Document LpXyeD9Y5qw1J1aenZ5mRo4rX

Coke Ovens Rule Presidential Exemption Request March 31, 2025 Page 4 of 7 'Ile Coke Ovens Rule imposes numerous new MACT and work practice standards covering multiple hazardous air pollutants (HAP), which EPA claimed are in response to the D.C. Circuit decision in Louisiana Environmental Action Network v. EPA (LEA:7\1 955 F.3d 1088 (D.C. Cir. 2020). However, the technologies that would be needed to control these IIAP arc not available and have not been demonstrated to work for the coke byproduct recovery industry, either in the CS or internationally. The very short 1 8-month compliance period (i.e., January 5, 2026) in the Coke Ovens Rule is one-half the time allowed under the Clean Air Act and was based on EPA's incorrect and unsupported assumption that facilities would only need to do testing to confirm EPA's assumption that all coke facilities can meet the new MACT limits. EPA failed to address specific concerns and data submitted by commenters showing that facilities cannot meet the new standards without costly and undemonstrated control technologies. EPA also did not address data submitted by commenters showing raw material (i.e., coal) and process variability that affect emission performance, which make these limits unachievable without developing and installing novel emission control technology that is not commercially available. As provided in numerous technical reports and declarations, 2. emission control technologies to achieve compliance with the PQBS emission limitations and coke oven leak rates and benzene action levels are not commercially available. -' Even assuming that facilities are ultimately able to research and develop the new technologies needed to implement these new MACT standards, facilities need much longer than the 1 8-month compliance period under the Coke Ovens Rule. A Presidential Exemption is wan-anted for several reasons: The technologies used in some other industries to control these HAP have not been demonstrated to work in the coke byproduct recovery industry. Controlling multiple pollutants and retrofitting controls into existing equipment and operations adds technical and engineering complexity due to process interactions of the requirements for control, including pollutant interactions, flow rates, chemistry, and temperatures. 'Ile Coke Ovens Rule includes first-time emission limits for hydrogen cyanide (HCIN); however, it is widely acknowledged that there arc no existing technologies available to control IICN. Air pollution control vendors indicate that any potential solution for control of I HCN is not technically feasible for coke battery combustion stack or pushing emissions.` 'Ile coke battery underfiring system is naturally drafted, with the uncierfire gas stream predominantly located underground. Added equipment such as heat exchangers, sorbent injection systems, etc., result in static pressure loss, necessitating installation of an induced draft fan. 'Ile impacts of added fans and equipment need to be studied to ensure adequate See ACCC'I..COFI'F Petition for Reconsideration and Stay (Sept 3, 2024); COEFF Comments (Oct 2, 2023),. COEFF \lotion for Stay, filed Sept. 30, 2024, in in/. rake and Coal ('Innonc..nls Ins'. and Cake Oven in 'I liilk Farce l, Case No 24-1287 (I).C'. Cir ) ("COFFF Motion for Stay"): COFFF Reply, filed November 5, 2024, in Coke and Con, ('hennenls Insf and Coke Oven 1.nv'I Farce v. EPA, Case No 24-1287 (I).C;. Cir.) ("COEFF Reply") and associated exhibits/attachments 3 Id. 4 Id. 1104095877,3\AMERICAS Sierra Club FOIA 2025-EPA-04883 ED_018388_00000167-00004 SC_EVERSPLIT0005943