# EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE F ACILITIES IN MN AND MI

1 of 31 sheets Page 1 to 4 of 60 09/12/2012 06:32:53 PM

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SHADDIX & ASSOCIATES ( 952 ) 888

- 7687 ( 800 ) 952

- 0163 1

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

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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 30

34

George Pruchnofski 41

Allen Miller 46

Carol Overland 51

Matthew Dinslage 53 3

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 1

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 2

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 3

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 . 4

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 5

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 6

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

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 8

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 9

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 10

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 11

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 12

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 i n 13

a m o m e n t . 14

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 15

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 16

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 , 17

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 ; 18

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 19

E P A R e g io n 5 . 20

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

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 i n 22

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 23

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 24

s u m m a ry o f th is p r o p o s e d ru le . 25 SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

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D o u g . 1

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 2

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 3

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 4

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 5

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 6

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 7

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 8

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 9

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 , 10

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 11

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 12

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 13

a r e a s . 14

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

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 it s 16

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. 17

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 18

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 19

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 20

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 21

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

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 23

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 24

lim it s fo r ta c o n ite f a c ilitie s . S im ila rly , o n 25 SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

# EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE F ACILITIES IN MN AND MI

09/12/2012 06:32:53 PM Page 5 to 8 of 60 2 of 31 sheets 

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

### 1 regional haze plan, but that approval did not 

### 2 address the taconite facility when it's found in th e 

### 3 Michigan plan. 

### 4 On August 15th, 2012 EPA published in the 

### 5 Federal Register proposed limits for the taconite 

### 6 facility in both Minnesota and Michigan. 

### 7 Today we are here to listen to your 

### 8 comments on all aspects of EPA's proposed limits on 

### 9 taconite facilities. The proposed regulation 

### 10 contains nitrogen oxide and sulfur dioxide limits a t 

### 11 all affected taconite facilities. These limits are 

### 12 intended to require nitrogen oxide production at al l 

### 13 facilities and additional sulfur dioxide production 

### 14 at two of these facilities, namely United Taconite 

### 15 and Tilden Mine. These limits will dramatically cu t 

### 16 emissions and effluents from the affected taconite 

### 17 process facilities. The emission productions will 

### 18 reduce the amount of regional haze and improve 

### 19 visibility in downwind areas. 

### 20 Section 169A of the Clean Air Act directs 

### 21 states or EPA, if implementing the federal 

### 22 implementation plan, or FIP, to evaluate the use of 

### 23 retrofit controls at certain larger, often 

### 24 uncontrolled, older stationary sources in order to 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 6 address visibility impacts from these sources. 

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

### 2 Clean Air Act requires EPA to implement a FIP to 

### 3 contain such measures as may be necessary to make 

### 4 reasonable progress toward the national visibility 

### 5 goal, including a requirement that certain 

### 6 categories of existing major stationary sources 

### 7 built between 1962 and 1977 procure, install, and 

### 8 operate the best-available retrofit technology, or 

### 9 BART, as determined by EPA. 

### 10 Under the regional haze rule EPA is 

### 11 directed to conduct BART determinations for such 

### 12 BART-eligible sources that may be anticipated to 

### 13 cause or contribute to any visibility impairment in 

### 14 a Class I area. The proposed limits found in the 

### 15 August 15th, 2012 Federal Register notice reflect 

### 16 best available retrofit technology, or BART, for th e 

### 17 affected taconite facilities. 

### 18 Today we are here to listen to your 

### 19 comments on all aspects of EPA's proposed limits on 

### 20 these facilities. 

### 21 I'll turn it back to Heriberto to go over 

### 22 the ground rules today. 

### 23 MR. LEON: Thank you, Doug. 

### 24 I would like to draw your attention to 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 7 the September 28th, 2012 deadline for submitting 

### 1 written comments on this proposal. This will hold 

### 2 the hearing record open for an additional 30 days 

### 3 beyond today's hearing to allow people to submit 

### 4 supplemental or rebuttal information that is relate d 

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

### 6 have until September 28th, 2012 to submit your 

### 7 comments and information. 

### 8 There are handouts in the registration 

### 9 area that have instructions for submitting the 

### 10 written comments. EPA will carefully consider your 

### 11 comments from today's hearing, along with written 

### 12 comments received, in order to move ahead with the 

### 13 completion of this rule. Under a settlement 

### 14 agreement, EPA would take final action on this 

### 15 proposal by November 15th, 2012. 

### 16 You will notice that we have a court 

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

### 18 to all of us speak in order to be able to create a 

### 19 written transcript of today's hearing. The 

### 20 transcript will become part of the official record 

### 21 on this rule and will be available to the public. 

### 22 Now let me describe the procedure for 

### 23 today's hearing. I will call scheduled speakers to 

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

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 8 please state your name and your affiliation before 

### 1 you begin your testimony. Please also spell out 

### 2 your name and talk clearly, because that will ensur e 

### 3 that our court reporter captures your name and your 

### 4 comments accurately. 

### 5 In order to be fair to everyone, we will 

### 6 limit testimony to five minutes each. Please remai n 

### 7 seated at the table until both speakers have 

### 8 finished. After you've finished your testimony, 

### 9 members of the panel may ask clarifying questions. 

### 10 If you have a written version of your comments that 

### 11 you would like to have entered in the docket, pleas e 

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

### 13 registration table over by the door. 

### 14 We have a timekeeping system consisting 

### 15 of green, yellow, and red sheets of paper. This is 

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

### 17 limit that we have set. You may begin speaking whe n 

### 18 I hold up a green sheet. At four minutes I will 

### 19 bring up the yellow sheet, and this is to indicate 

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

### 21 In the event that I notice that your eyes are 

### 22 looking at a paper and not looking up here, I may 

### 23 just say the word yellow. And when we have 

### 24 15 seconds to the 5 minutes, I will raise the red 

### 25 

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

# EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE F ACILITIES IN MN AND MI

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### 9 sheet of paper to indicate that you're coming close 

### 1 to your 5 minutes. And when your time is up at fiv e 

### 2 minutes, I will ask you to stop your testimony. I 

### 3 will, however, exercise some discretion and offer 

### 4 additional time either immediately after your 

### 5 elapsed time or later, depending on the line of 

### 6 speakers that we have. 

### 7 Today's hearing will conclude at 

### 8 2:00 p.m. We will extend the session reasonably if 

### 9 necessary to accommodate speakers who have signed u p 

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

### 11 not yet registered to do so, please sign at the 

### 12 registration table with Sarah Cervak. 

### 13 We ask for your patience as we proceed 

### 14 through the list of speakers. We may need to make 

### 15 some adjustments as the day progresses. 

### 16 Before we begin, I would like to 

### 17 acknowledge Brian Gordon from the office of 

### 18 Congressman Chip Cravaack, who is here today and 

### 19 will participate in the hearing and provide some 

### 20 comments. Thank you, Mr. Gordon. 

### 21 And also I would like to acknowledge Al 

### 22 Juhnke from the office of Senator Al Franken, who i s 

### 23 also here. Thank you. 

### 24 Finally, if you have any questions during 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 10 the hearing, please see Sarah, who is sitting at th e 

### 1 registration table over by the door, for any 

### 2 assistance. 

### 3 And thank you all for coming out and 

### 4 participating in today's proceeding. 

### 5 So we'll go ahead and get started by 

### 6 calling the first couple of attendees whose names I 

### 7 have up here, and that would be Bob Tammen and Bria n 

### 8 Gordon. 

### 9 All right. Mr. Tammen, go ahead. 

### 10 MR. TAMMEN: Thank you. I'm Bob Tammen 

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

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

### 13 electrician. My wife, Pat, elementary teacher for 

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

### 15 home. I worked in several of the taconite plants i n 

### 16 my younger days. And of course you probably know 

### 17 that we have elevated levels of mesothelioma in 

### 18 northern Minnesota. I imagine you have the numbers , 

### 19 but I go to the funerals. 

### 20 A couple of months ago a report came out 

### 21 that many of the babies born in the Lake Superior 

### 22 drainage, northern Minnesota are born with elevated 

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

### 24 but my wife and I watch those children grow up in 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 11 our communities. 

