FOIA ID Number: 2025-EPA-04883

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Summary Year FOIA ID Number Production ID Pages
Comments submitted by the Class of '85 Regulatory Response Group on the EPA's proposed revisions to the National Emission Standards for Hazardous Air Pollutants for coal- and oil-fired electric utility steam generating units, addressing compliance challenges with the revised fPM standard. 2018 2025-EPA-04883
0005922
1
The EPA's 2018 MATS RTR comments detail challenges in achieving continuous compliance with the revised fPM standard due to technological limitations and operational constraints, as noted by PGEN and other stakeholders. 2018 2025-EPA-04883
0005928
1
An interim release from the EPA dated September 10, 2025, discusses operational challenges and technological limitations faced by Kincaid units in meeting the revised fPM standard under the MATS rule, including compliance measurement issues with PM CEMS. 2018 2025-EPA-04883
0005932
1
Technical comments by Ralph L. Roberson on EPA's proposed Mercury and Air Toxics Standards, addressing the challenges of compliance with revised particulate matter standards and the unavailability of Continuous Emissions Monitoring Systems (CEMS) for coal-fired units, dated 2023. 2018 2025-EPA-04883
0005937
1
Comments submitted by PGLA on June 28, 2023, regarding the EPA's proposed Mercury and Air Toxics Standards Risk and Technology Review, highlight technological and cost barriers to compliance with the revised emissions limits for coal-fired units. 2018 2025-EPA-04883
0005949
1
The 2018 EPA report discusses the unavailability of Continuous Emissions Monitoring Systems (CEMS) for coal-fired units to meet revised particulate matter standards by July 2027 due to technological, cost, and market limitations. 2018 2025-EPA-04883
0005954
1
A letter from Otter Tail and co-owners requests a two-year exemption from MATS RTR standards for the Big Stone facility, citing technological unavailability of PM CEMS required for compliance, dated March 31, 2018. 2018 2025-EPA-04883
0005959
1
The 2018 EPA report discusses challenges faced by Big Stone Plant in meeting new PM standards due to limitations of PM Continuous Emission Monitoring Systems and the need for PM spiking services. 2018 2025-EPA-04883
0005960
1
Comments submitted by PGEN on June 28, 2023, regarding EPA's proposed NESHAP rule highlight significant financial and technological challenges in meeting stringent fPM standards, necessitating an extension for compliance. 2018 2025-EPA-04883
0005975
1
Talen Montana, LLC submitted comments on April 24, 2023, regarding EPA's proposed amendments to the National Emission Standards for Hazardous Air Pollutants, expressing concerns about the economic feasibility of compliance for the Colstrip Steam Electric Station. 2018 2025-EPA-04883
0006098
1
The 2018 report details the performance of venturi wet scrubbers at Colstrip Units 3 and 4, noting their inability to meet proposed SO2 emission limits and the limitations of upgrades to existing technology. 2018 2025-EPA-04883
0006101
1
EPA's 2018 proposal to tighten filterable particulate matter (fPM) limits disproportionately impacts the Colstrip facility, which would require new emissions control technology to comply with the proposed standard. 2018 2025-EPA-04883
0006110
1
A table prepared by Trinity Consultants outlines the cost effectiveness of installing a new baghouse at Colstrip, detailing emission reductions and costs based on EPA's post-IRA IPM model scenarios. 2018 2025-EPA-04883
0006125
1
A 2018 report discusses the challenges Colstrip, Montana faces in utilizing carbon capture and sequestration (CCS) due to high costs, lack of nearby sequestration sites, and the absence of necessary pipeline infrastructure. 2018 2025-EPA-04883
0006220
1
EPA's Cichanowicz Technical Report discusses the impact of higher sulfur content in lignite fuels on mercury emissions control at lignite plants, noting that Minnkota continues to use activated carbon injection without new developments since the MATS rule. 2018 2025-EPA-04883
0006373
1
Minnkota argues that compliance with the EPA's new fPM limit of 0.010 lb/MMBtu is unachievable and will cause immediate harm, as it necessitates costly upgrades to existing pollution control technologies. 2018 2025-EPA-04883
0006386
1
EPA's interim release dated September 10, 2025, discusses the agency's failure to incorporate relevant stack test data submitted by SunCoke in establishing MACT floor limits for emissions, citing the need for a rational connection between data and regulatory decisions. 2017 2025-EPA-04883
