 


DATE:	October 15, 2020

SUBJECT:	Technology Review for the Carbon Black Production Source Category  -  Proposed Rule

FROM:	Korbin Smith, Environmental Protection Agency
	

TO:	Docket EPA-HQ-OAR-2020-0505

I.	BACKGROUND 
Requirements of Section 112(d)(6) of the CAA
Section 112 of the Clean Air Act (CAA) requires the EPA to establish technology-based standards for sources of HAP. These technology-based standards are often referred to as maximum achievable control technology, or MACT, standards. Section 112 also contains provisions requiring the EPA to periodically review these standards. Specifically, paragraph 112(d)(6) states:
      (6) REVIEW AND REVISION.  -  The Administrator shall review, and revise as necessary (taking into account developments in practices, processes, and control technologies), emissions standards promulgated under this section no less often than every 8 years.
      
Description of the Carbon Black Production Source Category and Requirements of the Current NESHAP
The current National Emissions Standards for Hazardous Air Pollutants (NESHAP) for the Carbon Black Production source category were promulgated on July 12, 2002 (67 FR 46258) as 40 CFR part 63, subpart YY. The NESHAP applies to affected sources of HAP at carbon black manufacturing facilities that are major sources of HAP. The affected source covered by this subpart is each new, reconstructed, or existing facility that manufactures carbon black by either the furnace, thermal, acetylene decomposition, or lampblack processes. 
Carbon black is used for a wide variety of applications, including reinforcing, pigments, conductivity, heat dissipation, and many others. Carbon black is used in the production of tires, belts, hoses, wire & cable sheathing, rubber & plastic moldings, roofing materials, seals & gaskets, toners, printing inks, paint and colorants, refractories, and all types of plastics. Approximately 90% of the produced carbon black is used in rubber applications, primarily automotive tires, with 9% used as a colorant for inks, paints, plastics, and paper, and the remainder used for hundreds of other diverse applications. We identified 15 carbon black manufacturing facilities that are subject to the NESHAP. 
II.	DEVELOPMENTS IN PRACTICES, PROCESSES, AND CONTROL TECHNOLOGIES
For the purposes of this technology review, a "development" was considered to be a(n): 
 Any add-on control technology or other equipment that was not identified and considered during development of the original MACT standards;
 Any improvements in practices, processes, or add-on control technology (that were identified and considered during development of the original MACT standards) that could result in significant additional emissions reduction;
 Any work practice or operational procedure that was not identified or considered during development of the original MACT standards;
 Any process change or pollution prevention alternative that could be broadly applied to the industry and that was not identified or considered during development of the original MACT standards;
 Any significant changes in the cost (including cost-effectiveness) of applying controls (including controls the EPA considered during the development of the original MACT standards).

We investigated developments in practices, processes, and control technologies through discussions with industry representatives, and included questions related to the technology review in the site visit request letters that were sent to both companies thought to be subject to the NESHAP. We also conducted a review of EPA's Technology Transfer Network (TTN) Clean Air Technology Center  -  RACT/BACT/LAER Clearinghouse (RBLC) database. The results of these analyses are presented in the following sections.
 Particulate Matter Control
 In the case of carbon black production, the particulate matter is the resulting product. In order to maximize profit all facilities operate multiple control devices to capture the maximum amount of PM (carbon black).
PM controls are used universally and are viewed as an integral component of carbon black production, a cost analysis on installing them was not necessary. 

 
 VOC control
 Our review of post-control options for the Carbon Black Production source category identified incinerators as an option for reducing organic HAP emissions. The use of incinerators to control organic HAP emissions was evaluated and determined to not be cost effective during the original NESHAP, see the memorandum "1999 Incremental Cost Comparison" available in the docket for this rulemaking Upon review, we do not believe the associated costs for installing and operating incinerators have changed significantly since the original NESHAP. Thus, we still find requiring the use of an incinerator to not be cost effective.

 C.	RACT/BACT/LAER Clearinghouse Search
Under EPA's "New Source Review" (NSR) program, if a company is planning to build a new plant or modify an existing plant such that air pollution emissions will increase by a large amount, then the company must obtain an NSR permit. The NSR permit is a construction permit which requires the company to minimize air pollution emissions by changing the process to prevent air pollution and/or installing air pollution control equipment.[1]
The terms "RACT," "BACT," and "LAER" are acronyms for different program requirements under the NSR program. RACT, or Reasonably Available Control Technology, is required on existing sources in areas that are not meeting national ambient air quality standards (i.e., non-attainment areas). BACT, or Best Available Control Technology, is required on major new or modified sources in clean areas (i.e., attainment areas). LAER, or Lowest Achievable Emission Rate, is required on major new or modified sources in non-attainment areas. BACT and LAER (and sometimes RACT) are determined on a case-by-case basis, usually by State or local permitting agencies.[1]
The EPA established the RACT/BACT/LAER Clearinghouse, or RBLC, to provide a central data base of air pollution technology information (including past RACT, BACT, and LAER decisions contained in NSR permits) to promote the sharing of information among permitting agencies and to aid in future case-by-case determinations. However, data in the RBLC are not limited to sources subject to RACT, BACT, and LAER requirements. Noteworthy prevention and control technology decisions and information are included even if they are not related to past RACT, BACT, or LAER decisions.[1]
The RBLC permit data base contains over 5,000 determinations that can help you identify appropriate technologies to mitigate most air pollutant emission streams. The RBLC permit data base was designed to help permit applicants and reviewers make pollution prevention and control technology decisions for stationary air pollution sources, and includes data submitted by several U.S. territories and all 50 States on over 200 different air pollutants and 1,000 industrial processes.[1]
The RBLC provides several options for searching the permit database on-line to locate applicable control technologies. Searches of the RBLC database were conducted in October 2020. The permit dates for the searches used the NESHAP part 63 subpart YY promulgation date (July 12, 2002) through October 16, 2020. 
To search the database for applicable sources we used the NAICS industry group search feature limiting results to those containing the NAICS codes 3265182. The result yielded 15 inquiries. Upon review, there is no new information from the RBLC search for the technology review.

References
       U.S. EPA. RACT/BACT/LAER Clearinghouse. Available at: https://www3.epa.gov/ttn/catc/rblc/htm/welcome_eg.html
      
