Document rBZezpNOpD1Ydeay1GQQ6kbME

Facility Name: Cabot Corporation Facility Location: 700 East U.S. Highway 36, Tuscola, Illinois Date of Inspection: May 9, 2019 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGIONS 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 DATE: SUBJECT: FROM: TH.RU: TO: MAY 3 1 2019 CLEAN AIR ACT INSPECTION REPORT Cabot Corporation, Tuscola, Illinois Eleanor Kane, Environmental Engineer AECAB (MI/WI) Sarah Marshall, Section Chief AECAB (MI/WI) File BASIC lNFORMATION Facility Name: Cabot Corporation Facility Location: 700 East U.S. Highway 36, Tuscola, Illinois Date ofinspection: May 9, 2019 EPA Inspectors: 1. Eleanor Kane, Environmental Engineer 2. Victoria Nelson, Environmental Engineer Other Attendees: 1. Tammy Bennet, Environmental Manager, Cabot Corporation 2. Todd Ray, Senior Production Engineer, Cabot Corporation 3. Carl Troike, Facilities General Manager, Cabot Corporation 4. John Butcher, Production Engineer, Cabot Corporation Contact Email Address: tammy.bennett@cabotcorp.com Purpose of Inspection: Evaluate compliance with the Clean Air Act, the facility's Title V Permit, and the NESHAP for Hydrochloric Acid Production. Facility Type: Chemical Plant Page 1 of3 Facility Name: Cabot Corporation Facility Location: 700 East U.S. Highway 36, Tuscola, Illinois Date of Inspection: May 9, 2019 Arrival Time: 8:50am Departure Time: 12:35pm Tn"'rwrtion T:r:r~~ ISi Unannounced Inspection D Announced Inspection OPENING CONFERENCE ISl Credentials Presented ISl CBI warning to facility provided The following infom1ation was obtained verbally from facility staff: Process Description: Cabot produces a variety of fumed silica products by flame hydrolysis. At the AB and DE lines, raw materials including silicontetrachloride, hexamethyldisilazane, and methyltrichlorosilane are combusted with air and hydrogen. lmmediately following the main reaction, methane and hydrogen are injected into the process stream to convert byproduct chlorine (Ch) to hydrochloric acid (HCI), which can be removed as a saleable product. After the gas injection. the silica solids are sent to a calciner (at AB) or a fluid bed reactor (at DE), and the gases are sent to the acid side. In the acid area, three (at DE) or four (at AB) towers are used to concentrate the HCI gases to 32% for sale. The emissions from AB and DE are combined to a single stack and monitored for chlorine constituents using mass spectrometers. The HCl production process is subject to the NESHAP for Hydrochloric Acid Production (Part 63 Subpart NN'NNN). At the FGHI units and TDC units, the solid material from the AB and DE lines (or similar material from other plants) is further treated using various chemicals and milling processes. Depending on the treatment chemicals, these processes are potential sources of an1monia and/or fonnaldehyde. Staff Interview: Due to the safety hazards involved in transporting the raw materials necessary for the flame hydrolysis process, Cabot plans to move the production processes at the AB and DE lines to a new facility being built in Kentucky. Once the shift is finalized, the facility will no longer have any processes that are subject to Subpart NNNNN requirements. Production at FGHI and TDC will continue, potentially with changes. A hydrogen production plant is collocated with the Cabot facility, but is operated by a separate company. They have separate emission calculations and reporting. Page 2 of3 Facility Name: Cabot Corporation Facility Location: 700 East U.S. Highway 36, Tuscola, Illinois Date of Inspection: May 9, 2019 TOUR INFORMATION EPA toured the facility: Yes Photos and/or Videos: were taken during the inspection. CLOSING CONFERENCE Requested documents: Site Plan, including emission points (if possible) Site Specific Monitoring Plan Start Up / Shut Down Plan LDAR Plan and 2019 Ql Reports and any follow up Notice of Compliance Status for Subpart NNNNN Testing reports from 2017 emissions testing, including evaluation for Kl 6 Emissions Tracking from 2018 SIGNATURES ~ ~ Report Author: -~~~-+-~-----------Date:---~--~- Section Chief: ~ Page 3 of3 Facility Name: Cabot Corporation Facility Location: 700 East U.S. Highway 36, Tuscola, Illinois Date of Inspection: May 9, 2019 APPENDIX A: DIGITAL IMAGE LOG 1. Photographer Name: Victoria Nelson j. Compar1y/~"'aCiiiry iia1ne: Cabot Corporation 5. Number of Images: 2 2. Date of Inspection: May 9, 2019 4. Sfreel Adoress, City, State: 700 East U.S. Highway 36, Tuscola, Illinois 6. Archival Record Location: C:\Users\Vnelson\OneDrive - Environmental Protection Agency (EPA)\Targeting and Inspections\Cabot Corp Image Number 1 File Name P5090004.JPG Date and Time (Central Time) 2019:05:09 11 :16:48 Latitude and Longitude 39.795317, -88.338437 2 P5090005.JPG 2019:05:0911:17:07 39.795317, -88.338437 Description of Image MACT Compliance Continuous Monitoring Control Panel Continuous Emissions Monitoring Control Panel Appendices Page 1 of 1