Economic Impact Analysis
For the Proposed Carbon Black
Manufacturing NESHAP
Prepared by:
Eric L. Crump
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Innovative Strategies and Economics Group
MD-15, Research Triangle Park, NC 27711
EPA-452/D-00-003
May 2000
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CONTENTS
1. OVERVIEW 1
2. INDUSTRY PROFILE 1
What is carbon black? 1
How is carbon black made? 1
What are the end uses for carbon black? 2
What companies/facilities make carbon black? 3
What are the production costs for carbon black manufacturing? 5
What are the prices for carbon black? 5
How much carbon black is imported to/exported from the United States? 6
Are there consumer substitutes for carbon black? 7
What is the anticipated growth for the carbon black manufacturing industry
over the next few years? 7
3. HAP EMISSIONS AND PROPOSED CONTROLS 7
What HAP are emitted from carbon black plants? 7
What health effects do these HAP present to the public? 8
What is the source of HAP emissions in carbon black manufacturing facilities? 8
What level of control does the proposed rule specify for affected facilities? 8
4. COSTS AND IMPACTS 9
What costs will this proposed regulation impose on the carbon black
source category? 9
What is the anticipated impact of control costs on the industry? 11
Are any small businesses significantly impacted by this NESHAP? 13
Are any government entities significantly affected by this NESHAP? 13
5. REFERENCES 14
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LIST OF TABLES
Table 1 - U.S. Carbon Black Uses and Estimated 1997 Consumption 2
Table 2 - Carbon Black Facilities and Estimated Production Capacity 4
Table 3 - 1997 Annual Production Costs 5
Table 4 - Carbon Black Price Trends, 1985 - 1997 6
Table 5 - Proposed Level of Control for Carbon Black Facilities 9
Table 6 - Annual Costs for Carbon Black Manufacturing NESHAP 10
Table 7 - Monitoring, Inspection, Recordkeeping and Reporting Costs 11
Table 8 - Screening Analysis for Firms Affected by the Proposed Rule 12
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1. OVERVIEW
The EPA is proposing national emission standards for hazardous air pollutants (NESHAP) that will
affect major sources of hazardous air pollutant (HAP) emissions in covered under the carbon black
manufacturing source category. Carbon black manufacturing is classified under Standard Industrial
Classification (SIC) code 2895 and North American Industrial Classification System (NAICS) code
325182.
This analysis provides a brief economic profile of the carbon black manufacturing industry, an overview
of the HAP emissions and proposed NESHAP, and a screening analysis of the impact the proposed
NESHAP will have on firms in the carbon black manufacturing source category.
2. INDUSTRY PROFILE
What is carbon black?
Carbon black is a black, powder or granular substance made by burning hydrocarbons in a limited
supply of air. This produces a black smoke containing extremely small carbon black particles which
can be separated from the combustion gases to form a fluffy powder of intense blackness.1'2'3 Carbon
black is used mostly as a reinforcing agent for rubber. The largest use of carbon black is in the
manufacture of automotive tires. It is also used to color printing ink, painting, paper, and plastics. *
through 6
How is carbon black made?
There are five processes currently used to make carbon black:
# Furnace black process - aromatic oils (based on crude oil) are burned in a reactor, producing
carbon black and tailgas. After cooling, the carbon black is separated from the tailgas,
densified, and processed into pellets of varying grades/sizes. This process is the most widely
used in the U.S, comprising over 95% of all domestic carbon black production.
# Thermal black process - natural gas is burned in a reactor to produce carbon black and tailgas,
and is then processed in a fashion similar to the furnace black process.
# Acetylene black process - similar to the thermal black process, except that acetylene is the raw
material used, and the carbon black is not processed into pellets.
# Lampblack process - one of the oldest carbon black processes. An aromatic oil (based on
coal tar) is heated in a flat cast-iron pan to produce carbon black.1'2'3
The bone black process has been excluded from the carbon black manufacturing source category,
since they have no combustion-related processes, and do not appear to be significant sources of HAP
emissions.
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What are the end uses for carbon black?
Rubber products - especially rubber tires - is the primary end use for carbon black. Table 1 below
lists the primary uses of carbon black, along with estimated 1994 carbon black consumption.
1 through 6.
