### May 4 , 2012

VIA FEDERAL EXPRESS Attn: Compliance Tracker, AE

- 17J Air Enforcement and Compliance Assurance Branch U.S. Environmental Protection Agency Region 5 77 W. Jackson Boulevard Chicago, Illinois 60604

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

Dear Mr. Czerniak:
This letter and the enclosed information are the response of United Taconite LLC (referred to herein as “UTAC” or “Uni ted”) to Appendix C of the U.S. EPA Region V Clean Air Act Section 114 Information Request (the “Request”), regarding the facility located at 1200 West County Road 16, Forbes, Minnesota, which was received on April 6, 2012. The Request originally required a response within 15 days of receipt, but subsequent conversation and correspondence with Ms. Molly DeSalle of EPA staff on April 20, 2012 extended the deadline for submittal to May 7, 2012. UTAC hereby provides this timely response to the Request, with the understandings and clarifications noted herein.

UTAC has given careful consideration to this Request and each of its questions to ensure that its response is properly tailored to the information EPA has requested UTAC has made a good faith effort to re spond to this Request in the time allotted. To the extent that the response does not include all of the information anticipated by your request, we ask that EPA first consider the information attached hereto and evaluate what, if anything, may still be re asonably required under Clean Air Act Section 114(a). To the extent that EPA identifies continuing needs for information, please contact us to discuss how we may further assist you.

This response restates each of the questions in the Request and provide s a narrative explanation of the responsive information as necessary. Responsive documents are referenced in the narrative and included with this letter. The attachments are organized by numeric references that correspond to the questions below. Documen ts responsive to multiple questions are identified in the narrative response to each question, and are included under the question to which the documents are most responsive. The documents provided have been scanned for viruses using Symantec Endpoint Pro tection Version 11.

### U.S. Environmental Protection Agency Attn: Compliance Tracker, AE

- 17J Page 2

As part of its response, United wishes to note that while it is the present owner/operator of the facility, it was not the original owner, constructor or operator. The facility was constructed and commenced operations in the 1960s by Eveleth Taconite Co., developed through a joint effort of Oglebay Norton and the Ford Motor Co. In 1996, ownership was transferred to Eveleth Mines, LLC, held by Rouge Steel, AK Steel, and Stelco, and operated as EVTAC Mining. Following the bankruptcy o f EVTAC in 2002, Cliffs Natural Resources , in partnership with Laiwu Steel , purchased the assets of the former Eveleth Taconite in 2003 and began operating the facility later that year. In 2008, Cliffs Natural Resources purchased Laiwu Steel’s portion of ownership in the facility , and has operated the facility since that time.

In responding to this Section 114(a) Information Request, United has found some documents relevant to EPA’s inquiries for periods prior to United’s ownership. Copies of those documents are enclosed as appropriate throughout United’s response. UTAC has no way of verifying the completeness and/or veracity of documents which pre

- dated its ownership of the facility and thus that information is enclosed herewith without certificati on of any kind and are specifically excluded from the certification set forth below.

For the record, UTAC notes that while it has made a good faith effort to respond to the Information Request, it does not waive any of its rights to object to the form and content of the Information Request or any legal defenses that it might have to this Information Request or its admissibility in any administrative or judicial proceeding. To the extent, this Information Request is overly broad and unduly burdensome; it seeks information that is not relevant to the compliance status of its facility; it is vague and ambiguous, and requires that legal conclusions be made to it, UTAC objects to the Information Request on the grounds that it exceeds U.S.EPA’s authority und er Section 114 of the Clean Air Act. UTAC also objects to the Information Request to the extent that it requests information that is subject to attorney

- client privilege or other applicable privilege, or that constitutes attorney work product or is other wise not discoverable. Finally, to the extent that the questions are vague, ambiguous, overly broad, or otherwise exceed U.S. EPA’s authority under Section 114(a), UTAC has made appropriate and reasonable efforts to respond to the questions to the best of its ability, and has made reasonable interpretations of the questions.

If you have any questions regarding this information, please contact Ms. Candice Maxwell of my staff at (218) 744

- 7849.

### / Certification U

. S. Environmental Protection Agency Attn : Compliance Tracker, AE-17J Page 3

I certify under penalty of law that I have examined and am familiar with the information in the enclosed documents, including all attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certify that the statements and information are, to the best of my knowledge and belief, true and complete

. I am aware that there are significant penalties for knowingly submitting false statements and information, including the possibility of fines or imprisonment pursuant to section 113(c){2) of the Act, and 18 U.S

. C. §§ 1001 and 1341.

Santi Romani General Manager

Enclosure

cc: Jeff T

. Connell, Manager Air Quality Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155

Ms. Mary Gade, Gade Environmental Group LLC Mr. Michael Long, Cliffs Natural Resources Mr. Scott Gischia, Cliffs Natural Resources