International Carbon…

International Carbon
Black Association

11 December 2017

Lubna Hussain Manager
Ministry of the Environment and Climate Change
Environmental Sciences and Standards Division
Standards Development Branch
40 St. Clair Avenue West Floor 7
Toronto Ontario
M4V 1M2

The International Carbon Black Association (ICBA) respectfully submits the following comments to the Ontario Ministry of the Environment and Climate Change (MOECC) in response to Ontario's proposal to amend Ontario Regulation 419/05: Air Pollution - Local Air Quality (0. Reg. 419/05 or the "Regulation") with regards to Sulfur Dioxide, EBR Registry number 013- 0903.

The ICBA is a scientific, non-profit corporation originally founded in 1977. ICBA's purpose is to sponsor, conduct, and participate in investigations, research, and analyses relating to the health, safety, and environmental aspects of the production and use of carbon black. There are two carbon black manufacturing facilities in the Province of Ontario, Cabot Corporation's facility in Sarnia and Birla Carbon's facility in Hamilton. These facilities are critical to important supply chains throughout North America. Cabot and Birla Carbon are members of the ICBA and have been operating these plants in compliance with existing standards for more than 4 decades, directly and indirectly employing hundreds of Ontario citizens. These two facilities employ over 200 Ontario citizens with jobs that offer highly competitive compensation, excellent benefits and indirectly support an additional 500-750 jobs in the community. Our facilities contribute nearly $15 million in taxes, purchase raw materials from Canadian suppliers and our employees contribute over $200,000 in donations to local charities.

On behalf of Cabot and Birla Carbon and other members of the ICBA, we have specific concerns with the proposed amendments to Regulation 419/05 and would like to offer the following comments.

Establishment of the 1-hour 502 Point of Impingement (POI) Ambient Air Quality Standard at 100 µg/m3 will result in the two facilities facing higher costs than the other global carbon black producers

The ICBA understands the need to revise the current Ambient Air Quality Standard of 695µg/m3 that is currently in-place in Ontario. However, the establishment of the 1-hour ambient air point of impingement standard at 100 µg/m3 would be the lowest 1-hour standard promulgated globally. Further, this standard would be half of the United States EPA 1-hour NAAQS standard of 196 µg/m3 promulgated in 2010, which was established based on the same health effects data used by Ontario and has been shown to be protective of human health and the environment.

The impact of the proposed standard in Ontario is significant. Both Carbon Black facilities actively compete with carbon black producers in the United States and nearly 50% of our production enters the US market. By establishing the standard at the lower level, Ontario would in effect impact the ability of these two important facilities to cost effectively compete on a level playing field with other operating facilites in the US for business in the North American market. Further, other global carbon black producers outside of the North American market are increasing their presence in Canada. Many of these facilities do not have any ambient air standards in-place, giving them a distinct cost advantage.

As a minimum, by using the same value as the EPA NAAQS, the resulting ambient air standard in Ontario would achieve a 70% reduction in emissions and will be protective of public health and the environment without affecting the competitive nature of this market with the other North American producers.

Increasing demand on low sulfur feedstocks will create supply issues affecting the availability of control options
The need to reduce global emissions of sulfur dioxide is recognized by national and international organizations. Several economies and countries have taken positive steps toward reducing S02 emissions from anthropogenic sources. This has resulted in significant reductions to the ambient air levels of S02 throughout the world, in Canada and specifically in Ontario. One very effective way that has been widely used to accomplish S02 emissions reduction is through the use of low sulfur containing feedstocks or by switching to natural gas. This has the direct benefit of reducing S02 emissions without other environmental effects associated with waste generation.

The carbon black process requires feedstocks that contain high carbon content relative to the other chemical constituents. Natural gas does not have the same level of carbon relative to other constituents and is typically only used for ancillary purposes (e.g., as secondary feedstock) in the production of carbon black. As a result, the carbon black process uses liquid feedstocks that are also used for generating steam, electricity or for use in shipping. As these markets move to cleaner, low sulfur fuels, there will be a much greater demand on these feedstocks which will make it more difficult to obtain these feedstocks for the carbon black process.

As a case in point, the shipping industry will be required by International Marine Organization to reduce the sulfur content of their fuel from 3.5% to 0.5% by 2020, creating significant shifts in the supply and demand for feedstocks available for use in carbon black manufacturing. This and other similar supply chain dynamics will ultimately impact costs and availability of feedstocks. That will in turn impact the availability and cost of carbon black, a key ingredient to many industrial and rubber products which are crucial to our everyday lives, creating opportunities for lower cost global producers who do not have the same regulatory constraints to enter the market at more attractive prices.

Emissions controls required to meet the more stringent standard will result in adverse environmental impacts associated with significant quantities of solid waste

The available technologies that have been proven most effective in reducing emissions from Carbon Black production are flue gas scrubbers. These units produce negative environmental impacts as a result of the generation of significant quantities of solid waste. In general, for every ton of S02 removed from the air stream, about 5-7 tons of solid waste which will have to be landfilled. In addition, carbon dioxide (C02) emissions will also increase as a result of the chemical reaction needed to remove the S02 emissions.

Scrubbers also require significant quantities of water and require more advanced wastewater treatment systems to ensure that waterways are protected from unwanted contaminants.

The ICBA recognizes the need to establish ambient air quality standards that are protective of the citizens of Ontario. We believe that a sound approach consistent with that of other jurisdictions will provide that level of protection while maintaining a healthy jobs environment and continued competitiveness of Ontario businesses. We urge you to consider all of the impacts associated with the reduction of the current standard and strongly suggest that you not promulgate a standard that is lower than what other nearby jurisdictions have already put into effect. Establishing the 100 µg/m3 standard will impact the ability of the two facilities in Ontario to compete in the NA market and jeopardize the long-term viability of over 200 direct jobs for hard working citizens of Ontario.

We appreciate the opportunity to participate in this process. We look forward to maintaining our dialogue to ensure this process continues to be transparent and allow for input from the regulated community.

Best regards,

Randy Waskul
Vice President, ICBA
Meghan Morgan
Chair, ICBA North American Product
Safety & Regulatory Committee

[Original Comment ID: 211528]