
Date:		September 24, 2019
Subject:	Site Visit  -  Orion Engineered Carbons LLC  -  Borger, TX 
From:		Korbin Smith
      SPPD/MMG
		U.S. Environmental Protection Agency
		Research Triangle Park, NC 27711
To:		Docket: 
		
I.	Purpose
The purpose of this trip was to gather information in support of the work for the Residual Risk and Technology Review (RTR) of 40 CFR Part 63 National Emission Standards for Hazardous Air Pollutants (NESHAP) for carbon black manufacturing (subpart YY). The second part of the visit was to tour a carbon black manufacturing plant and observe the carbon black manufacturing process. The site visit focused on identifying all possible emission sources from raw ingredients to final product, as well as any associated control devices used during carbon black production. 
II.	Place and Date
	Orion Engineered Carbons LLC Facility  -  Borger, TX
      9440 FM1559
      Borger, TX 79007 
      (806) 274-6347  -  Office
      
      September 17, 2018
III.	Attendees
      U.S. Environmental Protection Agency (EPA)
      Korbin Smith, SPPD/MMG
      Keith Barnett, SPPD/MMG
      
      Liskow & Lewis / International Carbon Black Association
      Greg Johnson

      Orion Engineered Carbons
	Jimmy Boyd
	Richard Randolph
	Dawnetta Pompeo
	
	


IV.	Discussion
This section presents the findings of the visit to the Orion Engineered Carbons LLC., facility in Borger, TX. The following report is divided into sections which include, discussion, site visit background, and emissions.
Discussion
      The morning of September 17, 2019, EPA met with representatives of Orion Engineered Carbons LLC. We discussed the effectiveness of the current NESHAP from industries point of view, as well as the potential impact of the Residual Risk and Technology Review  (RTR). In addition to the information discussed above, the attendees noted the following:
 Orion representatives present stated that overall, they were satisfied with the current rule.
 They stated that the cross references in the G-MACT can be difficult to follow and stated that including all the requirements in a rule specific to carbon black would be less confusing.
 When discussing the court decision, requiring the removal of the startup, shutdown and malfunction exemptions, Orion stated they didn't expect this to have a significant impact on their operations.
 Orion representatives mentioned the recent consent decree impact on the carbon black industry and discussed the anticipated NESHAP impact.

Site Visit Background
After the discussion representatives from EPA, Greg Johnson, and Orion employees, toured Orion's Borger  plant. This plant produces carbon black using both the furnace process, which accounts for 98% of all carbon black production, and the thermal process. The facility currently operates boilers to control tail gas emissions. The steam from the boilers is used to power a cogeneration process. Orion also has flares available as a backup in case they encounter an issue with a boiler. As part of a consent decree, the Borger plant can only run the flares 144 hours per year, and 744 hours every five years.
The thermal process for producing carbon black utilizes natural gas as the raw ingredient, resulting in a much cleaner process compared to the furnace process which uses heavy stock oil. The thermal process is only used for producing large sized particle carbon black, which has limited use. There are currently no emission limits for furnace process.

Emissions
 Fugitive Emissions
 Under normal operations it is a closed process in which carbon black manufacturing from raw ingredient until packaging is done in closed piping and machines. Emissions are sent to boilers for incineration
 Boiler Emissions
 Emissions from boilers at carbon black facilities are excluded from the boiler MACT and are considered source category emissions for the Carbon Black Manufacturing source category. There is not an emission limit for boilers in the carbon black MACT. 

