 

Date:
February 1, 2017
To:
Susan Fairchild, EPA/OAQPS/SPPD
Korbin Smith, EPA/OAQPS/SPPD
From:
David Bullock, RTI International
Cassy Becker, RTI International
Subject:
Identification of Major Sources for the NESHAP for Friction Materials Manufacturing Facilities (40 CFR Part 63, Subpart QQQQQ)

I.	Introduction
Section 112 of the Clean Air Act (CAA) outlines the statutory requirements for the EPA's stationary source air toxics program. Section 112 requires EPA to set maximum achievable control technology (MACT) standards for HAP-emitting processes in source categories listed for regulation of hazardous air pollutants (HAP). The MACT standard for the final promulgated rule for this category was developed under Section 112 of the CAA; was developed under Part 63, subpart QQQQQ; and was completed in October 2002 (67 FR 64498).
The Risk and Technology Review (RTR) is a combined effort to evaluate both risk and technology as required by the CAA after the application of the MACT standards. Section 112(f)(2) directs EPA to conduct risk assessments on each source category subject to MACT standards, and to determine if additional standards are needed to reduce residual risks. Section 112(d)(6) of the CAA requires EPA to review and revise MACT standards, as necessary, taking into account developments in practices, processes and control technologies. The Agency will conduct both these reviews at once under the RTR review. In addition to the requirements of the RTR review, EPA also reviews the standards to determine whether any HAP or HAP-emitting processes exist which were not regulated by the 2002 MACT and whether emission limits for surrogates in the rule should be corrected or replaced by the original listed HAP.
The purpose of this memorandum is to describe the sources of data obtained for identifying major source friction products manufacturing facilities with processes subject to 63QQQQQ. A friction materials manufacturing facility is defined as any facility that manufactures friction materials using a solvent-based process. Thus, facilities not containing equipment utilized in the solvent-based process include the phrase, "no equipment to which 63QQQQQ is applicable."
II.	Sources of Data
The main sources of data were the Enforcement and Compliance History Online (ECHO) website, National Emissions Inventory (NEI), and trade organization membership rosters.  Supplemental information was gathered from Title V permits, technical support documents, air emissions inventories, Toxics Release Inventory (TRI) reports, and contacts with relevant EPA Regions and state agencies.
Subpart QQQQQ currently has no electronic data reporting requirements, therefore no information was obtained from the Compliance and Emissions Data Reporting Interface (CEDRI).
The Applicability Determination Index (ADI) database was also reviewed, but no determinations for 63QQQQQ were found.
A. 	Enforcement and Compliance History Online (ECHO)
Three primary searches of the ECHO website were conducted in efforts to identify major facilities subject to 63QQQQQ.  These three searches are described in the sections below.
 All Sources With MACT Subpart QQQQQ
The ECHO website was searched initially for any sources with a MACT Subpart of QQQQQ.[1] The search returned five facilities.  The ECHO search results are summarized in Table 1.
              Table 1. ECHO Search Results  -  MACT Subpart QQQQQ
Facility Name
Street Address
City
State
FRS ID
KNOWLTON TECHNOLOGIES LLC
213 FACTORY STREET
                                   WATERTOWN
                                      NY
                                 110000325988
RAILROAD FRICTION PRODUCTS CORP
13601 AIRPORT ROAD
                                    MAXTON
                                      NC
                                 110000349980
TR MILLER MILL COMPANY INC
215 DEER ST
                                    BREWTON
                                      AL
                                 110012508599
BROWN WOOD PRESERVING CO., INC
16851 HIGHWAY 96 WEST
                                    KENNEDY
                                      AL
                                 110043631077
DYNAX AMERICA CORP
568 E PARK DR
                                    ROANOKE
                                      VA
                                 110064119387

