Document LKQQzQ2n4vgvapVKp0RjLE78d

fractions in each test run of. the SunCoke Middletown 1CR Method 29 test show that the measured values in each sample fraction were either below the Method Detection Limit ("MDL") or barely above the MDL ( lx to 2x MDL). Using such noise-level data to establish emission limits is unreasonable. Normal variability in measurement error on future stack test programs will make it difficult, if not impossible, to stay compliant with such low limits. The proposed MACT limit is so low that it allows for significant sampling error. 3. HNR Pushing Emissions are Different from ByP Pushing Emissions EPA improperly used data collected from ByP pushing control devices to develop emission limits for SunCoke's unique pushing control devices; the data collected from ByP coke plants is not representative of SunCokc's HNR operating conditions. EPA's proposal to impose the same pushing emission limits on coke oven batteries in 40 C.F.R. 63.7290(b-e) regardless of the type of coking technology--diverges from Subpart CCCCC's long-standing practice of distinguishing between I INR and ByP facilities for emission limits and work practice standards. Pushing emissions at 13y1) facilities arc controlled using stationary devices (baghouses), whereas IINR facilities use a cokeside shed or mobile multiclone (on the hot car) to control pushing emissions. The current rule on pushing emissions distinguishes between I INR and ByP facilities by setting separate limits; it is clear from the plain language of the rule and its descriptions of the distinct capture systems and control devices which of the rule's limits apply to HNR or ByP coke facilities.32 The proposed amendments would impose the same emission limits regardless of the type of coking process or the type of capture and control device used, which is neither appropriate nor reasonable since the design and operation of SunCokc's cokemaking process is fundamentally different than 13yPs, resulting in differences in emissions. While EPA properly accounted for these differences in the original MACT standard, it ignored them in the Proposed Rule.33 EPA should establish separate limits for I INR and ByP facilities, consistent with EPA's long-standing practice of differentiating between the technologies. EPA's use of ByP data to establish the proposed pushing limits applicable to I INR facilities is improper and arbitrary. EPA's technical memorandum (MACT memo) indicates that it used testing data from both I INIR and ByP facilities to establish the proposed pushing limits.34 It was unreasonable for EPA to use data from ByP facilities to establish limits for the I INR facilities. Differences in the design and operation of IINR and ByP facilities result in differences in their 1' The current rule on pushing emissions. 40 C.F.R. 63.7290, limits PM emissions from pushing. The current rule's PM limits differ in form and numerical value depending on the type of capture system used and whether the control device is stationary or mobile. While the capture and control devices in use primarily control PM emissions, they also help reduce IIAP emissions, as EPA acknowledged in the 2003 final rule. Sc'e 68 Fed. Reg. at 18015. EPA should have therefore followed the same approach (as setting PM limits) when it proposed limits on IlAPs from pushing " For example, the proposed new paragraph (b) in the redline version of the Proposed Rule would impose a mercury emissions limit of 3 4E-07 lb'ton coke on "a control device applied to pushing emissions from a new coke oven battery" or 8 9E-07 lb'ton coke from an "existing coke oven battery " The proposed new limits would therefore apply to any type of control device applied to pushing emissions on any type of coking process This is neither appropriate nor reasonable EPA-HQ-OAR-2003-0051-0785, EPA, Mernorandurn,,lfiMMUM lchievahie Con'rol Technology .Standard Ca ulenions, Cos' Mewls, and licyon i he-Floor rosf [mimeis Jo,. Coke Oven Faci Hies under 40 CFI? par, 63, subpar, CCCr(1, at H-6 and Tables H-] through H-4 (May 1, 2023). 29 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00030 SC_EVERSPLIT0005704