SunCoke Energy, Inc.
−Removed: (“SunCoke Energy,” “SunCoke,” “Company,” “we,” “our” and “us”) is the largest independent producer of high-quality coke in the Americas, as measured by tons of coke produced each year, and has over 55 years of coke production experience.
+Added: (“SunCoke Energy,” “SunCoke,” “Company,” “we,” “our” and “us”) is the largest independent producer of high-quality coke in the Americas, as measured by tons of coke produced each year, and has more than 60 years of coke production experience.
Coke is a principal raw material in the blast furnace steelmaking process and is produced by heating metallurgical coal in a refractory oven, which releases certain volatile components from the coal, thus transforming the coal into coke.
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Cokemaking Operations
−Removed: The following table sets forth information about our cokemaking facilities:
−Removed: Annual Cokemaking Nameplate
−Removed: (thousands of tons)
−Removed: Use of Waste Heat
−Removed: Owned and Operated:
−Removed: Vansant, Virginia
−Removed: December 2020
−Removed: Partially used for thermal coal drying
−Removed: Indiana Harbor
−Removed: East Chicago, Indiana
−Removed: Heat for power generation
−Removed: Haverhill Phase I
−Removed: Franklin Furnace, Ohio
−Removed: December 2020
−Removed: Process steam
−Removed: Haverhill Phase II
−Removed: Franklin Furnace, Ohio
−Removed: December 2021
−Removed: Power generation
−Removed: Granite City, Illinois
−Removed: December 2024
−Removed: Steam for power generation
−Removed: Middletown (1)
−Removed: Middletown, Ohio
−Removed: December 2032
−Removed: Power generation
−Removed: Vitória, Brazil
−Removed: ArcelorMittal Brazil
−Removed: Steam for power generation
−Removed: Cokemaking nameplate capacity represents stated capacity for production of blast furnace coke.
−Removed: Middletown production and sales volumes are based on “run of oven” capacity, which includes both blast furnace coke and small coke.
−Removed: Using the stated capacity, Middletown nameplate capacity on a “run of oven” basis is approximately 578 thousand tons per year.
We are a technological leader in cokemaking.
−Removed: We have designed, developed, built, own and operate five cokemaking facilities in the United States (“U.S.”) with collective nameplate capacity to produce approximately 4.2 million tons of coke per year.
+Added: We have designed, developed, built, own and operate five cokemaking facilities in the United States (“U.S.”) with collective nameplate capacity to produce approximately 4.2 million tons of blast furnace coke per year.
Additionally, we have designed and operate one cokemaking facility in Brazil under licensing and operating agreements on behalf of ArcelorMittal Brasil S.A.
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in approximately 30 years and are the only North American coke producer that utilizes heat recovery technology in the cokemaking process.
+Added: To diversify our business and customer base, SunCoke began exploring the foundry coke market in 2020.
+Added: Foundry coke is a high-quality grade of coke that is used at foundries to melt iron and various metals in cupola furnaces, which is further processed via casting or molding into products used in various industries such as construction, transportation and industrial products.
+Added: Throughout 2020, we tested production capacity and executed successful test sales of foundry coke.
+Added: We will begin to produce and sell foundry coke on a commercial scale in 2021, but not at a level that will be material to our operations.
+Added: Therefore, the discussion that follows is specific to blast furnace coke ("coke"), our main operation.
We believe our advanced heat recovery cokemaking process has numerous advantages over by-product cokemaking, including producing higher quality coke, using waste heat to generate derivative energy for resale and reducing the environmental impact.
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Steel") and Haverhill I provides steam, at minimal cost, to Altivia Petrochemicals, LLC.
−Removed: Our Middletown facility and the second phase of our Haverhill facility, or Haverhill II, have cogeneration plants that use the hot flue gas created by the cokemaking process to generate electricity, which either is sold into the regional power market or to AK Steel Holding Corporation ("AK Steel") pursuant to energy sales agreements.
+Added: Our Middletown facility and the second phase of our Haverhill facility, or Haverhill II, have cogeneration plants that use the hot flue gas created by the cokemaking process to generate electricity, which either is sold into the regional power market or to Cleveland-Cliffs Steel Holding Corporation pursuant to energy sales agreements.
Our core business model is predicated on providing steelmakers an alternative to investing capital in their own captive coke production facilities.
We direct our marketing efforts principally towards steelmaking customers that require coke for use in their blast furnaces.
−Removed: Substantially all of our coke sales are made pursuant to long-term, take-or-pay agreements with ArcelorMittal USA LLC and/or its affiliates (“AM USA”), AK Steel and U.S.
−Removed: Steel, who are three of the largest blast furnace steelmakers in North America, each of which individually accounts for greater than ten percent of our consolidated revenues.
−Removed: The take-or-pay provisions require us to produce the contracted volumes of coke and require our customers to purchase such volumes of coke up to a specified tonnage or pay the contract price for any tonnage they elect not to take.
+Added: Substantially all of our coke sales are made pursuant to long-term, take-or-pay agreements, which require us to produce the contracted volumes of coke and require our customers to purchase such volumes of coke up to a specified tonnage or pay the contract price for any tonnage they elect not to take.
As a result, our ability to produce the contracted coke volume is a key determinant of our profitability.
−Removed: We generally do not have significant spot coke sales since our domestic capacity is consumed by long-term contracts;
−Removed: accordingly, spot prices for coke do not generally affect our revenues.
−Removed: To date, our coke customers have satisfied their obligations under these agreements.
−Removed: Our coke sales agreements contain pass-through provisions for costs we incur in the cokemaking process, including coal and coal procurement costs, subject to meeting contractual coal-to-coke yields, operating and maintenance expenses, costs related to the transportation of coke to our customers, taxes (other than income taxes) and costs associated with changes in regulation.
+Added: Our domestic capacity is largely consumed by long-term contracts.
+Added: With the exception of 400 thousand tons in 2021 and 800 thousand tons in 2022, our 4.2 million tons of domestic cokemaking capacity will be produced under long-term contracts.
+Added: Accordingly, spot prices for coke do not significantly affect our revenues.
+Added: Historically, substantially all of our coke sales were made under long-term, take-or-pay agreements with three primary customers in the U.S.:
+Added: ArcelorMittal USA LLC ("AM USA"), AK Steel Holding Corporation ("AK Steel") and United States Steel Corporation ("U.S.
+Added: Steel"), each of which individually accounted for greater than ten percent of our consolidated revenues.
+Added: In March 2020, Cleveland-Cliffs Inc.
+Added: ("Cliffs"), a leading producer of iron ore pellets, completed the acquisition of AK Steel, and subsequently changed the name of AK Steel to Cleveland-Cliffs Steel Holding Corporation.
+Added: In December 2020, Cliffs completed the acquisition of AM USA, and subsequently changed the name of AM USA to Cleveland-Cliffs Steel LLC.
+Added: Collectively, we refer to Cleveland-Cliffs Steel Holding Corporation and Cleveland-Cliffs Steel LLC as "Cliffs Steel."
+Added: Our contracts with each entity were not impacted by the transactions that occurred in 2020.
