Document jgDQGJBw4077y2XaeODRdmpyN

data providing the basis for this rulemaking were not publicly available until the Proposed Rule was published on August 16, 2023.' For example, EPA's MAC-I. Standard Calculations, Cost Impacts, and Beyond-the-Floor Cost Impacts for Coke Ovens Facilities consists of 114 pages each plus nine separate excel sheets tilled with technical data that necessitate detailed review and analysis. It took EPA 10 years to develop the Proposed Rule, yet SunCoke and the other affected sources were given less than 2 months to evaluate and provide thoughtful comments on it. Providing a full and comprehensive evaluation of the expected costs, feasibility, and other implications of the proposed amendments and preparing timely and thoughtful comments was virtually impossible for SunCoke (and undoubtedly other affected sources) to accomplish within the comment period provided. For example, SunCoke was unable to: Fully evaluate EPA's calculations and proposed emission limits; Perform modeling, including an analysis of the implications of the fenceline monitoring provisions; Conduct risk modeling on site-specific profiles; Fully analyze energy consumption requirements associated with installing, operating, and maintaining the additional pollution control equipment required by the Proposed Rule; or Fully analyze the cost and benefit estimates for the proposed requirements specifically described herein. SunCoke also was unable to comment on many of the topics EPA specifically requested comment on, including: 'Ile merits of a 1-hour opacity standard (88 Fed. Reg. at 55861); The validity of the assumption of two for an acute factor for all sources at coke facilities (Id. at 55871); Alternative approaches to establishing emissions standards for IIRSG main stacks and bypass stacks (Id. at 55879); 'Ile feasibility of capturing and controlling soaking COE (Id. at 55884); Alternative methods to reduce leaks from doors, lids, and offtakes, and from charging at coke oven batteries (Id. at 55884); The suitability of selecting benzene or other I IAP, including naphthalene and other PAII, as the indicator to be monitored by fenceline samplers (Id. at 55887); 'Ile revised equation to estimate coke oven door leaks (Id. at 55889); Whether any situations exist where separate standards, such as work practices, would be more appropriate during periods of startup and shutdown (Id. at 55890); 'Ile content, layout, and overall design of the quarterly and semiannual compliance reports templates (Id. at 55892); 'Ile use of 1 BP and any potential emissions of 1 BP from this source category (Id. at 55892); Additional data that may improve the risk assessments and other analyses (Id. at 55899); Cost and benefit estimates for the proposed action (Id. at 55899); I" In contrast, the preamble to the Proposed Rule indicates that EPA began collecting and analysing relevant data as part of this rulemaking as early as 2016 88 Fcd Reg at 55,866 15 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00016 SC_EVERSPLIT0005690