Questions about additional air pollution restrictions
on proposed "U.S. Coking Group" plant

May 17, 2004

Mr. Christopher Jones, Director
Ohio EPA
122 S. Front St.
Columbus, OH 43215

Dear Director Jones,

Ohio EPA has acknowledged that it is seeking to issue the permit for the proposed U.S. Coking Group plant in Oregon, Ohio by June 15, 2004. If the permit were to be issued after that date, the plant would have to meet additional air pollution restrictions, which were designed to protect areas which are not meeting ozone attainment levels. As was evident at the public hearing held in Oregon on May 13, 2004, many people who live in the vicinity of the proposed plant are already suffering from the heavy levels of air pollution from current sources in their neighborhood.

Please answer the following questions:

What would be the difference between the level of emissions contained in the current draft permit, and the level of emissions which would be allowable if the permit were to be granted after June 15, 2004? Please compare the net affect on air pollution which would be allowed for the permit if issued before and after June 15, 2004, and list the types of emissions which are included.

If the permit for the FDS coking plant were to be issued after June 15, 2004, rather than before June 15, 2004, what additional procedures, such as emissions trading, would U.S. Coking Group have to undertake to comply with the new standards?

What technological changes would U.S. Coking Group be required to make if the permit were to be issued after June 15, 2004? What would be the effect of these changes on reducing emissions from the facility?

What would the cost be to U.S. Coking Group to make the needed technological changes to meet the standards for ozone non-attainment areas? Would this cost factor be a consideration in Ohio EPA's evaluation of whether to issue the permit before June 15, 2004?

I look forward to your reply. Please include this letter and my April 26, 2004 letter to you in the public comment file for the U.S. Coking Group proposed permit.


Sandy Buchanan
Executive Director