US Steel Corp - Tailings - Wastewater Permit

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Comment From: Amy Okaya

9/22/25 @ 11:51 PM

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Comment From: Maureen Johnson

9/22/25 @ 11:33 PM

Keetac tailings basin and mining area draft permits comments
Maureen Johnson
Stacy, MN

As a former MPCA Superfund project manager, I am encouraged by the inclusion of sulfate with a limit, but I continue to be disappointed in the MPCA's overall m...↓ining permit quality. When this mining area is done, the mine, sold several times over, will bankrupt and the soils and water cleanup and stabilization will be left to be financed by the people of Minnesota under the state superfund, while the companies walk away with decades of profitability based on local people's lives and jobs. Mines are not innocuous. They continue to discharge solutes from leftover chemicals or from exposed rock that previously was sealed away. Tailings basins are not stable --they need maintenance. Tailings basins do not drain water alone. They drain everything that was put in, all the chemicals from extraction, scrubber waste water, and solutes from the surface area of every "sand" grain of mined mineral or other rock that was not high enough quality to go out for steel making, including mercury, sulfate, nitrates from explosives, the separation and treatment chemicals. Many other unnamed chemicals can be found if the analyses include them. If they don't analyze a discharge for an input chemical, for sure it won't be found in the discharge!

Keetac has very few limits, most are "monitor only" which does not encourage a company to improve its discharges. Sulfate is one of the few I am scientifically pleased to see begin – but it should begin with the permit term beginning, not after 3 more years on top of the past decades.

Except for the few parameters with actual limits, these permits basically means that Keetac can do whatever it wants with many chemicals and mining effects on water at any time with no consequences.

Ground water flow and quality is ignored, against all reason for having ground water rules in the first place. The permits need sampling and physical measurements to assure ground water is not contaminated for downflow users.

Salts and ionic conditions expressed by specific conductance can be fatal to local fauna, just as sulfate can be fatal to wild rice. Keetac should be required to meet the MPCA's already determined local natural water concentrations and conditions after the allowed amount of dilution time/volume for each discharge to state waters, from the mining/plant area and from the tailings basin. Permit needs to mention the state waters and their current conditions affected by the discharges.

This permit's WET requirements ignore fact that mining companies change recipes for extraction and technologies over time. Mining companies often change their operations formulae to fit the ore components, for efficiency, for more profitability, to test new chemical options, various reasons. Although in some mining files, I have seen reporting of the changes, I have not seen MPCA analysis or followup questions as to effects on discharge concentrations -- just a standard form approval of the change.
What WET results are negative in the past may be positive for toxicity in a few weeks if the discharge changes significantly. Testing should always be quarterly, not yearly, to accommodate seasonal changes in tolerance to discharges.

"This permit does not include a chronic WET limit...shall begin chronic toxicity testing quarterly during year three of the permit. " Why no limit? Our rules are provided to protect the quality of our waters. Permits must have ability to enforce protection. That is MPCA's job too, as unpleasant as it is.

I agree with Water Legacy's comments.
MPCA's draft Keetac permits would not require compliance with Minnesota's sulfate standards until April 30, 2030. From 2011 through 2016, MPCA already went through a planning, study, and testing process for Keetac sulfate reduction water quality treatment. There is no need to start over. The U.S. EPA, in September 2024, told MPCA that more delay for compliance with the wild rice sulfate standard would not be appropriate. The new owner of U.S. Steel, Nippon Steel, has promised $11 billion in capital upgrades in order to increase U.S. Steel profits to $1.7 billion per year. Keetac sulfate treatment should be included in those upgrades.

MPCA's draft Keetac permits do not include protection of groundwater which is required under state law. The permits have no groundwater monitoring locations and don't disclose how much polluted wastewater is seeping into groundwater, particularly from the tailings basin.

MPCA's draft Keetac permits don't adequately protect aquatic life. MPCA permits let Keetac wait three years before even starting to test if its discharge is toxic to aquatic life. No justification is given for this delay. The permits only require biological assessments "once every five years" with no date to start the testing. Since there is no testing, there are also no limits on pollution (salts and ions) that kill sensitive aquatic life.

MPCA's draft Keetac permits add mercury monitoring at discharge points, but don't require monitoring for mercury in surface water. Downstream waters are impaired for mercury in fish. Sulfate pollution increases mercury released from sediments to water and mercury bioaccumulation in the food chain.

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Comment From: Jesse Amo

9/22/25 @ 11:16 PM

Thank you for the opportunity to comment on the U.S. Steel Keetac Mine and Tailings Basin permits and U.S. Steel's application for a variance. I stand with the MPCA to protect and improve the environment and human health by protecting our water from ...↓causing known health impacts from sulfate reactions and the toxic metals impacted.

1) U.S. Steel permits should require, at a MINIMUM, compliance with Minnesota's wild rice sulfate standard of 10 parts per million (mg/L) at both the Keetac Mine and Tailings Basin. I understand that draft permit limits of 14 mg/L monthly average and 24 mg/L daily maximum are based on this standard. This is a minimum protective standard that can only be speculatively effective with cumulative impact elements like sulfate/sulfide.

2) U.S. Steel should be denied a variance from compliance with the sulfate standard. There are no grounds for a variance that is not necessitated and would degrade the environment and human health.