0005743
1
EPA's response to SunCoke's comments on Method 23 sampling volume and acceptable makeup water definitions, dated 2017, indicates insufficient adjustments to sampling requirements, raising safety and operational concerns for testing procedures. 2017 2025-EPA-04883
0005757
1
An internal communication from 2017 discusses the challenges faced by the Facility in managing higher concentration flows, the risks of an accelerated implementation schedule for new systems, and concerns regarding EPA's prohibition on bypass lines critical for process safety. 2017 2025-EPA-04883
0005845
1
The 2017 document from the EPA discusses national security implications of copper production, citing President Trump's acknowledgment of the U.S. copper reserves and the need for enhanced domestic smelting and refining capacity. 2017 2025-EPA-04883
0005914
1
The National Lime Association requested a two-year presidential exemption from compliance with the Lime Manufacturing Plants emissions standards set for July 16, 2027, citing the unavailability of technology and national security interests, in correspondence dated March 12, 2025. 2017 2025-EPA-04883
0006017
1
A 2017 EPA document discusses the environmental impacts of proposed emissions standards for lime kilns, arguing that compliance technologies would cause more harm than benefit, including increased greenhouse gas emissions and solid waste. 2017 2025-EPA-04883
0006023
1
Request for Presidential exemption from compliance dates for National Emission Standards for Hazardous Air Pollutants for lime manufacturing plants, submitted by the National Lime Association on March 12, 2025, citing technology unavailability and national security interests. 2017 2025-EPA-04883
0006048
1
EPA's 2017 analysis on lime kiln compliance with mercury standards indicates that necessary control technologies are currently unavailable, may cause environmental harm, and recommends a two-year extension for compliance. 2017 2025-EPA-04883
0006054
1
EPA's interim release for FOIA request 2025-EPA-04883 includes calculations and cost estimates related to fine particulate matter emissions and compliance measures for the Colstrip facility, dated 2017. 2017 2025-EPA-04883
0006126
1
A request dated January 10, 2025, from the National Lime Association to the EPA seeks a two-year exemption from compliance with emissions standards for lime manufacturing plants, citing technological infeasibility and national security concerns. 2017 2025-EPA-04883
0012691–0012700
10
A comment letter from SunCoke dated 2016 critiques the EPA's new MACT floor emission limits for IINR plants, arguing they are based on insufficient data and do not account for variability in coal composition. 2016 2025-EPA-04883
0005745
1
A 2016 EPA document argues that all SunCoke facilities should be classified as "existing sources" under the Clean Air Act, citing case law and challenging the agency's proposed emission limits for the Jewell facility as flawed and unachievable. 2016 2025-EPA-04883
0005694
1
Test report detailing 2016 ICR data from SunCoke Middletown facility, criticizing EPA's use of limited data and methodology for establishing MACT floor limits, dated November 2017. 2016 2025-EPA-04883
0005706
1
Email from SunCoke to the EPA regarding the proposed reconsideration of National Emission Standards for Hazardous Air Pollutants, expressing concerns about compliance requirements and the elimination of exemptions for startup, shutdown, and malfunction, dated July 12, 2016. 2016 2025-EPA-04883
0005726
1
A 2016 document critiques EPA's methods for establishing new emissions limits for heat non-recovery plants, arguing they are arbitrary and lack scientific merit due to reliance on inappropriate data sources and obsolete testing methods. 2016 2025-EPA-04883
0005744
1
EPA's proposed rule for benzene monitoring at coke oven facilities requires fenceline measurements and root cause analyses for exceedances, while excluding offsite emissions as outliers, contradicting CAA Section 112. 2015 2025-EPA-04883
0005715
1
EPA's interim release regarding FOIA ID 2025-EPA-04883 discusses SunCoke's concerns about the proposed benzene sampling frequency reduction to 0.3 ug/m3, arguing it could lead to inaccurate data and adverse monitoring implications. 2015 2025-EPA-04883
0005720
1
