Document KRpO8wrGOmjeXKzLMdB86Ndrx

recovery and byproduct plants. EPA ignored these differences (and the Fenceline Monitoring data) when it determined, for example, that it was "necessary" to require Fenceline Monitoring for both. Comparison of Heat Recovery and Byproduct Benzene and PAH* Emissions C 4C C 3C C 2C C C X r Polycy Aromatic Hydrocarbons BydrpaJzt s Heat Recc.ier> 2. SunCoke's Facilities Do Not Emit COE Directly' to the Atmosphere SunCoko does not omit coke oven emissions ("COE") directly to the atmosphere through its bypass or waste heat stacks. EPA makes significant mischaractcrizations of SunCoke's venting process in the Federal Register notice and in its analysis of SunCoke's emissions: The one facility without I IRSGs .rends COL directly to the atmosphere via waste heat stacks, 24 hours per day, 7 days a week. At the current heat recovery each HRSG can be bypassed ranging from 192 to 1,139 hours per year, depending on the facilities' permits, sending COL directly into the atmosphere. 88 Fed. Reg. 55858, 55864 (Aug. 16, 2023) (emphasis added); see also id. 55877. The volatiles in the coke oven emissions arc already fully combusted when vented out of the waste heat and bypass vent stacks and therefore, no COF is vented directly to the atmosphere. See Section III.A. Instead fully combusted oven flue gases (primarily CO,, Ili, and excess oxygen and nitrogen) arc vented to the atmosphere. This is because, as described in Section 1II.A above, SunCoke's ovens operate under negative pressure such that the volatilcs in the coal arc combusted within the oven system, which moans they are not vented to the atmosphere like ByP coke ovens. SunCoke performs quarterly industrial hygiene monitoring for COEs at all of its facilities pursuant to OSHA's Coke Oven Emissions Standard, 29 CFR 1910.1029. As part of this monitoring, SunCoko monitors employees' potential exposure to COEs by collecting personal air samples during normal operations from several categories of workers, including burners, hot car operators, door machine operators, and PCM operators, among others. This monitoring has consistently demonstrated that air samples taken from employees working in close proximity to operational coke ovens shows that the potential exposure to the relevant PAIIs (phonanthrone, 12 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00013 SC_EVERSPLIT0005687