Document ypj2OQpDvj6b1pmrXzDoME3GX

1I. EPA WAS RUSHED TO PUBLISH PROPOSED AMENDMENTS TO LONGESTABLISHED COKE OVEN MACT STANDARDS EPA is proposing to amend two existing rules at the same time: the NEST TAP for Coke Ovens: Pushing, Quenching, and Battery Stacks (40 CFR Part 63, Subpart CCCCC) and the NESHAP for Coke Oven Batteries (40 CFR Part 63, Subpart L). EPA promulgated Subpart I, in 1993. 57 Fed. Reg. 57534, 5753E (Dec. 4, 1992); 58 Fed. Reg. 57898, 57898 (Oct. 27, 1993). For IINRs, Subpart I. addresses leaks of coke oven emissions (COP:)`' from oven doors and charging emissions. According to EPA, the controls and work practice requirements included in the rule provide "concurrent control of many air taxies and hazardous pollutants included in the coke oven emissions from batteries or bypass/bleeder stacks." 58 Fed. Reg. at 57906. EPA made minor corrections to the standards in 1994. 59 Fed. Reg. 1992C (Jan. 13, 1994). EPA amended Subpart L in 2005 after an R.I.R review in order to address health risks remaining after implementation of the 1993 standards and new calculations based on revised cancer guidelines. 69 Fed. Reg. 48338 (Aug. 9, 2004); 70 Fed. Reg. 19992 (Apr. 15, 2005). In the 2005 rule, EPA used particulate matter as "a surrogate for particulate !TAP in [MEL" 70 Fed. Reg. at 19994, and considered in the risk assessment a group of PAH and lead." Id. at 20002. EPA noted that it "continuc[s] to consider the M1R [maximum individual risk] due to emissions at the limits in the 1993 national emission standards to be an acceptable level of risk." 70 Fed. Reg. at 19993. EPA promulgated Subpart CCCCC in 2003. 66 Fed. Reg. 35326 (Jul. 3, 2001); 68 Fed. Reg. 18008 (Apr. 14, 2003). Subpart CCCCC established MACT standards that included PM limits as a surrogate for l 'AP metals]] for pushing, opacity limits for PM/I 'AP metals from battery stacks of oven combustion air, and a work practice standard to limit PM and volatile HAP emissions for quenching EPA made corrections to these standards in 2003. 68 Fed. Reg. 19885C (Apr. 22, 2003). EPA issued a direct final rule amending these standards in 2004, but withdrew a part of that direct final rule in 2005. 69 Fed. Reg. 60813 (Oct. 13, 2004); 70 Fed. Reg. 1670 1(> "CUE are a separately-listed hazardous air pollutant (HAP) emitted from most subpart L sources that is thought to consist of more than approximately 71 chemicals, including volatile and semi-volatile organic IIAP and particulate matter (PM) IIAP." EPA-HQ-OAR-2002-0085-0873, EPA, Memorandum, Technology Review for YESIL1P for Coke Oven,s. Pushing, Quenching, allcl Batters. Slacks (40 CPR part 63, mihpari CCCM, and \ESIL1I' for Coke Oven Batteries- (40 CPR part 63, mihpari I.) (May 1, 2023). I- The IIAP metals are antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, nickel, and selenium. I' EPA noted in a response to comments that regulation of PM through the use of control devices directly reduces individual IIAP emissions, stating: We agree with the comment that baffles reduce PM emissions. In addition, we believe that baffles also reduce the emission of HAP metal compounds contained in the particles of grit released, as well as sernivolatile and \'O(' such as polvcyclic aromatic hydrocarbons (PA II) and benzene, when green coke is quenched. Semivolatile organic compounds evolve from green coke and condense to form fine PM or condense on other particles during the quenching process. Consequently, baffles reduce emissions of both metal and organic IIAP 71 Fed. Reg at 18018. EPA also defended the continued use of opacity as a surrogate, citing the correlation between opacity and HAP: "Ifigher opacities mean a higher concentration of particles and therefore higher concentrations of HAP." 71 Fed Rcg at 18020. 7 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00008 SC_EVERSPLIT0005682