Document mB7KYrrwm4xjJzD4j0yYDaxm0

II&S Rule Presidential Exemption Request March 31, 2025 Paue 4 of 10 I. Technology to Implement the hazardous Air Pollutant Emission Standards is Not Feasible Cliffs has provided numerous technical reports and declarations' evidencing that new HAP limitations in the 1I&S Rule for the Cliffs' facilities listed above are unachievable and require development and installation of unproven control technologies and/or retrofitting that have never been installed domestically or internationally for these sources because the technologies are not available and have not been demonstrated in practice. The 1I&S Rule fails to consider that not only is this untested technology, but that the facilities also require time for development, trialing, design, procurement, fabrication, and testing to ensure the technology could even achieve its intended purpose. As one industry engineering expert notes: "Typical capital project delivery steps for a major emission control project of this scale typically require 2 3 years to implement. 'Ile research and development required to conceive of, test and validate a novel solution which does not exist today could easily add another 2-3 years to this typical implementation timeline, provided that a solution is identified."c' 'Ile affected sources and specific issues with the feasibility of. HAP emission limit control technologies are summarized as follows:7 BOPFs: Together, the five Cliffs' facilities have fifteen (Is) BOPF furnaces, and there is no existing emission control system that can be added to a 13O1)12 furnace that is known to address dioxin/furan, total hydrocarbons, or hydrogen chloride to meet the limits provided in the 2024 II&S Rule. Addressing I IAPs for BOPF furnaces will require significant retrofit upgrades to the current systems, the extent of which will depend on whether there is dry electrostatic precipitator or wet scrubber technology already in place. These system upgrades arc expected to be particularly challenging, given they will likely need to incorporate (or in the case of wet scrubbers, completely replace with) novel treatment technology such as a recirculating baghouse system with injected lime and/or carbon, which arc not commercially available. BF Casthouses: Together, the five Cliffs' facilities have seven (7)13F casthouses, and there is no existing add-on emission control that is proven to meet the I IAP limitations for hydrogen chloride or total hydrocarbons. Moving forward with the limits in the rulemaking ' See Comments of the American Iron and Steel Institute [including member Cliffs] and United States Steel Corporation on National Emission Standards for Ila7ardous Air Pollutants Integrated Iron and Steel Manufacturing Facilities Technology Review: Proposed Rule, 88 Fed. Reg. 49,402 (July 31, 2023), submitted September 29, 2023 ("AISI Comments"), Docket No EPA-HQ-OAR-2002-0083-1631; Cliffs' Petition for Reconsideration and Request for Administrative Stay ("Cliffs' Reconsideration Petition"), submitted June 3, 2024; Cliffs' Motion for Stay, filed June 28, 2024, in Cleveland-Cliffs Inc. v. U.S. EIM. Case No. 24-1170 (D.C. Cir.) ("Cliffs' Motion for Stay"; Cliffs' Reply in Support of Motion for Stay, filed September 19, 2024, in Cleveland-Cie Inc. v. US. EP4, Case No. 241170 (D.C. Cir.) ("Cliffs' Reply") and associated exhibits'attachments. Declaration of David Mysko, P.E. of Hatch Associates Consultants, Inc. (Sept. 17, 2024) (attached as Exhibit L to Cliffs' Reply). Sec aiy) Declaration of Stephen Palmer, Cleveland-Cliffs Enterprise Director Engineering (June 13, 2024) (attached as Exhibit C to Cliffs Motion for Stay). Declaration of David Mysko, P.E. of Hatch Associates Consultants, Inc. (Sept. 17, 2024) (attached as Exhibit L to Cliffs' Reply): Declaration of Ryan Siats of Harr Engineering (June 18, 2024) (attached as Exhibit E to Cliff's Motion for Stay) 1104059958 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000118- 00004 SC_EVERSPLIT0005810