From: "Long, Michael E" <Michael.Long@CliffsNR.com>

To: Steven Rosenthal/R5/USEPA/US@EPA,

Cc: Douglas Aburano/R5/USEPA/US@EPA, Kathleen Dagostino/R5/USEPA/US@EPA, Sarah

Cervak/R5/USEPA/US@EPA, William Wagner/R5/USEPA/US@EPA, Molly

DeSalle/R5/USEPA/US@EPA, Kevin Vuilleumier/R5/USEPA/US@EPA

Date: 11/29/2012 10:32 AM

Subject: RE: Cliffs Regional Haze Proposal

Steve,

Per your email below, Cliffs is in agreement with the SO2 limits outlined in your e

‐ mail below with the

following clarifications:

1. Please confirm our understanding that the UPL method to determine SO2 limits for Tilden

and Northshore that you reference will use the 99 th percentile UPL of all valid CEMs data.

2. If we agree to install SO2 CEMs at Hibbing and Northshore, we ask that the 30

‐ day rolling

average SO2 limits be aggregated for Hibbing (Line 1 + Line 2 + Line 3) and Northshore (Furnace

11 + 12) similar to the method agreed to for UTAC. We are still trying to determine whether

reliable CEMS measurement is even possible for Northshore’s 0

‐ 2ppm SO2 emissions rates and

would appreciate EPA’s recognition that Northshore would pursue CEMS, but may be halted by

the practical limits of the technology.

3. The final rule will allow at least 18 months to install CEMs at Northshore and Hibbing as

j ustified in the 18

‐ month CEM installation schedule (including design, engineering, procurement,

fabrication, installation and tuning) in our comments. The current timeline in the FIP for Hibbing

and Northshore is 3 months and 6 months, respectively, which does not allow us the time to

properly install CEMS on multiple stacks. We can also use the additional time to consider the

site

‐ specific monitoring options for representative SO2 measurement that you suggest for cost

savings in your e

‐ mail.

To avoid needless and avoidable challenges or administrative changes post FIP issuance, we would

appreciate an opportunity to review the relevant language in the p re

‐ signature version of the “final

FIP” that implements the changes affecting Cliffs. Our review would be limited to the major issues

outlined below and we will provide our feedback within the day to avoid delays.

I would also like to continue our discussion toward resolving the NOx matter, and follow

‐ up with you on

the dialog between counsel yesterday afternoon. Are you available at 3 PM eastern (2 PM central) today

to discuss further?

Regards,

MICHAEL E. LONG

Director – Corporate Environmental Regulatory Strategy and Analysis

P 216.694.7359 (O) 216-262-8797 (M) Michael

. Long @ cliffsnr

. com

CLIFFS NATURAL RESOURCES

200 Public Square, Suite 3300, Cleveland, OH 44114-2544

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______________________________________________________________________________________________________From: Rosenthal.Steven@epamail.epa.gov [mailto:Rosenthal.Steven@epamail.epa.gov]

Sent: Wednesday, November 28, 2012 3:31 PM

To: Long, Michael E

Cc: A burano.Douglas@epamail.epa.gov; Dagostino.Kathleen@epamail.epa.gov;

Cervak.Sarah@epamail.epa.gov; Wagner.William@epamail .epa.gov; DeSalle.Molly@epamail.epa.gov;

V uilleumier.Kevin@epamail.epa.gov

Subject: Cliffs Regional Haze Proposal

Mike,

Thanks very much for the detailed explanation and clarification of your proposal that you provided

yesterday. We have discussed your approach for addressing BART for NOx with our Office of General

Counsel and are considering how to best address your concerns as well as our requirements and are

hopeful that we can come to agreement with you on how to best establish NOx limits for your facilities.

However, I would like to see if we can reach agreement with you at this time regarding the SO2 limits. We

basically accept your proposal for Tilden and United Taconite but are not willing to waive the requirement

for SO2 CEMS. More specifically:

Tilden Mining: Tilden Line 1 will be limited to natural gas fuel and within 60 days after collecting one

year's worth of data an SO2 lbs/hr limit will be established based upon the UPL method you received

from us yesterday.

United Taconite: We accept a combined 529 lbs SO2/hr limit for Lines 1 and 2 on a 30-day rolling

average within 54 months.

Hibbing Taconite: We will accept an 83 lb/hr limit for each line provided that compliance is established

using CEMs.

Northshore: We will agree to an initial limit of 19.5 lbs SO2/hr, and to waive the 80% control requirement,

provided that CEMs are installed and within 60 days after collecting one year's worth of data an SO2

lbs/hr limit will be established based upon the UPL method you received from us yesterday.

However, we feel the requirement to install CEMS is reasonable, cost effective and necessary to assure

continuous compliance with the emission limits established by the rule. Beyond the ability to assure

ongoing compliance, the data from the CEMS can be used by industry to further improve process

operations and control device operation which can further reduce emissions through optimization and

periodic adjustments. Such actions can further aid in achieving improved visibility which is the goal of all

parties involved through the issuance of this rule.

Concerns regarding the number of CEMS required and other issues identified through comments are

being addressed in the response to comments portion of the rule. In general, there is an incorrect

assumption that a CEMS will be required on every stack from which emissions are emitted. Many of the

"multiple stacks" originate from a common header which receives emissions from one or two process

vents. Installation of a single CEMS within a process vent just prior to common headers is one of several

options which can be addressed in site-specific monitoring plans required by this rule. Other options like

multiple sampling lines with a single analyzer can further reduce costs associated with monitoring all

stacks of concern.

Regardless of whether or not you have concerns about installing CEMS we would appreciate knowing

whether we are in agreement on the Tilden and United Taconite SO2 approach described above and in

your proposal.

Thanks