### 1 A week ago a film company came to 

### 2 northern Minnesota. They wanted to go up in an 

### 3 airplane and get some videos of mining country. 

### 4 They asked me to go along because I know which mine 

### 5 is which; I have some history of the taconite 

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

### 7 in the afternoon, because they wanted the sun just 

### 8 right for their filming. And we were about 

### 9 800 feet. It was an impressive day, but it was a 

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

### 11 natural haze or taconite haze. You know, you have 

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

### 13 death and toxicity and haze, and we'd like to see i t 

### 14 cleaned up. 

### 15 Now we're sitting here in the Minnesota 

### 16 Pollution Control Agency building, and I know 

### 17 there's a lot of good people working in this 

### 18 building. They want to take care of our natural 

### 19 resources. And I also know that a previous 

### 20 commissioner of this agency went to work for the 

### 21 mining industry. 

### 22 The Department of Natural Resources 

### 23 routinely has their heads of the Land and Mineral 

### 24 Department retire young and go to work for the 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 12 mining industry. There is a revolving door at the 

### 1 top. I know that the people in the middle went to 

### 2 work here because they love our natural resources 

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

### 4 the Environmental Protection Agency will enforce th e 

### 5 regulations that we have and encourage our 

### 6 regulators and our legislators in Minnesota to clea n 

### 7 up northern Minnesota. 

### 8 Thank you. 

### 9 MR. ABURANO: Thank you. 

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

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

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

### 13 the congressman dated August 27th, 2012 to 

### 14 Administrator Jackson, the EPA agency in Washington , 

### 15 D.C. 

### 16 Dear Administrator Jackson, On behalf of 

### 17 3,900 constituents of the Eighth District of 

### 18 Minnesota who are directly employed by the mining 

### 19 industry and the over 40,000 constituents that 

### 20 depend on the mining industry for their livelihood, 

### 21 I am writing to express my concern with the recent 

### 22 proposed rule published in the Federal Register on 

### 23 August 15th, 2012. 

### 24 I request that the EPA reconsider its 

### 25 

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

# EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE F ACILITIES IN MN AND MI

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### 13 rejection of the state implementation plan for 

### 1 upgrading taconite facilities. The Minnesota 

### 2 Pollution Control Agency has carefully examined the 

### 3 feasibility of best-available retrofit technology, 

### 4 the time it would take to implement, and the 

### 5 potential operating risk it presents to taconite 

### 6 mines in northeastern Minnesota. 

### 7 I request that EPA work with the state to 

### 8 continue improving visibility in protected areas 

### 9 while allowing taconite plants to obtain flexibilit y 

### 10 needed to cost effectively update their furnaces on 

### 11 a feasible time frame without endangering the 

### 12 stability of these operations. 

### 13 In an August of 2012 opinion EME Homer 

### 14 City Generation versus EPA, the DC Circuit of the 

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

### 16 the complex regulatory challenge, Congress did not 

### 17 authorize EPA to simply adopt limits on emissions a s 

### 18 the EPA deemed reasonable; rather, Congress set up a 

### 19 federalism-based system of air pollution control. 

### 20 Under this cooperative federalism approach, both th e 

### 21 federal government and the state play significant 

### 22 roles. The federal government sets air quality 

### 23 standards for pollutants. The states have the 

### 24 primary responsibility for determining how to meet 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 14 those standards and regulating resources within 

### 1 their borders, unquote. 

### 2 I request that EPA work with the state to 

### 3 effectively address the needs of Minnesotans. EPA' s 

### 4 proposed federal implementation plan contains the 

### 5 timeline that is not technically and economically 

### 6 feasible for some plants and could negatively impac t 

### 7 thousands of jobs at a time when Minnesota is 

### 8 meeting its regional haze reasonable progress goal. 

### 9 Minnesota taconite mining provides 

### 10 tremendous benefits to our entire state with nearly 

### 11 $1.8 billion annual benefit to our economy. 

### 12 According to a University of Minnesota-Duluth study , 

### 13 2.5 ancillary jobs are produced for every mining 

### 14 job. In times of such high unemployment, these are 

### 15 good-paying jobs we cannot jeopardize. 

### 16 I am happy to be of any assistance in 

### 17 moving forward with this effort. Sincerely, Chip 

### 18 Cravaack. 

### 19 MR. ABURANO: Thank you. 

### 20 MR. LEON: Thank you very much. We'll 

### 21 move on to the next couple of speakers. Thank you. 

### 22 MR. ABURANO: What I should say, if you 

### 23 have written copies of your testimony that you woul d 

### 24 like to submit to us today, we're more than happy t o 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 15 take them. 

### 1 MR. LEON: Wayne Rohde and Kevin Reuther. 

### 2 Sorry. 

### 3 Mr. Rohde. 

### 4 MR. ROHDE: Good morning. My name is 

### 5 Wayne Rohde, and I'm a resident of Woodbury, 

### 6 Minnesota. I'm here to comment on the potential fo r 

### 7 other emissions increasing as a result of this rule

. 

### 8 First, we want to commend the EPA for 

### 9 their efforts to improve air quality in Minnesota. 

### 10 Given the widespread use of natural gas by the iron 

### 11 ore industry on the Iron Range for processing 

### 12 taconite, this proposed rule should increase 

### 13 positive impacts on air quality while minimizing 

### 14 economic impacts, since the price of natural gas ha s 

### 15 steadily dropped as new reserves have been 

### 16 developed. 

### 17 Second, reducing sulfates and nitrous 

### 18 oxide emissions produced by furnaces during taconit e 

### 19 processing to improve visibility beyond the state 

### 20 proposal will not only further improve overall 

### 21 visibility in the region, it would also help reduce 

### 22 the amount of respiratory and cardiovascular health 

### 23 impacting pollution, impairing our local air 

### 24 quality, and reducing potentials for acid rain. 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 16 However, that said, the proposed changes 

### 1 to improve visibility may result in unanticipated 

### 2 changes in the HAP emissions. Our concerns relate 

### 3 to the increased temperature that will be created b y 

### 4 the improvements in combustion and resulting effect s 

### 5 on the amount of mercury and other HAPs these plant s 

### 6 will emit. As the process temperatures increase du e 

### 7 to greater efficiencies proposed, the potential fro m 

### 8 increased volatilization and changes in combustion 

### 9 chemistry could result in increased HAP emissions. 

### 10 We believe localized impacts due to 

### 11 hazardous air pollutants emissions from these 

### 12 facilities already exist. Recently the Minnesota 

### 13 Department of Health indicated infants born to 

### 14 people in the vicinity of the Iron Range and North 

### 15 Shore of Lake Superior have greater mercury burdens 

### 16 in their bodies than residents in other areas of th e 

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

### 18 mercury emissions already coming from taconite 

### 19 processing. 

### 20 We encourage the industry, the State of 

### 21 Minnesota, and the EPA to undertake further 

### 22 research. Answers are needed about the associated 

### 23 impacts that will occur as a result of the proposed 

### 24 rules effects on HAPs emissions to ensure continuou s 

### 25 

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

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### 17 improvement in local public health and reduction of 

### 1 toxic pollution downwind and downstream from the 

### 2 taconite and iron ore industry. 

### 3 In closing, while we welcome the changes 

### 4 being proposed here, we're also -- we also note tha t 

### 5 there is sufficient evidence to require further 

### 6 investigation into the potentials for HAP emission 

### 7 increases and the need to address these as well. 

### 8 We will submit further documentation if 

### 9 needed on the issues related to impacts of mercury 

### 10 on the Iron Range and North Shore as well as other 

### 11 related information about our concerns. 

### 12 Thank you, and I appreciate this 

### 13 opportunity to speak. 

### 14 MR. ABURANO: Just a clarifying question. 

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

### 16 share information about the effects of mercury that 

### 17 are currently found there. Do you have anything 

### 18 supporting what you said about the increase in 

### 19 temperature increasing the HAPs that would be 

### 20 emitted? Are there any studies or things you could 

### 21 share with us? 

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

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

### 24 those to you before the deadline. 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 18 MR. ABURANO: That would be great. Thank 

