Document mwyN0wMj15zo738282D2ajEg

REGION 5 Enforcement and Compliance Assurance Division Inspection Date: Time: Media: Statute (s)/Program(s): Type of inspection: Access: INSPECTION REPORT May 28, 2025 Inspection Announced: No Entry: 7:50 AM EST Exit: 12:30 PM EST Water Clean Water Act, National Pollutant Discharge Elimination System (NPDES), Industrial CEI - Compliance Evaluation Inspection Granted Permittee Name: Facility or Site Name: Facility/Site Physical Address: (city, state, zip code) County/Parish: Cleveland-Cliffs Steel Corp. - Mansfield Works Cleveland-Cliffs Steel Corp. - Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Richland Permit Number: OH0006840 Page 1 of 38 REGION 5 Enforcement and Compliance Assurance Division Persons Participating in Inspection: Title Name Physical Scientist, Matthew EPA Schulte Life Scientist, EPA Megan Bobb Physical Scientist, Sophie Bazan EPA Environmental Health and Safety Manager Nathan O'Connor Associate Environmental Engineer Cody Chalfant Phone (312) 886-2405 (312) 353-6057 (312) 886-6068 -- -- Email schulte.matthew@epa.gov bobb.megan@epa.gov bazan.sophie@epa.gov Nathan.oconnor@clevelandcliffs. com -- Present at Opening Conference Yes Yes Yes Yes Yes Present at Closing Conference Yes Yes Yes Yes Yes Lead Inspector: Matthew Schulte Matthew Schulte MATTHEW SCHULTE Region 5 Digitally signed by MATTHEW SCHULTE Date: 2025.07.31 15:56:24 -05'00' schulte.matthew@epa.gov Supervisor Review: Molly Smith MOLLY SMITH Region 5 Digitally signed by MOLLY SMITH Date: 2025.07.31 16:01:41 -05'00' smith.molly@epa.gov (312) 886-2405 (312) 353-8773 SECTION I - INTRODUCTION Site Entry and Inspection Objectives Region 5 Lead Inspector, Matthew Schulte, and inspectors Sophie Bazan and Megan Bobb arrived at the Cleveland-Cliffs Mansfield Works Facility (the "Site" or "Facility"), located at 913 Bowman Street, Mansfield, Ohio at 7:30 AM on May 28, 2025, for an unannounced inspection. Inspectors presented their credentials to Nathan O'Connor and informed the Facility that this was an EPA Region 5 inspection to investigate elements of the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) permit program. Page 2 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): May 28, 2025 The inspection was conducted under the authority of the CWA NPDES permit program and Section 308 of the CWA. The table above identifies the attendees that participated in the inspection. This report is based on information supplied by Facility representatives, observations made by the Region 5 inspectors, and records and reports maintained by the permittee and Region 5. These include the following: direct observations made by the Region 5 inspectors, photographs taken by Region 5 inspectors, physical evidence collected by Region 5 inspectors, measurements taken by Region 5 inspectors, verbal or written statements made or supplied by Facility representatives (the permittee) during or subsequent to the on-site inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the Region 5 inspectors by Facility representatives during or subsequent to the on-site inspection. In addition, information gathered prior to or subsequent to the inspection from a review of U.S. EPA, State, and public records may be included in this report. Facility/Site Description Region 5 Lead Inspector confirmed the following Facility information: The Facility is a steel mill that specializes in metal sheet production for exhaust pipes in automobiles. The Facility has approximately 300 employees and operates 24 hours per day 7 days a week. Every eight to nine weeks the Facility will perform an outage for maintenance that typically lasts 4 days. There is also a one to two week planned maintenance outage in fall every year. Prior to 2020, the Facility was owned and operated by AK Steel. The Facility receives a couple tons of raw materials every month. The raw materials received include aluminum, chrome, lime, scrap metal, iron ingots and powder. Water used in the production process comes from the city, but the Facility does have an onsite water well that is used for dust suppression. Production occurs in three main building at the Facility: the melt shop, caster, and hot strip. Water in the melt shop is for non-contact cooling. Water usage in the caster and hot mill includes contact cooling with runoff eventually being discharged to the hot mill pond. All outfalls, but Outfall 001, receive stormwater flows. According to the Facility, Outfall 004 was closed prior to 2010. SECTION II - OBSERVATIONS Observations may not be in sequential order. Unique Identifying No. MS5-OB-001 MS5-OB-002 Observation During the site tour, inspectors observed a metal sheet in the effluent channel for Outfall 005. (Photo 2) During the site tour, inspectors observed a pile of scrap metal and debris near Outfall 006. (Photo 7) Area of Concern? Yes Yes Page 3 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Unique Identifying No. MS5-OB-003 MS5-OB-004 Observation During the site tour, inspectors observed new stormwater barriers and filters surrounding storm water drains around the Facility. (Photo 8) During the site tour, inspectors observed various scrap metal debris around the