:21, 14:22, 

29:23, 33:18, 

48:6

course [3] - 10:17, 

19:4, 34:4

COURT [3] - 1:20, 

54:2, 54:6

court [6] - 7:17, 

8:4, 21:14, 

21:20, 40:21, 

40:24

Court [5] - 13:16, 

34:21, 35:22, 

36:4, 60:19

Cravaack [2] - 

9:19, 14:19

Cravaack's [1] - 

12:12

create [1] - 7:19

created [2] - 16:4, 

56:13

creates [1] - 33:13

criteria [3] - 33:15, 

36:22, 42:20

critically [1] - 

40:12

cross [1] - 41:2

cross-state [1] - 

41:2

current [2] - 29:4, 

33:7

customers' [2] - 

30:24, 33:2

cut [1] - 5:16

CVL [2] - 55:15, 

56:17

D

D-O-U-G-L-A-S [1]

- 34:11

D-U-P-U-I-S [1] - 

22:5

D.C [1] - 12:16

DAKOTA [1] - 

60:2

data [4] - 19:16, 

37:4, 42:12, 

55:2

date [1] - 43:21

dated [2] - 12:14, 

47:1

Dated [1] - 60:14

day-to-day [1] - 

21:23

days [4] - 7:3, 

10:17, 19:20, 

39:25

DC [5] - 13:15, 

34:21, 35:22, 

41:1, 41:4

deadline [4] - 7:1, 

17:25, 20:10, 

53:11

deal [1] - 13:16

dear [1] - 12:17

death [1] - 11:14

debated [1] - 

35:20

decades [3] - 

19:15, 19:22, 

38:17

December [3] - 

4:15, 43:2, 

43:12

decide [1] - 36:1

decided [2] - 36:4, 

45:4

decision [2] - 

37:13, 38:12

decisions [2] - 

37:8, 39:2

deciview [1] - 46:3

deemed [2] - 

13:19, 24:23

defer [1] - 20:15

deficient [1] - 

37:17

define [1] - 21:21

degradation [1] - 

23:20

delays [1] - 26:1

delegated [3] - 

47:14, 52:21, 

52:23

deleterious [1] - 

23:24

demonstrate [1] - 

31:16

demonstrated [2]

- 20:23, 44:11

demonstrates [1]

- 24:15

demonstrating [1]

- 35:13

demonstration [1]

- 25:18

demonstrations

[1] - 45:19

Department [5] - 

11:23, 11:25, 

16:14, 22:25, 

29:14

departs [1] - 28:2

dependent [1] - 

33:3

deploy [1] - 31:21

deprive [1] - 36:8

deprived [1] - 36:6

describe [1] - 7:23

described [1] - 

34:22

design [8] - 24:16, 

25:24, 28:9, 

32:20, 33:6, 

33:18, 40:2

designates [1] - 

29:10

designed [2] - 

28:12, 49:5

designers [1] - 

28:22

designing [1] - 

32:17

desirable [1] - 

26:3

desk [1] - 57:24

SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

4

desulfurize [1] - 

49:25

detail [1] - 45:17

detailed [2] - 

20:25, 53:10

determination [9]

- 24:2, 25:13, 

29:11, 37:21, 

37:22, 38:5, 

38:25, 40:10, 

42:6

determinations

[11] - 6:12, 32:6, 

34:4, 36:12, 

36:13, 36:18, 

38:12, 41:22, 

42:1, 42:10, 

45:14

determine [5] - 

31:23, 35:3, 

36:21, 40:4, 

45:21

determined [5] - 

6:10, 32:10, 

44:8, 44:9, 

44:17

determining [2] - 

13:25, 37:14

detrimental [1] - 

33:19

develop [5] - 

20:19, 28:10, 

35:12, 35:15, 

43:23

developed [7] - 

15:17, 19:16, 

20:25, 31:15, 

33:11, 41:18, 

56:1

developing [1] - 

57:1

development [1] - 

42:16

device [2] - 25:7, 

48:14

diesel [2] - 54:23, 

55:4

difference [1] - 

48:13

different [2] - 

34:20, 55:7

DIN [1] - 54:4

Dinslage [2] - 

2:13, 53:25

DINSLAGE [3] - 

53:24, 54:4, 

54:7

dioxide [3] - 5:11, 

5:14, 44:18

direct [3] - 3:12, 
EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

09/12/2012 06:32:53 PM Page 5 to 5 of 16 20 of 31 sheets

27:9, 38:17

directed [1] - 6:12

directions [1] - 

37:2

directly [2] - 

12:19, 35:8

director [2] - 

18:17, 26:14

directs [2] - 5:21, 

37:18

disciplined [1] - 

56:22

discretion [2] - 

9:4, 38:7

discussion [1] - 

48:16

diseases [2] - 

19:10, 19:11

disposal [1] - 25:5

disregarded [1] - 

45:3

disregarding [1] - 

21:2

distribution [1] - 

33:4

District [1] - 12:18

DOCKET [2] - 1:7, 

1:8

docket [2] - 8:12, 

47:2

document [1] - 

48:2

documentation

[1] - 17:9

documented [1] - 

19:10

dollar [2] - 46:2, 

46:3

dollar-perdeciview [1] - 

46:3

dollar-per-ton [1]

- 46:2

dollars [3] - 55:7, 

55:13, 55:19

domestic [2] - 

27:1, 27:6

done [6] - 40:9, 

47:19, 49:6, 

50:16, 56:17, 

59:18

door [5] - 8:14, 

10:2, 12:1, 

57:25, 58:7

Doug [3] - 4:1, 

6:24, 30:1

Douglas [4] - 2:9, 

3:15, 3:24, 

34:11

downstream [1] - 

17:2

downwind [2] - 

5:20, 17:2

draft [1] - 27:23

drag [1] - 52:6

dragged [1] - 47:5

drainage [1] - 

10:23

dramatic [1] - 55:4

dramatically [1] - 

5:16

draw [1] - 6:25

dropped [1] - 

15:16

dryers [1] - 50:20

Du [2] - 22:6, 

22:10

due [3] - 16:7, 

16:11, 28:3

dug [1] - 56:2

Duluth [1] - 14:13

Dupuis [4] - 2:6, 

22:1, 22:3, 22:5

DUPUIS [1] - 22:4

during [5] - 9:25, 

15:19, 22:19, 

43:14, 49:20

E

early [1] - 33:10

eastern [1] - 30:9

echoed [1] - 28:21

ecological [1] - 

48:20

economic [1] - 

15:15

economically [3] - 

14:6, 31:24, 

39:20

economicallyviable [1] - 39:20

economies [1] - 

27:10

economy [1] - 

14:12

effect [4] - 28:23, 

39:18, 47:5, 

47:11

effective [3] - 

19:20, 20:8, 

50:25

effectively [2] - 

13:11, 14:4

effectiveness [1] - 

45:13

effects [5] - 16:5, 

16:25, 17:17, 

23:21, 23:24

efficiencies [2] - 

16:8, 39:19

efficiency [1] - 

30:10

effluents [1] - 5:17

effort [3] - 4:6, 

14:18, 22:22

efforts [1] - 15:10

eight [1] - 27:1

Eighth [1] - 12:18

either [1] - 9:5

elapsed [1] - 9:6

electrician [1] - 

10:14

elementary [1] - 

10:14

elevated [2] - 

10:18, 10:23

eligible [1] - 6:13

eliminate [1] - 

19:21

embraces [1] - 

29:3

EME [2] - 13:14, 

40:25

emission [16] - 

5:18, 17:7, 

38:23, 39:9, 

39:12, 39:18, 

40:4, 40:6, 42:8, 

43:1, 45:20, 

46:9, 46:13, 

54:22, 55:3, 

55:20

emissions [32] - 

5:17, 13:18, 

15:8, 15:19, 

16:3, 16:10, 

16:12, 16:19, 

16:25, 19:9, 

27:13, 27:18, 

29:2, 31:9, 

31:10, 31:18, 

31:22, 33:10, 

33:21, 34:5, 

37:4, 42:4, 

44:19, 44:23, 

46:10, 46:11, 

49:1, 49:3, 49:7, 

50:12, 50:17, 

55:10

emit [1] - 16:7

emitted [1] - 17:21

emitters [1] - 35:5

emphasize [1] - 

27:12

Empire [1] - 30:17

employed [1] - 

12:19

employs [1] - 27:8

encountered [1] - 

26:1

encourage [3] - 

12:6, 16:21, 

34:17

end [3] - 38:5, 

39:8, 43:21

endangering [1] - 

13:12

endeavors [1] - 

30:9

endpoint [1] - 

38:4

energy [4] - 25:6, 

29:13, 39:19, 

49:18

Energy [1] - 18:25

Energy's [1] - 52:3

enforce [1] - 12:5

enforceable [1] - 

42:11

engine [1] - 55:5

engineer [5] - 

3:18, 30:19, 

41:14, 54:18, 

54:19

engineered [2] - 

33:1, 33:3

Engineering [1] - 

41:14

engineering [4] - 

28:9, 31:23, 

32:21, 48:11

engineers [2] - 

32:2, 33:17

engines [1] - 

54:23

ensure [5] - 8:3, 

16:25, 38:5, 

40:11, 46:14

enter [1] - 29:19

entered [1] - 8:12

entire [3] - 14:11, 

27:2, 27:6

Environmental [6]

- 3:5, 4:5, 12:5, 

18:17, 23:1, 

29:14

environmental [5]

