The Non-Financial Ledger

Silver Bay, Minnesota sits on the western shore of Lake Superior. The lake is the largest freshwater lake on Earth by surface area. About 40 million people depend on the Great Lakes basin for drinking water. Northshore Mining has operated in that basin for decades, processing iron ore taconite in a region where the water is the entire economy, the entire identity, and for many communities, the entire future.

On July 31, 2023, a federal inspector walked into that facility and found containers of hazardous waste sitting without labels. Not hidden. Not buried. Just sitting there, unlabeled, in a central accumulation area, with no indication of what was inside them or when the clock had started ticking on safe disposal. Two separate containers did not say “Hazardous Waste.” Two separate containers had no start date for the accumulation period. Multiple smaller containers in the central accumulation area had never been evaluated for whether their contents were hazardous at all.

Those rules exist because someone, somewhere, has to handle those containers. A worker who does not know a drum holds hazardous material cannot protect themselves. A first responder arriving at a spill cannot make the right call without a label. The rules are not bureaucratic red tape. They are the difference between a worker going home or going to a hospital.

Then there were the oil spills. Two active releases of used oil were sitting on the ground, uncontained, unaddressed. Used oil from heavy mining equipment is laced with metal particulates, solvents, and combustion byproducts. It does not stay in one place. It migrates through soil and, in a facility near Lake Superior, the direction that contamination travels is not a mystery.

Thirteen containers of used oil had no “Used Oil” label. One container of fluorescent lamps, a large-quantity universal waste handler’s inventory, had no required labeling. These are not obscure technicalities. These are the basic minimum requirements that stand between industrial operations and environmental contamination of a shared public resource.

The penalty for all of this: $8,750. Divide that by seven violations and the price per documented federal or state environmental breach is $1,250. For a company operating under the umbrella of Cleveland Cliffs, which reported billions in revenue, that number does not register as a deterrent. It registers as a rounding error.

Legal Receipts

The following passages are quoted verbatim from the EPA’s Expedited Settlement Agreement and Final Order, Docket No. RCRA-05-2024-0020, signed September 9, 2024. Each quote is followed by a breakdown of what it confirms.

“On July 31, 2023, two (2) containers were not clearly marked with the date upon which the period of accumulation began, and Respondent had not obtained a permit or interim status.”

• This confirms that Northshore Mining was storing hazardous waste without the legal authorization to do so. The 90-day permit exemption that allows generators to accumulate waste without a full permit only applies if they follow specific labeling and tracking rules. By failing to date those containers, the company forfeited the exemption and was, in the eyes of the law, operating a hazardous waste storage facility without a permit.
• The absence of a start date is not trivial. It means regulators, workers, and emergency personnel had no way of knowing how long that waste had been sitting there or whether the 90-day legal limit had already been exceeded.

“On July 31, 2023, two (2) containers were not clearly marked with the words ‘Hazardous Waste’ and Respondent had not obtained a permit or interim status.”

• This is a second, independent permit violation triggered by the same containers. The company was cited separately for missing accumulation dates and missing “Hazardous Waste” labels. Both failures occurred simultaneously on the same containers, meaning the company’s hazardous waste labeling system had completely broken down at the point of inspection.
• Federal law requires the label because it triggers a chain of awareness: workers, handlers, transporters, and emergency responders all need that label to make safe decisions. Its absence is a worker safety failure, not just a paperwork failure.

“At the time of the inspection, Respondent had not made a determination whether the waste generated as expired liquid material in two containers and multiple smaller waste containers in central accumulation area were hazardous.”

• This is perhaps the most alarming finding in the document. Northshore Mining did not know, and had not attempted to determine, whether the expired liquids it was storing were hazardous. Federal law requires generators to make that determination. It is the first step in the entire hazardous waste management chain.
• Skipping this step means the company could have been improperly storing, handling, or disposing of hazardous material while treating it as ordinary waste. It also means no one was tracking it in regulatory reporting systems.

“At the time of the Inspection, Respondent had not submitted a biennial report for the year 2021. Respondent’s failure to submit biennial reports for the year 2021 violated Minn. R. 7045.0248, Subpart 1(B).”