NorthWestern Energy's report outlines its dependence on market purchases for electricity during peak demand, noting rising prices and reduced availability due to recent closures of several power plants in Montana and the Pacific Northwest. 2015 2025-EPA-04883
0006149
1
NorthWestern Energy's report details its independent evaluation process for selecting proposals to meet short-duration power needs, including a 50 MW battery facility near Billings, while noting transmission limitations and the transition from being a net energy exporter following plant closures. 2015 2025-EPA-04883
0006151
1
Email correspondence from SunCoke to the EPA dated September 10, 2025, discusses the futility of fenceline monitoring at IINR facilities, citing a decade of data from the Haverhill facility and proposing revisions to the EPA's monitoring frequency requirements. 2014 2025-EPA-04883
0005719
1
Email correspondence dated September 10, 2025, discusses Ameren's request for a two-year compliance exemption from the MATS rule due to challenges in meeting new PM emissions standards and the associated costs of compliance technology. 2014 2025-EPA-04883
0005799
1
EPA correspondence discusses Colstrip's particulate matter Continuous Emissions Monitoring System (PM CEMS) challenges, including variability issues and compliance monitoring requirements under its Title V Operating Permit, dated September 2020. 2014 2025-EPA-04883
0006122
1
The 2012 report details Minnkota's mercury control strategies, including the use of Potassium Iodide fuel additives and non-halogenated PAC injection at the Young Station, which combusts lignite coal sourced from BNI Coal Inc. 2012 2025-EPA-04883
0006368
1
The U.S. Environmental Protection Agency (EPA) amended testing requirements in 40 CFR 63 Subpart UCUCU, increasing PM sampling volume for PM CEMS correlation validation, as discussed in comments submitted by GVEA regarding compliance challenges with new emission standards. 2012 2025-EPA-04883
0005598
1
SunCoke submitted a Petition for Reconsideration and Stay Pending Reconsideration to the EPA on September 10, 2025, arguing that the agency failed to provide adequate notice and opportunity for public comment on the Final Rule, violating the Administrative Procedure Act. 2012 2025-EPA-04883
0005738
1
A 2012 communication from Luminant argues for exemptions from the MATS rule's revised PM standard and CEMS requirements, citing national security concerns related to energy generation capacity and grid reliability, referencing President Trump's Executive Orders 14154 and 14156. 2012 2025-EPA-04883
0005923
1
EPA's interim release dated September 10, 2025, discusses Oak Grove Management's request for a two-year exemption from the MATS RTR mercury standard, citing unavailability of required technology and national security interests. 2012 2025-EPA-04883
0005926
1
Cynthia Vodopivec, Senior Vice President of Environmental, Health & Safety at Sierra Club, submitted comments regarding the MATS RTR's impact on energy generation and national security, referencing President Trump's Executive Orders 14154 and 14156, on September 10, 2025. 2012 2025-EPA-04883
0005929
1
Comments submitted by Luminant regarding the MATS rule highlight significant costs and market limitations associated with compliance, emphasizing the national security implications of energy generation capacity and grid reliability as outlined in President Trump's Executive Orders. 2012 2025-EPA-04883
0005933
1
Comments submitted to the EPA regarding the MATS RTR highlight concerns over the reliability and cost of PM Continuous Emissions Monitoring Systems (CEMS) and argue for national security exemptions from compliance due to potential impacts on energy generation and grid stability. 2012 2025-EPA-04883
0005938
1
Comments submitted by Luminant regarding the MATS RTR emphasize the national security implications of compliance costs and the potential impact on energy generation capacity and grid reliability, referencing Executive Orders from January 2025. 2012 2025-EPA-04883
0005950
1
Cynthia Vodopivec, Senior Vice President of Environmental Health and Safety at Sierra Club, submitted a request for exemptions from the MATS RTR on September 10, 2025, citing national security concerns regarding energy generation and grid reliability. 2012 2025-EPA-04883
0005955
1
Indorama's compliance request for a four-year extension to meet emission control standards at its Port Neches Facility, citing the need for additional time and referencing EPA's statutory authority under 42 U.S.C. 7412. 2012 2025-EPA-04883