Knowlton Technologies, LLC manufactures a variety of specialty papers, including automotive friction and filter paper. Their Title V permit was obtained and reviewed. The permit clearly indicates that Emission Unit 1-SVSAT, Process MIX is subject to 63QQQQQ. The permit review report (dated 7/20/2015) states, "Emission unit 1SVSAT involves solvent coating operations. It consists of a resin kitchen with mix vessels (mixvs) and solvent wash tank (wshtk), two paper saturator sections (satur) an unwind/wind area (windu), a dryer section (dryer), and final winder area (fwind). Hap and voc emissions from these sources are controlled by a boiler/incinerator (blrin), and are exhausted through ep m0001. After the dryer section, there is an inking station (inkst), which also vents to the boiler/incinerator. ... Process: MIX is located at Building BBISL - This process involves the mixing of coatings for use on the coating lines. The mixing process is subject to the friction materials manufacturing MACT." The permit review report further notes that Emission Unit 1-SVSAT, Process MIX is subject to the emission limitation for existing large solvent mixers.
Railroad Friction Products Corporation (RFPC) manufactures high-friction and low-friction composition brake shoes, specialty shoes, and disc brake linings for freight, locomotive and transit vehicles. Their Title V permit was obtained and reviewed. The permit clearly indicates that One Sigma Mixer (ES-10) is subject to 63QQQQQ.
According to their company website, TR Miller Mill Company Inc. is one of the 150 largest sawmills in the US.[2] They manufacture various specialty pine products, including pine flooring, siding, and pattern products, as well as a selection of 4 x 8 lattice panels. They are also one of the 10 largest producers of treated poles and pilings in the US.  Their Title V permit was not obtained (Alabama does not maintain their Title V permits online), however, it is highly probable that this facility is subject to 63QQQQQQ, Wood Preserving Area Sources NESHAP (rather than 63QQQQQ).
According to their company website, Brown Wood Preserving Company, Inc. manufactures only treated wood poles.[3] Their Title V permit was not obtained (Alabama does not maintain their Title V permits online), however, it is highly probable that this facility is subject to 63QQQQQQ, Wood Preserving Area Sources NESHAP (rather than 63QQQQQ).
The Dynax facility manufactures steel friction disks and mating plates for motor vehicle automatic transmissions and torque converters. Their Title V permit was obtained and reviewed. The permit states, "From determination letter of June 16, 2005, this regulation [MACT QQQQQ] does not apply to the facility."
Of the five facilities identified from the initial ECHO search, only two appear to be subject to 63QQQQQ.
 Major Sources With Facility Name Including the Term "Friction"
The ECHO website was then searched for major sources with a facility name including the term "friction." The search returned six facilities.  The ECHO search results are summarized in Table 2. 
Table 2. ECHO Search Results  -  Major Sources with Facility Name Containing "Friction"
Facility Name
Street Address
City
State
FRS ID
RAILROAD FRICTION PRODUCTS CORP
13601 AIRPORT ROAD
                                    MAXTON
                                      NC
                                 110000349980
FEDERAL MOGUL CENTURY FOUNDRY
3700 FOREST PARK AVE
                                  SAINT LOUIS
                                      MO
                                 110000440880
FEDERAL-MOGUL CORPORATION
2410 PAPERMILL ROAD
                                  WINCHESTER
                                      VA
                                 110000868945
FEDERAL-MOGUL FRICTION PRODUCTS
1 GRIZZLY LANE
                                  SMITHVILLE
                                      TN
                                 110056964691
MANHEIM AREA ECONOMIC DEV CORP
123 EAST STIEGEL ST
                                    MANHEIM
                                      PA
                                 110000618172
SK WELLMAN CORP
5372 WEST 130TH STREET
                                   BROOKPARK
                                      OH
                                 110000388081

The Railroad Friction Products facility was previously identified through the initial ECHO search for facilities subject to 63QQQQQ, and is described above.
According to the ECHO website, the Federal Mogul facility in Saint Louis, Missouri was a major source, but is now permanently closed.  It is not in the 2011 NEI.
According to the ECHO website, the Federal Mogul facility in Winchester, Virginia was a minor source, but is now permanently closed. They do not report being subject to any MACT standards in the 2011 NEI, and a review of their NEI records identified no equipment to which 63QQQQQ is applicable.
The Federal-Mogul, Smithville facility manufactures automotive disc brake pads. Their Title V permit was obtained and reviewed. The permit states, "The Smithville facility no longer uses solvent based product as part of the mixing process. Therefore, this facility is not subject to 40 CFR 63 Subpart QQQQQ, National Emission Standards for Hazardous Air Pollutants for Friction Materials Manufacturing Facilities because there are no solvent mixers present as specified at §63.9490 and §63. 9565 of this MACT regulation. Agreement Letter dated June 4, 2003." The agreement date was before the initial compliance date, thus this facility is not subject to 63QQQQQ.
According to the ECHO website, the Manheim Area Economic Dev Corp facility (formerly Raymark, and Universal Friction Composites) was a major source, but is now permanently closed.  It is not in the 2011 NEI.
According to the ECHO website, the SK Wellman Corp facility was a major source, but is now permanently closed.  It is not in the 2011 NEI.
No additional major sources subject to 63QQQQQ were identified.
 Major Sources With NAICS Code 33634
Friction materials manufacturing is covered by several Standard Industrial Classification (SIC) codes and North American Industry Classification System (NAICS) codes. Friction materials manufacturing is typically classified under SIC 3714, Motor Vehicle Parts and Accessories, Brake and Brake Systems, Including Assemblies and NAICS 33634, Motor Vehicle Brake System Manufacturing. Some facilities manufacture other products in addition to friction materials, and may report the SIC code for the product which makes up the majority of their annual production. A summary of NAICS codes reported in the original ICR responses for the four major facilities is presented in Table 3.
Table 3. NAICS Codes Reported in ICR Responses for Major Sources in the Friction Materials Manufacturing Source Category [4]
NAICS Code
NAICS Definition
                                     33634
Motor Vehicle Brake System Manufacturing
                                    327999
All Other Miscellaneous Nonmetallic Mineral Product Manufacturing
                                    332999
All Other Miscellaneous Fabricated Metal Product Manufacturing
                                    333613
Mechanical Power Transmission Equipment Manufacturing