+Added: Contracts with Cliffs Steel are expected to account for approximately 75 percent of our domestic cokemaking capacity in 2021 and approximately 65 percent of our domestic cokemaking capacity in 2022.
+Added: The following table sets forth information about our cokemaking facilities:
+Added: Facility Location Customer Year of
+Added: Start Up Contract
+Added: Expiration Number of
+Added: Coke Ovens Annual Cokemaking Nameplate
+Added: (thousands of tons)
+Added: Use of Waste Heat
+Added: Owned and Operated:
+Added: Jewell Vansant, Virginia
+Added: Cliffs Steel 1962 December 2025 (3)
+Added: 142 720 Partially used for thermal coal drying
+Added: Indiana Harbor East Chicago, Indiana
+Added: Cliffs Steel 1998 October 2023 268 1,220 Heat for power generation
+Added: Haverhill I Franklin Furnace, Ohio
+Added: Cliffs Steel 2005 December 2025 (3)
+Added: 100 550 Process steam
+Added: Haverhill II Franklin Furnace, Ohio
+Added: Cliffs Steel 2008 June 2025 (4)
+Added: 100 550 Power generation
+Added: Granite City Granite City, Illinois
+Added: Steel 2009 December 2024 120 650 Steam for power generation
+Added: Middletown (2)
+Added: Middletown, Ohio
+Added: Cliffs Steel 2011 December 2032 100 550 Power generation
+Added: Total 830 4,240
+Added: Vitória Vitória, Brazil ArcelorMittal Brazil 2007 January 2023 320 1,700 Steam for power generation
+Added: Total 1,150 5,940
+Added: (1) Cokemaking nameplate capacity represents stated capacity for production of blast furnace coke.
+Added: The minimum tons in our coke sales agreements may be lower than the annual cokemaking nameplate capacity.
+Added: (2) The Middletown coke sales agreement provides for coke sales on a “run of oven” basis, which includes both blast furnace coke and small coke.
+Added: Middletown nameplate capacity on a “run of oven” basis is 578 thousand tons per year.
+Added: (3) In July 2020, the Jewell and Haverhill I contracts with AM USA, now known as Cliffs Steel, were amended to extend the contract expiration date from December 2020 to December 2025.
+Added: Under the contract amendments, Jewell and Haverhill I will supply a combined 800 thousand tons for the 2021 contract year and a combined 400 thousand tons annually for the 2022 through 2025 contract years.
+Added: See "Management's Discussion and Analysis Financial Condition and Results of Operations" for further discussion on contract amendments.
+Added: Each facility will continue to operate at full capacity.
+Added: The remaining capacity from Jewell and Haverhill I is expected to be sold into the spot market and/or the foundry coke market.
+Added: (4) In July 2020, the Haverhill II contract with Cliffs Steel was amended to extend the contract expiration date from December 2021 to June 2023.
+Added: In October 2020, the contract expiration date was further extended to June 2025.
+Added: The energy supply agreement, whereby Cliffs Steel purchases electricity produced from the Haverhill II cogeneration plant, will expire in December 2021.
+Added: See "Management's Discussion and Analysis Financial Condition and Results of Operations" for further discussion on contract amendments.
+Added: Our coke sales agreements contain pass-through provisions for costs we incur in the cokemaking process, including coal and coal procurement costs, subject to meeting contractual coal-to-coke yields, operating and maintenance expenses,
+Added: costs related to the transportation of coke to our customers, taxes (other than income taxes) and costs associated with changes in regulation.
When targeted coal-to-coke yields are achieved, the price of coal is not a significant determining factor in the profitability of these facilities, although it does affect our revenue and cost of sales for these facilities in approximately equal amounts.
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These features of our coke sales agreements reduce our exposure to variability in coal price changes and inflationary costs over the remaining terms of these agreements.
−Removed: The coal component of the Jewell coke price is typically fixed annually for each calendar year based on the weighted-average contract price of third-party coal purchases at our Haverhill facility applicable to AM USA coke sales.
+Added: The coal component of the Jewell coke price is typically fixed annually for each calendar year based on the weighted-average contract price of third-party coal purchases at our Haverhill facility applicable to Cliffs Steel coke sales.
Our coke prices include both an operating cost component and a fixed fee component.
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The actual return on invested capital at any facility is based on the fixed fee per ton and favorable or unfavorable performance on pass-through cost items.
−Removed: Our steelmaking customers continue to operate in a challenging environment.
−Removed: Imports of finished steel have decreased from approximately 23 percent of domestic steel consumption in 2018 to approximately 19 percent of domestic steel consumption in 2019.
−Removed: Lower imports were replaced by higher production from domestic steel producers.
−Removed: However, the overall profitability of steel producers was affected by downward pressure on steel price.
−Removed: Steel restarted both of the blast furnaces at its Granite City Works facility during 2018, in 2019, it announced it will temporarily idle two other blast furnaces in the U.S.
−Removed: Despite these challenging conditions, our customers continue to accept tons in excess of
−Removed: our contract minimums, and due to the take-or-pay nature of our contracts with our customers, the lower prices did not have an impact on our full-year results.
−Removed: In December 2019, Cleveland-Cliffs, a leading producer of iron ore pellets, announced its intent to acquire AK Steel.
−Removed: The transaction is expected to close in 2020, and we do not currently anticipate any impact to our contracts at Haverhill or Middletown.
−Removed: Our Brazil cokemaking operations are located in Vitoria, Brazil, where we operate our ArcelorMittal Brazil cokemaking facility for a Brazilian subsidiary of ArcelorMittal S.A.
+Added: Steelmaking customers faced significant challenges earlier in the year resulting from the novel coronavirus pandemic ("COVID-19").
+Added: In response to the decline in end user demand, as well as in an effort to slow the spread of COVID-19, in March 2020, end user manufacturers began idling plants, which directly and adversely impacted our customers.
+Added: As a result, the U.S.
+Added: steel production utilization rate declined approximately 25 percent during the first half of 2020 from a stable 80 percent in December 2019 to 55 percent as of June 30, 2020.
+Added: In order to help navigate through this challenging environment, SunCoke worked with our customers to provide near-term coke supply relief for customers in exchange for extending certain contracts.
+Added: See "Management's Discussion and Analysis of Financial Condition and Results of Operations" for further detail.
+Added: In the second half of 2020, demand and capacity utilization in the U.S.
+Added: steel industry largely recovered from the impacts of COVID-19 as many of the temporarily idled blast furnaces restarted, resulting in a U.S.
+Added: steel production utilization rate of 75 percent as of January 2021.
+Added: We expect continued recovery of U.S.
+Added: steel production utilization rates in 2021.
+Added: Our Brazil cokemaking operations are located in Vitória, Brazil, where we operate our ArcelorMittal Brazil cokemaking facility for a Brazilian subsidiary of ArcelorMittal S.A.
Revenues from our Brazilian cokemaking facility are derived from licensing and operating fees, which include a fixed annual licensing fee, a licensing fee based upon the level of production required by our customer and full pass-through of the operating costs of the facility.
Logistics Operations
−Removed: Our logistics business consists of CMT, KRT, Lake Terminal and Dismal River Terminal (“DRT”).