3) I support MPCA's requirement that U.S. Steel monitor waste streams at both the Keetac Mine and Tailings Basin for sulfate and other pollutants, further that the burden would be on U.S. Steel to fund the assessment and remediation of pollutant impacts on flora and fauna.

The permits should be strengthened in the following ways:

1) U.S. Steel needs to meet the sulfate standard now. Sulfate limits were set over a decade ago for this permit and are a minimum requirement. MPCA should demand full compliance with sulfate limits as swiftly as can be accomplished under real world conditions when all of U.S. Steel resources are allocated to do so. Nippon Steel must allocate budget and priority to meeting the sulfate standard including remediation and monitoring.

2) MPCA should revise the Keetac permits to require a sufficient number of groundwater monitoring wells to effectively monitor all groundwater potentially impacted by this site.

3) MPCA should require U.S. Steel to test wastewater discharge preemptively for all sulfate/sulfide related impacts to both water quality and flora/fauna. Assessments of both chemical parameters and impacts to aquatic life (flora/fauna) should be required following BMPs and financed by U.S. Steel. These assessments should extend to contiguous surface waters sufficient to monitor all site impacts.
I appreciate the MPCA holding U.S. Steel accountable to protective permit standards at Keetac Mine and Tailings Basin. I ask that MPCA revise the draft permits immediately and to better protect water and all aquatic life that have immediate impacts to human health.

Thank you,
Jesse Amo

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Comment From: Leech Lake Band of Ojibwe (Craig Tangren)

9/22/25 @ 10:50 PM

Please find attached the Leech Lake Band of Ojibwe's comments on the draft NPDES permits for the Keetac mine and tailings basin (Permits MN0031879 and MN0055948) and preliminary determination to deny variance.

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Comment From: Laurentian Chamber of Commerce (Teresa Appelwick)

9/22/25 @ 10:47 PM

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Comment From: Teresa Simetkosky

9/22/25 @ 9:59 PM

I am writing to provide comments regarding public notice of draft NPDES permits MN0055948 and MN0031879 for the U. S. Steel Keetac tailings basin and mining area, respectively. I have interest in these draft permits because I, like most Minnesotans, ...↓care deeply about protecting the environment.

I am concerned about the Minnesota Pollution Control Agency's (MPCA) sulfate water quality standard of 10 mg/L for wild rice waters and its consequences to the Iron Range and communities across the state. MPCA was directed to review and update the wild rice sulfate standard in 2011 but has not done so to date. The future of Minnesota mines, local governments and other industries are critically affected by the enforcement of this outdated standard.

I strongly urge MPCA to update the wild rice sulfate standard considering current science and site-specific variables. The current 10 mg/L sulfate standard oversimplifies the environmental needs of wild rice. Many other factors determine wild rice resilience, such as water depth and fluctuation, predation, and competing vegetation. Wild rice has even proven to be successful in waters with sulfate levels up to 1,600 mg/L and beyond – 160 times higher than our current standard. The current 10 mg/L standard is not proven to be effective and compliance with it is unattainable for many businesses and communities. From wastewater facilities and small businesses to mines employing thousands of Minnesotans, the cost of meeting a 10 mg/L sulfate standard puts Minnesota at risk with no guaranteed outcome. Do not waste time, money and energy on a sulfate standard that doesn't make sense. I strongly urge you to refrain from including permit limits for sulfate until the time and resources are invested to develop a sulfate standard that follows modern science, addresses site-specific variables and contains cost as required by the 2011 law.

Beyond environmental science, this issue carries significant economic implications for our region and the State of Minnesota. Mining is a cornerstone of Northeast Minnesota's economy, contributing over $1.8 billion annually and supporting more than 4,000 family-sustaining jobs. These positions offer wages significantly above the regional average, with mining workers earning approximately $1,708 per week, nearly $950 more than the average across all industries. The sector also accounted for over one-third of net new jobs in the region during recent growth periods.

The current Keetac compliance schedule is too short and unattainable. There are currently no commercially proven and economical sulfate treatment strategies in place anywhere in the world. Time is needed to evaluate and develop treatment alternatives that are effective and achievable. Since these are some of the first permits to contain the 10 mg/L sulfate limit, other permittees will use the testing and engineering developed for compliance as a model in the future. Current treatment technologies to reduce sulfate levels result in increased solid waste that will be required to be landfilled, increased electrical usage, increased greenhouse gas emissions, and other negative environmental outcomes. Time and careful consideration are needed to develop feasible sulfate treatment that all Minnesotans can benefit from. The MPCA should allow a longer compliance schedule, or grant the variance, to provide more time to effectively find a feasible solution. The current compliance schedule does not include time for regulatory agency requirements such as environmental review, permitting and other authorizations that may be required.

The two draft permits require wild rice sulfate compliance at each of Keetac's outfalls, yet they all discharge to one water body where the MPCA has said the wild rice standard applies. The compliance point should protect that water body and be representative of the combined discharges from the Keetac facility. The permittee requested to combine sulfate compliance points to factually represent offsite discharges, however the MPCA denied that request. It is concerning that the MPCA will not consider the request, even though it is more factually accurate than what is contained in the draft permits. MPCA must modify the permits to include a single downstream compliance point as proposed by the permittee.