- 3:18, 22:7, 

25:6, 26:14, 

34:13

ENVIRONMENT

AL [1] - 1:1

environmentally

[1] - 48:19

EPA [57] - 3:20, 

4:2, 4:17, 4:22, 

4:23, 5:1, 5:5, 

5:22, 6:3, 6:10, 

SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

5

6:11, 7:11, 7:15, 

12:15, 12:25, 

13:8, 13:15, 

13:18, 13:19, 

14:3, 15:9, 

16:22, 19:2, 

20:13, 20:17, 

20:21, 21:2, 

24:24, 29:1, 

29:5, 29:12, 

29:17, 32:7, 

32:21, 33:25, 

35:20, 36:11, 

36:21, 36:23, 

36:24, 37:1, 

37:16, 38:1, 

38:18, 38:25, 

40:9, 40:10, 

40:14, 41:1, 

45:12, 47:20, 

51:24, 52:11, 

52:20, 52:23, 

53:5, 54:21

EPA's [13] - 3:17, 

5:9, 6:20, 14:4, 

20:3, 21:6, 28:2, 

36:4, 36:7, 

37:10, 37:17, 

37:23, 39:22

EPA-R05-OAR2010-0037 [1] - 

1:7

EPA-R05-OAR2010-0954 [1] - 

1:8

equally [1] - 28:21

equipment [1] - 

32:13

equity [1] - 25:14

errors [2] - 42:22, 

42:25

especially [1] - 

29:7

Essar's [1] - 24:9

establish [2] - 

31:16, 34:3

establishes [1] - 

34:20

establishing [1] - 

46:8

estimated [1] - 

24:21

estimating [1] - 

44:22

evaded [1] - 19:22

evaluate [6] - 

5:23, 20:14, 

20:21, 38:22, 

39:17, 40:13

evaluated [2] - 
EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

21 of 31 sheets Page 6 to 6 of 16 09/12/2012 06:32:53 PM

33:14, 50:19

evaluation [3] - 

32:21, 36:19, 

45:11

evaluations [8] - 

32:1, 44:6, 

44:16, 44:20, 

44:23, 45:3, 

45:4, 45:16

evening [1] - 53:8

event [1] - 8:22

evidence [1] - 

17:6

evolution [1] - 

37:19

examined [1] - 

13:3

example [4] - 

19:17, 33:16, 

48:18, 52:2

Excelsior [1] - 

52:3

except [1] - 4:24

exclude [1] - 

49:11

exempt [1] - 50:5

exercise [2] - 9:4, 

35:14

exist [1] - 16:13

existing [6] - 6:7, 

33:5, 42:3, 

44:18, 44:25, 

45:7

expanded [1] - 

26:16

expansion [1] - 

27:15

expectations [2] - 

29:6, 29:8

expected [1] - 

39:15

experience [5] - 

30:19, 38:17, 

44:21, 45:2, 

45:15

expert [1] - 33:17

explained [1] - 

31:5

exploration [1] - 

49:9

express [1] - 

12:22

extend [2] - 9:9, 

40:11

extends [1] - 

38:14

extent [2] - 28:16, 

39:12

extremely [1] - 

49:5

extremely-poorly

-designed [1] - 

49:5

eyes [1] - 8:22

F

F.3d [1] - 41:4

face [2] - 22:20

face-to-face [1] - 

22:20

facilitate [1] - 3:22

facilities [24] - 3:6, 

4:17, 4:21, 4:25, 

5:10, 5:12, 5:14, 

5:15, 5:18, 6:18, 

6:21, 13:2, 

16:13, 24:4, 

24:10, 25:19, 

27:2, 28:16, 

30:21, 30:25, 

34:2, 40:16, 

43:8, 45:1

Facilities [2] - 1:4, 

42:21

facility [5] - 5:3, 

5:7, 28:21, 

33:13, 45:7

fact [6] - 20:2, 

20:17, 25:15, 

39:7, 48:20, 

50:24

factor [1] - 45:1

factored [2] - 

44:23, 48:22

fails [3] - 27:25, 

28:8, 36:23

failure [1] - 52:21

fair [1] - 8:6

fairly [1] - 49:14

familiar [1] - 19:11

family [1] - 54:13

far [1] - 47:23

faster [1] - 37:5

fault [1] - 38:1

feasibility [3] - 

13:4, 21:3, 

32:22

feasible [5] - 

13:12, 14:7, 

24:6, 31:25, 

50:22

February [1] - 

47:1

federal [23] - 3:5, 

4:8, 5:22, 13:22, 

13:23, 14:5, 

22:16, 23:2, 

27:24, 31:3, 

31:20, 34:16, 

34:24, 35:7, 

38:1, 39:24, 

40:15, 42:17, 

42:18, 42:24, 

43:22, 43:25, 

47:17

Federal [4] - 1:4, 

5:6, 6:16, 12:23

federalism [2] - 

13:20, 13:21

federalismbased [1] - 13:20

feet [1] - 11:10

few [6] - 38:8, 

49:17, 51:14, 

53:4, 56:7

film [1] - 11:2

filming [1] - 11:9

final [2] - 7:15, 

46:7

finalizing [1] - 

38:4

finally [3] - 9:25, 

32:16, 46:7

finish [1] - 46:19

finished [2] - 8:9

FIP [31] - 5:23, 

6:3, 24:1, 28:16, 

28:24, 33:18, 

34:1, 34:17, 

36:7, 36:24, 

37:2, 37:12, 

37:24, 38:11, 

39:3, 39:22, 

40:10, 44:3, 

44:10, 45:3, 

45:14, 45:24, 

45:25, 46:9, 

46:16, 47:24, 

49:11, 49:22, 

51:2, 52:19, 

56:24

first [13] - 3:23, 

10:7, 15:9, 

20:13, 24:5, 

25:2, 27:12, 

28:13, 29:16, 

33:19, 35:4, 

40:25, 51:15

firsthand [1] - 

32:8

fishing [1] - 23:17

fits [2] - 31:25, 

32:22

five [7] - 8:7, 8:17, 

9:2, 53:3, 53:22, 

58:13, 59:17

five-minute [2] - 

8:17, 58:13

flame [2] - 33:22, 

49:2

flaws [3] - 27:25, 

42:22, 42:25

flexibility [1] - 

13:10

flight [1] - 11:7

focused [1] - 

33:12

follow [1] - 32:4

followed [1] - 

43:22

following [2] - 

23:25, 38:1

follows [1] - 34:23

Fond [2] - 22:6, 

22:10

foreclose [1] - 

39:5

foregoing [1] - 

60:9

foremost [1] - 

27:12

form [1] - 46:25

formally [1] - 

59:15

formation [1] - 

31:10

formed [1] - 25:1

forward [6] - 

14:18, 29:14, 

39:23, 47:17, 

47:25, 52:19

four [3] - 8:19, 

23:25, 58:14

fourth [1] - 25:12

frame [2] - 13:12, 

28:8

Franken [1] - 9:23

frenzy [1] - 39:23

Fresh [1] - 18:25

Friends [1] - 18:24

fronting [1] - 

47:12

fuel [15] - 20:16, 

20:18, 25:9, 

30:25, 33:19, 

48:17, 48:25, 

49:13, 49:15, 

49:25, 50:3, 

50:4, 50:6, 50:7, 

55:14

fuel-making [1] - 

30:25

fuels [1] - 20:14

full [2] - 24:14, 

60:12

full-scale [1] - 

24:14

fully [4] - 21:6, 

SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

6

32:19, 45:12, 

46:16

fundamentally [2]

- 47:7, 48:14

fundamentallysimilar [1] - 

48:14

funerals [1] - 

10:20

furnace [5] - 28:2, 

32:25, 40:3, 

42:7, 44:9

furnace-specific

[1] - 44:9

furnaces [20] - 

13:11, 15:19, 

24:8, 24:9, 

24:11, 24:12, 

24:19, 31:21, 

32:24, 36:14, 

37:1, 37:22, 

38:18, 39:8, 

44:9, 44:22, 

45:18, 56:11, 

56:12, 56:15

future [3] - 27:15, 

29:4, 39:6

G

G-I-S-C-H-I-A [1] - 

26:13

gained [1] - 19:8

gas [6] - 15:11, 

15:15, 25:10, 

49:5, 49:16, 

49:20

gasification [1] - 

52:4

gather [1] - 45:15

gathering [1] - 

23:18

general [4] - 

30:13, 30:16, 

53:15, 54:8

generally [1] - 

52:16

generated [2] - 

25:10, 55:18

generation [3] - 

33:7, 33:10, 

38:22

Generation [1] - 

13:15

George [3] - 2:10, 

41:7, 41:12

gigawatts [1] - 

55:18

GISCHIA [1] - 
EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

09/12/2012 06:32:53 PM Page 7 to 7 of 16 22 of 31 sheets

26:12

Gischia [5] - 2:7, 

22:2, 26:11, 

26:13, 31:5

given [2] - 15:11, 

26:8

glad [1] - 51:24

global [1] - 55:25

globally [1] - 

54:23

globe [1] - 55:12

goal [4] - 6:6, 

14:9, 26:22, 

54:14

goals [4] - 27:20, 

36:10, 37:5, 

39:15

God [1] - 56:13

good-paying [1] - 

14:16

GORDON [2] - 

12:11, 12:12

Gordon [5] - 2:3, 

9:18, 9:21, 10:9, 

12:12

Government [2] - 

23:13, 23:15

government [6] - 

13:22, 13:23, 

21:16, 21:23, 

34:24, 35:7

gradual [1] - 31:8

grate [6] - 24:8, 

24:9, 24:10, 

24:19, 33:7, 

33:17

grate-kiln [1] - 

33:17

great [4] - 11:7, 

18:1, 18:15, 

19:23

greater [4] - 16:8, 

16:16, 46:11, 

56:6

green [2] - 8:16, 

8:19

greenhouse [1] - 

25:10

ground [3] - 6:23, 

56:2, 58:1

groups [2] - 

18:22, 22:16

grow [1] - 10:25

Growers [1] - 41:3

guaranteed [1] - 

45:20

guess [1] - 59:11

guessing [1] - 

36:11

guidance [9] - 

28:2, 32:5, 38:2, 

42:17, 42:18, 

42:19, 43:9, 

43:25

Guidance [1] - 

42:20

guideline [1] - 

56:23

guidelines [4] - 

37:18, 43:15, 

43:23, 56:22

H

half [1] - 46:10

handful [1] - 55:23

handouts [1] - 7:9

hands [1] - 38:13

HAP [3] - 16:3, 

16:10, 17:7

happy [3] - 14:17, 

14:25, 17:24

HAPs [3] - 16:6, 

16:25, 17:20

hazardous [1] - 

16:12

haze [48] - 4:7, 

4:16, 4:20, 4:24, 

5:2, 5:19, 6:11, 

11:11, 11:12, 

11:14, 14:9, 

19:3, 19:4, 

19:10, 22:13, 

22:23, 23:5, 

23:7, 23:19, 

23:21, 26:2, 

26:7, 27:24, 

29:16, 31:3, 

31:7, 31:11, 

31:14, 31:18, 

34:16, 35:12, 

35:17, 35:21, 

36:5, 36:10, 

37:5, 39:7, 

39:15, 41:16, 

42:8, 42:17, 

43:1, 52:11, 

52:12, 52:14, 

52:15, 52:17

haze-causing [1] - 

23:21

hazy [1] - 11:11

heads [1] - 11:24

health [7] - 15:23, 

17:1, 18:19, 

19:8, 28:14, 

39:14, 39:18

Health [1] - 16:14

health-based [1] - 

39:14

health-related [1]