−Removed: CMT, located in Convent, Louisiana, is one of the largest export terminals on the U.S.
−Removed: CMT provides strategic access to seaborne markets for coal and other industrial materials.
+Added: Our logistics business consists of Convent Marine Terminal ("CMT"), Kanawha River Terminal ("KRT"), Lake Terminal and Dismal River Terminal (“DRT”).
+Added: CMT is located in Convent, Louisiana, with strategic access to seaborne markets for coal and other industrial materials.
The terminal provides loading and unloading services and has direct rail access and the current capability to transload 15 million tons annually with its top of the line ship loader.
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KRT is a leading metallurgical and thermal coal mixing and handling terminal service provider with collective capacity to mix and transload 25 million tons annually through its operations in Ceredo and Belle, West Virginia.
−Removed: Lake Terminal is located in East Chicago, Indiana and provides coal handling and mixing services to our Indiana Harbor cokemaking operations.
−Removed: DRT supports our Jewell cokemaking facility in Vansant, Virginia in its direct procurement of third-party coal.
+Added: Lake Terminal and DRT provide coal handling and mixing services to SunCoke's Indiana Harbor and Jewell cokemaking operations, respectively.
Our logistics business has the collective capacity to mix and/or transload more than 40 million tons of coal and other aggregates annually and has storage capacity of approximately 3 million tons.
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Revenues are recognized when services are provided as defined by customer contracts.
−Removed: See Note 19 to our consolidated financial statements for further discussion of our revenue recognition policies.
Logistics services provided to our domestic cokemaking facilities are provided under contracts with terms equivalent to those of arm's-length transactions.
Certain CMT customers are impacted by seaborne export market dynamics.
−Removed: Fluctuations in the benchmark price for coal delivery into northwest Europe, as referenced in the Argus/McCloskey's Coal Price Index report (“API2 index price”), as well as Newcastle index coal prices, as referenced in the Argus/McCloskey's Coal Price Index report (“API6 index price”), which reflect low-ash coal prices shipped from Australia, contribute to our customers' decisions to place tons into the export market and thus impact transloading volumes through our terminal facility.
+Added: Fluctuations in the benchmark price for coal delivery into northwest Europe, as referenced in the Argus/McCloskey's Coal Price Index Report ("API2 index price"), as well as Newcastle index coal prices, as referenced in the Argus/McCloskey's Coal Price Index ("API6 index price"), which reflect low-ash coal prices shipped from Australia, contribute to our customers' decisions to place tons into the export market and thus impact transloading volumes through CMT.
+Added: API2 and API6 prices declined during the first half of 2020, driven by tempered demand from Europe and increasing Russian coal supply, unfavorably impacting export volumes from our customers.
+Added: During the fourth quarter, the coal export market showed signs of recovery, as reflected by an increase in API2 prices of 15 percent and an increase in Gulf Coast thermal coal export volumes of approximately 70 percent.
+Added: The API2 forward curve projections indicate continued recovery of the coal export market, and we expect between 4 million and 5 million tons of coal to be exported from CMT in 2021.
Our KRT terminals serve two primary domestic markets, metallurgical coal trade and thermal coal trade.
Metallurgical markets are primarily impacted by steel prices and blast furnace operating levels whereas thermal markets are impacted by natural gas prices and electricity demand.
−Removed: API2 and API6 prices declined during 2019 by approximately 37 percent and 27 percent , respectively, driven by reduced demand from Europe and increasing Russian coal supply.
−Removed: While we expect the U.S.
−Removed: to continue to be a significant participant in the seaborne coal trade, export volumes were lower in 2019 as compared to 2018 and are expected to further decline in 2020.
−Removed: The decline in market conditions led to the bankruptcy of one of CMT's major customers, which contributed to, along with other factors, impairment charges discussed further in "Items Impacting Comparability" and in Note 8 to our consolidated financial statements.
+Added: Challenging market conditions impacted the volume of coal moving through our domestic logistics terminals in 2020, including the terminals that serve our own cokemaking facilities, as a result of the volume relief provided to our Domestic Coke customers.
+Added: In 2021, we expect our cokemaking facilities to operate at full capacity.
+Added: Therefore, we expect throughput volumes at our domestic logistics terminals to increase to approximately 10 million tons, up from approximately 9 million tons in 2020.
+Added: Volumes from third party customers in 2021 are expected to be consistent with 2020.
+Added: A significant portion of our logistics business has historically been from long-term, take-or-pay contracts with Murray American Coal, Inc.
+Added: ("Murray") and Foresight Energy LLC ("Foresight"), which were adversely impacted by declining coal export prices and domestic demand.
+Added: Murray filed for Chapter 11 bankruptcy on October 29, 2019.
+Added: Foresight engaged outside counsel and financial advisors to assess restructuring options during 2019 and subsequently filed for Chapter 11 bankruptcy on March 10, 2020.
+Added: Both the Murray and Foresight contracts with CMT were subsequently rejected by the bankruptcy courts.
+Added: CMT began handling tons in 2020 under an agreement with Javelin Global Commodities (UK) Ltd (“Javelin”), the global coal trading and marketing agent for Foresight and others.
+Added: In December 2020, CMT entered into a long-term, take-or-pay agreement with Javelin, which includes 4 million tons in 2021 and 3 million tons in 2022.
Our revenues in our cokemaking business are tied to long-term, take-or-pay contracts and as such, are not seasonal.
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Excessively hot summer weather or cold winter weather may increase commercial and residential needs for heat or air conditioning, which in turn may increase electricity usage and the demand for thermal coal and, therefore, may favorably impact our logistics business.
−Removed: Additionally,
−Removed: at CMT, service fluctuates with global thermal coal prices and end market demand.
−Removed: Operating costs at CMT are impacted by water levels on the Mississippi River, which are often higher in the spring months.
+Added: Additionally, operating costs at CMT are impacted by water levels on the Mississippi River, which are often higher in the spring months.
Raw Materials
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Each ton of coke produced at our facilities requires approximately 1.4 tons of metallurgical coal.
−Removed: We purchased 6.3 million tons of metallurgical coal in 2019.
+Added: We purcha sed 5.4 million tons of metallurgical coal in 2020.
Metallurgical coal is generally purchased on an annual basis via one-year contracts with costs passed through to our customers in accordance with the applicable coke sales agreements.
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As with typical annual purchases, the cost of these supplemental purchases is also generally passed through to our customers.
−Removed: In 2020, certain of our metallurgical coal contracts contain an option to reduce our commitment by up to 15 percent, based on coke production requirements.
+Added: In 2021, our metallurgical coal contracts are based on coke production requirements and do not contain a minimum annual purchase requirement.
Most metallurgical coal procurement decisions are made through a coal committee structure with customer participation.
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At facilities with multiple transportation options, including rail and barge, we enter into short-term transportation contracts from year to year.
−Removed: All delivery costs are passed through to the customers.
+Added: Delivery costs are generally passed through to the customers.
For coke sales, the point of delivery varies by agreement and facility.