0006003
1
Hugo Generating Station submitted a 2012 Presidential Exemption Request to the EPA, arguing that compliance with the Final Rule's continuous monitoring requirements for fPM emissions is infeasible due to technology limitations and emphasizing the importance of energy grid reliability. 2012 2025-EPA-04883
0006060
1
EPA's 2012 proposal to tighten the surrogate fPM emission standard for coal-fired EGUs from 0.030 lb/MMBtu to 0.010 lb/MMBtu lacks sufficient basis as it does not identify new control technologies or practices, violating statutory authority under 42 U.S.C. 7412(d)(6). 2012 2025-EPA-04883
0006105
1
NorthWestern Energy reported limited available transmission capacity for imports on Path 80 and Path 18, with ongoing challenges in managing generation and loads as of February 23, 2023. 2012 2025-EPA-04883
0006154
1
NorthWestern Energy's 2012 report details the indefinite postponement of the Mountain States Transmission Intertie project due to permitting challenges, alongside anticipated costs for compliance with proposed regulations affecting the Colstrip facility. 2012 2025-EPA-04883
0006157
1
Overview of the Mercury and Air Toxics Standards (MATS) since the 2012 final rule, including emissions changes, benefits, and costs, as part of FOIA request 2025-EPA-04883. 2012 2025-EPA-04883
0006300
1
The 2012 MATS mercury emission limitation allowed lignite power plants to manage higher mercury emissions due to variable coal quality, as noted in the EPA FOIA record 2025-EPA-04883. 2012 2025-EPA-04883
0006371
1
EPA's assessment indicates that lignite units may not meet the New Mercury Limitation of 1.2 lb/TBtu, while citing the effectiveness of brominated activated carbon for achieving over 90 percent mercury control, referencing a 2012 memorandum and a technical publication. 2012 2025-EPA-04883
0006374
1
Email from EPA regarding the Presidential Exemption under Section 112 of the Clean Air Act for San Miguel Electric Cooperative, Inc., detailing emission standards, compliance challenges, and technical feasibility issues related to mercury and particulate matter emissions. 2011 2025-EPA-04883
0025040–0025043
4
The 2011 technical memorandum critiques EPA's assumptions regarding emissions reductions and cost estimates for the Jewell facility, asserting significant underestimations and methodological errors in calculating necessary capital investments and operational efficiencies. 2011 2025-EPA-04883
0005698
1
SunCoke's comments on EPA's proposed MACT floor regulations detail anticipated costs exceeding $474.9 million for capital investments and $66 million annually, citing the need for extensive testing and modifications to comply with new HAP emission limits. 2011 2025-EPA-04883
0005766
1
Robert McLennan, President and CEO of Minnkota Power Cooperative, submitted a declaration detailing his qualifications and responsibilities in support of a motion for a stay pending review, dated 2011. 2011 2025-EPA-04883
0006362
1
The 2010 report from Minnkota details testing results indicating that brominated powdered activated carbon (PAC) does not effectively reduce mercury emissions to meet the EPA's New Mercury Limitation of 1.2 lb/TBtu at the Young Station. 2010 2025-EPA-04883
0006316
1
Minnkota's report details the inability of Units 1 and 2 to meet the New Mercury Limitation under the revised MATS RTR, citing insufficient technology and the need for significant investment in further testing and equipment. 2010 2025-EPA-04883
0006317
1
The ACI Fuel 2010 Article presents a chart of mercury removal test results from DOE systems, noting limitations in data representation and concluding that achieving over 90% mercury removal across the lignite industry is unsupported. 2010 2025-EPA-04883
0006375
1
An interim release from the EPA dated 2010 indicates that Minnkota's recent testing results show MRY cannot meet the New Mercury Limitation at full load, with projected mercury removal rates significantly below EPA's expectations. 2010 2025-EPA-04883
0006378
1
The Hugo Generating Station's MATS Presidential Exemption Request from WFEC outlines challenges in meeting the revised fPM emissions standard by 2027 due to unavailable technology and operational variability, dated September 10, 2025. 2009 2025-EPA-04883
0006058
1
A 2007 EPA document discusses the agency's failure to propose standards for eight unregulated hazardous air pollutants (HAP) and critiques its arbitrary setting of MACT floor limits, as argued by SunCoke in a petition likely to succeed on the merits. 2007 2025-EPA-04883
