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Minnesota Pollution Control Agency (MPCA)

Letter of notification from James Swearingen to Lisa Thorvig: includes the US Filter Proposal

U.S. Steel
Jim Swearingen
Minnesota
Ore Operations General Manager
P.O. Box 417
Mt. Iron, MN 55768

February 19, 1996

Ms. Lisa J. Thorvig
M innesota Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155-3898

RE: Project XL

Dear Ms. Thorvig:

The Minnesota Pollution Control Agency (MPCA) has invited USS-MINNTAC to propose a framework upon which a multi-media operating agreement, in the form of an XL Pilot Project, could be developed. The purpose of this proposal is to provide MPCA with generic components which MINNTAC believes could be the basis for a final XL agreement. MINNTAC is prepared to work with MPCA to jointly develop this draft proposal into a final proposal, mutually agreeable to MPCA and MINNTAC. The following USS personnel will represent MINNTAC on the XL implementation team:

Rick Lanari, USS Minntac
Larry Salmela, USS Minntac
Bill Kubiak, USS Environmental Affairs
Tishie Worley, USS Law Department

Attached to this proposal is a decision chart detailing a procedure which MINNTAC believes to be a realistic approach to the development of a final XL agreement. It is MINNTAC's understanding that the XL process is intended to function outside the framework of existing environmental laws and regulations with a goal of establishing reasonable operating and monitoring guidelines that are protective of the environment and meet or exceed both MINNTAC and MPCA objectives in a resource-effective manner. It is anticipated that both MPCA and MINNTAC will have expectations as to certain high priority issues. The following are examples of issues essential to MINNTAC in committing to a final XL agreement.

1. All outstanding Prevention of Significant Deterioration (PSD) issues must be resolved.

2. The planned expansion of the West Pit must be expedited, with special emphasis on the cost-effective resolution of wetlands issues.

3. Dissolved solids issues associated with the tailings basin effluents must be resolved.

4. Develop a plan to eliminate the use of PCB's.

POLLUTION PREVENTION

1. Develop a plan to recycle waste lubricants as an alternate fuel.

2. Development of a commodity control procedure.

3. Development of a tank containment plan.

ADMINISTRATIVE

1. Possible development of a plant-wide Environmental Management System (EMS).

2. Possible development of an Electronic Data Management System.

3. Environmental awareness training for employees and possible expansion to include governmental agencies or community groups.

4. Possible ISO 14000 certification.

5. Development of a mechanism to share environmental information with environmental agencies and other industries.

6. Possible wildlife habitat or wildlife enhancement projects.

7. Possible community beneficial environmental projects.
MINNTAC will work in good faith with MPCA to formalize this proposal. If this proposal is acceptable to MPCA, USS -
MINNTAC will draft a Memorandum of Understanding, detailing the draft proposal and implementation procedure.
MINNTAC appreciates the opportunity to work with MPCA in this innovative and ambitious program.

Please contact Larry Salmela at (218) 749-7569 to initiate discussions on this program.

Very sincerely yours: ____________________________________
James E. Swearingen General Manager

cc: CC Gedeon FJ Lanari CG Carson LC Salmela FJ Lanari LW Worley WS Kubiak


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