The ECHO website was searched for major sources with a NAICS code of 33634. The search returned 11 facilities.  Searches were not conducted for the other NAICS codes because they are far too broad to yield valuable results.  The ECHO search results are summarized in Table 4. 
     Table 4. ECHO Search Results  -  Major Sources with NAICS Code 33634
Facility Name
Street Address
City
State
FRS ID
CARDONE INDUSTRIES
5660 RISING SUN AVENUE
                                 PHILADELPHIA
                                      PA
                                 110000336636
AKEBONO ELIZABETHTOWN PLANT
300 RING ROAD
                                 ELIZABETHTOWN
                                      KY
                                 110000381220
HONDA OF AMERICA ANNA ENGINE PLANT
12500 MERANDA RD
                                     ANNA
                                      OH
                                 110000393958
GUNITE CORP
302 PEOPLES AVE.
                                   ROCKFORD
                                      IL
                                 110000437091
ROBERT BOSCH CORPORATION
8101 DORCHESTER RD.
                                 N CHARLESTON
                                      SC
                                 110000500869
CONTINENTAL TEVES
13456 LOVERS LANE
                                   CULPEPER
                                      VA
                                 110000702311
HITACHI AUTOMOTIVE SYSTEMS AMERICAS INC-BEREA KY
301 MAYDE RD.
                                     BEREA
                                      KY
                                 110000741537
BREMBO NA
29991 M-60 EAST
                                     HOMER
                                      MI
                                 110000783082
FEDERAL MOGUL CENTURY FOUNDRY
3700 FOREST PARK AVE
                                  SAINT LOUIS
                                      MO
                                 110000440880
FEDERAL-MOGUL CORPORATION
2410 PAPERMILL ROAD
                                  WINCHESTER
                                      VA
                                 110000868945
FEDERAL-MOGUL FRICTION PRODUCTS
1 GRIZZLY LANE
                                  SMITHVILLE
                                      TN
                                 110056964691

According to the ECHO website, the Cardone facility is a major source. Their Title V permit was not obtained (Pennsylvania does not maintain their Title V permits online). They do not report being subject to any MACT standards in the NEI, and a review of their NEI records identified no equipment to which 63QQQQQ is applicable.
According to the ECHO website, the Akebono facility is a major source. Their Title V permit was not obtained (Kentucky does not maintain their Title V permits online). They do not report being subject to any MACT standards in the NEI, and a review of their NEI records identified no equipment to which 63QQQQQ is applicable.
According to the ECHO website, the Honda facility is a major source.  Their Title V permit was obtained and reviewed.  This is an engine manufacturing plant.  The permit includes no equipment to which 63QQQQQ is applicable and no permit conditions related to 63QQQQQ.  In the NEI, they report being subject to 63EEEEE, 63MMMM, 63PPPPP, and 63ZZZZ.
According to the ECHO website, the Gunite facility is a major source.  Their Title V permit was obtained and reviewed.  This is an iron foundry, and is not a major source of HAP.  The permit includes no equipment to which 63QQQQQ is applicable and no permit conditions related to 63QQQQQ.
According to the ECHO website, the Robert Bosch facility is a major source.  Their Title V permit was obtained and reviewed. The permit states the facility is subject to 63N (Chromium Electroplating, 63 ZZZZ (Reciprocating Internal Combustion Engines (RICE)), and is not subject to 63QQQQQ.
According to the ECHO website, the Continental facility is a synthetic minor facility.  No Title V permit could be located on the Virginia DEQ website.  They do not appear in the 2011 NEI.  They last reported for TRI in 2002 (which included only 500 pounds of polychlorinated alkanes emissions to the air).  It is unlikely that this facility is a major source of HAP.
According to the ECHO website, the Hitachi facility is a major source. Their Title V permit was not obtained (Kentucky does not maintain their Title V permits online).  In the NEI, they report being subject only to 63MMMM.  A review of their NEI records identified no equipment to which 63QQQQQ is applicable.
According to the ECHO website, the Brembo facility is a major source.  Their Title V permit was obtained and reviewed.  This facility is a major source for miscellaneous metal parts coating (63MMMM).  The permit includes no equipment to which 63QQQQQ is applicable and no permit conditions related to 63QQQQQ.
The three Federal Mogul facilities were previously identified in the ECHO search for major sources with a facility name including the term "friction," and are discussed above.
No additional major sources subject to 63QQQQQ were identified.
B. 	National Emissions Inventory (NEI)
The 2011 NEI was reviewed to identify facilities reporting a Regulatory Code of 63QQQQQ.[5] Two facilities were identified with 63QQQQQ as Regulatory Code 1. The search results are summarized in Table 5.
                Table 5. 2011 NEI, Regulatory Code 1 = 63QQQQQ
Facility Name
Street Address
City
State
FRS ID
TR MILLER MILL COMPANY INC
215 DEER ST
                                    BREWTON
                                      AL
                                 110012508599
KNOWLTON TECHNOLOGIES LLC
213 FACTORY STREET
                                   WATERTOWN
                                      NY
                                 110000325988

One facility was identified with 63QQQQQ as Regulatory Code 2. The search results are summarized in Table 6.
                Table 6. 2011 NEI, Regulatory Code 2 = 63QQQQQ
Facility Name
Street Address
City
State
FRS ID
RAILROAD FRICTION PRODUCTS CORP
13601 AIRPORT ROAD
                                    MAXTON
                                      NC
                                 110000349980

One facility was identified with 63QQQQQ as Regulatory Code 4. The search results are summarized in Table 7.
                Table 7. 2011 NEI, Regulatory Code 4 = 63QQQQQ
Facility Name
Street Address
City
State
FRS ID
DYNAX AMERICA CORP
568 E PARK DR
                                    ROANOKE
                                      VA
                                 110064119387