−Removed: The destination for coke sales from our Jewell and Haverhill cokemaking facilities is generally designated by the customer and shipments are made by railcar under long-term transportation agreements, which are passed through to our customers.
+Added: The destination for coke sales under long-term, take-or-pay agreements from our Jewell and Haverhill cokemaking facilities is generally designated by the customer and shipments are made by railcar under long-term transportation agreements, which are passed through to our customers.
At our Middletown, Indiana Harbor and Granite City cokemaking facilities, coke is delivered primarily by a conveyor belt leading to the customer’s blast furnace, with the customer responsible for additional transportation costs, if any.
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Research and Development and Intellectual Property and Proprietary Rights
−Removed: Our research and development program seeks to improve existing and develop promising new cokemaking technologies and enhance our heat recovery processes.
+Added: Our research and development program seeks to improve existing and develop promising new cokemaking technologies, including new product development, and enhance our heat recovery processes.
Over the years, this program has produced numerous patents related to our heat recovery coking design and operation, including patents for pollution control systems, oven pushing and charging mechanisms, oven flue gas control mechanisms and various others.
+Added: Additionally, we have successfully utilized our existing coke ovens to produce foundry coke in addition to our primary product of blast furnace coke.
At Vitória, Brazil, where we operate one cokemaking facility on behalf of ArcelorMittal Brazil, we have intellectual property and licensing agreements in place for the entity’s use of our technology, under which we receive a per ton licensing fee as well as an annual licensing fee.
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Most of the world’s coke production capacity is owned by blast furnace steel companies utilizing by-product coke oven technology.
−Removed: The international merchant coke market is largely supplied by Chinese, Colombian and Ukrainian producers, among others, though it is difficult to maintain high quality coke in the export market, and when coupled with transportation costs, coke imports into the U.S.
+Added: The international merchant coke market is largely supplied by Chinese, Colombian and Ukrainian producers, among others, though it can be more challenging to maintain high quality coke in the export market, and when coupled with transportation costs, coke imports into the U.S.
are often not economical.
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Our Domestic Coke segment accounts for approximately 30 percent of the U.S.
−Removed: coke market capacity, excluding the capacity used to produce foundry coke.
+Added: blast furnace coke market capacity.
Current production from our cokemaking business is largely committed under long-term, take-or-pay contracts.
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thermal coal exports from the U.S.
−Removed: Gulf Coast and approximately 15 percent of total U.S.
+Added: Gulf Coast and approxi mately 15 percent of total U.S.
thermal coal exports.
CMT has a state-of-the-art ship loader, the largest of its kind in the world.
−Removed: We believe this ship loader has the fastest loading rate available in the Gulf Region, which should allow our customers to benefit from lower shipping costs.
+Added: We believe this ship loader has the fastest loading rate available in the Gulf Region, which should allow our
+Added: customers to benefit from lower shipping costs.
Additionally, CMT has a strategic alliance with a company that performs barge unloading services for the terminal, which provides CMT with the ability to transload and mix a significantly broader variety of materials.
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Lake Terminal and DRT provide coal handling and/or mixing services to our Indiana Harbor and Jewell cokemaking facilities, respectively, and therefore, do not have any competitors.
+Added: Human Capital Management
+Added: Each employee at SunCoke is part of our collaborative and complimentary team.
+Added: We are committed to maintaining an inclusive workplace that brings out the best in all of us.
+Added: We respect all employees for their unique expertise and welcome the ideas they bring from their individual experience, education and training.
+Added: We continually strive to make our operations more efficient, while creating a respectful work environment for each team member.
+Added: Company leadership and our Board of Directors are actively involved in overseeing the Company’s human capital management programs.
+Added: Our Chief Legal Officer & Chief Human Resources Officer, in partnership with local Human Resources and General Managers, sponsors the development and oversight of all human capital programs in the organization including:
+Added: (i) culture, (ii) workforce composition, recruitment and our commitment to diversity, equity and inclusion, (iii) workforce stability, (iv) employee development and training, (v) benefits, (vi) performance management and incentives, (vii) safety, and (viii) ethics and compliance.
+Added: Workforce Culture
+Added: Our culture at SunCoke is driven by our core values.
+Added: SunCoke’s values of excellence, innovation, commitment, integrity and stewardship are at the heart of who we are and how we work every day.
+Added: They guide our actions and decisions so we can always strive to do the right thing for our stakeholders, our business and each other.
+Added: • Excellence:
+Added: expect the best from yourself, remove obstacles, inspire and support others, embrace diversity and celebrate success.
+Added: • Innovation:
+Added: master the science and process, create a better way, find a better solution and push the envelope.
+Added: • Commitment:
+Added: deliver results, be accountable, work as a team, continuously improve and grow and always communicate effectively.
+Added: do what is right, say what you mean, do what you say, earn trust and treat others with respect.
+Added: • Stewardship:
+Added: provide safe, reliable and environmentally sound operations for our people and their families, our customers and the communities where we do business.
+Added: Workforce Composition, Recruitment and Our Commitment to Diversity, Equity and Inclusion (“DEI”)
As of December 31, 2020, we have approximately 841 employees in the U.S.
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Additionally, approximately 3 percent of our domestic employees are represented by the International Union of Operating Engineers.
−Removed: During 2019, the labor agreements at KRT, Lake Terminal and Haverhill were renewed and will expire on April 30, 2022, June 30, 2022 and October 31, 2023, respectively.
−Removed: In addition, during 2019, the labor agreement at Indiana Harbor was retroactively renewed, with an effective date of September 1, 2018 and an expiration date of August 31, 2022.
+Added: Labor agreements at Granite City and Haverhill were renewed in 2020 and will expire on September 1, 2023 and November 1, 2023, respectively.
As of December 31, 2020, we have approximately 292 employees at the cokemaking facility in Vitória, Brazil, all of whom are represented by a union under a labor agreement.
−Removed: During 2019, the labor agreement at our Vitoria, Brazil facility was renewed for an additional year, and it expires on November 30, 2020 .
−Removed: We are committed to maintaining a safe work environment and ensuring environmental compliance across all of our operations, as the health and safety of our employees and the communities in which we operate are paramount.
−Removed: We employ practices and conduct training to help ensure that our employees work safely.
−Removed: Furthermore, we utilize processes for managing and monitoring safety and environmental performance.
−Removed: We have consistently operated within the top quartiles for the U.S.
−Removed: Occupational Safety and Health Administration’s ("OSHA") recordable injury rates as measured and reported by the American Coke and Coal Chemicals Institute.
+Added: During 2020, the labor agreement at our Vitória, Brazil facility was renewed for an additional year, and it expires on November 30, 2021.
+Added: We partner with reputable recruitment firms to fill key positions.
+Added: Through those partnerships, we have a commitment to fill our candidate slates with a diverse group of candidates.
+Added: SunCoke’s commitment to diversity recruiting includes a partnership with Professional Diversity Network ("PDN"), which allows us to develop our talent pipeline directly from eight affinity networks.
+Added: Approximately 11 percent of the Company's global workforce is female and minorities represent approximately 17 percent of the Company's U.S.
+Added: The tables below provide breakdowns of gender representation globally and racial/ethnic group representation for U.S.