• Large quantity generators of hazardous waste are required to submit a biennial report to the EPA every two years. This report documents what hazardous waste the facility produced, how much of it, and where it went. Northshore Mining skipped the 2021 report entirely.
• The biennial report is one of the primary mechanisms regulators use to track hazardous waste from cradle to grave. Missing it means that for the 2021 reporting cycle, there was effectively a regulatory blind spot over this facility’s hazardous waste output. The EPA had no verified accounting of what Northshore Mining generated or disposed of that year.

“On July 31, 2023, two (2) releases of used oil were observed and had not been managed properly.”

• This confirms that active spills were present and untreated at the time of inspection. Federal rules require a generator to stop, contain, clean up, and properly manage any used oil release upon detection. The fact that inspectors found them already in progress means the company had either not detected them or had detected them and done nothing.
• Used oil from industrial mining equipment can carry heavy metals, polycyclic aromatic hydrocarbons, and other toxics. Uncontained releases near Lake Superior represent a direct pathway to contamination of the most significant freshwater system in the world.

“Respondent: (1) admits that Respondent is subject to RCRA and its implementing regulations; (2) admits that EPA has jurisdiction over Respondent and Respondent’s conduct as alleged herein, (3) neither admits nor denies the factual allegations contained herein.”

• This is the standard liability shield built into expedited settlements. Northshore Mining paid $8,750 and accepted the penalty without ever having to go on record confirming that any of the violations actually occurred as described. This is a legal mechanism that allows companies to settle federal environmental violations without creating an admission that could be used against them in civil litigation by affected parties.
• The “neither admits nor denies” clause is a routine feature of EPA expedited settlements. Its routine nature does not make it less consequential. It means no one from the company was ever required to stand before a judge and confirm that used oil was left spilling on the ground near Lake Superior.

Societal Impact Mapping

Environmental Degradation

Northshore Mining operates within the Lake Superior watershed, one of the most ecologically critical freshwater systems on the continent. The documented violations point directly to risks of contamination that extend well beyond the facility fence line.

• Two active used oil releases were found uncontained at the time of inspection. Used oil from heavy industrial equipment contains known toxic compounds including polycyclic aromatic hydrocarbons (PAHs), lead, cadmium, and benzene. Uncontained releases on facility grounds near Lake Superior create a direct migration pathway for these compounds into soil and groundwater feeding the lake.
• The company’s failure to determine whether expired liquid materials in multiple containers were hazardous means those materials may have been managed, stored, or disposed of incorrectly. Misclassified hazardous waste handled as ordinary waste can enter waste streams, landfills, and water systems entirely outside of regulated hazardous disposal channels.
• The missing 2021 biennial hazardous waste report means that for one full reporting cycle, regulators had no verified accounting of what Northshore Mining generated, in what quantities, or where it went. Any improper disposal during that period would have been effectively invisible to oversight agencies.
• Thirteen unlabeled used oil containers and one unlabeled universal waste lamp container represent a systemic labeling failure, not isolated incidents. A pattern of labeling non-compliance suggests the hazardous materials management system at this facility was not functioning as designed, increasing the probability of improper handling across multiple waste streams.

Public Health

The workers inside this facility bear the most direct exposure risk from these violations. Unlabeled hazardous waste and active uncontained spills are conditions that increase the probability of occupational exposure to toxic materials without workers knowing what they are handling.

• Workers handling or moving containers that were not labeled “Hazardous Waste” had no way of knowing they required special precautions. Hazardous waste labeling requirements exist specifically to trigger protective behavior from anyone who comes into contact with the container. Without those labels, the human body is the last line of defense.
• The two active used oil spills left uncontained on the facility floor create an immediate slip-and-fall hazard and a dermal and inhalation exposure risk. Used oil contains carcinogenic compounds. Chronic low-level skin exposure to used oil has been linked to occupational skin cancer in industrial workers.
• Fluorescent lamp waste classified as universal waste contains mercury. The unlabeled lamp container found during inspection means that waste was not being properly tracked or segregated. Mercury vapor exposure from broken fluorescent lamps is a serious acute and chronic neurological hazard. Workers in proximity to unsegregated universal waste lamps face elevated exposure risk.
• Communities around Silver Bay that draw from Lake Superior-adjacent water sources face downstream risk from any contamination that migrated from the facility’s uncontained releases or improperly managed waste during the period of non-compliance.