### 1 you. Appreciate that. 

### 2 MR. WAGNER: Could you identify the 

### 3 organization you represent? 

### 4 MR. ROHDE: Yes. The Canary Party and 

### 5 also Safe Mines Institute. 

### 6 MR. LEON: Mr. Reuther. 

### 7 MR. REUTHER: Yeah. Thank you. Good 

### 8 morning. Is this on? 

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

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

### 11 not lit, then you should be on. 

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

### 13 MR. ABURANO: Yep. 

### 14 MR. REUTHER: Okay. Great. I'm Kevin 

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

### 16 director for the Minnesota Center for Environmental 

### 17 Advocacy, MCEA. We, along with a number of other 

### 18 conservation and public health organizations, 

### 19 submitted lengthy comments in the technical review 

### 20 to you in response to the proposed rule. Those 

### 21 groups include the National Parks Conservation 

### 22 Association, Voyageurs Park -- Voyageurs National 

### 23 Park Association, the Friends of the Boundary Water s 

### 24 Wilderness, Fresh Energy, and also the Sierra Club. 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 19 Our organizations represent thousands of 

### 1 members here in Minnesota. And we thank you, EPA, 

### 2 for rejecting MPCA's haze SIP. We value cleaner ai r 

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

### 4 is primarily about scenic views and ridding our 

### 5 national treasures of the visibility impairments 

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

### 7 health and the benefits that will be gained by 

### 8 reducing emissions. These same pollutants cause -- 

### 9 that cause haze cause well-documented diseases, lun g 

### 10 diseases, heart attacks. You're very familiar with 

### 11 that, as are we. 

### 12 Minnesota's Class I areas are iconic 

### 13 places, and they belong to everyone; and the 

### 14 taconite industry has for decades been polluting 

### 15 these areas. The data in your record developed by 

### 16 the MPCA show that Minntac, for example, just one o f 

### 17 these plants alone, affects visibility in the 

### 18 Voyageurs National Park more than 50 percent of the 

### 19 days of the year. There are clearly cost-effective 

### 20 controls that can eliminate some of that smog; and 

### 21 taconite has for decades evaded control, while othe r 

### 22 industries have made great progress on pollution 

### 23 reduction. It's time now for the taconite industry 

### 24 to invest in modern controls and stop polluting the 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 20 public's air and the public's parks. 

### 1 In fact, there isn't really anything that 

### 2 aggressive or novel about EPA's action here. If 

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

### 4 rejecting the MPCA plan, which required nothing at 

### 5 all of this industry. 

### 6 Now that being said, we believe there are 

### 7 additional cost-effective technologies that could 

### 8 reduce pollution further. And we will be submittin g 

### 9 comments to you by the comment deadline in mid 

### 10 September, but I'll just summarize the two main one s 

### 11 that we see in the proposed rule. 

### 12 First, with regard to SO2, EPA did not 

### 13 evaluate alternative fuels; and, instead, the 

### 14 proposed rule seems to defer to industry's view tha t 

### 15 BART doesn't include fuel switching. But that's no t 

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

### 17 other instances required fuel switching as BART. S o 

### 18 we will develop that argument in our written 

### 19 comments. 

### 20 With regard to NOx, EPA did not evaluate 

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

### 22 having demonstrated that SCRs are infeasible. 

### 23 However, in our original comments -- and this will 

### 24 be developed further -- we detailed the 

### 25 

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### 21 insufficiencies of the study relied on in 

### 1 disregarding SCRs. And so we would challenge EPA t o 

### 2 take another look at SCRs and the feasibility of 

### 3 SCRs in this context. 

### 4 In summary, our organizations and our 

### 5 members fully support EPA's action to require 

### 6 taconite to reduce its pollution of Voyageurs 

### 7 National Park and the Boundary Waters wilderness, 

### 8 and we find that these minimal controls are long 

### 9 overdue. Thank you. 

### 10 MR. LEON: Thank you very much. 

### 11 MR. ABURANO: Just a reminder to any 

### 12 subsequent speakers, please remember to state your 

### 13 name and spell out your name for the court reporter

. 

### 14 And also I know that, you know, a lot of people 

### 15 talking about government regulations also have a lo t 

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

### 17 like BART or SCR, you know, best-available retrofit 

### 18 technology or selected catalytic reduction, please, 

### 19 for the court reporter's benefit, spell out the 

### 20 acronym or define the acronym that you're using, 

### 21 just for the people that aren't involved in 

### 22 government as much as some of us are on a day-to-da y 

### 23 basis. Thank you. 

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

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 22 up the next two speakers. Wayne Dupuis and Scott 

### 1 Gischia. 

### 2 Wayne Dupuis, go ahead. 

### 3 MR. DUPUIS: Good morning. My name is 

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

### 5 from the Fond Du Lac Reservation. I'm an 

### 6 environmental program manager there. And appreciat e 

### 7 your time this morning. I'd like to read what we'v e 

### 8 -- we're submitting. 

### 9 The Fond Du Lac Band has been involved 

### 10 for the past several years in working towards the 

### 11 implementation of the requirements of the regional 

### 12 haze rule, which was promulgated in 1999. The Band 

### 13 was a member of the Central Regional Air 

### 14 Partnership, CENRAP, Coalition in nine states, 

### 15 federal land managers, industry groups, and several 

### 16 tribes for a number of years, the staff serving as 

### 17 the secretary/treasurer of this organization. 

### 18 During the time that CENRAP was active, staff 

### 19 participated in numerous face-to-face meetings and 

### 20 conference calls on this topic. 

### 21 We appreciate the time and effort that 

### 22 Region 5 has put into reviewing the regional haze 

### 23 state implementation plan submitted by the Minnesot a 

### 24 Pollution Control Agency and the Michigan Departmen t 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 23 of Environmental Quality and in subsequently issuin g 

### 1 a federal implementation plan that replaces the 

### 2 portion of these SIPs that were found to be 

### 3 inadequate. 

### 4 Regional haze is a matter of concern to 

### 5 the Band because two of the areas affected by the 

### 6 regional haze rule, the Boundary Waters Canoe Area 

### 7 and the Wilderness Area and Voyageurs National Park 

### 8 lie within the Band's treaty-ceded territories. 

### 9 Treaty-ceded territories consist of roughly 8 

### 10 million acres in the arrowhead portion of Minnesota 

### 11 that were ceded by the Band and other Lake Superior 

### 12 Chippewa bands, the United States Government, and 

### 13 the 1854 Treaty of La Pointe, together with the 

### 14 territory ceded to the United States Government in 

### 15 the 1837 Treaty of St. Peters where the Band retain s 

### 16 usufructuary rights, including hunting, fishing, an d 

### 17 gathering. The Band believes that the application 

### 18 of the requirements of the regional haze rule will 

### 19 protect these lands not only from visual degradatio n 

### 20 but also from additional effects of haze-causing 

### 21 pollutants such as the potential acidification and 

### 22 nitrification of the water resources as well as 

### 23 deleterious effects on soil, plants, and wildlife. 

### 24 For the following four reasons the Band 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 24 strongly supports the FIP proposed by Region 5, 

### 1 particularly with regard to Region 5's determinatio n 

### 2 that low NOx burners are best-available retrofit 

### 3 technology for taconite facilities. 

### 4 First, Region 5's analysis shows that 

### 5 this option is technically feasible as these burner s 

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

### 7 grate kiln furnaces and are being installed on 

### 8 Essar's straight-grate kiln furnaces. While some 

### 9 taconite facilities utilizing straight-grate kiln 

### 10 furnaces are concerned about how this technology 

### 11 will translate to these furnaces, the bench scale 

### 12 pilot study performed at SR, as well as SR's 

### 13 willingness to move ahead with full-scale 

### 14 construction of this technology, demonstrates this 

### 15 should not be a problem. The vendors who design an d 

### 16 install low NOx burners also do not anticipate 

### 17 problems in installing their product in 

### 18 straight-grate kiln furnaces. 

### 19 Second, low NOx burners have been shown 

### 20 to be affordable with control costs estimated at 

### 21 roughly $500 per ton, which is well within the rang e 

### 22 of costs that have been deemed affordable for BART 

### 23 by both the states and the EPA. 

### 24 Third, low NOx burners are a wise control 

### 25 

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### 25 choice because they prevent NOx from being formed i n 