+Added: Gender Representation for Global Employees
+Added: Number of employees Percent of employee level Number of employees Percent of employee level
+Added: Executive (1)
+Added: 4 40 % 6 60 %
+Added: Non-Executive Management (2)
+Added: 30 29 % 73 71 %
+Added: Senior Leaders (3)
+Added: 34 30 % 79 70 %
+Added: Professionals (4)
+Added: 38 39 % 59 61 %
+Added: All Other Employees (5)
+Added: 51 6 % 872 94 %
+Added: Grand Total 123 11 % 1010 89 %
+Added: Racial/Ethnic Representation of US Employees
+Added: Asian Black or African American Hispanic or Latino White Other
+Added: Number of employees Percent of employee level Number of employees Percent of employee level Number of employees Percent of employee level Number of employees Percent of employee level Number of employees Percent of employee level
+Added: Executive (1)
+Added: 0 — % 0 — % 0 — % 10 100 % 0 — %
+Added: Non-Executive Management (2)
+Added: 4 4 % 3 3 % 2 2 % 82 90 % 1 1 %
+Added: Senior Leaders (3)
+Added: 4 4 % 3 3 % 2 2 % 92 90 % 1 1 %
+Added: Professionals (4)
+Added: 4 5 % 2 3 % 5 7 % 62 85 % 0 — %
+Added: All Other Employees (5)
+Added: 1 — % 64 10 % 44 7 % 546 82 % 11 1 %
+Added: Grand Total 9 1 % 69 8 % 51 6 % 700 84 % 12 1 %
+Added: (1) Represents Executives/Senior Officers and Managers as defined by the EEO-1 Job Classification Guide
+Added: (2) Represents First/Mid Officers and Managers as defined by the EEO-1 Job Classification Guide.
+Added: (3) Represents a weighted average of Executive Management and Non-Executive Management.
+Added: (4) Represents Professionals and Administrative Support Workers as defined by the EEO-1 Job Classification Guide.
+Added: (5) Represents all other classified employees as defined by the EEO-1 Job Classification Guide.
+Added: Workforce Stability & Leadership Experience
+Added: Our commitment to employee retention through our development, benefits, performance management and incentive programs is shown through our low regrettable turnover rate of less than 1 percent in 2020.
+Added: The stability of our workforce is anchored by our experienced corporate leadership team along with our General Managers that lead the day-to-day operations at our facilities.
+Added: Our leaders each have an average of 20 years of leadership experience and an average of over 10 years with SunCoke.
+Added: Employee Development & Training
+Added: SunCoke provides a robust training program that meets or exceeds all applicable regulatory requirements.
+Added: We also provide specialized trainings on an as-needed basis for current topics throughout the year.
+Added: Over the past several years, special training topics have included Active Shooter Preparedness, Harassment, Worker’s Compensation, Diversity and Inclusion, Conducting Effective Investigations and Retirement Planning.
+Added: SunCoke’s Personal Information & Privacy Policy lays out specific procedures to ensure that employees handle sensitive information in a secure and responsible manner.
+Added: The Personal Information & Privacy Policy is updated to remain consistent with data security best practices.
+Added: SunCoke utilizes a variety of information security training methods, including in-depth, periodic policy training, annual interactive video-based Code of Conduct training segments on data security best
+Added: practices, and periodic security awareness communications that remind employees to stay vigilant with respect to data security.
+Added: We believe in developing our employees both within their daily roles and to be ready for their next assignment at SunCoke.
+Added: Development occurs in the form of leadership training, stretch assignments, and on the job training.
+Added: On an annual basis, we engage in succession management to ensure we focus development and training activities on our high performing and high potential talent, preparing potential successors for our most critical roles.
+Added: Of the 107 positions filled in 2020, 47 (44 percent) were filled from within the Company.
+Added: In many cases, we take a hands-on approach to training at SunCoke.
+Added: As we pursued an additional business opportunity with foundry coke, we utilized intra-Company training of existing personnel to develop, implement, and execute this initiative.
+Added: Leadership had the opportunity to provide many insights on topics from producing foundry to engaging new customers, highlighting the ability of our workforce to adjust to changing demands and grow with the Company.
+Added: We pride ourselves on being a lean workforce that focuses on developing and promoting talent internally.
+Added: We offer comprehensive health, welfare and retirement benefits.
+Added: We also offer supplemental benefits programs designed to enhance the daily life and well-being of our employees, including:
+Added: weight-loss, benefits services price-transparency, retirement planning education and coaching, paid-time off (including for community service), tuition reimbursement, health management for chronic conditions and a 24/7 employee assistance program.
+Added: Performance Management and Incentives
+Added: Our full-year performance management process begins with setting annual goals for the Company, which guide the development of functional, local and individual employee goals.
+Added: Employees and their managers are accountable for the goals and must review their performance against the goals on an ongoing basis.
+Added: We provide employee base wages that are competitive and consistent with employee positions, skill levels, experience, and geographic location.
+Added: Additionally, we believe that individual performance and the results of the Company are directly linked to the payment of annual short-term incentives, which is why a significant portion of employee compensation is performance-based.
+Added: Our short-term incentives include both financial metrics as well as performance-based environmental and safety metrics.
+Added: The level of pay at risk increases progressively with positions of greater responsibility, with long-term cash and equity incentives with multi-year vesting periods granted at the Director, Vice President and Senior Vice President levels.
+Added: Further, below the Director level, top performers may be granted long-term cash and equity incentives with multi-year vesting for retention.
+Added: This helps the Company to retain those identified as having the top skills and abilities that are critical to our business.
+Added: We live by the ethos:
+Added: Our top priority has always been the safety of our employees, contractors and visitors.
+Added: With the onset of the COVID-19 pandemic, this became even more challenging as we worked to ensure workplace safety was maintained while also ensuring that our employees were protected from the virus.
+Added: In response to the pandemic, we established an internal task force of subject matter experts, initiated enhanced health and safety measures across our facilities and enacted a work from home program for all qualifying personnel.
+Added: Each of our sites implemented screening procedures consistent with U.S.
+Added: Centers for Disease Control and Prevention ("CDC") recommendations such as screening questionnaires and temperature checks for employees, contractors and other service providers.
+Added: Additionally, to ensure employee safety, we adopted further protocols consistent with CDC, state and local guidance including mask wearing, social distancing, contact tracing and quarantine requirements.
+Added: Safety is so important to SunCoke that we include safety in our core values and also incorporate safety as a metric in our short-term incentive program.
+Added: We have an ambition of zero incidents and injuries in the workplace.
+Added: To reach our goal, we follow our Safety Vision, which is comprised of five core components including:
+Added: • Visible safety leadership - Site and corporate leadership have made a commitment to safety as the paramount value within the company and our site leadership practices visible safety leadership on a daily basis.
+Added: • Communication and training - All team members and contractors take responsibility for their own safety and the safety of those around them and we train to ensure proper safety knowledge.
+Added: • Safe work practices - All team members and contractors take the time necessary to properly identify and mitigate all hazards and safely do each job.
+Added: • Incident investigation – We comply with all applicable laws and regulations and perform root cause analysis on all incidents.
