SunCoke Energy, Inc. (SunCoke) and Haverhill North Coke Co. (Haverhill) Settlement

• Overview of Company
• Violations
• Injunctive Relief
• Pollutant Reductions
• Health and Environmental Benefits
• Supplemental Environmental Projects
• Civil Penalty
• Comment Period
• Contact

Overview of Company

SunCoke Energy, Inc. (SunCoke) and Haverhill North Coke Co. (Haverhill) own and operate the facility located in Franklin Furnace, Ohio. SunCoke and Gateway Energy & Coke Co. (Gateway) own and operate the facility located in Granite City, Illinois. SunCoke, Haverhill and Gateway are incorporated in the State of Delaware. SunCoke is also an owner of three other Non-Recovery Coking plants in the United States.  SunCoke and its partners are the only companies using the Non-Recovery Coking method in the United States.

The coke making process involves carbonization of coal at high temperatures to concentrate the carbon. Commercial coke is generally made in one of two ways: (1) By-Product Coking and (2) Non-Recovery/Heat Recovery Coking. A majority of the coke produced in the United States comes from By-Product Coking, where the coal is carbonized in large ovens and the off-gas is collected and processed to recover various carbon-based by-products, such as napthalene, benzene, toluene and xylene. 

In facilities using the Non-Recovery Coking process, the ovens are heated differently such that no external heat source is required. The volatile products from the coal are combusted with oxygen in the chamber providing heat from above, and gas flues in the bottom of the chamber collect the combustion gases and provide heat from below. The typical carbon-based pollutants from carbonizing the coal in the By-Product Coking process (e.g., benzene) are not present in the gas stream exiting the coke ovens because they are collected, recirculated to the oven, and combusted to provide heat. Because there are no coking by-products to recover, the process is called Non-Recovery Coking Process.

The gas stream from the Non-Recovery Coking process is vented through a stack to create a natural draft for the negative-pressure process. These gases cannot be sent directly to pollution control equipment because of the high temperatures. The gases are, however, sent to a waste heat recovery boiler, where cooling takes place, such that the gases can then continue to pollution control equipment such as flue gas desulfurization for sulfur control and bag houses for particulate control. The Non-Recovery Coking process offers advantages over the By-Product Coking process in that it reduces the coking cycle and results in better quality coke, if operated correctly.  

Violations

The majority of the violations at issue in this case resulted from chronic, excessive by-passing of the heat recovery steam generators (HRSGs) and emission control equipment during malfunctions, maintenance, or other operational problems. Both facilities’ permits contain a limited number of allowable bypass hours for each bypass stack (e.g., 192 hrs/yr/stack), along with hourly and yearly emission limits for SO₂, NOx, CO, PM, and lead. In addition, the Illinois permit contains emission limits for sulfuric acid and volatile organic compounds, while the Ohio permit contains emission limits for mercury and hydrochloric acid. Both the Illinois and Ohio facilities exceeded permit limits for hours of bypass and for the corresponding emissions of SO₂, PM, and lead.

Injunctive Relief

Under the proposed settlement, the Companies will install redundant HRSGs at the two facilities that will minimize the need to vent directly to the atmosphere when a problem occurs or maintenance is needed at a primary HRSG. The Companies estimate that the design and installation of the redundant HRSGs will cost approximately $100 million. The Companies are required to amend their permits to reflect the reduced bypass hours and emissions. In addition, the Companies must minimize emissions for all anticipated bypass vents by reducing the coal charge and sulfur content.  The Companies must also conduct a root cause analysis for all bypass venting lasting longer than a total of thirty minutes in a 24 hour period in order to ensure that bypass venting is limited to either planned maintenance or malfunctions. Bypass venting not associated with these causes may be subject to stipulated penalties if not in accordance with good engineering pollution control practices.  Finally, the Companies will install monitoring equipment at each facility to continuously monitor sulfur dioxide emissions from certain bypass vents, at an estimated cost of $700,000.

Pollutant Reductions

When fully implemented, EPA estimates that the actions required by the proposed consent decree will reduce emissions of SO₂ by approximately 1,204 tpy, PM by 131 tpy, and lead by 1,839 lbs/yr.  Other estimated emission reductions stemming from the injunctive relief embodied in the proposed consent decree include mercury (32 lbs/yr), hydrochloric acid (180 tpy), sulfuric acid (72 tpy), VOCs (3.4 tpy), nitrogen oxides (84 tpy), and carbon monoxide (16 tpy).  Furthermore, the installation of redundant HRSGs is reasonably expected to have a collateral impact on total greenhouse gases because both facilities sell electricity to the local grids. Currently, when bypassing occurs, the energy in the gas is wasted. Arguably, other fossil fuel burning facilities will likely have to compensate for energy loss, resulting in greater greenhouse gases to the atmosphere. 

Health and Environmental Benefits

Health and environmental impacts from the pollutants addressed in this settlement include the following:

• Particulate Matter – Particulate matter has been linked to a range of serious respiratory and cardiovascular health problems. The key effects associated with exposure to ambient particulate matter include: premature mortality, aggravation of respiratory and cardiovascular disease, aggravated asthma, acute respiratory symptoms, chronic bronchitis, decreased lung function, and increased risk of myocardial infarction. Recent epidemiologic studies estimate that exposures to particulate matter may result in tens of thousands of excess deaths per year, and many more cases of illness nation wide.

• Sulfur Dioxide – Sulfur dioxides can be converted to fine particulate matter once in the air. High concentrations of SO₂ affect breathing and may aggravate existing respiratory and cardiovascular disease. Sensitive populations include asthmatics, individuals with bronchitis or emphysema, children and the elderly. Sulfur dioxide is also a primary contributor to acid deposition, or acid rain.

• Lead - The effects of lead are the same whether it enters the body through breathing or swallowing. Lead can affect almost every organ and system in the body. The nervous system is the main target for lead toxicity, both in adults and children. Long-term exposure of adults can result weakness in extremities. Lead exposure also causes small increases in blood pressure, particularly in middle-aged and older people. Exposure to high lead levels can severely damage the brain and kidneys in adults or children and ultimately cause death. In pregnant women, high levels of exposure to lead may cause miscarriage. High level exposure in men can damage reproductive organs.

Supplemental Environmental Projects

The proposed settlement includes a lead abatement project at residential facilities surrounding the Gateway facility to reduce lead hazards in owner-occupied low-income residences with priority given to families with young children or pregnant women. The Companies must complete the lead abatement project within two years of the effective date of the proposed Consent Decree. 

Civil Penalty

The Companies have agreed to pay $1.995 million to resolve the claims in the complaint. The United States will receive a cash payment of $1.27 million. Illinois will receive a cash payment of $575,000. Ohio will receive a cash payment of $150,000. Under the settlement, the Companies must also spend at least $255,000 on a lead abatement project.   

Comment Period

The proposed settlement, lodged in the U.S. District Court for the Southern District of Illinois, East St. Louis Division, is subject to a 30-day public comment period and final court approval. Information on submitting comments is available at the Department of Justice website.

For more information, contact:

Gina Harrison
U.S. EPA Region 5
312-353-6956
Gina Harrison ([email protected])

Teresa Dykes
Senior Attorney
U.S. EPA
1200 Pennsylvania Ave. NW
Washington, DC 20460
202-564-9883
Teresa Dykes ([email protected])