### 1 the first place, rather than just collecting the 

### 2 pollutant after it has been produced, which is a ke y 

### 3 concept in pollution prevention. Selection and 

### 4 disposal of pollutants can lead to secondary 

### 5 environmental problems as well as increased energy 

### 6 consumption by the control device. It is also 

### 7 advantageous that low NOx burners do not lead to 

### 8 increased use of fuel whereby additional pollutants 

### 9 could be generated, including greenhouse gas 

### 10 pollutants. 

### 11 Fourth, in addition to the compelling 

### 12 results of the BART determination, the Band contend s 

### 13 that installation of these burners is an equity. 

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

### 15 have already made the commitment to low NOx burners 

### 16 and have taken the majority of the burden of 

### 17 demonstration upon themselves, it would be unfair t o 

### 18 allow other facilities to upgrade without having to 

### 19 install this technology. 

### 20 The Band also supports the installation 

### 21 schedule that Region 5 has proposed. It is our 

### 22 understanding that product vendors anticipate 

### 23 roughly a six-month design time for each line and a n 

### 24 installation time of about a week per line. With 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 26 the numerous delays that have been encountered in 

### 1 implementing the regional haze rule, we believe it 

### 2 is reasonable and desirable to require installation 

### 3 of low NOx burners on the schedule that is being 

### 4 proposed. 

### 5 We want to thank you for your careful 

### 6 review of regional haze in northeastern Minnesota. 

### 7 We appreciate the time you've given us. 

### 8 MR. ABURANO: Thank you. 

### 9 MR. LEON: Thank you. 

### 10 Scott Gischia. 

### 11 MR. GISCHIA: Morning. My name is Scott 

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

### 13 director of environmental compliance for Cliffs 

### 14 Natural Resources U.S. iron ore operation. 

### 15 My comments here today will be expanded 

### 16 upon by several others and ultimately supported by 

### 17 written comments by Cliffs, but Cliffs believes it 

### 18 important to briefly highlight some of the terms 

### 19 here today and appreciate the opportunity. 

### 20 By way of introduction, Cliffs Natural 

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

### 22 is responsible mining of products that support the 

### 23 steel industry. Iron ore is the key ingredient to 

### 24 making steel. And the whole of the United States' 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 27 domestic iron ore reserves originate from only eigh t 

### 1 facilities in the entire country. Cliffs' three 

### 2 Minnesota and two Michigan operations represent the 

### 3 backbone of our company, rated to produce 32 millio n 

### 4 tons of iron ore annually, which represents nearly 

### 5 two-thirds of the entire domestic supply of iron 

### 6

ore. 

### 7 Cliffs employs nearly 6,000 men and women 

### 8 across the U.S., with both direct and indirect 

### 9 impact on the economies in these areas of roughly $ 2 

### 10 billion annually. 

### 11 First and foremost I'd like to emphasize 

### 12 that emissions reduction are an important part of 

### 13 Cliffs overall business strategy, whether to pave 

### 14 the way for future expansion opportunities because 

### 15 of the recently updated national ambient air qualit y 

### 16 standards or in recognition of concerns from a 

### 17 variety of stakeholders. Emissions reductions 

### 18 simply make good business sense. And in that light 

### 19 Cliffs has similar goals as many others interested 

### 20 in this issue. 

### 21 Cliffs' concerns, however, with the 

### 22 reductions approach presented by the draft regional 

### 23 haze federal implementation plan that is based on 

### 24 serious technical flaws fails to recognize the 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 28 complexities involved with each unique taconite 

### 1 furnace, departs from EPA's own guidance for 

### 2 implementation of BART, bypasses due process at a 

### 3 number of stages, most significantly presents a 

### 4 serious risk to Cliffs' product quality which is 

### 5 central to the sustainability of any producer like 

### 6 Cliffs that must sell product to the open market, 

### 7 and all under a time frame that fails to recognize 

### 8 the necessary design and engineering steps required 

### 9 to develop well thought out sustainable approaches 

### 10 for this industry. 

### 11 You recall that BART is designed as the 

### 12 first step of a 60-year program to improve 

### 13 visibility. It's not a health-related standard. I t 

### 14 secured a quick available retrofit to subject 

### 15 facilities. To the extent that the proposed FIP 

### 16 suggests technologies that inherently challenge the 

### 17 viability of the business, it is outside the scope 

### 18 and intent of BART. 

### 19 While Cliffs presents these concerns as 

### 20 facility operators, they are equally echoed by the 

### 21 designers of the underwriting processes whom Cliffs 

### 22 would call upon to attempt to effect the changes 

### 23 considered by the FIP. The technology simply is no t 

### 24 available to the industry at this point in time; an d 

### 25 

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### 29 the timeframes proposed by EPA are, quite simply, 

### 1 unrealistic. Emissions reductions of some scale, 

### 2 however, are always possible; and Cliffs embraces 

### 3 that idea as part of its current and future 

### 4 operations, but it is irresponsible of EPA to 

### 5 promote expectations that are not based on the 

### 6 available technical and knowledge base, especially 

### 7 when those expectations could negatively impact the 

### 8 quality and marketability of the product. 

### 9 The Clean Air Act designates the states 

### 10 as the primary responsibility for determination of 

### 11 BART. Cliffs requests that EPA recognize the time, 

### 12 energy, and ultimately the reasonable approaches pu t 

### 13 forward by both Michigan Department of Environmenta l 

### 14 Quality and Minnesota Pollution Control Agency as 

### 15 the first steps of the regional haze plan and that 

### 16 EPA validates those state implementation plans. 

### 17 This concludes my comments here today. 

### 18 Thank you for the opportunity to enter this into th e 

### 19 record. 

### 20 MR. ABURANO: Thank you. 

### 21 MR. LEON: Thank you very much. 

### 22 I'd like to call up the next couple of 

### 23 speakers, Mike -- is it -- 

### 24 MR. MLINAR: Mike Mlinar. 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 30 MR. LEON: -- Mike Mlinar, okay, and Doug 

### 1 Williams. 

### 2 MR. MLINAR: Good morning and thank you 

### 3 for the opportunity to speak this morning. My name 

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

### 5 I'm vice president for Cliffs Natural Resources 

### 6 North America Iron Ore Initiatives, and in this 

### 7 position I have responsibility for the U.S. iron or e 

### 8 and eastern Canadian operations initiative endeavor s 

### 9 to improve efficiency, look at alternative products , 

### 10 and improve overall performance. 

### 11 Before this position I was the vice 

### 12 president and general manager for the North Shore 

### 13 Mining Company, the Hibbing Taconite Company, the 

### 14 United Taconite Company in Minnesota, and prior to 

### 15 that was the vice president and general manager for 

### 16 the two Michigan mines, the Tilden Empire and 

### 17 Michigan's Upper Peninsula. Therefore, with over 

### 18 35 years of experience as a professional engineer 

### 19 and manager of iron ore mining and taconite 

### 20 processing facilities, I have a thorough 

### 21 understanding of the process technology that's used 

### 22 to convert iron-ore-bearing rock into higher 

### 23 iron-bearing pellets needed for our customers' 

### 24 fuel-making facilities. 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 31 I'm here today to provide a perspective 

