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Paul Balserak [pbalserak@steel.org] 7/19/2017 9:38:14 PM Brown, Byron [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=9242d85c7df343d287659f840d730e65-Brown, Byro] CERCLA 108b Hardrock Mining Comments on Iron Ore Mining MDEQ OGMD Resp USEPA HardRock Mining Rules 2017.pdf; IMA - CERCLA 108b Final 7 1117.pdf; Proposed FR Rule for the Hardrock Mining lndustry.pdf; CERCLA 108b Hardrock Mining One Pager for EPA Meeting final.pdf; AISI Comments on EPA Financial Responsibility Requirments under CERCLA 108b for Hardrock Mining.pdf; CERCLA 108(b) Proposal -- Industry Coalition Comments.pdf
Dear Byron,
Thank you again for meeting with my members and me on June 20th regarding the CERCLA 108b hardrock mining proposed rule. Attached for your convenience are comments/materials specific to the iron ore mining issue which were submitted to EPA by the July 11, 2017 comment period due date. Included are the following:
AISI Comments on the CERCLA 108b Hardrock Mining Proposed Rule AISI CERCLA 108b Hardrock Mining One Pager for June 20 2017 EPA Meeting Michigan DEQ Comments on CERCLA 108b Hardrock Mining Proposed Rule Minnesota DNR Comments on CERCLA 108b Hardrock Mining Proposed Rule Iron Mining Association Comments on CERCLA 108b Hardrock Mining Proposed Rule
I have also attached comments prepared by a coalition of industry groups, including AISI, which address more generally the CERCLA 108b Hardrock Mining proposed rule requirements.
We continue to believe that the CERCLA 108b hardrock mining requirements as laid out in the Dec 2016 proposal would be impossible for our industry to comply with if finalized as is. We also continue to believe that iron ore mining should have never been included among the high risk mining categories that will ultimately be subject to the final rule requirements. If we can answer any questions or aid in any way, please do not hesitate to let me know. Hope you are doing well.
Best regards,
Paul
Paul Balserak Vice President, Environment
American Iron and Steel Institute25 Massachusetts Ave. NW, Suite 800 Washington, DC 20001
I Ex. 6 (office) (mobile)
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Sierra Club v. EPA 18cv3472 NDCA
Tier 7
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