Economic Inequality

The financial penalty structure of this settlement exposes a fundamental imbalance in how environmental enforcement operates when the violator is a subsidiary of a major industrial conglomerate.

• The $8,750 penalty amounts to a fraction of a fraction of one percent of Cleveland Cliffs’ annual revenue. For a company operating at industrial scale, this settlement functions as an operating cost, not a deterrent. There is no financial mechanism in this outcome that incentivizes better compliance.
• The communities nearest to industrial facilities of this type are statistically more likely to be working-class and have fewer resources to pursue independent legal remedies. Silver Bay is a small, post-industrial Minnesota city. Its residents do not have the legal or financial infrastructure to supplement federal enforcement when that enforcement settles at $8,750.
• Workers at the facility who were exposed to the conditions documented in the inspection have no direct remedy under this settlement. The EPA’s expedited settlement resolves only federal civil penalties. It does not compensate workers, fund medical monitoring, or require the company to inform affected employees of their potential exposures.
• The “neither admits nor denies” structure of the settlement contractually limits the document’s usefulness in any future civil litigation. If a worker or community member later sought damages related to these violations, Northshore Mining’s settlement agreement could not be used as an admission of the underlying facts. The $8,750 bought that protection too.

The Cost of a Life Metric

What Now?

The people responsible for this settlement and the facility operations are documented in the agreement. The accountability pathway runs through regulators, public pressure, and organized community response.

Key Signatories on Record

• Shane Holman, General Manager, signed the settlement on behalf of Northshore Mining Company on August 5, 2024, certifying that all violations had been corrected.
• Michael D. Harris, Division Director, Enforcement and Compliance Assurance Division, EPA Region 5, approved the settlement on behalf of the EPA on September 9, 2024.
• Ann L. Coyle, Regional Judicial Officer, EPA Region 5, signed the Final Order on September 9, 2024.
• The Respondent’s settlement contact email was routed through Andrea.Hayden@clevelandcliffs.com, confirming the corporate parent relationship between Northshore Mining and Cleveland Cliffs.

Watchlist: Regulatory Bodies With Jurisdiction

• EPA Region 5: The federal office that handled this case. Region 5 covers Minnesota, Illinois, Indiana, Michigan, Ohio, and Wisconsin. EPA reserves the right to pursue future violations. Public comments on EPA enforcement priorities can be submitted through the regional office at r5lecab@epa.gov.
• Minnesota Pollution Control Agency (MPCA): The state agency responsible for enforcing Minnesota hazardous waste rules (Minn. R. 7045) that Northshore Mining violated. The MPCA received notice of this action and has independent state enforcement authority.
• OSHA (Occupational Safety and Health Administration): Worker exposure to unlabeled hazardous waste and uncontained oil spills falls within OSHA jurisdiction. If workers at this facility were not informed of their exposures, OSHA has independent authority to investigate and penalize.
• Securities and Exchange Commission (SEC): Cleveland Cliffs is a publicly traded company. Material environmental liabilities and compliance failures may be subject to disclosure requirements. Shareholders have the right to demand transparency on the company’s environmental compliance record.

What You Can Do

• Contact the Minnesota Pollution Control Agency directly and ask whether state-level enforcement action was pursued independently of this federal settlement, and whether the company’s 2021 biennial report gap was investigated at the state level.
• If you are a worker at or near the Northshore Mining facility in Silver Bay, contact your union, or if unrepresented, contact the National Council for Occupational Safety and Health (NCOSH) for guidance on your right to request OSHA inspection records and hazardous materials disclosures.
• Demand that environmental advocacy organizations operating in the Lake Superior region, including the Lake Superior Binational Program and local tribal environmental offices, be kept informed of any future compliance inspections at this facility. These groups have standing and expertise to apply public pressure when federal penalties fall short.
• Share this settlement document. It is a public federal record. The more people who know that a mining company near Lake Superior was fined $8,750 for seven environmental violations including two active uncontained oil spills, the harder it becomes for regulators to accept this kind of outcome as standard practice.
• Support local mutual aid networks in Silver Bay and surrounding communities in Lake County, Minnesota, particularly groups focused on environmental monitoring, worker health, and Indigenous land protection in the Lake Superior watershed.