Facility. May 28, 2025 Area of Concern? No Yes SECTION III - RECORDS REVIEW Records reviewed may not be in sequential order. No. MS5-RR-001 MS-RR-002 Record Documents requested during the inspection were received by USEPA on May 30, 2025. Last revision to the Storm Water Pollution Prevention Plan (SWPPP) was on June 9, 2023 to reflect the updated benchmark monitoring schedule. SECTION V - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. No. MS-OB-001 During the site tour, inspectors observed a metal sheet in the effluent channel for Outfall 005. (Photo 2) NPDES Permit Part IV. Stormwater Control Measures and Pollution Prevention Programs. Part C - Minimize Exposure - You shall minimize the exposure of manufacturing, processing, and material storage areas (including loading and unloading, storage, disposal, cleaning, maintenance, and fueling operations) to rain, snow, snowmelt, and runoff by either locating these industrial materials and activities inside or protecting them with storm resistant coverings. MS-OB-002 During the site tour, inspectors observed a pile of scrap metal and debris near Outfall 006. (Photo 7) NPDES Permit Part IV. Stormwater Control Measures and Pollution Prevention Programs. Part C - Minimize Exposure - You shall minimize the exposure of manufacturing, processing, and material storage areas (including loading and unloading, storage, disposal, cleaning, maintenance, and fueling operations) to rain, snow, snowmelt, and runoff by either locating these industrial materials and activities inside or protecting them with storm resistant coverings. Page 4 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): May 28, 2025 No. On July 16, 2025, the Facility provided USEPA with documentation of clean-up activities of scrap metal debris around the "Clean Fill Area" near Outfall 006. MS-OB-004 During the site tour, inspectors observed various scrap metal debris around the Facility. NPDES Permit Part IV. Stormwater Control Measures and Pollution Prevention Programs. Part C - Minimize Exposure - You shall minimize the exposure of manufacturing, processing, and material storage areas (including loading and unloading, storage, disposal, cleaning, maintenance, and fueling operations) to rain, snow, snowmelt, and runoff by either locating these industrial materials and activities inside or protecting them with storm resistant coverings. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The Lead Inspector held a closing conference with Facility personnel on May 28, 2025, for the inspection. During the closing conference, the Lead Inspector discussed the observations and Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. SECTION VII - LIST OF APPENDICES Appendix 1 - Photo Log [times listed on images are in Central Standard Time, times listed on left side are in Eastern Standard Time]. Page 5 of 38 REGION 5 Enforcement and Compliance Assurance Division Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 1 Time: 9:50 AM Direction Photo Taken: West Photo Description: Outfall 005. Offsite sampling location. Photographer: Megan Bobb Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_01.JPG Page 6 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 2 Time: 9:55 AM Direction Photo Taken: North Photo Description: Outfall 005 effluent channel. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_02.JPG Page 7 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 3 Time: 9:57 AM Direction Photo Taken: North Photo Description: Outfall 005 effluent storm doors on pipes. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_03.JPG Page 8 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 4 Time: 10:03 AM Direction Photo Taken: East Photo Description: Outfall 006 effluent. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_04.JPG Page 9 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 5 Time: 10:05 AM Direction Photo Taken: Northeast Photo Description: Outfall 006 influent. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_05.JPG Page 10 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 6 Time: 10:05 AM Direction Photo Taken: Northeast Photo Description: Outfall 006 influent from Stein Slag Processing. Visible sheen from slag runoff. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_06.JPG Page 11 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 7 Time: 10:09 AM Direction Photo Taken: South Photo Description: Rocky pile and metal scrap bordering river near Outfall 006. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_07.JPG Page 12 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 8 Time: 10:14 AM Direction Photo Taken: South Photo Description: Outfall 011 storm drain inlet. Surrounded by new filters. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_08.JPG Page 13 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 9 Time: 10:22 AM Direction Photo Taken: East Photo Description: Outfall 007. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_09.JPG Page 14 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 10 Time: 10:25 AM Direction Photo Taken: West Photo Description: Outfall 009 Stein runoff backend. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_10.JPG Page 15 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 11 Time: 10:28 AM Direction Photo Taken: West Photo Description: Runoff from natural holding pond. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_11.JPG Page 16 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 12 Time: 10:36 AM Direction Photo Taken: Northwest Photo Description: Smaller hot mill pond with oil skimmer. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_12.JPG Page 17 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 13 Time: 10:36 AM Direction Photo Taken: North Photo Description: Oil skimmer in hot mill pond. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_13.JPG Page 18 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 14 Time: 10:36 AM Direction Photo Taken: Northeast Photo Description: Hot mill pond south polyfloc pump. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_14.JPG Page 19 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 15 Time: 10:36 AM Direction Photo Taken: Northwest Photo Description: Large hotmill north polyfloc recycled water tower. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_15.JPG Page 20 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 16 Time: 10: 41 AM Direction Photo Taken: North Photo Description: Caster cooling towers. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_16.JPG Page 21 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 17 Time: 10:42 AM Direction Photo Taken: down Photo Description: Scale pit. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_17.JPG Page 22 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 18 Time: 10:45 AM Direction Photo Taken: East Photo Description: Drying sludge with runoff channel to hot mill pond. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_18.JPG Page 23 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 19 Time: 10:45 AM Direction Photo Taken: North Photo Description: Drying channel from sludge to hot mill pond. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_19.JPG Page 24 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 20 Time: 10:47 AM Direction Photo Taken: North Photo Description: Large hot mill pond. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_20.JPG Page 25 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 21 Time: 10:48 AM Direction Photo Taken: East Photo Description: Outfall 012. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_21.JPG Page 26 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 22 Time: 10:48 AM Direction Photo Taken: East Photo Description: Outfall 012. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_22.JPG Page 27 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 23 Time: 10:53 AM Direction Photo Taken: West Photo Description: Outfall 008. Only gets flow during heavy rain events. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_23.JPG Page 28 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 24 Time: 10:57 AM Direction Photo Taken: Southwest Photo Description: Used oil storage area. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_24.JPG Page 29 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 25 Time: 11:02 AM Direction Photo Taken: North Photo Description: Pump hose from well. Water used for dust control. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_25.JPG Page 30 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 26 Time: 11:07 AM Direction Photo Taken: down Photo Description: Outfall 003 Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_26.JPG Page 31 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 27 Time: 11:13 AM Direction Photo Taken: -- Photo Description: Outfall 003 influent from offsite. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_27.JPG Page 32 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 28 Time: 11:19 AM Direction Photo Taken: North Photo Description: Outfall 002. Stormwater only. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_28.JPG Page 33 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 29 Time: 11:24 AM Direction Photo Taken: West Photo Description: Old cold mill lot. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_29.JPG Page 34 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 30 Time: 11:44 AM Direction Photo Taken: East Photo Description: Polishing ponds. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_30.JPG Page 35 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 31 Time: 11:46 AM Direction Photo Taken: West Photo Description: Polishing ponds. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_31.JPG Page 36 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 32 Time: 11:54 AM Direction Photo Taken: -- Photo Description: Outfall 001 sampling station. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_32.JPG Page 37 of 38 Cleveland-Cliffs Steel Corp.: Mansfield Works Inspection Date(s): Facility Name & Location: Cleveland-Cliffs Steel Corp.: Mansfield Works 913 Bowman Street Mansfield, Ohio 44903 Date Photograph Was Taken: May 28, 2025 Photo No.: 33 Time: 11:55 AM Direction Photo Taken: down Photo Description: Outfall 001. Photographer: Megan Bobb May 28, 2025 Camera: Olympus Tough TG-6 (S/N #BJ5B21169) File: CCMW_33.JPG Page 38 of 38