Document e7a8QkxxjKbpgqqJ9jvmLzdEE

where alternate work practices would be more appropriate, EPA cannot reject all of the comments and refuse to establish any work practice standards because commenters did not provide specific work practices. IIad EPA asked commenters to identify specific work practices that should be applied, SunCoke would have identified the following: Common -Funnel 40 C.F.R. 63.303(a)(1) requires monitoring and recording pressure in each oven or in each common battery tunnel once per day during pushing, charging, and coking to ensure that the ovens are operated under a negative pressure. Possible malfunctions: Pressure cells malfunction duc to instrumentation failures, negatively affecting draft and resulting in positive pressure in common tunnels. Potential alternative limit: Visually observe relevant section of common tunnel to confirm absence of visible emissions from tunnel. Pushing/Charging Machines For charging operations, the owner or operator shall implement, for each day of operation, the work practices specified in section 63.306(b)(6).7' Requirement to continuously operate baghouse and maintain baghouse differential pressure within a certain range. Possible malfunctions: Failure of control system or electrical infrastructure components, causing baghouse to shut down; differential pressure outside of normal range. Possible startup concern: After PCM baghouse fabric filter cartridges are changed during routine maintenance, the fabric filter cartridges need to gather a layer of material to operate efficiently and keep the differential pressure within range. Potential alternative limit: Observe baghouse stack and hood PCM area for visible emissions greater than 20% over 6 minutes. Flat Push Hot Car Machines 40 C.F.R. 63.7290(f)(4) requires, for each multicyclonc, maintaining the daily average pressure drop at or below the minimum level established during the initial performance test. Potential malfunctions: Loss of control system components or electrical service, failure of multiclone, differential pressure outside of normal range, fan amps outside of threshold values, failure of continuous monitoring system. Potential alternative limit: Observe hot car stack for visible emissions greater than 20% over six minutes. r 40 C.F. R 63.303(h)(3). - 17 - Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00077 SC_EVERSPLIT0005751