Haverhill North Coke Facility is considered "HPV" - High Priority Violator by the USEPA

"The applicant (SunCoke) must certify that all existing major stationary sources owned or operated by the applicant (or any entity controlling, controlled by, or under common control with the applicant) in Ohio as the proposed major stationary source or major modification are in compliance with all applicable emission limitations and standards under the Clean Air Act (or are in compliance with an expeditious schedule which is federally enforceable or contained in a court decree."

Attached is a summary of six (6) Notices of Violation and one (1) warning letter issued by Portsmouth Air Agency to Haverhill North Coke Facility and two (2) USEPA NOV's issued.  To date, the 7/17/09 two NOV's and the two USEPA NOV's are unresolved.

On Friday, August 28, 2009, Sunoco issued a statement certifying that their facilities were in compliance in an attempt to satisfy this Clean Air Act requirement for the Middletown Coke NSR permit.  I've attached the letter for your review.

You can also visit the following EPA database to locate compliance information:

http://www.epa-echo.gov/echo/compliance_report_air.html

Summarized below is additional violation information for SunCoke, Sunoco and AK Steel:

Haverhill North Coke Facility

U.S. EPA’s Enforcement & Compliance History Online (“ECHO”) database reports that the Haverhill North facility has been a High Priority Violator (“HPV”) of Clean Air Act requirements since July 2008. HPV is the “most serious level of violation noted in EPA databases,”[1] and those violations are identified as unaddressed on the database. The ECHO report notes violations of PSD requirements at the facility for the last four quarters, and of the sulfur dioxide requirements for the current quarter.

Sunoco, Inc. Haverhill Facility (Sunoco is the parent company of SunCoke)

The U.S. EPA ECHO database reports that Sunoco’s Haverhill facility has been an HPV for the past 12 quarters (since October 2006). Violations at the facility are identified on the database as “unaddressed,” and include violations of MACT standards in the October to December 2006 and January to March 2007 quarters. U.S. EPA also issued a Clean Air Act Notice of Violation to Sunoco on September 29, 2005. Sunoco Oregon, Ohio Refinery On Nov. 15, 2007, U.S. EPA sent a Finding of Violation (“FOV”) to Sunoco due to violations of the National Emission Standards for Hazardous Air Pollutants (“NESHAPs”) at the company’s refinery in Oregon, Ohio.[2] The FOV alleged violations due to equipment leaks of hazardous organic compounds, in violation of the applicable NESHAPs, and the company’s failure to fix those leaks within 15 days of when they were detected.[3]

AK Steel Middletown Works

The U.S. EPA ECHO database reports that the AK Steel Middletown Works facility has been an HPV for the past 12 quarters (since October 2006). The violations have reportedly been addressed, but not yet resolved, through a formal enforcement action. In addition, the Ohio EPA has issued four Clean Air Act Notices of Violation, dated June 19, 2007, June 27, 2007, August 15, 2007, and October 6, 2008. In addition, on May 15, 2006, AK Steel entered into a consent decree dealing with Clean Air Act violations, which included a $230,000 penalty.

AK Steel Mansfield Works

According to the U.S. EPA ECHO database, the Ohio EPA issued a Clean Air Act Notice of Violation to AK Steel’s Mansfield facility on March 19, 2009. On December 20, 2006, Ohio EPA issued an NOV regarding violations of Title V permit limits on the emission of several pollutants from two electric arc furnaces at the Mansfield facility.[4] According to AK Steel’s most recent 10-Q filing with the U.S. Securities and Exchange Commission (“SEC”), the company is still working to resolve the NOV with the Ohio EPA.

http://www.middletownjournal.com/news/middletown-news/suncoke-certificat...

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Haverhill violations.xls20.5 KB
Sunoco Certification letter.pdf77.51 KB