Table 1 - U.S. Carbon Black Uses and Estimated 1997 Consumption
Carbon black uses
Estimated consumption
(Million Ibs/yr)
Percent of total estimated
consumption
Tires
Automotive (other than tires - belts, hoses, etc.)
Industrial Rubber Products (molded and
extruded goods)
Non-Rubber Uses (e.g., paint, plastics, paper,
ink, and ceramics)
Total
2,450
370
340
350
3,510
70
11
10
10
100*
* - percentages do not add up to 100 due to rounding.
Reference: Chemical Economics Handbook, SRI International
The particle size, structure, and surface area of carbon black plays a significant role in the material
properties of rubber, plastics, and other products, For this reason, carbon black is made in various
grades to meet the varying material needs and specifications of manufacturers. In general, carbon black
grades with smaller particle size have better reinforcing and abrasion resistance qualities than those with
larger particle size.
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What companies/facilities make carbon black?
From the mid-1970s through the mid-1980s, the use of carbon black declined due to such factors
as smaller cars with smaller tires, the use of longer lasting radials, and lower highway speeds, which
increased tire life. Since 1986, these factors have leveled off and carbon black use has been
experiencing slow but steady growth.
The EPA has identified 22 domestic carbon black production facilities, owned and operated by
eight companies. Fourteen of these facilities are located in Louisiana and Texas. Table 2 lists the
companies involved in carbon black production, the general location of each of their facilities, the
primary production process used at each facility uses, and the 1997 estimated production capacity for
each facility. The top six companies accounted for approximately 99 percent of total domestic
production capacity.
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Table 2 - Carbon Black Facilities and Estimated Production Capacity
Company/facility location 1998 estimated capacity Carbon black process
(millions Ibs/yr)
Cabot Corp. - 995 million Ibs., 24 percent of total capacity, 4800 employees
Franklin, LA 355 Furnace
Ville Platte, LA 355 Furnace
Pampa, TX 65 Furnace
.....Wayerly^WV 220 Furnace.
Sid Richardson - 750 million Ibs., 19 percent of total capacity, 500 employees
Addis, LA 255 Furnace
Big Springs, TX 205 Furnace
...Borger,.TX 290 Furnace
Columbian Chemicals3 - 795 million Ibs., 19 percent of total capacity, 13,924 employees (parent corp.)
El Dorado, AR 130 Furnace
Ulysses, KS 115 Furnace
Centerville, LA 350 Furnace
...Moundsyjlle,WV 200 Furnace
Engineered Carbons Corpb - 570 million Ibs., 14 percent of total capacity, 1,190 employees
Baytown, TX 180 Furnace
Borger, TX 210/45 Furnace/Thermal
Orange, TX 135 Furnace
Continental Carbon0 - 560 million Ibs., 13 percent of total capacity, 2000 employees (parent corp.)
Phenix City, AL 100 Furnace
Ponca City, OK 280 Furnace
Sunray? TX 180 Fumace
Degussa Corporation - 495 million Ibs., 12 percent of total capacity, 25,000 employees
Louisa, LA 220 Furnace
Belpre, OH 145 Furnace
Aransas Pass, TX 130 Furnace
Chevron Chemical
Baytown, TX 20 Acetylene .I6.??.™?.??.!™??.
General Carbon Company
^.Lo.s.AnS.eJ.e.Sj.CA 1 Lampblack
Hoover Color Corporation
Hiwassee, VA 1 Charring of animal bones
Source category total 4.195
Sources: Chemical Economics Handbook, SRI International
aOwned by Phelps-Dodge Corporation
bOwned by Ameripol-Synpol
"Owned by China Synthetic Rubber Corporation
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What are the production costs for carbon black manufacturing?7
The U.S. Census Bureau's 1997 Economic Census breaks down the annual production costs for
22 carbon black facilities in NAICS code 325182 (carbon black manufacturing) by capital
expenditures, labor costs, and total material costs. These costs are summarized in table 3 below. The
cost of production totals approximately $625 million, which is 63 percent of the value of shipments for
1997.
While the Economic Census provides a subtotal of electricity costs as part of total material costs, it
does not provide cost subtotals for fuel, contract work, or resales. These subtotals are listed in the
table below under "other production costs".