+Added: • Continuous improvement – We are always focused on preventing safety incidents and Thinking Safe, Acting Safe and Being Safe.
+Added: Our target for Total Recordable Incident Rate ("TRIR") at SunCoke for 2020 was 0.70 company-wide, and at the end of the year, it was 0.81.
+Added: At SunCoke, our focus is on continuous safety improvement and while we did not achieve our target this past year, we improved our safety performance from 2019 and continue to perform well above industry standards, as detailed below.
+Added: Our excellent safety record is best understood in comparison to industry-wide safety performance.
+Added: According to the Bureau of Labor Statistics, the TRIR within our sector of Petroleum and Coal Products Manufacturing was 1.3 for 2019.
+Added: For comparison, it was 2.4 for the Iron and Steel Mills sector.
+Added: Our year-over-year safety performance is consistently lower than average industry-wide rates, signaling fewer recordable incidents and demonstrating our strong commitment to safety.
+Added: In a year especially filled with external stressors and distractions, we successfully managed to keep our employees focused on safety and the job at hand.
+Added: Year Employee TRIR Contractor TRIR
+Added: 2018 0.59 1.03
+Added: 2020 1.08 0.38
+Added: Ethics & Compliance
+Added: We have adopted a Code of Business Conduct and Ethics that applies to all of our officers, directors and employees, including senior financial officers and executives.
+Added: Our Code of Business Conduct and Ethics, along with our Core Values, establish the principles that guide our daily actions to uphold the highest standards of ethical and legal behavior.
+Added: Whether working with customers, vendors, business partners or neighbors, we always strive to act with integrity.
+Added: All employees must complete annual training on our Code of Business Conduct and Ethics, which we review and update as needed.
+Added: The most recent updates occurred in 2019.
+Added: We educate all employees to avoid potential conflicts of interest.
+Added: Our Prohibited Payments and Political Contributions Policy addresses payments made to U.S.
+Added: officials, including campaign contributions.
+Added: Our Gifts, Entertainment and Sponsored Travel Policy provides guidance regarding business courtesies, including reporting obligations and value limitations.
+Added: We also have a Human Rights Policy, which affirms our commitment to a fair living wage for all employees.
+Added: Guidance & Reporting Without Fear of Retaliation
+Added: All employees, officers and directors must report suspected policy violations of our Code of Business Conduct and Ethics to the Compliance Team, which consists of our Chief Compliance Officer and other leaders from the Human Resources and Legal Departments.
+Added: They can do so through a variety of channels, including, but not limited to, directly reporting to a supervisor, providing email or verbal reports directly to the Compliance Team and using our confidential, third-party 24/7 reporting hotline or website.
+Added: Calls and online submissions are anonymous, unless the notifying party discloses his or her identity.
+Added: We take the anonymity of these communications seriously and SunCoke’s Compliance Team follows up on each submission.
+Added: In addition to the anonymous hotline, hourly employees represented by a collective bargaining unit can also file a report using the applicable union grievance process.
Legal and Regulatory Requirements
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However, the main requirements for obtaining environmental construction and operating permits are found in the federal regulations.
−Removed: Once all requirements are satisfied, a state or local agency produces an initial draft permit.
−Removed: Generally, the facility reviews and comments on the initial draft.
−Removed: After accepting or rejecting the facility’s comments, the agency typically publishes a notice regarding the issuance of the draft permit and makes the permit and supporting documents available for public review and comment.
−Removed: A public hearing may be scheduled, and the EPA also has the opportunity to comment on the draft permit.
−Removed: The state or local agency responds to comments on the draft permit and may make revisions before a final construction permit is issued.
A construction permit allows construction and commencement of operations at the facility and is generally valid for at least 18 months.
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A facility's operating permit may be a state operating permit or a Title V operating permit.
−Removed: Our cokemaking facilities employ MACT standards designed to limit emissions of certain hazardous air pollutants.
−Removed: Specific MACT standards apply to door leaks, charging, oven pressure, pushing and quenching.
−Removed: Certain MACT standards for new cokemaking facilities were developed using test data from SunCoke's Jewell cokemaking facility located in Vansant, Virginia.
−Removed: Under applicable federal air quality regulations, permitting requirements may differ among facilities, depending upon whether the cokemaking facility will be located in an “attainment” area—i.e., one that meets the national ambient air quality standards (“NAAQS”) for certain pollutants, or in a “non-attainment” or "unclassifiable" area.
−Removed: The status of an area may change over time as new NAAQS standards are adopted, resulting in an area change from one status or classification to another.
−Removed: In an attainment area, the facility must install air pollution control equipment or employ BACT.
−Removed: In a non-attainment area, the facility must install air pollution control equipment or employ procedures that meet LAER standards.
+Added: • Air Quality.
+Added: Our cokemaking facilities employ Maximum Achievable Control Technology (MACT) standards designed to limit emissions of certain hazardous air pollutants.
+Added: Specific MACT standards apply to oven door leaks, charging, oven pressure, pushing and quenching.
+Added: Certain MACT standards for cokemaking facilities were developed using test data from SunCoke's Jewell cokemaking facility located in Vansant, Virginia.
+Added: Additionally, under applicable federal air quality regulations, permitting requirements may differ among facilities, depending upon whether the cokemaking facility will be located in an “attainment” area—i.e., one that meets the national ambient air quality standards (“NAAQS”) for certain pollutants, or in a “non-attainment” or "unclassifiable" area.
+Added: The status of an area may change over time as new NAAQS standards are adopted, resulting in an area changing from one status or classification to another.
+Added: In an attainment area, the facility must install air pollution control equipment or employ Best Achievable Control Technology (BACT).
+Added: In a non-attainment area, the facility must install air pollution control equipment or employ procedures that meet Lowest Achievable Emission Rate (LAER) standards.
LAER standards are the most stringent emission limitation achieved in practice by existing facilities.
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Any changes in attainment status for areas where our facilities are located presents a risk that we may be required to install additional pollution controls, which may require us to incur greater operating costs at those facilities.
−Removed: More stringent NAAQS for ambient nitrogen dioxide and sulfur dioxide went into effect in 2010.
+Added: • More stringent NAAQS for ambient nitrogen dioxide ("NO2") and sulfur dioxide ("SO2") went into effect in 2010.
In July 2013, the EPA identified or "designated" as non-attainment 29 areas in 16 states where monitored air quality showed violations of the 2010 1-hour SO2 NAAQS.
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If redesignated, we may be required to install additional pollution controls and incur greater costs of operating at those of our facilities located in areas that EPA determines to be non-attainment with the 1-hour SO2 NAAQS.
−Removed: In 2012, more stringent NAAQS for fine particulate matter, or PM 2.5, went into effect.
−Removed: In January 2015, the areas where the Granite City and Indiana Harbor facilities are located were designated unclassifiable
−Removed: for PM 2.5, and the areas where the Haverhill and Jewell facilities are located were designated unclassifiable/attainment for PM 2.5.
+Added: • In 2012, more stringent NAAQS for fine particulate matter ("PM"), or PM 2.5, went into effect.
