Document emjJjw2871gK0nV3q6zmMpeNm

USCA Case #24-1287 Document #2077531 Filed: 09/30/2024 Page 8 of 81 these data "better accounted for test-to-test and plant-to-plant variations." Ex. A at :3:3-34. 21. Contrary to EPA's expectations, SunCoke's data reveal that multiple SunCoke facilities cannot meet the MACT floor Emits. 22. Here are two examples from only one facility's main stack to illustrate the point. a. In March of 2022, a trial was conducted at the main stack of SunCoke's facility, HH1, to ascertain its particulate matter emissions. The relevant MACT floor is 4.00E-03 gr/dscf. Here are the measurements taken from the trial: (1) 4.10E-03, (2) 5.26E-03, and (3) 6.43E-03. The test result was 5.26E-03, which is 107% of the Final Rule's MACT floor. So if the Final Rule were in effect in 2022, HH1 would have exceeded the PM limit for its main stack. b. In January of 2006, a trial was conducted at the main stack of HH1 to ascertain its mercury emissions. The Final Rule's MACT floor is 3.00E-06 gr/dscf for main stack mercury emissions. These are the measurements obtained from the trial: (1) 5.08E-06, (2) 4.80E-06, and (3) 4.33E-06. The test (Page 8 of Total) 8- Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00107 SC_EVERSPLIT0005781