Costs of Production
Capital Expenditures
Material Costs
Labor Costs
Electricity Costs
Other costs
TOTAL
Table 3 - 1997 Annual
Amount ($1,000)
89,107
368,595
90,694
30,775
45,932
625,083
Production Costs
Percent of Total
Production Cost
14.3
59.0
14.5
4.9
7.3
100
Percent of Value of
Shipments
9.0
37.2
9.2
3.1
4.6
63.1
Source: 1997 Economic Census (Reference 7).
What are the prices for carbon black?6
Prices vary for carbon black, depending on the grade of carbon black desired. Table 4 reflects the
trend in carbon black prices over the past decade. Since the grades of carbon black used in industry
are numerous and varied, three of the grades used most commonly in rubber production were selected
for presentation in table 4. These three grades represent an upper, middle, and lower bound in terms of
price, based on the information readily available.
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Year
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
Table 4 - Carbon Black
Prices
general purpose carbon black
(N660 grade, larger particle
diameter)
31.25
31.25
24.75
25.75
20.75
21.50
20.50
21.50
28.25
30.25
32.75
32.75
32.75
Price Trends, 1985 - 1997
, cents per pound (bulk carload)
high abrasion (N330 grade)
33.00
33.00
27.00
28.00
28.00
25.00
23.00
24.50
32.50
34.50
37.50
37.50
37.50
super abrasion carbon
black (Nl 10, smaller
particle diameter)
38.50
38.50
32.50
33.50
30.00
30.00
29.00
30.00
41.25
43.75
46.75
46.75
46.75
Source: SRI International (Reference 6).
As shown, carbon black prices have rebounded from a sharp decline in the late 1980's, holding
steady in the years 1995-1997. Prices for the most commonly used rubber grades ranged in 1997
from $0.47 per pound for super abrasion carbon black (Nl 10, smaller particle diameter) to $0.33 per
pound for general purpose carbon black (N660 grade, larger particle diameter). If ordered in bag or
box lots, the price per pound was generally 3 or 4 cents per pound higher. 1997 prices for specialty
blacks (used mostly for pigments, paints, inks, etc.) range from $0.50 to over $5.00 per pound.
How much carbon black is imported to/exported from the United States?7
According to the U.S. Census Bureau, approximately 255 million pounds of carbon black was
imported into the United States in 1997, down from a high of 335 million pounds the previous year. In
the decade preceding 1997, the trend has been toward steady increases in carbon black imports,
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mostly from Canada, Columbia, and Mexico. The value of these imports ranges from $0.18 per pound
(Columbia) to $1.68 per pound (Japan).
In 1997, the United States exported 337 million pounds of carbon black to other countries. Over
the past several years, exports have fluctuated widely, but have generally increased from a low of 71
million pounds in 1985. More than half of U.S. carbon black exports (178 million pounds) went to
Canada. The overall average unit value of exported carbon black was $0.48 per pound, ranging from
an average of $0.27 per pound (Luxembourg) to an average of $1.13 per pound (United Kingdom).
Are there consumer substitutes for carbon black?6 8
For rubber production, the most notable substitute for carbon black is precipitated silica. In recent
years, tire manufacturers have replaced up to 25% of the carbon black with silica to create what is
commonly called a "green" tire. The tires are so named because they reduced the rolling resistance of
tires significantly, improving traction, wear, and fuel efficiency. However, the material cost of adding
silica is nearly twice the cost of carbon black, and the cost of processing and compounding the
materials are higher. While the green tire has had some marketing success in Europe, the Asia-Pacific
region, and Latin America, that success has not been equaled in the United States.
What is the anticipated growth for the carbon black manufacturing industry over the next few
years?
Estimates for projected growth in the industry range from 1.5% to 3% per year over the next
several years. This growth is expected to track gains in rubber demand, particularly in the tire
industry.6'9 Industry news suggests limited expansion of production capacity was planned for the years
1997-19989. The EPA has found no information on upcoming facility expansions or new facility
construction. Based on 1997 U.S. production amounts (3,650 million Ibs) and reported capacity
(approximately 4,000 million Ibs), it appears reasonable that the projected growth over the next could
be absorbed by existing facilities without need for expansion or new facilities.6'10
3. HAP EMISSIONS AND PROPOSED CONTROLS
What HAP are emitted from carbon black plants?11 through 14
HAP emitted from the furnace black process primarily take the form of reduced sulfur compounds
(e.g., carbon disulfide and carbonyl sulfide). There are three primary HAP emitted from the carbon
black process (1) carbon disulfide, (2) carbonyl sulfide, and (3) hydrogen cyanide.