+Added: In January 2015, the areas where the Granite City and Indiana Harbor facilities are located were designated unclassifiable for PM 2.5, and the areas where the Haverhill and Jewell facilities are located were designated unclassifiable/attainment for PM 2.5.
In April 2015, the area where the Middletown facility is located was designated unclassifiable/attainment for PM 2.5.
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In June 2018, EPA designated the areas where the Granite City, Indiana Harbor, and Middletown facilities are located as marginal nonattainment for ozone.
−Removed: Nonattainment designations under the new standard and any future more stringent standard for ozone have two impacts on permitting:
−Removed: (1) demonstrating compliance with the standard using dispersion modeling from a new facility will be more difficult;
−Removed: and (2) facilities operating in areas that become non-attainment areas due to the application of new standards may be required to install Reasonably Available Control Technology (“RACT”).
−Removed: A number of states have filed or joined suits to challenge the EPA’s new standard in court.
−Removed: While we are not able to determine the extent to which this new standard will impact our business at this time, it presents a potential risk of having an impact on our operations and cost structure.
+Added: In December 2020, the Ohio Environmental Protection Agency informed stakeholders in the Cincinnati and Cleveland nonattainment areas, including the Middletown facility, that the agency anticipates those areas will be reclassified as moderate nonattainment areas by the U.S.
+Added: EPA in late 2021.
+Added: Nonattainment designations under the new standard and any future more stringent standard for ozone have two potential impacts:
+Added: (1) demonstrating compliance with the standard using dispersion modeling for permitting new facilities or significant new projects may be more difficult;
+Added: and (2) facilities operating in areas that are classified moderate non-attainment areas may be required to install Reasonably Available Control Technology (“RACT”) or demonstrate that they already meet RACT standards.
+Added: While we are not able to determine the extent to which this new standard will impact our business at this time, it presents a potential risk of having an impact on our operations.
• The EPA adopted a rule in 2010 requiring a new facility that is a major source of greenhouse gases (“GHGs”) to install equipment or employ BACT procedures.
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Our heat recovery cokemaking technology does not produce wastewater as is typically associated with by-product cokemaking.
−Removed: Our cokemaking facilities, in some cases, have wastewater discharge and stormwater permits.
+Added: Our cokemaking facilities, in some cases, have wastewater and/or stormwater discharge permits.
The primary solid waste product from our heat recovery cokemaking technology is calcium sulfate from flue gas desulfurization, which is generally taken to a solid waste landfill.
−Removed: The material from periodic cleaning of heat recovery steam generators has been disposed of as hazardous waste.
On the whole, our heat recovery cokemaking process does not generate substantial quantities of hazardous waste as is typically associated with by-product cokemaking.
−Removed: Pursuant to a court-mandated deadline, EPA published a proposed rule in December 2019 that does not impose financial assurance requirements for managing hazardous substances on the coal products manufacturing sector under Section 108(b) of the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (“CERCLA 108(b)”).
−Removed: EPA’s proposal determined that the risks associated with these facilities’ operations are addressed by existing federal and state programs and regulations and modern industry practices.
−Removed: If EPA changes this determination as a result of public comment or any future judicial decisions, CERCLA 108(b) has the potential of requiring us to secure an instrument or otherwise self-insure for an undetermined amount, demonstrate to EPA the proof of the security, and maintain the security until EPA releases facilities from the CERCLA 108(b) regulations.
+Added: The material from periodic cleaning of heat recovery steam generators has been disposed of as hazardous waste.
+Added: Our facilities only generate wastes and do not have permits for waste transportation, storage or disposal.
Endangered Species Act.
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These obligations are unfunded.
−Removed: Further, although specific criteria varies from state to state as to what constitutes an “owner” or “controller” relationship, under SMCRA the responsibility for reclamation or remediation, unabated violations, unpaid civil penalties and unpaid reclamation fees of independent contract mine operators can be imputed to other companies which are deemed, according to the regulations, to have “owned” or “controlled” the contract mine operator.
Failure to comply with the regulatory requirements can result in sanctions.
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• Clean Air Act.
−Removed: The Clean Air Act and similar state laws and regulations affect our cokemaking operations, primarily through permitting and/or emissions control requirements relating to particulate matter (“PM”) and sulfur dioxide (“SO2”) and MACT standards.
+Added: The Clean Air Act and similar state laws and regulations affect our cokemaking operations, primarily through permitting and/or emissions control requirements relating to PM and SO2 and MACT standards.
The Clean Air Act air emissions programs that may affect our operations, directly or indirectly, include, but are not limited to:
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the Clean Air Interstate Rule;
−Removed: MACT emissions limits for hazardous air pollutants;
+Added: MACT emissions standards for hazardous air pollutants;
the Regional Haze Program;
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Our cokemaking facilities are subject to two categories of MACT standards.
−Removed: The first category applies to pushing and quenching.
+Added: The first category
+Added: applies to pushing and quenching.
The second category applies to emissions from charging and coke oven doors.
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While we believe that our operations are in material compliance with these permits, it is possible that such challenges or claims will be made against our operations in the future.
−Removed: Moreover, our terminal operations may be affected by the impacts of additional regulation on petcoke or on the mining of all types of coal and use of
−Removed: thermal coal for fuel, which is restricting supply in some markets and may reduce the volumes of coal that our terminals manage.
+Added: Moreover, our terminal operations may be affected by the impacts of additional regulation on petcoke or on the mining of all types of coal and use of thermal coal for fuel, which is restricting supply in some markets and may reduce the volumes of coal that our terminals manage.
• Federal Energy Regulatory Commission.
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Any changes to hazardous waste standards or the constituents in the wastes generated at our facilities presents a potential risk of having an impact on our operations and cost structure.
+Added: • Comprehensive Environmental Response, Compensation, and Liability Act.
+Added: Under the Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”), also known as Superfund, and similar state laws, responsibility for the entire cost of clean-up of a contaminated site, as well as natural resource damages, can be imposed upon current or former site owners or operators, or upon any party who released one or more designated “hazardous substances” at the site, regardless of the lawfulness of the original activities that led to the contamination.
+Added: In the course of our operations we may have generated and may generate wastes that fall within CERCLA’s definition of hazardous substances.
+Added: We also may be an owner or operator of facilities at which hazardous substances have been released by previous owners or operators.
+Added: Under CERCLA, we may be responsible for all or part of the costs of cleaning up facilities at which such substances have been released and for natural resource damages.
+Added: We also must comply with reporting requirements under the Emergency Planning and Community Right-to-Know Act and the Toxic Substances Control Act.
+Added: • Pursuant to a court-mandated deadline, EPA published a final rule in December 2020 that does not impose financial assurance requirements for managing hazardous substances on the coal products manufacturing sector under Section 108(b) of the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (“CERCLA 108(b)”).
+Added: EPA’s final rule determined that the risks associated with these facilities’ operations are addressed by existing federal and state programs and regulations and modern industry practices.
• Climate Change Legislation and Regulations.
12 unchanged sentences
Supreme Court rejected any further challenges to the decision to repeal the Clean Power Plan.
−Removed: EPA then proposed the Affordable Clean Energy rule as a replacement for the CPP in August 2018, which it finalized in June 2019.
