Document x1dBR49371ZXzwbJQjZvwK2mg

draft bypass vent stacks can be used to vent the hilly comhusied flue gases to the atmosphere. These stacks arc typically open for established limited periods during the year such that the lids arc closed the majority of the time. 1. LIN R Coke Ovens and ByP Coke Ovens are Fundamentally Different The design and operation of SunCoke's cokemaking process is so fundamental and unique that SunCoke's facilities should not be compared to ByPs. EPA nevertheless appears to confuse SunCoko's cokomaking process with that of byproduct coke manufacturing. This leads to several inaccuracies in EPA's development of the proposed emissions limits, proposed benzene fenccline monitoring work practices, and other portions of. the Proposed Rule. For example, in the Proposed Rule, EPA makes the following mischaractori7ations of the coking process at both types of coke oven The process begins when a batch of coal is discharged from the coal bunker into a larry car (i.o., charging vehicle that moves along the top of the battery). The tarry car is positioned over the empty, hot oven; the lids on the charging ports arc removed; and the coal is discharged from the hoppers of the larry car into the oven. . . . This process takes place at two types of facilities: (1) by-product recovery (ByP) facilities, where chemical byproducts are recovered from coke oven emissions (COE) in a co-located coke byproduct chemical recovery plant (CBRP); or (2) heat and nonrecovery, or only nonrecovery with no heat recovery (HNR) facilities, whore chemicals are not recovered but heat may be recovered from the exhaust from coke ovens in a heat recovery steam generator (IIRSG). 88 Fed. Reg. 55858, 55863 (Aug. 16, 2023). These statements arc false for several reasons, including: 11NR cokomaking does not use a tarry car; does not have a car of any kind on top of the battery; transfers coal via conveyor bolts instead of cars; and has a different coking cycle timeframe than that described by EPA. The two cokemaking processes are fundamentally different and must be evaluated as such in this rulcmaking. PrCG:uri[.lt ion Air ErfrISI.rarK SunCoke Heat Recovery Haza.,dOuS Inputs , . Voi.at le Organ c Compounds I J Solid Wastes Wastewater r',J J Traditional By-Product `. JC,bb p I p J 10 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000109-00011 SC_EVERSPLIT0005685