Document M4nv1epkzpjGQEyoyzNgYNB4V

stacks, and bypass vent stacks that cannot be met with existing controls and the technology to implement the new limits is not available.' a. PI,Shing linzils ai 40 ( .F.R. 63.7290(h) (e): For pushing, EPA promulgated numeric MACT floor emission limits for acid gases (AG), hydrogen cyanide (HCN), mercury (Hg), and polycyclic aromatic hydrocarbons (PAH). 3 the technology to implement these new pushing limits is not available. Pushing emissions at byproduct (ByP) facilities are controlled using stationary devices (ba2houses). In contrast, SunCoke's facilities use flat push hot cars, which have roofs and multicycloncs (also referred to as multiclones) that capture pushing emissions.1 The flat push hot cars cannot be equipped with additional controls needed to meet the new limits because flat push hot cars are mobile, subject to significant vibration, and have very limited space or structural capacity for additional equipment.' Moreover, unlike ByP facilities, SunCoke's HNR facilities' configuration does not allow for controls, like a traveling hood with a fixed baghousc, on flat push hot cars!' SunCoke's ovens arc hori7ontal and their batteries and tunnels arc longer, whereas ovens at byproduct coke facilities arc vertical and their batteries and tunnels are shorter. Because of the unique configuration of SunCoke's ovens and batteries, SunCoke would not be able to pull sufficient draft to run a traveling hood fixed to a baghousc, and if SunCoke were unable to pull sufficient draft, that could create positive pressure that increases the likelihood of emissions of pollutants into the environment. SunCoke's negative pressure technology requires a specific configuration that uses negative pressure and draft to pull pollutants through environmental treatment technology. SunCoke's technology requires this configuration, and SunCoke cannot reconfigure its equipment at existing I INR facilities to install controls. For the reasons described above, SunCoke requests a two-year exemption from compliance with the new MACT floor emission limits established in the Coke Ovens Rule for pushing (40 C.F.R. 63.7290(b) (e)). SunCoke also requests a two-year exemption from compliance with the following obligations associated with the new MACT floor emission limits: initial performance tests to demonstrate compliance with the new emission limits ( 63.7320(a)); subsequent performance tests ( 63.7321); compliance report requirements specific to the new MACT floor SunCoke submitted extensive comments in response to EPA's proposed revisions to NESIIAP Subparts CCCCC and L. as well as a petition for reconsideration of the final Coke Ovens Rule. SunCoke Comment. Docket ID EPAIIQ-OAR-2002-008.5-0968 (Oct. 2, 2023) [attached at Tab A, without attachments]: SunCoke Petition for Reconsideration to M. Regan, former EPA Administrator (Sept. 3, 2024) [attached at Tab Ii]. In the comment letter and petition for reconsideration. SunCoke extensively addressed its inability to meet new MACT floor emission limits with existing controls and the technological infeasibility of installing new controls. See SunCoke Comment: SunCoke Petition for Reconsideration. 89 Fed. Reg. at 55708: 40 C.F.R. 63.7290(b) (e). See SunCoke Comment at 9 ' See ri. at 30 6 Id 3 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000084-00003 SC_EVERSPLIT0005655