Document RpaBQrMOv36dErYwDpdVL2MEV

USCA Case #24-1287 Document #2077531 Filed: 09/30/2024 Page 4 of 81 9. Unlike HNR facilities, ByP facilities recover chemicals from coke oven gas in an on-site chemical plant. Another important difference between ByP and HNR facilities is that the ByP ovens operate under positive pressure, whereas HNR facilities' ovens operate under negative pressure. Because HNR facilities operate under negative pressure, they have very low fugitive emissions. 10. EPA has recognized that SunCoke's cokemaking process is the most environmentally friendly way to make coke, and it has adopted SunCoke's heat-recovery cokemaking process as the industry maximum achievable control technology ("MACT"). See, e.g., 66 Fed. Reg. 35326, 35328-29 (Jul. 3, 2001); 42 U.S.C. 7412(d)(8)(A). EPA Finalized a Rule that Established 17 Numerical MACT Floor Limits for Previously Unregulated HAPs. 11. On August 16, 2023, EPA published a proposed rule that would amend two National Emissions Standards for Hazardous Air Pollutants (NESHAP) for the coke ovens industry. 88 Fed. Reg. 55858, 55858 (August 16, 2023) (The Proposed Rule). 12. On October 2, 2023, SunCoke submitted comments to EPA on the agency's Proposed Rule. Attached as Exhibit A to this Declaration is a true and correct copy of SunCoke's comments on the Proposed Rule (Page 4 of Total) 4- Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00103 SC_EVERSPLIT0005777