U. S. Steel has submitted two site-specific standard (SSS) requests for sulfate at Hay Lake near Keetac. The 2014 request was never acted upon by MPCA and the 2022 request was denied. These applications followed MPCA guidance and show that a higher sulfate standard than 10 mg/L is warranted. It is concerning that the MPCA does not take into account modern science and site-specific conditions. I urge the MPCA to reconsider the SSS applications as Keetac has been discharging to Hay Lake for almost 60 years with healthy wild rice in existence.

In summary, I urge the MPCA:

To refrain from including sulfate limits in Keetac's permits. If the permit limits remain as proposed, the MPCA must modify the permits to contain a single sulfate compliance point and allow more time for compliance.
To abide by the 2011 law and update the 10 mg/L sulfate standard that the state of Minnesota has recognized as being incorrect.
Thank you.

Teresa Simetkosky
1028 1st St S
Virginia, MN

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Comment From: Aaron Kania

9/22/25 @ 9:43 PM

As a person who lives downstream from the Minntac tailings basin, I am interested in the results of this process as the decision may have ramifications for the future of the watershed where I fish and gather wild rice, but also on the economic well b...↓eing of the communities on the Iron Range and beyond.

During the comment period the MPCA was asked to be brave. This was in the context of ignoring the law and granting the variance permit. The MPCA explained that the sulphate standard in wild rice waters is a uniquely Minnesota standard that the state has implemented. This has been upheld by the Minnesota courts and affirmed by the US EPA. To grant the variance would be arbitrary on the part of the MPCA and would therefore open the state up to a valid point of law for litigants. It is unfortunate that the MPCA will need to be brave when they are following the rules as set forth by the legislature, executive and courts.

In the economic analysis it would be beneficial for the MPCA to more clearly articulate the impacts of the mitigations. There were several comments that were related to the effects of the electricity needed to be successful with a reverse osmosis system. This system would also create a brine slurry that would need to be safely disposed of as well. Through this analysis the MPCA could articulate the number of jobs that would be created in the local area. It would seem that these jobs would be necessary to manage the tailings basins wastewater systems, electrical service needs, and also manage the reverse osmosis plant.

Further, there were mentions of other possibilities such as bacterial systems that can remove the sulphur from water sources. This was not fully analyzed as an alternative.

Lastly US Steel had offered some other modifications in design that may streamline removal and mitigations. This entailed going from four discharge points to one discharge point. This may be a viable cost savings opportunity. The MPCA and US Steel should work closely together to find reasonable solutions under the current regulatory framework.

The ultimate goal of these regulations is to ensure that wild rice waters remain viable into the future and provide the quality and quantity of rice we have historically relied upon. This may take creative solutions to ensure that we can be proud of both our environmental legacy and the economy our communities hold dear.

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Comment From: Northeastern Minnesota School ... (Paul Peltier)

9/22/25 @ 9:22 PM

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Comment From: Iron Range Mayors (Paul Peltier)

9/22/25 @ 9:19 PM

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Comment From: Cleveland-Cliffs (Jason Aagenes)

9/22/25 @ 8:51 PM

Please find attached comments on behalf of Cleveland-Cliffs.

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Comment From: St. Louis County (Michael Jugovich)

9/22/25 @ 8:38 PM

Please see attached letter.

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Comment From: Dan Hadrava

9/22/25 @ 6:47 PM

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Comment From: Connie Lehr

9/22/25 @ 6:43 PM

This permit should not be given. The state of MN agencies have ignored the the noncompliance of iron mining for decades and this is the result.
Married to a geologist in MN for 45 years and they see through your acceptance of unregulated mining and b...↓

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Comment From: Lisa Ciorlieri

9/22/25 @ 6:34 PM

I was in Virginia for your public meeting September 3. (MCPA knows how to conduct a public hearing.) Full compliance with the sulfate standard was required by 2019. No treatment plant was ever built. In 2024 the EPA found that between Sept 2019 a...↓

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Comment From: CURE (Hudson Kingston)

9/22/25 @ 6:32 PM

Please see attached.

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Comment From: Leanna Goose Rise and Repair A... (Leanna Goose)

9/22/25 @ 6:20 PM

Submitting a letter signed on by Organizations within Minnesota and Individual citizens with 469 signatures. Submitting multiple research articles on wild rice, sulfate, and methylmercury. Submitting the Tribal Task Force on Wild Rice Report. Submitt...↓

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Comment From: MiningMinnesota (Julie Lucas)

9/22/25 @ 5:37 PM

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Comment From: Iron Range Resources and Rehab... (Ida Rukavina )

9/22/25 @ 5:32 PM

Attached please reference Iron Range Resources & Rehabilitation's public comments and corresponding attachments as it relates to U.S. Steel Corp. NPDES/SDS Permit for Keetac Mining Area (MN0031879), U.S. Steel Corp. NPDES/SDS Permit for Keetac Tailin...↓

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Comment From: Pete Stauber

9/22/25 @ 5:29 PM

Comments from Rep. Pete Stauber (MN-08)

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Comment From: Northeastern Minnesotans for W... (Matt Norton)

9/22/25 @ 4:58 PM

Please use this copy of NMW's comments on the USS-Keetac NPDES/SDS permits and MPCA's preliminary determination to deny USS' application for a variance from sulfate standard to protect wild rice. The file uploaded earlier was not the final version o...↓

