National Emission Standards for Hazardous Air Pollutants: Integrated Iron and Steel Manufacturing Legacy Docket ID #: A-2000-44

Please find the attached American Iron and Steel Institute (AISI) cover letter, introduction, executive summary and Sections I - VIII of the joint comments previously submitted September 29, 2023 by AISI and the United States Steel Corporation concerning EPA's Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission compiles the comments, into one more convenient document, that were previously filed in numerous separate uploads due to the limitations of regulations.gov to accept larger files. This submittal of 333 pages does not include the appendices which were also previously submitted. EPA should associate this submittal with Legacy Docket ID #: A-2000-44 and https://www.regulations.gov/docket/EPA-HQ-OAR-2002-0083 Appreciation of the dedication of Angela R. Morrison, Lianne Mantione and Mary Kaplan is being highlighted to recognize their significant contributions to these comprehensive comments, especially considering the short comment period and the magnitude of new flawed technical information posted in the docket just prior to the submittal of these previous comments. Sincerely, Richard M. Zavoda

Please find attached Section VI of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Section IV of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix A (Industry's UFIP Memorandum (Sept. 2023) with attachments) of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix G (Lead and Arsenic EPA Ambient Monitoring Memorandum) and Appendix H (Industry's Fenceline Monitoring Data and Cost Analysis (Sept. 2023)) of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix P (Barr Consulting Gary Works Fenceline Monitoring Analysis) of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix Q Part 1 - which has Fenceline Monitoring Information and Analysis from AISI representing Cleveland-Cliffs Inc. -- of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix Q Part 2 containing information presented to OMB for U. S. Steel Corporation -- of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix R information (risk modeling) that supports the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. The detailed modeling input files are not compatible file formats for regulations.gov. These supporting input data are available upon request from EPA and can be provided electronically via secure file transfer. In the meantime, the relevant information has been provided in the comments themselves. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix B (Industry's UFIP UPL Memorandum (Sept. 2023) with Attachments) of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix C Part 1 (2019 AISI and USS Comments) of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix C Part 2 (2019 AISI and USS Comments) of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

See attached Please find attached Appendix C - Part 3 (AISI and USS 2019 Comments) of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Section III of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix D - Part 2 of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix D - Part 3 of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix E (AISI Presentation Oct 2018) and Appendix F (Realtime Cost Estimates Cr Monitor) of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix O - AISI Submittal Re Cr Report - of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix M - Model to Monitor Comparison - of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix N - Test Report for Cr6 to Total Cr to support the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix K - Uncontrolled Emission Calcs - of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Appendix J - Point Source Supporting Information -- of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Section VII of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached Section V re BOPF and BF Casthouse Fugitive emissions of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP

Please find attached the Introduction, Executive Summary, and Section I of the joint comments submitted by the American Iron and Steel Institute, representing Cleveland-Cliffs Inc., and the United States Steel Corporation on the Proposed Integrated Iron and Steel Manufacturing Facilities Technology Review. This submission should be associated with the larger comment package that we are filing in separate increments due to the limitations of regulations.gov to accept large files. The comment package consists of a cover letter, an introduction, executive summary, eight subsequent sections addressing several specific aspects of the proposal, and at least 17 appendices. EPA should associate this submittal with both the AISI cover letter and the United States Steel cover letter and with the additional submittals identified with similar comment text. Please contact me at sbroome@huntonak.com if you have any questions regarding the elements of the submittal or need help assembling the complete submission into a single package. Sincerely, Shannon S. Broome Partner, Hunton Andrews Kurth LLP