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 “United”) 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 respond to this 

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

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

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

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

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

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

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

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

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

viruses using Symantec Endpoint Protection Version 11. 
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 of 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 certification 

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 under 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 otherwise not discoverable. Finally, to the extent that the questions are vague, 

ambiguous, overly broad, or otherwise exceed U.S. EPA’s authority under Section 114(a), 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