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Comment From: Northeastern Minnesotans for W... (Matt Norton)

9/22/25 @ 4:34 PM

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Comment From: ERIC MORRISON

9/22/25 @ 4:31 PM

MPCA's draft Keetac permits does not require compliance with Minnesota's sulfate standards until April 30, 2030 but what is required is an accelerated program of compliance to meet this standard AT A MINIMUM. This is because sulfate's threshold for i...↓

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Comment From: Pete Hyduke

9/22/25 @ 4:13 PM

Commissioner Katrina Kessler
Minnesota Pollution Control Agency
520 Lafayette Road North
St. Paul, MN 55155

RE: Comments on Draft Wastewater Permits and Preliminary Denial of Sulfate Variance Request for U.S. Steel Keetac Facility

Dear Commissioner...↓

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Comment From: WaterLegacy (Paula Maccabee)

9/22/25 @ 3:55 PM

The attached Comments and Exhibits 1-36 are respectfully submitted on behalf of WaterLegacy.

Sincerely yours,
Paula G. Maccabee, WaterLegacy Executive Director and Counsel

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Comment From: Kristen Blann

9/22/25 @ 3:46 PM

As an ecologist and a rice harvester, I support the denial of a waiver. It is my understanding that MPCA has made the right decision here, and US Steel has not shown that it would face financial hardship in complying with state water quality protect...↓

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Comment From: U. S. Steel Corporation - Minn... (Eric Williams)

9/22/25 @ 3:44 PM

Please find attached comments regarding Permit MN0055948 and preliminary variance denial.

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Comment From: Iron Ore Alliance (Mike Bakk)

9/22/25 @ 3:42 PM

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Comment From: Rebecca and Jim Myerly

9/22/25 @ 3:14 PM

RE: U.S. Steel Keetac Mine and Tailings Basin Permits (MN0031879 and MN0055948) and Application for Variance

Dear Minnesota Pollution Control Agency Staff,

Having lived on the St Croix River for a decade and previously on a lake for over three deca...↓

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Comment From: Minnesota Power (Kurt Anderson)

9/22/25 @ 3:14 PM

Please see our attached comment letter.

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Comment From: Tracey Dagen

9/22/25 @ 2:47 PM

Save Wild Rice !! No more permits !!!
Being a life long wild ricer, we must protect our water !! No more permits !!!

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Comment From: Wildflower grp (johnny barber)

9/22/25 @ 1:48 PM

Numerous comments were made by industry reps regarding the health of wild rice in Hay Lake on Sept 3rd, 2025 at the MPCA public hearing in Virginia. Words like "abundant", "growing like crazy", and "healthy and beautiful." We went to Hay Lake to see ...↓

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Comment From: Minnesota Center for Environme... (Ashlynn Kendzior)

9/22/25 @ 12:47 PM

Please see the attached comment and exhibits.

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Comment From: Minnesota Discovery Center (Char Conger)

9/22/25 @ 12:36 PM

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Comment From: Benjamin Erickson

9/22/25 @ 11:20 AM

As a miner and lover of our beautiful Minnesota environment, I'd like to say the sulfide standard is over the top and economically crushing. The lands of the Iron Range are uniquely beautiful from the mining of the past. Yet with the standards of the...↓

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Comment From: Elijah olson

9/22/25 @ 10:38 AM

Clean water is so important for the iron range. And especially for the wild rice and wildlife/eco systems. Please don't let huge companies strip the land while polluting the water!

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Comment From: Amy Brallier

9/22/25 @ 9:50 AM

Please enforce limits on Keetac and protect our waters and wetlands. The damage cannot be contained once it happens.

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Comment From: Amanda Nygard

9/22/25 @ 8:57 AM

My name is Amanda Nygard and I am writing from the Cuyuna range.
The waste from industrial mining is threatening the wild rice patties and the water quality in your area. Please make decisions that are based on the idea that there is a future. Don't...↓

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Comment From: Jena Mertz, Owner of Giant (Jena Mertz)

9/22/25 @ 8:41 AM

I am writing as a Duluth business owner who works closely with the mining industry and its supply chains. My business, like many others in our region, work closely with Minnesota's mines and the thousands of jobs they support. Because of this, I have...↓ a vested interest in the outcome of the draft NPDES permits MN0055948 and MN0031879 for U.S. Steel Keetac.

While I, like most Minnesotans, care deeply about protecting our environment, I am concerned about the Minnesota Pollution Control Agency's (MPCA) sulfate water quality standard of 10 mg/L for wild rice waters and its consequences for the Iron Range, Duluth, and communities across the state. MPCA was directed in 2011 to review and update this standard but has not done so. In the meantime, the outdated 10 mg/L standard places enormous strain on industries, local governments, and businesses like mine that depend on a reliable mining economy.

The 10 mg/L sulfate standard does not reflect modern science. Wild rice health depends on many factors—water depth, fluctuations, predation, and competing vegetation—not simply sulfate levels. In fact, wild rice has been documented thriving in waters with sulfate concentrations up to 1,600 mg/L and beyond. A standard that ignores these realities is unworkable and sets businesses and communities up for failure. Compliance with this limit is not only unattainable but also comes at great economic cost with no guarantee of protecting wild rice.

