                                                                              
DRAFT MEMORANDUM 
DATE: 	September 17, 2020 
TO: 		Korbin Smith, U.S. EPA OAQPS/SPPD/MMG 
FROM:	SC&A Incorporated
SUBJECT: 	Identification of Area Sources for Carbon Black Production NESHAP
 1.0  Purpose and Introduction
Section 112 of the Clean Air Act (CAA) outlines the statutory requirements for the Environmental Protection Agency (EPA) stationary source air toxics program. CAA section 112(k) requires the development of standards for area sources located in urban areas which account for 90 percent of the emissions of the 33 identified urban hazardous air pollutants (HAP) listed in the Integrated Urban Air Toxics Strategy (UATS). These area source standards can require control levels which are equivalent to either maximum achievable control technology (MACT) or generally available control technology (GACT), as defined in section 112(d)(3) and section 112(d)(5) of the CAA, respectively.
Carbon black production was listed as an area source under CAA sections 112(c)(3) and 112(k)(3)(B)(iii) in November 2002 (67 FR 11670) based on emissions of polycyclic organic matter (POM). Area source standards were promulgated under 40 CFR 63.11400 of subpart MMMMMM (NESHAP for Carbon Black Production Area Sources)(72 FR 38864, July 16, 2007). At the time the area source NESHAP for Carbon Black Production Area Sources was promulgated, the EPA identified one carbon black production area source facility. The facility identified at that time, no longer produces carbon black.[,]
Technology reviews, as prescribed in CAA section 112(d)(6) are required for area sources, however risk reviews are not required as stated explicitly in CAA section 112(f)(5). The purpose of this memorandum is to identify existing area source carbon black production facilities in support of the technology review required for area sources under CAA section 112(d)(6).
 2.0  Sources of Data
The primary source of data assessed to identify HAP area sources for the carbon black production source category was the Enforcement and Compliance History Online (ECHO) website (which incorporates records from the Toxics Release Inventory (TRI) and National Emissions Inventory (NEI)). Supplemental information was also gathered and assessed from background internet searches and communications with facilities. The following paragraphs outline the methods and results of this assessment.
An ECHO website air search for any active facility with the Standard Industrial Classification (SIC) code 2895 or North American Industry Classification System (NAICS) code 325182 was performed and facility information (e.g., pollutant reports, facility reports, and emissions data) was examined for 37 facilities that met these criteria. The 15 major HAP sources identified and included in the EPA major source assessment for carbon black manufacturing were captured in this assessment and excluded from consideration as area HAP sources. Results from this search (excluding major HAP sources identified in the EPA major source assessment for carbon black manufacturing) are identified in Table 1. 
            Table 1: ECHO Results  -  Identified Major Sources Excluded
Company Name
City
State
3M COMPANY
KNOXVILLE
IA
3M MINNESOTA MINING & MANUFACTURING CO
KNOXVILLE
IA
BAYTOWN CARBON BLACK PLANT (DEGUSSA ENGINEERED CARBONS LP)
BAYTOWN
TX
CABOT CORPORATION
BILLERICA
MA
CABOT CORPORATION,  WAVERLY, OHIO RIVER           
SAINT MARYS
WV
CARB-RITE COMPANY
SCHNEIDER
IN
CHEVRON PHILLIPS CHEMICAL CEDAR BAYOU PLANT
BAYTOWN
TX
COLUMBIAN CHEMICALS COMPANY
NEW JERSEY
NJ
CONTINENTAL CARBON COMPANY
BARBERTON
OH
EVERRIS NA INC CHARLESTON
N CHARLESTON
SC
HYPERION CATALYSIS
CAMBRIDGE, TOWN OF
MA
JACOBI CARBONS, INC
COLUMBUS
OH
MARYVILLE CARBON SOLUTIONS LLC
MARYVILLE
MO
MCCOY B #5 FACILITY                                                             
LOGANSPORT                                                  
LA
NALCO PRODUCTION LLC - GARYVILLE FACILITY                                       
GARYVILLE
LA
NATIONAL PLASTICS COLOR                                   
VALLEY CENTER
KS
NILOK CHEMICALS ARANSAS PASS CARBON BLACK PLANT
ROCKPORT
TX
PYROLYX USA INCORPORATED
TERRE HAUTE
IN
SCOTTS COMPANY-CLSD
CHARLESTON
SC
SCOTTS COMPANY-CLSD
CHARLESTON
SC
SUN CHEMICAL CORPORATION
GOOSE CREEK
SC
In addition to facilities identified in ECHO, Table 2 lists additional facilities that were identified in EPA's HAP major source assessment that were not considered to be major HAP sources. 
              Table 2: Additional Facilities from Major Sources Memo
Company Name
City
State
CABOT CORP FMO DIV
TUSCOLA
IL
E I DUPONT DE NEMOURS CO - DELISLE PLANT
PASS CHRISTIAN
MS
HORSEHEAD CORP
ROCKWOOD
TN
ZINC CORPORATION OF AMERICA
PALMERTON
PA
Based on ECHO pollutant reports, facility reports, emissions data; and internet searches, the EPA has ruled out the listed facilities in Table 1 and 2 as carbon black production areas sources. Table 3 presents the context/basis for our assumptions by company and location.