- 28:14

hear [2] - 3:2, 56:9

heard [2] - 47:23, 

52:22

hearing [20] - 3:4, 

3:11, 3:13, 3:22, 

7:3, 7:4, 7:6, 

7:12, 7:18, 7:20, 

7:24, 9:8, 9:20, 

10:1, 53:12, 

54:10, 57:19, 

57:21, 58:23, 

59:19

HEARING [1] - 1:2

Hearing [1] - 1:11

heart [1] - 19:11

heat [5] - 32:14, 

32:17, 32:19, 

33:3, 33:17

heating [1] - 48:8

help [3] - 8:17, 

15:22, 39:15

helped [2] - 41:20, 

53:7

hereby [1] - 60:8

Heriberto [3] - 3:8, 

6:22, 58:1

Hibbing [1] - 

30:14

high [2] - 14:15, 

33:6

higher [2] - 30:23, 

55:15

highlight [1] - 

26:19

highway [4] - 

54:23, 55:4, 

55:15, 56:17

history [2] - 11:6, 

35:23

hold [2] - 7:2, 8:19

holding [1] - 

53:12

home [1] - 10:16

Homer [2] - 13:14, 

41:1

hope [3] - 12:4, 

38:19, 51:25

hunting [1] - 

23:17

I

iceberg [1] - 51:22

iconic [1] - 19:13

idea [3] - 29:4, 

37:3, 37:12

identified [2] - 

48:7, 50:11

identify [1] - 18:3

ignored [1] - 32:7

ignores [1] - 31:25

imagine [1] - 

10:19

immediately [1] - 

9:5

impact [4] - 14:7, 

27:10, 29:8, 

48:20

impacting [1] - 

15:24

impacts [13] - 6:1, 

15:14, 15:15, 

16:11, 16:24, 

17:10, 31:2, 

31:7, 31:18, 

32:14, 33:19, 

33:24, 34:6

impaired [1] - 36:1

impairing [1] - 

15:24

impairment [1] - 

6:14

impairments [1] - 

19:6

implement [2] - 

6:3, 13:5

implementation

[21] - 3:6, 5:23, 

13:1, 14:5, 

22:12, 22:24, 

23:2, 27:24, 

28:3, 29:17, 

31:4, 31:13, 

31:20, 34:16, 

34:18, 35:12, 

40:15, 41:16, 

42:24, 43:2, 

47:18

Implementation

[1] - 1:4

implementations

[1] - 31:13

implemented [1] - 

57:4

implementing [3]

- 5:22, 26:2, 

35:21

implications [1] - 

48:17

important [4] - 

26:19, 27:13, 

31:6, 54:8

importantly [2] - 

37:10, 39:4

impose [1] - 37:11

imposed [1] - 35:5

SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

7

impressive [1] - 

11:10

improve [10] - 4:6, 

4:9, 5:19, 15:10, 

15:20, 15:21, 

16:2, 28:13, 

30:10, 30:11

improvement [2] - 

17:1, 46:3

improvements [1]

- 16:5

improving [1] - 

13:9

inadequate [2] - 

23:4, 39:24

include [3] - 

18:22, 20:16, 

49:19

included [3] - 

4:16, 4:21, 47:2

includes [2] - 

42:17, 46:13

including [3] - 

6:6, 23:17, 

25:10

inclusion [1] - 

46:6

incomplete [2] - 

45:5, 45:11

inconsistent [1] - 

43:25

increase [7] - 

15:13, 16:7, 

17:19, 33:19, 

33:21, 52:13, 

52:17

increased [6] - 

16:4, 16:9, 

16:10, 25:6, 

25:9, 49:7

increases [1] - 

17:8

increasing [2] - 

15:8, 17:20

independently [1]

- 32:3

indicate [5] - 8:20, 

9:1, 58:13, 

58:15, 58:17

indicated [2] - 

16:14, 37:9

indirect [1] - 27:9

indisputable [1] - 

47:21

individual [2] - 

35:3, 56:14

individuals [1] - 

56:13

indurating [3] - 

32:19, 32:24, 
EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

23 of 31 sheets Page 8 to 8 of 16 09/12/2012 06:32:53 PM

56:15

industrial [1] - 

48:21

industries [3] - 

19:23, 50:2, 

55:22

industry [37] - 

11:7, 11:22, 

12:1, 12:20, 

12:21, 15:12, 

16:21, 17:3, 

19:15, 19:24, 

20:6, 22:16, 

26:24, 28:11, 

28:25, 31:4, 

32:2, 32:11, 

34:19, 35:13, 

38:13, 38:23, 

39:17, 41:18, 

41:20, 41:25, 

44:22, 47:9, 

47:12, 55:11, 

55:14, 55:15, 

55:24, 55:25, 

56:8, 56:18, 

57:5

industry's [1] - 

20:15

infants [1] - 16:14

infeasible [1] - 

20:23

influence [1] - 

47:8

information [18] - 

7:5, 7:8, 17:12, 

17:17, 36:16, 

37:9, 37:16, 

37:24, 40:12, 

43:3, 43:6, 

43:24, 44:2, 

44:3, 45:12, 

45:16, 50:23, 

58:10

ingredient [1] - 

26:24

inherently [1] - 

28:17

initial [1] - 38:25

initiative [1] - 30:9

Initiatives [1] - 

30:7

innocuous [1] - 

49:14

input [1] - 55:6

install [3] - 6:8, 

24:17, 25:20

installation [4] - 

25:14, 25:21, 

25:25, 26:3

installed [2] - 

24:7, 24:8

installing [2] - 

24:18, 45:6

instance [2] - 

35:4, 52:8

instances [1] - 

20:18

instead [2] - 

20:14, 34:17

Institute [1] - 18:6

instructions [2] - 

3:13, 7:10

insufficiencies [1]

