Terry Harris (Environmental Manager) SunCoke Energy Middletown Operations (MTO): Its First 2 years of Operation

WHO IS SUNCOKE ENERGY MTO? Originally named the “Middletown Coke Company” in its 2008 PTI application Plant was constructed on a greenfield site in the southern section of Middletown (on Yankee Road adjacent to Monroe) Construction commenced in February 2010 and the plant started-up on October 29,2011. Plant consists of 100 non-recovery metallurgical coke ovens, organized into 3 batteries along with coal/coke material handling equipment.

SunCoke Manufacturing Process MTO’s coke ovens have a proprietary design that enables them to produce coke with minimal HAP emissions (defined as MACT) Flue gases from the ovens are routed to Heat Recovery Steam Generators (HRSGs) to recover waste heat and produce superheated steam The superheated steam is sent to a steam turbine to generate electricity (up to 67 MW) The cooled flue gas is routed to a Flue Gas Desulfurization system for SO2, PM, Hg, and acid gas emissions control

SunCoke Video “Coke Manufacturing”

Major MTO challenges during its first 2 years of Operation Community Relations Operational Regulatory

Community Relations Challenges “NIMBY” syndrome with certain Monroe residents who live adjacent to MTO resulted in the formation of the “SunCoke Watch” organization. Plant construction was delayed to address various community concerns. MTO formed a Community Advisory Panel (CAP) which meets bi-monthly to maintain an active dialogue with its stakeholders. SunCoke Watch, Monroe, and the NRDC appealed OEPA’s issuance of MTO’s PTI. The appeal was eventually settled in July 2012. During its first year of operation, MTO was typically blamed for all odor and PM deposition nuisances that occurred in the area. MTO responded by implementing a progressive complaint investigation program to address all nuisance complaints it receives.

Operational Challenges Startup of Flue Gas Desulfurization System – 12/1/11 dusting event Process control system malfunctions 1/4/12 UPS trip: 6 days of intermittent bypass venting 3/2/12 Steam Turbine trip – 2 days of bypass venting Flue Gas Desulfurization system malfunctions 10/5/12 Spray Dryer Adsorber malfunction – 7 days of bypass venting HRSG malfunctions – most frequent type of malfunction MTO experience (HRSGs don’t have backups) Dust issues – MTO installed additional dust control equipment on its coke conveying system to reduce the potential for generating visible emissions Hg emission control issue - new system currently being installed to meet Hg emission control requirements

Regulatory Challenges High level of scrutiny from SWOAQA and OEPA Frequent agency visits & contacts Any deviation MTO experiences usually results in the issuance of a Notice of Violation by the agency Unsatisfactory environmental performance at other SunCoke locations SunCoke plants in Franklin Furnace, OH and Granite City, IL are subject to a consent decree with USEPA, OEPA, and IEPA which requires them to install redundant HRSGs to reduce their bypass venting MTO is on USEPA’s radar as a result of their performance

The Future MTO’s new Hg emission control system will be on-line in October MTO continues to make improvements in the reliability of its HRSGs MTO will continue to be a good neighbor that is responsive to community and regulatory issues.