Document X7bxvNDQzybazQL8MwRN6km0K

standard applies "during 13y1) waste heat combustion in battery flues," 89 Fed. Reg. at 55708. And 'Fable 5 under 40 CFR part 63, subpart CCCCC specifically limits the work practice standard to "ByP battery (combustion) stacks." Moreover, IINR facilities do not operate "battery waste heat flues." To avoid unnecessary confusion among state regulatory agencies and the regulated community, section 63.7300(c)(4) should be clarified to specify that the new work practice standard is limited to byproduct facilities. 6. Discrepancy in number of iesi runs required fl)r initial compliance Under the Final Rule, section 63.7322(e)(2) sots the number of test runs required to determine compliance with a process-weighted mass rate of HCN (lb/ton of coke) from a control device applied to pushing emissions and battery stacks. The Final Rule requires facilities to "[c]ollect minimum of night spectra for each of six runs (or hours) evenly spaced over the test period" (emphasis added). But only "iiihree valid test runs are needed to comprise a performance test" (emphasis added). So, it is unclear whether three or six runs is sufficient to comply with section 63.7322(e)(2). Three runs should be sufficient and would be consistent with other sections using Method 320. Mconsisient pushing Section 63.7326(a) establishes what regulated parties must do to demonstrate initial compliance with the emission limits from a control device applied to pushing emissions. Paragraphs (a)(2) through (a)(.5) identify pushing omission limits for Hg, AG, IICN and PAII respectively, but these limits do not match the limits provided in section 63.7290(b) through (e) and in Table 7 of the Final Rule 5.1E-07 lb/ton. 89 Fed. Reg. at 55708. The limit in section 63.7326(a) should match the limit provided in section 63.7290 and 'Fable 7. ( FOSS reference error in PAH emission limits The Final Rule's references to " 63.7290(b) through (d)" should be changed to " 63.7290(b) through Le" in sections 63.7282 and 63.7283. Section 63.7290(e) provides the PAH emission limits for capture systems and control devices applied to pushing emissions. Sec attachment A for the corrections (in rod) required to fix the typo throughout section. ( ross erence error in recordkeeping requirements 40 C.F.R. 63.311(f)(1)(v) requires keeping "[r]ecords to demonstrate compliance with the work practice requirements for oven uptake damper monitoring and adjustments in 63.303(c)(1)(iv)." But section 63.303(c)(1)(iv) does not exist. The relevant recordkeeping requirement is in paragraph section 63.303(c)(1). II. Stay Pending Reconsideration While EPA is reconsidering a rule pursuant to section 307(d)(7)(13), the CAA permits EPA to stay "the effectiveness of the rule" . . . for a period not to exceed throe months."`10 This stay gives the Agency time to reconsider its position and review the Final Rule's requirements without imposing 9 42 U.S.C. 7607(d)(7)(13). - 26 - Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00086 SC_EVERSPLIT0005760