- 21:1

integrity [1] - 47:9

intended [2] - 

5:13, 35:25

intense [2] - 44:5, 

44:15

intent [1] - 28:19

interested [3] - 

27:20, 57:9, 

58:5

introduced [1] - 

33:9

introduction [1] - 

26:21

invalid [1] - 36:5

invest [1] - 19:25

invested [3] - 

35:11, 55:6, 

56:7

investigation [1] - 

17:7

invite [1] - 53:17

involved [5] - 

21:22, 22:10, 

28:1, 51:17, 

52:2

involvement [1] - 

3:9

iron [15] - 15:11, 

17:3, 26:15, 

26:24, 27:1, 

27:5, 27:6, 30:8, 

30:20, 30:23, 

30:24, 33:1, 

44:22, 55:25, 

56:1

Iron [5] - 15:12, 

16:15, 17:11, 

30:7, 38:14

iron-bearing [1] - 

30:24

iron-ore-bearing

[1] - 30:23

irresponsible [1] - 

29:5

Isle [1] - 4:11

issue [3] - 27:21, 

33:12, 52:25

issues [3] - 17:10, 

51:12, 51:17

issuing [1] - 23:1

J

Jackson [3] - 

12:15, 12:17, 

47:1

January [2] - 37:1, 

43:5

jeopardize [1] - 

14:16

job [4] - 7:18, 

14:15, 52:24, 

55:24

jobs [4] - 12:4, 

14:8, 14:14, 

14:16

joining [1] - 3:15

Juhnke [1] - 9:23

June [1] - 4:23

K

K-E-V-I-N [1] - 

18:16

keep [1] - 8:17

Kevin [3] - 2:5, 

15:2, 18:15

key [2] - 25:3, 

26:24

kids [1] - 54:15

kiln [6] - 24:8, 

24:9, 24:10, 

24:19, 33:8, 

33:17

kind [1] - 58:1

knowledge [2] - 

29:7, 32:9

knowledgeable

[1] - 32:19

known [1] - 4:13

knows [2] - 49:17, 

49:25

L

L-A-G-E [1] - 54:5

l-e-g-a-l-e-c-t-r-ic [1] - 51:10

Lac [2] - 22:6, 

22:10

Lafayette [1] - 

1:12

Lake [3] - 10:22, 

16:16, 23:12

Lakeville [1] - 

53:25

Land [1] - 11:24

land [1] - 22:16

lands [1] - 23:20

large [2] - 44:19, 

55:5

larger [1] - 5:24

last [5] - 12:11, 

41:13, 45:23, 

59:1, 59:17

lead [3] - 25:5, 

25:8, 33:20

leading [1] - 42:25

least [1] - 53:7

leave [1] - 38:12

leaves [1] - 35:3

left [1] - 11:7

legal [1] - 18:16

Legalectric [1] - 

51:10

legislative [1] - 

35:23

legislators [1] - 

12:7

legitimate [3] - 

34:3, 39:1, 

42:15

lengthy [4] - 

18:20, 42:15, 

44:5, 44:16

LEON [18] - 3:1, 

6:24, 14:21, 

15:2, 18:7, 

21:11, 21:25, 

26:10, 29:22, 

30:1, 34:9, 41:6, 

46:20, 51:6, 

53:14, 53:21, 

57:8, 58:4

Leon [1] - 3:8

less [1] - 50:17

letter [1] - 46:25

level [1] - 16:18

levels [5] - 10:18, 

10:24, 39:21, 

50:2, 50:13

lie [1] - 23:9

light [3] - 18:10, 

27:19, 41:11

lightly [2] - 47:20, 

48:22

likely [1] - 40:5

limit [4] - 8:7, 

8:18, 34:5, 

46:11

limited [1] - 37:10

limits [21] - 4:16, 

4:21, 4:25, 5:6, 

5:9, 5:11, 5:12, 

SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

8

5:16, 6:15, 6:20, 

13:18, 31:22, 

42:11, 46:9, 

46:13, 48:4, 

49:10, 49:12, 

49:19, 50:6

line [3] - 9:6, 

25:24, 25:25

list [2] - 9:15, 

57:13

listen [4] - 5:8, 

6:19, 7:18, 34:7

listened [1] - 

54:11

lit [1] - 18:12

live [4] - 10:15, 

11:13, 46:23, 

53:25

livelihood [1] - 

12:21

lobbyists [1] - 

53:9

local [3] - 15:24, 

16:18, 17:1

localized [1] - 

16:11

lone [1] - 42:7

long-range [1] - 

39:6

long-term [2] - 

31:12, 41:15

look [18] - 21:3, 

30:10, 48:15, 

50:13, 50:15, 

51:2, 51:13, 

51:25, 52:20, 

53:1, 54:19, 

54:21, 55:4, 

55:11, 55:16, 

55:22, 55:24, 

59:6

looked [4] - 47:6, 

50:4, 56:25

looking [3] - 8:23, 

55:7

looks [2] - 50:15, 

58:19

love [1] - 12:3

low [11] - 16:18, 

24:3, 24:17, 

24:20, 24:25, 

25:8, 25:16, 

26:4, 33:5, 

33:11, 50:11

low-level [1] - 

16:18

lower [2] - 49:2, 

50:2

lunch [1] - 59:10

lung [1] - 19:10
EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

09/12/2012 06:32:53 PM Page 9 to 9 of 16 24 of 31 sheets

M

M-C-W-I-L-L-I-AM-S [1] - 34:12

M-L-I-N-A-R [1] - 

30:5

magnitude [1] - 

48:13

main [1] - 20:11

maintenance [1] - 

3:16

major [2] - 4:6, 6:7

majority [1] - 

25:17

manager [4] - 

22:7, 30:13, 

30:16, 30:20

managers [1] - 

22:16

March [1] - 42:21

margin [1] - 46:13

marine [3] - 54:23, 

55:11, 56:17

market [2] - 28:7, 

55:5

marketability [1] - 

29:9

massive [1] - 

48:20

matter [2] - 23:5, 

55:9

Matthew [2] - 

2:13, 53:25

MCEA [1] - 18:18

MCWILLIAMS [4]

- 34:10, 38:10, 

40:22, 40:25

McWilliams [4] - 

2:9, 34:9, 34:11

mean [1] - 52:8

means [2] - 3:11, 

46:10

measure [1] - 49:1

measured [2] - 

38:24, 39:23

measures [1] - 6:4

mechanical [1] - 

54:18

meet [5] - 13:25, 

33:2, 36:22, 

39:15, 56:22

meeting [4] - 14:9, 

39:10, 53:2, 

59:16

meetings [1] - 

22:20

meets [1] - 31:12

member [1] - 

22:14

members [4] - 

8:10, 19:2, 21:6, 

53:4

men [1] - 27:8

mention [1] - 48:6

mercury [6] - 

10:24, 16:6, 

16:16, 16:19, 

17:10, 17:17

Mesaba [1] - 

52:13

mesothelioma [1]