### 1 on the operation on pellet product quality impacts 

### 2 of USEPA's proposed regional haze federal 

### 3 implementation plan for the taconite industry. As 

### 4 Scott Gischia explained, Cliffs understands and we 

### 5 accept our role and the important objective to 

### 6 reduce regional haze impacts, and we have 

### 7 contributed significantly to the gradual reduction 

### 8 in these emissions. We remain committed to further 

### 9 reducing emissions that contribute to the formation 

### 10 of regional haze. We do have a strategic plan that 

### 11 meets the state's long-term strategy outlined in th e 

### 12 state implementation plan to reduce implementations 

### 13 that contribute to regional haze and request that 

### 14 the USEPA respect the confidence plan developed in 

### 15 the SIPs that establish BART and demonstrate 

### 16 reasonable and significant further progress towards 

### 17 reducing haze emissions and impacts. 

### 18 We have serious concerns that USEPA's 

### 19 federal implementation plan concludes that taconite 

### 20 furnaces can successfully be retrofitted to deploy a 

### 21 pilot technology and achieve emissions limits 

### 22 without conducting any engineering to determine if 

### 23 the technology is technically or economically 

### 24 feasible. This one size-fits-all assumption ignore s 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 32 the comprehensive technical evaluations performed b y 

### 1 engineers specializing in the taconite industry and 

### 2 the conclusions independently reached by the states 

### 3 of Minnesota and Michigan which follow the USEPA's 

### 4 guidance in conducting their technology 

### 5 determinations. 

### 6 Even more perplexing, EPA ignored the 

### 7 Minnesota Pollution Control Agency's firsthand 

### 8 knowledge of the readiness of this pilot technology 

### 9 and surprisingly determined after years of study by 

### 10 the mining industry and the state agencies that the 

### 11 technology was viable, based upon the opinion of 

### 12 equipment vendors and others unfamiliar with 

### 13 potential impacts to the unique heat balance and 

### 14 product quality aspects. 

### 15 Finally, the OEM technical resources that 

### 16 were responsible for designing the heat balance 

### 17 process are a part of SIP and are the only ones 

### 18 fully knowledgeable of the unique indurating heat 

### 19 balance design. None of them were asked to conduct 

### 20 any engineering evaluation for the EPA to assess th e 

### 21 feasibility that validates this one-size-fits-all 

### 22 conclusion. 

### 23 Each of our taconite indurating furnaces 

### 24 are unique. None are the same. Each furnace is 

### 25 

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### 33 engineered to process its unique iron ore bodies to 

### 1 meet its customers' specifications that are all 

### 2 dependent on a carefully engineered, heat balanced 

### 3 distribution. 

### 4 Retrofitting existing burners from a low 

### 5 stoic design to a high stoic design, which is the 

### 6 current generation being pilot trialed at 1 grate 

### 7 kiln process, requires more primary combustion air 

### 8 to be introduced into the burner to cool the plane 

### 9 and reduce NOx emissions. This early generation of 

### 10 low NOx burner pilot is being developed to resolve a 

### 11 singularly-focused NOx compliance issue at one 

### 12 taconite facility and creates other potential 

### 13 negative consequences that have not been evaluated 

### 14 by the USEPA and would not satisfy BART criteria. 

### 15 For example, according to the OEM 

### 16 engineers that are expert in the grate-kiln heat 

### 17 balance design, the NOx FIP would have a couple of 

### 18 detrimental impacts. First, the increase of fuel 

### 19 switching by up to 60 percent would lead to 

### 20 collateral increase in related combustion emissions ; 

### 21 and, secondly, they would produce an altered flame 

### 22 temperature profile, which has negative collateral 

### 23 impacts on our quality process. 

### 24 In conclusion, we ask that the EPA 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 34 withdraw the proposed FIP for the taconite 

### 1 facilities in Minnesota and Michigan and approve th e 

### 2 state SIPs which establish legitimate BART 

### 3 determinations, and of course the reasonable furthe r 

### 4 progress to limit emissions that reduce visibility 

### 5 impacts. 

### 6 Thank you for the opportunity to listen. 

### 7 MR. ABURANO: Thank you. 

### 8 MR. LEON: Mr. McWilliams. 

### 9 MR. MCWILLIAMS: Thank you. My name is 

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

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

### 12 outside environmental counsel, Squire Sanders U.S., 

### 13 and Cliffs Natural Resources has asked that I 

### 14 provide some comments for the record on the propose d 

### 15 regional haze federal implementation plan and to 

### 16 encourage USEPA to withdraw its FIP and, instead, 

### 17 approve the state implementation plans for the 

### 18 taconite industry. 

### 19 The Clean Air Act establishes different 

### 20 rules for USEPA and states. The DC Circuit Court o f 

### 21 Appeals recently described the relationship as 

### 22 follows, and I quote: Under the Clean Air Act the 

### 23 federal government sets air quality standards, but 

### 24 states retain the primary responsibility if the 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 35 states want it for choosing how to attain those 

### 1 standards within their borders. The act, thus, 

### 2 leaves it to the individual states to determine in 

### 3 the first instance the particular restrictions that 

### 4 will be imposed on the particular emitters within 

### 5 their borders. If a state refuses to participate, 

### 6 the federal government regulates the sources 

### 7 directly, closed quote. 

### 8 Minnesota and Michigan did not refuse to 

### 9 participate; and, to the contrary, these states 

### 10 invested significant resources over many years to 

### 11 develop their regional haze state implementation 

### 12 plans for the taconite industry, demonstrating 

### 13 clearly that they were willing to exercise their 

### 14 primary responsibility to develop valid state plans

. 

### 15 The primary role for states is very clear 

### 16 in the regional haze provisions of the Clean Air Ac t 

### 17 as well. In 1977 Congress added visibility 

### 18 protection in Section 169A of the act. Congress 

### 19 actively debated whether to place EPA or the states 

### 20 in charge of implementing the regional haze program , 

### 21 and Congress chose the states. The DC Circuit Court 

### 22 recently reviewed the legislative history of the 

### 23 visibility protection provisions of the act and 

### 24 concluded, again I quote: Congress intended the 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 36 states to decide which sources impaired visibility 

### 1 and what BART controls should apply to those 

### 2 sources, closed quote. 

### 3 The Court then decided that EPA's 1999 

### 4 regulations, regional haze rules, were invalid 

### 5 because they deprived the states of some of the tha t 

### 6 statutory authority. EPA's proposed FIP is another 

### 7 attempt to deprive states of their statutory 

### 8 authority and the primary role in choosing how to 

### 9 achieve the regional haze goals within their 

### 10 borders. This time EPA is second-guessing the 

### 11 best-available retrofit technology determinations, 

### 12 or BART determinations, submitted by Minnesota and 

### 13 Michigan for taconite furnaces not because the 

### 14 states did something wrong, but because new 

### 15 information has been presented that was not 

### 16 available when the states arrived at their BART 

### 17 technology determinations and which still has not 

### 18 been peer reviewed or subject to evaluation by the 

### 19 affected stakeholders. 

### 20 EPA reviews SIPs to determine if they 

### 21 meet clean air criteria. And if the state process 

### 22 fails to produce a compliant SIP, EPA can produce a 

### 23 FIP. That's not what happened here. EPA had 

### 24 proposed approving the Minnesota SIP for taconite 

### 25 

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### 37 furnaces on January 25th of 2012. EPA changed 

### 1 directions and is proposing a FIP because it thinks 

### 2 it has a better idea for BART that is based on newe r 

### 3 data that it believes will reduce emissions and 

### 4 reach regional haze goals faster than the state's 

### 5 plan. 

### 6 Based on our preliminary review, it is 

### 7 premature to make any regulatory decisions based on 

### 8 this new information, as others have indicated. 

### 9 But, more importantly, EPA's limited authority unde r 

### 10 the Clean Air Act does not authorize it to impose a 

### 11 FIP because it thinks it has a better idea. That 

### 12 undercuts Congress' decision to give states the 

### 13 primary role in determining BART for sources within 

### 14 their borders. 

### 15 EPA cannot rely on new information as the 

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

### 17 own guidelines, Part 51, Appendix Y, directs states 

### 18 to stop considering the evolution of available 

### 19 technologies after they close public comment on 

### 20 their state's BART determination. Minnesota's BART 

### 21 determination for taconite furnaces closed in 2009, 

### 22 and Michigan's closed in 2010. EPA's proposed BART 

### 23 FIP is based on questionable new information that 

### 24 was submitted for consideration in 2011 and 2012. 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 38 EPA cannot fault the states for following federal 