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What health effects do these HAP present to the public?11 through 14
Health effects identified include: chronic (long term exposure non-cancer effects), acute (short term
exposure non cancer effects), reproductive and development effects, and cancer effects. The degree of
adverse effects to health can range from mild to severe, depending upon:
# the ambient concentrations observed in the area (e.g., as influenced by emission rates,
meteorological conditions, and terrain),
# the frequency of and duration of exposures
# characteristics of exposed individuals (e.g., genetics, age, pre-existing health conditions, and
lifestyle) which vary significantly with the population, and
# pollutant specific characteristics (e.g., toxicity, half-life in the environment, bioaccumulation, and
persistence).
What is the source of HAP emissions in carbon black manufacturing facilities?12 through
19
From the data available, the EPA has concluded that process vents account for the vast majority of
HAP emissions from carbon black facilities. While some HAP may be emitted from other emission
points (e.g., storage vessels, equipment leaks, and wastewater) they generally would not exceed more
than one percent of a facility's total HAP emissions.
Process vent emissions are primarily tailgases from the reactors. The gases are sent to a baghouse
were the carbon black is removed from the tailgases. After separation of the carbon black product,
most of the tailgases are then emitted to the atmosphere or sent to a combustion control device. Some
of the gases may be sent to a carbon monoxide (CO) boiler as fuel to supply heat for product dryers.
What level of control does the proposed rule specify for affected facilities?
The levels of control proposed for process vents at affected carbon black manufacturing facilities
are shown in Table 5 below.
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Table 5 - Proposed Level of Control for Carbon Black Facilities
If a facility is
considered an. .
And its process vents. . .
The facility must vent emissions
through a closed vent system to. . .
Existing facility # handle an emission stream with a HAP
concentration equal to or greater than 260 parts per
million volume (ppmv), and
# are associated with the main unit filter
# a flare, or
# any combination of control
devices that reduces emissions
of HAPs by either:
>• 98 percent by weight or
>• to a concentration of 20
parts per million by
volume (ppmv), whichever
is less stringent.
New facility handle an emission stream with a HAP concentration
equal to or greater than 260 parts per million volume
(ppmv)
a flare, or
any combination of control
devices that reduces emissions
of HAPs by either:
>• 98 percent by weight or
>• to a concentration of 20
parts per million by
volume (ppmv), whichever
is less stringent.
In addition, there are leak detection and repair requirements (LDAR) for regulated equipment at
both existing and new facilities. LDAR programs must be implemented for regulated equipment after
the reactor if the equipment:
# contains or contacts HAP in amounts equal to or greater than 500 ppmv, and
# operates equal to or greater than 300 hours per year (hr/yr).
4. COSTS AND IMPACTS
What costs will this proposed regulation impose on the carbon black source category?
Based on the criteria established in the proposed NESHAP, EPA believes that seven carbon black
facilities will need to add control equipment in order to comply with the regulation. Five facilities are
expected to install incinerators, and two facilities are expected to install flares. These facilities are all
privately owned. The EPA estimates the total annual cost for these seven facilities combined to be
approximately $10.5 million per year. This total includes capital recovery, labor, maintenance, energy,
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and administrative costs. Table 6 below provides a breakdown of the estimated annual costs for the
seven facilities, in fourth quarter 1997 dollars.
Table 6 - Annual Costs
Manufacturing
Cost item
Operating labor
Supervisory labor
Maintenance labor
Maintenance materials
Natural gas
Electricity
Overhead
Taxes, insurance, and administration
Capital recovery
Total annual costs
for Carbon Black
NESHAP
Amount ($000)
52
8
54
54
557
60
92
2,195
7,474
$10,546
In addition, EPA estimates the proposed rule would subject facilities within the source category to
additional monitoring, inspection, recordkeeping and reporting (MIRR) costs. The facilities would be
affected as follows:
# Five facilities are expected to install incinerators to meet the proposed NESHAP. These
facilities would conduct all MIRR activities, including testing and related tasks.