Regulatory Code 63QQQQQ does not appear in any other 2011 NEI Regulatory Code fields.
Each of these facilities was previously identified through the initial ECHO search for facilities subject to 63QQQQQ and their review is discussed above.  No additional major sources subject to 63QQQQQ were identified. 
C. 	Trade Organizations
Two trade organizations were identified that are relevant to the friction products manufacturing industry: the Friction Materials Standards Institute (FMSI), and the Brake Manufacturers Council (BMC).  Member rosters for these organizations were reviewed for major source friction products manufacturing facilities.
 Friction Materials Standards Institute (FMSI)
The Friction Materials Standards Institute is a trade association of automotive aftermarket friction manufacturers.  Membership in FMSI is open to any manufacturer of friction and related products covered by the trademarked FMSI(R) and FMS(R) part numbers.[6] The FMSI active members list is provided in Appendix A.
Of the 26 member companies listed, 11 are located outside the US and are not considered further.
Three Advics facilities were identified.  None are major sources.
 LaGrange, Georgia (110000357177): synthetic minor source. Manufactures brake pads.
 Terre Haute, Indiana (110014371303): synthetic minor source. Does not appear to manufacture friction material.
 Lebanon, Ohio (110000392389): minor source. Does not appear to manufacture friction material.
Seven Akebono Brake facilities were identified.  One is a major source, but has no processes subject to 63QQQQQ.
 Clarksville, Tennessee (110043976230): minor source.
 West Columbia, South Carolina (110002236465): minor source.
 West Columbia, South Carolina (110066986239): no Title V air permit. No TRI report.
 Glasgow, Kentucky (110000380472): synthetic minor source.
 Elizabethtown, Kentucky (110063022303): no Title V air permit. No TRI report.
 Elizabethtown, Kentucky (110000381220): major source. This facility was previously identified in the ECHO search for major sources with a NAICS code of 33634, and is discussed above.
 Springfield, Kentucky (110015722280) (Amtec Brake LLC): synthetic minor.
Eight Bosch Brake facilities were identified.  None are major sources. 
 Sumter, South Carolina (110040926120) Corporate Way: permanently shut down.
 Sumter, South Carolina (110002233976) 1 Corporate Way: no Title V air permit. Last reported for TRI in 2004 (which included only 1,306 pounds of combined HAP emissions to the air).  It is unlikely that this facility is a major source.
 Frankfort, Ohio (110063882838) 3186 County Road 550: permanently closed.
 Gallatin, Tennessee (110000370072): minor source.
 South Bend, Indiana (110009569635): no Title V air permit. No TRI report.
 Frankfort, Ohio (110009428351) 3186 County Road 550: no Title V air permit. No TRI report.
 Johnson City, Tennessee (110000820675): was a minor source; permanently closed.
 Sumter, South Carolina (110038787505) 1 Corporate Circle: was a minor source; permanently closed.
Nine Brake Parts, Inc. facilities were identified.  None are major sources.
 McHenry, Illinois (110046393817) 1100 Corporate Drive: no Title V air permit. No TRI report.
 Stanford, Kentucky (110000379288): synthetic minor source.
 Fredericksburg, Virginia (110000340970): was a major source; permanently closed.
 Dallas, Texas (110013840790) Cockrell Hill Road: no Title V air permit. No TRI report.
 McHenry, Illinois (110043308729) 1380 Corporate Drive: no Title V air permit. No TRI report.
 McHenry, Illinois (110001347007) 1415 North Industrial Drive: was a minor source; permanently closed.
 McHenry, Illinois (110018136514) 1600 North Industrial Drive: no Title V air permit. No TRI report.
 Dallas, Texas (110000457185) 5122 Cockrell Hill Road: no Title V air permit. Last reported for TRI in 2002 (which included no air emissions).  It is unlikely that this facility is a major source.
 Chowchilla, California (110009547589): no Title V air permit. No TRI report.
Brunner International, Inc. (110000809484) located in Medina, New York has no Title V air permit. They last reported for TRI in 2006 (which included only 289 pounds of combined HAP emissions to the air).  It is unlikely that this facility is a major source.
Six Carlisle Brake facilities were identified.  None are major sources.
 Catoosa, Oklahoma (110017765765): synthetic minor source.
 Medina, Ohio (110000388839): minor source.
 Solon, Ohio (110055572795): minor source.
 Logansport, Indiana (110000401529): synthetic minor source.
 Bloomington, Indiana (110000846185): no Title V air permit. No TRI report.
 Nampa, Idaho (110015838478): no Title V air permit. No TRI report.
Ceco Friction Products Incorporated (110007376598) located in Landis, North Carolina has no Title V air permit. They also do not report for TRI.  It is unlikely that this facility is a major source.
FDP Virginia, Inc. (110000341041) (Quality Automotive) located in Tappahannock, Virginia is a synthetic minor source.
Seven Federal Mogul friction products facilities were identified.  One is a major source, but has no processes subject to 63QQQQQ.
 Orangeburg, South Carolina (110001672878): was a synthetic minor facility; permanently closed.
 Berkely, Missouri (110000441656): minor source.  Last reported for TRI in 2006 (which included only 74 pounds of glycol ether emissions to the air).
 Mahwah Township, New Jersey (110032054951): no Title V air permit. No TRI report.
 Smithville, Tennessee (110056964691): major source.  This facility was previously identified in the ECHO search for major sources with a facility name including the term "friction," and is discussed above.
 Salisbury, North Carolina (110010449005): no Title V air permit.  Last reported for TRI in 2001 (which included only 2,775 pounds of asbestos and phenol emissions to the air).  It is unlikely that this facility is a major source.
 Manila, Arkansas (110000452493): no Title V air permit.  Last reported for TRI in 1999 (which included only 23 pounds of asbestos emissions to the air).  It is unlikely that this facility is a major source.
 Scottsville, Kentucky (110000380579): no Title V air permit.  Last reported for TRI in 2004 (10 pounds for all releases combined, which included no air emissions).  It is unlikely that this facility is a major source.
Two Fras-Le North America, Inc. facilities were identified.  None are major sources.
 Prattville, Alabama (110069240468) 103 Echlin Boulevard: no Title V air permit. 2015 TRI report includes only phenol air emissions (6,750 pounds).  It is unlikely that this facility is a major source.
 Prattville, Alabama (110000368539) 101 Echlin Boulevard (formerly Haldex): synthetic minor source.
Performance Friction (110001669123) located in Clover, South Carolina is a synthetic minor source.
Stemco Rome (110060257074) located in Rome, Georgia is a synthetic minor source. They manufacture brake shoes for medium and heavy duty truck and bus applications.
Three Tek-Motive facilities were identified.  None are major sources.
 East Haven, Connecticut (110002484311) 470A Frontage Road: no Title V air permit; no TRI report.
 East Haven, Connecticut (110002089454) 29 Baer Circle: no Title V air permit; TRI only for 1993 (barium only).
 East Haven, Connecticut (110030321603) 110 Commerce Street: no Title V air permit; no TRI report.
Two TMD Friction facilities were identified.  None are major sources.
 Troy, Michigan (110015893336): no Title V air permit; no TRI report.
 Dublin, Virginia (110000343058): synthetic minor source; temporarily closed.
Uni-Bond Brake, Inc. (110000407006), located in Ferndale, Michigan is a minor source. They manufacture brake shoes.
No additional major sources subject to 63QQQQQ were identified.
 Brake Manufacturers Council
The Brake Manufacturers Council is an operating council of the Motor & Equipment Manufacturers Association (MEMA) and is managed by its affiliate, the Automotive Aftermarket Suppliers Association (AASA).[7] The BMC active members list is provided in Appendix B.
Of the 23 member companies listed, 5 are located outside the US and are not considered further.  Eight of the BMC member companies do not manufacture friction material (they are service providers, or manufacturers of related hardware or systems). Additionally, six of the BMC member companies are also FMSI members and were reviewed with the FMSI member list, above.
Four Brembo facilities were identified.  One is a major source, but has no processes subject to 63QQQQQ.
 Homer, Michigan (110000783082): major source.  This facility was previously identified in the ECHO search for major sources with a NAICS code of 33634, and is discussed above.
 Homer, Michigan (110049337491): no Title V air permit; no TRI report.
 Homer, Michigan (110067548194): no Title V air permit; no TRI report.
 Laredo, Texas (110031318045): no Title V air permit; no TRI report.
StopTech, Inc. (110065197174), located in Compton, California does not have a Title V air permit, and does not report to TRI.  It is unlikely that this facility is a major source.  No facilities were found for Centric Parts.
Five Continental Automotive Systems facilities were identified.  None are major sources.
 Auburn Hills, Michigan (110044975024): no Title V air permit; no TRI report.
 Dearborn, Michigan (110042279548): no Title V air permit; no TRI report.
 Dearborn, Michigan (110042282357): no Title V air permit; no TRI report.
 Auburn Hills, Michigan (110003641792): no Title V air permit; no TRI report.
 Rochester Hills, Michigan (110062929844): no Title V air permit; no TRI report.
Five Rayloc facilities were identified.  None are major sources.
 Payson, Utah (110002274048): minor source. Last reported to TRI for 2012.
 Memphis, Tennessee (110000374050): synthetic minor facility.
 Houston, Texas (110005016909): no Title V air permit; no TRI report.
 Hancock, Maryland (110000340444): was a minor source; permanently closed. Last reported for TRI in 2000.
 Morganfield, Kentucky (110000741699): was a major source; permanently shut down. Last reported for TRI in 2007.
No additional major sources subject to 63QQQQQ were identified.
D. 	State-Specific Review
The Background Information Document (BID) prepared for the proposal of 63QQQQQ noted that of the 147 friction products manufacturing facilities for which ICR responses were submitted, 4 were estimated to be potential major sources.[4]  All four of the major sources were resin-based friction materials manufacturers that utilize solvent mixers in the manufacturing process. These four facilities were located in Indiana, North Carolina, Tennessee, and Wisconsin.  These four states were reviewed more specifically for major source friction products manufacturing facilities.  The results of these searches are summarized below.  No additional major sources subject to 63QQQQQ were identified.
 Indiana
A search for friction products manufacturing facilities in Indiana identified six facilities in addition to those already identified above. The search results are summarized in Table 8.
                        Table 8. Indiana Search Results
Facility Name
Street Address
City
State
FRS ID
RAYBESTOS POWERTRAIN, LLC
110 INDUSTRIAL PARK DR.
                                   SULLIVAN
                                      IN
                                 110000767377
RAYBESTOS POWERTRAIN, LLC
1204 DARLINGTON AVE.
                                CRAWFORDSVILLE
                                      IN
                                 110000404385
RAYBESTOS POWERTRAIN, LLC
609 EAST CHANEY STREET
                                   SULLIVAN
                                      IN
                                 110042001614
RAYBESTOS POWERTRAIN, LLC
210 STEWART ST
                                   SULLIVAN
                                      IN
                                 110058829834
HIBBING INTERNATIONAL FRICTION
2001 TROY AVE
                                  NEW CASTLE
                                      IN
                                 110058673813
NF FRICTION COMPOSITES INCORPORATED
1441 HOLLAND ST
                                  LOGANSPORT
                                      IN
                                 110043991892