### 1 guidance, particularly when that guidance promotes 

### 2 the common sense position that states must be able 

### 3 to choose an endpoint for finalizing their BART 

### 4 determination to ensure there is an end to the 

### 5 regulatory process. 

### 6 May I ask for your discretion to have a 

### 7 few more minutes to complete my comments? 

### 8 MR. ABURANO: Sure, go ahead. 

### 9 MR. MCWILLIAMS: Thank you. The proposed 

### 10 FIP also approves -- or proves, rather, the wisdom 

### 11 of Congress' decision to leave BART determinations 

### 12 in state hands. The taconite industry is unique to 

### 13 the Iron Range that extends across northern 

### 14 Minnesota and into the upper peninsula of Michigan. 

### 15 These two states, Michigan and Minnesota, have 

### 16 decades of direct experience regulating taconite 

### 17 compliance and pelletizing furnaces that EPA 

### 18 cannot -- cannot hope to replicate. 

### 19 Minnesota and Michigan are in a better 

### 20 position to assess the time and resources that it 

### 21 will take to evaluate the next generation of 

### 22 emission controls for this industry. The states 

### 23 appropriately chose a more conservative and measure d 

### 24 approach to the initial BART determination. EPA ha s 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 39 a statutory obligation to approve these legitimate 

### 1 state decisions and should withdraw its proposed 

### 2 FIP. 

### 3 Importantly, though, Minnesota's approach 

### 4 does not foreclose additional NOx reductions in the 

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

### 6 haze strategy. In fact, Minnesota has required 

### 7 these taconite furnaces by the end of this year to 

### 8 offer NO2 modeling and offer NOx emission controls 

### 9 as necessary to meeting ambient concentrations of 

### 10 NO2. 

### 11 To the extent that NOx emission reduction 

### 12 strategies are necessary to achieve these 

### 13 health-based national standards, the reductions are 

### 14 also expected to help meet the regional haze goals 

### 15 of the Clean Air Act. This approach allows the 

### 16 industry and its vendors more time to evaluate 

### 17 emission control options and their effect on health 

### 18 quality, preserving energy efficiencies, and 

### 19 sustaining pellet production at economically-viable 

### 20 levels. 

### 21 EPA's FIP usurps the state's reasoned and 

### 22 measured path forward and replaces it with a frenzy 

### 23 federal plan with inadequate support, and we have 

### 24 just 44 days on which to comment. Vendors are 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 40 telling us that they need more time. Vendors are 

### 1 telling us they need months to design a burner 

### 2 system that might work for each furnace, more month s 

### 3 to determine the rate of emission reduction that 

### 4 that is likely to achieve, and even more months to 

### 5 assess the true cost of retrofit emission controls. 

### 6 Modelers are telling us they need more time than 

### 7 remains in the comment period to perform the 

### 8 visibility analysis that EPA should have done to 

### 9 support its BART FIP determination. EPA should 

### 10 extend the comment period to ensure that it will ge t 

### 11 the quality of information necessary to critically 

### 12 evaluate the proposed control technology. 

### 13 To close, we ask that EPA approve the 

### 14 SIPs, withdraw the proposed federal implementation 

### 15 plan for the taconite facilities in both Minnesota 

### 16 and Michigan. 

### 17 Thank you for your time. 

### 18 MR. ABURANO: Thank you. One clarifying 

### 19 question. At the beginning of your statement you 

### 20 talked about a court ruling -- 

### 21 MR. MCWILLIAMS: Yes. 

### 22 MR. ABURANO: -- that you quoted from. 

### 23 Can you tell us which court ruling it was? 

### 24 MR. MCWILLIAMS: The first one was EME 

### 25 

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### 41 Homer versus EPA, DC Circuit 2012 vacating the 

### 1 cross-state air pollution rule. There was a brief 

### 2 second quote, and that is from American Corn Grower s 

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

### 4 MR. ABURANO: Thank you. 

### 5 MR. LEON: Thank you. 

### 6 I'd like to call up George Pruchnofski 

### 7 and Allen Miller. 

### 8 Go ahead, Mr. Pruchnofski. 

### 9 MR. PRUCHNOFSKI: Is it working? Oh, the 

### 10 red light should be on for it to be working? 

### 11 Good day. My name is George Pruchnofski. 

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

### 13 a principal engineer with Barr Engineering Company. 

### 14 Barr has a unique and long-term perspective on the 

### 15 regional haze SIP BART implementation plans -- BART 

### 16 is the best-available retrofit technology -- that 

### 17 was developed for the taconite industry in Minnesot a 

### 18 and Michigan. 

### 19 In 2006 Barr helped the taconite industry 

### 20 respond to the original state's request for BART 

### 21 technology determinations. In 2003 Barr provided a 

### 22 report to MPCA, the Minnesota Pollution Control 

### 23 Agency, on the state of retrofit technology for the 

### 24 taconite industry. The MPCA attached that report t o 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 42 their BART determinations in 2009 when they 

### 1 concluded that good combustion practices constitute d 

### 2 BART from NOx submissions and existing controls 

### 3 constituted BART for SO2 emissions. 

### 4 Michigan relied on Barr's work for 

### 5 Minnesota to render its BART determination in 2010 

### 6 for the lone taconite furnace that is subject to 

### 7 regional haze regulation emission. Barr also 

### 8 provided support to the state process in 2011-2012 

### 9 that converted the state technology determinations 

### 10 into enforceable numerical limits using available 

### 11 test data. 

### 12 Throughout this process we witnessed the 

### 13 Minnesota Pollution Control Agency proceeding 

### 14 through a complete, lengthy, and legitimate SIP 

### 15 development process consistent with state and 

### 16 federal regional haze guidance. This includes the 

### 17 federal BART guidance published at 40 CFR Part 51, 

### 18 Appendix Y, and the Minnesota guidance that adopts 

### 19 the Appendix Y criteria and is called Guidance For 

### 20 Facilities Conducting a BART Analysis, March 2006. 

### 21 We are not aware of any errors or flaws in 

### 22 Minnesota's BART SIP process, and USEPA does not 

### 23 claim in its proposed federal implementation plan 

### 24 that Minnesota made errors or flaws leading up to 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 43 its emission of its regional haze state 

### 1 implementation plan in December 2009. 

### 2 USEPA points to new information made 

### 3 available to USEPA in the comment period on its 

### 4 proposed approval of the Minnesota SIP in January o f 

### 5 2012. This new information was not available to 

### 6 Barr when we were preparing the BART SIP technology 

### 7 reviews for taconite facilities. 

### 8 According to USEPA's own guidance, 

### 9 Minnesota was allowed to close this review of BART 

### 10 technologies when it closed public comment on the 

### 11 December 2009 SIP because -- to quote, Because a ne w 

### 12 technology may become available at various points i n 

### 13 time during the BART analysis process, we believe 

### 14 that guidelines are needed on when the technology 

### 15 must be considered. In order to provide certainty 

### 16 to the process, all technologies should be 

### 17 considered, if available, before the close of the 

### 18 state's public comment period. You need not 

### 19 consider technologies that become available after 

### 20 this date, end quote. 

### 21 MPCA reasonably followed federal 

### 22 guidelines to develop its SIP based on the 

### 23 information available at the time. It would be 

### 24 inconsistent with federal guidance to require that 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 44 the SIP be reopened to consider this new 

### 1 information. But USEPA seems to be willing to 

### 2 propose a FIP based solely on this new information. 

### 3 That doesn't make sense to me. 

### 4 After thorough, intense, and lengthy 

### 5 reviews and additional evaluations required by the 

### 6 states, BART for nitrogen oxides controls was 

### 7 determined to be good operating practices for 

### 8 furnaces as determined on a furnace-specific basis. 

### 9 Now USEPA's proposed FIP relies on technologies tha t 

### 10 were not available, demonstrated, or were not 

### 11 permitted when the BART SIPs were submitted to USEP A 

### 12 in 2009 and 2010 for Minnesota and Michigan 

### 13 respectively. 

### 14 After similarly thorough, intense, and 

### 15 lengthy reviews and additional evaluations required 

### 16 by the states, the SIPs determined that BART for 

### 17 sulfur dioxide control was existing controls withou t 

### 18 additional add-on emissions controls, in large part 

### 19 based on cost considerations. The cost evaluations 

### 20 were completed by professionals with experience in 

### 21 cost estimating for iron industry furnaces and 

### 22 emissions controls. These cost evaluations factore d 

### 23 in the significant cost of ancillary changes that 

### 24 would need -- would be needed at the existing 

### 25 

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

# EPA PUBLIC HEARING RE: PROPOSED FIP FOR TACONITE F ACILITIES IN MN AND MI

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### 45 facilities through use of a retrofit factor based o n 