The compliance schedule in the draft Keetac permits is far too short. No commercially proven, cost-effective sulfate treatment technologies exist today. Rushing compliance risks forcing untested methods that create more problems—such as increased waste needing disposal, higher energy use, and greater greenhouse gas emissions. A longer schedule, or a variance, is necessary to allow time for research, regulatory review, and development of real solutions that both protect the environment and sustain Minnesota jobs.

The permits require sulfate compliance at every Keetac outfall, even though they all discharge to the same water body. A single downstream compliance point would both protect wild rice and reflect the true nature of the discharge. Denying Keetac's request to combine compliance points ignores the facts on the ground and creates unnecessary burdens.

U.S. Steel has submitted site-specific standard (SSS) requests for Hay Lake, following MPCA's own guidance, yet these were dismissed or left unacted upon. Keetac has discharged into Hay Lake for nearly 60 years, during which wild rice has continued to grow. Ignoring this evidence undermines the credibility of the permitting process and disregards the reality of site conditions.

As a business owner whose employees and customers are connected on a strong mining industry and supply chain, I urge the MPCA to:

Refrain from including sulfate limits in Keetac's permits until a modern, science-based standard is established.

If sulfate limits remain, modify the permits to use a single downstream compliance point and extend the compliance schedule to a realistic timeframe.

Abide by the 2011 law and update the sulfate standard using sound science and site-specific data.

The decisions made in these permits will not only impact Keetac, but also ripple across Duluth, the Iron Range, and Minnesota's entire economy. Please give this issue the thoughtful consideration it deserves.

Jena Mertz, Owner of Giant

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Comment From: Jeff LeDoux

9/22/25 @ 7:02 AM

I disagree with the 10 Mg/L standard and encourage a new scientific study because wild rice grows in levels much higher. There is large crops of rice in that watershed. Change the standard

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Comment From: Multiple Senders

9/22/25 @ 12:00 AM

Email comments from multiple senders received 9/22/25 - variance.

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Comment From: Multiple Senders

9/22/25 @ 12:00 AM

Email comments from multiple senders received 9/22/25.

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Comment From: Multiple Senders

9/22/25 @ 12:00 AM

Email comments from multiple senders received 9/22/25.

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Comment From: WaterLegacy (Multiple Senders)

9/22/25 @ 12:00 AM

442 comments received from WaterLegacy supporters between 8/13/25 - 9/22/25 - File 1 of 11

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Comment From: WaterLegacy (Multiple Senders)

9/22/25 @ 12:00 AM

442 comments received from WaterLegacy supporters between 8/13/25 - 9/22/25 - File 2 of 11

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Comment From: WaterLegacy (Multiple Senders)

9/22/25 @ 12:00 AM

442 comments received from WaterLegacy supporters between 8/13/25 - 9/22/25 - File 3 of 11

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Comment From: WaterLegacy (Multiple Senders)

9/22/25 @ 12:00 AM

442 comments received from WaterLegacy supporters between 8/13/25 - 9/22/25 - File 4 of 11

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Comment From: WaterLegacy (Multiple Senders)

9/22/25 @ 12:00 AM

442 comments received from WaterLegacy supporters between 8/13/25 - 9/22/25 - File 5 of 11

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Comment From: Multiple Senders

9/22/25 @ 12:00 AM

442 comments received from WaterLegacy supporters between 8/13/25 - 9/22/25 - File 6 of 11

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Comment From: WaterLegacy (Multiple Senders)

9/22/25 @ 12:00 AM

442 comments received from WaterLegacy supporters between 8/13/25 - 9/22/25 - File 7 of 11

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Comment From: WaterLegacy (Multiple Senders)

9/22/25 @ 12:00 AM

442 comments received from WaterLegacy supporters between 8/13/25 - 9/22/25 - File 8 of 11

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Comment From: WaterLegacy (Multiple Senders)

9/22/25 @ 12:00 AM

442 comments received from WaterLegacy supporters between 8/13/25 - 9/22/25 - File 9 of 11

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Comment From: WaterLegacy (Multiple Senders)

9/22/25 @ 12:00 AM

442 comments received from WaterLegacy supporters between 8/13/25 - 9/22/25 - File 10 of 11

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Comment From: WaterLegacy (Multiple Senders)

9/22/25 @ 12:00 AM

442 comments received from WaterLegacy supporters between 8/13/25 - 9/22/25 - File 11 of 11

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Comment From: WaterLegacy (Multiple Senders)

9/22/25 @ 12:00 AM

442 comments received from WaterLegacy supporters between 8/13/25 - 9/22/25 - File 6 of 11

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Comment From: Austin Siekkinen

9/21/25 @ 10:00 PM

MPCA should read what levels are suggested by the EPA on drinking water levels than what they're suggesting. MPCA should also consider testing this is a real world application and not a test tube, that's how you determine real science.

