Document JJ0OMg4o390KyjqK97wjjMb3X

USCA Case #24-1287 Document #2077531 Filed: 09/30/2024 Page 19 of 81 46. Any money SunCoke spends bringing its facilities into compliance is lost forever. SunCoke can never expect EPA to cover any of SunCoke's costs for testing or additional controls--even if a court eventually vacates the Final Rule. And any additional controls would not benefit the coke production process in any way. Complying with Some Limits Is Simply Impossible. 47. In some instances, for safety reasons, SunCoke will never be able to comply with the new MACT floor limits for the bypass vent stacks. 48. According to SunCoke's data, there are particulate matter failures at four of its six plants, marginal passes for mercury and acid gas, and a lack of data for PAHs and formaldehyde. 49. Here are just two examples: a. In November of 2020, a trial was conducted at the bypass vent stack of SunCoke's facility, IHO, to ascertain its particulate matter emissions. The MACT floor is 3.20E-02 gr/dscf. Here are the measurements obtained: (1) 4.54E-02, (2) 1.43E-01, (3) 4.48E-02, and (4) 2.79E-02. The test result was 6.52E-02, which is 204% of the Final Rule's MACT floor limit. So if the (Page 19 of Total) - 19- Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00118 SC_EVERSPLIT0005792