Document zQd7KVGN1VX1N9MB7vNn8Dmpm

Hon. Lee M. Zeldin March 31, 2025 Page 2 EXECUTIVE SUMMARY U. S. Steel is respectfully requesting a two-year Clean Air Act 112(i)(4) Presidential Exemption from all of the 2024 Coke MACT amendments -the Coke RTR Rule- because, as U. S. Steel has clearly shown in prior submissions to EPA, no coke plant is actually meeting the I IAP limits; nor does any coke plant employ technology that demonstrates the limits can consistently be met. Furthermore, even outside the coke industry, no technology exists that has demonstrated that the limits can consistently be met. U. S. Steel's efforts to comply with the 2024 amendments to the Cokc RTR Rulc would result in significant, adverse financial and operational impacts to the company and the domestic steel industry. Without a Presidential Exemption, U. S. Steel's and the domestic steel industry's ability to provide for the critical infrastructure, investments and national security would be significantly compromised. EXEMPTION REQUEST The President has the authority to grant exemptions from NESIIAP emissions standards of up to two years pursuant to Clean Air Act (CAA) 112(i)(4) and 40 C.F.R. 63.6(j). U. S. Steel is requesting a two-year Presidential Exemption, with the possibility to extend the period for additional periods if necessary and appropriate as authorized under the Clean Air Act, of the following Coke RTR Rule compliance requirements for U. S. Steel's Mon Valley Works Clairton Coke Plant, 400 State Street, Clairton, Pennsylvania 15025: 1. July 7, 2025, compliance date to begin fenccline monitoring (see 63.314); 2. July 7, 2025, compliance date to begin complying with the revised limits for allowable leaks from coke oven battery doors, lids, and offtakes and related reporting (see 63.302(a)(4), 63.302(d), 63.304(b)(8), and 63.311(h); and 3. January 5, 2026, and July 7, 2026, compliance dates to begin complying with MACT standards for sources in the PQBS NESHAP and related reporting (see 63.7283(d), 63.7341(f), and 63.7300(c)(4)). A two-year Presidential Exemption of these compliance dates is necessary and appropriate to prevent irreparable harm to the domestic metallurgical coal and domestic steel industry and is supported for the reasons provided below. BACKGROUND In CAA 112(i)(4), Congress gave exclusive authority to the President to "exempt any stationary source from compliance with any standard or limitation under this section [Clean Air Act Section 112] for a period of not more than 2 years if the President determines that the technology to implement such standard, which has been recognized as including "unavailable in time for Sierra Club FOIA 2025-EPA-04883 ED_018388_00000141-00002 SC_EVERSPLIT0005857