Document vV5wdROo7j3LGg3REmJRVZy7q

I he redlined versions of the Proposed Rule's changes includes the following new term and definition: -I-he proposed changes provide an inaccurate description of the equipment and the process. SunCoke requests revising this term and the definition as follows: Heal recovery steam generator main stack means the exhaust stack from a I IRSG that is the point of final discharge to the atmosphere of the gases emanating from a HRSG and any auxiliary processes, if present. Ikilt recovery steam generator m-Main stack means the exhaust stack from a IIRSG that is the point of final discharge to the atmosphere of the flue gases emanating from a heat recovery facilityFIRSG and any auxiliary processes, if present. the redlined versions of the Proposed Rule's changes includes the following revised definition for "nonrecovery coke oven battery": -I-he proposed changes provide an inaccurate description of the equipment and the process. SunCoke requests revising this definition as follows: Nonrecovery coke oven battery means a group of ovens connected by common walls and operated as a unit, where coal undergoes destructive distillation under negative pressure to produce coke, and which is designed for the combustion of the coke oven gas from which by-products are not recovered. Also known as heatinonrecovery. Nonrecovery coke oven battery refers to units from which heat is recovered from the coke oven gas exhaust as well as units where heat is not recovered. Nonrecovery coke oven battery means a group of ovens connected by common walls and a common tunnel after burner operated as a unit, where coal undergoes destructive distillation under negative pressure to produce coke, and which is designed for the combustion of the coke oven gas from which by-products arc not recovered. Also known as heatinonrecovery. Nonrecovery coke oven battery refers to units from which heat is recovered from the combusted coke oven gas exhaust [i.e., flue p,as.) as well as units where heat is not recovered. The redlined versions of the Proposed Rule's changes includes the following new term and definition: Waste heal stack at a heat and/or nonrecovery facility means a stack that allows coke oven gas to be vented directly to the atmosphere without control and where there are no units available for heat recovery. SunCoke requests deleting this term and its definition because the term is already defined under the new proposed U.= "heal recovery steam generator bypassA,vasie heat stack" and because, as written, this definition for "waste heat stack" is an inaccurate description of the equipment and process. XVII. CONCLUSION In closing, SunCoke would like to express that if the Proposed Rule is finalized as written, the rule would impose onerous new limits and requirements that are unnecessary for environmental 54 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00055 SC_EVERSPLIT0005729