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Comment From: Terry Grosshauser

9/21/25 @ 8:08 PM

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Comment From: David Herring

9/21/25 @ 8:03 PM

I would hope you would seriously reconsider your sulfate standard for waste water. If drinking water has a much higher sulfate standard than wild rice, something doesn't seem right. Being the only state in the country with a sulfate standard seems ...↓

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Comment From: Blake Kolquist

9/21/25 @ 7:18 PM

Setting an unrealistic sulfate level to which bottled water doesn't pass the mustard speaks volumes to how insane this is. I've worked for almost 20 years in both mining and more recently in municipal water/wastewater. A "One size fits all" standard ...↓

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Comment From: David Toole

9/21/25 @ 6:38 PM

I'm a second generation miner. My daughter is a third generation miner who just started at Minntac in March. The standard that is being proposed would shut the mines and lots of waste water treatment plants down. That means no one would be around the...↓

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Comment From: Jason Jukich

9/21/25 @ 4:19 PM

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Comment From: Mike Galli

9/21/25 @ 3:59 PM

I normally don't do this type of thing, but this is very important to the range. I feel I'm being lied again by the state of Minnesota. As a duck hunter, I know that wild rice crops are different from year to year. It has more to do with water lev...↓

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Comment From: John Taray

9/21/25 @ 3:51 PM

The 10 mg/l is not realistic for the wild rice standard because wild rice can survive with levels of 1600 mg/l. The National standard is 250 mg/l and most bottle water has levels of 55 mg/l or higher.
Please give Kee Tac their permits to allow good p...↓

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Comment From: William Copeland

9/21/25 @ 3:43 PM

These mines support our community's, livelihoods, schools, family's etc... Please stop this senseless attack on our region.

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Comment From: Skull Joseph

9/21/25 @ 3:21 PM

Please consider a real review with updated science. This will effect the iron range for generations to co e.

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Comment From: Joe Koski

9/21/25 @ 3:03 PM

As a 4th Generation Miner we need these permits to sustain our industry and way of life here in Northern Minnesota. I personally am laid off From Cliffs Minorca Mine after 18 years of service and this will effect every mine on the Iron Range. Our w...↓

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Comment From: Multiple Senders

9/21/25 @ 12:00 AM

Email comments from multiple senders received 9/21/25 - Variance.

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Comment From: Multiple Senders

9/21/25 @ 12:00 AM

Email comments from multiple senders received 9/21/25.

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Comment From: Dennis Greben

9/20/25 @ 11:48 AM

Dear Sir, I am a 37 year pharmacist with Essential Health. I know first hand the difference in old information from new information. The sulfate standards proposed are very old information. The human ingestion limits for sulfates are very much higher...↓

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Comment From: George Pliml

9/20/25 @ 9:40 AM

For many years I worked in the industrial construction business and was always excited when a new or addition to an existing project was announced. It seemed like clockwork that the proponents of the project would always say that we should build it a...↓

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Comment From: Multiple Senders

9/20/25 @ 12:00 AM

Email comments from multiple senders received 9/20/25 - Variance.

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Comment From: Multiple Senders

9/20/25 @ 12:00 AM

Email comments from multiple senders received 9/20/25.

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Comment From: MICHAEL BAKK

9/19/25 @ 2:55 PM

My name is Mike Bakk and I live in Mountain Iron with my two teenage sons. I was born and raised in northeastern Minnesota and I'm proud to be an Iron Ranger. I am the senior director of mining operations at U. S. Steel. I am also the co-chair of ...↓the Iron Ore Alliance, a joint initiative between the United Steelworkers and U. S. Steel. Prior to this, I was the director of operational readiness at U. S. Steel's Keetac facility in Keewatin, where I worked on the DR-grade pellet project. The infusion of $150M into Keetac breathed new life into the facility and lets us be at the front end of the electric steelmaking process. With over 25 years in the mining industry, I have seen firsthand how poorly informed regulations impact not only the sustainability of our businesses but the livelihood of the people and communities that rely on them.
I am writing today regarding the draft NPDES permits for the Keetac tailings basin and mining area. My concern lies with the MPCA's proposal to enforce the current 10 mg/L sulfate standard – a scientifically outdated and short-sighted rule that threatens jobs and communities across Northern Minnesota.
I know the human impact that this enforcement would have all too well. During a past downturn at Keetac, I was in the difficult position of laying off workers. One employee stopped in my office on his way out the door to thank me for hiring him – just hours short of completing his probationary period. Another longtime worker reminded me, "When these places shut down, you never know if they'll open again." These moments stay with me because they underscore the real and lasting consequences of well-meaning requirements.
Keetac has weathered ups and downs since 2008, driven largely by supply and demand in a global market. Adding an expensive and ineffective sulfate treatment requirement would cripple our global competitiveness. I'm a firm believer in preserving our environment. But the 10mg/L standard does not achieve its intended purpose. Modern science shows that wild rice survival depends on a variety of site-specific factors including water depth and fluctuations, predation, competing vegetation, carbon and iron content, and others. In fact, wild rice has been proven to thrive in waters with sulfate concentrations far above the existing limit, even as high as 1,600 mg/L. In Hay Lake, directly downstream from Keetac, the wild rice crop is healthy.
I, along with my colleagues in the mining industry, value environmental stewardship and want to protect the Iron Range's beauty and natural resources. Many of us spend our free time enjoying outdoor activities like fishing, hunting, camping, golfing and canoeing. I don't want to pollute the very waters I enjoy so much with my family. Enforcing this standard would be an ineffective means of protecting those waters. Not only is the science outdated, it is also financially unattainable for many businesses and communities, and puts Minnesotans at risk without any guaranteed environmental benefit.
I urge the MPCA to refrain from including sulfate limits in Keetac's permits until a modern, science-based standard is adopted – one that reflects what we know today, not what we thought we knew in 1973.
The economic implications of enforcing the current standard simply cannot be ignored. Mining is a cornerstone of Northeast Minnesota's economy, contributing over $1.8 billion annually and supporting more than 4,000 family-sustaining jobs. These positions offer wages significantly above the regional average, with mining workers earning approximately $1,708 per week, nearly $950 more than the average across all industries. To jeopardize this economic powerhouse with an arbitrary and unworkable standard is to put the prosperity of the Iron Range – and thousands of Minnesotans – at risk.
I applaud the MPCA's commitment to protecting our environment and preserving the Iron Range. But Minnesotans deserve environmental standards that are grounded in science, effective in practice and fair to the communities they impact. The current sulfate rule fails on all these counts.
Thank you for your consideration.