+Added: EPA then proposed the Affordable Clean Energy ("ACE") rule as a replacement for the CPP in August 2018, which it finalized in June 2019.
+Added: In 2020, various legal challenges to ACE were filed by more than two dozen states and cities, along with environmental activist groups and a coalition of utility companies.
Currently, we do not anticipate these new or existing power plant GHG rules to apply directly to our facilities.
−Removed: However, the impact of current and future GHG-related legislation and regulations have on us will depend on a number of factors, including whether GHG sources in multiple sectors of the economy are regulated, the overall GHG emissions cap level, the degree to which GHG offsets are allowed, the allocation of emission allowances to specific sources, actions by the states in implementing these requirements and the indirect impact of carbon regulation on coal prices.
−Removed: We may not recover the costs related to compliance with
−Removed: regulatory requirements imposed on us from our customers due to limitations in our agreements.
+Added: However, the impact of current and future GHG-related legislation and regulations have on us will depend on a number of factors, including whether GHG sources in multiple sectors of the economy are regulated, the overall GHG emissions cap level, the degree to which GHG offsets are allowed, the allocation of emission allowances to specific sources, and actions by the states in implementing these requirements.
+Added: Any new GHG reduction laws on regulations that apply to us will likely require us to incur increased operating and capital costs and/or increased taxes on GHG emissions.
+Added: We may not recover the costs related to compliance with regulatory requirements imposed on us from our customers due to limitations in our agreements.
The imposition of a carbon tax or similar regulation could materially and adversely affect our revenues.
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We no longer operate coal mines subject to the Miner Act.
−Removed: Our facilities are subject to regulation by OSHA and other agencies with standards designed to ensure worker safety.
+Added: • Occupational Safety and Health ACT (OSH Act).
+Added: Our facilities are subject to regulation by OSHA or MSHA under the OSH Act and other agencies with standards designed to ensure worker safety.
+Added: These standards impose minimum requirements for our operations to maintain and operate sites and equipment in a safe manner.
As noted above, we have consistently operated within the top quartiles for OSHA’s recordable injury rates as measured and reported by the American Coke and Coal Chemicals Institute.
4 unchanged sentences
• Black Lung Benefits Revenue Act of 1977 and Black Lung Benefits Reform Act of 1977, as amended in 1981.
−Removed: Under these laws, each U.S.
+Added: Under these laws, U.S.
coal mine operator must pay federal black lung benefits and medical expenses to claimants who are current and former employees and last worked for the operator after July 1, 1973.
The Patient Protection and Affordable Care Act (“PPACA”), which was implemented in 2010, amended previous legislation and provides for the automatic extension of awarded lifetime benefits to surviving spouses and changes the legal criteria used to assess and award claims.
+Added: SunCoke is not an active coal mine operator and does not perform or oversee coal mining.
+Added: However, SunCoke has retained certain black lung liabilities associated with legacy coal operations.
Our obligation related to black lung benefits at December 31, 2020 was $64.6 million and was estimated based on various assumptions, including actuarial estimates, discount rates, number of active claims, changes in health care costs and the impact of PPACA.
−Removed: Comprehensive Environmental Response, Compensation, and Liability Act.
−Removed: Under the Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”), also known as Superfund, and similar state laws, responsibility for the entire cost of clean-up of a contaminated site, as well as natural resource damages, can be imposed upon current or former site owners or operators, or upon any party who released one or more designated “hazardous substances” at the site, regardless of the lawfulness of the original activities that led to the contamination.
−Removed: In the course of our operations we may have generated and may generate wastes that fall within CERCLA’s definition of hazardous substances.
−Removed: We also may be an owner or operator of facilities at which hazardous substances have been released by previous owners or operators.
−Removed: Under CERCLA, we may be responsible for all or part of the costs of cleaning up facilities at which such substances have been released and for natural resource damages.
−Removed: We also must comply with reporting requirements under the Emergency Planning and Community Right-to-Know Act and the Toxic Substances Control Act.
Environmental Matters and Compliance
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Please see Note 13 to our consolidated financial statements for a discussion of the Notices of Violation ("NOVs") issued by the EPA and state regulators for our Haverhill, Granite City, and Indiana Harbor cokemaking facilities.
−Removed: Many other legal and administrative proceedings are pending or may be brought against us arising out of our current and past operations, including matters related to commercial and tax disputes, product liability, antitrust, employment claims, natural resource damage claims, premises-liability claims, allegations of exposures of third-parties to toxic substances and general environmental claims.
+Added: Other legal and administrative proceedings are pending or may be brought against us arising out of our current and past operations, including matters related to commercial disputes, antitrust, employment claims, premises-liability claims, allegations of exposures of third-parties to toxic substances and general environmental claims.
Although the ultimate outcome of these proceedings cannot be ascertained at this time, it is reasonably possible that some of them could be resolved unfavorably to us.
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A copy of any of these documents will be provided without charge upon written request to Investor Relations, SunCoke Energy, Inc., 1011 Warrenville Road, Suite 600, Lisle, Illinois 60532.
−Removed: Executive Officers of the Registrant
+Added: Information about our Executive Officers
Our executive officers and their ages as of February 25, 2021, were as follows:
−Removed: President and Chief Executive Officer
−Removed: Senior Vice President and Chief Financial Officer
−Removed: Senior Vice President, Chief Legal Officer and Chief Human Resources Officer
−Removed: Michael Hardesty
−Removed: Senior Vice President, Commercial Operations, Business Development, Terminals and International Coke
−Removed: Vice President, Controller and Treasurer
−Removed: Vice President, Chief Technology Officer
+Added: Rippey 63 President and Chief Executive Officer
+Added: Fay West 51 Senior Vice President and Chief Financial Officer
+Added: Gates 44 Senior Vice President, Chief Legal Officer and Chief Human Resources Officer
+Added: Michael Hardesty 58 Senior Vice President, Commercial Operations, Business Development, Terminals and International Coke
+Added: Lausas 41 Vice President, Controller and Treasurer
+Added: Quanci 59 Vice President, Chief Technology Officer
Rippey was appointed as Chief Executive Officer, President and a director of SunCoke Energy, Inc., effective December 1, 2017.
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since October 22, 2015.
+Added: In both of these roles Ms.
+Added: Gates led the Company’s environmental and sustainability function, including all Environmental, Social, and Governance matters.
Gates joined SunCoke in February 2013 as Senior Health, Environment and Safety Counsel.
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Hardesty joined SunCoke Energy, Inc.
−Removed: in 2011 as Senior Vice President, Sales and Commercial Operations, and has more than 30 years of experience in the mining industry.
+Added: in 2011 as Senior Vice President, Sales and Commercial Operations, and has more than 30 years of
+Added: experience in the mining industry.
Before joining SunCoke, Mr.
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Quanci holds a Ph.D.
−Removed: in Chemical Engineering from Princeton University and is a registered Professional Engineer with over one hundred US and international patents and patent applications.
+Added: in Chemical Engineering from Princeton University and is a registered Professional Engineer with over one hundred U.S.
+Added: and international patents and patent applications.
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.