
Date:		September 17, 2018
Subject:	Site Visit  -  Tokai Carbon CB Plant  -  Addis, LA and meeting with Carbon Black Manufacturers
	
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 first meet with manufacturers of carbon black and to gather information in support of the work for the 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
	Law Offices of Liskow & Lewis
	701 Poydras Street, Suite 5000
	New Orleans, Louisiana 70139
      (504) 581-7979

      Tokai Carbon CB Plant  -  Addis, LA
      5221 Sid Richardson Rd.
      Addis, LA 70710
      (Mailing address)  -  Box 267
      (225) 343-5704  -  Office
      
      September 11, 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
	Lesley Pietras

      Orion Engineered Carbons
	Jimmy Boyd

	Tokai Carbon CB 
	Long Nguyen

	Cabot Corporation
	Lauren Bradford

	Birla Carbon
	Megan Morgan
IV.	Discussion
This section presents the findings of the visit to the Tokai Carbon CB., facility in Addis, Louisiana and a meeting with carbon black member companies. The following report is divided into sections which include, member discussion, site visit background, and emissions.
Member Discussion
      The morning of September 11, 2018, EPA met with representatives of four carbon black companies and two representatives from the International Carbon Black Association (ICBA). Jimmy Boyd (Orion Engineered Carbons) gave a presentation on carbon black production and the current MACT standard.  The presentation is attached to this site visit report. In addition to the information exchanges in the presentation, the attendees noted the following:
 Industry representatives present stated the current rule overall worked for them.
 They requested a guidance document clarifying that if facilities use tail gas for fuel, that tail gas is excluded from the definition of a process vent and the associated emission limit. 
 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.

Site Visit Background
In the afternoon, representatives from EPA, Greg Johnson of Liskow & Lewis, and Long Nguyen and David Baker of Tokai Carbon CB toured Tokai's Addis plant. This plant produces carbon black using the furnace process, which accounts for 98% of all carbon black production. The facility currently operates flares to control tail gas emissions. As part of a consent decree, the Addis plant will be converting to an incinerator to control these emissions, but retaining the flares as a back-up if issues arise with the incinerator. 

Emissions
 Fugitive Emissions
 The only expected emission point at the Addis plant are the flare stacks. These are also the only regulated emissions points. 
 It is a closed process in which carbon black manufacturing from raw ingredient until packaging is done in closed pipings and machines. 
 Fugitive emissions of tail gas can occur due to equipment leaks that happen prior to the flares due to the corrosive nature of tail gas. Due to the black color of the carbon black, leaks are typically identified and fixed quickly. Equipment leaks are addressed in §63.1107.
 Boiler Emissions
 Emissions from boilers at carbon black facilities are not subject to the boiler MACT. Additionally, there is not an emission limit for boilers in the carbon black MACT. 