Four Raybestos facilities were identified.  One is a major source, but has no processes subject to QQQQQ.
 Sullivan, Indiana (110000767377): no Title V air permit. Their 2015 TRI report includes only lead and manganese air emissions (271 pounds, combined).  It is unlikely that this facility is a major source.
 Crawfordsville, Indiana (110000404385): major source.  Their Title V permit was obtained and reviewed. This is a major source for miscellaneous metal parts coating (63MMMM) and reciprocating engines (63ZZZZ) but has no equipment to which 63QQQQQ is applicable and no permit conditions related to 63QQQQQ. The permit notes a Banbury mixer (P019) which is a non-solvent mixer used for producing rubber friction material.
 Sullivan, Indiana (110042001614): synthetic minor.
 Sullivan, Indiana (110058829834): no Title V air permit; no TRI report.
Hibbing International Friction has a synthetic minor air permit; no TRI report.
NF Friction Composites Incorporated has no Title V air permit; no TRI report.  It is unlikely that this facility is a major source.
 North Carolina
A search for friction products manufacturing facilities in North Carolina identified no facilities in addition to those already identified above.
 Tennessee
A search for friction products manufacturing facilities in Tennessee identified one facility in addition to those already identified above. The search results are summarized in Table 9.
                       Table 9. Tennessee Search Results
Facility Name
Street Address
City
State
FRS ID
HONEYWELL BENDIX
3000 20TH STREET NORTH EAST
                                   Cleveland
                                      TN
                                 110000371231