0005764
1
EPA correspondence dated 2007 discusses the economic impacts and national security interests related to compliance exemptions for Freeport-McMoRan's Miami Smelter under the Clean Air Act's Copper Rule. 2007 2025-EPA-04883
0005913
1
EPA memorandum discusses the insignificance of HAP and mercury emissions from SunCoke's pushing operations, arguing against the need for additional emission limits or testing due to their de minimis nature. 2006 2025-EPA-04883
0005703
1
EPA's analysis of SunCoke's proposed emission limits for HRSG bypass/waste heat stacks indicates that the limits are based on an inadequate data set and may not be achievable due to technical and spatial constraints at the plants. 2006 2025-EPA-04883
0005709
1
On January 10, 2005, the EPA finalized provisions related to SunCoke's heat-recovery cokemaking technology, which has consistently met emissions standards, while also detailing ongoing information collection requests and proposed amendments to regulations affecting coke oven source categories. 2005 2025-EPA-04883
0005683
1
A 2005 EPA document discusses the ambiguity in proposed amendments regarding the classification of SunCoke facilities as 'existing' or 'new' sources under the Clean Air Act, emphasizing the need for clarity in regulatory standards. 2005 2025-EPA-04883
0005692
1
EPA's April 15, 2005 Federal Register notice discusses the application of new source standards for emissions, clarifying that only facilities constructed after the proposal date would be considered 'new sources' under the Clean Air Act. 2005 2025-EPA-04883
0005693
1
SunCoke's communication to the EPA on September 10, 2025, requests a three-year extension for compliance with proposed emissions standards due to installation challenges and inadequate evaluation time for the ACI system at the Haverhill facility. 2005 2025-EPA-04883
0005708
1
EPA document discusses operational differences between heat recovery (HNR) and byproduct (ByP) coke oven facilities, emphasizing emissions control and health impacts, dated August 9, 2004, under FOIA ID 2025-EPA-04883. 2004 2025-EPA-04883
0005686
1
EPA's interim release dated August 16, 2023, critiques the agency's proposed MACT standards under CAA Section 112, arguing that the measures are arbitrary and capricious, lacking demonstration of achievability and proper cost consideration. 2004 2025-EPA-04883
0005695
1
A 2014 letter from the Ohio EPA to Haverhill Coke Company confirmed the termination of HAP and VOC monitoring requirements due to demonstrated minimal impact on ambient levels, as outlined in FOIA request 2025-EPA-04883. 2004 2025-EPA-04883
0005718
1
SunCoke's comments on EPA's proposed rule changes argue against new opacity limits and pressure monitor requirements, citing excessive costs and lack of necessity, while asserting compliance with existing standards. 2004 2025-EPA-04883
0005724
1
EPA's 2004 National Emission Standards for Hazardous Air Pollutants for Lime Manufacturing Plants established regulations to protect public health by reducing emissions of hazardous air pollutants, concluding that no new regulations were necessary based on scientific evaluations. 2004 2025-EPA-04883
0006018
1
NIA's comments on the EPA's Lime Rule, dated 2023, argue that the rule's compliance costs exceed $2 billion for the lime industry, with necessary control technologies unavailable by the July 16, 2027 compliance date. 2004 2025-EPA-04883
0006019
1
EPA's 2004 National Emission Standards for Hazardous Air Pollutants for Lime Manufacturing established regulations to protect public health by reducing hazardous air pollutant emissions, with no challenges from the industry or environmental groups. 2004 2025-EPA-04883
0006049
1
EPA's 2004 assessment indicates that no cost-effective technology is available to implement the Lime Rule standards, estimating compliance costs at $2.4 billion over 20 years, with significant concerns raised by the Small Business Administration regarding feasibility. 2004 2025-EPA-04883
0006050
1
A 2003 report details SunCoke's significant role in the U.S. foundry coke market, producing 31% of the supply and employing 887 workers, while warning that proposed EPA regulations could harm domestic steel production and local economies. 2003 2025-EPA-04883
0005681
1