- 10:18

Met [1] - 1:15

Michigan [21] - 

1:4, 3:7, 4:20, 

4:21, 5:4, 5:7, 

22:25, 27:3, 

29:14, 30:17, 

32:4, 34:2, 35:9, 

36:14, 38:15, 

38:16, 38:20, 

40:17, 41:19, 

42:5, 44:13

MICHIGAN [1] - 

1:8

Michigan's [3] - 

5:1, 30:18, 

37:23

mid [1] - 20:10

middle [1] - 12:2

might [2] - 40:3, 

49:13

Mike [5] - 2:8, 

29:24, 29:25, 

30:1, 30:5

MIKE [1] - 30:5

mill [1] - 56:3

Miller [5] - 2:11, 

41:8, 46:21, 

46:23, 52:18

MILLER [1] - 

46:22

million [4] - 23:11, 

27:4, 50:14, 

55:17

millions [3] - 55:6, 

55:7, 55:19

mine [1] - 11:5

Mine [1] - 5:16

Mineral [1] - 11:24

Mines [1] - 18:6

mines [2] - 13:7, 

30:17

minimal [1] - 21:9

minimizing [1] - 

15:14

Mining [1] - 30:14

mining [12] - 

10:13, 11:4, 

11:22, 12:1, 

12:19, 12:21, 

14:10, 14:14, 

26:23, 30:20, 

32:11, 47:8

Minnesota [59] - 

1:4, 1:11, 1:12, 

3:7, 4:15, 4:18, 

5:7, 10:12, 

10:19, 10:23, 

11:3, 11:16, 

12:7, 12:8, 

12:19, 13:2, 

13:7, 14:8, 

14:10, 14:13, 

15:7, 15:10, 

16:13, 16:22, 

18:17, 19:2, 

22:24, 23:11, 

26:7, 27:3, 

29:15, 30:15, 

32:4, 32:8, 34:2, 

35:9, 36:13, 

36:25, 38:15, 

38:16, 38:20, 

39:7, 40:16, 

41:18, 41:23, 

42:6, 42:14, 

42:19, 42:25, 

43:5, 43:10, 

44:13, 46:24, 

47:9, 47:10, 

51:18, 51:23, 

54:1, 54:14

MINNESOTA [2] - 

1:7, 60:1

Minnesota's [5] - 

4:24, 19:13, 

37:21, 39:4, 

42:23

MinnesotaDuluth [1] - 

14:13

Minnesotans [1] - 

14:4

Minntac [3] - 

19:17, 25:15, 

48:8

Minntac's [1] - 

24:7

minute [5] - 8:17, 

8:21, 45:8, 

58:13, 58:15

minutes [12] - 8:7, 

8:19, 8:25, 9:2, 

9:3, 38:8, 49:17, 

53:23, 57:14, 

58:14, 58:16, 

59:18

Mlinar [4] - 2:8, 

29:25, 30:1, 

30:5

MLINAR [2] - 

29:25, 30:3

modelers [1] - 

40:7

modeling [1] - 

39:9

modern [1] - 

19:25

moment [3] - 3:14, 

3:23, 59:9

money [1] - 57:1

monitoring [1] - 

4:3

month [1] - 25:24

months [5] - 

10:21, 40:2, 

40:3, 40:5, 

45:15

morning [15] - 

1:17, 3:1, 3:2, 

3:3, 15:5, 18:9, 

22:4, 22:8, 

26:12, 30:3, 

30:4, 46:22, 

47:23, 51:8, 

58:5

most [4] - 4:23, 

28:4, 53:2, 

55:25

motion [1] - 52:6

move [3] - 7:13, 

14:22, 24:14

movement [1] - 

50:1

moving [1] - 14:18

MPCA [12] - 19:17, 

20:5, 41:23, 

41:25, 43:22, 

47:12, 48:24, 

52:1, 52:3, 

52:11, 52:15, 

52:24

MPCA's [2] - 19:3, 

52:20

MR [65] - 3:1, 4:2, 

6:24, 10:11, 

12:10, 12:11, 

14:20, 14:21, 

14:23, 15:2, 

15:5, 17:15, 

17:23, 18:1, 

18:3, 18:5, 18:7, 

18:8, 18:10, 

18:13, 18:14, 

18:15, 21:11, 

21:12, 21:25, 

22:4, 26:9, 

26:10, 26:12, 

SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

9

29:21, 29:22, 

29:25, 30:1, 

30:3, 34:8, 34:9, 

34:10, 38:9, 

38:10, 40:19, 

40:22, 40:23, 

40:25, 41:5, 

41:6, 41:10, 

46:20, 46:22, 

51:5, 51:6, 

53:13, 53:14, 

53:18, 53:21, 

53:24, 54:4, 

54:7, 57:7, 57:8, 

57:10, 57:18, 

58:4, 58:19, 

59:8, 59:15

MS [1] - 51:8

must [3] - 28:7, 

38:3, 43:16

muted [1] - 18:11

N

name [19] - 8:1, 

8:3, 8:4, 12:11, 

15:5, 21:14, 

22:4, 26:12, 

30:4, 34:10, 

41:12, 41:13, 

46:22, 51:7, 

51:8, 53:21, 

53:25, 58:9

name's [1] - 3:8

namely [1] - 5:15

names [1] - 10:7

national [6] - 4:3, 

4:9, 6:5, 19:6, 

27:16, 39:14

National [8] - 

4:10, 4:12, 

18:22, 18:23, 

19:19, 21:8, 

23:8

Natural [5] - 

11:23, 26:15, 

26:21, 30:6, 

34:14

natural [7] - 4:6, 

11:12, 11:19, 

12:3, 15:11, 

15:15, 49:16

near [1] - 52:5

nearly [3] - 14:11, 

27:5, 27:8

necessary [6] - 

6:4, 9:10, 28:9, 

39:10, 39:13, 

40:12

need [8] - 9:15, 
EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

25 of 31 sheets Page 10 to 10 of 16 09/12/2012 06:32:53 PM

17:8, 40:1, 40:2, 

40:7, 43:19, 

44:25, 47:20

needed [7] - 

13:11, 16:23, 

17:10, 30:24, 

43:15, 44:25, 

45:19

needs [1] - 14:4

negative [3] - 

33:14, 33:23, 

48:22

negatively [2] - 

14:7, 29:8

new [12] - 15:16, 

36:15, 37:9, 

37:16, 37:24, 

43:3, 43:6, 

43:12, 44:1, 

44:3, 45:4, 

45:18

newer [1] - 37:3

next [7] - 14:22, 

22:1, 29:23, 

38:22, 54:16, 

56:22, 57:13

nine [1] - 22:15

nitrification [1] - 

23:23

nitrogen [4] - 

5:11, 5:13, 44:7, 

50:12

nitrous [1] - 15:18

NO [2] - 1:7, 1:8

NO2 [2] - 39:9, 

39:11

nobody's [1] - 

49:14

noncompliance

[1] - 46:12

none [3] - 32:20, 

32:25, 49:17

noon [1] - 9:11

North [5] - 16:15, 

17:11, 30:7, 

30:13, 48:9

northeastern [2] - 

13:7, 26:7

northern [5] - 

10:19, 10:23, 

11:3, 12:8, 

38:14

note [3] - 17:5, 

51:14, 52:25

notes [1] - 60:11

nothing [1] - 20:5

notice [4] - 1:15, 

6:16, 7:17, 8:22

novel [1] - 20:3

November [2] - 

4:19, 7:16

NOx [21] - 20:21, 

24:3, 24:17, 

24:20, 24:25, 

25:1, 25:8, 

25:16, 26:4, 

33:10, 33:11, 

33:12, 33:18, 

39:5, 39:9, 

39:12, 42:3, 

48:8, 49:3, 

50:11, 55:10

number [7] - 

18:18, 20:17, 

22:17, 28:4, 

55:1, 55:16

numbers [6] - 

10:19, 10:24, 

11:13, 55:12, 

55:13, 55:18

numerical [1] - 

42:11

numerous [2] - 

22:20, 26:1

O

objections [1] - 

45:10

objective [1] - 

31:6

objectively [1] - 

47:6

obligation [1] - 

39:1

obtain [1] - 13:10

obviously [1] - 

48:10

occur [1] - 16:24

OEM [2] - 32:16, 

33:16

OEMs [6] - 55:1, 

55:6, 55:13, 

55:18, 55:23, 

56:7

OF [2] - 60:1, 60:2

offer [4] - 9:4, 

39:9, 59:11

offered [1] - 59:2

office [6] - 3:10, 

3:17, 3:18, 9:18, 

9:23, 12:12

Office [1] - 3:19

officer [1] - 3:11

official [1] - 7:21

officially [1] - 

59:18

often [1] - 5:24

oil [8] - 49:11, 

49:13, 49:22, 

49:25, 50:3, 

50:4, 50:6, 50:7

old [2] - 10:13, 

26:22

older [1] - 5:25

on-highway [1] - 

55:4

one [23] - 8:21, 

19:17, 31:25, 

32:22, 33:12, 

40:19, 40:25, 

45:8, 45:23, 

48:3, 49:3, 49:4, 

49:12, 50:21, 

51:6, 52:2, 

53:22, 56:12, 

56:14, 57:3, 

58:15, 59:16

one-off [1] - 57:3

one-size-fits-all

[1] - 32:22

ones [2] - 20:11, 

32:18

open [2] - 7:3, 

28:7

operate [1] - 6:9

operating [3] - 

13:6, 44:8, 

49:24

operation [2] - 

26:15, 31:2

operations [5] - 

13:13, 27:3, 

29:5, 30:9, 

46:14

operator [1] - 

50:21

operators [1] - 

28:21

opinion [3] - 

13:14, 32:12, 

47:21

opportunities [2]

- 27:15, 51:3

opportunity [8] - 

17:14, 26:20, 

29:19, 30:4, 

34:7, 51:16, 

57:14, 59:2

optimistic [1] - 

46:1

option [1] - 24:6

options [1] - 39:18

orally [1] - 59:3

order [6] - 5:25, 

7:13, 7:19, 8:6, 

43:16, 48:13

ore [14] - 15:12, 

17:3, 26:15, 

26:24, 27:1, 

27:5, 27:7, 30:8, 

30:20, 30:23, 

33:1, 55:25, 

56:1, 56:6

Ore [1] - 30:7

organization [2] - 

18:4, 22:18

organizations [3]

- 18:19, 19:1, 

21:5

oriented [1] - 

54:20

original [4] - 4:18, 

4:20, 20:24, 

41:21

originate [1] - 

27:1

ought [2] - 50:3, 

50:7

ourselves [1] - 

59:9

outlined [1] - 

31:12

outside [3] - 

28:18, 34:12, 

34:13

outweighed [1] - 

47:9

overall [4] - 15:21, 

27:14, 30:11, 

48:20

overdue [2] - 20:4, 

21:10

OVERLAND [1] - 

51:8

Overland [3] - 

2:12, 51:7, 51:9

own [4] - 28:2, 

37:18, 43:9, 

56:15

oxide [5] - 5:11, 

5:13, 15:19, 

50:12, 50:17

oxides [2] - 44:7, 

49:8

P

P-R-U-C-H-N-O-F

-S-K-I [1] - 41:13

p.m [2] - 9:9, 

59:20

PAGE [1] - 2:1

pages [1] - 60:10

paid [1] - 53:9

pairs [1] - 7:25

panel [1] - 8:10

paper [5] - 8:16, 

SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

10

8:23, 9:1, 58:15, 

58:17

Park [7] - 4:10, 

4:12, 18:23, 

18:24, 19:19, 

21:8, 23:8

Parks [1] - 18:22

parks [5] - 4:4, 

4:6, 4:9, 20:1, 

54:16

Part [2] - 37:18, 

42:18

part [6] - 7:21, 

27:13, 29:4, 

32:18, 39:6, 

44:19

participate [4] - 

9:20, 35:6, 

35:10, 52:10

participated [1] - 

22:20

participating [1] - 

10:5

participation [1] - 

53:6

particular [2] - 

35:4, 35:5

particularly [4] - 

24:2, 38:2, 

47:13, 50:5

particulate [1] - 

55:9

Partnership [1] - 

22:15

Party [1] - 18:5

past [1] - 22:11

Pat [1] - 10:14

path [1] - 39:23

patience [1] - 9:14

pattern [1] - 51:22

paul [1] - 1:12

pave [1] - 27:14

paying [1] - 14:16

peer [1] - 36:19

pellet [2] - 31:2, 

39:20

pelletizing [1] - 

38:18

pellets [1] - 30:24

peninsula [1] - 

38:15

Peninsula [1] - 

30:18

people [14] - 7:4, 

11:18, 12:2, 

16:15, 21:15, 

21:22, 53:2, 

53:4, 53:8, 53:9, 

56:7, 57:20, 

57:22, 58:20
EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

09/12/2012 06:32:53 PM Page 11 to 11 of 16 26 of 31 sheets

per [6] - 24:22, 

25:25, 46:2, 

46:3, 48:7, 

50:14

percent [3] - 

19:19, 33:20, 

49:23

perform [1] - 40:8

performance [1] - 

30:11

performed [2] - 

24:13, 32:1

period [4] - 40:8, 

40:11, 43:4, 

43:19

periods [2] - 

49:20, 50:6

peripherally [1] - 

51:17

permitted [1] - 

44:12

perplexing [1] - 

32:7

perspective [2] - 

31:1, 41:15

persuaded [1] - 

48:25

Peters [1] - 23:16

pilot [5] - 24:13, 

31:22, 32:9, 

33:7, 33:11

place [4] - 25:2, 

35:20, 50:21, 

54:22

places [2] - 19:14, 

48:2

plan [27] - 3:6, 

4:16, 4:20, 4:24, 

5:2, 5:4, 5:23, 

13:1, 14:5, 20:5, 

22:24, 23:2, 

27:24, 29:16, 

31:4, 31:11, 

31:13, 31:15, 

31:20, 34:16, 

37:6, 39:24, 

40:16, 42:24, 

43:2, 47:18, 

56:14

Plan [1] - 1:4

plane [1] - 33:9

planning [1] - 

3:16

plans [5] - 29:17, 

34:18, 35:13, 

35:15, 41:16

plants [9] - 10:16, 

13:10, 14:7, 

16:6, 19:18, 

23:24, 52:5, 

54:25, 55:17

play [1] - 13:22

pleasant [1] - 

47:11

point [5] - 28:25, 

52:7, 53:19, 

55:8, 57:19

Pointe [1] - 23:14

points [3] - 43:3, 

43:13, 48:5

political [1] - 47:8

pollutant [1] - 

25:3

pollutants [7] - 

13:24, 16:12, 

19:9, 23:22, 

25:5, 25:9, 

25:11

polluting [2] - 

19:15, 19:25

Pollution [10] - 

1:11, 11:17, 

13:3, 22:25, 

29:15, 32:8, 

41:23, 42:14, 

51:18, 51:23

pollution [9] - 

13:20, 15:24, 

17:2, 19:23, 

20:9, 21:7, 25:4, 

41:2, 52:8

poorly [1] - 49:5

portion [2] - 23:3, 

23:11

position [4] - 

30:8, 30:12, 

38:3, 38:21

positive [1] - 

15:14

possible [1] - 29:3

potential [8] - 

13:6, 15:7, 16:8, 

23:22, 32:14, 

33:13, 52:11, 

52:13

potentials [2] - 

15:25, 17:7

pounds [1] - 50:14

power [4] - 54:25, 

55:16, 55:18, 

56:18

practices [2] - 

42:2, 44:8

preceding [1] - 

60:10

preliminary [3] - 

37:7, 45:24, 

45:25

premature [1] - 

37:8

preparing [1] - 

43:7

present [1] - 59:16

presented [2] - 

27:23, 36:16

presents [3] - 

13:6, 28:4, 

28:20

preserving [1] - 

39:19

president [3] - 

30:6, 30:13, 

30:16

press [1] - 18:11

pretty [1] - 50:15

prevent [1] - 25:1

prevention [1] - 

25:4

previous [1] - 

11:20

previously [1] - 

46:24

price [1] - 15:15

prices [2] - 49:14, 

49:18

primarily [2] - 

19:5, 51:12

primary [8] - 

13:25, 29:11, 

33:8, 34:25, 

35:15, 35:16, 

36:9, 37:14

principal [1] - 

41:14

problem [2] - 

24:16, 52:11

problems [2] - 

24:18, 25:6

procedure [1] - 

7:23

procedures [2] - 

3:12, 3:21

proceed [1] - 9:14

proceeding [6] - 

10:5, 42:14, 

46:25, 47:5, 

52:7, 58:2

proceedings [2] - 

48:25, 60:13

Proceedings [1] - 

59:20

process [22] - 

5:18, 16:7, 28:3, 

30:22, 32:18, 

33:1, 33:8, 

33:24, 36:22, 

38:6, 42:9, 

42:13, 42:16, 

42:23, 43:14, 

43:17, 47:10, 

52:25, 54:20, 

56:4, 56:5, 

56:16

processoriented [1] - 

54:20

processes [2] - 

28:22, 56:16

processing [4] - 

15:12, 15:20, 

16:20, 30:21

procure [1] - 6:8

produce [4] - 

27:4, 33:22, 

36:23

produced [3] - 

14:14, 15:19, 

25:3

producer [1] - 

28:6

product [7] - 

24:18, 25:23, 

28:5, 28:7, 29:9, 

31:2, 32:15

production [5] - 

5:13, 5:14, 

39:20, 54:25, 

56:18

productions [1] - 

5:18

products [2] - 

26:23, 30:10

professional [1] - 

30:19

professional's [1]