Mike Bakk
Mt. Iron, MN

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Comment From: United Steelworkers (USW) (David McCall)

9/19/25 @ 10:28 AM

Please the attached comments.

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Comment From: Paul Deaner

9/19/25 @ 6:04 AM

I'm opposed to Keetac's request to increase the sulfate water quality standard for waters used for the production of wild rice.

I believe they can afford installing controls to achieve the current legal standard.

I'm stunned how long the current st...↓

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Comment From: Multiple Senders

9/19/25 @ 12:00 AM

Email comments from multiple senders received 9/19/25 - Variance.

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Comment From: Multiple Senders

9/19/25 @ 12:00 AM

Email comments from multiple senders received 9/19/25.

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Comment From: Regina Brant

9/18/25 @ 3:04 PM

I am writing to provide comments regarding public notice of draft NPDES permits MN0055948 and MN0031879 for the U. S. Steel Keetac tailings basin and mining area, respectively. I have interest in these draft permits because I, like most Minnesotans, ...↓care deeply about protecting the environment.
I am concerned about the Minnesota Pollution Control Agency's (MPCA) sulfate water quality standard of 10 mg/L for wild rice waters and its consequences to the Iron Range and communities across the state. MPCA was directed to review and update the wild rice sulfate standard in 2011 but has not done so to date. The future of Minnesota mines, local governments and other industries are critically affected by the enforcement of this outdated standard.
I strongly urge MPCA to update the wild rice sulfate standard considering current science and site-specific variables. The current 10 mg/L sulfate standard oversimplifies the environmental needs of wild rice. Many other factors determine wild rice resilience, such as water depth and fluctuation, predation, and competing vegetation. Wild rice has even proven to be successful in waters with sulfate levels up to 1,600 mg/L and beyond – 160 times higher than our current standard. The current 10 mg/L standard is not proven to be effective and compliance with it is unattainable for many businesses and communities. From wastewater facilities and small businesses to mines employing thousands of Minnesotans, the cost of meeting a 10 mg/L sulfate standard puts Minnesota at risk with no guaranteed outcome. Do not waste time, money and energy on a sulfate standard that doesn't make sense. I strongly urge you to refrain from including permit limits for sulfate until the time and resources are invested to develop a sulfate standard that follows modern science, addresses site-specific variables and contains cost as required by the 2011 law.
Beyond environmental science, this issue carries significant economic implications for our region and the State of Minnesota. Mining is a cornerstone of Northeast Minnesota's economy, contributing over $1.8 billion annually and supporting more than 4,000 family-sustaining jobs. These positions offer wages significantly above the regional average, with mining workers earning approximately $1,708 per week, nearly $950 more than the average across all industries. The sector also accounted for over one-third of net new jobs in the region during recent growth periods.
The current Keetac compliance schedule is too short and unattainable. There are currently no commercially proven and economical sulfate treatment strategies in place anywhere in the world. Time is needed to evaluate and develop treatment alternatives that are effective and achievable. Since these are some of the first permits to contain the 10 mg/L sulfate limit, other permittees will use the testing and engineering developed for compliance as a model in the future. Current treatment technologies to reduce sulfate levels result in increased solid waste that will be required to be landfilled, increased electrical usage, increased greenhouse gas emissions, and other negative environmental outcomes. Time and careful consideration are needed to develop feasible sulfate treatment that all Minnesotans can benefit from. The MPCA should allow a longer compliance schedule, or grant the variance, to provide more time to effectively find a feasible solution. The current compliance schedule does not include time for regulatory agency requirements such as environmental review, permitting and other authorizations that may be required.
The two draft permits require wild rice sulfate compliance at each of Keetac's outfalls, yet they all discharge to one water body where the MPCA has said the wild rice standard applies. The compliance point should protect that water body and be representative of the combined discharges from the Keetac facility. The permittee requested to combine sulfate compliance points to factually represent offsite discharges, however the MPCA denied that request. It is concerning that the MPCA will not consider the request, even though it is more factually accurate than what is contained in the draft permits. MPCA must modify the permits to include a single downstream compliance point as proposed by the permittee.
U. S. Steel has submitted two site-specific standard (SSS) requests for sulfate at Hay Lake near Keetac. The 2014 request was never acted upon by MPCA and the 2022 request was denied. These applications followed MPCA guidance and show that a higher sulfate standard than 10 mg/L is warranted. It is concerning that the MPCA does not take into account modern science and site-specific conditions. I urge the MPCA to reconsider the SSS applications as Keetac has been discharging to Hay Lake for almost 60 years with healthy wild rice in existence.
In summary, I urge the MPCA:
• To refrain from including sulfate limits in Keetac's permits. If the permit limits remain as proposed, the MPCA must modify the permits to contain a single sulfate compliance point and allow more time for compliance.
• To abide by the 2011 law and update the 10 mg/L sulfate standard that the state of Minnesota has recognized as being incorrect.

