On November 10, 2014, the Court entered a consent decree in this action resolving our Clean Air Act claims relating to excessive bypass venting brought against Defendants Gateway Energy & Coke Company, LLC, Haverhill Coke Company, LLC. Because operation of the Redundant HRSGs has exacerbated corrosion-related issues at the SDAs, Defendants must replate the SDAs to upgrade their metallurgy and to make them more corrosion-resistant, and assist in more effective operation of the SDAs. The Second Amendment would allow Defendants to use tie-in hours to address the corrosion at the SDAs and increase the number of available tie-in hours. Because the SDA Replating Project will result in additional emissions of SO2 and other pollutants beyond those anticipated under the consent decree, the proposed Second Amendment requires Defendants to: (1) meet even lower bypass venting emissions limits relating to SO2 at both coking facilities than were required by the consent decree, and seek to incorporate such lower limits into construction permits and Title V operating permits; and (2) continue to operate the flue gas desulfurization units (FGDs) at the two facilities to over-control SO2, particulate matter (?PM?), lead, and, as to the Ohio Facility, hydrochloric acid (HCl) emissions from the main stacks by, among other things, injecting excess lime slurry into the SDAs. The Second Amendment also requires that Defendants continue to operate the continuous emissions monitors (CEMS) required