- 45:2

professionals [1]

- 44:21

profile [1] - 33:23

program [3] - 

22:7, 28:13, 

35:21

progress [5] - 6:5, 

14:9, 19:23, 

31:17, 34:5

progresses [1] - 

9:16

project [2] - 52:4, 

52:13

promote [1] - 29:6

promotes [1] - 

38:2

promulgated [1] - 

22:13

properly [1] - 57:4

proposal [3] - 7:2, 

7:16, 15:21

propose [1] - 44:3

Proposed [1] - 1:4

proposed [43] - 

SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

11

3:5, 3:25, 5:1, 

5:6, 5:9, 5:10, 

6:15, 6:20, 

12:23, 14:5, 

15:13, 16:1, 

16:8, 16:24, 

17:5, 18:21, 

20:12, 20:15, 

20:22, 24:1, 

25:22, 26:5, 

28:16, 29:1, 

31:3, 34:1, 

34:15, 36:7, 

36:25, 37:23, 

38:10, 39:2, 

40:13, 40:15, 

42:24, 43:5, 

44:10, 45:3, 

45:14, 46:8, 

46:16, 52:4

proposing [1] - 

37:2

protect [1] - 23:20

protected [1] - 

13:9

PROTECTION [1]

- 1:1

protection [2] - 

35:19, 35:24

Protection [3] - 

3:5, 4:5, 12:5

proves [1] - 38:11

provide [5] - 3:24, 

9:20, 31:1, 

34:15, 43:16

provided [2] - 

41:22, 42:9

provides [1] - 

14:10

providing [1] - 

46:5

provisions [2] - 

35:17, 35:24

Pruchnofski [5] - 

2:10, 41:7, 41:9, 

41:12, 46:20

PRUCHNOFSKI

[1] - 41:10

Public [1] - 52:8

public [16] - 3:4, 

7:22, 17:1, 

18:19, 19:7, 

37:20, 43:11, 

43:19, 53:4, 

53:5, 53:6, 

54:10, 57:19, 

57:21, 58:2, 

58:22

PUBLIC [1] - 1:2

public's [2] - 20:1
EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

27 of 31 sheets Page 12 to 12 of 16 09/12/2012 06:32:53 PM

published [3] - 

5:5, 12:23, 

42:18

purify [1] - 56:5

pursuant [1] - 

1:15

push [1] - 48:3

pushed [1] - 56:24

put [4] - 22:23, 

29:13, 55:19, 

56:3

Q

quality [15] - 4:6, 

13:23, 15:10, 

15:14, 15:25, 

27:16, 28:5, 

29:9, 31:2, 

32:15, 33:24, 

34:24, 39:19, 

40:12, 54:12

Quality [2] - 23:1, 

29:15

questionable [1] - 

37:24

questions [2] - 

8:10, 9:25

quick [1] - 28:15

quite [4] - 29:1, 

48:12, 54:13, 

55:3

quote [8] - 13:16, 

34:23, 35:8, 

35:25, 36:3, 

41:3, 43:12, 

43:21

quoted [1] - 40:23

R

R-E-U-T-H-E-R [1]

- 18:16

rain [1] - 15:25

raise [1] - 8:25

range [3] - 10:15, 

24:22, 39:6

Range [5] - 15:12, 

16:15, 17:11, 

38:14, 52:4

rate [1] - 40:4

rated [1] - 27:4

rates [1] - 45:20

rather [4] - 13:19, 

25:2, 38:11, 

47:12

reach [1] - 37:5

reached [1] - 32:3

read [1] - 22:8

readiness [1] - 

32:9

really [3] - 20:2, 

49:17, 56:25

reasonable [7] - 

6:5, 13:19, 14:9, 

26:3, 29:13, 

31:17, 34:4

reasonably [3] - 

9:9, 43:22, 50:9

reasoned [1] - 

39:22

reasons [1] - 

23:25

rebuttal [1] - 7:5

received [1] - 7:13

recent [1] - 12:22

recently [4] - 

16:13, 27:16, 

34:22, 35:23

recognition [1] - 

27:17

recognize [4] - 

27:25, 28:8, 

29:12, 47:7

reconsider [1] - 

12:25

reconvening [1] - 

59:10

record [6] - 7:3, 

7:21, 19:16, 

29:20, 34:15, 

46:19

red [5] - 8:16, 

8:25, 18:10, 

41:11, 58:17

Red [2] - 46:24, 

51:11

reduce [10] - 5:19, 

15:22, 20:9, 

21:7, 31:7, 

31:13, 33:10, 

34:5, 37:4, 49:3

reducing [5] - 

15:18, 15:25, 

19:9, 31:10, 

31:18

reduction [14] - 

17:1, 19:24, 

21:19, 27:13, 

31:8, 39:12, 

40:4, 46:2, 49:1, 

50:13, 50:16, 

55:3, 55:9, 

56:11

reductions [9] - 

27:18, 27:23, 

29:2, 39:5, 

39:14, 48:4, 

48:8, 54:22, 

55:20

references [1] - 

49:21

refine [1] - 56:5

refinery [1] - 

49:24

reflect [1] - 6:16

Refuge [1] - 4:13

refuse [1] - 35:9

refuses [1] - 35:6

regard [4] - 20:13, 

20:21, 24:2, 

49:7

regarding [2] - 

51:17, 52:15

region [2] - 15:22, 

47:14

Region [8] - 3:10, 

3:17, 3:20, 

22:23, 24:1, 

24:2, 24:5, 

25:22

Regional [2] - 

3:19, 22:14

regional [33] - 4:7, 

4:16, 4:24, 5:2, 

5:19, 6:11, 14:9, 

22:12, 22:23, 

23:5, 23:7, 

23:19, 26:2, 

26:7, 27:23, 

29:16, 31:3, 

31:7, 31:11, 

31:14, 34:16, 

35:12, 35:17, 

35:21, 36:5, 

36:10, 37:5, 

39:6, 39:15, 

41:16, 42:8, 

42:17, 43:1

Register [3] - 5:6, 

6:16, 12:23

registered [1] - 

9:12

registration [6] - 

7:9, 8:14, 9:13, 

10:2, 57:24, 

58:6

regular [1] - 53:8

regulate [1] - 

52:21

regulates [1] - 

35:7

regulating [2] - 

14:1, 38:17

regulation [3] - 

5:10, 42:8, 

52:18

regulations [3] - 

12:6, 21:16, 

36:5

regulators [1] - 

12:7

regulatory [5] - 

13:17, 37:8, 

38:6, 47:10, 

50:6

rejecting [2] - 

19:3, 20:5

rejection [1] - 13:1

relate [1] - 16:3

related [6] - 7:5, 

17:10, 17:12, 

28:14, 33:21, 

52:15

relationship [1] - 

34:22

relied [2] - 21:1, 

42:5

relies [1] - 44:10

rely [1] - 37:16

remain [2] - 8:7, 

31:9

remains [1] - 40:8

remember [1] - 

21:13

reminder [1] - 

21:12

render [1] - 42:6

reopen [1] - 57:18

reopened [1] - 

44:1

replaces [2] - 

23:2, 39:23

replicate [1] - 

38:19

report [3] - 10:21, 

41:23, 41:25

reporter [3] - 7:18, 

8:4, 21:14

REPORTER [3] - 

1:20, 54:2, 54:6

Reporter [1] - 

60:19

reporter's [1] - 

21:20

REPORTER'S [1]

- 60:5

represent [3] - 

18:4, 19:1, 27:3

representations

[1] - 48:18

represents [1] - 

27:5

request [6] - 

12:25, 13:8, 

14:3, 31:14, 

41:21, 52:9

requesting [1] - 

45:17

SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

12

requests [1] - 

29:12

require [5] - 5:13, 

17:6, 21:6, 26:3, 

43:25

required [7] - 

20:5, 20:18, 

28:9, 39:7, 44:6, 

44:16, 58:21

requirement [1] - 

6:6

requirements [2] - 

22:12, 23:19

requires [2] - 6:3, 

33:8

research [3] - 

16:23, 55:20, 

56:10

researched [2] - 

56:25, 57:4

Reservation [1] - 

22:6

reserves [2] - 

15:16, 27:1

resident [1] - 15:6

residents [1] - 

16:17

resolve [1] - 33:11

resources [7] - 

11:20, 12:3, 

14:1, 23:23, 

32:16, 35:11, 

38:21

Resources [5] - 

11:23, 26:15, 

26:22, 30:6, 

34:14

respect [1] - 31:15

respectively [1] - 

44:14

respects [1] - 

48:21

respiratory [1] - 

15:23

respond [1] - 

41:21

response [1] - 

18:21

responsibilities

[2] - 47:13, 47:14

responsibility [5]

