Document RjZgj9qvy1eMygNKgMpvBZ1rv

Hon. Lee M. Zeldin March 31, 2025 Page 4 TECHNOLOGY IS UNAVAILABLE A. Fenceline Monitoring Requirements For the reasons set forth in U. S. Steel's and the ACCCUCOET12 petitions for reconsideration, the fenceline monitoring benzene action level in the Cokc Ovens Rule is overly stringent and is not based on modeling showing the correct highest benzene concentration at the facility fenceline using allowable (vs. actual) emissions. To implement the fenceline monitoring requirements, new currently undeveloped emission controls and new leak detection/repair programs must be evaluated, designed and installed to comply with the action level. The technology that would be used to comply with the fenceline monitoring requirements and action level are not known and, therefore, are unavailable at this time. Due to the complex nature of coke facilities, this potentially involves engineering suitable capture and control systems at multiple locations. Identifying these locations and engineering controls for them takes much longer than one year, and may involve permitting new emission controls, which would delay installation of controls. In addition, additional time is needed to install the benzene fenceline monitoring and meteorological stations. Siting the monitoring locations, specifically the locations around the non-source category operations will take additional time to determine the delta c. In addition, for the reasons set forth in the ACCCl/COFTF and U. S. Steel petitions for reconsideration, the fenceline monitoring benzene action level in the Coke RTR Rule, which is not health-based, was incorrectly determined, is overly stringent, and is not based on modeling showing the correct highest benzene concentration at the facility fenceline using allowable (vs. actual) emissions. In further support of the Presidential Exemption, additional compliance time beyond one year is also needed to develop (and for EPA to approve) the facility-specific monitoring plans, which arc a compliance measure technology, that arc required under the rule. Thus, the technology to implement the requirements is not available. Identifying specific source contributors to each fenceline monitoring location poses significant challenges due to the closely located sources (e.g., coke batteries, byproduct recovery plant, storage tanks, marine barges, etc.) within a coke facility, which is unlike more widely spaced sources common in the petroleum refinery sector. Likewise, "root cause" investigations required by the Coke RTR Rule add significant time and complexity, considering the many miles of piping and thousands of valves and flanges at a coke facility. Projects to reduce benzene emissions further include redesign, fabrication, and installation or modification of process vessels, tar decanters, gas blanketing and vapor collection systems, replacing sections of coke oven gas piping, and redesign of tar and light oil loadout systems to reduce allowable fugitive emissions or leak rates. Because the Clairton plant is complex and has numerous "non-categorical" operations -- which fall outside the scope of the requirements, the standard fenceline monitoring requirements arc not appropriate or feasible. It will take C. S. Steel more time to generate sufficient data and Sierra Club FOIA 2025-EPA-04883 ED_018388_00000141-00004 SC_EVERSPLIT0005859