Erin Rykken. Ross, Deb, and Dirk,

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Erin Rykken From: Sent: To: Cc: Subject: Attachments: Fay, (DNR) <> Monday, October 27, 2014 3:29 PM Ross Vellacott; Deb McGovern; Dirk Leemkuil Johnson, Bill H (DNR); Comardicea, Irina (DNR); Howard Levine; Jimenez, Michael -FS (mjimenez@fs.fed.us); mrye@fs.fed.us FW: PolyMet information on HRF residues RE: Follow-up on PolyMet information on HRF residues ; RCRA Memo.pdf; Hydromet Testing Memo.pdf Ross, Deb, and Dirk, DNR has received the response below from MPCA regarding that agency s review of the attached items submitted by PolyMet regarding the proposed NorthMet hydromet residue facility. Please use this information as appropriate in developing responses to comments received on the NorthMet SDEIS and in development of the FEIS. If you have questions, please let me know. Fay, EIS Project Manager From: Clark, Richard (MPCA) Sent: Friday, October 24, 2014 8:34 AM To: Fay, (DNR) Cc: Foss, Ann (MPCA); Robin, Jim (MPCA) Subject: RE: PolyMet information on HRF residues, 1

Thank you for forwarding Jennifer Saran s Sept. 12, 2014 email (attached) providing information on (a) whether elimination of the bulk hydrometallurgical mode from the project materially affect the chemical composition of the residue proposed to be stored in the HRF and (b) future monitoring of residue to be generated during pilot testing and/or Phase 2 of project operation. With that information, MPCA staff can make the following statements: MPCA Solid Waste staff reviewed the results of the 2005 and 2009 TCLP testing performed on pilot test residues (attached) and agreed that the results showed that the residues did not meet the thresholds to be regulated as a RCRA hazardous waste. In the Sept. 12, 2014 email PolyMet states that elimination of the bulk hydrometallurgical mode from the project does not materially affect the chemical composition of the residue proposed to be stored in the HRF and elimination of this mode will not result in any significant changes to residues produced, or result in any new residues produced. MPCA staff agree that this is a reasonable conclusion for the residue from the currently proposed project and that the 2005 and 2009 testing results would be representative of the residues that will be stored in the HRF if the current project is approved. MPCA staff also agree that any new residue produced during future hydrometallurgical pilot testing and/or Phase 2 of the project should be further tested at that time to verify that it indeed is similar to the residue tested in 2005 and 2009 and that it remains under the RCRA hazardous waste threshold. Please feel free to contact me with any questions. Richard 651 757 2280 From: Fay, (DNR) Sent: Thursday, October 23, 2014 1:09 PM To: Robin, Jim (MPCA); Clark, Richard (MPCA) Cc: Comardicea, Irina (DNR); Johnson, Bill H (DNR); Kunz, Michael (DNR); Jimenez, Michael -FS (mjimenez@fs.fed.us); Augustin, Ralph (ralph.j.augustin@usace.army.mil); Ross Vellacott; Howard Levine (Howard.Levine@erm.com) Subject: RE: PolyMet information on HRF residues Jim and Richard, I m forwarding to you a follow up email (attached) related to the HRF information submitted by PolyMet. During your review of the two documents forwarded to you on Monday, please also look at the attached email. Thanks, 2

Fay, EIS Project Manager From: Fay, (DNR) Sent: Monday, October 20, 2014 12:32 PM To: Robin, Jim (MPCA); Clark, Richard (MPCA) (richard.clark@state.mn.us) Cc: Comardicea, Irina (DNR); 'Johnson, Bill H (DNR)'; Kunz, Michael (DNR); Jimenez, Michael -FS (mjimenez@fs.fed.us); Augustin, Ralph (ralph.j.augustin@usace.army.mil); Ross Vellacott; Howard Levine (Howard.Levine@erm.com) Subject: FW: PolyMet information on HRF residues Hello Jim and Richard. Please find attached, two documents submitted by PolyMet describing analytical testing and associated results for pilot plant HRF residue samples. Please review the information submitted and let me know if MPCA concurs with the information, including the management approach proposed by PolyMet for this issue. If possible, would you let me know by the end of this week, or early next? Fay, EIS Project Manager From: Fay, (DNR) Sent: Wednesday, August 06, 2014 7:16 PM To: Kunz, Michael (DNR); Robin, Jim (MPCA); Carlson, Erik (MPCA); 'Liljegren, Michael W (DNR)'; mrye@fs.fed.us; 'Johnson, Bill H (DNR)'; Jimenez, Michael -FS (mjimenez@fs.fed.us); Augustin, Ralph (ralph.j.augustin@usace.army.mil); Ross Vellacott; Howard Levine (Howard.Levine@erm.com) Cc: Comardicea, Irina (DNR) Subject: PolyMet information on HRF residues All, 3

PolyMet has provided the attached documents describing the analytical testing and associated results for pilot plant HRF residue samples. At this time, the documents are being distributed to you for information purposes. During the project manager call on Monday, we will discuss our potential use of the information. If you have questions, please let me know. Fay, EIS Project Manager From: Jennifer Saran [mailto:jsaran@polymetmining.com] Sent: Tuesday, August 05, 2014 1:57 PM To: Fay, (DNR); Comardicea, Irina (DNR) Cc: PolyMet Environmental Subject: information on HRF residues Attached please find two documents describing the analytical testing and associated results for pilot plant HRF residue samples. Please let me know if you have any questions thanks! Jennifer Jennifer Saran Director of Environmental Permitting and Compliance Mobile: 651 600 5457 Office: 651 389 4108 Fax: 651 389 4101 jsaran@polymetmining.com www.polymetmining.com This message is intended for the sole use of the intended recipient. The message and any files transmitted with it may contain material that is confidential and/or legally privileged. Any review, reliance or distribution by others or forwarding without express permission is strictly prohibited. If you are not the intended recipient, please contact the sender and delete all copies. 4

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