Honeywell Bendix does not appear to have a Title V air permit (Tennessee does not maintain their Title V permits online).  They have not reported for TRI since 2005 (which included only 190 pounds of combined HAP emissions to the air).  They do not appear in the 2011 NEI.  It is unlikely that this facility is a major source.
 Wisconsin
A search for friction products manufacturing facilities in Wisconsin identified ten facilities in addition to those already identified above. The search results are summarized in Table 10.
                      Table 10. Wisconsin Search Results
Facility Name
Street Address
City
State
FRS ID
GREAT LAKES FRICTION PRODUCTS
8964 N 51ST STREET
                                   MILWAUKEE
                                      WI
                                 110041375614
GREAT LAKES FRICTION PRODUCTS / BUTZEN CO
8601 N 43RD ST
                                  BROWN DEER
                                      WI
                                 110005419537
GREAT LAKES FRICTION PRODUCTS INC
6591 N SIDNEY PL
                                   MILWAUKEE
                                      WI
                                 110005412794
OERLIKON FRICTION SYSTEMS (US) INC
10607 N BAEHR RD
                                    MEQUON
                                      WI
                                 110055066654
REXNORD INDUSTRIES
4701 W GREENFIELD AVE
                                   MILWAUKEE
                                      WI
                                 110013962408
REXNORD INDUSTRIES
5150 INTERNATIONAL DR
                                    CUDAHY
                                      WI
                                 110012178678
REXNORD INDUSTRIES
3001 W CANAL ST
                                   MILWAUKEE
                                      WI
                                 110000418502
REXNORD INDUSTRIES
5555 S MOORLAND RD
                                  NEW BERLIN
                                      WI
                                 110000742625
STOLPER-FABRALLOY LLC
115 N JANACEK RD
                                  BROOKFIELD
                                      WI
                                 110012625873
THERMOSET  -  JACKSON FACILITY
N CENTER ST
                                    JACKSON
                                      WI
                                 110000767858

Three Great Lakes Friction Products facilities were identified.  None are major sources.
 Milwaukee, Wisconsin (110041375614): no Title V air permit, and no TRI report.
 Brown Deer, Wisconsin (110005419537): no Title V air permit, and no TRI report.
 Milwaukee, Wisconsin (110005412794): no Title V air permit, and no TRI report.
Oerlikon Friction Systems in Mequon, Wisconsin has no Title V air permit, and no TRI report.  It is unlikely that this facility is a major source.
Four Rexnord facilities were identified.  None are major sources.
 Milwaukee, Wisconsin (110013962408): no Title V air permit.  Their 2015 TRI report includes only 1,1,1-trichloroethane, chromium, and manganese (6.85 pounds of air emissions, combined).  It is unlikely that this facility is a major source.
 Cudahy, Wisconsin (110012178678): no Title V air permit.  Their 2015 TRI report includes only lead and lead compounds (0.2 pounds of air emissions, combined).  It is unlikely that this facility is a major source.
 Milwaukee, Wisconsin (110000418502): synthetic minor. Title V permit was obtained and the facility has facility-wide 10/25 ton HAP limits.
 New Berlin, Wisconsin (110000742625): synthetic minor.
Stolper-Fabralloy in Brookfield, Wisconsin has no Title V air permit, and last reported for TRI in 1994 (which included only 5,400 pounds of 1,1,1-trichloroethane emissions to the air).  It is unlikely that this facility is a major source.
Thermoset in Jackson, Wisconsin is permanently shut down, and last reported for TRI in 2004. 
E. 	Synthetic Minor Source Follow Up
During the course of the review for major sources, 18 synthetic minor sources were identified. Appropriate EPA Region and state agencies were contacted to confirm that none of these facilities are major for HAP, became synthetic minor after the 63QQQQQ compliance date (October 18, 2005), or have solvent mixers that would otherwise be subject to 63QQQQQ. In some instances, additional resources were reviewed, including facility operating permits, technical support documents, air emissions inventories, and Toxic Release Inventory submittals. No additional sources to be included in the risk modeling for 63QQQQQ were identified. The results of this follow up are summarized in Appendix C.
III.	References
 EPA ECHO: https://echo.epa.gov/facilities/facility-search?srch=adv
 T. R. Miller Mill Co., Inc.:  http://www.trmillermill.com/
 Brown Wood Preserving Co., Inc.:  http://www.brownwoodpoles.com/Home/tabid/38/Default.aspx
 EPA (U.S. Environmental Protection Agency).  2001.  Background Information Document: National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Friction Materials Manufacturing Industry.  Publication No. EPA-453/R - 01-008.  September 2001.
 EPA 2011 National Emission Inventory: 2011 EIS v2 facility list 05142015.accdb; 2011NEIv2_ALLNEI_CAP_20150512.accdb; and 2011NEIv2_ALLNEI_OTH_20150512.accdb.
 Friction Materials Standards Institute (FMSI):  http://www.fmsi.org/members/active.php
 Brake Manufacturers Council (BMC):  https://www.aftermarketsuppliers.org/councils/BMC