               Table 3. Basis for Area Source Status Assumptions
Company Name
Location
Context for Assumptions Re: Area Source Status
3M COMPANY
Knoxville, IA
No associated HAPs listed in air pollutant report. Carbon black manufacturing not listed under industry description of air pollutant report. Internet search indicates that facility is involved in tape and adhesive manufacturing: (https://www.3m.com/3M/en_US/plant-locations-us/knoxville/)
3M MINNESOTA MINING & MANUFACTURING CO
Knoxville, IA
Same 3M Company as listed above under a different Integrated Compliance Information System (ICIS)-Air Source ID.
BAYTOWN CARBON BLACK PLANT (DEGUSSA ENGINEERED CARBONS LP)
Baytown, TX
Facility stopped manufacturing and is currently a distribution center.[3]
CABOT CORPORATION
Billerica, MA
No TRI releases recorded. Internet search indicates that the facility is a sales and research and development (R&D) facility: (https://www.cabotcorp.com/company/worldwide-locations).
CABOT CORP FMO DIV
Tuscola, IL
Facility manufactures fumed silica.
CABOT CORPORATION, Waverly, Ohio River
Saint Mary's, WV
Internet search indicates that carbon black production ceased in 2008: (https://cabotog.gcs-web.com/news-releases/news-release-details/cabot-corporation-close-west-virginia-carbon-black-plant). Communications with facility confirm that the facility no longer produces carbon black.
CARB-RITE COMPANY
Schneider, IN
Only the SIC code is listed, no pollutant information. Internet search indicates that facility produces the following: Metallurgical Coke, Anthracite Coal, Petroleum Coke, Graphite, Fluid Coke. Carbon black is not listed as a product produced at this site on the company's website: (https://ejbognar.com/).
CHEVRON PHILLIPS CHEMICAL CEDAR BAYOU PLANT
Baytown, TX
No associated HAPs listed in air pollutant report. Carbon black manufacturing not listed under industry description of air pollutant report. Internet search indicates that the facility produces the following: Ethylene, High-Density Polyethylene, Low-Density Polyethylene, Linear Low-Density Polyethylene, Normal Alpha Olefins, Polyalphaolefins, On-purpose 1-Hexene. Carbon black is not listed as a product produced at this site: (https://www.cpchem.com/locations/north-america/baytown-texas)
COLUMBIAN CHEMICALS COMPANY
New Jersey, NJ
Internet search of the Birla Carbon company website (purchased Columbian Chemicals in 2011) appears to indicate that this facility is no longer active (not listed on list of company facility locations): (https://www.birlacarbon.com/locations/).
CONTINENTAL CARBON COMPANY
Barberton, OH
Internet search indicates that the facility is a distribution facility, and no carbon black is manufactured: (http://www.continentalcarbon.com/locations.asp).
E I DUPONT DE NEMOURS CO - DELISLE PLANT
Pass Christian, MS
Facility manufactures titanium dioxide.[3] 
EVERRIS NA INC CHARLESTON
N. Charleston, SC
No associated HAPs listed in air pollutant report. Carbon black manufacturing not listed under industry description of air pollutant report. Internet search indicates that the company is involved with chemical and fertilizer mining: (https://www.dandb.com/businessdirectory/everrisnainc.-northcharleston-sc-20154837.html).
HORSEHEAD CORP
Rockwood, TN
Facility is a zinc recycling facility.
HYPERION CATALYSIS
Cambridge, Town of MA
No associated HAPs listed in air pollutant report. Carbon black manufacturing not listed under industry description of air pollutant report. Internet search indicates that the company is involved with the development of novel forms and morphologies of carbon: (http://www.hyperioncatalysis.com/).
JACOBI CARBONS, INC
Columbus, OH
Internet search indicates that the facility produces activated carbons (and not carbon black): (https://www.jacobi.net/products/).
MARYVILLE CARBON SOLUTIONS LLC
Maryville, OH
Internet search indicates the facility is a tire recycling facility: (https://www.bolderindustries.com/locations).
MCCOY B #5 FACILITY 

Logansport, LA
Owned by Cypress Operating Inc who produces oil not carbon black. 
NALCO PRODUCTION LLC - GARYVILLE FACILITY
Garyville, LA
No associated HAPs listed in air pollutant report. Carbon black manufacturing not listed under industry description of air pollutant report.
NATIONAL PLASTICS COLOR
Valley Center, KS
Facility produces color concentrates, and does not appear to produce carbon black: (https://www.npccolor.com/services/services.htm).
NILOK CHEMICALS ARANSAS PASS CARBON BLACK PLANT
Rockport, TX
Production ceased in 2013: (http://www.rockportpilot.com/news/article_e02e7fe5-f668-53eb-b567-0381834560d0.html).
PYROLYX USA INCORPORATED
Terre Haute, IN
Internet search indicates that the facility is a tire recycling facility: (https://pyrolyx.com/).
SCOTTS COMPANY-CLSD
Charleston, SC
No associated HAPs listed in air pollutant report. Carbon black production is not listed under industry description of air pollutant report. Facility assumed to be closed. Scotts Company does not produce or distribute carbon black.
SCOTTS COMPANY-CLSD
Charleston, SC
Same as Scotts Company listing above under a different ICIS-Air Source ID.
SUN CHEMICAL CORPORATION
Goose Creek, SC
Facility manufactures pigments using aluminum.
ZINC CORPORATION OF AMERICA
Palmerton, PA
Facility manufactures zinc.

                                       
