Document NNemOZJ0kYJydeXNamvvxBoYp

CLEVELAND-CUFFS INC CLIFFS March 31, 2025 U.S. Environmental Protection Agency 1200 Pennsylvania Ave., NW Washington, DC 20460 Submitted by Electronic Mail to: .-tir,[ct],,11.,i Re: Presidential Exemption: National Emission Standards for Hazardous Air Pollutants for Coke Ovens: Pushing, Quenching, and Battery Stacks, and Coke Oven Batteries; Residual Risk and Technology Review, and Periodic Technology Review (89 FR 55684; July 5, 2024) (Coke Ovens Rule) Cleveland-Cliffs Inc. hereby requests a Presidential Exemption under Clean Air Act (CAA) section I 12(i)(4) for Cleveland-Cliffs Bums Harbor I,I,C; Cleveland-Cliffs Cleveland Works Warren Location; and Cleveland-Cliffs Monesscn Coke LLC (collectively "Cleveland-Cliffs") from compliance with the standards and limitations in the National Emission Standards for Hazardous Air Pollutants for Coke Ovens: Pushing, Quenching, and Battery Stacks, and Coke Oven Batteries; Residual Risk and Technology Review, and Periodic Technology Review, 89 Fed. Reg. 55684 (July 5, 2024) (collectively, the "Coke Ovens Rule"). Cleveland-Cliffs operates three coke oven plants that feed our five integrated steel mills across Indiana, Michigan, and Ohio. We also purchase coke from merchant suppliers including Sun Coke and ESS Coke. Cliffs invested 51 billion to build a facility to produce I Iot Briquetted Iron (HBI), consumption of which in our furnaces has reduced coke consumption. However, Cliffs' ironmaking operations must still rely on coke as a key raw material to meet critical production needs. On July 5, 2024, EPA promulgated the final Coke Ovens Rules, which establishes: 1) New maximum achievable control technology (MAC-I-) standards for acid gases (AG), dioxin and furans (D/1-.), formaldehyde, hydrogen cyanide (HCN), mercury (Hg), polycyclic aromatic hydrocarbons (PAII), and volatile organic I IAP (VOIIAP) from coke oven pushing operations; 2) MAC-I. and work practice standards for AG, D/12, HCN, Hg, PAH, particulate matter (PM), HAI' metals, and VOHAP from coke oven battery stacks; 3) New facility fenceline emission monitoring and corrective action requirements; and Sierra Club FOIA 2025-EPA-04883 1104095877,3\AMERICAS ED_018388_00000167-00001 SC_EVERSPLIT0005940