- 13:25, 29:11, 

30:8, 34:25, 

35:15

responsible [2] - 

26:23, 32:17

restart [1] - 57:21

restrictions [1] - 

35:4

result [5] - 15:8, 
EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

09/12/2012 06:32:53 PM Page 13 to 13 of 16 28 of 31 sheets

16:2, 16:10, 

16:18, 16:24

resulting [2] - 

16:5, 46:12

results [1] - 25:13

retain [1] - 34:25

retains [1] - 23:16

retire [1] - 11:25

retired [2] - 10:13, 

10:15

retrofit [12] - 5:24, 

6:9, 6:17, 13:4, 

21:18, 24:3, 

28:15, 36:12, 

40:6, 41:17, 

41:24, 45:1

retrofitted [1] - 

31:21

retrofitting [1] - 

33:5

REUTHER [3] - 

18:8, 18:13, 

18:15

Reuther [5] - 2:5, 

15:2, 18:7, 

18:16, 47:25

review [6] - 18:20, 

26:7, 37:7, 

43:10, 45:24, 

45:25

reviewed [2] - 

35:23, 36:19

reviewing [1] - 

22:23

reviews [4] - 

36:21, 43:8, 

44:6, 44:16

revolving [1] - 

12:1

ridding [1] - 19:5

rights [1] - 23:17

risk [2] - 13:6, 

28:5

Road [1] - 1:12

rock [1] - 30:23

ROHDE [3] - 15:5, 

17:23, 18:5

Rohde [4] - 2:4, 

15:2, 15:4, 15:6

role [5] - 31:6, 

35:16, 36:9, 

37:14, 52:21

roles [1] - 13:23

Room [1] - 1:11

Rosenthal [1] - 

3:17

roughly [5] - 

23:10, 24:22, 

25:24, 27:10, 

46:10

routinely [1] - 

11:24

Royale [1] - 4:11

rule [17] - 3:25, 

6:11, 7:14, 7:22, 

12:23, 15:8, 

15:13, 18:21, 

19:4, 20:12, 

20:15, 20:22, 

22:13, 23:7, 

23:19, 26:2, 

41:2

rules [6] - 4:7, 

6:23, 16:25, 

34:21, 36:5, 

58:2

ruling [2] - 40:21, 

40:24

S

S-C-O-T-T [1] - 

26:13

Safe [1] - 18:6

safety [1] - 46:14

Sam [1] - 54:4

Sanders [1] - 

34:13

Sarah [5] - 8:13, 

9:13, 10:1, 

57:12, 58:6

satisfied [2] - 

50:9, 50:17

satisfy [1] - 33:15

saw [1] - 52:11

scale [3] - 24:12, 

24:14, 29:2

scenic [1] - 19:5

schedule [3] - 

25:22, 26:4, 

54:9

scheduled [1] - 

7:24

scheme [1] - 

58:12

scope [1] - 28:18

Scott [5] - 2:7, 

22:1, 26:11, 

26:12, 31:5

SCR [2] - 21:18, 

50:18

SCRs [5] - 20:22, 

20:23, 21:2, 

21:3, 21:4

scrubbing [1] - 

50:24

seated [1] - 8:8

seats [1] - 57:20

second [4] - 

15:18, 24:20, 

36:11, 41:3

secondguessing [1] - 

36:11

secondary [1] - 

25:5

secondly [1] - 

33:22

seconds [2] - 

8:25, 58:16

secretary/

treasurer [1] - 

22:18

section [1] - 3:17

Section [3] - 5:21, 

6:2, 35:19

sectors [1] - 50:1

secured [1] - 

28:15

see [7] - 10:1, 

11:14, 20:12, 

50:20, 50:23, 

51:24, 57:12

seeing [2] - 50:1, 

51:21

seem [3] - 49:11, 

49:13, 49:23

selected [1] - 

21:19

selection [1] - 

25:4

sell [1] - 28:7

Senator [1] - 9:23

Seney [1] - 4:12

sense [3] - 27:19, 

38:3, 44:4

September [6] - 

7:1, 7:7, 20:11, 

59:1, 59:4, 

60:14

serious [3] - 

27:25, 28:5, 

31:19

serving [2] - 3:10, 

22:17

session [2] - 9:9, 

53:7

set [2] - 8:18, 

13:19

sets [2] - 13:23, 

34:24

setting [1] - 49:19

settlement [1] - 

7:14

seven [1] - 55:5

several [5] - 

10:16, 22:11, 

22:16, 26:17, 

46:1

share [2] - 17:17, 

17:22

sheet [5] - 8:19, 

8:20, 9:1, 58:14, 

58:17

sheets [1] - 8:16

shipping [1] - 

54:24

ships [1] - 55:12

Shore [4] - 16:16, 

17:11, 30:13, 

48:10

show [2] - 19:17, 

58:24

shown [2] - 24:20, 

47:22

shows [2] - 24:5, 

59:17

sides [1] - 47:22

Sierra [1] - 18:25

sign [2] - 9:12, 

57:24

signed [2] - 9:10, 

57:23

significant [4] - 

13:22, 31:17, 

35:11, 44:24

significantly [3] - 

28:4, 31:8, 45:5

similar [2] - 27:20, 

48:14

similarly [4] - 

4:25, 44:15, 

48:24, 49:21

simply [4] - 13:18, 

27:19, 28:24, 

29:1

sincerely [1] - 

14:18

singularly [1] - 

33:12

singularlyfocused [1] - 

33:12

SIP [13] - 19:3, 

32:18, 36:23, 

36:25, 37:17, 

41:16, 42:15, 

42:23, 43:5, 

43:7, 43:12, 

43:23, 44:1

SIPs [7] - 23:3, 

31:16, 34:3, 

36:21, 40:15, 

44:12, 44:17

sit [1] - 58:21

sitting [3] - 8:13, 

10:1, 11:16

six [2] - 25:24, 

53:3

SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

13

six-month [1] - 

25:24

size [2] - 31:25, 

32:22

size-fits-all [1] - 

31:25

slated [1] - 58:20

smog [1] - 19:21

SNCR [1] - 50:18

so.. [2] - 54:10, 

58:18

SO2 [2] - 20:13, 

42:4

soil [1] - 23:24

solely [1] - 44:3

someone [2] - 

59:5, 59:17

sorry [1] - 15:3

sorted [1] - 46:4

Soudan [2] - 

10:12, 10:13

sources [8] - 5:25, 

6:1, 6:7, 6:13, 

35:7, 36:1, 36:3, 

37:14

SOx [1] - 55:9

SPEAKER [1] - 

2:1

speaker [1] - 

57:13

speakers [12] - 

7:24, 8:8, 9:7, 

9:10, 9:15, 

14:22, 21:13, 

22:1, 29:24, 

53:19, 58:24, 

59:8

speaking [1] - 

8:18

specializing [1] - 

32:2

specialty [1] - 

51:14

specific [3] - 44:9, 

49:12, 51:19

specifically [1] - 

6:2

specifications [1]

- 33:2

specify [1] - 50:7

spell [5] - 8:2, 

21:14, 21:20, 

54:2, 58:9

spelled [1] - 41:13

spend [1] - 50:10

spent [2] - 55:13, 

57:1

spray [1] - 50:20

Squire [1] - 34:13

SR [2] - 24:13, 
EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

29 of 31 sheets Page 14 to 14 of 16 09/12/2012 06:32:53 PM

25:15

SR's [1] - 24:13

ss [1] - 60:1

St [1] - 23:16

st [1] - 1:12

stability [1] - 

13:13

staff [2] - 22:17, 

22:19

stages [1] - 28:4

staggering [2] - 

55:14, 55:21

stakeholders [2] - 

27:18, 36:20

standard [2] - 

28:14, 56:16

standards [7] - 

13:24, 14:1, 

27:17, 34:24, 

35:2, 39:14, 

55:3

standpoint [6] - 

54:12, 54:13, 

54:21, 54:24, 

55:25, 56:18

started [3] - 3:2, 

10:6, 56:10

STATE [1] - 60:1

state [31] - 4:8, 

8:1, 13:1, 13:8, 

13:22, 14:3, 

14:11, 15:20, 

16:18, 21:13, 

22:24, 29:17, 

31:13, 32:11, 

34:3, 34:18, 

35:6, 35:12, 

35:15, 36:22, 

38:13, 39:2, 

41:2, 41:24, 

42:9, 42:10, 

42:16, 43:1, 

53:21, 54:15, 

58:8

State [1] - 16:21

state's [8] - 31:12, 

37:5, 37:21, 

39:6, 39:22, 

41:21, 43:19, 

52:22

statement [2] - 

12:13, 40:20

States [4] - 23:13, 

23:15, 55:1, 

55:17

states [27] - 5:22, 

13:24, 22:15, 

24:24, 29:10, 

32:3, 34:21, 

34:25, 35:1, 

35:3, 35:10, 

35:16, 35:20, 

35:22, 36:1, 

36:6, 36:8, 

36:15, 36:17, 

37:13, 37:18, 

38:1, 38:3, 

38:16, 38:23, 

44:7, 44:17

States' [1] - 26:25

stationary [2] - 

5:25, 6:7

statutory [3] - 

36:7, 36:8, 39:1

steadily [1] - 

15:16

steel [4] - 26:24, 

26:25, 48:21, 

56:4

Steel [3] - 20:22, 

24:7, 25:15

steel-making [1] - 

56:4

stenographic [1] - 

60:11

step [1] - 28:13

steps [2] - 28:9, 

29:16

Steve [1] - 3:17

still [1] - 36:18

stoic [2] - 33:6

stop [3] - 9:3, 

19:25, 37:19

straight [3] - 24:9, 

24:10, 24:19

straight-grate [3]

- 24:9, 24:10, 

24:19

strategic [1] - 

31:11

strategies [1] - 

39:13

strategy [3] - 

27:14, 31:12, 

39:7

stricter [1] - 48:4

strongly [1] - 24:1

studies [1] - 17:21

study [4] - 14:13, 

21:1, 24:13, 

32:10

subject [4] - 

28:15, 36:19, 

42:7, 49:8

submissions [1] - 

42:3

submit [7] - 7:4, 

7:7, 14:25, 17:9, 

17:24, 48:4, 

53:10

submittal [1] - 

4:19

submitted [9] - 

4:16, 4:18, 4:20, 

18:20, 22:24, 

36:13, 37:25, 

44:12, 46:24

submitting [4] - 

7:1, 7:10, 20:9, 

22:9

subsequent [1] - 

21:13

subsequently [1]

- 23:1

successfully [1] - 

31:21

suffer [1] - 19:7

sufficient [1] - 

17:6

suggested [1] - 

48:1

suggests [1] - 

28:17

sulfates [1] - 

15:18

sulfur [7] - 5:11, 

5:14, 44:18, 

49:7, 49:22, 

50:2, 50:16

summarize [1] - 

20:11

summary [2] - 

3:25, 21:5

sun [1] - 11:8

Superior [3] - 

10:22, 16:16, 

23:12

supplement [1] - 

4:18

supplemental [1]