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Comment From: John Engesser

9/18/25 @ 8:17 AM

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Comment From: Multiple Senders

9/18/25 @ 12:00 AM

Email comments submitted by multiple senders on 9/18/25.

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Comment From: JEREMY SMOLICH

9/17/25 @ 2:51 PM

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Comment From: Brian Hubbard

9/17/25 @ 12:00 AM

Email comment submitted 9/17/25

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Comment From: Multiple Senders

9/17/25 @ 12:00 AM

Email comments from multiple senders received 9/17/25 - Variance.

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Comment From: Minnesota Chamber of Commerce (Andrew Morley)

9/16/25 @ 10:07 AM

Please see attached PDF.

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Comment From: Kevin Hakala

9/16/25 @ 12:00 AM

Email comment submitted 9/16/25

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Comment From: Kevin Hakala

9/16/25 @ 12:00 AM

Email comment submitted 9/16/25.

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Comment From: Multiple Senders

9/16/25 @ 12:00 AM

Email comments from multiple senders received 9/16/25 - Variance.

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Comment From: Jared Johnson

9/15/25 @ 2:22 PM

Need to protect MN mining
Enforcing this now, with economic headwinds, prioritizes speculative harms over proven benefits, especially since wild rice beds have persisted despite historical sulfate discharges.The Unfairness: Political Overreach Igno...↓ring Practical Realities. These regulations exemplify regulatory overreach, disproportionately targeting an industry that's already investing in cleaner technologies while providing minimal gains for wild rice. Tribes and environmental advocates rightly value wild rice for its cultural and ecological significance, but the standard's enforcement overlooks that many affected waters aren't prime rice habitats and that sulfate from mining is just one of multiple sources (including natural runoff and wastewater).

Sudden strict application after years of laxity smacks of inconsistency, punishing miners for a standard that was deemed unenforceable until recently.

Moreover, the link to mercury methylation—often cited by proponents—is indirect and site-dependent, not a justification for economy-crushing limits.

This isn't about denying environmental protection; it's about fairness. Why cripple a key industry when variances, monitoring, and targeted protections could suffice?A Path Forward: Innovative Solutions for BalanceRather than blanket enforcement, we should pursue affordable innovations like bioreactors, which use bacteria to reduce sulfates at a fraction of reverse-osmosis costs—potentially turning waste into sellable byproducts like iron sulfide.

Site-specific standards, as explored by the MPCA, could account for local conditions, allowing higher limits where risks are low.

Collaboration between industry, tribes, and regulators—fueled by state investment in research—can protect wild rice without sacrificing livelihoods. Examples from Sweden prove it's possible.In conclusion, the sulfate regulations are unfair because they rely on flawed science, impose ruinous costs, and ignore viable alternatives, all while threatening the Iron Range's future. By reforming them, we safeguard jobs, bolster national industry, and achieve true environmental stewardship. The choice is clear: don't let rigid rules destroy what built America—adapt them to sustain it

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Comment From: Dan Lippincott

9/15/25 @ 10:31 AM

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Comment From: Bob Peterson

9/15/25 @ 10:30 AM

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Comment From: John Andrican

9/15/25 @ 10:28 AM

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Comment From: Jeff Cullen

9/15/25 @ 10:24 AM

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Comment From: Multiple Senders

9/15/25 @ 12:00 AM

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Comment From: Sue Lyback

9/14/25 @ 10:49 AM

Please deny ANYTHING that can potentially harm our beloved freshwater in Minnesota. Water IS life and we cannot continue to risk harming this essential resource. Thank you.

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Comment From: Multiple Senders

9/14/25 @ 12:00 AM

Email comments from multiple senders received 9/14/25 - Variance.

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Comment From: Linda Koskiniemi

9/13/25 @ 11:38 AM

Please allow the variance for Keetac sulfate discharge into tailing pond until updated research can determine what an acceptable limit of sulfate is. There are other variables such as amount of predation by birds and level of water in the rice beds t...↓

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Comment From: Cindy Lustig

9/13/25 @ 8:35 AM

Please continue to deny the variance
and uphold the Standard that is in place.

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Comment From: Multiple Senders

9/13/25 @ 12:00 AM

Email comments from multiple senders received 9/13/25 - Variance.

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Comment From: Diane Flakne

9/12/25 @ 12:38 PM

I understand the need for mining, but the ecology has already been compromised for years. Along with scientific studies and conclusions thereof, I believe that, as stated by the Minnesota Pollution Control agency and the MPCA, United States Steel Cor...↓

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Comment From: Sandy Daniels-Milton

9/12/25 @ 12:00 AM

Email comment received 9/12/25 - variance.

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Comment From: Ryan Vesey

9/11/25 @ 10:52 AM

It is critical to approve the proposed site specific standards for the US Steel mine. The site specific standards provide water quality far exceeding the standard for drinking water and there isn't evidence that these standards would negatively impac...↓

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