Document vLVnZ4kXgjymeOn6vqN9L9e6

'Ile redline versions of the Agency's proposed amendments to the current Subpart L and Subpart CCCCC include several new and revised terms and definitions. In the limited time SunCoke has had to comment on the Proposed Rule, SunCoke has evaluated the proposed redlines to 40 C.F.R. 63.301 and 63.7352, and asks the Agency to make the below-requested changes to both sections. SunCoke has not attempted to identify every error or mischaracterization in the below table, nor has SunCoke included errors or mischaractcrizations to the extent they are otherwise addressed earlier in these comments. An omission of an incorrect statement from this table is not an indication that SunCoke agrees with that error.' SunCoke also notes that in this rulcmaking. EPA uses a number of different terms to refer to its operations, including but not limited to "I INR," "heat and/or nonrecovery coke oven battery," "nonrecovery coke oven battery," "non-recovery," "heat/nonrecovery," "heat recovery," "I IN R facilities that have HRSCis," and "HNR facilities that do not have HRSCis," among other terms. SunCoke suggests retelling to its facilities as (1) heat recovery facilities (e.g., Haverhill, Granite City, Middletown, and Indiana harbor) or (2) non-recovery facilities (e.g., Jewell). EPA's Proposed Redlined Text I he redlined versions of the Proposed Rule's changes includes the following new term and definition: Bypass slack at a heat and/or nonrecovery facility means a stack that allows coke oven gas to be vented to the atmosphere and not through a heat recovery unit. I he redlined versions of the Proposed Rule's changes includes the following new term and definition: Heal and/or nonrecovery coke oven battery means a group of ovens connected by common walls, where coal undergoes destructive distillation under negative pressure to produce coke and coke oven gas from which by-products are not recovered. For nonrecovery plants (i.e., no chemical recovery) with heat recovery, the oven gases are sent to a heat recovery steam generator that produces steam. For nonrecovery coke oven batteries (i.e., no chemical recovery) without heat recovery, oven gases arc released to the atmosphere through waste heat stacks. bleat recovery coke oven batteries also may SunCoke's Response SunCokc suggests deleting this term and its definition because the term is already defined under the new proposed terni "heal recovery steam generator kipasslwasle heat stack" and because, as written, this definition for "bypass slack" is an inaccurate description of the equipment and the process. EPA appears to be trying to distinguish between heat recovery and non-recovery ovens within these definitions, however the definitions themselves do not actually provide differentiation. This proposed definition, as written, is duplicative of EPA's definition of "nonrecovery coke oven battery." If EPA believes a separate definition is warranted, this definition should be revised. Additionally, the proposed changes provide an inaccurate description of the equipment and the process. SunCokc requests revising this definition as follows: Heal and/or nonrecovety coke Oven battery means a group of ovens connected by common walls and a common tunnel after burner, where coal undergoes destructive ''SunCoke also requests the .Agency make the definition changes identified in SunCoke's Initial Comments for Coke Oven MACT RTR Proposed Rule, submitted on May 22, 2023 Sc'e Attachment II 52 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00053 SC_EVERSPLIT0005727