From: McWilliams, Douglas A. [ mailto:douglas.mcwilliams@squirepb.com ]

Sent: Monday, May 18, 2015 4:18 PM

To: Greenberg, Alan (ENRD)

Cc: Kacenjar, Allen A.; Franz, Katy M.

Subject: Release of Confidential Business Information for BART FIP Settlement Rule Support

‐‐ FCT UTAC Line 2 Phase 3 Modeling

Report released from CBI [I

‐ AMS.FID1382186]

Alan,

As we discussed during our telephone conference on Friday, Cliffs is transmitting documents requested by EPA for use in support

of the BART FIP settlement rulemaking. These are documents previously marked confidential business information (CBI). In this

e

‐ mail, Cliffs is transmitting the FCT Combustion Cliffs UTAC Line 2 Phase 3 Modeling Report with redactions sufficient for Cliffs

to withdraw its CBI claim. Thus, Cliffs withdraws is CBI claim as to the redacted version of this document only.

With this transmission, Cliffs has provided public, non

‐ CBI, versions of the majority of the documents mentioned in your May 14,

2015 Letter to support the settlement rulemaking record. Specifically, you now have the documents numbered 1, 3, 5, and 6 in

your letter as well as the Attachment L and BB documents requested by e

‐ mail on April 22, 2015. This leaves only the Coen

documents (nos. 2 and 4), which we cannot unilaterally release from CBI. The Coen information comes into the record indirectly

via the Metso Reports. Coen is a burner manufacturer whose reports were evaluated by the furnace expert, Metso. Metso took

relevant input information from the Coen reports and facility information, some of which remains CBI, and ran models based on

this information to determine furnace performance. We believe the Metso reports provide sufficient record support for the

settlement. However, if EPA believes that additional information is needed from the Coen reports to support the record, we are

willing to arrange a technical discussion this week in the interest of generating an alternative source of that information.

Please let me know if such a discussion is needed.

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the co rrect file and location. Douglas A. McWilliams

Partner

Squire Patton Boggs (US) LLP

4900 Key Tower

127 Public Square

Cleveland, Ohio 44114

T +1 216 479 8332

O +1 216 479 8500

F +1 216 479 8780

M +1 216 407 4968

Douglas.McWilliams@squirepb.com | squirepattonboggs.com



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