# Two facilities are expected to install flares to meet the proposed NESHAP. Since flares cannot
be tested, both facilities would conduct all MIRR activities except testing and related activities.
# The EPA expects that an additional 13 facilities will basically conduct only MIRR activities,
except testing and related tasks. These facilities would not install any control equipment to
meet the proposed NESHAP.
# Two other facilities will need to do nothing more beyond reading the rule.
The MIRR costs for the first three years after promulgation of the NESHAP are summarized in
table 7 below.
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Table 7 - Monitoring, Inspection, Recordkeeping and
Level of MIRR Effort
Reading the rule
MIRR except testing and
related tasks
All MIRR
No. of Facilities Total Cost per Facility
2 $500
15 $49,700
5 $52,900
Reporting Costs
Cost per Facility, annualized
over the first three years
$200
$18,900
$20,200
What is the anticipated impact of control costs on the industry?
To assess the impact of the impact the proposed NESHAP would have on the industry, EPA
performed a "sales test" as a initial impacts screening analysis for affected firms in the industry. Under
this analysis, EPA looked at the annualized cost of compliance with the rule as a percentage of annual
sales. Using this approach, if a firm has a cost-to-sales ratio of 1% or less, it is presumed that the
regulation has no significant economic impact.
This analysis also presumes that firms cannot pass on the cost of complying with the proposed
NESHAP to their consumers. Since it is likely that these firms could pass on some portion of the
compliance cost to their customers, the cost-to-sales ratios presented here overstate the economic
impacts incurred by the affected firms.
The results of this screening analysis are shown in table 8 below.
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Table 8 - Screening
Analysis for
Firm (Parent) Company No. of Facilities
Affected by Rule
Continental Carbon
(China Synthetic Rubber Corp.)
Columbian Chemical (Phelps-
DodgeCorp.)
Degussa-AG
Cabot Corporation
Engineered Carbon
(Ameripol Synpol Corp.)
Sid Richardson
3
4
3
4
3
3
Firms Affected by
Annualized cost of
control, including MTRR
($000)
$2,688
$6,112
$1,942
$76
$57
$57
the Proposed Rule
Parent Company
Total Sales for
1997 ($000)
$218,200a
$3,914,300a
$8,524,000b
$l,629,989a
$475,000°
Not available
Cost-to-
sales ratio
(%)
1.21
0.15
0.02
>0.01
0.01
Not
available
Sources: aFrom company annual reports (References 20, 21, 22).
bTableBase, 1999 (Reference 23).
cD&B-Duns Financial Records Plus, 1999 (Reference 24)
As shown in the preceeding table, only one firm (Continental Carbon) has a cost-to-sales ratio that
exceeds 1%. The EPA therefore concludes that one company may experience significant impact to
some undetermined degree as a result of the carbon black NESHAP.
Financial information on one additional firm (Sid Richardson Company) could not be found.
However, this firm would incur only minimal MIRR costs as a result of the regulation. The EPA
believes it reasonable to assume that the cost-to-sales ratio for this firm would be less than 1%, based
on comparison to firms with similar production.
The price elasticity of demand for output for SIC 289 (the 3-digit parent for the carbon black
industry - SIC 2895) is -0.8. In general this implies that a 1% increase in output price leads to a 0.8%
decrease in output demand. Since this represents a case of somewhat inelastic demand (i.e., a price
elasticity of demand less than one), carbon black produccers would have some capability to pass some
of their operating costs - including pollution control costs - onto their consumers. This may mitigate the
impact of the proposed NESHAP to affected firms, including Sid Richardson Company.
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Are any small businesses significantly impacted by this NESHAP?
The Regulatory Flexibility Act (RFA), as amended by the Small Business Regulatory Enforcement
Fairness Act (SBREFA) of 1996, requires Federal regulatory agencies to determine whether a
proposed or final regulation will have a significant impact on a substantial number of small entities. For
SIC 2895, a small entity is defined by the Small Business Administration as a firm with 500 or fewer
employees (a small entity cut-off for NAICS 325182 will not be available before October 1, 2000).
This cut-off is made based on parent company employment. At this time, only one parent company
included in the carbon black source category has been identified as having 500 or fewer employees
(Sid Richardson Company). As discussed above, this company is expected to incur only minimal
MIRR costs as a result of the proposed NESFLAP.
