Document e7Vv3Ny9ZOQben0ezOoDp0nQy

B. EPA Relied on Erroneous Assumptions to Compute Costs of Implementing the Proposed BTF Measures at Jewell Under the approach adopted by EPA, only one category of facilities (IINR facilities that do not have IIRSCis)--which has only one facility (SunCoke's Jewell plant at Vansant, VA)-- would be required to implement the proposed BIT measures. 88 Fed. Reg. at 55893. The Jewell plant has a unique configuration that is a product of its topography, as EPA recognized when estimating the amount of time needed for Jewell to complete the work necessary to comply with the proposed new BTF PM limit: The facility that is affected by the new BIT PM limit is located between three rivers, a state road, and a railroad track. Therefore, due to the unique configuration of the facility, the resulting lack of space available to construct control devices and ductwork to reduce arsenic emissions from bypass stacks creates an impediment to a typical construction schedule. 88 Fed. Rcg. at 55882, n.30. These same unique features arc the reasons that SunCoke expects the changes that would be required under EPA's proposal to be exponentially more costly at Jewell-- if they arc technically or physically achievable at all. The plant's location in a river valley with rivers, a state road, railroad tracks, and extremely steep gradients on both sides does not provide sufficient space for baghouscs of sufficient size to accommodate the exhaust flows from the exhaust coke oven batteries. See Attachment C for Jewell facility description and pictures. 21 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00022 SC_EVERSPLIT0005696