- 7:5

supply [1] - 27:6

support [6] - 21:6, 

26:23, 39:24, 

40:10, 42:9, 

47:24

supported [2] - 

26:17, 45:11

supporting [1] - 

17:19

supports [2] - 

24:1, 25:21

surprisingly [1] - 

32:10

sustainability [1] - 

28:6

sustainable [1] - 

28:10

sustaining [1] - 

39:20

switching [5] - 

20:16, 20:18, 

33:20, 48:17, 

49:1

system [3] - 8:15, 

13:20, 40:3

T

T-A-M-M-E-N [1] - 

10:12

table [5] - 7:25, 

8:8, 8:14, 9:13, 

10:2

taconite [52] - 3:6, 

4:17, 4:21, 4:25, 

5:3, 5:6, 5:10, 

5:12, 5:17, 6:18, 

10:16, 11:6, 

11:12, 13:2, 

13:6, 13:10, 

14:10, 15:13, 

15:19, 16:19, 

17:3, 19:15, 

19:22, 19:24, 

21:7, 24:4, 

24:10, 28:1, 

30:20, 31:4, 

31:20, 32:2, 

32:24, 33:13, 

34:1, 34:19, 

35:13, 36:14, 

36:25, 37:22, 

38:13, 38:17, 

39:8, 40:16, 

41:18, 41:20, 

41:25, 42:7, 

43:8, 55:22, 

55:24, 56:5

Taconite [4] - 1:4, 

5:15, 30:14, 

30:15

TAMMEN [1] - 

10:11

Tammen [4] - 2:2, 

10:8, 10:10, 

10:11

teacher [1] - 10:14

technical [6] - 

18:20, 27:25, 

29:7, 32:1, 

32:16, 54:20

technically [4] - 

14:6, 24:6, 

31:24, 50:22

technologies [9] - 

20:8, 28:17, 

37:20, 43:11, 

43:17, 43:20, 

44:10, 45:18, 

SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

14

55:8

technology [30] - 

6:9, 6:17, 13:4, 

21:19, 24:4, 

24:11, 24:15, 

25:20, 28:24, 

30:22, 31:22, 

31:24, 32:5, 

32:9, 32:12, 

36:12, 36:18, 

40:13, 41:17, 

41:22, 41:24, 

42:10, 43:7, 

43:13, 43:15, 

46:12, 54:12, 

57:2, 57:3

technologybased [1] - 46:12

temperature [3] - 

16:4, 17:20, 

33:23

temperatures [2] - 

16:7, 49:2

ten [1] - 55:5

term [2] - 31:12, 

41:15

terms [3] - 26:19, 

55:9, 56:10

territories [2] - 

23:9, 23:10

territory [1] - 

23:15

test [1] - 42:12

testimony [14] - 

7:6, 8:2, 8:7, 

8:9, 9:3, 14:24, 

47:22, 57:12, 

57:23, 58:3, 

58:14, 58:20, 

59:12, 59:17

themselves [1] - 

25:18

therefore [1] - 

30:18

thinks [2] - 37:2, 

37:12

third [1] - 24:25

thirds [1] - 27:6

thorough [3] - 

30:21, 44:5, 

44:15

thousands [2] - 

14:8, 19:1

three [1] - 27:2

Threlkeld [2] - 

1:20, 60:8

THRELKELD [1] - 

60:19

throughout [6] - 

42:13, 54:14, 
EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

09/12/2012 06:32:53 PM Page 15 to 15 of 16 30 of 31 sheets

54:25, 55:12, 

56:1, 56:2

tighten [1] - 52:18

tightening [1] - 

51:3

Tilden [2] - 5:16, 

30:17

timeframes [1] - 

29:1

timekeeping [1] - 

8:15

timeline [1] - 14:6

timing [1] - 3:12

tip [1] - 51:22

today [18] - 3:10, 

5:8, 6:19, 6:23, 

9:11, 9:19, 

14:25, 26:16, 

26:20, 29:18, 

31:1, 47:17, 

54:17, 55:8, 

55:21, 57:23, 

58:2, 59:3

today's [11] - 3:22, 

7:4, 7:6, 7:12, 

7:18, 7:20, 7:24, 

9:8, 10:5, 49:14, 

59:19

together [2] - 4:8, 

23:14

ton [5] - 24:22, 

46:2, 48:7, 48:9, 

48:10

tons [1] - 27:5

top [1] - 12:2

topic [1] - 22:21

topics [1] - 54:9

toward [1] - 6:5

towards [3] - 

22:11, 31:17, 

50:2

town [1] - 10:13

toxic [1] - 17:2

toxicity [1] - 11:14

track [1] - 8:17

transcript [5] - 

7:20, 7:21, 60:9, 

60:11, 60:12

transcription [1] - 

58:10

translate [1] - 

24:12

transmission [1] - 

51:12

treasures [1] - 

19:6

treaty [1] - 23:9

Treaty [3] - 23:10, 

23:14, 23:16

treaty-ceded [1] - 

23:9

Treaty-ceded [1] - 

23:10

tremendous [1] - 

14:11

trialed [1] - 33:7

tribes [1] - 22:17

true [3] - 40:6, 

45:21, 60:12

turn [3] - 3:23, 

6:22, 7:25

two [9] - 5:15, 

20:11, 22:1, 

23:6, 27:3, 27:6, 

30:17, 38:16, 

45:23

two-thirds [1] - 

27:6

types [1] - 50:24

U

U.S [13] - 1:1, 3:4, 

4:5, 13:16, 

20:22, 24:7, 

25:15, 26:15, 

26:22, 27:9, 

30:8, 34:13, 

56:1

ultimately [2] - 

26:17, 29:13

unaggressive [1]

- 48:2

unanticipated [1]

- 16:2

uncontrolled [1] - 

5:25

under [6] - 6:11, 

7:14, 13:21, 

28:8, 34:23, 

37:10

undercuts [1] - 

37:13

underestimate [1]

- 45:6

underestimating

[1] - 46:2

undertake [1] - 

16:22

underwriting [1] - 

28:22

unemployment

[1] - 14:15

unfair [1] - 25:18

unfamiliar [1] - 

32:13

unique [10] - 28:1, 

32:14, 32:19, 

32:25, 33:1, 

38:13, 41:15, 

56:12, 56:13, 

56:15

United [7] - 5:15, 

23:13, 23:15, 

26:25, 30:15, 

54:25, 55:17

University [1] - 

14:13

unless [1] - 59:17

unquote [1] - 14:2

unrealistic [1] - 

29:2

up [30] - 8:19, 

8:20, 8:21, 8:23, 

9:2, 9:10, 10:8, 

10:25, 11:3, 

11:15, 12:8, 

13:19, 22:1, 

29:23, 33:20, 

41:7, 42:25, 

50:8, 51:3, 51:7, 

52:18, 53:17, 

57:23, 57:24, 

58:8, 58:16, 

58:18, 58:24, 

59:5, 59:17

update [1] - 13:11

updated [1] - 

27:16

upgrade [1] - 

25:19

upgrades [1] - 

48:12

upgrading [1] - 

13:2

upper [1] - 38:15

Upper [1] - 30:18

USEPA [16] - 3:9, 

31:15, 33:15, 

34:17, 34:21, 

41:4, 42:23, 

43:3, 43:4, 44:2, 

44:12, 45:3, 

45:10, 45:17, 

46:1, 46:8

USEPA's [5] - 

31:3, 31:19, 

32:4, 43:9, 

44:10

usufructuary [1] - 

23:17

usurps [1] - 39:22

Utilities [1] - 52:9

utilizing [1] - 

24:10

V

vacating [1] - 41:1

valid [1] - 35:15

validates [2] - 

29:17, 32:22

value [1] - 19:3

variety [1] - 27:18

various [1] - 43:13

vary [1] - 48:12

vendor [2] - 45:12, 

45:16

vendors [6] - 

24:16, 25:23, 

32:13, 39:17, 

39:25, 40:1

version [1] - 8:11

versus [3] - 13:15, 

41:1, 41:4

vetted [1] - 57:4

viability [1] - 

28:18

viable [2] - 32:12, 

39:20

vice [3] - 30:6, 

30:12, 30:16

vicinity [1] - 16:15

videos [1] - 11:4

view [1] - 20:15

views [1] - 19:5

visibility [18] - 4:3, 

4:9, 5:20, 6:1, 

6:5, 6:14, 13:9, 

15:20, 15:22, 

16:2, 19:6, 

19:18, 28:14, 

34:5, 35:18, 

35:24, 36:1, 

40:9

visual [1] - 23:20

volatilization [1] - 

16:9

Voyageurs [6] - 

4:10, 18:23, 

19:19, 21:7, 

23:8

W

WAGNER [1] - 

18:3

Wagner [1] - 3:19

wait [1] - 58:23

wants [1] - 59:5

Washington [1] - 

12:15

watch [1] - 10:25

watched [1] - 47:4

SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

15

water [1] - 23:23

Water [1] - 4:11

Waters [3] - 18:24, 

21:8, 23:7

Wayne [7] - 2:4, 

2:6, 15:2, 15:6, 

22:1, 22:3, 22:5

WAYNE [1] - 22:5

ways [1] - 54:21

week [2] - 11:2, 

25:25

weigh [2] - 52:3, 

52:12

weight [1] - 49:23

welcome [1] - 

17:4

welldocumented [1]

- 19:10

West [2] - 46:23, 

51:10

whereby [1] - 25:9

whole [1] - 26:25

widespread [1] - 

15:11

wife [4] - 10:14, 

10:25, 11:13, 

54:19

Wilderness [2] - 

18:25, 23:8

wilderness [4] - 

4:4, 4:7, 4:10, 

21:8

wildlife [1] - 23:24

Wildlife [1] - 4:12

Williams [1] - 30:2

willing [3] - 17:16, 

35:14, 44:2

willingness [1] - 

24:14

wind [1] - 50:8

Wing [2] - 46:24, 

51:11

wisdom [1] - 

38:11

wise [1] - 24:25

withdraw [4] - 

34:1, 34:17, 

39:2, 40:15

witnessed [1] - 

42:13

women [1] - 27:8

wood [2] - 48:19, 

48:21

Woodbury [1] - 

15:6

word [1] - 8:24

world [3] - 11:13, 

49:25, 56:2

wrap [2] - 8:21, 
EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE FACILITIES IN MN AND MI

31 of 31 sheets SHADDIX & ASSOCIATES Page 16 to 16 of 16 (952)888-7687 (800)952-0163 09/12/2012 06:32:53 PM

16

58:16

wrapping [1] - 

58:18

writing [1] - 12:22

written [12] - 7:2, 

7:11, 7:12, 7:20, 

8:11, 12:13, 

14:24, 20:19, 

26:18, 48:5, 

58:25, 59:4

wrote [1] - 13:16

Y

year [2] - 19:20, 

39:8

years [11] - 10:15, 

22:11, 22:17, 

30:19, 32:10, 

35:11, 47:6, 

51:20, 54:14, 

54:16, 55:3

yellow [4] - 8:16, 

8:20, 8:24, 

58:14

young [1] - 11:25

younger [1] - 

10:17