Enforcement

Cabot Corporation Clean Air Act Settlement

(Washington, DC – November 19, 2013) The U.S. Environmental Protection Agency (EPA) and the Department of Justice announced a Clean Air Act (CAA) settlement with Cabot Corporation (Cabot) that will significantly reduce air pollution from three carbon black manufacturing plants in Louisiana and Texas. This settlement will be the first settlement reached pursuant to the EPA’s NSR investigations of all carbon black manufacturing plants in the United States, part of the EPA’s national enforcement initiative aimed at reducing air pollution from the largest sources.

Overview of Company

Cabot owns and operates three carbon black manufacturing plants in Franklin and Ville Platte, Louisiana, and in Pampa, Texas, and is headquartered in Boston, Massachusetts. Cabot is the second largest carbon black manufacturer in the Untied States.

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Violations

The EPA initiated investigation of the carbon black manufacturing sector in 2007, and of Cabot in 2009. Based upon Cabot’s response to the EPA’s CAA Section 114 information requests and other information obtained during its investigation, the EPA concluded that modifications were performed at its plants that violated the Prevention of Significant Deterioration (PSD) provisions of the CAA. The parties initiated settlement discussions in 2010.

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Injunctive Relief

The consent decree secures injunctive relief from all of Cabot’s carbon black manufacturing facilities in the United States. Compliance with the settlement will reduce sulfur dioxide (SO2), oxides of nitrogen (NOx), and particulate matter (PM) emissions by approximately 14,355 tons per year from 2011 levels. The EPA estimates that the cost of the injunctive relief will be approximately $84 million.

The settlement requires:

  • Installation and operation of selective catalytic reduction (SCR) and compliance with enforceable 7-Day and 365-Day rolling average emissions limits for NOx at all three of its facilities;
  • Installation and operation of wet flue gas desulfurization (WGS) and compliance with enforceable 7-Day and 365-Day rolling average emissions limits for SO2 and enforceable 3-hour average emissions limits for PM at its two larger facilities in Canal and Ville Platte, Louisiana;
  • Compliance with enforceable permit limits of no more than 1.5% sulfur content feed, on an annual average basis, and 1.75% sulfur content feed, on a monthly average basis, by December 31, 2014, at its Pampa, Texas, facility;
  • Optimization and maintenance of existing control devices on other PM emissions points (e.g., baghouses, reactors, various vents and filters) at all three of its facilities;
  • Compliance with a fugitive emissions best management practices control plan at all three of its facilities;
  • Operation of an early warning PM detection system, that signals when there has been a non-nominal release of PM, at all three of its facilities; and
  • Installation and operation of NOx CEMs at all three of its facilities and SO2 CEMs at its two largest facilities in Canal and Ville Platte, Louisiana.  

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Pollutant Reductions

As compared to Cabot’s 2011 emissions, EPA expects the following emission reductions to result from this settlement:

  • SO2 about 12,380 tons per year
  • NOx about 1975 tons per year

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Health Effects and Environmental Benefits

The pollutants reduced under this settlement have numerous adverse environmental and health effects. Sulfur dioxides and nitrogen oxides can be converted to fine particulate matter once in the air. Fine particulates can be breathed in and lodged deep in the lungs, leading to a variety of health problems and even premature death. Other health and environmental impacts from the pollutants addressed in this settlement include the following:

Sulfur Dioxide – High concentrations of SO2 affect breathing and may aggravate existing respiratory and cardiovascular disease. Sensitive populations include asthmatics, individuals with bronchitis or emphysema, children, and the elderly. Sulfur dioxide is also a primary contributor to acid deposition, or acid rain.

Particulate Matter – Short term exposure to particulate matter can aggravate lung disease, cause asthma attacks and acute bronchitis, may increase susceptibility to respiratory infections and has been linked to heart attacks.

Nitrogen Oxides – Nitrogen oxides can cause ground-level ozone, acid rain, particulate matter, global warming, water quality deterioration, and visual impairment. Nitrogen oxides play a major role, along with volatile organic chemicals, in the atmospheric reactions that produce ozone. Children, people with lung diseases such as asthma, and people who work or exercise outside are susceptible to adverse effects such as damage to lung tissue and reduction in lung function.

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Environmental Mitigation Projects

The proposed consent decree requires Cabot to spend $450,000 on environmental mitigation projects in the communities surrounding each of its facilities, with no less than $100,000 spent in each community. The projects will consist of various energy savings projects that also have criteria pollutant reduction benefits. Cabot self-funded a study during settlement negotiations to determine which projects have the best environmental benefits and the greatest municipality support.

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Civil Penalty

Cabot will pay a total of $975,000 in civil penalties.

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Comment Period

The proposed settlement, lodged in the U.S. District Court for the Western District of Louisiana, is subject to a 30-day public comment period and final court approval.  Information on submitting comments is available at the Department of Justice website.

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For more information, contact:

Kellie Ortega
Air Enforcement Division
U. S. Environmental Protection Agency
1200 Pennsylvania Ave, NW, MC 2242A
Washington, DC 20460
(202) 564-5529
Kellie Ortega (ortega.kellie@epa.gov)

Patrick Foley
Air Enforcement Division
U. S. Environmental Protection Agency
1200 Pennsylvania Ave, NW, MC 2242A
Washington, DC 20460
(202) 564-7978
Patrick Foley (foley.patrick@epa.gov)

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