### 1 a professional's experience. However, for the 

### 2 proposed FIP USEPA has disregarded these evaluation s 

### 3 and decided to complete the new cost evaluations 

### 4 that are currently incomplete and significantly 

### 5 underestimate the cost of installing the controls a t 

### 6 an existing facility. 

### 7 May I have one more minute, please, sir? 

### 8 Thank you. 

### 9 USEPA is now asking that any objections 

### 10 to this incomplete cost evaluation be supported by 

### 11 vendor information. EPA should have fully complete d 

### 12 its cost effectiveness analysis prior to making its 

### 13 proposed determinations of BART in its proposed FIP

. 

### 14 Our experience is that it will take months to gathe r 

### 15 the vendor information and complete the evaluations 

### 16 USEPA is requesting at the detail they want. For 

### 17 new technologies applied to complex furnaces, the 

### 18 time to conduct the demonstrations needed for 

### 19 clients to get guaranteed emission rates and 

### 20 determine true costs could take considerably more 

### 21 time. 

### 22 My last two comments are very brief. One 

### 23 is that our preliminary review of the FIP appears - - 

### 24 our preliminary review of the FIP, it appears that 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 46 USEPA is making several optimistic assumptions that 

### 1 are underestimating the dollar-per-ton reduction 

### 2 improvement costs and also the dollar-per-deciview 

### 3 cost and will take time to get this sorted out. 

### 4 We'll be providing those comments for our clients 

### 5 for inclusion in their comments. 

### 6 And finally we have a final concern that 

### 7 in some cases USEPA may be establishing its propose d 

### 8 BART emission limits in the FIP based on average 

### 9 emissions, which means that roughly half the time 

### 10 actual emissions would be greater than the limit, 

### 11 resulting in noncompliance. Technology-based 

### 12 emission limits always includes some margin of 

### 13 safety to ensure that operations will achieve 

### 14 continuous compliance. We are concerned that the 

### 15 proposed FIP does not fully take this consideration 

### 16 into account. 

### 17 Thank you so much for your time, allowing 

### 18 me to finish the comments into the record. 

### 19 MR. LEON: Thank you, Mr. Pruchnofski. 

### 20 Mr. Miller. 

### 21 MR. MILLER: Good morning. My name is 

### 22 Allen Miller. I live at 1110 West Avenue in 

### 23 Red Wing, Minnesota. I previously submitted some 

### 24 comments in this proceeding in the form of a letter 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 47 to Administrator Jackson dated February 24th, 2012; 

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

### 2 it isn't already. 

### 3 I think that anyone who's watched this 

### 4 proceeding, which has dragged out, in effect, for 

### 5 many years, and looked at it objectively would have 

### 6 to recognize that what's fundamentally going on her e 

### 7 is that the political influence of the mining 

### 8 industry in Minnesota has outweighed the integrity 

### 9 of the regulatory process in Minnesota. And 

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

### 11 the MPCA is fronting for the industry rather than 

### 12 carrying out its responsibilities, particularly 

### 13 those responsibilities delegated to it by the regio n 

### 14 and the agency. 

### 15 So I want to thank you for being here 

### 16 today, for bringing forward the federal 

### 17 implementation plan. I think we're all aware that 

### 18 this is not something that is done commonly or 

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

### 20 my opinion is indisputable. And that's very clearl y 

### 21 shown by the testimony on both sides that we've 

### 22 heard so far this morning. 

### 23 So I support the FIP, as you have brought 

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

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 48 suggested, that it is a very conservative, 

### 1 unaggressive document and there are many places in 

### 2 which one could arguably push for more aggressive 

### 3 reductions and stricter limits. And I can submit 

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

### 5 just mention a couple of them. 

### 6 You know, you identified the cost per ton 

### 7 of NOx reductions from the Minntac heating boilers 

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

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

### 10 boilers aren't all the same, and the engineering 

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

### 12 difference of an order of magnitude in a 

### 13 fundamentally-similar device, and I would take a 

### 14 look at that. 

### 15 I'm concerned about the discussion of 

### 16 fuel switching and the implications of that. For 

### 17 example, there have been representations that 

### 18 burning wood is environmentally beneficial when, in 

### 19 fact, the overall ecological impact of massive 

### 20 industrial steel wood burning is, in many respects, 

### 21 very negative, and it shouldn't be lightly factored 

### 22 in. 

### 23 Similarly, the MPCA seems to have been 

### 24 persuaded in some proceedings that the fuel 

### 25 

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### 49 switching to coal was an emissions reduction measur e 

### 1 in which it's argued that lower flame temperatures 

### 2 of coal reduce NOx emissions. But if one can make 

### 3 that argument at all, one can do it only by 

### 4 comparing coal to extremely-poorly-designed gas 

### 5 burners. And it seems to have been done without 

### 6 much regard for increased emissions of sulfur 

### 7 oxides. So, again, I think that is a subject that 

### 8 could use a little bit more exploration. 

### 9 I am concerned that some of the limits in 

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

### 11 to specific cites, but one says these limits do not 

### 12 apply when burning fuel oil. And that might seem 

### 13 fairly innocuous because of today's prices, nobody' s 

### 14 going to burn much fuel when they have access to 

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

### 16 than a few minutes knows that none of us really kno w 

### 17 where energy prices are going. So I'm concerned 

### 18 about setting limits that don't include limits 

### 19 during periods of gas burning. 

### 20 Similarly, there are references in the 

### 21 FIP to the burning of oil with sulfur concentration s 

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

### 23 appropriate to me. Every operating refinery in the 

### 24 world now knows how to desulfurize fuel oil, and 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 50 we're seeing a broad movement across sectors and 

### 1 industries towards much lower levels of sulfur in 

### 2 fuel oil. So I think that's something that ought t o 

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

### 4 Burning -- particularly if you're going to exempt 

### 5 fuel oil burning periods from regulatory limits, yo u 

### 6 ought to specify clean fuel oil. 

### 7 And I'll just wind up then with this 

### 8 comment: That I am reasonably satisfied, based on 

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

### 10 that low NOx burners are appropriately identified a s 

### 11 BART for the control of nitrogen oxide emissions. 

### 12 And when we look at a reduction in baseline levels 

### 13 from something like 4 pounds per million and BTUs t o 

### 14 1.2, that looks pretty good. But when we look at 

### 15 the work that's been done on the reduction of sulfu r 

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

### 17 apparent that SCR and SNCR have been adequately 

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

### 19 spray dryers has been adequately considered. I see 

### 20 that in one place that was found by one operator to 

### 21 be technically feasible and by others not. I would 

### 22 like to see a little bit more information on why 

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

### 24 cost effective. 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 51 So, with that, I'll just close by saying 

### 1 please go ahead with the FIP; please take a look at 

### 2 opportunities for tightening it up a bit. Thank 

### 3

you. 

### 4 MR. ABURANO: Thank you. 

### 5 MR. LEON: We have -- well, I have one 

### 6 more name up here. Carol Overland. 

### 7 MS. OVERLAND: Good morning. My name is 

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

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

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

### 11 working primarily in transmission issues, so I 

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

### 13 my specialty. But a few things I wanted to note. 

### 14 First, I want to thank you for the 

### 15 opportunity to make comments on this. I've been 

### 16 peripherally involved in some issues regarding the 

### 17 Minnesota Pollution Control Agency, and the agency 

### 18 has consistently taken no action in this specific 

### 19 case over many, many years. And what I would like 

### 20 you to consider is that what you're seeing here is 

### 21 just the tip of the iceberg, and this is a pattern 

### 22 of behavior on behalf of the Minnesota Pollution 

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

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

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 52 happening at the MPCA. 

