Document LqbdX2zMB4rRnDXoxwdZeDaQ

Beveridge & Diamond Heidi C Knight 155 Federal Street, Suite 1600 Boston, MA 02110 +1.617.419.2365 HKnightgbdlaw.com Subniiited ria luths: L.S. Environmental Protection Agency EPA Docket Center Mail Code 28221T 1200 Pennsylvania Avenue NW Washington, DC 20460 October 2, 2023 Re: Comments on Proposed Rule, National Emission Standards for Hazardous Air Pollutants for Coke Ovens: Pushing, Quenching, and Battery Stacks, and Coke Oven Batteries, Docket 1D Nos. EPA--HQ--OAR-2002-0085 and EPAHQ-OAR-2003-0051 I o Whom It May Concern: On behalf of SunCoke Energy, Inc. ("SunCoke"), Beveridge & Diamond, P.C., respectfully submits these comments to the U.S. Environmental Protection Agency ("EPA" or "the Agency") on the Agency's Proposed Rule: National Emission ,S.tandards .f0r Hazardous Air Pollutants for Coke Ovens: Pushing, Quenching, and Battery Stacks, and Coke Oven Batteries, as published in 88 Fed. Reg. 55858 (Aug. 16, 2023) (the "Proposed Rule"). SunCoke believes that the Proposed Rule would impose numerous, onerous new limits and requirements that are unnecessary for environmental protection and are technically and economically infeasible, despite the Agency's findings of acceptable risk and lack of developments in practices, processes, or control technologies.[ In fact, EPA's proposed requirements could cause irreparable harm to SunCoke. 'Ile 45-day comment period was woefully inadequate, as SunCoke explained in its request for an extension (Attachment A), which EPA denied without any explanation (Attachment B). In the limited time provided, SunCoke spent considerable effort evaluating the proposed amendments and the technical memoranda and other new information that was only recently made available to SunCoke and other affected parties; however, there was a See, c'.g., 88 Fed. Reg. 55858, 55858 (Aug. 16, 2023): see also infra Section II (describing Agency's RTR findings and its analysis of IINR cokemaking process and emissions in prior rulemakings). Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00002 SC_EVERSPLIT0005676