Appendix A
Friction Materials Standards Institute Member List


Table A-1.  Friction Materials Standards Institute Member List
Member
Location
Website
Comment
ABS Friction Inc.
Guelph, Ontario, Canada
www.absfriction.com 
Not in the U.S.
Advics North America
Plymouth, Michigan
www.advics-na.com
No major sources.
Akebono Brake Corporation
Elizabethtown, Kentucky
www.akebonobrakes.com 
One major source (not subject to 63QQQQQ)
Auto Manufacturas Brake SA de CV
Hidalgo, Mexico
www.canabrake.com 
Not in the U.S.
Bosch Brake Components LLC
Chicago, Illinois

No major sources.
Brake Parts Inc.
McHenry, Illinois
www.brakepartsinc.com 
No major sources.
Brunner International Inc.
Medina, New York

No major sources.
C.M. Brake Inc.
Toronto, Ontario, Canada
www.cmbrake.com 
Not in the U.S.
Carlisle Brake & Friction
Solon, Ohio
www.carlislecbf.com 
No major sources.
Ceco Friction Products
Landis, North Carolina
www.cecofriction.com 
No major sources.
FDP Virginia, Inc.
Tappahannock, Virginia
www.fdpbrakes.com 
No major sources.
Federal-Mogul
Southfield, Michigan
www.federal-mogul.com 
One major source (not subject to 63QQQQQ)
Franco-Mex, S.A.
Naucalpan, Mexico

Not in the U.S.
Fras-Le North America, Inc.
Prattville, Alabama
www.fras-le.com 
No major sources.
Friccion y Tecnologia SA de CV (FRITEC)
Mexico City, Mexico
www.fritec.com.mx 
Not in the U.S.
Gonher de Mexico
Nuevo Leon, Mexico

Not in the U.S.
MaxPower Friction, Inc.
Brampton, Ontario, Canada
www.maxpowerfriction.com 
Not in the U.S.
New World Friction
Cambridge, Ontario, Canada
www.autopartsource.com 
Not in the U.S.
Nucap Industries
Scarborough, Ontario, Canada
www.nucap.com 
Not in the U.S.
Performance Friction Corporation
Clover, South Carolina

No major sources.
Silverline America
Mexico City, Mexico

Not in the U.S.
STEMCO Rome
Rome, Georgia
www.stemcobrakeproducts.com 
No major sources.
Tek-Motive, Inc.
East Haven, Connecticut
www.tek-motive.com 
No major sources.
TMD Friction, Inc.
Troy, Michigan

No major sources.
Uni-Bond Brake, Inc.
Ferndale, Michigan

No major sources.
Util Canada Limited
Concord, Ontario, Canada
www.utilgroup.com 
Not in the U.S.




Appendix B
Brake Manufacturers Council Member List

Table B-1.  Brake Manufacturers Council Member List
Member
Location
Website
Comment
ABS Friction, Inc.
Guelph, Ontario, Canada
www.absfriction.com 
Not in the U.S.
Advics North America
Plymouth, Michigan
www.advics-na.com
FMSI List
Bosch Brake Components LLC
Chicago, Illinois

FMSI List
Brake Parts Inc.
McHenry, Illinois
www.brakepartsinc.com 
FMSI List
Brembo North America
Plymouth, Michigan
www.brembo.com
One major source (not subject to 63QQQQQ)
Centric Parts  -  StopTech
Carson, California

