Date: 	August 31, 2020
To: 	Docket
From: 	Korbin Smith, US EPA
Subject:	Identification of Major Sources for the NESHAP for Carbon Black Manufacturing (40 CFR Part 63, Subpart YY)
      
       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 as Part 63, subpart YY; and was completed in July 2002 (67 FR 46258).
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 during the RTR review.
The purpose of this memorandum is to describe the sources of data obtained for identifying major source carbon black production facilities with processes subject to 40 CFR 63 Subpart YY.
       Sources of Data
The main sources of data were the Office of Enforcement and Compliance (OECA), Enforcement and Compliance History Online (ECHO) website, 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.
 Office of Enforcement and Compliance
The EPA's Office of Enforcement and Compliance issued several consent decrees for carbon black production facilities from 2013-2017. As part of this effort a list of all major source facilities were identified and shared with OAQPS at the start of this rule making. The identified facilities are listed in table 1 below. 


                  Table 1: Major Source Facilities from OECA
                                 Company Name
                                     City
                                     State
CABOT CORP -  PAMPA PLANT
PAMPA
TX
CABOT CORP - CANAL PLANT
FRANKLIN
LA
CABOT CORP - VILLE PLATTE PLANT
VILLE PLATTE
LA
COLUMBIAN CHEMICALS CO - NORTH BEND PLANT
CENTERVILLE/FRANKLIN
LA
COLUMBIAN CHEMICALS COMPANY - ULYSSES
ULYSSES
KS
CONTINENTAL CARBON COMPANY- PHENIX CITY
Phenix City
AL
CONTINENTAL CARBON SUNRAY PLANT
SUNRAY
TX
CONTINENTAL CARBON - PONCA CITY
PONCA CITY
OK
Orion Engineered Carbons LLC - Ivanhoe Carbon Black Plant
FRANKLIN
LA
ORION ENGINEERED CARBONS LLC- BELPRE PLANT
BELPRE
OH
ORION ENGINEERED CARBONS LLC- BORGER PLANT
BORGER
TX
ORION ENGINEERED CARBONS LLC-ORANGE PLANT
ORANGE
TX
SID RICHARDSON CARBON BIG SPRING FACILITY
BIG SPRING
TX
SID RICHARDSON CARBON BORGER PLANT
BORGER
TX
SID RICHARDSON CARBON CO - ADDIS PLANT
ADDIS
LA

 Trade Organization
The International Carbon Black Association (ICBA) represents all identified major sources subject the Carbon Black Manufacturing RTR. Members of ICBA include, Birla Carbon, Cabot Corporation, Cancarb Limited, Continental Carbon, Imerys, Orion Engineered Carbons, and Tokai Carbon CB. The ICBA confirmed the list of major sources provided by OECA, with the one change to ownership. Sid Richardson Carbon has sense been purchased by Tokai Carbon CB. The updated list with correct ownership can be found in table 2 below. 
After review, all facilities listed in Table 1 were determined to be subject to subpart YY. All facilities listed in Table 2 became synthetic area source permits before the initial compliance date of July 11, 2005 and are not subject to subpart YY. The facilities in table 3 are not subject to the subpart. 
                    Table 2: ICBA major source member list
                                 Company Name
                                     City
                                     State
CABOT CORP -  PAMPA PLANT
PAMPA
TX
CABOT CORP - CANAL PLANT
FRANKLIN
LA
CABOT CORP - VILLE PLATTE PLANT
VILLE PLATTE
LA
COLUMBIAN CHEMICALS CO - NORTH BEND PLANT
CENTERVILLE/FRANKLIN
LA
COLUMBIAN CHEMICALS COMPANY - ULYSSES
ULYSSES
KS
CONTINENTAL CARBON COMPANY- PHENIX CITY
Phenix City
AL
CONTINENTAL CARBON SUNRAY PLANT
SUNRAY
TX
CONTINENTAL CARBON - PONCA CITY
PONCA CITY
OK
Orion Engineered Carbons LLC - Ivanhoe Carbon Black Plant
FRANKLIN
LA
ORION ENGINEERED CARBONS LLC- BELPRE PLANT
BELPRE
OH
ORION ENGINEERED CARBONS LLC- BORGER PLANT
BORGER
TX
ORION ENGINEERED CARBONS LLC-ORANGE PLANT
ORANGE
TX
TOKAI CARBON CB BIG SPRING FACILITY
BIG SPRING
TX
TOKAI CARBON CB BORGER PLANT
BORGER
TX
TOKAI CARBON CB - ADDIS PLANT
ADDIS
LA

 Enforcement and Compliance History Online (ECHO)
                All Active Major Sources with NAICS Code: 325182
The ECHO website was searched for any active, major sources with the NAICS code 325182. The search returned 22 major source facilities, seven of which were previously unidentified and are shown in Table 3. There were no new facilities found subject to the rulemaking 

                  Table 3: ECHO Results  -  MACT Subpart XXXX
Name
City
State
CABOT CORP FMO DIV
TUSCOLA
IL
DEGUSSA ENGINEERED CARBONS LP
BAYTOWN
TX
E I DUPONT DE NEMOURS CO - DELISLE PLANT
PASS CHRISTIAN
MS
HORSEHEAD CORP
ROCKWOOD
TN
NILOK CHEMICALS ARANSAS PASS CARBON BLACK PLANT
ROCKPORT
TX
SUN CHEMICAL BUSHY PARK FACILITY
GOOSE CREEK
SC
ZINC CORPORATION OF AMERICA
PALMERTON
PA

 CABOT CORP FMO DIV: manufactures fumed silica
 DEGUSSA ENGINEERED CARBONS LP: stopped manufacturing and is currently a distribution center 
 E I DUPONT DE NEMOURS CO - DELISLE PLANT: manufactures titanium dioxide 
 HORSEHEAD CORP: is a zinc recycling facility 
 NILOK CHEMICALS ARANSAS PASS CARBON BLACK PLANT: closed in 2018
 SUN CHEMICAL BUSHY PARK FACILITY: manufactures pigments using aluminum
 ZINC CORPORATION OF AMERICA: manufactures zinc 