### 1 For example, one that I was involved in 

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

### 3 coal gasification project proposed for the Range 

### 4 near the plants that you're considering here until 

### 5 my clients had made a motion to drag them into the 

### 6 proceeding. And at that point they did, after the 

### 7 instance the pollution -- I mean, the Public 

### 8 Utilities Commission made a request that they do 

### 9 participate. And when -- in that case, where the 

### 10 MPCA saw no problem with haze potential, the EPA di d 

### 11 weigh in. They were concerned about the haze and 

### 12 the potential for the Mesaba project to increase 

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

### 14 related where the MPCA is not acting regarding haze 

### 15 and it's not acting generally. 

### 16 And I ask that you do increase the haze 

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

### 18 and that you go forward with this FIP. 

### 19 And I ask that the EPA look at the MPCA's 

### 20 failure to regulate in its delegated role. You 

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

### 22 but that authority has been delegated by the EPA, a s 

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

### 24 And I -- also, as a process issue I note 

### 25 

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

### 1 when most people work. And when you have a meeting 

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

### 3 Cliffs people and very few members of the public. 

### 4 And it does not work for the public. And the EPA 

### 5 does have a public participation component, and it 

### 6 would have helped to have at least another session 

### 7 in the evening so that people could attend, regular 

### 8 people and not paid lobbyists. 

### 9 And I will submit more detailed comments 

### 10 by the deadline. And thank you for taking this 

### 11 action, and thank you for holding this hearing. 

### 12 MR. ABURANO: Thank you. 

### 13 MR. LEON: Thank you. 

### 14 Just a general announcement, if there's 

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

### 16 like to invite you to come up. 

### 17 MR. ABURANO: Because I don't think we 

### 18 have any additional speakers at this point, so 

### 19 we're -- okay. 

### 20 MR. LEON: So please state your name and 

### 21 affiliation, if you have one, and you have five 

### 22 minutes. 

### 23 MR. DINSLAGE: All right. Thanks. My 

### 24 name is Matthew Dinslage. I live in Lakeville, 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 54 Minnesota. 

### 1 COURT REPORTER: Could you spell that, 

### 2 please? 

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

### 4 L-A-G-E. 

### 5 COURT REPORTER: Thank you. 

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

### 7 general constituent of the area, so -- and importan t 

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

### 9 attend this public hearing, so... 

### 10 I've listened to a lot of the comments 

### 11 from a technology standpoint, from an air quality 

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

### 13 all throughout Minnesota. My goal over the years i s 

### 14 to have my kids attend and camp at all the state 

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

### 16 accomplished getting to about 22 of them today. 

### 17 But I'm also a mechanical engineer. My 

### 18 wife is a chemical engineer. And we look at things 

### 19 from a very process-oriented and technical 

### 20 standpoint. If you look at the ways that the EPA 

### 21 and the emission reductions have taken place on 

### 22 highway diesel engines globally, from a marine 

### 23 shipping standpoint and then also just from the 

### 24 power production plants throughout the United 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 55 States, the number of OEMs and the number of 

### 1 analysis and data analysis that has gone into those 

### 2 emission reduction standards over the years is quit e 

### 3 dramatic. When you look at the on-highway diesel 

### 4 engine market, you have probably seven to ten large 

### 5 OEMs who have input -- or invested millions and 

### 6 millions of dollars at looking at different 

### 7 technologies to get to the point where we are today 

### 8 in terms of particulate matter reduction and SOx an d 

### 9 NOx emissions. 

### 10 If you look at the marine industry for 

### 11 the numbers of ships throughout the globe, again, 

### 12 the numbers of OEMs and the dollars spent and the 

### 13 amount of fuel used in that industry is staggering, 

### 14 much higher than the CVL on highway industry. 

### 15 When you look at the number of power 

### 16 plants in the United States, the over 16 million 

### 17 gigawatts of power generated and the numbers of OEM s 

### 18 that put in millions and billions of dollars of 

### 19 research to get to the emission reductions we are 

### 20 today is staggering as well. 

### 21 When you look at the taconite industries, 

### 22 there are just a handful of OEMs that are in this 

### 23 job. And when you look at the taconite industry or 

### 24 iron ore industry from a global standpoint, most of 

### 25 

### SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 56 the iron ore developed throughout the U.S. -- 

### 1 throughout the world is dug out of the ground and 

### 2 put right into the mill -- or right into the 

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

### 4 taconite process to refine and to purify that to a 

### 5 much greater concentration of ore, which there is 

### 6 very few OEMs and very few people invested into tha t 

### 7 industry. 

### 8 So the amount -- when I hear a lot of the 

### 9 research that has started to go out there in terms 

### 10 of reduction in some of these furnaces, these 

### 11 furnaces are very unique from one another. Just 

### 12 like God created each of us as unique individuals 

### 13 with an individual plan, each one of these 

### 14 indurating furnaces are very unique in their own 

### 15 processes. And to apply a standard thought process 

### 16 like is done in the CVL on highway or marine 

### 17 industry or the power production standpoint, you 

### 18 can't just brushstroke that across and say if we ca n 

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

### 20 not going to take. We have to have a very 

### 21 disciplined approach to meet these next guidelines. 

### 22 I agree that there should be a guideline, 

### 23 but I think this FIP should be pushed off and then 

### 24 looked at and really researched and looked at how 

### 25 

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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 1

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 2

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 3

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 4

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

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

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

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

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

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 10

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 lik e 11

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 12

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 13

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 14

s p e a k . 15

T h a n k y o u . 16

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

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

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 19

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 20

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

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

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 u p 23

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 a t 24

th e d o o r . 25 SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

58

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 1

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 2

te s tim o n y . 3

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

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 5

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 6

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 7

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 8

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 e t 9

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 10

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

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

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 13

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 14

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 15

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 16

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 17

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

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 19

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 . 20

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 21

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 22

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

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 24

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 25 SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 59 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 'l l 1

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 2

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 3

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 . 4

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 5

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

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

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 8

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 9

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 10

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 ffe r 11

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 12

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 . 13

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

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

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 16

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 fiv e 17

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 18

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

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

21

22

23

24

25 SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163 60 S T A T E O F M IN N E S O T A ) 1 ) s s . C O U N T Y O F D A K O T A ) 2

3

4

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

6

7

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

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, 9

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 10

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 11

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

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

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

15

16

17

18

A N G IE D . T H R E LK E LD 19 C o u rt R e p o rte r 20 21 22 23 24 25 SHADDIX & ASSOCIATES (952)888-7687 (800)952-0163

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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 F ACILITIES IN MN AND MI

17 of 31 sheets Page 2 to 2 of 16 09/12/2012 06:32:53 PM 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 F ACILITIES IN MN AND MI

09/12/2012 06:32:53 PM Page 3 to 3 of 16 18 of 31 sheets 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 F ACILITIES IN MN AND MI

19 of 31 sheets Page 4 to 4 of 16 09/12/2012 06:32:53 PM 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 F ACILITIES 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, 46:3dollar-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, 39:20economicallyviable[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, 39:22EPA-R05-OAR2010-0037 [1] - 1:7EPA-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 F ACILITIES 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, 13:21federalismbased [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, 48:14fundamentallysimilar [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 F ACILITIES 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 F ACILITIES 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] - 54:5l-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 F ACILITIES 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, 42:23MinnesotaDuluth [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 F ACILITIES 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 F ACILITIES 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, 56:16processoriented [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 F ACILITIES 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 F ACILITIES 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, 41:3secondguessing [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] - 33:12singularlyfocused [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 F ACILITIES 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, 57:3technologybased [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 F ACILITIES 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] - 17:4welldocumented [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 F ACILITIES IN MN AND MI

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



# SHADDIX & ASSOCIATES ( 952 ) 888

- 7687 ( 800 ) 952

- 0163 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