Therefore, the EPA does not believe that the proposed carbon black NESFLAP will have a significant
impact on a substantial number of small entities.
Are any government entities significantly affected by this NESHAP?
No government agencies manufacture carbon black. They therefore would not be subject to this
rulemaking.
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5. REFERENCES
1. U.S. Environmental Protection Agency. Production of Carbon Black (Draft). Research Triangle
Park, NC. August 1997.
2. Memorandum from J. Schaefer, EPA:OCG, to S. Wyatt, EPA:OCG. March 15, 1996. Carbon
Black Summary.
3. Donnet, J., R. Bansal, and M. Wang. Carbon Black (Second Edition, Revised and Expanded).
Marcel Dekker, New York, NY. 1993.
4. Materials downloaded from U.S. Bureau of Census Internet web site, including Tables 4, 5, and
6 from the Annual Survey of Manufacturers and Tables la, 3, 7, and 1 la from the Current
Industrial Reports. Tables include Standard Industrial Classification (SIC) code 2895 - Carbon
Black.
5. Chemical Market Reporter. Chemical Profile: Carbon Black. September 29, 1997.
6. Auchter, John F., with A. Leder and Y. Yoshida. CEH Marketing Research Report: Carbon
Black. Chemical Economics Handbook, SRI International. February 1999.
7. U.S. Bureau of Census. Carbon Black Manufacturing. 1997 Economic Census, Manufacturing
Industry Series. August 1999.
8. Chemical Market Reporter. Green Tires are Driving Growth for Precipitated Silicas Worldwide.
November 17, 1997.
9. Freedonia Group. World Carbon Black. March 1998.
10. Chemical Information Services, Inc. Chemical Profile: Carbon Black. October 6, 1997.
11. Memorandum from G. Viconovic, EC/R Incorporated, to J. Schaefer, EPA:OCG. April 2, 1998.
Summary of Carbon Black Presumptive MACT Meeting, February 25, 1998, Houston, Texas.
12. Preliminary analysis of company responses to the EPA's section 114 survey questionnaire.
Company responses received by the EPA in July 1998.
13. U. S. Environmental Protection Agency. Production of Carbon Black (Draft). Research Triangle
Park, NC. August 1997.
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14. Memorandum from J. Schaefer, EPA:OCG, to S. Wyatt, EPA:OCG. March 15, 1996. Carbon
Black Summary.
15. State of Louisiana, Department of Environmental Quality. Air Toxic Compliance Plan Final
Review, Cabot Corporation Evangeline Parish. July 7, 1994.
16. State of Louisiana, Department of Environmental Quality. Air Toxic Compliance Plan Final
Review, Cabot Corporation Canal Plant. February 13, 1995.
17. State of Louisiana, Department of Environmental Quality. Air Toxic Compliance Plan Final
Review, Sid Richardson Carbon & Gasoline Company Addis Carbon Black Plant. September
26, 1994.
18. State of Louisiana, Department of Environmental Quality. Air Toxic Compliance Plan Final
Review, Degussa Corporation Ivanhoe Carbon Black Facility. July 25, 1994.
19. State of Louisiana, Department of Environmental Quality. Air Toxic Compliance Plan Final
Review, Columbian Chemicals Company North Bend Facility. February 6, 1995.
20. China Synthetic Rubber Corporation. Financial Summary, downloaded from the corporate web
site December 2, 1999. Taiwanese dollars (TWD) converted to U.S. dollars (USD) using an
exchange rate of 29 TWD/USD for the year 1997.
21. Phelps-Dodge Corporation. 1997 Annual Report, downloaded from the corporate web site
December 2, 1999.
22. Cabot Corporation. 1997 Annual Report, downloaded from the corporate web site December
7, 1999.
23. Tablebase. Global top 94 chemical companies ranked by chemical sales, in U.S. dollars for fiscal
1997. Accessed through the Dialog Corporation web site December 2, 1999. Copyright 1999
by Responsive Database Services, Inc.
24. Dun and Broadstreet. Duns Financial Records Plus. Accessed through the Dialog Corporation
web site December 7, 1999. Copyright 1999 by Dun and Broadstreet.
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