Document dQRY6yjVo9pG1BRDxG2jnwazb

USCA Case #24-1287 Document #2077531 Filed: 09/30/2024 Page 14 of 81 designing, engineering, and validating feasible and practicable emissions controls (where such controls exist). 33. Based on the data currently available, and despite EPA's assertions to the contrary, it is clear that SunCoke must install at least some controls to meet the new MACT floor limits. :34. One example that conclusively demonstrates this fact is, as discussed, SunCoke has data showing that its HH1 facility's main stack fails to meet the MACT floors for mercury and particulate matter emissions. 35. As discussed, unlike some other SunCoke plants, HH1 has no mercury controls--such as a PAC or a hydrated PAC. SunCoke does not yet know whether bringing HH1 into compliance with the new MACT floor for mercury main stack emissions is as simple as adding a hydrated PAC system at a cost of about $4 million ($3 million for equipment and $1 million for additional testing), which would be the absolute minimum cost to control the mercury emissions. SunCoke might also need more expensive equipment to ensure that the newly installed hydrated PAC does not degrade HH1's ability to control other pollutants--such as sulfur dioxide. In that event, an extra spray dryer absorber, a baghouse, and a (Page 14 of Total) - 14- Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00113 SC_EVERSPLIT0005787