﻿                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
           SECTOR POLICIES AND PROGRAMS DIVISION
           OFFICE OF AIR QUALITY PLANNING AND STANDARDS
           OFFICE OF AIR AND RADIATION


DATE:December 13, 2021 

SUBJECT:Documentation of Phone Conference with KMG chemicals/CMC Materials

FROM:John Bradfield (EPA/OAR/OAQPS/SPPD/NRG)

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TO:EPA-HQ-OAR-2021-0133
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The purpose of this memorandum is to discuss the phone conference between John Bradfield of the U.S. Environmental Protection Agency (EPA) with Chip Leen of CMC Materials on December 13, 2020 regarding manufactured preservatives for use in the wood preserving process. This information will be used in the technology review for the National Emission Standards for Hazardous Air Pollutants for Wood Preserving Area Sources (Subpart QQQQQQ).  

I.  KMG Operations

Chip Leen of CMC Materials, owner of KMG Chemicals, the only North American supplier of pentachlorophenol, confirmed the following information regarding KMG's chemical plant in Mexico. Other wood preservation treatment suppliers had previously provided similar information. 
The company had announced in public filings that their Mexican operations would cease production of pentachlorophenol in 2021.
The chemical business was for sale, but no one had expressed interest in a purchase.
Based on a survey from 2019, the estimate of use for pentachlorophenol for utility poles was for 50% of the market.

