Document gaEvvZyyOxo6m65JXa4xkq4NQ

USCA Case #24-1287 Document #2077531 Filed: 09/30/2024 Page 16 of 81 million ($:3 million for testing + $59 million for mercury controls/testing + $37 million for particulate matter controls) depending on whether more equipment is needed. These are necessary costs to control only two HAPs from one source for one SunCoke facility. If Further Testing Reveals More Failures, the Projected Costs of Installing Additional Controls Are Exorbitant. :38. To determine what SunCoke needs to do to bring its facilities into compliance, I have separated the results of the limited data into five groups: (1) clear fails, which necessitate additional controls; (2) marginal passes, which likely necessitate additional controls to maintain a comfortable margin of compliance; (3) passes, but an insufficient amount of data to feel confident in the results of the testing; (4) no data; and (5) clear passes, requiring no further controls. 39. As discussed, based on the clear fail category, SunCoke must immediately spend, at minimum, $62 million to bring its facilities into compliance with the new MACT floor emission Emits. For the reasons provided above, more testing may reveal significant additional costs in this category, which could increase to $99 million. 40. Depending on what future testing reveals, SunCoke will also need to install additional controls wherever the data show that emissions (Page 16 of Total) - 16- Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00115 SC_EVERSPLIT0005789