No major sources.
Continental
Auburn Hills, Michigan
www.conti-online.com
No major sources.
FDP Brakes, Inc.
Tappahannock, Virginia
www.fdpbrakes.com 
FMSI List
Federal-Mogul
Southfield, Michigan
www.federal-mogul.com 
FMSI List
Fras-Le North America, Inc.
Northville, Michigan
www.fras-le.com 
FMSI List
Friccion Y Tecnologia SA de CV
Mexico
www.fritec.com.mx
Not in the U.S.
Friction Materials Standards Institute
Madison, Connecticut
www.fmsi.org
Does not manufacture friction material.
Link Engineering
Plymouth, Michigan
www.linkeng.com
Does not manufacture friction material.
MAT Holdings
Long Grove, Illinois
www.matholdingsinc.com
Does not manufacture friction material.
NSF International Strategic Registrations, Ltd.
Ann Arbor, Michigan
www.nsf.org
Does not manufacture friction material.
NUCAP Industries, Inc.
Toronto, Ontario, Canada
www.nucap.com
Not in the U.S.
OE Quality Friction, Inc.
Mississauga, Ontario, Canada
www.oeqf.com
Not in the U.S.
Rayloc / Division of Genuine Parts Co.
Atlanta, Georgia
www.genpt.com
No major sources.
Specialty Lubricants Corp.
Macedonia, Ohio
www.speclubes.com
Does not manufacture friction material.
TRW Automotive
Washington, Michigan
www.trw.com
Does not manufacture friction material.
Trelleborg Rubore
South Haven, Michigan
www.rubore.com
Does not manufacture friction material.
UTIL Group
Concord, Ontario, Canada
www.ctdonline.com
Not in the U.S.
Wolverine Advanced Materials
Dearborn, Michigan
www.warmglobal.com
Does not manufacture friction material.




Appendix C
Summary of Synthetic Minor Source Follow Up

Table C-1.  Summary of Synthetic Minor Source Follow Up
Company
City
State
Disposition
Advics
Terre Haute
IN
Per EPA Region 5, the permit support document indicates that this facility does not manufacture friction materials, as defined in 40 CFR 63, Subpart QQQQQ. A review of the permit and technical support document reveals no friction material manufacturing or solvent mixing operations.
Advics (SAFA)
La Grange
GA
Per EPA Region 4, this facility received a synthetic minor permit on December 20, 2006. The facility has avoidance limits for VOC and HAP. Per the permit, this facility uses a dry mix process to manufacture automotive disc brake pads. This facility does not use a solvent-based manufacturing process and has no solvent mixer.
Akebono
Glasgow
KY
Per EPA Region 4, this facility is Title V due to VOC's, but is an area HAP source.
Akebono (Amtek Brake)
Springfield
KY
Per EPA Region 4, this facility closed in 2008.
Brake Parts Inc.
Stanford
KY
Per EPA Region 4, this facility closed in 2015.
Carlisle Brake
Catoosa
OK
Per Oklahoma DEQ, this facility has been a synthetic minor since applying for construction in 2005, and appears to be a true minor source for HAP. The permit lists no solvent mixing operations; products are sintered. The permit specifically indicates that there are no MACT standards that apply to operations or equipment at this facility.
Carlisle Brake
Logansport
IN
This facility's Title V permit with synthetic minor HAP emission limits was first issued on October 17, 2005 (prior to the QQQQQ compliance date). The permit includes one extrusion area with three extruders that appear to use toluene as a solvent. There is no mention of mixers, or HAP solvent mixers.
Continental Teves
Culpepper
VA
Per Virginia DEQ, Blue Ridge Regional Office, this facility has had VOC emission limits since 1992 and appears to be a natural minor source for HAP. Additionally, the facility does not appear to mix or manufacture friction materials, and there are no mixing operations listed in the permit.
FDP Virginia
Tappahannock
VA
Per Virginia DEQ, Piedmont Regional Office, this facility has had synthetic minor permit limits since at least 1999 (prior to the QQQQQ compliance date). Per a previous site visit report, this facility does not use a solvent mixing process.
Fras-Le (Haldex)
Prattville
AL
Per EPA Region 4, this facility received a synthetic minor permit for PM in 2009, and has always been considered a natural minor HAP source.
Hibbing International
New Castle
IN
This facility has synthetic minor emission limits for PM. The facility is a natural minor HAP source. A review of this facility's permit and technical support document reveals two dry mixers. Emissions estimates for these mixers indicate no HAP emissions. The facility has no HAP solvent mixing operations.
Performance Friction
Clover
SC
Per EPA Region 4, this facility obtained a synthetic minor operating permit on January 4, 2001 (prior to the QQQQQ compliance date). Per a previous site visit report, this facility does not use a solvent mixing process.
Raybestos
Sullivan
IN
A review of this facility's permit and technical support document reveals a saturation line, but emission estimates for this process include no HAP solvents. The saturant appears to be a phenol-formaldehyde based resin. There is no indication of mixing operations, or HAP solvent mixing operations.
Rayloc
Memphis
TN
This facility has synthetic minor emission limits for VOC, but is a true area source for HAP. A review of the facility's permit and technical support documents reveals that this facility is a brake shoe remanufacturer. The facility includes no friction material manufacturing processes or equipment.
Rexnord
Milwaukee
WI
Per EPA Region 5, this facility designs and manufactures gear drives, flexible shaft couplings, and related parts. Based on a review of their Title V permit, this facility is an iron and steel foundry; they do not manufacture friction materials.
Rexnord
New Berlin
WI
Per EPA Region 5, this facility is a power transmission coupling facility. Based on a review of their air emission inventory and last reported TRI submittal, there is no indication of any mixers or friction material manufacturing at this facility.
Stemco
Rome
GA
Per EPA Region 4, this facility received a synthetic minor permit on February 5, 2016. The permit describes this facility as a metal stamping facility. There is no indication of any mixers or friction material manufacturing at this facility.
TMD Friction
Dublin
VA
Per Virginia DEQ, Blue Ridge Regional Office, this facility has had synthetic minor HAP permit limits since at least 1999 (prior to the QQQQQ compliance date).