EPA memorandum discusses the inadequacy of using ByP facility data to set emission limits for SunCoke's HNR facilities, arguing that the proposed MACT limits do not account for significant operational differences, dated May 1, 2023. 2003 2025-EPA-04883
0005704
1
Proposed performance testing requirements for IICN emissions from pushing are deemed unfeasible due to challenges with FTIR equipment on mobile hot cars, as outlined in a memorandum dated July 1, 2023, under FOIA ID 2025-EPA-04883. 2003 2025-EPA-04883
0005710
1
EPA's 2003 assessment criticized its benzene action level of 3ug/m3 as arbitrary and technically flawed, lacking correlation to actual risk metrics and ignoring significant variability in short-term fenceline concentrations. 2003 2025-EPA-04883
0005717
1
SunCoke requested a two-year exemption from compliance with new MACT floor emission limits for pushing emissions under the Coke Ovens Rule, citing technological infeasibility due to the unique configuration of its facilities, in correspondence dated October 2, 2023. 2002 2025-EPA-04883
0005655
1
SunCoke requested a two-year exemption from compliance with new MACT floor emission limits for pushing emissions under the Coke Ovens Rule, citing technological infeasibility due to the unique configuration of its facilities, in correspondence dated September 3, 2024. 2002 2025-EPA-04883
0005669
1
Memorandum from the EPA dated May 1, 2002, details the coking cycle processes at SunCoke's plants, including emissions control measures and water usage standards. 2002 2025-EPA-04883
0005684
1
EPA's 2002 review of coke oven emissions standards argues against the necessity of proposed oven pressure monitoring, citing a lack of evidence for its effectiveness and questioning the need for changes to existing practices. 2002 2025-EPA-04883
0005722
1
SunCoke Energy, Inc. submitted a petition for reconsideration and stay of the EPA's final rule on National Emission Standards for Hazardous Pollutants for coke ovens, citing significant financial impacts and lack of measurable air quality benefits, under FOIA ID 2025-EPA-04883. 2002 2025-EPA-04883
0005735
1
A 2002 comment letter from SunCoke to the EPA requests revisions to definitions and emission limits in 40 C.F.R. 63 regarding coke oven operations, emphasizing inconsistencies and the need for clarity in regulatory language. 2002 2025-EPA-04883
0005759
1
EPA FOIA record 2025-EPA-04883 details emissions reductions of 60% for MRY Units 1 and 2 since 2002, describing their configurations and control technologies including SNCR, wet scrubbers, and ESPs. 2002 2025-EPA-04883
0006367
1
A 2001 document from the EPA discusses SunCoke's concerns regarding the Proposed Rule's compliance costs and its impact on coke production, emphasizing the company's environmental performance and the inadequacy of the 45-day comment period. 2001 2025-EPA-04883
0005677
1
EPA correspondence discusses the regulatory treatment of Heat Non-Recovery (HNR) and By-Product (ByP) coke oven facilities, advocating for their classification as separate subcategories due to differences in emissions characteristics and operational processes, dated from 2001. 2001 2025-EPA-04883
0005688
1
Attachment A outlines emission limitations and compliance deadlines for affected sources at coke plants, specifying conditions for new and existing sources under EPA regulations 63.7282 and 63.7283. 2001 2025-EPA-04883
0005771
1
Contact information for Jeff Holmstead, a partner at Bracewell LLP, including email and phone number, is provided in a confidential message related to Sierra Club FOIA request 2025-EPA-04883. 2001 2025-EPA-04883
0005831
1
Technical memo detailing annual costs of control options at Colstrip to meet the proposed 0.010 lb/MNIBtu fPMI limit, including capital and annualized costs based on specific assumptions and factors. 2001 2025-EPA-04883
0006116
1
Contact information for Jeff Holmstead, a partner at Bracewell LLP, including email, phone numbers, and office address, is provided in relation to Sierra Club FOIA request 2025-EPA-04883. 2001 2025-EPA-04883
0006407
1
On September 10, 2001, Jeffrey R. Holmstead of Bracewell LLP requested a two-year extension for DPE's compliance with CAA Section 112 standards for its Neoprene Production Facility in LaPlace, Louisiana, under FOIA ID 2025-EPA-04883. 2001 2025-EPA-04883
0006421
1
A 2000 communication from SunCoke to the EPA critiques the agency's MACT floor limits for hazardous air pollutants, arguing they are unachievable and requesting reconsideration under CAA section 307(d)(7)(B). 2000 2025-EPA-04883
0005742
1